Severn Seabed mapping of humped material - NRW in denial

The Cardiff Grounds dump-site (LU110) normally disperses dumped dredgings in the strong currents, but the Titan survey identified a lot of mounds on the seabed around a metre high and 30 metres across. Their radar survey was carried out 6 months post-dumping from the huge Pagadder and Shloeber barges of Hinkley material. As the site is supposed to be a dispersal site where material is swept away in the strong currents, NRW asserts the site is “sustainable” as the material would “disperse over time”. They also claim the sea bed has not been raised on the average, though Titan’s mapping shows it’s generally higher.
A third claim by NRW is that it’s impossible to attribute the left-over sediment to Hinkley.

Penarth Times report 10 September 2020

Here is one of Titan's detailed images - seabed height differences between the April 2019 and 2018 surveys

The images show a series of four discrete disposal events along a transect (“Transect 01”), with each disposal identified as two parallel lines of deposited material (i.e., accretion), consistent with material being released through the hopper doors of a dredging vessel.

To the left is Titan’s result that implies accretion (orange) through much of the area as well as the mounds showing recent dumping. to the right is NRW’s favoured adjustment that implies the area has generally eroded (white to blue), except for the humps. This 'adjustment' comes from moving up the zero by 24cm. This picture shows that though an adjustment be a few cm is possible, 24cm is implausible. The mounds would be expected to spread and raise the adjacent levels.

Elevations were also depicted by Titan's Figure 7:


It appears that these parallel mounds did not spread much laterally in the 6 months post dumping, except for the right-most trail where the left side slumped into the depression.

Grab-samples of the seabed were also collected by Titan. One sample taken happened to be quite close to the lowest of the 4 trails (upper picture); it has an extreme composition of 95% mud and is characterised as “very poorly sorted”. The sample point (S4) happens to be along the parallel trail and within about 30m of the metre-high mounded material. It’s highly likely to come from Hinkley, not from a shipping channel dredger.

The Titan report is in no doubt that they see deposition in the April 2019 survey compared with the pre-dumping survey in 2018. They looked carefully into the zero-ing uncertainty, settling on 8.5cm. The NRW's 24cm on top of this implies erosion of the seabed in the area of the mounds. They are in denial not just that the mounds are Hinkley material, but also that much of the dumped material could have remained in the dump site.

Severn Seabed Survey shows heavy Hinkley materials

Seabed surveys before and after dumping were required under a Licence condition. The report  was issued quietly in July 2020 following an April 2019 survey and much revision (8th Edition). Released after a Freedom-of-Information request by Barry&Vale FoE    https://publicregister.naturalresources.wales/Search/Download?RecordId=34343 

Titan Environmental Surveys Ltd conducted a bathymetric survey and collected some grab samples between 3rd and 12th April 2019.  The 12 samples were analysed for sizes, from clay to gravel. compared with pre-dumping levels the samples showed both coarse gravel and clay remained from the dumped material. 

Titan Explorer surveyed the seabed of Cardiff Grounds dump-site in April 2019

The bathymetry – depth measurements from the vessel - mapped the heights of the seabed compared with pre-dumping heights. Titan found problems in that the total increase was greater than the volume dumped.  They found an antenna offset and corrected for it. But this was not enough, so CEFAS invented a further fudge (3 times as big) which reduced the total amount remaining on the seabed to 103 cu m (compared with 58 000  cu m dumped).  Incredible!

The bathymetry differences pre/post-dumping are shown below.  The red spots show mounds about a metre high and 30 metres across, each might contain 50-100 cu m.  The Titan survey links the pattern to trails of the dumping boats.  The distribution of the spots shows the dumpers avoided going close to the eastern limit of the triangle, but also avoided the top of the triangle and the western apex.  The licence prescribed that EDF must dump evenly over the dumping ground – to avoid building up banks – which they failed to do.

Difference map of seabed pre/post-dumping
North is to right, West at top.  The lower left (blue) corner shows erosion.
The spots (red) around 1-metre high are identified in more detailed maps as dump trails (east-west).

Thus even after 6 months of the stormy winter weather 2018-19, the claim by NRW that dumped materials would simply disperse in the strong currents is shown to be untrue by both the sampling and the bathymetry.  NRW’s error stems from their equating ‘capital’ dredge with port maintenance dredge, because the Cardiff Grounds site was classed as a dispersive dump-site to take port and shipping channel dredging. 

