EUROOPPALAINEN ATOMIVOIMA-KRIITTINEN 
KONFERENSSI HELSINGISSÄ 9.-11.11.2007

EUROPEAN NUCLEAR CRITICAL CONFERENCE 2007 

  The Ostrich Posture
Response to Consultation Paper on ‘Managing Radioactive Waste Safely’
By Dr David Lowry*

“I do not have an answer in the many notes that I have to the point made by the Baroness, Lady Sharp, about security and the note that she read out. I will say, however, that it is a long-term problem. It has, of course, been consulted on…..Security is an extremely fair and, in some ways, very obvious issue to raise. It is certainly not the case that the current security arrangements for nuclear waste are inadequate. The UK’s civil nuclear sites apply stringent security measures, which are regulated by the security regulator, the Office for Civil Nuclear Security. This office works closely with the Health and Safety Executive, the safety regulator that provides advice on safety implications and events, including external hazards such as plane crashes at nuclear installations. Civil nuclear operators must have site security plans dealing with security arrangements for the protection of nuclear sites and nuclear material on such sites. These arrangements cover, for example, physical protection such as fencing, CCTV, turnstile access, the role of security guards, the Civil Nuclear Constabulary, the protection of proliferation-sensitive data and technologies, and the trustworthiness of individuals who have access to them. Security at nuclear sites is kept under regular review in the light of the prevailing threat and has been significantly enhanced since the terrorist attacks in the United States of America on 11 September 2001. It is not our policy, of course, to disclose the particular details of those.”
- Lord Rooker, Defra minister, responding to House of Lords debate on the Lords Science & Technology committee report on Radioactive Waste Management, 29 October 2007
Lord Rooker, who does not hold departmental responsibility for radioactive waste policy, according to his Defra ministerial profile, was responding to the comments made in the debate by Liberal Democrat peer, Baroness Sharp of Guildford, reproduced immediately below.
“In our report, we raised the issue of nuclear security, and asked that the Government engage in much more open dialogue with local communities and stakeholders on the risks associated with the current storage facilities.
Among the evidence that we received during this inquiry was a very long paper from Dr. David Lowry, who I understand is an expert on nuclear security, in which he asks questions about the security aspects of nuclear storage. We followed this up with the NDA and the Minister and, as our report reflects, were reassured that the Office for Civil Nuclear Security—the OCNS—kept a strict eye on these issues, and that the NDA and OCNS work to a site-security plan on all sites. Obviously, the details of these plans must remain secret. Nevertheless, as Dr. Lowry points out on page 75 of the evidence that is published with our report, it is alarming that, in an exhibition at Sellafield hosted by BNFL and prepared by the Science Museum, the following statement was apparently among the displays:
“The high-level liquid waste that comes from reprocessing is stored in constantly cooled tanks at Sellafield. These tanks represent one of the world's most hazardous concentrations of long-lived radioactive material and are, therefore, a prime terrorist target. An attack on these tanks, similar to the one in New York in September 2001, could have extremely serious consequences for much of the UK and Ireland”.
I do know when the exhibition took place but would guess that it was two or three years ago. Will the Minister therefore assure us that the Government are well aware of these risks and have taken or are taking appropriate action? In particular, with the build-up of high-level nuclear waste and spent fuel as a result of the decommissioning programme, can we be assured that further concentration of such material at Sellafield will be sanctioned only if it can be safely housed? As I said, since geological disposal is still some two to three decades off, we are talking about an interim not of two to three years but of 20 to 25 years.”
(Lords Hansard, 29 October 2007 : Column 1225)

These concerns frame this submission.

Introduction

In this submission I will concentrate on two matters, security and accountability, arising from the MRWS consultation paper, on which I think ministers need to give particular additional attention, on which in my judgment the consultation paper is inadequate in its coverage.

Some of the material used in this submission was originally presented to government in my submission dated 31 January 2007 (written at the time for SERA, of which I am no longer a member) responding to selected sections of the 'Response to the Report and Recommendations from the Committee on Radioactive Waste Management (CoRWM) by the UK Government and the devolved administrations', dated on 25 October 2006.

Section One: Insecurity

This section comments on chapter 4 of the MRWS consultation paper (hereafter referred to as MWRS), and addresses question 4 posed as:

Question 4: Government believes the system of regulation outlined in paragraphs 4.2 to 4.14 is strong and robust in relation to a geological disposal facility. Do you agree? If not, what other regulation do you feel is necessary?

