TL: TRANSPORT BY SEA OF IRRADIATED NUCLEAR FUEL, PLUTONIUM AND
     HIGH-LEVEL RADIOACTIVE WASTES
SO: Greenpeace International (GP)
DT: April 1992
Keywords: Nuclear power waste plutonium transportation japan
europe ships safety risks gp /
 
Action by the Maritime Safety Committee
Proposed by Greenpeace International
 
Prepared for the 60th Session of the Maritime Safety Committee
(MSC) of the International Maritime Organisation (IMO)
6-10 April 1992
London, UK
 
Greenpeace International 
 
INTRODUCTION
 
During its 60th Session, the MSC will consider the issue of the
maritime transport of Irradiated Nuclear Fuel (INF) under Agenda
item 9: Report of the forty-third session of the Sub-Committee on
the Carriage of Dangerous Goods.
 
INF is highly radioactive and therefore poses an extreme
threat to port and ship workers, to the general public, and to
the environment. Nonetheless, these singularly hazardous
cargoes are currently carried on standard cargo vessels, roll
on/roll off passenger ferries, and so called purpose-built
vessels which carry material containing many times the
radioactivity released at Chernobyl.
 
Currently, INF transports by sea are taking place in European
waters, the Atlantic, the Caribbean, the Panama Canal, and the
Pacific. They have also taken place, and might again in the
future, along the West and South African coast and the Indian
Ocean.
 
These shipments are conducted on vessels without due concern for
damage stability, fire protection, structural concerns, cargo
control and security, and radiological protection and monitoring. 

IAEA INADEQUATE POLICY
 
This unacceptable state of affairs rests on the current system by
which nuclear transports are regulated. The International Atomic
Energy Agency (IAEA) has promulgated testing criteria for
prototypes of the casks which are used for the carriage of INF.
The IAEA states that these tests guarantee such a high state of
protection to and from the nuclear materials that safety is
assured regardless of the transport mode used. The IAEA has in
fact pressed the IMO stating that CDG and MSC deliberations are
unnecessary due to the IAEA's own
regulations, and that actions by IMO could have the effect of
limiting the activities of the nuclear industry.
 
Unfortunately, IAEA test criteria are inadequate to guarantee the
integrity of INF casks under the extreme circumstances of ship
accidents in port and at sea.
 
 
INADEQUACY OF IAEA THERMAL TESTS
 
The IAEA thermal test requires that only cask prototypes and
selected cask specimens be tested to withstand a fire of 30
minute duration at temperatures up to 800 degrees Centigrade. Yet
in its own submission to the MSC, the IAEA itself states that
fire statistics show that maritime fires burn, on
average, in excess of 20 hours. In addition, 1000 degrees
Centigrade is considered a standard temperature measurement for
shipboard fires involving hydrocarbons fuels.
 
The IAEA has defended itself against the obvious inadequacy of
its thermal test by stating that maritime fire ". . . data
contains information on vessels such as oil tankers and bulk
cargoes such as cotton which is not pertinent to a cargo ship
carrying spent nuclear fuel". This statement suggests an
inexplicable rejection of the "worst case" or "maximum
credible accident" scenarios which are applied by regulatory and
environmental protection agencies worldwide. Ships do not
themselves need to carry tanker loads of petroleum, chemicals, or
cotton to become involved in solitary accidents or
collisions which could lead to long duration, high intensity
fires. In addition, as a result of the IAEA's position that the
transport of INF can occur on any vessel, the transport of INF
has been conducted on cargo vessels carrying mixed
hazardous goods, fuel, and petro-chemicals. It is the case with
the roll on/roll off cargo/passenger ferry "Nord-Pas-de-Calais",
which in 1990 was scheduled to cross the English Channel 37 times
with INF casks on board, and is expected to undertake in 1992
over 40 voyages with such radioactive
cargoes. 
 
Even vessels exclusively used for the carriage of INF, like the
five Pacific Nuclear Transport ships which may be required to
carry enough fuel for trips of some 17,000 nautical miles, can
carry enough fuel oil to support fire loads beyond the IAEA test
criteria.
 
INADEQUACY OF IAEA DROP TESTS
 
Other IAEA test criteria are similarly inadequate. The IAEA drop
test only requires casks to be dropped from nine metres onto a
flat unyielding surface or from one metre onto a steel bar of 15
centimetre diameter. While these test heights are not adequate to
even guarantee the integrity of casks which might drop while
suspended over docks or vessels, the impact damage from ship
collisions could provide extreme
circumstances beyond test criteria. For example, in a report
commissioned by Greenpeace to Eco Engineering Inc. from
Annapolis, Maryland (USA), it is estimated that "the kinetic
energy associated with a vessel whose displacement is 5,000 long
tons and travelling at 15 knots is approximately 250 million
foot-pounds which roughly equates to dropping a cask weighing 2.5
long tons a vertical distance of 2000 feet" (610 metres). Impact
of ship collisions are in fact sometimes so severe as slice the
struck vessel in half. 
 
 
INADEQUACY OF IAEA IMMERSION TESTS
 
Similar shortcomings are to be found with the IAEA's immersion
tests. While IAEA tests submerge casks to depths of 15 metres for
up to eight hours these figures bear little bearing on the depths
and periods of cargo submersion following accidents. For example,
INF transports currently cross open sea areas covering depths of
hundreds and even thousands of metres. In addition, absent of
serious evidence from the transport
companies involved, it is difficult to believe that salvage
operations could be conducted on casks at depth in a matter of
hours let alone days. 
 
 
ADDITIONAL RISKS FROM THE SEA TRANSPORT OF PLUTONIUM AND HIGH-
LEVEL WASTES
 
While approached with data suggesting these obvious
discrepancies between their tests and the reality of maritime
transport accidents, the IAEA has chosen to condone plans for the
massive increase of transport involving not only INF but also
plutonium and high level nuclear waste. As early as July or
August 1992, one-tonne plutonium shipments will begin to be
transported from Europe to Japan. Within the decade, as much as
45 tonnes of plutonium could be transported from and to these
locations. Crossing over 17,000 nautical miles, these shipments
represent an unprecedented threat to human health and the
environment. Within the next two to three years,
shipments of high level nuclear waste many times more
radioactive than INF will also make these voyages. In fact, if
current IAEA procedures continue, transports of both plutonium
and high level waste would take place from the UK to Europe on
standard Cross-Channel ferries. 
 
 
RECOMMENDATIONS
 
The IMO is currently considering the addition of new safety
criteria beyond those presented by the IAEA. Greenpeace would
like to strongly support this intention. We believe that the
current state of affairs calls for more severe measures. 
 
The IMO should require the IAEA to conduct new tests on its casks
to demonstrate that they can withstand the effects of worst-case
maritime accidents.
 
Until such time as the IAEA conducts such tests, and submits the
data to the IMO for consideration, Greenpeace urges the IMO to
ask all its member-States not to undertake any further transports
of INF, plutonium or high level nuclear waste by sea, as current
standards do not provide for adequate safety.
 =end=