Much of Hinkley’s capital dredge removes consolidated or hard stuff (clay, pebbles, cobbles etc) whereas as maintenance dredge removes short term, mobile soft sediments.  International rules (OSPAR) say solid material should be separated and not dumped at sea, but NRW insists on classifying all as port dredgings and reports them to OSPAR as this.

Penarth Esplanade Parking proposals

Comments/objections on Parking proposals for Penarth Esplanade ref. IF733,  submitted to Vale Council (c1v@valeofglamorgan.gov.uk)

We want these proposals changed, primarily to remove parking adjacent to Beachcliff to free the street-space for al-fresco eating and snacking away from car-fumes and to allow unobstructed sea-views.  The 2-hour limit to apply only in the summer season.

• extra disabled parking is welcome outside Alexandra Court (past the bus-stop); do apply the 2-hour limit to all the disabled parking. Carry out an Equality impact assessment to see if more of the 2-hour parking should be reserved for disabled persons.
• remove parking in front of Beachcliff for the chip-shop, wine-bar and restaurant (when it re-opens), to make permanent the use for outdoor tables and sea-views unobstructed by cars. Only unloading and trades-parking allowed at the south end.
• guarantee wardens will check the 2-hour limitation during weekends and busy times
• apply the 2-hour limit only in the 'season' April-Sept., to save the costs of parking wardens at slack times.
• reduce the 'no-parking' on the east side of Cliff Parade, from the entrance to no.7 southwards, which was needed and used without undue problem when the Council closed the car-park and does not impact on the residents of the brash new fenced-off house.
• extend the 2-hour parking up the straight part of Beach Rd, east side, which has been used in the past without problem and without enforcement to stop it, for say 50m instead of 24.0m
• agree that parking outside the Italian Gardens will be suspended on high-summer days, to allow busking and informal street activities.

Beachcliff Winebar, to the right of the Chip-shop, both taking up car-parking space post-Covid

Changes in words at: penarth.nub.news/n/changes-to-parking-proposed-at-penarth-esplanade-by-vale-council

Penarth Town Council's post-COVID traffic plans - unwanted and unacceptable

Friends of the Earth Barry&Vale oppose Penarth Town centre traffic and parking changes

www.penarthtowncouncil.gov.uk/ptcmedia/uploads/20.08.03A-Town-Centre-Proposals-Amended-for-PTC.pdf

Encourage and facilitate street-trading - via partial pedestrianisation - yes!

But no to the drastic 1-way traffic changes and crammed car-parking.

Disabled parting in lower Glebe St - yes - but with sufficient spacing.

The Active Travel (Wales) Act requires priority in any new scheme for walking and cycling. A traffic scheme motivated to maximise parking is out of sync.  Though not the highways or planning authority, the Town Council should be aware of the transport policies of the VoG Council and WG, especially the latter’s guidance on active travel, and therefore indicate how to include cycling priority in their plan. The parking and one-way ring road proposals appear to ride roughshod over the Vale’s Active Travel network plans agreed with the Welsh Government.  They pay no regard to “walkable neighbourhoods, where a range of facilities are within walking distance of most residents, and the streets are safe, comfortable and enjoyable to walk and cycle.”  

The Well-being of Future Generations Act requires planning for sustainability, which excludes any increase in car-parking. No justification is given for replacing the on-street parking lost under pedestrianisation.  Parking places have already been lost due to Covid measures, but there are still many vacancies.  Nobody can foretell the post-Covid ‘new normal’, with more shopping on-line and increased readiness to walk and cycle for health and fitness.  The WG offers funds to increase the attractiveness of active travel; try that first and wait to see how things work out before trying any disruptive schemes.

A one-way traffic scheme of necessity forces longer vehicle journeys, with noise air pollution and CO2 emissions as direct effects.   Further, in deterring some walking and cycling trips, the one-way scheme has indirect effects that may be as large or larger.

Any planning has to recognise existing walking and cycling routes and links to them. 
1. Penarth Haven (Pont-y-Werin bridge) –Paget Rd – Arcot St  - Hickman Rd – Penarth Station – Railway path  (National Cycleway Route 88)

2. Cardiff  Bay Barrage –Paget Rd – Clive Place (or Albert Rd) – Beach Hill – Esplanade (Wales Coastal Path) and Stanwell Rd – The Railway

3. Pont y Werin to Penarth centre via Windsor Rd - Plassey St to join Arcot St route, or to the end of Plassey St to join the Albert Rd route to the Esplanade.

