“North Wales Deserves Better – A response”

Re. Written Statement – Up-date on the Nuclear Sector in Wales – Ken Skates 23/10/2020

It is difficult to comprehend why the Welsh Government is clinging to the hopes that a nuclear revival will solve regeneration issues in North Wales. There is now clear evidence that nuclear power is : yesterday’s technology, costs the earth, leaves a legacy of highly radioactive waste and is no answer to climate change … It is too little too late.

1. Wylfa Newydd – The Written Statement claims Wylfa Newydd could significantly contribute towards the 2050 zero CO2 emissions target. BUT

· Climate change is now and is the most important issue facing us today. We need to invest in low carbon renewable technologies NOW – we cannot afford to wait

· The latest research claims we have less than 12 years to act on climate change before it becomes seriously problematic. Currently Wales generates no energy from nuclear and the most optimistic scenario for new nuclear generation at Wylfa Newydd is now looking like 2030 at the earliest.

· If Wylfa Newydd goes ahead it will create a massive extra legacy of radioactive waste that future generations will have to manage long after the stations have been shut-down .

· Wylfa Newydd is a costly distraction that is neither low carbon, renewable or needed and requires enormous government subsidies. The estimated cost of the new build when Hitachi was around was running between 15 and 20billion.

The Zero Carbon Britain Project demonstrates how we can rapidly reduce UK Greenhouse gas emissions to zero by 2030 using only currently available technology. It outlines how we can provide a reliable energy supply with 100% renewable energy sources and flexible carbon neutral back up – without fossil fuels, nuclear power, or gambling on future technology. In addition it can deliver a modern lifestyle, create employment, improve our wellbeing, and ensure a safe and sustainable future for future generations http://www.zerocarbonbritain.org

2. Trawsfynydd a new development company called Cwmni Egino – The Written Statement claims this will help exploit the huge economic benefits of small modular reactors (SMR’s) and associated technologies. BUT

· It’s the same old technology. The basic idea dates back to the 1940s, when the US. Air Force, Army, and Navy each initiated R&D on various types of small reactors. They still have the same problems facing large reactors eg soaring costs, safety, and radioactive waste.

· Are SMR’s safer and more secure than conventional nuclear power stations? –Well that depends on how many modules are built on the same site with the added complications and costs of a variety of new forms of nuclear waste on a number of different sites.

· The SMR ‘dream’ is to gain sufficient orders to set up production lines which then create their own problems; such as inspecting production lines, health and safety, procedures for recalls etc .But to date, worldwide there are insufficient orders to proceed with a factory.

· Cheaper does not necessarily mean cost-effective – In Dec 2017 The Atkins Consultancy report for BEIS found that power from SMRs would cost nearly one-third more than conventional nuclear stations because of reduced economies of scale and the costs of deploying first-of-a-kind technology

· It’s the last ditch stand of a dying industry. You need more SMR’s to produce the same amount of energy so that raises issues of safety, quality, licencing and security

· Efficiency and most renewable technologies are already cheaper than new large reactors. The time it will take to certify SMRs will do little or nothing to help with the global warming problem and will actually complicate current efforts underway.

3. Existing expertise and skills in North Wales,

Skills and expertise in the nuclear field exist and there is plenty of scope for them to be fully utilised in the major challenges faced with decommissioning on both the Trawsfynydd and Wylfa nuclear sites. In addition there is the continuing problem of radioactive legacy waste and the long-term management problems that exist for future generations.

Wales provides substantial opportunities to ‘ lead the way ‘ in developing existing, emerging and new renewable energy projects based on truly sustainable principles .

