1 Much importance is emphasised by NRW in what is required under legislation of
dumping at sea in this process of determining the suitability of dredged sediments
from the Hinkley C project intake and outfall infrastructure being constructed off the
Somerset coastline.
2 This , however, is not my concern . I am very familiar with discharge of radionuclides into the marine environment due to my involvement in the Sizewell B Public
Inquiry in 1983-4 , and specifically with the role and responsibilities of the
Department of Environment , Ministry of Agriculture Fisheries and Food , and BNFL
Sellafield in the licensing of those discharges .
3 To get straight to the point , it is the effect of the dredging operation upstream from
the Hinkley Point area that concerns me , which is not in fact a marine or coastal
area , but is , in fact, within the bounds of the river mouth itself and beyond .
4 Firstly , I would argue that a comparison of the emitted radiation from manmade
and discharged sources to those found naturally occuring has no bearing on licensing
at all , but that radiological protection standards are set for each radio-isotope on the
basis of specific properties of each radio-isotope and the environmental and
biological hazzards that each isotope may display . As was explained by the RPII in
their Marine Survey Reports to BNFL Sellafield , when the same sort of distorted
picture was presented in order to minimize the concern about levels of discharges of
radio-activity into the Irish Sea , K-40 , for example , has been in our bones for the
considerable period of evolution we have existed and we are used to it , whereas the
concentration of various new radioactive substances through environmental and
biological processes into specific places in our bodies , and that of the flora and fauna
, shows different parameters when considering radiological protection .
5 Secondly , historic discharges from the four nuclear power stations on the Severn
and it’s estuary , did not , unlike the discharges from purely coastal power stations ,
dilute and disperse to sea only , but also concentrated upstream in the area of the tidal
reaches of the River Severn . These discharges were governed by licensing under the
auspices of ICRP 26 , a legislative regime wholly inadequate to afford protection in
the light of advances in the understanding of environmental and biological effects
affecting the ultimate fate and hazzard exhibited by those discharges .
6 Moreover , it was seen that , unfortunately , the MAFF data supplied through the
coastal monitoring of radioactivity reports of that era could not be relied upon to give
an accurate picture of what was accumulating in the environment . The MAFF
preferred to ‘sidestep’ by slight of hand , any perusal of the evidence concerning
monitoring of the marine environment at the Sizewell B inquiry , an inquiry set up to
be the only opportunity to ever question the entire nuclear industry on the effects of
INNACURATE IN SEVERAL CASES . It is time the record was set straight .
7 I have it on good authority (as reputable as that of those receiving this
consultation) that there was a cover-up of the effects of radio-active discharges
upstream from the four operating gas-cooled reactors , as regards the quantities of
radio-activity in the sediments , and it’s pathways through the environment , resulting
in real health detriment to the local human population . This scenario would also
entail detriment to some of the other species populating the lower tidal reaches of the
Severn River .
8 I find it doubtful that the normal discharge to sea operations from the actual
reactors could do more than just contribute to this situation , and that we are possibly
looking at a high level of beta-gamma emitters from the cooling ponds of the magnox
programme reactors . That is , of course , unless irresponsible activities allowed a
level of discharge from possibly the experimental Berkeley site when far too little
was as yet known about the effects of the pollution . I do not discount the idea that
any of these sites may have been responsible for extreme pollution events taking
place at some time during their lifetime before the radiological protection regimes
downsized discharge activity . Indeed , there are several other potential sources of
radioactivity on the Severn Estuary and Bristol Channel that may have been
responsible for high levels of pollution during the 1950’s through to the 1970’s . We
may never know the sources of what may lie hidden in the mud !
9 Far from suggesting that the mud to be dredged from off the Hinkley project is
contaminated to a great extent – only those testing it could ascertain that – I want to
remind the NRW that what contribution to other radioactivity already bound up in
sediments in the Severn River and Estuary is being made by even the small amounts
of man-made radioactivity in the dredged mud , should be of paramount concern in
the sampling process undertaken by the NRW , before licensing can take place . If the
NRW are to exercise it’s duty to protect the flora and fauna of the lower Severn
region , then sampling must also take place of the sediments between the Berkeley
site and several miles above the Oldbury site on both sides of the river . By
extrapolation backwards , the extent of historical pollution could be ascertained and
the correct licensing evaluation take place for any future radio-activity related
operation in the Severn and it’s reaches .
10 Of particular interest , in addition to the target radionuclides to be sampled , I
would like to see testing for Ruthenium 106 and Barium 140 take place . There are
other radionuclides of great interest when it comes to seaborne radioactive pollution ,
but I am sure that the NRW are aware of these and I do not need to innumerate them .
11 If the NRW see fit to avoid it’s duties in respect of what has been said above , I do
not see a difficulty in someone else taking a few core samples of sediment in the
areas of concern I have mentioned and there are places where they can be taken for
analysis , but hopefully the public body responsible is up to the task .
With Regards
Wayne Jones