The Reduction And Elimination Of Tc-99 Discharges From Sellafield Submitted by Greenpeace International to the Working Group on Radioactive Substances (RAD 98) of the Oslo and Paris Commissions Stockholm: 19-23 January 1998 Introduction: 1. Greenpeace welcomes the commitment of the United Kingdom to demonstrate to OSPAR, how it is meeting its obligations under the OSPAR Convention with respect to reducing discharges, and eliminating any pollution from, discharges of technetium-99 from Sellafield to the Irish Sea (see Para. 4.20 of OSPAR 97). 2. Greenpeace has continually drawn the attention of the OSPAR Commission to the continued routine discharge and emission of radioactive wastes from the nuclear reprocessing facilities at Sellafield. Recently particular attention has been focused on the extremely high and sharply rising levels of technetium-99 in lobsters in the Irish Sea (RAD 97/9/NGO.1, HODCM 97/NGO.1, OSPAR/97/4/NGO.2). At the start of OSPAR 97, following a detailed review of UK positions, the UK Environment Minister announced that the levels of technetium-99 in lobsters were worrying and that he wanted the problem to be stopped (see Para. 4.17 of OSPAR 97). This commitment was welcomed by all other OSPAR Contracting Parties (see Para. 4.19 of OSPAR 97), who also expressed their urgent concern about the increased discharges and concentrations of technetium-99 (see Para. 4.18 of OSPAR 97). Greenpeace therefore trusts that the UK and OSPAR will now take prompt and effective action on this matter. 3. RAD has invited Contracting Parties to inform the UK (as soon as possible) and to report to RAD 1998 about specific techniques that would be suitable for reducing discharges and eliminating any pollution from these discharges (see Para. 4.21 of OSPAR 97). Greenpeace proposes the course of action below, as a practical and effective means to achieve this end. The strategy proposed is a means to prevent, reduce and eliminate the discharges of technetium-99 which reach, or could reach, the marine environment. Sources of Tc-99 and Options for Discharge Reduction. 4. Discharges of technetium-99 from Sellafield arise largely from the practice of reprocessing spent Magnox fuel. Medium active concentrate (MAC) from the Magnox reprocessing plant (known as B205) is stored for 3-5 years at Sellafield and then processed through the Enhanced Actinide Removal Plant (EARP), before being discharged to sea. This process accounts for some 96% of the technetium-99 discharged from the Sellafield site. 1 5. The Magnox reprocessing plant at Sellafield began operating in 1964 and reprocesses spent nuclear fuel from the UK Magnox reactors and from Japan. It has an annual capacity of 1500 tonnes of spent nuclear fuel.2 The majority (up to 160) of the 200 "estimated deaths from each year of future operation" of Sellafield, calculated by the UK Government’s Radioactive Waste Management Advisory Committee 3, are a result of discharges caused by the practice of reprocessing spent Magnox fuel. 6. The high levels of Tc-99 in the MAC effluent stream are inherent to the 1950s design of the Magnox reprocessing plant. BNFL, which owns Sellafield, states4 : "Consideration has been given to the possibility of modifying the Magnox reprocessing plant to re-route the Tc-99 to the highly active liquor stream for vitrification (ie as for Thorp) or to re-route the MAC through other plants to eliminate Tc-99. None of these have been found to be practicable due to engineering difficulties in modifying the existing operational plant, dose uptake and cost." BNFL has thus ruled out modifying its ageing plant to bring it in line with modern standards. 7. BNFL has instead investigated the possibility of building new MAC storage tanks or modifying existing ones. It estimates that new tanks would take 5 years to build and cost £30M-£70M, whilst modifying existing tanks would cost £10M and take 3 years. As well as being expensive, the Nuclear Installations Inspectorate (NII) has pointed out5 that additional tanks "could only be a temporary expedient by holding MAC rather than resolving the problem of disposal". The NII notes that deferring discharge following extended storage of MAC "will in no way reduce the total dose that will be received by members of the public but will increase the dose to the workforce". Continuing storage of MAC in liquid form is contrary to Government policy for reasons of on-site safety. 