Windsor Rd from the Plassey junction through to the Esplanade and route 2. to the Railway are current 5yr projects in the 2017 map of the  Penarth Cycling INM Network https://www.valeofglamorgan.gov.uk/Documents/Our%20Council/consultation/Active-Travel/Penarth-CYCLING.jpg  Windsor Rd and Albert-Stanwell Rd are routes in the 2017 map of the  Penarth Walking INM Network.  Converting Albert and Stanwell to parking streets with chevron parking contradicts the Vale Council’s active travel plans, required in the Act and agreed with Welsh Government.  Bridgeman Rd is likewise designated a walking route. Increasing the traffic by the one-way system may increase pollution and worsen safety, requiring these to be taken into consideration.

The Windsor Rd route passes through the section proposed to be pedestrianised. 

The Town Council’s plan fails to say whether cycling is to be permitted in it. If you propose to divert it via the one-way traffic ring, you have to address the conflict with Active Travel policy.

We are not aware of any problems with cycling in the shopping streets.  Occasional cycling the ‘wrong way’ on wide lower Glebe St will be resolved if pedestrianised. 

We support pedestrianisation as long as cycling is permitted for access to shops etc.

The WG Active Travel guidance advises two-way cycling on 1-way streets “wherever safe and practicable”.  Contraflow cycling up Stanwell Rd and Albert Rd needs to be provided, both for trips to the town centre and for the local cycling network.  It has priority over changing parking to chevron-style.

The proposed chevron parking does not provide for larger vehicles, neither in width (all spaces are the minimum 2.4m, 2.7m is becoming standard) or length (4.8m). Unless a 1-metre buffer is provided as in Arcot St, protruding vehicles present a hazard while policing the parking to stop them is not easy.  2.4 m leaves to little space for frail elderly stick-users and wheelchair users.  If this minimal cramped chevron parking is excluded, the claimed advantage in cramming in more cars becomes much less.

Allowing buses on the Stanwell Rd-Rectory Rd route is important for bus operation.  Waiting time at the Windsor Terrace terminus with driver access to the public toilets is needed. More bus stops are needed to encourage sustainable travel to the centre.

• one at lower end of Windsor shops (or outside the RAFA club)
• unofficial stops in Plassey St (for 89) need to be in plans, at Glebe St and High St junctions; these need build-outs (removing parking places)
• the stop at bottom of Clive Place needs a build-out.
• the terminus stop on bottom of Albert Rd needs to take 2, occasionally 3 buses and a big bus-shelter
• the first Stanwell Rd stop should be at the Rectory Rd corner, close to the Library.

Blocking half the 'clock' roundabout for unloading and pick-up is unacceptable.  Emergency and other vehicles need passage, while the 88 bus turns around it. 

Equality Act discrimination.

Despite the Town Council claims to make Penarth ‘disabled-friendly’, no consideration is given to contrary aspects of these plans.  The over-narrow echelon parking replaces roadside parking suitable for disabled persons. Buses less accessible with bus-stops on slopes making boarding difficult for disabled persons.  The proposals discriminate against women as cyclists as Planning Policy Wales considers women are more likely to be deterred from cycling by perceived dangers of cycling on the one-way high-traffic ring.

Hinkley nuclear station: NRW sampling approval just issued

   Halt the Dumping of Hinkley Mud in the Severn Estuary

NRW in their Position Statement** now admit there was leakage of nuclear spent fuel in 1969 into the spent-fuel cooling pond and that Magnox were convicted of not maintaining the effluent filters on liquid discharges from the ponds.

The effluents included plutonium and EDF have now agreed to use alpha-spectrometry to assess the sediments for it.

NRW and EDF repeatedly refused this previously, claiming gamma-spectrometry was adequate.  Neil McEvoy AM was ridiculed for demanding it and the Environment minister accused critics of “scaremongering” over nuclear contaminants in the Hinkley mud.

A virtual meeting of opposition groups on 15 June received a presentation Prof. Keith Barnham of Imperial College, with his evidence on Hinkley Point's plutonium discharges in the 1970s and 80s.

