Letter from the Ministry of Environment to Sellafield Review Environment Agency, England, 02.03.01

Technetium discharges from Sellafield

COMMENTS ON THE ENVIRONMENT AGENCY’S PROPOSALS FOR THE FUTURE REGULATION OF TECHNETIUM-99 DISCHARGES FROM SELLAFIELD

Reference is made to the Environment Agency’s announcement of 30 November 2000, inviting comments on the Agency’s proposals for the future regulation of technetium-99 discharges from Sellafield. We are grateful for this opportunity to express the view of a major "recipient country" with regard to radioactive pollution from UK reprocessing facilities. Norway depends heavily on the utilisation of marine resources and the quality of the marine environment. Radioactive contaminants which are transported from UK reprocessing facilities to Norwegian waters is therefore an issue of considerable public concern in Norway.

We strongly urge the Environment Agency (EA) to reconsider their proposal with regard to future regulation of technetum-99 discharges from Sellafield. In line with earlier proposals by the Nordic Ministers of Environment, we suggest that the discharges of technetium-99 (Tc-99) should be reduced to pre-1994 levels immediately, and that the total amount of Tc-99 entering the marine environment from reprocessing of stored as well as "new" liquid waste (MAC) must be kept at a minimum level.

It is well known that technetium-99 from Sellafield is transported with ocean currents to Norwegian waters. The likely result of continued discharges at the present high levels is that the increasing trends of Tc-levels in marine biota such as seaweed and lobster in Norwegian waters will continue. From experience we know that the international sea-food markets are extremely susceptible even to rumours of radioactive pollution. We are therefore concerned that continued pollution from Sellafield may taint the public perception of our sea-food and other marine products.

From the consultation paper it is clear that the Environment Agency’s proposal to retain the current high technetium discharge limit of 90 terrabequerel/year for Sellafield until 2006 actually means that the entire backlog of stored liquid waste (MAC) from the reprocessing of Magnox fuel will be treated in the Enhanced Actinide Removal Plant (EARP) before any technology to remove Tc-99 from the waste is installed. In fact, the proposal implies that techniques to remove Tc-99 will be installed only after the storage tanks have been completely emptied and their entire contents of Tc-99 discarged into the marine environment. This option also means that more than 70% of the total amount of Tc-99 in stored as well as "new" MAC from the remaining period of Magnox reprocessing will enter the marine environment. From our perspective, this is neither an acceptable nor a rational option.

In their consultation paper, the Environment Agency (EA) has outlined four potential options, ranging from reducing the technetium-99 discharge limit to 10 terrabequerel/year in 2001, to retaining the current discharge level of 90 Tbq/year. The option to reduce the technetium-99 discharge limit to 10 terrabequerel/year in 2001 includes continued storage of all MAC until 2005-2006, when the storage tanks will be full. At this stage technology to remove Tc-99 from MAC will be installed at EARP, allowing the treatment off all MAC with adequate removal of TC-99. According to the consultation paper, this would reduce the total discharges of Tc-99 by more than 80% compared to the EA’s preferred option. To reduce the technetium-99 discharge limit to 10 terrabequerel/year in 2001 will be in line with what has been suggested by the Nordic Ministers of Environment.

At the ministerial meeting of the OSPAR Commission in Sintra in July 1998, the ministers adopted a Strategy with Regard to Radioactive Substances. According to this strategy, the pollution of the maritime area from ionising radiation should be prevented through progressive and substantial reductions in emissions and discharges of radioactive substances to the maritime area in the years to come. This strategy also includes a commitment already in 2000 to work towards achieving further substantial reductions or elimination of discharges, emissions and losses of radioactive substances. This commitment and the interests of "recipient countries" have apparently not been taken into due consideration by the Environmental Agency in the recommendation of their preferred option.

It is our sincere hope that the concerns and interests of recipient countries and the commitments under the OSPAR Convention will lead the EA and the UK Government to conclude that the option to reduce the discharge limit to 10 Tbq/year already in 2001 is the right choice.

Yours sincerely,
Turid Sand
Acting Director General

Fredrik Juell Theisen
Adviser

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Department of the Environment Transport and the Regions
Eland House, Bressenden Place, London SW 1 E 5 DU
Royal Norwegian Embassy, London
Norwegian Ministry of Foreign Affairs
Norwegian Radiation Protection Agency, Postboks 55 1332 Østerås