There is minimal information presented in MRWS on security issues. Paras.4.11 & 4.12 assert the following:

“4.11 Nuclear installations must have a site-specific security plan approved by the OCNS and any proposed changes to security plans must also be approved in advance by OCNS. The security plan needs to provide details on site security management, policing and guarding and to describe in detail the site security measures and arrangements for managing and reporting incidents.
Approved carriers and approved transport plans will also be required by OCNS where movement of nuclear material to the facility is involved.
4.12 At present, the security plan must be approved before operations are allowed to commence, but the Government is considering whether to bring this requirement forward such that a security plan must be approved by OCNS before construction can begin.”

Earlier, on page 26, there is a short description in a box of the role and regulatory responsibility of the OCNS. This follows mention in an introductory box on regulatory scrutiny of the following: 

“Government will look to early and continued involvement of the safety, environmental and security regulators throughout the MRWS implementation programme. Transport regulation and nuclear safeguard requirements will also be strictly applied;”

and 

“All aspects of regulatory decision-making except those which could prejudice national security or commercial confidentiality will be open and transparent and will provide opportunity for input and assessment of public and stakeholder views.”(italics added)

There is also a passing reference to security matters in Chapter 3, at Para.3.26, where MWRS asserts:
“As with any radioactive waste facility, integrated and well-planned security arrangements will
need to be in force throughout the operational life of a geological disposal facility, to counter
threats from malicious action or theft. Such security arrangements are already routinely applied
at sites throughout the UK. As with other civil nuclear sites, the security regulator (the Office for
Civil Nuclear Security, OCNS) will be involved throughout the process. There is also a need for
robust independent regulation of both safety and environmental protection (both radiological and
non-radiological), which will be ensured through involvement of the safety and environmental
regulators. This is discussed further in Chapter 4.”

But listing the existence of security provisions, and the roles of the security regulator, is not the same as applying robust security in practice. My aim is to indicate several short comings in the discussion of security issues in MRWS. 
 

In chapter 3, para 3.15 on co-location, it argues  that such a strategy of emplacing the whole radioactive waste inventory, ie LLW, ILW and HLW in adjoining geologic repositories sharing the surface and access infrastructure, would be “technically possible” and that there is “no reason it should jeopardise security.”

My view is that while this statement is probably defensible in the strictest terms, depending on design of access tunnels, the following argument in para.3.17 setting out the view out, viz, that:
“If new build waste were to be accommodated in the same facility as legacy waste, additional vaults would have to be provided and the design would need to be modified. The facility would also have to stay open longer, as new power stations would be decommissioned later than existing plants,” 
could increase insecurity as it would require the access routes to the storage chambers to be kept open longer, hence keeping open a potential route for malevolent intruders to stored HLW, and conceivably immobilised plutonium and HEU, depending on the forthcoming Government policy decision on what to do with the currently stored stockpiles of these surplus weapons-useable fissionable materials, as para.3.13 indicates is currently being considered.

Indeed, this concern is addressed in para 3.19, Chapter 3 also includes the earlier observation and comment raising  security, at para. 3.19:
“The UK Government acknowledges that there is a divergence of views on this subject, but on balance considers that CoRWM’s conclusion was correct, i.e. that “leaving a repository open, for
centuries after waste has been emplaced, increases the risks disproportionately to any gains”. Closure at the earliest opportunity provides greater safety, greater security from terrorist attack,
and minimises the burdens of cost, effort and worker radiation dose transferred to future generations. The UK Government also notes, however, as has CoRWM, that it is likely to be at least a century until final closure is possible, which the UK Government believes provides sufficient flexibility for further research to be undertaken to achieve public confidence
and approval and to provide for key decisions to be taken in future.”

But the relationship of this concern to the impact of keeping open any repository to accept radioactive waste from putative new build reactors is not made. It needs to be!
While it may work out cheaper in pure financial terms to use an existing repository for new build waste by keeping it open longer, it may pay the price of making malevolent access easier, which could have literally incalculable consequences.

I remain greatly concerned that ministers and government officials alike seem determined to take an ostrich–like posture on security exigencies of nuclear waste, on the fallacious belief that by burying one’s head deep enough in the sand, potential and predictable  problems will go away. They will not.

