Possible toxic effects from the nuclear reprocessing plants at Sellafield (UK) and cap de la Hague (France) : a first contribution to the scientific debate.
Date: 2018-03-01
Institutions: Directorate-General for Parliamentary Research Services
Subjects: France, United Kingdom, health risk, international law, nuclear power station, radioactive waste, toxic substance

STOA

Scientific and Technological Options Assessment

POSSIBLE TOXIC EFFECTS
FROM THE
NUCLEAR REPROCESSING PLANTS
AT SELLAFIELD (UK)
AND
CAP DE LA HAGUE (FRANCE)

A first contribution to the scientific debate

1.) Introduction: Letter to the reader by the Chairman of the STOA
Panel on the decision taken by the Panel on 23 October 2001

2.)  Study by WISE - Paris

3.)  Evaluation reports by experts

Luxembourg, November 2001

Directorate General for Research

 EN

QA-48-02-448-EN-N

               EN

Title:

POSSIBLE  TOXIC  EFFECTS  FROM  THE  NUCLEAR
REPROCESSING  PLANTS  AT  SELLAFIELD  AND  CAP  DE  LA
HAGUE

Workplan Ref.:

EP/IV/A/STOA/2000/17/01

Publisher:

European Parliament

Directorate General for Research

Directorate A

The STOA Programme

Authors:

WISE - Paris,

Study director: Schneider, M.,

Study team: Coeytaux, X., Faïd, Y.B., Marignac, Y., Rouy, E.,

Thompson, G. (IRSS, Cambridge, USA)

Fairlie, I., Lowry, D., Sumner, D. (Independent consultants)

Editor:

STOA Unit

Date:

November 2001

PE number:

PE  303.110

This document is a working Document for the 'STOA Panel'.  It is not an official publication of STOA.

This  document  does  not  necessarily 

represent 

the  views  of 

the  European  Parliament

POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

1. LETTER TO THE READER................................ ................................ ................................ ....3
2. STUDY BY WISE-PARIS ............................................................................................................5
EXECUTIVE SUMMARY AND GENERAL CONCLUSIONS................................ ................................ .....9
1. Introduction................................ ................................ ................................ ................................ ...... 9
2. Reprocessing Status and Issues................................ ................................ ................................ ......... 9
3. International and European Legal Framework................................ ................................ ................... 9
4. Risk Assessment of Radioactive Releases................................ ................................ ....................... 10
5. Case Study Sellafield................................ ................................ ................................ ...................... 11
6. Case Study La Hague................................ ................................ ................................ ...................... 13
7. Comparative and Cumulative Analysis................................ ................................ ............................ 15
8. Alternative Options................................ ................................ ................................ ......................... 15

3.1.3.1. Euratom Treaty

General Conclusions ................................. ......................................................................................... 16
1.
INTRODUCTION ................................ ................................ ................................ ...................... 17
1.1. OBJECTIVE OF THE STUDY ................................ ................................ ................................ .................. 17
1.2. BACKGROUND AND CHRONOLOGY OF THE PROJECT ................................ ................................ ........... 18
2. REPROCESSING STATUS AND ISSUES................................ ................................ ....................... 19
2.1. NUCLEAR REPROCESSING ................................ ................................ ................................ ................... 19
2.2. ORIGINS OF REPROCESSING ................................ ................................ ................................ ................ 19
2.3. IMPLICATIONS OF REPROCESSING ................................ ................................ ................................ ....... 20
3.
INTERNATIONAL AND EUROPEAN LEGAL FRAMEWORK................................ ......................... 21
3.1. INTERNATIONAL LEGISLATION AND TREATIES................................ ................................ .................... 21
3.1.1. Major International Bodies................................ ................................ ................................ ........ 21
3.1.2. Major International Conventions................................ ................................ ............................... 21
3.1.3. The European Legal Framework And Its Implementation................................ .......................... 22
22
3.2. MARINE POLLUTION - APPLICATION OF THE PRECAUTIONARY PRINCIPLE................................ ........... 26
4. RISK ASSESSMENT OF RADIOACTIVE RELEASES................................ ................................ .....28
4.1. RELEASES FROM REPROCESSING................................ ................................ ................................ ......... 28
4.2. COLLECTIVE DOSES................................ ................................ ................................ ............................ 28
4.2.1. Introduction................................ ................................ ................................ .............................. 28
4.2.2. Theoretical Justification................................ ................................ ................................ ............ 28
4.2.3. Global Collective Doses................................ ................................ ................................ ............ 29
4.2.4. Important Radionuclides in Reprocessing Releases................................ ................................ ... 29
29
29
29
30
30
4.3. UNCERTAINTIES IN RISK ASSESSMENT................................ ................................ ................................ 31
5. CASE STUDY SELLAFIELD ................................ ................................ ................................ ......33
5.1. NATIONAL REGULATORY FRAMEWORK ................................ ................................ .............................. 33
5.2. OPERATIONS AT SELLAFIELD................................ ................................ ................................ .............. 33
5.3. RELEASES FROM SELLAFIELD ................................ ................................ ................................ ............. 34
5.3.1. Air Emissions................................ ................................ ................................ ........................... 34
5.3.2. Liquid Discharges................................ ................................ ................................ ..................... 35
5.3.3. Technetium Discharges................................ ................................ ................................ ............. 37
5.3.4. Expected Future Sellafield Discharges................................ ................................ ...................... 37
5.4. IMPACT OF SELLAFIELD DISCHARGES ................................ ................................ ................................ . 39
5.4.1. Plutonium and other actinides near Sellafield................................ ................................ ............ 39
5.4.2. Estimated Doses from Consumption of Irish Sea Fish and Shellfish................................ .......... 40

4.2.4.1. Carbon-14 (14C)
4.2.4.2. Krypton-85 (85Kr)
4.2.4.3.
4.2.4.4. Tritium (3H)
4.2.4.5. Technetium-99 (99Tc)

Iodine-129 (129I)

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Intermediate Level Waste (ILW)

5.4.5.1. Technetium-99 Concentrations in Marine Samples
5.4.5.2. Uptake of Technetium-99 by Marine Plants and Animals

5.4.4.1. Changes between 1989-1999
5.4.4.2. Detailed Concentrations in Fish, Shellfish, Sediments and Aquatic Plants

5.4.3. Doses to Critical Groups................................ ................................ ................................ ........... 40
5.4.4. Environmental Concentrations................................ ................................ ................................ .. 40
40
41
5.4.5. Technetium Concentrations................................ ................................ ................................ ....... 41
41
42
5.4.6. Conclusions on Concentrations and Doses................................ ................................ ................ 43
5.5. THE HAZARD POSED BY LIQUID HIGH LEVEL WASTE AT SELLAFIELD................................ ................. 44
5.6. HEALTH EFFECTS AT SELLAFIELD................................ ................................ ................................ ....... 46
5.6.1. Childhood Leukemia at Seascale................................ ................................ ............................... 46
5.6.2. Paternal Pre-Conception Irradiation................................ ................................ .......................... 47
5.6.3. Population Mixing................................ ................................ ................................ .................... 47
5.6.4. Other Possible Health Effects at Sellafield................................ ................................ ................ 47
5.6.5. Conclusions on Health Effects................................ ................................ ................................ .. 48
6. CASE STUDY LA HAGUE................................ ................................ ................................ ......... 49
6.1. NATIONAL REGULATORY FRAMEWORK ................................ ................................ .............................. 49
6.1.1. Authorisations of discharges................................ ................................ ................................ ..... 49
6.1.2. Licensing Procedures................................ ................................ ................................ ................ 50
6.1.3. Supervision................................ ................................ ................................ ............................... 51
6.1.4. Radioprotection................................ ................................ ................................ ........................ 51
6.1.5. References to International Legislation................................ ................................ ..................... 52
6.2. OPERATION AT LA HAGUE................................ ................................ ................................ .................. 52
6.2.1. Reprocessing at La Hague................................ ................................ ................................ ......... 52
6.2.2. Waste Production of La Hague................................ ................................ ................................ .. 53
55
55
55
55
55
6.3. DISCHARGES FROM LA HAGUE ................................ ................................ ................................ ........... 56
6.3.1. Authorisations ................................ ................................ ................................ .......................... 56
6.3.2. Discharge levels of major radionuclides................................ ................................ .................... 59
6.3.3. Discharge trends................................ ................................ ................................ ....................... 60
6.3.4. Unplanned Radioactive Releases................................ ................................ ............................... 60
60
60
6.4. ENVIRONMENTAL CONCENTRATIONS AND DOSES................................ ................................ ............... 61
6.4.1. Environmental Concentrations................................ ................................ ................................ .. 61
6.4.2. Doses from Environmental Radiation................................ ................................ ........................ 62
6.5. IMPACT OF LA HAGUE DISCHARGES – BACKGROUND STUDIES ................................ ........................... 62
6.5.1. Marine effects................................ ................................ ................................ ........................... 62
6.5.2. Health Effects................................ ................................ ................................ ........................... 63
63
63
63
65
65
6.5.3. Uncertainties in Dose Assessments................................ ................................ ........................... 65
65
66
7. COMPARATIVE AND CUMULATIVE ANALYSIS................................ ................................ ......... 68
7.1. COMPARISON OF RELEASES IN 1999 FROM LA HAGUE AND SELLAFIELD ................................ ............. 68
7.2. KEY NUCLIDES FOR COLLECTIVE DOSE CALCULATION................................ ................................ ....... 69
7.2.1. Carbon-14................................ ................................ ................................ ................................ . 69
7.2.2. Krypton-85................................ ................................ ................................ ............................... 69
7.2.3. Iodine-129................................ ................................ ................................ ................................ 69

6.5.2.1. Cancer morbidity inquiry in the Manche Department
6.5.2.2. Epidemiological study by Viel and Pobel
6.5.2.3. The Radioecological Group of North-Cotentin (GRNC) survey
6.5.2.4. La Hague Childhood Leukaemia Study 2001
6.5.2.5. “Radiological impacts of spent nuclear fuel management options”, NEA, 2000

6.2.2.1. Low Level Waste (LLW)
6.2.2.2.
6.2.2.3. High Level Waste (HLW)
6.2.2.4. “Curie-swap”
6.2.2.5. Reprocessing at La Hague and HLW long-term management

6.5.3.1. A Mandate for the Radio-ecological Group of North-Cotentin to Assess Scientifi c Uncertainties
6.5.3.2. Sources of Uncertainties

6.3.4.1. Major accidents and list of incidents at La  Hague plant
6.3.4.2. Potential Hazards at the La Hague plant

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7.3.1.1. European Doses
7.3.1.2. Global Doses

7.3. COLLECTIVE DOSES FROM REPROCESSING RELEASES ................................ ................................ ......... 70
7.3.1. Collective Doses from Reprocessing................................ ................................ ......................... 70
70
71
7.3.2. Commentary on Collective Doses from Sellafield and La Hague................................ ............... 71
7.3.3. Use in Comparative Studies................................ ................................ ................................ ...... 72
7.3.4. Use in Cost/Benefit Studies................................ ................................ ................................ ....... 72
7.3.5. Chapter Conclusions................................ ................................ ................................ ................. 73
8. ALTERNATIVE OPTIONS ................................ ................................ ................................ ......... 74
8.1. WASTE MANAGEMENT ISSUES................................ ................................ ................................ ............ 74
8.1.1. Re-use of plutonium and uranium................................ ................................ ............................. 74
8.1.2. Final volume of waste................................ ................................ ................................ ............... 75
8.2. ECONOMICS OF DIRECT DISPOSAL VS. REPROCESSING ................................ ................................ ........ 75
8.3. DRY STORAGE................................ ................................ ................................ ................................ .... 77
9. POLICY OPTIONS................................ ................................ ................................ .................... 78
9.1. RELEASES OF RADIOACTIVE WASTES AND THEIR EFFECTS ON THE ENVIRONMENT AND HEALTH ....... 78
9.2. MANAGEMENT OF NON-DISCHARGED RADIOACTIVE WASTES ................................ ............................ 80
9.3. MANAGEMENT OF PLUTONIUM STOCKS................................ ................................ .............................. 80
9.4. DEVELOPMENT OF SPENT FUEL MANAGEMENT ALTERNATIVES................................ .......................... 81
9.5. DEVELOPMENT OF DEMOCRATIC DECISION MAKING TOOLS................................ ............................... 81
ANNEXES................................ ................................ ................................ ................................ .......82
ANNEX 1 Excerpts from Petition 393/95................................ ................................ ................................ ... 83
ANNEX 2 International Conventions................................ ................................ ................................ ......... 84
ANNEX 3 OSPAR Convention................................ ................................ ................................ .................. 85
ANNEX 4 European Legislation, Regulation and Policy Statements................................ ........................... 87
ANNEX 5 The Precautionary Principle: Not Using the Sea as an Experimental Laboratory ........................ 89
ANNEX 6 Background Information on Collective Dose................................ ................................ ............. 90
ANNEX 7 Individual Exposures from Consumption of Seafood around Sellafield................................ ...... 92
ANNEX 8 Concentration of Radionuclides in Seafoods from Sellafield................................ ..................... 93
ANNEX 9a Environmental Concentrations of Nuclide Discharges from Sellafield................................ ....... 94
ANNEX 9b Environmental Concentrations of Nuclide Discharges from La Hague................................ ..... 100
ANNEX 10 Specific Radiobiological Issues................................ ................................ ............................... 103
ANNEX 11 Possible Causes for the Discrepancy between Observed Cancers and Estimated Low Doses.... 106
ANNEX 12 Evolution of the Waste Stockpiles Managed at La Hague................................ ........................ 108
ANNEX 13 The Return of Foreign Waste from Reprocessing at La Hague................................ ................. 109
ANNEX 14 Compared Discharge Limits of La Hague and a Typical Reactor Site................................ ...... 110
ANNEX 15 Compared Real Radioactive Discharges from La Hague and One PWR................................ ... 111
ANNEX 16 Chronological List of 8 Significant Accidents at La Hague since 1968 ................................ .... 112
ANNEX 17 Incidents/Accidents at La Hague declared to the French Safety Authorities between 1989 and

2000 ................................ ................................ ................................ ................................ ....... 114
ANNEX 18 Type of Accidents and Consequences at Reprocessing Sites................................ .................... 117
ANNEX 19 Comparison of Caesium-137 Contained in Spent Fuels Stored at La Hague and Released During

the Chernobyl Accident................................ ................................ ................................ .......... 118
ANNEX 20 Concentration Factors for Selected Radionuclides................................ ................................ ... 119
ANNEX 21 Comparison between the Morbidity Observed in the District of Cherbourg and in the District of

Avranches................................ ................................ ................................ ............................... 120
ANNEX 22 Individual Committed Dose for Six Reference Groups near La Hague (GRNC Estimates)....... 121
ANNEX 23 OECD Nuclear Energy Agency Dose Estimates for the Public and Workers for the Reprocessing
and Direct Disposal Options................................ ................................ ................................ ... 122

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ANNEX 24 Assessment of the “non-attributed”  activity of Iodine-129 at La Hague ................................ ... 123
ANNEX 25 Letter to Annie Sugier, President of the Radio-Ecological Group North-Cotentin, about

Iodine-129 ................................ ................................ ................................ .............................. 124
ANNEX 26 Separation, Re-Use and Exportation of Plutonium in France................................ ................... 129
ANNEX 27 Material and Economic Balances over the French Reactor Lifetime - Direct Disposal vs.

Reprocessing................................ ................................ ................................ .......................... 130
ANNEX 28 Dry Storage Technologies................................ ................................ ................................ ....... 131
ANNEX 29 Dry Storage Economics................................ ................................ ................................ .......... 135
ANNEX 30 Data on Radionuclides................................ ................................ ................................ ............ 138
GLOSSARY................................ ................................ ................................ ................................ ...139
BIBLIOGRAPHY ................................ ................................ ................................ ........................... 142
LIST OF TABLES AND FIGURES ................................ ................................ ................................ ....155

 . - . - . - .- .

3. EVALUATION REPORTS BY EXPERTS

Evaluation Report Croudace ..................................................................................................................

160

Evaluation Report Mitchell ....................................................................................................................
Evaluation Report Zerbib ......................................................................................................................    168

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EXECUTIVE SUMMARY AND GENERAL CONCLUSIONS

1. Introduction

The  principal  aim  of  this  report  is  to  assist  the  Committee  of  Petitions  of  the  European  Parliament  in  its
consideration  of  Petition  393/95  brought  by  Dr.  W.  Nachtwey.  The  Petition  expresses  concerns  about
radioactive discharges from nuclear reprocessing plants at Sellafield in the UK and La Hague in France, and
their  possible  adverse  health  effects.  Six years  after  the  Petition  was  introduced,  the  Petitioner’s  main
concerns  remain  relevant.  This  report  concludes  that  reprocessing  discharges  are  a  valid  matter  for  the
Committee’s  consideration.  It  also  concludes  that,  on  balance,  the  Petitioner's  concerns  over  radioactive
discharges from Sellafield and La Hague are justified.

The report presents evidence and data on:

• radioactive discharges from the Sellafield and La Hague sites;
• resulting nuclide concentrations in environmental media including foodstuffs;
• radiation doses from nuclide discharges to critical groups near the sites;
• adverse health effects near the two sites; and
• resulting collective doses from nuclide discharges.

The report also examines a number of current issues in radiobiology concerning health effects from exposure
to ionising radiation, in particular genetic and in utero effects.

In  addition,  in  accordance  with  contract  specifications,  the  report  examines  other  major  factors  that  might
influence  future  decision-making  on  reprocessing.  It  provides  information  on  the  legal  framework,  the
operational history of the plants and the economic case for reprocessing compared with available alternatives
for  spent  nuclear  fuel  management.  The  report  also  makes  policy-related  recommendations  that  take  into
account  current  knowledge and  uncertainties  in  risk  assessment  and  the  availability  of  alternatives  to
reprocessing in spent fuel management.

2. Reprocessing Status and Issues

Only  5%  to  10%  of  world  annual  spent  fuel  arisings  is  submitted  for  reprocessing,  with  the  rest  stored
pending final disposal in a repository. The largest centres in the world for commercial reprocessing remain
Sellafield  in  the  UK  and  La  Hague  in France.  Reprocessing  involves  the  dissolution  of  the  spent  fuel  in
boiling  concentrated  nitric  acid  and  subsequent  physico-chemical  separations  of  uranium  and  plutonium.
Multiple  waste  streams  are  created  by  these  physical  and  chemical  processes.  While  some  wastes  are
retained  and  conditioned,  considerable  volumes  of  liquid  and  gaseous  wastes  are  released  to  the
environment.  Reprocessing  operations  release  considerably  larger  volumes  of  radioactivity  than  other
nuclear activities, typically by factors of several 1,000 compared with nuclear reactors.

3. International and European Legal Framework

The  report  provides  a  brief  overview  of  Major  International  Bodies  that  play  a  role  in  the  development  of
international  nuclear  standards  and  the  main  International  Conventions  relative  to  nuclear  reprocessing
are presented.

The OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic, to which
the  European  Commission  is  a  Contracting  Party,  is  of  particular  relevance  to  reprocessing  activities.  The
OSPAR  Commission  has  declared  its  commitment  to  the  application  of  the  precautionary  principle,  the
polluter-pays principle, and to the application of Best Available Techniques (BAT) and Best Environmental
Practice (BEP), including, where appropriate, Clean Technology. At the Sintra Meeting in 1998, Ministers
agreed  to  reduce  marine  pollution “with  the  ultimate  aim  of  achieving  concentrations  in  the  environment

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near  background  values  for  naturally  occurring  substances  and  close  to  zero  for  man-made  synthetic
substances.” They emphasised the importance of the Precautionary Principle in this work. It is notable that
the commitment is to achieve concentrations in the environment close to zero, not merely concentrations in
discharges. At the Copenhagen Meeting in June 2000, the OSPAR Commission voted unanimously (with the
abstentions  of  the  UK,  France  and  the  European  Commission)  that  discharge  authorisations  be  reviewed
“with a view to, inter alia: implementing the non-reprocessing option (for example dry storage).”

The Euratom Treaty provides the basis for the European regulation of the nuclear sector. Article 34 requires
Member  States  to  obtain  the  opinion  of  the  European  Commission  before  they  carry  out “dangerous
experiments.”  According  to  the  Commission,  France  has  not  requested  the  Commission’s  opinion  under
Article 34 concerning activities in La Hague nor has the UK as regards activities in Sellafield.

å Conclusions on “Dangerous Experiments”

The  Member  States  UK  and  France  apparently  have  not  complied  with  Article 34  of  the  Euratom  Treaty,
since  they  have  never  requested  the  European  Commission’s  opinion  under  the  article  concerning  any  of
their activities at Sellafield and La Hague.

Article 35  of  the  Euratom  Treaty  grants  control  rights  to  the  European  Commission  for  the  verification  of
operation  and  efficiency  of  monitoring  equipment  at  nuclear  facilities.  However,  only  one  verification
mission  was  carried  out  at  Sellafield  (1993)  and  La  Hague  (1996).  These  are  considered  to  be  outdated.
Furthermore, the Commission is apparently highly dependent on information provided by Member States. It
is  equally  doubtful  whether  the  Commission  is  in  a  position  to  determine,  as  required  under  Article 37,
whether the reprocessing activities are liable to result in the radioactive contamination of the water, soil or
airspace  of  another  Member  State.  In  addition  to  the  dependence  on  Member  States’  information,  the
Commission  spends  only  extremely  limited  manpower  into  the  evaluation  of  nuclear  projects  (2  person-
months in the case of reprocessing plants).

å Conclusions on European Commission Responsibilities under Article 35 of the Euratom Treaty

The  Commission’s  verification  activities  make  ineffective  use  of  its  control  rights  over  monitoring
equipment. Statements by the Commission on monitoring at Sellafield and La Hague are not backed up by
credible data. It is noted, however, that the Commission is currently reviewing its verification activities.
The  Commission  is  apparently  not  in  a  position  to  guarantee  that  the  Basic  Safety  Standards  are  respected
concerning  the  La  Hague  and  Sellafield  facilities  and  to  determine  whether  the  reprocessing  activities  are
liable to result in the radioactive contamination of the water, soil or airspace of other Member States.

4. Risk Assessment of Radioactive Releases

Radioactive  discharges  from  both  sites  are  very  large  and  indeed  rank  among  the  largest  anthropogenic
sources  of  radioactivity  to  the  world.  As  such  they  constitute  a  reasonable  subject  for  enquiry  by  the
Committee.  Nuclides  released  to  air  and  sea  result  in  the  contamination  of  food  chains  via  a  number  of
pathways. Individuals may also receive radiation doses from immersion in radioactive aerosols, inhalation of
radioactive gases and particulate matter, and ground shine from nuclides deposited on land.

Various computer models have been designed to estimate radiation doses from nuclide releases to members
of critical groups living near nuclear facilities. These calculated doses are used to regulate discharges from
nuclear facilities.

However, this approach protects individuals and not populations. The use of collective doses has therefore
been  stipulated  by  various  international  bodies,  including  the  European  Commission  in  the  Basic  Safety
Standards  Directive  (96/29).  Crucial  theoretical  underpinning  for  collective  dose  was  provided  by  the
scientific  community’s  adoption  of  the  Linear  No-Threshold  model  for  radiation’s  adverse  health  effects.
This  states  that  there  is  no  level  of  radiation  exposure  below  which  there  is  no  effect:  risks  continue  with
declining doses until zero dose. Even the smallest possible dose, i.e. a photon passing through a cell nucleus,
carries with it a risk of cancer. Although this is an extremely small risk, it is still a finite risk.

Collective dose estimates strongly depend on the size of the population considered and the time scale used.
Opinions vary as to which populations and time scales should be used. Given the very long term half-lives of

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some  radionuclides  released  by  reprocessing  plants (e.g.  iodine-129,  16  million  years)  and their  global
distribution, there should be no time limits and dose evaluations should be global. There is no reason why
future generations or distant populations should be any less protected than current generations in the vicinity
of the facilities.

Comparisons of doses from nuclear activities with those induced by natural background radiation are flawed
because,  inter  alia,  these  omit  to  indicate  the  health  impact  of  background  radiation  itself.  It  has  been
estimated that natural background radiation results in about 6,000 to 7,000 UK cancer deaths per year in the
UK with a similar figure for France.

å Conclusions on Dose Estimates

In  order  to  evaluate  the  risk  of  large  releases  of  radionuclides  into  the  environment,  in  addition  to  critical
group  dose  estimates,  collective  dose  calculations  should  be  carried  out  and  taken  into  account  during
decisions on the continued operation of reprocessing plants.

5. Case Study Sellafield

Between 1965 and the end of year 2000, about 26,000 tonnes of spent gas graphite fuel were reprocessed by
the  B205  line  at  Sellafield.  About  3,000  tonnes  of  spent  light  water  reactor  fuel  have  been  reprocessed  at
THORP since 1994. Based on current contracts and annual throughput rates, both plants are expected to shut
down within the next 10 years or earlier.

Although  gaseous  releases  of  most  nuclides  from  Sellafield  have  not  varied  to  a  marked  extent  since  the
1970s, iodine-129 emissions have increased 10-fold. Radioactive marine releases of carbon-14, strontium-90
and caesium declined markedly in the early 1980s, while in the mid 1990s increases occurred in releases of
carbon-14,  cobalt-60,  strontium-90,  technetium-99  and  iodine-129.  Over  the  same  period,  actinide  (mainly
plutonium) discharges have declined markedly.

Internal  BNFL  documents  suggest  significant  increases  in  nuclide  releases  in  the  future  at  Sellafield.  For
some “worst  case”   scenarios,  the  operator  predicts  for “levels  approaching  or  above  the  limits”  for  sea
discharges  of  over  half  the  currently  authorised  radionuclides.  A  similar  situation  is  expected  for
aerial releases.

å Conclusions on Sellafield Releases

Increases  of  releases  of  key  radionuclides  from  Sellafield  in  the  late  1990s  and  expected  future  discharges
are inconsistent with obligations under the OSPAR Convention.

The deposition of plutonium within 20 km of Sellafield attributable to aerial emissions has been estimated at
160-280 GBq (billion becquerels), that is two or three times plutonium fallout from all atmospheric nuclear
weapons testing. In addition, significant quantities of radionuclides can become airborne in sea spray and be
transported inland by the wind. The average activity due to actinides from the sea may occasionally exceed
the international limit of 1 mBq/m3.

It  has  been  estimated  that  over 40,000 TBq  (trillion  becquerels)  of  caesium-137,  113,000 TBq  of  beta
emitters  and  1,600 TBq  of  alpha  emitters  have  been  discharged  into  the  Irish  Sea  since  the  inception  of
reprocessing at Sellafield. This means that between 250  and 500 kilograms of plutonium from Sellafield is
now adsorbed on sediments on the bed of the Irish Sea. The migration of undersea deposits of actinides to
coastal environments represents a long-term hazard of largely unknown proportions.

Technetium-99  (half-life  214,000  years)  discharges  have  led  to  particular  concern.  In  1997,  technetium
concentrations  in  crustacean –  particularly  in  lobster –  reached  13 times  the  European  Council  Food
Intervention  Level (CFIL)  in  the  vicinity  of  Sellafield.  Some  technetium  concentrations  above CFIL  limits
have  also  been  found  in  molluscs (winkles,  mussels,  limpets  and  whelks).  Recent  environmental  surveys
along the Norwegian coast indicate a six-fold increase in technetium concentrations in seaweed since 1996.
Concentration  factors  are  greater  than 1,000  for  some  biota  such  as  macrophytic  brown  algae,  worms  and
lobsters  and  are  particularly  high  for  some  seaweeds  (around 100,000).  In  1999,  a  number  of  high

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concentrations  of  various  radionuclides  were  also  recorded  in  fish,  shellfish,  sediments  and  aquatic plants,
some  exceeding  CFILs  several  times.  Large  uncertainties  remain  in  the  field  of  transfer  of  technetium  in
the biosphere.

å Conclusions on Radionuclide Concentrations in the Sellafield Environment

Marine  discharges  at  Sellafield  have  led  to  significant  concentrations  of  radionuclides  in  foodstuffs,
sediments and biota. Discharges lead to current concentrations in some foodstuffs, which exceed European
Community Food Intervention Levels (CFILs). The transfer of technetium to the biosphere is of particular
concern,  because  of  its  long  half-life  (214,000  years),  its  mobility  in  seawater  and  the  high  concentration
factors  in  plants.  Large  uncertainties  remain  as  to  the  transfer  mechanisms  and  environmental  fates  of
many radionuclides.

During  the 1970s  and 1980s,  peak  doses  to  critical  groups  in  the  Sellafield  region  possibly  reached  2.5  to
3.0 mSv per year (as compared to a dose constraint of 0.3 mSv in the UK and 1 mSv  in  the  EU).  Latterly,
doses to marine-related critical groups have declined to about 0.2 mSv per year.

A  recent  study  commissioned  by  the  German  Federal  Office  for  Radiation  Protection,  using  German
statutory  dose  assessment  assumptions,  calculated  that  annual  doses  from  consumption  of  contaminated
foodstuffs were more than 5 times the annual limit imposed by the European legislation and about 20 times
the annual dose constraint used in the UK and Germany. Most of the dose was received via the technetium
contaminated  seaweed  fertiliser/animal  feed/meat  consumption  pathway.  The  conclusion  of  the  German
study  was  that  the  Sellafield  reprocessing  facilities  would  not  be  “licensable”  in  Germany.  European
legislation  does  not  prescribe  specific  assumptions  in  dose  assessment  models.  The  European  Commission
has responded that “the guidance currently being produced on realistic dose assessments will comment on
this issue.”

å Conclusions on Doses Induced by Sellafield Discharges

Discharges  to  the  Sellafield  marine  environment  have  led  in  the  past  to  doses  to  critical  groups  exceeding
10 times  current  UK  and  3  times  EU  limits.  The  doses  calculated  by  the  UK  administration  from  current
environmental  radionuclide  concentrations  reach  respectively  2/3  and  1/5  of  the  UK  and  EU  limits.  These
doses  remain  problematic,  considering  that  doses  from  past  discharges  and  from  direct  radiation  are not
included.  Doses  calculated  under  German  statutory  dose  assessment  assumptions  exceed  UK  and  EU  dose
constraints. In addition, German dose limits for organs (also used in the US but not in the rest of the EU)
would  also  be  exceeded  by  the  ingestion  of  relatively  small  quantities  of  seafood  from  Sellafield.  The
Sellafield  reprocessing  plants  would  not  be  licensable  in  Germany.  Also  very  large  uncertainties  in  dose
estimates  remain,  with  differences  between  5th  and  95th  percentiles  often  exceeding  several  orders  of
magnitude.  This  raises  the  question  of  whether  “realistic”  assessments  should  be  used  rather  than
“conservative”  dose assessments.

The  risk  potential  of  certain  hazards  at  Sellafield  is  very  large.  Liquid  high  level  wastes  currently  stored
at Sellafield  contains  about  7 million TBq  (2,100 kg)  of  caesium-137,  which  is  about  80  times  the  amount
released through the 1986 Chernobyl accident. Assuming a 50 percent release of caesium-137 in an accident
at Sellafield, population dose commitment would range up to tens of millions of person-Sv resulting in over
a million fatal cancer cases.

å Conclusions on Hazards Posed by Liquid High Level Waste at Sellafield

The hazard potential of liquid high level wastes in particular is very high. A serious accident might lead to
large releases of radioactivity and on the long term globally to over one million fatal cancer cases.

Higher  incidences  of  childhood  leukaemia  than  expected  were  first  identified  near  Sellafield  in  1983.  The
cause or causes of the observed increases in childhood leukaemia near Sellafield have not been determined,
nor is it known whether a combination of factors is involved. The UK Committee on the Medical Aspects of
Radiation in the Environment (COMARE) has stated: “As exposure to radiation is one of these factors, the
possibility cannot be excluded that unidentified pathways or mechanisms involving environmental radiation
are implicated.”

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Various hypotheses, including paternal preconception irradiation and population mixing have been advanced
without being conclusive. Possible explanations for the discrepancy between observed cancers and estimated
low  doses  include  erroneous  dose  assessments  (in  particular  foetal  doses)  and  uncertainties  as  to  the
parameter of “dose”  and what it measures.

Besides childhood leukaemia, other areas of concern have arisen, including reports of increased incidence of
retinoblastoma in children and a statistically significant increase in stillbirth risk in the Sellafield region.

å Conclusions on Health Effects from Reprocessing at Sellafield

More than fifteen years of research has established that the excess incidence of childhood leukaemia around
Sellafield  is  statistically  significant  and  is  continuing.  The  cause  or  combination  of  causes  of  the  observed
leukaemia  increases  are  not  known.  Many  uncertainties  remain.  Radiation  exposure  due  to  radionuclide
releases from Sellafield cannot be excluded as a cause for the observed health effects.

6. Case Study La Hague

Between 1966 and the end of 2000, about 21,000 tonnes of spent fuel have been reprocessed at La Hague.
Most waste generated at La Hague has remained unconditioned – in other words they were not stabilised and
packaged for long term or permanent storage – for many years, and some is stored under very unsatisfactory
(or  39,000  containers  equivalent)  of  plutonium
safety  conditions, 
contaminated sludge.

including  over  9,000 m3 

In 1999, the total radioactivity released by La Hague to the environment was 15,000 times higher than that
released by a nearby nuclear reactor. While releases of some radionuclides (e.g. technetium-99, plutonium)
have  decreased  or  remained  constant,  releases  of  other  radionuclides  from  La  Hague  have  significantly
increased  over  the  past  decade.  These  include  liquid  discharges  (iodine-129 x 5;  tritium x 3)  as  well  as
gaseous  releases (carbon-14 x 8;  krypton-85 x 5;  tritium x 3).  Also,  some  important  radionuclides  are  not
measured at all, including chlorine-36, technetium-99, and strontium-90 aerial emissions.

å Conclusions on La Hague Releases

Releases  of  radioactivity  from  La  Hague  to  the  environment  are  several  orders  of  magnitude  larger  than
releases from a nuclear reactor. Releases of some radionuclides have decreased in the past while liquid and
gaseous discharges of other key radionuclides have increased significantly. A further group of radionuclides
is  not  being  measured  in  effluents.  Increases  of  radioactive  releases  from  La  Hague  in  the  1990s  and
expected future discharges are in violation of obligations under the OSPAR Convention.

There  have  been  numerous  accidents  at  La  Hague,  some  involving  significant  radioactive  releases.  For
example,  as  a  consequence  of  a  severe  discharge  pipe  break  in 1980,  doses  to  individuals  of  the  critical
group (fishermen) exceeded the annual EU limit of 1 mSv by 3.5 times. Main potential hazards at La Hague
are linked to the risk of fires and explosions in the storage pools, in the vitrification plants or in the effluent
treatment  plants,  and  to  the  risk  of  dispersion  of  the  caesium-137  stocks  in  the  spent  fuel  pools,  or  of  the
separated plutonium stocks.

å Conclusions on Accidental Releases from La Hague

Past accidents at La Hague include at least one accident that led to population doses significantly exceeding
EU limits. Accidents are estimated to be responsible of 36% of the leukaemia risk level for the 0-24 year age
category around the La Hague site. The hazard potential of the La Hague spent fuel stores is very large. The
accidental release of a fraction of the caesium inventory in the cooling pools could cause up to 1,5 million
fatal cancers.

Concentrations  of  most  of  the  nuclides  measured  in  samples  taken  in  the  La  Hague  environment  reached
their  peak  during  the  1980s.  Nuclide  concentrations  have  decreased  on  average  unequally,  depending  on
nuclides and samples, by factors between 5 and 50 if compared to 1997 levels. These developments do not
reflect the large increases in releases of some radionuclides (in particular tritium, iodine-129 and carbon-14).
However, there is a notable lack of complete series of data and redundant measurements. Occasionally, there
have  been  samples  taken  that  exceed  EU  Community  Food  Intervention  Levels  (CFILs),  in  particular  in

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crabs.  While  most  of  the  samples  are  taken  and  measured  by  operators,  it  is  remarkable  that  the  highest
readings were obtained by independent measurements.

å Conclusions on Radionuclide Concentrations in the La Hague Environment

Radionuclide  concentrations  in  the  La  Hague  environment  have  generally  decreased  since  the  1980s.
However,  a  comprehensive  trend  analysis  is  difficult  or  impossible  because  of  lacking  data  on  some  key
radionuclides. The sampling and analysis should be significantly extended in order to guarantee redundancy
and  a  thorough  analysis  of  the  impact  of  the  large  increases  in  releases  of  some  radionuclides  during
the 1990s.

Calculated  doses  from  routine  radionuclide  releases  of  the  La  Hague  reprocessing  plant  generally  remain
small and well within the EU limits. However, the uptake of radioactivity taken into account in critical group
scenarios  is  very  small  and  can  be  reached  with  very  small  amounts  of  higher  contaminated  foodstuffs.
Doses can increase accordingly through the consumption of such foodstuffs. The cumulative effective doses
induced by the consumption of seafood, as calculated under German statutory dose assessment assumptions,
significantly exceed German and EU dose constraints. It is questionable whether the current French practice
of dose assessment can be considered conservative.

å Conclusions on Doses Induced by La Hague Discharges

Calculated doses from routine releases at La Hague generally remain well within EU limits. However, doses
calculated  under  German  statutory  dose  assessment  assumptions  exceed  German  and  EU  dose  constraints.
The La Hague reprocessing plants would not be licensable in Germany. The current French dose assessment
practices do not appear to be conservative.

In  1983,  morbidity  was  found  to  be  higher  than  expected  in  the  greater  La  Hague  area  for  men  in  case  of
leukaemia and respiratory organs, and for women in case of leukaemia and lung cancer. Moreover, mortality
data show an increased rate of cancers for the digestive organs in the Department. In 1995, a study identified
an excess of leukaemia cases among persons aged 0-24 years living in the canton about 10 km from the La
Hague  plant.  In 1997  case  control  study,  the  authors  claimed  “convincing”  evidence  for  a  causal  role  in
childhood leukaemia for environmental radiation exposure from recreational activity on beaches and fish and
shellfish consumption.

In 1999, the GRNC (Groupe Radio-écologique Nord-Cotentin) reported that the contribution to doses from
nuclear  facilities  was  low,  as  regards  the  increased  incidence  of  leukaemia  revealed  in  earlier
epidemiological studies. While GRNC calculated  individual  doses  up  to  six  times  higher  than  the  operator
values,  these  did  not  exceed  6%  of  the  EU  annual  limit.  The  report  stated  that  the  result  was  an  average
estimate  and  that  uncertainty  margins  were  not  quantified.  The  quantification  of  these  uncertainties  is
currently underway.

In  June  2001,  a  new  study  confirmed  earlier  findings  on  leukaemia  in  the  La  Hague  region.  The  study
indicated  that  the  increased  incidence  was  continuing,  and  provided  more  data  to  allow  statistical
significance to be established for the increases in leukaemia in the La Hague area.

å Conclusion on Health Effects around La Hague

A statistically significant increase in the incidence of leukaemia in the La Hague area has been established.
This increase is continuing. There is, as yet, no conclusive evidence for a causal link to radioactive releases
from La Hague. However, these cannot be ruled out as a factor contributing to the health effects observed.

The  assessment  of  doses  and  their  effects  are  surrounded  by  many  uncertainties.  These  include  errors  in
assumptions  on  parameters,  errors  in  computer  codes,  measurement  errors  and  paucity  of  environmental
monitoring.  GRNC  has  identified  more  than 4,000 parameters,  including  200  critical  parameters,  in  its
methodology to assess dose impact.

On  the  question  of  iodine-129  releases,  WISE-Paris  has  quantified  the  differences  between  the  theoretical
activity in spent fuel and the activity discharged to sea and air. Large gaps are observed in the beginning of
the 1990s, as only 50% of the theoretical values were reported discharged. In the worst case, the committed
collective dose from non-attributed iodine-129 in the period 1989-1999 would be about the magnitude of a

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serious  nuclear  accident such  as  the  Windscale  fire  (Sellafield)  or  the  Kyshtym  (Russia)  waste  explosion
in 1957.

The  Precautionary  Principle  is  clearly  laid  down  in  various  binding  international  agreements  (e.g.
Agenda 21,  EC  Treaty).  In  1992,  Agenda 21  pointed  out  that  radioactive  wastes  are  among  “the
contaminants  that  pose  the  greatest  threat  to  the  marine  environment.”  The  Earth  Charter  of  March  2000
calls  notably  to “place  the  burden  of  proof  on  those  who  argue  that  a  proposed  activity  will  not  cause
significant harm, and make the responsible parties liable for environmental harm.”

å Conclusions on Uncertainties and the Precautionary Principle

Many  uncertainties  remain  regarding  dose  assessments.  In  addition,  error  margins  may  be  large  and  might
modify  assessed  doses  significantly.  Under  these  conditions,  the  continued  release  of  large  quantities  of
radionuclides into the environment from Sellafield and La Hague violates the Precautionary Principle.

7. Comparative and Cumulative Analysis

Differences  exist  in  effluent  treatment  between  Sellafield  and  La  Hague.  Carbon-14  which  is  the  major
contributor to collective doses, for example, is partially removed from air emissions at Sellafield while all of
it is released at La Hague. Its abatement is not considered cost effective by Cogema.

In 1999, a representative year, releases from La Hague and Sellafield were broadly comparable. In general
terms,  La  Hague  discharges  were  marginally  greater  than  those  from  Sellafield,  except  for  iodine-129  and
tritium air emissions and technetium-99 liquid discharges.

Until 1992, Sellafield and La Hague released a total of some 1.2 tonnes of iodine-129  to  the  environment.
This  is  several  hundred  times  that  released  at  Chernobyl.  In  the  period  1993-1998,  a  further  1.7 tonnes  of
iodine-129  were  discharged  (of  which 80%  from  La  Hague).  Iodine-129  discharged  from  La  Hague  and
Sellafield  in 1999  alone  was  eight  times  greater  than  that  released  by  the  fallout  from  all  nuclear
weapons testing.

å Conclusions on Comparative and Cumulative Analysis

In  1999,  radioactive  releases  to  the  environment  from  La  Hague  and  Sellafield  were  broadly  comparable.
Iodine-129  discharged  from  La  Hague  and  Sellafield  that  year  was  eight  times  greater  than  the  total
iodine-129 released by the fallout from all nuclear weapons testing.
The  estimated  global  collective  dose  of  a  decade  of  radioactive  releases  from  Sellafield  and  La
Hague (77,000 manSv) corresponds to about 1/7 of the collective dose from the Chernobyl accident, or to a
Kyshtym scale accident every year. This raises the question of the justification of these releases as required
under the radiological principles of the International Commission on Radiological Protection.
Also, in conventional cost-benefit studies, monetary values are attributed to a human life. When applied to
untruncated  global  doses  from  10  years’  of  Sellafield  and  La  Hague  releases,  very  large  sums  are
obtained (£ 1.8 and 5.9 billion – respectively 2.9 and 9.4 billion Euro): the amounts that therefore could be
spent on abatement measures comfortably exceed annual operating profits at each site.

8. Alternative Options

å Conclusions on Alternative Options

Non-reprocessing  options,  and  available  dry  storage  technologies  in  particular,  are  considerably  less
expensive  than  reprocessing.  In  addition,  their  social  and  political  acceptability  are  much  greater  than
reprocessing.  Nuclear  utilities  are  increasingly  moving  towards  dry  storage  solutions,  including  utilities  in
the  US,  Canada,  Germany,  Russia  and  many  eastern  European  countries.  Direct  disposal  options  also
significantly reduce waste volumes to be disposed, due to the large volumes generated by reprocessing.

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General Conclusions

The reprocessing of spent nuclear fuel at Sellafield (UK) and at La Hague (France) leads to the largest man-
made  releases  of  radioactivity  into  the  environment  worldwide.  The  releases  correspond  to  a  large-scale
nuclear accident every year. Some of the radionuclides released in great quantities have half-lives of millions
of years. Concentrations identified in recent years in the environment repeatedly exceeded EU Community
Food Intervention Levels (CFILs).
The discharge trends through the 1990s towards large increases in the releases of certain key radionuclides at
Sellafield and La Hague and further planned increases in releases constitute a violation of letter and spirit of
the OSPAR Convention.
Accidental radionuclide releases from Sellafield and La Hague could be by two orders of magnitude larger
than in the case of the Chernobyl disaster and could lead globally over the long term in both cases to over
one million fatal cancers.
The  European  Commission  does  not  effectively  use  its  verification  rights.  The  Commission  is  highly
dependent  on  information  provided  by  Member  States  and  is  therefore  apparently  not  in  a  position  to
guarantee that the Basic Safety Standards are respected concerning the La Hague and Sellafield facilities. It
is  doubtful  whether  the  Commission  is  in  a  position  to  determine  whether  the  reprocessing  activities  are
liable to result in the radioactive contamination of the water, soil or airspace of another Member State.
Operational and/or accidental releases from Sellafield and La Hague have led in the past to population doses
that exceed current EU limits. Reprocessing alone accounts for about 80% of the collective dose impact of
the French nuclear industry. In the UK, about 90% of nuclide emissions and discharges from the UK nuclear
programme result from reprocessing activities.
In the surrounding regions of Sellafield and La Hague a statistically significant increase in the incidence of
leukaemia has been established. While research on the causal relationship with environmental radiation has
not  been  conclusive,  it  cannot  be  ruled  out  that  exposure  to  radiation  is  an  initiating  or  at  least  a
contributing factor.
There  are  great  uncertainties  involved  in  the  assessment  of  doses  to  populations  and  subsequent  health
effects.  The  release  of  large  quantities  of  long  lived  radionuclides  at  Sellafield  and  La  Hague  therefore
violates  the  Precautionary  Principle,  laid  down,  inter  alia,  in  the  European  legislation,  Agenda  21  and  the
Earth Charter of March 2000.

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1. INTRODUCTION

1.1.  OBJECTIVE OF THE STUDY

The  principal  aim  of  this  report  is  to  assist  the  Committee  of  Petitions  of  the  European  Parliament  in  its
consideration  of  Petition  393/95  brought  by  Dr.  W.  Nachtwey.  The  Petition  expresses  concerns  about
radioactive discharges from nuclear reprocessing plants at Sellafield in the UK and La Hague in France, and
their possible adverse health effects (see summary of the Petition at Annex 1).

The reprocessing of spent nuclear fuel involves its dissolution and the chemical separation of uranium and
plutonium. As spent fuel remains extremely radioactive and, as many radioactive waste streams are created
by these chemical processes, reprocessing results in significant radioactive releases to atmosphere and sea.

The original rationale for reprocessing was the recovery of fissile plutonium for nuclear weapons. This has
declined  and  officially  is  no  longer  a  reason  for  continued  reprocessing  in  the  UK  and  France.  Other
rationales,  including  recovery  of  plutonium  for  breeder  reactors  and  mixed  oxide  fuel,  have  declined  or
remained  static  in  recent  years.  As  a  result,  the  frequency  of  new  reprocessing  contracts  is  declining.  In
world terms, most (>80%) spent fuel arisings are stored rather than reprocessed: new developments concern
storage rather than reprocessing technologies.

The  nuclear  fuel  cycle  involves  a  number  of  steps  from  uranium  mining  and  milling,  through  enrichment,
fuel  fabrication,  reactor  operations,  spent  fuel  storage,  radioactive  waste  conditioning  and  final  disposal.
Some nuclear operators have chosen to reprocess rather than store and condition their spent fuel. The single
step  of  reprocessing  emits  considerably  more  radioactive  discharges  than  all  other  steps  combined.
Reprocessing discharges from Sellafield and La Hague rank among the largest anthropogenic discharges of
radioactivity throughout the world, and constitute a reasonable subject for enquiry by the Committee.

Controversy  exists  over  the  reprocessing  of  spent  nuclear  fuel:  views  are  polarised  and  strongly  held  by
proponents  and  opponents.  The  Governments  of  Member  States  UK  and  France  continue  to  support
reprocessing  activities  in  their  countries,  despite  declining  public  enthusiasm  according  to  opinion  polls  in
the UK, and despite protests from other Member States. In recent years, doubts over waning rationales for
reprocessing  have  been  raised  by  some  government  and  industry  officials  and  by  politicians  of  various
political  parties,  even  in  the  UK  and  France.  The  Committee  will  be  aware  that  continued  reprocessing
within the European Union is, to a major extent, a political rather than scientific matter.

As requested by STOA, this report concentrates on the effects of reprocessing discharges on health, safety
and the environment. In particular, this report presents evidence and data on :

• radioactive discharges from the Sellafield and La Hague sites;
• resulting nuclide concentrations in environmental media including foodstuffs;
• radiation doses from nuclide discharges to critical groups near the sites;
• adverse health effects near the two sites; and
• resulting collective doses from nuclide discharges.

The report examines a number of current issues in radiobiology concerning health effects from exposure to
ionising radiation, in particular genetic and in utero effects.

In  addition,  in  accordance  with  contract  specifications,  the  report  examines  other  major  factors  that  might
influence future decision-making on reprocessing. It describes the legal framework, the operational history of
the  plants  and  the  economic  case  for  reprocessing  compared  with  available  spent  fuel  management
alternatives. The report does not examine mixed oxide fuel (MOX) matters in detail, as these would require a
separate study.

The report also makes a number of conclusions and policy-related recommendations that take into account
the current knowledge and uncertainties on risk issues and of the availability of alternatives to reprocessing
in spent fuel management.

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1.2.  BACKGROUND AND CHRONOLOGY OF THE PROJECT

Petition n° 393/95  was  introduced  by  Dr. W. Nachtwey  and  a  group  of 22 senior  citizens  from  Hamburg,
Germany, in February 1995. The petitioners raised concerns over the radioactive pollution of the North Sea
and  the  Atlantic  Ocean  due  to  the  operation  of  nuclear  reprocessing  facilities  at  Sellafield (UK)  and
La Hague (France). The present study project, as requested by the Committee of Petitions, was included in
the Year 2000 Work Plan adopted by the STOA Panel on 17 February 2000. It was subsequently approved
by the Bureau of the European Parliament on 1 March 2000.

Although  Petition  n° 393/95  has  its  origin  in  an  initiative  by  individuals,  it  reflects  widespread  concern  in
many  countries  about  radioactive  discharges  and  the  incidence  of  radiation-induced  illnesses  near  facilities
discharging  radioactive  matter.  For  example,  concerns  over  the  levels  of  radioactive  contamination  from
Sellafield  and  La  Hague  discharges  have  been  expressed  by  international  and  regional  bodies,  including
Agenda 21 and OSPAR meetings.

Within  individual  countries,  the  public  has  also  expressed  concern  about  the  local  impact  of  reprocessing
facilities  on  environment  and  health.  This  has  led  to  initiatives  by  national  authorities  to  assess
corresponding  risks,  including  studies  by  COMARE (Committee  on  Medical  Aspects  of  Radiation  in  the
Environment)  in  the  UK,  and  by  GRNC (Groupe  Radioécologie  Nord-Cotentin)  in France.  Some  Member
States (Denmark,  Ireland)  and  countries  close  to  the  EU (Norway)  have  protested  for  many  years  over
continued reprocessing at Sellafield and La Hague.

Concerns over reprocessing discharges have also resulted in a growing number of studies exploring the risks
which  may  be  associated  with  large-scale  nuclide  discharges,  including  raised  incidences  of  childhood
leukemias  near  both  reprocessing  facilities.  So  far,  no  consensus  has  emerged  on  whether  radioactive
discharges  have  caused  the  increased  incidences  of  leukemia,  even  although  at  least  one  recent  study
involved  representatives  from  both  industry  and  environmental  groups.  Six years  after  the  Petition  was
introduced, the Petitioner’s main concerns remain relevant. Therefore the prime objective of this study has
been  to  examine  the “possible  toxic  effects  from  the  nuclear  reprocessing  plants” ,  and  derive  concrete
Policy Options according to the specifications of the contract.

A  Scoping  Meeting  was  held  in  Brussels  on  24  January  2001.  The  co-ordinator  of  the  project  presented  a
Scoping Paper for the study. Only one comment on the Scoping Paper (by the Petitioner) had been received
prior  to  the  meeting.  A  Scoping  Meeting  Report  was  delivered  on  27 February 2001  that  notes  that  while
“there was no basic disagreement with the content of the Scoping Paper and the methodology presented by
Mr. Schneider  on  the  basis  of  the  contract  with  STOA,  there  has  been  some  concern  that  health  and
environmental issues will get appropriate attention in the study.”

An Interim Report was presented to the STOA Panel on 10 April 2001. The report reflected the current work
in progress, and at that stage was felt not satisfyingly balanced between the different parts to be analysed.
The  co-ordinator  of  project  enlarged  the  project  team  in  response  to  the  remarks  by  the  STOA  Panel  and
associated  two  additional  experts  in  the  field  of  radiation  effects,  Dr.  Fairlie  and  Dr.  Sumner,  to  the team.
The focus of the present report reflects the views of the STOA Panel expressed at the earlier meetings.

The Interim Report also contained a set of proposed Policy Options, taking into account the specific roles of
major actors in this area. These include the nuclear industry at operational level, the national governments
for  their  key  role  in  decision  making  on  spent  fuel  management (UK  and  France  but  also  other  Member
States), the European Commission, which has powers of supervision and regulation of nuclear activities in
the EU,  and  finally  the European  Parliament  for  its  legislative  and  overview  roles.  The  Parliament’s  roles
include the protection of the populations against industrial risks, but also decision-making procedures, public
information and participation, independent auditing and decisions on EU  institution  budgets.  The  proposed
Policy Options were submitted for comments to MEPs and to some experts. The Policy Options presented in
this final report take into account comments received.

In the process of the research, the authors have formally consulted, inter alia, the European Commission (DG
Environment,  Radiation  Protection  Unit),  the  French  national  Institut  de  Protection  et  de  Sûreté  Nucléaire
IPSN (the  Director  of  Protection  and  Chairperson  of  the  Radioecological  Group  Nord-Cotentin),  the
DRIRE (Regional Division of Industry, Research & Environment) of the La Hague region. The authors also
consulted informally with many other organisations and individuals, particularly in the UK. The co-ordinator
wishes to thank all those who contributed to this project.

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2. REPROCESSING STATUS AND ISSUES

2.1.  NUCLEAR REPROCESSING

The  reprocessing  of  spent  nuclear  fuel  has  been  carried  out  since  the 1950s  in  a  number  of  countries  to
retrieve fissile plutonium, originally for weapons purposes. Reprocessing has been also carried out by a few
other countries in small amounts for fuel purposes (e.g. Japan and India). However clearly the largest centres
in the world for commercial reprocessing remain Sellafield in the UK and La Hague in France.

The United Nations [UNSCEAR, 2000] has stated that only “about 5% to 10%” of world spent fuel arisings
is submitted to reprocessing: the rest is stored pending final disposal in a repository. The number of countries
relying on reprocessing to deal with their spent fuel has been declining [IAEA, 1999].

The  reprocessing  of  spent  nuclear  fuel  involves  its  dissolution  in  boiling  concentrated  nitric  acid  and
subsequent physico-chemical separations of uranium and plutonium. Multiple waste streams are created by
these  physical  and  chemical  processes.  These  waste  streams  include  releases  from  fuel  storage  ponds,
dissolver units, solvent treatment plants, HLW (liquid) processes and tanks, ILW processes and tanks, LLW
processes, off-gas treatment plants, and liquid scrubber plants [Homberg, 1997].

As  spent  fuel  contains  high  levels  of  radioactivity,  discharges  from  reprocessing  are  correspondingly
radioactive.  Most  fission  product  releases  and  plutonium  releases  from  the  UK  and  French  nuclear
programmes  result  from  their  respective  reprocessing  activities.  It  will  be  seen  below  that,  apart  from
reductions  in  discharges  of  a  few  radionuclides,  discharges  and  emissions  from  the  two  facilities  have  not
decreased over the past few decades and indeed, in the case of some nuclides, have increased.

Reprocessing  operations  release  considerably  larger  volumes  of  radioactive  discharges  than  other  nuclear
activities,  typically  by  factors  of  several 1,000  compared  with  nuclear  reactor  discharges.  According  to
a European  Commission  report [CEC, 1995]  produced  by  the  Centre  d’Étude  sur  l’Évaluation  de  la
Protection dans le domaine Nucléaire (CEPN, a research agency essentially funded by CEA and COGEMA),
reprocessing alone accounts for about 80% of the collective dose impact of the French nuclear industry. In
the  UK,  Fairlie [1997]  has  estimated  that  about 90%  of  nuclide  emissions  and  discharges  from  the  UK
nuclear programme result from reprocessing activities.

2.2.  ORIGINS OF REPROCESSING

Uranium-fuelled reactors produce plutonium in their nuclear fuel during normal operation. The main fissile
plutonium isotope, plutonium-239, is produced through neutron capture by the uranium isotope uranium-238.
As stated above, the main purpose of reprocessing is to retrieve plutonium from spent fuel. Plutonium is a
man-made element, which exists only in trace amounts in nature. In France and the UK, bulk quantities of
weapons plutonium were produced in the first generation of nuclear power plants, and separated from spent
fuel initially in dedicated reprocessing plants.1

Early in the development of nuclear technology, plutonium became of particular interest to the nuclear power
industry.  The  establishment  of  breeder  reactor  technology  became  a  major  goal.  The  basic  concept  was
fascinating:  plutonium  generated  as  by-product  in  first-generation,  uranium-fuelled  nuclear  reactors  would
be  separated,  incorporated  into  fuel  assemblies,  and  re-introduced  into  second-generation  breeder  reactors
that  would  produce  more  plutonium  than  they  consumed.  In  this  manner,  the  lifetime  of  uranium  reserves
would  be  greatly  extended.  Decision-makers  were  impressed  by  this  concept,  and  research &  development
funds were distributed generously. In fact, the first reactor to produce electricity was the US Experimental
Breeder Reactor EBR-1, in 1951.

1  The name “plutonium factory”  (usine de plutonium, UP) given by the French to its plutonium separation facilities

may be more apposite than the term “reprocessing plant”.

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By  the  early 1970s,  the  major  nuclear  countries  had  breeder  programs  under  way.  France  commissioned
the 250 MWe Phenix in 1973 and the UK the Prototype Fast Reactor (PFR) in 1974. During the same period,
the European 1,200 MWe Superphenix project was launched. In 1977, the head of the French Atomic Energy
Commission (CEA) predicted the operation of 540 large breeder reactors in the world by the year 2000.

To supply plutonium for the expected fleet of breeders, the European nuclear establishment launched large-
scale  reprocessing  plant  projects  in  the  1970s.  After  the  first  international  project,  the  reprocessing
plant EUROCHEMIC in Belgium, failed because national projects received higher priority, utilities chose to
have their spent fuel reprocessed in France at La Hague and in the UK at Sellafield. Between 1976 and 1979,
following  a  first  series  of  smaller  agreements,  contracts  were  signed  for 
the  reprocessing  of
some 7,000 tonnes  of  spent  fuel  at  each  plant,  UP3  and  THORP.  These  reprocessing  contracts  have  been
mostly  completed  between  1990  and  2000.  Utilities  from  EU  Member  States  Belgium,  France,  Germany,
Netherlands, Sweden and the UK, plus Japan and Switzerland, signed up to those contracts.2
Two decades later the situation has changed radically. Massive new uranium ore sources3 have been found –
much greater than had been expected. Consequently the prices of natural uranium have been falling from one
historical  low  to  another.  Breeder  programs,  which  proved  more  expensive  and  less  technically  successful
than anticipated, have been shelved. Germany abandoned its completed SNR-300 reactor at Kalkar in 1991
before it started up. The plant was turned into an amusement park. The UK shut down its PFR in 1994. The
world’s only commercial-size breeder reactor, Superphénix in France, was shut down in 1996 after achieving
a lifetime load factor of 6.3% (actual electricity generation as a fraction of the theoretical maximum).

However  plutonium  production  programs  were  not  modified  in  response  to  these  developments.  Large
reprocessing plants at Sellafield and La Hague were put into operation between 1989 and 1994 as if nothing
had  changed.  As  a  result,  large  stockpiles  of  plutonium,  reprocessed  uranium  and  reprocessing  wastes
continue to build up in both countries. The impacts of reprocessing should be viewed within a broad context.
Reprocessing does not occur in isolation, but as an element of a country’s wider political policies. The social
costs and benefits of reprocessing should be analysed accordingly.