The Institute of Welsh Affairs Report “ The Economic Costs and Benefits of Renewable En-ergy Transition in Wales “ shows that the development of an energy system that can enable Wales to become 100% self-sufficient in renewable electricity by 2035, requires around £25bn of investment in renewable electricity generation, and £5bn in domestic energy effi-ciency interventions. This analysis also shows that some 40% of renewable electricity spending could potentially be captured by Wales, along with 70% of domestic energy effi-ciency spending. In addition these investments could support some 20,150 jobs annually across Wales during the investment period . AND there is no need for nuclear power https://www.iwa.wales/click/2018/11/the-time-is-now-tick-tock-its-ticking-away/

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


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

Mud Leaflet Feb 2020

Natural Resources Wales (NRW)

Hinkley Point C sediment sampling plan consultation SP1914

Deadline for comments March 18th 2020

All comments to marinelicensing@naturalresourceswales.gov.uk

Quote ref no SP1914

Marine Licensing Team / NRW Permitting Services.

Cambria House. 29, Newport Road. Cardiff CF 24 0TP

EdF Energy have applied to NRW for a licence to dump 760,000 more tonnes of mud with radioactive contaminants from Hinkley into the Severn Estuary at Cardiff Grounds (6 times more than last time) less than 2km off the Welsh coastline.

BUT what is in it for Wales ? ……EdF are a French Company dumping sediment containing radioactive particles from England in Welsh waters which will reach our beaches, mudflats and river estuaries

Radioactive Mud Dumping in Cardiff Bay – Why you must object to the license to dump more.

1. “ Out of sight – out of mind”

The Cardiff Grounds site in the Severn Estuary was designated for dredgings from harbour channels only. It was never licensed to take mud from a massive construc-tion site, nor for the heavy clay which EdF intend to dig out towards the building of Hinkley C. Their closest dump site is alongside on land, with their other construction waste. EdF’s real motive for dumping in the estuary is the mud contains radioactive particles that if stored on land, would have to be isolated from the environment.

2. Sampling for radioactivity last time failed to meet basic standards.

Most samples taken before the mud was dumped last time in 2018 were just recent deposits scooped off the seabed (1-3cm). The few borehole samples showed mixed results, indicating patchy radioactive deposits. There is little evidence that their new tests will be done thoroughly enough to safeguard the health of coastal populations; independent academics tell us that the tests are inadequate.

Clearly there is a need for an Independent Expert Committee to advise the Welsh Government on such an important issue. NRW have clearly stated they do not have the expertise, this is a very important decision that could have major consequences for the wellbeing of future generations.

3. Do not disturb

Radioactive particles from the Hinkley Point A and B nuclear power stations have been disturbed by the previous dredging in 2018 and higher levels of radioactive par-ticles have now been detected along the Somerset coast.

RIFE (Radioactivity in Food and the Environment) the UK wide annual marine monitoring programme, which focuses on areas close to existing nuclear sites has provided information showing a significant, and time relevant, increase in some

radioactive particles known to be present in the dumped sediment. These increases are seen following shoreline construction and mud dredging at Hinkley Point, along the Somerset coastline.

4. What impact did the previous ‘ mud dump’ in 2018 have on Wales ?

We have no idea as no data was collected on the impacts of the previous mud dump despite repeated requests. In 2018 we urged the Welsh Government and their regulators Natural Resources Wales (NRW) to conduct radioactivity measurements along the Welsh shorelines likely to be affected by the dumping of the Hinkley mud before and after the dumping took place. ….They refused and allowed the nuclear industry to go ahead and dump the mud anyway.

5. There is a lack of any radiation based data effecting the South Wales coast

The Severn Estuary is one of the most concentrated areas of nuclear activity anywhere in the world, yet there is a complete failure of the Welsh Government to insist on comprehensive and long term monitoring of the South Wales coastal environments for any nuclear discharges from the 6 nuclear power stations sited along the Estuary. Hence any commentary from the Welsh Government or NRW on the risks or impacts of those radioactive wastes on welsh coastal environments, wildlife or human communities has no scientific validity.

