KINGS CLIFFE WASTE WATCHERS

a. The grant of an authorisation before the NDA has finished its consultation on the disposal of LLW would prejudice any conclusions it might make. The NDA might decide to build a national LLW site, and if LLW had already gone into King's Cliffe, locals would have to suffer the consequences needlessly for over 60 years.

b. The proposal is evidence of a practical ‘bottom up dynamic’ by which decisions on the disposal of this nationally significant material are impelled from below, when what is needed is an overall, strategic plan, decided by Government, which suggests the optimum locations for LLW disposal.

c. Augean have failed to supply evidence to show that low dose levels are not harmful to health. It has maintained that dose levels are safe, but this ignores that there are already high levels from radon, and that each person has their own tipping point for contracting cancer or leukaemia.

d. The risk assessment works from the assumption that dose levels are safe, and that therefore lack of risk can be proved by calculating dose levels, rather than by measures to reduce emissions. Augean do not offer ways to reduce emissions or deal with accidents like an air crash from an RAF plane from Wittering, other than by measuring the dose level.

e. The methodology used to calculate risk is untested, and its application has been prejudiced by insufficient inputted data fields. The methodology was also commissioned by the Environment Agency and the HPA, who are advising Augean on the application.

f. The proposal fails to show that the site is the most suitable, either by BPEO (Best Practicable Environmental Option), BPM (Best Practicable Means), or BAT (Best Available Techniques). WW have shown that neither its location, nor its construction, indicate its suitability.

g. Augean’s use of the principle of optimisation, in its attempts to justify not taking extra measures to ensure protection of public health, is inapplicable to a private company. Optimisation is the theory by which risk need only be reduced to the level at which further reductions are not justified by cost. In other words, public safety is subject to Augean’s profits.

h. Augean reject established principles and procedures, such as proximity (the need to bury waste as close as possible to its source), and classifying the site as a nuclear installation (which an EU council directive says it technically will be).

i. Augean have not drawn attention to any security measures at the site, nor indicated the need for such security. It is simple to stray onto the site, either accidentally or on purpose, and such intrusion could lead to the escape of radioactivity.

j. The monitoring, especially where it relates to the health of the local population, is inadequate, and fails to give confidence to the community. No monitoring will take place outside the site, and the health of the general public will not be checked.

k. The extent of the consultation exercise has been woefully inadequate and has not met standards required by Government policy. One public meeting was held in King’s Cliffe right at the start of the process. There is no evidence Augean took any notice of what was said to them.

l. Augean’s safety record is poor, and becoming worse. The number of near misses, and minor and major accidents, on the King’s Cliffe site rose significantly last year. Its financial instability is a threat to its ability to fulfil its obligations under the authorisation.

m. The size of the local community has been underestimated, and its fears over the dump have been neither considered, nor allayed, by Augean. Around 250,000 people live within 12 miles of the dump, and this figure is rising all the time.

These are technical objections based on the wording of the application. For more objections based on the effects of this proposal on us, click here