Canadian Coalition
for Nuclear

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la surveillance
du nucléaire


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TO: The Federal Environmental Assessment Panel

RE: The Concept of Geologic Burial
       of High Level Radioactive Waste
       from CANDU Nuclear Reactors
       advanced by Atomic Energy of Canada Limited.

The AECL concept of burying high level radioactive waste produced by the nuclear industry in the rock of the Canadian Shield is not acceptable for the following reasons:

  1. Both the Government of Canada and the nuclear industry have made it very clear that they intend to keep producing nuclear waste indefinitely into the future if the burial concept is approved. Thus, the burial concept is intended not to eliminate the problem, but to provide a justification for perpetuating the problem. Since the most intensely radioactive waste -- that portion which is less than ten years out of the reactor -- is too hot to be buried, it will always be present on the surface of the earth as long as reactors continue to operate. Thus, unless the nuclear plants are shut down, no amount of burial will significantly reduce the risk at the surface. This is an unacceptable aspect of the concept itself.

  2. The Government of Canada and the nuclear industry have shown themselves to be contemptuous of democratic process, by preventing the citizens of Canada from having any official opportunity to debate the merits of nuclear power as an energy option, and by preventing this panel from considering the policy option of stopping the production of high level radioactive waste altogether. This is bad politics, and it is also bad science. Any concept of waste management that requires the muzzling of legitimate dissent is unacceptable.

  3. The inhabitants of the Canadian Shield are, for the most part, aboriginal peoples and small, sometimes isolated communities. With few exceptions, these people had no say in the production of high level radioactive wastes, and received little or none of the electrical energy that accompanied the production of these wastes. Moreover, they have neither the resources nor the expertise to assess the nature of the wastes which will be visited upon them by the government and the nuclear industry. It is unacceptable and fundamentally unjust to expect disadvantaged people to bear the burdens of more affluent populations, who received the benefits.

  4. Disposal, in the sense of permanent isolation from the biosphere, is for all practical purposes an undefined term, and therefore incapable of scientific verification. The human race has never successfully "disposed" of anything. Nature has ingenious ways of recycling almost everything. Nuclear scientists are claiming that they can prevent Nature from recycling radioactive wastes; but we do not believe that science has the power to dictate to Nature, or to foresee events, thousands of years hence. Science cannot even predict the weather for next month,

  5. If we bury radioactive waste deep in underground rock and seal up the openings, and the containment fails, then by the time anyone on the surface notices that the repository is leaking, it will be literally impossible to take effective corrective action. Even if the repository is re-opened and the waste removed, the extent of contamination underground would be so massive that little would be accomplished by such an operation. For this reason, in our view, irretrievability equals irresponsibility. Such an approach is unacceptable.

  6. We accept as probable that certain geological formations have remained stable for millions of years. However, it is impossible to put waste into such a geologic formation without disturbing it. Deterioration of the engineering materials used to seal the shaft cannot be predicted with any certainty into the distant future. In addition, the expansion and contraction of the subterranean rocks due to the heat produced by buried radioactive wastes will affect the repository for fifty thousand years or more.

  7. The nuclear industry has not set aside the estimated $13 billion necessary to pay for implementing the geologic burial concept, nor has it demonstrated any financial capability to generate this money in time for implementation. Moreover, the $13 billion figure may well be an underestimate. In the past, AECL capital cost estimates have been underestimated by a factor of three or more. And what about contingency plans? What if the first repository site chosen proves to be unacceptable after excavation and extensive subterranean site characterization efforts? In the absence of any interest-earning funds to accumulate the needed financial resources, the concept itself is unacceptable because it is unaffordable to the industry.

  8. The geologic burial concept is based on the unfounded assumption that institutional control will not be necessary. There is no basis for assuming that future generations will not compromise the integrity of a repository, either wittingly or unwittingly. Large population centers may arise in previously uninhabited areas and penetrate the burial site repeatedly like a pincushion. Archeologists of the future may be intrigued by the evidence of massive man-made excavations, and dig down to unearth imagined treasures. Future military leaders may go after the plutonium contained in the used nuclear fuel to build an arsenal of nuclear weapons. The assumption that institutional control will not be needed is unacceptable.

  9. We believe that this panel is being subjected to strong pressure from the industry, from the government, and from some elements of the scientific community, to approve this concept, despite the fact that it has not been demonstrated to be safe or acceptable. (In each case, there is some self-interest at work: the industry wants a clean bill of health, the government wants to silence the critics, and the scientists want the research to continue.) We implore the panel not to submit to this pressure, but to have the courage to tell the truth -- that the proponent has not presented a convincing case that burying nuclear waste is safe or acceptable. That's all we ask for: truth and honesty.

  10. We believe that the panel is also being pressured to recommend that a site be selected for possible implementation of the proposal. We implore the panel not to yield to this pressure. For if the panel recommends proceeding to siting, that recommendation will be interpreted by many as an approval of the concept in principle. We believe that such an action on the part of the panel will be used here in Canada and throughout the world to stifle honest and open debate about nuclear power rather than to clarify the legitimate issues and to foster an enlightened dialogue on the best options for our common future. Do not let yourselves be used in this way.

In our opinion, there is a something fundamentally wrong in giving hundreds of millions of dollars of taxpayers' money to Atomic Energy of Canada Limited, a corporation devoted to the promotion of nuclear power, paying them to develop a concept designed to justify nuclear power rather than to solve a serious health and environmental problem. Neither the industry nor the government has ever characterized high-level radioactive wastes as posing an enormous danger to human health or to the natural environment. That way they can "have their cake and eat it too"; they can bury the waste and yet continue to produce it, leaving the most radioactive portion on the surface at all times.

While these hearing have been taking place, Jean Chrétien has been selling nuclear reactors abroad, thereby spreading the problem overseas. Without benefit of parliamentary debate or public input, Mr. Chrétien has stated that Canada agrees in principle with bringing in plutonium from other countries. Government and industry plans are totally predicated on this panel's acceptance of the concept. Meanwhile, nuclear advocates openly talk about importing nuclear wastes from overseas as a way of paying for geologic disposal.

For a concept to be acceptable, the motive behind it must be above-board, the implications must be clear, the proponent must be trustworthy, and the discussion must be carried out in a spirit of good faith. None of this is so in the present instance. Moreover, the concept has not been demonstrated to be safe beyond a reasonable doubt; scientific knowledge is not sufficiently advanced to determine one way or another whether geologic disposal can be relied upon to work as intended. Hence, for us, and we hope for you too, the concept is unacceptable.

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