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Wednesday, 17 October 2018

Hinkley Mud letter of Mark Drakeford “seriously wrong”

How wrong can the Minister be when he claims to have “followed carefully the scientific evidence” and regards itas an important and serious matter” ?

On Tue, 16 Oct 2018 at 10:56, Drakeford, Mark (Aelod Cynulliad | Assembly Member) <Mark.Drakeford@assembly.wales> wrote:

Thank you for writing to raise your concerns with me. I can assure you that I regard this as an important and serious matter.

We have followed carefully the scientific evidence and the testing regime employed by Natural Resources Wales. While I understand that there will be differing views, there is no doubt that the results of the studies undertaken conclude that down to a depth of 4.7m no radioactive material can be found [1]. Furthermore, tests developed by the Atomic Energy Agency, have been conducted within the estuary have found that the level of radiation was well below the recommended level [2]. Moreover, Natural Resources for Wales concluded that the material tested did not have unacceptable levels of radiation and that the material was suitable to be disposed at sea [3].

You will be aware that this matter is now concluded, as the mud has been moved.

More broadly, within the Welsh Labour leadership campaign, I have made a commitment that if I were to be in the position of First Minister that we should establish an independent expert committee to provide advice on all matters which pertain to the proposed development at Hinckley Point.
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Scientific Notes - errors in each sentence

[1] down to a depth of 4.7m no radioactive material can be found
Three of the five borehole samples had elevated radioactive Uranium and Radium at 2 to 4metres, but not elevated in the two boreholes deeper than 4.3m. All five borehole samples show Uranium and Radium.  The bulk of extracted matter is between 1 and 4m; there are too few samples of this material under international protocols (minimum of 7-15 under OSPAR).  Parts of the sediment could contain much higher levels of nuclear contamination.
Table B.15  Uranium-238 and Radium-226 concentrations for Vibro core samples.
FUGRO survey of five locations in vicinity of intake, outfall and jetty, on 9/11 and 15/11 2009
Sample              U: surface/deep       Ra: surface/deep        depth           Date
1230/1231        48.73 / 46.13        25.25 / 27.65      4.35-4.42m      9/11
1232/1233        43.98 / 71.23        24.46 / 71.25      3.0-3.08m         9/11
1234/1235        39.46 / 41.25        22.43 / 30.30      4.7-4.8m         15/11
1236/1237        30.83 / 50.9          15.56 / 29.10     1.94-2.16m      15/11
1238/1239        50.65 / 68.56        25.29 / 73.57       3.0-4.12m       15/11
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Uranium is naturally occurring and produces radium in its decay chain. So the results do not prove they come from the Hinkley nuclear plant, but other points do:
# There are several times more U-235 relative to U-238 than in natural Uranium
# The surface Ra:U is close to 0.5 (normal), the deep Ra:U is nearer 1 and variable, indicating mixing of a source with higher Ra.
# Americium (Am-241) is detected (Figure from Cefas) and Europium-155 (Eu-155) both indicate leakage of used reactor fuel (Green Audit, Jan. 2018).  Am-241 is an indicator of Plutonium which the nuclear reactor was designed to produce.

[2] level of radiation was well below the recommended level.
No, there are no recommended levels; all levels cause harm according to ICRP (International Commission on Radiological Protection).  Calculated levels in the graph are quite close to their limit of 10μSv/a.  If the average U is twice that in surface mud – as compatible with the few measurements and with higher past leakages – then the total is close to 10μSv/a, not “well below”.
Figure from CEFAS Tech.Report TR444, 2017 on the NRW website http://www.naturalresources.wales/CardiffGroundsSedimentDisposal
[3] NRW concluded “the material was suitable to be disposed at sea”. 
The 10μSv in the first line in the Table below is close to being exceeded, while the “collective” public dose (line 2) was calculated quite wrongly – it assumed the discharge was into the Irish sea, affecting beach users and sea-food consumers around Morecambe Bay.  The last 3 lines in the Table, impact on marine organisms, were not assessed at all. (The CEFAS ‘experts’ used the outdated 2003 protocol that does not have the bio-tests of the 2015 protocol.)  
   So NRW could conclude nothing about ‘suitability’ for sea dumping on 'de minimis' tests.  
Moreover, toxic metals and PCBs were found to be over Action Level-1 and no detailed assessment was carried out as required under OSPAR, prior to deciding on ‘suitable’ for dumping in the Severn Estuary sea.



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