Friends of the Earth Barry&Vale are opposing the mud dumping both on the basis of nuclear contamination and also that sea dumping of construction of materials is banned under international treaties to which the UK is committed.  In this case, EDF could use or dispose of the excavated material on their huge construction site, so cannot argue an exception.

    Max Wallis of the FoE group says: “the NRW are clearly wrong to ignore this basic ban on sea-dumping by declaring it ‘out of scope’.  Welsh politicians need to tell NRW that we have the power and the duty to apply the international ban on dumping in Welsh seas.  End of.”

** for more on NRW’s  Position statement, see  Halt the Dumping of Hinkley Mud in the Severn Estuary 

NRW requirement on Plutonium sampling using alpha spectrometry reads:

8.   The chosen sample location for plutonium should be explained. Clear justification on the number of stations in relation to risk will need to be provided. In addition, each core chosen for such analysis will require subsamples to be taken from all depths.  Alpha spectroscopy will be used to determine the plutonium (Pu-239+240) and americium (Am-241) isotopes. Alpha spectroscopy will be undertaken on cores which are also used for the gamma spectroscopy in line with ISO 185891, to enable direct comparison of results from each analysis.

After contamination by nuclear fuel-element ruptures in 1969 etc., the cooling ponds were emptied to sea over many years (the license limited the total radioactivity released) till 2014. For many of these years, the filters were not maintained, so potentially letting through radioactive particles.   NRW's answer given to the NFLA objection says:  

The Environment Agency is aware of an incident in the R1 fuel pond in the late 1960s which led to a release of fission products into the pond. The pond has now been treated and emptied of effluent and sludge.

 Discharges are matter for Magnox Ltd, but the Environment Agency is aware of these historic events that may have led to higher levels the Hinkley Point A pond excursion in the late 1960s. The EA also prosecuted Magnox for poor maintenance of effluent filters at Hinkley Point A (and Bradwell) in June 2001. They (Magnox Electric) were fined £100,000 plus £28,000 costs.

NRW refuses to disclose the Cardiff dump-site Licence

NRW refuses** to disclose the Licence they hold for the Cardiff Grounds dump-site.

NRW are the WG’s marine licensing authority, yet say FoE have to go to the Welsh Government for the licence (dating from the 1980s).  

FoE believes the licence applies for sediments from dredging ports and shipping channels and does not permit dredgings from the capital works at Hinkley Point.  NRW refuse to disclose the licence because it would show they ignored it for the previous dredging campaign.

NRW fail to require EDF to show why they seek to dump a further 600,000m³ (840,000 tonnes).  This volume is more than twice the original demand, on top of the original plan. There is no planning permission for this extended 'dredging'.

Nor do NRW report on compliance with the dumping license issued to EDF.  A condition was placed on the previous dumping that material be spread throughout the dump-site, to avoid mounding of the clays and gravels.   We think they failed to spread it evenly and dumped material outside the limits of the dump-site. 

MV Sloeber opening its bottom to dump Hinkley mud on 16 October 2018.
It was caught with its bottom opened (sh***ing) outside the dump site.

The NRW allowed EDF to submit a Summary of Dredging Campaign 2018-19 that fails to meet quality requirements for reporting and specifically the international OSPAR requirements.

NRW told everyone that they met all the international licensing requirements on sea-dumping last time.  They did not.  They ignored the 2014 IMO guidelines that require them to minimise sea dumping, and expect to do the same again. 

The 1972 London agreement stopped sea dumping, with some exceptions for dredging operations.  The Protocol added in 2014 tightened  the requirement to reuse dredged material on land.  NRW are still in the dark ages, believing that sea dumping is the first choice.

## Hinkley Mud: NRW flouts licence rules gives FoE's detailed response to NRW's proposal ##

 -------------------------------------------------

** NRW Refusal

On Tue, 11 Feb 2020 at 12:27, Marine Licensing <marinelicensing@cyfoethnaturiolcymru.gov.uk> wrote to Friends of the Earth Barry&Vale

Thank you for your email to Mr Evans. As part of a pre-application request the Marine Licensing team has received the proposed sample plan from EDF for further dredging at Hinkley Point C construction site. This will help us understand whether the material can be deemed suitable for disposal at sea. We have not received a marine licence application from EDF. The consultation we are running is to provide members of the public with the opportunity to express their views on the suitability of the submitted sample plan and this will inform our pre-application response. 

