Comments on the Proposed Bruce Used Nuclear Fuel Dry Storage Facility

Chippewas of Nawash First Nation

Comments on Ontario Hydro's ''Comprehensive'' Study

OF THE PROPOSED
BRUCE USED NUCLEAR FUEL DRY STORAGE FACILITY

Consultants: Andrew Orkin and Gordon Edwards



SUBMITTED TO THE

CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY

NOVEMBER 1998



Table of Contents

I.   WHO WE ARE

II.   OUR RELATIONSHIP WITH OUR TRADITIONAL LANDS, WATERS AND RESOURCES

III.   THE CONNECTION BETWEEN OUR CONSTITUTIONALLY AFFIRMED FISHING RIGHTS, THE BNPD AND THE PROPOSED NUCLEAR WASTE DRY STORAGE FACILITY

IV.   THE PRESENT EXERCISE: PUBLIC COMMENT ON A "COMPREHENSIVE STUDY"

V.   CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY ASSESSMENT OF THE PRESENT PROPOSAL

VI.   KEY GENERAL CONSIDERATIONS

VII.   A FUNDAMENTAL ASSESSMENT REQUIREMENT NOT MET: CUMULATIVE, OR INTEGRATED, ASSESSMENT

VIII.   ISSUES RELATED TO THE NORMAL AND ABNORMAL OPERATION OF THE BUFDSF

IX.   UNCERTAINTY CREATED BY HYDRO'S DESIGN CHANGES

X.   OTHER KEY ISSUES ARISING OUT OF THE PRESENT "COMPREHENSIVE" STUDY

XI.   IMPLICATIONS OF THE MOX PROPOSAL

I.   WHO WE ARE

  1. We are the Chippewas of Nawash First Nation. Along with the Chippewas of Saugeen, we constitute the Saugeen Ojibway Nation. We are an Aboriginal people as recognized in s. 35 of the Constitution Act, 1982 , and have lived, governed and sustained ourselves since time immemorial in our traditional lands.

  2. Our present "reserve" is located at Cape Croker, on the west side of Georgian Bay on the Saugeen (Bruce) Peninsula.

  3. We are also known as Neyaashiingigmiing , "a point of land surrounded by water".

  4. Our people are the original inhabitants, possessors and stewards of our traditional territory, which consists of 2 million acres of lands and the waters adjacent to this land, encompassing the Saugeen (Bruce) Peninsula and the watershed of the Saugeen and Rankin River systems, extending as far south as modern-day Goderich, as far inland as modern-day Arthur and north to Collingwood.

  5. Our traditional territory also includes the waters and fisheries which surround our traditional lands.

  6. We retain important constitutional, legal, economic, social, cultural and/or spiritual links and ties with our entire traditional lands and waters, and are indeed the stewards of these lands even where they are used as well by others.


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II.   OUR RELATIONSHIP WITH OUR TRADITIONAL LANDS, WATERS AND RESOURCES


II. A.   Our traditional lands 

  1. Along with indigenous peoples everywhere, our relationship with our traditional lands, waters and resources is profound, ongoing and an essential part of our identity and culture as well as the economy of our people that sustains us to this day. Who we are comes from the land. Our language comes from the land, our culture comes from the land, our sustenance comes from the land.

  2. Starting in the early 1800's we were subjected to great pressures to move our people off the land. In spite of the terms of Imperial Proclamations and treaties, we have suffered encroachments and forced surrenders, until now in the late 1990's we are down to a small portion of our original territory.

  3. This compression of the space we have in our traditional lands has subjected our people to great stresses. The pressures on the land itself have increased greatly. The pressure on the water has increased greatly, through overwhelming competition for resources from the other people that came to our traditional lands. The pressure on our culture, on our capacity to survive as an Aboriginal people, has also increased greatly. These stresses to which we have been subjected are very relevant to the environmental and social assessment of any proposed project that may affect us, and particularly any project whose cumulative impacts may affect our economy, subsistence, culture or way of life.

  4. It is the Ojibway understanding that all things that are of nature are living -- stones are living, trees are living and fish are living -- everything is living that has not been modified by man. Things that non-natives typically see as non-living are given a spirit and a value by aboriginal people including our people, the Chippewas of Nawash.

  5. Anything that nature provides must be respected, because then you are respecting yourself at the same time. There is a very strong obligation to respect the fact that we are all interconnected and interdependent.

  6. Our primary concern arising out of our relationship with our lands, the animals and Creation is the health and safety of our people and the web of life of which we are all a part. We find the word "environment" inadequate, for it suggests that nature is important only insofar as it surrounds or "environs" us human beings. It implies that humans are of central importance and nature is of peripheral concern. It reinforces the fallacious view that nature is something separate from humans, whereas our people have always seen themselves as an inseparable part of the web of life.

  7. We now require a public review process which will allow us to express our concerns on these matters and obtain truly comprehensive answers from Ontario Hydro.


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II. B.   Seven Miles Offshore: Our Unextinguished Aboriginal and Treaty Rights to Fish the Waters of the Saugeen (Bruce) Area  

  1. Of extreme importance, the land surrenders that we have experienced did not affect or diminish our Aboriginal rights in the surrounding waters which are part of our traditional territory, or the fishing rights traditionally exercised by our people since time immemorial. Our rights in these waters and to our fishery have also been assured to us as treaty rights. These Aboriginal and treaty rights have been recognized and affirmed in s. 35 of the Constitution Act, 1982 .

  2. We have never in any way ceded, surrendered or given up our waters or our fisheries.

  3. This context has been judicially recognized in the case of R.  v. Jones  (1993) 14 O.R. (3d) 421, which case also confirms our fishing rights in our traditional fishing grounds. According to Mr Justice Fairgrieve,

      "Consideration of the historical, anthropological and archival evidence leaves an existing Aboriginal right to fish for commercial purposes that essentially coincides with the treaty right already stated   [ arising inter alia   from the Bond Head Treaty  of 1836, confirmed by the Imperial Proclamation  of 1847 ] : the Saugeen   [ Ojibway Nation ]   have a collective ancestral right to fish for sustenance purposes in their traditional fishing grounds... on both sides of the peninsula."

  4. It is our position that our Aboriginal and treaty rights, at least to the offshore areas and fishery of the Saugeen (Bruce) Peninsula are (among other things) rights of title, ownership and possession. From a legal perspective, the court in Jones,  Nadjiwon  recognized our rights in this regard as "as a right of access to, and use of their traditional fishing grounds" and "the right to fish in those waters and to enjoy the benefit of the resource to be found there." Moreover, the recent Supreme Court ruling in the Delgamuukw  case reaffirms the fundamental importance of, and Crown obligations of respect for, Aboriginal title and treaty rights, including the resource components of these rights and title.

  5. It is of critical importance in the present context to repeat that our Aboriginal and treaty rights are recognized and affirmed in s. 35, being Part II of the Constitution Act, 1982 . These rights may not be infringed, abridged, curtailed or diminished.

  6. Our Aboriginal rights to our Lake Huron fishery are not only legal rights. These rights have important commercial, economic, subsistence, cultural, spiritual, symbolic and educational components. This pursuit is a core component of who we are , and a harm or potential harm to the fish or to our fishery is a direct harm to us. 


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III.   THE CONNECTION BETWEEN OUR CONSTITUTIONALLY AFFIRMED FISHING RIGHTS, THE BNPD AND THE PROPOSED NUCLEAR WASTE DRY STORAGE FACILITY


    [ BNPD = Bruce Nuclear Power Development ]

  1. Although the Chippewas of Nawash reserve at Cape Croker is situated on Georgian Bay some 80 kilometers northwest of BNPD, our commercial fishery pursuant to our Aboriginal and treaty rights are conducted, to a large extent, in the waters of Lake Huron.

  2. From a commercial fishery perspective, the BNPD is located on the shore of Lake Huron Management Area 4-4. Radioactively contaminated water from Bruce Nuclear Generating Stations A and B is discharged directly into the waters of Management area 4-4. In addition, atmospheric emissions may end up in these same waters.

  3. The harvest of fish from Management Area 4-4 represents the single largest component of the Nawash commercial fishery. A great deal of our lake whitefish (Coregonus clupeaformis )   comes from the Management Area 4-4. Therefore, the health of the water and the fish populations in the vicinity of the BNPD is fundamentally important to us.


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IV.   THE PRESENT EXERCISE: PUBLIC COMMENT ON A "COMPREHENSIVE STUDY"


  1. The present exercise consists of public comment in the course of environmental assessment, pursuant to the provisions of the Canadian Environmental Assessment Act  (''the CEA Act'') ,  concerning the "Comprehensive Study" (CS) relating to the proposed Bruce Used Fuel Dry Storage Facility or UFDSF ("the proposed Facility"). The Comprehensive Study consists mainly of

      the 1997 Environmental Assessment [''EA (1997)''] and

      the 1998 Addendum to the Environmental Assessment [''Addendum to the EA (1998)''] , as well as

      the Safety Report,

      a Summary Report and

      a number of other ancillary documents.

    Our comments will focus primarily on EA (1997) and Addendum to the EA (1998) .

  2. These comments are submitted to the Canadian Environmental Assessment Agency (the "Agency") as part of the environmental assessment of the proposed Facility. Our comments are provided under reserve of, and without prejudice to:

    • the status and rights of the First Nation,

    • any positions we may take with respect to the jurisdiction of the Agency, and

    • any positions we may take with respect to the scope of the present assessment or the "splitting" of this assessment in such a way as to deal with the proposed high-level nuclear waste storage facility isolated from consideration of other aspects of the nuclear fuel cycle.

  3. This comment from the Chippewas of Nawash First Nation is submitted pursuant to the requirements of the CEA Act. It is therefore important to identify the key requirements of the CEA Act in this regard, and evaluate the Comprehensive Study according to these requirements.


