EDF halted its transfer of mud from the Hinkley site to Cardiff Grounds on Friday 12th October. This followed the WAG debate on Thursday 10th October when Welsh Labour defeated the anti-dumping motion by 26:22 votes which had asked for a suspension of EdF’s permit to dump, and had asked for more testing of the mud. However, marine notices were then cancelled on Friday October 12th and NNB Genco’s dredgers returned to Belgium, though a survey ship working for EdF has subsequently been reported in the sea off Hinkley Point.

The debate at the Welsh Assembly was predicated by the decision in the High Court that an Environmental Impact Assessment (EIA) had not been carried out by NRW on the effects of the dumping. It was an opportunity for WAG to review its original decision to grant a licence to EdF, made without following proper process as governed by The Marine EIA Regulations (2007). This had required the WG’s Marine Consent to direct the applicant to request a screening opinion on the application to dump at sea, and this EIA screening decision, as a formal document, was required by law to be published. None of this was done at the time of the original application.

In 2013, NRW took over marine licensing and stricter OSPAR rules came into force. But NRW did not review the decision or the lack of an EIA, but instead re-issued the licence for EdF to dump in 2014. Rather than admitting that the lack of an EIA was problematic, Lesley Griffiths stated in debate that the original WG decision to grant the licence was legal and also suggested that the permissions granted by the Countryside Commission in England to allow preparation for the building of Hinkley C would also cover the dumping of mud to Cardiff Grounds.

Unfortunately these statements were not debated in the chamber and are not being referred for scrutiny as they would be at the Westminster parliament. It has been established that WAG did not follow proper process and properly examine the issue from the Welsh perspective in 2012, and will not recall its decision now that legislation is stricter and the reality of the potential damage caused by the dumping of mud from Hinkley has come home to Wales.

NNB Genco announced that the dumping had been halted because the process had been completed, though they had in fact just hit the underlying sediments and had expected 40% of tonnage to be clay. Dumping was stopped when their equipment found the sticky, estuary clays difficult to handle and hard to deposit from the barges at Cardiff Grounds. The dumping barge was observed with an open hull, outside the dump-zone, trying to wash out the clays. However, the dumping of solid clays into seas or estuaries is forbidden under international OSPAR rules. Dumping silt is only permitted when clays contained within the dredged material are separated and managed on land. The current licence is still valid until March 2019 and pressure is needed to ensure that dumping is not resumed. EdF plan to make another application to dump dredged material when a further stage of the proposed Hinkley C build commences. This is to install header equipment to the giant 7-metre wide, 3km long pipes carrying cooling water to the new nuclear plant. This excavation will include sediments that will have drifted into the hole already dredged, during this winter’s (2018/19) storms. We call on WG to insist that NRW must receive a new application from EdF, which includes full information on the dump-site and on the impacts to Severn Estuary wildlife.

The three reasons to oppose further dumping are:-

* Jurisdiction – The 2018 license effectively copied the unlawful 2014 one, without review. Now that the lack of an EIA has been exposed we expect WG and their NRW arm to carry out their responsibilities under the law. Elected members need to understand how they are failing the Welsh electorate by not calling the minister responsible, Lesley Griffiths, account over this. We expect the WA to protect the interests of Wales rather than carrying out Westminster’s wishes to make an unwanted and imposed nuclear rebuild program run more smoothly.

* Effects on Welsh beaches and coastal environments. Clearly WAG has done the absolute minimum to provide protection from the potential damage that Hinkley mud may now be causing and has failed to require a survey of its physical, chemical and radiological effects. In 2018 the people of Wales demand that an EIA is carried out before more dumping is allowed, and that OSPAR guidelines, which aim to protect waterfowl, are fully complied with. Additionally, the evidence now disclosed on leakage from Hinkley A (Magnox plant) and possibly from Hinkley B (AGR), after reactor nuclides were detected in the sediments tested, requires full investigation. Where did leakage from the spent-fuel cooling ponds get to and are there areas of high nuclear pollution that need isolation and clean-up, in the sediments or on land? Additionally, the presence of other nuclear power stations in the Severn estuary, both decommissioned and planned will also have an impact on the health of the people of South Wales and on their surroundings, so we call for the proper testing of the present distribution of radio-activity in the marine and coastal environment of the South Wales. A survey of the current state of our beaches, our coastal areas and the Severn estuarine environment urgently needs to be established.

* What levels of man-made radioactive pollution should be permitted in the Severn estuary and on the Welsh coast, and in the wider environment? Post-war models assess damage from ionising radiation as a dose spread over the whole body area, and this is how the I.A.E.A. decides on a safe level of exposure. A different risk level is derived when instead we look at internal emitters, lodged within organs of the body. Single alpha-emitting ‘hot’ particles, inhaled or ingested, generate cancers in soft body tissue. Bio-accumulation in the food-chain as for the beta-emitter technetium-99 also has to be considered – recall the Sellafield lobster scandal. Also, the beta-emitter tritium tends to be enhanced in DNA, which is especially vulnerable to beta-damage. The UK is obliged under the original OSPAR treaty to reduce radioactivity in the marine environment to near zero (for artificials) or historic levels (for natural nuclides) by the year 2020. We want a Joint Fact Finding Group under the WG to look at the current situation and at assessment methodologies. Mark Drakeford has indicated that he will take this up if he is chosen as First \Minister to succeed Carwyn Jones. WANA is supporting the formation of a Joint Fact Finding Group in forwarding progress on the issue of what are acceptable levels of exposures to man-made radioactivity, in order to minimise harm to people and to all living things in areas subject to elevated levels of these long lasting and irretrievable pollutants.