In January 2007I was the author of the security section of a submission made in response to the Government statement in October 2006 responding to the recommendations of the CoRWM final report and recommendations.

I reproduce this section in italics in full immediately below, because all evidence of which I am aware, indicates that the concerns set out in detail then have been overlooked by the author(s) of the MRWS document.

CoRWM Recommendation 2 stated: 
A robust programme of interim storage must play an integral part in the long-term management strategy. The uncertainties surrounding the implementation of geological disposal, including social and ethical concerns, lead CoRWM to recommend a continued commitment to the safe and secure management of wastes that is robust against the risk of delay or failure in the repository programme.

Due regard should be paid to:
I. reviewing and ensuring security, particularly against terrorist attacks
II. ensuring the longevity of the stores themselves
III. prompt immobilisation of waste leading to passively safe waste forms
IV. minimising the need for repackaging of the wastes
V. the implications for transport of wastes.

1. Security

In respect of point (i) above, the Government while broadly accepting the recommendation qualified this in stating:

 "(i) the security of all stores is of paramount importance. The NDA’s contractors are regulated and advised by the Office for Civil Nuclear Security and already take account of such matters including the design and engineering of new stores and the refurbishment of existing ones in light of the risks to the security of their contents, now and into the future. This includes, but is not limited to, the vulnerability of the waste form and the degree of protection provided against attack."

Comments
There are serious issues of security and concern about terrorist attack.

This assurance as to the robustness of  nuclear waste stores against potential attack by a terrorist adversary was repeated by Dr Pearson MP, the Defra Minister of State for Climate Change and the Environment (whose responsibilities also include radioactive waste policy) in his oral evidence to the House of Lords Science & Technology Committee on 29 January 2007.

S&T Committee member, Lord Flowers [whose own credentials on the matter include his chairing the seminal Royal Commission on Environmental Pollution inquiry, whose report on radioactive waste and nuclear materials management was published 31 years ago] rightly raised a particular statement issued in January 2006, by a group of experts convened by CoRWM to advice it on security aspects of nuclear waste management, the full quote on which is reproduced immediately below. 

The Specialists were keen to make the following statement, which they strongly believe should appear at a prominent place in the final CORWM documentation.

“The security Specialists appointed to the CORWM Specialist Security Workshop recognise that CoRWM is not responsible for the priority that is being given to the conditioning and mode of storage of nuclear waste forms prior to their transportation to the selected storage/disposal facility that may not occur for some decades into the future. However, it is our unanimous opinion that greater attention should be given to the current management of radioactive waste held in the UK, in the context of its vulnerability to potential terrorist attacks.

We not aware of any UK Government programme that is addressing this issue with adequate detail or priority, and consider it unacceptable for some vulnerable waste forms, such as spent fuel, to remain in their current condition and mode of storage. We urge the Government to take the required action and to instruct the NDA, in cooperation with the regulators, to produce an implementation plan for categorising and reducing the vulnerability of the UK’s inventory of radioactive waste to potential acts of terrorism, through conditioning and placement in storage options with an engineered capability specifically designed to resist a major terrorist attack.”

Extracted from CoRWM Specialist Workshops - December 2005
[http://www.corwm.org.uk/PDF/1502%20-%20Overall%20Specialist%20scoring%20report%20V1.1.pdf]

Dr Pearson told the Lords Science & Technology Committee in terms that ministers were satisfied with the robustness of the present protection arrangements against a potential terrorist adversary. He indicated ministers took advice from the Government's security adviser, the Office for Civil Nuclear Security (OCNS).

But what Dr Pearson did not clarify, but which is materially important to be publicly clarified, is that amongst the specialist experts who agreed to the unanimous statement of concern was John Reynolds, the deputy director of OCNS who was one of the participants along with the then director of security for BNFL, Dr Roger Howsley.

It is clear the repeated assertions as to the satisfaction of ministers over current UK nuclear security arrangements covering radioactive waste are dangerously complacent. Minimally ministers need to explain publicly what changes have been made in  current UK nuclear security arrangements by OCNS, that have resulted in the satisfaction that current and future security arrangements changed the views of the OCNS, since OCNS’ deputy director signed up to the CoRWM specialist expert’s statement.

