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Submitted by Greenpeace International to the Joint Meeting of the Oslo and Paris Commissions (OSPAR 97) Brussels, 2-5 September, 1997 Agenda Item 4.3.f Introduction For many years, several Contracting Parties, as well as Greenpeace International, have drawn the attention of the OSPAR Commission to the continued routine discharge and emission of radioactive wastes from the nuclear reprocessing facilities at La Hague, Sellafield and Dounreay. In response, the OSPAR Commission has been far too hesitant and failed to act in accordance with its obligation to protect the marine environment against pollution and to, inter alia, "take all possible steps to prevent and eliminate pollution and [to( take the necessary measures to protect the maritime area" (Art. 2.1(a) of the OSPAR Convention). So far, the OSPAR Commission has collectively accepted the views of the UK and France that radioactive discharges were not causing pollution under the meaning of the Paris and OSPAR Convention. But new data and developments at Sellafield and La Hague have shown that these countries´ activities are clearly a case of pollution. Radioactive discharges and emissions are clearly causing pollution as defined in Article 1(d) of the OSPAR Convention, namely: the introduction by man, directly or indirectly, of substances or energy into the maritime area which results, or is likely to result, in hazards to human health, harm to living resources and marine ecosystems, damage to amenities or interference with other legitimate uses of the sea. OSPAR says it has taken action with PARCOM Recommendation 88/4 on Nuclear Reprocessing, PARCOM Recommendation 91/4 on Radioactive Discharges, PARCOM Recommendation 93/5 Concerning Increases in Radioactive Discharges from Nuclear Reprocessing Plants, PARCOM Recommendation 94/8 Concerning Environmental Impact Resulting from Discharges of Radioactive Substances, and with PARCOM Recommendation 94/9 Concerning the Management of Spent Nuclear Fuel. But the reality is what counts; and the reality is that since the 1992 OSPAR Ministerial Meeting recognised (in the Ministerial Declaration´s section entitled "Priorities and Objectives for Future Work" !) "the need to reduce radioactive discharges from nuclear installations to the marine environment" , radioactive discharges have continued to increase. Clearly, the UK and France have not fulfilled their obligations under the Convention, and have continued to pollute the Convention area. The collective inertia within RAD and OSPAR, feeds those who maintain that "the OSPAR Convention is not worth the piece of paper it is written on". Greenpeace International in contrast has always supported the OSPAR Commission in good faith, but the effectiveness of your action to stop nuclear reprocessing discharges and emissions between now and the MMC will be among the main test-case by which the success or failure of the OSPAR Commission will be measured. Irish Proposal (PRAM 97/6/5) Greenpeace International has already expressed (HODCM 97/NGO.1) support for the Draft OSPAR [PARCOM ?( Recommendation on Radioactive Discharges presented by Ireland (see: PRAM 97/6/5, and section 4.3.f of the Annotations to the Draft Agenda, OSPAR 97/1/1). Yet we find that Ireland´s proposal would be strengthened if it was amended as follows: (1) The measures referred in Operative paragraph (b) should not be restricted to the use of Best Available Techniques and abatement programmes, measures and techniques; they should also involve alternative nuclear spent management options (i.e. BAT for spent fuel management; and (2) Operative paragraph (c, or an additional operative paragraph, should address other radionuclides in addition to Technitium-99. We would expect consensus on at least the first amendment, given that it is consistent with PARCOM Recommendation 94/9 Concerning the Management of Spent Nuclear Fuel. New Evidence Of Environmental Pollution At La Hague In June 1997, Greenpeace took samples of seabed sediments and seawater at the end of the La Hague nuclear waste discharge pipe. Analysis of these samples for beta and gamma radiation confirmed that the environment around the pipe is heavily polluted. The pollution is so great that parts of the environment itself have become classified radioactive waste. Tables 1a and 1b show radionuclides detected in seabed sediments. The analysis shows that near the end of the La Hague discharge pipe the seabed itself is classified radioactive waste. The classifications of radioactive waste vary within OSPAR countries, but for example, the levels of each of the radionuclides Co-60, Ru-106, Sb-125 and Cs-137 alone would all qualify the seabed itself for treatment as low-level radioactive waste (LLW) under UK classifications. Tables 2a and 2b show radionuclides detected in two analyses of seawater discharged from the pipe. The results show that, at times, the sea itself is so polluted that it becomes classified radioactive waste. For example, the levels of tritium (H-3) alone would classify this seawater sample as intermediate-level waste (ILW) under UK classifications, and the levels of Cs-137 alone would classify it as low-level waste (LLW). Whilst these extremely high levels of pollution close to the pipe are of major concern, they reveal only the immediate and obvious pollution caused by La Hague's discharges. There is also evidence that pollution of the wider environment is significant. Collective doses arise however low the concentration, because there is no dose of radiation at which health and environmental effects do not occur. Thus dilution of radioactivity further from the pipe does not protect the environment or human health. In addition, many radionuclides are also persistent and may physically or biologically accumulate to high levels elsewhere in the environment. Thus dilution of radioactivity does not mean high concentrations cannot arise elsewhere or that health effects do not arise. Further evidence of these processes occurring in the Irish Sea is given below. Table 1a. Radioactivity detected in a small stone near the pipe (analysed by the University of Bremen, D)
Table 1b. Radioactivity detected in 3 samples of stones and sediment near the pipe (analysed by Hamburg Department of Environment, D)
Table 2a. Radioactivity detected in one of the seawater samples analysed by the NIOZ laboratory (NL).