6. Models used to measure radiation by EDF ignore the sea-to-land transfer of radioactive particles.

EdF use calculations as if the mud was dumped in the open sea. However, the Sev-ern Estuary mud does not get swept down the channel, it swishes back and forth with the twice daily tides. Some particles get deposited on mud banks and some get into the wind as microspray drops. From the mud banks, it moves up estuaries like the Rhymney and Usk. When the mudbanks dry out or at low tide when the Cardiff Grounds are often exposed, particles blow onto land and are taken up in the soil. The nuclear contaminants get to people via inhalation and local foodstuffs.

7. EdF’s analysis of the dredged mud does not include an analysis for pluto-nium or organically bound tritium,

Research provided by Emeritus Professor Keith Barnham has confirmed that the Hinkley nuclear reactors were used for the manufacture of plutonium for the nuclear weapons programme in the 1970’s and that significant amounts of plutonium were discharged into the Bridgwater bay sediments during that process as a result of mis-haps. In addition the United Nations have published data showing significant amounts of uranium particles discharged. The greatest fear is of the ‘hot’ particles of used nuclear fuel released in that sludge, because these are not detected by the conventional analysis.

Independent academic studies confirm that the gamma spectrometry analysis used by CEFAS and EdF did not and could not possibly record the presence of beta and alpha emitters like strontium 90, the plutonium nuclides, and a number of radioactive elements. In addition the RIFE reports fail to analyse for plutonium and uranium.


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. Continue reading “DUMPING SUSPENDED !!! WHAT’S NEXT?”


The dumping of radioactive mud would break the law because the project has had no Environmental Impact Assessment carried out to ensure that the radioactive mud has been properly assessed as to the risk to the environment and people’s health ! Without such an assessment it would also fall foul of Section 4 of the Environment Wales Act 2016 which requires full consideration of all relevant evidence and gather evidence on uncertainties, and the Well-being of Future Generations Act 2015 which requires public bodies in Wales to think about the long-term impact of their decisions, to work better with people, communities and each other, and the Marine Works (Environmental Impact Assessment) (Amendment) Regulations 2017.

But the Welsh Government is supposed to protect us from harm by legislating that no decision should be taken by the NRW until they have carried out an independent EIA instead of just accepting what EdF (Electricité de France – the builders of Hinkley C) told them. The Welsh Government cannot let them off the hook by going ahead with the dumping when no EIA has been carried out. If the Welsh Government Minister responsible, Lesley Griffiths, does not call in the Marine Licence and halt the radioactive mud for it to be tested properly then she will have broken the law because she is ultimately responsible for the unlawful dumping.

According to the law an EIA should happen because “If the proposed development is likely to have a significant effect on the environment then it should have EIA.” This is the law passed by a Welsh Labour Government which has passed such well-meaning but useless legislation as the “Wellbeing for Future Generations”. In such cases, the applicant for planning permission must provide the required information so the environmental effects of the development can be assessed. This information, in the form of an Environmental Statement, will then be considered in the determination of the planning application.

The NRW says that there was an EIA because they used the EIA done by EdF who are building Hinkley C. But CEFAS says a Habitats Regulations Assessment carried out for the Hinkley Point C development does not cover the disposal of material to Cardiff Grounds. So if the NRW give the go ahead to the radioactive dumping it will break the law. The EIA Regulations state that, where an application needs to have EIA, planning permission shall not be granted unless the person determining the application has first considered the environmental information.

The fundamental problem about the NRW’s decision to go ahead with the dumping is that the scientific argument about the inadequacy of the data is what EdF have told them and the NRW does not have any independent expertise about radiation to be able to make a sensible judgement. Until then the Marine Licence should be called in so that an independent EIA is carried out based on thorough testing of the radiation in the mud before it dumped near to Cardiff and Penarth.
Tim Richards, LLB.PGCE

Cardiff Radioactive Mud Fudge Exposed, Fragmentation Hazard Overlooked

WANA member the Low Level Radiation Campaign has published a new report on dumping radioactively contaminated mud near Cardiff. The report was presented last month to Natural Resources Wales with documentary evidence that health risks have been underestimated.