In recent years, the plutonium industry put forward MOX fuel (plutonium-uranium mixed oxide fuel) as a
rationale  for  continued  reprocessing.  These  claims,  like  reprocessing  itself,  are  the  subject  of  conflicting
views. This report refrains from examining MOX issues in detail as these lie outside its remit. However it is
noteworthy  that  the  maximum  anticipated  MOX  fuel  use,  i.e.  about  200  tonnes  per  year,  is  small  in
comparison with the 11,000 tonnes of uranium fuel used each year.

Also  in  recent  years,  proponents  of  reprocessing  have  stated  that  it  continues  to  offer  utilities  a  method  of
managing their spent fuel stocks. This report discusses the safer and less expensive alternative of medium-
term  dry  storage.  However  it  is  noted  that,  in  some  cases,  decisions  by  different  utilities  on  spent  fuel
management differ widely for reasons which appear to have more to do with policy and belief than technical
necessity or commercial considerations. These attitudes are often not amenable to rational discussion.

2.3.  IMPLICATIONS OF REPROCESSING

Reprocessing is one option among various spent fuel management options. In the year 2000, the volume of
spent fuel reprocessed was about a sixth of the spent fuel generated worldwide: most reprocessing occurs at
La  Hague  and  Sellafield.  As  can  be  seen  from  this  low  fraction  of  spent  fuel  reprocessed,  most  utilities
operate  their  nuclear  power  plants  without  reprocessing  and  plutonium  use.  Therefore  this  report’s
examination of reprocessing does not imply any comment on nuclear power programmes.

Differences  of  view  exist  between  Member  States  of  the  European  Union  on  reprocessing.  Views  on
continued  reprocessing  remain  polarised  between  different  groups  within  Member  States,  and  within
European Union bodies. Consequently, nuclear reprocessing remains a highly politicised subject, on which a
consensus may be difficult to achieve.

2  Swedish utilities eventually subcontracted their shares in the reprocessing agreements to other utilities but remained,

formally, as contracting parties.

3  In Kazakhstan, Uzbekhstan and Canada particularly.

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3. INTERNATIONAL AND EUROPEAN LEGAL FRAMEWORK

3.1.  INTERNATIONAL LEGISLATION AND TREATIES

Although  the  regulation  of  nuclear  energy  remains  the  responsibility  of  national  authorities,  the  fact  that
nuclear-related activities have potential transboundary impacts, has brought the international community to
take on the elaboration of some common standards. A list of the main texts is presented in the Annex 2.

3.1.1. Major International Bodies

International and regional organisations have played a major role in the development of nuclear standards.

• The International Commission on Radiological Protection (ICRP)

International  action  in  the  field  of  radiation  protection  standards  started  with  the  establishing  of
the International  Commission  on  Radiological  Protection (ICRP).  The  ICRP  was  founded  in 1928 (and
reconvened after the II. World War in 1950) by the International Society of Radiology as its commission
on international issues. The main committee of the ICRP, 13 members, voted in by co-optation, provides
recommendations  and  guidance  on  all  aspects  of  the  protection  against  ionising  radiation  that  is  turned
into a legal framework by most of the countries in this world.

• United Nations Committee on the Effects of Atomic Radiation (UNSCEAR)

The United Nations Committee on the Effects of Atomic Radiation (UNSCEAR) was established in 1955
by the United Nations to evaluate doses, effects and risks from ionising radiation on a world wide scale
following  growing  concerns  over  potential  effects  from  nuclear  weapons  testing.  Most  of  the  standards
elaborated  by  international  and  regional  organisations  such  as  Euratom  and  the  International  Atomic
Energy Agency (IAEA) are based on the research undertaken by the ICRP and UNSCEAR.

• The International Atomic Energy Agency (IAEA)

The  United  Nations  International  Atomic  Energy  Agency,  IAEA,  is  primarily  an  inter-governmental
forum  for  scientific  and  technical  co-operation (and  promotion)  in  the  nuclear  area.  The IAEA  today
counts 130 Member  States.  The  Agency  provides  its  Member  States  with  guidance  and  standards  as  a
complementary element to national criteria and regulations when the latter are not based on other existing
international conventions.

• OECD Nuclear Energy Agency (NEA)

The  Nuclear  Energy  Agency (NEA)  is  a  semi-autonomous  body  within  the  Organisation  for  Economic
Co-operation  and  Development (OECD).  The  Agency  provides  assistance  to  its  Member  countries  in
developing  scientific  and  legal  bases  for  the  safe  use  of  nuclear  energy.  The  NEA  counts 27 Member
States, representing “85% of the world installed nuclear capacity.”

3.1.2. Major International Conventions

The  international  legal  framework  in  the  nuclear  sector  is  composed  of  legally  binding  agreements  and
recommendatory  standards.  Among  the  most  important  international  conventions  on  radioactive  material
management  that  have  contributed  to  the  development  of  the  international  legal  framework  in  the  nuclear
sector one may cite:

• The Convention on Nuclear Safety

It entered into force on 24 October 1996. The Convention commits the signatories to ensure the safety of
civil nuclear power plants including the storage, handling and treatment of radioactive materials.

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• The Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive

Waste Management

It was open for signature in September 1997. Within the framework of this agreement, the parties must
take  the  necessary  measures  to  ensure  the  safe  and  environmentally  sound  management  of  radioactive
waste and spent fuel.

A large number of bilateral and multilateral agreements have also dealt with safety standards and regulations
in the nuclear sector, particularly in the field of marine pollution.

While  major  international  conventions  have  referred  to  the  necessity  to  prevent  marine  pollution  from
nuclear  activities,  for  instance  Agenda 21 (June 1992)  and  the  Earth  Charter (June 2000),  others  were
specifically devoted to this matter, notably:

• The Convention on the Prevention of Marine Pollution by Dumping of Wastes and other Matter –

“London Dumping Convention”

It was signed on 29 December 1972. Aiming at improving the protection of the marine environment, the
Convention  encourages “States, with a common interest in particular geographical areas, to enter into
appropriate  agreements”  to  promote  the  effective  control  of  all  sources  of  pollution.  In  particular,  it
prohibits the dumping of wastes if not duly authorised and controlled by the Member States’  authorities.

• The Convention for the Protection of the Marine Environment of the North-East Atlantic –

“OSPAR Convention” (see also Chapter 3.2 and Annex 3)

It  was  opened  for  signature  at  the  Ministerial  Meeting  of  the  Oslo  and  Paris  Commissions  in  Paris,
on 22 September 1992. The Convention has been signed and ratified by all of the Contracting Parties and
it entered into force on 25 March 1998. It defines general guiding principles to deal with the problem of
pollution,  from  land-based  sources  notably (Annex I  of  the OSPAR  Convention),  such  as  the
precautionary  principle;  the  polluter  pays  principle  and  best  available  techniques (BAT)  and  best
environmental practice (BEP), including clean technology. It also provides for the OSPAR Commission,
established by the Convention, to adopt binding decisions.

3.1.3. The European Legal Framework And Its Implementation

The basis of European law is established in the European Community Treaties. In particular, the majority of
legislation dealing with nuclear activities is found in the Euratom Treaty, signed in Rome on 25 March 1957.

In  addition  to  Council  Directive  96/29/Euratom,  there  are  a  number  of  other  directives  and  regulations
relating to specific activities within this sector, which deal with the different issues, among which:

• health  and  safety  at  work (Radiation  Protection  of  Outside  Workers,  Council  Directive

90/641/EURATOM);

• transport  of 

radioactive  substances (Shipments  of  Radioactive  Waste,  Council  Directive

92/3/EURATOM);

• and shipments of Radioactive Substances, Council Regulation (Euratom) No. 1493/93.

The main documents applying are listed in the Annex 4.

3.1.3.1.  Euratom Treaty

The Treaty Establishing the European Atomic Energy Community (Euratom Treaty) lays the foundation for
the  Community  regulation  in  the  nuclear  sector.  Other  relevant  legislation  can  also  be  found  in  the EEC
Treaty and supplement and the Single European Treaty.

European legislation does not provide for a control of the Member States’  national procedures leading to the
granting of authorisations of releases of radioactivity to the environment.

As  a  primary  legislative  instrument,  the  Euratom  Treaty  imposes  obligations  on  the  Member  States  under
Articles 33 to 37 concerning notably the monitoring of the environment and the disposal of wastes.

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• Application of Article 34

Article 34  states:  “Any  Member  State  in  whose  territories  particularly  dangerous  experiments  are  to  take
place  shall  take  additional  health  and  safety  measures,  on  which  it  shall  first  obtain  the  opinion  of  the
Commission. The assent of the Commission shall be required where the effects of such experiments are liable
to affect the territories of other Member States.”

The Commission declared that: “France has not requested the Commission’s opinion under Article 34 of the
Euratom  Treaty  concerning  activities  on  La  Hague  nor  has  the  UK  as  regards  activities  in  Sellafield.” 4
Given  the  number  of  previously  untested  activities  carried  out  at  La  Hague  and  Sellafield,  it  is  extremely
surprising that there has not been a single request by the operators for opinion under Article 34. In fact, there
has  never  been  a  single  request  for  a  Commission  Opinion  by  the  UK (unclear  for  France).  The  oral
explanation  given  by  the  Commission5  that  the  original  aim  of  the  article  was  to  cover  peaceful  nuclear
explosions –  that  were  never  carried  out  in  the  EU –  is  not  satisfying.  The  legal  analysis  of  the  non-
application of Article 34 would go beyond the scope of this study but seems to be absolutely indispensable.

• Application of Article 35

Article 35  is  the  strongest  legal  basis  for  the  implementation  of  an  efficient  control  mechanism  of  nuclear
installations  in  the EU.  It  states:  “Each  Member  State  shall  establish  the  facilities  necessary  to  carry  out
continuous monitoring of the level of radioactivity in the air, water and soil and to ensure compliance with
the  basic  standards.  The  Commission  shall  have  the  right  of  access  to  such  facilities;  it  may  verify  their
operation and efficiency.”

The Basic Safety Standards for the protection of health of the general public and workers against the danger
of ionising radiation are laid down in the Directive (80/836) of 15 July 1980. These standards were revised in
the Euratom Directive (96/29EURATOM) of 12 May 1996.

European  Commission  verification  activities  provided  for  in  Article 35  are  very  limited  due  to  resource
constraints:  “Since  the  re-launch  of  the  verification  activities  in  1990  the  Commission  has  performed
verification visits at the Sellafield site on  6-10 December 1993 and at the La Hague site on 22-26 July 1996.
Each  verification  visit  is  normally  performed  by  4  inspectors,  who  carry  out  checks  on  the  operation  of
instruments  for  environmental  monitoring  and  follow  the  data  chain  for  a  number  of  randomly  chosen
samples from sampling through to transmission of the final results to the competent authorities. The quality
assurance system is also checked. The Article 35 of the Euratom Treaty verification activities are currently
being reviewed by the Commission.” 6

The  Commission  has  commented  on  the  issue  on  a  number  of  occasions  in  answers  to  parliamentary
questions. One of those answers stated: “The installations which were the object of this check are primarily
those which have a direct impact on the environmental radioactivity level…  The equipment for monitoring
gaseous and liquid effluents from these establishments was also checked as part of the assessment of their
impact  on  the  environment”.  Parliament  and  other  Member  States  are  forwarded,  on  request, “the  main
comments formulated by the Commission.”  The Council and the Parliament are periodically provided with a
report summing up “the progress made with its programme of checks.” 7
During a meeting with the Co-ordinator of the present study8 and in a subsequent letter9 the Commission has
clarified a certain number of points:

• The  Commission  has  repeatedly  made  reference  to  the “re-launch”  or  the  “resumption”  of  Article 35
verification  activities.  However,  the  term  is  based  on  oral  information  about  some  earlier  verification
activities that would have been carried out in the 1960s. No written evidence exists within the Commission

4 Stephen  Kaiser,  Head  of  Radiation  Protection  Unit,  Commission  of  the  European  Communities,  e-mail  to  Mycle

Schneider dated 10 May 2001.

5  Meeting  between  Stephen  Kaiser  and  four  other  representatives  of  the  unit  with  Mycle  Schneider,  Luxembourg,

17 May 2001.

6  European Commission, Answer to Question n°46 by MEP Nuala Ahern, 14 June 2001.
7  Answer given by Mrs Wallström on behalf of the Commission (31 March 2000) to question E-0477/00 by Hiltrud

Breyer (Verts/ALE) to the Commission (24 February 2000, OJ C 330 E, 21/11/2000 (p. 170)).

8  Meeting in Luxembourg, 17 May 2001, op. cit.
9  Stephen Kaiser, Commission of the European Communities, e-mail to Mycle Schneider dated 12 June 2001.

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services  to  back  up  that  information.  The  Commission  representatives  exclude  that  La  Hague –  military
significance –  or  Sellafield –  the  UK  joined  the  EC  later –  were  amongst  these  potential  verifications  in
the 1960s.

• In 1990, the Commission planned to carry out about 60 verifications per year. The goal was to inspect each
facility in the EU on average about once every five years and major facilities like reprocessing plants every
two  years.  In  reality,  only  two  to  three  verifications  have  been  carried  out  per  year  and  in
total 20 verifications have been carried out in the 10 year period between October 1990 and December 2000.
Only two are planned for 2001. The main reason indicated by the Commission are of budgetary nature.

• The  Commission  considers  that  the  conclusions  reached  at  the  verifications  at Sellafield  in 1993  and  La
Hague in 1996 “with respect to arrangements for monitoring environmental radioactivity could be expected
to  be  broadly  the  same.  There  have  however  been  developments,  particularly  at  Sellafield  (e.g.  start  of
operation  of  THORP  and  EARP)  that  did  not  operate  at  the  time  of  the  visits.”   During  the  meeting  in
Luxembourg the Commission representatives clearly stated what that means: the verification, particularly at
Sellafield but also at La Hague, is “out of date.”

• The  Commission  stated  that  “although  compliance  with  the  requirement  to  assess  and  limit  doses  is  a
Member State responsibility, the Commission does have a significant amount of information available to it
on this matter. These data indicate that, in general, the radiation doses received by the public are a small
fraction  of  the  dose  limits  and  that  the  maximum  credible  range  of  uncertainties  would  not  compromise
respect of this limit. The Commission is aware of the circumstances under which dose limits to the public
might be exceeded and is vigilant in taking a proactive approach to verify compliance.”

• Member  States  consider,  as  stated  by  Michael  Meacher,  Minister  for  the  Environment  in  the  UK,  that
“under  Article  35  of  the  Treaty  the  European  Commission  has  the  right  of  access  to  certain  facilities.
The Article does not require submissions to be made to the Commission.”  10

The  Commission  was  not  in  a  position  to  supply  the  STOA  Study  Team  with  copies  of  the  verification
reports on Sellafield and La Hague because they “fall under the exemptions to access provided for under the
access policy and that there is therefore no entitlement to see them.”  However,  the  Commission  informed
the  STOA  Study  Team  that  it  has “asked  the  UK  and  France  if  they  would  agree  to  the  reports  being
released to you.” 11 As of the end of July 2001, the Study Team had not received any answer on the issue
from the Commission.

However, the STOA Study Team in the mean time found out that a copy of the 1993 Sellafield Verification
Report had been placed in the Library of the UK House of Commons. The 29 page report (plus tables) is a
stunning indication of the superficial nature of the Article 35 verification exercise:

- The preparatory documents referenced were essentially of statistical nature.

- The  four  person  verification  team  had  a  huge  visiting  programme  during  a  three  and  a  half  day

presence at Sellafield and in the surrounding area, including visits of the BNFL ship Seascan, of a laboratory
in Whitehaven, witnessing demonstrations of measurements in the environment and of collection of winkles,
visiting a dairy farm, an air sampler at Calderbridge and at least seven stacks besides a “conducted tour of
the disposal site” at Drigg.

- The introduction to the report states that “given the complexity of the facilities, the purpose of the
review was not to undertake a systematic verification of all of the aspects but to provide an overview of the
system with a number of spot checks limited by the time available”  and  “while  only  part  of  the  discharge
monitoring  facilities  could  be  verified,  their  selection  was  representative  for  the  overall  surveillance
programme, thus allowing to draw general conclusions on its adequacy.”  However, the report fails to justify
the methodology and the representative nature of its verification activities.

- The  general  conclusion (less  than  1 page  of  text)  states  that  the  team  “observed  the  proper
functioning of a representative subset of stack monitoring equipment”  and that any controlled ground level
aerial releases are “properly accounted for” and that the overall arrangements “ensure that aerial releases

10 Written reply to question by Llewelyn Smith, dated 11 May 2001.
11 Stephen Kaiser, Commission of the European Communities, e-mail to Mycle Schneider, dated 10 May 2001.

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and  their  environmental  impact  are  well  controlled”  and  finally  that  discharges  to  the  sea  are
“adequately monitored.”

- The  report  is  of  exclusively  descriptive  nature.  It  does  not  contain  any  analysis,  nor  any
discussion (for  example  of  error  margins  or  technical  and  conceptional  uncertainties),  nor  any  kind  of
criticism. The verification team obviously found the situation at Sellafield perfect.

The  STOA  Study  Team  considers  that  the  Commission’s  activities  carried  out  under  Article 35  are
obviously  not  appropriate  to  make  effective  use  of  its  control  rights  of  monitoring  facilities  and  “verify
their operation and efficiency.” Statements by the Commission on the appropriate nature and efficiency of
such monitoring facilities at Sellafield and La Hague are not backed up by credible data.

Furthermore, the Commission is apparently highly dependent on information provided by Member States
and is therefore apparently not in a position to guarantee that the Basic Safety Standards are respected in
the Member States and concerning the La Hague and Sellafield facilities in particular.

• Application of Article 37

Since  1979,  the  Commission  has  issued  three  opinions  concerning  La  Hague  within  the  framework  of
Article 37 of the Euratom Treaty that requires that “each Member State shall provide the Commission with
such general data relating to any plan for the disposal of radioactive waste in whatever form as will make it
possible  to  determine  whether  the  implementation  of  such  plan  is  liable  to  result  in  the  radioactive
contamination of the water, soil or airspace of another Member State.”

The  Commission  gives  its  Opinion  after  consulting  a  group  of  experts.  Article 37  is  completed  by  the
Commission  Recommendation 1999/829/Euratom  of  6 December 1999  which  defines  the  data  to  be
transmitted to the Commission and the time limits to be respected.

As an illustration, the Commission Opinion concerning the nuclear fuel reprocessing plants UP3 and UP2–
800 of the La Hague Establishment was issued according to the following procedure:

• On  1 March 1989,  reception  of  “the  general  data  concerning  the  plan  for  the  disposal  of  radioactive
waste” transmitted by the French authorities. The general data is not available from the Commission as it is
considered confidential with the Member States.

• On 8 June 1989, meeting of the Group of Experts set up pursuant to the Treaty, in Cherbourg. The experts
required further complementary information.

• On  20 July 1989,  the  Commission  concluded  in  its  Opinion  on  the  La  Hague  facilities  that:
“the implementation of the plan for the disposal of radioactive waste from the UP3 and UP2-800 plants at
the La Hague Establishment is not liable, either in normal operation or in the case of an accident of the type
and magnitude considered in the general data, to result in radioactive contamination, significant from the
point of view of health, of the water, soil or airspace of another Member State; however, in certain severe
accidental circumstances, significant levels of contamination might be obtained in the Channel Islands, but
the projected doses could be reduced at non-significant levels by the introduction of countermeasures.”

The selection of reference accidents is made by the national authorities and “it is not in the intention of the
Commission or the experts to impose specific reference accidents. Nevertheless, it is the responsibility of the
Commission  and  the  experts  to  consider  if  the  accidents  taken  into  consideration  are  those  which  are  of
importance  for  the  type  of  installation  concerned,  as  regard  the  frequency  and  the  potential  for
major release.” 12

The loss of cooling to a High Active Liquor feed vessel was considered as a reference accident in the case of
Sellafield.  As  regards  the  La  Hague (UP3  and  UP2-800)  submission,  the  reference  accident  taken  into
consideration was the loss of cooling in the concentrated fission products vessels.

At Commission level, “the estimated number of man-months spent to analyse the General Data and to draft
the  Report  of  the  Group  of  Experts  and  the  Commission’s  Opinion  is  about  2  for  reprocessing.”  13  The

12 Stephen Kaiser, Commission of the European Communities, e-mail dated 12 June 2001.
13 Augustin Janssens, Commission of the European Communities, e-mail dated 3 May 2001.

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Commission  managed  to  present  its  Opinion  in  less  than  five  months  after  the  submission  of  the  General
Data  by  France.  Considering  the  difficulty  in  co-ordinating  a  Group  of  Experts  of  over  40 people,  not  to
speak about the time necessary to countercheck a significant amount of complex data and review additional
input from the experts, two man-months over four and a half month period seems a very small time budget.

It  is  highly  questionable  whether  the  Commission  under  these  conditions  is  in  a  position  to  fulfil  its
obligation under Article 37 “to determine whether the implementation of such plan is liable to result in the
radioactive contamination of the water, soil or airspace of another Member State.”  The Opinion expressed
by the Commission appears to excessively rely on the General Data submitted by the Member States. This
reliance  is  not  being  adequately  expressed  in  the  various  generally  re-assuring  statements  made  by  the
Commission on the impact of the facilities at Sellafield and La Hague.

3.2.  MARINE POLLUTION - APPLICATION OF THE PRECAUTIONARY PRINCIPLE

While the marine environment is sometimes treated as convenient sink, or even as interesting laboratory (see
Annex 5), international conventions have repeatedly justified the application of the precautionary principle,
especially for discharges of radioactive effluents into the sea, as a means to respond to uncertainty.

In  1992,  Agenda 21  put  forward  the  characteristics  of  radioactive  wastes  to  call  for  a  safe  and
environmentally  sound  management, “including  their  minimisation,  transportation  and  disposal”  (Chapter
22). It clearly pointed out that radioactive wastes are among “the contaminants that pose the greatest threat
to the marine environment.”

The  signatories  were  called  upon  to “support  efforts  within  IAEA  to  develop  and  promulgate  radioactive
waste safety standards or guidelines and codes of practice as an internationally accepted basis for the safe
and environmentally sound management and disposal of radioactive wastes” (Chapter 22).

Highlighting  the  fact  that  there  was “no  global  scheme  to  address  marine  pollution  from  land-based
sources”,  Agenda 21  called  on  nations  to “commit  themselves  to  control  and  reduce  degradation  of  the
marine environment to maintain and improve its life-support and productive capacities”,  the  aim  being  to
“anticipate and prevent further degradation of the marine environment and reduce the risk of long-term or
irreversible effects on the oceans” (Chapter 17).

In  its  Section II.  Ecological  Integrity,  Paragraph 6,  the  Earth  Charter  of  March 2000  called  on  nations  to
“Prevent  harm  as  the  best  method  of  environmental  protection  and,  when  knowledge  is  limited,  apply  a
precautionary approach:

a. Take  action  to  avoid  the  possibility  of  serious  or  irreversible  environmental  harm  even  when

scientific knowledge is incomplete or inconclusive.

b. Place  the  burden  of  proof  on  those  who  argue  that  a  proposed  activit y  will  not  cause  significant

harm, and make the responsible parties liable for environmental harm.

c. Ensure that decision making addresses the cumulative, long-term, indirect, long distance, and global

consequences of human activities.

d. Prevent pollution of any part of the environment and allow no build-up of radioactive, toxic, or other

hazardous substances.

e. Avoid military activities damaging to the environment.”

The  London  Dumping  Convention  of 1972,  in  which  the  signatories  convened  to “promote  the  effective
control of all sources of pollution of the marine environment”  (Article 1),  gave  an  impulse  to  international
co-operation some twenty years later with the conclusion of the OSPAR Convention. The latter considered
that additional international actions aiming at preventing and avoiding marine pollution had to be taken as
part of a progressive and coherent program for the protection of the sea.

The  OSPAR Convention  required  the  application  of  the  precautionary  principle  by  “taking  every  possible
measure”  to  prevent  and  eliminate  pollution  and  protect  the  maritime  zone  against  prejudicial  effects  of
human  activities (Article 2).  The  French  authorities,  nevertheless,  consider  that  the  OSPAR  Convention
defines only “general obligations, such as the prevention and elimination of pollution with the application of
the  precautionary  and  the  polluter-pays  principles”  notably.  Further  detailed  decisions  taken  within  the

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framework of the OSPAR Convention “commit only the Member States which voted them.” 14 There is a risk
that such decisions remain unapplied as long as they are not signed by France and Great Britain.

In 1999, the OSPAR Commision defined the following strategy regarding radioactive substances :

“-by the year 2000

a. the  Commission  will,  for  the  whole  maritime  area,  work  towards  achieving  further  substantial

reductions or elimination of discharges, emissions and losses of radioactive substances;

-by the year 2020

b. the  Commission  will  ensure  that  discharges,  emissions  and  losses  of  radioactive   substances  are
reduced  to  levels  where  the  additional  concentrations  in  the  marine  environment  above  historic  levels,
resulting from such discharges, emissions and losses, are close to zero.”

The  decision  adopted  in  June 2000 (and  which  came  into  force  in  January 2001)  concerning  discharges  in
relation with reprocessing compels the signatories to review “as a matter of priority”  the authorisations for
radioactive  discharges  from  reprocessing  plants,  and  work  towards “implementing  the  non-reprocessing
option.” The United Kingdom and France, although they refused to sign the decision, are politically obliged
to  comply  with  the  orientation  defined  by  the  Commission. Similarly,  the  Sintra  Declaration  signed
in July 1998, calling for near zero-level discharges of liquid radioactive substances by the year 2020, is much
more a plea for a common political will to protect the environment than a legally-binding instrument.

The matter therefore should clearly be addressed at European level in application of Article 174(2) of the EC
Treaty: “Community policy on the environment shall be (…) based on the precautionary principle and on the
principles  that  preventive  action  should  be  taken,  that  environmental  damage  should  as  a  priority  be
rectified at source and that the polluter should pay.”

14 P.  Saint-Raymond,  Assistant  Director  of  DSIN,  in  “La  Convention  OSPAR  et  les  rejets  radioactifs  dans

l'Atlantique”, Contrôle, n° 137, November 2000.

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4. RISK ASSESSMENT OF RADIOACTIVE RELEASES

4.1.  RELEASES FROM REPROCESSING

Nuclide  releases  from  reprocessing  depend  on  the  tonnages,  types,  enrichments,  storage  periods  and  burn-
ups of fuels, which are reprocessed. Nuclear inventories in spent fuel are estimated by computer codes that
analyse nuclide concentrations from fission rates and neutron fluxes in reactors. Most codes are derived from
US programs for light water reactors, such as ORIGEN or its derivatives.

Nuclide  emissions  to  air  from  nuclear  facilities  are  transported  in  radioactive  plumes,  which  deposit
particulates and aerosols downwind. This results in contamination of local food chains, including the grass-
cow-milk-infant chain. In addition to doses from the ingestion of contaminated local foods, local individuals
may also receive radiation doses from immersion in radioactive aerosols, inhalation of radioactive gases and
particulate  matter,  and  ground  shine  from  nuclides  deposited  on  land.  From  nuclides  discharged  to  sea,
individuals  may  receive  doses  from  ingestion  of  fish,  crustaceans  and  molluscs.  The  use  of  contaminated
seaweed as animal feed and as fertiliser, the return of nuclides via sea spray and foam are additional marine
contamination pathways.

Various  computer  models  have  been  designed  to  estimate  radiation  doses  to  members  of  critical  groups
living near nuclear facilities from nuclide releases. These groups are expected to receive the highest levels of
radiation: limits are designed to protect these individuals on the theory that if these people are protected, all
other individuals in the population will also be protected. As discussed below, these critical group limits only
protect individuals and not populations.

4.2.  COLLECTIVE DOSES

4.2.1. Introduction

Radiological impacts of nuclide discharges are conventionally measured in two ways. First, by estimating the
average individual dose to members of critical groups near nuclear facilities; second, by estimating doses to
whole populations affected by nuclide discharges. The latter are usually termed collective doses. The main
advantage  of  collective  dose  is  that,  were  only  individual  dose  used,  the “dilute  and  disperse”  approach  to
waste management might be encouraged rather than the “retain and concentrate”  approach preferred by some
Member States [see DETR, 2000].

Differences  of  view  exist  within  radiation  protection  circles  over  the  usefulness  of  collective  dose.  On  the
one  hand,  international  agencies  and  some  national  authorities  use  and  recommend  the  use  of  collective
doses.  For  example,  the  European  Commission  has  implemented  a  Directive (Euratom  96/29)  containing
detailed  procedural  requirements  on  collective  dose,  as  described  in Annex 6.  On  the  other  hand,  despite
legal requirements and authoritative recommendations, there remains a reluctance within the nuclear industry
and  some  national  regulatory  agencies  to  embrace  collective  dose.  Although  rarely  discussed  in  the  open
literature, unco-operative attitudes towards the use of collective doses remain in some quarters.

4.2.2. Theoretical Justification

The crucial theoretical underpinning for collective dose lies in the adoption by the scientific community of
the  Linear  No-Threshold (LNT)  model  for  radiation’s  adverse  health  effects [ICRP,  1991;  NCRP,  1995].
This model states that there is no level of radiation exposure below which there is no effect: risks continue
with  declining  doses  until  zero  dose.  Even  the  smallest  possible  dose,  i.e.  a  photon  passing  through  a  cell
nucleus, carries with it a risk of cancer. Although this is an extremely small risk, it is still a finite risk. The
LNT relationship is important for collective dose, as most individual doses in a collective dose are extremely
small. The LNT model justifies the estimation of these extremely small doses, and justifies their addition to

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produce  collective  doses.  More  detailed  information  on  the  use  and  calculation  of  collective  doses  is
contained in Annex 6.

4.2.3. Global Collective Doses

Global  collective  doses  arise  from  the  discharge  of  certain  nuclides  with  long  half-lives,  including  tritium,
carbon-14,  chlorine-36,  krypton-85  and  1291,  which  are  globally  distributed  and  act  as  long-term  low-level
sources of radiation exposure to the world’s population. Recent high discharge levels of technetium-99 have
prompted  consideration  of  its  likely  global  distribution [Fairlie  and  Sumner,  2001].  Global  compartmental
models estimating global doses from releases of several nuclides have been constructed by the IAEA [1985],
and the European Commission [Simmonds et al, 1996] and [Titley et al, 1995].

4.2.4. Important Radionuclides in Reprocessing Releases

Radiation doses depend strongly on the individual radionuclides to which the public is exposed. Therefore a
brief description of the main nuclides discharged from reprocessing facilities is set out below.
4.2.4.1.  Carbon-14 (14C)
Carbon-14  is  a  radioactive  isotope  of  carbon  with  a  half-life  of 5,730 years:  it  emits  beta  particles  of
maximum energy 156 keV. The major sources of carbon-14 in irradiated nuclear fuel are neutron activation
of nitrogen (in fuel as impurity and/or additive) and oxygen (in fuel as UO2). carbon-14 is retained in spent
fuel until reprocessing when it is released in both gaseous and liquid forms.

Carbon-14 is produced naturally in the upper atmosphere as a result of the capture of cosmic ray neutrons by
nitrogen-14.  Because carbon-14  behaves  in  the  same  way  as  stable  carbon,  it  is  rapidly  distributed  among
environmental  compartments –  stratosphere,  troposphere,  biosphere  and  surface  ocean  waters.  Transfers
between  atmosphere,  biosphere  and  surface  ocean  waters  take  place  with  time  constants  of  a  few  years;
transfer to deep ocean proceeds more slowly.

Carbon is a major constituent of all life forms. All carbon-14, whether anthropogenic or naturally-occurring
enters  the  natural  carbon  pool  including  all  biota.  Because  the  half-life  of  carbon-14  is 5,730  years,  doses
from carbon-14 introduced into the environment will be delivered to local, regional and global populations
for  many  generations.  carbon-14  is  the  main (>80%)  contributor  to  collective  doses  from  reprocessing
discharges,  as  discussed  in  Chapter 7.  Carbon-14  collective  doses  are  similar  whether  released  to
atmosphere or sea.
4.2.4.2.  Krypton-85 (85Kr)
Krypton-85 is a strong beta-gamma emitter with a half-life of 10.7 years. It is a fission product  retained  in
reactor fuel until released during reprocessing. Krypton-85 released to atmosphere exposes people to external
beta irradiation of the skin, and to uniform whole body gamma irradiation. Although the dose from a single
decay  of  krypton-85  is  small,  the  amounts  of  krypton-85  discharged  are  very  large –  the  largest  of  all
nuclides  emitted  by  reprocessing.  Accordingly  doses  from  krypton-85  are  appreciable.  Krypton-85
distributes uniformly throughout the earth’s atmosphere within a few years after release, so collective doses
from krypton-85 are important.

Krypton-85 is an inert gas and is currently not thought to enter life processes nor be incorporated in biota,
unlike  iodine-129, carbon-14 and tritium. Krypton-85 dosimetry is based on theoretical  models  rather  than
experimental  data.  The  little  data  which  exists  refer  to  acute,  non-equilibrium  exposures:  it  is  difficult  to
estimate long-term doses reliably from such information.
4.2.4.3.  Iodine-129 (129I)
Iodine-129  is  a  weak  beta  emitter  with  a  half-life  of  16  million  years.  It  is  produced  during  the  fission  of
uranium with a yield of 1% and is released during reprocessing in large quantities. Its long half-life means it
will widely distribute in the environment, become part of the iodine pool, and deliver a thyroid dose to the
global population. Iodine is mobile in the environment, and rapidly incorporated in foodstuffs. The highest
environmental concentrations of iodine occur in seawater.

Considerable  uncertainty  surrounds  the  transfer  of  iodine-129  to  deep  oceans  and  the  sedimentation
processes that may remove activity from biological chains [UNSCEAR, 1988]. The observed residence time
of iodine in the ocean is about 100,000 years [Raisbeck, 1995]

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The estimation of radiation doses from all environmental radionuclides is carried out by models of varying
complexity. Their results should be validated by comparison with environment measurements.

The lack of monitoring and model validation for iodine-129 releases from La Hague has been criticised by
CRII-Rad [1997]. Their report drew attention to iodine-129  measurements  one  or  two  orders  of  magnitude
higher than those predicted by the MARINA model. It stated that these under-estimations were probably due
to incorrect iodine concentration factors.

CRII-Rad  also  pointed  out  that  the  estimation  of  doses  to  individuals  did  not  take  into  account  use  of
seaweed in industrial applications (e.g.  extraction  of  polysaccharides  from Chondrus  crispus  for  use  in  ice
cream, desserts etc.), and use of seaweed as an agricultural fertiliser. Iodine in seaweed can be transferred to
vegetables with very high transfer factors; for maize the concentration factor is 3. Raised iodine-129 levels in
seaweed  is  not  just  local  to  La  Hague,  but  occurs  on  the  French  coast  from  North  Brittany  to  the  Pas-de-
Calais, and to a lesser extent on the south coast of England and on North Sea coasts.

The  release  of  iodine-129  to  atmosphere  is  an  important  component  of  dose  to  the  “terrestrial” (i.e.  land)
critical  group.  Predicting  iodine-129  concentrations  in  milk  is  a  difficult  and  uncertain  process:  widely
different values of iodine-129 dose have been estimated around the Sellafield plant [Fulker et al, 1997a].

Problems with iodine-129 dosimetry include:

• Uncertainties concerning the chemical and physical forms of iodine, i.e. the proportions of organic,

inorganic and particulates iodine.

• Iodine-129 is difficult to measure at the concentrations encountered in the environment
• Some parameters in iodine models are very uncertain, including the grass to milk parameter [Fulker

et al, 1997a, 1997b] .

the  French  National 

Institut  de  Protection  et  de  Sûreté  Nucléaire (IPSN)  has

Recently it has become possible to measure iodine-129 using neutron activation analysis, which has a lower
limit  of  detection.  The  Groupe  Radioécologique  Nord  Cotentin,  chaired  by  Dr.  Annie  Sugier,  Director  of
Protection  at 
highlighted [GRNC, 1999]  the  significant  difference  between  calculated  and  measured  quantities  of
iodine-129  discharged  into  the  environment.  However,  the  Group  did  not  analyse  possible  reasons  for  this
nor potential impacts of the problem. It has been shown (see Annex 25) that considerable differences exist
between estimated iodine-129 inventories in fuels processed and actual iodine-129 releases: up to 50% of the
theoretical activity could not be accounted (see Chapter 6 on La Hague).
4.2.4.4.  Tritium (3H)
Tritium (3H) is the radioactive isotope of hydrogen. It is a weak beta emitter with a maximum decay energy
of 18 MeV, and a half-life of 12.3 years. Tritium is formed naturally through cosmic ray interaction with H
in  the  upper  atmosphere.  However,  anthropogenic  tritium  emissions  considerably  exceed  natural  sources.
Tritium commonly occurs as tritiated water, i.e. 3HOH, and as elemental tritium gas, 3HH. Tritium is created
in nuclear fuel by the activation of hydrogen (1H) and deuterium (2H), and as a tertiary fission product. Some
tritium is released at reactors but the majority is released from reprocessing plants at fuel dissolution stage.

In  some  respects,  tritium  is  an  unusual  radionuclide.  The  high  mobility  of  tritiated  water  in  the  biosphere,
cycling in the biosphere, multiple pathways to man, ability to bind with cell constituents to form Organically
Bound  Tritium,  and  the  heterogeneous  dose  distribution  of  bound  tritium  mark  it  out,  potentially,  as  a
hazardous radionuclide. These characteristics are not reflected in tritium’s safety limits that are based on its
dose per unit intake, which is relatively low. In sum, tritium is a very efficient distributor of radioactivity in
the environment and in the human body [Fairlie, 1992].

Ingested tritiated water has a biological half-life of about 10 days. Ingested tritiated foodstuffs (OBT) have
much longer half-lives, which are poorly defined and may extend to several years in some tissues.
4.2.4.5.  Technetium-99 (99Tc)
Technetium-99  is  a  radioactive  isotope  of  technetium,  which  emits  beta  particles  and  has  a  half-life
of 214,000 years. It is produced at relatively high yield in the fission of uranium.

Technetium  does  not  occur  naturally  in  the  environment.  Globally,  the  dominant  sources  of  technetium-99
are fallout from nuclear weapons testing in the atmosphere, releases from nuclear fuel reprocessing and the
use  of 99mTc (which  decays  into 99Tc)  in  diagnostic  nuclear  medicine [Smith et al, 1997].  Technetium  is

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present in the marine environment mainly in the form of the pertechnetate ion (TcO4
may be transported over long distances.

-), which is soluble and

In the human body, the pertechnetate ion behaves in a similar way to the iodide ion, i.e. it concentrates in the
thyroid (although  unlike  iodide  it  is  not  incorporated  into  hormones).  Hardly  anything  is  known  however,
about the possible existence of other chemical forms, and their stability and environmental pathways.

Because technetium-99 is soluble and unbound to sediments, it travels rapidly from its point of release. From
Sellafield,  the  transit  time  to  the  North  Channel (between  Northern  Ireland  and  South  West  Scotland)  is
about  3 months,  to  the  Northern  North  Sea  6 months  and  the  Norwegian  Coastal  Current  around
2.5 years [Leonard et al, 1997].

4.3.  UNCERTAINTIES IN RISK ASSESSMENT

There are two main ways to assess potential environmental and health impacts associated with reprocessing
discharges:

• direct measurement of environmental contamination, and of health effects (i.e. morbidity) through

epidemiological studies;

• use  of  computer  models,  on  dispersion/concentration  of  nuclides  in  the  environment,  and  on  the

evaluation of doses to critical groups and to populations.

In practice, the two approaches are complementary, and linked: measurements are needed as for input and
benchmarks  for  models,  and  models  are  used  to  establish  monitoring  priorities  in  the  environment  and
epidemiological studies.

Figure 1  illustrates  successive  steps  taken  in  an  evaluation  of  environmental  and  health  risks  from
reprocessing  operations  based  on  models,  and  the  areas  of  associated  uncertainties.  This  is  similar  to  the
approach  used  by  GRNC (Groupe Radioécologie Nord-Cotentin) in their evaluation  of  health  risks  around
the La Hague plant. Each step uses models, sometimes validated by measurement, and each involves many
parameters  and  the  use  of  many  assumptions,  which  result  in  high  levels  of  uncertainty.  After  a  brief
description of the steps is given below, the main uncertainties lying in this evaluation process are discussed
in relevant chapters of the report [on some of the uncertainties found in these approaches, see Smith et  al,
1998; IPSN, 2001].

The starting point is the set of assumptions used in computer models to assess nuclide inventories in spent
fuel. Data on spent fuel reprocessed, especially its type, initial enrichment and burnup, are used in computer
codes to calculate the nuclide content of spent fuel, hence the input of various nuclides into the reprocessing
plant.  To  assess  actual  discharges,  detailed  knowledge  (based  on  theoretical  calculations  by  the  plant
engineers) of the physical and chemical processes in the plant, leading to the release of nuclides to air and
sea  is  required.  These  releases  are  verified  through  material  balance  assessments  in  the  plant,  which  will
include stack measurements of discharges.

This results in the nuclide inventories in gaseous and liquid discharges. Then physical data on the nuclides,
and  their  behaviour  in  relevant  environments  are  used  to  estimate  their  concentrations  in  the  environment.
The estimates derived from these tranport models have to be validated by measurements in the environment.
Local data are used for local and national models, rather than global models. In the case of certain long-lived
nuclides, global transport models are also necessary.

Estimates  of  concentrations  in  the  environment  allow  for  the  evaluation  of  doses  to  critical  groups  and  to
populations  through  the  definition  of  exposure  scenarios.  Finally,  models  of  the  dose-effect  relation,  like
those defined by the ICRP, are used to estimate the heath risks.

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Figure 1 Uncertainty in the Evaluation of Environmental and Health Risks

from Reprocessing Operations

STEP 1

Reprocessing operations

Spent fuel features................................ ...............
Processes features................................ ................

................................ .................. Computer codes
................................ ................ Material balance

STEP 2

Activity of radionuclides
in liquid and gaseous discharges

Characteristics of radionuclides...........................
Environmental features................................ ........

................................ ................................ . Model
................................ ......................... of transport

STEP 3

Activity of radionuclides
in the environment

Scenarios for external................................ ..........
and internal exposure................................ ...........

................................ ................................ . Model
................................ ......................... of exposure

STEP 4

Doses (to individuals or populations)
from exposure

Dose / effect ................................ ........................
relation................................ ................................

................................ ................................ . Model
................................ ................................ . of risk

STEP 5

Health risks

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

5. CASE STUDY SELLAFIELD

5.1.  NATIONAL REGULATORY FRAMEWORK

The United Kingdom has developed a large set of national nuclear regulations in the five decades its atomic
energy programme has been in operation.15

The  Food  Standards  Agency –  which  has  the  legal  status  of  a  Government  department  but  without  a
minister – also plays a role in nuclear regulation and radiological protection in the UK.

The first nuclear regulation dates to the passing of the Radioactive Substances Act in 1948. Next came the
Atomic Energy Act in 1954, followed by the revised Radioactive Substances Act in 1960. In 1959, a  White
Paper –  covering  the  proposed  policy  framework –  was  published  on  radioactive  waste,  including
discharges.  This  was  followed  in 1965  by  the  Nuclear  Installations  Act,  consolidating  earlier  legislation,
covering the licensing of nuclear sites, including reprocessing plants.

The most relevant recent legislation, or draft legislation in process covering radiological protection includes:

• Radioactive Substances Act 1993: Regulation of Radioactive Discharges;

• Variations  to  the  BNFL  Sellafield  Radioactive  Waste  Discharge  Authorisations:  Decisions  of  the
Secretary  of  State  for  the  Environment,  Transport  and  the  Regions  and  the  Minister  of  Agriculture,
Fisheries and Food;

• UK Strategy for radioactive discharges 2001-2020.

In recent years, the United Kingdom government has increased the opportunity for citizens to be consulted
policy  review  via  submissions  to  official  Consultations,  including  the  House  of  Lords  Consultation  on
Radioactive  Waste  strategy (1998-99);  the  Environment  Agency  Consultation  on  proposed  revision  of
authorisations  for  technetium-99  and  other  radioactive  waste  discharges  from  Sellafield (2000);  and
the DETR Consultation on UK Strategy for Radioactive Discharges, 2001-2020 (2000). In addition there is a
five part Consultation on discharges and other aspects of the MOX fabrication plant (SMP) at Sellafield, first
by the Environment Agency in 1997-98, then by the DETR16 in 1999, and 2001.

5.2.  OPERATIONS AT SELLAFIELD

Reprocessing  has  been  carried  out  at  Sellafield (originally  Windscale)  since  the  early  1950s,  when  the
purpose  was  to  separate  plutonium  for  nuclear  weapons.  Table 1  sets  out  annual  tonnage  throughputs
since 1970.  Early  data  concerning  reprocessing  by  the  (now  shut)  B204  reprocessing  plant  is  unavailable.
Since  1965,  the  B205  fuel  reprocessing  plant  at  Sellafield  has  been  operating  principally  for  commercial
purposes. The B205 plant reprocesses Magnox fuel, i.e. metallic uranium fuel clad in magnesium alloy from
Magnox gas-cooled reactors. These reactors are in the process of being phased out by about 2010.

Approximately 26,000 tonnes of spent fuel have been reprocessed by the B205 line at Sellafield up to year
ending 2000. Estimates vary as to how long reprocessing will continue at B205 [see discussion in RWMAC,
2000] but an informed estimate would be about 2012 based on current annual throughput rates.

15 Details  of  the  current  radiological  protection  and  nuclear  licensing  legislation  may  be  found  on  the  relevant

departmental web sites:
Department of Trade & Industry: http://www2.dti.gov.uk/energy/nuclearsafety.htm
Department of the Environment, Transport and the Regions: http//www.environment.detr.gov.uk/radioactivity.htm
16 The environmental functions of the former DETR were transferred to the new Department of Environment, Food and

Rural Affairs (DEFRA) in June 2001.

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The  THORP (THermal  Oxide  Reprocessing  Plant)  plant  started  operations  in 1994  to  reprocess  uranium
oxide  fuel  in  stainless  steel  cladding  from  Advanced  Gas-cooled  Reactors  (AGR)  and  Light  Water
Reactors (LWR). So far about 3,200 tonnes of oxide fuel have been reprocessed at THORP.

No new reprocessing contracts (domestic or overseas) are likely at THORP. Estimates vary as to how long
reprocessing could continue at THORP [RWMAC, 2000] under current contracts but an informed estimate
would be also about 2012 based on its lifetime throughput rate.

Table 1 Annual Fuel Throughputs at B205 and THORP (financial years April-April)

Year Magnox B205

Year

Magnox B205

THORP

1971-72
1972-73
1973-74
1974-75
1975-76
1976-77
1977-78
1978-79
1979-80
1980-81
1981-82
1982-83
1983-84
1984-85
1985-86

880
674
935
995
553
1,130
823
666
803
859
923
893
860
781
705

1986-87
1987-88
1988-89
1989-90
1990-91
1991-92
1992-93
1993-94
1994-95
1995-96
1996-97
1997-98
1998-99
1999-00
2000-01

983
804
875
1,129
739
819
728
1,664
1,059
1,590
601
520
465
500
366

65
208
408
781
461
879
362

Sources: CEGB reports, CORE reports, 1971-2 to 83-84 from CEGB reports, 1984-85 to 92-93 from BNFL Data Book.
“BNFL to again shut Sellafield plant to boost reprocessing of Magnox fuel”  Nuclear Fuel Vol. 25 No. 16, Aug. 7, 2000;
BNFL Annual Reports.

Total

~25,000

3,164

5.3.  RELEASES FROM SELLAFIELD

Releases from Sellafield are presented below. Emissions to air are presented in Figure 2. Liquid discharges
are presented in Figures 3a and 3b: light and heavy nuclides (mainly activation products) in the second one,
and others nuclides (mainly fission products) in the first one. The reason for the division into two graphs is
merely  to  present  the  mass  of  data  points  more  clearly,  not  because  there  is  any  difference  between  their
treatments  at  Sellafield.  Logarithmic  Y-axes  are  used  to  encompass  the  wide  ranges  of  data.  It  should  be
noted that logarithmic scales do not show small fluctuations in data points.

5.3.1. Air Emissions

It may be seen from Figure 2 that radioactive air emissions at Sellafield have not varied to a marked extent
since  the 1970s,  with  the  possible  exception  of  iodine-129  emissions  which  have  increased  10 fold  in  this
20 year time period. As stated in Chapter 4, radiation protection concerns exist over iodine-129, which has a
16 million year half-life.

The  question  of  the  contribution  of  carbon-14  releases  from  the  Calder  Hall  reactors  to  global  Sellafield
releases  was  raised  during  the  research.  According  to  the  UK  Environment  Agency  it  is  insignificant:
“Carbon-14  aerial  discharges  from  Calder  Hall  nuclear  power  station  are  small  compared  to  Magnox

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Reprocessing  and  THORP  and  represent  only  a  small  percentage  (2.3%)  of  discharges  from  Sellafield.
Carbon-14 is currently discharged to air from the power station without abatement.”  17

Figure 2 Annual Air Emissions from Sellafield Reprocessing Operations, 1976–1999 (TBq)

100000

10000

1000

100

10

1

0,1

0,01

0,001

1976

1978

1980

1982

1984

1986

1988

1990

1992

1994

1996

1998

Carbon-14

Tritium

Krypton-85

Iodine-129

Source: BNFL Annual Reports on Discharges and Monitoring of the Environment

5.3.2. Liquid Discharges

With  liquid  discharges  to  sea,  the  picture  is  more  complex.  In  the  late 1970s,  very  high  levels  of  fission
products  and  actinides (particularly  plutonium  isotopes)  were  contained  in  pond  liquors  discharged  to  sea.
These discharges occurred as a consequence of Magnox fuel assemblies being held in ponds for long periods
awaiting  reprocessing.  This  resulted  in  the  disintegration  of  many  assemblies  and  in  heavy  radioactive
contamination of pond liquids. These were subsequently discharged untreated to sea.

In the early 1980s, discharges of carbon-14, strontium-90, caesium-134 and caesium-137 declined markedly
as a result of the introduction of a new abatement plant, the Site Ionisation and Exchange Plant (SIXEP) at
Sellafield.  However,  in  the  mid 1990s  smaller  increases  occurred  in  carbon-14,  cobalt-60,  strontium-90,
technetium-99 and iodine-129 discharges.

It is understood from the Commission’s comments [see European Parliament, undated] that these increases
resulted from the reprocessing of older oxide fuels at Sellafield. Technetium-99 increases resulted from the
commencement  of  treatment  of 14 years’  arisings  of  Medium  Activity  Concentrate  wastes  from  Magnox
reprocessing  which  had  previously  been  stored.  These  wastes  were  treated  by  the  new  Enhanced  Actinide
Removal Plant (EARP) at Sellafield. Over the same timespan, there  has  been  a  notable  decline  in  actinide
discharges, partly due to the commencement of EARP operations.

17 Environment Agency, Explanatory Document for the 2001 Review of Sellafield Releases, Appendix 6, 31 July 2001

       35

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE
Figure 3a Annual Liquid Discharges from Sellafield Reprocessing Operations, 1976–1999 (TBq)

Cobalt-60; strontium-90; technetium-99; iodine-129; caesium-134, 137

10000

1000

100

10

1

0,1

0,01

1976

1978

1980

1982

1984

1986

1988

1990

1992

1994

1996

1998

Cobalt-60
Caesium-134

Iodine-129
Caesium-137

Technetium-99
Strontium-90

Source: BNFL Annual Reports on Discharges and Monitoring of the Environment

Figure 3b Annual Liquid Discharges from Sellafield Reprocessing Operations, 1976–1999 (TBq)

Tritium; carbon-14; plutonium (alpha, -241), americium-241

10000

1000

100

10

1

0,1

0,01

1976

1978

1980

1982

1984

1986

1988

1990

1992

1994

1996

1998

Tritium
Plutonium-241

Carbon-14
Americium-241

Plutonium-alpha

Source: BNFL Annual Reports on Discharges and Monitoring of the Environment

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

5.3.3. Technetium Discharges

In  recent  years,  concern  has  been  expressed  by  Member  States (including  Denmark  and  Ireland)  over
technetium  discharges  from  Sellafield.  Technetium  does  not  exist  naturally  in  the  environment:  all
concentrations  found  in  the  biosphere  and  hydrosphere  are  man-made.  Technetium-99  is  mobile  in  the
environment, and has a half-life of 214,000 years, which means that its distribution will eventually be global.
It  should  be  noted  that  technetium  discharges  result  mainly  from  Magnox  reprocessing:  it  occurs  in  light
water reactor fuel and thus in current La Hague discharges only in relatively low concentrations.

Figure 4  examines  annual  technetium  discharges  from  Sellafield  in  more  detail.  It  will  be  seen  that
between 1977 (when  measurement  of  technetium  discharges  commenced)  and 1980,  technetium  discharges
were high due to the direct discharge of Medium Activity Concentrate (MAC) wastes as mentioned above.
Between 1981  and 1993,  MAC  wastes  were  stored  in  tanks,  then  from 1994  they  were  treated  in  the
new EARP plant for the enhanced removal of actinides and caesium isotopes. This plant however does not
remove  technetium-99 (and  has  relatively  low  removal  rates  of  strontium-90,  cobalt-60  and  carbon-14  as
seen  from  Figures 3a  and b).  This  lack  of  removal  capability  was  known  in  the  early  1990s  during  the
planning  stages  of  EARP.  However  the  decision  was  then  taken  that  the  increased  cost  of  additional
abatement  plant  to  reduce  technetium-99 (and  other  nuclide)  discharges  was  not  worthwhile.  The  result  is
seen  below  in  the  evolution  of  discharges,  although  they  have  been  generally  declining  since 1995.  In
November 2000, 
technetium  discharges
of 90 TBq (million millions or trillion becquerels) from Sellafield. This matter is still the subject of a formal
Consultation procedure in the UK.

the  UK Environment  Agency  proposed 

to  permit  annual 

Figure 4 Annual Technetium-99 in Liquid Discharges from Sellafield, 1978–1999 (TBq)

1000

100

10

1

1978

1980

1982

1984

1986

1988

1990

1992

1994

1996

1998

Technetium-99

Source: BNFL Annual Reports on Discharges and Monitoring of the Environment

5.3.4. Expected Future Sellafield Discharges

Internal BNFL documents [BNFL, undated] leaked to the UK press and environmental groups in June 2001
suggest  that  BNFL  envisages  increases  in  nuclide  releases  in  the  future,  as  shown  in Figures 5  and 6.  The
document,  which  contains  detailed  analyses  of  current  and  expected  discharges,  states  as  regards  liquid
discharges: “Comparison of the total worst case discharge with the current authorised limits  (…) shows that
discharges of over half of the currently authorised radionuclides are predicted to be at levels approaching or
above the limits.”

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE
Figure 5 Past and Projected Liquid Discharges from Sellafield Reprocessing Operations, 1990–

2008 (TBq, Index 1 in 1990)

OSPAR (PARCOM 91/4): “The contracting parties (…) agree (…) to apply the Best Available Technology to minimize
and, as appropriate, eliminate any pollution caused by radioactive discharges.”
OSPAR (PARCOM 93/5): “Contracting parties (…) agree (…) to adopt further measures, including the application of
Best Available Techniques for the reduction or elimination of inputs of radioactive substances to the maritime area.”

Technetium-99

Cobalt-60

60

50

40

30

20

10

OSPAR
(PARCOM 91/4)

OSPAR
(PARCOM 93/5)

0
1990

12

10

8

6

4

2

0
1990

1992

1994

1996

1998

2000

2002

2004

2006

2008

OSPAR
(PARCOM 91/4)

OSPAR
(PARCOM 93/5)

Iodine-129

Carbon-14

Tritium

1992

1994

1996

1998

2000

2002

2004

2006

2008

Source: [BNFL, undated]

A  similar  situation  was  expected  with  aerial  releases  from  Sellafield: “A  number  of  predicted  worst  case
discharges  are  close  to  or  exceed  the  current  annual  authorisation  limits,  which  implies  a  risk  that  these
limits could be breached in future as a consequence of normal activities .”

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Increases  of  Sellafield  releases  would  conflict  with  the  UK  Government’s  obligations  set  out  in  various
OSPAR  resolutions  that  call  for  the  reduction  and  eventual  elimination  of  radioactive  discharges  into
the environment.

Figure 6 Past and Projected Gaseous Emissions from Sellafield Reprocessing Operations, 1990–

2008 (TBq, Index 1 in 1990)

OSPAR (PARCOM 91/4): “The contracting parties (…) agree (…) to apply the Best Available Technology to minimize
and, as appropriate, eliminate any pollution caused by radioactive discharges.”
OSPAR (PARCOM 93/5): “Contracting parties (…) agree (…) to adopt further measures, including the application of
Best Available Techniques for the reduction or elimination of inputs of radioactive substances to the maritime area.”

9

8

7

6

5

4

3

2

1

0
1994

Krypton-85

Tritium

Carbon-14

Iodine-129

1996

1998

2000

2002

2004

2006

2008

Source: [BNFL, undated]

5.4.  IMPACT OF SELLAFIELD DISCHARGES

5.4.1. Plutonium and other actinides near Sellafield

When radionuclides are discharged into the sea from Sellafield, some (e.g. fission products caesium-137 and
technetium-99) are soluble and diluted in large volumes of seawater. Others (notably plutonium) tend to be
concentrated in sediments close to Sellafield, in the Irish Sea and in the Solway Firth. Up to 1995, discharges
into the sea of plutonium (alpha) and americium-241 from Sellafield amounted to about 1,600 TBq. Kershaw
et  al [1992]  estimate  that  at  least  240 TBq  of  plutonium-239/240  remains  bound  to  the  seabed  within  a
coastal strip approximately 30 km wide, running from Kirkcudbright Bay to the Ribble estuary in the south.
The quantity outside this zone amounts to about 40 TBq of plutonium-239/240.

Radionuclide  deposition  around  Sellafield  was  analysed  by  Day [1992].  Plutonium  deposition  plots  show
two main features: a major deposition peak centred on Sellafield falling sharply with distance, and a minor
peak, centred a short distance inland from the Ravenglass Estuary. The peak centred on Sellafield dominates
the plutonium deposition map for this part of Cumbria. A slightly raised level of deposition is also apparent
along the coastal strip. Peak values of plutonium concentration are about three orders of magnitude higher
than  the  concentrations  due  to  weapons  fallout.  Day  concluded  the  plutonium  deposited  within  20 km  of
Sellafield attributable to aerial emissions was 160-280 GBq, compared with 90 GBq from bomb fallout.

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A potentially important pathway for discharged radioactive material to humans involves sea-to-land transfer.
Although  this  mechanism  was  disregarded  before 1980,  it  has  since  been  established  that  significant
quantities of radionuclides can become airborne in sea spray and be transported inland by the wind [McKay
and Pattenden, 1990]. Actinides with an activity of 2.5x105 Bq, equivalent to about 1,000 body burdens, can
be transported inland relatively quickly. The average activity due to actinides is 40 µBq/m3 15-120 m  from
the sea, and may occasionally exceed the ICRP limit of 1 mBq/m3 [Branford, 1994].
From  these  data,  the  scale  of  past  nuclide  discharges  from  Sellafield  may  be  seen  to  be  large.  Consequent
concerns  have  been  expressed  about  resulting  nuclide  concentrations  in  the  environment.  For  example,
Lambert [1989]  and  Aarkrog [1997]  have  estimated  that  over 40,000 TBq of  caesium-137,  113,000 TBq of
beta emitters and 1,600 TBq of alpha emitters have been discharged into the Irish Sea since the inception of
reprocessing  at  Sellafield.  Baxter [1991]  has  observed  that  this  means  between 250  and 500 kilograms  of
plutonium from Sellafield is now adsorbed on sediments on the bed of the Irish Sea. Hunt and Smith [1999]
have  commented  that  a  storm  could  bring  contaminated  sediment  onshore,  leading  to  increased  doses  to
critical groups in the years following the event. Baverstock [1997] has stated that the migration of undersea
deposits of actinides to coastal environments represents a long-term hazard of largely unknown proportions.

Apart from bomb test fallout, past discharges at Sellafield are easily the largest anthropogenic discharges of
radioactivity  to  the  oceans.  Current  discharges  from  Sellafield  and  La  Hague  still  rank  among  the  largest
anthropogenic releases of radioactivity in the world.

