Evidence of illegal sewage dumping revealed by 'Dry Spills'

Evidence of illegal sewage dumping revealed

 in SAS 2022 Water Quality Report

24 November 2022

We found water companies have committed 146 ‘dry spills’ in the last year. For the first time, we’ve used rainfall data to investigate potentially illegal ‘dry spills’. Sewage outflows are only permitted in ‘unusually heavy rainfall’, but our analysis shows water companies have been dumping untreated sewage into our waterways even when there hasn’t been any rain. We would love to hear from water companies on why they’re releasing highly concentrated swathes of raw sewage into our parched waterways during one of the hottest summers on record?

The SAS Water Quality Report 2022 reveals 146 ‘dry spills’ in the last year, using rainfall data to show potentially illegal spills from CSO overflows.

SAS looked only at the most popular surf and swim spots, so not at Barry and Penarth

 

“Dry spills” are evident also for Lower Penarth’s Brockhill Rise CSO which spilled 114 times in 2020 and 67 times last year, averaging near 3 hours a time.  Other CSOs in Penarth discharge many fewer times, most 10-20 times nearer to storm frequencies.  In Barry, The Knap long outfall and Barry Dock storm CSO are worse (Welsh Water data).

 

Brockhill Rise CSO, goes from the pumping and storage plant on the
Railway Path (left) to the discharge point just below the low tide mark

 

NRW’s licence for the Brockhill Rise CSO specifies discharges are permitted solely of “storm sewage”.  Welsh Water built a huge underground storage tank on the railway path in the noughties. The CSO was modernised and discharges just below the low tide mark.  Welsh Water have to store peak flow there until there’s capacity to pump it through to Cog Moors works for treatment.  Instead, they appear to discharge it frequently to sea, evidently during many non-storm times.  

Extract of discharge consent from Brockhill Rise CSO
The discharge pipe is high capacity 1050mm

Welsh Water should report the licence breach to NRW but don’t.  And NRW make no check of the clearly over-frequent use of the CSO.  Welsh Water save on the treatment costs at Cog Moors and on the pumping cost to get the sewage there and pump the treated effluent to the Lavernock Point long outfall.

FOE briefed the regional MS on the 23 Dec.2020 flooding 

Barry&Vale FoE met with Heledd Fychan MS for the Cardiff region early November, briefing her on flooding due to sewer overload relating to the 23 Dec’2020 rainstorm, and unlawful discharges of untreated sewage. Flooding in Dinas Powys happened when the surface water sewers were unable to discharge into the river at high flows and the ‘attenuation’ tanks at Llandough hospital discharged quickly to the Eastbrook which itself overflowed and fed the Cadoxton river. The VoG Section 19 statutory report ducked these issues while the Section 19 report for Penarth is still delayed.  

 

Heledd agreed to take up the issues, alongside her findings on flooding in the Rhondda.  The last Senedd report in March disregarded sewage impacts on sea recreation, as does the Welsh Government. Heledd agreed this needs to change - the special Senedd committee on the floods could take up the evidence on NRW failing to regulate sewage spills during both floods and dry spells.

Welsh Minister Julie James taken in by "carbon-negative" nonsense

Incredibly, the Minister Julie James has been persuaded that the Barry Biomass incinerator would be “carbon negative” so help “build a stronger greener economy... towards decarbonisation”.

These words are in the Minister's letter of 29 July 2021 to DIAG, when she announced that she would assist the company's to overcome the EIA failure. So one would expect this assessment to be firmly based. But it isn't. She repeated numbers from the company, numbers that NRW repeated without scrutiny, apparently lacking any capability among her officials.

Here are Some Numbers, taken from the company 

Burns annually 86 000 tonnes wood wastes - gives direct emissions of 129 000 tonnes CO2. 

Uses over 5000 tonnes for process chemicals and start-up diesel (company figures in 2017), 

Another 20-30 000 tonnes CO2 is due to transport and chipping (the company ignores)

The company say they'd produce 80 000 MWh electricity a year, displacing electrical power otherwise coming from the Grid.

Figures for the average CO2 per MWh from the Grid are published each year - about 0.2 tonnes now with projected decrease to 0.1 tonnes per MWh in 2028 and lower in the 2030s. 

 So their electrical output will save a puny 8000 tonnes CO2 annually coming from Grid electricity - much less than the 25-35 000 tonnes above just for transport, chipping and chemicals+start-up diesel.

Julie James should have smelt a rat when the company claimed the 129 000 tonnes emitted CO2 doesn't count because it's “biomass”. Yet waste wood

# contains composites like MDF (10% level of glue etc.), as well as coatings and preservatives

# much is chipboard, whose coating can be stripped and the chips recycled into new board.

CO2 from glues and coatings is largely fossil; CO2 from burning recyclable woodchip has to be counted even on the bio-CO2 excuse.

Europe has ended subsidy to incineration, as they've realised it impedes the transition towards a carbon-neutral and circular economy. Julie James is responsible in Wales, but incredibly none of her civil servants are able to manage the numbers.

