November 5, 1997

Rt. Hon. Dr. Gavin Strang MP
Minister for Transport
Departrnent for the Environment, Transport and the Regions
Great Minster House
76 Marsham Street
London SW1P 4DR
United Kingdom

Dear Dr. Strang:

The Nuclear Control Institute is seeking clarification of the British Government's policy concerning the international transport of nuclear material, especially mixed-oxide nuclear fuel.

At a recent international conference in Wyoming, hosted by the U.S. government, we learned that BNFL in October 1996 sent unirradiated MOX fuel to a German nuclear utility aboard the MS Arneb, described by the shipper as a roll-on/roll- off vessel. This shipment was a departure from BNFL's established practice of sending MOX fuel by air to the Continent.

NCI is pleased that BNFL chose not to ship MOX fuel by air because of our concerns about safety. But we are concerned about the alternative arrangements made to transport MOX fuel by sea on a roll-on/roll-off ship. Roll-on/roll-off vessels do not meet the highest safety standards for shipments of nuclear material, as codified in the International Maritime Organization's Code of Practice for Irradiated Nuclear Fuel (INF Code). We believe, therefore, that the use of a roll-on/roll-off vessel for nuclear cargo is entirely inappropriate.

According to the German shipper, Nuclear Cargo & Service Company, security considerations made a roll-on/roll-off vessel an attractive choice. The MOX fuel was driven into the ferry's cargo hold and transferred there from a British to a German carrier.

If the dockside transfer of MOX fuel is not advisable, are there not similar concerns about the transfer of MOX fuel from a van to a plane, especially given the recent security breach prior to a planned plutonium flight from Belgium to the U.K.? We believe this is a further reason to eliminate plutonium transports by air.

We would appreciate your response as to whether the policy of the British government will be to continue to allow shipments of MOX fuel to the Continent by air and by sea. If so, please indicate the countries to which MOX will be shipped by each modality. Also, we would appreciate information concerning the type of physical protection that will be required for shipments of MOX fuel in both modalities. Finally, we would like to know how use of roll-on, roll-off vessels can be justified when safer vessels are available for mantime transport.

We appreciate your consideration of these questions and look forward to your response.


Paul Leventhal

U.K. Government Response

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