5.4.2. Estimated Doses from Consumption of Irish Sea Fish and Shellfish

The main pathways of radiation exposure for those living near Sellafield are: (1) external radiation from both
airborne  and  deposited  radionuclides;  (2) internal  exposure  after  inhalation  of  airborne  radionuclides;  and
(3) ingestion of radionuclides present in foodstuffs.

In the Sellafield area, the critical group is now thought to consist of members of the local fishing community
who consume significant quantities of locally caught fish and shellfish. This is contaminated with a number
of  radionuclides;  plutonium  and  americium  are  particularly  important  from  the  point  of  view  of
potential toxicity.

The RIFE-5 report [FSA, 2000], sets out estimated doses to consumers of seafood from the Irish Sea. Those
are presented in Annex 7. It will be seen that these estimated doses are relatively low in comparison with the
current UK dose constraint of 0.3 mSv/a.

5.4.3. Doses to Critical Groups

A recent review [Jackson et al, 2000] of critical groups doses states that, during the 1970s and 1980s, peak
doses  possibly  reached 2.5  to 3.0 mSv  per year.  Latterly,  doses  to  marine-related  critical  groups  have
declined to less than 0.15 to 0.2 mSv per year.

Although there has been a comprehensive programme of environmental monitoring in recent years, there has
been  limited  monitoring,  i.e.  body  scans,  of  radionuclides  in  members  of  the  public  living  near  Sellafield.
A rather  dated  study  carried  out  by  the  UK  Ministry  of  Agriculture  (the  precursor  to  the  FSA)  and  the
National  Radiological  Protection  Board  (NRPB)  in  1984-85  found  that  caesium-137  body  contents
of 16 adult fish and shellfish consumers near Sellafield were only about one third of predicted values [Hunt
et al, 1989]. However, measurements of plutonium in autopsy tissues taken at the same time showed higher
concentrations in Cumbria [Popplewell et al, 1985].

5.4.4. Environmental Concentrations

5.4.4.1.  Changes between 1989-1999

The  latest  RIFE-5 [FSA,  2000]  report  of  the  UK  Food  Standards  Agency  includes  tables  that  chart
concentrations 
the  main
radionuclides (carbon-14,  technetium-99,  caesium-137,  plutonium-239  and  plutonium-240,  americium-241)
are measured in winkles, lobsters and cod. These results are presented in Annex 8.

from  Sellafield  between  1989-99.  Concentrations  of 

seafoods 

in 

It  may  be  seen  from  these  figures  that  caesium-137  and  transuranic  concentrations  in  seafoods  have  been
generally  declining  over  the  past  10  years,  reflecting  the  continuing  decline  in  caesium  and  alpha  emitters

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from Sellafield in the same period. The same picture of concentrations in seafood following carbon-14 and
technetium-99 discharges is also apparent.

5.4.4.2.  Detailed Concentrations in Fish, Shellfish, Sediments and Aquatic Plants

1999  environmental  measurements  of  key  nuclides  in  fish,  shellfish,  sediments  and  aquatic  plants  close  to
Sellafield are set out in Annex 9a. The same measurements have been made in biota at greater distances to
indicate the distribution of radioactive pollution from Sellafield. The data in these tables are obtained from
the latest UK RIFE-5 report  [FSA,  2000].  In  these  tables,  a  number  of  high  concentrations  were  recorded,
some exceeding European Community Food Intervention Levels (CFILs). These high levels give some cause
for concern and they have been marked in red for ease of reference.

CFILs were introduced by Council Regulations (Euratom Nos 3954/87, 944/89 and 2218/89) following the
Chernobyl  accident  to  restrict  the  import  of  contaminated  foodstuffs  to  Europe.  These  limits  in  force  at
present are set out in Table 2.

Table 2 Community Food Intervention Levels (Bq/kg)

Isotopes of strontium (notably 90Sr)
Isotopes of iodine (notably 131I)
Alpha-emitting isotopes of plutonium and
transplutonium elements (notably 239Pu, 241Am)
All other nuclides of half-life greater
than 10 days (notably 134Cs, 137Cs) (1)

Baby Foods

Dairy Produce

Other Foods

75

150

1

400

125

500

20

1,000

750

2,000

80

1,250

(1) The following radionuclides are not included in this group: tritium, carbon-14, and potassium-40.

Source: Council Regulations, Euratom Nos 3954/87, 944/89 and 2218/89

These  environmental  concentrations  result  in  small  but  measurable  radiation  doses  to  local  people (see
Tables in Annex 9a) discussed below. RIFE-5 report states that the dose to the Sellafield Critical Group from
current  discharges  was 0.21 mSv,  c.f. the  UK  dose  constraint  of  0.3 mSv.  The  UK  NRPB  continues  to
conclude that radiological hazards from consuming marine foodstuffs at these levels are acceptable.

5.4.5. Technetium Concentrations

5.4.5.1.  Technetium-99 Concentrations in Marine Samples

As a result of elevated technetium discharges in the mid 1990s, technetium concentrations in marine biota in
the Irish Sea near Sellafield increased. After 1994, technetium-99 concentrations in crustacea – particularly
in lobster –, rose reaching a peak of about 16,000 Bq/kg in 1997. This level is 13 times the European Council
Food  Intervention  Level (CFIL)  for  technetium-type  nuclides (1,250 Bq/kg)  in  post-accident  situations.
Concentrations  in  local  lobster  have  subsequently  declined,  reflecting  a  reduction  in  technetium-99
discharges:  the  highest  measurement  in  1999  was 4,700  Bq/kg.  Figure 7  shows  the  annual  trend  of
technetium concentrations in lobster.

Some technetium-99 concentrations above CFIL limits have also been found in molluscs (winkles,  mussels,
limpets  and  whelks)  in  the  vicinity  of  Sellafield.  In 1995,  technetium-99  concentrations  in  local  winkles
reached 1,600 Bq/kg [Environment Agency, 2000]. However, generally speaking, technetium concentrations
in local molluscs are a factor of 10 lower than in lobsters, and a factor of 1,000 lower in cod. The reasons for
these widely divergent concentration factors in marine biota are presently not known.

1996-1997  surveys  in  Norwegian  coastal  waters  showed  technetium-99  concentrations  in  seawater  had
increased  tenfold  compared  with 1991  concentrations.  This  matched  the  scale  of  increase  observed  in  the
Irish  Sea  near  Sellafield.  The  travel  time  from  Sellafield  to  Norway  for  the  initial (1994)  pulse  of
technetium-99  contamination  was  estimated  at  about  2.5 years.  Recent  environmental  surveys  along  the
Norwegian  coast  reportedly  indicate  a  six  fold  increase  in  technetium-99  concentrations  in  seaweed  since
1996 – i.e. from 100 to 600 Bq/kg dry weight.

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These technetium concentrations result in elevated collective doses to critical groups near Sellafield, and in
high collective doses not only to local and UK populations, but also to European and global populations.

Figure 7 Technetium-99 Concentrations in Lobster, in Bq/kg wet weight, 1986 to 1998

18000

15000

12000

9000

6000

3000

0

1986

1987

1988

1989

1990

1991

1992

1993 1994

1995

1996 1997

1998

Source: Annual MAFF and RIFE Reports

5.4.5.2.  Uptake of Technetium-99 by Marine Plants and Animals
In order to estimate the concentrations of technetium-99 in elements of the marine environment for a given
level of discharge, computer models are necessary. These models consist essentially of two main parts:

(1) a model to predict the dispersion of technetium-99 in seawater currents and

(2) a model to predict the uptake of technetium-99 from seawater into marine plants and animals. Both

modelling stages have associated uncertainties.

A  Working  Group  set  up  by  the  Commission  of  the  European  Communities  used  the MARIN1  suite  of
computer  models  to  estimate  the  dispersion  of  radionuclides  in  northern  European  waters  and  their
consequent radiological impact. In 1990 they reported that:
“As  a  tracer  radionuclide,  99Tc  suffers  somewhat  from  the  limited  availability  of  monitoring  data.  (...)
although MARIN1 adequately predicts water concentrations in seas around the British Isles, describing  99Tc
dispersion  to  within  factors  of  a  few  of  measured  concentrations,  it  tends  to  underestimate  at  greater
distances from the reprocessing plants over the same period. This may be due, in part, to the accuracy of
values used in the model for exchange rates in these waters. Any deficiencies in the modelling of  99Tc with
regard to transfer coefficients are likely to be compounded by uncertainties in the choice of concentration
factor used....in addition to the above uncertainties in the modelling of  99Tc dispersion and uptake, it should
be  noted  that  there  is  also  uncertainty  about  discharges  of  technetium  from  Sellafield  prior  to
1978.” [MARINA Project, 1990]

The  concentration  factor  referred  to  above  is  the  ratio  of  technetium-99  activity  in  the  tissue  of  a  plant  or
animal  to  the  activity  in  seawater.  Only  limited  data  are  available  on  technetium-99  concentration  factors;
there are large and real inter-species differences [Dehut et al,1990].

Both  aerobic  and  anaerobic  marine  bacteria  from  coastal  sediment  are  capable  of  concentrating
technetium [Vandecasteele et al, 1989]. This may result in the transfer of technetium-99 to higher levels in
the food chain. Concentration factors are greater than 1,000 for some biota such as macrophytic brown algae,
worms and lobsters [Masson et al, 1989]. Concentration factors for some seaweeds are particularly high – for
example, that for Fucus vesiculosus is around 100,000 [Dahlgaard et al, 1997].

A recent study of technetium-99  activity  in  Cumbrian  seafood  found  concentration  factors  of  between 380
and 1,200 in lobster muscle tissue (the part most commonly consumed by man), 7,700 in the hepatopancreas

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and 65,000 in the green gland. In Nephrops (the Norwegian lobster) the concentration factors are 1,700 for
claws  and 970  for  abdomen  muscle.  The  tail  muscle (the  part  of  Nephrops  most  commonly  consumed  by
man) had a higher activity than the average level in lobster, although the authors of the study do not actually
report the activity.

Several studies have estimated concentration factors using laboratory experiments, but concentration factors
in the marine environment have been found to be one to two orders of magnitude higher than in laboratory
experiments [Masson et al, 1989]. For example, Busby et al [1997] reported concentration factors in winkles
and  mussels  “much  greater”  than  any  reported  from  laboratory  investigations (>100X  in  some  cases).
McCartney  &  Rajendran [1997]  in  a  study  of  technetium-99  activities  in  seaweeds,  muscles  and  winkles
confirmed that the uptake (of technetium-99) by marine organisms in the field “far” exceeded that expected
from laboratory studies. They concluded that, given the radiological importance of this nuclide, the provision
of more accurate information on its environmental behaviour was required.

It should be noted that ingestion of seafood containing technetium-99 may not be the only pathway by which
humans incur radiation doses. In some areas, seaweed is used as agricultural fertiliser. A report published by
Atomic  Energy  Authority  Environment  and  Energy  at  the  Harwell  Laboratory [Nicholson  et  al,  1992]
estimates that, if seaweed were used in this way, individual doses from this pathway alone could be around
260 µSv per year (assuming a discharge rate of 200 TBq per year).

Our  present  understanding  of  the  behaviour  of  technetium-99  was  summarised  by  Zeevaert et
al [1989].“Despite the substantial amount of quantitative information about the transfer of technetium in the
biosphere that has recently become available, large uncertainties in this field persist.”  Twenty years ago in a
key study, Ng [1982] warned that long-term extrapolations based on short-term experiments were risky: this
warning remains relevant. This remains the case in 2001.

A  recent  study  carried  out  on  behalf  of  the  German  Office  for  Radioprotection [Beninschke,  2000],  using
German  statutory  dose  assessment  assumptions,  calculated  the  dose  impact  of  seaweed  use  as  fertiliser.
Annual induced effective doses from consumption of contaminated foodstuffs were 5.88 mSv for adults and
5.82 mSv  for  children.  That  is  more  than  5 times  the  annual  limit  imposed  by  the  European
legislation (1 mSv  per year)  and  about  20 times 
in  UK  and
Germany (0.3 mSv  per  year).  Most  of  the  calculated  dose  was  received  via  the  seaweed  fertiliser/animal
feed/meat  consumption  pathway.  The  authors  used  the  consumption  habits,  transfer  factors  and  other
assumptions prescribed by German legislation. European legislation does not prescribe specific assumptions
in  dose  assessment  models.  The  European  Commission  has  stated  that “the  guidance  currently  being
produced on realistic dose assessments will comment on this issue.”  18

the  annual  dose  constraint  used 

This raises the question of the differences between the values used for consumption habits and life patterns in
models  used  by  national  authorities  to  calculate  doses  to  individuals  near  reprocessing  plants and  other
nuclear  facilities.  The  European  Commission  has  stated  that  it  is “working  to  prepare  guidelines  on  the
harmonisation of realistic assessment of doses. Article  45 of the new Basic Safety Standards Directive indeed
states that Member States competent Authorities shall ensure that dose estimates from practices subject to
prior  authorisation  shall  be  made  as  realistic  as  possible  for  the  population  as  a  whole  and  for  reference
groups.”19  However  it  is  noted  that  Article  45  concerns  population  (i.e.  collective)  doses  rather  than
individual doses.

The  German  Federal  Office  for  Radiation  Protection  recently  stated: “On  the  question  what  is  ‘realistic’,
there is no consensus visible on the short term on the  EU level. A corresponding examination in national and
international framework is considered urgently necessary.” 20

5.4.6. Conclusions on Concentrations and Doses

National  radiological  authorities  state  that  radionuclide  concentrations  in  local  contaminated  materials
continue  to  result  in  doses  to  critical  groups  that  fall  within  agreed  safety  limits.  These  conclusions  are
reached  after  dose  estimates  have  been  arrived  at  through  the  use  of  computer  models  using  many
assumptions and estimated parameters. Although these dose estimates are best estimates arrived at using the

18 Stephen Kaiser, Commission of the European Communities, e-mail to Mycle Schneider dated 12 June 2001.
19 ibidem
20  See: http://www.bfs.de

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best endeavours of regulatory teams in both countries, nevertheless large uncertainties remain. For example,
the NRPB [Smith et al , 1998] has concluded that uncertainties in dose estimates via the food chain may be
very  large:  differences  between  5th  and  95th  percentile  values,  for  example,  often  exceeded  three  orders
of magnitude.

These uncertainties are discussed further in Annex 10.

In addition, the effects of historical discharges are not considered when comparing radiation doses with the
dose constraint. This is an important factor as these doses from past discharges at Sellafield are considerably
greater (probably by a factor of 3) than doses from current discharges.

Also as discussed above, current concentrations of radionuclides in the marine environment near Sellafield
could  already  lead  to  doses  that  exceed  the  UK  and  German  constraint  by  a  factor  of 20  and  the  current
European  limit  by  a  factor  of 5  for  a  “reference  person” [Beninschke,  2000],  with  food  consumption
patterns as defined in the German legislation. The conclusion would appear to be that the Sellafield facility
would not be suitable to receive a license to operate in Germany at current levels of discharge.

In addition, German dose limits for organs (also used in the US but not in the rest of the EU) would also be
exceeded by the ingestion of relatively small quantities of seafood from Sellafield. For example:

• consumption of 3.41 kg of winkles from St. Bees in the vicinity of Sellafield is sufficient to reach the

adult limit for bone surface [Beninschke, 2000, see Table 5.1-11];

• consumption of 11.6 kg of food grown on soil fertilised with contaminated seaweed from the Irish Sea

is enough to reach the dose limit for the lower colon of a small child [id., Table 5.1-16];

• consumption  of 4.44 kg  of  meat  of  beef  fed  with  seaweed  from  the  Irish  sea  is  enough  to  reach  the
dose limit for the lower colon of an adult [id., Table 5.1-19]; the consumption of 0.6 kg is enough to
reach the limit for small children [id., Table 5.1-20].

5.5.  THE HAZARD POSED BY LIQUID HIGH LEVEL WASTE AT SELLAFIELD

Reprocessing  at  Sellafield  has  generated  large  inventories  of  radioactive  waste,  in  various  physical  and
chemical  forms.21  A  substantial  part  of  this  waste  is  in  readily-mobilisable  forms,  including  liquids  and
sludges.  The  potential  exists  for  unplanned  releases  of  radioactive  material  from  the  Sellafield  waste
inventories. This potential is especially great where the waste is held in a readily-mobilisable form.
The largest hazard of this kind is posed by the storage of high-level radioactive waste (HLW) as a liquid.22
The  loss  of  cooling  to  a  High  Active  Liquor  feed  vessel  was  also  considered  as  a  reference  accident  by
the UK authorities in the case of Sellafield in their General Data submission to the European Commission.
Reprocessing at the B205 and THORP facilities produces comparatively dilute liquid HLW, and this liquid is
transferred  through  shielded  overhead  pipelines  to  the B215  facility.  There,  the  concentration  of  the  liquid
HLW  is  increased  in  evaporators,  and  the  concentrated  liquid  is  stored  in 21  above-ground  steel  tanks.
The liquid  HLW  is  self-heating  due  to  the  very  high  levels  of  radioactive  decay.  This  method  of  storing
HLW  has  been  used  since  reprocessing  began  at  Sellafield  in  the 1950s,  and  was  adopted  because  it  is
comparatively inexpensive.

The  concentrated  liquid  HLW  in  the  tanks  is  hot  and  acidic,  and  requires  constant  cooling,  agitation  and
supervision.  If  cooling  were  to  be  interrupted,  the  liquid  could  begin  boiling  after  about  half  a  day  and
evaporate completely over a subsequent period of about three days, leaving a solid residue that would oxidise
and melt.23 Volatile radionuclides – such as caesium-137 – would be evaporated from the solid residue and
could pass through the ventilation system to the atmosphere.

21 These and other radioactive waste inventories in the UK are catalogued periodically by the UK government. [See, for

example, DETR, 1999]

22 Liquid HLW poses the largest hazard of an unplanned release at Sellafield because of: (i) its large inventory of long-

lived radioactivity; and (ii) its readily-mobilisable form.

23  The timing of tank boiling and dry-out would vary with the characteristics of the liquid HLW. The times mentioned
here are BNFL-calculated numbers for liquid HLW from PWR fuel aged 5 years after discharge from a reactor. [See
Thompson, 1998, Appendix C]

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Caesium-137 is an important indicator of the hazard potential of the liquid HLW at Sellafield. This fission
product  is  volatile,  and  is  therefore  released  to  the  environment  in  comparatively  large  quantities  during
accidents at nuclear facilities. Caesium-137 has a half-life of 30 years, adheres to surfaces when deposited
from  an  atmospheric  plume,  and  emits  intense  gamma  radiation.  The 1986  Chernobyl  reactor  accident
released  about  85,000 TBq (27 kg)  of  caesium-137 to  the  atmosphere,  accounting  for  most  of  the  offsite
radiation  exposure  from  the  accident.  For  comparison,  the  1,300 cubic  metres  of  liquid HLW,  currently
stored at Sellafield [NII, 2000c], contain about 7 million TBq (2,100 kg) of caesium-137 [Thompson, 1998,
Appendix D].

Analyses have shown that influences such as human error, equipment failure, natural forces (e.g. earthquake)
or  acts  of  malice  could  initiate  a  sequence  of  events  that  releases  a  substantial  fraction  of  the  radioactive
material in the liquid HLW tanks to the environment, either as an atmospheric plume or as a liquid release to
the Irish Sea. Events that could breach a tank and its surrounding concrete cell, leading directly to a liquid or
atmospheric release, include an explosion, aircraft crash, earthquake or act of sabotage. A larger atmospheric
release could arise indirectly from such events. The initial event – an explosion, for example – could disable
tank cooling systems and radioactively contaminate the vicinity of the affected tanks to a level that would
preclude the restoration of cooling. Then, the affected tanks would dry out, and volatile radionuclides would
evaporate from the solid residue. This release could contaminate the vicinity of the tanks to a higher level,
precluding the ongoing provision of cooling to unaffected tanks. Thus, the initial event could ultimately lead
to an atmospheric release from every tank that contains liquid [Thompson, 1998].

In 1957,  an  atmospheric  release  occurred  from  a  liquid HLW  tank  at  a  military  reprocessing  plant  near
Kyshtym,  USSR,  when  the  tank  dried  out  and  exploded.  Reprocessing  plants  are  prone  to  chemical
explosions, as is shown by incidents in Japan, the United States and Russia/USSR. A particular concern at
Sellafield is the potential for an explosion in one of the evaporators at the B215 facility, due to inadvertent
forwarding  of  organic  chemicals  from  the B205  or  THORP  reprocessing  plants.  An  explosion  in  an
evaporator  could  ultimately  lead  to  an  atmospheric  release  from  every  liquid  HLW  tank,  as  explained
above [Thompson, 1998, Appendix G].

tanks  could 

The  long-term  consequences  of  a  release  from  the  Sellafield  HLW  tanks  could  be  much  greater  than  the
consequences of the Chernobyl accident, due to the large amounts of caesium-137 and other radioisotopes in
the Sellafield tanks. According to the US Department of Energy (DOE), the Chernobyl release caused a 50–
year  Northern  Hemisphere  population  dose  commitment  of  1.2 million person-Sv,  primarily  from
the 90,000 TBq  of  caesium-137  in  the  release24 [DOE,  1987].  An  atmospheric  release  from  the Sellafield
HLW 
inventory.  Assuming  a 50 percent
release (3.5 million TBq of caesium-137), extrapolation of the DOE’s Chernobyl estimate would yield a 50-
year  Northern  Hemisphere  population  dose  commitment  of  47 million person  Sv  from  a  Sellafield  release.
This extrapolation should not be regarded as more than a crude estimate of the consequences of a possible
Sellafield  release,  because  of  the  different  characteristics  of  the  Chernobyl  accident  and  the  postulated
Sellafield release, but the result illustrates the potential order of magnitude of the consequences. In 1994, the
COSYMA computer model assessed the consequences of an atmospheric release from the Sellafield HLW
tanks, to range up to tens of millions of person-Sv [Taylor, 1994].

include  a  substantial 

fraction  of 

their 

In 1976,  about  600 cubic  metres  of  liquid  HLW  was  stored  at  Sellafield,  and  it  was  predicted  that
about 6,000  cubic  metres  would  be  stored  in 2000 [Flowers  et  al,  1976,  page 64].  The  present  volume –
about  1,300 cubic  metres –  is  lower  because  the  scale  of  reprocessing  at  Sellafield  has  been  lower  than
predicted,  and  because  vitrification  of  liquid  HLW  has  been  proceeding  since 1991.  The  liquid  HLW  is
transferred from the B215 tanks to an adjacent vitrification plant, where it is incorporated into glass that is
cast into steel containers. The containers are stored in a vault where they are cooled by the natural circulation
of air. The UK Nuclear Installations Inspectorate (NII) has described the cooling arrangement in this vault as
follows: “This cooling does not depend on the continued availability of installed services such as electricity
and water, and is sometimes referred to as passively safe. This may be compared with the situation in  B215
where  active  systems,  requiring  operator  control,  are  needed  to  keep  the  HAL  [liquid  HLW]  in  a  safe
state.” [NII, 2000c, page 4] Production rates at the vitrification plant have been insufficient to eliminate the
backlog of liquid HLW stored in the B215 tanks. Thus, BNFL has predicted that the volume of liquid HLW
will rise by about 10 percent during the period 2000-2004, after which the volume will begin to fall.

24 [NEA, 1995] gives a figure of 85,000 TBq released of a total of 280,000 TBq in the core.

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BNFL and the NII have been slow to investigate or take action about the hazard posed by the liquid HLW
tanks.  This  hazard  was  debated  during  the  Windscale  Inquiry  of 1977,  but  no  action  was  taken.  Public
concern about the hazard arose during the 1990s, initially in the context of the commissioning of THORP,
and has continued at a high level. In response to ongoing public concern the NII eventually required BNFL
to  perform  safety  analyses  and  to  undertake  repairs  and  modifications  to  the B215  facility.  However,
neither BNFL nor NII has ever published any of its safety analyses for B215.

In  January 2001,  the  NII  issued  BNFL  with  a  Specification (a  legal  order),  which  limits  the  volume  of
liquid HLW to 1,575 cubic meters, lowers this limit by 35 cubic meters per year  until 2012,  and  requires  a
subsequent reduction to 200 cubic  meters  in 2015;  thereafter,  BNFL  would  be  permitted  to  store 200 cubic
meters  of  liquid HLW  as  a  buffer  stock [NII,  2000c].  This  Specification  is  designed  to  accommodate
BNFL’s business plan, and to minimise the cost and inconvenience to BNFL of reducing the stock of liquid
HLW.

Although  the  liquid HLW  tanks  at  B215  pose  the  largest  hazard  of  an  unplanned  release  at  Sellafield,  this
hazard is not unique. Other facilities at Sellafield contain significant amounts of radioactive material, often in
a readily-mobilisable form. Transport of radioactive material to and from Sellafield also creates a potential
for  unplanned  releases.  Analytic  techniques –  known  as  probabilistic  risk  assessment (PRA) –  have  been
developed,  whereby  the  probability  and  consequences  of  unplanned  releases  can  be  investigated.25  PRA
findings, properly applied, can provide a basis for public debate about the hazard posed by a nuclear facility,
and  can  guide  regulatory  action  to  address  that  hazard.26  No  PRA  study  has  ever  been  published  for  any
facility  at  Sellafield  or  any  transport  operation  associated  with  Sellafield,  although  BNFL  officials  have
conceded that the preparation and publication of PRA studies would be required if the Sellafield site were
licensed in the United States. There is evidence that the quality of BNFL’s unpublished safety analyses does
not meet contemporary PRA standards [Thompson, 1998; 2000b].

5.6.  HEALTH EFFECTS AT SELLAFIELD

The  attribution  of  possible  health  effects  to  contamination  from  radioactive  discharges  at  Sellafield  has
proved difficult and contentious. Most controversy centres on the issue of childhood leukaemia and cancer.

5.6.1. Childhood Leukemia at Seascale

In  1983,  the  UK Yorkshire  Television  company  produced  a  film  which  reported  a  higher  incidence  of
childhood  leukaemia  in  the  village  of  Seascale,  near  Sellafield,  than  was  expected  from  national  incidence
rates.  The  Prime  Minister  at  that  time,  Margaret  Thatcher,  set  up  a  Committee  of  Enquiry  chaired  by  Sir
Douglas Black. The Black Committee asked the National Radiological Protection Board (NRPB) to estimate
the  probable  radiation  doses  to  children  in  Seascale  from  the  discharges.  These  calculations  showed  that,
using  conventional  dosimetry  and  risk  factors,  the  radiation  doses  likely  to  have  been  received  from  the
discharges were too low (by a factor of >200) to result in the observed incidence of leukaemia [Stather et al,
1984 and Addendum]. Subsequently, a permanent Committee was set up to study aspects of radiation in the
environment (Committee On Medical Aspects of Radiation in the Environment – COMARE).

More than fifteen years of research has established that the excess incidence of childhood leukaemia around
Sellafield is statistically significant, i.e. highly unlikely to be a chance finding. Craft et al [1993] examined
the incidence of cancer in young people under 25 years of age in 1,272 census wards in the north of England
in  the  years 1968-85  and  found  that,  of  the  six electoral  wards  with  the  most  extreme  excesses  of
lymphoblastic  leukaemia  in  young  people  under 25,  two  were  close  to  Sellafield –  Seascale  3 km  to  the
south (4 cases, expected 0.3) and North Egremont 7 km to the north (4 cases, expected 0.6).

A further study of the period 1963-90 by Draper et al [1993] showed that the incidence of malignant disease
continued  to  be  higher  than  expected  in  Seascale.  COMARE  concluded  that  the  raised  incidence  of
leukaemia  and  non-Hodgkins  lymphoma  in  the  young  people  of  Seascale,  and  its  persistence  over  several
decades, were “probably unique” in the UK [COMARE, 1994]. As noted above, doses from environmental
radioactivity were not thought high enough to explain the raised incidence of leukaemia.

25 The state of the art for nuclear reactor PRAs is illustrated by [NRC, 1990].
26 For a review of the strengths and limitations of PRA, see [Hirsch et al, 1989].

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5.6.2. Paternal Pre-Conception Irradiation

In 1990,  an  alternative  explanation  was  offered  by  Martin  Gardner  and  colleagues [Gardner,  1990]  who
showed an association between pre-conception radiation dose to a father and leukaemia risk in his children.
Gardner  estimated  that  a  dose  of  100 mSv  or  more  to  a  father  was  associated  with  a  six-fold  increase  of
leukaemia risk in children born subsequently. The implication was that ionising radiation caused a mutation
in the father’s sperm, which can be expressed as leukaemia in his children.

There  remain  several  problems  with  this  hypothesis [see  Baverstock,  1993].  It  is  not  consistent  with  the
observed  incidence  of  leukaemia  in  the  survivors  of  Hiroshima  and  Nagasaki,  nor  is  it  supported  by  other
studies of childhood leukaemia in the children of nuclear workers. More important, it would imply a rate of
production of a specific mutation that was many times greater than the sum of all dominant mutation rates
known to occur in humans [Doll et al, 1990]. The plausibility or otherwise of the Gardner hypothesis formed
the central theme of two cases heard in the High Court of Justice, London, over the period October 1992 to
June 1993.  The  plaintiffs  in  these  cases  claimed  that  the  cause  of  a  fatal  leukaemia  and  a  non-fatal  non-
Hodgkin’s lymphoma was paternal preconception irradiation (PPI) at Sellafield.

While  the  court  cases  were  in  progress,  a  study  by  Kinlen [1993]  demonstrated  that,  contrary  to  earlier
observations, the leukaemia excess included cases who lived (but had not been born) in Seascale. According
to Kinlen, of the six cases born in Seascale five had high Parental Preconception Irradiation (PPI >90 mSv).
Of  five  cases  born  elsewhere,  only  one  was  associated  with  high PPI.  Kinlen  concluded  that  the  Gardner
hypothesis could not account for all the cases in the Seascale cluster. Looking at the problem in another way,
if  the  Seascale  excess were  entirely  due  to  PPI,  many  more  cases  should  have  occurred  in  West  Cumbria
outside Seascale. As noted above, there is a significant cluster of leukaemia cases in Egremont North; but
none  of  the  fathers  of  these  four  cases  had  a  recorded  dose  of PPI [Wakeford  and  Tawn,  1994].  These
findings, together with the problems mentioned above, led the judge to find (in October 1993) in favour of
the defendants (BNFL). However, the cause (or causes) of the increased incidence of leukaemia at Seascale
remain(s) unclear.

5.6.3. Population Mixing

Kinlen et  al [1991]  have  put  forward  a  hypothesis  that  population  mixing  results  in  the  spread  of  viral
infections and that childhood leukaemia is a rare consequence of such an infection. This hypothesis appears
to be supported by data on the incidence of leukaemia in England, Wales, and Scotland. However, Draper et
al [1993] have pointed out that the high incidence in Seascale has occurred over an extended period, and was
unlikely to be explained by Kinlen’s hypothesis, i.e. because population mixing stopped many decades ago.
They also pointed out that the risk of childhood acute lymphoblastic leukaemia is doubled in isolated towns
and villages, but the excess in Seascale is too large to be accounted for in these ways.

The  possibility  remains  that  ionising  radiation  is  at  least  one  of  a  number  of  causative  factors.  COMARE
has stated:

“The cause of the excess rate of cancer in the 0-24 year old age range in the village of Seascale is currently
unknown.  There  are  a  number  of  possible  causes,  which  may  have  led  to  this  excess.  There  is  insufficient
evidence  to  point  to  any  one  particular  explanation  and  a  combination  of  factors  may  be  involved.  As
exposure to radiation is one of these factors, the possibility cannot be excluded that unidentified pathways or
mechanisms involving environmental radiation are implicated.”  [Bridges,1993]

In  conclusion,  the  cause  or  causes  of  the  observed  increases  in  childhood  leukaemia  near  reprocessing
facilities are not known, nor is it known whether a combination of factors is involved. Many observers admit
radiation  is  likely  to  be  involved  to  some  degree,  but  in  the  absence  of  working  hypotheses,  the  question
remains open. Further consideration of possible explanations is contained in Annex 11.

5.6.4. Other Possible Health Effects at Sellafield

Investigation  of  possible  health  effects  due  to  Sellafield  discharges  has  been  dominated  by  the  childhood
leukaemia issue outlined above. However, some other areas of concern have also arisen.

Stiller [1993] has reported an increased  incidence  of  retinoblastoma  in  children  born  to  mothers  who  have
lived in Seascale. In 1999, Parker et al [1999] reported a statistically significant increasing trend of stillbirth
risk  with PPI  dose  among  the  offspring  of  workers  at  the  Sellafield  nuclear  reprocessing  plant  over  the

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period 1950-89. However Little [1999] has countered that these findings should be interpreted with caution
as they are inconsistent with observations in the Japanese Atomic Bomb survivors. This matter is discussed
further in Annex 10.

5.6.5. Conclusions on Health Effects

A statistically significant excess of childhood cancer continues in the area around Sellafield, notably in the
village  of  Seascale.  COMARE  has  examined  current  leading  hypotheses  and  pathways  by  which  the
observed excess could have come about and have been unable to find a convincing explanation. Nevertheless
COMARE  has  recommended  support  for  further  research  on  a  number  of  radiobiological  aspects.  This
indicates that radiation as a possible cause of the cancers has not been discounted by COMARE. The authors
have  verified  this  in  discussion  with  COMARE  members  in  the  UK.  The  assertion  of  the  European
Commission  to  the  contrary  among  its  replies [see  European  Parliament,  undated]  to  the  Committee  on
Petitions is incorrect.

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6. CASE STUDY LA HAGUE

6.1.  NATIONAL REGULATORY FRAMEWORK

Hierarchically,  the  French  regulatory  framework  governing  the  discharges  of  radioactive  effluents  in  the
nuclear sector can be divided into two levels :

- The general technical regulation

The monitoring of effluents discharged by Basic Nuclear facilities (Installations Nucléaires de Base or INB)
is  governed  by  the  general  technical  regulations  taken  at  ministerial  level  in  application  of  the  Decree  n°
63-1228 of 11 december 1963 concerning nuclear facilities and the Decree 95-540 of 4 may 1995 concerning
the discharges of liquid and gaseous effluents and water use of basic nuclear facilities.

- Fundamental safety standards

These are mainly recommendations drawn up by the Safety authority (Direction de la sûreté des installations
nucléaire, DSIN also called Autorité de sûreté nucléaire, ASN) or codes established by the French nuclear
industry. The DSIN’s  recommendations  are  in  no  way  legally  binding  regulations.  The  nuclear  industry  is
not compelled to abide by them if it proves that alternative means were implemented to achieve the targets.

6.1.1. Authorisations of discharges

French regulation’s official acknowledgement of radioactive discharges from nuclear facilities dates back to
the  early  1960s.  At  the  time,  measures  were  adopted  to  regulate  discharges  in  application  of  general  laws
such as the law of 2 August 1961 on atmospheric pollution and odours.27

As  far  as  La  Hague’s  reprocessing  activities  are  concerned,  the  first  document  to  refer  to  radioactive
effluents,  is  the  Decree  of  17  January  1974,  of  which  Section E,  Al. 3,  explains  that “liquid  and  gaseous
effluents  are  released  in  the  ambient  environment”  in  compliance  with  the  regulation  in  force.
The CEA (Commissariat  à  l’énergie  atomique)  had  in  fact  applied  for  an  authorisation  to  modify  its
treatment  facilities,  involving  the  presentation  of  the  whole  activities  including  discharges.  The  CEA’s
application  for  a  license  to  discharge,  dated  19 May 1972,  introduced  annual  limits  for  effluents  that  were
based on surveys that were neither referred to nor included in the document, and which were to become the
basis for future authorisations of discharges.

It is only in 1980, 14 years after the facilities had started operating, that regulations specifying general annual
maximum limits were issued to restrict COGEMA’s radioactive discharges.

In  fact,  the  departmental  order  of  22 October 1980  authorising  COGEMA  to  release  liquid  and  gaseous
radioactive effluents fixed the annual limits for discharges. The limits were then confirmed by the prefectoral
orders of 27 February 1984 and 28 March 1984 respectively for gaseous effluents, with:

“480,000 TBq for gases other than tritium;

2,200 TBq for tritium;
110 GBq for halogenes;
74 GBq for aerosols.” (Article 1)28

and liquid effluents,

“37 000 TBq for tritium;

1700 TBq for radio-elements other than tritium;

27 “Loi n° 61-842 du 2 août 1961 relative à la lutte contre les pollutions atmosphériques et les odeurs.”
28 “Autorisation de rejets d'effluents radioactifs gazeux par les usines dénommées UP 2-800 et UP 3-A et par la station

de  traitement  des  effluents  liquides  et  des  déchets  solides,  dénommes  STE  3  sur  le  site  nucléaire  de  La
Hague (Manche), 27 février 1984.”

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220 TBq for the totality of strontium -90 and caesium-137;
1.7 TBq for alpha radioelements.” (Article 1)29

In addition to the release of radioactive effluents, rainwater discharges from La Hague were also subjected in
the 1980s to an authorisation procedure.

COGEMA was for instance authorised in the ministerial orders of 22 November 1988 to discharge rainwater
into Saint-Hélène and Moulinets streams, provided that radioactivity tests are undertaken on regular basis30.

There are three main disadvantages in the French authorisation system:

- firstly, it regulates annual limitations of discharges and not concentrations. The amount of effluents
released into the sea may vary considerably from day to day, reaching sometimes significant peaks of
discharges;

- secondly, the classification of the effluents given in the authorisations is far from being detailed (for
example, they lack limits for each radionuclide) and the way they were categorised is questionable as
far as some radionuclides are concerned.

- thirdly, significant levels of discharges are granted without public access to relevant underlying data
that would allow for the justification of these figures.

6.1.2. Licensing Procedures

There are two different legal procedures COGEMA has to go through today, prior to any modification on its
discharges into the environment:

•  Authorisation procedure

Applications  for  authorisations  of  discharges  are  addressed  to  the  Ministers  in  charge  of  Industry  and  the
Environment. It is also submitted for opinion to the Ministers in charge of Health and Civil Security.

They  include  general  information  on  plans,  programs,  description  of  the  concerned  activities  and  their
predictable impact on the environment, the compensatory measures proposed and the monitoring operations
and further information that may be required by the concerned ministers.

The  applications  are  then  transmitted  to  the  Prefect  who  orders  a  public  inquiry  and  consults  with  the
concerned municipal councils and regional bodies.

The results of the public inquiry and the different meetings are handed over to the Ministers of Industry and
the Environment who take the decision to authorise the discharges.

The Ministers’  decision determines:

- the limits of discharges authorised for COGEMA,
- the operations of analysis, monitoring and control of these activities,
- the conditions in which the exploiting company gives account to the Ministers in charge of Health
and the Environment and to the Prefect, of the water monitoring and the impact of effluents on the
environment, and
- modes of information of the public

•  Notification procedure

Similarly, notifications are submitted to the Ministers in charge of Industry and the Environment.

In  the  case  of  discharges,  they  indicate  the  quantities  of  effluents  and  their  composition  as  well  as  the
conditions in which such activities are to be carried out. A document must provide the necessary information
on the impact of the operation on the environment, and proposed compensatory or corrective measures.The
Prefect and the municipality concerned by the discharges are sent a copy, which the public can consult, at the

29 Autorisation de rejets d'effluents radioactifs liquides par les usines dénommées UP 2-800 et UP 3-A et par la station

de  traitement  des  effluents  liquides  et  des  déchets  solides,  dénommes  STE3  sur  le  site  nucléaire  de  La
Hague (Manche), 28 mars 1984.

30 Arrêtés du 22 novembre 1988 autorisant la COGEMA à rejeter les eaux pluviales dans le ruisseau des Moulinets et

dans le ruisseau de Saint-Hélène.

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level  of  the  city  hall.  The  draft  decision  is  sent  to  the  company,  which  has  15  days  to  address  written
observations to the concerned ministers.
The  DSIN  has  recently  launched  a  procedure31  to  review  downwards  the  limitations  of  discharges  of
radioactive effluents from nuclear sites.

6.1.3. Supervision

The day-to-day monitoring and control of effluents are entrusted to the operator COGEMA itself, which is
also charged with monitoring the impact of its discharges on the environment. COGEMA is by law impelled
to  record  the  results  of  its  controls  and  transmit  them  to  State  control  authorities.  This  self-control  is,  in
principle, guaranteed by more-or-less independent State bodies, which by inspecting “unexpectedly” the La
Hague facilities and checking COGEMA’s records can “tell whether (the limitations) are departed from.” 32

Today, such inspections are provided for in Article 28 of the ministerial order of 26 November 1999 and are
entrusted to three State bodies. In addition to the monitoring of the impact of radioactive discharges on the
surrounding environment of La Hague, the State bodies, among which OPRI (Office de Protection contre les
Rayonnements Ionisants), are charged with operations of inspections of COGEMA’s monitoring laboratories
and controls on the facilities effluents.

According to the DRIRE (Direction Régionale de l’Industrie, de la Recherche et de l’Environnement), such
controls were hardly undertaken by any State authorities in the 1960s. It is only in the 1980s that the DRIRE,
as  regional  representative  of  the  national  safety  authorities,  organised  inspections  at  La  Hague  on  regular
basis.  Of 80  inspections  carried  out  in 1999,  “2 or 3”  inspections  concerned  the  discharges  of  effluents.
However,  the  fact  that  the  regulation  in  force  provides  for  annual  radioactivity  limitation  values  only,  the
State control bodies have limited means “to  ensure  that  such  yearly  values  are  complied  with,  unless  it  is
done through the control of the company’s (COGEMA) records.”

It is worth noting that until today, COGEMA has basically set its own “concentration”  limits of effluents,
which  the  inspectors  of  the  State  bodies  may  control.  Things  are  likely  to  change  in  the  future. “Draft
ministerial orders” are said to be under preparation, fixing regulatory “instantaneous concentrations.”

6.1.4. Radioprotection

The  Decree  n° 66-450  of  6 June 1966,  concerning  the  general  principles  of  protection  against  ionizing
radiation  was  amended  by  the  Decree  n° 2001-215  of  8 March 2001.  The  Decree  transposed  partially  the
Directive 96/29/Euratom of the Council of the European Union of 13 May 1996, laying down Basic Safety
Standards for the protection of the health of workers and the general public against the dangers arising from
ionizing radiation, nearly one year after the deadline for transposition into national legislation.

In  compliance  with  the  European  Directive,  Article 17  of  the  Decree  of 1966  was  modified  to  take  into
consideration the new annual maximum dose limit of 1 mSv for individuals (down from 5 mSv).

The  transposition  of  the  Directive  has  had  important  implications  on  French  radioprotection  legislation.
Not only  did  France  have  to  rewrite  part  of  its  health  and  work  regulation,  it  also  has  to  take  into
consideration  new  principles  introduced  by  the  Directive,  such  as  the  justification  principle.  This  principle
may be applied to “new” as well as to “existing classes or types of practice”  which “may be reviewed as to
justification whenever new and important evidence about their efficacy or consequences is acquired.”

Responsibility is left to “individual Member States to ensure compliance with the basic safety standards and
the  Commission  would  intervene  only  if  it  thought  that  Member  States  were  not  exercising  those
responsibilities.” 33 This and the ALARA (as low as reasonably achievable) principle, also provided for in

31 See: http://www.asn.gouv.fr/data/information/arretes.asp
32 Declarations by the DRIRE about its supervision of La Hague activities are based on private communications with:

- Mr. Seifried, DRIRE Basse-Normandie (Direction Régionale de l'Industrie, de la Recherche et de l'Environnement,
i.e. Regional Division of Industry, Research & Environment), 20 April 2001,
- and Mr. Benssassen, DRIRE Basse-Normandie, 23 April 2001.

33 Answer given by Mrs Bjerregaard on behalf on the Commission (18 November 1997, OJ C 158, 25/05/1998 (p. 77))
to  Question E-3278/97  by  Undine-Uta  Bloch  von  Blottnitz  (V)  to  the  Commission  (20 October  1997  OJ  C 158,
25/05/1998 (p. 76)).

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the  Directive,  will  in  all  likelihood  have  considerable  consequences  on  the  French  present  authorisation
system for radioprotection.

It  is  worth  noting  that  to  lighten  the  legislative  procedural  system,  the  French  Parliament  passed  a  law
on 3 January 2001  providing  for  the  transposition  of  a  number  of  European  Directives  through  simple
parliamentary  ordinances.  Interestingly  enough,  the  Directive  96/29/Euratom  was  discretely  transposed
through a governmental Decree in March 2001, either to avoid a public debate on the matter or to keep the
decision centralised and under the control of the executive power.

6.1.5. References to International Legislation

Except  for  radioprotection  and  the  transposition  of  European  directives  and  specific  multinational  treaties,
French  regulation  concerning  the  discharges  of  radioactive  effluents  hardly  or  ever  mentions  international
legislation, conventions or recommendations. Several international agreements today call for more stringent
national  regulations  aimed  at  reducing  if  not  eliminating  discharges  of  radioactive  effluents,  especially
releases into the sea.

Because  most  of  them  are  legally  non-binding,  the  French  Administration  has  had  a  rather  contemptuous
attitude towards the results of such milestone international conventions.

The London Dumping Convention recognises that “the capacity of the sea to assimilate wastes and render
them  harmless,  and  its  ability  to  regenerate  natural  resources,  is  not  unlimited”   and  that  Member  States
must  “promote  the  effective  control  of  all  sources  of  pollution  of  the  marine  environment”,   including
“radioactive pollutants.”

Within  the  framework  of  the  Convention  for  the  Protection  of  the  Marine  Environment  of  the  North-east
Atlantic, the OSPAR Commission called its Member States in 1998 to “work towards achieving substantial
reductions  or  elimination  of  discharges,  emissions  and  losses  of  radioactive  substances.”   The  OSPAR
Decision 2000/1, which entered into force on 16 January 2001, even calls for reviewing the “authorisations”
of discharges.

6.2.  OPERATION AT LA HAGUE

6.2.1. Reprocessing at La Hague

The first reprocessing plant at La Hague, the UP2-400 plant for gas graphite reactor fuel, was started in 1966
for civil and military purposes – the investment was covered for one half by the military and for the other
half  by  the  civil  budget  of  the  Atomic  Energy  Commission  CEA –  and  operated  until  1998,  with
about 9,350 tonnes  being  reprocessed.  In 1990,  UP-3  was  brought  into  operation,  and  in 1994,  UP2-800
as well. These two plants have reprocessed about 12,000 tonnes so far. Table 3 below shows the annual fuel
throughputs  at  the  three  reprocessing  plants  in  La  Hague  from 1966  to 2000.  The  cumulated  total  of  spent
fuel reprocessed at La Hague up to the end of 2000 was approximately 21,200 tonnes.

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Table 3 Reprocessing History at La Hague Plants by Fuel Category, 1966-2000 (in tonnes)

Year

1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000

UNGG

UP2 (400) (1)
LWR

MOX / FBR

UP2 (800)
LWR

UP3
LWR

52.8
97.6
188.7
227.8
136.0
164.5
250.4
212.5
634.5
441.4
218.2
351.3
371.5
264.6
253.1
250.0
226.1
117.0
185.3
109.3
75.8
68.2

14.6
18.0
38.2
79.9
104.9
101.3
153.5
221.3
255.1
351.4
332.6
424.9
345.7
430.3
331.1
311.1
219.9
353.8
317.3
0.0
12.4
0.0
32.0
0.0

Phenix 2.2
Phenix 1.5
Phenix 2.2

Phenix 2.0
Phenix 2.1

German MOX 4.7

EDF MOX 4.9

30.3
194.6
351.4
448.2
601.4
700.4
800.6
818.9
820.3
821.9
712.9
387.2

258.6
758.1
849.6
849.6
774.8
848.6
810.3

TOTAL
(1) This doesn’t include reprocessing of a small quantity of RNR fuel in AT1, which is part of UP2 of the INB n° 33,

4,896.5

4,449.4

5,150.0

6,688.2

19.6

between 1969 and 1979.

Source: Various documents and personal communications, COGEMA, 1997-2000

6.2.2. Waste Production of La Hague

As  shown  in  Tables 4  and 5,  the  reprocessing  operations  at  La  Hague  produce  significant  quantities  of
wastes.  Table 4  indicates  the  quantity  of  waste  that  would  be  produced  annually  from  the  reprocessing  of

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one year’s spent fuel output from a 1,300 MWe PWR (around 30 tonnes); Table 5 shows annual quantities of
conditioned and unconditioned reprocessing wastes s accumulating on the La Hague site. The year-to-year
evolution of those stocks over the past 8 years is summarised in Annex 12.

Table 4 Annual Wastes Arising from Spent Fuel Reprocessing at La Hague of a 1 000 MWe PWR (1)

Conditioned waste for storage

Process wastes

Beta, gamma emitters Alpha emitters

Activity (GBq/an)

Conditioning
materials

Volume
(m3/year)

Solution of fission products

Structural wastes (hulls and nozzles)

Sludge from liquid effluents treatment
Technological waste from zone 4 (3)
Technological waste from zones 3-2

555,106

74,105

37,104
< 37.103
37.103

(2) 2,775,103
2,775

2,590
< 37.103
Negligible

Glass

Cement

Bitumen

Cement

Cement

3

15

13

5 to 8

35 to 45

(1) One 1,000 MWe PWR discharges around 30 t of spent fuel annually.
(2) Of which 99.5% of transuranians (less than 0.5% of plutonium).
(3) Zones 4, 3 and 2 are corresponding to a decreasing potential risk of radioactive dissemination.

Source: COGEMA.

Table 5 Waste Inventory at La Hague, Quantities and Volumes (as of the end of 1999)

Waste inventory

As of
31.12.1999

Evolution
1998-1999

Volume (1)
As of
31.12.1999

Evolution
1998-1999

Cumulated amount of spent fuel reprocessed (tons)

15,097.2

+ 1,561.5

Conditioned wastes

Bituminised waste (drum)
Hulls and nozzles (drum) (2)
Cemented technological waste (drums)
Waste contaminated with alpha emitters (drum) (3)
Canisters of vitrified waste

Unconditioned wastes

Hulls, nozzles, and other ILW (tons)
Magnesium, graphite and metal (m3)
Sludge (m3)
Storage resin (tons)

Nympheas resins cartridges (tons)
Graphite resins (m3)
Low contaminated soil, sludge and metal (m3)

9,898

4,249

4,311

3,958

6,759

2,245.4

3,058.8

9,288.0

34.4

30.5

319.0

14,500.0

+ 93

+ 591

- 252

- 405

+ 468

- 8.8

- 8

+ 24

- 0,3

- 28.1

0

+ 80

2,355

7,435

4,900

495

1,325

2,600

3,058.8

9,288

???

???

319

14,500

+ 22

+ 1,034

+ 285

- 50

+ 91.7

- 10

- 8

+ 24

???

???

0

+ 80

(1) Calculation of volumes by WISE-Paris where not indicated in the inventory colon.
(2) On the total of 4,249 drums of conditioned hulls/nozzles, 2,731 drums (4,780 m3) are to be re-conditioned in the

future compacting ACC workshop (planned for 2001).

(3) Some of these wastes are planned to be re-conditionned.

Source: National Inventories of Radioactive Wastes, ANDRA, 1999-2000

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6.2.2.1.  Low Level Waste (LLW)

Low Level Waste (LLW)  in  France  is  radioactive  waste  with  a  total  activity  of  less  than 3,700 Bq/g  and  a
content of alpha emitters of less than 370 Bq/g. LLW stemming from the contamination of materials used for
reprocessing at La Hague has been sent from 1969 to 1994 to the neighbouring final disposal site Centre de
la  Manche (CSM).  During  this  period,  the CSM  accepted 1,470,000  containers (527,000 m3)34  of  low  and
intermediate level waste issued from reprocessing of French and foreign spent fuel. After the CSM closure in
1994,  LLW  from  La  Hague  has  been  sent  to  a  new  final  disposal  site,  the  CSA (Centre  de  stockage  de
l’Aube) in the east of France.

6.2.2.2.  Intermediate Level Waste (ILW)

Intermediate  Level  Waste (ILW) 
less
than 370,000  Bq/g.  It  is  essentially  sludge  issued  from  the  Effluents  Treatment  Stations (STE2  and  STE3)
and hulls and nozzles from the sheared fuel assemblies. Sludge has been conditioned under a bitumised form
until 1997  and COGEMA  is  now  developing  another  conditioning  technology  for  this  waste.  Hulls  and
nozzles have been compacted and cemented in containers.

is  radioactive  waste  with  a 

total  activity  of 

in  France 

There  is  no  national  repository  in France  for  these  wastes  which  are  temporarily  stored  on  the  La  Hague
site (STE3 building for bitumised waste and EDS and E/D EDS buildings for cemented waste). As of the end
of 1999, 4,249 packages of hulls and nozzles and 9,898 packages of bitumised waste were in storage on the
La  Hague  site.  Moreover,  9,288 m3 (or  39,000 containers  equivalent)  of  sludge  have  been  stored  as  raw
waste  and 2,076 m3  of hulls and nozzles (together  with 540 m3  of  some  other  waste)  have  been  waiting  for
more than six years to be conditioned. In 1990, the IPSN (Institute for Nuclear Safety) wrote already that it:
“considers that the re-conditioning of sludge contained in the storage silos of STE2 is of high priority due to
the risks of contamination of the water table.”  35

6.2.2.3.  High Level Waste (HLW)

High Level Waste (HLW) is radioactive waste from the dissolution of the fuel in nitric acid and recovered
after  separation  of  the  different  radionuclides.  The  glass  logs  in  which  they  are  immobilised  in  the R7 (for
UP2-800) and T7 (for UP3) facilities of La Hague, contain essentially fission products and minor actinides,
or  around 99%  of  the  radioactivity  of  the  spent  fuel  reprocessed.  Production  rate  of HLW  at  La  Hague  is
around 200 m3/year (around 130 m3for 1,000 tons of spent fuel reprocessed). As of the end of 1999, a total
of 6,759 canisters  of  vitrified  waste  were  stored  in  the R7,  T7  and  NPH  facilities  of  the  La  Hague  site
and 608 canisters had been returned to foreign clients as of March 2001.

6.2.2.4.  “Curie-swap”

If most of the La Hague foreign reprocessing contracts include return clauses for radioactive waste, they do
not include clauses concerning specific categories of waste. To simplify the waste management, COGEMA
and  its  foreign  clients  agreed  to  interpret  the  contract  clauses  in  terms  of  radioactivity  content  and  not  in
terms of volume, i.e. they preferred to return smaller volumes of waste with higher radioactivity content over
return  of  waste  corresponding  to  the  volumes  generated  by  the  reprocessing  of  foreign  fuel.  This
interpretation of the return clauses leads to the management of huge volumes of foreign intermediate level
waste  at  La  Hague  and  management  by  ANDRA  of  the  low  level  waste  issued  from  the  reprocessing  of
foreign fuels at La Hague. The case of foreign waste storage in France is illustrated in Annex 13.

6.2.2.5.  Reprocessing at La Hague and HLW long-term management

As  in  nuclear  countries  that  have  chosen  the  direct  disposal  option  for  spent  fuel,  decisions  on  definitive
solutions for HLW management are yet to be taken in France, as shown in Table 6.

34 ANDRA, “Où sont les déchets radioactifs en France ?”, édition 2000.
35 IPSN,  “Programme  de  reprise  des  boues  issues  du  retraitement  des  combustibles  usés  entreposées  sur  le  site

COGEMA de La Hague”, October 1999.

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Table 6 Waste Management in France by Category (as of the end of 2000)

Very Low Level Waste

Low Level Waste

Intermediate Level Waste

High Level Waste

Short lived
main elements < 30 years

Current studies for

application at CSA
Surface storage (CSA)

Studies on management of
tritium contaminated waste

Long Lived
> 30 years

Studies on management of mining
tailings

Studies (radium, graphite)

Research and Laboratory Site Investigations

(under the law of 30 December 1991)

Source: DSIN, 2001

Only  recently,  as  pointed  out  in  a  parliamentary  report [Bataille,  2001],  it  was  admitted  that  some  French
spent fuel, both uranium fuel and MOX, would also go to final disposal. Final waste volumes to be managed
are  unfavorable  to  the  reprocessing  route  also  because  of  the  much  higher  heat  output  of  spent MOX  if
compared to uranium fuel [Charpin et al, 2000]. Spent MOX fuel requires a longer interim storage before its
final disposal – some 150 years instead of 50 years for uranium fuel.

6.3.  DISCHARGES FROM LA HAGUE

La Hague discharges are set out in Figures 8 and 9. Note logarithmic scales are used in these illustrations in
order to deal with the wide range of data points.

6.3.1. Authorisations

The  La Hague  site  is  authorised  to  release  a  significantly  higher  quantity  of  radionuclides  both  in  marine
media  and  in  the  atmosphere  than  any  other  nuclear  facility  in  France. Annex 14  presents  a  comparison
between the reprocessing plant authorisations at La Hague and two typical French light water reactor sites.
The  comparison  of  the  authorised  release  levels  at  La  Hague  and  a  Flamanville  reactor,  17 km  along  the
seashore from the La Hague site shows that the La Hague limits are roughly:

- 20,000 times higher for gases, excluding tritium (krypton-85, carbon-14…),
- 1,000 times higher for gaseous and liquid tritium,
- 275 times higher for halogenes (iodine, chlorine, etc)
- 8,000 times higher for liquid beta emitters, excluding tritium, discharge.

No  specific  limit  exists  at  La Hague  concerning  the  atmospheric  release  of  alpha  emitters  while  they  are
prohibited at EDF power plants. Discharges of alpha emitters into water are also prohibited at EDF plants.

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Figure 8 Annual Air Emissions from La Hague (in TBq)

1000000

100000

10000

1000

100

10

1

0,1

0,01

0,001

0,0001

0,00001

1991

1992

1993

1994

1995

1996

1997

1998

1999

Tritium

Carbon-14

Krypton-85

Ruthenium-106

Iodine-129

Source: COGEMA [1998], Dossier d’Enquête Publique

Figure 9 Annual Liquid Discharges from La Hague (in TBq)

100000

10000

1000

100

10

1

0,1

1991

1992

1993

1994

1995

1996

1997

1998

1999

Tritium
Technetium-99

Carbon-14
Iodine-131*

Ruthenium-106
Iodine-133*

Iodine-129

Source: COGEMA [1998], Dossier d’Enquête Publique

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Figure 10 Evolution of La Hague gaseous discharges 1990-1999 (index 100 in 1990)

OSPAR (PARCOM 91/4) :
« The contracting parties […] agree […] to apply the Best 
Available Technology to minimize and, as appropriate, 
eliminate any pollution caused by radioactive discharges »

OSPAR (PARCOM 93/5) :
« Contracting parties […] agree […]
to adopt further measures, including 
the application of Best Available 
Techniques for the reduction or 
elimination of inputs of radioactive 
substances to the maritime area »

800

700

600

500

400

300

200

100

0

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

Reprocessed quantities

Iodine 129

Tritium

Krypton 85

Carbon 14

Figure 11 Evolution of La Hague liquid discharges 1990-1999 (index 100 in 1990)

Source: [GRNC, GT-1, 1999]; communication COGEMA, 2001

OSPAR (PARCOM 91/4) :
« The contracting parties […] agree […] to apply the Best 
Available Technology to minimize and, as appropriate, 
eliminate any pollution caused by radioactive discharges »

OSPAR (PARCOM 93/5) :
« Contracting parties […] agree […]
to adopt further measures, including 
the application of Best Available 
Techniques for the reduction or 
elimination of inputs of radioactive 
substances to the maritime area »

600

500

400

300

200

100

0

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

Reprocessed quantities

Iodine 129

Tritium

Source: [GRNC, GT-1, 1999]; communication COGEMA, 2001

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6.3.2. Discharge levels of major radionuclides

Nuclide  releases  from  La Hague  are  several  orders  of  magnitude  higher  than  those  from  French  power
reactors (see  Annex 15).  In 1999,  La Hague  released  over  7,000 times  more  radioactivity  into  the
environment than the two light water reactors 17 km along the seashore from the La Hague site.

The UP2-800 plant began to operate in 1994 and the tonnage of fuel reprocessed at UP2 increased by a factor
of  four  within  10 years.  The  graphs  presented  in  Figures 10  and 11  for  major  radionuclides  illustrate  the
increased discharges since 1994, in correlation with the increasing production.
Krypton-85  (85Kr,  half-life:  10.7 years)  releases  have  been  increased  five  fold  over  the  last decade,  in  line
with the tonnage throughput.