As with regards to your question of the operating licence for Cardiff Grounds; this disposal site is ‘designated’ by Welsh Government and further information on its designation should be requested from them. The area has been used since the mid-1980s and each marine licence application for disposal at the site is assessed on its own merits. 

Regards,  Maria

   Trwyddedu Morol/ Marine Licensing

   Cyfoeth Naturiol Cymru / Natural Resources Wales

SUCCESS! Council comes out firmly against Biomass Incinerator

 All but one of the Vale of Glam Councillors voted on Wed. 27^th to

1 Share public concern that no EIA was ever done

2 Review all VoG planning decisions on the incinerator

3 Urge Welsh Govt to issue a Discontinuance Order

4 Consider the expediency of taking enforcement action

This massive industrial plant, close to homes, has no valid planning permission.
Many Conditions on the Outline permission are still unmet, and the buildings differ.
They have to re-start with a proper EIA for a DNS application, or just give up.

The Welsh Minister has to do what she has been avoiding since last April when her Planning officers advised her to issue a Discontinuance Order to comply with her duty to prevent the plant operating without EIA.

The Council Motion's 4th point was amended from the original moved by Cllr Vince Bailey that specified the cessation of all operations on site.  These words were copied from their own Planning Officer who warned the company that 

the only remedy to such a breach of planning control would be to require the removal of the development in its entirety or, at the very least, the cessation of all operations on site.

That is what the public is expecting, now that the Incinerator is in breach of a whole slew of Conditions on the 2015 outline planning consent.  The Vale officers allowed them to breach conditions on noise, emissions and no nightime working when constructing the plant.  At last the Councillors have stepped firmly against this lawless company.

Objecting to JME's Incinerator-linked Waste Site on Barry Dock

The Natural Resources Wales consultation lasted till 9th February.  
Many members of DIAG sent in objections.  Barry&Vale FoE concentrated on some fundamental points for rejection of the license application.  Winning the point that the process comes under the Industrial Emissions Directive (IED) will be important in stopping the current operations, supposedly restricted to a Standard License.
JME have also started a pre-planning consultation - their present operations have no planning consent, but the VoG Council has failed to enforce against them.

JME want to take in waste wood, sort and chip it to make fuel for the Biomass incinerator, and also receive incinerator ash for onwards transfer.  They would do this in the open air, spreading the harmful dust everywhere with no regard to impacts.  The waste-wood is classed as "non-hazardous" but of course the dust from chipping it can be and is hazardous when breathed in.  NRW officers appear not to understand this!

FoE Objection to License 
for   J M Envirofuels (Barry) Limited, Berth 31 Wimborne Road, Barry Docks

   We point out this application for sorting and shredding wood for use of incinerator fuel comes under the Industrial Emissions Directive, as the processes improve the nature of the fuel and its quality for feeding the incinerator.

We therefore object fundamentally to licensing it outside the Directive's requirements.

We are aware that the NRW has formally agreed to exclude changes to the "physical nature" from its definition of processes that improve the nature of the fuel.

We challenge this as a wrong decision that has no basis in law or industry usage.

# Standard descriptions include physical and thermal methods to improve fuel quality. 

A quick internet search finds the Conference publication describes "commonly used methods to improve biomass fuel quality by physical and thermal transformation" in Research progress of biomass fuel upgrading and distributed utilization technology, by Liu, Shuguang et al.  DOI - 10.1088/1755-1315/227/2/022002  IOP Conference Series: Earth and Environmental Science

# Elsewhere are descriptions of improving biomass fuel quality by densification and moulding, like processes for producing fuel pellets   Thus industry usage shows NRW were wrong to exclude physical treatments from their definition of methods that improve fuel quality.

# The physical processes proposed at Berth 31 in fact improve quality.

JME say they collect materials from skips, such as doors, window frames, roof timbers, kitchen cupboards, used work-tops etc. These are likely to include metal handles and fitments, window glass which they sort out.  Excluding non-combustibles by definition improves the calorific value. Thus sorting undoubtedly improves its nature as fuel.

