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

c/o LLRC, Times Bldg. South Cresc.
Llandrindod Wells Powys LD1 5DH
Secretary
info@wana.wales
www.wana.wales

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.
    Cont’d….
    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.
    Signed:
    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

NATIONAL RESOURCES WALES CONSULTATION HINKLEY C SAMPLING OF ESTUARINE SEDIMENTS

CONSULTATION RESPONSE FROM WAYNE JONES
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
it,s activities . WE KNOW THAT THE DATA SUPPLIED BY MAFF WAS
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.

DUMPING SUSPENDED !!! WHAT’S NEXT?

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?”

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.

WHY NRW’S PERMIT TO DUMP HINKLEY MUD IS WRONG FOR WALES

Analysis of sediment – Do samples from the deeper levels breach permitted “de minimis” limit? Samples analysed for 2013 and 2017 reports were from the top 2cm of the surface of the mud deposits. These will be recent and highly mobile sediments derived from the whole of Bridgewater Bay. They will not be representative of the older and deeper sediments accumulated in past decades from higher nuclear discharges. The previous deep core-samples of 2009 showed significantly higher radioactivity in 3 out of 5 samples, implying that the bulk of excavated material could be of higher levels of radioactivity, which would take the mud closer to the de minimis limit. Exceeding this level would make disposal at sea illegal. EdF have refused the Petitions Committee’s request for more sampling at metre-depths, stating that no artificial radioactivity was observed below 2m. NRW have failed to demand from CEFAS an appropriate test to detect alpha-emitters, such as Uranium and Plutonium and instead relied on gamma spectrometry to test the mud samples. CEFAS then omitted to report indirect evidence of these same alpha-emitters in their reporting to NRW.

Deep Sea or Severn Estuary? The disposal site is in the Severn Estuary and not in the open sea. NRW appears to be permitting the mud dumping because the expected yearly received dose of radiation will not exceed that allowed for sea disposal under the terms of the London Convention, the law regulating the disposal of radioactive material at sea. However, the Cardiff Grounds dispersal site is situated within the Severn Estuary, rather than in open sea.

New assessments by CEFAS of the expected dose of radioactivity are based on only three available samples, meaning their anticipated level of 5.8 µSv/yr could be unrepresentative. The actual dose could exceed the 10 µSv/yr “de minimis” level, making the dump illegal anywhere at sea and even more potentially damaging in an estuarine environment.

The London Convention permits the dumping of artificial radioactive material at sea “where proper account has been taken of the marine environmental and other conditions” and meets “de minimis” criteria. International Atomic Energy Authority guidelines stipulate that disposal can include well-mixed coastal waters but states that disposal should take place a few kilometres off the coast, so that the actual shape of the coastline does not influence dispersal significantly. There is no approved protocol for estuarine disposal.

IAEA guidelines, updated in 2015, require that an assessment on the affects of the disposal on wildlife must be carried out, prior to permissions being granted. Therefore NRW should have produced a Habitat Regulations assessment, prior to granting EdF permissions to dump. Cardiff Grounds is within a Ramsar site, a protected area of international importance to wetland birds, and is also situated within a Special Area of Conservation.

Toxic metal and organic contamination of sediments.

EdF have disclosed to CEFAS that there are excessive levels of metal and organic compounds in the Hinkley mud, which amount to “a quite small breach” of CEFAS’s “Action Level 1”. NRW should have assessed and reported on this anticipated impact to wildlife, but failed to do so before granting EdF permission to dump.

In conclusion, NRW’s expected commitment to sound science and rigorous regulatory standards does not seem to have held sway when granting permission to move mud from Hinkley Point to Cardiff Grounds. They acknowledge that they do not have expertise in nuclear matters, but they were appointed by WAG to approve the removal and re-location of this mud, a legacy of reactors A and B, at Hinkley.

The people of Wales and its environment will not benefit from this mud and we expect our Assembly to exercise due rigour when deciding on its suitability, or not, for dispersal in Welsh waters. We demand that the decision to grant to EdF permission to dump is suspended until proper rigorous testing of deep samples is carried out. This proper testing should be carried out in a manner that will re-assure the public, who do not wish to accept increased radio-active contamination of the Welsh coastline and its tidal waters.

EVEN MORE RADIOACTIVE MUD FOR CARDIFF BAY ? HOW RADIOACTIVE IS IT ALREADY?

Even more radioactivity is to be added to the Severn Estuary around Cardiff, if plans to dump 300,000 tonnes of mud dredged from the Hinkley Point nuclear power complex go ahead and are dumped at a site called Cardiff Grounds, one mile from the city.

Welsh ministers granted permission in 2013 for the French energy giant EDF to dredge and dump this material at Cardiff Grounds, a sandbank in the Bristol Channel as part of their plans to build the new £19.6bn Hinkley Point C nuclear power station in Somerset. What adds insult to injury is that the Welsh Government has agreed to take nuclear waste so a French Company can build a nuclear plant in England that is not needed, it is a potentially serious health hazard and will cost the earth.

Man-made radioactive discharges into the Severn Estuary have been ongoing since 1967 when Hinkley Point A and then B started operations, and have also included discharges from other nuclear installations conveniently located along the Severn Estuary, i.e. Berkeley and Oldbury nuclear plants. EDF describes the mud as having a small amount of artificial radioactivity, which they say will have originated from legacy discharges from hospitals, medical isotope manufacturing facilities (including those formerly based in Cardiff) and lastly, unspecified nuclear facilities. However, the sediments to be dredged are located close to the existing long-term discharge pipes of the original plants at Hinkley Point and will have accumulated some of the leaked and accidental discharges from Hinkley A & B, as well as the routine liquid discharges of radioactive elements, as detailed in RIFE reports elsewhere on the EDF website

EDF have said that dredging will take 3-6 months and will begin in summer 2018. They have defended their actions by saying they are one of many companies (over many decades) dredging and depositing sediment in the Bristol Channel and that their mud is no different to that already at Cardiff Grounds. They claim that their tests, carried out by CEFAS in May 2017, show that the sediment “is not classed as radioactive under UK law and poses no threat to human health or the environment”

This is an infinitesimally small level of exposure to radiation, far below the threshold requiring a more detailed assessment or even close to approaching a radiation dose that could impact human health or the environment.

However, WANA has supported its own research. Tim Deere-Jones, an independent marine pollution researcher, has raised a number of concerns.

· Tests by CEFAS of the mud that could be dumped at Cardiff Grounds were flawed because of the 50 different radionuclides likely to be present, CEFAS only recorded the presence of 3 radionuclides.

· EDF has not accounted for the effect of dredging activity which will disturb and re-mobilise sediments.

· Sediments dumped in Cardiff Grounds are likely to be re-distributed by currents into mudflats and tidal estuaries and there may be significant sea to land transfer of radioactive particles via sea spray.

Additional work by Dr Chris Busby for WANA has confirmed that the CEFAS findings are flawed, CEFAS have not used analytical techniques that would reveal whether particles or Uranium and Plutonium are in the sediment. Official reports since the 1980s consistently state that the Bristol Channel contains radioactivity from Sellafield. It is highly probable that particulates are present. The precautionary principle dictates that CEFAS should have looked for such particles using alpha spectrometry but they did not. Data from the gamma spectrometry they did use suggests the presence of Plutonium and Uranium but it was deleted. See references below.