Moreover, ministers’ repeated deference to the competence and authority of the OCNS may be misplaced. The most recent Annual Report to government by the OCNS’ Director Roger Brunt reveals the UK nuclear industry has reported 39 lapses in security against terrorism in the past year, including laptop thefts, internet misuse, a power cut and lightning strikes.

The OCNS report revealed that "Assessments suggest that no major damage had occurred, but the fact that they continue to happen reinforces the enduring need to combat complacency. The information security inspector continues to work closely with security managers within the industry to raise the standard of personal security awareness."

OCNS also expressed concern about "additional security challenges" posed by the growing use of wireless computer networks and portable e-mail devices like the Blackberry. Nuclear plant operators reported a further 26 breaches of site security to OCNS last year. They included "a failure of mains power at a control room", "lightning causing alarm faults" and "spoil being placed too close to a perimeter fence".

Overall, the OCNS Director nonetheless concluded, somewhat incredibly, that that civil nuclear security was satisfactory, commenting. "I am satisfied that the security of nuclear material has not been prejudiced." 

In early August 2007, the director of the OCNS published his most recent annual report to ministers. His section on radioactive waste states:

SECURITY OF RADIOACTIVE WASTE 

“22. On a number of occasions during this reporting period, I have been asked for my view on the security of radioactive waste held in interim storage facilities on licensed nuclear sites. For the record, I believe that the best place for radioactive waste is in a long term repository, having first been properly conditioned in line with the best research and technology available at the time to ensure that it is in a passive state. Until that aspiration can be realised, there is no option but to store radioactive waste on licensed nuclear sites. All such sites though, are strictly regulated in accordance with the demanding requirements of the NISR 03. I require appropriate standards of security, commensurate with the category of nuclear material and the activity level, for all radioactive waste, held on each site. Without this, an SSP [site security plan] for a licensed nuclear site holding radioactive waste would not be approved. OCNS Inspectors include radioactive waste stores in their programme of inspections to ensure compliance.”

It is unclear from this passage whether the chief security regulator is including stored spent nuclear fuel in his category of  radioactive waste, but if he is, then he conveys none of the concern  signed up to by  his former deputy director, who without qualification signed on to the statement of concerns to CoRWM in the statement cited above.
 
At another juncture in the security regulator’s report (para.74, p.17) he states:

“At the time of writing, I have no requirement for further changes to the Regulations applicable to security in the industry but looking to the future, OCNS would need to regulate the security of new nuclear facilities that might be built, such as the long term waste repository or any interim waste storage, whilst they are being constructed.” 

But, as established above, 4.12 of MWRS, published six weeks before the OCNS 2007-07 annual report, states:

“At present, the security plan must be approved before operations are allowed to commence, but the Government is considering whether to bring this requirement forward such that a security plan must be approved by OCNS before construction can begin.”

Ministers should clarify whether the Government intends such a security plan to be produced before or during construction of a repository.

The Government responded to the recommendations of the Lords Science & Technology Committee Inquiry into Radioactive Waste Management on 3 June 2007. Recommendation 16 of the Committee report read:

“The Government must engage in a much more open dialogue with local communities and other stakeholders regarding the risks presented by current temporary storage and the steps taken to address them. We therefore recommend that the Government review the amount and level
of detail of information on nuclear security that is made available to stakeholders or published. Security arrangements form an integral part of the implementation programme and information on their nature should be readily available. (3.35)”

The Government response in full to this recommendation read:
”The NDA is currently undertaking a national review of waste storage
arrangements. These will form part of its next strategy statement, to be
published in 2008, which will be the subject of national consultation. There
will also be discussions with local stakeholders with an interest in the storage
sites involved.
Nuclear installations must have a site-specific security plan approved by the
Office for Civil Nuclear Security (OCNS) and any proposed changes to
security plans must also be approved in advance by OCNS. The security plan
needs to provide details on site security management, policing and guarding
and to describe in detail the site security measures and arrangements for
managing and reporting incidents. Approved carriers and, where necessary,
approved transport plans will also be required by OCNS where movement of
nuclear material to the repository is involved.
It is not Government policy to publish security plans for obvious reasons. It
will be for the NDA and its contractors to agree with OCNS how much security
planning information they could reasonably and safely be made available to
stakeholders to help provide appropriate reassurance.”

It is sadly clear that when publicly available nuclear security-related information is critically appraised by independent expertise, ministers steadfastly ignore the criticisms.

