We are one of FOE's local groups, organised like other groups in Wales through FOE Cymru, whose office is in Cardiff - Castle Arcade Balcony, tel 029 20229577. Contact us, Barry&Vale FoE via greenkeith 'at' virginmedia.com, tel. 07716 895973

Wednesday, 29 August 2018

Toxic mud dumping to start 6th September

Stop Press:    DUMPING DELAY 
  likely to begin next week from Monday 10th Sept.

The Cardiff Habourmaster has announced that two dredger-barges MV Sloeber and MV Pagadder will begin dumping next Thursday, daily for 3 to 6 months.  The operator  Marine Co-ordination can be contacted on 07936 335247.
Penarth Daily News has discovered that the 300 000 tonnes is to be followed by further dumping in 2020.
NRW who awarded the license have suddenly accepted (letter to FoE of 29 August) that there had been no EIA (Environmental Impact Assessment) or HRA (Habitats Regs Assessment) by the company, as they had previously stated.
But no matter, they now say
"an EIA was not required", and
"we did undertake an HRA as part of this licence determination"/
Are we expected to believe them, changing their position and saying there's been another study that was previously undisclosed, not posted in their License file?  Their rules say EIA is alwys required for works in a European-designated Conservation Area.
The only document called HRA is a pro-forma completed in 2013, prior to rules updated in 2015. That outdated document is not with the key documents on the NRW website.  Of course, FoE immediately asked for disclosure of a copy and the NRW referred it through their slow (20 working days) system for information requests.

 

Friday, 24 August 2018

Hinkley Mud sends EdF bananas

EdF try to excuse their radioactive mud by comparing the gamma-radiation to that from eating 20 bananas.
They also use airline pilots and radon-homes as comparators in their statement to the Senedd .  They doubtless use these hoary old arguments because they have not met the real international standard for dumping at sea (see FoE Brief).

What's wrong with the banana argument?  Bananas contain potassium, with the tiny fraction of radio-potassium (0.01%) as throughout the environment.  The human body needs potassium - contains far more than from 20 bananas - but quickly excretes any more than it needs. Eating bananas adds nothing to the body burden.  Radio-carbon, as in all foods, contributes more to damaging the body's cells in emitting beta-radiation. Radiopotassium has fewer emissions but of gamma radiation which very largely passes out of the body, like X-rays.

Airline pilots are at risk from cosmic radiation; they choose to take that risk and are paid highly for it. Homes in radon areas are fitted with measures to disperse this radioactive gas filtering through the rocks, which otherwise filters into homes and causes comparable risks to tobacco smoking.  For EdF to impose the risk on everyone who uses local beaches, eats local food, or simply breathes in microparticles from sea-spray is quite different.  Individual risks may be small, but international regulation sets a limit on the "collective" risk to the population.

A second point is the failure to assess the total harm to humans.  The main damage is not from the gamma rays that pass through us, but from inhaled and ingested  nuclides which emit alpha or beta radiation. The nuclear industry assesses gamma-equivalent dose, as in the ICRP standard, but this has long been disputed. The Government's Cerrie committee on internal radioactive emitters, reporting in 2004, established significant science behind internal emitters.  Its minority report led to alternative ECHR standards, but nuclear interests have refused to take these up in the IAEA standards - these still cover simple gamma-radiation alone.  Alpha and beta emitters must however be taken into account in specific assessment of the harm from Hinkley's mud, as the radionuclides are taken up in marine life and by humans around the Severn Estuary.  The radium measured in the deep mud samples is an alpha emitter, causing damage at the cell-level - the radium-girls painting luminous dials are the famous example.  The Wales-based Low Level Radiation Campaign has longstanding expertise in this area, proceeding from the Cerrie findings.

EdF's claim 
"an infinitesimally small level of exposure to radiation, far below the threshold requiring a more detailed assessment or even close to approaching a radiation dose that could impact human health or the environment"
is obviously false, even on IAEA/ICRP standards.  The gamma-exposure of dredge workers was calculated at 5.8 uSv/yr, which is only marginally below the IAEA limit of 10 uSv/yr.  These numbers alone are close enough to require that the deep mud is sampled to international standards and the 5.8 figure revised upwards.  Then compliance with international standards requires the "detailed assessment" they want to avoid by the banana argument.

