''Do Not Approve
Plutonium Imports'':

Comments on AECL's Proposed
Import of MOX Fuel Rods
from Russia and the U.S.

submitted on October 15 1999 by the
Canadian Coalition for Nuclear Responsibility
to the Transport of Dangerous Goods Directorate
of Transport Canada

Parallex Test Documentation
Transport Dangerous Goods Directorate
Transport Canada
Place de Ville, 9th Floor
330 Sparks St.
Ottawa, Ontario
K1A 0N5 (Fax: (613) 990 2917)

To Whom It May Concern:

These comments may be posted
on Transport Canada's web page
for public viewing.

As President of the Canadian Coalition for Nuclear Responsibility (CCNR), and on behalf of the Board of Directors of CCNR, I am writing to urge Transport Canada not to approve the proposal from Atomic Energy of Canada Limited (AECL) to import test quantities of MOX fuel from the United States and Russia, each shipment incorporating approximately 120 grams of weapons-grade plutonium extracted from nuclear warheads.

Lack of Community Awareness and Training

CCNR believes that it has become perfectly evident that the shipment is not in accordance with the wishes of the Canadian population, who were never previously consulted by AECL or by the Government of Canada on this important project. As a result, both community awareness and training for the transit communities is entirely unsatisfactory. Several Canadian cities along the proposed route, including Sault Ste Marie, Sudbury, Thessalon, North Bay, Cornwall, and Nepean, have passed resolutions opposing the shipment. In addition, the Canadian Federation of Municipalities has passed a strong resolution of opposition, as have the Mayors of the St. Lawrence and Great Lakes Region. We have noted that the Mayor of the US border community, Sault Ste Marie, Michigan, has also expressed strong and active opposition to the US shipment, and has threatened to block the shipment.

It is likewise evident that the First Nations of Canada are opposed to these shipments and are angered by the complete lack of consultation. As regards the US shipment, the North Shore Tribal Council, representing seven First Nations, has indicated that "any attempt to transport MOX fuel through our Territorial lands and waterways will be met with full resistance." As regards the Russian shipment, the Mohawks of Kahnawake and Akwesasne have expressed very similar sentiments and have announced their intention to resist the shipments to the fullest extent possible.

In December 1998, a unanimous recommendation from the House of Commons Standing Committee on Foreign Affairs called on the Government of Canada to abandon its plan to import weapons plutonium into Canada.

This recommendation, supported by members of all parties, echoed the views of the only other party in Canada that has officially listened to all sides of the plutonium import debate. I refer to Franklyn Griffiths, George Ignatieff Professor of Peace and Conflict Studies at the University of Toronto, who was approached by officials from the Department of Foreign Affairs and International Trade to organize a two-day seminar in October 1996 to discuss AECL's plutonium import plan. In his report, Professor Griffiths concludes that the plutonium import plan should be "consigned to oblivion".

Emergency personnel have also expressed their opposition, expressing their dismay at the lack of information, training, equipment, and consultation with regard to these shipments. In the spring of 1999, Sean McManus, the Canadian director of the International Association of Fire Fighters, stated publicly that his Association has asked the federal government to shelve its plan to import weapons-grade plutonium, because they can't ensure a "reasonable level of public safety" in the event of an accident. Just yesterday, Mr. Paul Bailey, the administrator for the Police Association of Ontario, which represents about 13,000 municipal police officers province-wide, told the Ottawa Citizen that "We don't have the equipment or the radiation suits or training in nuclear disasters." The group says that any serious accident involving plutonium would also endanger the lives of its members.

It is evident that neither AECL nor the Government of Canada have prepared the communities or the emergency personnel for these plutonium-based fuel shipments, although they have had many years to do so. The "test burn" of MOX fuel derived from weapons plutonium has been planned since the spring of 1996, if not earlier, and the entire plutonium import proposal has been actively pursued by AECL since 1994, if not earlier.

In stark contrast to the total lack of consultation with Canadian communities and the Canadian public, AECL for years maintained an office in Washington DC and consulted extensively with American nuclear scientists and with the US Department of Energy on the MOX proposal.