8. BNFL has also considered six ‘end-of-pipe’ Tc-99 abatement development options6 . All except one have been rejected by it on technical grounds. The remaining option (the POROCELL process) has only been demonstrated at a laboratory scale. BNFL claims that, even assuming the development of this technology proved successful it could not expect to be implemented until 2005. BNFL then estimates capital costs at £100M and operating costs at £1M/year. 9. Since OSPAR 97, BNFL has revisited some of the options previously rejected by it on technical grounds7 . It claims to have demonstrated that organic precipitation of Tc-99 in EARP is now feasible and that the modified sludge can be encapsulated meeting relevant waste criteria. The only drawback as far as BNFL is concerned is the increase in solid waste volumes, and the likelihood that these wastes would not meet regulatory requirements for a deep repository, because of their high organic content. However, BNFL also notes that work on removal of other radionuclides discharged to sea from EARP, namely strontium-90 and caesium-137, has been delayed. It states that this delay is due to pressure to examine technetium-99 abatement options as a matter of priority. BNFL also fails to provide details of the costs and time-scales for implementing this option. Preventing Future Arisings of Tc-99. 10. The first step in reducing discharges, and eliminating pollution from discharges of Tc-99 from Sellafield, should be to prevent future arisings of MAC from the ageing Magnox reprocessing plant. 11. If this step is not taken, future arisings of Tc-99 will continue to accumulate indefinitely and will either require long-term storage or be discharged into the environment. Neither of these options can be implemented without further treatment and costs, since the storage of liquid MAC wastes in tanks at Sellafield gives rise to concern about worker safety, whilst their discharge is causing pollution of the Irish Sea. 12. The achievable time-scale, technical feasibility and costs of removing Tc-99 from discharges are uncertain. However, prevention of future waste arisings could be implemented now. 13. All the UK Magnox reactors which send their spent nuclear fuel to Sellafield, are operating well beyond their 25-year design lifetimes and the UK Government has accepted that they cannot ever generate enough revenue to meet all their liabilities8 . Included in the Magnox liabilities are the massive costs associated with the reprocessing of spent nuclear fuel. BNFL expects "a near £4 billion Magnox order book to reprocess fuel from the first generation of Magnox stations into the 21st century"9 . Magnox Electric, which currently owns the reactors, has openly stated that they are not economically viable and raised considerable concern over these "back-end costs"10 . 14. The Magnox reactors have remained operational on the grounds that the avoidable costs of running the stations are low, and a significant proportion of the costs are sunk11 . However, this analysis does not take into account the true (avoidable) costs of reprocessing the Magnox fuel12 . Furthermore, since Magnox reprocessing is currently operating without due regard for the need to protect the marine environment, its true costs have been underestimated in all existing economic analyses. If the Magnox programme continues operating, the urgent need for expenditure on abatement technology for Tc-99 could only add to its costs. These abatement costs are currently avoidable and thus strengthen the economic case for shutting the whole Magnox programme now, before any further money is invested. 15. BNFL is due to take over ownership of the Magnox reactors in the near future, and with them a £4 billion undertaking from the UK Government "to enable the Company to meet its financial obligations as they fall due" 13. This Government subsidy is controversial14 , particularly as it is clear that it is supporting continued reprocessing rather than only truly unavoidable costs, such as those associated with decommissioning reactors. 16. Whilst BNFL has failed to invest in abatement technology for Tc-99, it has recently invested £130M in extending the lifetime of the Magnox reprocessing plant by a further 20 to 25 years15 . This increased investment (sunk costs) in the Magnox programme was made in spite of the continuing financial losses of the reactors and in spite of the UK’s OSPAR obligations to eliminate pollution from the plant. To supply more spent nuclear fuel to the reprocessing plant BNFL also plans to extend the lifetimes of the Magnox reactors. These lifetime extensions would significantly add to, rather than reduce, total discharges into the Irish Sea. The long half-life (213,000 years) of technetium-99 means that the existing burden in the environment does not significantly decay as more is added over a period of decades. 