Exactly a year ago the then DTI energy minister answered a question about the adequacy of resources available to the security regulator to conduct its mission
 Dai Davies: To ask the Secretary of State for Trade and Industry what assessment he has made of the adequacy of resources available to the Office for Civil Nuclear Security to regulate the security of radioactive wastes in (a) store and (b) transit. [98193]
Malcolm Wicks: The Office for Civil Nuclear Security (OCNS) is responsible for the regulation of the security of all radioactive material on licensed civil nuclear sites, and of nuclear material in transit.
OCNS assesses its own resource needs regularly and resources are provided through the Department of Trade and Industry.  Successive directors of Civil Nuclear Security have commented on these resource levels in their annual reports, documents which primarily provide assurance that security arrangements within the civil nuclear industry are stringent and comprehensive, and regulated by a competent security authority, independent of industry interests.
(Official Report, 2 November 2006: Column 559W)

The italics are mine. I highlight them because this phrase does not mean that all security arrangements are adequate, even though ministers might like it to be the case. The purpose of the OCNS annual report to ministers ought to be to provide the truth, not assurance. The response was ambiguous to say the least. 

Another Parliamentary answer, in September this year, to Liberal Democrat environment spokesman Chris Huhne, provided details of annual expenditure by the Nuclear Decommissioning Authority on security. Energy minister Malcolm Wicks stated that out of £273.17 million in total spent by the NDA on its reactors generating electricity in the financial year 2006-07, Security costs comprised £7.81m ( other  relevant figures  within this total were: Transport of Radioactive Materials £5.27m; Radioactive Waste Removal
£1.62m; & Radioactive Waste Storage £0.70m) (Official Report, 10 September 2007: Column 2038W) .The proportions of the total, as well as the absolute amounts, accounted by these operational headings will certainly increase as the NDA reactors are closed and decommissioned. It is to be hoped that the security element is fully funded to ensure optimum security of the hazardous operations to come.

Later this month (19-22 November), the United Kingdom Government is co-hosting in Edinburgh for the United Nations’ International Atomic Energy Agency (IAEA) an ‘International Conference on Illicit Nuclear Trafficking: Collective Experience and the Way Forward’, which the pre-publicity  suggests will be attended by representatives and experts from over 70 nations, indicating a considerable international concerns over the nuclear security issue

The IAEA states that the “Conference is being convened to review the global experience in combating illicit trafficking and to consider a possible international strategy to prevent, detect and respond to this phenomenon. For that purpose, the appropriate experts and policy officials will be brought together to share knowledge and information about progress achieved, to examine the threats and risks involved in nuclear trafficking and to recommend a better way forward to thwart illicit trafficking. The specific objectives of the conference are: 
§ To examine the risks and threats of illicit trafficking of radioactive material 
§ To better understand current and future patterns and trends in the illicit trafficking of radioactive material 
§ To determine progress on efforts to establish detection capabilities at borders and to exchange information on developments in detection technology and response methodologies 
§ To strengthen existing networks and cooperation for sharing information on illicit trafficking 
§ To examine how an enhanced export/import regime can assist in combating illicit trafficking 
§ To share information on activities intended to implement international obligations, recommendations and guidance relevant to nuclear security 
§ To suggest actions by which the international effort, through the IAEA, would be strengthened. 
In light of the government decision to host this international conference - which will showcase to  the world the hazards and risks of the failures of the nuclear security regime – and the earlier IAEA conference on nuclear security  hosted by the UK three years ago ( ie International Conference on Nuclear Security: Global Directions for the Future 16 - 18 March 2005, in London), it is hard to understand why, in its  response to the CoRWM experts’  explicit concerns over  the insecurity of stored  irradiated ’spent’ nuclear fuel at reactor sites, the government persists to rely on repetition of assurances and seeks to hide behind the existence of the OCNS, despite the fact that the OCNS’ own reports to ministers indicate several unresolved inadequacies of nuclear security controls. 
 

