Braystones Beach, Nr. Beckermet,

Cumbria. CA21 2YL

21

st July, 2015.

FREEPOST – MOORSIDE HAVE YOUR SAY Re.: Proposed NuGen “Moorside” Nuclear Power Station

Dear Sir, Please find enclosed documents which express our concerns about the proposed Moorside nuclear power station. You will note that the various facts within the document are all referenced and verifiable. We had hoped to be able to obtain and include additional information in respect of the suitability of the area’s geology, and indications of the attitude of Manx and Irish governments, but these have not yet been forthcoming. If they do arrive before the end of the consultation period we will send them separately. During the course of the preparation of the document, a number of other matters came to our attention. For example, in last Sunday’s Times newspaper there appeared an article about fresh water mussels in the River Ehen and the plans for United Utilities to spend £25 million on a pipeline linking Ennerdale, the Ehen’s source, with Thirlmere, ostensibly to comply with EU directives about endangered species. Being somewhat cynical, we believe there is an ulterior motive linked to your proposed development, especially as the same river flows past your proposed Moorside site, but time will tell whether our cynicism is justified. Another matter relates to the basis for the global warming issue and the way in which those promoting the premise stand to gain trillions of dollars, which does sound alarm bells to the independent mind. Our suggestion that the global warming science may be suspect seems to be borne out by news today of yet another increase in the reported volume of polar ice ensuing from the current cold summer. This follows a 2012-13 increase of 29%. In 2007 scientists were forecasting an ice-free Arctic by 2013, according to the BBC. Global warming was the mainstay of the argument for the proliferation of the nuclear industry but had to be changed to climate change as a result of a change in the science. We are aware, too, that in calculating the excess available electricity capacity projected for the forthcoming winter, the availability of supplies from mainland Europe were overlooked, making the figures unduly pessimistic. Even so, without that spare capacity, there is still sufficient excess capacity to meet demand.

We have commented on the consultation process in the document, and have learned that NuGen held a consultation session at the Tarnside caravan site in Braystones last Saturday. Regardless of this, our comments still hold. Like us, many of the beach residents are seasonal visitors who have invested heavily in their properties and the maintenance thereof, along with improvements to the amenity – all at their own cost. Yet the consultation process will have ended by the time these seasonal occupiers return to the beach, depriving them of a voice. The detrimental effect of your proposed development will nonetheless affect them. Also of note has been the reporting on BBC television regional news of the plethora of jellyfish (e.g. Northwest Tonight, 14/7/15). Despite the Environmental Impact Assessment admitting that NuGen do not know what the impact of the heat dissipation via “heat tunnels” will be, it must be obvious that the abundance of jellyfish will increase as the water is warmed, and, due to the carnivorous nature of the jellyfish – they eat small fish, fish eggs, crustaceans, etc., the impact on the Irish Sea’s ecosystem will be severe. Marine scientists have noted that efforts to curb the number of jellyfish have failed as the creatures merely increase their propagation to compensate. Other adverse effects will also manifest themselves, we are sure. Another change announced on 15/7/15 is a reduction of 5% in consumer gas prices. With the low level of electricity prices, it seems that the financial viability of nuclear generation is even further diminished. Information from friends in Cumbria indicates that there is a considerable body of animosity to your proposals, as with other unfavourable aspects of the consultation, this is not mentioned. If any corroboration is still needed in relation to the dishonest and corrupt nature of the industry, one only has to look at today’s news, which indicates that Toshiba, a member of the consortium that forms NuGen, has overstated its profits by over £700 million.

Source: http://www.bbc.co.uk/news/business-33605638

For the reasons explained in the enclosed document, we are against any further expansion of the nuclear industry on the Cumbrian coast. Yours sincerely,

This letter and the accompanying documents will be shared openly with a variety of newspapers, journals and other interested parties.

Submission to NuGen’s Consultation

re. Proposed Moorside Nuclear Generation Site

Alternative views for future visitors.

Braystones Beach,

Cumbria

July, 2015

Contents

EXECUTIVE SUMMARY ............... 1

INTRODUCTION ........................ 3

FINANCE ................................... 5

BEACH PARTICLE FINDS ............ 9

INTERFERENCE AND INFLUENCE 11

HEALTH EFFECTS ...................... 15

OTHER RISKS ............................. 19

TRUST ........................................ 22

TRANSPORT .............................. 25

OTHER ....................................... 26

COMPUTER & ELECTRONIC EQUIPMENT VULNERABILITY .. 31

COMMUNITY ............................ 33

CONSULTATION FLAWS ............ 36

SUMMARY ................................ 39

SELLAFIELD DATA ON BEACH FINDS ..... 41

GRAPH OF BEACH FINDS ......... . 42

RADIOACTIVITY FLOW & CONCENTRATION LEVELS ... 43

Additional material:

Documents relating to safety of the Braystones railway crossing and the

concerns of residents with regard to the condition of railway infrastructure.

Page 1 of 43

EXECUTIVE SUMMARY

1. Our objections to the proposed Moorside nuclear power station are comprehensive and range from potential legal issues: judicial review and E.U. actions re. illegal subsidies; financial arrangements with foreign powers whose long-term aims may be suspect, to environmental, health, computer system liabilities, community matters and changes to the infra-structure.

2. Our opinion is that the legal issues could challenge the consultation process itself, with its known

weaknesses and failure to present any objective matters. This is supported by the High Court’s finding in another case where they found that the consultation was “misleading, seriously flawed, manifestly inadequate and procedurally unfair”. We think this consultation process, along with the entire procedure leading to nuclear expansion, has made the same errors.

3. We note our rights under the various articles of the “Human Rights Act” and express our concern

that they may be being infringed by NuGen’s proposals.

4. We list problems, too, in the way members of the government and civil service have favoured certain generating companies and consortia, noting examples of deliberate manipulation to achieve individual’s aims, while wilfully ignoring facts.

5. Included are our fundamental objections to the financial sense, safety, and necessity of

continuing nuclear power generation, and why it is no longer viable financially.

6. We say that we believe that choosing only to look at CO2 emissions, the propaganda is misleading, as the pollutants caused by the nuclear industry are far more toxic than CO2 is. Nuclear pollutants and waste are unnatural and thus more difficult to deal with than CO2.

7. We show our concerns that there seems to be too much easy access and excessive familiarity

between the bodies, including the P.R. company, NDA, DECC, and others. It is our view that this does not bode well for objective, impartial assessments and decision-making, but would, in conjunction with the other evidence, tend to support an application for judicial review.

8. Mention is made of the Weightman Report into the current and future staffing problems of the

Nuclear Inspectorate, and the consequent potential for reduced quality of inspections, thereby putting the population at greater risk.

9. We show that the funding processes depend almost entirely on foreign aid, specialised materials

and equipment, as does the construction process itself, and yet the insurance risk is to be entirely borne by the U.K. taxpayers, and we opine that there can be little doubt that the acceptance of these risks by the government can be regarded as anything but subsidies.

10. We show recent confirmation that there is a correlation between long-term low dose exposure

to radiation and health problems. We suggest that NuGen workers, in the construction and operational phases, will be exposed to materials previously discharged from Sellafield.

11. We explain our concerns about the low level of detail provided in the consultation brochures

from NuGen, and point to unexplained consequences of the proposed construction, while a lot of the material supplied by NuGen implies that the industry can be trusted to do the right thing, so we explain why there is no faith that all ramifications have been seen, considered and will be acted on in any way that will be beneficial to residents rather than the industry.

12. Modern reliance on modern technology involves risk of computer misuse, and vulnerability from

sources that may not be obvious, e.g. a virus which specifically targeted nuclear processing equipment, but could equally have been embedded in other firmware for a different purpose.

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13. We suggest that the consultation process may be premature in that the final design of the reactors intended to be used has yet to be concluded. We show there are 51 known faults or weaknesses in the design, concluding that the over-riding factor has been cost, not quality or safety.

14. We illustrate the lack of information on how the residents in the Braystones beach community

will be affected and how the impact on their amenity will be mitigated, explaining why we think the noise, dirt, dust, impact on transport and amenity, social and health services, and other consequences of the build are skimped on in NuGen’s brochures.

15. Braystones Residents’ Group has long been complaining about the state of the railway line and

the potential safety issues on a railway line that has changed little and has received too little maintenance in 165 years. It is an unsafe system of working, we believe.

16. The campaign by NuGen has suggested that improvements will be made to services and amenity

when the project is under way. This is a form of blackmail, as the improvements should already be supplied by local and national government – residents should not have to accept nuclear development in order to have a reasonable standard of care and good health services.

17. Official data suggests the development will also put at risk alternative industries - such as

tourism, and the very character of this rural area and add that the imposition of many miles of 150’ high pylons will merely aggravate the situation. We show that there is potential in those other industries and that NuGen’s proposals will overall have an adverse effect on employment.

18. We ask when the area is no longer attractive to the industry - for whatever reason – what will be

left for future residents? Experience suggests the typical sprawl of finished and contaminated buildings, high fences with warning signs thereon, and lots and lots of pollution, much of it carcinogenic. The decommissioning process will be incomplete and much of the material will be extremely dangerous for millennia with no safe means of disposal currently available.

19. We conclude that, as with Sellafield, cleaning up will use as much power as was produced during

the site’s productive lifetime, and the financial input from taxpayers will further reduce benefits.

20. We question whether the proposed Moorside site is suitable to permit a stable construction, and whether the disturbances caused by the construction would so affect the geology that it would put an end to ideas that the area could host the subterranean dump of waste materials, and also whether the new construction might cause problems for the old Sellafield sites.

21. Our opinion is that NuGen’s consultation process has not provided sufficient detail for an

informed opinion to be made. We say that there is a need not just for the positive side of the case to be made, but also the drawbacks - there is no balance. By promoting NuGen’s cause and ignoring the adverse aspects, we believe the consultation documents to be misleading and thus in breach of requirements.

22. We think people have a right to know what the true impact will be on their health, their environment, and their amenity. This project is a national and international gamble that the financing, design, construction, and use of the reactors will proceed as without fault. We illustrate numerous examples globally where this has not been the case. We see no reason why NuGen’s should differ from that norm.

23. We concluded that there is no logical reason for imposing the new reactors on a community

already over-burdened with risk and greatly-reduced amenity.

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Submission to NuGen’s Consultation

re. Proposed Moorside Nuclear Generation Site INTRODUCTION In 2007, the High Court dictated that the Government’s consultation was "misleading, seriously flawed, manifestly inadequate and procedurally unfair", and its plans to build a new generation of nuclear power stations were "unlawful", yet ministers still continue to push ahead.

Source: http://www.theguardian.com/uk/2007/feb/15/nuclear.greenpolitics1

Accordingly, we look forward to a legal challenge being mounted to stop this development. A recent explanation from NuGen for some residents not receiving the brochures that provide the information that the company wants them to know blames the lapse on the distributors. This is, of course, immaterial. The fact remains that the system failed. The reason is irrelevant. Such an important development as that proposed should be put to all those who will be affected by it. To suggest that the company has done enough is wrong. Nor is it incumbent on residents to have to buy a local newspaper to glean such information. It is NuGen’s responsibility to provide for all circumstances and ensure that the opportunity to respond to consultations is extended to everyone. We would also draw attention once again to the sheer number of the consultation exercises in which one has to participate in order to avoid the proliferation of nuclear and associated developments in the Copeland area. The plans drawn up by NuGen for three reactors on a site to be known as Moorside, adjacent to the existing site at Sellafield, will involve destruction of a lot of the amenity of the area. Although blighted by the Sellafield site and heavily polluted with radioactive materials from “incidents” and deliberate discharges from the same source, the area which will be destroyed has an intrinsic natural beauty. We find it noteworthy that the view used in the brochures to illustrate the proposed site looks away from the sprawling and ever-expanding industrial area which Sellafield now presents. When the two sites are visualised together it is an unsightly mess, and surely intolerable even to the hardest pragmatist. It is even more difficult to imagine that the infra-structure can cope with either the construction process per se, or the influx of the number of workers purported to be employed – whether in the construction and commissioning phases, or in the eventual running of the plants. If the “population mixing” which is supposed to have caused the excess leukaemia cases in the area is correct, then residents must be prepared to accept that the new levels of population mixing will produce even more cases. The amount of work needed to be undertaken to make the situation even bearable will surely have a much greater impact on residents, especially those nearest to the sites, than is conveyed by the expensive glossy brochures. We believe this to be a deliberate understatement of the inconvenience, travel disruption, dirt, dust and noise that will have to be endured by residents throughout. Other considerations, which, being detrimental to the positive nature of the propaganda contained in the promotional brochures, are unmentioned. Included in those is the apparent disregard for our community’s presence, and the profound effects that the proposed development will have on us. We have noted the same ignorance as that demonstrated when R.W.E. was applying to build on a site just above the beach bungalows at Braystones. The head of that project, at a public meeting in Beckermet, was totally unaware of the presence of the community, thus no thought had been given to the impact the project would have. NuGen seem to have made the same mistake.

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As with all things nuclear in Copeland, it seems that the views of residents are being misrepresented and there seems to be an assumption that, having tolerated Sellafield for nearly three quarters of a century, we are all pro-nuclear. It has to be pointed out that this is not the case. As can be seen from the recent poll of parish councils – not just in Copeland, but throughout Cumbria - considerable numbers of residents are against nuclear expansion and further destruction of their environment. The most vocal supporters are those who gain, or expect to gain, directly or indirectly, from the nuclear industry. Almost all are beholden to Sellafield in some way. We would like information about what will happen to the beach community. Not just superficial and uncertain ideas, but firm details of how the project will deal with residents. How the project will affect the beach itself, during construction and use. For example, how property price falls due to the plans will be moderated; what compensation will be offered to offset the loss of amenity; what degree of nuisance will the residents be expected to tolerate, etc. Presumably there will be 24 hour working, with associated noise, vibration, dust, dirt, light pollution - on the site itself as well as on the many major changes to access routes that will be necessary to permit the conveyance of very large and heavy loads together with the increased traffic the project will engender. It is obvious that, merely by having announced the plans, you have produced what is known in local politics as “planning blight”. All the houses in the area now have reduced expectations of selling prices. All in all, it is difficult to see that there is any wisdom at all in the proposed site, from any aspect. Any further expansion, including Moorside, will result in destruction (not too emotive a word for the impact the development will have) of the area’s unique character, put the country at grave risk of terrorist attack, kill the small remaining tourist industry, risk recycling radioactive materials, blight the property market, and make the entire West Cumbria economy entirely dependent on one industry. Along with many other local residents, we have seen the manipulation of polls and the rigging of questionnaires in recent times. We have become very aggravated by the assumption that we are automatically pro-nuclear, merely because of our proximity to Sellafield. The manner in which opinion, not just in our area, but throughout Cumbria has been misrepresented by pro-nuclear politicians seeking to secure their future, is also very trying. Previously, in respect of the proposed dump, we were advised by central government that failure of any one of the three bodies to agree to site it in the area would mean the end of the road for it. Cumbria County Council refused it, so now the terms and conditions are being changed to make it possible once again. Virtually all the parish councils in the county voted against the plans, but their views were not taken into consideration. We believe that, given the opportunity to oppose this development they would all do so. Have they all been consulted? Prime Minister Cameron has made much of localism:

“We will always protect the green belt and make sure planning decisions are made by local people."

Source: http://www.thetimes.co.uk/tto/news/politics/article4487948.ece (4/7/15)

Yet, it seems, this only applies when it suits the government’s purpose. The ‘greater national benefit’ clause provides a useful excuse for taking no notice of local opinion. The only surprise is that some of the consultation isn’t (yet!) limited to just those present in the canteen at Sellafield, in order to gain a “real” mandate for the project. Contrary to what the NuGen rhetoric suggests, there is a substantial body of people who are not in favour of seeing their homes and surrounding countryside destroyed, especially when alternatives are available.

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We explain later on the machinations and manipulations used by the various pro-nuclear factions in order to impose new nuclear installations on the Cumbrian community and the way in which relevant information is suppressed or distorted in order to achieve their aims. It has also been illustrated that the more the public become aware of the detrimental aspects of such large projects the more they object to them. We can only assume that this is the reason why everything is currently superficial and no idea is given of the impact, detail, longevity or severity of the proposed new-build in the information offered to the public.

FINANCE

The supposed key advantages of nuclear power, such as a relatively low fuel cost, security of supply, and, superficially at least, a lower CO2 output, are broadly well understood, but little is said about the disadvantages. We explain some of them below. Nuclear power stations are complex, difficult to build, and have high risks in their build and operation. The new-build projects are highly capital intensive and are sensitive to variability of interest rates – even relatively small fluctuations can have sufficient effect on the eventual costs to render any project financially unsound. They also have long lead times and their payback periods will be distended. Other detrimental factors include construction cost uncertainty, regulatory, design, and policy risks. These serious problems are exacerbated by the recent and continuing global financial crises. Investors are also greatly influenced by the perceived safety risks, as per the example set by the Fukushima Daiichi and Chernobyl accidents in 2011 and 1986 respectively. We note elsewhere the unfortunate history of nuclear incidents in this country. This is without taking into consideration the deliberate discharges which largely seem to have escaped penalty. Where the construction risks are potentially large, as is the case at Moorside, with the previous history of Sellafield’s terrestrial and marine pollution affecting so much of the area, this, too leads to increased credit rating pressure, even when government borrowing guarantees are provided. Moody's Investors Service said in September last year that construction of nuclear power plants is generally "credit negative" because cost over-runs are more frequent compared with other technology. Other major challenges to financing nuclear power plants include foreign exchange risk, cost escalation risk (for example, Olkiluoto 3, Flamanville 3, Levy County, Angra 3, Watts Bar 2, Taishan 1 and 2, and Hongyanhe are all examples where investment costs have substantially increased beyond the initial cost estimates), EU policy on subsidies, uncertainty in the regulatory process, design changes required to improve safety and reduce risk, construction supply chain risks, operational performance risk, negative public perception of nuclear, nuclear liability insurance cap levels to cover extraordinary occurrences, management of used fuel and waste, and decommissioning. It appears that the government is ignoring the risk associated with equity ownership, and has guaranteed long term power purchasing agreements, long term infrastructure changes, loan guarantees, state budget, and export credit all of which extend so far into the future that they are serious and potentially very costly, even if no incidents occur. All these benefits are designed to improve financing terms, but seem to be contrary to EU agreements on subsidies. Challenging NuGen’s proposals in a legal environment is beyond our resources, but a major institution or state (such as Austria) will probably mount one pro bono. State aid appeals could last six years or more and the average appeal take almost three years to resolve. This will increase costs substantially, and the risk of failure by the U.K. government will certainly incur heavy losses and result in a complete rethink of nuclear generation, as well as having to restart the negotiation process with generating companies from scratch. It must be obvious that, if they are to be scrutinised by less partial interests, the terms will not

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be as favourable as the double-current-cost arrangement with insurance benefits which could mean a withdrawal of interest from the generating companies. Finance houses and institutions are unlikely to view this favourably and will probably be even less willing to take risks. Électricité de France used its own finance for its Flamanville 3 project in France, but the construction cost has risen by 360%, from an initial figure of £2½ billion in July 2007 to £9 billion, causing considerable problems for their financial managers. Not only that, but the project is five years behind schedule. Unsurprisingly, the unit cost of electricity produced will be 17½% higher than forecast. The Daily Mail also reported that:

In reality, the history of the Normandy project is one beset by financial mismanagement with rocketing costs, the deaths of workers, an appalling inability to meet construction deadlines, industrial chaos, and huge environmental concerns. Source: http://www.dailymail.co.uk/news/article-2477202/Deaths-chilling-safety-apses-lawsuits-huge-cost-

overruns-delays-Why-trust-French-Britains-nuclear-future.html#ixzz3cwsklSCA

No matter what form the borrowing takes, or the terms arrived at by the poor team of negotiators for DECC in order to provide long-term subsidies to the companies involved, there is still an awful lot of uncertainty and risk, as well as a requirement for very long-term investment. Investments enduring far into an increasingly uncertain, unstable and risky future make it seem that the risk grow exponentially. Any shrewd investor would almost certainly be deterred. Small wonder then that DECC were described by one M.P. as, ”Dysfunctional and misfiring” over its unabashed promotion of the industry’s plans.