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IV. A.   Environmental effects 

  1. As discussed immediately below, a CEA Act comprehensive study is concerned with "environmental effects. "Environmental effects" are defined in s. 2(1) of the CEA Act as:

        "(a) any change that the project may  cause in the environment, including any effect of any such change on health and socio economic conditions, on physical and cultural heritage, on the current use of lands and resources for traditional purposes by aboriginal persons , or on any structure, site or thing that is of historical, archaeological, paleontological or architectural significance . . . .

      whether such change occurs within or outside Canada . . . .  "

      (Emphases added)

    1. The CEA Act defines "the environment" in s. 2(1) as

        ". . . the components of the Earth, and includes:

          (a) land, water  and air, including all layers of the atmosphere,

          (b) all organic and inorganic  matter and living organisms, and

          (c) the interacting natural systems  that include components referred to in paragraphs (a)  and (b); ... "

          (Emphases added)

    2. It should thus be noted that in the terms of the Canadian Environmental Assessment Act, environmental impacts:

        i) need not be certain, or even probable, but only possible;

        ii) include any effect of any such change on:

        • health conditions 

        • socio-economic conditions 

        • physical and cultural heritage , and

        • the current use of their traditional lands and resources for traditional purposes by aboriginal persons ;

        iii) clearly envisage consideration of such impacts beyond narrow geographic, political or cultural boundaries;

        iv) include and comprehend lands and waters , and all organic and inorganic matter and living organisms, thus including fish and ourselves (the Chippewas of Nawash people).


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    IV. B.   Cumulative impacts and other aspects of comprehensive study 


    1. The Canadian Environmental Assessment Act provides in s. 16(1) that:

        "16. (1) Every... comprehensive study of a project... shall  include a consideration of the following factors:

          (a)  the environmental effects  of the project, including the environmental effects of malfunctions or accidents that may occur in connection with the project and any cumulative environmental effects  that are likely to result from the project in combination with other projects that have been or will be carried out ;..." (Emphases added)

          (b)  the significance of the effects referred to in paragraph (a) ,

          (c)  comments from the public that are received in accordance with this Act and the regulations;

          (d)  measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the project; and

          (e)  any other matter..." (Emphases added.)

    2. The CEA Act further provides in s. 16(2) that:

        "In addition to the factors set out in subsection (1), every comprehensive study of a project... shall include a consideration of the following factors :

          (a) the purpose of the project;

          (b) alternative means of carrying out the project  that are technically and economically feasible and the environmental effects of any such alternative means..." (Emphases added.)

    3. It can be seen that the content  of a comprehensive study is thus statutorily prescribed in mandatory terms.

    4. With respect to the scope  of the factors identified in s. 16 (1)(a), (b) and (d) of the CEA Act, and certain other specified factors, the Act does provide that this is determined by the ''responsible authority'' (in this case the Atomic Energy Control Board [AECB]).

    5. It can be presumed, however, notwithstanding the power of the responsible authority to determine the scope  of some of the key factors to be considered including cumulative impacts, that this provision (s. 16 (1)) in the CEA Act clearly does not  envisage that:

      • the treatment of these required elements in a comprehensive study may be patently false, inaccurate, misleading, selective, superficial or otherwise inadequate; or

      • public concern be somehow constrained by such a determination of scope.


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    V.   CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY ASSESSMENT OF THE PRESENT PROPOSAL


    V. A.   Description of the environment in the Comprehensive Study  


    1. It is critically important to our people that the environment in which we live be adequately described to include us and our understanding of our environment. Only thus will the description offer some meaningful potential that our concerns will be understood.

    2. The description of the environment provided in the Comprehensive Study is however, from the perspective of the Chippewas of Nawash, wholly inadequate and inaccurate in significant respects.

    3. The Comprehensive Study does not adequately describe the Chippewas of Nawash relationship with our traditional lands and waters. It is impossible to adequately discuss or assess the impacts of an undertaking on our people where the proponent [Ontario Hydro] and the Responsible Authority [the Atomic Energy Control Board] provide a Comprehensive Study that so "misses the mark" with respect to such fundamental factors.

    4. With respect to fishing activities, there is a brief reference to the use of Lake Huron for "sport and commercial fishing" in EA (1997) s. 3.4.1, but this two-line statement does not even mention the Chippewas of Nawash.

    5. With respect to Aboriginal peoples, a one-page section in the Comprehensive Study (EA (1997), s. 3.7.2) under the heading "Social and Economic Conditions" describes the Chippewas of Nawash and of Saugeen in a literal and shallow manner. Our traditional lands and waters are mentioned, but our profound relationship with these elements of the environment fail to gain the attention of the proponent.

    6. There is a considerable body of literature available -- including legal, political, sociological and anthropological studies concerning our people, written by our own people and by non-Aboriginal authors -- that considers the environment from a perspective of Aboriginal peoples and meaningfully includes us and our relationships with our lands in their description. In addition, our people themselves are always available to those who ask to explain these things. It is very distressing to us that in spite of this information being readily accessible, such inadequate descriptions of the environment have been drafted by the proponent [Ontario Hydro]and declared acceptable by the Responsible Authority [AECB].

    7. Our economy, culture, values, rights and our relationship with our lands, waters and fishery are worthy of full description and consideration in this context. The failure of the Comprehensive Study to adequately address and assess (a) the social and economic effects and (b) the "cumulative" effects of this proposed Facility are attributable to this failure in the Comprehensive Study to adequately describe the environment in a manner that includes our concerns.

    8. The proponent and Responsible Authority cannot state that they are unaware that this is necessary; indeed in EA (1997) s. 4.7 (at p. 113), it is stated that "Socio-economic impacts are effects on people, their livelihoods, lifestyles, communities and culture, from development, including those effects they perceive as significant. "

    9. We therefore ask: when will these our most significant and fundamental concerns "appear on the radar" of those whose works are proposed for our traditional lands? Is it unreasonable to insist that this be done, not perfectly because no-one can perfectly portray the work of the Creator, but just that our own understanding of our environment -- including our social, economic, cultural, spiritual and physical relationships with our traditional lands and waters -- be adequately described?

    10. The failure in the Comprehensive Study to do so is itself a breach of our Aboriginal and treaty rights, and of the fiduciary relationship of the Crown, its officials and its agents towards us.


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    V. B.   No precedent for the proposed facility 


    1. It is stated in the Comprehensive Study (at EA (1997), s 2.2.3) that dry storage technology is currently used elsewhere in Canada.

    2. From the perspective of the Chippewas of Nawash, there is no applicable precedent anywhere for the proposed facility, because there is no other environment in which the present, unique environmental, social and economic circumstances exist as they do in the Saugeen (Bruce) context. 

    3. These unique circumstances include:

      • the presence of a unique Aboriginal people -- the Chippewas of Nawash -- which has fundamental Aboriginal and treaty rights that are exercised in the immediate vicinity of a facility such as the proposed facility, and which exercise is and may be further infringed or destroyed by the proposed facility and the undertaking of which it is part;

      • the unique nature of the fundamental Aboriginal rights that are involved, namely rights to a commercial fishery in the immediate vicinity and in the immediate terrestrial, aquatic and atmospheric discharge zone of the proposed facility and the nuclear plants of which it is an integral part;

      • an entirely new range of circumstances under which this project is now being proposed, which include:

        • the shutdown of Bruce A, occasioned by recent revelations that the nuclear industry is not, as was stated and assumed, consistently operated in a safe and competent manner;

        • the radical reorganization of the North American energy sector including Ontario Hydro;

        • the failure of the nuclear industry's concept for deep geologic burial of high level nuclear waste to obtain approval as being sufficiently safe or socially acceptable to the Canadian public;

        • increasing understanding and legal acceptance of the rights and interests of Aboriginal peoples; and

        • increasing uncertainty in Canada and elsewhere concerning the viability of the nuclear power industry.

    4. With respect to the unique circumstances mentioned in the preceding paragraph, it is not important whether the proponent or the Responsible Authority agree with, or consider these circumstances relevant. As acknowledged in EA 1997, s. 4.7 of the Comprehensive Study , socio-economic effects include those effects perceived as significant , and it stands to reason that these must be assessed according to a description of the environment that is adequate to do these perceptions justice.


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    VI.   KEY GENERAL CONSIDERATIONS


    1. We are keenly aware of the fact that Ontario Hydro, in its proposed dry UFDSF, is planning to store highly dangerous radioactive poisons which must be sequestered from the environment for millions of years. Although we accept that Ontario Hydro wishes and intends to do this in a safe and secure way, we do not share Hydro's confidence as presented in the Comprehensive Study and in general of its own technological prowess and managerial ability, to ensure that virtually all of these radioactive materials will be kept out of our air, food and water under all normal and abnormal conditions, for the lifetime of the facility.

    2. The public record establishes that our surroundings and traditional lands and waters are already significantly contaminated with radioactive substances -- particularly radioactive hydrogen and carbon -- from normal and abnormal operations of the Bruce reactors and waste management facilities.

    3. Given Ontario Hydro's track record on tritium and carbon-14 emissions at Bruce and recent revelations regarding deficient operations and management practices in the corporation, we submit that we are now entitled to have an opportunity to question Hydro's abilities in regard to the dry storage proposal through a federal assessment conducted by an independent panel, with public hearings.

    4. We are concerned that the Report does not provide any comparative data by which to assess the radioactivity levels in Lake Huron fish, especially considering the availability of such data. By virtue of the legal requirement for cumulative impact assessment, this data is relevant and material in the present context. In Ontario Hydro's "Annual Summary and Assessment of Environmental Radiological Data for 1995", the tritium concentrations used in calculation of 1995 Critical Group Dose are shown on Table 5.1.2.2A. The measurements reported for locally caught fish in the vicinity of nuclear reactor sites are as follows:

        Darlington Nuclear Generating Station: 8 Bq/L

        Pickering Nuclear Generating Station: 34 Bq/L

        Bruce Nuclear Power Development: 97 Bq/L

    5. We ask:

        Why are the tritium concentrations in Lake Huron fish more than eleven times higher than the concentrations measured at Darlington, and nearly double the concentrations measured at Pickering? 