Carbon-14 and tritium gaseous releases have been increased by a factor of four and three respectively, in the
period  1990-1999.  These  nuclides  exchange  easily  with  carbon  and  hydrogen  atoms  in  living  organisms.
Carbon  and  hydrogen,  of  course,  are  major  constituents  of  organic  matter  and  hydrogen  is  a  major
constituent  of  water.  Gaseous  releases  of  these  nuclides  have  been  increasing  since  the  beginning  of
La Hague operations, and reached a maximum in 1996 for the 1966-1996 period.
COGEMA does not report measurements for gaseous chlorine-36 (36Cl, half-life of 300,000 years), gaseous
technetium-99 (99Tc, 214,000 years) and gaseous strontium-90 (90Sr, 28.8 years) releases.36

There is a trend towards lower marine discharges of some radionuclides from La Hague (see Figure 12) and
marine  discharges  of  technetium-99  exhibit  a  sharp  decrease  since 1990  with  the  phase  out  of  the
reprocessing  of  gas-graphite  fuel.  However  marine  discharges  of  most  long-lived  radionuclides  have
increased, in some cases significantly: e.g. iodine-129, chlorine-36, and carbon-14.

Figure 12 Evolution of La Hague plutonium, strontium-90 and caesium-137 liquid discharges 1990–

1999 (index 100 in 1990)

200%

180%

160%

140%

120%

100%

80%

60%

40%

20%

0%

Total plutonium

Strontium-90

Caesium-137

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

Source: [GRNC, GT-1, 1999]; communication COGEMA, 2001

36 Sellafield releases gaseous Strontium-90 and it is highly likely that La Hague does as well.

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6.3.3. Discharge trends

The  direct  relationship  between  reprocessing  throughput  and  nuclide  discharges  at  La  Hague  means  that,
under current technical conditions, emissions will not decrease without a decline in reprocessing activity. On
the  contrary,  the  future  conditioning  of  the  large  stocks  of  raw  intermediate  level  wastes  might  lead  to
additional radionuclide releases.

6.3.4. Unplanned Radioactive Releases

6.3.4.1.  Major accidents and list of incidents at La Hague plant

There  have  been  numerous  incidents  and  accidents  at  the  La  Hague  plants. Annexes 16  and 17  give  an
overview  of  a  number  of  examples.  Some  accidents  have  led  to  the  release  of  significant  quantities  of
radioactivity to the environment, in some cases by a factor of 10 or more in excess of the annual limits. In a
few cases, doses delivered to workers and/or members of the public have been substantial. For example, as a
consequence of a severe discharge pipe break in 1980, individuals of the critical group (fishermen) received
approximately 3.5 times the currently authorised annual dose (namely 3,486 mSv, to be compared with the
current European limit of 1 mSv/year).

In  many  cases,  a  proper  evaluation  of  environmental  and  health  consequences  were  not  carried  out  at all.
However, accidents/incidents are estimated to be responsible of 36% of the leukaemia risk level for the 0-
24 year  age  category  around  the  La Hague  site,  according  to  the  Radio-ecological  Group  of  North-
Cotentin [GRNC, GT–4, 1999].

6.3.4.2.  Potential Hazards at the La Hague plant

Neither COGEMA nor any governmental institution in France has published a thorough global risk analysis
for the La Hague plant.

The main consequences of hazards likely to be induced at La Hague are:

-public and workers exposure to radiation or to chemical matters during operations,
-dispersion of radioactive materials or chemical products in the environment,
-fires and explosions giving rise to public or workers exposure.

The main sources of potential hazards are listed below:

·   Fire  and  explosions.  There  is  a  serious  risk  of  fires  and  explosions  in  the  storage  pools,  in  the
vitrification plants or in the effluent treatment plants at La Hague. The Annex 18 lists the main fires or
explosions  occurred  in  the  reprocessing  plants  around  the  world.  A  loss  of  coolant  in  storage  pools
could  lead  to  a  self-sustained  fire  that  would  release  large  amounts  of  radionuclides  into
the environment.

·   Caesium-137  (137Cs,  half-life  30 years)  stocks  in  the  spent  fuel  pools  of  La Hague.  One  ton  of
reference  spent  light  water  reactor (LWR)  fuel37  contains  just  above 1 kg,  or 3.25 103 TBq  of
caesium-137. COGEMA is expected to soon be authorised to enhance the capacity of storage of the
pools to 17,600 tons of spent fuel. Considering  that  7,508 tHM of different spent fuels are currently
stored  in  La Hague  cooling  ponds (as  of 31 May 2001),  the  caesium-137  stock  in  La Hague  ponds
could be close to 7.58 t, that is 287 times the quantity released by the Chernobyl accident (26.4 kg).
The  accidental  release  of  the  total  quantity  of  caesium-137  stored  at  La Hague  in  the  marine
environment,  according  to  a  report  commissioned  by  the  European  Commission [Dreicer,  1995],
would lead to a dramatic regional collective dose of 2 million man.Sv, that would mean an expected
100,000 fatal cancers, according to ICRP risk factors (5% per man.Sv). More calculations of collective
doses are presented in Annex 19.

·   Separated  plutonium  stocks  at  La Hague.  Potential  risks  of  dispersion  of  some  of  the  50 tons  of
separate plutonium currently stored at La Hague are not analysed by COGEMA in the public inquiry

37 Spent UOX fuel with a burn-up of 33 GWd/t, 3.25% of initial enrichment and 3 years of cooling period [GRNC, GT–

1, 2000].

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report.  These  stocks  raise  concern  for  nuclear  proliferation  since  plutonium  is  a  key  ingredient  for
nuclear explosive devices. Several kilograms are sufficient to manufacture a crude nuclear device.

6.4.  ENVIRONMENTAL CONCENTRATIONS AND DOSES

6.4.1. Environmental Concentrations

Radionuclide concentrations in foodstuffs that exceed the EU Community Food Intervention Levels (CFILs)
have  been  only  rarely  identified  in  the  La  Hague  environment.  Royal  crabs  caught  in  the  area  of  the  sea
discharge  point  of  the  La  Hague  plant  were  measured  in  1997  with  strontium-90  concentrations  and
plutonium exceeding the CFIL respectively by a factor of eight and two (see Annex 9b for details).

However,  only  selective  samples  have  been  taken  until  recently  and  very  few  radionuclides  have  been
measured  before  1990.  No  measurements  at  all  are  available  for  key  isotopes  such  as  carbon-14,  or
krypton-85  before  1996.  Serious  efforts  to  begin  completing  the  range  of  measured  isotopes  have  started
only  in  1996/1997.  Also,  the  full  range  of  samples  has  not  been  taken  systematically  every  year,  but
sometimes only as spot checks with very few sites fully sampled. This lead to incomplete series of data and
“orphan”  sites, both very difficult or impossible to interpret. Sampling redundancy is very low and the few
redundant  samples  sometimes  differ  in  concentrations  by  a  factor  of  two.  This  illustrates  the  absence  of  a
coherent surveillance program of environmental contamination, especially before 1996.

Of the 500,000 measures conducted between 1978 and 1997 and inventoried by the GRNC, 51% have been
carried out by the operator COGEMA, 16% by the national marine’s department GEA (Marine Nationale –
Groupe  d’Études  Atomiques),  which  operates  a  nuclear  submarine  base  at  Cherbourg  and  17.5%  by  the
national radiation protection board OPRI (Office de Protection contre les Rayonnements Ionisants) [GRNC,
GT-2, 1999]. Given the very low share of samples analysed by other institutes (for example ACRO [1997],
University of Bremen [1997]), it is worth noting that some of the highest readings were identified by these
latter  laboratories  on  some  of  the  least  measured  radionuclides.  This  should  be  an  additional  incentive  to
enlarge the redundancy of measurements.

Given the absence of a systematic and coherent long-term sampling and measuring program, it is difficult to
carry  out  a  trend  analysis  of  nuclide  concentrations  in  the  environment  due  to  the  La  Hague  reprocessing
activities. The following historical overview of the La Hague area contamination (Table 7) should therefore
be read as a tentative partial analysis only that also illustrates the lack of continuous data series.

Table 7 Overview of peak years of nuclide concentrations in the La Hague environment

Sample type

137Cs, 60Co, 125Sb, 106Ru/106Rh, 40K

90Sr

Fucus

Limpets, mussels,
oysters

Drinking water

Grass

Milk

Fishes

1979/80

1984/85

1980/81

1985/86

1979/80

1980/81

1980/81

1982/83

No peak

No peak

1985/86

1987/88

3H

?

?

1981/82

?

131I

?

?

?

?

?

?

?

?

1984

1984

1982

1985/86

?

?

99Tc

1985

?

?

?

?

?

Source: WISE-Paris, 2001, from [GRNC, GT-2, 1999]

Concentration peaks in 1979/1980 vary in intensity depending on the sampling area, the sample type and the
measured radionuclide, but reduction factors between 10 and 50 if compared to 1997 levels can be retained.
Reduction  factors  between  5  and  25  if  compared  to  1997  levels  can  be  retained  for  the  1984/1985
contamination peaks. Since 1990, measures of contamination seem to indicate a slight but regular decrease of
radionuclide concentrations where measured.

The  sharp  increase  in  releases  of  some  radionuclides  from  La  Hague  to  the  sea  (in  particular  tritium  and
iodine-129) and the air (in particular tritium and carbon-14) throughout the 1990s is not really reflected in

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the  trend  analysis  because  of  lacking  data.  The  GRNC  conclusions  about  both  carbon-14  and  iodine-129
concentrations  is  that “there  are  not  enough  data  to  evaluate  the  representativity  and  dispersion  of  the
values” [GRNC, GT-2, 1999]. However, the GRNC concluded for carbon-14 that “the results of measures in
the  marine  or  terrestrial  environment  superior  to  250 Bq/kg  show  recent  anthropogenic  contribution.”  It
also noted ”an increase of iodine-129 concentrations in fucus since 1988.”

6.4.2. Doses from Environmental Radiation

While the official figures have generally shown a very small dose impact from environmental radiation in the
La  Hague  region  (see Annex  27),  the  analysis  of  the  potential  impact  of  more  highly  contaminated  food
stuffs, which have rarely been published but have been identified occasionally near La Hague in the past (see
previous point 6.4.1), gives a different picture, as illustrated by a study commissioned by the German Office
for Radiation Protection (BFS) [Beninschke, 2000].38

The  Critical  Group  around  La  Hague,  as  defined  by  COGEMA  [2000],  the  fishers  from  Goury,  have  a
defined annual uptake (ingested activity for adults corresponding to the nominal discharges) of:

- strontium-90:
8.6 Bq
- technetium-99:
28 Bq
- iodine-129:
44.7 Bq
- caesium-137:
329 Bq
- ruthenium-106:
4,816 Bq
- tritium:
6,722 Bq
- artificial carbon-14: 13,985 Bq

These  are  very  small  quantities  of  radionuclides  if  compared  to  concentrations  found  in  the  La  Hague
environment and foodstuffs. The supposed uptake of strontium-90,  for  example,  would  be  already  reached
with the ingestion of 1.7 grams of crabs taken close to the discharge point of the liquid effluents. Moreover,
the  consumption  of  320  g  of  those  crabs  are  sufficient  to  reach  the  German  dose  limit  for  the  red  bone
marrow. It is therefore plausible that parts of the local population around La Hague has been and is exposed
to much higher doses than considered in the official dose estimates.

The  cumulative  effective  dose  (adult:  2.3  mSv/a;  child:  0.83  mSv/a)  induced  by  the  consumption  of
seafood (especially  relevant  are  the  crabs  from  the  vicinity  of  the  discharge  pipe39),  as  calculated  under
German statutory dose assessment assumptions, exceed German and EU dose constraints (0.3 mSv/a and 1
mSv/a respectively).

6.5.  IMPACT OF LA HAGUE DISCHARGES – BACKGROUND STUDIES

6.5.1. Marine effects

Long range transport of long-lived radioelements can spread contamination beyond the European continent.
The  mean  residence  time  of  iodine  in  the  atmosphere  is  14 days,  sufficient  to  allow  contamination  of  the
southern  hemisphere,  according  to  [Moran,  1998].  Moran  also  alleged  that  global  tropospheric  circulation
could drive the air masses across the Atlantic and could result in transport of iodine-129 from European fuel
reprocessing  facilities  to  the  continental  US.  After  deposition,  iodine-129  infiltrates  the  soil  and  is  then
washed into rivers and other surface bodies.

Water movements in seas adjacent to a source point of marine discharge allows long-lived radionuclides to
be  transported  over  long-range  distances.  Releases  from  Sellafield  reach  the  Norwegian  coast  by  ocean
currents for instance, within two to three years. Higher transfer rates of soluble radionuclides from La Hague
compared to Sellafield were observed and explained by a coastal current from the English Channel, along the
European coast, to the Norway coastal areas. [Brown, 1998]

38 Calculations under 6.4.1 from [Beninschke, 2000].
39 According  to  certain  sources,  crabs  move  up  to  more  than  1  km per  day.  Therefore,  the  significance  of  the  exact

location where they were caught remains unclear.

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Discharges of iodine-129, technetium-99, carbon-14 concentrate in marine organisms and sediments. Some
recommended  values  of  the  concentration  factor  in  various  marine  organisms,  provided  by  the  Groupe
Radioécologie  Nord-Cotentin (GRNC),  are  compiled  in  Annex 20.  Long-lived  radionuclides  such  as
iodine-129, technetium-99 exhibit the highest concentration factors in seaweed. Seaweed is for instance used
in the food processing industry (in ice cream and milk-based products) and in the formulation of cosmetics.
In  the  past,  farmers  spread  seaweed  on  the  soil  as  fertiliser  and  used  it  as  animal  feedstock.  The  French
independent laboratory CRII-Rad40. has stated that these possible transfer patterns should be included in the
evaluation of global collective doses. The French National Evaluation Commission (CNE) on research into
radioactive  waste  management  [CNE,  2000]  raised  the  specific  problem  of  improving  iodine-contaminated
waste  packaging.41  The  increasing  discharges  of  iodine-129  and  tritium  from  La Hague  reprocessing
facilities appear to be in breach of France’s obligations under the OSPAR Convention.

6.5.2. Health Effects

6.5.2.1.  Cancer morbidity inquiry in the Manche Department

In  1983,  a  3  year  epidemiological  study  by  the  Observatoire  Régional  de  la  Santé  de  Basse-Normandie
determined  the  frequency  and  the  distribution  of  cancer  in  the  region [Collignon,  1983].  Morbidity  was
found  to  be  higher  than  expected  in  the  surroundings  of  Cherbourg  for  men  in  case  of  leukaemia  and
respiratory  organs,  and  for  women  in  case  of  leukaemia  and  lung  cancer (see  Annex 21).  Moreover,
mortality  data  show  an  increased  rate  of  cancers  for  the  digestive  organs  in  North-Cotentin,  and “only
Cherbourg county shows a mortality significantly higher than the regional mean value for men.”

6.5.2.2.  Epidemiological study by Viel and Pobel
In 1995,  Viel et  al  published  the  results  of  a  study  of  the  incidence  of  leukaemia  among  persons  aged  0–
24 years living in a 35 km radius around the La Hague reprocessing plant [Viel, 1995]. This study suggested
an excess of leukaemia cases in the canton of Beaumont-Hague (corresponding  to  about  10 km around the
plant). Four cases were observed between 1978 and 1992, compared with 1.4 expected. In 1997, Pobel and
Viel  published  the  results  of  a  case-control  study,  which  they  claimed  provided “convincing”  evidence  in
childhood  leukaemia  of  a  causal  role  for  environmental  radiation  exposure  from  recreational  activity  on
beaches.

Two kinds of behaviour were found to be potentially connected with the increase in leukaemia risk:

-the use of local beaches for recreational activities by children and mothers during gestation, and

-fish and shellfish consumption.

In the first case, the relative risk was found to be 2.87 (compared with 1.00 where children or mothers never
went  to  the  beach).  Ingestion  of  seafood  increased  the  relative  risk  to 2.66 (to  be  compared  to 1.00  if  no
seafood was consumed).

Viel’s  concluded  that “there  is  some  convincing  evidence  in  childhood  leukaemia  of  a  causal  role  for
environmental  radiation  exposure  from  recreational  activities  on  beaches” [Pobel,  1997].  These  findings
resulted  in  the  French  Government  ordering  a  new  inquiry  by  the  Radioecological  Group  of  North-
Cotentin (GRNC) to look into the leukaemia risks around La Hague.

6.5.2.3.  The Radioecological Group of North-Cotentin (GRNC) survey
In 1997, the French Ministry of Land Use Planning and of the Environment and the Secretariat for Health
and  Social  Security  commissioned  a  study  by  the  Nord-Cotentin  Region  which  set  up  the  Nord-Cotentin
Radioecology  Group (GRNC)  for  this  purpose.  The  report  of  the  Group  in  July 1999 [GRNC,  1999]
concluded  that  the  number  of  cases  of  radiation-induced  leukaemia  attributable  to  radiation  doses  from
discharges from local nuclear facilities would be around 0.002. They stated that it seemed improbable that
exposures  due  to  discharges  from  local  nuclear  facilities  would  contribute  significantly  to  explaining  the

40  “Contrôles radiologiques sur des organismes marins à La Hague”, CRII-RAD laboratory., May 1997.
41  “International agreements (OSPAR Convention) lead to think that in future Iodine-129 will have to be held back and
its conditioning or an efficient treatment will have to be carried out, this all the more since the very small quantity of
Iodine  (relative  to  the  entire  quantity  of  generated  iodine)  contained  in  intermediate  level  waste  [déchets  B]
represent the dominating radiological impact at the exutory of an eventual storage”  [CNE, 2000].

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elevated  incidence  of  leukaemia  observed  among  the  young  people  aged  0-24  years  in  the  canton  of
Beaumont-Hague over this period [Rommens et al, 2000].

This conclusion is similar to that reached in the UK concerning the increased leukaemia incidence in young
children at Seascale near Sellafield. Also, as at Sellafield, important uncertainties exist over the estimation of
radiation  doses  from  environmental  discharges.  The  GRNC  report  expressed  reservations  over  whether
conclusions  could  be  drawn  without  a  quantitative  analysis  of  uncertainties;  this  analysis  is  now
underway [see Simmonds, 2000].

The  GRNC  report  stated  that  the  contribution  to  doses  from  nuclear  facilities  was “low,  regarding  the
incidence  of  leukaemia  showed  by  recent  epidemiological  studies.”  Nevertheless,  the  Group  added:  “this
result is a mean estimation and it is worth underlining that uncertainty margins were not quantified.”

CRII-Rad Laboratory representatives, members of the GRNC, refused to sign on to the report’s conclusions.
Their main objections were [CRII-Rad, 1999]:

-the  Group  excluded  investigations  into  collective  doses  and  the  long-term  impacts  of  long-lived
radionuclides (including carbon-14, iodine-129, technetium-99);

-high  levels  of  contamination  of  marine  life  surrounding  the  discharge  pipe  were  set  apart  although  local
fishing practices give rise to non-negligible exposures;

-only 0,23% of the measurements used in the study were carried out by independent laboratories, and 75%
by the operator;

-exposures  from  radioactive  transports  was  not  taken  into  account:  spent  fuel  is  currently  moved  by  train
following usual routes, and the public can be exposed to non-negligible doses;

-involuntary transport of radioactive particles by workers to their home was not considered;

-possible evolution of human practices regarding diets and food hsabits was not explored , including possible
increased seaweed consumption, and public use of the Sainte-Hélène contaminated stream;

-no  analysis  on  a  multi-factorial  impact  of  possible  synergistic  effects (chemical  discharges,  non-ionising
radiation…) was carried out;

-father exposures to ionising radiation before conception were not studied;

-mother exposures during gestation included routine but not uncontrolled releases of radioactivity (although
the latter represent 36% of ex-utero exposures.

The GRNC did not use a collective dose model to assess both leukaemia risk and doses committed towards
various reference groups.

In  the  case  of  leukaemia,  the  experts  summed  up  the  contribution  of  routine  discharges  for  a  30 year
operational  period  in  terms  of  individual  dose  to  the  bone  marrow (not  to  the  whole  body).  Then,  this
individual  dose  was  multiplied  by,  roughly,  a  definite  number  of  persons,  supposedly  representative  of  the
evolution of the population of the county between 1966 and 1996.

In  the  case  of  the  dose  evaluation,  the  GRNC  used  an  individual  dose  approach  that  was  applied  to  a
reference  group.  The  annual  committed  doses  are  presented  in Annex 22.  COGEMA  dose  estimates  are
under  10 micro  Sievert (m Sv)  per  year  for  the  two  reference  groups  it  has  chosen.  GRNC  calculated  an
individual  dose  six  times  higher  than  the  COGEMA  values  for  four  different  reference  groups (least  case:
60 m Sv/year).

GRNC  did  not  use  a  global  model  to  assess  leukaemia  doses  and  risks.  A  global  model  that  takes  into
account  the  earth’s  population  truncated  at  100,000 years  was  developed  by  CEPN  in  its  study  for  the
European  Commission [Dreicer,  1995].  This  model  reflects  the  collective  and  long  term  impact  of  longer
lived radionuclides, than the 30 year estimate by GNRC. Given the 16 million year half-life of iodine-129, an
untruncated dose model should really be used (i.e. extending doses to infinity).

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6.5.2.4.  La Hague Childhood Leukaemia Study 2001

In June 2001, a new epidemiological study extended the earlier Pobel study to include new data from 1992 to
1997  [Guizard,  2001].  In  this  period,  3  cases  of  acute  lymphoblastic  leukaemia  were  observed  while  0.47
were expected.

The  key  findings  were  that  the  study  confirmed  the  earlier  findings  by  Viel  and  Pobel.  The  study  also
indicated  that  the  increased  incidence  was  continuing,  and  had  not  stopped.  Most  important,  the  study
provided  more  data  to  allow  statistical  significance  to  be  established (for  the  first  time  in  France)  for  the
increases in leukemias at La Hague.

The study “indicates  the  predominance  of  acute  lymphoblastic  leukaemia  over  childhood  leukaemia  cases
diagnosed in the Beaumont-Hague electoral ward. Although not conclusive, this observation could be linked
to the dramatic intensity of population movement that occurred in this particular area.”

The  authors  conclude: “In  view  of  statistically  significant  clusters  of  childhood  leukaemia  near  other
European  nuclear  reprocessing  sites,  and  the  concerns  of  the  local  population,  these  findings  argue  in
favour of continued investigations in Nord  Cotentin. Three lines should be followed: measuring the incidence
of  child  leukaemia  among  people  who  have  lived  at  any  time  in  Beaumont-Hague;  identifying  possible
causes of leukaemia in the area (studies  of  population  movements);  and  measuring  the  incidence  of  other
diseases  the  occurrence  of  which  could  be  linked  to  radiation (other  cancers,  and  reproductive
function disorders).”

6.5.2.5.  “Radiological impacts of spent nuclear fuel management options”, NEA, 2000

The Nuclear Energy Agency began in 1995 a comparative assessment between two fuel cycle options, at the
request of the OSPAR Commission. This study aimed at comparing from the standpoint of the radiological
impact the reprocessing activities and a once-through fuel cycle where spent fuel is not reprocessed.

According  to  the NEA  study,  both  public  and  workers  exposures  could  be  reduced  by  about  20%  through
reprocessing. The report assumes that MOX fuel use avoids extraction of natural uranium in this proportion.
However,  this  is  a  highly  theoretical  assumption  that  has  been  contradicted  by  various  other  sources.  A
report  to  French  Prime  Minister  presented  in  mid–2000 [Charpin  et  al,  2000]  indicates  that  the  uranium
savings  of  the  plutonium  path  do  not  exceed 8%.  However,  reprocessing  operations  clearly  add  a  higher
collective dose, mainly towards the public.

The  NEA  Report  concludes  that “the  differences  between  the  two  fuel  cycles  examined  options  are  small
from the standpoint of radiological impact. In this connection, it is simply not justifiable to draw definitive
conclusions (…). Consequently, radiological impact is not a key factor favouring one option or the other.”

However this conclusion is contradicted by a number of independent studies [Sumner, 1992; Fairlie, 1997],
which found that doses from reprocessing considerably exceeded those from dry storage routes, sometimes
by  three  or  four  orders  of  magnitude.  Even  from  cursory  examination,  it  is  clear  that  doses  from  large
discharges of nuclides from reprocessing will exceed the very low doses from dry stores.

And in fact, that is not put into question by the NEA study, as OSPAR Resolution 2000/1 from June 2000
points  out: “Noting  further  that  the  NEA  study  has  demonstrated  that  implementing  the  non-reprocessing
option (dry storage) for spent fuel would eliminate the discharges and emissions of radioactive substances
that currently arise from reprocessing it.”

6.5.3. Uncertainties in Dose Assessments

6.5.3.1.  A Mandate for the Radio-ecological Group of North-Cotentin to Assess

Scientific Uncertainties

Many  uncertainties  exist  in  the  assessment  of  doses  from  discharged  nuclides.  For  example,  as  regards
nuclide inventories, Task Group n°1 of the Radioecological Group of North-Cotentin (GRNC) has stated that
it  was  “difficult  to  thoroughly  quantify  or  even  to  estimate  the  activity  of  the  radionuclides  discharged
because of their various behaviours, depending on the step in the process”  and because “the efficiency of the
cleaning treatment of the effluents is not known with high precision for each radionuclide.”  (GRNC, 1999)
Moreover, estimates are made when measurements are unavailable.

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As  regards  final  doses,  GRNC  Task  Group n°4  stated  that  “the  different  steps  leading  to  risk  assessment
required many hypotheses and approximations that imply an uncertainty surrounding the final results , which
is  difficult  to  quantify.  (…) It  is  worth  underlining  that  the  uncertainty  margins  were  not  quantified.”   The
GRNC42  is  presently  carrying  out  a  sensitivity  and  uncertainty  analysis  of  the  main  parameters  associated
with the leukaemia risk in Nord-Cotentin. So far, it has identified no fewer than 4,000 parameters, including
200 critical  parameters,  in  the  methodology  used  to  assess  dose  impact.  A  final  report  is  expected  to  be
published later in 2001.

6.5.3.2.  Sources of Uncertainties

• Computer codes
Several  computer  codes  exist  to  determine  radionuclide  activities  in  spent  fuel.  According  to J.C. Zerbib43,
senior consultant to the French CEA and a member of the Task Group n°1 of the GRNC, these codes have an
error  margin  of  about 5% (up  to 10%  for  some  radionuclides).  In  the  case  of  iodine-129,  literature  figures
range  from  170 to  230  grams  per  ton  of  spent  fuel  (a  difference  of 30%).  The  lack  of  an  international
consensus on these values could result in significantly under-estimated releases.

• Paucity of measurements and environmental monitoring

The CRII-Rad Laboratory has drawn attention to the lack of environmental measurements by the regulatory
bodies  IPSN  and  OPRI44  for  many  radionuclides  [CRII-Rad,  1999].  For  instance,  technetium-99  and
plutonium-241 so far has not been measured in marine organisms by OPRI. No measurements are currently
carried out in the vicinity of the discharge pipe by IPSN, and no measurements at all are carried out by the
European Commission under Article 35 verification rights.

75% of the measurements available in [GRNC, 1999] were provided by operators which suggests a lack of
independent environment monitoring around the La Hague plant. A telling criticism was voiced by a member
of the GRNC45 in the conclusions of the Group’s report: “up to now, measurements were conducted only to
check the correct operation of the installations and not in order to monitor health effects on populations.”

• Disputed measurements

Some  local  practices  of  fishermen  around  the  discharge  pipe  have  been  ignored  although  of  considerable
impact on the local population (some hundreds of microsieverts, to be compared with the committed doses of
the GRNC scenarios, see Annex 22). Furthermore, M. Guillemette46 contested measurements by COGEMA
in  molluscs  at  the  moment  of  the  discharge  pipe  incident  in 1979.  As  a  consequence,  the  president  of  the
GRNC created a new group of experts that has been focusing for six months on this issue. The impact of the
incident  was  assessed  again  and  the  individual  dose  for  a  fisherman  rose  from  0.874 mSv (before
rectification)  to  3.486 mSv,  i.e  a  four-fold  increase.  The  annual  EU  limit  is  1 mSv  for  an  individual  of
the public.

• Lack of transparency inside the facilities of COGEMA
Since 199947, OPRI has checked COGEMA measurements of marine or gaseous effluents, in a more regular
manner.  The  technical  service  of  the  safety  authority,  the  IPSN,  also  assesses  radionuclide  concentrations
inside  the  plant  on  the  basis  of  the  operator  data,  during  modifications  or  the  commissioning  of  a  new
facility. But all these data are kept confidential.
WISE-Paris  studied  the  very  long-lived  nuclide,  iodine-129  (129I,  half-life:  15.7  million  years).  Using  two
models (those of COGEMA and UNSCEAR) and values recorded by COGEMA, WISE-Paris quantified the
differences between the theoretical iodine-129 activity in spent fuel and the discharged activity to sea or air.

42  Mandate by the Ministry of Environment and the Secretary of State of Health in a letter dated 24th July 2000.
43 Private communication, May 2001
44  OPRI: Office de Protection contre les Rayonnements Ionisants
45  Monique Séné, President of the GSIEN (Groupement de Scientifiques pour l'Information sur l'Energie Nucléaire).
46 M. André Guillemette was a previous member of the CSPI (Commission Spéciale et Permanente d'Information) at
La Hague. He provided the measurements of the CFDT trade union, in the same location and time as COGEMA’s
measurements. The CFDT values were 200 times higher than COGEMA’s measurements.
47 Such inspections are carried out in accordance with the ministerial order of 26 November 1999.

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Annex 24  compiles  the  results  of  these  calculations  from 1989  to 1999.  Large  gaps  are  observed  in  the
beginning of the 1990s, as only 50% of the theoretical values were reported discharged.

The  president  of  the  GRNC  has  agreed  that  the  iodine-129  problem  was  important  enough  to  justify  the
creation  of  a  working  group  under  the  responsibility  of  GRNC.48  Correspondence  with  Dr.  Sugier  is
presented in Annex 25.

WISE-Paris  has  assessed  the  individual  dose  committed  by  an  accidental  release  of  the  “non-attributed”
activity for the year 1997 (least case using the UNSCEAR code). We have assumed that all the activity was
released  either  by  the  atmospheric  pathway (uptake  by  inhalation)  or  by  the  marine  pathway  (uptake  by
ingestion of seafood). In both cases, the additional committed individual doses reach half of the annual dose
that COGEMA alleges to be induced by all radionuclides to anyone of the reference group. The committed
collective dose from non-attributed iodine-129 in the period 1989- 1999 would be about 2,500 manSv, about
the magnitude of a serious nuclear accident such as  the  Windscale  fire  or  the  Kyshtym  waste  explosion  in
1957 (for details of the calculation and references see Annex 25).

48 Meeting with Dr. Annie Sugier, IPSN, Clamart, April 27th 2001. The plenary of the GRNC agreed in principle on 29

June 2001 to set up such a working group including experts from IPSN, COGEMA and WISE-Paris.

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7. COMPARATIVE AND CUMULATIVE ANALYSIS

7.1.  COMPARISON OF RELEASES IN 1999 FROM LA HAGUE AND SELLAFIELD

Figure 13  indicates  that  in  1999 (a  representative  year)  discharges  from  La  Hague  and  Sellafield  were
broadly  comparable,  except  for  technetium-99  discharges.  In  general  terms,  La  Hague  discharges  were
marginally greater than those from Sellafield, except for tritium air emissions, iodine-129 air emissions and
technetium-99 liquid discharges. These differences are partly due to the higher fuel throughput at La Hague
compared to Sellafield in 1999.

Figure 13 Discharges in 1999 from Sellafield and La Hague (TBq, Logarithmic Scale)

Sellafield

La Hague

1000000

100000

10000

1000

100

10

1

0,1

0,01

0,001

Tritium
Air

Tritium
Liquid

Carbon-14
Air

Carbon-14
Liquid

Krypton-85
Air

Iodine-129
Air

Iodine-129
Liquid

Tech.-99
Liquid

Source: BNFL, 2000; COGEMA, 2001

With Sellafield, discharges have tended to follow the fluctuating fortunes of the site’s reprocessing facilities.

In earlier years, it is likely that discharge data was estimated from operating data, i.e. fuel throughputs and
burn-ups,  as  older  measuring  equipment  was  often  incapable  of  detecting  and/or  measuring  many
radionuclides,  including  weak  beta  emitters.  Particular  difficulties  existed  with  detecting  iodine-129  levels
given  its  low  specific  activity,  low  concentrations  and  weak  decay  energy.  In  many  cases,  environmental
levels were below the Lower Limits of Detection (LLD) of measurement instruments.

In  the  case  of  Sellafield,  in  the  late 1970s,  efforts  were  clearly  made  to  reduce  the  high  levels  of  nuclide
discharges  and  these  were  successful  in  the  case  of  SIXEP  and  partly  successful  in  the  case  of  EARP.
However  high  radionuclide  concentrations  from  past  discharges  remain  in  the  environment  especially  near
Sellafield.  As  will  be  discussed  below,  total  doses  to  critical  groups  near  Sellafield  are  dominated  by
radiation (>75% of total dose) received from historic discharges rather than current discharges.

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7.2.  KEY NUCLIDES FOR COLLECTIVE DOSE CALCULATION

7.2.1. Carbon-14

Although carbon-14 discharged from reprocessing is distributed globally, there are significant local increases
in concentration. For example, Begg et al [1991] have reported that carbon-14 discharged from Sellafield has
resulted  in  an  approximate  doubling  of  current  ambient  concentrations  in  the  Irish  Sea.  In 1998  and 1999,
carbon-14  levels  in  botanic  plants  near  La  Hague  as  measured  by  OPRI  and  COGEMA  were 500
to 2,000 Bq/kg (c.f.  natural  background  levels  of  250 Bq/kg).  Guillemette  [2000]  states  that  a  level  of
2,000 Bq/kg in humans corresponds to an annual dose of about 130 µSv, of which 115 µSv would be due to
La  Hague  carbon-14  discharges.  This  is  an  appreciable  fraction  of  the  300 µSv  dose  constraint  usually
applied to critical group doses.

Different  approaches  exist  to  carbon-14  management  at  reprocessing  plants.  For  example,  the  Rokkasho-
mura plant under construction in Japan is designed to remove most carbon-14 to atmosphere. At Sellafield,
about  27% [Environment  Agency,  2001]  of  carbon-14  arisings  are  removed  in  a  caustic  soda  washing
column, precipitated as a solid (barium carbonate), then encapsulated in cement [BNFL, 1993b]. COGEMA,
which currently releases all carbon-14 arisings from reprocessing, recently stated that carbon-14 abatement
was not cost effective in their view [COGEMA, 1999a].

7.2.2. Krypton-85
In 1989,  the  global  inventory  of  krypton-85  was  estimated  to  be  about  3,300 PBq (i.e.  3,300 x 1015 Bq)
nearly all from reprocessing plants [Kollert and Butzin, 1989]. Since 1989, this will have decayed by about
half, but since then a further 2,000 PBq have been discharged from La Hague and 1,000 PBq from Sellafield.

A  more  precautionary  approach  to  krypton-85  has  been  adopted  in  the  United  States.  An  NCRP [1975]
Report  concluded  “…prudence  would  seem  to  dictate  that  fuel  reprocessing  plants  be  equipped  with
krypton-85  removal  systems  as  soon  as  the  technology  is  practicable.”   Since  1983,  US  regulations  have
limited releases of krypton-85  to  a  maximum  of  1,850 TBq  per  1,000 MW electricity produced, a ten fold
reduction from previous practice at the time [NCRP, 1980]. Diethorn and Stockho [1972] from the Nuclear
Engineering  Department  of  Pennsylvania  State  University  concluded  that “…although  the  dose  from
krypton-85 is small, …there seems to be little justification for continuing the present world-wi de practice of
dumping it into the atmosphere (…) the only solution for krypton -85 is permanent storage.” Eisenbud [1987]
has stated  “if... fuel is reprocessed, 90% of the krypton -85 must be removed for extended storage until the
gas has decayed sufficiently for release.”

7.2.3. Iodine-129

Iodine-129  discharges  from  La  Hague  during 1975-1992  are  estimated  to  be  about  632 kg,  and  from
Sellafield  during 1967-1992  about  608 kg:  the  total  from  the  two  plants  up  to 1992  is  therefore  about
1.2 tonnes.  This  is  10 times  larger  than  the  total  iodine-129  present  in  the  oceans  before  the  nuclear  era,
approximately 25 times that released by nuclear weapons testing, and several hundred times that released by
Chernobyl. [Raisbeck et al, 1995]

In  the  period  from 1993-1998,  a  further  1.4 tonnes  of  iodine-129  were  discharged  from  La  Hague
and 0.36 tonnes  from  Sellafield,  i.e.  discharges  in  the  6  years  after  1992  were  more  than  in  the
previous 25 years. Iodine-129 discharged from La Hague and Sellafield in 1999 was eight times greater than
the total iodine-129 released by the total fallout from all weapons testing.

In comparison, annual reprocessing emissions of caesium-137 and strontium-90 were never larger than 1%
of cumulative nuclear weapons fallout.

Most La Hague discharges follow sea currents through the English channel to the North Sea, and Sellafield
discharges flow mostly north around the Scottish coastline then also into the North Sea. Iodine-129  transit
time from La Hague to the Norwegian coast is about 3-4 years. Iodine-129 discharges from both Sellafield
and La Hague have risen over the past decade by a factor of about five.

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7.3.  COLLECTIVE DOSES FROM REPROCESSING RELEASES

7.3.1. Collective Doses from Reprocessing

The process of reprocessing results in large-scale releases of long-lived nuclides, which are mobile and are
distributed  throughout  Europe  and  the  world.  These  nuclides  include  tritium,  carbon-14,  chlorine-36,
krypton-85,  technetium-99  and  iodine-129.  The European  Commission  has  constructed  models,  which
estimate  doses  to  the  UK,  Europe  and  the  world  from  distributions  of  carbon-14,  tritium  and  iodine-129
nuclides.  A  rudimentary  model  also  exists  for  krypton-85,  which  is  assumed  to  remain  a  gas  and  not  to
interact  with  the  biosphere,  lithosphere  and  hydrosphere.  No  models  yet  exist  for  the  global  transport  of
chlorine-36 and technetium-99 although it is understood that the UK NRPB is presently considering a model
for  technetium-99.  Little  data  exist  for  the  source  term  of  chlorine-36  in  spent  fuel,  and  its  subsequent
environmental transport. This is a subject for future research.

The  following  tables  present  European (8a  and b)  and  global (9a  and b)  collective  doses  from  tritum,
carbon-14,  krypton-85  and  iodine-129  releases  in 1999.  These  have  been  estimated  simply  by  applying
Person Sv/TBq  conversion  factors  to TBq  discharges  from  Sellafield  and  La  Hague  in 1999.  Relevant
conversion factors were obtained from [Simmonds, 1996] and [Mayall, 1993].

Totals are rounded to two significant figures, as global and regional models use parameters whose values are
correct only to two significant figures.

7.3.1.1.  European Doses

Table 8a European Collective Doses from 1999 Discharges at Sellafield

Nuclide

Carbon-14

Iodine-129

Krypton-85

Tritium

Total

Aerial

Liquid

Aerial

Liquid

Aerial

Aerial

Liquid

Dose Coefficient
(Person Sv/TBq)

Sellafield Releases
(TBq)

European Dose
(Person Sv)

7.97

8.33

107.4

481

0.000037

0.0016

0.0000037

2.9

5.8

0.0025

0.48

100,000

622

1,800

23

48

0.3

230

3.7

1

0.007

300

Table 8b European Collective Doses from 1999 Discharges at La Hague

Nuclide

Carbon-14

Iodine-129

Krypton-85

Tritium

Total

Aerial

Liquid

Aerial

Liquid

Aerial

Aerial

Liquid

Dose Coefficient
(Person Sv/TBq)

La Hague Releases
(TBq)

European Dose
(Person Sv)

7.97

8.33

107.4

481

0.000037

0.0016

0.0000037

19

10

0.0074

1.83

300,000

80

12,900

150

83

0.8

880

11

0.13

0.05

1,100

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7.3.1.2.  Global Doses

Table 9a Global Collective Doses from 1999 Discharges at Sellafield

Nuclide

Carbon-14

Iodine-129

Krypton-85

Tritium

Total

Aerial

Liquid

Aerial

Liquid

Aerial

Aerial

Liquid

Dose Coefficient
(Person Sv/TBq)

Sellafield Releases
(TBq)

Global Dose
(Person Sv)

115

115

9,454

690

0.004

0.002

0.00004

2.9

5.8

0.0025

0.48

100,000

622

1,800

330

670

24

330

400

1.2

0.07

1,800

Table 9b Global Collective Doses from 1999 Discharges at La Hague

Nuclide

Carbon-14

Iodine-129

Krypton-85

Tritium

Total

Aerial

Liquid

Aerial

Liquid

Aerial

Aerial

Liquid

Dose Coefficient
(Person Sv/TBq)

La Hague Releases
(TBq)

Global Dose
(Person Sv)

115

115

9,454

690

0.004

0.002

0.00004

19

10

0.0074

1.83

300,000

80

12,900

2,180

1,150

70

1,260

1,200

0.16

0.52

5,900

Until recently it had been assumed that collective doses from tritium, carbon-14, krypton-85 and iodine-129
would  constitute  over 99%  of  total  Regional/Global  collective  doses  from  all  nuclides  released.  It  is  now
understood  that  technetium-99  will  also  become  globally  distributed  and  will  add  to  Regional/Global
collective  doses.  Although  no  global  model  has  yet  been  constructed  for  technetium-99,  preliminary
estimates  by  Fairlie  and  Sumner [2001]  indicate  that  the  global  untruncated  dose  from  the  70 TBq  of
technetium-99 released from Sellafield in 1999 might add about 700 person Sv to the total global dose from
Sellafield releases, and about 4 person Sv to the European dose. Technetium-99 releases from La Hague are
relatively low.

7.3.2. Commentary on Collective Doses from Sellafield and La Hague

The previous tables indicate that, each year, the Sellafield and La Hague reprocessing plants release nuclides
that  result  in  a  collective  dose  to  Europe’s  population (600 millions)  of  approximately  1,400 person Sv.
Expressed in global terms, each year, the two plants release nuclides which result in a collective dose to the
world’s  population (6 billion)  of  approximately  7,700 person Sv.  These  doses  will  be  delivered  gradually
over many millennia to future generations throughout Europe/the world.

As  discussed  in Annex 6,  many  uncertainties  exist  over  whether  these  doses  will  actually  occur  in  the
absolute  sense.  Nevertheless,  given  the  information  available  to  us  today  and  given  currently  accepted
models of radiation effects, these are the best estimates available to us of future radiological detriment from
reprocessing releases at the two sites.

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7.3.3. Use in Comparative Studies

Because  of  these  uncertainties,  it  is  recommended  that  the  European  Parliament  should  consider  collective
dose estimates in a relative, rather than absolute, sense. In other words, these estimates should be used as a
tool to make comparisons with collective doses from other processes, in order to inform decision-making and
policy.  The  UK  NRPB’s  Board  Statement  on  Radiological  Protection  Objectives  for  the  Land-based
Disposal of Solid Radioactive Wastes [NRPB 1992] has stated (paragraph 73) that comparisons of collective
doses from different options were more reliable than absolute values. For example, it stated that collective
dose estimates may be used in design studies of planned repositories to compare different options.

Table 10 Global Collective Doses From Anthropogenic Radiation Sources

Source of Exposure

Chernobyl Accident

World Nuclear Power Production to 1989

World Radioisotope Production and Use to 1989

World Nuclear Weapons Fabrication to 1989
La Hague Reprocessing for 10 years(1)
Sellafield Reprocesing for 10 years(2)
Kyshtym Accident USSR 1957

Windscale Accident UK 1973

World Underground Nuclear Testing to 1989

Three Mile Island Accident US 1979

(1) Estimated from 5,900 person Sv/year x 10 years
(2) Estimated from 1,800 person Sv/year x 10 years

Global collective dose (Person Sv)

600,000

400,000

80,000

60,000

~ 59,000

~ 18,000

2,500

2,000

200

40

Source: Bennett, 1995; UNSCEAR, 1993

Similarly  with  reprocessing,  collective  doses  from  discharges  may  be  compared  with  collective  dose
estimates  from  other  nuclear-related  activities.  For  example, 
the  European  collective  doses  of
300 person Sv (from Sellafield) and 1,100 person Sv (from La Hague) may be compared with the reference
level for releases from Swedish nuclear reactors of 5 person Sv per GWyear capacity.

Other comparisons are made in Table 10 which ranks collective doses from other nuclear processes/accidents
with collective doses from 10 years’  discharges from Sellafield and La Hague, using figures from the latest
available year, 1999. Future life expectancies of these plants is understood to be at least 10 years, based on
information from internal industry sources.

7.3.4. Use in Cost/Benefit Studies

To compare costs and benefits of options which have no common comparator (e.g. to compare the costs of
new abatement facilities with the discharges they may save), collective dose estimates may be converted to
fatalities  using  the  conventional ICRP  radiation  risk  factor  of 5%  per  person Sv,  and  fatalities  may  be
converted to £, $ or €  values using monetary values per statistical life. The two costs may then be compared
as occurs in conventional Cost-Benefit Analysis techniques. Conventionally, this procedure is shortened to
adopting a £, $ or €
 value per person Sv saved. Unfortunately the range of values of a person Sv is wide and
has been reported as extending from £20,000/person Sv in 1988 prices to £100,000/person Sv in 1990 prices.

The UK Department of Transport value of £700,000 per life has been used in cost benefit analyses in road
traffic  studies.  It  is  equivalent  to  a  person Sv  value  of  £35,000  using  a  fatal  cancer  risk  of  5%  per  Sv.  In
1995, the European Commission used a value of £2 million (US $3 million) in its statistical valuation of a
life for the external costs of fuel cycles, equivalent to a person Sv value of £100,000 [CEC, 1995]. Indeed,
the  latter  figure  is  used  by  BNFL  to  reflect “statistical  risk  and  corporate  profile”  [Robb,  1990].  These
figures are set out in Table 11.

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Table 11 Values of Person Sv

Agency

UK NRPB

UK Dep’t of Transport

BNFL

European Commission

US NRC

Year

1991

1992

1991

1995

1995

Value Of Statistical Life (£)

Value Of Person Sv (£)

–

700,000

–

2,000,000

–

 20,000

 35,000

100,000

100,000

133,000

Sources: [CSERGE, 1992; Robb and Croft, 1990; UK Department of Transport, 1992; Robb, 1994; CEC, 1995]
and [NRC, 1995; at conversion rate of £1= $1.50]

A  reasonable  figure  for  comparison  purposes  is  the  figure  derived  from  the  European  Commission’s
£2 million value of a human life i.e. £100,000 per person Sv. When applied to untruncated global doses from
10 years’  of Sellafield and La Hague releases, the values in Table 12 are obtained.

Table 12 Maximum Values for Optimisation Measures

Annual
Global Doses

Global Doses
Over 10 Years

Value Per
Person Sv £

Maximum Values
£ Billion

Sellafield

La Hague

1,800

5,900

18,000

59,000

100,000

100,000

1.8

5.9

Sources: see Table 11

In optimisation studies (i.e. studies to reduce doses as low as reasonably achievable), expenditure up to these
amounts  should  be  considered  for  remedial  or  abatement  measures  to  reduce  these  doses.  These  are  very
large  sums:  the  amounts  that  could  be  spent  on  abatement  measures  comfortably  exceed  annual  operating
profits at each site.

7.3.5. Chapter Conclusions

This chapter has derived global untruncated collective doses from annual reprocessing releases at Sellafield
and  La  Hague.  In  order  to  assist  the  Committee  on  Petitions  assess  the  significance  of  these  doses,  this
chapter  has  compared  these  doses  with  other  nuclear  related  activities  and  has  valued  them  using
conventional Cost Benefit Analysis techniques.

The results are that global untruncated collective doses from annual reprocessing releases may be seen to be
very large relative to other nuclear processes. When valued in monetary terms, the valuations are also very
large. For example, they easily exceed the annual operating profits of Sellafield. From these considerations,
continued  operation  of  these  plants  do  not  appear  to  fulfil  conventional  expectations  of  commercial  or
radiological  justification.  Clearly,  their  continued  operation  depends  on  other  matters,  including  social  and
political  factors,  which  lie  outside  the  scope  of  this  report  and  remain  for  the  Committee’s  and  the
Parliament’s consideration.

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8. ALTERNATIVE OPTIONS

From  a  global  perspective,  the  so-called  “alternative  options”  to  reprocessing  are  in  fact  the  preferred
options:  most  spent  fuel  discharged  from  reactors  worldwide 
is  not  reprocessed.  The  United
Nations [UNSCEAR, 2000] has stated that only about 5% to 10% of world spent fuel arisings is submitted
for reprocessing: the rest is stored pending final disposal in a repository. Among the countries that operate
nuclear reactors, a majority does not reprocess their spent fuel. At national level, most countries have only
reprocessed  part  of  their  irradiated  fuel.  Even  countries  that  have  made  a  clear  choice  and  pretend  to
reprocess all of their spent fuel, like France or the UK, have left large stocks unreprocessed. As of the end
of 1998,  only 17,000 tonnes  of  the  30,000 tonnes  of  spent  fuel  unloaded  from  the  French  reactors (of  all
types) had been reprocessed [Coeytaux et al, 2000].

Most  countries  are  moving  towards  storage  as  a  medium-term  strategy  for  spent  fuel.  According  to  the
IAEA [1999], new developments in spent fuel management concern storage rather than reprocessing and dry
rather than wet storage.

This evolution corresponds to a clear decline of the rationale for reprocessing. Storage of spent fuel over the
medium-term (20  to  40  years)  or  long-term (>40  years)  is  increasingly  viewed  as  a  more  attractive
management option than reprocessing spent fuel. This is particularly the case with dry storage compared to
wet storage, i.e. in fuel ponds.

8.1.  WASTE MANAGEMENT ISSUES

Compared to direct disposal of the irradiated fuel, reprocessing is sometimes presented as a way of sorting
waste  and  recycling  valuable  resources –  i.e.  the  uranium  and  plutonium contained  in  spent  fuel.  This
attractive theory does not stand up to rigorous scrutiny, as recent studies have shown (see below).

8.1.1. Re-use of plutonium and uranium

After the closure of the fast-breeder reactor Superphénix in France (decided in 1997), the use of MOX (mix
of oxides of uranium and plutonium) in light water reactors is the only rationale left for the reprocessing of
spent fuel. Similarly, the use of REPU (uranium from reprocessing) instead of conventional uranium in fuel
is the only way to re-use uranium.

In the UK, there is no program for the use of MOX fuel. In France, 20 reactors have the license to operate a
maximum of 1/3 MOX loading. Only two reactors use re-enriched reprocessed uranium fuel.

As  of  the  end  of  1998,  the  French  reprocessing  program  has  led  to  the  separation  of  around  84 tonnes  of
plutonium contained in French spent fuel, or just more than one third of the total plutonium content of the
cumulated  unloaded  fuel (around  223 tonnes  of  plutonium  in  30,000  tonnes  fuel).  From  these  84 t,  only
41.9 t had been re-used at the time, or less than 20% of the total production of plutonium in French nuclear
reactors.  Some  of  these  results  are  detailed  in Annex 26.  The  situation  is  even  worse  as  regards  uranium,
with only 5.5% of the total uranium content of spent fuel unloaded from French reactors being re-used at the
end of 1998 [Coeytaux, 2000].

A recent study, commissioned by the French Prime Minister [Charpin et al, 2000] clearly demonstrates the
additional cost of reprocessing scenarios. Annex 27 sums up the detailed material and economic balances of
the 58 French PWRs (Pressurized Water Reactors), from the first year of operation in 1977 to the theoretical
shut down of the last reactor in the years 2040s. One key result of this study is to show that, over the lifetime
of  operating  reactors,  reprocessing  could  only  reduce  by  some  15%  the  quantities  of  plutonium  in  final
waste,  assuming  that  all  MOX  fuel  and  some  of  the  uranium  fuel  would  not  be  reprocessed –  as  it  is
presently the case. This allows for an economy in natural uranium of around 8%. These results are obtained
at very high cost. Each ton of plutonium that is effectively avoided through reprocessing/reuse and not going
into final disposal costs about 1 billion FRF.

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8.1.2. Final volume of waste

Reprocessing requires the final disposal of vitrified wastes plus the direct disposal of some spent fuel, and
various  additional  wastes  produced  through  reprocessing,  such  as  bituminised  waste,  hulls  and  nozzles,
technological  waste,  and  most  separated  plutonium  and  uranium  which  is  not  re-used.  Not  only  does  the
direct disposal option produce fewer waste categories, it also produces smaller volumes of final waste. Spent
MOX fuels have much higher heat outputs than spent uranium fuels, and thus require much longer storage
times before disposal and/or much larger volumes in any final repository.49 These factors imply much larger
costs for handling spent MOX fuel than ordinary uranium fuel.

According  to  preliminary  specifications  defined  by ANDRA  in 1998  for  final  disposal  in  a  deep  ground
repository in clay,50 the same type of small galleries –  only  with  different  lengths –  could  be  used  to  store
either  canisters  of  vitrified  waste,  or  UOX  or  MOX  spent  fuel.  One  gallery  could  receive  8 canisters  of
vitrified waste, or 4 so-called S3U packages, each containing 3 assemblies of spent UOX, or 2 SM packages,
each containing 1 assembly of spent MOX. The respective length of the galleries would be around 20, 28 and
17 m;  the  volume  of  one  package (including  overpack  of  the  canister)  is  around  0.5,  4.1  and 1.9 m3.
Assuming that the reprocessing of one UOX assembly in La Hague produces around one canister of vitrified
waste, these ANDRA concept lead to the following volume orders:

• Disposal of vitrified waste from the reprocessing of 1 UOX assembly:

0.5 m3 of package, 12.5 m3 of package plus structure;

• Direct disposal of 1 spent UOX assembly:

1.4 m3 of package, 11.5 m3 of package plus structure;

• Direct disposal of 1 spent MOX assembly:

1.9 m3 of package, 42.5 m3 of package plus structure.

These results can be used for a basic comparison of the two options: (a) the direct disposal of 8 UOX  and
(b) the reprocessing of 7 UOX plus the direct disposal of 1 MOX.51 For 8 assemblies, the reprocessing option
only produces 5.5 m3 of HLW, while the direct option produces 11 m3. But, if including the volume of the
structures in the calculation, the ratio is of 92 m3 for direct disposal against 130 m3 for reprocessing. Again,
this  is  not  taking  into  account  the  additional  waste  in  the  reprocessing  option,  like  unrecycled  uranium,
technological and process ILW from reprocessing, etc.

8.2.  ECONOMICS OF DIRECT DISPOSAL VS. REPROCESSING

The economic advantages of direct storage of spent fuel versus reprocessing are considerable. In simplified
terms, reprocessing may be viewed 2 to 3 times more expensive than wet storage, and wet storage about 4 to
20 times more expensive than dry storage. It is not surprising that, in worldwide terms, nuclear utilities are
moving  towards  dry  storage  solutions,  including  utilities  in  the  US,  Canada,  Germany,  Russia  and  many
eastern European countries.

Comparative costs studies of storage and reprocessing routes conventionally require examination of the costs
of  all  stages  of  the  fuel  path  from  reactor  discharge  through  to  final  (often  termed  “direct”)  disposal  in  a
permanent  repository.  Four  major  studies  have  examined  these  matters:  the  German  utilities  studies,  the
OECD/NEA study, the EWI study at the University of Köln, and the recent Charpin study in France. Their
main results are presented in Table 13 after they are briefly summarised.

• German  Utilities  Studies.  Main  German  utilities  studies  were  carried  out  by  three  German  institutes,
Rhine-Westfalische Energie (RWE) utility, Vereinigung Deutscher Elektrizitätswerke (VDEW) the German
Fuel Industry Association, and Projekt Andere Entsorgung at the Kernforschungszentrum Karlsruhe (PAE-

49 Belgian radioactive waste management schemes envisage 3 times the volume in final storage for spent MOX than for

spent uranium fuels. The costs are correspondingly higher.

50  Communication by ANDRA, 2000.
51  This  is  assuming  that  the  reprocessing  of  7 UOX  produces  the  right  amount  to  produce  1 MOX,  that
7 UOX + 1 MOX deliver as much energy as 8  UOX  and  that  in  the  reprocessing  option  all  UOX  and  none  of  the
MOX is reprocessed.

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KfK),  a government-funded  research  agency  in  the  early  1990s.  These  predicted  direct  disposal  would  be
approximately 50% (RWE and PAE-KfK) to 70% (VDEW) less expensive than reprocessing.

Other national studies agree with these studies. A report by the German Federal Rechnungshof [BRH, 1993],
the national parliamentary audit office, stated that reprocessing had become twice as expensive as storage,
and  that  reprocessing  was  no  longer  feasible.  In  a  report  prepared  for  the  Irish  government  on  THORP,
Berkhout [1993]  estimated,  using  conservative  assumptions, 
that  dry  storage/disposal  costs  were
approximately half reprocessing/disposal costs.

• OECD/NEA Study. In 1994, the OECD/NEA examined levelised lifetime fuel cycle costs [OECD/NEA,
1994]. The report was concerned to develop fuel costs averaged over the whole fuel cycle. The consequence
was that relevant costs were calculated on a lifetime basis and not discounted to a start up date. This resulted
in reprocessing and once through costs being about equal.

However  the  chairman  of  the  OECD  Expert  Group  which  drafted  the  report  refuted  the  report’s  main
conclusions [NuclearFuel, 1995a]. The chairman, Dr. David Groom of UK’s  Nuclear  Electric (now  British
Energy),  stated  that  back-end  costs  were  not  spread  over  the  whole  fuel  cycle,  and  that  reprocessing  costs
were incurred immediately. On the other hand, most storage, and all encapsulation and disposal costs would
occur many years hence and could be discounted at 5% over decades. COGEMA, whose directing manager
was  chairman  of  OECD’s  Steering  Committee  for  Nuclear  Power,  replied  stating  that  discounting  to  this
extent was inappropriate [NuclearFuel, 1995b]. This issue remains unresolved by the OECD.

The  figures  that  reflect  the  view  taken  by  the  Chairman  of  the  Expert  Group  are  as  follows:  with  $340
per kg HM (range $85-410), direct disposal is more than twice cheaper than reprocessing, which total cost is
$775 per kg HM (range $565-830). This approach is preferred as it reflects more accurately the position of
utilities and governments faced with the decision between storage and reprocessing. The figures indicate that
in  the  reference  case  the  predicted  costs  of  the  storage  route  were  less  than  half  the  predicted  costs  of  the
reprocessing route.

The main conclusion reported by the chairman of the OECD Expert Group was that storage was predicted to
be half the cost of reprocessing. Nevertheless, the OECD report was criticised by the EWI report [Hensing
and Schulz, 1995] – see below – for unrealistic assumptions, which substantially reduced reprocessing costs.
These included the postponement of reprocessing to the year 2006, high uranium prices, new reprocessing
plant  being  built,  a  low  price  for  reprocessing  services,  and  a  low  price  for  MOX  fuel  fabrication.  In
addition,  the  OECD  report  used  a  positive  value  for  plutonium ($5,000/kg)  and  uranium ($33-$135/kg)
extracted  from  reprocessing.  These  assumptions  were (and  are)  not  widely  followed.52  For  these  reasons,
OECD estimates of reprocessing costs are considered to have limited applicability.

• EWI  Report.  The  Energie  Wirtschaftliches  Institut  (EWI)  at  Köln  University  evaluated  various  waste
disposal options from the viewpoint of a nuclear utility [Hensing and Schultz, 1995]. The EWI Institute has
close working contacts with the German nuclear industry. The study carried out a comprehensive financial
appraisal  of  both  the  storage  and  reprocessing  routes  using  a  zero  discount  rate.  It  concluded  that  direct
disposal  had  a  clear  cost  advantage  over  the  reprocessing  option  with  the  disposal  cost  option  being  48%
lower  than  that  of  reprocessing  option.  Calculated  over  the  German  nuclear  industry,  the  cost  advantage
amounted to 31.5 million DM or $20 million per year. The report stated that its estimated disposal costs were
lower than those calculated by the German Fuel Industry Association due to assumed higher fuel burn-ups in
the EWI scenario.