Brussels officials are in the middle of an investigation to see whether the first plant in the planning pipe-line - the £16bn Hinkley power station in Somerset - breaches EC subsidy rules. Sources in Brussels say the chief concern is a £10bn loan guarantee for the construction of the plants, insurance against a meltdown, help with decommissioning costs and the inflation-linked “strike price” of £92.50 per megawatt hour for 35 years.

Source: http://www.telegraph.co.uk/finance/newsbysector/energy/10935226/NuGen-agree-plans-to-build-

first-new-UK-nuclear-plant.html

It has been suggested that U.K. customers will have to pay more than £17 billion in subsidies – more than the cost of the plant itself. They will also bear the risk. No doubt NuGen will demand the same terms. Foreign investors, such as the Chinese, always willing to express an interest, but somewhat harder to actually involve, are changing the terms for helping to underwrite some of the cost of the new plant. China National Nuclear Corporation and China General Nuclear Power Corporation, involved in the Hinkley Point project with Électricité de France, are using that help as a lever to push for commitments to build and operate their own plant at Bradwell in Essex. Now it seems that Électricité de France wish to sell the whole of their Bradwell operation to the Chinese. Some people have concerns about human rights aspects of Chinese operations, too. As we note elsewhere, the Austrian government is likely to challenge the arrangements made by DECC to the massive benefit of Électricité de France, suggesting that the agreed measures amount to subsidies. The massive increases in actual and potential costs to the U.K. public have not been made clear.

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At Hinkley Point, critics of the £24.5bn nuclear programme in Somerset have highlighted the industry’s poor track record for constructing facilities on time and on budget, questioning whether the plants would be able to meet even their revised timetable of opening for operations in 2023. The design proposed for that development is the same as the problematical one at Flamanville, previously mentioned. The Olkiluoto project, again of the same design has been beset with problems is and massively behind its schedule. We have no reason to believe NuGen’s plans will fare any better. The French Nuclear Safety Authority are concerned that the Areva design of reactor being built for Électricité de France at Flamanville is weak and thus unsafe. Critics suggest that these problems in the design of crucial components will be the death knell for the reactor and those of a similar proposed construction in the United Kingdom. There is also to be an investigation into whether the errors are due to lack of competence or surveillance - presumably by nuclear inspectors. If the weaknesses are confirmed then the expense and delay in replacing the affected vessel may well end the project as it is already costing three times as much as forecast and is at least five years late.

Source: http://www.thetimes.co.uk/tto/business/industries/utilities/article4414718.ece (17/4/15)

We are unclear how this state of affairs will be reflected in the proposed reactors for Moorside, whose design flaws we note elsewhere. The three French companies, GdF-Suez, Areva, and Électricité de France all seem to have had financial problems. Paul Flynn, M.P., states on his blog that one company is bankrupt, while the other, Électricité de France, has a debt of €33 billion. Électricité de France was obliged to suspend operations at two British sites: Heysham 1 and Hartlepool nuclear power stations were off-line due to potential technical faults, upsetting Électricité de France Energy’s 2014 financial results, at the same time as the company was also hit by a £136m charge related to the value of the company’s gas generating and storage assets. The agreement that relates to the all-important principle of awarding subsidies to Sellafield is reported in Hansard, on the 14th July, 2008:

"The Department has been informed by the Nuclear Decommissioning Authority (NDA) that it expects to have to grant an indemnity against uninsurable claims arising from a nuclear incident that fall outside the protections offered by the Nuclear Installations Act and the Paris / Brussels Convention to whichever of the four bidders for the Sellafield contract is successful. "The NDA is conducting the Sellafield parent body organisation competition under the EU Competitive Dialogue procedure, evaluating the four bids received against agreed evaluation criteria. Within that process bidders were invited to make proposals for a nuclear indemnity under competitive tension against an established framework. "It would not be viable for any of the bidders to proceed without an indemnity because any fee earning benefits of the contract would be overwhelmed by the potential liabilities. The NDA has assessed that the benefits of engaging a new contractor far outweigh the remote risk that an indemnity might be called upon. The final form of the indemnity will reflect the specific terms proposed by the preferred bidder." Source: Hansard, 14 July 2008 : Column 76W

No statutory authority existed for this arrangement, which was made by DECC purely to the advantage of Nuclear Management Partners. M.P.s were, in the main, kept unaware of the existence of this arrangement for 75 days, after which time it was announced to the Public Accounts Committee. One might imagine that it takes a certain kind of person to perform this kind of obfuscation and deception.

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One might also wonder at the integrity of the other arrangements made by that kind of person. How does such an arrangement benefit the average consumer or citizen? Why would any honest M.P. agree to such an arrangement which is patently against the principles of representation? There are obvious answers, of course. However, it did set a precedent that could then be extended to future deals relating to the nuclear industry – initially with Électricité de France, but once awarded to one company will have to be extended to all to avoid allegations of bias. In January, Parliamentary Public Administration Select Committee member, Paul Flynn, M.P., asked Treasury Permanent Secretary, Sir Nicholas Macpherson, who was appearing before a committee inquiry, whether, "Just as a general principle, are you happy for the public purse to take all the risk, as I pointed out as clearly as possible in 2008, and for the private company, a foreign company, to take any profit that will come out? Is that an abiding effort for the Treasury?" Sir Nicholas Macpherson answered: "Put in those terms, I would never be happy with any contract like that. Ensuring that risk is borne in the right place is one of the biggest lessons of the financial crisis. I do not want to get into this individual issue, because I am not sufficiently informed about it." A sum “between £88billion and £208 billion” (!) will ultimately be spent on Sellafield and the clean-up, with a lot of uncertainty even as to the accuracy of the final figure. [According information supplied to the Public Accounts Committee.] Naturally and inevitably, there will be commensurate increases in benefit to those providing the service, as well as to private industry and the shareholders. On 16th January, 2015, John Robertson MP, (Labour), pro-nuclear chair of the All Party Nuclear Power Group, just three days after Nuclear Management Partners were sacked, said, "The industry really has turned Parliament around. We do now have a political House singing from the same hymn sheet on nuclear power. We need to work hard to keep it that way!" That is an interesting observation on the influence achieved by the nuclear industry and the extent of the benefits achieved. The government is clearly over a barrel and being pushed by a powerful group of M.P.s and peers. Quite why some of those people feel able to be so confident in pushing the nuclear agenda is unclear, but, no doubt, the future will demonstrate what is in it for them. We don’t think it will be public approbation – a jail sentence, perhaps?

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BEACH PARTICLE FINDS See P. 42 for data analysis derived from Sellafield’s own website. Compare that with the details in the article reproduced below. NuGen confirms that one of the primary concerns must be safety. However, the areas, marine and terrestrial, which will be excavated for the reactor sites are already contaminated by nuclear waste.

UKAEA advised to close Dounreay beach

The Dounreay Particles Advisory Group (DPAG) has recommended that UKAEA close off the beach immediately adjacent to its north Scotland nuclear site due to the radioactivity of fuel fragments being found there. Fuel particles have been found at various offsite locations, including Sandside beach and the Dounreay foreshore. One was detected at a popular tourist beach at Dunnet, several miles east of Dounreay. The foreshore closure recommendation, which came as part of DPAG’s third report, was accompanied by a decision that monthly monitoring of nearby Sandside public beach should be increased to fortnightly. DPAG said that most beaches in the vicinity of the plant could remain open to the public because the chances of coming into contact with a fuel fragment there were sufficiently low and the activity of fragments there were smaller, resulting in less health effects. The pollution was caused by bad waste management practices over many years, which resulted in thousands of shards of irradiated fuel from reprocessing being released to the environment through a variety of routes. The particles are similar in size to a grain of sand and those being found at the Dounreay foreshore are at the higher end of the particle radioactivity scale. DPAG noted that there is still a significant bank of fuel fragments on the seabed off Dounreay, mainly in a plume emanating from the subsea effluent diffusion chamber and adjacent to the site. At the report launch in Thurso, DPAG chairman Keith Boddy reinterpreted the former secretary of state for Scotland’s 1998 direction that all particles finding their way to Sandside beach should be promptly detected and removed. Boddy considered that the approach to particles should be based on the risk entailed. UKAEA used the launch to highlight plans to undertake trials of remotely operated technology to remove particles from offshore sediment. UKAEA has placed a notice in the Official Journal of the European Union seeking expressions of interest from firms capable of finding and removing the particles from the seabed. Source: The journal of Nuclear Engineering International, 24/11/06.

Up to 2015, a total of 249 particles has been found at Sandside, prompting the closure call, but Sellafield (1220 particles) and Braystones (313 particles) have not been closed, nor are warning posters in place, despite the presence of tourist caravans on two formal sites and beach bungalows. Holiday makers and fishermen are present on the beaches as the survey vehicle follows its grid patterns and finds particles. Regular boat trips from Whitehaven fish at the end of the discharge pipe.

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A similar problem exists at Dalgety beach, in Fifeshire, where beach closure was threatened unless radioactive material was cleared up. Even then an area of the beach was cordoned off, so the public were made aware. Solutions include concreting the bay over, fencing it off and erecting warning signs, or clearing up the pollutants. Hopefully, if they concrete it over, the particles will do the honourable thing and stay put until the concrete has set. Clearing up particles is unlikely to be 100% successful, apparently – but isn’t that the case along the Braystones coast? The beach bungalows between Sellafield and Nethertown have never been examined for the presence of particles, despite some being permanently occupied. However, they must surely be at risk due to the exposure to wind-borne particles and also because it is likely that all of them have utilised materials obtained from the beach in their construction. During the storms of 2014, a tremendous amount of beach material was deposited on residents’ gardens. In our own case, several tonnes of shingle, stones and sand had to be laboriously removed by hand. A few bungalow owners were less fortunate as the debris was actually deposited in their living accommodation. We wonder how much of this material has been checked for radioactive particles? Very little, we would suggest.

The Groundhog Shares the Beach with Holidaymakers. Note the rocky area, typical of this beach, which renders much of it unavailable for testing.

The contract for this service is worth around £40 million, we believe.

We note a report (HPA-CRCE-018, J. Brown and G. Etherington, 2011) that suggests that beach users are not at risk, but would point out that the examination of the beaches by Nuvia is two dimensional. The number of particles found is thus given as being within an area, not a volume. Nor is the surveyed area constant. Rocky/stony areas cannot be surveyed by the vehicular method used. Is this reliance on detectable materials being on the surface of the sand, or at least within the top layer, an oversight or deliberate? Whichever it is, the residents and beach users are at risk. In 1983, warnings were given to avoid “unnecessary use” of 20 miles of Cumbrian beach following the discharge by Sellafield, of material that formed a radioactive slick off Seascale before washing ashore. No mention was made of what action residents should take. Was all the material collected before the beaches were declared fit to use again? It seems very unlikely. The “Groundhog” equipment used is limited in its detection capabilities, only being able to penetrate the top layers of sand. The sand is regularly “churned” by the tides, especially storms. The monitored area totals are the sum of the individual days' monitoring areas: noting that there is sand movement of 10 cm expected between tides and the displacement could be up to several metres for a storm tide. We draw

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attention to the changes to the beach topography following the storms in early 2014. These shifted considerable quantities of sand and shingle. Even now there is considerable rock exposure where there used to be sand, so it must be apparent then that a survey only examines a miniscule sample of the total, and the number of particles discoverable at any one time is down purely to chance that they exist in the top 10cm at the time a survey is being undertaken. Since the equipment is unable to scan rocky or uneven surfaces, the upper beaches and rock pools cannot be checked. It seems to us that only about a third of the beach surface is even available for checking. We also dismiss the suggestions by the Environment Agency that the particles are not likely to be injurious, are largely immobile, and thus are unlikely to affect beach residents and regular users. It is also our belief that not all the discharged products can even be tested for. We note, too, the constant increases in permitted levels of tritium that Sellafield are allowed to discharge into the atmosphere. Tritium has a close affinity with water, which is not a good thing for aquifers and lakes, especially when it is used for drinking water, not just locally, but also in Manchester. The construction process at Moorside will, according to NuGen’s superficial Environmental Impact Assessment, release particles into the atmosphere. Given the site’s proximity to Sellafield, it is almost inevitable that the soil is already contaminated, as a result of the numerous incidents, but particularly from the fall-out from the chimney fires in 1957. It thus appears that any soil particles released to the atmosphere may cause recycling of that radioactive contamination. Again, despite the contrary assertions of the Environment Agency, following close association with the beach over more than 60 years, we say that there is now considerably less marine life and far fewer sea weeds than in previous years. Collection of seaweed used for making larva bread would be impossible nowadays, but used to be a cottage industry, with sackfuls being sent by train to Wales each week. Despite the obvious possible cause, the radioactive discharges from Sellafield are exempt from blame and there will be no health consequences. INTERFERENCE AND INFLUENCE

One reason for the acceptance of global warming in this country may be that Harold Bolter C.B.E., a former senior manager at British Nuclear Fuels, and erstwhile Financial Times journalist, wrote his autobiography, entitled "Inside Sellafield", in 1996. On Page 210 he wrote that following years of “bad publicity” (in truth, revelations of large-scale leaks and health effects which the spin managers at Sellafield had failed to counter), especially Yorkshire television’s “Windscale: The Nuclear Laundry” programme, which demonstrated the elevated levels of childhood leukaemia around Seascale:

Geoffrey [Tucker - former publicity director to the Conservative party, appointed as consultant to Sellafield on recommendation of Lord McAlpine], Con Allday, chairman of BNFL, and [Harold Bolter] had regular "blue-sky" meetings, at which we bounced ideas off each other about how we could take the company forward. Several important new initiatives were pursued as a result. I remember in particular how we discussed ways of getting the greenhouse effect, caused by burning fossil fuels, on to the political and environmental agenda. We wanted to drive home the message that the UK's nuclear stations saved some 50 million tonnes of CO2 emissions a year. We made the greenhouse effect the talk of a series of dinners which Geoffrey organised and, whether they were effective or not, it is a fact that shortly after Bernard Ingham, Mrs. Thatcher's chief press secretary, had attended one of the dinners, the Prime Minister began to show an interest in the issue. At several of the blue-sky meetings we also talked about education and my belief that we must capture the minds, if not the hearts, of young children, who were clearly being influenced by the

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stream of anti-nuclear programmes appearing on television and, it has to be said, by the attitude of many of their teachers.

To our minds, this demonstrates the intent to corrupt, or at least distort, the truth about the dangers inherent in the nuclear industry and to deflect attention elsewhere. The tenets of these arguments have certainly been adhered to, with Sellafield and the nuclear industry having considerable influence in education, health and social amenities, all of which should be in the province of national government – as it is elsewhere around the country - and not in the hands of a local company. This is a system which NuGen seek to perpetuate and expand, thus having even more control and influence on the community. NuGen’s importation of labourers and staff will further distort the influence held by the nuclear industry.

Following the Fukushima accidents, in 2011, Brian Wilson put his name to an article which was circulated by the Energy Coast consortium to most residents, also being distributed as a supplement to the Whitehaven News. In it he claimed that there had been no melt-down as a result of the tsunami. This was patently untrue. He was obliged to publish a retraction a short time later by the Press Complaints Council. A critique of this non-executive director of AMEC Nuclear Holdings Ltd., can be found here:

Source: http://bellacaledonia.org.uk/2013/10/23/nuclear-meltdown/

Another Brian Wilson, this time a councillor in Northern Ireland, made a speech to the Northern Ireland

Assembly in 2007:

We have always been concerned about the activities of Windscale at the Sellafield nuclear plant, owing to its proximity to the Irish coast and to the secrecy with which those activities have been carried out. We are particularly concerned about the activities of the BNFL ship the Atlantic Osprey and the reason that it spends a great deal of time around Beaufort’s Dyke. That raises serious safety issues: a ship that is carrying nuclear fuel is spending so much time in an area in which large quantities of munitions have been dumped. The Green Party was not surprised to learn that the initial estimates of the radioactive contamination that spewed into the atmosphere from Windscale were grossly underestimated. The Windscale/Sellafield site has been shrouded in a mist of lies, misinformation and outright fraud from the day of its inception. For example, after the Windscale fire in 1957, the men who risked their lives to prevent that fire spreading were made scapegoats by the Government’s inquiry into the cause of the accident. The name of the site may have been changed to Sellafield, but the Windscale legacy of deception has persisted. In 2000, a damning Nuclear Installations Inspectorate report painted an alarming picture of management incompetence and a culture of complacency at the Sellafield site. The scandal concerned safety procedures in a factory that produced batches of uranium and plutonium. One batch that was bound for Japan was found to have had false records, and that prompted the investigation. Indeed, British Nuclear Fuels later admitted that the records had been deliberately falsified. We are particularly concerned that earlier this year the nuclear safety authorities in Britain decided to reopen the facility for reprocessing at THORP in Sellafield. That plant is considered to be a nuclear dustbin, taking in nuclear waste from all parts of the world. Even if one supports nuclear power, the waste from the rest of the world should certainly not be taken in at that plant, which is what currently happens. THORP has been out of operation since April 2005, when a major leak of radioactive material was discovered. My Green Party colleagues and I have spoken to representatives of the Nordic Council, and they share our grave concerns about the prospect of THORP reopening.

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I ask the Assembly to support the Nordic Council’s call to the Government to permit a full, independent and international investigation into the safety culture at THORP at Sellafield. Despite years of campaigning for the closure of the nuclear facilities at Sellafield, the prospect of its closure is distant. Indeed, a new master plan that was drawn up by the west Cumbrian authorities sets out proposals for the further development of nuclear power. Those proposals include the construction of two third-generation, 1·6 gigawatt nuclear reactors and the development of fourth-generation reactors at Sellafield. Discussions have also taken place between Cumbria County Council and the Government about the future storage of highly active radioactive waste, even though, at present, Sellafield already holds 70% of the country’s most dangerous nuclear waste. The Green Party is opposed to any expansion of nuclear activity. When the joint agreement between the Scottish Green Party and the SNP was drawn up, the first point that was agreed with the new Scottish Administration was that there would be no support for new nuclear power in Scotland. Nuclear power is not the answer to the energy crisis. It will restrict investment in alternative technologies, and it does not make economic sense. It produces radioactive waste that will create problems for generations for thousands of years to come. Despite improvements in technology, it is not totally safe. Accidents can happen, and if one does, it will be a disaster.