    6. Surely this elevated tritium level represents a cumulative environmental effect worth considering, both from the perspective of the current use of resources by aboriginal people and from the perspective of overall health and socio-economic conditions. Yet these data are nowhere mentioned in the Comprehensive Study, nor is the issue of drastically reducing overall tritium emissions at Bruce addressed. The proponent is content to claim simply that tritium emissions from the proposed dry UFDSF will be a relatively small contribution in view of the overall emissions.

    7. The Section of EA 1977 which discusses radioactivity in drinking water notes that "tritium concentrations are higher at Port Elgin than at Kincardine due to the higher frequency of lake currents flowing from BNPD towards Port Elgin." (EA 1977, s. 3.6.3.4, p. 69). The existence of a predominantly northward lake current must have implications for our fishery, directing radioactivity toward the major spawning grounds for lake whitefish. Regrettably this potential effect has not been considered by the Report.

    8. Our concerns are reinforced by our reading of a report concerning tritium levels in drinking water in Scarborough (on Lake Ontario) and Port Elgin (on Lake Huron) (see excerpt attached to this document as "Appendix 1"). The report attempts to analyze the pattern of tritium contamination in drinking water at the two locations (using time series) without much success. In the Concluding section of the report, the author writes:

        "When comparing the Scarborough and the Port Elgin series, we notice two features. The vertical scales differ drastically: the Scarborough measurements range from 3.70 to 159.84 Bq/l, whereas those at Port Elgin range from 7.4 to 732.6 Bq/l.

        The two series also differ in structure: excluding the one outlier in August 1992, there are no large peaks in the Scarborough series after May 1988. In fact, we observe a slight downward trend in the mean towards the end of the series in 1993. The Port Elgin series, on the other hand, continues to show occasional large peaks throughout the entire observation period.

        These differences can be attributed to two factors: the currents in Lake Ontario vary greatly in terms of direction, so the tritium is well dispersed by the time any of it reaches any given WSP. On the other hand, Lake Huron currents are predominantly towards the North, so Port Elgin received most of the leaked tritium.

        Management philosophies at the two stations are also different: at Pickering NGS, several units were shut down, starting in 1988, for extended periods of time in order to inspect the primary heat exchangers and to plug tubes with significant wall loss before they started to leak. This may well be the reason for not seeing any major peaks in the Scarborough series after 1988. At Bruce A and B, however, the objective has been to keep the units running for as long as possible, tolerating minor leaks until they reached certain levels. Scheduled inspections and repairs were done, but not to the same extent as at Pickering. Thus we continue to see occasional peaks reflecting spills at the two stations over the entire Port Elgin series."

        Ontario Hydro internal report
        (1994; author not identified)

    9. We ask:

        Why are tritium levels in drinking water at Port Elgin from 2 to 6 times as high as the tritium levels in drinking water at Scarborough, close to the Pickering Nuclear Generating Station?

        Why is this not discussed in the Comprehensive Study, as part of the ongoing and cumulative impacts of the proposed Facility and the undertaking of which (in the words of Ontario Hydro) it is an integral part? 


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    VI. C.   Selection of dry storage option 

    1. We are not confident that Ontario Hydro has a commitment to put protection of people and other living things above the operational and economic priorities of the corporation. This is how Ontario Hydro describes its own internal reasons for choosing the dry storage option:

        "Used fuel generated by the operation of Bruce NGS-A and Bruce NGS B is currently stored under water in primary and secondary Irradiated Fuel Bays (IFBs) of each station. These fuel bays are projected to be full in 1999 and 2003, respectively. Additional storage capacity will, therefore, be required to allow operation of the stations beyond the year 2000....

        To provide the additional storage space needed for used fuel at BNPD site, various dry and wet options were considered. Based on a comparison of these options with respect to their technical feasibility, implementation schedule, constructability, operability, licensability and cost , the dry storage option was chosen as the overall best option.... " (Emphasis added.)

        Section 1.1.1, BUFDSF Safety Report, 1997

    2. Significantly, Hydro makes no mention of cumulative impacts, health, safety, or environmental protection (for example)  in determining which option to pursue. This does not inspire confidence in Ontario Hydro's approach. It suggests a frame of mind in which cumulative impacts, health, safety, and environmental protection are at best "after-thoughts" rather than uppermost. The Chippewas of Nawash must be given an opportunity to question Ontario Hydro representatives on their priorities.

    3. In the fall of 1997, an internal review of Ontario Hydro's nuclear operations was concluded by American experts brought in by senior Hydro management. One of the major findings of that review was that the "safety culture" in Hydro's nuclear division was so far below standard that it was only "marginally acceptable" -- as low as it could get without being unacceptable. Safety-related procedures were in many cases handled in a superficial, slap-dash and unprofessional manner, without an appreciation by managers or workers of the potential consequences of following substandard practices. The situation was so serious, with such a large backlog of safety-related maintenance problems, that seven of Ontario Hydro's reactors were shut down to allow time for improvements to be made in the physical plant as well as in the attitudes and practices of management and workers. These events have shaken our confidence in Ontario Hydro's assurances.

    4. The Chippewas of Nawash are not convinced that Ontario Hydro displays the necessary humility and respect for the inherent biological dangers associated with the radioactive poisons in irradiated nuclear fuel. Other responsible bodies, independent of the nuclear industry, have described irradiated nuclear fuel as the most potentially dangerous and toxic material known to humankind.

    5. We have read that in its Interim Report on Nuclear Energy, the Ontario Royal Commission on Electric Power Planning reported that:

        "The extreme lethality of a freshly removed spent fuel bundle is such that a person standing within a metre of it would die within an hour. During the next forty years (and probably for thousands of years), the management of hundreds of thousands of such bundles (in Ontario alone), which at all times must be isolated from the earth's ecosystem, will clearly present a problem of massive proportions."

        A Race Against Time , p. 87
        Ontario Royal Commission on Electric Power Planning

    6. We have also read that the Ontario Select Committee on Ontario Hydro Affairs wrote:

        "The radioactive products in spent nuclear fuel pose a threat to human health for a period of time that is longer than the history of civilization. The initial threat is the most intense. It comes from the heat and radioactive emissions of the active fission products. After about 600 years these products will have decayed to relatively low levels. For several hundred thousand years, radioactive emissions from long-lived elements called actinides continue.

        After about 17,000 years unreprocessed spent fuel has about the same level of toxicity as the Elliot Lake uranium ore body from which it was taken. Given the very long life of these toxic materials, no man-made containment system can ever be predicted to give sufficient protection."

        The Management of Nuclear Fuel Waste , June 1980.
        Select Committee on Ontario Hydro Affairs

    7. And, in the same report, the Select Committee on Ontario Hydro Affairs added the following:

        "The consensus of the Committee is that communities are not likely to easily accept the siting of what will be perceived as a garbage dump for frightening nuclear poisons. The waste must be disposed of. It must be disposed of safely and permanently. In the Committee's view, it is most likely that government will ultimately have to choose where the unpopular site will be located...."

        The Management of Nuclear Fuel Waste , June 1980.

    8. Given the nature of these materials and the controversy surrounding their ultimate disposition, we feel that a federal environmental assessment of Hydro's proposed dry storage Facility, conducted in public by an independent panel, is absolutely required.


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    VII.   A FUNDAMENTAL ASSESSMENT REQUIREMENT NOT MET: CUMULATIVE, OR INTEGRATED, ASSESSMENT


    1. The official AECB "Summary Report" states, in reference to the Cumulative Effects Assessment supposedly undertaken in the Comprehensive Study , that "the project will be a relatively minor contributor to adverse and positive cumulative environmental effects" at BNPD.

    2. The AECB summary declares that this conclusion was "based on a broad based and qualitative assessment of the potential effects of the proposed Facility in combination with those of existing/ongoing, planned and foreseeable actions/physical works at the BNPD site over the short, medium and long terms."

    3. In light of the provisions of the CEA Act referred to above regarding cumulative assessment of environmental effects that are likely to result from the project in combination with other projects that have been or will be carried out,   we feel that it is imperative that the environmental effects of the other aspects of the BNPD of which it is part be adequately assessed, in a fully integrated manner .

    4. Significantly, Ontario Hydro's itself states (in EA (1997), at s. 1.2) that the proposed Facility is "a necessary and integral part  of the program of operating and maintaining the Bruce A and Bruce B stations " and (in the AECB "Summary Report") that "the continued operation of radioactive waste management facilities at the BNPD, including the proposed Used Dry Fuel Storage Facility, is integral to the ongoing nuclear power generation activities of Ontario Hydro... ". (Emphases added.)

    5. Notwithstanding this official picture of integration of storage and generation, the present comprehensive study assessment is biased to consideration of the environmental impacts of the proposed Bruce Used Fuel Dry Storage Facility as a discrete undertaking. In the Comprehensive Study no meaningful attempt is made to integrate the environmental assessment of the proposed dry UFDSF with various options such as:

      • the (unanticipated) lay-up of Bruce A,

      • the restart (or not) of Bruce A,

      • the early retirement (or not) of Bruce B,

      • the expansion of Radioactive Wastes Operations Site 2,

      • the siting (or not) of a low-level radioactive waste repository at Bruce,

      • the siting (or not) of a high-level radioactive waste repository somewhere in Canada,

      • the use of MOX fuel (or not) at Bruce,

      • the launch of a fusion research facility (or not) at Bruce...

    6. In the half-page (out of three-and-a-half pages) devoted to cumulative assessment in the AECB "Summary Report", it is stated -- falsely and misleadingly in our view when the Summary is compared with the Comprehensive Study itself  -- that the Cumulative Effects Assessment conclusions were "based on a broad-based and qualitative assessment of the potential effects of the proposed Facility in combination with those of existing/ongoing, planned and foreseeable actions/physical works at the BNPD site over the short, medium and long terms." We will have more to say on this subject below.