Av. CO2 from UK electricity.  Drops below 100 (kg/MWh or g/kWh) in the 2030s, while Julie James believed Biomass's quote of levels from 2013-14 in claiming CO2 "offset" makes it "carbon negative".

----  References to the Circular Economy ----

The EU in 2021 ended subsidies to Waste-to-Energy incineration, recognizing that WtE opposes the transition towards a carbon-neutral and circular economy

 Waste incineration is a carbon-intensive process [1] undermining the efforts to decrease carbon emissions and, thus, to reach carbon neutrality on time. Additionally, it .harms rather than supports the transition to a circular economy [2] Since both non-recyclable and recyclable waste can be used as a feedstock to a waste incinerator, waste prevention and recycling are discouraged [3],

[1] https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/ZWE_Policy-briefing_The-impact-of-Waste-to-Energy-incineration-on-Climate.pdf

[2] https://zerowasteeurope.eu/2019/09/waste-to-energy-is-not-sustainable/

[3] https://zerowasteeurope.eu/2017/10/deliver-pay-waste-incineration-causes-recycling-slow/

Sewage dumped into sea at Barry for hundreds of hours

 The Cardiffian reported in February:   Swimmers and surfers may not be aware of how much has been released

VAST amounts of untreated sewage are being released into the sea at the Old Harbour, despite council ambitions to turn it into “an area for nature”.

Wetland Birds looking for food in the Old Harbour with a sewer overflow in the background (from Cardiffian)

Sewage is also being released into Barry docks where a new marina and waterfront developments are planned.  Untreated waste is released from combined sewer overflows, pictured above, after heavy rain when sewer capacity is exceeded says the Cardiffian report 

Combined sewer overflows, also known as sewer storm overflows regularly release raw sewage into the sea

There's one CSO discharge into the Harbour.  Last year, 2021, the second "Barry Town" CSO spilled over 4 times more frequently than as in the picture for 2020:  65 times for a total 71 hours,.

"Barry Town CSO" is thought to be the short outfall from the Knap (not as depicted).  There's a second main long outfall from the Knap, built about 1990.  Discharges were supposed to end when the Cog Moors works came in 1997. DCWW have been concealing continuing use until the 2021 data came out:

Barry Town SPS - Long Sea Outfall   205 times   2236 Hours

This shows far more use than the Town and Harbour Rd CSOs, and for 10 hours a time. FoE suspects 

DCWW are using it unlawfully to relieve pressure on the overloaded Cog Moors sewage works and NRW are turning a blind eye.

Marine conservation group Surfers Against Sewage say on their website they are: “increasingly concerned that CSOs are being used to regularly dispose of untreated sewage, even during times of low rainfall or none at all.” 

 The Cardiffian received a response from Welsh Water:  sewage overflows

 “do not have an impact on the excellent bathing water quality at Barry”

This is false.  First the monthly water monitoring at both Whitmore Bay and Jackson's Bay in recent years has shown failures of the Blue Flag standard (exceed the virus and/or bacteria standard in more than one of the 20 weekly samples, summer season only).  

Second, NRW required use of UV disinfection on sewage overflows from Cog Moors sewage works to reduce bacteria and virus levels, in order to meet standards during the summer bathing season.  Welsh Water discharges untreated sewage at peak times at even greater volumes than the sewage it treats in  the Cog Moors works, with the UV equipment turned off from October to April.  

NRW inspections report visible evidence of sewage debris on both Whitmore Bay and Jackson Bay beaches. NRW do not monitor the water quality for viruses and bacteria outside the 20 summer weeks.  

And NRW are complicit with Welsh Water's nonsense claims that sewage 'spills' are

“highly regulated and closely monitored by our regulator Natural Resources Wales.”

Key objections to the Voluntary Retrospective travesty of the law for Barry Biomass Incinerator

 This Voluntary Retrospective EIA deserves ridicule and should be dumped.

responses to documents on barrybiomassconsultation.online were due by 17 January, but it's now blocked.  FoE's full response can be downloaded from Facebook

The “scope” was limited in cosy discussions between the WGovt and Barry Biomass outside EIA rules. Welsh policy supports community Health Impact Assessments, but this was ignored. The Welsh Government supports the rights of children to be consulted, but ignored it here.

They limited the site to the original area, yet operating the plant depends on using the northern extension and using Berth 31. They've been caught out by the VoG's enforcement action including the northern extension.

By basing the EIA on 2016, they tried to avoid Welsh 2017 policy on air pollution which adopted the WHO findings of harm at pollution levels below the legal limits and greater harm to vulnerable people.

What are the Critical Objections that should cause the downfall of this Incinerator?

#  Tight air pollution standards issued by the WHO in September over-rule the old limits used in the EIA. This arises as the legal criterion in waste management is no-harm-to-health; the new WHO Guidelines implement this. Barry already comes above the WHO standards.

