November 5, 1996
The Honorable Christos Papoutsis
Commissioner for Energy
The European Commission
200, rue de la Loi
Brussels B1049, Belgium
Request to Bar Air Shipments of Radioactive Material from European Union
Dear Commissioner Papoutsis:
We are writing to you in response to your remarks in last week's debate in the European Parliament concerning impending transports of radioactive material by air. We urge you to recommend that the European Commission issue a directive suspending all air transport of radioactive material in the European Union as of January 1, 1997.
In September, the International Atomic Energy Agency (IAEA) revised its "Safety Series 6" transportation guidelines for radioactive material, after acknowledging that existing "Type B" transport casks do not offer a comparable level of protection for air crashes as for surface accidents. The new guidelines purport to bar air transport of radioactive materials in Type B transport casks. However, dangerous air transports of plutonium, (as presently conducted by Great Britain), can continue to take place because the new guidelines will not take effect for several years. When they do, it is likely that plutonium in the form of mixed-oxide (MOX) fuel will be subject to an exemption that will permit MOX fuel to be flown in the existing casks.
We urge the Commission to take immediate steps to bar any air transport of radioactive materials by member states of the European Union under the old guidelines. Given the serious health, safety and environmental issues at stake, air transport of radioactive materials in Type B casks can no longer be tolerated. Unless the Commission acts now to bar any air shipments of radioactive material---including plutonium oxide and mixed-oxide fuel---these shipments could criss-cross Europe for several years in containers incapable of withstanding a serious crash. We urge you to act promptly to remedy this highly dangerous situation.
The revised IAEA guidelines call for use of a new "Type C" cask designed to withstand more severe accident conditions than the Type B cask, including an impact at higher speeds and a fire of longer duration. However, the IAEA specifications for a Type C cask fall far short of U.S. standards and of the International Civil Aviation Organization's (ICAO) standards for the "Black Box" packaging of flight data recorders. No cask meeting the strict U.S. and ICAO criteria has been successfully developed for transport of commercial quantities of radioactive materials, and it is expected that none can be developed at an acceptable cost. It is even doubtful whether a cask meeting the IAEA's lesser Type C standard can be developed successfully.
It is of particular concern, in this context, that the new IAEA transport guidelines contain an exemption that would permit MOX fuel to be transported by air in existing Type B casks if shippers can demonstrate that MOX fuel meets certain "low-dispersibility" criteria and can persuade national authorities to adopt them. The notion that MOX fuel would not disperse plutonium in severe fire and impact conditions is highly questionable, as are the actual testing methods that could prove low-dispersibility beyond a reasonable doubt. Thus, although the new IAEA standards appear to be an improvement over current practice, they are far from sufficient.
ICAO recently began a two-year review of the new air-transport safety code with a meeting in Vienna of a working group of its Dangerous Goods Panel. Pending completion of this review, we urge the Commission to issue a directive that would suspend all air transport of radioactive material as of January 1, 1997.
Attached you will find two studies by our Institute that provide greater detail on the IAEA's new air-transport standards.
We look forward to your response to this urgent matter.
Edwin Lyman, Ph.D.
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