    7. There is only very limited discussion in the Comprehensive Study of cumulative effects from an Aboriginal perspective: EA (1997) at s. 4.10, pp 126 - 29 (three pages out of one hundred and fifty); and Addendum to the EA (1998) at Tab 3, Table 2 (four lines) as well as Tables 13 and Appendix A Table ("Potential Aboriginal Issues and Significance"; unnumbered).

    8. From our Chippewa/Aboriginal perspective, the cumulative assessments provided in both EA (1997) and in Addendum to the EA (1998) are inadequate and unsatisfactory.

    9. In EA (1997), there is no apparent understanding or even meaningful mention of cumulative effects from an Aboriginal perspective. Nevertheless it is stated conclusively and without any substantiation  (at p.129) that:

      • "there are no significant adverse socio-economic effects anticipated  with this proposal" (emphasis added), and

      • "there are established mechanisms for ongoing public involvement and problem resolution", and

      • "the project is therefore considered to have no significant incremental or cumulative adverse environmental effects ." (emphasis added)

      It is against the backdrop of these superficial and tendentious statements and sweeping conclusions that the subsequent cumulative assessment in Addendum to the EA (1998) must be viewed.

    10. The cumulative assessment undertaken in the Addendum to the EA (1998) is considerably more detailed, but displays, in our view, little more comprehension. For example, the Addendum to the EA (1998) cumulative assessment simply repeats verbatim highly problematic statements from EA (1997) -- for example at p. 1:

        "The project is not intended to alter the basic purpose, use or capacity of the existing on-site generation facilities. It is intended to allow these facilities to continue operating as planned and approved."

    11. As indicated above, this statement is at best misleading and at worst false. BUFDSF is acknowledged to be an integral part of the Bruce nuclear power development facility , but it will greatly increase the capacity and possibly extend the duration of high-level waste stored at the site, perhaps indefinitely, thus transforming the nature of the entire BNPD facility. This transformation was never ''planned and approved''. BNPD was not originally conceived as a potentially permanent radioactive waste-storage facility with outdoor high-level radioactive waste storage components. The manner of presentation in the Comprehensive Study , which is imbued with a tone of self-justification, coupled with the uncritical acceptance of ill-supported conclusions, such as those mentioned in the preceding paragraph, bring the cumulative assessment into doubt.

    12. The treatment of surface water / aquatic biology effects is, in our view totally inadequate, reflecting the cursory treatment given to our fishery concerns in EA (1997). In this regard, it is simply stated that (at Table 9, Tab 3):

        "Bruce B operations will continue to be a source of potential  contaminants to the soils, groundwater and surface water. The adverse effects of contaminants in surface waters on aquatic life is expected  to be very minor." (Emphasis added.)

    13. The above statement disturbs us greatly.

        First, we believe it is plainly false, in that contamination of water is not merely a "potential" effect, but an existing one, for example with tritium contamination at Bruce established to be at levels disturbingly higher than other Ontario nuclear contexts.

        Second, we cannot accept that there is adequate knowledge -- especially in light of past experience with respect to "safe" thresholds of nuclear or toxic contamination -- that it can be stated with any confidence that the adverse effects of radioactive contaminants in surface waters will be "very minor" or "minor... as the site will continue to operate within regulatory limits".

        Third, what exactly is the established relationship between "minor impacts" and current "regulatory limits"?

    14. Department of Fisheries and Oceans (DFO) staff have expressed concerns that the railway ditch close to the proposed UFDSF may have become a viable fish habitat in need of protection. However, we have found no quantitative data in Hydro's documentation concerning current habitat suitability in the ditch, even though it "contains some small open areas of water in which schools of minnow sized fish of unspecified species were observed." [Addendum to the EA (1998), s. 7, p. 9] This information gap is not an isolated case, but is symptomatic of a general lack of reliable data regarding potentially affected aquatic environments. We believe that the lack of adequate baseline data adds significantly to the uncertainty as to the nature and extent of any adverse effects that might occur. Tritium is well-known as a teratogen and mutagen as well as carcinogen (UNSCEAR 1977 - Appendices G and H). Also, tritium has ready access to all living cells including reproductive and embryonic cells. Thus the inherent uncertainty in biological effect following radiation exposure is greatly increased when affected fish populations are spawning, hatching, or maturing as they are exposed to tritium. An independent assessment by a panel is needed.

    15. The drainage ditch from the proposed UFDSF site runs directly into the railway ditch, which "in turn flows into a wetland and then Stream C, eventually flowing into Baie du Doré, Lake Huron. Fish sampling studies have been done in Stream C, as far upstream as the railway tracks. Brook trout were found at this location. Since there is no barrier to fish movement in the watercourse system from Lake Huron to well past the proposed dry storage facility site, it is necessary to establish the extent to which fish use the area upstream of Fish Sampling Station G (brook trout location)." (Addendum to the EA (1998), s. 7, p. 9) Despite these facts, which were ascertained by DFO staff, and although in Appendix F it is noted that salmon and trout do use sections of Stream C as reproductive habitat Hydro's documentation in support of the proposed UFDSF does not discuss the extent to which Stream C may be used as a spawning habitat or as a juvenile nursery area for salmonids. In fact, as far as we can determine, Hydro has collected no data on the following economically or recreationally important fish species found in the vicinity of the proposed development:

        Brown trout (Salmo trutta  )

        Brook trout (Salvelinus fontinalis  )

        Rainbow trout (Oncorhynchus mykiss  )

        Smallmouth bass (Micropterus  dolomieu )

        Largemouth bass (Micropterus salmoides )

        Chinook salmon (Oncorhynchus tshawytscha )

    16. In the absence of data on habitat quality or suitability baselines, Hydro has no basis for claiming "minimal environmental effects" from the proposed facility. In fact, Hydro is not in any position to compare actual post-project conditions to pre-project conditions in order to establish whether or not significant effects have occurred. Although Hydro has promised to carry out monitoring and remediation if necessary, no specifics as to the planned monitoring activities have been given.

    17. In its Addendum to the EA (1998), Hydro argues that the lack of complete aquatic environmental data is balanced -- and to some extent justified -- by the extremely low chance that any contamination might occur. Citing the 1977 BUFDSF Safety Report (Addendum to the EA (1998), s. 7, p. 9) Hydro states that the release of contaminants from the UFDSF is "very unlikely" -- especially in liquid form. However, these assurances -- drawn from the BUFDSF Safety Report -- are based on the assumption that there is no contamination on the surface of the containers, thanks to the dry loading procedure that will be used. Specifically, the Bruce Used Fuel Dry Storage Containers are designed to be loaded using a dry transfer method so that ''there will be no spread of contamination to areas off-site when the containers are transported to the storage area.'' (EA (1997), s. 4.6.1.1.1, p. 98)

    18. But even while the Addendum to the EA (1998) cites the 1977 Safety Report -- with its fixation on dry spent fuel transfer and zero surface contamination -- the same Addendum suggests very strongly that a wet-loading method may end up being used at Bruce instead. (Addendum to the EA (1998), s. 2 in toto). The wet-loading method would be similar to the one currently employed at the Pickering NGS: the container is lowered into the pool, filled with irradiated fuel, then lifted out, drained, and dried. One of the drawbacks of this method is that the surface of the container can become contaminated with radioactive corrosion products or fission products that are found in the pool water. Any radioactive contamination on the surface of the containers could later be washed off in a storm and contaminate the nearby surface water systems. Evidently this will increase the probability of radioactive contamination of surface waters, and add to the uncertainty regarding possible environmental effects.

    19. The declared limitations to the Addendum to the EA (1998) cumulative effects section (at Tab 3, p. 5) provide important insights as to the validity of its conclusions that affect our people:

        "No original field work, new  [ presumably, post EA (1997) ]   research or consultation with potentially affected people and groups was possible... identification of potential effects were based largely on the information provided in the EA report already submitted by Ontario Hydro..."

          Thus, we must ask, does the Addendum to the EA (1998) cumulative assessment simply recycle the blanket, unsubstantiated positive conclusions of EA (1997)?

        "only limited information available regarding ... future activities... ... as a result this overview CEA   [ Cumulative Effects Assessment ]   is largely qualitative in nature..."

          Thus, we must ask, what of our Aboriginal cumulative effect concerns, which are significantly concerned with these future activities, to which the project is linked?

        "[ only ]   addresses effects under normal operational conditions and does not include effects from significant abnormal events..."

          Thus, we must ask, what confidence would one have had in a cumulative assessment of a Three Mile Island or Chernobyl plant had also been restricted to normal operational conditions? Are not concerns about the cumulative impacts of significant abnormal events of the essence in such an assessment? Is the proponent declaring us wrong in believing this to be the case, by virtue of the terms of reference for this cumulative assessment?

        "It was more difficult to assess the cumulative effects on First Nations communities because there is only limited information available and the difficulty of assessing the meaning or significance of comments made by some First Nations people."

          It is hard to know how to respond to a statement such as this. We must ask: ''limited information ?''   ''difficulty of assessing meaning or significance?''

          We cannot accept that a large, sophisticated and wealthy corporation such as Ontario Hydro, and its consultants, could not obtain the information required in this context, particularly through first-hand consultation with our people in conjunction with any necessary expert assistance.

          Was this cumulative effects assessment ''difficulty'' a budgetary restraint or a time problem? Or was it actually based on indifference? We do not believe that our concerns are hard to understand, or to recognize as extremely significant (if not to everyone, then at the very least to most of our people).

    20. With respect to the consideration of "cumulative effects on Aboriginal issues" (in Addendum to the EA (1998), Tab 3, Table 13), we can only agree with some of the (unfortunately very brief and mechanically repeatedly cut-and-pasted) tabular "assessments" of our concerns, namely those regarding stewardship of lands, waters and resources, and the incompatibility of these undertakings with our culture, way of life and economy.