Section Two: Accountability

In his response to the Lords debate on 29 October this year on the Lords Science & Technology Committee report on Radioactive Waste Management, Lord Rooker took pains to mention he had read “the whole transcript” of a meeting Defra minister Phil Woolas had held on nuclear waste with the Committee on 11th October. Unfortunately, my research with the Lords Committee authorities, The House of Commons Library, and Mr Woolas’ private office in Defra, has established that it has been decided to designate this meeting as an informal private exchange of views, and there are no plans to make public the transcript to which Lord Rooker was privy.
In the same speech Lord Rooker asserted: “There must be proper scrutiny. That can be done best if everything is open and transparent.” I agree with him, but it is a pity his department does not practice what it preaches about openness and transparency.
I use this as a contemporaneous example of  problems over accountability to introduce my concerns that the proposals for accountability arrangments in MRWS are inadequate.
A key to getting the accountability right for the next steps is how CoRWM’s newly constituted  committee with perfom. Of the  reconstitution of CoRWM, Lord Rooker told  peers in the debate referenced above:
 “Turning to the appointment of the reconstituted CoRWM, we committed to strengthening the scientific, technological and social science expertise as the Science and Technology Committee advocated. The learned societies, as well as the Science and Technology Committee, were invited to draw the advertisements to the attention of those who could have been suitable members. As well as ensuring that the right mix of skills and expertise were sought, a representative of Defra’s Chief Scientific Adviser advised the appointments panel on the relevance of the science behind the applications.
On 25 October—last Thursday—we announced the new committee. We are confident that it has the strengthened scientific and technical make up and that it will continue the high standards of evidence-based advice, founded on openness, transparency and engagement, set by its predecessor. Furthermore, our commitment to appointing the best possible committee means that in two specific scientific and technological skills areas—hydrogeology and mining—we will be re-advertising to ensure we get the right members for the roles.”

While nobody can doubt the importance of CoRWM having technically compentent experts, it is a pity that the template decided for the range of expertise required did not include someone with  expert knowledge in decision-making  or on environmental policy development. Experts with  these skills did apply for positions on CoRWM, but were not chosen. I fear the  scrutiny of the decision-making processes as the NDA takes forward the MWRS programme will be undermined by the absence of this  expertise, and the  public accountability of the programme with consequently suffer detrimental effects.

I next want to make some comments on Question 6, which read:

Question 6: Do you agree with this approach to defining ‘community’ for the purposes of the site selection process? If not, what alternative approach would you propose and why?

I think this process got off to a very bad start when former Environment Secretary David Miliband, a strong advocate of nuclear power, in welcoming and accepting the CoRWM proposals in a Parliamentary statement in October 2006, having introduced his support for volunteerism thus: 
We have made it clear that we are not seeking to impose radioactive waste on any community. In that context, we strongly support exploring the concept of voluntarism and partnership, as described by CoRWM, with the local authorities serving communities that might be affected. As CoRWM recognises, there is a need to consider further how such arrangements will work in practice. Accordingly, we will look to develop further an approach that includes: the stages and decision points; how communities would be involved; the role of democratically elected bodies locally; and the potential for involvement and community packages as suggested by CoRWM.
Disposal facilities will be built only in a geologically suitable area, and we will also consider how geological and scientific considerations will be meshed with other societal considerations as, for a successful programme, all the criteria will need to be met.”
He then gratuitously and inappropriately added:

“I invite any local authority—or group of local authorities—that wishes to be involved in those discussions to contact me, the Minister for Climate Change and the Environment, or my officials directly. Similar invitations are being extended by my colleagues in the devolved Administrations.”(Official Report, 25 October 2006 : Column 1521)
This invitation was premature in the extreme, and could have led to discrediting the concept of volunteerism before it had been fully worked out.
Paras. 5.9  to 5.16 of MRWS more appropriately  set out the considerations that  need to be explored before any community (however defined) volunteers itself as a prospective host community for a repository.
Para.5.12 rightly address a very important issue thus:
“Outside this host community, there are likely to be other communities that have an interest in whether or not a facility should be built in the host community, and there needs to be a mechanism that allows them to become involved in the process. Such a community might be the next village, a community on the main transport routes to the host community, or even the whole democratic unit (e.g. county) within which the host community is situated. Government proposes that such communities be termed ‘Wider Local Interests’.”
I think the communities on prospective transport routes will prove to be very important when judgments are made about the equity of distribution of various forms of “community benefits packages.” Even though it may be argued that the community hosting a d final repository  faces the  greatest potential risk, as the final concentration of radioactivity will be under their feet, it is arguable that  those communities on the main transport routes  face the  greatest potential hazard, as accidents  and/or malevolent intervention or interruption of radioactive wastes in transit by rail or road are potentially more likely than when these materials are emplaced in affixed place in a purpose -built underground  cavern. The vulnerability of these radioactive cargoes – which will increase their regularity manifold when the management programme gets underway – means that  securing agreement of en route communities will be as important as volunteer  host communities.
In the United States, which for two decades has been planning a single centralized repository at Yucca Mountain in Nevada for the final disposal of much of its irradiated spent fuel, currently stored at many of the nation’s 100 plus reactors, there has been growing opposition from prospective en route communities which have provocatively dubbed  the transports as ‘mobile Chernobyls.’ Although the distances radioactive wastes will need to be transported in the UK to wherever a final disposal site (or possibly sites) is located are necessarily much shorter than in the United States, it is predictable that concerns along prospective transport routes will – in my view legitimately – emerge, and almost certainly grow.
For reasons of equity between prospective host and en route communities, I believe it is important that the Government should commit to making public via a press release and posting on Defra & BERR web sites on issue, any letter of invitation to local authorities to consider volunteering themselves as prospective host communities, along with a complete list of volunteer communities, with their respective letters of response.