  

Thursday, 23 August 2018

Hinkley mud - how NRW ignored international science-based asseessment

Why we can't "trust the regulator", NRW - they have disregarded the international agreements on detailed guidance from OSPAR (2014) and the expanded updated IAEA guidance (2015). OSPAR gets no mention and NRW's advisors CEFAS use guidance from 2003 that was superseded in 2015.
The IAEA Table below has five criteria: NRW's experts CEFAS find the first is met, but marginally; for the second CEFAS wrongly take the discharges to disperse as in Sellafield's discharges to the Irish sea, so far underestimate uptake of radioactivity by fish and exposure of beach-users. The three other bio-criteria - newly included in 2015 - were just ignored by CEFAS and NRW. NRW provides the 2017 CEFAS report which explains "Under the London Convention of 1972, only materials below de minimis levels for radioactivity may be considered for disposal at sea. The IAEA describes a generic procedure for calculating individual and collective doses that could arise from the disposal of candidate material at sea (IAEA, 2003; 2004) which has then been adopted for use in the UK using the procedure described by McCubbin and Vivian (2006) ... used to assess the sediment samples as safe for disposal at sea:  
consumption of fish, crustacean and molluscs as near the sea in Cumbria; also dirt ingested by the public active on the beaches".
Proper assessment in their scientific terms required CEFAS to conduct a 'habits survey' of sea-food consumption and beach use around the Severn Estuary, and to assess the amounts of contaminated sediments and spray coming ashore in our much more highly populated area. Quite a task, so NRW didn't require EdF to fund it and CEFAS covered up with "more detailed case-specific assessment is not necessary" while ignoring the fact that the public's collective dose (second criterion) could not be calculated without an assessment relating to the Severn Estuary. 
As the caption to the above Table says, these are not just IAEA guidelines (International Atomic Energy Authority) but have been adopted by IMO (International Maritine Organisation) to implement the "de minimis" concept. By ignoring the 2015 expansion of "de minimis" criteria, CEFAS fail the international criteria; NRW should of course have checked and picked up this failure, but didn't.  
The IMO 2015 document explains: 
"For candidate materials containing artificial radionuclides (other than from global fallout that is referred to in Step 2) and/or altered natural radionuclides stemming from human activities, the national permitting authority should consider previous decisions and action taken by the national radiation protection authority....The pertinent question in such cases is whether the decisions on exclusion, exemption, or clearance were made considering marine environmental pathways of exposure to humans and to marine flora and fauna and whether these are suitable to an assessment of the proposed dumping operation. If this is the case, the materials are de minimis."
This blocks the excuse, common to UK regulators, that the basic licensing decision had been taken under the old (2003) IAEA rules, so the 2018 decision can avoid using the 2015 rules. The NRW have not offered this excuse so far; if they and CEFAS were aware of the 2015 rules, they apparently decided not to draw attention to their failure to use the 2015 definition of de minimis..
The 2014 OSPAR Guidelines for management of dredged material at sea set the standards for sampling and assessing the Severn Estuary dumping site, and it specifies points to be included in a license. These will be detailed in a separate blog-post. NRW has a duty to follow these guidelines, but show no evidence of doing so, simply inventing their own criteria, taken from previous dumping practice.

Sunday, 12 August 2018

Dumping postponed of Hinkley's toxic mud

The dumping of radioactive mud a mile offshore from Penarth and Cardiff has been abruptly postponed – less than a week before the operation was due to begin .

Hinkley nuclear station builders had notified the start for this week 
Dumping would last 6 months, with some 300 000tonnes to disperse up and down the Estuary.  Penarth’s beach (lowest reaches) receives mud around low tide, so is the obvious first place for the mud to accumulate.  Both the Welsh Labour Government and Natural Resources Wales claim the mud is “safe” – that claim is hotly disputed by Friends of the Earth on the basis of data in NRW's own report (by CEFAS).  Toxic metals breach “Action Level 1” while gamma-radioactivity verges on the no-sea-dumping limit.

Tests of five deep mud samples are fewer than the international minimum.  The anti-dumping law (London Convention and Protocol) requires a specific assessment of the potential adverse impacts to the marine environment including effects upon human health and to marine flora and fauna. The normal Environmental Impact and Habitats Regs Assessments under UK law failed to cover the dumping in Welsh waters; NRW was wrong to suggest these covered our marine environment and asre breaching the anti-dumping law.

Campaigners challenge the Welsh Ministers’ failure to comply with the international agreements (OSPAR, London Convention) and to meet their Marine Act duties. We further challenge NRW for failing to comply with the Environment (Wales) Act 2016 and a precautionary approach.

Sign the Petition  to Welsh Government:  Halt the dumping of Hinkley mud in the Severn Estuary

Wednesday, 8 August 2018

Hinkley Mud Dumping - meeting/protest @ Eisteddfod

Protest Meeting in Cardiff Bay THURSDAY
  the Cafe-Bar is close to the top of Roald Dahl Plass: 36 James St.  CF10 5EY 
  close to Butetown Police Station and the no.89 bus stop
Very convenient after your visit to the Eisteddfod in and around the Millenium Centre
  (apologies that the meeting room is up one flight of stairs)

All Welcome
 Neil McEvoy  AM  who took the issue through the Senedd
 Richard Bramhall   rep. of Low Level Radiation Campaign
 Max Wallis   Friends of the Earth  Barry&Vale
Richard is also chair of the revived Wales Anti-Nuclear Alliance