    21. Sadly, these few blanket observations in Table 13 regarding our "issues" does not translate into what we would consider a full cumulative effects assessment . Rather, it appears to result in three central "products" of relevance to us:

      • at p. 47 - 48, a statement that Ontario Hydro intends to "work with First Nations to provide a more complete assessment of the social and economic effects of all current and planned activities at the BNPD site. This ongoing work may address  [various issues are listed]..." (emphasis added);

      • a statement that in spite of various acknowledgments of increased radioactive contaminant discharges, "public concern" about these discharges into the aquatic environment is only
        "Moderate - Potential for contamination of Lake Huron remains a concern".
        We strongly dispute the accuracy of this conclusion, and believe that it brings the competence and adequacy of the Comprehensive Study into doubt. (It should be noted in this context that it is acknowledged in Addendum to the EA (1998) that in most other respects, Aboriginal public concern regarding various effect of the proposed Facility is "high"); and

      • a single page table titled "Potential Aboriginal Issues and Significance" at the end of the cumulative effects section in Tab 3, Addendum to the EA (1998).

    22. With respect to the first bulleted item in the preceding paragraph, we do not find in the CEA Act that it is envisaged that cumulative assessment of First Nations' socio economic concerns can legally be postponed at the proponent's pleasure until after the CEA Act assessment has been commenced or completed. This statement is outrageous and appears to us for that reason to constitute a clear strategy to evade the requirements of the governing legislation .

    23. With respect to the second bulleted item, we must ask: Why are our profound concerns about aquatic discharges not explicitly acknowledged to be high, in the Addendum to the EA (1998) Appendix Table, section on aquatic effects?

    24. With respect to the third bulleted item, we are gratified to note that the intensity of our (Aboriginal) "public concerns" are reflected as being generally high, and that our concerns are at least briefly acknowledged. Unfortunately, they are not reflected in the body of the report accordingly, and most importantly, do not make it into the general conclusions (particularly, as noted, in the Summary of the Comprehensive Study).


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    VII. A.   Need for a Comprehensive Baseline Study 

    1. As mentioned above, according to section 16(1) of the Canadian Environmental Assessment Act, Hydro has an explicit requirement to assess cumulative effects, which are changes to the environment that are caused by an action in combination with other past, present and future human actions. In assessing cumulative effects, temporal and spatial boundaries must be enlarged so that environmental changes brought about by such actions can be adequately tracked in time and space.

    2. We believe that this requirement has not been met by Ontario Hydro. Indeed, we maintain that there are insufficient baseline data concerning radioactivity (especially tritium and carbon-14 levels) in the region around BNPD at present to be able to detect incremental changes and ascribe them to a specific action. This makes a consideration of some of the most significant cumulative effects impossible, and greatly increases the uncertainty related to the detection of adverse effects.

    3. The Chippewas of Nawash believe that no major new facilities should be added to the BNPD site until a comprehensive baseline study has been conducted and a reliable database established. We believe that this should entail a study of existing radionuclide concentrations in living and non-living components of the neighbouring region, including the fish of Lake Huron Management Area 4.4 -- where many lake whitefish are harvested by the Nawash commercial fishery, and where the BNPD itself is located (on the shore adjacent to the Management Area).

    4. In particular, the Chippewas of Nawash believe it is essential for such a comprehensive baseline study to be completed before consideration is given to the construction of a Used Fuel Dry Storage Facility (UFDSF) as currently proposed.


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    VII. B.   Cumulative effects assessments concerning specific radionuclides: tritium, carbon-14, etc. 

    1. To be truly useful in tracking the cumulative radiological impact of Ontario Hydro facilities on the region, a baseline study should focus on the degree to which specific radionuclides which are routinely or occasionally released into the natural environment by BNPD, such as tritium, carbon-14, or cesium-137, are interacting with and affecting the living and non-living components of the region. We believe that Ontario Hydro should undertake such a comprehensive baseline study with the goal of restoring the natural environment as much as possible to its natural state. This would involve eliminating all unnecessary radioactive emissions and adopting as an ultimate goal the achievement of zero emissions for radiological pollutants -- a goal that has been articulated by the International Joint Commission for all persistent toxic materials entering the Great Lakes, including radioactive materials having a half-life of more than six months. These would certainly include tritium, with its 12 year half-life, carbon-14, with its 6,000 year half-life, and cesium-137, with its 30-year half-life.

    2. Yet there is no discussion  by Ontario Hydro of "measures that are technologically and economically feasible and that would mitigate any significant adverse effects of the project", possibly "in combination with other projects that have been or will be carried out." (CEA Act, s. 16(1).)

    3. Ontario Hydro routinely compares radiation exposures resulting from activities at BNPD with so-called "background levels", which are taken to include all sources of radiation exposure other than Ontario Hydro nuclear stations. In section 3.6.4 of the EA, recent (1997) Hydro calculations are cited indicating that, on average, a typical Ontario resident is exposed to 3,300 microsieverts (330 millirems) per year, of which 2,000 microsieverts is from natural sources (including 1,000 microsieverts from radon exposure) and 1,300 microsieverts is from human-made sources (including bomb fallout, medical exposures and technological products and services).

    4. We find it strange that Hydro should include medical exposures and other technologically-related exposures as "background" in the context of an environmental assessment. This important methodological assumption is not justified by the authors of the Comprehensive Study . We do not believe this assumption is warranted or useful.

    5. If exposures of human origin are excluded from the calculation, Hydro's background radiation figure is immediately reduced by 40 percent , from 3,300 to 2,000 microsieverts per year. In this way, Hydro's contribution to total radiation exposure in the region is measured against natural background radiation levels rather than technologically enhanced levels. If we were to exclude radon from the calculation as well, on the grounds that radon is a highly specific internal alpha-emitter whose effects are concentrated on a specific organ, namely the lung, then natural background radiation drops to 1,000 microsieverts per year -- 70 percent less than the 3,300 microsieverts per year used by Hydro as ''background'' .

    6. In any event, generalized comparisons with "background radiation" are not helpful in assessing the degree to which specific radionuclides released into the natural environment by BNPD are affecting humans, animals and fish in the region. Much more useful would be a series of explicit measurements comparing (for example) elevated tritium levels with background tritium levels; elevated carbon-14 levels with background carbon-14 levels; elevated cesium-137 levels with background cesium-137 levels; and so on.

    7. For cesium-137, there is no "natural" (i.e. pre-fission) background level; in that case Hydro's contribution can be compared with the contribution from atomic bomb fallout -- the only other component of human-made radiation which has, unfortunately, left an indelible environmental footprint on the earth. In the case of tritium and carbon 14, there is both a natural background component (cosmogenic radiation) and another component that comes from bomb fallout; in such cases, comparisons can be made both ways.

    8. Radioactive materials, like toxic chemicals, have their own peculiar physical, biological and chemical properties, and in the case of internal emitters, they pose their own unique biological hazards. Inside the body, iodine-131 has an entirely different spectrum of effects than either radon or radium has, and these are all quite different in their effects from those of tritium or carbon-14. It thus makes little scientific or medical sense to treat them as more-or-less interchangeable aspects of the same phenomenon. Radionuclides should be tracked and assessed individually, just as we track and assess individual toxic chemicals.

    9. In some cases, the term "background levels" can be highly misleading, because they may refer not to natural background levels, but to background levels in an already polluted environment. One can see an example of this in the 1994 internal Ontario Hydro study on tritium levels in drinking water cited earlier:

        "Tritium concentration is measured in terms of radioactivity per unit volume: Becquerels per litre, or Bq/l. The maximum allowable concentration in drinking water set by the Atomic Energy Control Board is 240,000 Bq/l. The Ontario Ministry of the Environment limit is 40,000 Bq/l, and the Ministry is considering lowering this limit to 7,000 Bq/l. In the data we examined, all the concentrations are well below 1,000 Bq/l.

        Naturally occurring tritium as measured at control locations across Ontario is approximately 10 Bq/l. Ontario Hydro has already adjusted this data for naturally occurring tritium concentration. Thus the term ''background'' used in this report refers to the elevated levels of tritium that can be attributed to the normal operation of the NGS's but not to any sudden large emissions."

    10. Thus, chronic levels of pollution can come to be portrayed as part of the "background". This is routine practice when it comes to radioactive fallout from atomic bomb tests. It is a "slippery slope", however, which ultimately leads to the unacceptable position that any degree of pollution or radioactive discharges can become acceptable over time .

    11. According to the linear hypothesis, which has been adopted by regulatory bodies around the world, including the Atomic Energy Control Board (AECB), and which has been supported by such scientific bodies as the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) and the US National Academy of Sciences Committee on the Biological Effects of Ionizing Radiation (BEIR), there is no safe dose of radiation exposure -- except zero. According to this hypothesis, every extra dose of radiation, however small, adds to the incidence of radiation-induced cancer or genetic damage in an exposed population of people or animals.

    12. For this reason, the UN Scientific Committee has said that radiation protection policies are supposed to be based on "the principle of eliminating any exposures which are not necessary and of keeping all doses as low as is reasonably achievable" (UNSCEAR 1977 p.14). While the ALARA principle (to keep doses "as low as reasonably achievable") is discussed by Ontario Hydro (EA (1997), s. 3.6.1), the principle of eliminating any exposures which are not necessary (identified by UNSCEAR) is never discussed in the Comprehensive Study , the EA or the Addendum to the EA (1998), as far as we can determine. And although Ontario Hydro is required by law to deal with cumulative effects, there is almost no discussion of cancer or genetic damage in any of the documentation we have reviewed . It is true that cancer and genetic effects are mentioned briefly on one page (p. 123) in EA s. 4.8.2, but there is no mention of these effects at all in EA s. 4.6.1.3: "Radiation Effects on General Public", or EA s. 4.6.1.4 : "Radiation Effects on Aboriginal People", or EA s. 4.6.1.5 : "Ecological non-Human Effects". Nor is there any discussion of other types of radiation damage.