• Charpin  Study.  The  recent  study  commissioned  by  the  French  government [Charpin et al, 2000]
illustrated the additional cost of reprocessing plus MOX scenarios. The “all reprocessing”  scenario produced
additional  costs  of FF39 billion,  in  comparison  with  the  “abandonment  of  reprocessing  in  2010”  scenario,
representing FF800 million per year of remaining power plant life. The storage option was much less costly:
total savings compared to the reprocessing scenario were FF164 billion (5.5% of total cost), i.e. a saving of
more  than FF2 billion  per  year  over  remaining  power  plant  life,  or  around  FF2.7 billion  per  GWe.  This
saving is reflected in total average cost per kWh of 13.65 centimes, 0.5 to 1.5 centimes lower than average
costs in other scenarios (see Annex 27).

52  The French utility EDF, for example, attributes a zero monetary value to its plutonium stocks.

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• Comparison  of  costs  per  kWh.  Table  13  below  sets  out  results  of  studies,  which  have  compared  costs
per kWh  of  storage/disposal  and  reprocessing  options.  Strictly  speaking,  these  studies  are  not  comparable
because of different assumptions employed and different values in currencies at various times, however the
ratios  in  the  final  column  may  be  compared.  Storage/direct  disposal  is  consistently  less  expensive  than
reprocessing, whichever method, part of the fuel cycle, or discount rate is used.

Table 13 Fuel Cycle Costs (1)

Study

Stages
compared

Discount

Rate Reprocessing

Direct
Disposal

Ratio Reprocessing
to Disposal Costs

Back-end
KfK/EWI [1984]
Complete fuel cycle
OECD/NEA [1985]
Back-end
Fichtner [1991]
VDEW [1993]
Back-end
OECD/NEA [1994] (2) Complete fuel cycle
OECD/NEA [1994] (3)
Back-end
Back-end
EWI [1995]
Charpin et al [2000] (4)
Back-end
Complete fuel cycle

0%
5%
0%
0%
5%
5%
0%
0%
0%

0.56
>2.17
0.97
1.53
1.25
0.36
1.064
1.82
4.68

0.38
1.97
0.63
0.91
1.09
0.15
0.718
0.99
4.02

1.47
<1.10
1.54
1.68
1.15
2.40
1.48
1.83
1.16

(1) Pfennig/kWh 1994, current prices in year of study, except OECD- in 1991 $, Charpin et al in 1999 FF.
(2) Reference case reported as “lifetime levelised fuel cycle costs”.
(3) Reference case reported in tables 5.7 and 5.8 of the OECD report as sub-totals for the back-end of the fuel cycle.
These figures, calculated by discounting to the year 2006 using a 5% discount rate, were explicitly referred to by
the chairman of the OECD study group in his intervention [NuclearFuel, 1995a] following the publication’s report.
The disjunction between discounted and lifetime levelised estimates is not discussed in the OECD report.

(4) This  study  is  not  centred  on  the  fuel  cycle,  but  calculates  detailed  costs  of  the  nuclear  option  over  the  French

nuclear fleet operational lifetime. The general results of this study are detailed in Annex 27.

Sources: VDEW –  as reported in Nuclear Fuel [1994], [NEA, 1994; Hensing and Schultz, 1995; Charpin et al 2000].

8.3.  DRY STORAGE

For  nuclear  waste  management  policies,  an  important  issue  is  the  degree  to  which  dry  storage  may  be
considered a viable long-term option for managing spent fuel. Dry storage in inert gas presents relatively few
theoretical  or  practical  difficulties.  The  IAEA  has  concluded  after  reviewing  national  experiences  of  dry
storage  that  it  is  an  acceptable  waste  management  option  for  the  storage  of  spent  fuel  for  periods  of 50  to
100 years [IAEA, 1996]. By this time heat rates will have declined by about two orders of magnitude. The
anticipated longevity of dry stores (50 to 100 years) is expected to exceed that of wet stores [Schneider and
Mitchell,  1992a].  It  is  concluded  that  passive  dry  storage  systems  appear  to  be  an  acceptable  means  of
managing spent nuclear fuel in the medium to long term. When reprocessing and dry storage are compared,
large  differences  in  costs  become  apparent:  the  former  are  clearly  greater  than  the  latter.  US/Canadian
storage  systems  are  less  expensive  than  European  systems:  US  dry  storage  systems  for  PWR  fuel  are
estimated to be 8 to 20 times less expensive per tonne than reprocessing [Supko, 1995; Wisconsin PSC, 1994].

Dry stores are considerably less expensive to construct and to operate than wet stores: annual costs are about
a  factor  of  4  lower.  Dry  stores  also  seem  to  have  a  much  higher  acceptability  than  any  other  spent  fuel
management  option.  Environmental  and  local  groups  in  some  countries  have  not  opposed  dry  storage
developments.  This  was  evidenced  by  the  1987  agreement  among  major  UK  environmental  groups,
supported by over 40 regional and local groups, to a collective strategy of long-term on-site storage. During
the  1992-1994  UK  public  inquiry  into  Scottish  Nuclear’s  dry  storage  plans [Hickman,  1994],  no
environmental  group  made  representations  against  the  plans.  Dry  storage  technologies  and  economics  are
detailed in Annexes 28 and 29 respectively.

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9. POLICY OPTIONS

The following outline of policy options for the official actors involved in the reprocessing industry is based
on a first set of suggestions contained in the Intermediate Report of 2 April 2001. The STOA Study Group
has  invited  comments  on  these  proposals,  in  particular  from  MEPs,  but  has  received  few  responses.  The
options have been modified and further options added in order to take the development of the project and the
comments received into account.

The STOA Study Group has identified five main areas of concern:

• Releases of Radioactive Wastes and Their Effects on the Environment and Health

• Management of Non-Discharged Radioactive Wastes

• Management of Plutonium Stocks

• Development of Spent Fuel Management Alternatives

• Development of Democratic Decision Making Tools

Following  comments  during  the  Scoping  Meeting  and  the  presentation  of  the  Intermediate  Report,  the
research has been focussed on the evaluation of environmental and health effects. However, on each of the
areas  identified,  we  look  at  policy  options  for  the  European  Parliament,  the  European  Commission,  the
European Council of Ministers, the Governments of Member States and the Nuclear Industry.

There are a certain number of possible policy options that are applicable for all of the five areas identified.
The European Parliament has passed a certain number of resolutions on the issue of nuclear reprocessing and
associated matters (i.e. nuclear transports). It is unclear under what procedure the European Parliament has
followed up the application of its resolutions and its effects. The European Parliament might wish:

1. 

2. 

3. 

to  reflect  on  a  clearly  defined mechanism  in  order  to  periodically  evaluate  the  follow  up  of  its
resolutions by the relevant institutions;

to clarify what time frame is allocated to its requests, in particular to the European Commission and the
European Council;

to reflect on procedures that better take into account the interactions  between  issues  and  therefore  the
different  parliamentary  committees  (in  particular Industry,  External  Trade,  Research  and  Energy,
Environment, Public Health and Consumer Policy, Budgets).

Possible policy options concerning specific issues:

9.1.  RELEASES OF RADIOACTIVE WASTES AND THEIR EFFECTS

ON THE ENVIRONMENT AND HEALTH

The  reprocessing  industry  releases  very  large  amounts  of  radioactivity  into  the  environment.  A  certain
number  of  measures  have  been  taken  in  the  past  in  order  to  regulate  and  limit  these  discharges.  Other
measures to further reduce discharges are as follows: The application of Best Available Technology (BAT) is
already  required  under  decisions  taken  by  signatory  countries  of  the  OSPAR  Convention  (of  which  12  are
EU countries). The decisions taken by the Copenhagen meeting of OSPAR in July 2000 require a review of
current  authorisations  for  discharges  from  reprocessing  facilities “as  a  matter  of  priority”   with  a  view  to
“implementing the non-reprocessing option (for example dry storage) for spent nuclear fuel management at
appropriate  facilities.”  The  European  Commission  and  the  reprocessing  countries  France  and  the  UK
abstained from voting on this decision, while the other 10 EU countries voted in favour.. Nevertheless, it is
clear that neither BAT nor the Copenhagen decision is being applied at Sellafield and La Hague. Therefore
the following Policy Options should also be considered.

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4.  The European Parliament should consider ways of encouraging the European Commission to press for
the interests of the large majority of EU countries by limiting radioactive discharges from reprocessing
plants.

5.  The  reprocessing  industry  should  respect  decisions  taken  under  internationally  binding  conventions  to

put into practice BAT in order to decrease significantly radionuclide releases.

6.  National  regulatory  agencies  should  require  the  reprocessing  industry  to  respect  the  decisions  taken

under international conventions and in particular under OSPAR.

7.  The European Commission, while it has published a Recommendation on the application of article 37 of
the EURATOM Treaty,53 has not demonstrated that it is in a position to guarantee that Member States
respect  the  basic  safety  standards  (96/29/Euratom).  The  European  Commission  should  clarify  in  its
public statements on environmental and health impact, and in its answers to MEPs in particular, to what
extent its conclusions are based on its own expertise and to what extent they are depending on Member
States’  data.

8.  The European Commission should require Member States to make public the general data on which its
opinions are based. Specific parts of the data, whose commercially confidential nature must be justified,
can be deleted from the documents.

9.  The  European  Commission,  as  envisaged,  should  carry  out  its  own  sampling  and  measurements  in  the

framework of its Article 35 verifications.

10. The  European  Parliament  should  strongly  support  efforts  by  the  European  Commission  to  increase  its

verification capacities under Article 35, including in the budgetary decision-making.

11. Operators and supervisory agencies should be obliged to increase the number of radionuclides measured
in effluents - in particular in gaseous effluents at La Hague- and their concentrations in the environment.

12. The European Commission should publish its evaluation of the health impact of radioactive discharges
into  the  environment  at  Sellafield  and  La  Hague,  in  particular  based  on  information  transmitted  by
Member  States  under  Commission  Recommendation 2000/473/Euratom.  The  data  published  should
include the details of dose calculations and justified uncertainty margins.

13. The  European  Council  should  follow  up  on  Euratom  Directive  96/29  on  radiation  safety  standards.

Implementation  in  Member  States  was  to  have  occurred  before  13  May  2000.  Article 6 (2)  says  that
“existing classes or types of practice may be reviewed as to justification whenever new and important
evidence about their efficacy or consequences is acquired.” Current licensing requests by COGEMA for
its  La  Hague  facilities  as  similar  requests  for  various  facilities  at  Sellafield  should  be  examined
according to the justification principle.

14. Some  long-lived  mobile  radionuclides  from  Sellafield  and  La  Hague  result  in  the  long-term
contamination  of  Europe  and  the  world.  For  example,  iodine-129  has  a  half-life  of  some  16  million
years.  Dose  assessments  in  the  framework  of  licensing  procedures  should  always  be  conservative  in
order to protect current and future generations. The European Commission should take this aspect into
account  when  considering  guidance  on “realistic  dose  assessments”  under  Article  45  of  Euratom
Directive  96/29.  Member  States  should  modify  licensing  procedures  of  nuclear  facilities  to  require  the
transparent  evaluation  of  collective  doses  from  radionuclide  releases  for  all  affected  populations  over
untruncated time periods.

15. The  European  Commission  should  investigate  in  detail  and  report  to  the  European  Parliament  on  the
extent  to  which  the  global  and  long-term  natures  of  nuclides  discharged  by  Sellafield  and  La  Hague
facilities have been taken into account.

16. The  European  Commission  should  give  detailed  consideration  to  expressing  acceptable  limits  (for
exposures to nearby residents) in terms of nuclide concentrations in biota and foodstuffs, as well in terms
of  doses.  This  would  be  similar  to  Community  Food  Intervention  Levels  (CFILs)  used  in  the  case  of
acute releases.

53 1999/829/Euratom.

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17. The European Commission and Member States should encourage more research on the distribution and

dosimetry of low energy nuclides particularly within cell nuclei.

18. Results from the quantitative analyses of uncertainties in radiation doses and risks in the La Hague area,
underway at present, should be made widely available. A similar study should be carried out for the area
around Sellafield.

19. European  Parliament  should  call  for:  (i)  appropriate  treatment  in  the  ongoing  Marina  study  of  factors
such as uncertainty, variability and the potential for re-mobilisation of radionuclides from sediments; and
(ii) an ongoing process for review of, and input to, the Marina study.

20. The  European  Commission  should  examine  the  impact  of  chemical  discharges  from  Sellafield  and  La

Hague into the environment and their potential synergies with radionuclide releases in risk assessments.

21. The  European  Parliament  (through  STOA)  should  convene  a  conference,  as  recommended  by  the
German  Office  of  Radiological  Protection  (BfS),  to  discuss  national  dose  models  and  model
assumptions,  given  the  apparent  variation  in  doses  estimated  by  models  used  by  national  regulatory
agencies in Europe.

22. Statistically significant increases in the incidences of childhood leukaemia near Sellafield and La Hague
continue  to  the  present  day.  To  date,  no  conclusive  causal  link  with  doses  from  environmental
radioactivity has been established by national radiation authorities. Nevertheless, it cannot be excluded
that  radionuclide  releases  from  the  reprocessing  plants  are  the  initiating  and/or  contributing  factor.
Significant uncertainties remain, in particular in the areas of cellular dosimetry and environmental dose
assessments..  Under  these  circumstances,  the  continued  release  of  large  quantities  of  radionuclides  is
clearly  inconsistent  with  the  Precautionary  Principle.  The  European  Parliament  should  consider
requesting  an  immediate  moratorium  on  further  radionuclide  releases  to  the  environment  until  these
uncertainties have been elucidated.

9.2.  MANAGEMENT OF NON-DISCHARGED RADIOACTIVE WASTES

The Agenda-21, part of the Rio 1992 Convention, in its Chapter 22 asks that the States “should not promote
or allow the storage or disposal of high-level, intermediate-level and low-level radioactive wastes near the
marine  environment  unless  they  determine  that  scientific  evidence,  consistent  with  the  applicable
internationally agreed principles and guidelines, shows that such storage or disposal poses no unacceptable
risk to people and the marine environment or does not interfere with other legitimate uses of the sea, making,
in the process of consideration, appropriate use of the concept of the precautionary approach.”  There are
vast amounts of waste stored and disposed of at Sellafield and La Hague.

23. The UK and France should provide evidence that the storage and disposal methods at Sellafield and La

Hague are in accordance with the letter and spirit of Chapter 22 of the Agenda-21.

24. Generally,  Member  States  should  adopt  a  responsible  attitude  towards  the  management  of  spent  fuel
options. In particular, national regulatory agencies should implement policies requiring that passivity of
spent fuel forms be addressed by utilities. Passivity involves the adoption of spent fuel policies whereby
the  final  waste  form  requires  the  least  inputs  for  human  intervention  and  control,  including  posing
reduced threats from diversion and proliferation.

25. The  European  Parliament  should  introduce  a  proposal  for  legislation  prohibiting  the  import  of  foreign
radioactive waste or spent nuclear fuel into any Member State without prior authorisation to process the
material.

9.3.  MANAGEMENT OF PLUTONIUM STOCKS

The  Euratom  Safeguards  Agency  is  at  the  limit  of  its  capacities,  mainly  stretched  by  the  inspection  effort
dedicated  to  the  plutonium  industry.  Euratom’s  former  Safeguards  Director  recently  declared  at  an
international plutonium conference that “despite the overwhelming need for verification in the nuclear field,
governments  and  the  EU  Commission  are  unwilling  to  commit  the  necessary  resources.”  It  is  of  utmost
importance that:

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26. the European Parliament and the European Commission make sure that the Euratom Safeguards Agency
has  the  appropriate  funding  to  carry  out  its  mission  of  verification.  The  level  of  appropriate  funding
should be determined and periodically reviewed in a joint working group between representatives of the
Parliament, the Commission and Euratom Safeguards.

27. the  European  Parliament,  in  order  to  reduce  the  global  nuclear  proliferation  risks,  considers  the
introduction  of  legislation  to  prohibit  the  separation  of  plutonium  unless  the  utility  can  demonstrate  a
short term use of the separated plutonium.

9.4.  DEVELOPMENT OF SPENT FUEL MANAGEMENT ALTERNATIVES

In  comparison  with  reprocessing,  the  long  term  dry  storage  of  spent  fuel  appears  to  be  a  more  safe,  less
expensive,  and  less  problematic  option.  In  principle,  the  European  Directive  85/337/EEC  provides  an
appropriate tool to require an analysis of alternative options to a given project. However, current licenses of
Sellafield  and  the  ongoing  licensing  procedure  at  La  Hague  have  not  addressed  the  issue  of  alternative
options. Therefore, further Policy Options are

28. the  European  Commission  should  request  Sellafield  and  La  Hague  operators  to  carry  out  appropriate

analyses of spent fuel storage and publish the results.

29. the European Parliament should initiate a follow-up evaluation of the performance of non-reprocessing

versus reprocessing options (for example, initiative report, new STOA project…);

30. the  European  Commission  and  the  European  Parliament  should  reorient  funding  from  plutonium  fuel
technologies  to  non-reprocessing  options  in  order  to  guarantee  the  availability  of  appropriate  R & D
results to enlighten the further decision-making process.

9.5.  DEVELOPMENT OF DEMOCRATIC DECISION MAKING TOOLS

A  recent  parliamentary  report  suggested  that  a  directive  should  transpose  into  EU  legislation  the  Aarhus
Convention  on  Access  to  Information,  Public  Participation  in  Decision-Making  and  Access  to  Justice  in
Environmental  Matters  (25  June  1998).  Directive  96/29  Euratom  having  omitted  to  provide  for  an  open
access  to  safety  and  other  fundamental  technical  reports,  the  public  has  had  only  limited  access  to
information in relation with nuclear activities, despite the fact that many European institutional bodies have
repeatedly called for more transparency concerning this matter.54

Similarly, the present EU regulation does not provide for a systematic dissemination of information to local
authorities  about  convoys  transporting  radioactive  materials.  While  it  is  stipulated  in  the  Parliamentary
Resolution of 13 March 2001 on the Safe transport of nuclear material, that “the local and public authorities
legally  and  operationally  responsible  for  the  safety  of  persons  and  goods  must  be  informed  in  advance  of
transitory convoys” transporting notably “nuclear materials.”

Finally, while nuclear activities concern primarily local communities, little has been done so far at the EU
level to include their opinion and perspectives in the nuclear energy policy, outside the public inquiries at the
environmental  impact  assessment  stage.  Here  again,  Articles  6,  7  and  8  of  the  Aarhus  Convention  could
provide  an  appropriate  legal  basis  for  future  legislation  in  the  field  of  public  access  to  environmental
decision making. Accordingly,

31. the European Parliament should pursue its efforts to initiate the transposition of the Aarhus Convention

into European legislation;

32. the  European  Parliament  should  carry  out  an  evaluation  of  the  current  application  of  the  existing  legal
framework  on  access  to  information  and  public  participation  in  the  decision  making  process.  This
initiative  should  be  accompanied  by  an  extensive  hearing  of  NGOs,  local  administrations  and  other
stakeholders in the process.

54 Council  Resolution  of  19  December  1994  on  radioactive  waste  management,  Resolution  of  the  Committee  of  the
Regions on ‘Nuclear Safety and Local/Regional Democracy”  of 14 May 1998, and the Parliamentary Resolution on
the Safety of transport of nuclear fuel and waste of 18 June 1998, are examples among others.

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Annexes

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ANNEX 1

Excerpts from Petition 393/95

Note: The following is a short summary of Petition 393/95 submitted by the Petitioner to the Committee of
Petitions  of  the  European  Parliament.  A  longer  English  summary  of  the  Petition  and  other  documents  in
German  subsequently  transmitted  by  the  Petitioner  to  the  Committee  of  Petitions  were  done  by
Mycle Schneider in order to allow the STOA Study Team to better understand the background of the original
STOA study request.

Letter to the President of the European Parliament (EP), dated 22 may 1995

In  his  letter  Dr.  Nachtwey  stated  that  he  is  acting  on  behalf  of  22  senior  citizens  of  Hamburg  who  are  all
signatories of the petition to the EP. “We are asking the EP to prevent any further nuclear pollution of the
oceans.” Today the question is whether the oceans will be available as a food source in future given all the
chemical and radioactive pollution.

[The petitioner later added references and comments that are noted where particularly relevant.]
Until the beginning of 1995, 7 million litres of radioactive discharges per day.55 Certainly the cheapest way
to discharge the radioactive waste. “But what will this procedure cost our grand-children and grand-grand-
children?”

The  second  reprocessing  plant  will  significantly  increase  the  pollution  of  the  environment.  In  December
1993  THORP  got  the  license  to  discharge  16.78  million  Curies.56  In  1991  the  discharge  was  1.25  million
Curies.  The  release  to  the  Irish  Sea  will  increase  by  900%.  There  is  no  doubt  about  the  fact  that  the
Cumbrian  Coast  is  already  highly  charged  with  contaminants.  The  universities  of  Bremen  and  Manchester
had in 1992 the possibilities to examine soil samples.57 In Manchester concentrations up to 13,000 Bq Ce-
137  and  up  to  27,000  Bq  of  Am-241  [supposedly,  in  each  case,  per  kg  of  soil]  and  up  to  10,800  Bq  of
plutonium were measured. Families come for a picnic, kids play here. Plutonium has been found in plants,
animals  and  houses.  The  consequences  will  only  be  visible  in  their  full  scale  over  the  next  decades  or
centuries, some only in thousands of years. A terrible thought if one thinks that already now the childhood
leukaemia around Sellafield is ten times the Great Britain average.58

Of  course,  the  contamination  problem  is  not  confined  to  the  UK  and  Ireland,  but  has  been  identified  in
Iceland, Norway and Denmark.

The operation of Sellafield and THORP renders PARCOM signed in 1974, ridiculous.

The extent of the pollution through Sellafield and the caused damage is well known. The British government
has met ecological and moral concern with grand carelessness.

The  Sellafield  plant  is  not  the  only  one.  But  the  French  government  is  less  careless:  information  about
radioactive discharges and the degree of coastal pollution are much more difficult to obtain than in the case
of  Sellafield.  We  ask  the  EP  to  bring  about  transparency  in  this  respect.  The  citizens  of  France  and
neighbouring  countries  have  a  right  to  this.  The  French  government  would  do  well  to  commission
independent universities with unlimited and uncensored measurements.

The  object  of  our  petition  is  under  the  responsibility  of  the  EU.  The  problems,  environmental  harm  and
dangers  linked  to  the  issue  have  transboundary  character  and  therefore  they  can  only  be  met  in  the
framework of the federation of European States.

55 In the meantime that rose to 9 million litres daily, BNFL Monthly Effluent Reports, January 2000
56 HMIP,  Draft  Authorisation  for  the  Disposal  of  Liquid  and  Gaseous  Radioactive  Wastes  from  Sellafield,

November 1992.

57 University  Bremen,  Fachbereich  Physik/Elektrotechnik,  10  June  1992;  University  of  Manchester,  Department  of

Chemistry, 11 August 1992

58 Black 1984

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ANNEX 2

International Conventions

(a) Main Conventions and Protocols Applying to the Use of Nuclear Energy

• Vienna Convention on Civil Liability for Nuclear Damage (21 May 1963);

• Optional Protocol Concerning the Compulsory Settlement of Disputes to the Vienna Convention on Civil

Liability for Nuclear Damage (21 May 1963);

• Convention on Physical Protection of Nuclear Material (26 October 1979);

• Convention on Early Notification of a Nuclear Accident (26 September 1986);

•

Joint  Protocol  Relating  to  the  Application  of  the  Vienna  Convention  and  the  Paris  Convention  (21
September 1988);

• Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency (26 September

1986);

• Convention on Nuclear Safety (17 June 1994);

•

Joint  Convention  on  the  Safety  of  Spent  Fuel  Management  and  on  the  Safety  of  Radioactive  Waste
Management (1997);

• Convention on Supplementary Compensation for Nuclear Damage (12 September 1997).

(b) Other Relevant Conventions and Documents

• Earth Summit’s Agenda for Change - Agenda 21 (June 1992);

• Earth Charter (March 2000);

•

IAEA Code of Practice on International Transboundary Movement of Radioactive Waste (1990);

• Convention  for  the  Protection  of  the  Marine  Environment  of  the  North-East  Atlantic –  OSPAR

Convention (22 September 1992);

• Convention  on  the  Prevention  of  Marine  Pollution  by  Dumping  of  Wastes  and  Other  Matters  (29

December 1972);

• Vienna Convention on Civil Liability for Nuclear Damage (21 May 1963);

• Convention on Access to Information, Public Participation in Decision-making and Access to Justice in

Environmental Matters (25 June 1998);

• The United Nations Convention on the Law of the Sea (10 December 1982).

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ANNEX 3 OSPAR Convention

The OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic, to which
the  European  Commission  is  a  Contracting  Party,  is  relevant  to  the  deliberations  of  the  Committee  on
Petitions on nuclide discharges from Sellafield and La Hague. In recent years, the OSPAR Commission has
made  a  number  of  strongly  worded  recommendations  on  the  continuing  radioactive  contamination  of
European seas and waters by Sellafield and La Hague activities.

The  OSPAR  Convention  came  into  force  on  25  March  1998.  The  Convention  established  the  OSPAR
Commission,  an  international  secretariat  based  in  London,  to  administer  the  Convention  and  to  develop
policy and international agreements in this field. The Commission is essentially a merger of the former Oslo
and  Paris  Commissions.  The  Commission  has  declared  its  commitment  to  the  application  of  the
precautionary principle, the polluter-pays principle, and to the application of best available techniques (BAT)
and best environmental practice (BEP), including, where appropriate, clean technology.

At the Sintra Ministerial Meeting on 22-23 July 1998, Ministers attending OSPAR agreed

“to  prevent  pollution  of  the  marine  area  by  continuously  reducing  discharges,  emissions  and
losses  of  hazardous  substances  (that  is,  substances  which  are  toxic,  persistent  and  liable  to
bioaccumulate  or  which  give  rise  to  an  equivalent  level  of  concern),  with  the  ultimate  aim  of
achieving  concentrations  in  the  environment  near  background  values  for  naturally  occurring
substances and close to zero for man-made synthetic substances. We shall make every endeavour
to  move  towards  the  target  of  cessation  of  discharges,  emissions  and  losses  of  hazardous
substances  by  the  year  2020.  We  emphasise  the  importance  of  the  precautionary  principle  in
this work.”

Specifically on radioactive substances, Ministers further agreed

“to  prevent  pollution  of  the  maritime  area  from  ionising  radiation  through  progressive  and
substantial  reductions  of  discharges,  emissions  and  losses  of  radioactive  substances,  with  the
ultimate  aim  of  concentrations  in  the  environment  near  background  values  for  naturally
occurring  radioactive  substances  and  close  to  zero  for  artificial  radioactive  substances.  In
achieving this objective, the following issues should, inter alia, be taken into account:

• legitimate uses of the sea;
• technical feasibility;
• radiological impacts to man and biota.

We shall ensure that discharges, emissions and losses of radioactive substances are reduced by
the  year  2020  to  levels  where  the  additional  concentrations  in  the  marine  environment  above
historic  levels,  resulting  from  such  discharges,  emissions  and  losses,  are  close  to  zero  (see
paragraph 15)”.

These  commitments  are  more  onerous  than  appear  at  first  sight.  Ministers  have  committed  themselves  to
achieving  concentrations in  the  environment  close  to  zero;  not  concentrations in  discharges.  Nuclide
concentrations in the environments at Sellafield and La Hague are already high. For example, critical group
doses from previous discharges at Sellafield account for about 75% of total annual dose: only 25% of dose
comes  from  present  annual  discharges.  In  other  words,  in  order  to  achieve  such  reductions,  present
discharges  at  Sellafield  and  La  Hague  would  have  to  be  severely  curtailed.  Furthermore  the  phrase
“progressive  and  substantial  reductions”  appears  to  indicate  that  decisions  leading  to  increases,  even  if
temporary, would not be in accord with Ministers’  commitments.  It  is  noted  that  four  documents  from  the
Sintra meeting need to be considered when evaluating the implications for radioactive substances These are:
the Sintra Statement; the OSPAR Strategy with regard to Radioactive Substances; the OSPAR Action Plan
1998-2003, 
the  OSPAR  Working  Group  on
Radioactive Substances.

the  1998-1999  Work  Programme 

and 

for 

However  since  1998,  progress  has  been  limited.  Both  Sellafield  and  La  Hague  have  issued  proposals  to
increase radioactive discharges, which have been looked upon with favour by the Governments involved. In
November  1999,  the  UK  Government  approved  a  new  variation  to  Sellafield’s  discharge  authorisations,
which  allowed  aerial  emissions  of  some  nuclides  to  increase.  In  France,  COGEMA  in  2000  issued

       85

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

proposals [1998, 2000] for increased reprocessing throughputs at La Hague which would result in significant
increases in specified nuclide discharges, without apparent opposition from the French Government.

In  June  2000,  at  the  Annual  Meeting  of  the  OSPAR  Commission  in  Copenhagen,  the  UK  submitted
proposals  for  significant  increases  in  alpha  and  beta  discharges  from  Sellafield  and  Dounreay.  At  this
meeting, Decision 2000/1 was agreed by all Contracting Parties, apart from the abstentions of UK, France
and the EC. Luxembourg was not present but agreed to the Decision later. Decision 2000/1 states that:

“The current authorisations for discharges or releases of radioactive substances from nuclear
reprocessing  facilities  shall  be  reviewed  as  a  matter  of  priority  by  their  competent  national
authorities,  with  a  view  to,  inter  alia:  implementing  the  non-reprocessing  option  (for  example
dry storage) for spent nuclear fuel management at appropriate facilities.”

The Summary Record shows that the UK and France abstained as they took the view that the Decision was
outside  OSPAR’s  remit. (Reported  from  Summary  Record,  Meeting  of  the  OSPAR  Commission,
Copenhagen, 26-30 June, OSPAR 00/20/1-E). As a result of their abstentions, it is understood the UK and
France do not consider Decision 2000/1 binding on themselves.

It  is  also  understood  that  the  EC  may  not  take  a  position  (i.e.  vote)  when  Member  States  are  divided.
However, in October 2000, Margot Wallstrom, European Environment Commissioner stated

“there is now broad support for the implementation of the non-reprocessing option.”  59

She added that the Commission would continue to contribute to allow the strategy on radioactive substances
to  be  implemented  and  progress  to  be  assessed.  In  addition,  the  European  Commission  would  give  its  full
support to requiring OSPAR Contracting Parties to implement the Strategy adopted at Sintra.

A  study  by  the  Nuclear  Energy  Agency  of  the  OECD  was  presented  at  the  Copenhagen  meeting.  OSPAR
Decision 2000/1 noted the study demonstrated that implementing the non-reprocessing option (dry storage)
for  spent  fuel  would  eliminate  the  discharges  and  emissions  of  radioactive  substances  that  currently  arise
from reprocessing it.

59 Margot Wallström, Letter to Greenpeace International, 17 October 2000.

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE
European Legislation, Regulation and Policy Statements

ANNEX 4

(a) European Treaties

• Treaty establishing the European Community, signed in Rome and entered into force on 1 January 1958;

• Treaty establishing the European Atomic Energy Community (Euratom), signed in Rome and entered into

force on 1 January 1958;

• The Single European Act (SEA), signed in Luxembourg and The Hague and entered into force on 1 July

1987;

• Treaty on European Union, signed in Maastricht and entered into force on 1 November 1993;

• Treaty of Amsterdam, which entered into force on 1 May 1999.

(b) European Commission Regulations, Recommendations, Opinions

• Regulations

• Commission  Regulation  (Euratom)  No  3227/76  of  19  October  1976  concerning  the  application  of  the

provisions on Euratom safeguards;

• Commission  Regulation  (Euratom)  No  3227/76  of  19  October  1976  concerning  the  application  of  the

provisions on Euratom safeguards.

• Recommendations

• Commission  Recommendation  82/74/Euratom  of  3  February  1982  on  the  storage  and  reprocessing  of

irradiated nuclear fuels;

• Commission Recommendation 1999/829/Euratom of 6 December 1999 on the application of Article 37 of

the Euratom Treaty;

• Commission  Recommendation  00/473/Euratom  of  8  June  2000  on  the  application  of  Article  36  of  the
Euratom  Treaty  concerning  the  monitoring  of  the  levels  of  radioactivity  in  the  environment  for  the
purpose of assessing the exposure of the population as a whole.

• Opinions
• Commission  Opinion  89/475/Euratom  of  20  July  1989  concerning  the  nuclear  fuel  reprocessing  plants

UP3 and UP2800 of the La Hague Establishment (France);

• Commission opinion of 5 October 2000 concerning the plan for the disposal of radioactive waste from the
the  region  of  Lower

radioactive  waste  storage  facility 

‘Centre  de 
Normandy (France), in accordance with Article 37 of the Euratom Treaty.

la  Manche’ 

located 

in 

(c) Council of the European Union Directives and Regulations

• Directives

• Council Directive of 15 July 1980 amending the Directives laying down the basic safety standards for the
health  protection  of  the  general  public  and  workers  against  the  dangers  of  ionizing  radiation
80/836/Euratom;

• Council Directive of 3 September 1984 amending Directive 80/836/Euratom as regards the basic safety
standards  for  the  health  protection  of  the  general  public  and  workers  against  the  dangers  of  ionizing
radiation 84/467/Euratom;

• Council  Directive  92/3/Euratom  of  3  February  1992  on  the  supervision  and  control  of  shipments  of

radioactive waste between Members States and into and out of the Community;

• Council Directive 96/29/Euratom of 13 May 1996 laying down basic safety standards for the protection of

the health of workers and the general public against the dangers arising from ionizing radiation.

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

• Regulations

• Council Regulation (Euratom) 1493/93 of 8 June 1993 on shipments of radioactive substances between

Member States;

• Commission  Regulation  (Euratom)  No  2130/93  of  27  July  1993  amending  Regulation  (Euratom)  No
3227/76  concerning 
safeguards  Council
Regulation (Euratom)  No  1493/93  of  8  June  1993  on  shipments  of  radioactive  substances  between
Member States;

the  provisions  on  Euratom 

the  application  of 

• Council Resolution of 19 December 1994 on radioactive-waste management.

(d) European Parliament Resolutions

• Resolution on nuclear waste and pollution at sea of 16 November 1995;

• Resolution on radioactive waste 27 March 1996;

• Resolution on the safety of transport of nuclear fuel and waste of 18 June 1998;

• Resolution on the safe transport of radioactive material of 13 March 2001.

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ANNEX 5

The Precautionary Principle: Not Using the Sea
as an Experimental Laboratory

In  the  recent  years,  suggestions  have  been  made  that  the  environment  may  be  treated  akin  to  a  large
experimental laboratory. For example, a MAFF Report [Kershaw et al, 1992] stated that:

“...the  likely  increased  discharge  of  technetium-99  from  Sellafield...from  1993  onwards  will
provide  an  opportunity  to  use  this  tracer  to  study  water  movements,  and  validate  transfer
models,  within  the  Irish  Sea,  and  exchange  in  the  North  Channel,  Malin  Shelf  and  along  the
Scottish coastal current.”

A similarity exists between this statement and that made by John Dunster in 1958 to a UN Conference on the
Peaceful Uses of Atomic Energy on “The Environmental Aspects of the Large Scale Use of Atomic Energy”:

“In general terms the intention has been to discharge fairly substantial amounts of radioactivity
as  part  of  an  organised  and  deliberate  scientific  experiment  and  the  aims  of  this  experiment
would in fact have been defeated if the level of activity had been kept to a minimum.”

And, from more recent publications:

“99Tc…  which  is  less  susceptible  to  removal  from  the  water  column  and  has  effectively  no
history because of the stepped nature of the discharge, offers a better tool to study the movement
of effluent within and from the Irish Sea.” [Leonard et al, 1997]

And also

“The  increase  in  discharges  has  resulted  in  increased  concentrations  in  certain  environmental
media  found  in  the  Irish  Sea,  providing  an  ideal  opportunity  for  further  study.”  [Busby  et
al, 1997]

Given the uncertainties described in the present report, it is clearly contrary to the Precautionary Principle to
continue  to  discharge  radionuclides  such  as  technetium-99  at  high  levels,  treating  the  marine  environment
both as convenient sink and interesting laboratory.

In  addition,  important  information  about  the  behaviour  of  technetium-99  is  not  in  fact  being  obtained:  for
example,  the  beaches  and  tidewashed  pastures  of  the  Solway  Firth (in  South  West  Scotland)  are  regularly
inundated  with  seawater  containing  nuclides  from  Sellafield  effluent,  and  are  grazed  by  sheep  and  cattle.
Apart  from  limited  FSA  monitoring  of  shellfish  and  seaweed,  there  has  been  no  effort  as  yet  to  obtain
additional information about the environmental behaviour of technetium-99 in this area, despite the fact that
“saltmarshes  are  important  ecological  areas,  and  may  facilitate  the  transfer  of  radionuclides  from  the
marine environment to terrestrial foodchains.” [Nicholson et al, 1992]

A  more  responsible  approach  would  be  to  apply  the  Precautionary  Principle,  and  to  defer  such  technetium
discharges  while  important  uncertainties  about  its  behaviour  remain.  BNFL  claims [see  accompanying
evidence  to  Environment  Agency,  2000]  that  the  costs  of  technetium-99  removal  are  “grossly
disproportionate”  to  the  detrimental  cost  of  the  dose (to  the  critical  group)  from  technetium-99  at  the
proposed  limit.  Even  if  it  were  accepted  that  radiological  detriment  could  be  offset  against  financial  gain,
such  an  assertion  assumes  a  high  degree  of  confidence  in  estimates  of  detriment.  This  confidence  is  not
warranted by the uncertainties described above.

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ANNEX 6

Background Information on Collective Dose

Collective dose is a measure of the exposure of a population over time from a given release of radionuclides
and is an indicator of total detriment to health from the resulting radiation. The ICRP [1991] has stated that
collective dose represents the total consequences of an exposure of a population or group, and has defined
collective effective dose, S, as

å=

S

_

(
i NE

i

)

where Ei is mean effective dose to population subgroup i and Ni is the number of individuals in subgroup i.
In  other  words,  collective  dose  is  the  product  of  the  average  dose  to  a  population  times  the  size  of  the
population. The concept of collective dose has been described by Fairlie and Sumner [2000] and Barraclough
et al [1996].

(a) Official Use of Collective Dose

The  use  of  collective  dose  by  international  agencies  and  national  regulatory  bodies  has  a  lengthy
pedigree [see discussion in NCRP 1995]. For example, in 1965, the Canadian Atomic Energy Control Board
introduced  an  annual  population  dose  limit  of  100 person Sv  per nuclear  power  station.  In 1985,  Sweden
introduced a “reference level” for the management of releases from Swedish nuclear reactors of 5 person Sv
per GW year of electricity generating capacity [Snihs, 1996].

International  and  national  agencies  routinely  estimate  collective  doses,  including  UNSCEAR [UNSCEAR,
1983;  1988;  1993;  2000];  the  Canadian  Environmental  Assessment  Agency  [CEAA,  1995];  the
IAEA [1985]; and the UK NRPB [Lawson et al, 1990; Mayall et al, 1993]. The UK NRPB’s dose model (PC
CREAM) for estimating doses from nuclide releases estimates both collective and individual doses.

Euratom  Directive 96/29  on  Basic  Safety  Standards  in  Radiation  Protection  stipulates  that  Member  States
should  have  introduced  national  legislation (by  May  2000)  requiring  their  national  agencies  on  radiation
protection  to  fulfil  procedural  requirements  on  radiation  protection.  In  particular,  the  Directive  contains
numerous provisions requiring national agencies to calculate and use population (i.e. collective) doses. These
include (in the order listed in the Directive):

i.  Article 14 on optimisation of population doses.

ii.  The whole of Title VIII on radiation protection for the population.

iii.  The whole of Title IX on lasting exposures.

iv.  Article 45  on  calculation  of  collective  doses  as  a  condition  of  authorisations  and  licensing  of

radioactive discharges

v.  Annex I on exemption provisions that use collective dose as the criterion for exemption.

(b) Estimation of Collective Doses

To estimate collective doses, the population and the truncation period, if any, must be defined. Populations
whose doses are calculated may consist of the workforce, the people in the immediate locality, the relevant
country, Europe, and the world. Methods for estimating such doses are described in the various reports cited
above.

As  regards  truncation  periods,  the  UK NRPB  estimates  two  types:  truncation  after 500 years  and  no
truncation.  UNSCEAR  routinely  uses  a  truncation  period  of 10,000 years  in  its  reports.  Few,  if  any,  rules
exist on which period should be used. The UK NRPB’s view is that, as there are uncertainties over events in
the long-term future (for example, a cancer cure could be found) both sets of doses are estimated.

Fairlie  and  Sumner [2000]  have  raised  ethical  and  practical  points  against  truncation.  Ethically  speaking,
truncation at 500 years negates detriment to generations after 500 years, which runs counter to the principle
of sustainable development and the IAEA’s Radioactive Waste Management Principles [1995].  In  practical
terms,  truncation  after 500 years  is  unsound  in  the  case  of  very  long-lived  nuclides  such  as  iodine-129  or
technetium-99, as it would ignore almost all (>99%) detriment. [see IAEA, 1995]

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

(c) Uncertainties

Inevitably,  uncertainties  remain  about  the  existence,  sizes  and  habits  of  populations,  climate,  and  the
environment for long periods into the future. For example it is expected that another ice age will peak in the
northern  hemisphere  in  approximately  10,000 years  and  that  repeated  glacial  cycling  will  occur
thereafter [NRPB, 1992].

However the use of uncertainty as a reason for avoiding the use of collective dose does not appear to satisfy
the Precautionary Principle, which states, inter alia,  that lack of scientific certainty should not be employed
as a reason for deferring measures to enhance the quality of the environment [Hey, 1995]. The precautionary
principle  is  one  of  the  supporting  principles  underpinning  the  policy  of  sustainable  development  formally
accepted by the European Commission at the 1992 UN Conference on Environment and Development.

In addition, similar large uncertainties in other parameters used in radiation protection do not prevent their
use. For example, large uncertainties exist in the assessment of terrestrial foodchain doses [Smith et al 1998],
and  in  estimates  of  individual  doses  to  members  of  critical  groups  from  projected  radioactive  waste
repositories  arising 104  to 106 years  in  the  future [Neall  et  al,  1994].  Of  course,  these  uncertainties  are
acknowledged,  but  they  do  not  prevent  publication  and  peer  discussion,  nor  their  usefulness  for
heuristic [McCombie et al, 1991; NAGRA, 1994] or for decision-taking [AECL, 1994] purposes. Estimates
of collective dose should be treated similarly.

(d) Comparisons with Background Radiation

Collective  doses  are  received  from  background  levels  of  radiation (on  average  –  there  are  large  variations
from  one  area  to  the  other  –  about  2.4 mSv  per person  per year  in  the  UK  and  France)  and  some
commentators  compare  collective  doses  from  discharges  with  background  doses,  in  attempts  to  put  them
“into  context” [see,  for  example,  RWMAC,  1993;  Clarke,  1994;  Coulston,  1994;  BNFL, 1998].  Such
comparisons  run  the  risk  of  inviting  the  lay  reader  to  infer  that  anthropogenic  collective  doses,  and  the
practices which caused them, are therefore acceptable.

A number of objections can be made against such comparisons. First, comparisons with natural background
doses infer that background radiation may be viewed with equanimity. This is not quite the case, of course.
The NRPB has estimated that natural background radiation results in about 6,000 to 7,000 UK cancer deaths
per  year  in  the  UK [Robb,  1994].  The  application  of  the  collective  dose  and  the  ICRP  risk  factor  to  the
French population leads to a similar figure for France.

Second,  a  number  of  authors  have  stated  that  comparisons  of  radiation  exposures  from  anthropogenic
releases  with  natural  background  radiation  levels  are  inappropriate.  See  comments  by  Lindell [1989],
NRPB [1990],  Webb  et  al [1983]  and  in  European  Commission  documents,  for  example  chapter 8.3.4  in
Bush  et  al [1984].  Comparisons  with  background  radiation  of  course  conflate  different,  i.e.  naturally-
occurring  and  anthropogenic,  risks.  Risks  from  anthropogenic  releases  are  subject  to  social  and  political
processes as the Committee’s hearing attests: background radiation risks are not.

Third,  comparisons  with  background  exposures  are  not  used  to  justify  the  acceptability  of  industrial
discharges of naturally occurring chemical toxins, e.g. carbon monoxide, ozone, dioxins or furans.

Finally,  the  ICRP  system  of  radiation  protection  of  limitation,  optimisation  and  justification [ICRP,  1991]
notably refrains from using background radiation as a criterion of radiological acceptance.

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ANNEX 7

POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE
Individual Exposures from Consumption of Seafood
around Sellafield

Table 14 Individual Radiation Exposures from Consumption of Irish Sea Fish and Shellfish

Exposed population(1) Foodstuffs

14C

60Co

Exposure (mSv/a)
90Sr

99Tc

106Ru

137Cs

0.005

0.002

0.005

0.016

0.003

0.009

Sellafield fishing
community

plaice, cod, crabs, lobsters,
winkles

Whitehaven
commercial fisheries

plaice, cod, Nephrops,
whelks

Dumfries Galloway

Morecambe Bay

Fleetwood

Isle of Man

Northern Ireland

North Wales
Member of public(5)

0.002

0.002

0.003

plaice, cod, salmon, crabs,
lobster, Nephrops, winkles
mussels

flounders, plaice, shrimps,
cockles, mussels

plaice cod shrimps whelks

0.002

fish, shellfish

fish, shellfish

fish, shellfish

plaice, cod

0.002

0.005

0.002

0.003

0.002

0.005

0.005

0.012

0.010

0.003

0.005

0.002

0.001

(continued)

238Pu

239Pu
+ 240Pu

241Pu

241Am Other(6)

Ext

Total

Sellafield fishing
community

plaice, cod, crabs, lobsters,
winkles

Whitehaven
commercial fisheries

plaice, cod, Nephrops,
whelks

0.008

0.046

0.010

0.082 <0.002

0.023

0.2l(4)

0.002

0.009

0.002

0.015 <0.002

0.009

0.038

Dumfries Galloway

Morecambe Bay

Fleetwood

Isle of Man

plaice, cod, salmon, crabs,
lobster, Nephrops, winkles
mussels

flounders, plaice, shrimps,
cockles, mussels

0.002

0.005 <0.001

0.028(2)

0.002

0.012

0.003

0.023 <0.001

0.013

0.071(3)

plaice cod shrimps whelks

0.003

0.004 <0.002

<0.004

0.003 <0.003

0.002 <0.002

<0.001

0.021

0.010

0.013

0.006

0.002

fish, shellfish

Northern Ireland

fish, shellfish

North Wales
Member of public(5)

fish, shellfish

plaice, cod

Blank data indicate a dose of less than 1 µSv.

(1) Representative of people most exposed unless stated otherwise
Including exposure due to 1000 h/year occupancy over intertidal sediments
(2)
Including exposure due to 900 h/year occupancy over intertidal sediments
(3)
Including exposure due to 1000 h/year occupancy over intertidal sediment
(4)
(5)
“Other”  comprises data for all radionuclides with doses below 1 µSv.
(6) Member of public consuming fish landed at Whitehaven and Fleetwood

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Source: [FSA, 2000]

POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 8 Concentration of Radionuclides in Seafoods from Sellafield

Figure 14 Concentrations in Cod, Lobsters and Winkles from Sellafield in Bq/kg (wet)

Carbon-14

Winkles
Lobsters
Cod

Technetium-99

Winkles (x10)
Lobsters
Cod (x1,000)

18000

15000

12000

9000

6000

3000

0

1989

1991

1993

1995

1997

1999

1989

1991

1993

1995

1997

1999

Plutonium-239, -240

Winkles

Lobsters (x100)
Cod (x1,000)

Caesium-137

Winkles

Lobsters
Cod

80

70

60

50

40

30

20

10

0

1989

1991

1993

1995

1997

1999

1989

1991

1993

1995

1997

1999

Americium-241

Winkles

Lobsters

Cod (x1,000)

300

250

200

150

100

50

0

45

40

35

30

25

20

15

10

5

0

90

75

60

45

30

15

0

1989

1991

1993

1995

1997

1999

The high americium-241 reading in cod in 1999 was stated in the FSA report as being “anomalous”

Source: [FSA, 2000]

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 9a Environmental Concentrations of Nuclide Discharges from Sellafield

In the following tables,

• * means that the nuclide was undetected using that particular method of detection,

• a blank entry means no sample was measured.

• < means that the concentration found was below the Lower Limit of Detection (LLD). To be more

precise,  taking  into  account  counting  time,  chemical  yield,  and  decay  since  collection,  the  nuclide
concentration was lower than the value indicated.

• “No.”  means the number of samples measured.

• Figures  in  bold  brown  signify  concentrations  above  relevant  CFILs (European  Community  Food

Intervention Levels).

Table 15a Fish: Beta/gamma Radioactivity in Fish from the Irish Sea Vicinity in 1999

(ranked by 137Cs concentration)

Location

Material No.

3H 14C 60Co

90Sr

95Zr

95Nb

99Tc

106Ru

134Cs

137Cs

Total
beta

Mean radioactivity concentration (wet), Bq/kg

Morecambe
(Flookburgh)

Flounder

Sellafield
coastal area

Sellafield
coastal area

Cod

Bass

Sellafield
coastal area

Grey
mullet

Sellafield
offshore area

Cod

Sellafield
offshore area

Whiting

Parton

Cod

Whitehaven Cod

Ravenglass Cod

Sellafield
offshore area

Sellafield
coastal area

Spurdog

Plaice

4

5

1

1

1

2

4

4

4

2

4

77 <0.09

<0.25 <0.28

<0.85 <0.09

17

0.67

<0.31 <0.57

<0.77 <0.16

14

160

<0.16

<0.12

<0.61 <0.80

<1.6 <0.17

<0.27 <0.28

<0.97 <0.10

85 <0.12

0.036 <0.24 <0.23

0.72 <0.86 <0.10

<0.08

<0.12

<0.21 <0.24

<0.62 <0.07

<0.20 <0.22

<0.68 <0.08

75 <0.20

0.037 <0.16 <0.13

<0.75 <0.09

<0.26 <0.38

<0.69 <0.08

13

12

12

12

12

11

10

150

<0.26 <0.37

<0.73 <0.07

9.5

0.33

<0.09

230

0.34

<0.31 <0.47

<0.76 <0.08

8.0

150

Source: [FSA, 2000]

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Table 15b Fish: Beta/gamma Radioactivity in Fish in Distant Area in 1999

(ranked by 134Cs concentration)

Location

Material No.

14C

60Co

90Sr

95Zr

95Nb

99Tc

106Ru

134Cs

Total
beta

Mean radioactivity concentration (wet), Bq/kg

Baltic Sea

Cod

Baltic Sea

Herring

Skagerrak

Herring

Skagerrak

Celtic Sea

Cod

Cod

Celtic Sea

Plaice

Barents Sea Cod

Iceland area Cod

Icelandic
processed

Cod

2

2

4

4

4

4

4

1

2

<0.06

<0.08

<0.07

<0.05

<0.32

<0.58

<0.61

0.17

<0.44

<0.82

<0.78

<0.09

<0.24

<0.31

<0.67

<0.07

<0.22

<0.44

<0.43

<0.05

19

<0.05

<0.024 <0.13

<0.14

<0.42

<0.05

<0.08

<0.07

<0.06

<0.23

<0.24

<0.74

<0.08

<0.52

<0.23

<0.67

<0.07

<0.22

<0.28

<0.54

<0.06

13

8.9

0.66

0.42

0.40

0.30

0.29

0.19

20

<0.04

<0.07

<0.05

<0.31

<0.04

0.19

Source: [FSA, 2000]

Table 16 Shellfish: Beta/gamma Radioactivity in Shellfish from Irish Sea Vicinity in 1999

(ranked by 99Tc concentration)

14C

150

58

110

110

98

140

120

Location

Material No.

3H

92

Sellafield
coast area

Lobsters

Ravenglass Lobsters

Sellafield
coast area

Sellafield
coast area

Nephrops

Limpets

Ravenglass Mussels

Sellafield
coast area

Sellafield
coast area

Sellafield
coast area

Winkles

Winkles

Whelks

Ravenglass Cockles

Sellafield
coast area

Sellafield
coast area

Crabs

Mussels

Sellafield
offshore area

Whelks

Ravenglass Winkles

8

4

1

4

4

4

4

2

4

8

4

2

2

Mean radioactivity concentration (wet), Bq/kg

60Co

90Sr

95Zr

95Nb

99Tc

106Ru

110mAg

3.9

2.8

0.77

6.2

8.4

25

25

3.4

36

4.4

14

4.1

12

0.70

<0.48

<0.84

4,700

<1.4

0.31

<0.42

<0.96

4,400

<0.94

4.4

4.4

<0.52

<0.66

990

<1.6

<0.30

6.1

<0.17

<0.17

<0.18

<0.13

<0.54

<0.56

990

920

290

<0.54

<0.56

290

4.7

4.7

0.15

<0.30

<0.56

120

2.5

1.6

<0.23

<0.16

<0.40

<0.69

58

53

9.9

4.8

12

19

19

2.3

14

<0.18

9.1

9.1

2.4

<0.32

<1.2

<2.4

2.0

<0.25

<0.20

20

<0.22

<0.22

<0.24

<0.22

<0.21

6.2

11

3.6

7.5

Source: [FSA, 2000]

       95

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE
Table 17 Fish and Shellfish: Transuranic Radioactivity in Fish and Shellfish from Irish Sea Vicinity

in 1999 (ranked by 239Pu + 240Pu concentration)

Mean radioactivity concentration (wet), Bq/kg

238Pu

239Pu+240Pu

241Pu

241Am

242Cm

244Cm

237Np

0.037

0.027

0.034

0.027

Location

Material No.

Nethertown Winkles

St Bees

Drigg

Tarn Bay

Winkles

Winkles

Winkles

Ravenglass Cockles

Sellafield
coastal area

Sellafield
coastal area

Winkles

Limpets

St Bees

Limpets

Sellafield
coastal area

Mussels

Nethertown Mussels

St Bees

Mussels

Ravenglass Mussels

Sellafield
offshore

Sellafield
coastal area

Sellafield
coastal area

Sellafield
coastal area

Sellafield
coastal area

Whelks

Whelks

Nephrops

Crabs

Lobsters

Ravenglass Crabs

Ravenglass Lobsters

Sellafield
coastal area

Plaice

Ravenglass

Plaice

Sellafield
coastal area

Cod

Ravenglass Cod

Saltom Bay Winkles

4

1

4

1

1

1

1

1

1

4

2

1

1

1

1

2

2

1

1

1

1

2

1

4

3.4

2.6

2.7

2.6

2.3

2.3

2.3

2.0

2.0

1.9

1.7

1.2

0.51

0.35

0.083

17

14

13

13

12

11

11

10

9.8

9.1

8.3

5.8

2.6

1.7

0.43

0.34

0.28

0.26

0.25

190

150

150

140

130

120

130

120

96

68

29

19

4.0

3.1

3.1

2.7

30

26

30

23

33

12

20

20

19

17

27

13

5.7

4.3

2.7

1.6

3.8

1.5

3.1

*

0.081

<0.018

0.057

0.047

<0.047

*

*

*

*

0.043

*

<0.018

*

*

*

*

0.070

0.048

0.024

0.037

0.037

0.045

0.046

0.075

0.021

0.011

0.0070

0.0022

0.0031

<0.0030

0.0036

*

0.0014

*

0.0088

0.0032

0.0088

0.003 8

0.024

0.032

0.000089

0.000049

0.0017

0.0082

0.014

*

0.000023

0.00090

0.0044

0.0073

<0.00022 <0.000073

0.00068

0.0035

0.0039

18

*

0.000011

Source: [FSA, 2000]

0.0044

0.070

0.02 1

0.059

0.052

0.054

PE 303.110

96

POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Table 18a Sediments: Radioactivity in Sediment from the Cumbrian Coast and further Afield in 1999

(ranked by 137Cs concentration)

Material

No.

60Co

95Zr

95Nb

106Ru

125Sb

134Cs

137Cs

144Ce

154Eu

Mean radioactivity concentration (dry), Bq/kg

Location

Cumbria

Newton Arlosh Turf

2.5

<2.4

<3.2

<8.2

<3.2

<0.80

Ravenglass -
Carleton Marsh

Newbiggin

Ravenglass -
Raven Villa

Mud

Mud

Mud, sand

Millom

Mud, sand

SandGatemarsh Turf

Flookburgh

Mud, sand

StBees

Sellafield

Sand

Sand

South-west Scotland

Kippford Merse Salt marsh

Kippford
Slipway

Palnackie
Harbour

Carsluith

Innerwell

Carsethorn

Garlieston

Mud

Mud

Mud

Mud

Mud, sand

Mud

Northern Ireland
Carlingford
Laugh

Mud

Oldmill Bay

Mud

Ballymacormick Mud

Strangford
Laugh Nickeys
point

Mud

Dundrum Bay Mud

LoughFoyle

Mud, sand

Portrush

Sand

4

4

4

4

6

2

4

2

2

2

2

2

2

2

49

52

43

11

1.2

<1.5

4.0

4.9

5.3

4.2

4.9

2.9

<2.0

0.49

1.0

<2.6

<2.5

110

<6.5

<1.0

<2.8

<3.1

<2.6

<2.7

<1,8

<1.4

<1.1

<0.88

<0.97

<1.7

<1.5

<1.2

<0.91

<0.95

87

73

<21

<5.3

<4.1

<3.3

<3.7

<6.1

<1.0

<5.2

<1.0

<2.3

<1.9

<1.3

<1.0

<1.2

<0.72

<0.58

<0.48

<0.34

<0.39

<0.40

<0.29

<10

2.2

0.25

<0.36

<0.23

7.1

<1.3

<0.30

<0.34 <0.25

14

<1.0

<0.17

<0.36

<0.69

<0.77

<0.25

<0.29

<0.65

<0.13

<0.20

8.9

<3.4

<0.91

<1.1

<0.91

<0.91

<0.37

<0.41

<0.18

<0.31

<0.12

<0.12

<0.49

<2.1

<3.0

<5.3

<1.6

<0.70

<0.44

<0.38

<2.0

<1.6

<3.9

<2.2

<4.3

<3.9

<1.2

<1.0

<0.53

<0.48

<0.19

<0.76

<1.0

<2.0

<0.57 <0.25

<0.24

<0.22

<0.18

<0.89

<0.95

<0.93

<1.1

<1.3

<1.4

<2.5

<2.6

<2.1

<0.63

<0.74

<0.49

<0.32

<0.31

<0.24

630

540

360

270

250

240

100

85

84

750

270

230

200

120

110

65

85

68

37

32

9.3

2.5

1.2

<4.3

<2.8

15

<12

9.7

<4.4

<2.9

<2.5

<1.9

<2.1

<1.0

<1.3

<0.97

<1.1

<1.7

<0.67

<0.78

13

8.9

7.0

4.4

<1.7

<1.2

1.5

1.9

5.8

2.2

2.3

2.2

<1.0

<0.35

<0.36

<3.1

<1.6

<2.1

<2.1

<1.3

<1.1

<1.4

<0.56

<1.6

<2.1

<1.1

<0.79

<0.69

<0.58

Source: [FSA, 2000]

       97

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Table 18b Sediments: Radioactivity in Sediment from the Cumbrian Coast and further Afield in 1999

(ranked by 241Am concentration)

Location

Material No.