# The remaining waste wood is unusable as fuel until it is chipped/shredded; large pieces have to be excluded as they pass through the system incompletely combusted. The chipping/shredding undoubtedly improves its nature as fuel for the incinerator.

We therefore object that this application be rejected, and one submitted under the more stringent requirements for a facility covered by the IED.

In the IED submission, we expect proper evidence on the nature of the dust from the process, much of which is not "sawdust" as stated but fragments of paint and non-wood materials.  Data from similar waste wood chippers must be supplied, on the nature and hazard of the dust, on health-experiences from people living close to such facilities, and on environmental effect of the dust including in leaching chemicals into surface waters.

The IED submission must justify each statement in the Risk Assessment, showing the capacity of drainage systems can cope with the heaviest rainstorms and worst-case firewater usage; restriction on recreational use of dock waters from run-off contamination etc.   It must detail all receptors liable to be affected, not use the vague term livestock, but include mussel-farms as well as fish stocks in Barry Dock.

The IED submission must also detail how the 20 000 tonnes of wood waste could be accommodated on this site, when the two 'maltese crosses' of chipped wood can hold at most 2000 tonnes. In what form is the rest to be stored?

Request for an IED licence that covers both the incinerator and Berth 31 that supplies it.  

NRW officers said they thought one licence could not cover two companies, yet the Directive allows this, as long as the specific responsibilities are set out. 

Reasons for a combined licence are that

# the incinerator cannot function without this supplier - and have signed a long-term contract with them.  

# The quarantine area to receive part-burned fuel in case of fire on the incinerator site is at Berth 31.   JME have to set aside that quarantine area.  

# The haulage road between the incinerator and Berth 31 is a private road, not subject to controls on sheeting of lorries or spillages (which can affect nearby receptors, including the Dock's controlled waters). Only by NRW requiring a combined IED licence can the haulage be brought under proper controls for the protection of people and the environment.

Hinkley nuclear station: New Cardiff Bay mud dumping plans

EDF Energy wants to "deposit" up to  600 000 cu metres (about 800 000 tonnes) of sediment dredged as part of building work for the Hinkley Point C plant into the sea off Cardiff Bay.

They got away with "only" 120 000t before, in 2018, and now think the compliant Welsh will give them an easy ride.   Natural Resources Wales (NRW) has received a plan for sampling and testing the mud, which will now be subject to a six-week consultation with specialists and the public.  NRW appear to have taken no notice of the basic errors in their previous license - including the lack of EIA confirmed in the High Court case - as summarised in the WANA briefing.

Image captionThe mud disposal site in 2018 was located about a mile off the south Wales coast

EdF's Chris Fayers was interviewed on Radio Wales on 5th February, followed by FoE coordinator Keith Stockdale.

The same old yarn - Cardiff is the closest suitable dump-site; important to keep the dredgings in the Severn Estuary; our sampling was sufficient last time and we're sure it will show no problem this time.  The radioactive dose to anyone is the same as eating bananas.

EdF use calculations as if the mud was dumped in the open sea - a model that is used for Sellafield's discharges in Morecambe Bay. 
As Keith Stockdale pointed out, the Severn Estuary mud does not get swept down the channel.  It swishes back and forth with the twice daily tides, some deposits on mud banks and in saltmarsh, and some gets into the wind as microspray drops.  From the mud banks, it moves up estuaries like the Rhymney and Usk.  When the mudbanks dry out, the mud particles blow onto land and are taken up in crops.  The nuclear contaminants get to people via inhalation and local foodstuffs. 

Thus the model calculations ignore sea-to-land transfer processes established by science.  They assume most or all of the mud disappears to the open sea, yet common observation sees mud banks accumulating and saltmarsh building up.  EdF's Fayers indeed argued for retaining the mud in the Severn Estuary system, as happens to much of it, but NRW has no idea how much reaches the land, nor have they yet required EdF to provide evidence on it.

The Cardiff Dump site was designated only for dredgings from harbour channels.  It was never licensed for ‘capital’ dredgings and not for the heavy clay (64% of the total) which EdF intend to dig out from their massive tunnels for installing 7-metre seawater pipes for cooling water.  Their closest dump site is in fact on land, with their other construction waste.  EdF's real motive in trying to dump in the estuary is they expect the mud to contain radioactive pockets of material that they’d have to test and deal with specially.  How much easier for them (and cheaper) to dump in our sea!