# Ignoring the law requiring use of the waste heat, refusing to assess opportunities for it

# Ignoring the EIA requirement to assess major accidents and disasters, with their off-site impacts on the local community. There is no assurance the plant can be operated without harm to health and the environment.

# Failure to conduct a community Health Impact Assessment and involve children it it, despite their vulnerability to pollutants, contrary to Welsh policy. Ignoring the health hazard from ultrafine particulates.

# Using the wrong stack diameter: that constructed is 2.75m, but they've calculated the fumes from a 1.6m stack, claiming little difference. In fact it means the smoke plume emerges too slowly, is caught in stack eddies and easily descends onto housing.  Plume calculations are poor in Barry's basin and the 43m height is too short to clear Barry's hills

# Refusal to provide data on the composition of the wood-waste, with its chemicals in coatings etc., likewise no data from comparable working plants abroad.

# Failure to consider noise and pollution at the nearest housing, currently being built at East Quay site. The excuse there was no housing there in 2016 won't wash. Suppressing the issue equals lying.

# Carbon emissions higher than the UK power supply. They falsely claim a huge carbon allowance from replacing other electricity generators (670 instead of the 200 in 2020 and under 100 gCO2/kWh in the 2030s). They claim the few % plastics in the waste is 'biogenic' and fail to exclude the fraction that's recyclable. The emissions from their inefficient wood burning come to 1600 gCO2/kWh, a complete embarrassment to Wales.

# Discharge of the industrial effluent to sewer cannot be allowed, as it frequently discharges (via the Barry Storm CSO, 120 times a year) into the Dock. Nothing is said on the environmental sensitivity and watersport activities that would be impacted by the effluent.

# Tidal surge flooding required the raising of the nearby East Quay site to 8.9m AOD (Q100 level: 8.76m). The David Davies road entrance is 7.6m AOD.

THE FINAL BLOW; The public has a right to expect government to follow the rule of law, not choose bit and make arbitrary changes to help BUK. This ECHR right is called Article 8: the Welsh Government collusion with BUK is in flagrant breach of it.

Review of the Vale's "Local Development Plan" FoE's FINAL RESPONSE

https://www.valeofglamorgan.gov.uk/Documents/Living/Planning/Policy/RLDP/Draft-Review-Report-2021.pdf

REVIEW OF THE VALE OF GLAMORGAN LDP STRATEGY

They Say:

1. To promote development opportunities in Barry and the South East Zone

2. The St. Athan area to be a key development opportunity

3. Cardiff Airport a focus for transport and employment investment

4. Other sustainable settlements to accommodate further housing and associated development

They attach “also” to   ## Climate Emergency and ## Nature Emergency

6.4.3 measures to address the climate and nature emergencies will also be key matters for the Replacement LDP

These as fundamental, not 'also' add-ons.                         Climate Change Wales Regs. 2021

Responses submitted 31 January

        “Emergency” means priority for climate and nature: freeze or drop past plans and projects

Instead of above list, we'd substitute

1. Priority to the climate crisis and the nature crisis; cut back development and save natural sites

2. Restrict housing sites to rail/bus linked + small developments within settlements for local need

3. Invest in flood mitigation +SuDS, sewage treatment and sustainable transport for resilient communities.

4. Plan to downgrade the Airport-St Athan enterprise zone (6.3.19) ; cut out the Model farm development

5. Boost local shops and facilities and rejuvenate town centre to reduce the needs for travel.

6. No developments in the coastal strip apart from facilities that need a coastal location

7. Promote tourist opportunities and facilities, restore beaches to Blue Flag standards

The LDP has to integrate responses to the climate and nature emergencies (CC Wales Regs.21

Reconstructing our economy has to cover planting trees and woodland; also re-wilding opportunities rather than “development” opportunities. Reconstruction has to cover our settlements that will flood when hit by rainstorms enhanced by climate change, to implement surface water drainage and to retrofit SuDS schemes. Reconstruction has to put in adequate sewerage and sewage treatment plant for the house-building allowed without foul sewage capacity. Reconstructing our economy includes expanding tourism and informal recreation on the Vale coast, to replace unsustainable holidaying abroad. Development as associated with Rhoose airport that does not integrate responses to climate and nature emergencies is blocked,

The LDP's previous promotion of growth has to be dropped. So much of what is important to our well-being lies outside of the purview of statistics. The misguided policies pursuing growth did not integrate climate and nature emergencies, nor did they assess wellbeing.

Cut back unsustainable Housing expansion

Review these stalled sites at Darren Farm and Cosmeston - two stalled major sites - for compliance with policies in the plan, as well as reviewing sites that have not progressed,as 6.3.15

Cosmeston – car-dependent, far from facilities; in the coastal zone; toxic landfill; access is vulnerable to floods; first planned to be Green Wedge; archaelogical find/listed farmhouse

Darren Farm – cut back as limited market demand; too big for sustainable development and Cowbridge to absorb

Hayes Wood – remote from facilities; not part of a sustainable settlement; poor bus services

Llandough Hill – land vulnerable to flooding from soakways in developments above which discharge rapidly through the permeable rock (limestone). Past permissions of soakaways and discharge into Llandough stream ('drain') have to be corrected. 