Table 2b. Radioactivity detected in one of the seawater samples analysed by the Hamburg Department of Environment (D).
New Evidence Of Environmental Pollution At Sellafield In its submissions to RAD and HOD, Greenpeace has repeatedly drawn the attention of OSPAR to the extremely high levels of technetium-99 in lobsters in the Irish Sea (Ref. RAD 97/9/NGO.1 and HODCM 97/NGO.1). Further data released in May 1997 has shown that levels of radioactivity in seafood continue to grow rapidly, with levels of up to 36,000 Bq/kg of technetium-99 measured in lobster in the last quarter of 1996 (BNFL, Statutory Environmental Monitoring Programmes, Quarter 4, 1996). These levels are now 92 times higher than those found in 1993. No action has been taken to reduce or eliminate the discharges giving rise to this contamination. In fact, BNFL, which operates Sellafield, is currently investing substantial amounts of money in extending the lifetime of its Magnox reprocessing plant, which is the source of the technetium-99 discharges. In the Annex to Greenpeace's submission to HOD (Ref. HODCM 97/NGO.1), health physicist Dr David Sumner noted the poor level of scientific understanding in relation to the behaviour of technetium-99 in the environment. He expressed concerns that the sea was being treated as an experimental laboratory and that the precautionary principle was not being applied. A recent paper, published in April 1997, has added yet further weight to these concerns (Hill et al., "The Summer Gyre in the Western Irish Sea: Shelf Sea Paradigms and Management Implications"). The authors report the discovery of a new gyre (ocean circulation) in the Irish Sea, which could trap radionuclides close to the Irish coast during the summer. They state that a pathway from Sellafield to Irish coastal waters has been suggested, and continue: The discovery of the gyre now provides a clear physical mechanism, assuming material can be entrained into the gyre north-west of the Isle of Man, for such a pathway (in spring/summer at least) and which is potentially quite rapid […] Hill et al also report that the western Irish Sea is an important spawning ground for cod, haddock, sprat, whiting and the Norway Lobster (Nephrops): A potentially important consequence of the seasonal gyre is that, just as it is able to retain marine plankton, so it can also retain contaminants. For this reason, populations associated with such systems may be at particular risk in the event of spring or summer oil and chemical spills. These recent measurements provide dramatic new evidence that the effects of radioactive discharges into the Irish Sea have not been understood. So-called predictions of the effects of discharges from Sellafield on human health and the environment have suffered from a significant lack of scientific knowledge and understanding. It has wrongly been assume that dilution and dispersion would prevent pollution Conclusion Urgent action to reduce and eliminate discharges is clearly needed to protect the coast and ecosystems of the North East Atlantic from nuclear reprocessing. In adopting the Irish proposal (PRAM 97/6/5) with the amendments suggested in Paragraph 8, above, OSPAR will act in accordance with its own legal and political obligations. They will also act in accordance with the Principles of Radioactive Waste Management adopted in 1995 by the International Atomic Energy Agency (IAEA Safety Series No. 111-F), namely: The preferred approach to radioactive waste management is concentration and containment of radionuclides rather than dilution and dispersion in the environment (Para 308 of IAEA Safety Series No.111-F); |