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.

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 ##

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** 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