In early December last year NuGen submitted its application to the Marine Management Organisation (MMO) for a licence to undertake offshore geotechnical investigations within West Cumbria’s inshore waters. The application is in support of its plans to build three AP1000 reactors at Moorside. The focus of the investigation will be the location for the sub-seabed tunnels required for the reactors’ cooling water intake and outlet systems.
The £20m contract for the work, which also includes onshore site investigations, was awarded last year to Dutch company Fugro. The company, with a major involvement in oil and gas extraction (including fracking) and relatively little experience in the nuclear field – which its classifies as a sustainable energy – describes itself as providing geotechnical, survey, subsea and geosciences services.
The offshore work is scheduled to start on 29th February 2016 and will involve the drilling of some 40 boreholes each between 34 metres to 92 metres in depth, with an expected average depth of 70 metres. With a 7-inch casing, these boreholes will be sunk within NuGen’s Marine Infrastructure Area with the use of a Skate3 ‘jack-up’ drilling platform operated by Fugro Seacore. With its investigation area extending out to 4.6km from the mean low water mark, the platform can operate in depths of up to 30 metres. The work is expected to be completed on 1st July 2016 (unless delayed by adverse weather) – a date likely to make the investigation’s findings unavailable for inclusion in NuGen’s Stage 2 ‘Proposed Scheme’ public consultation scheduled for May 2016.
Whilst the Fugro documents that accompany NuGen’s application to MMO relate largely to the towing, siting, crewing and operation of the drilling platform and the taking of core samples from the boreholes, a NuGen report ‘Ecology and Ornithology Assessment’ (N0008739) is also provided. Confirming that the physical disturbance to seabirds from the presence of the drilling platform and service boats can result in ‘loss of energy; impaired breeding; unrest through increased vigilance; disruption to incubation; and increased nest failures due to predation and nest abandonment’, NuGen intends to take no mitigating measures to protect the sea birds – despite its offshore drilling work clearly coinciding with the nesting/breeding season. Neither does it intend to take any mitigating measures for the likely disturbance to migratory fish.
This ‘take pot luck’ approach proposed by NuGen for marine wildlife extends also to the consequences of the disturbance to the West Cumbrian coast’s radioactive sediments through the placement of the drilling platform in numerous positions within the investigation area and through the collection of core samples via the 40 boreholes. Disturbance to these sediments which contain plutonium, americium and a cocktail of other radioactive elements leads not only to their spread in local waters but also to their being driven ashore where particles can be re-suspended and blown inland. NuGen however believes that the amount of radioactive sediment that will be disturbed by the borehole drilling and core extraction will be ‘small’ and no bigger than ‘storm background levels’ and therefore proposes to take no mitigation measures. Such a proposal is likely to be treated with a similar level of scepticism to that given to the pronouncement made many decades ago by the then Windscale site that its radioactive discharges to the Irish Sea would safely disperse into the wider oceans.
Only posted on MMO’s website on 16th January 2016, the NuGen application can be found under Marine Licence Application MLA/2015/00475 and representations or objections should be submitted to MMO within 28 days of that date.