In addition, according to an untitled AECL document obtained through the Freedom of Information Act, eleven Canadian Task teams worked throughout 1996 on different aspects of the Russia/Canada MOX proposal. Canadian nuclear scientists attended a MOX Transportation seminar and workshop in Russia from July 8 to July 16 1996:

"The Canadian Task 3 team provided a seminar to their Russian counterparts on each of the Task 3 aspects (Safeguards, Security, Transportation and Packaging), including a technical presentation on a proposed transport risk assessment process which would allow for Russian and Canadian input to the evaluation criteria."

After the seminar, the Russian team arranged for the Canadians to meet their transport and packaging experts based in St. Petersburg. Then in August 1996, according to the same AECL document cited above, a Russian delegation reciprocated by visiting the Zircatec CANDU fuel fabrication plant at Cobourg, touring the Ontario Hydro facilities at Pickering, and participating in meetings about the MOX project at Chalk River.

In September 1996, a Canadian delegation visited P.A. Mayak (Chelyabinsk-65), a hitherto top-secret Russian military installation that processed plutonium for Russian weapons during the Cold War era. All of this activity was funded by Canadian taxpayers and was predicated on the eventual use of the Bruce A reactors to begin using CANDU MOX fuel incorporating plutonium extracted from Russian and American nuclear weapons. Throughout this entire period, there was no attempt to educate or consult with Canadians on the nature and scope of the project.

An AECL Progress Report "Russian/Canadian Feasibility Study for Dispositioning Excess Russian Weapons-Grade Plutonium Using CANDU Reactors (Phase 2)" dated October 1996 states:

"The objective ... is to provide information to the Canadian public and decision makers on the technical, environmental and economical feasibility of fabricating CANDU MOX fuel in Russia and transporting it safely to Ontario Hydro's Bruce A nuclear power station for consumption there. Teams of experts from both countries are currently studying all the key activities related to the implementation of a large-scale plutonium disposition program."

AECL Progress Report, Oct. 1996, p.1

Yet these reports were NOT made available to the Canadian public, but had to be obtained by an appeal to Freedom of Information legislation. Moreover, when these publicly financed AECL reports were finally made available, a great deal of information was censored and deleted from the documents, including virtually ALL information on transportation and transportation routes.

In short, it seems clear to CCNR that AECL has made virtually no effort to communicate information concerning this project in an open and honest fashion to Canadians. Under the circumstances, Transport Canada should not give its approval for these shipments, for emergency preparedness must be based on good communications and a cooperative attitude among those who will of necessity be involved should something go wrong.

Inadequacy of the Emergency Plans

CCNR also finds that the AECL Emergency Response Assistance Plans are unsatisfactory in many respects.

First and foremost, AECL's plans are not so much designed to "assist" other emergency professionals -- as intended by Transport Canada regulations -- as they are to have AECL personnel take over almost complete control from other emergency professionals, thereby subjugating these other professionals to AECL's authority. In this way, perhaps, AECL seeks to obscure -- and in some measure to compensate for -- the lack of training, the lack of equipment, the lack of understanding, and the resulting lack of confidence and competence among these other professionals to deal autonomously, effectively and safely with a serious accident involving plutonium.

In this connection, CCNR is keenly aware of the fact that originally -- just two years ago -- AECL planned to have these shipments enter Canada without any escort vehicles at all. Since then a decision has been made to utilize a much larger transport vehicle, a much heavier form of packaging, and not one, but two escort vehicles -- both manned by AECL personnel. Such decisions may well reflect AECL's growing awareness of the fact that very little has been done to prepare other professionals to deal with these shipments under emergency conditions. Such an approach does little to inspire confidence.

It is particularly significant in this regard that the decision to activate or not to activate the emergency response plan is the sole responsibility of an AECL officer -- the Senior Emergency Officer -- who will be stationed at Chalk River and will not be at or near the site of the accident. In effect, this excludes the communities, the police, the firefighters, and other emergency personnel and local authorities from any serious decision-making responsibilities.

In fact, AECL's emergency response plan can be summed up in two words: "Trust Us".

CCNR believes that this is an unacceptable approach to emergency planning, particularly since AECL has a possible conflict-of-interest under accident conditions. For many months now, AECL has been going to considerable lengths to assure people along the transportation routes that there is no conceivable way in which the health of people or of the environment could be jeopardized by these shipments, even under the worst conceivable accident conditions. It would be a major public relations disaster for AECL if an accident occurred which contradicted these prior assurances. For that reason alone, AECL should not be allowed to be the sole source for all the competently trained and equipped emergency response personnel.