155Eu

238Pu

239Pu+240Pu

241Pu

241Am 242Cm+244Cm Total beta

Mean radioactivity concentration (dry), Bq/kg

6.6

1100

<4.8

110

520

6100

Cumbria

Ravenglass –
Carleton
Marsh

Mud

Newbiggin Mud

4

4

Ravenglass –
Raven Villa

Millom

Newton
Arlosh

Sellafield

St Bees

Sand Gate
marsh

Mud, sand 4

<3.2

Mud, sand 4

<3.0

Turf

Sand

Sand

Turf

4

4

4

4

<2.5

<1.2

<0.90

<1.3

Flookburgh Mud, sand 4

<1.3

South-west Scotland
Kippford
Merse

Salt marsh 4

Palnackie
Harbour

Mud

Carsluith

Mud

Kippford
Slipway

Mud

4

4

4

Carsethorn Mud, sand 1

Garlieston Mud

Innerwell

Mud

Northern Ireland
Oldmill Bay Mud

Bally-
macormick

Carlingford
Laugh

Strangford
Laugh -
Nickey’s
point

Dundrum
Bay

Mud

Mud

Mud

Mud

4

6

2

2

2

2

2

<2.5

<1.7

<1.3

<1.1

<0.7

<0.49

<1.7

<0.94

<0.96

<2.4

60

30

24

26

310

160

120

130

6.1

34

47

77

3.5

3.0

2.2

19

17

13

1.8

1500

2,100

0.066

0.031

810

550

350

240

200

180

97

55

450

310

200

200

40

28

20

8.3

<0.66

1.2

7.0

7.1

0.021

<0.79

LoughFoyle Mud, sand 2

<1.0

0.11

0.56

Portrush

Sand

2

<0.52

PE 303.110

98

<1.6

0.74

<0.61

0.0031

Source: [FSA, 2000]

POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Table 19 Aquatic Plants: Radioactivity in Aquatic Plants from the Cumbrian Coast and

further Afield in 1999 (ranked by 99Tc then 106Ru concentration)

Location

Material

No.

14C

60Co

90Sr

99Tc

106Ru

137Cs

239Pu
240Pu

241Am

Total
beta

Mean radioactivity concentration (wet), Bq/kg

England

Sellafield

St Bees

StBees

Fucus
vesiculosus

Fucus
vesiculosus

Porphyra

Rabbit Cat How,
Ravenglass

Samphire

4

4

4

1

50

45

Seascale

Porphyra

52

Braystones south Porphyra

StBees

Cockerham
Marsh

Rhody-
menia spp.

Samphire

Marshside Sands Samphire

Scotland

Auchencairn

Garlieston

Fort William

Cape Wrath

Knock Bay

Wick

Fucus
vesiculosus

Fucus
vesiculosus

Fucus
vesicolosus

Ascophyl.
nodosum

Porphyra

Fucus
vesiculosus

Northern Ireland

Carlingford
Laugh

Ardglass

StrangfordLough

Portrush

Fucus spp.

Fucus
vesiculosus

Rhodymeni
aspp.

Fucus
serratus

4

2

1

1

8

8

8

2

8

1

2

4

2

4

51

20

1.7

0.26

2.8

1.9

2.7

0.11

<0.03

1.8

1.3

<0.35

<0.05

<0.08

<0.05

0.12

<0.10

<0.12

<0.06

3.9

13,000

<2.4

3.2

9,800

<1.4

0.38

8.4

1.0

8.9

<0.43

<13

12

5.1

9.2

7.5

1.9

2.1

1.9

13

12

10

2.6

1,5

3.6

<0.25

2.1

<0.25

0.56

2,800

<0.76

6.6

1,800

<0.63

6.7

1,600

<0.67

2.2

910

<0.46

0.44

<0.46

0.39

<0.40

0.24

700

<0.81

1.7

500

<0.66

1.0

66

<1.1

0.99

<0.47

0.16

5.6

10,000

190

6.1

5.9

1.6

5.6

3,2

9.6

1.1

0.3

3.2

5.6

<0.35

<0.17

<0.49

<0.22

<0.11

<0.22

0.41

<0.16

Source: [FSA, 2000]

       99

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ANNEX 9b Environmental Concentrations of Nuclide Discharges

from La Hague

Table 20 Radionuclide concentration in fish from the La Hague area in 1996/1997 (in Bq/kg)

Sampling area

Material

Measured
by

60Co

106Ru/106Rh

Average Maximum Average Maximum

West Coast (1997)

West Coast (1997)

North Coast (1997)

North Coast (1997)

Round fish

COGEMA <0.08

Flat fish

COGEMA <0.88

Round fish

COGEMA <0.82

Flat fish

COGEMA <0.06

Les Huquets (1996)

Gadus luscus

Flamanville (1996)

Labrus bergylta

Cap Lévy (1996)

Gadus luscus

Fermanville-Cap Lévy (1996) Labrus bergylta

Flamanville (1997)

Labrus bergylta

GEA

GEA

GEA

GEA

EDF

0.38

<0.41

<0.23

<0.19

0.13

0.16

<1.10

<1.40

0.09

0.38

0.58

0.28

0.17

0.13

<1.07

<0.06

<0.88

<0.06

-

<3.23

-

-

-

<1.80

<0.09

<1.60

<0.11

-

1.66

-

-

-

Source: [GRNC, GT-2, 1999]

Table 21 Radionuclide concentration in limpets from the La Hague area in 1996/1997 (in Bq/kg)

Sampling area

Material

Querqueville (1996)

Anse St Martin (1996)

Dielette (1996)

Carteret (1996)

Goury (1996)

Moulinets (1997)

Barneville (1997)

Limpets

Limpets

Limpets

Limpets

Limpets

Limpets

Limpets

Anse des Moulinets (1997)

Limpets

Querqueville (1997)

Sciotot (1997)

Goury (1997)

Ecalgrain (1997)

Urville (1997)

Limpets

Limpets

Limpets

Limpets

Limpets

Measured
by

GEA

GEA

LERFA

LERFA

GEA

OPRI

OPRI

COGEMA

COGEMA

COGEMA

COGEMA

COGEMA

COGEMA

60Co

106Ru/106Rh

Average Maximum Average Maximum

0.45

0.69

0.4

0.37

0.95

0.34

0.28

0.61

0.41

0.78

0.43

0.69

0.42

0.57

1.49

1

0.62

1.69

0.47

0.32

0.79

0.53

0.8

0.55

1.3

0.55

<2.11

<2.68

-

-

<3

<2.6

<1.54

6

<1.2

6.5

3.8

5.6

2

2.48

3.65

-

-

4.7

<2.6

<1.9

7.6

1.6

10

5.3

8.5

2.8

Source: [GRNC, GT-2, 1999]

PE 303.110

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Table 22 Radionuclide concentration in mussels from the La Hague area in 1996/1997 (in Bq/kg)

Sampling area

East Coast

West Coast

East Coast (1997)

St Vaast (1996)

St Vaast (1997)

Material

Mussels

Mussels

Oysters

Oysters

Oysters

Measured
by

COGEMA

COGEMA

0.31

0.37

COGEMA <0.09

GEA

OPRI

0.13

<0.67

60Co

106Ru/106Rh

Average Maximum Average Maximum

0.78

0.67

0.12

0.21

<0.9

<0.9

<1.2

<l. l

<0.88

<1.20

-

-

<0.67

<5.00

<5.00

Source: [GRNC, GT-2, 1999]

Table 23 Radionuclide concentration in shellfish from the La Hague area in 1996/1997 (in Bq/kg)

Sampling area

West Coast

North Coast

Material

Shellfish

Shellfish

Measured
by

COGEMA

COGEMA

60Co

106Ru/106Rh

Average Maximum Average Maximum

1.8

3.1

1.9

4.4

2.1

2.82

2.3

4.7

Source: [GRNC, GT-2, 1999]

Table 24 Radionuclide concentration in fucus from the La Hague area in 1996/1997 (in Bq/kg)

Sampling area

Barfleur (1997)

Goury (1997)

Material

Fucus

Fucus

Anse des Moulinets (1997)

Fucus

Barneville/Carteret (1997)

Diélette (1996)

Diélette (1996)

Goury (1996)

Fucus

Fucus

Fucus

Fucus

Anse des Moulinets (1997)

Fucus

Barneville (1997)

Sciotot (1997)

Barfleur (1997)

Flamanville (1996)

Goury (1996)

Carteret (1996)

Gatteville (1996)

Barneville (1996)

Fucus

Fucus

Fucus

Fucus

Fucus

Fucus

Fucus

Fucus

Measured
by

COGEMA

COGEMA

COGEMA

COGEMA

EDF

GEA

GEA

OPRI

OPRI

OPRI

OPRI

EDF

EDF

EDF

GEA

GEA

60Co

106Ru/106Rh

Average Maximum Average Maximum

<2.65

<3.15

<5.7

<2.73

1.7

2.02

2.27

4.6

<2.32

<3.4

<1.49

1.3

2.9

<1.1

<2.7

4

7.2

<3

1.7

3.01

4.23

5.8

3.4

<3.8

<1.78

1.3

2.9

<1.1

0.59

1.82

1.9

1.16

2.4

2.14

2.5

2.05

1.3

1.35

0.59

1.6

3.3

0.8

0.88

0.73

0.69

2.9

2.2

1.5

2.4

2.27

3.88

3

1.6

2

0.61

1.6

3.3

0.8

1.1

0.73

Source: [GRNC, GT-2, 1999]

       101

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Table 25 Radionuclide concentration in royal crabs caught close to the La Hague sea discharge pipe,

in 1997 (in Bq/kg)

Measured by,
date

Nb of
samples

ACRO, 15.9.97

Univ. Bremen,
15.9.97

ACRO, 16.9.97

ACRO, 20.9.97

3

3

4

2

241Am 60Co

134Cs

137Cs

129I

106Ru

125Sb

90Sr

238Pu

239Pu
240Pu

2.2

202

n.n. 162.2

n.n.

n.n.

17

216

n.n.

n.n.

n.n.

n.n.

184

154

11

125

73

54

798

127

-

-

-

489

83.6

5.120 (1)

- 155 (1)

n.n. <17.6

79

355

3.3

61

-

-

-

-

-

-

(1) Concentration above relevant CFILs (Community Food Intervention Levels)

Source: [Greenpeace, 1997]

Table 26 Radionuclide concentration in fucus and limpets from the La Hague area

in 1997 (in Bq/kg)(1)

Sampling
area

Sample
type

Fucus
Anse des
Moulinets Limpet
Fucus

Barneville

238Pu

0.063

0.024

239Pu
240Pu

0.093

241Am 134Cs

137Cs

129I

- <0.14

<0.22

11.55

0.053

<0.23

<0.08 <0.11

0.64

106Ru
106Rh

<5.7

6.0

60Co

131I

90Sr

1.9 <1.08 <0.24

0.61 <1.06 <0.11

<0.036

0.048

<0.53

<0.19 <0.12

3.75 <2.32

1.3 <0.24

-

Limpet

0.006

0.010

<0.26

<0.07 <0.09 <0.36 <1.54

0.28 <0.59 <0.09

(1) Figures in italic indicate measurements by OPRI, others measurements by COGEMA

Source: [GRNC, GT-2, 1999]

Table 27 Radionuclide concentration measured by COGEMA in fucus and limpets

from the La Hague area in 2000 (in Bq/kg)

Sampling area

Sample type

Anse des Moulinets

Barneville

Fucus

Limpet

Fucus

Limpet

137Cs

-

<0.42

-

<0.07

129I

9.0

-

2.4

-

106Ru/106Rh

<2.98

4.43

<2.70

<1.02

60Co

1.46

-

<0.60

-

40K

227.5

68.5

287.5

77.0

Source: Database of CSPI (Commission Spéciale Permanente d’Information) La Hague

Table 28 Radionuclide concentration measured by COGEMA in fucus, molluscs and limpets in the

first semester of 2001 (in Bq/kg)

Sampling area

Sample type

Between Granville
and the Seine Bay

Fucus

Mollusc

Fish

(1) Total activity (artificial + natural).

137Cs

<0.32

<0.15

0.23

129I

106Ru/106Rh

5.01

<0.44

<0.60

<2.31

<1.18

<0.78

60Co

<0.84

<0.25

<0.11

241Am 14C (1)

<0.15

<0.17

-

31.1

55.1

43.1

Source: COGEMA (www.cogemalahague.fr)

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 10 Specific Radiobiological Issues

During the Interim Report Meeting of the STOA Panel, on 10 April 2001 in Brussels, it was requested that a
number of specific radiobiological issues should be addressed in the Final Report of the STOA Study Team.

(a) Genetic Effects
Ionising radiation can cause mutations in the DNA of male and female germ cells. These mutations will have
no  direct  effect  on  the  exposed  individuals  themselves,  but  may  have  consequences  in  future  generations.
Inherited  disease  in  humans  due  to  dominant  or  recessive  mutations,  or  chromosome  aberrations,  can  be
quantified  using  epidemiological  studies  in  humans  and  animal  experiments.  However,  there  is  a  broad
category  of  human  disorders –  so  called  multifactorial  diseases –  that  depend  on  both  genetic  and
environmental factors.

There  are  no  human  data  that  demonstrate  a  convincing  effect  of  genetic  damage  due  to  radiation.  The
children  of  the  survivors  of  Hiroshima  and  Nagasaki  have  been  studied  in  some  detail,  but  have  not
demonstrated  any  statistically  significant  increase  of  genetic  abnormalities.  This  does  not  mean,  however,
that  there  is  no  effect.  The  studies  may  simply  reflect  the  relatively  small  sample  size,  thus  low  statistical
power.

In a review of the data, Neel et al [1989] state that

“We  do  not  regard  these  studies  as  testing  the  hypothesis  that  radiation  produces  mutations.
It [radiation] has  done  so  in  every  plant  and  animal  species  which  has  been  properly studied
with regard to this question. Rather, we feel that our challenge is to take the observed results as
our  best  current  estimate  of  the  genetic  impact  of  radiation  on  humans  and  consider  how  to
organize  the  findings  to  extract  the  most  likely  genetic  doubling  dose  suggested  by
the indicators.”

Neel et al estimated the doubling dose at between 1.5 and 1.9 Sv. This is comparable with the doubling dose
obtained from animal studies (mainly mice).

In a review of this matter, NRPB [1993] concluded that:

“There  remain  many  uncertainties  in  the  formulation  of  risk  estimates  for  the  induction  of
genetic effects in man by radiation. The principal reasons for this are:

(i) the absence of directly informative human epidemiological data and

(ii)  doubts  on  the  relative  responsiveness  and  hence  appropriateness  of  some  of  the  genetic
endpoints employed in experimental animal studies.

In the case of single gene and chromosomal mutations animal data have been used to project
genetic  risks  to  man  but  it  may  be  argued  that  these  extrapolations  are  likely  to  overestimate
overall genetic risk. Uncertainties in genetic risk estimates are at their greatest in the case of
multifactorial  diseases.  For  this  complex  group  of  disorders  it  is  clear  that  a  lack  of
fundamental  knowledge  greatly  limits  the  capacity  to  provide  soundly  based  estimates
of risk.” [emphasis added]

This  last  comment  was  reinforced  by  the  ICRP  who  stated [1991]  that  the  contribution  [to  the  risk  factor]
attributable to [multifactorial diseases] can only be very approximately and tentatively estimated.

(b) Misconceptions about Genetic Effects

Contrary  to  commonly  held  beliefs,  most  radiation-induced  mutations  are  not  expected  to  be  harmful.  For
example,  no  recorded  instances  have  been  found,  so  far,  of  the  isolation  of  more  virulent  strains  of  a
microorganism  as  a  result  of  radiation-induced  mutation  of  a  less  virulent  population [Moseley,  1990].  This
misconception stems from misunderstandings about effects of radiation and the nature of mutational change.

Radiation’s main effects, i.e. cell death and mutation, occur through damage to cellular DNA, particularly during
cell reproduction. Where damage occurs to the DNA of a somatic cell - a cancer may result: where the damage is
to a germ cell, hereditary changes may occur. All life forms are subject to background levels of radiation and
corresponding  DNA  insult:  all  life  forms  have  evolved  defence  mechanisms  for  dealing  with  these  levels  of

       103

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

damage. DNA repair mechanisms are formidable in number: an estimated 10,000 repairs are effected per hour in
a mammalian cell [Billen, 1990;  Saul and Ames, 1986]. These repairs are not always effected correctly which
results  in  a  small  number  of  faults  in  the  transcription  of  the  genetic  code  to  succeeding  generations;  that  is,
in mutations.

The term “mutation”  is commonly used to refer to changes to both cells and to species. Mutations in cellular
DNA are different from mutations in the phenotype (outward form or function) of a species. In cellular terms,
most DNA mutations are deleterious to offspring cells and will result in their reproductive death, i.e. no colonies
of the mutated cell will form. Where cell mutations survive and reproduce in a species, there will usually be a
change in the phenotype of the individual. In species terms, most mutations to the phenotype which survive in
viable progeny will be recessive. They may also be deleterious in which case they will be removed from the gene
pool over time by natural selective pressures.

The  overall  process  of  evolution  -  the  gradual  change  in  species  which  occurs  through  the  mutation  of
phenotypes,  is  perceived  here  to  be  beneficial  (i.e.  more  adapted  to  their  environment),  which  may  appear  in
conflict  with  the  fact  that  individual  mutations  are  mostly  deleterious.  However  evolution  occurs  over  many
thousands of generations; perhaps only one in many thousands of mutations is beneficial and survives.

Accordingly, all life forms experience continuing low background rates of mutations. In most cases, mutations
are deleterious and are weeded out by natural selection: equilibrium is thought to exist between rates of mutation
and their elimination from gene pools. Increased radiation exposures will result in an increased mutation rate in
the gene pool, resulting in new equilibrium being formed.

The  question  remains  whether  the  increased  mutation  rates  from  anthropogenic  nuclide  releases  from
reprocessing are justified. As far as is known, this question has not been addressed in the literature available to
the  authors.  In  essence,  we  are  embarking  on  an  experiment  with  the  human  genome  with  such  large  nuclide
releases. The same of course is true with the genomes of all other plants and animals.

(c) Genomic Instability

In  a  seminal  paper [Kadhim et  al,  1992],  Professor  Wright  and  his  team  revealed  that  when  mouse  bone
marrow cells were traversed by single alpha particles, damage to the genome could be delayed for up to six
generations of cell replication.

The authors speculated that:

“...[if  there  are]  classes  of  unique,  initial  radiogenic  damage  induced  only  by  high-LET
radiations, then the RBE for such damage would be effectively infinite. Leukaemia’s arising from
such  a  situation  may  not  have  been  identified  as  radiogenic  from  human  epidemiological
data (which is based predominantly on considering low-LET radiation) and our findings may then
have  considerable  relevance  to  the  problem  of  low-dose  radiation  exposure  from  artificial  or
natural a emitters.”

After  almost  a  decade  of  further  research,  a  larger  and  more  complex  picture  is  emerging  as  described  by
Wright [2000].  The  phenomenon  has  been  demonstrated  in  human  cells,  is  not  restricted  only  to  high-
LET (Linear  Energy  Transfer)60  radiation,  may  not  be  due  to  direct  DNA  damage,  and  may  involve
neighbouring  cells  (the  “bystander”  effect).  More  important,  there  may  be  significant  inter-individual
differences in susceptibility.

This  adds  up  to  what  Professor  Wright  describes  as  a “major  challenge  to  conventional  radiobiological
concepts.” However Roger Clarke, Chairman of ICRP and Director of the NRPB has stated

“It has been claimed by some that the finding of this phenomenon poses a challenge to accepted
concepts  in  radiological  protection,  and  that  risks  may  be  higher  than  currently  judged.  The
phenomenon has yet to be associated with tumour risk or other possible health effects. Also, even if
it were to be established, there would be no obvious implications for the direct epidemiological-
based central estimates of cancer risk on which risk projections are founded.”  [Clarke, 1999]

60 LET is a measure for the density of the energy deposits left by the high-speed particles along their tracks. LET is
defined as the average amount of energy lost per unit of track-length. It can be measured in KeV per micrometer. X-
rays, gamma rays, and beta particles are low-LET radiations because the distance

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Clarke states that this phenomenon has yet to be associated with tumour risk or other possible health effects.
However it would be unwise to assume there are no such associations; absence of evidence is not evidence of
absence.  Earlier  in  the  same  article  Clarke  explains  the  difficulty  of  estimating  risks  at  low  doses  from
epidemiological  studies  — i.e.  insufficient  statistical  power.  Moreover,  his  remark  about  epidemiological-
based  estimates  of  cancer  risk  does  not  mention  that,  (as  pointed  out  in  the  Wright  team’s  1992  paper),
current  estimates  are  based  on  extrapolation  from  acute  high  doses  of  low-LET  radiation,  not  chronic  low
doses of high-LET radiation.

It  is  concluded  there  remains  much  to  learn  about  the  possible  role  of  genomic  instability  in  radiation-
induced cancer.

(d) Chronic Effects on Environment and Animals
In a letter to the Committee dated 22 January 2001, the Petitioner queried “the  long-term  consequences  of
chronic radioactive discharges on the marine environment and the genetic material of plants and animals
considering the extremely long half-lives of some of the discharged nuclides.”

Possible  genetic  effects  of  radiation  are  discussed  in  section  (a)  above  in  this  Annex.  As  regards  chronic
effects of radiation, our present understanding is that radiation effects are additive: the larger the dose, the
greater the effect. Many animal experiments at relatively high overall doses have shown a dose rate effect:
that  is,  protracted  doses  have  less  effect  than  single  doses  of  the  same  quantity.  The  extent  to  which  this
phenomenon is relevant in the case of the much smaller doses received from environmental discharges has
been questioned by UNSCEAR [1994 and 2000].

As regards the effects of radiation on animals and the environment, current ICRP guidance is that radiation
protection measures designed for humans will protect other species in the environment. This is partly based
on  the  observation  that,  as  regards  taxonomic  orders  and  kingdoms,  species  which  are  more  complex  and
have  evolved  furthest  (including  humans)  are,  generally  speaking,  the  most  radiosensitive,  mainly  due  to
their larger DNA cross-sections and increased cell differentiation. However the ICRP’s view is under review
and a number of major studies are underway. .

Rose [1989]  has  comprehensively  reviewed  radiation  effects  in  species  other  than  man.  For fatalities,  the
review reported that the lowest chronic  exposure resulting in death was 3.6 Gy61 per year (~0.36 mGy per
hour)  for  several  rodent  species.  The  lowest acute  dose  was  0.8  Gy,  which  led  to  the  death  of  a  small
proportion of young Douglas fir trees. These acute doses are considerably lower that those used for humans,
for whom the LD50 is conventionally accepted to be 4 to 6 Gy.
For teratogenic or genetic change, the lowest chronic exposure was 3 mGy per year (~0.3 mGy per hour),
which reduced birth mass and increased brain mass of laboratory rats irradiated as fetuses during the final
third of intra-uterine life. For acute exposures, a dose of 10 mGy to pregnant rats impaired the reflexes of
their offspring.

For changes  in  behaviour  or  development,  the  lowest chronic  exposure  was  around  10  mGy  per  year  (i.e.
1 microGy per hour), which can  be  detected  by  planarium  worms  and  mud  snails.  For acute  exposures,  a
dose of only 1 microGy caused a transient reduction in the growth-rate of a mould: cockroaches whose eyes
have adjusted to the dark can visually detect this dose.

61 A Gy or gray is a unit of radiation dose equal to a Sv or sievert for gamma radiation. Note that 1G = 1,000 mGy =

1,000,000 µGy.

       105

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE
ANNEX 11 Possible Causes for the Discrepancy between Observed Cancers and

Estimated Low Doses

With regard to the estimated low doses to those working or living near Sellafield, it is surmised that:

•

•

•

the estimated low doses are incorrect, or

the estimated risk factor for radiation-induced cancer is incorrect, or

the concept of “dose”  or “equivalent dose”  does not correctly reflect the level of damage by radiation
from ingested or inhaled nuclides.

These matters are examined in turn below.

(a) Dose Assessments

The estimation of radiation doses received from discharged nuclides requires:

·  

accurate  measurements  of  body  burdens  or  nuclide  contamination  of  food,  water  and  the
environment:
transport models to predict the movement of nuclides through the environment:

·  
·   metabolic models to predict the uptake, retention, and excretion of nuclides in the body:
·   dose conversion factors:
·  

radiation weighting factors.

These  models  and  factors,  and  their  predicted  radiation  doses,  are  in  some  cases  conservative,  (i.e.,  they
result in deliberately high estimated doses to allow for a margin of error). Others are less so.

All contain areas of uncertainty, as discussed by the Committee on the Medical Aspects of Radiation in the
Environment [COMARE,  1986]  following  the 1983  Black  Report  into  the  incidence  of  leukemias  at
Sellafield;  by  Sir  Richard  Southwood [1993]  former  chairman  of  the  National  Radiation  Protection
Board (NRPB); and by the 4th COMARE report [1994].

The  4th  COMARE  report  made  specific  recommendations  for  further  radiation  research  to  reduce  these
uncertainties, including the following

1. Uncertainties in estimating radiation doses and effects for particular target cells from:

(a) 

internal exposure to radionuclides in the developing embryo and fetus

(b) 

internal exposure to radionuclides in tracheobronchial lymph nodes.

(c)  biological hazards of ultra-short-range radiations including Auger emissions

2. Uncertainties in the differences between biological effects of radiations of differing quality
3. Information on the specific nature of early molecular radiation events in somatic or germ cells that
contribute to cancer initiation or development. Particular information is required on

(a) 

the genetic basis of differences in radiation sensitivity in somatic or germ cells

(b) 

the nature of radiation-induced high frequency events in somatic or germ cells

(c)  and the relevance to disease of

(d)  radiation-induced mini-satellite mutations in somatic and germ cells

(e) 

radiation-induced genetic instability in somatic or germ cells

4. Information on mechanisms of interaction between radiation and other agents.

An  important  source  of  uncertainty  is  the  estimation  of in  utero  exposures,  as  emphasised  by  GRNC  in
their report

“In the absence of an international consensus on exposure models for the foetus and embryo, the
risk of radiation-induced leukaemia associated with exposure received in utero could be estimated
only  for  the  routine  discharges  from  local  nuclear  facilities,  as  a  sensitivity  analysis.  For  the
cohort as a whole, taking the in utero doses into account increased the number of estimated cases

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

of radiation-induced leukaemia by roughly 33% compared with consideration of only the exposure
received during childhood. This substantial percentage underlines the need for a valid exposure
model for calculating in utero doses in future radioecological studies”  [Rommens, 2000].

At  a  Consultative  Exercise  on  Dose  Assessments  organised  in  October 2000  by  the UK  Food  Standards
Agency, it emerged that a sound basis still does not exist for estimating foetal doses: an ICRP task group is
presently considering this [CEDA, 2001; see comment by Thorne, page 21]. The matter could be important,
as evidence points to the initiation of childhood leukaemia originating in utero [CEDA, 2001; see comment
by Bridges, page 21].

(b) Radiation Risk Factors

Risk  factors  for  radiation-induced  cancer  are  derived  mainly  from  studies  of  the  survivors  of  the  atomic
bombs dropped on Japan in 1945. In its most recent review of this issue (in 1990), ICRP recommended a risk
factor  of 5% (0.05)  per Sv  for  radiation-induced  fatal  cancer.  This  is  an  approximately  three-fold  increase
over the pre-1990 accepted value. Although this factor may be changed in the future to take into account new
data,  any  future  changes  in  risk  estimates  are  unlikely  to  explain  the  excesses  of  childhood  cancer  around
Sellafield and La Hague.

(c) Parameter of “Dose”

Uncertainty remains over the parameter of “dose”  itself, and what it measures. The unit of absorbed dose is
the Gray, defined as the averaged deposition of one joule of energy in one kilogram of tissue. A kilogram of
tissue typically will be of decimetre dimensions (10-1 metres). But a cancer may be initiated through a single
adverse  change  to  the DNA  of  a  single  cell  nucleus [NRPB, 1995].  The  cross-section  of DNA,  the  target
structure  for  radiation’s  adverse  effects,  is  of  nanometer  dimensions (10-9 metres).  The  difference  between
where dose is measured (i.e. tissues or organs) and where radiation exerts its effects is about eight orders of
magnitude, i.e. a 100,000,000-fold difference.

This  discrepancy  normally  doesn’t  matter  where  large  numbers  of  photons  or  particles  are  averaged  over
organs or whole body masses. “Dose”  is accurate enough for external radiation, e.g. X-rays and gamma rays;
also  for  internally  deposited  nuclides  whose  photon  energies  of  disintegration  are  large  and  distributed
evenly  throughout  tissues  and  cellular  structures.  But  “dose”  is  less  accurate  in  the  case  of  low
concentrations of nuclides whose disintegration results in particles with very short tracks, e.g. alpha emitters,
low  energy  beta  emitters  and  Auger  emitters. (Although  low,  these  energies,  if  deposited  near  target
structures, are easily large enough to disrupt DNA.)

Alpha emitters, such as plutonium, and low energy beta-emitters, such as tritium (the radioactive isotope of
hydrogen)  and  carbon-14,  are  all  discharged  from  reprocessing  plants.  Their  distribution  within  cells  or
organs  becomes  critical  and  to  the  extent  that  they  are  not  uniformly  distributed  between  and  within  cells,
there  is  scope  for  question  about  the  accuracy  of  their  “doses”.  There  is  evidence  of  heterogeneous
distribution within cells in the case of tritium [Fairlie, 1992] and for heterogeneous distribution within organs
with plutonium [EPA, 1993]. The implication is that the heterogeneous distribution of ingested, absorbed or
inhaled  nuclides  could  result  in  a  small  estimated  “dose”,  but  a  large  effect  on  target  structures  within
cell nuclei.

It is recommended that more research should be carried out on the distribution of low energy nuclides within
cell  nuclei  structures.  The  measurement  of  radiation’s  effects  within  small  volumes 
termed
microdosimetry.  Unfortunately,  the  study  of  microdosimetry  over  a  number  of  decades  has  not  resulted  in
practical recommendations for radiation protection.

is 

       107

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 12 Evolution of the Waste Stockpiles Managed at La Hague

Table 29 Evolution of the Waste Stockpiles, Conditioned and non Conditioned,

Managed at La Hague (1993-1999)

12.1993

12.1994

12.1995

12.1996

12.1997

12.1998

12.1999

5,721.2

6,997.5

8,556.2

10,237.1

11,907.0

13,535.7

15,097.2

Cumulated amount of spent
fuel reprocessed (tonnes)

Conditioned wastes

Bituminised waste (drum)
Hulls and nozzles (drum) (1)

7,610

720

8,592

1,119

9,177

1,759

9,471

2,431

9,624

3,060

9,805

3,658

9,898

4,249

Cemented technological
waste (drum)

Waste contaminated with
alpha emitters (drum) (2)

9,116

9,224

8,158

6,589

5,144

4,563

4,311

4,639

4,858

5,043

4,984

5,019

4,363

3,958

Canisters of vitrified waste

2,400

2,896

3,692

4,555

5,382

6,291

6,759

Non conditioned wastes

Hulls, nozzles, and other
ILW (tonnes)

Magnesium, graphite and
metal (m3)
Sludge (m3)

2,234.8

2,254.9

2,250.1

2,230.1

2,231.5

2,254.2

2,245.4

2,971.8

2,972.8

2,972.8

2,972.8

2,972.8

2,975

2,930

12,757

11,769

10,647

9,688

9,264

9,264

9,288

(1) On  the  total  of  4,249 drums  of  conditioned  hulls/nozzles,  2,731 drums  are  to  be  re-conditioned  in  the  future

compacting ACC workshop (planned for 2001).
(2) Some of these waste are planned to be re-conditioned.

Source: National Inventories of Radioactive Wastes, ANDRA, 1994-2000

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 13 The Return of Foreign Waste from Reprocessing at La Hague

Table 30 Approval by the Foreign Clients of the COGEMA’s Specifications for Waste Conditioning

Japan
Germany
Belgium
Switzerland
Netherlands

Vitrified waste
Yes
Yes
Yes
Yes
Yes

Cemented
hulls and nozzles
Yes
Yes
No
Yes
No

Bitumized sludge
Yes
Yes
No
Yes
No

Cemented
technological waste
Yes
Yes
No
Yes
No

Source: Comité de Défense Civil, Guernsey,June 1995

Table 31 Timetable for the Return of the Reprocessing waste(1) – the German Case

Waste /
Container

Contracts

< 1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Total

Number of transports

HLW - Vitrified waste
CASTOR HAW 20/28CG

COGEMA
3 containers
0 containers
12 containers
12 containers
12 containers
12 containers
12 containers
12 containers
12 containers
12 containers
12 containers
12 containers
4 containers
–
–
–
–
–
–
–
–
–
–
–
127 containers

BNFL
–
–
–
–
–
6 containers
6 containers
6 containers
6 containers
6 containers
6 containers
3 containers
–
–
–
–
–
–
–
–
–
–
–
–
39 containers

Compacted waste
CASTOR CSDC 28

COGEMA(2)

–
–
–
–
–
–
–
–
–
6 containers
12 containers
12 containers
18 containers
24 containers
24 containers
24 containers
24 containers
24 containers
24 containers
24 containers
24 containers
24 containers
24 containers
24 containers
312 containers

(1) This  table  does not  include  the  large  amounts  of  low  level  radioactive  waste  as  well  as  the  bituminised  waste

drums already produced which, according to the French legislation, should also be returned to Germany.

(2) 1,5 container of compacted waste/t of U (figures from the terms of the contract of compacting). One should note
that this figure corresponds to the future compaction rate of the ACC workshop according to COGEMA, which is
by a factor 4 to 5 lower than the previous figures of hulls/nozzles waste production. Initially planned to start in
1999, the ACC workshop has not started at the end of March 2001.

Source: GNS, 10.2000

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ANNEX 14 Compared Discharge Limits of La Hague and a Typical Reactor Site

Table 32 Comparison of Discharge Limits for the La Hague Site, and the Nuclear Power Plants

of Saint-Laurent-des-Eaux and Flamanville

La Hague

Saint-Laurent

Flamanville

Ratio

Authorisation
for the whole site
(in GBq)

Authorisation
for 2 PWR
900 MWe
(in GBq)

Authorisation
for 2 PWR
1,300 MWe
(in GBq)

La Hague vs.
1 PWR
Flamanville (3)

480,000,000

2,200,000

110

74

1,700,000

37,000,000

220,000

37,101

4,000

0.8

–

330

45,000

–

46,401

5,000

0.8

–

425

60,000

–

1,700

prohibited (2)

prohibited (2)

20,689

880

275

–

8,000

1,233

–

–

Type of Effluent

Gaseous Releases (1)
Gases other than
tritium

Tritium

Halogenes (iodine,
chlorine…)

Aerosols

Liquid Discharges

Radio elements other
than tritium

Tritium

Strontium-90 et
caesium-137

Alpha emitters

(1) There  are  no  specific  gaseous  alpha  discharge  limits  for  La  Hague  (although  the  plutonium  is  included  in  the

aerosols, except for the Pu-241).

(2) The  discharge  of  gaseous  or  liquid  alpha  emitters  is  prohibited  at  the  reactor  sites  of  Saint-Laurent-des-

Eaux (Arrêté du 2 février 1999) and Flamanville(Arrêté du 6 juin 2000).

(3) The Flamanville site is 17 km of the La Hague site on the same coast.

Source: Journal Officiel de la République française.

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 15 Compared Real Radioactive Discharges from La Hague

and One PWR

Table 33 Comparison of Real(1) Radioactive Discharges from La Hague and Flamanville, 1999

Flamanville (2x1,300 MW)

1999 (GBq)

La Hague

1999 (GBq)

Ratio(2) La Hague vs.
1 PWR Flamanville

Category

GASEOUS RELEASES
Alpha Emitters

Noble Gases, Aerosols
Tritium 3H
Carbon-14

Iodine

Sum of other radionuclides

not authorized

15,000

1,266

337

0.41

1.82 10-3
300,000,000

80,000

19,000

8.16

0.27

Total of gaseous releases

16,603

300,099,008

LIQUID RELEASES
Alpha Emitters

Carbon-14
Tritium 3H
Iodine

Sum of other radionuclides

Total of liquid releases

Total of releases

not authorized

15.3

25,000

2.2

25,017

41,612

60.32

9,930

12,900,000

1,845

34,364

12,946,199

313,045,208

-

40,000

126

113

42

36,150

-

1,298

1,032

32,918

1,034

15,046

(1) Radioactivity released by category as indicated by the plant operator on the basis of his own measurements for the
year 1999.  Quantities  indicated  in italic  are  based  on  estimates  for  Flamanville  releases  of  tritium  in  gaseous
releases and carbon-14 in both gaseous and liquid releases, because those were not measured by EDF before the
beginning of 2001. These estimates are calculated as follows: figures given by EDF for January 2001 releases of
tritium (gas)  and  carbon-14 (liquid  and  gas)  provide  an  evaluation  of  the  year 1999  releases  using  the  ratio
between 
the  entire
the 
year 1999 (14,205 TWh).

January 2001 (1,739 TWh)  and  during 

total  production  of 

site 

the 

in 

(2) Although this does not modify the orders of magnitude, it should be stressed that this ratio corresponds to a year,

1999, when Flamanville had a load factor of only 60.9%, while the La Hague plants of UP2-800 and UP3 reached
a load factor of 97,6% (1,561.5 t for a nominal capacity of 1,600 t).

Source: COGEMA, 2000; CNPE Flamanville, 2001

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ANNEX 16 Chronological List of 8 Significant Accidents at La Hague since 1968

• 02 October 1968: Iodine release through the UP2-400 chimney.

Source: [GRNC, GT-1, 1999]
An  abnormal  rate  of  gaseous  iodine-131  (131I)  release  was  detected  at  the  UP2-400  factory.  The  release
exceeded the limit (370 Bq/s) by a factor of 10.000. This high level of iodine-131 release (37,000 Bq/s) has
continued for eight hours and has then been decreasing for 15 hours before the activity fell to a level under
the authorised limit.

The total amount of iodine-131  released  was  evaluated  at  185  GBq  (the  current  authorisation  for  iodine  is
110 GBq per year). This accident was caused by the treatment of insufficiently cooled gas-graphite fuels. A
release  of  iodine-129  (129I)  was  reported  as  well (7,4 GBq)  so  that  the  total  release  reached  twofold  the
annual authorisation for halogens. No evaluation of the impact on public health was established.

• 14 January 1970: Explosion during processing of Gas-Graphite fuel.

Source: [GRNC, GT-1, 1999]

During  the  chemical  dissolution  of  the  fuel,  the  temperature  of  the  reaction  increased  sharply  and  an
explosion  due  to  hydrogen  gas  emanation (H2)  occurred.  The  filters  of  the  chimney  recorded  an  activity
of 5,900 GBq, mainly due to antimony-125 (125Sb), 95%, and iodine-131 (131I), 5%. The iodine-129 activity
released  was  2,7 times  higher  than  the  annual  authorised  limit  (110  GBq). No  measurements  in  the
environment were undertaken following this accident, no evaluation of the impact on public health has been
carried out.

• 01 October 1976: Contamination of the “Sainte-Hélène” stream and other streams close to La Hague.

Source: [GRNC, GT-1, 1999; GSIEN, 1992; ACRO, 2000a]
A bad designed packaging of tritium (3H)-rich wastes allowed large amounts of tritium to be released in the
“Sainte-Hélène”  stream:  the tritium  activity  reached  7,400 Bq/l  in  October 1976.  Streams  outside  nuclear
areas usually exhibit a level below 1 Bq/l. From 1977 to 1983, the mean annual tritium activity released is
about 5,000 Bq/l. These unexpected high levels of contamination were due to the leakage. The operations of
re-packaging gave rise to the release of 52,000 GBq of tritium, which represents five times the annual release
of tritium at this period. Moreover, measurement devices taken into account to monitor radioactivity are not
representative for the localisation of main tritium contamination.

radionuclides  were  detected  over 

like  strontium-90 (90Sr),
Many  other 
caesium-137 (137Cs),  cobalt-60  (60Co).  Caesium  activity  in  sediments  was  found  to  be  10 times  higher  in
1991 
laboratories (ACRO, CRII-Rad62).

than  usual.  Some  other  evidence  of  contamination 

reported  by 

this  stream 

local 

independent

time 

in 

is 

• 02 January 1980: Discharge pipe leakage.

Source: [Guillemette, 1999; ACRO, 2000a]

A  one meter  long  through-wall  crack  has  been  discovered  on  the  La Hague  discharge  pipe  at
about 200 meters  from  the  shore.  The  radiological  impact  had  been  under-estimated  as  has  been  revealed
later by a member of the Permanent special commission for information (CSPI La Hague). Individuals of the
critical group (fishermen) received 3.5 times the annual authorised dose (namely 3,486 mSv, to be compared
with the current European limit of 1 mSv/year).

A  radiological  measure  on  mollusc  done  by  the CFDT  union  of  La Hague  in  1980  shows  a  200-fold
difference  with  COGEMA  analysis  carried  out  during  the  same  period :  407  Bq/kg  of  strontium-90 (90Sr)
detected in molluscs instead of 2 Bq/kg as reported by COGEMA.

62  ACRO: Association pour le Contrôle de la Radioactivité dans l'Ouest.

CRII-Rad: Commission de Recherche et d'Information Indépendantes sur la Radioactivité.

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

• 06 January 1981: Fire in waste silo.

Source: [GRNC, GT-1, 1999; BSN, 1981] and http://nucleaire.edf.fr

Graphite  elements  had  been  burning  for  24 hours  in  a  waste  silo.  Uranium  metal  caught  fire  following  a
mechanical  shock  during  operations.  The  maximum  measured  level  of  air  contamination,  700 Bq/m3,  was
reached 10 hours after the beginning of the fire.
The released activity is mainly due to caesium-137 and -134 (137Cs and 134Cs) and ranges between 740 GBq
and  1,850 GBq,  thus  10  times  of  more  the  annual  limit.  The  annual  limit  for  the  whole  La Hague  site
is 74 GBq of caesium-137. Strontium-90 (90Sr) was detected in rainwater and the authorised limit of surface
contamination  was  reached  in  6 km  distance  from  the  site.  A  worker  received  in  one  day  the  annual
admissible dose, 50 mSv. An off site health impact has not been carried out.

This fire was considered a major accident and was rated later at level 3 of the International Nuclear Event
Scale, INES (which has 7 levels).

• 13 February 1990: Uncontrolled release of caesium-137 (137Cs) by the ELAN II B plant chimney.

Source: [CILH, 1990]; Bulletin de sûreté nucléaire

A  routine  replacement  of  a  chimney  filter  has  led  to  the  release  of  non-filtered  and  contaminated  air  for
10 minutes.  An  estimated  3,7 MBq  of  caesium-137  have  been  released  in  the  atmosphere.  A  specific
limitation for caesium-137  does  not  exist.  No  evaluation  of  the  radiological  consequences  was  carried  out.
This accident was classified at level 1 of the International Nuclear Event Scale.

• 11 March 1997: Irradiation caused by the discharge pipe at low tide.

Source: [ACRO, 2000a]; Contrôle, June 1997

An independent laboratory (CRII-Rad) measured a high level of dose equivalent rate, close to the discharge
pipe at low tide. COGEMA confirmed the high value of 0,3 mSv/hour (which gives an individual the annual
dose  in  three hours  and  half  only).  The  safety  authority  rated  this  event  at  level 1  of  INES  since  the  pipe
provided  an  “unacceptable  potential  risk  of  irradiation  for  public.”   With  this  exposure  and  the
strontium-90 (90Sr)  concentration  reached  inside  the  pipe,  the  vicinity  of  the  pipe  would  have  required  a
classification of “nuclear facility”  in accordance with French legal framework on radioprotection.

• Since 1983: Permanent pollution due to strontium-90 (90Sr).

COGEMA  said  that  strontium-90  contamination  was  caused  by  metallic  waste  stored  in  concrete  pools
which released radionuclides in groundwater and near-by streams. As of the end of 1999, the contamination
is still detected [ACRO, 2000b]: 20 Bq/l in 1991, between 5 and 10 Bq/l  since  then  (maximum  admissible
concentration  in  drinking  water : 36 Bq/l). Moreover,  strontium-90  has  a  great  affinity  for  bones  and  bone
marrow. In a context of an excess of leukæmia cases found in North-Cotentin [see epidemiological studies of
Viel; and Spira et al], it seems abnormal that no specific monitoring of gaseous strontium-90 is carried out
by COGEMA, as Pierre Paris, vice-president of ACRO, notes in a letter to the CSPI La Hague (October 8th,
2000).

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ANNEX 17 Incidents/Accidents at La Hague declared to the French Safety

Authorities between 1989 and 2000

The incidents declared by COGEMA to the French nuclear safety authorities are rated on the International
Nuclear Event Scale (INES), that reaches from level 0 to level 7, since March 1989. Here is a selection of
incidents/accidents that the operator COGEMA has declared to the safety authorities between 1989 and the
end of the first semester of 2001 and that were published by the safety authorities.

• 2001:

3 incidents declared in the first semester of 2001. These are:

18 May: A breakdown of a ventilation system at the R7 vitrification plant (INES 1). The incident coincided
with  the  sticking  of  a  valve  on  the  emergency  ventilation,  which  ended  up  in  the  release  of  radioactive
materials  into  the  environment.  COGEMA  announced  that  the  measures  taken  at  the  chimney  that  day
indicated  a  source  term  of  11  MBq.  Yet,  ACRO  undertook  measures  shortly  after  the  incident  was  made
public. According to its calculations [ACRO, 2001], within one hour, COGEMA released nearly 100 times
as  much  gaseous  effluents  as  it  did  in  total  in  1999,  when  it  reached  its  record  level (153  MBq),  and
approximately 10 times as much as the annual limit it committed itself to comply with, in 2000 (1,850 MBq).
For  the safety  authority,  the  DSIN,  the  measures  undertaken  on  the  environment  confirm  that  the  incident
had no significant consequences neither on the populations’  health nor on the environment. It affirmed that a
dose  received  by  an  observer,  at  one  kilometer  from  the  site,  would  have  been  of  the  order  of  a  few
microsieverts, compared to the regulatory 1 mSv/year limit.

24 February: Leakage of a radioactive liquid solution into the drip tray pit during a rinsing operation at the
R1  shearing  plant  (INES 1).  The  incident  was  due  to  a  watertightness  fault  in  the  chute  connecting  the
shearer to the dissolver. The Safety authority came to the conclusion that the incident had no consequences
on the populations' health and/or on the environment.

5 January: Non-compliance with the exploitation regulations for the storage of plutonium oxide powder at
the BST1 plant (INES 1).

• 2000:

18 incidents declared in 2000. Amongst these are:

16  December:  Irradiation  of  an  employee  at  the  vitrification  plant  R7 (INES 1).  The  cap  of  a  well  that
contains vitrified High Liquid Waste had not been put back and a worker was not aware of it. The dosimeter
of the worker was not running while the dose rate reached 660 mSv/h above the well.

7 December: Temporary loss of the ventilation at the vitrification plant R7 (INES 0).

30 November: Flaw in the fire emergency system at R7 plant (INES 0).

12 October: Irradiation of a worker at UP2-400 plant (INES 1).

11 October: Fire in the decommissioning cell of the R7 facility (INES 0).

• 1999:

17 incidents declared in 1999. Among them:

17 October:  The  concentration  of  fissile  materials  in  the  dissolution  tank  of  UP3  was  not  checked  before
continuing the process. This measurement is necessary to insure that there is no criticality risk (INES 1).

24 September:  A  worker  died  during  a  maintenance  operation  on  a  transport  cask.  A  second  one  was
hospitalised. This accident was not classified on the INES scale.

16 August: Loss of water-tightness of a transfer pipe in the UP3 plant. The quantity of plutonium exceeded
authorised limits of the plant (INES 1).

25 June:  The  activity  of  a  spent  fuel  storage  pool “C”  in  UP2-800  exceeded  the  authorised  limit  after  the
transfer of leaking fuel assemblies (INES 1).

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

28 May: Loss of air-tightness of the first containment barrier at the vitrification plant T7 (INES 1).

20 May: Damage caused near the discharge pipe (not rated on the INES scale).

• 1998:

15 incidents declared in 1998. Among them:

9 December: Measurements of fissile materials concentration in the dissolution tank T1 of UP3 plant had not
been carried out (INES 1).

6 November: Contamination of the clothes of workers during operation on discharge pipe (INES 0).

4 June: Flaw in the flow of dissolution, centrifugation out of order (INES 1).

19 May: Inspections on the spent fuel stored in the NPH pool of UP2-400 were conducted without respecting
basic safety rules (INES 0).

23 April: Uncontrolled release of radioactive particles at the chimney of UP2-400 (INES 0).

20 February:  Irradiation  of  two workers  in  UP3.  The  door  of  an  irradiating  cell  was  kept  inadvertently
open (INES 1).

• 1997:

13 incidents declared in 1997. Among them:

17 October: Six assemblies were stored without authorisation in the pool “D” of UP3 (INES 1).

4 September: Recurrent contamination of workers during maintenance work at T2 plant (INES 1).

16 June: Contamination of workers at T2 plant (INES 0).

22 May:  Mechanical  dysfunction  of  the  elevator  of  the  spent  fuel  assemblies  above  the  storage  pool  of
the T1 plant (INES 1).

13 March:  Leakage  undetected  at  the  dissolution  tank  of  HAO  (UP2-400).  Accumulation  of  260 kg  of
uranium nitrate, plutonium and fission products.

12 March: Contamination of workers at T2 plant (INES 0).

11 March: Irradiation caused by the discharge pipe at low tide (INES 1, see Annex 16).

• 1996:

17 incidents declared in 1996. Among them:

18 November:  A  fuel  assembly  fell  down  while  it  has  been  transferring  from  the  storage  pool  to  the
dissolution tank (INES 0).
10 October: Fire in the R2 plant (INES 0).

2 October: Recurrent dysfunction of the last containment barrier filters (INES 0).

14 July: Error in the process of dissolution. Solutions were not changed before another one was added giving
rise to a potential risk of criticality (INES 1).

10 July: Death of a worker by inhalation of carbon mono-oxide (not rated on the INES scale).

• 1995:

No incident declared [? or published?].

• 1994:

12 December:  Overflow  during  the  transfer  from  the  dissolution  tank  of  900 litres  of  solution  (UP2-800).
The solution, which contained plutonium, fission products and uranium, was introduced while the reception
tank was not empty (INES 1).

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11 August: Overflow caused by an excess flow of solution in the dissolution tank at UP2-400 (INES 1).

• 1989-1993:

22 March 1993: Malfunction of the dissolution process at UP2-400 (INES 1).

20 November 1992:  Plutonium  and  uranium  concentrations  in  excess  inside  the  dissolution  tank  of  HAO,
UP2-400 (INES 1).

31 October 1992: Malfunction in the dissolution process at UP3 (INES 1).

27 September 1992:  Dispersion  of  radioactive  materials  inside  HAO plant (UP2-400),  contamination  of  a
worker (INES 1).

17 April 1992: Criticality risk in the dissolution tank of HAO (UP2-400) caused by an excess of processed
assemblies (INES 1).

March 1992: Incident during a maintenance operation at UP2-400 plant (INES 1).

5 July 1991:  The  filtration  system  in  the  storage  pool  “E”  of  UP3  stopped,  following  an  electricity  cut
off (INES 1).

20 June 1991: Fire in AT1 plant (INES 1).

18 April 1991:  Contamination  in  HAO,  release  of  caesium  and  ruthenium  by  the  chimney  of  the
plant (INES 1).

20 March 1991: The transfer of four assemblies between the unloading pool and the storage pond of HAO
was accidentally blocked by the shutdown system between the two pools (INES 1).

19 December 1990:  Abnormal  gaseous  release  by  the  chimney  of  the  effluent  treatment  station
STE3 (INES 1).

10 September 1990: An electricity cut off made the ventilation system of HAO inoperative (INES 1).

28 May 1990:  Waste  drum  inadvertently  containing  a  flammable  organic  liquid.  The  press  designed  to
compact solid wastes in UP3 was damaged (INES 1).

13 February 1990:  The  routine  change  of  the  Elan  II  B  filters  gave  rise  to  an  uncontrolled  release  of
radioactivity (Caesium 137) by the plant chimney (INES 1, see Annex 16).

16 August  1989:  Abnormal  increase  of  radioactivity  at  the  R7  vitrification  workshop  of  UP2-800  plant.
Evacuation of workers (not rated on the INES scale).

8 August 1989: Electricity cut off at UP2-400. Control systems of gaseous releases and cooling systems of
fission products tanks were disabled (INES 1).

1 August 1989: Contamination of a worker during the transfer of a pump. A contaminated liquid was spread
inside the MAPu workshop of UP2-400 plant and contaminated the worker (INES 1).

28 May  1989:  Leakage  on  a  pipe  inside  UP2-400  causing  an  increase  of  the  plutonium  and  uranium
concentrations in a high activity dissolution tank (not rated on the INES scale).

29 March 1989: Corrosion and subsequent leakage on the pipes of the bituminisation plant, STE3 (not rated
on the INES scale).

14 March 1989: Electricity cut off for the whole site of La Hague for about one hour (INES 2).

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ANNEX 18 Type of Accidents and Consequences at Reprocessing Sites

Table 34 Type of Accidents with Liquid and/or Gaseous Releases at Reprocessing Sites

and Occurences in Reprocessing Plants

Type of accident

Liquid
releases

Gaseous
releases

Criticality in dissolution tank

X

Fire

Explosion

Filtration  default  of  liquid  releases,
breach in releases structures

X

Loss of coolant

X

X

X

X

Occurrence

Windscale, 1973 (level 4)
Tokai(1), 1999 (level 4)

La Hague, 1981 (level 3)
Karlsruhe, 1985
Tokai, 1997 (level 3)

Savannah River, 1953
Kyshtym, 1957 (level 6)
Oak Ridge, 1959
La Hague, 1970
Savannah River, 1975
UTP, Ontario, 1980
Tomsk-7, 1993
Tokai, 1997 (level 3)
Hanford, 1997

La Hague, 1979-1980
Sellafield, 1983

Savannah River, 1965
La Hague, April 1980 (level 3)

(1) The September 1999 accident of Tokai Mura does not concern a reprocessing plant but is remarkable because of

the very generic nature of the accident, which could typically occur in a reprocessing facility
[see http://www.wise-paris.org/introournews.html for more information on the Tokai Mura accident]

Radiological consequences of some of the accidents listed above

One  of  the  most  important  accidents  in  a  reprocessing  plant  is  the 1957  explosion  at  the Chelyabinsk-65
nuclear complex, which engendered the evacuation of 10,000  people  in  a 1,000 km2  area.  In  the  evacuated
area,  the  concentration  of  strontium-90  exceeded  3 Ci/km2 (111,000 Bq/m2).  Contamination  in  the
surrounding  area  of  15,000 km2 (occupied  by 270,000  people)  revealed  concentrations  of  strontium-90
of 0.1-3 Ci per square km.

The fire plus explosion which occurred at Tokai Mura bitumenisation facility in March 1997 contaminated
37 workers while an area of 1 km2 around the plant was evacuated.

The  Tokai Mura  criticality  accident  is  exceptional  because  of  its  off-site  effects.  The  evacuation  area
extended to 350 m around the plant and people were ordered to stay at home in a surrounding area of 10 km.
As  of  30 October 2000,  Japan STA  reported 667  people  exposed  to  radiation.  Two  out  of  three  workers
directly  implied  in  the  accident  have  died.  In  total 73  people  received  doses  between 45  and  50 mSv,
200 people  received  dose  between 20  and  25 mSv,  103 people  received  dose  between 15  and  20 mSv  and
60 people received doses between 5 and 10 mSv. Contamination by iodine-131 has been detected in drinking
water and milk (max. 300 Bq/kg) as well as in food (max. 200 Bq/kg), according to CNIC (Citizen’s Nuclear
Information Center), Japan.

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ANNEX 19 Comparison of Caesium-137 Contained in Spent Fuels Stored

at La Hague and Released During the Chernobyl Accident

(a) Estimation of Caesium-137 Stored at La Hague

Table 35 Fuel Storage at La Hague (as of 31 May 2001, in tons of heavy metal tHM)

France

Germany

Belgium Switzerland Netherlands

Australia

Spent LWR

Spent REPU

Spent MOX

Spent MTR

Fresh MOX

6,846.7

176.5

45.2

94.5

20.6

17.9

164.4

0.32

81.6

1.4

48.9

0

9.6

0

0

0.22

0

0

0

0

0

0

0

0

0

0

0

0

0.15

0

Source: COGEMA (www.cogemalahague.fr)

With  a  total  of  fuels  stored  of 7,507.99  tHM,  caesium-137  contained  in  La  Hague  spent  fuel  storage63
is 7.58 tons.

(b) Release of Caesium-137 During the Chernobyl Accident

Conservative figure for caesium-137 fraction released: 85 PBq (for 280 PBq in core) [NEA, 1995]. Therefore
caesium-137 released64 from the Chernobyl accident was about 26.4 kg.

(c) Possible Impact of Caesium-137 in Case of a Major Accident at La Hague

Cooling Ponds

The  worldwide  impact  of  the  Chernobyl  accident  has  been  estimated  to  600,000 man.Sv,  of  which
around 75%  due  to  caesium-137  alone  (from  60%  for  Southern  countries  to  75%  for  Northern  countries
which are the most concerned areas in terms of impact, by the Chernobyl accident)65 [UNSCEAR, 1988; see
Annex D].  Considering  the  75%  share  of caesium-137  in  the  total  collective  dose  received  from  the
Chernobyl  accident,  it  can  be  estimated  than  the  worldwide  impact  of  the  Chernobyl caesium-137  release
alone is around 450,000 man.Sv.

In the following calculations, we consider the smallest UP3 cooling pond, or D pond, of 3,490 t of capacity
and  a  50%  load  factor.66  The  potential  for  a  zirconium  “fire”,  following  a  loss  of  water,  arises  from  the
packing of fuel pools to high densities [Thompson, 2000a]. A loss of water accident in the D cooling pond
could lead, because of exothermic oxidation reactions of zirconium and other metals, to an accidental release
up to 100% of the total caesium-137 contained in the 1,745 t of spent fuels stored [NRC, 2000]. This release
would  be  equivalent  to  1,762.1 kg  of  caesium-137,  or  66.7 times  the  total  caesium-137  release  as  a
consequence of the Chernobyl accident.

Assuming identical dispersion and impact pathways in the cases of the hypothetical La Hague accident and
the Chernobyl accident, the collective dose impact of the caesium-137 during the La Hague D cooling pond
accident can be estimated to some 30,000,000 man.Sv or 50 times the collective dose impact of Chernobyl.
Considering  the  ICPR-60  figure  of  a  5%  risk  of  fatal  cancer  per Sv [ICRP,  1991]  it  can  therefore  be
estimated that the caesium-137 release during a major accident such as the loss of coolant in the D cooling
pond of La Hague, could cause up to 1,5 million fatal cancers.

63  With caesium-137 activity in one ton of spent UOX with a burnup of 33 GWd/t, 3,25% of initial U-235 enrichment

and 3 years of cooling period: 8.78 104 Ci/t = 3.25 1015 Bq/t

64  With caesium-137 activity: 3.2174 1012 Bq/g [from Vade Mecum du technicien nucléaire, tome 2, Ed.1980].
65  The share of the collective dose is 53% in European coutries, 36% in the former USSR, 8% in Asia, 2% in Africa.
66 That is a realistic assumption considering that currently a total of 7,508 t of spent fuel are stored at La Hague for a

total capacity of 13,990 t.

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 20 Concentration Factors for Selected Radionuclides

Table 36 Concentration Factors of Some Key Radionuclides Released by Reprocessing Plants

Tritium
3H

Iodine-129
129I

Technetium-99
99Tc

Carbon-14
14C

Half-life (years)

12

15.7 106

Concentration factor (seaweed)

l/kg fresh

Concentration factor (shellfish)

l/kg fresh

Concentration factor (mollusc)

l/kg fresh

Concentration factor (sediments)

l/kg dry

1

1

1

1

10,000

100

100

500

214,000

30,000

5,730

5,000

1 300

5,000

400

100

5,000

2,000

Source : [GRNC, GT-3, 1999]

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ANNEX 21 Comparison between the Morbidity Observed in the District

of Cherbourg and in the District of Avranches

Table 37 Observed and Expected Cancer Cases in the District of Cherbourg and the District

of Avranches for the years 1979-1980-1981

Cancers

observed/expected cases

SIR(3)

observed/expected cases

SIR(3)

Cherbourg(1)

Avranches(2)

Men

Oral cavity, pharynx

Œsophagus

Stomach

Colon, rectum

Respiratory organs

Leukæmias

All cancers

Women

Œsophagus

Stomach

Colon, rectum

Bronchial tubes

Breast

Neck of the womb

Leukæmias

All cancers

138

87

87

91

214

33

937

6

45

93

16

196

41

20

625

/

/

/

/

/

/

/

/

/

/

/

/

/

/

/

117,6

94,8

75,1

96,6

147,3

26,9

867,5

7,5

49,4

87,9

11,0

178,5

40,3

14,9

659,8

117

92

116

94

145

123

108

80

91

104

145

110

102

134

95

87

92

63

84

74

16

/ 96,1

/ 79,4

/ 63,4

/ 82,0

/ 121,9

/ 21,8

622

/ 722,8

9

54

73

4

/ 6,5

/ 43,1

/ 78,1

/ 9,3

154

/ 148,7

26

6

/ 32,8

/ 11,8

571

/ 557,9

91

116

99

102

61

73

92

138

125

93

43

104

79

51

102

(1) Cherbourg is localized in the North-Cotentin, 15 km away from La Hague (North of the Manche département).
(2) Avranches is 150 km at the South of La Hague plant (South of the Manche département).
(3) SIR: Standardized Incidence Ratio (number of observed cases / number of expected cases x 100).  “When the SIR
is  beyond 120,  it  means  that […]  the  number  of  new  cancer  cases  has  been  beyond  the  average  of  the
département [Manche] for these three years [1979-1980-1981].”