 Llandough is not a sustainable settlement – this would be a car-borne extension of Cardiff.

Assess Sewage Treatment capacity for the purposes of new development

Dwr Cymru assurances cannot be accepted as they are unlawfully discharging untreated sewage to rivers and the sea

The assurances with the 2009 UV installation that they'd meet Blue-flag bathing water standards at Barry beaches has proved untrue. This is important for tourism, so must be reviewed.

Review Sewage Treatment capacity

Widely known that many sewage works are discharging untreated sewage frequently, at times when weather conditions are not "exceptional" and therefore unlawfully.  The VoG cannot claim not to know, as effluent from Cog Moors pollutes Barry Island waters

# summertime sampling is showing Whitmore Bay does not comply with Blue Flag standard

# data disclosed by DCWW shows untreated discharge ~80 times a year, more frequently in the winter months

#  the UV disinfection is switched off during the winter months, so Whitmore Bay sea bacteria are likely to be many times worse than summertime. 

The LDP should assess the excess flow over the treatment capacity and conclude there is no leeway for additional sewage in the system as at present.  Accepting assurances from DCWW that they can take the sewage from further connections amounts to collusion with criminals who take payments for dealing with your waste then dis[pose of it unlawfully.  It breaches the duty of care to accept assurances when you have reason to believe their disposal is (in part) unlawful.

As the Vale wants to promote tourism and leisure use of the sea, the LDP should get assurances on 

# use of UV disinfection at all times of the year when immersion activities take place

# specify DCWW has to invest in further treatment capacity to relieve overloading of Cog Moors STW and meet the Blue Flag standard as was intended when the UV plant was installed (2009) and now year-round when immersion sports take place.

In terms of new connections to the public sewer:

# require all new developments in the Cog Moors area (incl. the Kenson-Weycock and Cadoxton catchments in the Vale) to pay towards new treatment works and delay all over a threshold (say 10 dwellings) pending commissioning of the further sewage capacity

# seek that Cardiff Council freezes the Plas Dwr (Cardiff west) development until further sewage capacity is commissioned, or alternatively requires the developers to pay towards new sewage treatment plant.

Tighten spec for Attenuation Ponds

Capacity has been planned for average rainfall run-off storage

# settlement/attenuation pond to take run-off; if it discharges to Welsh Water  or to private drain, it had  to be covered in a S.106 Condition at this outline stage

# sizing the attenuation pond to take average annual run-off causes flooding during storms'  It has to have sufficient capacity for the maximum planned storms

Review the Cardiff Airport & Gateway Development Zone of 44.75 hectares of B1, B2 and B8 business park and associated car parking.

 speculative growth, no 'need' demonstrated, contrary to sustainable development

•  related to completely over-optimistic airport projections; put it on hold pending a clearer future for the failing airport

•  now 'need' under climate emergency to cut back air transport and related development

• infrastructure capacity is wanting -   roads, sewage....

• need under nature emergency to save this valuable countryside, farmed sustainably with care for nature.

Plan for expansion of the tourism sector, giving more jobs; valuing our coast (excluding development on it), and regaining our Blue flags (correcting the deficit in sewage treatment).

Enable use of Barry Dock for water sports (incl immersion sports) and cockle-farming by ending the routine sewer discharges into it (150 times a year)

Create a blue-green Country Park with conservation area and history trail on RWE's Aberthaw site (east of the ash-mound, plus south alongside the coastal path)

Proper appraisal of flooding with planning for more severe rainstorms under Climate Change

Flooding is due to housing and roadway run-off discharged to sewer (most of Penarth). In Dinas Powys to the river Cadoxton too. In Llandough to the Eastbrook. Barry has many old CSOs. In Sully, Penarth and Barry, surface water drainage systems need building and enhancing to take rainstorm run-off into the sea.

The Section 19 report on the 23 Dec 2020 floods was inadequate for LDP planning

## wrongly omitted flooding at east Llandough and lower Penarth

## lower Penarth is part of the Cadoxton River catchment, but completely wrongly modelled in NRW flood mapping – this assumes run-off into the Sully Brook, with flooding onto the Glamorganshire golf course. In fact little reaches the Brook, but goes into the sewer – the 23 Dec rainstorm overloaded the sewer and flooded Castle Ave and Lavernock Rd, then Cosmeston car-park and lake.

## found the roadway surface water pipe in Sully (discharge down Swanbridge Rd to sea) was inadequate; probably the housing surface water pipe (over sports field) is also inadequate, but no upgrades were promised.

## accepted that the 23 Dec. rainstorm was well below the 'extreme' but considered capacity only relative to this one, not planning for the 'extreme' rainstorms plus the 30-40% “climate uplift”.

The LDP needs to contain an honest appraisal, relative to the uplifted extreme storms

The S19 report fails to include retrospective SuDS schemes, despite policy for these. The LDP needs to map out the older housing areas which still rely on combined sewer systems, as preliminary to assessing practicality and priority for adding surface water drains.

