Letter to First Minister of Wales Rt. Hon. Mark Drakeford

c/o LLRC, Times Bldg. South Cresc.
Llandrindod Wells Powys LD1 5DH

First Minister of Wales
Rt. Hon. Mark Drakeford
Welsh Government
5th Floor
Tŷ Hywel
Cardiff Bay
CF99 1NA
27 May 2020

Dear First Minister,
We, the undersigned, write as representatives of the thousands of members of our organisations
who are also ordinary members of the public concerned about the state of the environment and
about securing a healthy future and a sustainable future for their families and children.
We wish to remind you of your obligations to uphold those aspirations as embodied in the Wellbeing of Future Generation (Wales) Act 2015 and, moreover, to abide by the law, in this case the
Environment (Wales) Act 2016 which requires you to take uncertainties into consideration when
assessing environmental impact. We consider that you and the Senedd Cymru are in danger of
failing those responsibilities in determining the application by Electricité de France to dredge a
further 600,000 tonnes of mud from Severn Estuary sediment adjacent to the Hinkley nuclear site
and dump it on Cardiff Grounds. This letter seeks your reassurance that you will take only actions
which demonstrate that the Senedd recognises its responsibilities and that you will observe them in
respect of the mud dump application process.
There are several compelling reasons why we oppose the granting of a licence to facilitate the
proposed dump:

