Saturday, 19 January 2019

Wylfa nuclear plant's secret weapons link

Letter submitted to the Morning Star:
Peter Lazenby’s report on the decision by Japanese nuclear company Hitachi to pull out of building a new nuclear plant on Anglesey was given a ludicrously misleading headline in “Lights ’could go out across Britain’ as Wylfa plan collapse." (M.Star, 18 January)

Had this failed plant been given the go ahead, it would have provided less than 7 % of national electricity supply, which is less than 2 % of delivered energy.
Nuclear supporters such as the trades union leaders from Prospect and the GMB quoted should not line-up  with the Tory  Business and Energy Secretary, Greg Clark, and massively over-inflate the  contribution to energy security in the UK of foreign-designed, foreign-funded nuclear power.

Clark’s Labour Shadow, Rebecca Long-Bailey should wean herself off cheerleading for new nuclear power, and read some of the excellent articles on real sustainable energy policies written by Labour energy advisor, former Labour left MP Alan Simpson, encouragingly published regularly in the Morning Star.

The cancellation of Wylfa Newydd means the secret story of the original Wylfa nuclear plant will now not be repeated


In an interview I conducted on 19 January 1983 with the late Lord Hinton, the first chairman of the CEGB, (barely five months before his death, at which point he was still advising the electricity industry) he said to me “Wylfa is a long and sad story. It ought not have been built at all, but when I suggested this to the Permanent Secretary [at what is now the Department  of Energy and Climate Change]  he said you have got to build it in order to meet the government programme.”


The programme to which Lord Hinton referred was not electricity generation but plutonium production, as became clear in the Sizewell B nuclear plant public inquiry  which had just begun when I interviewed Lord Hinton, and ran for 333 days.


During that inquiry, Professor Keith Barnham , who with myself  gave expert evidence for the CND Sizewell Working Group, produced technical evidence demonstrating  around 630 kilogrammes (+ or – 80 kgs) of plutonium produced in UK magnox reactors had been exported to the US for military use ( a nuclear warhead c typically uses 5-10 kilos). This research was published in detail in the prestigious international science weekly  journal, Nature, on 19 September 1985.


A decade later, in October 1995, former Labour peer, the late Lord Hugh Jenkins of Putney, a life-long CND supporter, asked the Government in a written Parliamentary question (headed, Wylfa Power Station: Plutonium Creation109WA) ‘how much plutonium Wylfa nuclear power station has created since it began operation in 1971, where it has gone and where it is now, and what relationship there is at the plant between plutonium production and the generation of electricity.


Lord Fraser of Carmyllie,  answering for the Conservative Government said: “Since 1986/87, estimates of the plutonium contained in the reactor discharges at Wylfa power station have been published as part of the annual plutonium figures. I cannot answer for previous Administrations. Amounts arising from Wylfa continue to contribute to the United Kingdom's civil holdings under international safeguards…Irradiated fuel from Britain's various civil Magnox reactors is reprocessed together and therefore the plutonium arising, whether in store or exported, is not linked to the specific power station in which it was created.”  [House of Lords 23 October 1995, column 109WA 109WA]


The give-away is the minister’s admission that nuclear fuel from all Magnox reactors was “processed together” (at Sellafield)   and hence the recovered plutonium  loses  it identity.


The export of UK plutonium to the US took place under a controversial 1958  bilateral  UK-US deal, called the Mutual Defense Agreement on Atomic energy matters ( as amended in 1959) The word defence is spelled with an ‘s’ even in the British edition, giving away the origin of its drafters in the US!)


When this draft agreement was discussed in the US Congress on 4 February 1958 (it was never debate in the British Parliament at all before coming into force) Lewis Stauss,  chairman of the US Atomic Energy Commission, let slip the following nuclear nugget of information on the aim of the deal with the UK “This is primarily to supply plutonium to us for our unrestricted use, which is to say , at present, our  military use.”


This UK-US MDA was  renewed in October 2014,( ) and despite being challenged by the then Labour back bench MP Jeremy Corbyn, in a Parliamentary debate on 6 November 2014 ( , remains in force.


So when Wylfa’s final discharge of spent nuclear fuel is finally reprocessed at Sellafield, the plutonium could still end up in US nuclear warheads


The agreement required the US Atomic Energy Commission, which took title to the plutonium, to put it solely to military use.


Wednesday, 16 January 2019

Dr David Lowry unearths important information about the nuclear fall-out of Brexit on the loss of co-operation and the ownership of plutonium