Source : “Le cancer dans la Manche, 1979.1980.1981”, Observatoire Régional de la Santé de Basse-Normandie

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ANNEX 22 Individual Committed Dose for Six Reference Groups

near La Hague (GRNC Estimates)

Table 38 Individual Committed Dose in 1985 and 1996 near La Hague for Six Reference Groups,

as calculate by Radio-ecological Group of North-Cotentin (in microSievert, µSv)

Scenarios

Inhabitants of “Digulleville” (1)

Fishermen of “Goury” (2)

Farmers living within an aera situated at less than
1500 m from the gaseous discharge point source

Fishermen “zone des Huquets”

Farmers of “Pont-Durand”

“Mean adult”  of the La Hague County

1985
(µSv)

1996
(µSv)

Main exposure pathway and
major radionuclides (1996)

14

41

38

226

53

18

8

5

24

20

59

5

Ingestion
85Kr, 14C, 129I,36Cl
Ingestion
14C, 129I, 85Kr ,106Ru, 60Co
Ingestion
14C, 129I, 85Kr
Ingestion
14C, 106Ru, 129I, 60Co
Ingestion
129I, 14C, 85Kr
Ingestion
85Kr, 14C, 129I

(1) These  two reference  groups  have  been  chosen  by  COGEMA,  they  have  been  described  in  the  public  inquiry

report, February 2000.

(2) During the 30 years of operation (1966-1996), marine discharges from La Hague were at a maximum in 1985 and

atmospheric releases were at a maximum in 1996.

Source: [GRNC, GT-4, 1999, Annex 12]

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ANNEX 23 OECD Nuclear Energy Agency Dose Estimates for the Public and

Workers for the Reprocessing and Direct Disposal Options

Table 39 Comparison of the Collective Dose to General Public and Workers in Two Options

for Spent Fuel Management – Direct Disposal (Once-Through Cycle) and Reprocessing

Public (generic calculations)
Collective dose truncated at 500 years
(man.Sv/GW.a)

Workers (operational data)
Annual collective dose
(man.Sv/GW.a)

Fuel cycle stage

Once-through

Reprocessing

Once-through

Reprocessing

Mining and milling

1.0

Fuel conversion and
enrichment

Fuel fabrication

Power generation

Reprocessing,
vitrification

Transportation

Disposal

Total

0.0009

0.6

Not applicable

Trivial

0

1.6

0.8

0.6

1.2

Trivial

0

2.6

0.02-0.18

0.008-0.02

0.016-0.14

0.006-0.016

0.007

1.0-2.7

0.094

Not applicable

0.014

0.005-0.02

Trivial

1.04 - 2.93

0.005-0.03

Trivial

1.14 - 2.99
Source : [NEA, 2000]

The  collective  dose  is  the  sum  of  the  doses  to  all  the  individuals  in  an  exposed  population (in  this  study,
collective doses are summed to a limited period of 500 years). The unit is the man.sievert (man.Sv). Releases
and  discharges  into  the  marine  environment  and  into  the  atmosphere  have  been  normalised  to  one  unit  of
electricity  produced (1 Gigawatt.year),  and  the  collective  dose  has  consequently  been  normalised  as
well (manSv/GW.a).

The  number  of  delayed  radiation-induced  health  effects  (fatal  cancers)  is  in  proportion  to  the  collective
dose (as notified in the International Commission on Radiological Protection Recommendations).

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ANNEX 24 Assessment of the “non-attributed” activity of Iodine-129

at La Hague

Differences between the theoretical quantities of iodine-129 (129I) brought into the La Hague plant (in spent
fuel) and iodine-129 discharges should be small.

The  theoretical  quantities  of  iodine-129  in  spent  fuel  have  been  calculated  according  to  two codes,
COGEMA 1998 and UNSCEAR 1993. Potentiel iodine-129 activity is calculated following the formula:

A (GBq/y) = (Reprocessed quantity in t / 25) x (Fuel burnup in MWdays per t / 33,000) x 0,925 GWe x K

where  K  is  the  conversion  factor  used  by  the  code.  The  codes  use  significantly  different  values  for  K,  i.e.
K = 30 GBq/GWe from  COGEMA;  K = 42 GBq/GWe  from  UNSCEAR (one  can  also  find  in  a  1980  code
from NEA/OCDE the value K = 50 GBq/GWe). There is no direct explanation to such a difference.

The gap is expressed in GBq per year and in percent of theoretical activity in spent fuel. The calculation does
not  take  into  account  the  quantities  of  iodine-129  that  are  held  in  the  filters,  as  they  are  supposed  to  be
negligeable.  Half  of  the  quantity  theoretically  introduced  into  the  La Hague  facilities  in 1991  remains
“unattributed”  following the UNSCEAR code. For 11 years of operation, 5,213 GBq, or 30.3% of the treated
iodine, remains “unattributed” with the same code. With the COGEMA code, 7% is unanswered for.

Table 40 Evaluation of “Unattributed”  Iodine-129 Activity at La Hague (1989-1999)

using COGEMA and UNSCEAR Codes

[A] Potential 129I activity

COG 98

UNS 93

[B]
Liquid
releases

[C]
Gaseous
releases

Reprocessed
quantities (t)

Fuel burnup
(MW.d/t)

Year

1989

460.6

25,623

1990

525.7

25,121

1991

662.5

30,509

1992

668.1

26,790

1993

955.2

24,657

397

444

680

602

792

556

622

952

843

1,109

262

327

455

479

646

1994

1.276.3

29,437

1,264

1,769

1,120

1995

1.558.7

30,519

1,600

2,240

1,530

1996

1.680.9

28,102

1,589

2,224

1,690

1997

1.669.9

30,000

1,685

2,359

1,630

1998

1.628.7

30,000

1,644

2,301

1,780

1999

1.562.0

30,000

1,576

2,207

1,830

Gap: A - (B + C)

COG 98
108
(27%)
99
(22%)
202
(30%)
112
(19%)
136
(17%)
123
(10%)
38
(2%)

-139

38
(2%)

-152

-261

UNS 93
267
(48%)
277
(45%)
474
(50%)
353
(42%)
453
(41%)
628
(36%)
678
(30%)
496
(22%)
712
(30%)
505
(22%)
370
(17%)

27

18

23

11

10

21

32

38

17

16

7

Total
17,182
(1) This total does not include any negative figure for logical reasons (i.e. unaccounted material cannot be negative)

11,749

12,273

5,213

220

856 (1)

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ANNEX 25 Letter to Annie Sugier, President of the Radio-Ecological Group

North-Cotentin, about Iodine-129

Madame Annie SUGIER

Directrice déléguée à la protection de l’IPSN
Présidente du Groupe Radioécologie Nord-Cotentin
Institut de Protection et de Sûreté Nucléaire
BP6
92225 FONTENAY-AUX-ROSES Cédex

Paris, le 9 mai 2001

Madame la Présidente,

Tout d’abord, je vous remercie vivement de l’intérêt que vous portez et du temps que vous avez consacré à la
discussion  de  questions  liées  à  l’étude  que  nous  menons  pour  le  programme  STOA  (Scientific  and
Technological Option Assessment) du Parlement Européen sur l’impact des usines de Sellafield et La Hague.

Si la réunion du 27 avril 2001 dans les locaux de l’IPSN n’a pas permis de conclure sur un certain nombre de
questions,  elle  a  clarifié  l’intérêt  d’évaluer  plus  à  fond  certaines  incertitudes  inhérentes  à  l’état  des
connaissances sur l’impact des rejets des usines de retraitement. WISE-Paris a notamment soulevé un certain
nombre de problèmes liés aux incertitudes sur le bilan en Iode 129 et l’évaluation de l’impact des émissions,
sans pour autant pouvoir exclure des problèmes similaires pour d’autres radionucléides rejetés. Vu la gravité
potentielle de l’impact sur l’homme et l’environnement  des  ces  émissions  nous  estimons  urgent  la  mise  en
place d’une procédure permettant d’apporter des réponses satisfaisantes à ces interrogations.

Nous  sommes  très  conscients  du  fait  que  l’analyse  de  ces  questions  prenne  largement  plus  de  temps  que
disponible dans le cadre de notre mission pour le Parlement Européen. C’est pourquoi nous reprenons avec
grand  intérêt  votre  suggestion  de  l’établissement  d’un  groupe  de  travail  avec  l’IPSN  (et  peut-être  d’autres
organismes  ou  experts  indépendants)  focalisé  sur  des  questions  précises  à  l’instar  du  groupe  de  travail
constitué  suite  aux  interrogations  formulées  par  André  Guillemette  en  octobre 1999.  Nous  sommes  prêts  à
participer à un tel groupe de travail, selon des modalités qui restent à définir ensemble.

Veuillez trouver ci-dessous un résumé des questions qui pourraient faire l’objet d’un examen par un groupe
de travail :

1) Incertitudes sur le bilan en Iode 129 :

Ce  point  fondamental  a  été  mis  en  évidence  par  le  GT 1  du  Groupe  Radioécologie  Nord-Cotentin,
notamment dans la figure 11c (page 144 du rapport) qui établit sur la période 1966-1976 la « comparaison de
l'activité  de  l'iode 129  dans  les  rejets  gazeux  avec  la  différence  d'activité  entre  le  combustible  et  les  rejets
liquides ».  Cette  figure  établit  en  particulier  à  partir  de  1977  une  comparaison  entre  l'activité
théorique (combustible  moins  rejets  liquides)  et  mesurée  des  rejets  gazeux,  et  démontre  des  écarts  très
importants, notamment pour la première moitié de la décennie 1990-2000.

Ce résultat important ne fait malheureusement l'objet d'aucune explication ni d'aucun commentaire du GT1.

Nous avons reconstitué, à partir des tonnages et des taux de combustion moyens des combustibles retraités,
les activités théoriques en iode 129 dans le combustible pour les années 1989 à 1999, en utilisant différents
coefficients de conversion (GBq d'iode 129 par GW électrique). Les chiffres obtenus ont été comparés à la

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chronique des rejets liquides et gazeux mesurés pour la même période. Les résultats sont présentés dans le
tableau 1 en annexe.

On constate des écarts très importants entre l'activité théorique et l'activité rejetée mesurée. Si l'on utilise la
valeur  du  coefficient  retenue  par  COGEMA  en 1998 (30 GBq/GWé),  cet  écart  peut  se  produire  dans  les 2
sens :  ainsi,  on  trouve 202 GBq  d'iode 129  non  attribués  pour 1991,  mais  inversement  les  rejets  mesurés
dépassent de 261 GBq l'activité théorique pour 1999. Toutefois, ce coefficient est inférieur à d'autres valeurs
utilisées  par  l'UNSCEAR  en 1993  et  l'AEN  en 1980 (respectivement  42  et  50 GBq/GWé).  Si  ces  valeurs
doivent être retenues, les évaluations de l'activité non attribuée (c'est-à-dire non retrouvée dans les mesures
de rejets) varient entre 267 et 1.161 GBq par an.

Selon  ces  calculs,  l'activité  non  attribuée  apparaît  certaines  années  égale  ou  supérieure  à  la  totalité  de
l'activité  mesurée  dans  les  rejets  (on  trouve  ainsi,  avec  le  coefficient  UNSCEAR,  474 GBq  non  attribués
contre 478 GBq mesurés dans les rejets pour l'année 1991). Les évaluations du bilan en iode 129 des usines
de retraitement à La Hague semblent donc soumises à une très grande incertitude.

Sur le même sujet du bilan en iode, j'attire également votre attention sur des calculs effectués par l'Institut de
Protection et de Sûreté Nucléaire en 1993 dans un rapport sur la sûreté de l'usine UP3-A. Ce document, dont
WISE-Paris n'a qu'une connaissance partielle, semble contenir des évaluations du bilan en iode 129 de 1990
au  premier  semestre 1993  marquées  par  de  multiples  erreurs  ou  approximations.  En  particulier,  le  bilan
semble basé sur une valeur plus faible de l'activité massique de l'iode 129 que la valeur usuelle (5,2 MBq/g
au lieu de 6,5 Bq/g).

Les résultats obtenus en remplaçant la première valeur par la seconde sont rassemblés dans le tableau 2 en
annexe :  les  calculs  de  l'IPSN  mettaient  en  évidence  des  écarts  inférieurs  à 5 %, sauf pour 1990  où  l'écart
atteint 43 % ; après correction de l'activité massique, l'activité non attribuée est toujours supérieure à 20 % de
l'activité théorique, et atteint même 54 % pour l'année 1990.

Cette analyse, si elle est confirmée, renforce le sentiment qu'il existe dans les bilans actuels une très grande
incertitude sur l'iode 129, résultant en quantités significatives d'activité non attribuée.

2) Les impacts potentiels de l'activité non attribuée en Iode 129 :

Les quantités en iode correspondant à cette activité non attribuée peuvent être retenues dans les installations,
« piégées »  dans  les  déchets  ou  rejetées  dans  l'environnement. Ces  quantités  paraissent  en  tous  cas
suffisamment  importantes  pour  que  l'on  s'interroge  sur  leur  impact  potentiel  en  termes  de  doses  à  la
population. On a ainsi cherché, par des calculs simples, à évaluer les ordres de grandeur de l'impact éventuel
lié à l'activité non attribuée en iode 129. On a développé ces calculs pour :

- la dose moyenne à la population du canton due à l'exposition interne par inhalation (rejets gazeux),
- la dose moyenne à la population du canton due à l'ingestion d'aliments marins (rejets liquides),
- la dose collective globale à long terme.

Dans  l'ensemble  de  ces  calculs,  on  a  retenu  systématiquement  l'hypothèse  la  plus  pénalisante,  afin  de
mesurer  le  risque  d'erreur  maximal  lié  à  l'incertitude  sur  le  bilan  en  iode 129.  Ainsi,  on  suppose  lorsqu'on
évalue la dose liée aux rejets gazeux par exemple que l'ensemble de l'activité non attribuée en iode 129  est
rejetée sous cette forme, ce qui est une hypothèse vraisemblablement maximaliste. De même on suppose que
la totalité se trouve dans les rejets liquides lorsqu'on calcule la dose par ingestion d'aliments marins.

• Exposition interne par inhalation  :

À partir de la formule 1 présentée en annexe, on peut calculer la dose induite pour la population du canton
par  l'iode 129,  selon  la  voie  aérienne  par  inhalation  directe.  Dans  le  cas  où  l'ensemble  de  l'iode 129
correspondant  à  l'activité  non  attribuée  se  retrouvait  dans  cette  voie,  on  obtient  ainsi  une  dose  de  33 mSv
pour  l'ensemble  de  la  période  1989-1999 (à  partir  des  résultats  du  tableau 1,  colonne AEN80).  Cette  dose
correspond  à  une  moyenne  de  3 mSv/an  pour  l'ensemble  de  la  population  du  canton,  ou  encore  de
0,4 microSv pour un individu en un an.

La  dose  potentielle  peut  atteindre,  pour  un  habitant  de  Pont-Durand (point  où  le  coefficient  de  transfert
atmosphérique  est  le  plus  élevé  du  canton,  avec  un  maximum  de 3,42 10-7 s/m3,  contre  5,36 10-8 s/m3  en

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moyenne) des valeurs 6 fois plus élevées. Ce chiffre se rapproche de la dose efficace totale calculée par le
GT 4 du GRNC pour un individu « moyen » du canton de Beaumont-Hague, qui s'élève à 5 microSv par an.

• Exposition interne par ingestion :

De  la  même  manière,  à  partir  de  la  formule 2  présentée  en  annexe,  on  calcule  la  dose  induite  pour  un
individu  ou  un  groupe  par  l'iode 129,  selon  la  voie  alimentaire.  Dans  le  cas  où  l'ensemble  de  l'iode 129
correspondant  à  l'activité  non  attribué  se  trouverait  dans  les  rejets  liquides,  celle-ci  représenterait  par
exemple pour le groupe de référence des pêcheurs de Goury une dose individuelle de 31,6 microSv pour la
période 1989-1999. Cette dose correspond en moyenne à 2,9 microSv par individu chaque année.

• Dose collective globale :

À  partir  des  modèles  de  dispersion  globale  utilisés  pour  calculer  la  dose  collective  à  très  long
terme (10.000 ans, 100.000 ans ou pour un temps infini) pour l'ensemble de la population mondiale, on peut
comparer  la  dose  collective  maximale  que  peut  représenter  l'activité  non  attribuée  en  iode 129  à  la  dose
collective estimée à partir des rejets mesurés.

Les  résultats  sont  résumés  au  tableau 3  pour  deux  modèles  développés  par  l'AIEA  en 1985  et  par
l'UNSCEAR  en 1993.  Si  le  modèle  UNSCEAR  retient  un  facteur  de  dose  très  faible  pour  l'iode 129,  le
modèle  AIEA  retient  des  facteurs  plusieurs  centaines  de  fois  plus  élevés  qui  conduisent  à  des  valeurs  très
fortes :  ainsi,  dans  l'hypothèse  la  plus  pénalisante (toute  l'activité  non  attribuée  est  rejetée  sous  forme
gazeuse),  l'activité  non  attribuée  représente  1.817 h.Sv,  alors  que  l'ensemble  des  principaux  rejets
déclarés (tritium, iode 129, carbone 14 et krypton 85) ne représente que 4 fois plus avec 7.265 h.Sv.

En vous remerciant par avance pour l’intérêt que vous voulez bien porter à ces questions, veuillez accepter,
Madame la Présidente, l’expression de mes salutations cordiales.

Mycle SCHNEIDER,
Directeur de WISE-Paris.

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Annexes à la Lettre à Annie Sugier, Présidente du GRNC :
Tableau 1. Estimation  de  l'activité  en  iode 129  dans  le  combustible  retraité1  et  calcul  de  l'activité  non

attribuée2 en iode 129 dans les installations de COGEMA-La Hague, 1989-1999 (en GBq)

Année

Tonnage
retraité (t)

1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999

460,6
525,7
662,5
668,1
955,2
1.276,3
1.558,7
1.680,9
1.669,9
1.628,7
1.562,0

Tc

(MW.j/t) AEN80

(A) Potentiel 129I combustible
COG98
UN93

25.623
25.121
30.509
26.790
24.657
29.437
30.519
28.102
30.000
30.000
30.000

662
740
1.133
1.003
1.320
2.106
2.667
2.648
2.808
2.739
2.627

556
622
952
843
1.109
1.769
2.240
2.224
2.359
2.301
2.207

397
444
680
602
792
1.264
1.600
1.589
1.685
1.644
1.576

(B) Rejets
liquides

262
327
455
479
646
1.120
1.530
1.690
1.630
1.780
1.830

(C) Rejets

Activité non attribuée (A-B-C)
UN93

COG98

gazeux AEN80

27
18
23
11
10
21
32
38
17
16
7

373
395
655
513
664
965
1.105
920
1.161
943
790

267
277
474
353
453
628
678
496
712
505
370

108
99
202
112
136
123
38
-139
38
-152
-261

1. Le  potentiel  d'activité  en  iode 129  dans  le  combustible  retraité (A)  est  calculé  à  partir  du  tonnage  retraité  TR  et  du  taux  de
combustion moyen Tc selon la formule : A (en GBq/an) = (TR/25) x (Tc/33000) x 0,925 x K.
Cette formule correspond à l'hypothèse selon laquelle 25 tonnes de combustible usé à 33 GW.j/t alimentent 0,925 GWélec par an.
K  exprime  le  ratio  GBq/GWélectrique  utilisé  pour  l'iode 129,  qui  dépend  du  code  de  calcul  utilisé  pour  évaluer  le  contenu  du
combustible irradié. On a utilisé ici trois coefficients :

- AEN80 : 50 GBq/GWé, utilisé par l'Agence de l'Énergie Nucléaire (OCDE) en 1980 ;
- UN93 :
42 GBq/GWé, utilisé par l'UNSCEAR (Nations-Unies) en 1993 ;
- COG98 : 30 GBq/GWé, utilisé par COGEMA en 1998, et qui correspond à une hypothèse de facteur de charge = 60 % par

rapport à un facteur de charge = 100 % pour l'AEN80.

2. L'activité  non  attribuée  en  iode  129  est  calculée  en  retranchant  de  l'activité  théorique  dans  le  combustible (A)  les  activités  en
iode 129 mesurées dans les rejets liquides (B) et gazeux (C).

Tableau 2. Bilan en iode 129 calculé par l'IPSN et « corrigé » pour l'usine UP3-A de La Hague et calcul
de l'activité non attribuée en iode 129 correspondante, de 1990 au 1er semestre 1993 (en MBq)

Année

Activité théorique1

IPSN

Corr.

Activité des différents rejets

Rejets
en mer

Transfert
à STE

Filtres

1990

190.632

238.290

101.000

3.484

1991

343.138

428.922

321.900

2.722

450

860

Résidus3
dissolution

2.288

Rejets
gazeux

1.107

4.118

4.217

1992

432.500

540.625

408.900

3.585

1.667

5.190

5.486

19932

379.000

473.750

351.600

2.876

1.102

4.548

3.697

Activité non attribuée4

IPSN

Corr.

82.303
(43,2 %)
9.321
(2,7 %)
7.672
(1,8 %)
15.177
(4,0 %)

129.961
(54,5 %)
95.105
(22,2 %)
115.797
(21,4 %)
109.927
(23,2 %)

1. L'activité théorique est calculée selon la formule : activité = activité massique x tonnage retraité x concentration.
On retient une valeur de 188 g/t pour la concentration en iode 129, valeur moyenne utilisée par l'IPSN pour les années 1992-1993 (on
trouve dans la littérature des valeurs variant au moins de 170 à 230 g/t).
La colonne IPSN indique l'activité théorique obtenue avec la valeur de 5,2 MBq/g utilisée par l'IPSN dans son rapport de 1993, la
colonne Corr. indique l'activité théorique corrigée avec la valeur usuelle de 6,5 MBq/g.

2. Bilan calculé pour le premier semestre de l'année 1993 seulement.

3. Les résidus de la ligne de dissolution représentent 1,2 % du total.

4. L'activité non attribuée en iode 129 est la différence entre l'activité théorique et la somme des activités des différents rejets.

       127

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Formule 1. Calcul de la dose collective pour la population du canton par inhalation d'iode 129 présent

dans les rejets gazeux des usines de La Hague

Dose = pop. canton x débit rejets x débit respiratoire x CTAdp x FCDinh

où :

• pop. canton est la population du canton (soit 7.572 personnes),
• débit rejets est le débit d'activité en iode en sortie de cheminée (en Bq/s),
• débit respiratoire est de 8.400 m3/an pour un adulte,
• CTAdp est le coefficient de transfert atmosphérique « doublement pondéré » (max. 5,36 10-8 s/m3),
• FCDinh est le facteur de conversion de dose pour l'iode 129, dans le cas de l'inhalation (soit 3,6 10–
8 Sv/Bq, selon la Directive Euratom 96/29).

Formule 2. Calcul  de  la  dose  collective  pour  la  population  du  canton  par  ingestion  dans  les  aliments

marins d'iode 129 présent dans les rejets liquides des usines de La Hague

Dose = ? i [Quantité Ai x Activité Ai] x FCDing

où :

• les Ai sont les aliments marins, avec :
Quantité Ai est la quantité absorbée par la population considérée (en kg/an),
Activité Ai = débit rejets x FD x fraction en suspension x FCi, (en Bq/kg frais),
avec :

- débit rejets est le débit d'activité en iode en sortie de conduite (en TBq/an),
- FD est le facteur de dilution (3,42 Bq/m3 par TBq/an à l'anse des Huquets),
- fraction en suspension (1 – taux de sédimentation) est supposée quasi égale à 1,
- FCi est le facteur de concentration de l'espèce marine donnant Ai (en l/kg),

• FCDing est le facteur de conversion de dose pour l'iode 129, dans le cas de l'ingestion (soit 1,1 10–
7 Sv/Bq, selon la Directive Euratom 96/29).

Tableau 3. Dose collective induite par les rejets de tritium, iode 129, carbone 14 et krypton 85 des usines
de La Hague pour l'année 1999, et estimation de la dose collective potentielle liée à l'activité
non attribuée en iode 129 pour la même année

Rejets1 1999
La Hague (TBq)

h.Sv/TBq2

h.Sv

AIEA 85

UNSCEAR 93

AIEA 85

UNSCEAR 93

Tritium

Iode 129

Carbone 14

Krypton 85

Total (1999)

Iode 129
non attribué
(1999, AEN3)

gaz
liquide
gaz
liquide
gaz
liquide
gaz
liquide

gaz
ou
liquide

1. Données COGEMA.

80
12.900
0,0074
1,83
19
9,93
30.000
-

0,79
ou
0,79

0,00942
0,000045
2.300
1.700

142

0,000093
?

2.300

1.700

0,00120
0,00012
4
4
85
85
0,0002
?

4

4

0,75
0,58
17,02
3.111,00

4.108,06

27,90
-
7.265,31

1.817
ou
1.343

0,096
1,548
0,0296
7,32
1.615
844,05
60
-
2.528,04

3,16
ou
3,16

2. Les facteurs de dose sont tirés des modèles de dispersion globale suivants :

- AIEA 85 :  modèle  développé  par  l'Agence  Internationale  pour  l'Énergie  Atomique  en 1985 (Technical  reports  Series
n° 250), repris par le CEPN pour les études préparatoires ExternE en 1995. Ce modèle prend en compte un e durée de 100.000 ans et
une population de 10 milliards d'individus ;

- UNSCEAR 93 :  modèle  développé  par  l'UNSCEAR  en 1993 (Report  to  the  General  Assembly)  pour  une  durée  de

100.000 ans et une population de 10 milliards d'individus (5 milliards pour le tritium et le krypton).

3. Valeur de l'activité non attribuée en iode 129 pour l'année 1999 selon le code AEN80 (cf. tableau 1).

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

ANNEX 26 Separation, Re-Use and Exportation of Plutonium in France

Table 41 Separation, Use or Exportation of Plutonium, France

Quantities as of the end of 1998 (t)

Separated Plutonium

UNGG fuel (reprocessed until 1989)

UNGG fuel (reprocessed from 1990)

UOX fuel (reprocessed until 1989)

UOX fuel (reprocessed from 1990)

RNR fuel (reprocessed until 1989)

RNR fuel (reprocessed from 1990)

MOX fuel (reprocessed from 1990)

[A] Total separated

Re-use or exportation of Plutonium

Use in RNR fuel

Use in MOX fuel

Sent to foreign country/client (others than Belgonucléaire)

Sent to Belgonucléaire

[B] Total re-used or exported

Plutonium stock in France [A - B]

17.3

5.5

26.5

102.9

5.7

0.2

0.5

158.6

18.1

24.1

25.9

14.6

82.7

75.9
Source: WISE-Paris, 2000

Table 42 Separation and Re-Use of French Plutonium

Origin / Use of Plutonium

Separated Plutonium Plutonium Re-Used

Plutonium quantities as of the end of 1998 (t)

UNGG Fuel

UOX Fuel

RNR Fuel

MOX Fuel

Military

Total

55,6

22,7

5,9

0,2

?

84,4

–

–

17,0

22,9

2,0

41,9
Source: WISE-Paris, 2000

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ANNEX 27 Material and Economic Balances over the French Reactor Lifetime -

Direct Disposal vs. Reprocessing

Table 43 Material and Economic Balances Associated to the French Nuclear Reactors, 1977-2049

(hypothesis of 45 years average lifetime)

Hypothesis
on Reprocessing

Stops
in 2010

Continued
Partial (60-70%
of spent fuel)

Continued
Total (100%
of spent fuel)

None
(over the
whole period)

Generated electricity (TWh)

20,238

20,238

20,238

20,238

Material balances

Natural uranium (kt)

Reprocessed UOX (kt)

Separated re-used Pu (t)

Irradiated UOX to Store (kt)

Irradiated MOX to Store (kt)
Final content in Pu (4) (t)
MLW (m3)

from reactors’  operation

from reprocessing

HLW (m3)

Economic balance

Capital investment (3)
Operation

Fuel Cycle

Cycle front end

Cycle back end

End of cycle

Total of expenses (GF)
Cost per kWh (1) (ctsF)
Capital investment

Operation

Fuel Cycle

Cycle front end

Cycle back end

End of cycle

460

15.0

146

41.0

2.0

602

31,786
20,000

11,786

1,601

682

1,297

909

602

195

112

2,888

14.27

3.36

6.41

4.49
2.97

0.96

0.55

447

26.2

275

28.6

3.5

555

34,825
20,000

14,825

3,325

682

1,297

931

589

232

110

2,910

14.38

3.36

6.41

4.60
2.91

1.15

0.54

437

36.1

387

17.6

4.8

514

38,091
20,000

18,091

4,808

682

1,297

948

578

263

107

2,927

14.46

3.36

6.41

4.68
2.86

1.29

0.53

475

0.0

0

58.3

0.0

667

20,000
20,000

0

0

652

1,297

814

611

86

116

2,763

13.65

3.22

6.41

4.02
3.01

0.42

0.57

(1) Constant French Francs, 1999 value – These levelised costs are not discounted; they are derived from the global

(2)

expenses over the reactors’  fleet operating lifetime.
“Retrospective”  scenario,  where  France  would  have  chosen  the  direct  disposal  option  for  its  spent  fuel
management from the beginning in 1977.

(3) The  difference  in  the  investment  line  between  the  three  scenarios  with  reprocessing  and  the  one  without

corresponds to 30 GF additional expenses in R&D for fuel cycle back-end dedicated to reprocessing.

(4) Plutonium (plus  americium)  content  in  the  stocks  of  spent  UOX  and  MOX  that  are  eventually  not  reprocessed,

thus in the final storage.

Source: [Charpin et al, 2000]

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ANNEX 28 Dry Storage Technologies

The world’s first dry store for spent fuel was constructed in 1970 in north Wales in the UK, as an integral
part  of  the  Wylfa  reactor,  This  was  built  as  a  buffer  store  for  spent  Magnox  fuel  prior  to  its  removal  to
Sellafield for reprocessing. The store originally had a capacity of 250 tonnes, later expanded to 950 tonnes.
In  the  US,  High  Temperature  Gas  Reactor  fuel  has  been  stored  in  dry  wells  at  the  Idaho  National
Engineering  Laboratory  since 1971.  In  Manitoba,  Canada,  fuel  from  a  PWHR  demonstration  reactor  has
been stored in sealed concrete storage casks since 1975. After the mid 1970s, interest in dry stores declinned
for a period mainly because of the adoption of inexpensive reracking and double-decking technologies at fuel
storage ponds.

Since the early 1990s, interest in dry storage has grown. Dry stores are presently being commissioned or are
under  construction  in  Argentina,  Belgium,  Canada,  the  Czech  Republic,  Germany,  Hungary,  Japan,  South
Korea, Lithuania, Russia, Ukraine and the US [IAEA, 1996; 1999]. In 1992, Scottish Nuclear, in evidence to
the 1992/3 public inquiry into its dry store plans, added Mexico, Italy, India, South Africa, and Taiwan to
this  list [Hickman,  1993].  Currently  about  14%  of  stored  fuel  throughout  the  world  is  kept  in  the  dry
form [IAEA, 1999].

(a) Descriptions of Dry Stores

The distinctive characteristic of dry storage systems is their passive cooling by radiation and air convection.
Convection results from the natural thermo-syphon effect of hot spent fuel which ranges in temperature from
~200º to ~360º C. Unlike wet stores, dry stores require virtually no electrical, water, or maintenance inputs,
apart  from  that  required  for  monitoring  and  surveillance.  This  results  in  enhanced  reliability  and  safe
operational running for long periods. The nominal life of the former planned Scottish Nuclear dry store in the
UK was 100 years, including a 35 year loading period, 50 year storage period and 15 year period for fuel
unloading and encapsulation, prior to disposal [Ealing, 1993]. It is expected that dry stores may be able to
operate for periods even greater than 100 years [Schneider and Mitchell, 1992b].

A second important characteristic of dry storage systems is their heavy radiation shielding. Spent fuel, even
after  10  years’  preliminary  cooling  in  ponds,  remains  highly  radioactive;  radiation  dose  rates  from
unshielded  PWR  canisters  range  from  10  to  100  Gy  per  hour.  Dry  stores  are  therefore  exercises  in  heavy
engineering  involving  massive  shielding,  commonly  60  to  100  cm  of  heavy  density  concrete,  ductile  iron,
steel  or  steel/lead  combinations.  This  reduces  surface  dose  rates  of  shielded  casks  to  between  200  and
800 µGy per hour.

Dry stores have been in operation since 1970 with relatively few reports of accidents or failure. In 1990, a
leak  from  a  flat  roof  at  the  UK  Wylfa  dry  store  permitted  rainwater  ingress  over  a  lengthy  period.  Failure
was  primarily  due  to  poor  building  standards  (i.e.  poor  drainage),  but  the  breach  was  exacerbated  by  two
other  factors.  First,  as  the  original  plans  did  not  envisage  fuel  corrosion,  fuel  was  not  encapsulated  in  a
stainless steel envelope prior to storage and not backfilled with inert gas67. Second, the original plans did not
foresee  that  such  water-induced  corrosion  would  be  accelerated  by  salt-laden  sea  air  used  for  cooling,  as
Wylfa is adjacent to the sea. Modern dry storage plants avoid these problems.

In  May  1996,  a  fire  occurred  inside  a  BNFL  Corporation  VSC-24  cask  at  Point  Beach  in  Wisconsin,  US,
during remote welding of the cask lid [NuclearFuel, 1996]. This was due to H2 gas released from interaction
between the zinc coating of the inner container and borated water adhering from wet storage. The US NRC
has issued guidance to avoid this problem.in future.

It  is  necessary  to  store  discharged  fuel  in  cooling  ponds  to  permit  nuclide  decay  before  the  fuel  can  be
transferred to dry storage. The required duration of the initial cooling period depends on fuel burnup and the
heat-handling  capacity  of  the  store.  For  high  burnup  (>40,000  MWday/tonne)  LWR  fuel,  about  3  years’
cooling  is  required  before  it  may  be  placed  in  a  vault,  and  10  years’  cooling  before  it  may  be  placed  in  a
cask, as casks have much smaller heat-handling capacities than vaults. In all cases, spent fuel assemblies are
first dried, in some cases dismantled and reconfigured, sealed within stainless steel canisters, and placed in

67 As a result, all fuel in current vault systems is encapsulated

       131

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

the outer cask or vault. Casks or modules are placed on concrete pads in the open air or within hangar-type
buildings..

(b) Functions and Regulatory Criteria of Storage

The  main  functions  of  spent  fuel  storage  systems  are  heat  removal,  subcriticality,  and  radiation  shielding.
Accordingly,  the  key  criteria  for  many  national  regulators [Ealing,  1993;  IAEA,  1994]  are,  in  order
of importance

• low temperature of stored fuel,
• subcriticality,
• assurance of heat removal,
• low doses to operators and public,
• environmental protection,
• low volume of waste produced,
• physical protection,
• safeguards against diversion, and
• storage not to prejudice final disposal route.

As  of  1994,  there  were  no  published  UK  regulatory  criteria  for  the  storage  and  disposal  of  spent  fuel  or
vitrified HLW [Griffin, 1994], and it would appear that the same is the case for French spent fuel.

Criticality  is  an  important  consideration.  Fuel  in  dry  stores  which  is  kept  in  the  same  geometrical
configuration  as  in  wet  stores  is  inherently  subcritical [Pacific-Sierra,  1991],  due  to  the  absence  of
moderating water. At least in theory, no burnup credit is allowed by US regulators [NRC, 1996] in deciding
criticality criteria, i.e., the geometric configuration of spent fuel in dry storage must be the same as that for
fresh fuel. This means that, although spent fuel contains lower concentrations of fissile isotopes than fresh
fuel,  US  spent  fuel  may  not  be  consolidated  to  save  space  in  dry  storage  containers.  Regulators  in  other
countries allow burnup credit however.

Another prime consideration for most nuclear regulators is that spent fuel should be maintained in the best
possible condition, in order to facilitate retrieval and final disposal in the future [Carter and Bower, 1995].
This  requires  fuel  to  be  kept  at  as  low  a  temperature  as  possible.  Fuel  temperatures  are  important  as  most
mechanisms  promoting  the  degradation  of  fuel  cladding  are  temperature  dependent [Manektela,  1993].  In
Hungary,  the  maximum  allowed  temperature  is  250°C  for  Russian  VVER  fuel.  In  the  US  and  Germany,
which  use  GE/Siemens  BWR  or  Westinghouse  PWR  fuels,  higher  maximum  temperatures  of  340°  to
360°C [NRC, 1996] are allowed, due to the higher resistance of zirconium-clad fuels to oxidation [Pacific-
Sierra, 1991]. In practice, temperature control is the main operating criterion of dry stores.

(c) Performance of Fuel Cladding in Dry Stores

The  performance  of  fuel  cladding  in  dry  stores  is  an  important  consideration.  The  cladding  integrity  of
LWR fuel is not affected in wet storage because water temperatures of ~50°C are too low for significant fuel
oxidation [Gilbert et al,  1990].  Indeed,  most  countries  store  defective  oxide  fuel  in  the  same  conditions  in
pools as intact fuel [IAEA, 1987]. The much higher temperatures (200° to 370°C) in dry stores require that
considerable attention be paid to cladding corrosion in dry stores. Therefore the main technical concern with
dry  storage  is  the  degradation  of  fuel  cladding  over  time.  Degraded  cladding  may  lead  to  accelerated
oxidation  of  UO2  in  oxide  fuel  to  the  less  dense  U3O8  which  causes  fuel  rods  to  split,  and  can  result  in
possible serious rod damage.

To ensure absence of cladding degradation and ease of retrieval, dry storage R&D has focused on potential
degradation mechanisms in spent fuel cladding in order to determine maximum permissible temperatures and
time  lengths  of  spent  fuel  in  storage [Manektela,  1993].  Cladding  integrity  depends  on  storage  conditions,
i.e.  temperature,  presence  of  oxygen,  time  stored,  and  absence  of  water.  The  critical  factor  is  temperature:
see  Table 45  in  Annex 29  for  maximum  cladding  temperatures  in  various  cask  types  at  their  maximum
heat capacities.

The  US  Nuclear  Regulatory  Commission  limits  the  maximum  permissible  LWR  fuel  temperature  for  dry
storage purposes to 360 °C to 370°C [Schneider and Mitchell, 1992a] depending on fuel type and burnup. In
practice, this means that normal burnup PWR fuel must be cooled in ponds for 5 years, and higher burnup

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

fuel cooled for up to 10 years before transfer to dry stores. MOX fuel would have to be stored for at least
15 years due to its much higher radioactivity upon exit.

These storage temperatures are close to the normal PWR operating temperatures of 370°-380°C. Gilbert et
al [1990] cite studies indicating that LWR spent fuel is expected to retain its integrity in inert gas for greater
than 50 and up to 100 years. Technical projections using Arrhenius plots for UO2 oxidation in CANDU fuel
predict spent fuel integrity for between 100 to 1,000 years [Stevens-Guille, 1994].

Nuclear regulators and/or nuclear industry engineers from different countries have adopted different rankings
for  the  licensing  criteria  of  dry  storage  systems.  For  example,  in  Germany,  greater  weight  is  accorded  to
meeting  the  requirements  of  stringent  transport  regulations  and  to  physical  protection  against  external
incidents, including aircraft crash, gas cloud explosion, fire, temporary burial, earthquake, transport crashes,
and  drop [Weh,  1993].  German  regulators  also  prohibit  ventilated  casks  due  to  concerns  over  genetic
mutations  to  insects,  bacteria  and  viruses  which  may  enter  ventilation  spaces [Janberg,  1994].  For  these
reasons, German CASTOR casks are built to resist physical insult and are sealed i.e. unventilated. Cooling is
by  direct  radiation  and  air  convection  of  outer  surfaces,  and  not  additionally  by  inner  air  convection.
The result  is  that  unventilated  German  casks  for  LWR  fuels  are  made  from  metal  rather  than  concrete,  as
metals have higher heat conductivities than concrete. This results, inter alia, in unventilated German metal
casks being more expensive than ventilated concrete casks.

Overall,  national  regulatory  and  licence  requirements  have  a  strong  influence  on,  and  indeed  limit  utility
choices  between  dry  store  systems.  Different  countries  have  emphasised  different  criteria,  placing  national
restrictions  on  storage  choices.  The  process  of  drawing  up  regulatory  or  licence  conditions  for  dry  fuel
storage has not been completed in many countries, and has not been started in France.

(d) Types of Dry Stores

Three main types of dry storage are currently in use, as follows

a)  vaults or silos, i.e. large ventilated buildings, capacity ~600 to ~2,000 tonnes;
b)  metal casks, i.e. unventilated metal cylinders, capacity ~10 to ~17 tonnes; and
c)  ventilated concrete casks or modules holding ~5 to ~15 tonnes.

• Vaults

According to Scottish Nuclear’s former plans for dry storage [Scottish Nuclear, 1992a], the maximum heat
load in each 60 tonne vault was 1 MW, with 20 vaults planned. This is an extremely large heat output, and
indicates the scale of the heat-handling capacities of vaults which are considerably larger than those of casks.
Cooling  in  vaults  occurred  by  natural  air  convection  with  temperature  differences  of  about  15°C  between
ingress  and  egress  air.  Airflow  rates  for  vaults  are  very  large  and  range  between  50-80  cubic  metres  per
second [Scottish Nuclear, 1992b].

The Modular Vault Dry Store system in Hungary handles loads of up to 17 kW per tonne of fuel when fully
loaded compared with about 1.4 to 2 kW per tonne for concrete casks. Vaults have sufficient heat removal
capacity  to  keep  fuel  cladding  temperatures  of  5  year-cooled  PWR  assemblies  below  200°C [Carter  and
Bower, 1995]. Maximum fuel cladding temperature of Scottish Nuclear’s planned store was 250°C [Scottish
Nuclear, 1992b]. On the other hand, concrete and metal casks hold their fuel temperatures near the maxima
of 360°C to 370°C allowed by the US Nuclear Regulatory Commission [NRC, 1996].

Gamma  and  neutron  shielding  is  afforded  by  60-100 cm  concrete  walls [Scottish  Nuclear,  1992b].  The
maximum public dose rate at the perimeter fence 100 metres from the vault was estimated to be 0.8 µSv/hour
from the side wall, or 2.1 µSv/year assuming a 30% occupancy rate). A small part of the radiation dose from
dry  stores  to  operators  and  the  public  was  due  to  skyshine  radiation.  In  addition,  doses  from  gaseous  and
liquid  effluents,  mostly  from  drying  operations,  were  estimated  at  2.3 µSv/a,  giving  a  total  of  about
4 µSv/a [Sumner, 1993]. This is low compared to the ICRP recommended limit to a member of the public of
1,000 µSv/a from all radiological sources.

• Concrete Casks

Maximum heat loads in concrete casks are 22 to 24 kW when fully loaded depending on model [Wisconsin
PSC, 1994]. Maximum fuel temperatures are about  360°C, depending on fuel type and burnup. Cooling in
concrete  casks  occurs  primarily  by  air  ventilation  between  inner  container  and  outer  concrete  shield.  The

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maximum volume of air flowing through a BNFL VSC-24 cask is 0.38 cubic metres per second or 825 cubic
feet  per  minute.  This  air  is  heated  20°  to  32°C  above  ambient  temperatures,  depending  on  the  ambient
temperature.  Some  cooling  is  also  provided  by  radiation  and  air  convection  from  the  outer  cask  surface.
Temperatures of the cask surfaces are a few degrees C above ambient temperatures.

Shielding from gamma radiation and neutrons is effected by borated concrete alone, as hydrogen and boron
atoms  in  concrete  thermalise  neutrons.  Maximum  calculated  dose  rates  at  the  side  of  concrete  casks  vary
from  480 µSv  per  hour  for  Vectra  Associates’  NUHOMS  24P  cask  to  about  600 µSv  per  hour  for  BNFL
VSC-24  flasks.  Maximum  calculated  dose  rates  to  the  public  at  site  boundaries  vary  with  site,  ranging
between 10 to 60 µSv/a [All data: Wisconsin PSC, 1994].

• Metal Casks

Maximum  heat  loads  in  metal  casks  vary  between  17  and  27 kW,  depending  on  model.  Cooling in  metal
casks is afforded solely by radiation and convection from outer finned surfaces: inner cores in metal casks
are unventilated. Cask surface temperatures are 10 to 20°C above ambient temperatures. Gamma shielding is
afforded  by  the  various  metals  used  including  steel,  iron,  and  lead.  Hydrogen-rich  polyethylene  inserts  in
outer  shielding  provide  neutron  shielding.  Maximum  surface  dose  rates  of  metal  casks  are  higher  than
concrete  casks  and  vary  between  800 µSv  per  hour  for  Nuclear  Assurance  Corporation  NAC-128  casks  to
500 µSv per hour from the German GNS Castor V/21 flask. [All data Wisconsin PSC, 1994].

The  main  operational  difference  between  the  two  types  of  casks  is  that  steel  casks  have  no  convection
cooling and are hotter to touch.

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ANNEX 29 Dry Storage Economics

(a) Comparison of Wet and Dry Stores

Siemens engineers [Peehs and Banck, 1993] have stated that marginal dry store capital costs are considerably
lower  stored  than  wet  stores,  particularly  in  the  case  of  small  stores.  In  addition,  the  multiple  operating
systems (filtration, boration, cooling and chemical buffering), and maintenance requirements of pool storage
result in considerably higher operating costs for pools. Bowser et al [1994] estimated that the annual running
costs of wet ponds to store fuel from the closed Rancho Seco reactor in California to be $10.6 million per
year and for dry stores – $2.6 million per year – a four-fold difference.

In most cases, since pool costs have been fully paid for and dry stores have yet to be constructed, a useful
comparison is the amortised cost of constructing a dry store plus annual operating costs, compared with the
annual  operating  costs  of  an  existing  pool.  In  the  above  Rancho  Seco  study,  the  costs  of  constructing  a
transportation  plus  dry  storage  system  to  store  spent  fuel  were  estimated  at  $12.4  million.  The  study
amortised this figure over a 10-year depreciation period using a 5% interest rate. This, plus annual running
costs,  resulted  in  an  estimated  total  annual  cost  of  $4.2  million  for  dry  storage  compared  with  annual
operating  costs  of  $10.6  million  for  wet  storage,  a  2.5  fold  decrease  in  annual  costs.  In  other  words,
considerable savings accrued from constructing dry stores and transferring fuel from pools to the dry stores.
The Table below compares estimated costs of wet and dry storage systems in more detail.

Table 44 Cost of Wet and Dry Storage Options

Management options for
spent LWR fuel

Estimated cost for
500 tonnes of fuel
for 20 years

Estimated cost
per tonne of fuel
over 20 years

Ratio of cost to dry
storage cost,
operating reactor

Pond storage (1)
Dry storage at closed reactor (1)
Dry storage at operating reactor (2)

$230 million

$148 million

$460,000

$180,000

$34-$50 million

$68,000-$100,000

4.6 to 6.7

1.8 to 2.6

~1

(1) Estimated from Browser [1994].
(2) Estimated from Supko [1995].

(b) Costs of Dry Stores Types

• Vaults vs Casks

An  older  study [IAEA,1990]  compared  the  costs  of  casks  and  vaults:  the  main  finding  is  that  after  about
350 tonnes,  the  marginal  cost  of  storing  fuel  was  lower  in  vaults.  This  represents  approximately  14 years’
fuel output from a 1,000 MW PWR reactor at 35-40,000 MWdays/tonne. A major difference between vault
and cask systems is that vaults provide only storage, whereas casks may also satisfy transport regulations and
be  suitable  for  final  disposal  in  a  repository,  depending  upon  future  regulatory  criteria (see  Annex 28  for
further discussion of the different types). In European practice, vaults will be more cost effective for at-site
storage  and  casks  will  probably  be  more  cost  effective  for  fuel  to  be  transported  to  a  central  site.  Castor
and NAC casks, for example, are designed for transportation.

• Cost Comparisons of Different Casks

Cost  comparisons  of  cask  systems  involve  uncertainties,  as  costs  may  include  estimates  of  transport  and
encapsulation costs. These require predictions or assumptions of transportation standards, which are likely to
be  improved  over  time,  and  predictions  of  future  repository  standards.  A  further  refinement  is  the  choice
between steel and concrete casks. The US Electrical Power Research Institute concluded that concrete casks
had  incremental  total  system  savings  of  10%  to  20%  over  metal  casks [Lambert  et  al,  1993].  This  was
primarily  due  to  the  less  expensive  material  costs  of  concrete  casks.  In  terms  of  immediate  storage,  i.e.
ignoring future transportation and encapsulation stages, Lambert concluded that concrete casks offered utility
operators 58% savings over the cost of steel casks. Cask costs account for about two thirds of total storage

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costs  over  a  20  year  period [Supko,  1995],  with  the  remaining  third  due  to  the  construction  of  drying  and
loading facilities.

In 1994, the Sacramento Municipal Utility District constructed a dry store for fuel from its closed reactor at
Rancho Seco in California. The utility predicted [Bowser et al, 1994] annual operating costs for the proposed
dry store of $2.6 million, with planning and construction costs of $12.4 million for the transportation and dry
storage  system.  Over  a  20  year  period,  total  undiscounted  costs  would  be  $64  million,  or  approximately
$280,000 per tonne.

its  Public  Utility  Commission  as  an  operating  overhead  and 

Supko [1995] predicted dry storage costs of an operating nuclear utility whose storage costs were permitted
by 
to  electricity
ratepayers [NuclearFuel,  1993a].  As  a  result,  operating  and  insurance  costs  were  significantly  lower  than
those at a closed site. Estimated representative life-cycle costs over a 20-year period for a 500 tonne dry store
were  $34  to  $50  million,  or  $68,000  to  $100,000  per  tonne.  These  are  considerably  lower  than  costs  at  a
closed  reactor.  In  1994,  a  US  study [Wisconsin  PSC,  1994]  calculated  total  costs  of  casks  ranging
from $35,000 to $68,000 per tonne, as set out in table below.

thus  charged 

Table 45 Comparison of Types of Dry Store Casks

Type

VSC-24 Nuhoms-24P

Manufacturer

Sierra Nuclear

Vectra

TN-24
Trans-nuclear
Inc.

TN-40
Trans-nuclear
Inc.

Country of
Manufacture
Air Ventilated

Cask Material

Max. Number of
PWR Assemblies
Max. Cladding
Temperature
Heat Capacity kW
Cost per cask
Estimated Total
Cost per tonne

NAC-128 Castor V-21

Nuclear Assurance
Corp’n

US

No

GNS

German

No

US

US Ger-Bel-Neth Ger-Bel-Neth

No

No

Yes
Steel-
reinforced
Concrete

Yes
Steel-
reinforced
Concrete

Pressure
Vessel Steel

Pressure
Vessel Steel

Stainless Steel,
Lead

Ductile Cast
Iron

24

24

24

40

364°C

24
$300,000

364°C

24
$380,000

332°C

24
$900,000

332°C

27
$700,000

26-31

230°C

17.4
$1,040,000

21-28

<250°C

21
$800,000

$35,000

$38,000

$62,000

$40,000

$68,000

$57,000

Source: [Wisconsin PSC, 1994]

Differences  between  cask  costs  are  due  to  the  different  characteristics  required  by  national  regulatory
criteria. Casks designed with future transport and/or disposal requirements in mind are more expensive than
those designed solely for storage. A major factor is whether casks are cooled by air ventilation or not. Such
casks  are  less  expensive  than  sealed  containers,  as  they  dissipate  heat  by  inner  convection  as  well  as
radiation,  thereby  eliminating  the  need  for  expensive  machined  metal  containers.  However  such  casks  are
limited  in  their  performance  capabilities  in  that  they  are  generally  not  able  to  be  used  for  transport  or
disposal, and have lower impact capabilities. Nevertheless their high heat-handling capacity combined with
low cost are attractive features for US utilities.

Even  lower  estimated  costs  of  $15,000  to  $20,000  per  tonne  have  been  cited  by  Ontario  Power
Generation [Stevens-Guille and Pare, 1994; Nash, 1997] for its planned 40,000 tonne dry storage facility in
Ontario. This will eventually use more than 6,000 unventilated steel and concrete containers. These very low
estimated marginal costs are due to a number of factors including

·  simple design reflecting straightforward regulatory requirements
·  economies of scale from standardised design/production
·  avoidance of high capital costs as canisters are constructed when required and stored in the open on

a concrete pad,

·  access to low cost finance by Government-owned corporation,
·  ability to charge costs to electricity tariffs, and

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·  less  shielding  and 

lower  heat-handling  capacity 

required 

for 

low  burnup  CANDU

fuels (~6,000 MWdays/tonne).

(c) Conclusions

Most (>80%) spent fuel arisings are stored and most countries are moving towards storage as a medium-term
strategy for spent fuel. According to the IAEA [1999], new developments in spent fuel management concern
storage  rather  than  reprocessing  and  dry  rather  than  wet  storage.  For  waste  management  policies,  an
important issue is the degree to which dry storage may be considered a viable long-term option for managing
spent fuel. Dry storage in inert gas presents relatively few theoretical or practical difficulties. The IAEA has
concluded  after  reviewing  national  experiences  of  dry  storage  that  it  is  an  acceptable  waste  management
option for the storage of spent fuel for periods of 50 to 100 years [IAEA, 1996]. By this time heat rates have
declined by two orders of magnitude. The anticipated longevity of dry stores (50 to 100 years) is expected to
exceed that of wet stores [Schneider and Mitchell, 1992a]. It is concluded that passive dry storage systems
appear to be an acceptable means of managing spent nuclear fuel in the medium to long term.

When  reprocessing  and  storage  are  compared,  large  differences  in  costs  become  apparent:  the  former  are
clearly greater than the latter. US/Canadian storage systems are even less expensive: US dry storage systems
for PWR fuel are estimated to be 8 to 20 times less expensive per tonne than reprocessing. In addition, dry
stores are considerably less expensive to construct and to operate than wet stores: annual costs are about a
factor of 4 lower.

Environmental  and  local  groups  in  some  countries  have  not  opposed  dry  storage  developments.  This  was
evidenced  by  the  1987  agreement  among  major  UK  environmental  groups,  supported  by  over  40  regional
and local groups, to a collective strategy of long-term on-site storage. Under this plan, waste would be stored
where  the  waste  was  generated  in  facilities  designed  to  optimise  monitorability  and  retrievability [CORE,
1987]. A US research organisation critical to nuclear power concluded that on site dry storage was needed to
resolve  capacity  problems  of  reactor  operators,  to  reduce  the  temperature  of  spent  fuel  thus  reducing
degradation risks, and to reduce transportation risks [IEER, 1989]. During the 1992-1994 UK public inquiry
into  Scottish  Nuclear’s  dry  storage  plans [Hickman,  1994],  no  environmental  group  made  representations
against the plans.

In France and the UK, the obstacles to the adoption of dry storage technology are the political, industrial and
financial  interests  committed  to  reprocessing.  This  results  in  the  philosophical  unwillingness  of  managers
within industry and Government to consider the issue of dry storage. Longer term dry storage is apparently
not within their frame of reference. The overall conclusion is that, despite the considerable advantages of dry
storage  over  reprocessing,  the  large  resources,  political  commitments  and  institutional  investments  in
reprocessing  in  France  and  the  UK  are  expected  to  continue  to  act  to  hinder  dry  storage  developments  in
these countries in the immediate future.

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ANNEX 30 Data on Radionuclides

Table 46 Main Radionuclides (1) Period, Radioactivity, Radiotoxicity and Origin

Number

Isotope

Symbol

Period (years, days,
hours, seconds)

Radioactivity (2) Radiotoxicity (3)

Release type

3
14
36
40
60
85
90
95
95
99
103
106
106
110
125
129
131
133
134
135
137
144
154
155
230
232
233
234
235
236
237
238
238
239
240
241
241
242
244

Tritium
Carbon-14
Chlorine-36
Potassium-40
Cobalt-60
Krypton-85
Strontium-90
Zirconium-95
Niobium-95
Technetium-99
Ruthenium-103
Ruthenium-106
Rhodium-106
Silver-110
Antimony-125
Iodine-129
Iodine-131
Iodine-133
Caesium-134
Caesium-135
Caesium-137
Cerium-144
Europium-154
Europium-155
Thorium-230
Uranium-232
Uranium-233
Uranium-234
Uranium-235
Uranium-236
Neptunium-237
Uranium-238
Plutonium-238
Plutonium-239
Plutonium-240
Americium-241
Plutonium-241
Curium-242
Curium-244

3H
14C
36Cl
40K
60Co
85Kr
90Sr
95Zr
95Nb
99Tc
103Ru
106Ru
106Rh
110mAg
125Sb
129I
131I
133I
134Cs
135Cs
137Cs
144Ce
154Eu
155Eu
230Th
232U
233U
234U
235U
236U
237Np
238U
238Pu
239Pu
240Pu
241Am
241Pu
242Cm
244Cm

12.3 y
5,730 y
300,000 y
1.3 x 109 y
5.3 y
10.7 y
28.8 y
64 d
35 d
214,000 y
39 d
372 d
30 s
250 d
1,010 d
1.57 x 107 y
8 d
20 h
2.1 y
2.3 x 106 y
30 y
285 d
8.6 y
4.7 y
75,000 y
69 y
162,000 y
245,400 y
7.1 x 108 y
2.3 x 107 y
2.1 x 106 y
4.47 x 109 y
86.4 y
24,390 y
6,563 y
432.2 y
14.4 y
163 d
18 y

 pure
 pure
g  soft
, g
, g
, g
 pure
, g
, g

, g

, g
, g
, g
, g  soft
, g  hard
, g
, g  hard

, g  hard
, g
, g
, g
,g
, g
,g

, g

,g
,g

, g

, g

, g

low (gr. IV)
moderate (gr. III)
moderate (gr. III)
low (gr. IV)
high (gr. II)
low (gr. IV)
high (gr. II)
high (gr. II)
moderate (gr. III)
low (gr. IV)
low (gr. IV)
high (gr. II)
low (gr. IV)
high (gr. II)
moderate (gr. III)
low (gr. IV)
high (gr. II)
moderate (gr. III)
moderate (gr. III)
moderate (gr. III)
moderate (gr. III)
high (gr. II)
high (gr. II)
high (gr. II)
very high (gr. I)
very high (gr. I)
very high (gr. I)
very high (gr. I)
very high (gr. I)
high (gr. II)
very high (gr. I)
low (gr. IV)
very high (gr. I)
very high (gr. I)
very high (gr. I)
very high (gr. I)
very high (gr. I)
very high (gr. I)
very high (gr. I)

liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid
liquid + gaseous
gaseous
liquid + gaseous
liquid + gaseous
gaseous
liquid
liquid + gaseous
liquid + gaseous
liquid
liquid
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid
liquid
liquid
liquid
liquid
liquid + gaseous
liquid + gaseous
liquid
liquid
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid + gaseous
liquid
liquid
liquid

(1) This  table  provides  details  about  all  radionuclides  for  which  measures  in  environmental  releases  and/or  in  the

environment are used in the report, plus other related radionuclides. They are ranked by number of mass.

(2) Radioactivity: a
(3) The classification in groups of radiotoxicity (gr. I to IV) is provided by the French regulation, Decree n° 86-1103.

