The Nuclear Free Local Authorities (NFLA) publishes on its website today a short summary (as well as the full long response) of a joint submission to Natural Resources Wales (NRW) to its consultation on a pre-application consultation by EDF Energy. The application seeks approval to dump as much as 600,000m3 of dredged material from the Hinkley Point site in Somerset to what are known as the Cardiff Deep Grounds, around 2kms from Cardiff Bay. (1)
The submission was jointly resourced and supported by the NFLA Welsh Forum, the Stop Hinkley group and CND Cymru / Wales and drafted by independent marine radioactivity consultant Tim Deere-Jones. In 2018, his research on EDF’s first application to dump dredged material was fully considered by the Senedd Petitions Committee and led to a full debate in the Welsh Assembly / Senedd.
The core conclusions of the submission are:
- Civil reactor sites have discharged “particles” of “enhanced” radioactive material into receiving marine environments over the course of their generating life.
- NRW should ensure that the proposed EdF sampling and analysis of Bridgwater Bay sediments must include a comprehensive analysis of ALL samples for the presence of these elevated radioactivity “particles”.
- The liquid effluent discharge records show that Hinkley A discharges of liquid effluent plutonium to the Bridgwater Bay receiving environment rose rapidly and peaked at an average of 10 times the magnitude of pre-production years. NRW should insist that the proposed EdF sampling and analysis of Bridgwater Bay sediments must include a comprehensive analysis of ALL samples for the presence of Plutonium isotopes.
- The submission argues that the IAEA assumptions on assumed pathways to which coastal populations could be exposed to low levels of radiation are overly simplistic and do not take account of the advance of empirical scientific evidence on pathways of exposure. NRW should take note of the updated empirical data and ensure that EdF commission analysis of the coastal sediments and coastal zone environments of south Wales in order to identify any variations in the radiological concentrations which may arise as a result of the proposed dump.
- There is a similar imperative for the monitoring and analysis by EdF of Tritium and Organically Bound Tritium (OBT) in the Bridgwater Bay sediments to be dredged and dumped at the Cardiff Grounds site.
- The submission references academic, and peer reviewed studies, which clearly demonstrate that the Severn Estuary and, to a lesser extent, the Inner Bristol Channel, have much higher concentrations of water column suspended fine sediments than the Sellafield coast, and that the adsorbtion of radioactivity to sedimentary particles is widely recognised as a major factor in the behaviour and end fate of sediment associated radioactivity discharged to sea. The submission is concerned that NRW, EdF and CEFAS have a limited understanding of such activity.
- The submission has consistently raised the issue of the lack of data on the behaviour and fate of radioactively contaminated sediments dumped at the Cardiff Grounds “dispersal” site and called for NRW to initiate appropriate research on that issue. Such research by NRW has not been undertaken.
- Tim Deere-Jones has analysed the effects of the Bridgwater Bay intertidal and subtidal construction activity through 2017 and 2018 by comparing the sediment (and other) analytical results published in the annual Radioactivity in Food in the Environment (RIFE) reports for those years and some years prior. The review of this data showed that the construction linked disturbance of previously sequestered radioactive sediments had generated an increase of the concentrations of Americium 241 and Cobalt 60 radioactivity in Bridgwater Bay shoreline intertidal sediments analysed through 2017/18, had generated elevated gamma readings above intertidal shoreline sediments, and generated a 215% increase in “total dose to the public”. These effects were also discernible for at least 12 miles downstream/down coast from the construction area.
- The submission calls on NRW to initiate a radiological analysis study of the current (post first dump) baseline for the south Wales coasts and into the potential future radiological impact outcomes of the proposed 2021 Cardiff Grounds dump activity.
- The submission calls on NRW and the Welsh Government to initiate a full and detailed Environmental Impact Assessment, preferably scoped by an independent panel of experts.
- NRW should insist that the number of sample points within the identified dredge areas should be at least doubled. The submission requests that borehole samples should not be analysed on a bulk basis, but in relatively short sections in order to identify those depths, and sediment types, with the highest concentrations of fine sediments and radioactivity concentrations.
- The submission postulates that the Welsh Government and the NRW may have denied the communities and individuals of the south Wales coastal zone a suite of information relevant to their physical and psychological health and the health and wellbeing of current and future generations, in breach of various “rights” encapsulated by the 1992 Rio Declaration (on the sustainable use of the environment).
- A legal question has arisen over whether the Cardiff Grounds dispersal site is situated in a “sea, a marine environment or an estuary”. The submission calls on the Welsh Government and the NRW to comment on these issues and make public the full opinion of their legal advisors.
NFLA plans to share this summary submission with its member authorities and also with councillors and relevant council officers in south Wales and the south west of England. It will share the submission and discuss future action with Welsh environmental groups. It will also forward on this submission to Assembly Members to seek their support and to ask questions in the Senedd.
NFLA Welsh Forum Chair, Councillor Ernie Galsworthy said:
“This detailed response shows the wide concerns groups like NFLA have on further proposed dumping of large amounts of material from the Hinkley Point site to the Cardiff Deep Grounds close to the south Wales coast. The response confirms to me that independent sampling should be undertaken on this material to consider what it may do with increasing low levels of radiation into the Welsh and Somerset marine and land environment. NFLA was very disappointed with the lack of public engagement from NRW and the Welsh Government in the last dumping application and remains highly concerned with what the impact of further dredging could be. We call on this application to be refused given the large level of uncertainty that exists with the impact of low levels of radiation on people and animals.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 00 44 (0)161 234 3244.
Notes for Editors:
(1) The submission is attached with this media release and will be placed on the NFLA website.
(2) NFLA Media Release, February 5th 2020