Mr. Hugh R. Collum, Chairman
British Nuclear Fuels Ltd (BNFL)
Hinton house
Warrington
Cheshire WA 3 6AS

IN REFERENCE TO THE SELLAFIELD PLANT AND COMMITMENTS PURSUANT TO INTERNATIONAL CONVENTIONS

Bedriftsforbundet (The Confederation of Norwegian Industry) and the Bellona Foundation represent central organisations within the business sector and the environmental movement respectively. Both organisations are very much concerned about the damage the Sellafield plant imposes on the Norwegian business sector and Norwegian environmental interests. The two organisations hereby request BNFL to utilise different technologies for their purification activities at Sellafield.

We can not exclude the possibility of BNFL being held liable for Norwegian enterprises’ financial losses related to depreciated commodity values and lost markets caused by pollution from Sellafield.

Threatened Norwegian business interests
 
Norwegian business interests are threatened by the discharges of nuclear waste from Sellafield. Norwegian enterprises basing their activity on raw materials such as seaweed, sea tangle, lobsters and related organisms experience a loss of both national and international market share. Norwegian aquaculture sell high-quality products of “arctic quality” harvested in cold and pure water in the northern areas.

Already measurements show increased pollution levels in raw materials from the sea. Obviously, international customers react strongly to buying polluted commodities, which also are the most expensive on the market. The value of being able to market raw materials as “clean” has now been lost. Norwegian enterprises experience that unique raw materials no longer satisfy the quality demands established by the international market. Most likely, the value of these commodities will be further reduced if Sellafield continues to handle technetium-99 (Tc-99) with its current technology.

Best Available Technology
 
According to the United Nations Convention on the Law of the Sea and the OSPAR Convention among others, Bedriftsforbundet and the Bellona Foundation are of the opinion that BNFL is obliged to utilise different purification methods at the Sellafield plant. The Sellafield plant pours out large volumes of technetium-99 to the Irish Sea, which is then carried by currents to Norwegian waters. Radioactive substances have a long time of decomposition, and may, even in minute concentrations, harm both humans and the environment. The recipient areas are already constrained and vulnerable with respect to both biodiversity and business potential. Tc-99 pollutes major areas along the entire Norwegian coast up to Spitsbergen and further northwards to Iceland and Greenland.

Bedriftsforbundet and Bellona request BNFL to vitrify its Medium Active Concentrate (MAC) waste which is stored in B211 so that the liquid Tc-99 waste is transformed into solid form. This initiative would eliminate the discharges of technetium-99.

The United Kingdom has through the OSPAR Convention committed itself to reduce the discharges from Sellafield so that the remaining concentrations of radioactivity in the marine environment are close to zero by 2020. In reality, this means that the discharges must be reduced immediately so as to cease in the long term. As far as we are aware, BNFL has not fulfilled the commitments that the government has committed itself to.

The problem of iron and sodium in the historic MAC waste can be solved by gradually mixing MAC into the constant stream of Highly Active Liquor (HAL) waste, which is being vitrified.

Violation of international conventions

BNFL is bound, through various international conventions, to an investment duty in order to keep itself updated on processes, facilities and operation routines that can limit both waste generation and discharges. The conventions also commit BNFL to apply any means necessary in order to prevent and eliminate pollution from land-based sources of pollution.

We feel that BNFL’s activities at the Sellafield plant involve the violation of a number of the provisions stated by Convention on the Law of the Sea, the OSPAR Convention, the Paris Convention of 1974 and the Espoo Convention.

Conclusion

In accordance with the principles of above-mentioned conventions, Bedriftsforbundet and the Bellona Foundation request from BNFL a written account of the pollution of international waters caused by Sellafield, as well as a detailed description whether BNFL considers the vitrification of MAC waste as an effective method for solidifying technetium-99.

Thank you in advance for providing us with a written reply as soon as possible, and at the latest by January 23^rd 2003.

Copy:

– The Norwegian Ministry of Foreign Affairs
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– The Norwegian Ministry of the Environment
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– The Norwegian Embassy in Great Britain
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The British Embassy