NTW member Dr David Lowry is widely known for his stubborn and very effective work on nuclear transparency in the UK. Over the years, he has used all the tools in the legal toolbox to prevent important information being kept out of the public domain and in that way influenced many important nuclear debates in Britain. His instruments include access to information requests, but also parliamentarian questions and intensive on-line research. Dr David Lowry calls on NTW members and others following nuclear developments to more intensively use these instruments. That is an important call, because his work shows that the lack of transparency in the nuclear sector still enables politicians to hide the complexity of nuclear decision making, including issues around the true cost of nuclear energy, the important role of co-operation in nuclear medicine, the ongoing radioactive waste problem, and even the link between civilian and military nuclear sectors. Lowry’s work gives extremely good examples how to go about delivering more transparency in real life and we certainly will feature more of them here in the future. NTW also plans to set up a library where this kind of information will be stored so that other nuclear transparency activists can maintain access.
Last month, Lowry revealed key-information on the nuclear fall-out of the Brexit process on the loss of co-operation in the field of nuclear power, that he had obtained over parliamentarian questions. In a detailed blog including the full response from the Chair of the Business, Energy and Industrial Strategy Committee in the British Parliament, Rachel Reeves, to the Energy Minister Richard Harrington, he sharply analysis how the industry bias of this MP leaves out important issues from the national debate and counters that with what a different Committee in the House of Lords has found on the subject and explanations and reactions from different other UK politicians, and adds background material.
 A second blog addresses the thorny issue how title swaps of plutonium from reprocessing will be influenced by Brexit. Again, Lowry extensively quotes from official answers Green MP Caroline Lucas received on Parliamentarian questions from the relevant responsible politicians.
This surfaces, amongst others, that special fissile material (e.g. plutonium left over from reprocessing in Sellafield) is collectively owned by Euratom, “but the operator with the legal title to the material has an ‘unlimited right of use and consumption’ over it, subject to their complying with the obligations imposed on them by the Treaty.” The Business and Industry department (BEIS) continues that Euratom’s overview will cease after Brexit, claiming that “These provisions will not have any practical impact on the day to day management and use of the material.”
Lowry then continues to analyse how this is fundamentally wrong and illustrates that with how Swedish plutonium from its closed R-1 reactor in Oskarshamn, now in the UK after reprocessing in Sellafield, is to be transferred into UK ownership, one of several of such transfers. This opens for me from this side of the Channel the concern that without Euratom overview, it becomes unclear what the long-term fate of this plutonium stockpile will be. Will it end up in MOX, will it have to be disposed of in a for now non-existing disposal in the UK, or may it be diverted to the UK’s military programme? The background documentation that Lowry gives only increases the picture of a lot of high-brow talk but little assurances.

Tuesday, 8 January 2019

Secrets of the Welsh Wylfa nuclear reactors

Letter submitted to the New York Times:
Re “For Wales, Nuclear Plant Would Mean New Jobs. For the U.K., It May Mean More,” (New York Times, foreign news, Jan. 8th;
As a Welshman who studied at S.U.N.Y. at Stony Brook at the time power utility L.I.L.C.O. abandoned the completed Shoreham nuclear power plant on Long Island, I was intrigued to read Stanley Reed’s account of the debate over plans to build a new nuclear plant in Wales.
Two matters arise that should interest readers.
Reed asks at the end of his article how pivotal the British Government believes the plant is to its climate change promises. In so doing, it would slip into the same mistaken belief  displayed by Senator John Barrasso - as chairman of the Environment and Public Works Committee and member of the Energy and Natural Resources Committee- in his op-ed “Cut Carbon Through Innovation, Not Regulation,” ( Dec. 18; in which  he inaccurately astonishingly stated “Nuclear energy is produced with zero carbon emissions.”
While it is true that most nuclear reactors do not emit CO2 at the point of generation, reactors are a small part of the nuclear fuel cycle, which emits large amounts of CO2.
These arise from the so-called front end of the fuel cycle - uranium mining, ore milling, uranium hexafluoride conversion, fuel enrichment and, finally, fabrication of the fuel rods. Moreover, nuclear waste management at the "back end" is already energy hungry in treatment, conditioning, transportation and final disposal in some future repository (if Congress ever give the green light).
Secondly, Reed’s article mentions the original reactor on the Wylfa site he discusses, which opened in 1971. This reactor called ‘Magnox” was generically similar to the reactors build in Britain to make plutonium for nuclear weapons ( just like the now closed reactors at the DoE reservation at Hanford, Wa.
Research undertaken by Professor emeritus Keith Barnham of London University’s Imperial College (supported by myself|)  has demonstrated that some plutonium from this generation of 'civilian' British Magnox plants was  exported to the U.S under an atomic barter agreement concluded with Britain after a series of hearing in the Congressional Joint Committee on Atomic Energy, which began in January 1958.
The agreement required the Atomic Energy Commission, which took title to the plutonium, to put it solely to military use.

Wednesday, 2 January 2019

Atomic chickens come home to roost, a second time!

This fascinating article on atomic chickens appeared in Popular Mechanics Magazine just before Christmas, written by a freelance author  based in San Francisco. It was picked up by The Sun a few days ago, the Daily Mail on line yesterday, and today in the Metro on line newspaper.
But nearly 15 years ago I scooped them all ( thanks to the UK National Archives) in the South Wales Evening Post. Read on and see how below....
Britain Built a Nuclear Land Mine and Almost Used Chickens To Detonate It

Blue Peacock may have been one of the strangest inventions of the Cold War.

By Kyle Mizokami
Popular Mechanics, Dec 21, 2018


The Cold War saw numerous oddball inventions of lethal intent, but leave it to the British to slap one with a silly name. And Blue Peacock's name wasn't the end of its peculiarities.

Blue Peacock was supposed to be a nuclear land mine. It was designed to blow up on a time lag, days after U.K. forces had given ground to invading Russian troops. British engineers even considered using chickens as a crude (but theoretically effective) detonator timer.

During the Cold War, days NATO forces including those of the British Army were heavily outnumbered by their Soviet-aligned Warsaw Pact adversaries. In the event of real war, NATO forces, particularly on the North German Plain, were expected to come under intense pressure and probably would have to fall back several times as they attempted to wear down the advancing Soviet Army and its allies.

The Western allies built nuclear rockets and artillery shells meant to repel invading communist forces, but there was another, often-overlooked weapons category in play: mines. This was a category British engineers at the Royal Armament Research and Development Establishment (RARDE) were ready to fill with an atomic land mine. In the YouTube video above, the channel Plainly Difficult describes the history of Blue Peacock.

Blue Peacock was designed to be buried on German soil along likely Soviet routes of advance. As the British were pushed back, the Soviet Army would advance, and probably would set up things like headquarters, supply depots, and other units directly above a buried Blue Peacock mine. Once the bomb went off, a ten-kiloton atomic explosion would made a significant dent in the Soviet invasion force.