While on the subject of individuals, it is noteworthy how so many of the friends and relatives of those in positions of influence within government have obtained links with companies involved in nuclear development. Then, of course, there are groups like Tanef – Transatlantic Nuclear Energy Forum, whose express aims are “to foster good relations between nuclear companies and government”. Haven’t we have seen more than enough of this kind of insidious conduct in recent years? Too many peers and politicians seem to have a suspiciously high profile in the promotion of nuclear energy. Too many MPs have been shown to be open to payments for (euphemistically) services rendered. A former chief executive of the loyally pro-nuclear Copeland Council has been fortunate enough to find himself a new job working with NuGen. It seems that he is joining as part of NuGen’s public consultation planning team. The company, Copper, is a PR firm with offices in various parts of the country. Sadly, they seem not to believe in democracy if the application of democratic principles stops their client from achieving its aims. It has been reported that this company suggested to the Department of Energy and Climate Change in 2013, following the surprise defeat of the very costly dump campaign in Cumbria, that allowing local authorities to determine the outcome of a process which was designed to deliver a national government policy, ‘May not be the most appropriate route.’ The argument went on, ‘ . . . local authorities are consultees, rather than decision makers.’ Strange when local and national government are supposed to be doing the will of the people they represent, not following some grand agenda without consultation. Although, perhaps easily foreseeable, given the determination of government to push ahead with nuclear expansion, regardless of the science, geology, or local opinion, it was further suggested by the company that the scheme for a national dump should be classified as an NSIP. Such a move would remove all the obstacles (except, perhaps legal ones aiming to protect the rights of the individual rather than big business.) Despite all the rhetoric about localism that was issued by politicians, all the rights of the individual have in fact been removed. The joke about you can have whatever colour you like for the gates has now worn a bit thin.

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Actually, the idea of disposing of democracy was proposed by the “shadowy” Maurice Strong, one of the originators of the global warming theory, who said, “Ballot-Box democracy may need to be modified to enable governments to take the difficult decisions on longer term issues that affect their own national interests and the future of the entire human community.” In another convenient move, Copper's former Executive Director is now the Stakeholder Engagement and Communications Director of Radioactive Waste Management (RWM) - the new arm of the Nuclear Decommissioning Authority (NDA). Copper have also just been awarded the PR job of selling new nuclear build at Moorside and new nuclear wastes to the public. It is Copper’s team that have missed most of the Braystones residents with its propaganda documents. Amusingly, even the NuGen staff member to whom we spoke, said that she had not received anything either, despite living in Whitehaven.

Source: http://nuclearmatters.co.uk/2015/03/NuGen-prepares-its-team/

We would like the Prime Minister to concern himself with “lobbying”, which he described as the next big scandal. There is no doubt to any informed observer that the people behind nuclear expansion are wielding a great deal of inappropriate power and have a lot of money to ease the way for their proposals. The agreements reached with Électricité de France are prime examples. Strangely, Électricité de France seems to like pretending to be a U.K. company and doesn’t use its full title very often. At one time a miscoloured Union Flag was used by company as an emblem. Is there a reason they want to appear not to be French?

We note a report that in January this year, the Government’s plans for a new £16 billion nuclear plant at Hinkley Point were dealt a blow by the United Nations and a powerful group of MPs. A United Nations environmental committee warned of “profound suspicion” that the UK had failed to carry out a proper consultation with neighbouring countries, including Norway and Spain, over the possible environmental impact of Hinkley Point C. The report also went on to say that Électricité de France will only build the plant if a minimum price is guaranteed for the electricity generated, so ensuring a return for shareholders worried about the enormous upfront construction costs. As we are aware, the cost of building will fall on the consumer, who will also be required to provide insurance – for construction and commission - but also will have to pay to clean up the waste at an unknown cost and using a yet-to-be-thought-of process, when the enterprise comes to an end. Then it will also have to provide the means of final disposal. What happens if these foreign companies just walk away at any point, perhaps after an accident, and leave a mess to be cleaned up? Or refuse to pay even their small contribution after an “incident”? How could any costs be recovered? Instead, the Energy Secretary seems to be somewhat superficial in her approach. According to a BBC news report, and others, on 6/6/15, the current Energy Secretary, Amber Rudd, has said:

Britain’s new nuclear power stations and other energy infrastructure projects must be designed to look beautiful to garner essential public support. The country is set for a complete overhaul of its energy infrastructure in the next decade as new green sources of electricity such as nuclear, wind and solar power stations replace polluting coal and gas plants.

One has to wonder whether she has any idea of the true nature of the nuclear industry, or is just following what the “advisors” are telling her. Even if one accepts the banal statement, is there truly any

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way in which Sellafield, Moorside, Hinkley Point, et al, can be made to blend into the essentially rural environment, or whether nuclear energy can honestly be regarded as green - in any way? When all the changes, including the 150’ tall pylons to connect to the national grid, are taken into consideration, there is nothing from an aesthetic, financial or resource viewpoint which is beneficial. Moorside will merely add to the huge inappropriate, ugly sprawl that so severely detracts from the area’s natural beauty and impinges on the amenity of the Lake District National Park. How much more of the coastline will be sacrificed? The more they are given the more they will want.

HEALTH EFFECTS

Scepticism was voiced by the NuGen staff member when I mentioned, on a visit to the NuGen Information Centre in Whitehaven, the incidence of cancers and leukaemia directly related to exposure to radioactive material, and it was suggested that there is no direct causal link between cancer and nuclear establishments. Yet there is irrefutable evidence. In the year following the deliberate discharge of 1983, the Black Report agreed that childhood leukaemias in Seascale are ten times the national average. For some reason, suggestions that “population mixing” might be a cause thereof was put forward. Counter arguments that the likes of Liverpool, Bristol, Plymouth, Hull, Portsmouth, et al, have had far more and diverse population mixing without increased childhood leukaemia seem to have been omitted. So what is it that makes Seascale different? The elevated incidence is surely not down to coincidence? In 1987, the Imperial Cancer Research Fund announced that children living near five nuclear plants: Capenhurst, Springfields, Aldermaston, Harwell and Amersham, have a four times greater risk of dying of leukaemia. Other studies in Europe demonstrate an average of 7% greater likelihood of childhood leukaemia in areas around nuclear sites. A Sellafield manager was reported as saying that male Sellafield employees should not have children. Perhaps this should be expanded to include all Cumbrians? After all, the pollution doesn’t respect fences and boundaries. Although leukaemia has been investigated, it now seems that breast cancer might be a better indicator of the effects of exposure to radiation. A 2011 BBC programme totally ignored the numbers of children suffering from genetic disorders, internal organ deformities and thyroid cancers reported by doctors working in the cancer hospitals of Minsk, Belarus, and the Vilne Hospital for Radiological Protection in the Ukraine. Yet these doctors are in no doubt that they are seeing unusually high rates of these illnesses which they unequivocally link to the Chernobyl accident 24 years ago. Russian doctors, not wishing to displease the state made light of it all. Yet infant mortality in these areas has increased 20-30% in 20 years, but the full effects have yet to be seen. In the programme, a professor was shown walking round a school playground near Fukushima. He was telling the audience that there was no danger at all, and that there was no reason why children could not come back to school and carry on as normal. He was, of course, fully kitted out in radiological protection clothing and footwear as he walked round the schoolyard.

Source: Fukushima: Is Nuclear Power Safe? BBC2 television, last broadcast 14/9/11.

The forecast figures for deaths from Fukushima's accidents range from the zero suggested in the programme to 500,000 by an independent expert. The official figures from Chernobyl were at odds with the facts, too. Even according to the WHO, the number of deaths to date is 56, with 4,000 expected to die from the effects eventually. Both were comparatively small leaks in the face of the potential result should there be an incident at Moorside or Sellafield – even without the domino effect.

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According to http://www.csrld.org.uk/html/annual_statement.php (the Compensation Scheme for Radiation Linked Diseases), there has been a total of 1454 cases submitted to it to 2013. Of these, 139 claims have been successful to date, resulting in payments amounting to £7.81 million. It is difficult to imagine Sellafield management being that altruistic if there is no evidence of a link. The link has also been demonstrated in America: a 1976 study of employees at the DOE’s Savannah River Plant, found a 114% excess of leukaemia incidence among male blue-collar workers; in two independent 1978 studies of the Navy’s nuclear shipyard workers in Portsmouth, New Hampshire; in a 1984 Oak Ridge Associated Universities/University of North Carolina report on workers exposed to uranium dusts; and in a 1991 study of Oak Ridge National Laboratory workers (49% excess death rate from leukaemia). In 2003, the Committee on Medical Aspects of Radiation in the Environment, (COMARE) concluded that, “The excesses around Sellafield and Dounreay are unlikely to be due to chance, although there is not at present a convincing explanation for them". The committee also found that there was elevated risk of childhood leukaemia in the Seascale areas – exacerbated when both parents came from outside the area.

Varying according to source, between ⅓ tonne and 7 tonnes of plutonium has found its way into the environment from Sellafield, the greatest part being in the Irish Sea, whilst Tritium is routinely dispersed to the atmosphere, with the Environment Agency’s licence. Increases in permitted levels seem to be made annually at the behest of Sellafield management. Earlier this year, the amount of highly radioactive liquid waste permitted to be stored on the Sellafield site was increased, as the Office for Nuclear Regulation accepted that it could do nothing else. The permitted levels of waste storage had already been breached, but no action, other than to increase the levels has been taken. Note the comment about Mr. Weightman’s staffing concerns on P.29. The levels are henceforth to be set by Sellafield themselves. All the foregoing illustrates not just the risk to the public, but also that which will affect NuGen construction and operating staff if the company decides to go ahead with the scheme to build immediately alongside the Sellafield site.

Source: http://www.corecumbria.co.uk/ (14/5/15)

Sellafield Considers Seagull Cull

The 645 acre Sellafield Nuclear Power Plant in West Cumbria is being overrun by mice, stray cats and seagulls, now managers are having come up with ways to contain the problem and culling the seabirds is seriously being considered. This is in response to concerns that some gulls have been swimming in open ponds which contain plutonium and radioactive waste, with some dating back to Britain’s 1950s and 1960s atomic weapons programme. Martin Forwood, of Cumbrians Opposed to a Radioactive Environment, remarked: “It’s a coastal site so there are thousands of seagulls around. They fly in and float around on the open waste ponds and act as a gateway to poison the wider area” According to Ali McKibbin, Sellafield’s media relations manager, there are already 350 animal carcasses being stored in an industrial freezer at the site, and although most of these are birds, there are some small mammals. Plus, there are around 30 new carcasses collected every month. Sellafield has to abide by Environment Agency rules which means any animal that dies within the perimeter fence must be treated as nuclear waste – as it could have been exposed to radiation. These carcasses are not allowed to decay naturally because they are considered “putrescent” nuclear waste – therefore, they are kept frozen until they can be disposed of in a special landfill facility on the site.

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Bird-control for the site is subcontracted to a company called Avian, according to an unnamed source, with two full-time staff employed to control bird numbers and deter them from nesting in and fouling buildings. Ms. McKibbin confirmed that discussions were under way in relation to an intensive culling programme. Source: http://www.thetimes.co.uk/tto/environment/article2145004.ece (25/2/10)

The area’s residents are not affected, apparently, despite the fact that carcases and the excrement from the birds and other wildlife may well be contaminated and be found in gardens or on the beaches. Earlier this year a herd of roe deer, re-introduced to the country by a European “re-wilding scheme” found themselves trapped between two security fences at Sellafield. Despite pleas from animal lovers, three of the deer were shot. Apparently this was the humane way of dealing with the deer. Most people would have seen the removal of a section of fencing to facilitate their self-escape as a much more humane way of dealing with it. There was no reason why the deer should have become “spooked” by the process. Just open a section of fencing and leave the deer alone until they have found the opening. Any terrorist would still find themselves with the inner fencing – fit for purpose for decades – to surmount. Perhaps they, too, could be shot and used for experimental purposes. Conveniently, however, because the animals had been grazing close to the site, their carcases provided Sellafield scientists with an alternative to the human body parts that they had been harvesting prior to Redfern. Apparently, deer flesh is similar in radiation take-up rates to a human’s. Deer carcases are known as bio-indicators, which is rather less emotive turn of phrase used by PR people. Interestingly, the animals had not even been inside the perimeter fencing, thus any radioactive material found in the examination would be the same as that unwittingly tolerated by residents over decades.

Source: Many and varied, including most national and local newspapers, BBC, ITV, etc.

On the 9th June, 2015, an article appeared in Wales Online:

“A Welsh nuclear power station may be responsible for elevated levels of cancer found in communities downwind of it. Research showed the incidence of breast cancer was five times higher downwind from Trawsfynydd Nuclear Power Station than would have been expected. A significant amount of radioactive material exists in the lake bed sediment. “Other forms of cancer showing elevated levels included prostate, leukaemia, mesothelioma and pancreas. Altogether, 38 people in the area researched were diagnosed with cancer between 2003 and 2005, against an “expected” level of 19.5.”

Source: http://www.walesonline.co.uk/news/wales-news/welsh-nuclear-power-station-responsible-9415019

Of course there is a huge number of studies which illustrate that the effects of radiation exposure are not fully understood, despite what the industry and somewhat biased experts try to tell us. A similar publication appeared in a peer-reviewed journal, Jacobs Journal of Epidemiology and Preventive Medicine, of a 2003 study of breast cancer mortality between 1995 and 2002 near Bradwell nuclear power station in Essex, where there are elevated risks of contracting some form of cancer and you stand twice the risk of dying of breast cancer if you live in the more radioactively polluted areas as opposed to nearby uncontaminated areas. Further study, at Burnham on Sea – where Hinkley Point is again responsible for pollution - yielded similar results.

Source: http://jacobspublishers.com/images/Epidemiology/J_J_Epidemiol_Prevent_1_1_006.pdf

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Of course, any perception of danger to health must have a reference value – a level below which almost everything can be deemed to be thought to be adversely unaffected. There have been many suggestions as to what that level should be. It has constantly been revised downwards as the effects of even low-level exposure have become plainer. The main statement has to be that there is no safe level of exposure to radiation. We are constantly told that we can expose ourselves to greater amounts of radiation by travelling in a plane, or that we already have a background level of exposure. This does nothing to placate anyone. Such things are, of course, irrefutable, but that does not excuse the additional exposure, and the greater risk presented thereby – especially when the additional dose is involuntary. Despite the inherent untruth, official bodies still do their best to imply that there might be a harmless excess exposure limit – usually basing their suggested levels on what nuclear scientists tell them. One might detect a certain potential conflict of interest in that. Sadly, not all scientists are concerned with the truth. As one representative at a 2009 Kiev conference stated, “To buy scientists in poor countries does not cost a lot. With $10,000 you can buy many persons.” This might go some way to explaining the widely differing statistics relating to past and future consequences of the Chernobyl disaster. As with so many forecasting programmes, from predictions about the degree and consequences of global warming to the future demands for electricity, the assessments depend on a suitably accurate computer modelling programme. Yet, despite heavy investment in competent mainframe computers, the Meteorological Office cannot accurately and reliably predict what the weather will be like just two weeks in advance. Even five days is dubious. Yet nuclear and meteorological scientists are definite about what will be happening in 50 years time. As with all computer models, the predictions are bound by the quality of the data input and the ability of the programmer. Garbage In = Garbage Out was the old adage, and it remains true today.

“The true history of the health effects of exposure to the radioactive substances released by both the Chernobyl and Fukushima catastrophes have been covered up by the power of the nuclear lobby. And the main instrument that has been used for this is the radiation risk model of the International Commission on Radiological Protection, the ICRP. But as far as scientific evidence goes, the simplistic ICRP risk model is now bankrupt. It is now clear to all, except governments who depend upon the ICRP model to justify their support of nuclear energy and nuclear weapons, that the model is unsafe.”

C. Busby, J. Busby, D. Rietuma and M. de Messieres

Source: http://www.euradcom.org/2011/2009confproc.htm

There is an overwhelming case that even very low levels of exposure – even well below the various levels proposed by major institutional bodies, such as the World Health Organisation, do nonetheless cause major illnesses in some people. The public are not homogenous, and it is obvious that some people will be more readily affected than others. Even trying to set a safe exposure level is therefore impossible.

“The nuclear industry can take a disaster like Chernobyl every year.”

Hans Blix, Director General of the I.A.E.A, 1981 – 1997. At places along the Cumbrian coast, and its hinterland, it is quite likely that residents are subjected to continuous levels of radioactivity as a result of past discharges. This is particularly true of the Sellafield area, as shown by the map on P. 42, also the graph and graphics illustrating the flow and concentrations on the following pages. We do not believe in the official explanations as they defy logic.

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The research undertaken around Chernobyl, as noted on P. 22, indicates that the health effects following the Chernobyl disaster include: cancers, heart problems, blood pressure problems – leading to strokes, even in young children, physical and mental development impairment. We also draw attention to the conclusions of the paper published in the Lancet, in June, 2015, which was entitled, “Ionising radiation and risk of death from leukaemia and lymphoma in radiation-monitored workers (INWORKS): an international cohort study, Leuraud, Klervi, et al”. The findings are that:

This study provides strong evidence of positive associations between protracted low-dose radiation exposure and leukaemia.

Source: http://www.thelancet.com/journals/lanhae/article/PIIS2352-3026(15)00094-0/fulltext

Who has the right to inflict this greater risk and consequent potential illness on a body of people? OTHER RISKS On 16/5/15, the Independent newspaper had the article:

Nuclear expert Arnie Gundersen warns of 'Chernobyl on steroids' risk in UK from proposed Cumbria plant

An American nuclear expert has warned that Westinghouse’s proposed reactor for Cumbria needs a $100m (£68m) filter to safeguard against a leak that would turn the region into “Chernobyl on steroids”. Arnie Gundersen lifted the lid on safety violations at a nuclear firm in 1990 – he claimed to have found radioactive material in a safe – and was CNN’s resident expert during the Fukushima nuclear disaster in Japan in 2011. Mr Gundersen told The Independent that he is concerned by designs for three reactors proposed for a new civil nuclear plant in Cumbria. A nuclear engineering graduate by background, Mr Gunderson believes that the AP1000, designed by the US-based giant Westinghouse, is susceptible to leaks. The reactor has been selected for the proposed £10bn Moorside plant, a Toshiba-GDF Suez joint venture that will power six million homes. It is going through an approval process with the Office for Nuclear Regulation (ONR). Mr Gundersen, who visited the Sellafield nuclear facility in Cumbria last week, warned that any leak would be like “Chernobyl on steroids”, referring to the 1986 nuclear disaster that killed 28 workers within four months. He passed on some of these fears to MPs at an event in Parliament during his visit to the UK. He said: “Evacuation of Moorside would have to be up to 50 miles. You could put a filter on the top of the AP1000 to trap the gases – that would cost about $100m, which is small potatoes. “If this leaks it would be a leak worse than the one at Fukushima. Historically, there have been 66 containment leaks around the world.” A spokeswoman for the ONR said that the regulator is currently ensuring that the reactor will be safe. She said: “We have received revised plans from Westinghouse for 51 outstanding issues. These will have to be resolved before the ONR can make any decisions [to approve the reactor].”