The LDP needs to include policy for the widest spectrum of SuDS schemes, for individual householders, businesses, and public buildings, as well as highways.

These should include

## holding pond/lake for Llandough Hospital and car-park run-off, with controlled discharge to the Eastbrook

## holding pond/lake for surface drainage waters from Castle Estate etc, (west Penarth) in Cosmeston Park

## retrofit surface water collection systems discharging to sea in lower Penarth, where the existing combined sewer (Brockhill Rise CSO) overflows frequently (over 100x per year) much more than only during the legally acceptable 'extreme' weather.

## expand capacity of Sully surface water discharges to sea.

## incentivise house-owners to install soakaways for drainage from rooves and patios.

## Require planning consent for new hardstanding (over 2 sq m) and that it's permeable and/or drains to soakaway.

# Avoid soakaways in permeable limestone (Llandough), where soakaway rainfall quickly reaches surface water drains and streams; instead retrofit larger holding ponds to reduce flooding of the Llandough stream.

## big programme of SuDS schemes in streets to take run-off into swales and grassed areas

Appraisal of the NRW flood-planning Map

The revision of TAN15 on Flooding has been delayed because of criticisms of the NRW map, which is supposed to be used for LDP purposes.  The VoG needs to examine its inadequacies here. 

# the predictions show limited flooding around Barry's No.2 Dock,though flood levels from the detailed 2008 Arup study for the Waterfront development gave flood levels about a metre higher.  The flood planning level for the East Quays housing development is thus a metre higher than what the Minister assumed for the Barry Biomass incinerator, though the two sites are 100 metres apart.  The rubric for the NRW map says it's not to be used for individual developments, where a specific study is needed.  The VoG needs to choose the Arup study over the NRW flood map and ask NRW to sort out the difference

# the NRW predictions for the east Vale were tested by the 4-hour intense rainstorm of 23 Dec. 2020.  Results in lower Penarth showed the NRW map was completely wrong in showing flooding from the Sully Brook over the Glamorganshire golf course.  In fact the flooding was on the Lavernock Road (Cosmeston) and across the carpark into the lake; the floodmap shows no flooding on the carpark and very little on Lavernock Rd.  

# The S.19 report on Sully and Dinas Powys which also suffered flooding in the 23 Dec. rainstorm did not assess what's needed to cope with the 'extreme' storm.  It reported the 23 Dec. flood was well below the 'extreme' that has to be taken into account for planning purposes.  The LDP therefore needs to make such flood assessments for all these communities and justify the spending on SuDS schemes (as above) against assessed outcomes.

Street Trees: Reverse VoG policy of not replacing street trees; positive schemes to restore tree-lined streets – Broad St in Barry; Plassey St in Penarth

Street trees help absorb some rainstorm run-off and can be combined with SuDS as in Grangetown to add permeable areas where rainwater infiltrates into the ground, relieving the sewer.

Street trees provide much needed shading during extreme heat waves, making shopping areas pleasant and attractive for street life

Street trees have cooling effect in urban areas during heat waves

People like street trees (they increase property values),

The VoG engineers' claim to require costly root-cages is not borne out in other towns; Cardiff has a positive planting policy, Bristol uses root barriers where necessary at a cost of ~£250 and finds many locations don't need them.

Positive strategy re. Nature Emergency

Countryside tree/woodland planting – develop strategy with regard to ecology and species

Policy to join up the Barry Woodlands SSSI - include extra fields and allow them to reforest.

Management plans for the countryside/woodland SINCs – eg. those of Pop Hill and south of Dinas Powys – joining them up and stopping fragmentation

Green and Blue Country Parks – for tourism and nature conservation

Aberthaw Country Park and Historical Site – to create by combining the existing conservation area in the old Thaw valley and Harbour with the coastal strip between the ash-mound and seawall.

Cosmeston Medieval Village: expansion to include the newly listed Farmhouse and archaeological site of Lower Cosmeston Farm..

Five-Mile-Lane archaeological site – save what's remaining with a proper plan for planting and management; exhibit records in a local museum

Value the Coast as a national asset

# planning for maintenance and improvement of the Wales Coastal Path

# exclude development on the coastal strip except for facilities that need a coastal location - this longstanding principle needs safeguarding in the LDP as it was ignored in allocating development land at Cosmeston.  Defining the "coastal strip" needs including in the LDP in consultation with the public, and taking into account the aim to promote tourism and expand the tourism business.

Reclaim Aberthaw Power Station site

With end of power stations from the 1950s, this complex site must be restored to a sustainable state with beneficial uses.  “Re-wilding” of the old Thaw valley and the ash-mound are well underway. Restoring the beach etc. for public recreation.