Atomic Armageddon: Swansea was a top 20 target

by Dr David Lowry

South Wales Evening Post, April 2004


IF the catastrophe described below had ever taken place, there would be no Evening Post, indeed no Swansea, to Look Back upon….


At the start his month (April) a blood curdling exhibition opened at the National Archives (formerly The Public Records Office) at Kew in London. Called ‘Secret State,’ it unveils some of the most terrifying secrets of the Cold War.


As a son of Neath, one stunning revelation jumped to my attention from the exhibition boards displaying original Official Documents from the 1950s and 1960s: Swansea was listed as one of the 20 major cities in a Top Secret report ‘Probable Nuclear targets in the United Kingdom: Assumptions for Planning’- prepared by the Joint Intelligence Committee. (Annex A, File TNA: DEFE 4/224, dated 2nd November 1967). The JIC is a hitherto obscure body which came to public prominence during the Hutton Inquiry hearings last Summer


As a 47 year-old, born in October 1956, I have vague memories of the 1962 Cuban Missile crisis, involving the US and Soviet Union in a nuclear stand-off, when Moscow tried to secretly deploy nuclear-tipped missiles in Communist Cuba, just 90 miles south of the American mainland in Florida. It is the first time I remember being aware of nuclear weapons.


The documents displayed at the ‘Secret State’ exhibition brought the nuclear threat the planet faced in the 1950s/60s alive in a frightening fashion.

One document –the ‘Strath Report’- prepared in 1955, so secret it was not publicly released until last autumn, was the best estimate of the atomic boffins of what would have happened if Britain was attacked by the Soviet Union with just 10 Hydrogen (H-) bombs. Its conclusions, made available only to ministers in strictest confidence, detailed in graphic terms the disaster that would have befallen Britain.


Professor Peter Hennessy, the curator of ‘The Secret State’ exhibition - and author of a recent book of the same title - described the ‘Strath Report’ as the "most chilling document ever prepared for British Cabinet ministers." I agree, and would add: before or since.


The combined explosive power of these 10 H-bombs would, the ‘Strath Report’ stated, be the "equivalent of 100million tonnes of TNT explosive," going on to reveal "This would be 45 times as great as the total tonnage of bombs delivered by all the allies on Germany, Italy and occupied France throughout the whole of the last war."(ie World War II)


Twelve million people would be incinerated in the first few seconds with another four million seriously injured, even before the radiation clouds had made their poisonous way across the country.


The ‘Strath Report’ asserted "Hydrogen Bomb war would be total war in a sense not hitherto conceived. The entire nation would be in the front line…life and property would be obliterated by blast and fire on a vast scale."

Diagrams included in the exhibition demonstrate that within a 31/2 mile radius from the centre of the atomic detonation, there would be "total destruction"; within 5 miles, the city would suffer "irreparable damage"; and up to 13 miles from the so-called ground zero, the area would suffer "severe damage."

As a researcher who has studied many documents for my doctorate in nuclear decision making, one striking thing about the new exhibition is it reveals that the military advisors to the Government in the 1960s had an even more pessimistic assessment of the impact of the use of nuclear weapons than the opponents of ‘the Bomb.’

I have in my personal collection many pamphlets written by anti-nuclear activists with titles such as ‘Towards the nuclear holocaust,’ Missile Madness,’ ‘Beyond the Cold War,’ ‘The Defence of Britain,’ ‘The Invisible Event,’ and many more. None spells out the disaster we faced as clearly as the official version kept secret by successive Governments.

With over 50,000 H-bombs in the atomic arsenals of the nuclear superpowers, what is crystal clear is that had any of this obscene military power ever been used in anger, the so-called "civil defence" plans promoted by ministers would have been useless.

And yet in all this overwhelming and depressing material on destruction compiled by Professor Hennessy, there were some instances of black humour.

Scientists working on an atomic land mine - meant for deployment underground in Germany’s northern plains - realised that it could fail in winter if vital components become too cold, so they explored ways of keeping the inner workings warm. One proposal put forward consisted of filling the casing of the mine with live chickens, which would give off sufficient heat - prior to suffocating or starving to death - to keep the delicate explosive mechanism from freezing.

Despite the potential importance of chickens to the project, the mine was codenamed ‘Blue Peacock’. This story was mischievously revealed on 1st April – but it was true!

  ������������Ministry of Information poster (Hydrogen Bomb)

Document reference: INF 13/281/7


Dr David Lowry , winner of 2001 Nuclear Free Future special award ;and 1995 Freedom of Information Award.


He is currently an independent environmental policy and research consultant, based in London.

Tuesday, 1 January 2019

Mobile Chernobyl threat from nuclear waste transports

Letter sent to the Daily Mail newspaper:

In his article on burial of nuclear waste (“Towns and villages are offered up to £2.5million to become Britain's 'nuclear dustbin' and bury masses of radioactive waste near their homes,” Daily Mail, 1 January 2019; in what he describes as an atomic ‘dungeon’, your environment correspondent writes that  To provide an incentive to hosting the dumping ground, the selected area will be given between £1million and £2.5million a year for community projects, the Government said.”

Although this financial offer has been dismissed as a bribe by several campaigners in communities they fear may be chosen, it would provide a measure of community   compensation for the disruption caused by such a massive infrastructural development.

But what ministers have refused to do is to offer similar risk compensation “danger money” to  communities along transport routes from the current location of the radioactive waste, to the facility needed for conditioning and packaging, and then to the community or communities hosting a deep underground geological disposal facility (GDF).