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A Westinghouse spokeswoman said: “The AP1000 nuclear power plant design offers unequalled safety through innovative passive safety systems and proven technologies that are based on Westinghouse’s 50-year leadership in nuclear energy technology.”

So, there are at least 51 outstanding issues yet to be resolved. This information is not displayed in NuGen’s exhibition, nor has it formed part of the information available from official sources as required by the protocols, thus the public are not properly fully informed about the risks inherent in nuclear development at Moorside. Even so, Westinghouse still claims to provide “unequalled safety”! If a secondary cooling system is to utilise sea water to facilitate heat dissipation, given the amount of radioactive material present in the immediate area of the proposed submarine circuit, how will any leak into the secondary circuit be detected? Plainly, if radioactive particles are sucked into the system they will be circulated and probably detected by monitoring equipment, but will that be competent to determine whether the source is legacy material from the marine environment or due to a leak from the contained system? If cooling water is to be obtained from elsewhere, will it be paid for at the proper rate? Or will it be supplied free, as with Sellafield’s supplies from Wastwater? There is no detailed assessment of the probable impact of the discharge of so much thermal energy into the relatively-contained Irish Sea, nor on the plans for a marine off-loading facility. So, what impact will discharges have on the marine environment? Wait and see, we are told. By which time it will be too late. An article in the Daily Mail last year reported that the nuclear dump at Drigg near Sellafield is “almost certain” to leak in the future. An Environment Agency report said that experts are concerned that the Drigg Low Level Waste Repository will be eroded by rising sea levels. The document says the repository will start leaking in a few hundred to a few thousand years' time, and went on to suggest it was a mistake to position Britain's nuclear dump so close to the Cumbrian coast because of the risk of flooding. One million cubic metres of radioactive waste produced over the last 55 years is so far housed at the site.

Source: http://www.dailymail.co.uk/sciencetech/article-2611145/Nuclear-dump-Cumbria-certain-leak-future-report-claims.html

Albeit of low-level waste - clothing, tools, JCBs, etc., one might feel it inevitable that there will be adverse consequences for the environment and health when the site does leak. We also seem to recall that some of the low-level waste was incorrectly categorised and should have been classed as medium level waste. Not only that, but sensors used to determine the radioactivity of items to be dumped at Keekle Head were incorrectly calibrated, and thus failed to detect the levels accurately. We find it strange how things always seem to work to the nuclear industry’s advantage. If and when the next nuclear power stations are built then there will be even more waste, of all levels, for which homes will need to be found. The number of incidents of illegal waste dumping is quite horrendous. The extent of European illegal dumping can be discerned by reading Greenpeace’s paper entitled, “Europe’s Radioactive Secret”. Whatever your view of the organisation, one has to respect the facts. The document can be found here:

http://www.greenpeace.org/international/Global/international/planet-2/report/2006/6/european-rad-secret.pdf

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The manipulation of the democratic process for determining the location of the dump can be discerned from:

http://www.theecologist.org/blogs_and_comments/commentators/2816566/to_dump_nuclear_waste_first_they_must_dump_democracy.html

Illegal dumping has taken place by Sellafield, by the MOD at Drigg, Caithness, Dounreay, Tresavean in Cornwall, Mayak (Russia), Egypt, Naples, Somalia, Texas, North Dakota, Missouri Lebanon, Tibet, New Brunswick, the Mediterranean, the Kara Sea, the Arctic Sea, and many, many places around the world.

Sample sources: http://www.thewestmorlandgazette.co.uk/news/10486663.Sellafield_handed___700_000_fine_for_dumping_radioactive_waste_at_landfill_site/

http://www.theguardian.com/uk/1999/mar/14/antonybarnett.theobserver

http://news.bbc.co.uk/1/hi/scotland/highlands_and_islands/6332669.stm

http://www.heraldscotland.com/dounreay-nuclear-waste-was-dumped-in-the-sea-1.852265 https://kcap89.wordpress.com/2013/03/15/nuclear-waste-dumped-illegally-in-cornwall-uk-press-release/

http://bellona.org/news/nuclear-issues/nuclear-russia/2011-12-russias-infamous-reprocessing-plant-mayak-never-stopped-illegal-dumping-of-radioactive-waste-into-nearby-river-poisoning-residents-newly-disclosed-court-finding-says

http://www.alphabetics.info/international/2012/11/13/nuclear-waste-in-egypt-22-are-not-4/

http://www.dailymail.co.uk/news/article-2483484/Toxic-nuclear-waste-dumped-illegally-Mafia-blamed-surge-cancers-southern-Italy.html#ixzz2jWB1xQa9

http://ecolocalizer.com/2011/03/27/more-illegally-dumped-radioactive-waste-found-on-somalias-coast/

It seems unlikely that, in future years, the nuclear industry will become more trustworthy, in fact quite the contrary, as they become ever more desperate for storage facilities. Moorside will merely add to the problem of waste proliferation at all levels. In recent years there have been 81 coolant leaks and 80 fires in the nuclear industry. Other incidents number over 1,750, and there have been incidents of falsification of data relating to the diameter of fuel rods, which could have had extremely dangerous results if the components been used and become jammed in the guide-ways, as noted in the NI councillor’s (Brian Wilson) article. Some of the better known incidents are: 2011 Macoule 2011 Fukushima Daiichi - Level 7 on INES scale 2004 Mihama - Level 1 on INES scale) 1999 Tokaimura - Level 4 on INES scale 1993 Severesk, (Tomsk-7) - Level 5 on INES scale. (Severesk is currently a surface dump for waste storage, including foreign-owned, especially France.) 1987 Goiânia 1986 Chernobyl - Level 7 on INES scale 1979 Three Mile Island - Level 5 on INES scale 1969 Lucens reactor 1961 Idaho National Engineering Lab. 1959 Santa Susana Field Lab. 1957 Kyshtym disaster - Level 6 on INES scale 1957 Windscale fire - Level 5 on INES scale 1957 Operation Plumbbob

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1954 Totskoye nuclear exercise 1951 Desert Rock exercises Current Problem areas include:

Bikini Atoll, Hanford Site, Rocky Flats Plant, Techa River, Sellafield legacy waste ponds.

The U.K. is responsible for 80% of the nuclear material dumped in the oceans. Currently the total dumped into the oceans around the world is around 100,000 tonnes. There are many nuclear-powered submarines that need to be decommissioned. Currently most of them are poorly stored while, in the case of Russia’s fleet, some have been sunk and potentially could cause explosions and pollution. TRUST Whenever there is a need for a response to a nuclear-related incident, an expert from the IAEA (international Atomic Energy Agency) is consulted. One might think that a body operating under the auspices of the World Health Organisation would be independent of the nuclear industry, but it isn’t. The only independent rôle it has relates to nuclear weapons, in which field it is properly independent. The relationship between the I.A.E.A. and the W.H.O. is difficult to understand. World Health might indicate that the prime concern would be just that, but, according to ex-Director General, H. Nakajima, speaking prior to a conference in Kiev, the W.H.O. is subservient to the I.A.E.A. This can be projected to mean that the health of the global population is secondary to the wishes of the nuclear industry and its supporters, who also have a lot of control over politicians. At that same meeting, D. Zupka from the UNOCHA (Office for the Coordination of Humanitarian Affairs) stated that legacy of Chernobyl will affect generations to come. He continued, “The consequences will not fade away, in many ways they grow more intense.” Noteworthy, perhaps, is that the World Health Organisation were absent from Chernobyl for the first five years after the melt-down. A scientist, Bandazhevsky, has demonstrated that the number of sudden deaths in the region directly correlated to the amount of incorporated radionuclides and the concentration of caesium in vital organs. He was subsequently jailed for eight years in what many see as punishment for daring to contradict the state. (With the help of Amnesty International he was released after serving half his sentence.) Data obtained by the official department for statistics in Chernobyl was shown to have been falsified to minimise the apparent effects of the radiation. However, this didn’t stop UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation) from using the data and thus arriving at a conclusion together with the I.A.E.A. that helped to minimise the damage.

The IAEA is widely known as the world's "Atoms for Peace" organization within the United Nations family. Set up in 1957 as the world's centre for co-operation in the nuclear field, the Agency works with its Member States and multiple partners worldwide to promote the safe, secure and peaceful use of nuclear technologies.

Noteworthy in recent times was the change in the quantity and quality of the information released following the Fukushima melt-downs. Initially situation reporting was of good, honest quality, but that became moderated considerably once the wordsmiths got into their swing. When did you last hear about progress at Fukushima from the U.K. media? Even the UK government was caught out trying to

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minimise the bad news, as they colluded with Électricité de France. Despite all their efforts it set the planned nuclear expansion back many years, as countries accepted that it wasn’t worth the risk. Research into the effects of Chernobyl by people like Bandazhevsky has shown that people suffer not only from cancers, but heart problems, blood pressure problems – leading to strokes, even in young children, physical and mental development impairment.

Source: www.iaea.org

The Redfern Report, published in 2010, found that tissue was taken from 65 workers at Sellafield in Cumbria between 1962 and 1992. Despite illegalities and/or breaches of faith, by hospital workers, union members, police, Sellafield and other staff in the nuclear industry, as well as some in the coronial system, no-one was prosecuted and only a small number of somewhat ineffective changes implemented. The feeling was thus engendered that the whole was supported by the government who viewed experimentation on members of the public as acceptable. Basically, residents in the area were being used as unwitting guinea pigs. The Redfern Report has 96 findings, but it is unclear just how many bodies were actually used in the harvesting of samples. There seems to be in excess of 3500, plus 95 fetuses, and the exercise was not limited to just West Cumbria. Redfern stated, "Pathologists often removed organs at both coronial and hospital post mortem examinations, without consent and hence in breach of the provisions of the Human Tissue Act 1961." (P.562, para. 86) All of the findings are worrying, but some stand out:

91. Coroners who did know that organs which did not bear upon the cause of death had been taken for analysis without their consent failed to act.

92. Coroners ignored the constraint that the law permitted them to request radiochemical analysis, which was a special examination, only if they had decided to hold an inquest.

93. Coroners asked BNFL to prepare analytical reports and used the information to guide them when determining whether the death was the result of an industrial disease. They ignored the potential conflict of interest in asking the deceased’s employer to comment on the likelihood of the death having been caused by the deceased’s employment.

94. Coroners did not ensure that the results of organ analysis were made available to them; in particular, on several occasions inquests were held and the results of the analysis, performed at the request of the coroner, were not adduced in evidence.

95. Coroners assisted BNFL, the NRPB and the MRC to obtain organs for their research, heedless of whether the necessary consent was obtained.

96. The relationship between the coroners, the pathologists and the Sellafield medical officers became too close. There were failures to adhere to professional standards.

The full report can be found at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/229155/0571_i.pdf

The British Legion is also investigating whether past members of the armed forces, too, were subjected to such treatment. The police did not even commence an investigation, despite the evidence available and the illegalities found. Why? It was not in the public interest - apparently. Usually that would be for the Director of

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Public Prosecutions to determine, but nothing was ever sent to that department for assessment. Who determined that the public didn’t need to know the truth and that some people are above the law? In 2003, the then Public Health Minister, Melanie Johnson, revealed that a study funded by the Department of Health had discovered that the closer a child lived to Sellafield, the higher the levels of plutonium found in their teeth. Her statement revealed that, “radioactive pollution from the Sellafield nuclear plant in Cumbria has led to children's teeth across Britain being contaminated with plutonium.” In a parallel system to that discovered by Redfern, it seems that extracted teeth from around the country were collected from dentists for analysis, without consulting the child or parents. According to the authorities, there is, of course, no danger from the presence of plutonium in teeth – leastways, that we yet know of. However, CERIE (Committee Examining Radiation Risks from Internal Emitters) members are more concerned. One of the country's leading experts on blood disorders, who is also a committee member, believes that, “The tiny specks of plutonium in children's teeth caused by Sellafield radioactive pollution might lead to some people falling ill with cancer.” He went on to say, “There are genuine concerns that the risks from internal emitters of radiation are more hazardous [than previously thought]. The real question is by how much; is it two or three times more risky, or more than a hundred?” When even the experts have such a tolerance range, how can anyone suggest that there is no risk? How can people have faith that the nuclear industry does know what it is doing? An article in The Guardian, in 2003, quotes Liberal Democrat environment spokesman Norman Baker as saying:

'[This] stinks of a cover-up. They have known for six years that Sellafield has contaminated the population with plutonium but done nothing. Yet the plant continues to discharge plutonium into the Irish Sea. It shows the wanton disregard the nuclear industry has for public health and there needs to be an independent inquiry.'

Source: http://www.theguardian.com/uk/2003/nov/30/greenpolitics.health

Tellingly, perhaps, the pollution was discovered by a scientist working for the Atomic Energy Commission, but it was six years before it appeared to the public. Typically, children from around Sellafield had twice the amount of plutonium as those from further away. The origin is indisputable as Sellafield is the sole producer of plutonium in the U.K.; in any case, radioactive materials have a unique “fingerprint” which means that any source can be pinpointed. A report in the Scottish Herald, 21/4/07, says:

Now documents from the National Archives in London have shed new light on other scandals involving the nuclear industry. A memo from the UK Atomic Energy Authority (UKAEA) in August 1965 summarised a series of "experiments involving exposure of volunteers to radiation". It said 10 volunteers from Harwell in Oxfordshire drank a liquid containing caesium-132 and caesium-134 in November 1962. Two volunteers from Sellafield, then known as Windscale, also ingested some strontium 90 to investigate "uptake by the gut". A further 18 volunteers at Harwell in 1964 breathed in a vapour of methyl iodide-132 to test its retention in the thyroid gland. If anyone became ill as a result, the memo said, they would be able to sue for damages, though the risk was dismissed as "negligible".

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A letter from May 1968 mentioned moral and practical concerns raised over two uranium tests planned for the Springfield nuclear plant near Preston. Another memo from 1962 referred to highly controversial US experiments in which elderly and sick hospital patients were injected with plutonium. It suggested carrying out a similar experiment in the UK, mentioning old people as potential candidates.

The public, therefore, would be right to disbelieve almost everything they are told that emanates from the nuclear industry, or from those bodies set up by the vested interests in Cumbria and London with the sole aim of expanding the industry by means of corruption, manipulation, deceit, obfuscation, misinformation, rigged questionnaires, by the removal of basic democratic rights, and by the deliberate introduction of specious doubt where none exists in reality. NuGen’s policy appears to be to provide the answers to some nasty questions only after they have started building, by which time it will be too late. Where there is no known answer we are expected to just trust them that all will be right; for example, in dealing with waste, or the impact on the temperature of the Irish Sea. The latter could well upset the thermo-haline circulation producing an impact on the “Great Ocean Conveyor Belt”, causing North Atlantic currents to change direction and intensity. This would, in itself, have a decidedly negative impact on the U.K.’s temperature – perhaps at least as great as the predicted impact of global warming. TRANSPORT For several years now, Braystones residents – through their committee, have been endeavouring to gain improvements for the level crossing which provides them with access to their homes, but which they consider to be dangerous. A copy of relevant correspondence is included herewith for your information. It is difficult to see how the existing railway line will be able to accommodate any increases in traffic without dramatically raising the risk of accident. What will be the impact of rail changes on the residents who already have to put up with vibration and noise from the existing rail services, especially including the nuclear flask trains? It is understood that the “Lego kits” which form the main parts of the reactors will weigh several hundred tonnes. Is it really the intention to load this, or other heavy loads, onto the 160-year-old line, with its aging infrastructure? NuGen omit to clarify what is intended, but we wonder about the impact of the recent announcement of a withdrawal of funding to Network Rail. We saw recently the procedure for using grounded barges to deliver new evaporators to the Sellafield site. Presumably this will be utilised again for some parts of the construction. Will this procedure be limited to daylight periods only, or will residents have to put up with nocturnal activity as the process is adjusted to take account of the tides? No information is supplied by NuGen. The road system is already at full capacity and can barely handle the traffic generated by a shift change at Sellafield. Queues and accidents are a feature of the A595. Any blockage of that road can entail lengthy delays with the only diversion being over 90 miles long. Short-journey alternative routes, such as the lanes through Beckermet, Middletown and St. Bees, already have Sellafield employees travelling at higher speed than is safe. A speed limit has even had to be employed over Cold Fell, as drivers using that road were accused of travelling at too high a speed - to the endangerment of themselves and other users. Corney Fell, to the south, is little better. It is difficult to imagine how these roads can be rendered suitable for the proposed increased number of users without making them even more unsafe or destroying the intrinsic character of the countryside. We see that the application by Cuadrilla to commence drilling for shale gas in Lancashire has been refused at two sites because of concerns over noise, which would "unnecessarily and unacceptably"

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affect neighbouring properties. At one site, it said there would be an increase in traffic, particularly heavy goods vehicles, which would result in "an unacceptable impact" on rural roads and reduce road safety. Quite obviously that project is considerably smaller, both in scale and impact than the NuGen proposals for Moorside.

Source: http://www.bbc.co.uk/news/uk-england-lancashire-30913269

Sadly, there is no mention of how much change will be produced by the plans, so residents cannot glean what impact the scheme will have and thus make an informed comment. As an example, 247 people were killed or seriously injured in road traffic accidents in Cumbria during 2008/09; the latest data shows that while the rate is dropping, there are still around 200 per year. The Centre for Public Health Studies, in February this year, showed that 2280 attendances at West Cumbria Hospital were the result of traffic accidents. Copeland has the highest number of Emergency Department attendances per 100,000 of the population, nearly twice the county average.

