LLRC sees a need for greens who are involved in dialogues with the nuclear industry and its regulators (as well as those who have withdrawn from dialogues) to coordinate efforts better than they are at the moment.
We kicked off a debate by circulating an email. The responses have included the idea that there ought to be a centralised electronic noticeboard where a discussion can go on. LLRC hasn't time to organise this, but for the time being we are pasting the correspondence here. If anyone wants to pick up the chat room or noticeboard idea, please get in touch. In the meantime you can contribute to the correspondence on this page by emailing greensaprising@llrc.org

Here are the messages so far, earliest at the top. Some have been anonymised since their authors didn't know they were for posting on an open site but in future all messages will be attributed.

----- Original Message -----
From: Richard Bramhall
To: val mainwood
Sent: Saturday, March 29, 2003 12:13 PM
Subject: magox SAPs our strength

Dear Val,
(copied to LLRC's mailing list; please feel free to forward)
This is partly to give you my email address, partly to tell you where I stand on the Magnox thing.
As I said at the Stakeholder meeting in London last Monday I am very concerned that the greens are being salami sliced. DAD (Decide Announce Defend) may be dead, but his brother the wicked UNCLE (Unlimited Nuclear Consultations Leading to Exhaustion), is alive and well. If you follow the Hamlet analogy through, maybe the greenies are playing the role of queen Gertrude.
My point is that dealing with the whole postnuclear shitpile is essentially a single issue, and that we are being tricked into treating it as many. I listed some consultations that are going on - land, very low level waste and minimally contaminated materials, MAGNOX, aspects of BNFL's national dialogue, DTI's NDA roadshow, exemption orders quietly being revised at DEFRA (a far bigger issue than is readily apparent) and no doubt others that I have forgotten for the time being or have not yet heard about - an invitation to get on board a new European process on radiological protection of the environment arrived here this very morning. Son of RaWMAC is stirring in the womb and meanwhile LLRC's time is taken up with the Committee Examining Radiation Risk of Internal Emitters and the MoD's DU Oversight Board (deliberative committees rather than dialogues, but a resource drain nonetheless).
There is to my knowledge no common NGO approach to the nuclear backend issue and in its absence we are being sucked in to a number of processes, divided, ruled as to agendas and generally worn out. This is entirely in the industry's interests.
My own attitude to dialogues is equivocal. I partly go along with Pete Wilkinson's idea that by participating we do gradually change attitudes (there's good evidence for this); I also sympathise with the abstainers.
As far as the Magnox dialogue itself is concerned, I cannot afford the time to take part in something which has such a narrow remit. I would have preferred a multifacetted approach like the BNFL national dialogue. The amount of green involvement in Magnox is reassuring but the other side of the coin is that on other parts of the issue - e.g. land and VLLWaste - the greens are far too few; often it's just me. So I am left thinking: "will the Magnox thing endorse solutions that have implications for contaminated land, low level wastes and recyclable/reusable materials? What standards will be built in to any such solutions and do the participants know how the ground is shifting? " We really need to work together on this, ideally in a forum that would create a number of checkpoints where reports were shared across the whole dialogue before being signed off.
It is unfortunate that the co-ordination of greens which FoE Greenpeace and NFLA supported last year had the plug pulled before we ever got to grips with anything much. Perhaps we should revive the approach Hugh Richards co-ordinated so effectively in the mid 1990s.
Richard Bramhall
Low Level Radiation Campaign
bramhall@llrc.org

Val Mainwood replies:

Dear Richard,
Thank you for your long and considered email. I would be grateful if this email too, could be posted to your respondents.
Much of what you say I agree with - which was why I was glad to hear your views at the Dialogue Main Group Meeting, and in your email. This sort of input is just what we need, so that all areas can be considered. As you say, there are plenty of greens willing to give it a go. But we need people like yourself, not to do piles of work, but to observe from the outside, making suggestions that we may not have considered, just as you are doing in this correspondence.
Strategic Action Planning, as proposed for the way forward in the Magnox Decommissioning Dialogue, is above all an exploration of the issues. There is no single answer, but a summation of areas of agreement and disagreement, which can be laid before a decision-making body. Along the way there are actions, some of which can be taken immediately, for example your excellent suggestion about co-ordination of effort in the different consultations which are currently proceeding. The spirit of SAP should mean that whatever the remit of the individual SAP, other issues must be dealt with in the requisite manner. So I will bring up both issues you have raised, that of consultation, and of the problem of very low level waste, at the next Steering Group meeting, on 22 April. A mechanism must be found for dealing with these problems.
Your analogy with Hamlet made me smile. I remember a disastrous production which I was involved with at University, where Polonius refused to die, and walked out unconcernedly from behind the curtain! I regret to say that we Greens tend to be felled by fratricide rather than homicide! Our great disadvantage last time round in the dialogue was the inability to work as a team. The SAP structure will make this easier. Even so, we will all need to spend some effort on doing this, ensuring that everyone outside the group knows what we are doing and feels free to input constructively. Perhaps someone out there has an idea of how we can all communicate better, despite our geographical distances? A centralised electronic noticeboard, perhaps, where we could paste things?
In anticipation of some good ideas!
Val

