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.