Source: http://www.cph.org.uk/wp-content/uploads/2015/02/TIIG-Cumbria-Road-traffic-collisions-across-Cumbria-2011-12-to-2013-14.pdf

These figures are with the contemporary levels of traffic and might reasonably be expected to rise commensurately – or perhaps, exponentially - with the increases in traffic arising from the projected building work. OTHER

As is typical of the misleading information emanating from the nuclear industry, we note in your brochure the comparison between activities likely to generate noise levels higher than 55dB and the sound of a food blender at 90dB. The obvious flaw in the offered comparison is that the dB scale is a logarithmic ratio, whose base level is variable. Thus it is necessary to know the baseline for the readings above which permits will be required. Will it be ambient silence, (i.e. with no extraneous noises included) or ambience with Sellafield or NuGen’s own construction noise – or both - as the base or 0dB level? Decibels (dB) have been described as "a useless affectation, which is impeding the development of noise control as an engineering discipline". If the scale based is the nominal threshold of hearing then the dB (SPL) should be used. Apart from that, It is obvious that a food blender is used only for a very short time during normal domestic periods of operation, whilst construction projects will cause noise pollution for much longer – possibly continuous – periods and will probably be composed of very low frequency vibrations which will be transmitted through the bedrock. Low frequencies are much more penetrative and more easily carried through bedrock over long distances. The comparison between construction noise and a short duration burst of 6kHz from an appliance mounted on rubber insulators on a work-top, is thus spurious and extremely misleading. It is possible to hear and feel (i.e. properties shake and windows rattle) the test-firing of armaments from Eskmeals firing range. (Eskmeals is approximately 15 miles away from Braystones, Moorside less than two miles.) If a food mixer were to be used at Sellafield it would not be heard outside the room, let alone the premises, in which it was operating. Is this likely to be the case with the huge construction process proposed? Sellafield has cost nearly £80 billion and has not even produced electricity since 2003, since when it has been a huge consumer of gas and electricity. It is a lucrative business for those involved, continuing to cost the taxpayer over £1½ billion each year with no end in sight. The management company was recently sacked – again demonstrating the difference between what the nuclear industry and its

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supporters tell the public and the truth. Incidentally, how much of the money received by the management company did actually benefit the local community? One has to wonder at the financial viability of such an installation as Sellafield. What was the true cost of the electricity per unit, when all the hidden costs are taken into consideration? A simple equation: cost of production (plus all on-costs – including insurance premiums and cooling water at commercial rates, and the compensation fund) plus electricity and gas used for cleaning up, divided by the total number of units of electricity produced in its lifetime. There should be some assessment of what commercial insurance premiums would cost, and this should be incorporated in the total cost. The major risk has been and will in future be carried by the taxpayer on terms which conveniently absolve the contractors from liability should they make a mistake – something which the government has again agreed to with new-build. It is almost universally agreed that the unit cost of electricity produced by nuclear power stations, as agreed by DECC, is far too high and will lead to vast increases in electricity costs to all users, and the sole benefit will be to companies from overseas in France, Japan, and possibly China. We believe that the costs would be much, much greater than the public perceive them to be and ultimately show nuclear generated electricity unviable financially. The astounding agreement on unit prices between Électricité de France and DECC means that prices will be crippling for many households for decades ahead. The unit price was more than doubled. At this period, the Secretary of State was Christopher Huhne, M.P., who was later sentenced to eight months in prison for perverting the course of justice. He was not on his own. Around that time over 300 MPs were being investigated: some for fraud, false accounting, or other criminal offences. Others were made to repay expenses claims to which they had not been entitled. A Braystones resident was called to give evidence to the Select Committee, in relation to R.W.E.’s expansion plans for Braystones. Sadly, the chairman of the committee was missing, having been charged with criminal offences. He was later jailed. Industry representatives were warmly greeted and addressed by their first name by civil servants and MPs, and the Braystones witness had to forcefully demand her full allotted time, as she had been interrupted by a division bell which saw the MPs disappear in order to vote. On their return the chairman, Dr. Whitehead, endeavoured to take the voting time out of her slot, which seemed rather biased but illustrated their disinterest in anything that residents had to say.

Hansard: 27/1/2010. Questions 524 – 539 refer. Numerous cases have come to light where members of Parliament have offered their services to “lobbyists”, some captured on video explaining how they have enabled other companies benefit from their efforts which even included changes in the law. The fees demanded, in comparison to the billions of pounds which the nuclear industry has to work with, are very small beer. Small wonder then that the intense activities of Électricité de France, including lobbying and brinkmanship, resulted in a unit price which cannot be justified, but which will produce guaranteed profits for half a century. That guaranteed price will, we believe, become the baseline price for all suppliers. Yet, currently, virtually every other source of power is supplying energy at considerably lower prices than the agreed tariff with Électricité de France, having fallen considerably since the agreement was made. Thus there will have to be an enormous jump in domestic costs to make nuclear-generated electricity even remotely viable. Riots are taking place in Armenia over a mere 16% rise in energy cost. We have a copy of a 2009 report by Citigroup, when nuclear expansion in the U.K. was being mooted with any degree of interest. It is entitled, “New Nuclear: The Economics Say No”, and it suggests five areas which pose risks to even the largest of electricity suppliers: planning; construction; power price; operational; decommissioning /waste.

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By a variety of means, sometimes devious and anti-democratic, those with the influence and connections have managed to “reduce” (i.e. manipulate) the apparent severity of the risks inherent in most of them. Planning rules were changed to suit, power price was set – albeit at a level deemed to be far too high, and the decommissioning and waste disposal has been subject to a variety of scenarios, including burial of high level waste in geology which has been deemed by experts to be too porous to be considered. No other method has been put forward, so the risk remains. As we ask elsewhere, how can any foreign-owned company be forced to clean up? Helpfully, a suitably low cap was put on liability in the case of accidents by means of a Labour-inspired move described by the Speaker, J. Bercow, as, “a gross abuse of parliamentary procedure”. The potential for enhanced risk must also be contemplated: is it sensible for this country to hand over control of such a sensitive utility to foreign interests? Has the possibility of acrimony arising between the parties involved been considered? Although we are currently at peace with all the parties, there is a considerable history – some recent - of warfare involving them all. How risky is it to hand control of such sites to others? How can they ignore the example given of Russia’s gas supplies being used as lever? Nuclear is touted as being low carbon, but this is only when the generating process itself is considered. When mining, processing, and all the other contributory processes are considered, it is not low carbon at all, and, as we have pointed out earlier, the wastes produced are far worse than CO2. There is still no plan to deal with the waste which will be produced. Neither is there any mention of how much there will be, how it will be stored and for how long on the site before it can even be considered for whatever reprocessing can be performed. We have been told, but not by NuGen, that modern reactors leave a smaller, but more concentrated form of waste. Furthermore, we have also discovered that it is proposed that every one of the new sites, presumably including Moorside, will have to store this waste for several decades until such time as its toxicity has decayed sufficiently to allow it to be treated – probably in excess of 50 years. There is no description of how this storage will affect potential risk, but to have the extra, more volatile, material so close to the problematic storage ponds at Sellafield for so long is surely foolhardy.

A corroded KBS-3 canister. Had it been used in an underground dump, the contents would have entered the environment very quickly and both that material and the remaining contents would have been irretrievable.

No system exists for safe disposal of any of the high level wastes. The best that can be offered is “future science”. The scheme for KBS-3 encapsulation, which was touted as the corrosion-free answer to subterranean storage, has been demonstrated to be a failure. A Russian infallible system was used to seal leaking reactors on abandoned submarines. The seals did not work and there are now frantic efforts to recover the submarines before there is an explosion. The current plan will have to involve disposal (i.e. irretrievable dumping) in a hole in the ground. As Professors Smythe and Haszeldene have shown, the ground in the sole area where the councils are volunteering for the dump – Allerdale and Copeland – is unsuitable geologically and eventual leakage

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from the dump is inevitable. One has to wonder whether the ground is also unsuitable for three nuclear reactors, too. Mr. M. Weightman, HM Chief Inspector of Nuclear Installations, said in 2011 that there were barely enough qualified English-speaking inspectors available to complete the necessary regular inspections of nuclear installations. He foresaw that in the future there would not be sufficient. He also pointed out that the only way would be for the industry to provide its own inspectors in the future – not exactly an independent and intrinsically safe way of ensuring standards are, at least, met. Who would dare to criticise his employer’s methods or practises and expect to avoid punishment?

Source: Health and Safety Executive Board - Below the Line Paper - No: HSE/09/13 (obtained under FOI)

Happily, we are deemed to be invulnerable to earthquakes and tsunami. A bit strange when tsunamis have occurred in the past, and there have been several earthquakes in recent times, most recently in Anglesey and Norfolk. Fracking also has been blamed for causing earth movements. The plans for that industry include sites in Lancashire, just over 50 miles away from Moorside. With what may seem to be an inherent bias, all the U.K.’s official reports were issued before other major bodies arrived at their conclusions. We think that it is a little premature to suggest that all the ramifications of the Fukushima disaster are known and its impact fully assessed.

See additional aspects at: http://www.greenpeace.org.uk/tags/weightman-report

Of course, there are other risks, as briefly considered in a document mistakenly posted on the Office for Nuclear Regulation's website, before being hastily removed. For the short time they were available, the questions (as posted) were:

Have they rehearsed adequately concurrent and inter dependant emergency scenarios, such as loss of power and other utilities?

Have they ‘played out’ an emergency exercise in REAL Time over say a 48+ hour’s basis?

Have they ever tried to secure off site Support Equipment in 'Real Time'? Specifically: cranes, Mobile generators, additional /replacement emergency staff etc.

Have they considered within their emergency planning the possibility of losing ALL the key utilities to the site? Electricity, water, steam, compressed air & other essential gases, concurrent with say chemical or other toxic releases.

Have they got contingency plans in place to secure whatever additional resources they may require?

Have they considered the scenario whereby staff on site at the time of a major Incident, also affecting the local area, may demand to be released to go to the aid of their families?

Possible scenarios were considered, including:

A terrorist team attack from out with the site security fence.

The team could destroy the following, without requiring access to the site.

Take out not only Fellside [for electricity & steam] but also the adjacent stand-by diesel & steam supply units.

Destruction of the standby gas turbine and diesels generators on the main site

Followed by destruction of the brow top reservoir & pumping station.

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Destroy a couple of electricity supply pylons to both north & south of the site, rendering it, and the whole of West Cumbria, completely devoid of electricity supplies.

The result would be the need to secure large diesel generators, pumps & fuel supplies from say Manchester or Newcastle: not an easy task if the attack was timed for, say, a bank holiday Friday!!

The writer concluded:

Had the above scenario been necessary last year when the bridges in Workington were down, how long could it have taken to secure equipment from those cities???

Yes it may have been possible to provide police escorts but many of these large items of equipment do not travel at speeds greater that approx 30 mph: and require considerable road space. If these items were acquired, what about the logistics of keeping them supplied with diesel fuel etc??

Apologies if this sounds negative, but it was a debate that was held by the Duty Engineering Teams following a terrorist attack some years ago, the site’s preparedness at that time was based on minimum personnel infiltration to the site, whereas it was considered that there is the potential for severe damage that could readily and easily be caused, without gaining access to the secure areas, and the impact would not only be to the site but also the surrounding areas.

The potential for infiltration for malicious purposes has already been tested, for example by Greenpeace. In 2012, a Greenpeace activist dropped a smoke bomb on the Bugey nuclear power station in France. Fortunately it was not a real bomb and the target was not Sellafield, but there is no reason why a similar, but more malicious incident could not happen there, whether by hang-glider pilot, remote missile attack, or just a drone. Dropping common explosives into the legacy pools would produce quite a lot of inconvenience. There have been several other infiltrations of nuclear sites, especially in France, where the incidents also included the use of illegally-operated drones. Already this year, there have been flights by five “industrial style” drones (i.e. not toys or low-capability drones). Attempts to shoot them down failed.

Source: http://www.independent.co.uk/news/world/europe/french-government-on-high-alert-after-unexplained-drone-flights-over-nuclear-power-stations-9850138.html

Security breaches are quite frequent and over 100 people have taken part in breaking through the security cordons. Consider: at what stage is a protester going to be shot merely for making a point? Almost all the concern seems to feature peaceful protesters scenarios. Yet who are the ones toting guns? Who is capable of the greatest damage? In America such gun crimes are a feature of modern life. We believe it is only a matter of time before a member of one of the security teams uses his weapon in a malicious way. Nowadays, the development of low-cost drone technology means that infiltration no longer requires breaches of any perimeter fencing. Although currently mainly used to host video cameras, there is no doubt that very soon they will be developed to carry other payloads. We believe that any such attack would be very difficult, if not impossible, to prevent.

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Over the past decade there have been several incidents involving aircraft and Sellafield; in 2004 an aircraft flew over the Sellafield plant for 15 minutes before jets scrambled from RAF Leuchars in Fife and RAF Coningsby in Lincolnshire managed to arrive. Even though this was part of an exercise.

Source: http://www.newsandstar.co.uk/news/raf-jets-race-to-save-sellafield-1.450450

It would take approximately 30 seconds for a plane to deviate into the exclusion zone of 1½ miles round Sellafield and crash into the plant. In 1993, a cargo flight from Southend to Glasgow crashed near Sellafield when weather deteriorated.

Source: http://www.aviation-safety.net/database/record.php?id=19930113-0

In 2005 a micro-light with two people on board made an emergency landing in a field near Sellafield because of fog.

Source: http://www.airliners.net/aviation-forums/general_aviation/read.main/2153169/

The Nuclear Installations Inspectorate recognised in the beginning of the paragraph dealing with the aircraft crash risk that, “There has been no specific design provision to protect against crashing aircraft”.

Source: http://www.wise-paris.org/english/ourbriefings_pdf/011029AircraftCrashSellafield3.pdf

Despite Sellafield's assertions that it couldn't happen, and even if it did little damage would ensue, all their studies were based on parameters set before 11th September, 2001. The idea of anyone deliberately crashing a plane into a structure was then far outside what could have been imagined. Now we know better. Even so, the measures taken by Sellafield are aimed at surviving light aircraft of military planes - not commercial airliners.

Source: http://www.theguardian.com/uk/2001/sep/23/robinmckie.olivermorgan

More than 700 airliners pass within 57 miles of Sellafield each week. It would take less than six minutes for a plane to divert into the plant. There have been calls for anti-aircraft weapons to be installed nearby, but it is akin to the social studies debate: at which point do you bring down a plane with hundreds of passengers just because you think it might crash into a nuclear installation. Who would take the risk? Still, it will not happen. After all, who would crash a loaded plane into any building? At least one drone has flown over Sellafield, shortly after 11/9/2001; hopefully NuGen’s storage of high activity waste will be bomb- and plane-crash-proof, but there is no mention of their plans for long-term on-site storage. We do hope they do not propose to leave it for a future generation to deal with. COMPUTER AND ELECTRONIC EQUIPMENT VULNERABILITY

The head of the inspectorate stated recently that the review of nuclear installations in the U.K. carried out post-Fukushima had revealed no real problems and all were safe. They may be safe from tsunamis and serious earthquakes, but they are not intrinsically safe and totally invulnerable. As has been demonstrated so frequently, even in a properly functioning system, human error is the most likely cause of error. Despite the evidence afforded by the Stuxnet virus, its derivatives and successors, together with those from totally different strains, we are expected to believe that every critical control process in the nuclear industry is beyond compromise. We find it difficult to believe that every firmware chip in a control system will be investigated to examine whether it contains embedded malware in its firmware code.

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It has to be hoped, too, that the control software will not be accessible via such common vulnerabilities as USB ports, or connected in any way to any system which can be accessed by an external network. Is that a likely situation? We are aware of an incident where a USB port was used to charge up an electronic cigarette by an employee – a piece of malware was embedded in the charger’s control system. Several countries, for example, Russian, China, North Korea, the United States, several central European states, and the religious fanatics who are based in the Middle East, are renowned for hacking into sensitive networks with malice in mind. Whether for terrorism, experimentation, or just commercial manipulation, networks which, just a short time ago were deemed to be intrinsically safe have proved to be anything but safe. The future for the Internet of Things, as it is referred to, envisions even the most mundane of items “talking” to each other via a network. Most of the chips utilised in network cards and PCs are made in either America or China. Both those countries have been involved in hacking exercises with no respect for other countries’ borders. The Stuxnet virus was a joint project by America and Israel and installed itself on PCs running Microsoft Windows. Sellafield uses Windows on PCs. The malware was then designed to target specifically Siemens industrial programmable logic controllers – which were installed in centrifuges being used for fuel enrichment purposes in Iran’s nuclear programme. Almost 60% of Iran’s computers were affected, together with those of several other countries. In this case the payload was specific, but there is no reason why, in future attacks, the payload could be less specific or target (or leave a deliberate vulnerability) in embedded logic processors in any PC. It has to be understood that firmware or other software products are not infallible. This includes the various programmable chips whose software is normally not routinely changed, for example BIOS chips which set the basic parameters of a computer system. The U.K.’s government seems to think that use of a mobile phone or computer is ineluctably linked to one individual and conflates the two, thus any criminal activity on a device is automatically deemed to have been committed by the owner thereof. Patently this is not necessarily always the case. There is no exclusivity associated with devices. There can be multiple legitimate users. With this level of understanding from those who should know better, it seems difficult to accept that they would know enough to ensure that any complex nuclear industry system is intrinsically safe from hacking and thus from outside control, possibly by malicious parties. When all the technical components and control systems on which safe operation of any nuclear plant depend are designed by other countries the potential for sabotage is immense. If the target were close enough to affect the world’s largest store of radioactive waste then the fallibility of the decision-making process is exposed. Last year The Guardian reported that:

Cyber attacks on countries and corporations are likely to increase in the next decade, according to a majority of internet experts surveyed for a new report by the US-based Pew Research Center. Among those who agreed, there were four themes. First, that internet-connected systems – from defence, energy, banking and finance to transportation – are “inviting targets” for cybercriminals. “Current threats include economic transactions, power grid, and air traffic control. This will expand to include others such as self-driving cars, unmanned aerial vehicles, and building infrastructure,” said Mark Nall, program manager for N.A.S.A. Source: http://www.theguardian.com/technology/2014/oct/29/major-cyber-attacks-internet-experts

The vulnerability of medical equipment has already been demonstrated. It is only a matter of time before those who do not share our views of the world succeed in hacking ever more vital infrastructure systems. Indeed, the U.S. Department of Homeland Security’s Industrial Control Systems Cyber

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Emergency Response Team (ICS-CERT) cited 300 medical devices from 40 companies that had unchangeable passwords. If an attacker were to obtain a list of these passwords, he could theoretically log in and change critical settings, with unfortunate consequences. Of course, legend has it that this cannot happen. This month there has been a report under the heading “U.S. government hacked; feds think China is the culprit”, which said that four million current and former federal employees, from nearly every government agency, might have had their personal information stolen by Chinese hackers.

Source: http://www.usatoday.com/videos/news/2015/06/05/28526247/

Not only system attacks will cause immense risks; so, too, will personnel and general management network disruptions. Another recent report has a computer engineer claiming to have been able to control a passenger aeroplane on which he was travelling by hacking into the plane’s control system via the on-board entertainment system. There is no explanation from the aircraft manufacturer as to why an entertainment system was added on to such a vital flight component, nor why the systems were not kept completely separate from each other on different and unconnected, computers. Large teams of computer specialists have been employed by almost every country. The aim is not standard warfare, but computer warfare – attacking the infrastructure, establishment, or financial structure can be far more insidious than risking being killed in standard warfare. Today we learned that a software flaw in an application on an iPad used by airline pilots caused planes to be grounded, whilst on 22nd June, the Polish airline LOT grounded planes after the control centre’s computers were hacked. "We're using state-of-the-art computer systems, so this could potentially be a threat to others in the industry," the airline’s spokesman said. Not just that industry, we would add.