Trawsfynydd is the only inland nuclear power plant in the UK, it was shut down in 1991 after 26 years of operation. However, in June 2018 the UK Government announced a £40m facility to support the design of Advanced Nuclear Technologies (ANT’s) would be developed on the site

Advanced Nuclear Technologies (ANT’s) encompasses Small Modular Reactors (SMR’s) – the term used to describe a wide range of developing nuclear reactor technologies that share a number of common attributes ;

* they are smaller (under 300 Mw) producing about a tenth of the power of a conventional nuclear station

* designed so that much of the plant can be made in a factory and transported to the site.

SMR’s generally fall into two categories

a) Generation III water-cooled SMR’s – similar to existing nuclear power station reactors but on a smaller scale, and b) Generation IV advanced modular reactors, which use other cooling systems or fuels . They range in scale between micro, small and medium scale reactors and which span technology types from conventional water-cooled reactors, to those using novel fuels and coolants.


The Westinghouse SMR is a >225 MWe integral pressurized water reactor

The Government is running a two-stage Advanced Modular Reactor (AMR) Programme, managed by Innovate UK where they have invited companies such as Rolls Royce to submit designs / ideas

Stage 1 – Launched in March 2016, offering grants of up to £4 million to support around 8 initiatives to undertake feasibility studies.

Stage 2 – Up to £40 million to support 3-4 vendors to accelerate their designs eg. at Trawsfynydd


It’s the same old technology – The basic idea actually dates to the 1940s, when the U.S. Air Force, Army, and Navy each initiated R&D on various types of small reactors. Some proponents see them as the solution to the problems facing large

reactors, particularly soaring costs, safety, and radioactive waste. Unfortunately, small-scale reactors can’t solve these problems, and would likely exacerbate them. As the history makes clear, small nuclear reactors would be neither as cheap nor as easy to build and operate as their modern proponents claim.

(IEER/PSR presentation  http://www.ieer.org/fctsheet/small-modular-reactors2010.pdf 


It’s the last ditch stand of a dying industry – nuclear power proponents are pinning their hopes on SMR’s without thinking about the new problems they will create such as inspecting production lines , procedures for recalls, or the complications and costs of a variety of new forms of nuclear waste on a number of different sites.

Safety concerns – You need more SMR’s to produce the same amount of energy as conventional stations so that raises issues of safety, quality, licencing and of course security

Cheaper does not necessarily mean cost-effective – In Dec 2017 The Atkins Consultancy report for the Department of Business, Energy and Industrial Strategy said there was “a great deal of uncertainty with regards to the economics of SMR’s. The Report found that power from SMRs would cost nearly one-third more than conventional nuclear stations because of reduced economies of scale and the costs of deploying first-of-a-kind technology.” http://www.atkinsglobal.com/en-GB/angles/all-angles/our-nuclear-future

Efficiency and most renewable technologies are already cheaper than new large reactors. The time it will take to certify SMRs will do little or nothing to help with the global warming problem and will actually complicate current efforts underway.


The Well-being of Future Generations (Wales) Act 2015 is unique to Wales and demands that we think about the long-term impact of decisions, it also offers a huge opportunity to make long-lasting, positive changes for current and future generations and yet the Welsh Government is condoning an energy policy at variance with the Act.

What is the future for Wales are we to be engulfed by nuclear power stations? – At present that looks possible;

* In 2010 the UK Government categorically stated it would not subsidise nuclear developments.

* 19th July 2011 the UK Government approved a National Policy Statement on Nuclear Generation. This listed 8 sites in England and Wales suitable for new nuclear reactors. Developers are currently planning 13 new reactors at 6 of the sites – the other nomi-nated sites are Heysham and Hartlepool.