???? replies to LLRC's email of 29th March:

Dear Richard
I agree with everything you say. I've been to one of the consultation sessions with DTI in Bristol and left with the strong feeling that it was really all just window dressing. On paper we've been consulted but our requests for eg new restrictions on nuclear site particle emissions might be noted, but we get nothing in return, not even a yes we'll impose those restrictions on any contractors, or a no, we're going to ignore you. We've agreed [in our Community Based Organisation] that [we] will go to the follow up in May/June but I think it's time for some written guarantees to be demanded in return for our participation. I think that if Bechtel get the UK contract to clean up all our sites, there is nothing to stop their building AP1000s "to burn up our waste plutonium", or to control emissions to any requirements other than those in their contract over which it seems no one will have any control except the DIT/LMA or whatever their new name is.
Regards
[name withheld]

???? replies to LLRC's email of 29th March:

Love the wicked UNCLE! Seriously, this is something that I have been concerned about - as one of the promulgators of consultation and dialogue (which I guess most of us agree is a good thing in principle), it has become very clear to me just how much of a burden participation places on the greens. This is one reason why I always try and get funding for 'participants who are otherwise unfunded', which at least provides some help, if not enough. If you think better co-ordination between greens could both build a stronger base, and be more efficient re resource sharing, then [ ... ] there may be funding sources (EU?) [which could be applied for].
The practices of consultation/dialogue (as distinct from the principles) have led me to be seriously considering the constraints, drawbacks, compromises that exist in the real world of trying to put the principles in practice, and whether these constraints etc so seriously undermine the principles that I/(we?) should at the least start to provide a serious critique, and attempt to challenge these constraints.
Incidentally, to add to your list of consultation activities, there's AWE Pascalea, UKAEA Dounreay activity (no, no one has heard about these - poorly publicised consultation is a contradiction in terms!), and the next stage of ISOLUS (nuke sub waste). And others.
Regards
[name withheld]

Douglas Holdstock replies:

Dear Richard,
Your email re Magnox was forwarded.
I agree that LLR is in a sense a single issue, and the key point (accepted also by the ICRP) is that there is no safe dose of radiation. I fear though that it is still necessary to deal separately with individual manifestations, as each have their separate issues. For example, the largest contributor to non-background radiation is medical; however, most of the exposure is to the more elderly, and it is impossible to imagine carrying out modern medicine without diagnostic and therapeutic X-rays.
It is also important that comments on individual sources are scientifically soundly based; over-the-top assertions discredit the whole attempt to minimise exposure (as you know, I am sceptical about many of the statements on DU for this reason). It is not possible to be expert on all aspects of LLR, and the LLRC must try to find someone for each; certainly you cannot do it all yourself.
You may not find this welcome, but nevertheless hope you will find it helpful on reflection. We in Medact certainly have great admiration for your efforts.
Best wishes,
Douglas Holdstock

Richard Bramhall (LLRC) replies to Dr Holdstock:

Dear Douglas,
I think it may be helpful to agree on some terminology here. In my original email (see above) I defined the nuclear backend as "essentially one issue". I stand by that. The issue has different aspects like Magnox, contaminated land, Very Low Level Waste, recycling and so on. Some of these aspects will be so closely related - e.g. Magnox decommissioning and the reusable materials it generates - that logically they cannot be separated. It is important that green stakeholders know what is going on across the field so that we can all insist on a coherent logical approach. The very idea that we in LLRC might do all this stuff ourselves gives us the screaming habdabs - that's why we are seeking better co-ordination.