    13. The Chippewas of Nawash believe that the without a commitment to eliminate all unnecessary exposures, the ALARA principle rings hollow. Although Ontario Hydro states (EA (1997), s. 3.6.3) "The objective of maintaining or reducing exposures to as low as reasonable achievable is the cornerstone of radiological protection programs." Yet, in the same 1994 internal Ontario Hydro Report on tritium levels in drinking water already referred to, we read the following:

        "Release of radioactive material into the environment occurs primarily through leakage in two separate heat exchange systems: water from the reactor heats ordinary purified water and turns it into steam in the primary heat exchange system. Once the steam has gone through the turbine, it is further cooled by lake water in another heat exchange system. The latter leaks quite frequently, so if there is a leak in the primary system, it is virtually guaranteed that some of the leakage will end up in the lake.

        When such a leak occurs, tritium levels measured at a WSP can be anywhere from 5 to 40 times the background levels. These high concentrations usually last for one or two measurement periods and appear as sharp peaks in time series plots. There is no regular pattern to the occurrence of these leaks, although a reactor with a leak is more likely to be allowed to continue to operate during high demand times in the middle of winter, thus making the leakage periods roughly seasonal....

        Management philosophies at the two stations are also different: at Pickering NGS, several units were shut down, starting in 1988, for extended periods of time in order to inspect the primary heat exchangers and to plug tubes with significant wall loss before they started to leak. This may well be the reason for not seeing any major peaks in the Scarborough series after 1988. At Bruce A and B, however, the objective has been to keep the units running for as long as possible, tolerating minor leaks until they reached certain levels. Scheduled inspections and repairs were done, but not to the same extent as at Pickering. Thus we continue to see occasional peaks reflecting spills at the two stations over the entire Port Elgin series."

    14. It appears from the above passages that certain "measures that are technologically and economically feasible and that would mitigate ... adverse effects" may not necessarily be adopted by Ontario Hydro -- or rather, they may be adopted selectively depending on the management philosophy at different stations. An independent federal assessment would allow for a critical examination of these practices and priorities.


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    VII. C.   "Critical receptors": pregnant women, foetuses, breast-fed babies not included  

    1. In calculating radiation dose to an individual, Ontario Hydro follows a methodology utilized by the ICRP [International Commission on Radiological Protection] whereby

        "... the three critical groups are defined as:

          (a) Infant A - An infant six months old living at the boundary of the facility and drinks [sic] fresh milk from local sources.

          (b) Infant B - Similar to Infant A except for drinking powdered formula reconstituted with tap water.

          (c) Adult - An adult living on the boundary of the facility.

        Detailed dose assessment procedures together with pathway parameters, critical group dose calculations methods and the calculation results of five nuclide groups (tritium, noble gases, Carbon-14, Iodine-131 and particulates) are given in Annual Ontario Hydro Reports.        "

      EA (1997), Section 3.6.4.1

    2. It is very puzzling and disturbing to us to see that neither a breast-fed baby, nor a foetus, nor a pregnant woman is considered to be a critical receptor. Yet a foetus is known to be more sensitive to radiation than an infant. In fact, a foetus is susceptible to an entirely different category of harm -- developmental ("teratogenic") effects -- in addition to the carcinogenic and genetic effects normally ascribed to ionizing radiation.

    3. The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR 1988) has stated that the most probable type of developmental effect experienced by a foetus exposed to ionizing radiation in utero, is mental retardation -- yet this effect is nowhere mentioned in Ontario Hydro's Cumulative Effects Assessment, and would certainly not be experienced by any of the three critical receptors identified in Ontario Hydro's EA.

        "Mental retardation is the most likely type of developmental abnormality to appear in the human species. In essence, analysis as a function of time showed that the probability of radiation-induced mental retardation is essentially zero with exposure before 8 weeks from conception, is maximum with irradiation between 8 and 15 weeks, and decreases between 16 and 25 weeks."

        UNSCEAR, New York, 1988, p.37
        United Nations: Sources, Effects and Risks of Atomic Radiation

      [ UNSCEAR = U.N. Scientific Committee on the Effects of Atomic Radiation. ]

    4. Apparently, mental retardation can result if a developing foetus is exposed to radiation at a time when the central nervous system and the brain are being formed. It appears that radiation-induced mental retardation may be a linear non-threshold effect -- one which depends on radiation dose in a linear or straight-line fashion, meaning that there is no absolutely safe dose; i.e., no dose so low that no retardation is experienced.

    5. We have seen that the U.S. National Academy of Sciences has reported:

        "In humans, mental retardation is the best documented of the developmental abnormalities following radiation exposure.... In those irradiated between weeks 8 and 15 the prevalence of mental retardation appeared to increase with dose in a manner consistent with a linear, non-threshold response although the data do not exclude a threshold."

        BEIR V, Washington, 1989, p.362
        U.S. National Academy of Sciences.
        Health Effects of Exposure to Low Levels of Ionizing Radiation.

      [ BEIR Committee = Committee on the Biological Effects of Ionizing Radiation. ]

    6. Nor is mental retardation (indicated by a smaller brain size) the only harmful developmental effect of pre-natal exposure to tritium. In 1980, even before mental retardation had been identified as a significant radiation-induced effect, the US National Academy of Sciences BEIR-III Committee reported:

        "Because tritium (hydrogen-3) is a potential pollutant from nuclear energy production, its effect on development [of unborn babies] has been the subject of a number of studies.

        Tritiated water (HTO) is a common chemical state of tritium, and it has easy and rapid access to living cells, including those of the embryo or foetus.

        HTO administered in the drinking water to rats throughout pregnancy produced significant decreases in relative weights of brain, testes, and probably ovaries ... and produced weight decreases in a number of organs at higher doses.

        The total damaging dose cannot yet be estimated. Relative brain weight was found to be reduced at only 0.3 rads per day (one microcurie per millilitre of drinking water) when exposure began at the time of the mother's conception.

        Even lower exposures (0.003 rads per day and 0.03 rads per day) have been implicated in the induction of behavioral damage, such as delayed development of the righting reflex and depressed spontaneous activity."

        BEIR-III, pp. 485-486

        "Until an exposure has been clearly established below which even subtle damage does not occur, it seems prudent not to subject the abdominal area of women of child-bearing age to quantities of radiation appreciably above background, unless a clear health benefit to the mother or child from such an exposure can be demonstrated."

        BEIR-III, Washington, 1980, p. 493
        U.S. National Academy of Sciences.
        The Effects on Populations of Exposure
        to Low Levels of Ionizing Radiation        .

      [ BEIR Committee = Committee on the Biological Effects of Ionizing Radiation. ]

    7. Even earlier, in 1977, the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) published reviews of the scientific literature documenting a wide range of genetic damage and developmental defects caused by tritium exposure in experimental animals:

        "During the past few years, there has been a growing interest in the study of the biological effects of radioisotopes, particularly of plutonium-239 and tritium.

        A number of genetic and cytogenetic studies that have so far been carried out in mice demonstrate that these isotopes are capable of inducing dominant lethals   [ i.e. lethal mutations ] , chromosome aberrations and point mutations (for the last category, only the effects of tritium have been studied)....

        In view of possible levels of tritium release, not only from existing nuclear installations but also from contemplated controlled thermonuclear reactors, these data are of great relevance." (emphasis added)

        UNSCEAR 1977,
        Report to the United Nations:
        Sources and Effects of Ionizing Radiation.
        Annex H: Genetic Effects of Radiation        .

      [ UNSCEAR = U.N. Scientific Committee on the Effects of Atomic Radiation. ]

    8. The Chippewas of Nawash are dismayed that none of the best-documented health effects of exposure to ionizing radiation -- cancer, genetic damage, and developmental defects including mental retardation -- are discussed at all in Ontario Hydro's Cumulative Effects Assessment. The regulatory standards seem more important than the people those standards are claimed to protect. Having now had an opportunity to examine the authoritative literature in this regard, we can have little or no confidence in the "comprehensiveness" of the "comprehensive" study as prepared by Ontario Hydro and approved by the atomic regulator and Responsible Authority (AECB).

    9. The Chippewas of Nawash believe that Ontario Hydro has failed to produce an adequate acceptable Cumulative Effects Assessment. The fact that the foetus and pregnant women are not regarded as critical receptors is perhaps indicative of something more profound -- an unwillingness on Hydro's part to acknowledge the possible biological effects of radioactive pollution emanating from its BNPD into our traditional waters.


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    VII. D.   Conclusions regarding the present cumulative effects assessment 


    1. In light of the foregoing information, particularly regarding the treatment of critical receptors in the Comprehensive Study , we are determined that these issues be openly and fully discussed. We hope and trust that the process will now afford us such a forum, through means of public hearings.

    2. We believe that this issue of cumulative assessment of radioactive contaminant discharges from the BNPD concerns all residents in the Bruce area, and indeed Ontario and elsewhere.

    3. The discussion of cumulative impacts in the Comprehensive Study is, we find to our concern, limited to mechanical and cursory mention, and descriptive treatment to varying degrees, of various spatial, temporal, radiological and socio-economic considerations. Most of the cumulative effects that are significant to us are minimized, and it is hard to believe from this analysis that the proposed UFDSF is part of a highly invasive, socially contentious and problem-plagued broader industry at all, and also that this assessment process is not disposed to a particular outcome.

    4. The actual assessment in the Comprehensive Study has been undertaken in isolation from full consideration of the environmental and social effects of the nuclear fuel cycle of which it is part. This nuclear fuel cycle obviously includes the production of nuclear waste in reactors at the Bruce Nuclear Power Development ("BNPD") and the subsequent permanent storage or "disposal" of nuclear waste elsewhere (for example in deep geological facilities), not to mention other aspects of the nuclear fuel chain from uranium mining to nuclear weapons.

    5. This failure to fully embrace cumulative analysis  is unacceptable to us, because the public and First Nations peoples must be made fully aware of how this proposal fits into the nuclear "big scheme of things". In addition, it is essential to us that these matters be assessed as a composite whole, which they obviously are, rather than at a disaggregated level.

