Natural Resources Wales (NRW)
Hinkley Point C sediment sampling plan consultation SP1914
Deadline for comments March 18th 2020
All comments to firstname.lastname@example.org
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.