Petition P-05-785 Suspend Marine License 12/45/ML
Comments
on NRW response of 27 March, from Friends of the Earth, Barry&Vale.
We formulated a briefing earlier, on
the basis of our FoI request to NRW for all documents relating to this license
application held by them. We are
therefore confident that we have viewed most of the background material. We enclose that briefing for use of the
Committee and add the following re the latest NRW letter to you.
Contrary to NRW we see the Sampling of sediment as not primarily for public reassurance, as stated, but
to meet licensing requirements. Sampling
at depth, as the Committee requested, is likewise needed to meet licensing
requirements: Licence Condition 9.5 requires satisfying NRW that the material
is suitable for deposit at the site.
1.
The applicant’s refusal of deep samples is unacceptable.
It depends on NRW’s statement
“there is no scientific basis for any additional sampling” which is
false. The Committee were wrongly told earlier there is no scientific evidence of
higher radioactivity in deeper sediments in the Hinkley Point area. (as on the NRW website). The
evidence is clear in the 2009 data for U238 and Radium, as in the reduced Table
below: the numbers show 3 out of the 5 samples were significantly higher at
depth (up to 3x for Radium - Ra).
2. No
specialist/expert assessment by Welsh authorities
"we consulted
Public Health Wales and NRW’s own internal expert in relation to the dose
analysis results"
No report is provided (no transparency); this sentence refers only to the radiological dose, not to the chemical constituents.
No report is provided (no transparency); this sentence refers only to the radiological dose, not to the chemical constituents.
3. The de
minimis criteria are for disposal at sea.
The IAEA-TECDOC-1375 defines this
to include well-mixed near-coastal waters
“The
disposal is assumed to take place a few kilometres off the coast so the actual
shape of the coastline does not influence the dispersion significantly.”
The Severn
Estuary site is not “sea” , but estuarial water with distinct
circulation and ecology, which does not satisfy the IAEA criterion.
4. Disposal in
the Estuary requires information on dispersal of the radioactivity and use of
a habits survey to calculate collective dose.
Cefas use a habits survey from the Cumbrian shore for sea-food consumption
and beach-combers/recreation. The Severn Estuary is very different and sea-land
transfer potentially much stronger.
5. the NRW
letter does not cover the chemical contaminants, though they are required to
assess their impacts. Their Website
says: Chemical contaminants were assessed against Cefas Action Levels[2]
UK guidelines to assess dredged material and
its suitability for disposal to sea. Several
metal and organic contaminants were measured as above Action Level-1, yet no
assessment has been made by NRW.
6. CEFAS say Dredged material with contaminant levels
between Action Levels 1 and 2 requires further consideration and testing before
a decision can be made.
The documents
show no further assessment – which of course must be against the
characteristics of the dump site and conducted under criteria relevant to
it. For this European “Special Area of
Conservation”, criteria from biodiversity/Habitat legislation obviously come
in, but none have been considered. The
end-fate of the contaminants must also enter, requiring consideration of the
cited studies on deposition on the estuarial mud flats and transfer to marine
life and to the land.
7. The Licence conditions 9.5, 9.11 require that the sediments are suitable
for deposit and that dispersal via re-suspension
should be avoided. It’s not
shown how this could be done in practice. Discharge is planned by
dropping from the barge, but the only way to ensure “deposit” of the bulk of
the material is to discharge via pipe to the sea bottom at tidal extremes and
minimising re-suspension requires cover with heavy material before inter-tidal currents
become strong.
9.5. The Licence Holder must
ensure that no material is deposited after 4th March 2016 without written
confirmation from NRW, acting on behalf of the Licensing Authority, that they
are satisfied the material is suitable for deposit at site LU110.
9.11. The Licence Holder
must ensure that best practice is used to minimise re-suspension of sediment
during these works.
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Data for U238 and Radium
in 2009 samples taken at depth
3 out of the 5
samples were significantly higher at depth (up to 3x for Radium - Ra). The NRW failure to require deep samples means
only the 2009 data are representative of the bulk of the material to be
dredged. As there are so few data, the
maximum plus a safety factor has to be adopted.
This raises CEFAS’s 5.8 μSv/yr calculated level, potentially to above the 10 μSv/yr limit.
Table B.15
Uranium-238 and Radium-226 concentrations for Vibro core samples (also in [1] Appx B)
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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