    6. To our mind, the approach taken in the Comprehensive Study is similar to the idea of assessing the overall health of a person through thorough examination of one part of his body only, for example the lower gastro-intestinal tract, while merely mentioning in passing that the person has eyes, ears, limbs, hair and other body parts and systems. Such an approach may yield interesting results. However it is clear to us that without a full physical, psychological, spiritual and social examination, including his interaction with his environment, family and community, one cannot possibly gain a full and accurate understanding of the person's real health.

    7. This is our understanding of the intent of the requirement for cumulative assessment in the CEA Act, namely to consider things as a whole. That requirement is consistent with our approach to the environment, our traditional laws, and respect for the Earth.

    8. To approach this proposed facility in such a disaggregated manner and thereby ignore or overrule our concerns is not only likely to bring the Canadian Environmental Assessment Act into disrepute among our people, but also to compel us to express our concerns about this proposal in whatever other forums we can access that may be more responsive. Our economic and cultural survival is too important for us to permit our concerns on respect of the full range of cumulative assessment of such a long-lived and invasive undertaking, in our traditional lands and waters, to be ignored. 


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    VIII.   ISSUES RELATED TO THE NORMAL AND ABNORMAL OPERATION OF THE BUFDSF


    VIII. A.   Nature of High-Level Radioactive Waste 


    1. We have come to understand that the safe and secure long-term storage of irradiated nuclear fuel ranks in the forefront of unsolved human problems. We have learned that irradiated nuclear fuel contains a bewildering variety of extremely toxic radioactive materials, most of them artificial (that is, not existing in nature in any measurable amounts prior to the advent of nuclear fission). We have read that this mix of radioactive poisons is capable in principle of killing or injuring an enormous number of people, and that it will remain dangerous for periods of time that dwarf the span of human history. The radionuclides in irradiated fuel are also potentially harmful to other living things, and hence to our mother the Earth. We wondered: where do all these artificial radioactive materials come from? A brief explanation would seem to be in order, even if it is a bit technical. However none is given in Ontario Hydro's documents.

    2. We understand that, before it is used as fuel in a nuclear reactor, a CANDU fuel bundle is not so dangerous. A fresh CANDU fuel bundle consists of a large number of uranium pellets stacked inside dozens of hollow metallic rods (called "fuel sheaths") which are then welded shut. These rods (or "fuel elements") are in turn welded together to form a metallic assembly -- a CANDU fuel bundle, about the size of a fireplace log. A fresh CANDU fuel bundle is not intensely radioactive. Most of its radiation, due to the presence of uranium, is alpha radiation, which -- while dangerous inside the body -- cannot even penetrate through a sheet of paper and thus poses no external radiation hazard. Only a small amount of penetrating radiation is given off by fresh fuel bundles; they can therefore be safely handled for short periods of time.

    3. Inside the nuclear reactor, however, the fuel bundles are bombarded with neutrons, causing violent and dramatic changes to take place in the subatomic structure of the uranium pellets and of the zirconium sheaths:

      • Many of the uranium-235 atoms are split or fissioned, resulting in the production of dozens of different kinds of radioactive materials called "fission products". Some of these are gases and vapours, and a portion of these migrate into the "gap" -- the space between the uranium fuel pellets and the zirconium sheath. (If the sheath is damaged, they are released.)

      • Many of the uranium-238 atoms absorb one or more neutrons without splitting; these atoms then undergo further radioactive transmutations to become transuranic elements (transuranic means heavier than uranium), often referred to as actinides: isotopes of plutonium, neptunium, americium, curium, et cetera, and their decay products. The actinides also include isotopes of uranium and thorium and their decay products.

        (Some of the plutonium atoms formed in the core of the reactor undergo fission, resulting in additional fission products.)

      • Many of the manufacturing impurities in the fuel absorb one or more neutrons, transforming them into radioactive materials called "fuel impurity activation products".

      • Many of the materials in the zirconium sheath (including impurities) absorb one or more neutrons, thereby becoming transformed into radioactive materials called "zircaloy activation products". This process also embrittles the sheath, making it more susceptible to the formation of pin-holes, cracks, blisters, and other defects, which may allow radioactive materials from the fuel to escape from the bundle.

    4. We now know that there are four kinds of atomic radiation: alpha, beta, gamma, and neutron. Gamma rays and neutrons are highly penetrating forms of atomic radiation; alpha rays and beta rays are not. Penetrating radiation is a hazard at a distance, requiring no direct contact to cause harm. Non-penetrating radiation requires quite close contact -- often internal to the body (inhaled, ingested, or absorbed through the skin) or on the outside surface of the body (e.g. skin contact or eye contact, esp. for beta emitters). For example, tritium is a beta emitter, and as such it is almost entirely an internal hazard. On the other hand, krypton-85 is a gamma emitter, so it is an external hazard as well as an internal hazard. Fission products are gamma and beta emitters, while many of the actinides (but not all) are alpha emitters.

    5. We wish to challenge Ontario Hydro's tendency to compare all radiation exposures to "background" radiation exposure. To the best of our knowledge, the natural background levels of fission products such as cesium-137, iodine-131, strontium-90, or actinides like plutonium-239 are ZERO. The fact that these materials have been disseminated into the environment by detonation of atomic bombs does not make them natural or acceptable. Each radionuclide has its own unique biochemical properties, making each one a unique hazard which should not be trivialized by inappropriate arithmetic.

    6. Ontario Hydro's documentation communicates no appreciation of this sense of great potential danger associated with irradiated nuclear fuel. Ontario Hydro seems to regard the problem of storing irradiated nuclear fuel, whether on a temporary or permanent basis, as an elaborate but straightforward technological matter, posing little or no potential threat to health, safety or the environment. The Chippewas of Nawash find Hydro's attitude disquieting. We believe that decisions regarding the storage of such dangerous materials, either on a temporary or permanent basis, requires the widest possible public debate.

    7. Accordingly, an independent environmental assessment conducted by a panel with public hearings is needed in connection with Ontario Hydro's proposal to store irradiated fuel from the Bruce A and B reactors in above-ground dry storage containers outside the confines of the respective reactor buildings.


    . . . back to [ TABLE OF CONTENTS ]

    VIII. B.   The Inventory of Radioactive Poisons in a Used Fuel Bundle 


    1. Exactly how many different radioactive poisons (or "radionuclides") are contained in one of these dry storage containers? Ontario Hydro addresses this question by stating that :

        "Each BDSC   [ BDSC is a Bruce Dry Storage Container ]   contains 600 used fuel bundles; 25 trays with 24 bundles in each tray. The radionuclide inventory in each container was calculated using ORIGEN S   [ ORIGEN-S is the name of a computer program used in the nuclear industry to predict the kinds and quantities of radioactive materials to be found in irradiated fuel at any time ]   and is listed in Tables 3-1 and 3-2."

        Section 3.1.4, 1997 Safety Report

    2. Table 3-1 of Hydro's Safety Report, entitled "Fission Product Inventory of one BDSC", lists 56 different radioactive substances.

      Table 3-2 of the Safety Report, entitled "Actinide Inventory of one BDSC", lists 39 other radioactive substances.

      Thus Ontario Hydro identifies a total of 95 different radioactive poisons, each of them having its own unique set of chemical and biological properties. For example,

        radioactive strontium-90 is chemically similar to non-radioactive calcium, and when it enters a living body, it goes wherever calcium normally goes -- to the bones, the teeth, and the milk; strontium-90 can cause bone cancer and blood disorders, and is easily passed on to a nursing infant.

        Radioactive iodine-129 behaves chemically like ordinary non radioactive iodine; it goes to the thyroid gland (in the throat), where it can cause cancer and a variety of other medical conditions, including developmental problems in young children.

        Radioactive cesium-137 behaves like potassium, so it goes to the fleshy parts of fish and animals.

      These particular substances (strontium-90, iodine 129, cesium-137) are biologically and chemically active, as well as radioactive; they tend to concentrate in food chains and to accumulate in the bodies of creatures which ingest food contaminated with these substances.

    3. As it happens, Ontario Hydro's radioactive inventory in its EA is far from complete . A document published in August 1989 by Atomic Energy of Canada Limited (AECL-9881) lists 211  different radioactive poisons contained in a typical ten year old fuel bundle from a Bruce A reactor, using the same assumptions and the same "ORIGEN-S" computer code as Hydro (see "Appendix 2" to this report). Thus, using the same assumptions and tools, AECL lists over twice as many (2.22 times as many) different radioactive substances as does Hydro; and AECL indicates that even its lists (which are summarized in the information below) are themselves not necessarily complete.

    4. The following chart identifies 211 radioactive poisons which are present in every ten-year old irradiated CANDU fuel bundle. The list is not a complete one. These data, compiled from AECL-9881, refer to the radioactive contents of irradiated fuel from the Bruce A reactors.

    5. The origin of each radioactive poison is indicated in the chart below:

      • F.P. indicates ''Fission Products'': these are the broken pieces of atoms which were split or fissioned in the reactor to produce energy.

      • F.I.A.P. indicates ''Fuel Impurity Activation Products'': during fission, impurities in the fuel become radioactive by absorbing neutrons.

      • Z.A.P. indicates ''Zircaloy-4 Activation Products'': elements in the zirconium sheath also become radioactive by absorbing neutrons.

      • ''Actinides'' refer to the radioactive decay products of uranium and the trans-uranium (heavier-than-uranium) elements created during fission, when uranium atoms absorb one or more neutrons.

      In the chart,

      • a single yen-sign   ¥   indicates the presence of a particular radioactive poison;

      • a triple yen-sign   ¥ ¥ ¥   indicates the presence of over a million becquerels of that radioactive poison
          - per kg of uranium fuel (for FP, FIAP, and Actinides) or
          - per kg of zirconium alloy (for ZAP).

      The list is organized according to the electric charge of the nucleus (the so-called "atomic number"), from the smallest charge (Hydrogen-3, also known as "tritium") to the largest charge (Californium-252).