Sampling last time failed to meet basic standards.  Most samples were just recent deposits scooped off the seabed (1-3cm).  The few borehole samples showed mixed results, indicating patchy radioactive deposits down to a metre or two.  The 3 boreholes out near the planned pipes were quite insufficient on international standards for the volume excavated (7-15 sampling positions are specified;  more if contaminants are found to be patchy).   The Senedd Petitions Committee maintained there should be more samples at depth, but the Minister ignored them (supported by Labour on the party whip).

Since that time, further evidence has been found that the nuclear station was discharging elevated levels of radioactivity in sludge from the cooling ponds (decommissioned 2014), arising from mishaps with the spent nuclear fuel elements about 1970 (Prof Keith Barnham).  The greatest fear is of the ‘hot’ particles of used nuclear fuel released in that sludge, because these are not detected by the conventional analysis - yet just one getting into the human body would be very dangerous.

Artificial radioactive components were detected in the 2013 sampling.  Caesium-137 and Americium-241 are the two fingerprints of nuclear reactor products. They are just visible on the CEFAS graph below, because that has been scaled to show "dose", not specific radioactivity.

As plutonium Pu-241 is the source of Am-241, the amounts of Pu-241 are inferred from the intensity of gamma radiation from Am-241.  The CEFAS graph makes the artificials look insignificant, but harm depends not on the gamma-ray dose, but depends strongly on whether the elements are taken up into food and the human body.  U-238 is 30-60% higher in the 3 relevant deep samples, so the real total dose may come close to the 10uSv/a limit.

Plutonium (Pu) is 30x more abundant than given by the government CEFAS analysis.  That assumed Pu-241 is 90% of total Pu (as average in Sellafield discharges), but Hinkley-A magnox reactor had only 3% Pu-241 in the total Pu, being operated to produce mainly ‘bomb’ Pu-239. So their basic numbers are seriously wrong. 

Pu has the property of being quickly adsorbed onto mud particles, which then mainly settle out locally, in the Bridgewater Bay mud.  The mud builds up by a mm or two per year, so deeper samples indicate levels of Pu in earlier years.  Sampling at a sequence of depths allows past discharges over the decades since 1970 to be assessed. Last time they just measured the average in 20cm and 110cm long cores, looking as if they want to hide the pattern of Hinkley's secret past discharges.

NRW failed to require assessment of what happened to the dumped mud in 2018. It's massively insulting to Welsh people to imagine EdF could play the same tricks again, get supine politicians to say it's not radioactive, so they can spread 6 times more mud with historical Hinkley contaminants on our beaches, mudflats and river estuaries, knowing there's no safe level of these nuclear fuel radionuclides and that dangerous 'hot' microparticles may be included, 

Long-outdated Air Pollution assessment still used in Wales

The official Welsh (WG) classification of Air Pollution levels (link) is inherited from the old Department of Health (DoH), based on COMEAP 'experts' who've changed their minds below). It’s still posted up for use, despite new Welsh policy issued in 2017. This included statutory guidance to Local Authorities on giving special consideration to the long-term risks posed to babies and children via exposure to air pollution. The old DoH/WG classification doesn’t.  This daily air quality index (DAQI) is also based on quite outdated standards for adults.

The World Health Organisation produced guidance in 2012/13, including identifying PM2.5 as a human carcinogen, but the WG took no notice until the Minister’s statement of June 2017. Revised WHO Air quality guidelines are due out in 2020. 

The WHO annual mean concentration guideline for particulate matter stipulates that PM2.5 not exceed 10 μg/m³ annual mean and 25 μg/m³ 24-hour mean; also that PM10 not exceed 20 μg/m³ annual mean, or 50 μg/m³ daily mean ( 24-hour).  PM2.5 is most closely related to ill-health impacts (see below).

The DoH/Welsh classification clings to the pre-WHO numbers, calling PM2.5 values below 35  “low” (40% higher than the WHO limit) and below 53 “moderate” (double the WHO limit).  It’s highly remiss of the Environment Minister that she has failed to withdraw this completely misleading classification and issue a new one for guidance of the people of Wales.