The language of the AECL documents submitted to Transport Canada strongly reinforce the perceptions described above. These are taken from document 100-37000-TD-005, dealing with the Los Alamos shipment:

It is a remarkable fact that the RPE's sole duty is to confirm that nothing very bad has happened. Does this mean that RPE is not fulfilling its duty if it reports that the package HAS sustained damage, that containment IS compromised, or that contamination IS spreading?

In this connection, it is remarkable that there are no details given as to HOW the radiological assessment will be carried out, or what instruments or techniques will be used. Plutonium is an alpha-emitter, and as such it is notoriously difficult to detect, especially when dispersed in the form of finely divided particles. Yet it is extremely toxic, precisely when it is in the form of finely divided particles, suitable for inhalation and retention in the lungs.

In this context, CCNR has secured a copy of a letter from Ms. Measures of the Atomic Energy Control Board indicating that the maximum permissible amount of plutonium in the lungs of a worker would be about 1.4 micrograms -- and for a member of the public, it would be about 0.1 micrograms. Thus 120 grams of plutonium is capable, in principle, of giving over-doses to 85 million atomic workers, or to 1 billion 200 million members of the public. (The Russian shipment, containing 132 grams of plutonium, is capable in principle of overdosing 94 million workers or 1 billion 320 million members of the public.) These figures merely serve to underscore the fact that -- practically speaking -- there is no such thing as a "small" amount of plutonium when it comes to potential health effects.

The Nobel-prize-winning organization International Physicians for the Prevention of Nuclear War (IPPNW) has published a book entitled "Plutonium -- Deadly Gold of the Nuclear Age" (International Physician's Press, Cambridge Mass., 1992) in which it is stated that 37 micrograms of plutonium is sufficient to cause a human lung cancer with virtual certainty. (Thus 120 grams could induce over 3 million cancers, while 132 grams could cause over 3 and a half million cancers.) Thus even minute quantities of plutonium can be very dangerous to exposed individuals. Yet nowhere does AECL indicate that it has the technological capability to measure or detect plutonium contamination in the microgram range.

Even if equipment capable of registering such minute amounts of plutonium contamination is available at the scene of the accident, the equipment would have to be very close to the contamination -- less than a few centimeters -- for the non-penetrating alpha radiation to register at all. This type of monitoring is difficult even in a laboratory; how is it to be done under accident conditions on a lonely stretch of wind-swept highway? There is no hint of any of these difficulties in AECL's documents, nor is there any description of the procedures to be followed.

Similar questions can be raised with regard to determining whether there are any contaminated humans who have inhaled plutonium particles. Since alpha rays only travel about 50 micrometers in soft tissue, and even less in hard tissue, internal alpha contamination is undetectable outside the body of the contaminated person. Moreover, external contamination of the skin and hair follicles by alpha-emitting particles can easily be missed by even an experienced individual using considerable time and care with a hand-held monitor.

How, then, is the RAT to determine whether there are any "contaminated casualties" (given that one of the responsibilities of the RAT Leader, as described in Appendix C, is to "provide an escort for ambulances transporting contaminated casualties to the hospital")? This question is not even addressed in the AECL documents. Should not other emergency personnel know about these procedures or be trained in them?

Likewise, there is no indication as to which hospitals along the selected routes would be appropriate ones to receive "contaminated casualties". What procedures are to be followed to prevent the spread of alpha contamination to ambulance assistants, nurses or doctors? Are the doctors and nurses in such hospitals trained to deal with or even identify contaminated casualties, or will they be given special training prior to the shipments? Or will AECL supply its own specially trained medical personnel? Again, these questions are nowhere addressed in the AECL documents.

Another responsibility of the RAT Leader, described in Appendix C, is to "restore the accident scene". Does this refer to decontamination of the accident scene? If not, what does "restore" mean? If so, what does "restoration" involve, and what criteria would be invoked for a permissible level of residual contamination in the restored area? How exactly does the RAT Leader go about "restoring" the accident scene?

These questions are even more pertinent when it comes to the possibility of a ship-board accident. Monitoring for alpha radiation is a demanding, highly specialized type of radiation monitoring; moreover, controlling the spread of alpha contamination (once it has started) is notoriously difficult, as is decontamination after the event.