      Within each chemical species, the radioactive varieties (called "isotopes" or "nuclides") are organized according to the mass of the nucleus (indicated by the accompanying number in the chart, called the "mass number").

      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      HHydrogen
      (Tritium)      		3¥ ¥ ¥¥¥ 
      BeBeryllium10 ¥¥ 
      CCarbon14 ¥ ¥ ¥¥ ¥ ¥ 
      SiSilicon32 ¥¥ 
      PPhosphorus32 ¥¥ 
      SSulphur35 ¥  
      ClChlorine36 ¥  
      Ar
      Ar      		Argon
      Argon      		39
      42      		 ¥
      ¥      		¥
      ¥      		 
      K
      K      		Potassium
      Potassium      		40
      42      		 ¥
      ¥      		 
      Ca
      Ca      		Calcium
      Calcium      		41
      45      		 ¥
      ¥      		 
      ScScandium46 ¥  
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      VVanadium50  ¥ 
      MnManganese54 ¥¥ ¥ ¥ 
      Fe
      Fe      		Iron
      Iron      		55
      59      		 ¥ ¥ ¥¥ ¥ ¥
      ¥      		 
      Co
      Co      		Cobalt
      Cobalt      		58
      60      		 ¥
      ¥ ¥ ¥      		¥
      ¥ ¥ ¥      		 
      Ni
      Ni      		Nickel
      Nickel      		59
      63      		 ¥
      ¥ ¥ ¥      		¥ ¥ ¥
      ¥ ¥ ¥      		 
      ZnZinc65 ¥¥ 
      SeSelenium79¥ ¥ ¥   
      Kr
      Kr      		Krypton
      Krypton      		81
      85      		¥
      ¥ ¥ ¥      		   
      RbRubidium87¥   
      Sr
      Sr      		Strontium
      Strontium      		89
      90      		¥
      ¥ ¥ ¥
      ¥      		¥
      ¥      		 
      Y
      Y      		Yttrium
      Yttrium      		90
      91      		¥ ¥ ¥
      ¥      		¥¥
      ¥      		 
      Zr
      Zr      		Zirconium
      Zirconium      		93
      95      		¥ ¥ ¥
      ¥      		¥
      ¥      		¥ ¥ ¥
      ¥      		 
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      Nb
      Nb
      Nb
      Nb
      Nb      		Niobium
      Niobium
      Niobium
      Niobium
      Niobium      		92
      93m
      94
      95
      95m
      ¥ ¥ ¥
      ¥
      ¥
      ¥
      ¥
      ¥
      ¥      		¥
      ¥ ¥ ¥
      ¥ ¥ ¥
      ¥
      ¥      		 
      MoMolybdenum93 ¥¥ 
      TcTechnetium99¥ ¥ ¥¥¥ 
      Ru
      Ru      		Ruthenium
      Ruthenium      		103
      106      		¥
      ¥ ¥ ¥      		   
      Rh
      Rh      		Rhodium
      Rhodium      		103m
      106      		¥
      ¥ ¥ ¥      		   
      PdPalladium107¥ ¥ ¥   
      Ag
      Ag
      Ag
      Ag
      Ag      		Silver
      Silver
      Silver
      Silver
      Silver      		108
      108m
      109m
      110
      110m      		¥
      ¥
      ¥
      ¥
      ¥      		¥
      ¥ ¥ ¥
      ¥
      ¥
      ¥      		¥
      ¥
      ¥
      ¥
      ¥      		 
      Cd
      Cd
      Cd
      Cd      		Cadmium
      Cadmium
      Cadmium
      Cadmium      		109
      113
      113m
      115      		¥
      ¥
      ¥ ¥ ¥
      ¥      		¥¥
      ¥
      ¥      		 
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      In
      In
      In
      In      		Indium
      Indium
      Indium
      Indium      		113m
      114
      114m
      115
      ¥
      ¥      		¥
      ¥
      ¥
      ¥      		 
      Sn
      Sn
      Sn
      Sn
      Sn
      Sn
      Sn      		Tin
      Tin
      Tin
      Tin
      Tin
      Tin
      Tin      		113
      117m
      119m
      121m
      123
      125
      126
      ¥
      ¥ ¥ ¥
      ¥
      ¥
      ¥ ¥ ¥
      ¥      		¥
      ¥
      ¥ ¥ ¥
      ¥ ¥ ¥
      ¥
      ¥      		 
      Sb
      Sb
      Sb
      Sb      		Antimony
      Antimony
      Antimony
      Antimony      		124
      125
      126
      126m      		¥
      ¥ ¥ ¥
      ¥
      ¥ ¥ ¥      		 ¥
      ¥ ¥ ¥
      ¥      		 
      Te
      Te
      Te
      Te
      Te      		Tellurium
      Tellurium
      Tellurium
      Tellurium
      Tellurium      		123
      123m
      125m
      127
      127m      		¥
      ¥
      ¥ ¥ ¥
      ¥
      ¥      		 ¥
      ¥
      ¥ ¥ ¥
      ¥
      ¥      		 
      IIodine129¥ ¥ 
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      Cs
      Cs
      Cs      		Cesium
      Cesium
      Cesium      		134
      135
      137      		¥
      ¥ ¥ ¥
      ¥ ¥ ¥      		   
      BaBarium137m¥ ¥ ¥   
      LaLanthanum138¥   
      Ce
      Ce      		Cerium
      Cerium      		142
      144      		¥
      ¥ ¥ ¥      		   
      Pr
      Pr      		Praesodymium
      Praesodymium      		144
      144m      		¥ ¥ ¥
      ¥ ¥ ¥      		   
      NdNeodymium144¥   
      PmPromethium147¥ ¥ ¥   
      Sm
      Sm
      Sm
      Sm      		Samarium
      Samarium
      Samarium
      Samarium      		147
      148
      149
      151      		¥
      ¥
      ¥
      ¥ ¥ ¥
      ¥      		  
      Eu
      Eu
      Eu      		Europium
      Europium
      Europium      		152
      154
      155      		¥ ¥ ¥
      ¥ ¥ ¥
      ¥ ¥ ¥      		¥
      ¥
      ¥      		  
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      Gd
      Gd      		Gadolinium
      Gadolinium      		152
      153      		¥
      ¥      		¥
      ¥      		  
      Tb
      Tb      		Terbium
      Terbium      		157
      160      		 ¥
      ¥      		  
      DyDysprosium159 ¥  
      HoHolmium166m¥¥  
      Tm
      Tm      		Thulium
      Thulium      		170
      171      		 ¥
      ¥      		  
      Lu
      Lu
      Lu      		Lutetium
      Lutetium
      Lutetium      		176
      176
      176      		  ¥
      ¥
      ¥      		 
      Hf
      Hf
      Hf      		Hafnium
      Hafnium
      Hafnium      		175
      181
      182      		  ¥
      ¥
      ¥      		 
      Ta
      Ta      		Tantalum
      Tantalum      		180
      182      		  ¥
      ¥      		 
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      W
      W
      W      		Tungsten
      Tungsten
      Tungsten      		181
      185
      188      		  ¥
      ¥
      ¥      		 
      Re
      Re      		Rhenium
      Rhenium      		187
      188      		  ¥
      ¥      		 
      OsOsmium194  ¥ 
      Ir
      Ir
      Ir
      Ir      		Iridium
      Iridium
      Iridium
      Iridium      		192
      192m
      194
      194m      		  ¥
      ¥
      ¥
      ¥      		 
      PtPlatinum193  ¥ 
      Tl
      Tl
      Tl
      Tl      		Thallium
      Thallium
      Thallium
      Thallium      		206
      207
      208
      209      		  ¥
      ¥
      ¥
      ¥
      Pb
      Pb
      Pb
      Pb
      Pb
      Pb
      Pb      		Lead
      Lead
      Lead
      Lead
      Lead
      Lead
      Lead      		204
      205
      209
      210
      211
      212
      214      		  ¥
      ¥

      ¥
      ¥
      ¥
      ¥
      ¥
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      Bi
      Bi
      Bi
      Bi
      Bi
      Bi
      Bi      		Bismuth
      Bismuth
      Bismuth
      Bismuth
      Bismuth
      Bismuth
      Bismuth      		208
      210
      210m
      211
      212
      213
      214      		  ¥
      ¥
      ¥
      ¥
      ¥
      ¥
      ¥
      Po
      Po
      Po
      Po
      Po
      Po
      Po
      Po      		Polonium
      Polonium
      Polonium
      Polonium
      Polonium
      Polonium
      Polonium
      Polonium      		210
      211
      212
      213
      214
      215
      216
      218      		  ¥¥
      ¥
      ¥
      ¥
      ¥
      ¥
      ¥
      ¥
      AtAstatine217   ¥
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product      		Actinide
      (includes progeny)
      Rn
      Rn
      Rn      		Radon
      Radon
      Radon      		219
      220
      222      		   ¥
      ¥
      ¥
      Fr
      Fr      		Francium
      Francium      		221
      221      		   ¥
      ¥
      Ra
      Ra
      Ra
      Ra
      Ra      		Radium
      Radium
      Radium
      Radium
      Radium      		223
      224
      225
      226
      228      		   ¥
      ¥
      ¥
      ¥
      ¥
      Ac
      Ac
      Ac      		Actinium
      Actinium
      Actinium      		225
      227
      228      		   ¥
      ¥
      ¥
      Th
      Th
      Th
      Th
      Th
      Th
      Th      		Thorium
      Thorium
      Thorium
      Thorium
      Thorium
      Thorium
      Thorium      		227
      228
      229
      230
      231
      232
      234      		   ¥
      ¥
      ¥
      ¥
      ¥
      ¥
      ¥ ¥ ¥
      Standard Chemical SymbolCommon Name of elementAtomic Mass
      Number      		F.P.
      Fission
      Product      		F.I.A.P.
      Activation Product      		Z.A.P.
      Activation Product