Just before Christmas, the Government released a 40-page ‘Summary of Responses to the Consultation ‘Working with Communities’: implementing Geological Disposal’ |(

I was one of 118 respondees to this consultation last year, when in my opening paragraph I wrote say:


The Working With Communities consultation document asserts at para 2.4: ‘The work to take into account the views of stakeholders and the public has supported an open policy making approach throughout the development of the Working with Communities policy proposals..’”


While public engagement is a good practice, listening to the views expressed, and altering draft policy as a result is better practice. Experience suggests this rarely happens in radioactive waste consultations, and when it does, the changes are minimal.”


I added: “It is hoped this consultation will mark a significant change from this hitherto counter-productive policy of early alienation of interested parties.”(my emphasis)


But, sadly, the same old strategy of ignoring responses containing inconvenient ideas and proposals by the business and energy department (BEIS) has continued.


Paragraph 22 of BEIS’s response asserts “The Government does not agree that the Potential Host Community should extend beyond those directly affected by the impacts. We believe it is fair that only those that are directly impacted should have a say (my emphasis)


The only transport links/routes to be taken into account will be the predictably relatively short distance “from the GDF site to the nearest port, railhead or primary road network (i.e. out to where minor roads meet the nearest A roads).”

In the United States community campaigners concerned with risk of radioactive waste being transported by road or rail close to homes, hospitals and schools have dubbed these dangerous transports ‘mobile Chernobyl’, after the major accident at the Ukrainian nuclear reactor in 1986.

Ministers surely need to reconsider their definition of endangered communities.


Saturday, 29 December 2018

Why the British atomic archives should not remain closed

Letter sent to The Guardian:

I agree with academic researcher Sue Rabbitt Roff ('Hiding Britain’s H-bomb secrets' letter, 27 December; that researchers into the UK’s nuclear history should be alarmed that the publicly-funded Nuclear Decommissioning Authority has ordered certain sensitive documents to be withheld from the regular release of official s documents (Guardian, 24 December;'British nuclear archive files withdrawn without explanation'; that always takes place in the final week of the year from the National Archives ( Guardian reports, 28 December).

A decade ago I undertook special research at the NA into the commitments made by the three supporting nuclear-weapons states (UK,USA, and Soviet Union) during the negotiating record of the 1968 nuclear non-proliferation treaty (NPT).

A foreign office memorandum prepared in advance of the visit to London of the then Soviet premier, Alexei Kosygin, in February 1967, included the following final paragraph:

“We assume that the Soviet Union regard, as we do, the proposed review conference (for the NPT) as being an adequate assurance  to the non-nuclears that the military nuclear powers are serious about the need for action on nuclear disarmament.”

The NPT committed each of its signatories, inter alia, to “undertake to pursue negotiations in good faith on effective measures relating to cessation of the nuclear arms race at an early date and to nuclear disarmament.”

In the fifty years since, the Soviet Union/Russia has participated successively in the SALT, START and INF nuclear disarmament negotiations. Meantime, the UK has not taken part in any multilateral or bilateral nuclear reduction or disarmament talks.

Future researchers may wish to find out from the atomic Archives why not. Will they be able to do so?

Thursday, 27 December 2018

Inconvenient truths on nuclear waste ignored or buried by UK Government (again)

Just before Christmas (19 December 2018) the Business Energy and Industrial Strategy (BEIS) department published two important new documents dealing with the UK radioactive waste strategy. They received no mainstream media print coverage.

One document was a new 68-page consultation policy paper on ‘Implementing geological disposal – working with communities: long term management of higher activity radioactive waste’ described as “An updated framework for the long term management of higher activity radioactive waste.” (

The second was a 40-page ‘Summary of Responses to the Consultation ‘Working with Communities’: implementing Geological Disposal’

The summary states “There were 118 responses to the consultation from a range of organisations and members of the public.” This included a submission by myself, although my name is omitted from listed respondees.


In my opening paragraph of my submission I say:

The Working With Communities consultation document asserts at para 2.4:

The work to take into account the views of stakeholders and the public has supported an open policy making approach throughout the development of the Working with Communities policy proposals. We are continuing this approach by seeking views through this consultation from the general public and stakeholders on the policy proposals. Once the consultation has closed, and the responses have been considered, a Government response and final policy position will be published.”


While public engagement is a good practice, listening to the views expressed, and altering draft policy as a result is better practice. Experience suggests this rarely happens in radioactive waste consultations, and when it does, the changes are minimal.


It is hoped this consultation will mark a significant change from this hitherto counter-productive policy of early alienation of interested parties.”(my emphasis)


But, sadly, the same old BEIS strategy of ignoring responses containing inconvenient ideas and proposals has continued.


Paragraph 22 of BEIS’s response asserts “The Government does not agree that the Potential Host Community should extend beyond those directly affected by the impacts.”

 We believe it is fair that only those that are directly impacted should have a say in whether their community hosts a GDF. (emphasis added) The Government, therefore, intends to maintain the approach set out in the consultation document, which allows for a clear definition of the boundaries of the Potential Host Community. It will include all the electoral wards in which the following are located:

• proposed surface and underground elements of a GDF;

• any associated development (as defined under the Planning Act 2008 in England) and any land required to mitigate impacts;

• transport links/routes from the GDF site to the nearest port, railhead or primary road network (i.e. out to where minor roads meet the nearest A roads);

• direct physical impacts associated with underground investigations, construction and operation of the GDF (identified through environmental impact assessment work carried out to support RWM’s engagement with communities and its development consent applications).


This thus dismisses the main substance of my own consultation submission, but without any reason for rejection being presented.