The LDP should identify the problems and allocate responsibilities to cover

# the artificial river Thaw mouth, which the sea blocks if not maintained

# the seawalls, ongoing maintenance and coping with increasing tidal surges under climate change

#  possible abandonment of the Gileston beach section of seawall with managed retreat plus new river Thaw estuary.

# ash-mound; assessment of managing its drainage and stability.

# New Rights-of-Way E.Aberthaw to St Athan and W. Aberthaw, using the railway bridges, also maintaining the Wales Coastal Path

# after-uses of the area, including for biodiversity, tourism, culture-historical recording, public access leisure-uses and rights-of-way.   Including conservation organisations in ongoing management

# create a Country Park, as above, for leisure and tourism on the coastal strip and eastern part of the site.

Transport Strategy

# town circular buses in Penarth-Llandough and Llantwit Major areas. Reliance on buses passing through on circuitous routes created poor and inflexible services.

# review active travel networks to meet gradient standards. The present networks discriminate against those with physical disability or mobility limitations, so breach the Council's duty to avoid indirect discrimination against the elderly and disabled.

# funding for upgrades to pavements and walking routes to meet good/high standards; the failure to provide reasonable funds (compared with highway maintenance) is indirect discrimination against the elderly and disabled

# make rail stations into activity hubs; the failure to develop retail and other activities at the Vale rail stations has given us very unattractive locations. Being poorly lit and isolated in evenings makes them unsafe particularly for women, so the failure is indirect discrimination against women.

Town Planning towards net-zero in local transport

WGovt wants public facilities to be located in town centres, to rebuild their attractiveness and facilitate access by walking or cycling. This research by RTPI and others show how to achieve it via positive planning rather than the VoG's laisser faire.

https://www.rtpi.org.uk/research/2020/june/net-zero-transport-the-role-of-spatial-planning-and-place-based-solutions/

 Final Comments:

The intention to proceed with old planning allocations that flout the Climate and Nature Emergencies is a dishonest attempt to continue Business-as-Usual.

This is particularly shown in the Model Farm and Cosmeston developments. The Welsh Government is deeply involved in both, so in no position to give disinterested planning advice. The public sees it as an undemocratic fix that discredits the planning system. So the VoG needs to find a way to openly and transparently review both these allocations. 

Severn Radioactivity Survey after Hinkley mud dumping

 

Report of citizen-science Radioactivity Survey

of Somerset and South Wales shoreline sediments      8^th Dec. 2021

Samples of mud taken under scientist guidance were sent for analysis by the French CRIIRAD laboratory. The results show the spread of radioactive nuclides from reactor discharges to the Bristol Channel is far more extensive and widespread throughout the region’s coasts than previously reported.

The survey was undertaken by members of Citizens Groups from both sides of the Bristol Channel/Severn estuary because EdF, who are dredging hundreds of thousands of tonnes of radioactive mud from the site of the proposed Hinkley C reactors, have repeatedly refused to carry out pre-dumping surveys of the Cardiff Grounds and Portishead sea dump sites where they have disposed of the HPC dredge waste. The survey was carried out in the summer of 2021 prior to the proposed dump at Portishead, but three years after the dump at Cardiff Grounds.

The Citizens Groups recognised that the lack of such “baseline” research meant that no one had any information on the pre-dump status of radioactivity, or of the post dump impacts of the disposal of such vast quantities of radioactivity, on the South Wales and North Somerset coastal environments or the people living on the adjacent coasts and coastal zones.

Speaking on behalf of the Somerset based Stop Hinkley and Welsh campaigns against the radioactive mud dump Marine Radioactivity Researcher Tim Deere-Jones said: “The results of this survey clearly demonstrate that there are serious grounds for concern that the Bristol Channel/Severn estuary coasts and communities had already been subjected to radiological contamination from Hinkley since the 1960s and that EdFs current programme of dumping radioactive wastes at Cardiff Grounds and Portishead should not have been permitted by the Welsh and English Agencies in the absence of the baseline data.”

In Summary the Survey:

# found that shoreline concentrations of 2 radio nuclides (Caesium 137 and Americium 241) typical of the effluents from the Hinkley reactors do not decline significantly with distance from the Hinkley site as Government and Industry surveys had previously reported

# noted that the presence of both Cs 137 and Am 241 are indicators of the presence of Plutonium 239/240 and 241. (These are all listed as fission products discharged to sea from the Hinkley reactors)

# found significant concentrations of Hinkley derived radioactivity in samples from all 11 sites (7 along the Somerset coast and 4 in South Wales)

# found unexpectedly high concentrations in sediments from Bristol Docks, the tidal R. Avon, the Portishead shoreline, Burnham-on-Sea and Woodspring Bay

# found that, along the Welsh coast all samples held significant (10Bq/kg or more) concentrations of Caesium 137 and positive (i.e: not <less than) concentrations of Americium 241

# found that the highest concentration of both radio nuclides was detected at the most westerly of the Welsh sample sites (Splott Bay: Cardiff), which is also the most distant from the Hinkley point effluent outfalls

# concluded that the degree of concentration of radioactivity at Splott Bay, implied a possible impact from the 2018 dumping of dredge wastes at the nearby Cardiff Grounds

# demonstrated that the widely used, official method of analysing samples for only 15 hours was far less precise than analysing samples for 84 hours

# proved that some of the sediment to be dredged from Bridgwater Bay and dumped at Portishead and Cardiff Grounds held well over twice as much Caesium 137 as the sediments around the dump sites, thus risking a localised increase in radioactivity concentrations as a result of the dumping of dredge waste

# proved that the, much repeated, EdF PR statement that the material to be dredged and dumped “is typical of sediment found elsewhere in the Bristol Channel” was false and not even aligned with the empirical evidence provided by EdF itself.

