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.