Vale of Glamorgan monitoring of the Barry 'Biomass' Incinerator

The Council has purchased two monitors that measure PM10, PM2.5 and NO2 every 15 minutes.  The averages for each hour are now posted daily.   We presume the numbers are accurate as the monitors have been working for two years.  However, users should ignore the low/moderate/high classification and colouring, which are the old defective WG/DoH ones above. 

View of the World Health Organisation (WHO) on particulate pollution (link)

Outdoor air pollution is a major environmental health problem affecting everyone in low-, middle-, and high-income countries.

   Ambient (outdoor) air pollution in both cities and rural areas was estimated to cause 4.2 million premature deaths worldwide per year in 2016; this mortality is due to exposure to small particulate matter of 2.5 microns or less in diameter (PM2.5), which cause cardiovascular and respiratory disease, and cancers.

  People living in low- and middle-income countries disproportionately experience the burden of outdoor air pollution with 91% (of the 4.2 million premature deaths) occurring in low- and middle-income countries, and the greatest burden in the WHO South-East Asia and Western Pacific regions. The latest burden estimates reflect the very significant role air pollution plays in cardiovascular illness and death. More and more, evidence demonstrating the linkages between ambient air pollution and the cardiovascular disease risk is becoming available, including studies from highly polluted areas.

  WHO estimates that in 2016, some 58% of outdoor air pollution-related premature deaths were due to ischaemic heart disease and strokes, while 18% of deaths were due to chronic obstructive pulmonary disease and acute lower respiratory infections respectively, and 6% of deaths were due to lung cancer.

  Some deaths may be attributed to more than one risk factor at the same time. For example, both smoking and ambient air pollution affect lung cancer. Some lung cancer deaths could have been averted by improving ambient air quality, or by reducing tobacco smoking.

  A 2013 assessment by WHO’s International Agency for Research on Cancer (IARC) concluded that outdoor air pollution is carcinogenic to humans, with the particulate matter component of air pollution most closely associated with increased cancer incidence, especially lung cancer. An association also has been observed between outdoor air pollution and increase in cancer of the urinary tract/bladder.

Origin of the Air Quality index and Banding

COMEAP first introduced the UK’s Air Quality index in 1998 (Committee on Medical Effects of Air Pollutants:  Statement on Banding of Air Quality, 1998. Link).

Their subsequent 2011 Review of the UK Air Quality Index (Daily AQI or DAQI) was introduced by Defra and devolved administrations from 1 Jan.2012.  It was COMEAP’s final publication before being disbanded and the last effort of British medical pollution ‘experts’ to maintain that only sensitive people need worry about air pollution (even said as “exquisitely sensitive” in Prof. Harrison’s evidence for an incinerator company – Portsmouth Incinerator Inquiry, 2000**).  British medical policy leaders in COMEAP, including Prof Harrison, were compromised in favour of incinerators at that time. Evidence on permanent harm to child-lung development was accumulating, measured as lung function, US/Calif authorities were recommending against children exercising outdoors during high ozone episodes, and European experts were developing the WHO guidance.  Prof Stephen Holgate chaired the COMEAP Review, which is thick with material on asthma, Holgate’s speciality.  They devised the irresponsible advice that only children with ‘lung problems’ should ‘consider’ ‘reducing’ ‘strenuous’ exercise at times of moderate or high pollution. The report says they were motivated by inter alia 

•          the need to avoid an exaggerated level of worry and concern
•          our view that children with no known respiratory disease were unlikely to be particularly susceptible to the effects of air pollution.

Most or all of the Review group published a scientific paper (Gowers et al. 2012) which found “outdoor air pollution might play a role in causing asthma in susceptible individuals”, but dismissed it as only a small contribution and a small proportion of the population. COMEAP in effect dismissed the then evidence of the pollution causing onset of new asthma cases, instead of taking a precautionary approach ("exaggerated level of worry and concern"). They had failed to learn from the BSE episode - scientists...part of the problem: Nature, Oct. 2000).   Their advice to asthmatic children was just use their inhaler.

Nowadays, however, Stephen Holgate talks of pollution worsening asthma and COPD and even emphasises the need to reduce NO2 as a cause of new-onset child asthma.  Prof Harrison likewise changed his view, but their COMEAP report lives on the DAQI.  Even though Welsh government policy is reduction of NO2, their Health Boards play it down and their NRW permits increases in NO2 up to the old limits. 

** Unpublished Evidence, via Public Interest Consultants, 2000