 = beta, g  = gamma

 = alpha, b

PE 303.110

138

b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
a
a
a
a
a
a
a
a
a
a
a
a
b
a
a
POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

GLOSSARY

Comité contre la Pollution Atomique dans La Hague

Atelier de Compactage des Coques
Association pour le Contrôle de la Radioactivité dans l’Ouest
Atomic Energy of Canada Limited
Advanced Gas-cooled Reactors

Agence Nationale pour la Gestion des Déchets Radioactifs
Autorité de sûreté nucléaire
Atelier Pilote de Retraitement, UP2-400
Best Available Technique, or Best Available Technology
Best Environmental Practice
British Nuclear Fuel Limited
Bundesrechnungshof
Bulletin de Sûreté Nucléaire
Plutonium oxide storage facility, UP2-400
Boiling Water Reactor
Canada Deuterium Uranium reactor

ACC
ACRO
AECL
AGR
ALARA   As Low As Reasonably Achievable
ANDRA
ASN
AT1
BAT
BEP
BNFL
BRH
BSN
BST1
BWR 
CANDU
CASTOR  Nuclear transport container type
CCPAH
CRILAN Comité Régional d’Information et de Luttes Anti-Nucléaires
CEA
CEAA
CEC
CEDA 
CEGB 
CEPN
CFDD
CFDT
CFIL
CILH
CNE
CNIC
CNPE
COGEMA Compagnie Générale des Matières Nucléaires
COMARE Committee on the Medical Aspects of Radiation in the Environment
CORE
COSYMA COde SYstem from MAria
CRII-Rad Commission de Recherche et d’Information Indépendantes sur la Radioactivité
CSA
CSERGE Centre for Social and Economic Research on the Global Environment
CSM
CSPI
DEFRA
DETR
DG
DNA
DOE
DRIRE
DSIN
DWG
EARP
EBR

Commissariat à l’Énergie Atomique
Canadian Environmental Assessment Agency
Commission of the European Communities
Consultative Exercise on Dose Assessments
Central Electricity Generating Board
Centre d’Étude sur l’évaluation de la Protection dans le domaine Nucléaire 
Commission Française du Développement Durable
Confédération Française du Travail
Council Food Intervention Level
Commission d’Information de La Hague
Commission Nationale d’Évaluation
Citizens Nuclear Information Centre
Centre Nucléaire de Production d’Électricité

Centre de Stockage de la Manche 
Commission Spéciale et Permanente d’Information
Department of Environment, Food and Rural Affairs
Department of the Environment, Transport and the Regions
Directorate General
Desoxyribonucleic Acid
Department of Energy
Direction Régionale de l’Industrie, de la Recherche et de l’Environnement
Direction de la Sûreté des Installations Nucléaires
Discharges Working Group, BNFL Stakeholder Dialogue
Enhanced Actinide Removal Plant
Experimental Breeder Reactor

Cumbrians Opposed to a Radioactive Environment

Centre de Stockage de l’Aube

       139

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Électricité de France
Entreposage de Déchets Solides
European Commission
European Community
European Economic Community
European Parliament
Environmental Protection Agency
European Union

EDF
EDS
EC
EC
EEC
EP
EPA
EU
EURATOM European Atomic Energy Treaty
Energie Wirtschaftliches Institut
EWI
Fast Breeder Reactor
FBR
Friends of the Earth
FOE
Food Standard Agency
FSA
General Electric
GE
Groupe d'Études Atomiques de la Marine Nationale
GEA
Groupe Radio-écologique Nord-Cotentin
GRNC
Gesellschaft für Anlagen und Reaktorsicherheit
GRS
Groupement de Scientifiques pour l’Information sur l’Énergie Nucléaire
GSIEN
Highly Active Liquid
HAL
Haute Activité Oxyde, UP2-400
HAO
Health and Safety Executive
HSE
High-Level Waste
HLW
Her Majesty’s Inspectorate of Probation
HMIP
International Atomic Energy Agency
IAEA
International Commission on Radiological Protection 
ICRP
Intermediate Level Waste 
ILW
Institute for Energy and Environmental Research
IEER
Installation Nucléaire de Base
INB
International Nuclear Event Scale
INES
Institut National de la Santé et de la Recherche Médicale
INSERM 
Institut de Protection et de Sûreté Nucléaire
IPSN
Institute for Resource and Security Studies
IRSS
Kernforschungszentrum, Karlsruhe
KfK
Linear Energy Transfer
LET
Lower Limit of Detection
LLD
Low Level Waste 
LLW
Linear No-Threshold 
LNT
Light Water Reactor
LWR
Medium Activity Concentrate
MAC
Ministry of Agriculture, Fisheries and Food
MAFF
MARINA EC Programme on Radiological Exposure from Radioactivity in North European Waters
MEP
MOX
MTR
NAC
NAGRA
NCRP
NEA
NII
NPH
NRC
NRPA
NRPB
NUHOM Storage cask system
OBT
OECD

Member of European Parliament
Mixed Oxide fuel
Material Testing Reactor
Nuclear Assurance Corporation
Nationalen Genossenschaft für die Lagerung radioaktiven Abfälle
National Council on Radiation Protection
Nuclear Energy Agency (OECD)
Nuclear Installations Inspectorate
Storage facility, La Hague plant
Nuclear Regulatory Commission
Norwegian Radiation Protection Authority
National Radiological Protection Board

Organically Bound Tritium
Organisation for Economic Co-operation and Development 

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

Office de Protection contre les Rayonnements Ionisants
Oslo-Paris Convention for the Protection of the Marine Environment of the North-East Atlantic

Prototype Fast Reactor 
Pressurized Heavy Water Reactors
Parliamentary Office of Science and Technology
Paternal Preconception Irradiation
Probabilistic Risk Assessment 
Public Service Commission
Pressurized Water Reactor
Research and Development
Shearing plant, UP2-800
Vitrification plant, UP2-800
Réseau des Amis de la Terre
Reprocessed Uranium
Radioactivity In Food and the Environment
Réacteur à Neutrons Rapides
Rhine-Westfalische Energie

OPECST Office Parlementaire d’Évaluation des Choix Scientifiques et Technologiques
OPRI
OSPAR
PAE-KfK Projekt Andere Entsorgung at the Kernforschungszentrum Karlsruhe
PARCOM Paris Commission
PFR
PHWR
POST
PPI
PRA
PSC
PWR
R&D
R1
R7
RAT
REPU
RIFE
RNR
RWE
RWMAC Radioactive Waste Management Advisory Committee
SEA
SIR
SIXEP
STA
STE
STOA
T1
T2
T7
THORP 
UK
UN
UNGG
UNSCEAR United Nations Committee on the Effects of Atomic Radiation 
UOX 
UP2-400
UP2-800
UP3
US
USSR
VDEW 
VSC
VVER
WISE-Paris World Information Service on Energy-Paris
WWG

Single European Act
Standardized Incidence Ratio
Site Ionisation and Exchange Plant 
Science and Technology Agency
Station de Traitement des Effluents
Scientific and Technological Option Assessment
Shearing plant, UP3
Separation plant, UP3
Vitrification plant, UP3
Thermal Oxide Reprocessing Plant
United Kingdom
United Nations
Uranium Naturel Graphite Gaz reactor

Uranium Oxide fuel
Usine de Plutonium 2-400
Usine de Plutonium 2-800
Usine de Plutonium 3
United States
Union of Soviet Socialist Republics
Vereinigung Deutscher Elektrizitätswerke
Ventilated Storage Cask system
Vodiano Vodianoi Energuietitcheski Reaktor

Waste Working Group, BNFL Stakeholder Dialogue

Table 47 Main Units Used

annum
Becquerel

a
Bq
°C Celsius
Curie
Ci
eV electron.Volt
gramme

g

Gy
h
l

Gray
hour
litre

m meter
second
s
Sievert
Sv

t

ton

tHM ton of heavy metal

electric Watt

We
Wd Watt.day
Wh Watt.hour
year

y

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LIST OF TABLES AND FIGURES

(a) Tables:

Annual Fuel Throughputs at B205 and THORP (financial years April-April)............................ 34
Table 1
Community Food Intervention Levels (Bq/kg) ................................ ................................ .......... 41
Table 2
Reprocessing History at La Hague Plants by Fuel Category, 1966-2000 (in tonnes)................... 53
Table 3
Annual Wastes Arising from Spent Fuel Reprocessing at La Hague of a 1 000 MWe PWR (1) ... 54
Table 4
Table 5 Waste Inventory at La Hague, Quantities and Volumes (as of the end of 1999) ......................... 54
Table 6 Waste Management in France by Category (as of the end of 2000)................................ ............ 56
Table 7
Overview of peak years of nuclide concentrations in the La Hague environment....................... 61
Table 8a European Collective Doses from 1999 Discharges at Sellafield................................ ................. 70
Table 8b European Collective Doses from 1999 Discharges at La Hague................................ ................. 70
Table 9a Global Collective Doses from 1999 Discharges at Sellafield................................ ..................... 71
Table 9b Global Collective Doses from 1999 Discharges at La Hague................................ ..................... 71
Table 10 Global Collective Doses From Anthropogenic Radiation Sources................................ .............. 72
Table 11 Values of Person Sv................................ ................................ ................................ .................. 73
Table 12 Maximum Values for Optimisation Measures................................ ................................ ........... 73
Table 13 Fuel Cycle Costs................................ ................................ ................................ ....................... 77
Table 14
Individual Radiation Exposures from Consumption of Irish Sea Fish and Shellfish.................... 92
Table 15a Fish: Beta/gamma Radioactivity in Fish from the Irish Sea Vicinity in 1999 (ranked

by 137Cs concentration)................................ ................................ ................................ ............. 94

Table 15b Fish: Beta/gamma Radioactivity in Fish in Distant Area in 1999 (ranked

by 134Cs concentration)     ................................ ................................ ................................ ......... 95

Table 16 Shellfish: Beta/gamma Radioactivity in Shellfish from Irish Sea Vicinity in 1999

(ranked by 99Tc concentration)................................ ................................ ................................ .. 95

Table 17 Fish and Shellfish: Transuranic Radioactivity in Fish and Shellfish from Irish Sea Vicinity

in 1999 (ranked by 239Pu + 240Pu concentration)................................ ................................ ........ 96

Table 18a Sediments: Radioactivity in Sediment from the Cumbrian Coast and further Afield in 1999

(ranked by 137Cs concentration)................................ ................................ ................................ . 97

Table 18b Sediments: Radioactivity in Sediment from the Cumbrian Coast and further Afield in 1999

(ranked by 241Am concentration)................................ ................................ ............................... 98

Table 19 Aquatic Plants: Radioactivity in Aquatic Plants from the Cumbrian Coast and further Afield

in 1999 (ranked by 99Tc then 106Ru concentration)................................ ................................ ..... 99
Table 20 Radionuclide concentration in fish from the La Hague area in 1996/1997 (in Bq/kg)............... 100
Table 21 Radionuclide concentration in limpets from the La Hague area in 1996/1997 (in Bq/kg) ......... 100
Table 22 Radionuclide concentration in mussels from the La Hague area in 1996/1997 (in Bq/kg)......... 101
Table 23 Radionuclide concentration in shellfish from the La Hague area in 1996/1997 (in Bq/kg)........ 101
Table 24 Radionuclide concentration in fucus from the La Hague area in 1996/1997 (in Bq/kg) ............ 101
Table 25 Radionuclide concentration in royal crabs caught close to the La Hague sea discharge pipe,

in 1997 (in Bq/kg) ................................ ................................ ................................ .................. 102
Table 26 Radionuclide concentration in fucus and limpets from the La Hague area in 1997 (in Bq/kg) .. 102
Table 27 Radionuclide concentration measured by COGEMA in fucus and limpets from the La Hague area
in 2000 (in Bq/kg)................................ ................................ ................................ ................... 102

Table 28 Radionuclide concentration measured by COGEMA in fucus, molluscs and limpets in the first

semester of 2001 (in Bq/kg)................................ ................................ ................................ .... 102

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Table 29 Evolution of the Waste Stockpiles, Conditioned and non Conditioned,

Managed at La Hague (1993-1999)................................ ................................ ......................... 108
Table 30 Approval by the Foreign Clients of the COGEMA’s Specifications for Waste Conditioning.... 109
Table 31 Timetable for the Return of the Reprocessing waste – the German Case................................ .. 109
Table 32 Comparison of Discharge Limits for the La Hague Site, and the Nuclear Power Plants of Saint-

Laurent-des-Eaux and Flamanville................................ ................................ .......................... 110
Table 33 Comparison of Real Radioactive Discharges from La Hague and Flamanville, 1999 ............... 111
Table 34 Type of Accidents with Liquid and/or Gaseous Releases at Reprocessing Sites and Occurences in
Reprocessing Plants................................ ................................ ................................ ................ 117
Table 35 Fuel Storage at La Hague (as of 31 May 2001, in tons of heavy metal tHM)............................ 118
Table 36 Concentration Factors of Some Key Radionuclides Released by Reprocessing Plants.............. 119
Table 37 Observed and Expected Cancer Cases in the District of Cherbourg and the District of Avranches

Table 38

for the years 1979-1980-1981 ................................ ................................ ................................ . 120
Individual Committed Dose in 1985 and 1996 near La Hague for Six Reference Groups,
as calculate by Radio-ecological Group of North-Cotentin (in microSievert, µSv)................... 121
Table 39 Comparison of the Collective Dose to General Public and Workers in Two Options for Spent Fuel
Management – Direct Disposal (Once-Through Cycle) and Reprocessing............................... 122

Table 40 Evaluation of “Unattributed” Iodine-129 Activity at La Hague (1989-1999)

using COGEMA and UNSCEAR Codes................................ ................................ ................. 123
Table 41 Separation, Use or Exportation of Plutonium, France................................ .............................. 129
Table 42 Separation and Re-Use of French Plutonium................................ ................................ ........... 129
Table 43 Material and Economic Balances Associated to the French Nuclear Reactors, 1977-2049

(hypothesis of 45 years average lifetime)................................ ................................ ................ 130
Table 44 Cost of Wet and Dry Storage Options................................ ................................ ..................... 135
Table 45 Comparison of Types of Dry Store Casks................................ ................................ ................ 136
Table 46 Main Radionuclides Period, Radioactivity, Radiotoxicity and Origin................................ ....... 138
Table 47 Main Units Used................................ ................................ ................................ ..................... 141

(b) Figures

Figure 1 Uncertainty in the Evaluation of Environmental and Health Risks from Reprocessing

Operations    ................................ ................................ ................................ ............................. 32
Figure 2 Annual Air Emissions from Sellafield Reprocessing Operations, 1976–1999 (TBq) .................. 35
Figure 3a Annual Liquid Discharges from Sellafield Reprocessing Operations, 1976–1999 (TBq)

Cobalt-60; strontium-90; technetium-99; iodine-129; caesium-134, 137 ................................ .... 36

Figure 3b Annual Liquid Discharges from Sellafield Reprocessing Operations, 1976–1999 (TBq) Tritium;

Figure 6

carbon-14; plutonium (alpha, -241), americium-241................................ ................................ .. 36
Figure 4 Annual Technetium-99 in Liquid Discharges from Sellafield, 1978–1999 (TBq)....................... 37
Past and Projected Liquid Discharges from Sellafield Reprocessing Operations, 1990–2008 (TBq,
Figure 5
Index 1 in 1990) ................................ ................................ ................................ ....................... 38
Past and Projected Gaseous Emissions from Sellafield Reprocessing Operations, 1990–
2008 (TBq, Index 1 in 1990)................................ ................................ ................................ ..... 39
Figure 7 Technetium-99 Concentrations in Lobster, in Bq/kg wet weight, 1986 to 1998.......................... 42
Figure 8 Annual Air Emissions from La Hague (in TBq) ................................ ................................ ........ 57
Figure 9 Annual Liquid Discharges from La Hague (in TBq)................................ ................................ .. 57
Figure 10 Evolution of La Hague gaseous discharges 1990-1999 (index 100 in 1990)............................... 58
Figure 11 Evolution of La Hague liquid discharges 1990-1999 (index 100 in 1990) ................................ .. 58
Figure 12 Evolution of La Hague plutonium, strontium-90 and caesium-137 liquid discharges 1990–

1999 (index 100 in 1990)................................ ................................ ................................ .......... 59
Figure 13 Discharges in 1999 from Sellafield and La Hague (TBq, Logarithmic Scale)............................. 68

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Figure 14 Concentrations in Cod, Lobsters and Winkles from Sellafield in Bq/kg (wet) ............................ 93

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EVALUATION REPORT PROF. CROUDACE

By Ian Croudace BSc, PhD & Phillip Warwick BSc, PhD, CChem, MRSC
Geosciences Advisory Unit,
Southampton Oceanography Centre,
Southampton, SO14 3ZH, UK

Assessors’  credentials and interests

The  Geosciences  Advisory  Unit  is  a  university-based  consultancy  that  carries  out  commissioned  research
contracts  for  a  variety  of  clients  in  the  UK  including  the  nuclear  industry,  government  agencies  and  local
government groups.  It is chosen by these clients on the basis of its perceived independence and its proven
capability  in  the  field  of  radiochemistry  and  environmental  radioactivity.    The  Unit  also  sponsors  PhD
studentships,  often  through  partial  industry  support,  in  the  field  of  environmental  radioactivity.  Two
significant contracts are held with two large civil authority groups one in Northern Ireland (NIRMCC) and
the  other  in  southern  England  (SERMG).  These  two  consortia  have  existed  since  the  late  1980s  and  are
concerned  with  radioactive  contamination  arising  from  nuclear  sites  but  particularly  from  Sellafield  (for
NIRMCC)  and  La  Hague  (for  SERMG).  The  Geosciences  Advisory  Unit  was  invited  to  contribute  to  the
STOA assessment through advocacy from Roy Perry MEP.

Introduction

1.
The  STOA  report  (Aug  2001)  represents  an  assessment  that  was  carried  out  by  WISE-Paris  under  the
direction of Mycle Schneider. It arose out of a petition from Hamburg citizens headed by Dr W Nachtwey in
1995 (393/95).  The main message of the petition was a request to the European Parliament 'to prevent any
further nuclear pollution of the oceans'. The 153 page report had nine contributors two of whom are cited as
'independent consultants'.

General Comments

2.
The STOA Report has drawn on a significant amount of material taken from a wide variety of sources. These
include  official  publications  from  international  agencies,  government  and  non-government  organisations,
literature  published  in  international  scientific  journals,  conference  proceeding  etc.  The  report  presents  an
historical  perspective  for  each  site,  relevant  discharge  and  environmental  impact  data,  accident  records,
radioactive  dose  implications,  putative  health  effects  and  accident  scenarios.  Data  for  each  reprocessing
facility are presented as two separate case studies. Aspects of radioactive discharges to the atmosphere and to
the marine environment are covered along with indications of environmental monitoring and the consequent
accumulation  of  radionuclides  in  marine  biota  and  sediment.  The  potential  for  future  accidents/disasters
involving stored high level waste at each site are also presented. Although, rather speculative and arguably
alarmist  the  point  is  well  taken  especially  with  recent  terrorist  events.  The  controversial  area  of  claimed
health  effects,  in  particular  a  statistically  significant  excess  of  childhood  cancer,  are  presented  but  it  is
conceded no proven radiation link exists and no explanation can be found.

The original historical needs for reprocessing plants has passed but clearly the complex interplay of national
political and financial interests has acted as an obstacle to change.  However, external political pressures, the
changing worldview and changing market requirements mean that the writing is on the wall for these plants.
The  STOA  report  only  briefly  mentions  some  planned  changes  that  will  occur  in  the  UK.  It  is  clear  from
some  recent  UK  documents  (DETR  UK  Strategy  for  Radioactive  Discharges  2001-2020)  that  OSPAR
obligations  will  force  a  wind  down  of  activities  at  Sellafield.  This  is  inevitable  unless  some  extraordinary
technology is developed that can arrest discharges and disable waste safely.

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Overall  this  is  an  interesting  document  that  has  assembled  an  array  of  data  from  various  sources  in  an
attempt  to  build  a  persuasive  case  for  ceasing  reprocessing  operations  in  France  and  the  UK.  We  suspect
however,  that  these  countries  (perhaps  reluctantly)  have  already  accepted  the  case  and  that  a  planned
winding down is underway. The STOA document provides a number of good reasons for curtailing nuclear
reprocessing  in  favour  of  fuel  storage  on  safety  and  financial  grounds.  The  rate  at  which  all  of  these
seemingly  inevitable  changes  will  occur  is  the  key  question.  .  There  are  several  areas  of  the  report  that
require re-appraisal and the details of these are given under ‘Specific criticisms and suggestions’.

Specific criticisms and suggestions:

3. 
There  are  a  number  of  issues  that  we  would  question  in  the  report.  Consideration  of  some  or  all  of  these
could lead to improvements in the report if it were redrafted.

1.  The  report  would  have  benefited  from  a  clear  statement  on  the  background  of  the  WISE-Paris
organisation  and  short  biographies  of  the  contributors.    This  information  would  have  made  clear  any
potential biases or vested interests. Even a scan of the WISE-Paris WEB-site does not make clear their
generalised source of funding or affiliation(s). My suspicion is that they are a pressure group and without
a transparent profile readers will have uncertainty judging the objectivity of the report. I would also be
interested to learn how the EP awarded this contract to WISE-Paris – was it by invitation or through a
competitive tender process ?

2.  The  two  reprocessing  plants  are  a  legacy  of  the  Cold  War  and  originated  before  any  European
agreements  had  come  into  force.  It  is  true  that  both  organisations  (or  governments)  have  invested
(significant) funds in reprocessing of spent fuel for developing civil nuclear programmes (mixed oxide
fuel).  The STOA report criticises both organisations for not having complied with the strictures of the
EURATOM Treaty. It is not clear whether these can be applied retrospectively - or is it that only new
practices require to be notified. Have there been any clear transgressions of the EURATOM treaty by
the UK and France and if so what are the official explanations for such transgressions?

3.  In  the  executive  summary  (page  5)  it  is  noted  that  doses  to  critical  groups  in  the  1970s  and  1980s
exceeded the current UK dose constraints. It is misleading to compare historical critical group doses with
current dose constraints.

4.  In  terms  of  collective  dose  the  current  contribution  from  each  of  these  two  plants  now  appears  to  be
moderate and is a small fraction of the average dose from natural (background) sources (~1%). A typical
natural  backround  annual  dose  might  be  construed  to  be  ~  2  mSv.  We  are  aware  that  two  of  the
contributors (Fairlie & Sumner) disagree with this approach (Annexe 6d). Part of their argument relates
to  the  wide  range  of  background  radioactivity;  for  example  high  backgrounds  may  pertain  to  radon
affected areas.  Our point is not to invoke natural = good and man-made = bad but to assume that living
creatures are able to cope with radioactivity to a degree and that very small increases may not produce
significant effects. The current dose to critical consumers (for Cumbria) adds perhaps as much as 20% to
the  ‘normal’  background  dose.  We  do  not  mean  to  imply  current  discharges  are  insignificant  or
acceptable but expect the contractors to provide a balanced presentation of the facts. It is acknowledged
that the dosimetric consequences of past discharges will have been appreciably greater than the current
state.

5.  Natural Radioactive wastes: There are several plants in the EU that process phosphate ores and these
discharge radioactive wastes into the marine or estuarine environment.  These discharges can involve (at
least historically) appreciable activities (and hence doses) of natural emitters (uranium, thorium, radium,
lead,  polonium  etc).    For  comparison  purposes  a  section  on  these  could  also  be  included  in  this  report
since  it  will  help  put  reprocessing  wastes  in  context  with  other  radioactive  wastes.  Politically,  the
phosphate  industry  has  avoided  (perhaps  anomalously!)  the  scrutiny  that  has  fallen  on  the  nuclear
industry. Another tangential point is that some of these phosphate plants now import raw phosphoric acid
from the source countries rather than processing the raw ore. This serves to transfer the radioactive waste
issue to these countries (often Third World). The EU might consider that it should take a share of this
responsibility for the environmental impact caused by such operations. Again the writers of the STOA

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report  may  be  criticised  for  non-objectivity  by  ignoring  other  significant  sources  of  radioactive
discharges into the marine environment.

6.  No mention is made of the new Joint Convention on the Safety of Spent Fuel Management and on the
Safety  of  Radioactive  Waste  Management.  The  UK  is  soon  to  ratify  this  Joint  Convention  -  should
further comment be made on this ?

7.  The two case studies (viz. for Sellafield and La Hague) present much valuable information. The use of
single  tables  to  summarise  and  incorporate  specific  aspects  of  the  two  plants  would  have  made
information  extraction  easier.  We  would  have  liked  the  two  plants  to  have  been  compared  more
frequently rather than the tendency to deal with each separately. Aspects of each site such as discharge
authorisations, individual radionuclide discharges to air and sea, stored inventories of medium and high
level  waste  etc  could  have  been  compared  for  the  two  sites.  Where  deficiencies  in  data  existed,  as  is
implied  on  page  43  for  the  La  Hague  plant,  this  would  have  served  as  a  powerful  message  that  the
French should perhaps be as open as the UK.

8.  The  report  does  not  make  clear  what  the  environmental  impact  differences  for  the  two  plants  are
although such information does exist in the literature. The marine environments around Sellafield and La
Hague  record  the  history  of  discharges  in  different  ways.    The  bed  of  the  Irish  Sea,  offshore  from
Sellafield,  contains  a  sub-tidal  mudbelt  and  suspended  muddy  sediment  scavenges  many  radionuclides
(to  a  greater  or  lesser  extent  depending  on  the  radionuclide)  from  the  effluent.  This  mudbelt  acts  as  a
store of historical discharges which is tapped during bottom current movements and storms. At La Hague
a combination of local hydrodynamics (rapid marine currents) and the mineralogy of the sediments (less
clay  and  more  sand  and  carbonate)  make  efficient  local  scavenging  less  likely.  Thus  many  La  Hague-
derived radionuclides are transported into the North Sea and further north. A portion of some particle-
reactive  radionuclides  (e.g.  Co,  Pu,  Am)  may  concentrate  in  the  central  Channel  (Boust  and  Bailly  du
Bois & Geugueniat Cont. Shelf Res. 1999). This information is perhaps worth including in a section on
environmental impact.

9.  There  is  an  implication  (perhaps  unintended)  on  Page  82  (Annexe  5)  that  scientists  are  culpable  for
carrying  out  research  in  environmental  radioactivity  -  in  some  way  they  are  criticised  for  using  the
environment as a laboratory.  This is a ridiculous assertion if this implication was intentional. Many of
the  scientists  who  carrried  out  this  work  are  independent  of  national  policy  decisions  concerning
reprocessing or otherwise. Some studies are officially funded (e.g. CEFAS studies on 99Tc  movement)
and  set  out  to  determine  radionuclide  behaviour  in  the  environment.  These  organisations  have  no
responsibility for any discharge practices and they should not be admonished for their work. Indeed the
results from these studies enable objective impact assessments to be made. Other studies are driven by
scientific curiosity and are funded by scientific research councils and other sources (see the Wigley PhD
study on 99Tc mentioned in 12 below).

10. In section 4.2.4.4, the maximum beta energy for 3H is quoted as 18 MeV. In fact the value is 18.6 keV.
In the same section, it is noted that ‘tritiated  foodstuffs  (OBT)  have  much  longer  half  lives,  which  are
poorly  defined  and  may  extend  to  several  years’.    The  term  OBT  (organically-bound  tritium)  more
correctly refers to tritium bound irreversibly in an organic molecule and not specifically to 3H present in
foodstuffs. The observed half-life will depend on the organic molecule that the 3H is associated with.

It  is  rather  questionable  that  ‘hardly  anything’  is  known  about 99Tc  speciation  and  transport  through
environmental pathways. A more detailed literature search of this area would prove useful (e.g. Desmet
G. and Myttenaere C. (eds) Technetium in the environment, Elsevier, London, UK pp419).

11. ‘In  addition,  important  information  about  the  behaviour  of 99Tc  is  not  being  obtained  for  tide  washed
pastures ......’  Annexe 5 (page 82). This is not entirely the case since Wigley studied 99Tc in Cumbrian

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saltmarshes  [Mechanisms  of  accumulation  and  migration  of 99Tc  in  saltmarsh  sediments,  2000  PhD,
University of Southampton (supervisors Croudace & Warwick).

12. In  section  5.3.3  it  is  noted  that 99Tc  is  discharged  into  the  environment  mainly  from  Magnox  fuel
reprocessing. However, it is stated that the absence of 99Tc in La Hague discharges is as a result of its
low abundance in LWR fuel.  As the thermal neutron fission yield of 99Tc is  ca 6% in both cases it is
unlikely that this alone is the cause of the differences. According to Luykx (1986), La Hague discharged
11.7  TBq  of  99Tc  during  1983  whilst  Sellafield  only  discharged  4.4  TBq.  Also  in  Figure  13,  a
comparison  between  Sellafield  and  La  Hague  discharges  is  provided  showing  a  significant  La  Hague
99Tc discharge.  It is therefore worth considering in more detail the impact of La Hague 99Tc discharges.
Luykx F. (1986) Technetium discharges into the environment. In Desmet G. and Myttenaere C. (eds)
Technetium in the environment, Elsevier, London, UK pp419

13. In section 8.1.1 it states that ‘In the UK, there is no program for the use of MOX fuel.’  We are not sure
that this is the case as we thought that some reactors had been granted licenses to run with MOX loads.

14. The reference to Doll et al (1990) in section 5.6.2 is not included in the reference list.

Appendixes

The Geosciences Advisory Unit is a consultancy/research group based at the Southampton Oceanography
Centre that specialises in environmental geochemistry and radioactivity.  The purpose of the unit is to carry
out contract work that has a direct benefit to the research activities of the University. The Unit also sponsors
PhD studentships in environmental radioactivity as well as supporting research in radioanalytical chemistry.
The Unit has analytical laboratories that are equipped to the best international standards.

The Southampton Oceanography Centre opened in 1994 and was formed through a partnership between
the Natural Environment Research Council (NERC) and the University of Southampton.

Recent contracts held by the GAU

Contractor
Southern  England  Radiation  Monitoring  Group.
SERMG: - a 47 local authority consortium
Newbury  District  Council  and  B&D  District
Council
Northern Ireland Radiation Monitoring Group
Orkney Islands Harbour Board
AWE Hunting-BRAE
States of Jersey
Greenpeace Research Laboratories
Food Standards Agency

Project description
A regional environmental radioactivity survey: a 15
year programme.
Greenham  Common  Survey:  a  study  of  an  alleged
military nuclear accident in west Berkshire.
Regional environmental radioactivity survey
Actinides in marine biota
U and Pu in the environments around the AWE sites
Radionuclide discharges from La Hague
99Tc in UK and European waters
Organically-bound Tritium in the environment

Ian  Croudace  (BSc,  PhD)  is  the  founding  director  of  the  Geosciences  Advisory  Unit  and  has  25  years
research experience and has written over 90 scientific publications and reports. He is also a Senior Lecturer
(environmental geology and geochemistry) at the Southampton Oceanography Centre. He obtained his PhD
in  geochemistry  from  the  University  of  Birmingham  and  subsequently  undertook  post-doctoral  research  at
the University of Paris VI and at the Centre d’Etude  Nucleaires,  Saclay  before  arriving  at  Southampton  in
1983 to carry out research and teaching in environmental radioactivity and environmental geochemistry. He
is  the  project  coordinator  for  the  Southern  England  Radiation  Monitoring  Programme  and  the  Northern
Ireland Radioactivity Monitoring Coordinating Committee (NIRMCC).

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Phillip  Warwick (BSc,  PhD,  CChem,  MRSC)  is  deputy  Director  of  the  Geosciences  Advisory  Unit.  He
previously  managed  the  Environmental  and  Biological  Chemistry  laboratory  for  the  Atomic  Energy
Authority  at  Winfrith.  He  is  a  specialist  in  radio-analytical  chemistry,  has  14  years  research  experience  in
environmental  radiochemistry  and  obtained  his  PhD  in  environmental  radioactivity  at  the  University  of
Southampton. He has written over 20 scientific papers and numerous scientific reports.

Relevant research publications by GAU staff since 1996 (in chronological order)
GAU Staff and associates are in bold

Warwick  P.E.,  Croudace  I.W.  and  Carpenter  R.  (1996)  Review  of  analytical  techniques  for  the
determination of americium-241 in soils and sediments. Appl. Radiat. Isot.,  47. 627-642.

Croudace I.W., Warwick P.E., Taylor R.N. and Dee S.J. (1997) Greening the Common. Chem. Brit., 26-29.

Toole J., Adsley I., Hearn R., Wildner H., Montgomery N., Croudace I., Warwick P. & Taylor R. (1997).
Status of analytical techniques for the measurement of uranium isotopic signatures. Workshop on the status
of measurement techniques for the identification of nuclear signatures. 25-27 February 1997. Geel Belgium.
Report EUR 17313.

Taylor R.N., Croudace I.W., Warwick P.E. and Dee S.J. (1998) Precise and rapid determination of 238U/235U
and uranium concentrations in soil samples using thermal ionisation mass spectrometry. Chem. Geol. 144, 73-
80.

Croudace I.W., Warwick P.E., Taylor R.N. , Dee S.J., Milton J.A. and Oh J.S (1998)  The determination
of  actinide  elements  in  environmental  materials  using  a  borate  fusion  followed  by  ion-exchange/extraction
chromatography. Radioact. Radiochem. 9, 41-48.

Croudace  I.W.,  Warwick  P.E.,Taylor  R.N.  and  Dee  S.J.  (1998).  Rapid  procedure  for  plutonium  and
uranium  determination  in  soils  using  a  borate  fusion  followed  by  ion-exchange  and  extraction
chromatography - Analyt. Chim. Acta. 371, 217-225.

Warwick P.E., Croudace I.W. & Howard A.G. (1999) An improved technique for the routine determination
of tritiated water in aqueous samples – Analyt. Chim. Acta. 382, 225-231.

Warwick P.E., Croudace I.W. and Dale A.A. (1999) An optimised and robust method for the determination
of uranium and plutonium in aqueous samples. Appl. Radiat. Isot..   50, 579-583.

Cundy A.B., Croudace I.W., P.E.Warwick and Bains M.E. (1999) Environmental decline of radionuclides
following nuclear reactor closure: a U.K. case study. Env. Sci. Technol.. 33,  2841-2849.

Croudace I.W., Warwick P.E., Taylor R.N. and Cundy A.B. (2000)  Investigation  of  an  alleged  nuclear
incident at Greenham Common airbase using TI-mass spectrometric measurements of uranium isotopes. Env.
Sci. Technol. 34,  4496-4503.

Taylor  R.N.,  Warneke  T.,  Milton  J.A.,  Croudace  I.W.,  Warwick  P.E.  and  Nesbitt  R.W.  (2001)
Plutonium  isotope  ratio  analysis  at  femtogram  to  nanogram  levels  by  multicollector  ICP-MS.  J.  Anal.  At.
Spectrom.. 16, 279-284.

Warwick P.E., Cundy A.B., Croudace I.W.,  Bains M.E.D. and Dale A.A. (2001) The uptake of iron-55 by
marine  sediment,  macro-algae  and  biota  following  discharge  from  a  nuclear  power  station. Env.  Sci.
Technol., 33, 35.

Warwick P.E., Croudace I.W. and Oh J.S. (2001)  Radiochemical determination of 241Am and Pu(alpha) in
environmental materials. Anal Chem. 73, 3410 – 3416.

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Evaluation Report Dr. Mitchell

P.I. Mitchell

Department of Experimental Physics

National University Of Ireland, Dublin

I have examined the above mentioned report in considerable detail and wish to make a number of comments,
some of a broad and rather general nature and others of a more specific character. If I may start with some
general impressions.

General comments:

The  report  contains  a  wealth  of  background  information  for  legislators  and  regulators  and,  in  the  main,
provides a lucid and uncomplicated description of the main issues attending the reprocessing of spent nuclear
fuel  at  the  present  time.  It  provides  background  to  the  origins  of  reprocessing  and  to  the  implications  of
reprocessing in comparison with alternative (non-reprocessing) management options such as dry storage. It
also provides a valuable summary of the legal framework at both international and European level that now
governs  all  activities  relating  to  nuclear  reprocessing,  including  radioactive  waste  discharges  to  the
environment. All of this I have found to be helpful and informative.

Overall,  the  report's  treatment  of  annual  discharge  levels  (gaseous  and  liquid)  appears  reasonable  to  this
reviewer,  though  I  would  comment  that  more  emphasis  might  have  been  given  to  the  very  substantial
reductions  achieved  at  Sellafield  for  many  nuclides  and,  in  particular,  radiocaesium  and  the  transuranics
(mainly plutonium and americium), since the mid- to late-1970s. The report highlights more recent increases
in  the  releases  of  several  important,  long-lived  radionuclides,  e.g.  C-14,  Tc-99  and  I-129,  though  it  does
recognise  that  from  the  individual  dose/critical  group  perspective  their  radiologically  importance  is  very
much less than that of the transuranics.

The  report  deals  objectively  with  the  subject  of  doses  to  individual  members  of  critical  groups  and,  in  the
context  of  Sellafield,  states  clearly  that  the  average  individual  dose  to  the  Sellafield  critical  group  from
current  discharges  is  about  0.21  mSv  compared  to  the  UK  dose  constraint  of  0.30  mSv.  However,  the
presentation of equivalent data on critical group doses in the executive summary could be seem as somewhat
disingenuous, as past doses are compared with current UK and EU limits, instead of with the limits in place
at the time in question.

The report also addresses certain issues in radiobiology concerning health effects from exposure to ionising
radiation  and  places  much  stress  on  the  importance  of  the  concept  of  collective  dose  when  evaluating  the
impact  of  reprocessing  in  comparison  to  alternative  strategies.  I  am  not  impressed  by  this  section  of  the
report as I consider it to be incomplete in more than one regard and, moreover, believe that it places undue
emphasis on collective dose. I shall return to this last point below.

Amongst  other  matters,  the  report  discusses  the  apparent  higher  incidence  of  leukaemia  in  the  regions
surrounding the Sellafield and La Hague reprocessing plants. This is an issue of great sensitivity, particularly
in  so  far  as  the  public  are  concerned,  and  one  which  has  already  received  enormous  publicity  in  both
countries  as  well  in  the  European  Union.  While  the  authors  concede  that  a  causal  relationship  with
environmental radioactivity has not, in fact, been established (and for all we know may never be established),
the  tenor  and  emphasis  of  their  conclusions  in  this  area  does  not  impress  the  reviewer.  I  have  a  genuine
concern about objectivity here. In effect, I sense that the report may have departed from strict objectivity in
some at least of the conclusions inferred.

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Specific comments:

Regarding  expected  future  discharges  from  Sellafield  (Sect.  5.3.4.),  the  report  makes  reference  to  internal
BNFL documents (undated) which were leaked to the UK press and various environmental groups in June
2001,  and  which  envisage  increases  in  radionuclide  releases  in  the  future  such  that  currently  authorised
discharge limits are likely to be approached or exceeded in the case of a number of radionuclides. Surely this
is,  in  the  first  place,  a  matter  for  the  authorising  authority  in  the  UK,  who  are  highly  unlikely  to  agree  to
increases in these limits in the light of the OSPAR Convention.

The  report  makes  reference  to  the  accumulation  of  transuranium  radionuclides  in  sediment  deposits
throughout  coastal  environments  following  their  release  from  the  above-mentioned  reprocessing  plants.
Whilst this is, of course, true scientifically, it is important to appreciate that actual concentrations of these
radionuclides  in,  for  example,  the  seabed  sediments  of  the  north-eastern  Irish  Sea  are  now  declining  as  a
consequence  of  reductions  in  discharges  since  the  mid-1970s,  as  well  as  remobilisation/desorption  from
previously  contaminated  sediment,  followed  by  transfer  and  dispersal  by  tides  and  currents.  Farther  afield
(e.g. the east coast of Ireland) the reduction is less evident but is, nevertheless, now beginning to take place.

It is my understanding that important new evidence has recently come to light in regard to exposure to alpha
particle radiation which would suggest that there may be an dose/exposure threshold below which there are
no injurious effects. If this proves to be the case and, I stress that we speak only of alpha irradiation, it will
profoundly alter the weight previously given to the concept of collective dose.

Regarding  the  report's  conclusions  on  health  effects  around  La  Hague,  I  would  make  the  following
observations:

The Nord-Cotentin Radiological Group's (GRNC) final conclusions were that epidemiological studies have
shown  that  the  total  number  of  cases  of  leukaemia  expected  in  the  Beaumont-Hague  canton  in  the  period
1978-96  would  be  of  the  order  of  two  if  the  occurrence  rate  of  this  disease  was  the  same  as  the  value
observed nationally. In fact, four cases were observed. Nevertheless, this difference was not considered to be
statistically significant. Further, the reconstruction of exposures from nuclear installations, as was performed
by the Nord-Cotentin Radiological Group, lead to a calculated number of 0.0014 cases of radiation-induced
leukaemia during the same period. However, they stressed that this result was an average estimate and that
the margins of uncertainty involved could not be quantified at that stage. Indeed, most of the members of the
GRNC  considered  the  results  obtained  to  be  a  'best  estimate',  which  needs  to  be  further  investigated,
espcialaly regarding analysis of the uncertainties involved.

The La Hague results may be compared with the results of similar studies carried out in the UK around the
Sellafield  and  Dounray  reprocessing  plants.  The  conclusion  of  the  British  studies  was  that  the  observed
number of cases of leukaemia cannot be explained by discharges from nuclear installations.

I question the report's conclusion that a serious accident involving loss of coolant to one or more of 21 high
level  liquid  radioactive  waste  (above  ground)  storage  tanks  at  Sellafield  might  result,  in  the  long-term,
globally, to over one million fatal cancer cases. Nevertheless, and in the light of recent events, it is patently
evident that this whole area of nuclear security needs to be revisited and thoroughly re-examined from every
possible perspective.

The  report  expresses  strong  doubts  that  the  European  Commission  is  in  a  position  to  ensure  the  full  and
efficient  implemenation  of Articles  35  and  37  of  the  Euratom  Treaty.  Although  I  am  not  in  a  position  to

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comment, one way or the other, on the implementation of Article 35,  I  have  served  for  over  15  years  as  a
member of an expert group that advises the Commission with in the framework of Article 37 and consider
that  my  experiences  here  permit  me  to  comment  with  some  authority.  Unlie  the  authors  of  the  report,  I
believe that the Commission has found itself in a position to fulfill its obligations under Article 37 and that,
in  general,  it  has  done  so  efficiently  and  expeditiously.  In  my  recall,  Member  States  have  usually  been
cooperative  and  have  provided  the  necessary  information  and  data  to  enable  the  Commission  (and  its
advisers) formulate and publish an informed and sound opinion. The report's comments regarding the paucity
of man-months over a four and a half month period) devoted to the La Hague opinion is rather meaningless,
as  it  takes  no  account  whatsoever  of  the  time  taken  by  the  40-odd  group  of  experts,  who  also  studied  the
documentation  and  data  in  advance  of  meeting  in  plenary  session  with  the  Commission,  national
representatives, and technical representatives of the operator.

Finally,  regarding  the  management  of  plutonium  stocks,  I  agree  strongly  with  the  report's  finding  that  the
European Parliament and the European Commission must ensure that the Euratom Safeguards Agency has
the necessary funding to carry out its mission of verification rigorously and efficiently. I do not, however,
agree  with  the  suggestion  that  the  Parliament  introduce  legislation  to  prohibit  the  separation  of  plutonium
unless a utility can demonstrate a short term use for the separated plutonium.

In  conclusion,  I  hope  the  above  observations  prove  helpful  to  members  of  the  STOA  Panel  in  their
deliberations and would be more than please to amplify the above or answer any questions, if required.

Yours sincerely,

Prof. Peter. I. Mitchell PhD CPhys FInstP

(Head, Department of Experimental Physics, UCD)

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Evaluation Report Prof. J.-C. Zerbib

Jean Claude Zerbib                                                                                                     October 2001

CRITICAL ANALYSIS OF THE WISE-PARIS REPORT

The  WISE-Paris  report  is  a  major  report  which  deserves  much  more  detailed  analysis  than  we  are  able  to
carry out in a short space of time. We will be looking at:

      -

inspections of nuclear installations,

- 

- 

- 

releases of liquid and gaseous radioactive effluents,

contamination of the environment,

dosimetric impact,

but  focusing  in  particular  on  releases  of  effluents.  Monitoring  of  environmental  contamination  and
calculation  of  the  associated  dosimetric  impacts  require  substantial  work  (validation  of  measurement  data,
the computation methods used, hypotheses made in relation to consumption, etc.).

We will not be able to address important points such as alternatives to reprocessing in the management of
waste, stockpiles of reprocessed plutonium and uranium or irradiated fuels. Such problems exist, however,
whatever  technical  and  political  options  the  Member  States  choose  in  the  medium  to  long  term,  for  it  is
necessary at very least to manage the material produced to date.

1 - Inspection of nuclear installations and the 'Euratom Treaty'

Fuel  reprocessing  plants  are  composed  of  a  series  of  installations  which  operate  'in  series',  each  with  a
distinct  function,  from  reception  of  casks  containing  fuel  assemblies  to  the  storage  and  consignment  of
conditioned  waste  and  radioactive  raw  materials  (uranium,  plutonium).  Each  of  these  installations  has  a
specific  single  function  but  is  nevertheless  sufficiently  complex  to  be  considered  a  'basic  nuclear  facility'
(INB) under French regulations. INBs are covered by 'safety records', which are compiled at each of stage in
their life, from planning to entry into service, and are subject to regulatory authority approval.

Irrespective  of  how  appropriate  and  effective  the  intrinsic  safety  arrangements  and  any  measures
implemented at a site like Sellafield or La Hague are deemed to be, the experts responsible for inspections
require  a  great  deal  of  time  to  obtain  all  of  the  data,  given  that  we  expect  them  to  produce  a  totally
independent  critical  analysis.  However,  such  analyses  cannot  be  produced  without  the  need  to  consult  the
operators and safety authorities, who have also conducted critical analyses and inspected the facilities on the
site.

In  view  of  the  foregoing,  if  the  information  supplied  in  the  WISE-Paris  report  (2  man-months  over  a  4.5
month period) concerning the time Euratom inspectors spend inspecting installations is accurate, we can also
conclude  that  the  Commission's  means  for  applying  the  provisions  of  the  Euratom  Treaty  are  not
commensurate with the requirements of Article 37 thereof.

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2 - Discharges of radioactive liquid and gaseous effluents from reprocessing plants

Analysis of the report, which compares releases of radioactive waste from irradiated fuel reprocessing sites
at Sellafield and La Hague, as well as the associated dosimetric impacts, necessitates prior verification of the
validity  of  the  data  on  which  the  WISE-Paris  findings  are  based.  For  that  purpose,  we  have  mainly  used
documents published by the EC pursuant to the Euratom Treaty [1-3], the NRPB68 [5], BNFL69 [6-8], the UK
authorities responsible for monitoring the environment and consumer products [9-13], and the GRNC70 [14]:

§  Table 1 presents, for the UK and French plants, from their entry into service to 1992, and then for
the  period  1993-1999,  figures  for  the  cumulative  activity  of  long-lived  radionuclides  present  in
liquid effluents, based on data from publications 1-14.

§  Table  2  presents,  for  the  same  periods,  figures  for  the  cumulative  activity  of  long-lived

radionuclides present in gaseous effluents from La Hague and Sellafield [1-14].

We  have  chosen  these  periods  in  view  of  the  report's  findings  concerning  the  overall  track  record  for
discharges from Sellafield and the fact that 1992 marked a turning point for both sites71.

Generally speaking, two trends can be observed at the UK and French plants:

- 

- 

a  clear  trend  towards  a  decrease  in  the  activity  of  discharged  material,  mainly  concerning
radionuclides with a half-life of less than about thirty years (incl. caesium-137 and strontium-90),

an increase in the activity of effluents concerning radionuclides which pose problems owing to the
complex processes needed to trap them (tritium and krypton-85) and/or the safety risks of long-term
storage owing to their very long half-lives (technetium-99 and iodine-129).

The decrease  is  due  to  improved  purification  processes  for  liquid  effluents  (effluent  separation,  recycling,
evaporation) and gaseous effluents (off-gas segregation, scrubber plants, use of special dust catchers prior to
high-performance filtration).

The increase is directly linked to the increase in the volume of material reprocessed and in burnup. There is
one exception, concerning the THORP plant (operational since 1994), which was equipped with a carbon-14
trapping system for gaseous effluents. However, the other facilities on the site are not equipped with such a
system. THORP's share of 14C releases from Sellafield was only 3.9% during the 1994-99 period.

We will be presenting, in Table 3, the key figures from the WISE report, in the light of which we will clarify
what we have found by analysing the activity values in Tables 1 and 2.

68 NRPB = National Radiological Protection Board
69 BNFL = British Nuclear Fuels plc
70 North Cotentin Radio-Ecological Group (GRNC), which has been commissioned by the Minister for the Environment
and the State Secretary for Health to estimate levels of exposure to ionising radiation (from nuclear installations in
the region) of population groups in the northern part of the Cotentin peninsula, the associated risk of leukaemia, and
levels of uncertainty affecting such estimates.

71 As from 1990-91, there was, at La Hague, a sizeable reduction in discharges whilst the tonnages reprocessed began to
increase  substantially  (in  1994,  the  tonnage  reprocessed  was  double  what  it  had  been  in  1990-91).  In  the  case  of
Sellafield, 1993 and 1994 were the years when the greatest tonnage of Magnox fuel was reprocessed (1664 t) and
when THORP became operational.

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Ø  Effluents from Sellafield:

Apart  from  the  increase  in  iodine-129  in  gaseous  discharges,  which  we  are  unable  to  confirm72,  as  all  the
reports  published  provide  different  results,  the  WISE-Paris  report  data  on  releases  of  liquid  and  gaseous
effluents have been verified in all cases.

§ 

The report (p. 32) also indicates that plutonium has been deposited in the soil, the activity of which
was  put  at  160-280  GBq  in  1992.  The  record  for  gaseous  effluents  shown  in  Table  2  indicates
aggregate releases to be far higher than that (3.7 TBq 239+240Pu and 23,7 TBq 241Pu). As the site is on
the  coast,  it  is  also  necessary  to  have  information  on  several  other  factors  (prevailing  winds  and
average  wind  speeds,  chimney  heights,  etc.)  in  order  to  estimate  the  proportions  of  plutonium
deposited in the soil and in the sea respectively.

§  As regards plutonium in liquid effluents deposited in sea-bed sediment, the report (p. 33) cites an
estimate from 1991 which puts the figure at 250-500 kg. Whilst it is possible to calculate the mass of
plutonium-238 (0.19 kg) and plutonium-239 (5.1 kg) from the figures for discharges of isotopes 239
and 240 between 1951 and 1992, we have to make hypotheses for their relative proportions of the
total activity of discharged material73. These depend on the figures for burnup of reprocessed fuels.
An  approximate  approach  would  be  to  consider  the  activity  of  the  various  isotopes  present  in  the
effluents  throughout  the  1951-1992  period.  The  reported  activity  of  isotopes 241Pu  /  239Pu+240Pu
would indicate the average burnup of reprocessed fuel to be low (2000-4000 MWthj ). In this case,
the weight of isotopes 239 and 240 would be between 171 and 209 kg and total plutonium between
176  and  214  kg.  More  precise  calculations  could  be  made  if  we  had  details  of  the  tonnages,  and
burnup, of fuel reprocessed annually at Sellafield.

It is worth pointing out here the significance of the WISE-Paris approach, which looks at the overall figures
for discharges in terms not only of the activity but also of the mass of the material released.

Ø  Effluents from La Hague:

WISE-Paris  indicates  (p.  52)  that  measurements  have  not  been  taken  for  three  radionuclides  in gaseous
discharges from La Hague, namely: chlorine-36, strontium-90 and technetium-99.  In this connection, we can
state  that,  at  the  request  of  the  GRNC,  special  measurement  exercises  were  conducted  to  verify  whether
measurable quantities were present in gaseous effluents from La Hague. Those exercises concerned releases
of  chlorine-36  (produced  as  a  result  of  activation  of  chlorine  impurities  possibly  present  in  fuel)  and
strontium-90 (a fission product):

§ 

In the case of chlorine-36, inspections focused on a variety of indicators (meat, poultry, eggs, milk,
cereals, soils and stream water). Measurements were also made using urine from people who, on the
basis  of  meteorological  data,  are  considered  to  live  close  to  the  point  of  maximum  fallout.  In  the
absence  of  meaningful  measurement  results,  an  evaluation  of  the  activity  of  gaseous  discharges
considered for dose calculation purposes was made on the basis of a detection limit for 36Cl in urine.

§ 

 In the case of strontium-90, two measurement exercises were conducted, which made it possible to
calculate the maximum release on the basis of a detection limit (0.1 GBq per annum for 1999 and
2000).

72 It is possible that a publication provided data which did not agree with those obtained by the NRPB [5] and used by
COMARE [15]. We have on several occasions encountered data which indicates widely varying levels of activity for
the same set of years.

73  Plutonium-239  and  plutonium-240  emit  alpha  particles  of  very  similar  energy  levels  (respectively  5.156  MeV  and
5.168 MeV at the most intense), as a result of which it is generally total alpha energy that is measured rather than the
energy for each isotope. However, the specific activity of the two isotopes differs: the mass of 1 TBq of plutonium-
239 is 441 g, whereas that of 1 TBq of plutonium-240 is 119 g. Calculation of the mass of the two isotopes therefore
requires some form of hypothesis to be made as regards distribution.

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§ 

It  is  true,  however,  that  the  absence  of  technetium  (established  by  the  measurements)  in  gaseous
effluents has not been the subject of investigations such as were carried out in the case of chlorine-
36 and strontium-90.

§  The WISE-Paris report also cites a challenge raised by Mr Guillemette (p. 59), who disputed certain
measurements  for strontium-90  that  were  taken  at  sea  following  the  discovery  by  COGEMA  in
January  1980  of  a  crack  in  the  sea  discharge  pipe.  This  challenge  was  taken  into  account  by  the
GRNC, and a working party (to which Mr Guillemette belonged) studied the points raised. A report
on the outcome of this review was published [16].

§  WISE-Paris raised the problem posed by the discrepancies in the overall figures (24.6% on average
between 1988 and 1993) observed in the case of iodine-129 in liquid effluents. The GRNC had in
fact  noted  this  discrepancy  ([14]  fig.  25a  and  25b)  but  had  not  offered  any  explanations  as  to  its
cause. It would appear to be linked to uncertainties attached to the measurement of 129I, but a GRNC
working party is to convene to study the problem. Experts from WISE-Paris will of course be part
of that working party, which the GRNC plenary decided to set up.

§  The report also considers alarming the difference noted between regulatory authorisations for liquid
and gaseous effluent discharges from a plant such as La Hague and those from a nuclear reactor like
Flamanville, 17km from the COGEMA site. There are objective differences between the hundred or
so tonnes of fuel that make up the core of the reactor, whose maximum integrity is ensured, and a
plant which cuts up and annually places in solution the equivalent of 16 reactor cores as powerful as
those at Flamanville.

§  As  regards  long-term  effects,  the  problem  concerns  in  particular  radionuclides  such  as  carbon-14,

krypton-85, technetium-99 and iodine-129. This implicitly raises the following question: 'Should we
ensure the best possible diffusion of such radionuclides or demand that they be trapped, despite the
uncertainties  as  regards  the  durability  of  containment  bearing  in  mind  their  very  long  half-lives
(14C - 5730 years, 129I - 15.7 million years, and  99Tc  - 214 000 years)?'

Obviously, responsibility for taking this decision must not rest with the nuclear power operator, but with the
regulatory authorities.

Ø  Potential incidents at reprocessing plants

The WISE-Paris report raises the issue of major fire risks in a radioactive material storage area (p. 53). After
the attacks of 11 September 2001, the authorities responsible for safety will obviously have to rethink their
reference  scenarios  and  reassess  malicious  acts  against  INBs.  In  a  reprocessing  plant,  the  zones  which
potentially pose a high risk are those used for storing:

- 

- 

- 

fuel, in ponds or in dry areas (Sellafield and La Hague),

fission products (Sellafield, for La Hague vitrifies these practically on line),

plutonium oxide (Sellafield and La Hague).

3 - Environmental measures and assessment of radiation doses received by members of the public

The EC has evaluated the doses received by members of the public, exclusively on the basis of models, in the
case  of  the  plants  at  Sellafield  and  La  Hague,  in  1983  [1]  and  1995  [2].  After  calculating  the  levels  of
contamination  (in  the  air,  soil  and  sea)  caused  by  discharges  of  liquid  and  gaseous  effluents,  the  resulting
doses  (external  exposure  and  inhalation)  were  estimated  for  people  living  0.5  km  from  the  point  source
(gaseous discharges) and up to 5 km away.

In the case of discharges into the sea, the level of exposure of a 'critical group' (fishermen) was evaluated, as
well  as  the  internal  exposure  of  two  groups  who  do,  or  do  not,  consume  radioactively  contaminated  local
produce.  The  doses  were  calculated  by  applying  the  coefficients  published  in  CIPR30.  A  model  was  also
used to evaluate the collective dose to the people of the European Community.

The WISE-Paris report cites from the work of the GRNC [15, 17], which:

169

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POSSIBLE TOXIC EFFECTS FROM THE NUCLEAR REPROCESSING PLANTS AT SELLAFIELD AND CAP DE LA HAGUE

§ 

compiled  as  full  an  inventory  as  possible  of  the  radionuclides  present  in  liquid  and  gaseous
discharges from La Hague from 1966 to 1996; radionuclides present in effluents, but not measured,
were reconstituted;

§  drew up an overview of all samples taken and types of measurement taken since La Hague became

operational (1966);

§ 

compared model-based forecasts with the results of measurements;

§  made calculations of ingested activity and exposure levels based on people's habits and lifestyles, as

indicated by locally conducted surveys;

§ 

calculated  doses  to  bone  marrow  for  a  cohort  of  individuals,  doses  to  the  whole  body  (effective
dose) in the case of 'reference groups', and doses received in certain specific scenarios.

The WISE-Paris report stresses (p. 54) that this work is essentially based on field measurements taken by the
operator (51%), the national marine (16%) and the national body responsible for  radiological inspections at
nuclear installations (OPRI) (17.5%). Whilst this is true, it should also be noted that this is the first time that
a  working  party  with  a  ministerial  mandate  has  taken  account  (albeit  to  a  very  limited  extent:  0.23%)  of
measurements taken by non-profit movements74- ACRO, CRII-RAD, GSIEN - and allowed their experts to
participate  in  its  work  as  a  whole.  The  report  therefore  rightly  draws  attention  to  the  small  number  of
measurements taken by these bodies, which is evidence above all of the fact that independent expertise is not
sought often enough and does not, in France, benefit from the necessary public- and private-sector aid.

WISE-Paris also stresses that the GRNC has not calculated the collective dose to the global population (p.
57). The report itself makes a calculation for the population of Europe (p. 63) using the model employed by
the EC in 1995 [2].

The GRNC did not, in fact, make such calculations as they were not part of the remit conferred upon it by the
French Ministry of the Environment and State Secretary for Health.

4 – Conclusions

The  WISE-Paris  report  constitutes  an  important  study  of  all  the  problems  posed  by  fuel  reprocessing  at
Sellafield  and  La  Hague.  Its  structure,  which  we  have  not  been  able  to  subject  to  critical  analysis  in  its
entirety, does cover the problems which such industrial operations pose.

As regards the analysis of liquid and gaseous effluents from UK and French plants, a section we have studied
in  great  detail,  it  is  evident  that  the  authors  have  been  able  to assemble  and  use  substantial  technical  and
scientific documentation.

Whilst some of the points addressed in this report are also covered in technical literature, we must point out
that the report  has no equivalent  as  far  as  overall  consideration  and  critical  analysis  of  each  of  the 'end  of
cycle' problems posed by nuclear fuel are concerned. The many technical annexes are a useful supplement to
the report, which, for all these reasons, deserves to be published so as to reach a wide readership.

74 ACRO = Association for the monitoring of radioactivity in western France.
CRII-RAD = Commission for independent research and information concerning radioactivity.
GSIEN = Group of scientists for information on nuclear energy.

PE 303.110

170

                                                   
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