17. The first step in reducing discharges and eliminating pollution from Tc-99 discharges from Sellafield, should therefore be to halt further spending on extending the ageing Magnox programme and to prevent future waste arisings by closing the Magnox reprocessing plant and all associated reactors. Considerable future detriment, due to radionuclides other than technetium-99, would also be avoided. 18. The application of "end-of–pipe" technologies is, in contrast to preventing future arisings, likely to be both ineffectual and expensive. For example, EARP, designed to remove actinides from Magnox effluents, and opened in 1994, cost some £500 million, and yet removes only some radionuclides. These do not include technetium-99. If Best Available Techniques (BAT) are also to be implemented for other radionuclides in future, costs will continue to rise. Until September 1997, BNFL was of the view that all "end-of-pipe" abatement options for technetium-99 are either "technically unfeasible" or involve "grossly disproportionate" costs. It has subsequently identified another potentially technically feasible option, but its implementation would delay work on removing other radionuclides and its costs have not been given. Investing in "end-of-pipe" abatement technologies for an already uneconomic industry is clearly highly unlikely to be the most realistic and effective option for the UK to fulfil its OSPAR obligations. Reducing Technetium-99 Discharges from Existing Wastes. 19. Immediate closure of the Magnox programme will still leave some existing spent Magnox fuel in pond storage and in the closed reactors. The backlog of MAC wastes at Sellafield will also remain to be addressed. 20. The most effective means of reducing discharges, and eliminating pollution from Tc-99 in these wastes would be to implement dry, above ground storage, which is managed, monitored and retrievable. Long-term storage of spent Magnox fuel is technically possible 16 and the youngest Magnox reactor, Wylfa, in fact already has an on-site dry-store for spent nuclear fuel. Other liquid Magnox wastes are being encapsulated in cement at Sellafield17 , and it seems unlikely that there are any major technical barriers to using the same process for MAC wastes. The costs of these storage options can best be limited by limiting the volumes of future waste arisings. Conclusion. 21. There is an urgent need to prevent future arisings of technetium-99 wastes at Sellafield, as the most effective means to prevent pollution. 22. Closing the ageing Magnox reprocessing plant is the most practical and effective option. In economic terms, it is also likely to be more realistic than investing in further "end-of-pipe" technologies. 23. Closure of the Magnox reprocessing plant at Sellafield could also prevent up to 160 expected future cancer deaths for every future year of operation of the plant. 24. If the concern of OSPAR delegations expressed in Brussels is not to be seen (prior to, during and beyond the OSPAR Ministerial Conference) as empty rhetoric, OSPAR must adopt the only effective route to end marine pollution caused by radioactive discharges from Sellafield. Footnotes 1. BNFL(1996) Application for a Variation to the Certificate of Authorisation for the Disposal of Low Level Liquid Waste from the Marine Pipeline at the Sellafield Site, December 1996, p.5,para 10. 2. Energy and Security, No.2, 1997. 3. RWMAC(1994), Fourteenth Annual Report of the Radioactive Waste Management Advisory Committee, HMSO, June 1994, Table 2, p.53. 4. Ref 1, Appendix 2, p.12. 5. Letter from R Haworth, HM Principal Inspector (Nuclear Installations) to Miss A Hajnrych, Environment Agency, 8 January 1997. 6. Ref 1, Appendix 2, p.11-13. 7. BNFL, 1997, Fourth Review of Developments in Technology and Techniques in Relation to Liquid Waste Streams, September 1997, Para 6. 8. DTI & SO (1995), The Prospects for Nuclear Power in the UK: Conclusions of the Government’s Nuclear Review, Cm2860, HMSO, May 1995, para 7.11 9. BNFL News, ‘Magnox on re-start’, August 1997. 10. Utility Week, 24 January 1997, p.3 11. Ref 8, para 7.12. 12. See, for example, Sadnicki, M.J. (1993), Nuclear Review Background Paper: Magnox Avoidable Costs, Hoskyns Group, November 1993; Sadnicki, M.J. (1995), Magnox Avoidable Costs (NFLA evidence to TISC), October 1995. 13. Magnox Electric (1997), Annual report and Accounts 1996-97, p.40. 14. See, for example, Financial Times, 11 September 1997, ‘BNFL hopes for Magnox merger soon’. 15. BNFL(1996), Sellafield Newsletter, Week Ending Thursday 12 December 1996. 16. RWMAC (1990) Eleventh Annual Report of the Radioactive Waste Management Advisory Committee, HMSO, November 1990, para 4.18, p.38. 17. ACSNI (1992), Advisory Committee on the Safety of Nuclear Installations, Report on the accumulation of radioactive waste at BNFL Sellafield and at UK nuclear power stations, HMSO, paras 49-52.