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August 29, 1994

The Right Honorable Dr. Brian Mawhinney
Secretary of State for Transport
2 Marsham Street
London SWAP 3EB
United Kingdom

Dear Sir:

On behalf of Nuclear Control Institute, I am writing to urge that the Ministry of Transport prohibit shipments by air of radioactive materials pending completion by the International Atomic Energy Agency of new, stricter air transport guidelines, expected in 1996. The IAEA itself has advised member states that until work on the new guidelines is completed, "[C]learly, individual states have the option to forbid" transport of radioactive material by air."1 We urge you to take this action because the current standard for the transport of radioactive material applies the same criteria to all transport modes - road, rail, sea and air. Transport casks tested to these standards may not be strong enough to survive a high-speed air crash, according to the IAEA.2 In the event of an accident, release of plutonium would be a serious health emergency as plutonium is a deadly carcinogen if inhaled in only microgram quantities.

Our request is prompted by British Nuclear Fuels Ltd's announcement that an air shipment of mixed-oxide (plutonium and uranium) nuclear fuel rods was recently flown from Carlisle Airport in England to Zurich, Switzerland, and that other air shipments will follow over the next 12 months. Since BNFL is obviously prepared to ignore the IAEA's advisory and carry on business as usual, it is up to the Ministry of Transport to put a halt to these dangerous flights.

This week, IAEA technical consultants are meeting in Vienna to consider a draft version of the new air transport guidelines. While their proposal for a specific air-transport standard is an improvement over the existing standard that applies equally to all transport modes, there is considerable room for improvement since the draft standard falls far short of much stricter U.S. air-transport requirements. The more rigorous U.S. standard is presumably what prompted the United Kingdom to ask for the IAEA upgrade exercise in the first placed we urge you, therefore, to instruct the U.K. delegation to the IAEA deliberations to engage in a thorough review of stricter U.S. air-transport requirements and to explain why the draft IAEA standard should not be upgraded to meet the more rigorous U.S. criteria.

A close look at present and proposed IAEA testing standards underscores the problem. The present IAEA tests call for a shipping cask to be dropped 9 meters onto a hard surface, the equivalent of 13 meters/second. The new guidelines would require an impact test of 85 meters/second. The United States requires a shipping cask to withstand an impact at 129 meters/second or (for international trans-shipments) to withstand the actual crash test of a cargo aircraft at an impact velocity of 282 meters/second.

In the event BNFL maintains that its cask already exceeds the draft IAEA standard, BNFL should be required to make public the criteria against which the cask has been tested as well as the sequence of tests used to prove the crashworthiness of its cask. Assuming the BNFL cask does not meet the U.S. limits noted above, BNFL should be required to explain how, in the event of impact and fire conditions in a crash that exceeds these limits, it would be able to prevent oxidation of MOX fuel pellets and release of intensely toxic plutonium particles into the air. Last year, German state authorities effectively blocked an impending plutonium flight to Scotland after we raised this concern.

Air shipment of plutonium and other radioactive materials under existing lax international standards poses an unacceptable risk to the public. We urge an immediate halt to such transports and call on the British government to instruct its representatives to the IAEA to support stringent new guidelines comparable to existing U.S. standards that would ensure adequate protection of public health and the environment.

Paul Leventhal

1.The air transport of radioactive material in large quantities or with hioh activity IAEA-TECDOC-702, International Atomic Energy Agency, no date, p. 35.

2. IAEA-TECDOC-702, p. 11.

3. "Guidance is required on the validity of the requirements of Safety Series No 6, 1985 Edition, in respect of air transport, taking into account the more stringent measures which are being applied by some transport authorities and the inconsistency and lack of harmony which result. The views of the IAEA and other Member States on this problem are invited." U.K. statement, IAEA Log. No. SS6/lP/87-012, quoted in U.S. Environmental Assessment of the Proposed New Agreement for Peaceful Nuclear Cooperation between the United States and Japan, 2-16.

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