Source: http://www.telegraph.co.uk/news/worldnews/europe/poland/11690425/Hacking-attack-grounds-planes-at-Polish-airport.html

COMMUNITY

A section of the Director of Public Health’s report in 2009, says that Cumbria has 24 specific communities that in 2009 were in the 10% most deprived in England and Wales. Seven of them are in the worst 3%. This means that approximately 16% of the Cumbria population lives in areas which officially rate as among the most deprived in the country. (More recent reports do not contain the same specific data.) The nuclear industry has existed in the area for almost seventy years and has benefitted, and continues to benefit, from many billions of pounds raised from public taxation. Where then are the benefits that are supposed to ensue following the community’s tolerance of continual nuclear expansion? Why are these basic amenities’ funds channelled through the nuclear industry? Why are the new promises any different from the old ones? These funds should be supplied, as they are elsewhere, by national and local government. As noted, the nuclear industry in Cumbria has been around for seventy years, and the promises were that the in-pouring of funds to Windscale/Calder Hall/Sellafield would benefit the area and provide electricity at “too cheap to meter” prices. Instead, it has produced very few tangible benefits – and those solely because they benefit the nuclear industry. Government policy is that no area should be dependent on a single employer, yet this is exactly the situation that they have produced and seek to continue. Tourism was once a viable alternative, yet who would want to come and visit when the area is a vast sprawling nuclear site. Several holiday-makers we have spoken to have expressed surprise when they discover that, although unmentioned in Hoseasons or

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other brochures, they are just a short distance from Sellafield and its pollution. Neither do they have any knowledge of the state of the beach, and are horrified when we inform them. Despite the efforts to persuade people of the contrary, these nuclear sites are seen by the general public for what they are: dangerous processes with little local benefit, but which produce highly toxic long-lived wastes for which there are no known safe disposal plans – nor can there be any possible plans as no-one knows what to do with such material, other than put it in a hole and hope that the hole doesn’t leak for 100,000 years. No human construction has ever been that long-lived. We note the promise of many thousands of jobs, but can find no substance to these claims from any source. We also have to ask how many available (i.e. fit and unemployed) members of the local population there are to fill these vacancies? Official figures show that to May, 2015, there were only 4,042 unemployed in the whole of Cumbria. Copeland had 785, and neighbouring Allerdale 972.

Source: www.cumbriaobservatory.org.uk

Are all these people guaranteed a job at Moorside? Or will the vast majority of employees – along with all the equipment - come from abroad, especially other EU countries, attracted by the employment prospects, but keeping wages low to the benefit of NuGen? How many of the local workforce will attract the top pay levels? The tourist industry has 33,000 full time equivalent employees. (i.e. with adjustment made for the seasonal nature of the jobs. The number of people actually employed, whether part-time or whole-time but just for the season, is nearer 57,000.) How many of these will be lost when tourists decide they no longer find the area attractive, or deem it to be too risky? It certainly seems unlikely that the vista presented by sprawling and ever-expanding 2 square miles of the Sellafield site added to that of the proposed Moorside site and its ancillary buildings and artefacts will appeal to many holiday-makers. Even now Copeland has only a third the number of tourists that neighbouring Allerdale has, with a commensurate reduction in revenue. Why might that be?

Source: http://www.cumbriaobservatory.org.uk/

What happens when the NuGen project is finished? Will all these temporary residents be reduced to claiming benefits, or will they seek work in menial tasks – thus driving down the already-depressed economy even further? Who will benefit from the thousands of empty houses left when temporary residents have returned home? Will current residents’ houses be devalued as a result? Merely by announcing the plans, NuGen has blighted the community and cost residents tens of thousands of pounds by devaluing their properties. What changes will there be to the infra-structure to accommodate the influx? Just recently, the two main hospitals for the area, in Carlisle and Whitehaven, have been “put in special measures” as they fail to cope with even the current levels of demand. There are continuing problems with Barrow Hospital. While accepting that Sellafield is a different site with different problems, the close proximity of Moorside to the Sellafield site does mean that there will be considerable interaction. A problem with one will inevitably have some effect on the other. Apart from the obvious dangers from the domino effect, other practical problems are bound to be encountered. Warnings to the public of a leak from one site could very well lead to confusion, for example. Despite having heard from sources such as The Whitehaven News - whose income is substantially derived from Sellafield and the nuclear industry - the rhetoric about how good things are at Sellafield, the management team, whose website says, “The Nuclear Management Partners mission is being delivered under the leadership of a team with proven ability and expertise”, were sacked after six years of escalating costs and mismanagement. Between 2009 and 2012, £6.6 million was shared amongst the managers, and £100,000 repaid for false expenses claims.

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According to the same website, if we understand correctly, the socio-economic benefit to the community amounted to around 1% of their income. If you doubt the paucity of benefits that have been seen in Cumbria you merely have to look at the state of Egremont and similar small towns just a few miles from Sellafield. Visit those towns during the evening at the week-end and see the effects of low income and social deprivation. The chasm between who those who have and those who have not is huge. Some Braystones properties have neither electricity nor running mains water, despite the proximity to the generating capacity of Sellafield for over 40 years. Building development is largely Sellafield spreading to adjacent towns as its current site is getting full. They seem to have no problems obtaining planning permission for buildings which have little intrinsic beauty and, especially in Whitehaven, utterly fail to blend in with the Georgian buildings and street plan. With regard to the planning, we assume that the commissioning of the NuGen plant will put an end to plans for an underground nuclear dump. At the Nirex inquiry it was stated that disturbance of water flows and other aspects of the geology would make the dump plans too risky. Since the proposed construction at Moorside will undoubtedly impinge on the geology, we believe that it will put an end to the dump being sited nearby. It is questionable, too, whether the decision regarding unsuitability of the geology in the area for the dump, automatically infers that the Moorside site is unsuitable or unsafe. We see that a senior structural engineer at the U.S. Nuclear Regulatory Commission, John Ma, has expressed grave concerns about various aspects of the AP1000 reactors. These extend from the type of materials used and the lack of secondary containment. He says that were a breach in the main chamber to occur, then radioactive materials would be discharged into the atmosphere. He also queried some of the computer models used to calculate material thicknesses, which he believes are too brittle to do the job they were designed to do. Other critics include Arnold Gundersen, a nuclear engineer commissioned by several anti-nuclear groups, who was concerned with the possible rusting through of the containment structure steel liner. As there is no secondary containment material would be vented to the atmosphere; Edwin Lyman, a senior staff scientist at the Union of Concerned Scientists, one of several of that body concerned about the design, has challenged some of the cost-saving design choices made for the AP1000. He, too, is concerned about the strength of the steel containment vessel as well as the concrete shield building around the AP1000. He says that the AP1000 containment vessel does not have sufficient safety margins. As recently as 2009, the NRC enforced a redesign of the outer structure surrounding the AP1000, saying, “It does not meet fundamental engineering standards with respect to design basis loads”, as well as several other concerns not disclosed to the public. In 2011 Westinghouse were again told to submit recalculations for its design and questioned as to why it had submitted incorrect information to the NRC. There have been no tried and tested prototypes of this design, all the strength and safety analysis is based on computer modelling – something which is known to be prone to mistakes. Yet we are expected to have confidence in this construction project. We note, too, in Mr. Gunderson’s paper entitled “ap1000-gundersen-containment-report.pdf” that there are vulnerabilities, too, in that the design is open to the atmosphere. The style of construction, which would be useful when wishing to dissipate excess heat by convection currents, means that, by design, the AP1000 containment has an even higher vulnerability to corrosion than containment systems of current reactor designs because the outside of the AP1000 containment is subject to a high-oxygen and high-moisture environment conducive to corrosion and is prone to collect moisture in numerous inaccessible locations that are not available for inspection.

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Given the proximity to the various chemicals discharged from Sellafield and the highly corrosive nature of the salt atmosphere from proximity to the coast, this problem of corrosion does seem rather an important issue. We also note that the convectional dissipation design will exacerbate the dissipation of radioactive materials in the event of a containment failure. We have doubts, too, as to the reliance on even the purely mechanical fail-safe aspects of the design. In such a hostile environment, even the most basic of mechanism can seize up and/or fail. On the basis of current knowledge, it is right to question whether the touted reliability, durability and safety can be considered to be true. It is no surprise that this kind of information is not included in your brochures, which are solely concerned with selling the idea that all is safe and enduring. Do the public really not have a right to know what they are being made to host and all the risks associated therewith? Reuter’s press agency reported that:

Austria will take legal action to block any subsidized nuclear power plants in an effort to discourage use of the technology in Europe and scare off investors, the country's environment minister, Andrae Rupprechter, said in a newspaper interview. Rupprechter's comments to business daily Wirtschaftsblatt reflect non-nuclear Austria's tough stance, as evidenced by its intent to take the European Commission to court over approval of Britain's plans for the Hinkley Point nuclear plant. The neighbouring Czech Republic also plans to extend its nuclear capacity. "Should other countries present similar subsidy plans, we will fight these in court," the minister said in the interview published on Wednesday, saying such state backing hindered the rollout of renewable energy technology. Giving preference to nuclear power is unacceptable. Nuclear energy is neither safe nor economical. A lawsuit may also make potential investors hesitant." Source: http://uk.reuters.com/article/2015/05/27/us-austria-nuclear-idUKKBN0OC0KD20150527

There can be little doubt that the terms offered to nuclear power generators include generous subsidies, no matter how they are fudged. Presumably, therefore, the NuGen proposal will also be tested in court on that basis and, perhaps, others. CONSULTATION FLAWS We believe the consultation process is flawed and fails to comply with legal requirements and we draw attention once again to the first paragraph of this submission. What is the point of a consultation that is not prepared to listen, accept changes and criticism, and where the outcome is at the whim of government and the industry, not the locals? In Whitehaven, the NuGen agent told us that nothing would stop the construction process. We have today learned that the fracking application in Lancashire was refused. This was by councillors abiding by the will of the people. If the process is unstoppable, why bother to consult us? How does this equate to democracy? As previously noted, the decision-making processes have already been accused of corrupt practices and breaches of democratic process, on one occasion causing the Speaker, J. Bercow, to describe it as “. . . a gross abuse of proper parliamentary process”. Instead of reviewing the system and making it fair and democratic, the entire planning process was changed to facilitate construction, removing the rights of those affected to challenge the decisions made by those who will remain unaffected.

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We say this not least because the informational material supplied to a few of the Braystones beach residents as part of the consultation process did not arrive until after the meeting at Beckermet had passed. Most of the other residents have received no communications at all on the matter. Some we have spoken to were completely unaware of the proposals and their potential impact. It is probable that the same applies to caravan owners at the sites in Braystones, casual visitors and the owners of holiday bungalows. Are they not entitled to know and have a say? The information supplied by NuGen only reflects the views of that company together with well-established patterns of misinformation, and does not present any contrary, adverse, or uncomplimentary information. It amounts to propaganda, not information. As I have mentioned, we can see no note of the opinion of the Manx government or Irish Assembly on the proposed new discharges, the probability of re-circulation of legacy discharges, nor on the proximity of such dangerous processes to their residents, especially when its proximity to the “dangerously corroded” cooling ponds at Sellafield are taken into account. As a result of this apparent omission, I have written to both the Northern Ireland and Manx governments enquiring about their views. We are aware that in the past they have not been complimentary about the nuclear industry. If they have been consulted, why have the views of those affected, whether at home or abroad, not been reported in your consultation documents? The two nearest neighbours represent affected groups: almost 90,000 residents in the Isle of Man and 2,000,000 in Northern Ireland. Together with the numbers of Cumbrians opposed to nuclear expansion, this represents a considerable body of objection. We understand that the Irish, Manx and Swedish governments have, in fact, expressed serious concerns and objected to the expansion in Cumbria. The information sheets do not contain any mention of these well-founded concerns. As the United Kingdom is a member of the Energy Community, we would ask whether this consultation conforms to Article 7 of Directive 85/337/EEC, which requires any country which is affected by a proposed development to be consulted.

https://www.energy-community.org/pls/portal/docs/36294.PDF refers. What countries have been consulted to date? Have they voiced an opinion? If so, what was it and why is it not included in the provided information? What may also be an interesting legal argument is whether it is possible to exclude the people of Cumbria from a decision-making process in order to impose a potentially lethal operation on the area. We have seen what the majority of Cumbrians feel about the nuclear industry and the dump. We have also seen the majority of those people excluded by careful selection and manipulation. If places like the Isle of Man and Ireland must, by law, be given a chance to have a say in the matter, how can people more immediately affected be excluded by the process or not be given a meaningful role in the decision? Presumably, the construction and, perhaps, the operation of the new site will involve ground-based vibrations, which we can only assume will shake the neighbouring legacy waste ponds, thereby exacerbating the “rapidly corroding” condition thereof. Any agitation of the contents could lead to unforeseen results. It is impossible to make meaningful representations when the proposals are so vague, even though they will have a dramatic and damaging effect on the area and its residents.

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That previous consultations were flawed and deliberately skewed can be discerned from examination of documentary and verbal evidence, as in a dissertation by Paul Hallows, who examined the background to the recent proposals for the nuclear dump proposed for the Copeland and Allerdale council regions. His analysis can be found on the internet at https://cumbriatrust.files.wordpress.com/2013/12/paul-hallows.pdf Anyone who was aware of the process at the time would have been aware of the dishonest nature of the consultation which was designed to have only one outcome. Even the questions were composed by the pro-nuclear groups and designed from the start to mislead. The person responsible was said to be extremely pleased that it had worked out as planned. The dump, as with the new reactors, was a proposal purely based on political expediency not scientific rigour, but the cause has nonetheless been espoused by peers of the realm, several politicians, councillors and support groups, such as the Energy Coast lobby - whose self-interest is obvious. One has to wonder what rewards they will be given or expect. It is our opinion that, because of the above – the failure to comply with consultation requirements, the lack of specific information and the failure to fully inform residents of the full impact of the development – the consultation and the build itself are open for judicial review or other legal challenge.

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SUMMARY As superficially outlined above, the industry has shown its capacity for deceit and disregard for legislation, human dignity, the environment, and public health. Scientific opinion relating to “safe levels of exposure” still produces dramatic and material differences, which indicates that no-one knows. Inevitably, when it is a fact that we are not homogenous, people will be affected in different ways and with differing severity. There is no level which can be said to be universally safe. Waste disposal and how to deal with it is another matter in which there is tremendous reliance on future science to provide an honest answer. Very recently we were told with all the false assurance that nuclear scientists seem prone to, that these materials could be safely disposed of. Then it was discovered the method was flawed. Despite all the evidence that the proposed system would be dangerously flawed, some people are still pushing for it to be put in place. These people are quite happy to use scientific arguments to bolster their cases until the science denies what they want or is proved not to work, at which point science becomes irrelevant. Such an attitude has produced the current mess that is Sellafield and the huge number of health effects that ensues from making false promises of competence. From the beginning of the nuclear industry people have been prevented from knowing the truth about it. Those involved at all levels have demonstrated that they prefer to keep people ignorant rather than reveal the true cost and impact that the nuclear process has on the environment and health. There is no reason why we should trust either the industry or its representatives now. That NuGen should come in and impose three large reactors whose design at present includes at least 51 known flaws and expect a welcome is a tremendous demonstration of arrogance. A cynic might also suggest that, if the risks were so low, the buildings so beautiful, and the impact on the environment as low as suggested by your propaganda, and the rewards (including financial benefits) so great, then the development would be in the south of the country, perhaps in London; not being imposed on this area where the poverty and the carefully-cultivated utter dependence on the nuclear industry is being used as a weapon. Such a move to the south would drastically reduce transmission line losses, too. When the profits from the generation of electricity are going to be mainly taken abroad, to France, Japan, Turkey, and possibly America and China, it is hard not to be greatly concerned whether corruption has taken place to allow politicians and peers to not only accept it, but to actively promote it in the face of so many strong contrary arguments. Those outsiders will have control of a vital U.K. resource. Article 1 of the First Protocol of the European Convention on Human Rights gives people the right to a peaceful enjoyment of their home. NuGen’s proposals to impose – against our will – several nuclear reactors, which will entail a great deal of risk, inconvenience and nuisance over a very long period will certainly disrupt our home lives. We have a home at Braystones to enjoy the scenery and natural beauty of the location. Your plans will disrupt that, throughout the construction phase and, we believe, once commissioned, the effects on the environment will be catastrophic. Article 2 of the same legislation requires that the Government take steps to safeguard the lives of everyone within the UK’s jurisdiction:

by having effective criminal legislation (i.e. making murder and manslaughter an offence) and properly enforcing it;

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by requiring the police to take reasonable steps to protect an individual’s life if they know or ought to know that there is a real and immediate risk to a person’s life - although this should not impose an impossible or disproportionate burden on the authorities;

by requiring the State to take appropriate steps to prevent accidental deaths by having a legal and administrative framework in place to provide effective deterrence against threats to the right to life.

We believe the pertinent part of that would be the requirement to prevent accidental deaths. It is known that some properties of radiation affect people’s health; exposure to radioactive materials will often result in illness and/or death. This is acknowledged by the existence of the compensation scheme, which is run for the benefit of Sellafield employees. By knowingly extending the risks and causing the recycling of legacy pollutants we believe a case could easily be made that the government and NuGen are failing in the requirement imposed by the above to prevent accidental deaths. We further believe that by knowingly recycling radioactive materials you will be threatening resident’s and visitor’s lives. If what you are proposing was to be in your own backyard, would you still be so keen? The nuclear industry needs to restore trust and democracy and dispose of its waste properly without thinking it can manage the future. It is not rational to believe that anything can be managed 200,000 years ahead. 6,000 generations cannot be dictated to and nothing is that stable, least of all politics or science. Then there is the question: what will be the ultimate result when the nuclear industry has finished with Cumbria? What will be left behind? We have always had problems understanding the concept that nuclear generation is in any way less polluting than conventional electricity generation. Indeed, it is difficult to see why CO2 production is in any way more injurious than radioactive waste. Quite how the industry has persuaded politicians of this, or the premise that the nuclear industry produces no CO2, is beyond us. One only has to look at the logic to discover both premises are false. Announcing that Austria is to challenge the U.K.’s subsidies to Électricité de France, Andrä Rupprechter, the Austrian environment minister, said that nuclear energy was no longer able to survive economically, and should not be artificially resuscitated through state subsidies. He went on, “Instead of funding unsafe and costly energy forms that are outdated, we have to support Europe’s energy turnaround with the expansion of renewable energies.” DECC is believed to be discussing with Électricité de France how to handle liability for costs incurred on the project if Austria’s challenge succeeded and the deal had to be cancelled.

Source: http://www.thetimes.co.uk/tto/environment/article4489726.ece (7/7/15)

We conclude with a pertinent quote from http://www.corecumbria.co.uk/:

“In swallowing their own perverted propaganda, the NuGen consortium has clearly lost touch with the realities on the ground both here and abroad.”

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0

200

400

600

800

1000

1200

0 4 2 9 4

122

313

1220

57

20 1

Data from: http://www.sellafieldsites.com/wp-content/uploads/2012/08/Beach_Monitoring_Summary_31-03-2013.pdf

Finds of Cs137 and Am241 , Calendar Years 2007 - 13

We note a discrepancy from previous data, e.g. Whitehaven shown as having 18 finds to the previous year-end. Places like Nethertown will probably have particles, but the nature of the terrain prohibits the use of the vehicle-mounted detection equipment.

We also consider that the number of variables - such as the typical tidal flow direction and churn factor of the sand renders the exercise somewhat meaningless.

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Screen grab from BBC programme “Coast”, depicting the flow of radioactive material from Sellafield’s discharges.

This material has now also been detected off the coast of Nova Scotia, Canada.

There is no safe level or threshold of ionizing radiation exposure.

Even exposure to background radiation causes some cancers. Additional exposures cause additional risks.

Radiation causes other health effects such as heart disease and stroke, and further study is needed to predict the doses that result in these non-cancer health effects.

It is possible that children born to parents that have been exposed to radiation could be affected by those exposures.

Reproduced from toxiccoast.com with permission.

