1st February 2020
At the centre of the FOFOC campaign for an Environmental Impact Assessment (EIA) of Peel Ports proposals for oil rig decommissioning at Hunterston is the concern that a ‘salami slicing’ approach to planning and licensing applications has been strategically adopted to avoid scrutiny of the overall and cumulative impact of the project on the surrounding marine ecosystem, which is home to a number of OSPAR protected species and Southannan Sands Site of Special Scientific Interest (SSSI). Hunterston is also surrounded by a number of coastal communities with their own concerns for the health and wellbeing of residents.
Those who are familiar with the geography of Hunterston Peninsula will be aware that the site of the proposed decommissioning project is a close neighbour of Hunterston Nuclear Power Station, which has itself been the subject of national scrutiny following the discovery of hundreds of cracks in the graphite bricks within the reactor core of Hunterston B. Hunterston B is served by a secondary water cooling system which is licensed to discharge waste coolant containing legally agreed levels radioactive isotopes via a number of ‘outfalls’ back into the sea.
The closest of these outfalls is approximately 1km from the proposed dredging area.
The issue of nuclear safety at Hunterston is of considerable interest to the local and wider community.
On the 5th September 2019 a representative of the Friends of Firth of Clyde attended the Hunterston Site Stakeholder Group (SSG)to ask the following questions.
(i) What is the level of radioactivity within the sediment at Hunterston and what implications might significant dredging in the area have on its release into the marine environment?
(ii) What is the planning / licensing relationship between Hunterston Nuclear Site & Hunterston PARC?
(iii) What liaison /communication had taken place between the Nuclear Licensing Division of SEPA and the SEPA Waste Management Division that was consulted by Marine Scotland regarding the EIA Screening?
A SEPA inspector for Hunterston, explained that radioactive discharge is trapped within the sediment surrounding Hunterston, and that Sellafield also has an influence on the west coast.
He confirmed that environmental monitoring is a site requirement and anything discharged in to the marine environment is lawfully discharged under permit via the outfalls. He explained that any activity which involved disturbance of sediment surrounding Hunterston would require, as part of any licensing process, an assessment of the likelihood of any radioactive deposits being disturbed and if over the legal limit, a further permit would be required and the Health and Safety Executive would have to be consulted on the subsequent disposal of any radioactive material.
The SEPA inspector stated that at the time of the meeting the Nuclear Licensing Division of SEPA had not had any contact regarding the Hunterston decommissioning proposals, but as a statutory consultee SEPA would be consulted on any planning application. By this stage we were aware that SEPA Waste Management Division had responded to Marine Scotland as a Statuary Consultee leading us to believe that the question of the impact of dredging on radioactive sediment had not been addressed.
Further more on 8th November 2019 Envirocentre submitted supplementary information to Marine Scotland that included a section on disposal of dredged material which makes no reference to the potential radioactive risks of the sediment and states:
“The Best Practicable Environmental Option (BPEO) for disposal of the dredge material has identified the following preferred options:
- material re‐use as part of the wider site redevelopment;
- material re‐use (partial) at a site along the coast at Ardrossan if dredge and development timings are compatible. “
We have written to Marine Scotland asking that they urgently confirm that:
- The response to the EIA screening they have received from SEPA addresses the risk and impacts of disturbing radioactive sediment and evidences that the response has been drawn-up in collaboration with colleagues from the Nuclear Licensing Division
- That they have clearly addressed and risk assessed the implications for the marine ecosystem and human health and safety.
We await a response from Marine Scotland.