Please use our letter below for inspiration – people don’t have to write a lot – just let the Marine Management Organisation know that you do not want radioactive mud from Hinkley to be dumped in Cardiff Bay – EDF want to do this to facilitate new build at Hinkley C. Please write before 26th March –
Send your consultation responses to MMO: ref. MLA/2012/00259/6
More info at Stop Hinkley
Please do use the below for inspiration
Consultation Submission to MMO re MLA/2012/00259/6
Radiation Free Lakeland are a voluntary nuclear safety group in Cumbria formed in 2008. We are writing to vehemently oppose the continued dumping of radioactively and chemically contaminated mud which is being dredged from the Bristol Channel in order to facilitate the controversial eye-wateringly expensive and uniquely dangerous new nuclear build at Hinkley C.
The Bristol Channel houses a nuclear waste dump largely (but not completely) immobilised in the silts resulting from routine and accidental discharges from the operations of Hinkley A & B. The last thing that should be done with a sitting nuclear waste dump is to disturb it. However this is proposed by this continued plan to dredge and dump Hinkley A & B’s decades of discharge materials into Cardiff Bay in order to make way for the new build of Hinkley C. This dispersal of radioactive wastes to the sea is not only environmentally degrading but is a human rights issue. Dumping English radioactive wastes in Wales or anywhere is an abuse of human rights. The Welsh have a right to assume their children will not be impacted by Hinkley’s radioactive wastes which have been dumped in Cardiff Bay. Here in Cumbria our own citizen science investigations with the help of American nuclear science students from Worcester Polytechnic Institute have shown that samples taken from Cumbrian beaches have radioactive contamination resulting from decades of Sellafield’s reprocessing of spent nuclear fuel – that includes fuel from Hinkley A & B. Arnie Gundersen former US nuclear regulator has said:
I met Marianne back in 2014 when her group hosted me for a series of speeches in the Cumbria region. Some of the samples I took back then were as radioactive as Fukushima. The UK samples contain largely Americium, a manmade transuranic element associated with bomb making. We still need funding to analyze the remainder of the UK samples. Where there is Americium there is likely Plutonium …..
It is important to note that this beach radiation was NOT found by prospecting with a geiger counter looking for hot spots. Rather, citizen scientists just took dirt/sand samples randomly between the low and high tide marks and then mailed the samples with a GPS location to be analyzed here in the US. The UK government has been covering up the severity of the radiation in the Irish Sea and on Cumbria’s beaches.“
Burning uranium fuel at Hinkley A & B has resulted in a kind of nuclear Midas touch – in that everything the spent fuel touches turns to nuclear waste, there is a snowball effect contaminating more and more as the waste is moved around in the environment. We Urge the Marine Management Organisation to call for a public inquiry into the continued dredging and dumping of radioactively contaminated mud from the Bristol Channel. This current tranche of dumping applications would just the beginning of the tsunami of dangerous radioactive wastes that would be inflicted on the silts of the Bristol Channel and Wales should Hinkley C’s high burn uranium fuel reactors ever be fired up.
Radiation Free Lakeland support the conclusions made by Tim Deere-Jones: (Marine Radioactivity Research & Consultancy) below:
- EdF have failed to collect (pre-dump) data on the Chemical/Metal and PAH concentrations at, and adjacent to the proposed Portishead LU070 disposal site: this breaches MMO’s Criteria requirement to obtain sufficient data for comparison purposes between the dredge site and the disposal site in respect of relative concentrations of these determinands.
- EdF have failed to collect (pre-dump) data on radioactivity concentrations at, and adjacent to the Portishead LU070 disposal site. This breaches MMO’s Criteria requirement to obtain sufficient data for comparison purposes between the dredge site and the disposal site in respect of their relative concentrations of these determinands. The absence of such “baseline” pre-dump data means that it will be impossible to identify any increase in radioactivity following deposition at LU070.