E-mail sent to ITV Borders re. Braystones Beach residents concerns about the level crossing.

15/5/15 Dear , Apologies for the delay in setting up a meeting at Braystones. This is not due to any inactivity on my part, but the chairman of the residents’ group has sold his bungalow and moved off the beach. I have been in touch with the new chairman and asked her to make the necessary approaches to other residents and supply convenient dates. We will be up there from the 22

nd, and I am hoping that it can all be

dealt with in the following week, before we have to return home. Hopefully, when other residents have been contacted I will be able to suggest a suitable timeframe. In the interim, I have received the data I requested from Network Rail, in respect of the traffic and the number of incidents relating to Braystones level crossing. They supplied a great pile of paperwork, but I have now worked through it and it shows that the traffic is actually 269% higher than the figures they used to feed into the computer model calculating risk at the crossing. That does not take into account any under-estimate of the pedestrian data that seems likely to have been made. Given the method used to glean their data, it would seem that the risks at level crossings generally are far higher than might appear – not just at Braystones. The actual figures are as below:

You may recall that one vehicle crossing entails five actual crossings, four trips on foot and one to get the vehicle across. Another point is that the records only show crossings that take place when the signal-box is manned and, obviously, exclude Sundays. Trains still run outside those hours on an ad hoc basis. The incident log seems to be somewhat incomplete – there are some incidents we are aware of which do not appear on it. For example, we know of three landslips that have occurred in the above period. There was a previous one in September, 2008, at the station, too. Nonetheless, the log amply illustrates why our concerns are legitimate, as even the partial log demonstrates, there have been 93 incidents within a 64 month period. The telephone problems are noteworthy; you will be aware that there is no viable alternative to using the closed-circuit telephone, the BT phone box having been removed many years ago, and if the Network Rail phone is out of order then residents have a problem. One entry complains that the crossing user was asked to advise the signaller when the train had passed, but put the phone down. From experience, I know that sometimes the phone line is so noisy and the instructions so mumbled that it is difficult to know what has been said. In high winds, with the stormy seas as a background, it is even more difficult. The entry “Pedestrians on the line” relates to youths and children with a dog and, on another occasion, a motorcyclist riding along the track. It prompts the question of whether these were holiday-makers unfamiliar with using a level crossing properly. As pedestrians are not required to obtain permission to cross the line, no record exists of the true number. We tend to assume that the numbers are commensurately higher, in line with the vehicle estimation, with holiday-makers increasing the numbers during the season. The incidents of damage (two accidental examples of which are listed under the “Other” category) ignore the occasions when vehicles have caused damage to the gates or posts, of which there seems to be no record, although we recall that there have been at least two incidents when the gates were rendered unusable after being struck in very recent times. The “Banking on fire” incident followed the passage of a tourist steam train. It was eventually extinguished by the local fire service, but then re-ignited. Given that the beach bungalows are predominantly wooden structures, the risks incurred by such events are very high. The tourist train service is hoping to achieve one a week this year, increasing in the future. In the days when steam was the motive power for all railways, the fires occurred fairly frequently and the dry undergrowth was thus burned off, reducing the potential for serious fires. However, nowadays, in the event of a bungalow fire occurring, it would result in total destruction, as the local fire service would not be able to attend within a time which would allow them to be effective. They are also aware of the problems of getting their equipment along the beach track, which would further impair their effectiveness. Similar problems exist for the other emergency services. We know of only one occasion when an emergency vehicle on a call was held up at the crossing due to the proximity of a train. Sadly, the information on how the risk scores are achieved was not supplied. I had hoped for some formula into which I could insert the proper data (as opposed to Network Rail’s sampled figures) and arrive at a true figure, but this was not supplied. One of the explanatory notes on the scores suggests that an increase in traffic does not increase an individual risk of serious injury or death. However, although this may be correct, the implication that there is no increased risk of an accident occurring would be a very wrong interpretation. An increase in the number of crossing users and/or rail traffic must result in an increase in the risk an accident will occur. Several hundred tonnes of nuclear train at 50 or 60 mph means a serious and costly accident, even if the load stays intact. Regards, cc: Cllrs

28th April, 2015.

Braystones Level Crossing - Progress Since 13th April, 2014

At the extra ordinary AGM on 13th April, 2014, I was nominated to pursue a number of Network Rail issues on behalf of the resident’s group. Since that time I have written many letters (12) and even more emails (50+). I have also sent regular up-dates on progress to Peter Graham for forwarding to the group. Copies of five documents produced by me were sent to a variety of relevant bodies. Subjects included a history of the crossing, modern improvements to crossing technology, and current opinion on such matters as the shape of embankments and the promoting factors in landslides affecting railway lines – as relevant to this section of line. SUMMARY OF THE ACTIONS TAKEN AND THE OUTCOME

i) Campaign with CRUG to improve the frequency of trains stopping at Braystones Copeland Rail Users Group (CRUG), myself and the owners of Tarnside caravan site were in correspondence with Northern Rail regarding this. As a result of this, the level of service from Braystones increased. I can claim little credit for this, as CRUG had been negotiating for some time for improvements. However, we added weight in support of their bid. Most people agree that the financial viability of providing a higher level of service is doubtful. Currently, five trains in each direction stop at Braystones daily, although some of them are request stops only. We queried why not all trains could stop on demand, but the answer was unsatisfactory. Should demand increase, then Northern Rail would be happy to look at the situation again. ii) Confirm the manning times of the Sellafield signal box The Office of the Rail Regulator (ORR) has provided some basic times for the manning of the Sellafield signal box, but, as I have pointed out to them, the times of ad hoc trains are so variable that the times quoted have little meaning. The official hours for Sellafield signal box to be manned are (Monday to Saturday) from 0600 to 2048. The reply from the ORR, advises that “the times are not published at the crossing due to the possibility of trains running outside normal hours”. Of course that is the basis for some of our concerns! They also say there is a telephone number inside the phone box for users to ring to obtain permission before crossing when there is no reply from the closed circuit line to Sellafield. Our complaint that there was no way of telling whether the signaller had gone off duty, or was just busy elsewhere, was ignored. That there is no phone nearby and mobile signals are often absent seems to be beyond their comprehension. iii) Seek clarification of a rumour that Braystones and Nethertown Stations may be closing All those contacted have denied that either of those stations will be closing, and say they have no knowledge of any plans for closure in the foreseeable future. Any such decision would be made by the Department for Transport. I believe that closure would require a long period of consultation and, eventually an act of parliament. Hopefully, that may be more trouble to them than it is worth. iv) Obtain formal clarification of Network Rail’s position on the flooding issues under the arch

between bungalows “Dalegarth” and “Snaefell” No progress has been made, as Network Rail appear not to consider it a problem. Suggestions that they could do the work on a pro bono basis have come to naught. An engineer’s examination

of the water passing between the blockwork was promised (7/8/14), but nothing further has been heard on that matter. v) Pursue Network Rail to provide lighting at Braystones crossing The reply from Network Rail suggested that lighting might be counter-productive. They assert that it would make it more difficult to see any approaching train. Despite quoting their own safety rules (which say that such illumination can be beneficial and may be installed if warranted) back to them, Network Rail appear to be intent on leaving the crossing non-illuminated.

2/8/12 Head of Level Crossings, Network Rail Dear Sir, Thank you for the letter which was awaiting us on our return to Cumbria after a period of absence. We have noted that there have been several accidents, including fatal accidents, at several level crossings around the country since we first wrote expressing our concerns about Braystones crossing safety. Indeed, we have contacted the Office of the Rail Regulator in respect of some, pointing out that we have kept all correspondence relating to our concerns and will, in the event of an accident at Braystones, press for personal culpability of both Network Rail and O.R.R. staff. It is our view that the crossing is unsafe and will remain thus until such time as a proper signalling system is installed. So far as we can understand the various responses we have received, the only reason for not installing a proper system is on the grounds of cost. We believe this to be very poor, when, according to recent news, “Pre-tax profit for Network Rail rose to £471m in the year to the end of March, from £438m the previous year.” Having read your letter of the 24th ultimo, we appreciate that efforts are being made to change the current management, and thus ultimate culpability insofar as Network Rail are concerned. However, we cannot see that any of it will make the crossing any safer. We have asked in the past for the number of “near misses”, but have been told that no system is in place to record such events. It is our understanding from ad hoc conversations with Network Rail staff that many such incidents are, in fact, reported to the signaller at either Sellafield or St. Bees. Perhaps you would obtain and supply us with the figures? Should not such a system be in place to verify matters? In the past we have noted that the cost argument against removing risk from crossing users would be negated if any incident involving a nuclear flask train were to be involved. Given the current increase in traffic of that type, we can only assume that the risks are continually rising commensurately. In relation to the continuing system at the Braystones crossing, I would point out that there is no method of telling crossing users whether the signaller has gone off duty or not. It used to be the case that the last train in the evening was around 1930 hrs. One could, therefore, assume that if crossing at 2100 hrs. it would be safe to do so without obtaining permission from the signaller. Nowadays the phone just rings out ad nauseum, making it difficult to know whether the signaller has gone home, or is just engaged elsewhere; we have noted some very late Sellafield trains. Perhaps, instead of just adjusting the management of crossings to make one individual liable for any corporate manslaughter charges which may be forthcoming, for I assume that is what is behind the changes you advise us of, you could see you way to installing a simple, automated, “safe/unsafe” signalling system for crossing users. In past correspondence I have pointed out to your organisation the presence of a holiday caravan park and the use of the crossing by children and other holiday-makers who may not be aware of the potential dangers. The typical (albeit silly) response has always been that the crossing is safe as long as it is used correctly. Despite our best efforts we have not yet managed to get any official to accept that not everyone uses the crossing correctly, despite that being the case. As before, we will keep this correspondence for use in any court case to press for personal culpability. Yours sincerely,

29th

March, 2015.

Dear Councillors, Thank you for the email of the 12

th inst. I delayed in acknowledging receipt of the same as I was hopeful of an

immediate explanation for the misleading statements made by Mr. W---. It would appear that this is not going to be forthcoming, which lends support to the possible 'intent to mislead' opinion that cynics might arrive at. I am not quite sure what being ‘on the same side’ is meant to mean. So far as I am concerned, on behalf of the beach residents, we have raised legitimate concerns about the safety aspects of a railway line used to transport nuclear flasks to and from destinations across the U.K. and around the world. Our concerns have not been supported by actions on the part of those charged with taking them. It isn't really about being on a team. Either our concerns are well-founded, supported by evidence and thus should be acted upon, or we are factually wrong. I have, to the best of my ability, supplied the evidence that unnecessary risks apply, and have yet to see any evidence to explain why resident's concerns are incorrect. Recently I have been looking at the report of the Transport Select Committee, 2014, having been directed to it by Mr. A. Hitchins, Senior Committee Assistant. Sadly, the committee could not take my concerns into consideration because of restrictions in their protocols. I am hopeful that nonetheless, word will arrive in the right ears. Be that as it may, in conjunction with documents available on Network Rail's website, it appears that our concerns are legitimate. What is referred to as "incidents" at Braystones crossing have risen from 9 (2012-13) to 11 in 2013-2014. Perhaps it is noteworthy that this is when matters reached a peak for the residents and caused the matters to be discussed at their annual meeting. There are various categories of risk for the crossing, separated into those for vehicles and those for pedestrians and cyclists. I can find no explanation for the figures, but note that the number of vehicular crossings daily is given as 14. We believe that this is very low and, looking at the comments in the Select Committee's report, we see that the assessment is based on a random 30 minute study between 9-30 a.m. and 4-30 p.m., with no consideration being given to seasonal or other factors. These times would also exclude the majority of shift workers and those on school runs. It also ignores the crossings made when there is no signaller on duty at Sellafield. Earlier today I wrote to Network Rail:

Dear Sir, For several years residents from the Braystones Beach community in Cumbria have been asking for improvements to the level crossing there and to the line in general, to no avail. We have noted the report from the House of Commons Select Committee on transport, March, 2014, (http://www.publications.parliament.uk/pa/cm201314/cmselect/cmtran/680/680.pdf) and are concerned about the assessment for Braystones level crossing in Cumbria. It would appear that the number of incidents has risen in the last records, being up to 11 from 9 the preceding year, confirming our opinion that safety there needs to be improved. In paragraph 17, Page 11 of the document, we note that there are significant weaknesses in the computer model used to determine risk. For example, from Network Rail document Level Crossing Data.xls, we see that the number of vehicle crossings per day is given as 14. This seems to be very low in comparison to our experience. However, since the system in place there requires a telephone call to the signaller at Sellafield we feel sure that his log will give a more accurate figure. The same Network Rail document assesses the individual risk for the two crossings (the vehicular and pedestrian traffic are separated, despite using virtually the same route) are given as B & D, whilst the collective risk is set at 4 & 6. Despite having viewed the whole document, I can find no key to indicate what these figures mean. We would be grateful for an explanation of what the risk figures mean in practical terms; for any reports which have been completed in respect of the incidents recorded; and for a copy of the log from the signaller's records at Sellafield from which we can determine for ourselves the number of crossings made

daily during the hours the signal box is manned. Since the Sellafield signal box is only manned part-time, some additional crossings are made out of hours without being recorded, of course. Braystones Beach Residents' Group is to hold its annual meeting in the next few weeks, thus I would appreciate it if the information could be supplied as soon as possible so that they can all be informed then. Yours sincerely,

As I said in the above correspondence, the residents will be holding their meeting very soon. It would appear that my report to them on the progress I have caused to be made in improving the crossing will demonstrate that nothing at all has been achieved, despite my best efforts. I fear that this will not reflect well on yourselves. At our last meeting at Braystones station, it was proposed that a meeting be set up to include yourselves, Network Rail, Sellafield and county council representatives. On the assumption that that meeting took place (I have not been advised either way), I would expect minutes to have been taken, decisions made, actions delegated, etc. Is this not the case? Have not Copeland and Cumbria County Council been officially advised of the situation? Did Mr. W--- get in touch with Network Rail engineers over our concerns about the bridge to the north of the station? What, if he did do as he promised, was the outcome? Did they attend and examine the structure – hopefully after a period of inclement weather? I can only assume not, if there are no documents or records available for us to see the actions taken. I am at a loss to understand how any meaningful action could have been taken without official engagement and thus supported by proper documentation. In the next fortnight or so I intend to compile a résumé of the correspondence that has been entered into and submit it to a variety of national newspapers, Private Eye, and the main broadcasters. I am sure some will appreciate the irony of proposals for HS2 and HS3 lines costing many, many billions, when the basic infrastructure of a main nuclear transport network system relies on 150 year-old technology. Regards,

Dear Cllrs. , Thank you for the information on the progress you have made regarding our concerns regarding the railway crossing at Braystones station, following our meeting last month. In the interim I have received the response from the Office of the Rail Regulator dated the 6th June, 2014, and have responded thereto. The salient points and my response to them are included below: [ORR]

2. Seek formal confirmation of the manning times of Sellafield station signal box and the procedure for crossing the railway outside the those periods when there is no signalman available; The information relating to the opening times of Sellafield signalbox is publicly available on the internet (via the Network Rail website – compendium of signal box opening times) and is currently as follows:

LNW Signal Box*

MON - FRI (24hrs) SAT SUN

OPEN CLOSE OPEN CLOSE OPEN CLOSE

Sellafield SB

06:00 20:48 06:00 20:48 Closed Closed

This is not posted in the phone at the crossing due to the possibility of trains running out of normal hours and it is for this reason that the alternative contact number is provided which should be used if there is no answer from the signalbox. Since the last discussion on the issue of additional protection at Braystones crossing, there have been a number of technological advances which mean that more cost effective solutions will hopefully start to be available in the near future. Network Rail has recently sought funding to install these solutions at a number of crossings in the North West, with Braystones being on that list. We will confirm later whether the funding for improvements at Braystones has been approved and if that is the case the likely date for installation. [My Response] The area in question is very remote and rustic. The idea that people all have internet connections is rather blasé. Some of the buildings have no running water, electricity is a luxury not available to all, and phone lines - where installed - liable to damage, rendering them unserviceable for days on end. Mobile phone signals are non-existent except on rare occasions, even when out of the wireless shadow of the embankment. I am thus very sure that none of the residents would think of seeking information on the internet - even the few who have that expensive luxury. The times you have supplied will be relayed to the other residents, with the rider warning that other services may occur outside that window. I am not at all sure how a crossing user would be able to use the number supplied to check on occasional train movements. As I have already said, the area is notoriously difficult for mobile phones and the old telephone kiosk which used to be near the gates has long been removed. Even if a mobile telephone signal were available, I doubt that such an expensive device would be considered vital equipment for beach users, especially holiday makers making their way over stones, pebbles and sand. Your explanation of why the timetable is not displayed at the crossing merely supports our arguments about safety. The ad hoc train movements are probably the most dangerous. We believe this will

become even more evident should the proposed commencement of a Sunday service be brought to fruition. [ORR]

3. Inform Network Rail of the potential dangers to users crossing at Braystones, as currently, the lights, which are presumed to be on a timer, switch off after the last train at 18:00hrs. This practice leaves the entire area in the dark, making passage over the crossing hazardous;

Network Rail have considered the issue of lighting at the crossing and are of the view that it is not needed for vehicular users as the crossing will be adequately lit by vehicle headlights. With regards to pedestrian users, they believe that the night time usage for pedestrians is very low and that lighting of the crossing is not necessary. I suggest that if you have evidence of night time usage which may enable a case to be built for the installation of lighting that you contact Network Rail’s level crossing manager Jonathan Hume who can be contacted via email via Jonathan.Hume@networkrail.co.uk. The latest (2012/13) published station usage data can be found on our website at: http://orr.gov.uk/__data/assets/excel_doc/0003/10785/Station-Usage-2012-13_Final_xls.xls [My Response] I would respectfully suggest that your response to Item 3, the matter of lighting at the crossing, fails to consider the problems properly. The crossing is not maintained to high standards. Currently the surface for road vehicles and pedestrians is very uneven, creating many trip hazards. There are considerable dips in the surface as heavy plant (for beach maintenance work - including Network Rail sub-contractors, Murphys'), tracked vehicles from Sellafield contractors, builders and delivery drivers of all types, as well as residents' vehicles, use the crossing many times each day. Obviously, while a vehicle's lights will indeed illuminate the path on the approach, once over the line there is no light above ambient level. Equally obviously, the crossing user is required by the regulations to close the gates after passage, and the vehicles' headlights will be either shining out to sea or illuminating the lane - not the crossing - and this is what makes it dangerous. In winter this is unsafe for all users, especially the elderly residents, hence our request. Liability for any injuries caused by the uneven surface exacerbated by lack of maintenance will certainly outweigh the cost of installing s couple of small lights operated via a PIR switch. Compared to the cost of the triple camera installation, this installation and running costs would be miniscule. We are not asking that the area be floodlit. Network Rail are reported having made more than £700 million profit last year. It is difficult to understand why the small amount required to bring Braystones crossing up to modern safety standards is such a low priority. [ORR]

5. Ask for formal clarification of Network Rail’s stance on the flooding issues under the arch between “Snaefell” and “Dalegarth” (the unnumbered bridges 500 metres north of Braystones station).