I made the following arguments:


Q1.Do you agree with this approach of identifying communities? Do you have any other suggestions that we should consider?


In the consultation document, the energy minister responsible for nuclear waste policy, Richard Harrington writes: “We believe the best way to select a site for a geological disposal facility is in partnership with communities.”


He adds “Building and operating a geological disposal facility is a multi-billion pound, intergenerational, national infrastructure project, which is likely to bring substantial benefits to its host community, with skilled jobs for hundreds of people over many decade.”

This short quote embodies the problem with how BEIS has characterised what comprises community for the purposes of the consultation document “Working with  Communities (WWC).” For BEIS in this document a “community” is really a “directly affected host community” around the location of the above-ground receipt and transfer terminal for waste packages transported to the GDF. It is a great pity BEIS has decided to use such a narrow definition, because it excludes by fiat several much wider issues of public, political and safety concerns that will inevitably arise with development of a GDF.

In the WWC consultation summary, it describes the nature of community concerns as follows:

“There are many different ways in which people identify with areas, or define themselves against localities within those areas. Lessons learned from previous processes have underlined the importance of finding an approach that is clear, flexible, reflects the long-term nature of the siting process, and represents local government at all levels and other community groups appropriately.”

BEIS thus sees the relevant community as a “locality” relatively closed to and surrounding the GDF above ground workings.

But several years ago, BEIS actually established and sponsored a ‘Community Representation Working Group (CRWG) to explore the meaning of community, and the consequences of defing “community” in a particular way. The WWC consultation summary states:


“Efforts have been made to include input from a range of stakeholders and the public. A call for evidence, a literature review and public dialogue events in Manchester and Swindon have been undertaken to help develop the proposals”


The relevant footnote points out that the call for evidence can be found at:



BEIS needs to revisit this evidence  when determining the final scope for the definition of community in this decision making process. Below I have extracted some of the discussion from reports published by the CRWG, which demonstrates the differing implications for policy of adopting narrow or broader conceptualization of “community.”


One major issue underpins the reason why the wider definition is essential is any GDF will require the transport to the GDF receipt facility of the radioactive waste packages, even if the GDF were to be build close to Sellafield, where the preponderance of waste  ( both by volume and radioactivity) is currently stored. This is actually recognised - in a minor way- in the WWC consultation, when it concedes that there are wider ‘affected’ communities from such a 100 plus year development, at Paragraph 4.7, which makes clear that transport links/routes, from the geological disposal facility site to the nearest port, railhead or primary road network (i.e. as far as where minor roads meet the nearest ‘A’ roads used for transport on a regional or county level’ will be considered relevant.


At footnote number 26 to the document adds: “In selecting a site, the ‘delivery body’ would give consideration to existing transport infrastructure, suitable transport modes and routes, and appropriate mitigation measures to minimise any adverse impacts on a community.” 


But the potentially hundreds of miles of ‘affected communities’ along road and rail routes from radioactive waste stores, to any centralized repository, are essentially ignored. Why does BEIS believe people living in these communities with multiple hundreds of loads of radioactive materials coming past where they live for many decades do not deserve significant attention, not least because radioactive waste in transit is more immediately dangerous to  people close to transport routes than it is in an engineered GDF deep underground?


The Draft National Policy Statement recognizes at para 4.11.3 that there are security implications of developing a GDF, stating inter alia:


“Where national security implications have been identified, the applicant should consult with relevant security experts from the Centre for the Protection of National Infrastructure, the Office for Nuclear Regulation Civil Nuclear Security Programme and the Department for Business, Energy and Industrial Strategy (BEIS) to ensure that physical, procedural and personnel security measures have been adequately considered in the design process and that adequate consideration has been given to the management of security risks. If the Centre for the Protection of National Infrastructure, the Office for Nuclear Regulation Civil Nuclear Security Programme and the Department for Business, Energy and Industrial Strategy (BEIS) are satisfied that security issues have been adequately addressed in the project when the application is submitted to the Examining Authority, they will provide confirmation of this. The Examining Authority should not need to give any further consideration to the details of the security measures in its examination.(emphasis added) The Office for Nuclear Regulation Civil Nuclear Security Programme is responsible for approving security arrangements within the civil nuclear industry and enforcing compliance to prevent the theft or sabotage of nuclear or other radioactive materials, the sabotage of nuclear facilities, and to protect sensitive nuclear information; it does this in accordance with the Nuclear Industries Security Regulations 2003 and the Ionising Radiations Regulations 1999. The Secretary of State is entitled to rely on appropriate regulation of impacts in considering development consent applications.”



The Centre for the Protection of National Infrastructure was contacted in February, asking for further details of the work it has done on protecting the GDF and associated transport networks, but failed to even acknowledge the request, let alone answer it.


It is surely unacceptable that a potentially key Government body that will be involved in the future security of the GDF project can ignore enquiries for relevant information helpful to clarifying the important consultation questions.


On page 19 of the new consultation document is a very short two paragraph section on ‘Transportation’, which reads as follows:


2.28. The UK has more than 50 years’ experience of safely transporting radioactive waste and materials by road, rail and sea. Nuclear fuel is transported routinely from fuel fabrication plants to nuclear power stations, and spent nuclear fuel is transported from power stations to Sellafield for reprocessing and storage.


2.29. This transportation is subject to strict controls and is robustly and independently regulated in order to protect people, property and the environment. There have been no transport incidents resulting in any significant radiation dose to an individual in connection with the transportation of radioactive waste and materials between UK nuclear facilities15.


