Anne Sandwith
I am representing Friends of the Earth, Guernsey. Our group is affiliated, and licensed by, Friends of the Earth, UK. We have over 100 members in Guernsey and were founded ten years ago.
I welcome the opportunity of being allowed to make this submission direct to the public inquiry here in Beaumont Hague and thank you for the Information Booklet. However, we find it regrettable that the only information we have seen has been provided by COGEMA, who obviously have a vested interest in the success of the public inquiry. Previously we have not been able to make representations direct to the French authorities, but have been obliged to channel our submissions via the British government. This has been unsatisfactory as Britain, like France, has heavy investments in the nuclear industry and is also a nuclear power. In view of this we do not consider the British government is in a position to make an unbiased representation of our views to the French authorities.
Our own government, the States of Guernsey, represented in matters of nuclear safety by the States Civil Defence Committee, does not reflect the views of many islanders. We believe their reluctance to express any concern relating to the nuclear installations on the nearby Normandy coast is due partly to a misplaced belief that to do so may harm our tourist and fishing industries. However, it is the belief of our organisation, together with many other islanders, that the Cap de la Hague reprocessing plant, operated by COGEMA gives rise to several legitimate concerns which can seriously affect our island environment and the health of its inhabitants.
We would like to stress that as your 'nuclear neighbours' we do not derive any benefit whatsoever from COGEMA's reprocessing plant. The operation is purely commercial and whilst obviously benefiting some of the surrounding neighbourhoods by offering employment possibilities and other economic trade-offs, we in the Channel Islands receive no such advantages. Therefore the dangers of the plant predominate in our attitude to it and are not tempered with any other considerations.
Whilst our Civil Defence Committee do carry out local monitoring of our immediate environment for radioactive emissions from Cap de la Hague, it is true to say that some deposits, including plutonium, have been found on our beaches, and this we find unacceptable. It is well known that plutonium has a half life of 24,000 years and, even a particle as tiny as one ten millionth of a gram, if ingested, can cause cancer and possible death. The radioactive effluent discharged into the sea from COGEMA's pipeline may be dispersed, but it is not diluted. Dispersal means that the radioactive isotopes are spread more widely over a larger area and some of them reach our shores.
We would like to remind the inquiry commission that France is a signatory to the OSPAR Convention. This obliges signatories to achieve continuous reductions in discharges, emissions and losses of radioactive substances, with the ultimate aim of achieving concentrations in the marine environment to close to zero for man made radioactive substances by the year 2020. In view of the expansion plans for the Cap de la Hague plant, it seems highly unlikely that this target can be met in just 20 years time. Surely the aim should be to start cutting emissions into the sea immediately. OSPAR was only mentioned briefly (page 34) in COGEMA's Information Booklet.
Whilst on the subject of the discharge pipeline into the sea, we would like to know what steps are currently being taken to clean up the pipeline and the immediate seabed at the end of the pipe. We are aware of the problems encountered there over the past two or three years, as highlighted by Greenpeace and verified by independent laboratories in several countries. An accidental release of radioactive waste took place in the summer of 1997 following an attempted cleaning operation.
We believe that reprocessing the spent fuel at La Hague makes it more dangerous than if the fuel were safely stored at the point of generation, that is the nuclear power plants. Reprocessing inevitably adds to the amount of transportation of this highly dangerous material, with all the inherent problems so caused. It is our view that reprocessing exacerbates the waste problem by creating large amounts of liquid waste which has to be dealt with. Also, the process of separating the plutonium from the spent reactor fuel is totally irresponsible as there is a world glut of this highly dangerous substance which is one of the most hazardous known to mankind. The terrorist threat of so much stock piled plutonium is a frightening prospect. We understand that much of the uranium that is separated out during reprocessing is also being stockpiled, due to a world glut and to the fact that it is cheaper to use freshly mined uranium of a higher quality. Even if reprocessing was phased out at La Hague there would be plenty of jobs there for many decades, if not centuries, to come as the waste already stockpiled there would require constant monitoring and management.
We disagree with some of the assumptions made in COGEMA's Information Booklet. For instance, on page 13, reprocessing is 'dressed up' as being environmentally desirable and called 'recycling'. The English phrase for this kind of truth bending is known as 'Greenwash'. To imply that to substitute plutonium for oil is environmentally desirable is disingenuous. As we have mentioned above, even a tiny particle of plutonium can be lethal and is extremely hazardous if it enters the food chain. We certainly wish to reduce the amount of fossil fuels burned in power stations but do not believe that the nuclear alternative is the best way to do this. It is our view that a policy of conservation and energy efficiency is preferable, combined with the political will to develop and harness renewable sources of energy such as wind, wave, solar, etc.
MOX fuel, presented as the new saviour of the nuclear reprocessing industry, presents many problems. Again, more transportation of waste is involved, which is to be discouraged for security reasons and the risk of contamination incidents. Even after reprocessing and "recycling" in a MOX plant, the amount of plutonium initially produced in the reactor does not reduce.
We are concerned to note on page 38 of the Information Booklet that MOX fuel is quoted as having a higher plutonium content and is therefore more hazardous. This leads on to one of our main concerns, the envisaged increase (by 10% according to the Information Booklet) of nuclear material shipments in and out of La Hague. Some of these shipments will presumably be of MOX fuel and one such has already taken place.
Shipments of nuclear waste into La Hague for reprocessing and return shipments of nuclear waste to the country of origin pose grave concerns for Guernsey. We are close to the shipping routes and it is well documented that the seas around the Channel Islands are very hazardous. There have been many shipwrecks around our coastline, even in recent times with the benefit of modern instruments. Such an incident occurred just over ten years ago when a cargo of the toxic substance 'Lindane' was lost and never recovered. This incident was the catalyst for the formation of our Friends of the Earth group on Guernsey. Our concerns about the close proximity of the nuclear cargoes to our island are very real and any increase in their frequency is to be deplored. Please find attached a photocopied document written by Edwin S Lyman, Ph.D., of Princeton University on Safety Issues in the Sea Transport of Vitrified High-Level Radioactive Wastes to Japan. This document contains some very relevant points which, to our knowledge, have not yet been addressed.
From time to time we hear of incidents at Cap de La Hague, such as the pipeline one mentioned above, and difficulties experienced at some of the waste storage plants. We also heard of a Health Ministry report that revealed that leukaemia incidence levels among French children who use the beaches near La Hague or regularly eat locally caught seafood are higher than average. At the end of March 1998 the director of the French government's nuclear 'watchdog', DSIN, Andre-Claude Lacoste said that COGEMA would be asked to make efforts to reduce its waste discharge levels. They must be as low as possible and the plant's industrial performance must be improved. He also said that one of DSIN's main worries was that the existing laws about waste generation and discharge were not tight enough. He said that a decision on discharge levels would be taken at the end of the year. We would like to know the outcome of the request from DSIN before further expansion is given the go-ahead.
Anne Sandwith
1st March 2000