  1. Past activities at the Hinkley nuclear site have almost certainly resulted in the dispersal of
    plutonium and other radioactive substances on land and in the Severn Estuary in the area
    adjacent to the plant. These carcinogenic materials are highly likely to be present in the
    mud EdF wants to dump on the north side of the estuary, close to Cardiff with a population
    of 350,000 people.
  2. Well-documented literature indicates that, as happens at Sellafield in Cumbria, radioactive
    particles from nuclear facilities are re-suspended by the action of currents, the sun and the
    wind as well as by wave action in areas of ‘white water’. Particles which can be re-mobilised
    by even gentle breezes are known to travel long distances inland. Once re-suspended, tiny
    particles of uranium and plutonium can easily be ingested or inhaled adding to the risk of
    cancer, leukaemia and congenital malformation at far higher rates than government advisers
    and the nuclear industry admit. An accessible account of the science is in a report “Radiation
    and reason: The impact of science on a culture of confusion” at
    http://www.llrc.org/children.htm. At the very least, it identifies substantial uncertainties
    over the official and industry view of radiation risk.
  3. The action of dredging and relocating the material will cause the disturbance of potentially
    contaminated silt over a wide area. This could lead to the re-suspension of carcinogenic
    material over the long term in silt which is not associated with the dump itself. The long term consequences of the dredging operation are therefore unknown but are potentially harmful to health.
  4. Disposal of material which has not been adequately assessed for content of plutonium and
    other alpha-emitting materials is highly irresponsible and represents a potential health risk for thousands of people in Cardiff and beyond.
    We therefore respectfully ask you to confirm that you will:
    • Ensure that the sampling programme is expanded so that more core samples are taken from the Hinkley site itself, on the shoreline, in the estuary, and in all the locations identified in the RIFE reports for 2016, 2017 and 2018 where Americium 241 levels have increased as a result of dredging associated with Hinkley Point C; and that you will ensure that they are analysed using techniques capable of revealing the presence or confirming the absence of particles and that the results of those analyses are published as soon as possible;
    • Comply with the requirements of the Environment (Wales) Act 2016 and acknowledge that the uncertainties in the science of health impact from internal alpha radiation means that new evidence such as that contained in the Children with Cancer UK-sponsored report referred to above is taken into full account;
    • Appoint an Expert Group which reflects the requirements of the Explanatory Note on
    Section 4 of the Act, paragraphs (c), (d) and (e), which state the need for “working with
    appropriate sectors of society, with decisions being made in consideration of the evidence
    and information gathered from relevant stakeholders and different sectors of society,
    including … the public.”
    We gather that Natural Resources Wales has received 151 responses to their Consultation, NRW SP1914, on this matter. It is vital that all of these are reviewed and responded to by the independent Expert Group. This will require the appointment to the Expert Group of people with a broad knowledge of the debatable issues surrounding the adverse health impacts, including cancer, which can result from exposure to ionising radiation in the environment. It is particularly important to consider internal emitters that have been inhaled or ingested. We request and recommend that at least four people from our list below are appointed.
    People recommended for inclusion in the Expert Group.
    Tim Deere-Jones timdj@talktalk.net
    Hons Graduate of Cardiff University Department of Maritime Studies: Field research in Bristol
    Channel and Severn Estuary: research dissertation on “Sea to Land Transfer of Marine Pollutants. 34 years’ work experience as freelance Marine Pollution Researcher and Consultant.
    Emeritus Professor Keith Barnham k.barnham@imperial.ac.uk
    Physicist at Imperial College London and a leading researcher and developer of silicon solar cells.
    Author of “The Burning Answer: a User’s Guide to the Solar Revolution” (2014).
    Dr. Chris Busby christo@greenaudit.org
    Member DoH and DEFRA Committee Examining Radiation Risk from Internal Emitters 2001-2004;
    MoD Depleted Uranium Oversight Board 2002-2007; Scientific Secretary: European Committee on Radiation Risk
    Richard Bramhall lowradcampaign@gmail.com
    Secretary of Low Level Radiation Campaign since 1996, member of Committee Examining Radiation
    Risks of Internal Emitters 2001- 2014.
    Denis Henshaw D.L.Henshaw@bristol.ac.uk
    Emeritus Professor of Human Radiation Effects, University of Bristol.
    Dr. Jill Sutcliffe jillsutcliffe1@gmail.com
    Environmental scientist specialising in radioactivity in the environment; co-led work on radioactivity and wildlife for English Nature (now Natural England)
    We respectfully ask you to reply to this letter at your earliest convenience.
    Sean Morris, UK & Ireland Nuclear Free Local Authorities and Mayors for Peace Chapter Secretary /
    Principal Policy Officer
    Dr Jill Sutcliffe, Jill Sutcliffe, Low Level Radiation and Health Conference
    Pete Roche, Editor No2Nuclear and former member of Committee Examining Radiation Risks of
    Internal Emitters (CERRIE)
    Linda Pentz Gunter, international specialist, Beyond Nuclear
    Sue Aubrey, Chair Stop Hinkley
    Richard Bramhall, Low Level Radiation Campaign
    Alasdair Philips, Director of Powerwatch (also a Trustee for Children with Cancer UK)
    Pete Wilkinson, Chairman, Together Against Sizewell C (TASC)
    Dr George M Reeves, Partner, Nuclear Waste Advisory Associates
    Mag Richards, Secretary, Welsh Anti-Nuclear Alliance
    Jo Brown, Parents Concerned About Hinkley and Delegate at NGO/BEIS Forums
    Professor Andrew Blowers OBE, Chair, Blackwater Against New Nuclear Group
    Jonathon Porritt, Author and campaigner
    Rita Holmes, Ayrshire Radiation Monitoring Group
    Janine Allis-Smith, Health Campaigner, Cumbrians Opposed to a Radioactive Environment
    Ian Ralls, Co-ordinator, Friends of the Earth Nuclear Network
    Dr Paul Dorfman, UCL Energy Institute, University College London, Founder/Chair, Nuclear
    Consulting Group (NCG)
    Dr Ian Fairlie, Independent consultant and Vice President CND
    Dylan Morgan, Co-ordinator, Pobl Atal Wylfa B/People Against Wylfa B
    Neil Crumpton, People Against Wylfa B
    Emeritus Professor Brian Wynne, Lancaster University, member 1994-2000, European Environment
    Agency Management Board and Scientific Committee
    David Thorpe, Founder/Director, The One Planet Centre, Carmarthenshire
    Doug Parr, Policy Director, Greenpeace UK
    Dr Alan Terry, member of Nuclear Consulting Group, Abergavenny
    Dr David Lowry, Member, Chief Nuclear Inspector’s Independent advisory panel; senior international
    research fellow, Institute for Resource and Security Studies, Cambridge, Massachusetts, USA.
    Professor Andy Stirling FAcSS, Science Policy Research Unit, University of Sussex
    Dr David Toke, Reader in Energy Politics, Department of Politics and International Relations,
    University of Aberdeen
    Councillor Ernie Galsworthy, NFLA Welsh Forum Chair
    Councillor David Blackburn, NFLA English Forum and UK Steering Committee Chair
    Steve Thomas, Emeritus Professor of Energy Policy, Public Services International Research Unit
    (PSIRU), Business School, University of Greenwich
    Dr Ruth Balogh, Co-ordinator, West Cumbria & North Lakes Friends of the Earth
    Tim Deere-Jones, Marine Radioactivity Research & Consultancy: Wales
    Alison Downes, Executive Director, Stop Sizewell C
    Emeritus Professor Keith Barnham, Distinguished Research Fellow, Imperial College London