Reference 15 refers to the following document, a report already three years old. Office for Nuclear Regulation report: Events reported to the Nuclear Safety Regulator in the period of 1 April 2001 to 31 March 2015 (

In my own submission to the ‘Communities Consultation’ early in 2018, I raised the transport issue as follows:

One day before the consultation closed, BEIS delivered by e-mail an additional set of four answers to questions raised at consultation forums several weeks earlier. One Question asked was:


If the eventual site for a GDF is not near Sellafield, what are the plans for transporting all of this waste out of Sellafield?  Have (RWM) considered the costs and safety and security considerations for transporting most of the GDF inventory out of Sellafield to the GDF?

The answer given was:

“Higher activity radioactive waste is currently stored at over 30 sites in England and Wales. It will be transported to a GDF site over a long period of operation and therefore the rate of movement of radioactive waste will be low. The preferred modes of transport for radioactive waste would be rail or sea, though consideration of the mode of transport will be undertaken on a site specific basis. As the developer, RWM will have to consider the transport impacts (and consult on this and other impacts) as part the planning process. Radioactive waste has regularly been transported around the country for many decades.   

Waste arriving at a GDF site will be in highly engineered transport containers. Radioactive materials have been safely transported not only in the UK but worldwide for over 60 years. There is a lot of experience in this area. There are very strict safety requirements laid out in national and international law. A number of large-scale safety demonstrations have been conducted to demonstrate that transport packages can withstand severe accident conditions.”

This is both an inaccurate and misleading answer by omission and commission.

BEIS needs to do better and more credible background research, rather than make unsupported safety assertions. Its claim “radioactive materials have been safely transported not only in the UK but worldwide is highly misleading. BEIS should review the internationally available reports on nuclear materials transport accidents, such as

‘Transportation accidents/incidents involving radioactive materials (1971--1991)’

The Radioactive Materials Incident Report (RMIR) database contains information on transportation-related accidents and incidents involving radioactive materials that have occurred in the United States.  (USDoE, Office of Science and Technology, OSTI, International symposium on the packaging and transportation of radioactive materials: PATRAM '92, Yokohama (Japan), 13-18 Sep 1992; &

The international standards and arrangements are included in this 468 page IAEA document: ‘Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material- Specific Safety Guide (No. SSG-26).’ (


The regulator of nuclear materials transports, the Office for Nuclear Regulation, published report in which indicated over 1000 accidents/ events involving radioactive material in transit within, to or from the UK since 1958. The abstract states:


“This report includes descriptions of thirty eight accidents and incidents involving the transport of radioactive materials from, to, or within the United Kingdom, which occurred in 2011. The number of events reported in 2011 was higher than in 2010 (30 events), and near the top of the range of the number of events that have occurred in the last five year period: 30 events in 2010, 33 events in 2009, 39 events in 2008, 26 events in 2007 and 29 events in 2006. Of the 38 events included in this review 11 involved irradiated nuclear fuel flasks (there were also 8 such events in 2010). Only one of the events reported, involving the transport of a radiopharmaceutical source, resulted in any potentially significant radiation dose.

The details of these events have been entered into the RAdioactive Material Transport Event Database (RAMTED), which now contains information on 1018 events that are known to have occurred since 1958.”

(Radiological Consequences Resulting from Accidents and Incidents Involving the Transport of Radioactive Materials in the UK – 2011 Review;


Thus the very error I spent considerable time researching and providing demonstrable information to explain why it was factually inaccurate has been completely ignored as the error is repeated in the new consultation!

I also include the following material in my consultation submission:

Here is what the Nuclear Free Local Authorities policy Briefing 145 on Nuclear security concerns how secure is the UK civil nuclear sector? ( – published in May 2016 - said on the security hazards from nuclear transports:

Risks from an attack on a nuclear material transport

One of the key issues for UK nuclear regulators and policy makers is around security with the

transportation of radioactive materials and their protection from a malicious attack. Many transports

of radioactive materials involve mildly radioactive material such as pharmaceuticals, ores, low-level

radioactive waste, and consumer products containing radionuclides (e.g., watches, smoke

detectors). However, increasing quantities of much more radioactive - and thus hazardous -

nuclear materials such as irradiated (“spent”) nuclear fuel and fresh, un-irradiated nuclear fuel,

including some containing plutonium (in so-called MOX or a mixed oxide plutonium-uranium mix),

is beginning to be transported around the UK as the existing nuclear programme is wound down

and decommissioned; and a new build programme of over a dozen new reactors distributed

around the country is planned.

High-level nuclear waste materials, such as spent nuclear fuel, are transported in very heavy,

robust containers, which must meet extremely demanding standards to ensure their integrity in the

most severe conditions, including sabotage.


International assessments of risk to transportation casks -

After September 11, 2001, the US NRC issued to licensees special new orders to increase security

in the transportation of specific types of radioactive materials, including spent fuel shipments. (24)

The September 11, 2001 terrorist attacks on the US caused the German government to reassess the

security of its nuclear power plants and spent fuel storage facilities. The German Nuclear Safety

Commission issued a statement recommending that an analysis be carried out on each plant to

assess its vulnerability to September 11-type attacks. Plant operators assert that terrorist attacks are

a general risk of society and should be treated like attacks on other infrastructure (e.g., chemical

facilities). Moreover, general analysis of the impact of the different civilian aircraft on commercial

nuclear plants was requested by the German Environment Ministry and has been carried out by a

nuclear industry consortium. (25)

A series of tests simulating terrorist attacks on transportation casks were undertaken in Germany,

France, the United States (for the German Government), and Switzerland (for the Swiss

Government). Additional tests may have been done that are not publicly acknowledged. As long ago

as 1979–1980, at the German Army facility in Meppen, a hollow charge (i.e. “ shaped charge”)

weapon was fired at a ductile cast iron plate and fuel assembly dummy to simulate a CASTOR cask.