- There are major flaws and weaknesses in the protocols and techniques employed by CEFAS, on behalf of EdF, to sample and analyse for gamma, beta and alpha emitting radio nuclides. These flaws mitigate against the production of accurate and precise radiological data concerning the concentration of radioactivity in the sediments of Bridgwater Bay, and relevant to the construction of potential dose estimates for local people who may be exposed to additional environmental radioactivity from the dredge plume and impacts at the Portishead disposal site LU070.
- There is a lack of coherent and clear explanation for the process of choice of dredge waste disposal sites. Initially EdF had committed to the disposal within the Hinkley sediment region (subject to meeting the MMO Criteria), then EdF decided to use the Cardiff Grounds site. No information has been provided to explain which of the MMO Criteria had been failed and prohibited the disposal of the wastes “within the Hinkley sediment” region.
- The Environment Agency proposed the use of Holm Deep, an offshore site in the centre of the Bristol Channel/Severn estuary, distant from any coastline (unlike both the Cardiff Grounds and the Portishead site) and otherwise very suitable for the disposal. This was rejected by EdF, on flimsy grounds. EdF were permitted, by a compliant Welsh Government, to dispose of the first tranche of wastes in welsh waters at Cardiff Grounds in 2018. Because this was outside the MMO’s jurisdiction EdF did not have to comply with MMO Criteria. The rejection, by EdF, of the offer of Holm Deep as a disposal site despite the advantages of its distance from vulnerable intertidal zones, inshore fisheries and coastal communities and a strongly “dispersive” environment has never been examined or reviewed.
- EdF have made a number of unsubstantiated claims about the nature and characterisation of the sediments at Bridgwater Bay, Portishead LU070 and Cardiff Grounds as set out in the full text of the Submission, including the claim that the sediments to be dredged from Bridgwater Bay are “like any other sediments” from the Bristol Channel/Severn Estuary. This is a claim made completely without any evidential support and in the denial of extensive empirical evidence to the contrary.
- This Submission concludes that these failings and weaknesses clearly indicate that the MMO’s Precautionary Principle Criteria must be invoked, and that in the absence of the required “scientific certainty” regarding Submissions 1 to 6 above, a Public Inquiry is now required in order to clarify these issues and generate the required degree of scientific certainty necessary for a clear and well informed decision making process to be carried through.
- The NRW have confirmed that an Environmental Impact Assessment will now be required for the dredge disposal marine licence application regarding the Cardiff Grounds. This decision has been made in line with Regulation 5 of Marine Works (EIA) Regulations (2017).
- This Submission notes that these issues remain outstanding despite, and because, the MMO have had the opportunity to scrutinise the EdF proposals in the past and have been unable to resolve them and ensure that the appropriate degree of scientific certainty is achieved.
- This Submission notes that in some circumstances the MMO can refer an application to government ministers for a decision rather than making a licensing decision itself. When certain criteria apply, the MMO will refer an application to ministers so they can decide whether to recover it. If ministers recover the application, they will set up a public inquiry. Ministers will then make the final decision on the application. The relevant criteria are that the application.
- falls in band 3 of MMO’s licence charging scheme, covering the larger and more complex projects
- is for an activity taking place wholly or partly in English waters up to 6 nautical miles from the coast
- it could have a significant effect and raise issues appropriate for examination in an inquiry (This Submission adds that both the previous application and the current application have been, and are, clearly in breach of the Precautionary Principle (need for scientific certainty) quoted by MMO in regard to dredge and disposal projects).
- This Submission therefore formally requests:
- that the MMO “refer” the EdF applications (dredge at Bridgewater Bay and dispose of dredge wastes at Portishead LU070) to Government Ministers for a decision to set up a Public Inquiry in order to clarify both the scientific and technical issues and the strategic and policy issues (decision making criteria etc)
- that the MMO initiate a full and detailed EIA and in depth of both applications, at both sites, in order to provide the appropriate level of high quality, detailed scientific evidence to inform a Public Inquiry.
on behalf of Radiation Free Lakeland