* March 2017 concrete pouring started on the first structures at Hinkley Point : an 8km network of tunnels to carry piping and cables around the site; mud from the site is sched-uled for dumping in Cardiff Grounds from July 2018 .

* June 4th 2018 Greg Clarke announces “Wylfa Newydd could cost more than £15 billion to build and be part-funded by taxpayers to the tune of £5 billion” thus overturning the 2010 pledge not to subsidize

Four reactor designs are being considered for UK new-build: the Areva/ Frama-tome EPR (originally the European Pressurised Reactor), Westinghouse’s AP1000, Hitachi-GE’s Advanced Boiling Water Reactor (ABWR), and the Chinese Hualong HPR1000. South Korean group Kepco is also preparing a bid to deploy its APR1400 in the UK


Hinkley Point – Scheduled for completion by 2025

Hinkley Point in Somerset is 14 miles from Barry and 19 from Cardiff. After years of negotiations the UK government has finally managed to convince EDF (a French utility company) to invest, but only after it guaranteed the company a set price for the electricity the plant produces, even if its higher than the open market price at the time. Even then, EDF only committed once it had secured Chinese backing. As the formerly pro-nuclear The Economist put it in 2016 in an analysis entitled “ Hinkley Pointless – Britain should cancel its nuclear white elephant and spend the billions on making renewables work” .

Wylfa Newydd (Ynys Mon) – Scheduled for completion 2024

Horizon Nuclear Power, owned by Hitachi plans to build two 1.3GWe ABWR’s at Wylfa and at least two at Oldbury (Gloucestershire). Hitachi is still trying to find funding partners to share the costs and is currently sounding out the Development Bank of Japan and other Japanese power companies ; a problem as many are struggling with the heavy financial fallout from the 2011 meltdown at Fukushima. Tepco for example has to raise huge amounts of money to decommission the Fukushima Dai-ichi station and compensate victims.

Moorside (Cumbria) – scheduled for completion 2024

Cumbria already has the biggest store of plutonium anywhere in the world and is now set for a further 3 new reactors. The original plan by NuGeneration, ( the British subsidiary of Toshiba-owned Westinghouse Electric Company) , had the station coming online from 2024.

Why is the UK Government so determined to push ahead with nuclear and why is the Welsh Government not challenging this energy programme when we have more than enough green renewable options here. We need to ask questions NOW


1. Write to your MP pointing out why a nuclear energy programme is unnecessary, is no solution to climate change and will cost the earth and the environment.

2. Write to your AM and ask them to justify why the Welsh Government is supporting the UK Government nuclear programme in light of the 2015 Wellbeing of Future Generations Act (Wales)

Points to raise

> Nuclear power is a financial nightmare not only will it cost the taxpayer billions the public will also have to run the risk of lengthy and costly over-runs; the hallmark of nuclear power construction worldwide

> Nuclear is no solution to climate change – The UK has a binding target of a cut in CO2 gases by 34% by 2020 but even at the most optimistic nuclear building rate ie. 10 new reactors by 2025, the UK’s carbon emissions would be cut by just 4%. And where do they think the uranium comes from ?

> Nuclear locks us into the same old inflexible, inefficient and outdated energy system, it also undermines the solutions that can deliver energy and cut our carbon footprint quicker and cheaper.

> Nuclear waste – we already have a 60 year legacy of waste we don’t know what to do with. New nuclear plants will increase the amount of atomic radioactivity by at least three times.

> Nuclear increases our chances of major radioactive contamination from accidents, routine releases and terrorism.

> Nuclear has a history of very serious accidents – Kyshtym 1957 (Soviet Union) level 6 on the INES(International Nuclear Events Scale) Level 7 being the worst possible. Windscale Fire (1957 Cumbria) ) INES level 5, Three Mile Island (USA 1979 ) level 5, Chernobyl (Ukraine 1986) level 7 and Fukishima (Japan 2011) level 7.