What kind of training will the crew have? What kind of certification or testing of crew members will there be? Who, on board ship, plays the respective roles outlined by AECL for emergency response on land? Will there be representatives of AECL or other Canadian emergency response units on board the ship? If not, why not?

Credibility of a Radiological Accident

Upon reviewing all information currently made available, CCNR has come to seriously question whether AECL has in fact carried out the accident scenario analyses that it should have done. For, in public meetings and on national television, various AECL spokespersons have indicated that the release of plutonium particles into the environment is a totally hypothetical worst-case scenario which has no credible probability of occurrrence.

For example, on Tuesday October 12, Mr. Bob Gadsby, Director of the AECL MOX Project, made the following quite categorical statement on the CBC National Magazine:

"The fuel itself is not going to spill, ignite, explode -- however, for the purposes of doing international assessments, a hypothetical case that is always included is what if it dispersed? And it's a what if scenario that from my perspective can't happen. There's just no scenario that is going to lead to that event. So if you say, what traffic accident causes that? I don't know what it is. The thing that is dangerous on the road is NOT the MOX shipment, it's the gasoline fuel, not the MOX fuel tanker."

Bob Gadsby, Director,
AECL MOX Project

CCNR believes that this is a shockingly irresponsible statement, reflecting ignorance or incompetence on the part of the AECL MOX Project Director.

Here is how the U.S. Department of Energy describes the kind of event alluded to by Mr. Gadsby:

"5.0 Accident Analysis

"Abnormal events or accidents are hypothetical incidents that are not a planned part of routine operations. This EA evaluates three hypothetical accident scenarios (see Appendix C) that have a reasonable probability of occurrence . . . .

"5.2 MOX Fuel Transportation Accidents

"Two credible transportation accident scenarios were analyzed for the shipment of MOX fuel to the Canadian border . . . .

"The first accident relates to an event that leads to the MOX fuel package container breaking open, igniting, and releasing plutonium dioxide particles into the air. As an upper bound, this accident scenario assumes the MOX fuel is transported in a one-shipment configuration. The public is assumed to be near enough to the accident to breathe air contaminated with plutonium dioxide. . . ."

"In reality, in a very severe accident involving a major fire, the thermal effects would be far more likely to loft any released material higher in the atmosphere, which results in considerable downwind dilution and, hence, lower individual doses. . . ."

Preliminary Environmental Assessment
''Parallex Project'' Proposed Action:
Fabrication and Transport of MOX

Los Alamos National Laboratory,
US Dept of Energy (1996)

(In passing, it may be observed that lofting the plutonium higher into the air would likely lead to a much larger population being exposed to much smaller individuals doses -- especially given the long-lived nature of the radiological hazard and the resuspension of dispersed plutonium particles. The net result could be a considerably higher population dose and hence a greater public health risk. It would certainly lead to far less of the released plutonium being collected for proper long-term management at a nuclear facility.)

Mr. Gadsby has stated on National television that any accident scenario involving dispersion of plutonium into the atmosphere is a total fiction, which suggests that the entire radiological component of the emergency response plan is a kind of window dressing which is not really needed.

Such a statement strongly suggests that AECL is being untruthful or has not done its own studies on accident scenarios involving collisions that might entail forces in the order of 88,000 pounds and fires in the order of 1000 o C. Such collisions are unlikely events, to be sure, but they are perfectly possible and must be planned for.

CCNR formally requests Transport Canada to provide a copy of any and all accident scenario analyses that have been carried out by or on behalf of Atomic Energy of Canada Limited.

In our view, it is an unacceptable for those in charge of an emergency response plan to regard a credible accident scenario as a complete fiction. Such an attitude could seriously compromise the effectiveness of preparations for such an accident as well as the response to such an accident.

We are reminded of a principle finding of the US President's Commission on Three Mile Island, which concluded that one of the major contributors to that famous reactor accident was the inappropriate attitude on the part of those in the industry that nuclear technology is inherently safe, and that accident scenarios do not reflect realistic possibilities but are more in the nature of intellectual exercises. A similar sloppy attitude has infested Ontario Hydro's workforce -- including managers -- which led in 1977 to a very low "safety culture" rating and the shutdown of seven reactors to allow for corrective actions to be taken.

Yours sincerely,

Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility

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