You invoke the example of medical x-rays. I am not quite sure why you choose this one - it's not simple. First, x-rays are external exposures and the external paradigm is, we contend, reasonably well understood. Risk estimates are being refined (upwards) in light of new research but revisions tend to stay in the same ball park. On the other hand (or other planet) the controversy over the internal risk paradigm is far more radical (see, for example, the recently published recommendations of the European Committee on Radiation Risk - www.euradcom.org).
Second, the justification of medical exposures, including x- rays, involves a cost/benefit analysis which takes into account the fact that while patients run a risk they stand to gain from improved diagnosis or treatment. However, medical practices involve another exposure route which cannot be justified:- hospitals and medical isotope factories like Nycomed Amersham dump large amounts of radioactive material into drains and into incinerators (even the sewage sludge may end up in incinerators). This means that the general public are inhaling and ingesting radionuclides which confer a risk of cancer or other genetic defect but with no benefit to offset or compensate for the risk. This doleful fact puts some aspects of medical practice into the same arena as Magnox decommissioning, Trident maintenance, fuel reprocessing etc. etc. etc. etc. So in the context of this debate (i.e. about co-ordination) we see medical practice as another reason for greens to put their heads together really seriously.
I'm not sure what your remarks about Depleted Uranium mean. Are you saying LLRC has got it wrong? If so, why, please?

Finally, I'd like to go back to my original email. I referred to CoRWM (the new Committee on Radioactive Waste Mangement) as Son of RaWMAC ... stirring in the womb but I can now expand on that 'cos I've been reading the bumf. It's clear that stakeholder dialogue will be a big feature of CoRWM from the very beginning, e.g. even in step one - deciding what kinds of material will be counted as waste. It's as if the wicked UNCLE (Unlimited Nuclear Consultations Leading to Exhaustion) just cloned himself. Gird your loins, oh Greenies, there's a load more work to do.

Pete Wilkinson replies to Bramhall's email of 29th March:

Richard,
I've thought hard and long about your email. The first thing I should say is that I don't believe there's a conspiracy to divide NGO resources between many different dialogues. Perhaps the effect is the same, but in my experience, government is not sufficiently sophisticated to be able to organise a conspiracy.
I do believe, however, that there needs to be some overhaul of the conditions which attend the radwaste debate and this needs to happen on both sides of the divide. Ideally, the greens would work co-operatively on an agreed policy with agreed objectives covering strategic and tactical aspects and the government departments involved, along with the industry, would rationalise their stakeholder/NGO/public interface aspirations as much as they can be rationalised in order to arrive at a coherent programme with identified outcomes on a common timetable.
Taking the first issue (I see in later correspondence you have characterised this as 'can the greens work together?') I think there's too much fragmentation of approach for there to be anything more than minimal and surface co-operation. There's too much rigidity in position from some key organisations and individuals. Which is a great shame, in my view. As I've said before, I believe positive and collaborative engagement in discussions about waste managment in particular are not only vitally important but offer an important opportunity to improve the environment and get green thinking into other important aspects of the nuclear debate. In that respect, I'm glad to see so much involvement at the regional forums held by the DTI. But as I suggest above, there needs to be greater governmental and industry linkage between all the issues which are in the public domain at the moment.
I think the most important of these are:

• Defra MRWS process
• DTI managing the nuclear legacy/NDA process/hand-over of assets and liabilities
• Magnox decommissioning dialogue
• BNFL national nuclear dialogue - business futures and interaction with NDA, utilities, non-nuke futures
• BNFL initiatives - site remediation programme, interim surface stores, waste conversion index etc

There are other issues such as the role of Nirex, green inputs to regulators etc but these could be seen as less demanding of peoples' time.
I think these main issues should be rationalised into an overall programme with clear sequential linkages and impacts or parallel programmes with lateral linkages over a clear timetable which would itself be a subject of stakeholder agreement. If we could bring a coherent and collaborative green input to this agenda - suitably unified on its LLR position - I think we would stand to gain a lot of ground. Of course, I appreciate that there is a need to keep up a public profile under the 'business as usual' banner and dialogue or engagement does not compromise this requirement. But engagement does require flexibility of position and an acknowledgement that we have to see the world through the eyes of other stakeholders. On the basis that many critical issues are to be decided in the next few years, I believe non-co-operative greens will gradually be sidelined by the process and will become marginalised and increasingly isolated from a national debate which is genuinely seeking solutions.
Take care and hope to see you soon.
Regards,
Pete
Wilkinson Environmental Consulting Ltd
e: wilx@btinternet.com