Network Rail carried out repair work to the culvert in 2009. Network Rail have been reminded about their responsibilities for the inspection and maintenance of the culvert. With regards to the various parties responsibilities for the maintenance of the water flows in the area, it is our understanding that the following applies:

The landowner, who we understand is a Mr Pallings at Middlebank Farm, is responsible for the maintenance of drainage of the land to the east of the railway;

Network Rail are responsible for the maintenance of the culvert running under the railway line; and

The owners of the foreshore, which we presume are the residents of the beachfront properties, are responsible for the discharge of the water from the end of the culvert to the sea.

[My Response] We are grateful for the information, but would point out that the land-owner on the beach side of the line at this point is, in fact, Leconfield Estates (land agents for Lady Egremont), who own the freehold of the shoreline to the north of Braystones station. I will endeavour to obtain some information from them about the discharge of drainage water onto their land. Although not my province, it seems strange that Network Rail can build a culvert that is not properly terminated, merely discharging onto someone else's property, this being the net result of the remedial work carried out in 2009, and subsequently affected by the storms of last winter. Again, however, it seems to be a matter of failure to do the right thing, then trying to justify it by saying the problem is someone else's and it would affect the profits. As with almost all the things we mention, this is low-cost work which should really be carried out, perhaps on a pro bono basis. [ORR] Our local railway inspector Mr Mark Lenderyou is happy to meet with you to discuss the issues falling within ORR’s remit (items 2, 3 and 5). Mark can be contacted via email at mark.lenderyou@orr.gsi.gov.uk [My Response] We have now met with two of your inspectors, one of whom later denied hearing comments made by train crew about the quality of wireless communications in the area, although three residents all heard clearly what was said, despite being further away than the inspector. This removed any confidence we might have had in the integrity of the ORR. The first inspector's visit, in May, 2010, coincided with a dramatic storm which caused the vehicular access ramp from the beach to collapse whilst copious amounts of debris washing off the elevated fields adjacent to the station covered the rail tracks with the consequence that trains could well have been derailed. In previous correspondence I had already pointed out that water was not being drained correctly and that the track-bed was sodden (and had been so for many months), but nothing was done, During the deluge, residents had informed the Sellafield signaller about the blockage, but the message had not been received by the train crew due to the poor quality of radio communications in this area. They had resolved to ask the signaller what his message was on arrival at Sellafield - after they had passed through Braystones! The other inspector, too, seemed not to rate our concerns very highly. Neither of the meetings gave us much faith that our concerns would be addressed. The arguments put forward being more an explanation of why nothing would be done. As users intimately acquainted with the crossing and its difficulties, it does seem strange that we are more concerned about the safety at the crossing than are those whose remit is to ensure the highest standards prevail. In the interim, and as we expected, little has been done to change the nature of the crossing. As usual, in the event of an accident occurring, all the correspondence regarding our endeavours to improve safety will be made available to the courts. In one recent case in Herefordshire, Network Rail were fined nearly half a million pounds for "an entirely preventable death". When considered with the personal culpability of all those who choose not to act on our concerns, we would have thought it much better, and a lower risk strategy, to opt to improve the crossing, but we are not experts - merely concerned users. Unlike the professionals we can demonstrate that at least we have tried. The technology, as you agree, has moved on and is now available. The current crossing does not, therefore, meet the standards which would obviate culpability on personal or corporate levels, in our opinion.

Braystones Station and Crossing Concerns

(Left) Braystones station, crossing and approaches, circa 1950, compared to the current view. The station master was responsible for virtually everything, from station maintenance to ticket issue and control of the crossing. The approach of

trains was also signalled to crossing users by means of a bell affixed to the side of the station building.

The railway line between Barrow and Carlisle was opened in 1850. It has sections of single-track and double-tracked lines and serves passengers as well as the nuclear fuel traffic to and from Sellafield. It is understood that the line only remains open because of its links to Sellafield and the necessity of transporting the dangerous loads around the country, with traffic extending to every nuclear site, including Hinkley, Capenhurst, Dounreay, Dungeness and Hartlepool. The trains usually comprise a minimum of two specially designed nuclear flasks and are hauled by a variety of locomotives, including Class 37s, and Class 21s, all of which are operated by DRS, the rail company set up by the Nuclear Decommissioning Authority, specifically for the purpose. Most passenger traffic is handled by DMUs, usually one- or two-car sets, operated by Northern Rail. The station at Braystones is currently a request halt for four services per day in each direction, except Sundays, when there is no service at all. Alongside the single-platform is a manually-self-operated level crossing. This serves to provide access to the traffic produced by the small beach-dwelling community and for holiday-makers from the nearby Haven caravan site, which overlooks the crossing. As some of the beach bungalows are permanently lived in, the crossing is fairly busy, especially in the spring and summer when visitors swell the numbers. A signalman at Sellafield, working in conjunction with another at St. Bees, controls the entire seven mile single-tracked section by means of the token exchange system which is fundamentally unchanged since the line opened 160 years ago. The crossing is at a point where the rail speed limit is 50 m.p.h. northwards and 60 m.p.h. to the south. There is no automatic indication for crossing users of the presence of trains in the section. Users are instructed by means of a collection of signs, all threatening dire consequences should one fail to adhere to the correct procedures, to use the closed-circuit telephone attached to the crossing fencing. It has not proved to be a very friendly or intuitive system to use; there is no ready way of determining whether there is a train nearby. With the telephone system, there is no indication as to when the signaller is present, busy elsewhere, or he has gone home as trains have finished for the day. Callers are left to their own decisions from around 1930 hrs. each day, as to whether it is safe to cross or not. Sometimes, though, nuclear flask trains or track maintenance trains pass through the station as late as midnight. In many ways, the safety of the crossing is lower now than ever, as there used to be a permanent station master, who was responsible for everything, including opening the crossing gates for vehicles and ensuring they were locked when trains were approaching. Traffic was a lot less frequent in those days, too, as there was no means of getting along the beach for non-specialist vehicles. Visibility to the north, towards St. Bees is quite good, but the topography towards Sellafield is such that entire trains can be hidden from view by a bend, eventually appearing about 200 yards away from the crossing. With a minimum of two, and often three Class 47s at their head and a string of nuclear flask wagons – several hundred tonnes in all, there is absolutely no chance of the train being able to stop in the event of an incident blocking the line, especially from the permitted 60 m.p.h.

It seems the rails are examined quite frequently, but the infra-structure has hardly been changed since its original construction. In 2010, the crossing and its environs were in very poor condition. Residents had noted that the track was awash after rain, and the drainage gullies were ineffective following changes to the road layout. Even the legally-required fencing, of concrete post and wire stringer construction, had succumbed to the corrosive effects of the salt air. This left very sharp points and was very dangerous to young fingers. It was these concerns that led us to write to the various bodies. Several years ago, residents individually expressed their concerns about the parlous state of the line to Network Rail, but nothing was done. As a consequence of Network Rail’s disinterest, the matter was escalated to the Office of the Rail Regulator. After some prodding, an inspector reluctantly agreed to attend to see for himself. The meeting was fixed for the 31

st May, 2010. Three residents were there to meet the

inspector, whose arrival coincided with a truly torrential storm. Material was washed down from the fields behind the station and the nearby holiday caravan site, completely blocking the line where it passed through the crossing. On the seaward side of the crossing, the approach ramp was partially washed away, and the supporting rock and substructure disappeared onto the beach, 20’ below. Even after the rain had cleared, the sides of the damaged ramp kept falling into the hole, disintegrating to within 6’ of the track. The ramp provides the sole means of access for residents and services.

After the deluge. The collapsed approach to the crossing. The railway line is about 2 yards to the right of the picture. The photographer was standing in almost the same place as the bystanders in the old heading picture of the station.

A resident used the supplied telephone to inform the Sellafield signaller of the danger to trains and the signaller said he would stop all traffic. However, a train had already left St. Bees heading south, towards Braystones and was thus beyond control of the signaller. A few minutes later, the train appeared under the bridge at Nethertown. In a good impression of the cast of “The Railway Children”, the residents ran to the end of the platform waving coats, etc. Fortunately the train-driver stopped. When asked by the inspector whether he had not been informed of the blockage, the driver replied that they had received a garbled message over the radio, but had

not been able to make sense of it. They had thus decided to wait till they got to Sellafield, when they could speak directly to the signaller and find out what he wanted to tell them! ‘Radio communication is useless here’, here said. Despite all this being witnessed first-hand by the ORR official, nothing changed. Six months later, correspondence revealed that the inspector had no recollection of the driver’s response – despite it having been heard by all three of the residents, two of whom are a bit deaf! Frustrated, an incident where a small child got onto the railway lines and walked towards Whitehaven, provoked us into querying whether the railway was legally obliged to provide and maintain fencing. (Some light railways are exempt, but speed limits and other operating conditions are imposed to maintain safety.) The question was ignored repeatedly. The ORR eventually informing residents that Network Rail were currently erecting fencing along the whole line, but at that time had only reached Barrow from Carnforth. Braystones would have to wait until 2014 at the earliest. The direct question as to whether Network Rail were obliged to provide it and should have replaced the rotten materials decades earlier was never answered, but at the end of 2012 a team arrived to erect brand new fencing and posts at Braystones. Shortly after, there was a flurry of activity as electronic equipment was installed immediately south of the crossing. Sadly, this turned out to be just a set of three closed-circuit television cameras to monitor the crossing. Nothing was done to improve safety there per se, just a means of prosecuting anyone who decided to use the crossing against the rules. The telephone system remained a pain to use, especially in inclement weather. Under the token-exchange system, once a train has left the issuing station, the signaller has lost its whereabouts and has no idea whereabouts in the section it is. Thus he cannot give permission for a user to cross. When the issuing station is St. Bees, a user might have to wait up to nine minutes for a passenger train, or longer still for a nuclear flask train. That can seem a long time. It can also become a matter of life and death for an emergency vehicle. The concerns we raised included the state of the crossing, the safety aspects of operating it with no indication of approaching trains, and the state of a bridge about 400 yards to the north of the station. Also included in later correspondence was a request that the crossing be illuminated after dark, utilising a proximity detection device to turn off the light once a crossing had been accomplished. We suggested that a simple two-aspect colour light signal would be simple and effective. The cost for such a system was alleged by a Network Rail official to be £147,000. When we suggested that figure was excessive, as the technology was already available and that spare cores in the communications cabling could be utilised for the purpose, we were told that there were no spare cores. Anyone who has worked in the electronics industry will know how unlikely that is to be true. We even sent them a photograph of an example of the kind of installation we were suggesting, as there is a precedent on the outskirts of Cardiff, at Morganstown. No reply was forthcoming.

There is a culvert which was designed to keep the brook’s waters away from the bridge’s foundations, but that has not functioned for many years. The route is to become part of the National Footpaths Programme, so it will become even more difficult to determine who is responsible for the problem: the landowner, Network Rail, or National Footpaths Association.

The bridge about which we have concerns, about 400 yards to the north of the station is one of the original bridges, and is thus about 160 years old. It is of stone block construction with mortar between the blocks. Over the years the mortar has decayed and after a period of rain water pours through the gaps. Obviously this must further erode the structure and the presence of a brook, which drains an adjacent small valley, together with the storm tides, cause further erosion. As the bridge is subjected to the low-frequency vibration of 500 tonne trains, without refurbishment we see the potential for disaster. Network Rail sent a questionnaire to each bungalow asking for personal details so that they could compile a list of “approved users”. Since a lot of the crossing users are summer visitors only, that seemed rather nonsensical. We asked for details of how many “near misses” there had been at the crossing, but were told that the term had a specific meaning within Network Rail and none had been logged. The system must be a real pain for the Sellafield signaller who is obliged to attend to the telephone calls from the crossing as well as his other duties. We remain convinced there must be a better system. The beach community held a meeting in 13

th April, 2013, and it was agreed that pressure to improve the

crossing and its safety should be re-applied. Letters were written to Northern Rail, Network Rail, the Office of the Rail Regulator, Copeland Rail User Group, a Cumbria County Councillor, and the local MP. The only ones to reply with alacrity were Northern Rail and Copeland Rail User Group. Both were very helpful and supportive. Network Rail, the ORR and the MP all opted to ignore the letters, although Network Rail did send an acknowledgement of receipt, but thereafter did nothing further. Following up the correspondence produced nothing from either Network Rail or the ORR, while the MP’s office said that they had not received the letter until more than a week after it had been sent. All letters were posted at a main post box in Carlisle simultaneously. Sadly, the MP’s staff were at a loss as to what they could do and, therefore, had done nothing. Eventually we were told that an official had advised a resident that the crossing would be supplied with power-operated gates and push-button operation. The line is also due to be re-signalled in 2021. In 2014 a group comprised of residents, the local councillor and the county councillor (a husband and wife team) met at Braystones. Present, too, were a Network Rail officer and Cumbria C.C.’s Railway Development Officer. The problems were explained yet the Network Rail officer’s view remained that continued reliance on 160 year-old safety systems were adequate. It was pointed out that just one accident involving a nuclear train, even a small one, would cost far more that installing modern safety equipment and refurbishing the infra-structure that is in such a parlous state; it would also damage the nuclear industry’s claims to be able to safely transport radioactive waste around the country – a practise that is set to increase dramatically in future. Despite that, the only decision was to hold a meeting with Network Rail, Cumbria C.C., and Sellafield management. It is our view that the problems are not Sellafield’s – but it might be an interesting legal question whether they, too, would be culpable now they have been advised of the potential and need for improvement if they continue using the line despite knowing its weaknesses. Earlier supplied documentation from the ORR (Document #256823.03) supported resident’s views that old technology and methods may not meet current legal requirements. Systems are available that would dramatically improve safety, not just at Braystones, but at all the 90 similar sites around Cumbria. Of course, not all of those sites handle nuclear flask trains. We conclude, therefore, that any incident at the crossing could result in prosecutions under criminal law. Health and Safety legislation includes a provision for personal culpability. We believe that any accident could render liable all those individuals we have approached with a request for improvement but have nevertheless determined to do nothing. There have been accidents and derailments on the line in recent times. Probably the most relevant was back in 1977, when a train hauling a load of tankers from Marchon Chemicals, in Whitehaven, to Port Sunlight on the Wirral, caused a metal girder bridge to collapse. Two of the beach bungalows, fortunately and purely by good chance unoccupied at the time, were demolished as the wagons crashed down onto them.

Trains have been derailed and stranded by landslides as unmaintained embankments have become unstable. Further north, the line was left hanging in mid-air by a winter storm.

One of the many landslips along the line. This was taken by a Granada Television film crew.

The journal “The Rail Engineer”, of February, 2014, on page 77, et seq, describes the consequences of the storm of the 3rd January, 2014 – the one that did so much damage to the beach properties. Just north of Workington the tide destroyed a 25 metre wave barrier of rock armour and a 70 metre stretch of 3½ metre concrete sea wall, leaving the line suspended in mid-air. Another recent incident is reported by ITV at:

http://www.itv.com/news/border/2012-08-30/train-derails-after-hitting-landslide/ Along the beach at Braystones, residents provide substantial protection to Network Rail’s property by dint of their own self-preserving efforts. In recent decades, a track has been established along the beach to serve the residents and to provide access to the requisite service vehicles. To protect this track and the individual properties, the residents pay to maintain it and rudimentary tide barriers. By protecting their properties, the residents are also protecting the lower embankment, which, as can be seen from the above photograph, would otherwise be even more vulnerable. On 16th August, 2013, a derailment of a nuclear flask train occurred near Barrow-in-Furness. So much for the prevalent, “it can’t happen” attitude. We accept that there was no risk of widespread contamination as the derailment happened at 5 m.p.h. The question is whether a nuclear flask train, which we have noted have increased in both frequency and load, becoming derailed at the line’s 50 m.p.h. speed limit, would survive intact. Even if it were to do so, the security and clean-up operations would cost far, far more than doing the right thing now. We understand that the wagons used to transport the waste are likely to be radioactive regardless of the integrity of its load, due to poor handling procedure or carelessness by Sellafield staff. Of course, the above is not a definitive list of the accidents and incidents along the line used by nuclear trains. We are aware of several others which have been the subject of official investigations and whose details can be found by searching the archives of Network Rail and the Rail Regulators.

This was the fourth landslip in less than two years – approximately 250 yards north of Braystones station, and immediately

behind a permanently-occupied bungalow. In previous slips, at Nethertown, 1½ miles to the north of Braystones, a southbound DMU became derailed. A train sent from Sellafield to rescue the passengers itself became stranded when a

further landslip occurred behind it.

The aftermath of the 1977 Marchon Chemicals spill. Underneath the debris are two bungalows. The site is less than ½mile to the south of the station.

Summary Residents’ concerns include:

1) The antiquity of the signalling and train-control system. This is 160 years old and does not comply with modern safety standards. It puts crossing users at risk and would be difficult to justify in the event of an accident, especially when seen in the light of modern technological advances. These advances include radar detection of the presence of people, vehicles, and other obstructions. Such a modern system would automatically inform all parties – users, signallers, and train staff – of the status of the crossing, and is available now.

2) Failure to provide lighting at the crossing after the passage of the last scheduled train. Such a system would be automatic, cheap, and in compliance with ORR safety literature.

3) The stability of the banking on the landward side of the track.

4) The integrity of the bridge to the north of Braystones. Not just from the stream that washes its foundations, but the amount of water that seeps through the block-work.

5) The physical requirements of the operation of the crossing gates and the unreliability of the telephone communications system.

6) The state of the ballast due to poor drainage at Braystones station.

7) Failure to achieve any material safety changes at the crossing, despite several years of lobbying by Braystones Beach residents, individually and collectively.

8) A survey needs to be conducted to assess whether the angles of the embankments is suitable for the level of stability required of them.

9) Assessments need to be conducted to assess the impact of the corrosive salt atmosphere on an infra-structure now over 150 years old and which has received scant attention in that time.

10) Network Rail should undertake a more positive rôle when it comes to protecting its assets and ensuring the safety of residents and crossing users.

Conclusion

Greenpeace have published an appraisal of the consequences of an incident in a document which can be found at http://www.greenpeace.org.uk/MultimediaFiles/Live/FullReport/7848.pdf. In its conclusion the writer writes:

“Movement of nuclear materials is inherently risky both in terms of severe accident and terrorist attack. Not all accident scenarios and accident severities can be foreseen; it is only possible to maintain a limited security cordon around the flask and its consignment; the transportation route will invariably pass through or nearby centres of population; terrorists are able to seek out and exploit vulnerabilities in the transport arrangements and localities on the route; and emergency planning is difficult to maintain over the entire route.”

INDEPENDENT NUCLEAR EXPERT, JOHN LARGE, 2006

Given the very high percentage of the nuclear traffic that has Sellafield at its hub, it is, perhaps, reckless of the rail providers not to have ensured the safest of all possible systems are in place. The attitude of the ORR is beyond our comprehension. Certainly, literature website relating to the matters we refer to, is available on the ORR’s and supports our assertion that improvements could, and should, be made in order to bring an antiquated system up-to-date, in order to improve safety and efficiency of use. On a more personal basis, we quite like our lives - and our beach bungalows, and don’t want to see them squashed under any train, nuclear or otherwise. Just one accident is all it will take, yet no-one seems able to achieve anything meaningful.