The cask plate was perforated but release fractions from the fuel assembly were not examined.

From this experiment, the German government concluded that the wall thickness of the cask should

not be less than 300 millimetres. (26) (27)

Other tests were carried out at the Centre d’Etude de Gramat in France in 1992 on behalf of the

BMU involving shaped charges directed at a CASTOR cask filled with nine fuel element dummies

with depleted uranium. The shaped charge perforated the cask and penetrated fuel elements. This

damaged the fuel and resulted in the release of fuel particles from the cask.

UK issues around the transportation of radioactive materials -

Looking more closely at these issues for the UK, regulations covering the safety and security of

transport of nuclear materials are based on the recommendations of the IAEA. (28)

The UK nuclear regulator, ONR states of its responsibilities and mission: ―ONR Transport carries out

a range of regulatory activities to assure the safe transport of radioactive materials. Approval is

granted for the designs of packages used to carry high-hazard radioactive materials to ensure they

meet exacting international safety standards, and the packages are built to robust quality assurance

plans, and are correctly used and maintained. Regulation is also carried out through a programme of

targeted, risk-informed inspections and engagement with duty holders which may lead to

interventions. Inspections examine the management systems utilised by duty holders, as well as

compliance with safety and security legal requirements. ONR Transport inspects duty holders across

nuclear; non-nuclear; and industrial, medical and carrier sectors. (29)

But groups like CND, CORE and the local pressure group Highland Against Nuclear Transport have

been critical about the robustness of the ONR oversight of such transports in practice. (30) NFLA

have also consistently been raising concerns over the safety of nuclear material transports for a

number of years, whether they be of radioactive waste material transports or nuclear weapon

convoys (which is being considered in a parallel briefing on the defence nuclear sector).

Of particular recent concern has been the transport of highly radioactive materials from Dounreay to

Sellafield. These exotic‘ fuels have been to date sent on rail transports, but the Nuclear

Decommissioning Authority (NDA) has also commenced sea transports. NFLA‘s concern relates to

the occurrence of a malicious incident or an accident taking place on a remoter part of the rail

network or close to one of Scotland‘s large towns or cities…

The [then] UK Energy Minister Andrea Leadsom also informed Parliament in April 2016 of a relevant new

report by the Office of Nuclear Regulation (ONR) Details of safety events involving the transport of

nuclear material both by rail and on the strategic road network.

This report noted that there have been 3866 noteworthy events‘ relating to health and safety and

security recorded either at civil sites or with the transport of nuclear materials between the 1st April

2001 and 31st March 2015 (a list which also includes conventional health and safety events). Of

these, 3141 were rated on the INES scale as being of ‘no nuclear safety significance‘ (INES level 0

or not rated), and 716 were rated at INES level 1 (anomaly), being the lowest level of nuclear safety

significance on the INES scale. There were eight events rated at INES Level 2 (incident), and a

single event rated at INES level 3 (serious incident), which was in 2005. No events occurred that

merited a higher INES rating during this period, and none were designated as ‗accidents‘. (33)

NFLA welcomes the publication of this report as a serious attempt to develop a culture of openness

and transparency between the nuclear regulator and nuclear policy groups on such matters. It also

welcomes the steady reduction of incidents in recent years. NFLA still remains to be convinced that

the large and increasing amount of nuclear transports taking place in the UK is best practice for the

future, despite a good safety record. NFLA would rather see transportation of nuclear materials

limited as much as is practical, with safe on-site storage facilities developed instead.

This comment of Dr John Large lay at the heart of NFLA‘s concerns:

“Movement of nuclear materials is inherently risky both in terms of severe accident and terrorist

attack. Not all accident scenarios and accident severities can be foreseen; it is only possible to

maintain a limited security cordon around the flask and its consignment; the transportation route will

invariably pass through or nearby centres of population; terrorists are able to seek out and exploit

vulnerabilities in the transport arrangements and localities on the route; and emergency planning is

difficult to maintain over the entire route” (34)

25) Federal Ministry for the Environment, Nature Conservation and Nuclear Safety Summary of GRS study -

Protection of German nuclear power plants against the background of the terrorist attacks in the USA on 11

September 2001, English version:

(26) F. Large, G.Pretzsch, J.Döhler, E.Hörmann, H.Busch, and W.Koch. 1994. ‗Experimental Determination of UO2-

Release from a Spent Fuel Transport Cask after Shaped Charge Attack‘. 35th INMM Annual Meeting

Proceedings (Naples, Florida). Vol. 23, pp. 408–413.

(27) RSK (Reaktorsicherheitskommission). 2001. Safety-Related Guidelines for the Dry Interim Storage of Spent

Fuel Elements in Storage Casks. Recommendation of the Commission on Reactor Safety. April 5. Available at

(28) Regulations for the Safe Transport of Radioactive Material 2012 Edition; IAEA, Vienna, http://wwwpub.

(29) Office for Nuclear Regulation

 (33) Office for Nuclear Regulation, April 2, 2016

(34) John Large, Briefing on the safety of transports of radioactive material transports for Greenpeace UK, 2006


The case for considering the implications of a GDF in respect of the impact on  the interests of affected en-route  communities  along the transport routes is thus  unchallengeable, and the revised tests must address this in detail.