This transparency is important, above all for prospective en route communities, who have not volunteered themselves.
Please post my submission the Defra web site as a soon as possible after receipt.
Dr David Lowry  
Environmental policy and research consultant
Stoneleigh
Surrey
drdavidlowry@hotmail.com
2 November 2007
__________________________________________________________________

*Biographical Note

Dr David Lowry works as independent research consultant with specialist knowledge of UK and EU nuclear & environment policy.
Since 1992, David Lowry has prepared over 6,000 parliamentary questions for UK MPs and MEPs, drafted motions for resolution, speeches and articles on their behalf, suggested amendments to Euro-Parliament reports and researched, drafted and steered through to successful European Parliament Plenary Assembly endorsement two committee reports. Up to the 1997 UK General Election David Lowry acted as policy adviser and researcher for former UK environment minister Michael Meacher MP (when he was shadow Secretary of State for Environmental Protection). In 2000-01 he was a co-author of a major report on the environmental and health implication of nuclear reprocessing at La Hague & Sellafield for the Science & Technology Options Assessment (STOA) programme of the European Parliament (2000-01), acted as a contributing editor of Plutonium Investigation (www.pu-investigation.org 1999-00) and contributed to an international scientific and policy study project on plutonium fuel (International MOX Assessment IMA Project 1995-97). 
David Lowry has broad experience in both lobbying & briefing the media as well as in preparing and presenting multimedia lectures and giving oral or written testimony to a wide array of audiences including academic fora, groups of politicians of several parties, European and UK Parliamentary Select Committees, pressure groups and public inquiries. He has lectured for several summers on Energy at an MSc course at Reading University, an MBA course for BNFL middle managers at Lancaster University and conducted interview research in France, Germany and Japan for an ESRC sponsored research project on global environmental change for the Open University. 
David Lowry was awarded a PhD on nuclear decision making by the Open University, Milton Keynes, UK) in 1987. He previously studied at the State University of New York (1978-79) and the London School of Economics, London University (1975-78). 
In 2001 he was presented with a special award for education at the Nuclear Free Future Foundation annual awards and the UK Campaign for Freedom of Information 1995 Award in the politics category (jointly with Llew Smith MP) for the most effective and persistent campaign of parliamentary probing through the use of parliamentary questioning on civil and military nuclear issues. Since 1980, David Lowry has published a large number of specialist and populist articles (together with many letters to the editor in local and national press), in a range of magazines. These have appeared in, inter alia, Futures, Public Administration, Science, Nature, New Scientist, Economist, Bulletin of the Atomic Scientists, New Statesman, Nuclear Engineering International, Africa Now, Third World Quarterly and newspapers like the Asahi Weekly, Observer, Sunday Times, The Times, Financial Times, Independent, Guardian, Daily Telegraph, Daily Mail, London Evening Standard, International Herald Tribune, The San Francisco Examiner and The New York Times.
He is a co-author of a book, ‘The International Politics of Nuclear Waste’, published by Macmillan in 1991; and is a contributing author of chapters on nuclear insecurities and radiaoctive waste policies, to a book on British energy choices, “Nuclear or Not?” published in February 2007 by Palgrave Macmillan, along with chapters on nuclear policy issues in several other books.
 
 
 

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Päivitetty 1.11.2007