CONSULTATION BY THE MARINE MANAGEMENT ORGANISATION (MMO) ON ELECTRICITÉ DE FRANCE (EDF)/NNB 2021 PROPOSALS TO DREDGE BRIDGWATER BAY SEDIMENTS AND DISPOSE OF DREDGE WASTES AT PORTISHEAD LU070 AND/OR CARDIFF GROUNDS LU110
RESPONSE FROM THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
(BANNG Paper No. 48)
This response is submitted on behalf of the Blackwater Against New Nuclear Group (BANNG). BANNG is a Citizens’ Based Organisation formed in 2008 to oppose new nuclear development at Bradwell on the Blackwater estuary in Essex.
BANNG has at times collaborated with Stop Hinkley and has responded to consultations in relation to the building of the new nuclear power station on the Bristol Channel, e.g. BANNG Paper No. 16 (see website: banng.info).
BANNG wishes to oppose the proposed dredging of mud at the Hinkley Point C site for dumping at Portishead and/or Cardiff Grounds at least until further research has been undertaken.
BANNG accepts that it is not as knowledgeable about the issues as others and is happy to support the submission made on behalf of Stop Hinkley by Tim Deere-Jones, who has also worked as a consultant for BANNG.
This consultation is of particular interest to BANNG as it raises issues of contamination, dredging and disposal of mud in estuarial and coastal locations such as the coasts surrounding the proposed new nuclear power stations at Bradwell and Sizewell, should these go ahead.
BANNG wishes to comment on the following issues –
(i) Unsuitability of proposed disposal sites:
BANNG is surprised to learn that EDF is proposing to dispose of the dredged mud close to an SSSI site, east of Cardiff, where its dispersal would have an environmental impact. This is instead of considering the recommendation of the Environment Agency (EA) to use the disposal site at Holm Deep which is: closer to the dredging site; in very deep water; and where high dispersal of the material could be expected. This recommendation is supported by Stop Hinkley and Nuclear Free Local Authorities (NFLA).
Not considering the recommendation implies that EDF believes it knows better than the Environment Agency.
BANNG believes that EDF should consider the recommendation of the Environment Agency that Holm Deep is a more suitable site for the dumping of the mud. This recommendation is supported by Stop Hinkley and the NFLA.
(ii) Environmental Impact Assessment (EIA) of the Portishead site:
Since Natural Resources Wales (NRW) is requesting a full EIA for any further proposals to dump the mud in Welsh waters, it is unquestionable that an EIA should also be undertaken for both the Somerset dredge and dump sites.
BANNG is surprised to learn that although an EIA has been requested in relation to the proposed dumping of the mud in Welsh waters, no EIA or any other assessment seems to be planned for the Somerset dredge and dump sites and believes that assessments must be undertaken.
(iii) Presence of radionuclides:
We understand that only six of approximately fifty radionuclides that are believed to be present in the mud were input to models for close estimation. Questions were raised by Dr. Richard Bramhall at a recent meeting of the BEIS/NGO Nuclear Forum concerning the adequacy of the CEFAS spectrometry tests. These questions need to be taken seriously.
Deploying such a small number of radionuclides leads to the conclusion that models cannot be relied on to provide adequate information relating to the protection of public health and the environment.
[BANNG is reminded of the information provided to the public in relation to discharges into the Blackwater estuary of the residue arising from the dissolution of fuel element debris (FED) project during decommissioning of Bradwell A. The residue was said to be a ‘saltwater solution’ and there was no mention of the radionuclides and heavy metals also being discharged!]
BANNG believes that for modelling relating to public health and the environment to be undertaken seriously, a much less selective process should be undertaken and all the radionuclides (and heavy metals) present in the mud must be estimated.
(iv) Radiation in Food and Environment (RIFE) Report:
We agree with the Stop Hinkley submission that higher beta emitter concentrations in shellfish and elevated levels of gamma emitters in sediments at Hinkley Point C, reported by RIFE, require research to be carried out prior to any dredging and dumping of mud taking place.
It is unconscionable, and surely extremely bad practice, that EDF is proposing to dump a massive 780,000 tonnes of mud without significant testing and any consideration of the impacts on people and the environment and of the implications for the Severn Estuary and Bristol Channel. It seems that the same ‘mistake’ was made by EDF before the first round of dredging and dumping of the mud in Cardiff Bay.
BANNG agrees that EDF must undertake significant testing and consider the impacts on people and the environment of the dredging and dumping of the mud as well as the implications for the Severn Estuary and the Bristol Channel before the mud is dredged from Hinkley Point. This would seem to be a very obvious first action to take.
(v) Effects on fish:
Hinkley Point C will be using a direct cooling water system and it is the installation of the two water intakes for this system that is necessitating the dredging and dumping of the mud.
Apart from the problems relating to the dredging and dumping of the mud raised by Stop Hinkley and others and referred to in this response, it is estimated that these cooling water intakes will cause an estimated 182 million fish to be killed every year during operations at Hinkley Point C. That means that over 60 years of operations the vast number of circa 11 billion fish will be destroyed. The Blue Marine Foundation, the Wildfowl and Wetlands Trust and the Somerset Wildlife Trust have grave concerns about the carnage caused by the cooling system.
Can the Bristol Channel really afford to lose so many fish every year, especially given that it seems fish stocks in general are in danger? Is it ethical that as a society we can wantonly destroy so much biodiversity over the long-term? What will be the effects on current and future generations of local fishermen?
BANNG regrets that the use of a direct cooling water system has led to the necessity to dredge and dump the Hinkley mud. It notes that the operations over the lifetime of Hinkley Point C will lead to what can only be called the premeditated and wanton destruction of an estimated 11 Billion fish. This latter issue should be enough to stop the building of Hinkley Point C. It is nothing short of a scandal.
BANNG is totally opposed to EDF’s proposals to dredge the mud at Hinkley Point C and to dump it in Cardiff Bay and at Portishead for the following reasons:
EDF should take seriously the recommendation of the UK’s Environment Agency that Holm Deep is a more suitable site for disposal of the Hinkley mud ;
an Environmental Impact Assessment and all other relevant assessments must be undertaken in relation to the proposed dumping of any mud at the proposed Portishead site;
before the mud is dredged from the Hinkley Point site, EDF must undertake significant testing and consider the impacts on people and the environment as well as the implications for the Severn Estuary and the Bristol Channel;
the questions raised concerning the adequacy of the CEFAS spectrometry tests must be addressed because of the potential adverse impacts on people and the environment caused by the disturbance of sediments and of the dredging and dumping of the mud.
BANNG regrets that:
the installation of two water intakes for the direct cooling water system at Hinkley Point C has resulted in the necessity to dredge and dump radioactive mud, to the detriment of people and the environment, and will lead to the premeditated and wanton destruction of billions of fish during the lifetime of the power station.
BANNG agrees with Stop Hinkley that:
EDF’s application for dredging and dumping of the mud should be referred to the Government for a decision to initiate a Public Inquiry.
BANNG fully supports the response made by Stop Hinkley to this consultation.
Prepared by Varrie Blowers, Secretary
on behalf of the Blackwater Against New Nuclear Group BANNG
26 March, 2021