Finally, in my submission to the Communities consultation, I forcefully made the following point about why so-called Learned Societies such as the Royal Society cannot  nor should not be trusted to provide accurate, impartial evidence to  potentially affected communities

I wrote:


“The WWC consultation identifies at para.4.31, Table 2, the important role to be played by ‘Independent facilitators” in managing the local discussions of interested stakeholders with the formative engagement team as a “Community Stakeholder Forum” – to  be engaged in ‘outreach’ activities to the wider communities- is established, stating:


“Independent facilitators can help ensure that discussions progress in a constructive and informative manner. The facilitators can assist in designing and delivering engagement with communities; asking relevant questions and directing conversation to cover the points of interest from the interested parties and other members of the community.”


What will be crucial to the legitimacy of the process is the genuine independence of the facilitation team. The Government needs to study very carefully how the West Cumbrian MWRS Partnership worked well; and learn from the instances where it did not deliver successfully.


The WWC consultation states at para. 4.53


“To support the operation of the Community Partnership, a Community Stakeholder Forum could be set up to provide outreach to the people in the community more widely. In addition, working groups could be set up to address specific issues, for example on technical issues or communication and engagement issues..”


But unfortunately, any further detailed description or framework for the establishing of any CSF is missing from the consultation document. It is unclear whether this is because BEIS has not yet devoted sufficient thought to how this should  happen, or  lacks sufficient interest to do so.


The UK Government says it will ensure that communities will be able to access third party expert views on contested and unresolved technical and/or scientific issues once communities are constructively engaged. There will be an agreed process whereby third party expert views can be accessed from Learned Societies, as was committed to in the 2014 White Paper. The delivery body will produce guidance to help communities understand when and how they can access the process for third party expert views.”


The BEIS memorandum of 10 April 2018 states, in respect of information availability to interested parties in the volunteer host community, that:


The intention of the working with communities proposals is for the delivery body (RWM) to be held to account, tasked with providing communities with all the information they require and with listening and responding to views and concerns in an open and responsive way.” ( emphasis added)


Neither the availability of Third Party expert views from so called ‘Learned Societies’ nor from the implementer, RWML, is acceptable, as they do not cover the range of  relevant expertise from which  analysis and assessment may be drawn.


Clearly the developer/implementer RWML, has a central stake in delivering the GDF project, so its information is almost certainly going to be selected to support the successful outcome of the project. RWML is very unlikely to provide the  interested parties in the  Directly Affected Host Community or  less still affected communities, with

“all the information they require.”


It is known from experience that when DECC decided to  produce its own supportive information for a national public consultation on the National  Policy Statement for Nuclear Power, it was forced to re-hold the consultation after a High Court  Judgment  supporting  a judicial review appeal from Greenpeace,  based on the Ngo’s claim that information provided by DECC was biased in favour of the Government policy This would be an extant concern in the case of  RWML  providing  information for the GDF project.


The issue of the independence of  the Learned Societies is more complex, and  perhaps more contestable. In general, British Learned Societies have a globally respected reputation for high quality of  research competence, scholarship and excellence.


Unfortunately, this reputation is underserved when it comes to work they have undertaken and published on nuclear power, including  nuclear waste. In this atomic arena, the reports have tended to be much too uncritically supportive eof  nuclear projects, drawing their  references form a far too  narrow  base, and  resulting in conclusions which are more cheerleading than objective. The Royal Society, the pre-eminent Learned Society, has been especially bad in publishing poorly edited and uncritically peer-reviewed papers on nuclear issues.

Two examples of this poor scholarship are:


Fuel cycle stewardship in a nuclear renaissance

The Royal Society Science Policy Centre report 10/11

October 2011 DES2159


A note by the Royal Society revealed in respect of this report: ‘The Royal Society is very grateful to the UK’s Strategic Programme Fund for its financial support and the Foreign and Commonwealth Office for its assistance’




Strategy options for the UK’s separated plutonium

September 2007

Policy document 24/07


Appendix 5 on page 29 of this report comprises map of nuclear facilities in the UK, but totally omits the UKAEA Dounreay fast breeder nuclear plants in Caithness, demonstrating shoddy scholarship and equally shoddy editing.


BEIS should re-examine the proposal that Learned Societies (LSs) should be the primary information source in the Third Party Mechanism. Citizens concerned over different aspects a of the GDF proposals should have the right to obtain funds to engage genuinely independent expertise- whether based in the UK or abroad- to examine aspects that concern them.


But ministers clearly know better. Despite my setting out why such Learned Societies cannot be trusted, they have nevertheless decided to rely upon them exclusively to provide information support to affected communities. In a third document, also released on 19 December, entitled MEMORANDUM OF UNDERSTANDING (MoU)

regarding the geological disposal facility Third Party Expert View Mechanism

BETWEEN THE DEPARTMENT FOR BUSINESS, ENERGY & INDUSTRIAL STRATEGY &  WELSH GOVERNMENT  &  RADIOACTIVE WASTE MANAGEMENT LIMITED  &  THE LEARNED SOCIETIES The Geological Society of London, The Institute of Environmental Management and Assessment, The Learned Society of Wales, (

BEIS  sets out how this information arbitration will work.


One paragraph reads:

“The purpose of this MoU is to establish a framework for the cooperation between BEIS, Welsh Government, RWM and the LSs to provide a Third Party Expert View Mechanism in circumstances where there exist contested and unresolved technical and/or scientific issues that have arisen during the GDF siting process, and one of the parties feels that a further view from a relevant LS member could be helpful. The mechanism will be available from the beginning of what is referred to as the ‘community engagement’ of a community in the GDF siting process and continue throughout the subsequent discussions with communities during the GDF siting process.”


The way BEIS has dismissed critical, inconvenient evidence, makes me wonder over the utility of spending  time researching and preparing a reponse to the new  public consultation, when the ministerial track-record is to dismiss and/or ignore  factual information that contradicts  Governmental ideological bias or pure pro-nuclear prejudice.