Tim Deere-Jones: (Marine Radioactivity Research & Consultancy) Dec 2021

On behalf of the Bristol Channel/Severn Estuary Citizens Science Radioactive Sediment Sampling Campaign

Contact: timdj@talktalk.net    Tel: 01834 871 011

ADDITIONAL NOTES:

Below, we provide Table 1 results from the Citizens Science project analysis of sediment samples taken from sites increasingly distant from Bridgewater Bay which has been receiving radioactive effluents from the 4 reactors of the Hinkley Point site for over 50 years.

For comparison and discussion, we also provide Table 2 details of Government sponsored annual monitoring of Hinkley sediment radioactivity sediment analysis and additional information on EdFs sponsored analysis of the Bridgwater Bay offshore sediments which were dredged and dumped at Portishead in 2020.

TABLE 1: Campaigners Bristol Channel sediment analyses 2021.

English/Somerset coastal samples

Sample site                          nuclide        Cs 137 (Bq/kg)    Am 241 (Bq/kg)

Stolford mud                                                              9.1                          0.53

Steart mud                                                                  5.1                          0.38

Combwich mud                                                        11.0                          0.60

Burnham/Brue mouth mud                                      12.0                          0.50

Woodspring Bay (mouth of R. Banwell) mud         14.7                          0.81

Portishead (Lifeboat st’n) mud                                11.9                          0.86

R.Avon (Pill ferry slip) mud                                    13.1                          1.50

R.Avon/Bristol Central mud                                    11.3                          0.56

Welsh Bristol Channel coastal samples

Sample site                       nuclide           Cs137 (Bq/kg)      Am 241 (Bq/kg)

Sudbrook mud                                                          10.4                          0.49

Goldcliff mud                                                           10.2                          0.72

St Brides lighthouse mud                                         11.8                          0.70

Splott Bay Cardiff mud                                            12.7                          1.10

Comment: It is evident that 83% (10 of 12) samples, including those most distant from the Bridgwater Bay/Hinkley Point effluent discharge, hold in excess of 10 Bq/kg of Cs 137 and in excess of 0.5 Bq/kg of Am 241. These results are in marked contradiction to those produced by the official 15 hour gamma counts, which all imply a steady, and significant decline, with distance from the Hinkley Point discharge points.

It is clear that the 84 hour counting time gamma spectrometry commissioned by the Bristol Channel Campaign has generated more precise Cs 137 and Am 241 outcomes than have other gamma spectrometry analyses carried out by Government agencies on behalf of EdF.

It is also clear that the 84 hour count has reduced the lower limits of detection for Am 241 and generated “positive” results for Am 241 in all Campaign samples as opposed to the <less than results reported for all RIFE samples in Table 2

TABLE 2: Government/Industry sponsored RIFE sediment sampling (RIFE-26: 2020 latest available data)

Sample site                  nuclide    Cs137 (Bq/kg)        Am 241 (Bq/kg)

Pipeline sediment                                      50                              <1.30

Stolford sediment                                      9.3                              <1.30

Steart Flats sediment                                 7.2                              <0.78

River Parrett (estuary) sediment                14                               <0.84

R. Parrett (B'water town) sediment           7.9                              <0.90

Burnham-on-Sea sediment                        0.75                             <0.49

Weston-Super-Mare sediment                   2.4                               <1.20

Commentary

N.B. We note that the RIFE sediment sample taken from the site named “pipeline” is remarkably high compared to recent years data: not since 1997 has Cs 137 concentration in sediments from the near Hinkley samples exceeded 50 Bq/kg. RIFE -26 has failed to discuss this analytical outcome and makes no attempt to offer an explanation for the very large year on year increase from around the upper “teens” which has been the norm for the last decade. However RIFE-26 does report that HPB suspended power generation in June 2020 to undertake “extensive inspections and maintenance operations”. It would be interesting to know when this sample was taken (before or after the suspension of power generation).

However, The RIFE sediment analysis results for 2020 are mostly representative of RIFE work over recent years. Only 2 of the 7 samples (43%) analysed by RIFE in 2020 had Cs 137 concentrations of 10 Bq/kg or above. All of the samples were recorded as having < less-than concentrations of Am 241.

Compared to the results of the Citizens Science sample analyses (Table 1) the RIFE results are anomalously low. We propose that this is a function of 2 flawed aspects of the official sampling and analytical methodology:

1: The short “counting time” (15 hours) of the RIFE agreed gamma-spectrometry methodology which, according, to a number of peer-reviewed academic reports, does not produce the most precise or accurate radiological data.

It is clear that the Table 1 longer “count times” provide notably lower Am 241 <less-thans than the Table 2 outcomes. When the shorter count-time methodology has been used, there are no “positive” results for Am 241, and the overall outcome has provided no usable or representative data for that nuclide. We note that many observers treat such outcomes as implying negative/nil Am 241 concentrations in the samples thus described.

Similarly, the RIFE Report’s low (and declining with distance from the HPC site) reported concentration of Cs 137 may also be attributed to the short count time. In that context, it is possible that the RIFE maximum Cs 137 results would be higher, had a longer “count time” been used.

We conclude that it is evident that the analytical methodology used by Government Agencies to produce RIFE radiological data over many decades has provided the public with incomplete and inaccurate data.

2: The RIFE reports provide only the descriptor “sediment” of the samples. In marine science terminology “sediment” is a broad term used to define “natural unconsolidated granular material with sediment density greater than water”. This term thus includes anything from very fine silt/mud material through to pebbles and cobbles. There is a very broad scientific consensus that higher concentrations of these radio nuclides are closely associated with the increased presence of fine particles, while lower concentrations are found in association with coarser particles.

Our review of technical data on the sedimentology of the Inner Bristol Channel and Outer Severn estuary confirm that the vast majority of the regional inter-tidal zone is composed of fine sediments and that these are therefore most representative of the sediments likely to hold highest concentrations of man-made radioactivity. We propose that the low (and declining with distance from HP) concentrations of Cs137 and Am 241 recorded by RIFE may be a function of poor choice of sediment sampling sites and that sites chosen for RIFE sampling produce mixed grain size sediments (added sand shingle etc) rather that high % of fine sediment “mud” or “silt”

In this context it is postulated that the lower Cs 137 concentrations reported by the RIFE (Table 2) report are a function of the presence of coarser sediments in the samples which are poorly described and do not consist of only the finer sediments. We conclude that RIFE reporting is indicative of poor methodology and does not provide either an accurate, or a conservative description/quantification of the radiological status of regional and dump-site adjacent sediments.

Note that the RIFE Report’s sample analytical outcome for Cs 137 at Burnham (0.75 Bq/kg) in a sample, described imprecisely as “sediment, is also clearly anomalous in comparison to our Citizens Science Cs 137 outcome for its Burnham sample (12 Bq/kg), precisely described as mud. This represents a percentage increase of 1,500%. We conclude that the official RIFE methodology is a further example of a combination of poor site (larger sediments) and short count times.

We conclude that it is evident that the analytical methodology used by Government Agencies to produce RIFE radiological data over many decades has provided the public with incomplete and inaccurate data and left coastal zone communities in ignorance of the long term radiological exposures from contact, diet and inhalation doses they have been receiving from marine radioactivity.

3: We further note that the shoreline “surface” (0 to 5cm deep) sediment sample outcomes of the RIFE and the Campaign surveys are both dis-similar from the outcome of EdFs 2020 radiological analysis of Bridgwater Bay sediment cores from the Cooling water intake and Effluent outfall areas where dredging is necessary. In summary, EdFs 2020 data on the gamma analysis of 23 deep core (0 to 5.6 metre) samples of Bridgwater Bay sediment from the dredge area, presented by CEFAS on behalf of EdF, shows the following:

Cs 137 concentrations in the surface to 0-5 metre subsamples of 15 sediment cores (65% of 23) exceeded 10 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 12 sediment cores (52%) exceeded 15 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 10 sediment cores (43%) exceeded 20 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 8 sediment cores (35%) exceeded 25 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 4 sediment cores (17 %) exceeded 30 Bq/kg,

These sample sets were from both the “outfall” and “intake” dredge sites. The maximum Cs 137 conc’ recorded was 34.8 Bq/kg. REF: “TR533 and TR534 Radiological Assessment of Dredging Application for HINKLEY POINT C (2020).” CEFAS: Part 1 and Part 2.

It is clear from the above that the samples referenced hold two to three times more Caesium 137 than the shorelines samples tabulated in Table 1 and Table 2.

It is also clear from the above that the, much repeated, EdF claim (made in respect of dredge sediment disposal at Portishead) that “The sediment is typical of sediment found elsewhere in the Bristol Channel” is deeply inaccurate, based on an un-evidenced EdF assumption and not even aligned with the empirical evidence provided by EdF itself.

We conclude that the EdF commentary is inaccurate and based on a total lack of Bristol Channel wide data. We conclude that the EdF statement should NOT have been made as it is clearly yet another major mis-representation of the true radiological status of Bristol Channel/ Severn estuary environments distant from Hinkley Point

………………………………………………………………………………………………………

Tim Deere-Jones (Marine Radioactivity Research & Consultancy) for Bristol Channel/Severn Estuary Citizens Science Radioactive Sediment Project: 02/11/2021