September 15, 2000

MOX Comments Officer
Transport Dangerous Goods Directorate
Transport Canada

Campaign for Nuclear Phaseout Comments on

Atomic Energy of Canada’s Emergency Response Assistance Plan Emergency Response Assistance Plan (ERAP) for MOX Fuel Shipment from Moscow to Chalk River, Ontario (PARALLEX Project 100-37000-TD-007, Revision 1)

1. Introduction

First, I would like to emphasize that the Campaign for Nuclear Phaseout remains firmly opposed to the Chrétien government’s plan to import weapons plutonium fuel into Canada.

The serious flaws in AECL’s original plans and its latest revision confirm our position that the federal government should call for an immediate halt to the entire plutonium fuel import project.

The risk to human health and the environment in the event of an accident involving plutonium fuel is completely unnecessary. The existence of weapons plutonium stocks is indeed one of the most perplexing hazardous waste problems facing humanity. However, the use of weapons plutonium as a reactor fuel will serve to compound this problem. In this regard, it is unfortunate that the Chrétien government has not adopted the 1998 all-party Standing Committee on Foreign Affairs and International Trade recommendation to scrap the project.

The Chrétien government continues to push the import weapons plutonium in face of evidence that the project will aggravate nuclear proliferation. This underscores the real goal behind the initiative, to provide a new lease on life for Canada’s dying nuclear industry.

2. Failure to deal with the potential spread of plutonium dust

On August 17th Transport Canada requested AECL address the issue of the spread of plutonium powder in the event of an accident. AECL’s revised Emergency Response Assistance Plan of September 2000 fails to adequately address this issue.

AECL’s description of the materials shipped (page 4) states that: “The MOX fuel will not explode, ignite or react with air or water. The properties of the MOX fuel material are such that high velocity impact tests do not generate a significant portion of the fuel as a fine powder that could be dispersed in an accident.” AECL does not provide any references for these assertions. Indeed, in his August 25th submission to Transport Canada on AECL’s previous ERAP, Dr. Ed Lyman of the Washington-based Nuclear Control Institute counters much of these assumptions and provides references to back up his claims (see pages 4 and 5 of Dr. Lyman’s submission). In light of the evidence provide by Dr. Lyman, Transport Canada should reassess AECL’s claims on the dispersibility of plutonium fuel.

Page 14 of the ERAP describes the fact that the Initial Response Team (IRT) will have decontamination equipment at its disposal. However, nowhere is there a description of how this equipment would effectively prevent or contain the dispersal of plutonium powder in the air. Moreover, there would be a three to six hour delay in responding to an accident (see page 12 of AECL’s ERAP). This amount of time may be far too late to adequately ensure the spread of plutonium powder. This problem is compounded by the fact that the Radiological Assessment Team (RAT) leader would “…make the determination if additional resources are required, and communicate this to the SEO” (p.16). This could mean several more hours of delay in additional emergency responders getting to the scene of an accident.

AECL’s revised ERAP acknowledges that emergency responders in the perimeter team will be dressed in special protective clothing, including full faces respirators and double rubber gloves (see AECL’s ERAP pages 16 and 17). In previous publicly made statements by AECL, it was claimed that a piece of paper would be enough to block the radiation in the event of an accident (See for example, The Montreal Gazette, March 23, 1999, p. A11, “Even if an accident happened en route, [AECL spokesperson, Larry Shewchuck] said, ‘all you’d need to block the radioactivity from hitting you would be a single piece of paper.’ ” See also: the Calgary Herald, April 27, 1999, p. A9) This admission on the part of AECL is important. It means that the consequences of an accident are potentially more harmful than it has acknowledged in communications with the media and that it may indeed be difficult to control the spread of plutonium powder.


3. Limitations of the ERAP process vis-à-vis nuclear materials

A major underlying assumption of AECL’s ERAP and Transport Canada’s treatment of it, is that nuclear power is a viable option and that emergencies involving nuclear materials can be effectively managed in a similar manner to other hazardous materials. Due to the extreme toxicity of plutonium (an element contained not only in weapons of mass destruction but also in spent nuclear reactor fuel) emergencies involving this type of material require different types of consideration in the event of an emergency situation. A more comprehensive approach to an emergency matters is required prior to embarking on the transportation of nuclear materials such as plutonium.

In a recent letter dated September 14, 2000 from Mr. John Read, Director General of Dangerous Goods Directorate to Theresa McClenaghan of the Canadian Environmental Law Association, it is revealed that “…clean-up is not required within the scope of an emergency response assistance plan.” This is a major limitation of the ERAP process, whether it involves nuclear materials or other hazardous materials.

However, in the case before us, the transportation of plutonium fuel, there is a great deal of uncertainty as to whether the spread plutonium powder can actually be contained or even cleaned-up. For this reason, and for the sake of public health and safety, Transport Canada should demand well-substantiated proof from independent sources that AECL and emergency responders can actually deal not only with the immediate consequences of an accident, but the long term implications.

On this front, AECL does not have a good track record. For example, in May 1999, two AECL workers from its Chalk River labs were overdosed with plutonium. The Canadian Nuclear Safety Commission (CNSC) has laid charges against AECL in connection with this incident and the case is still before the courts. Moreover, it is a matter of public record that there is little if any capacity to deal with radioactively contaminated casualties within Canada’s medical infrastructure.


4. New AECL data

At a public meeting at the Université du Québec à Chicoutimi, on September 14,2000, Dr. Gilles Grenier of Québec’s Régie régionale de la santé et des services sociaux revealed that he had just received new data provided by AECL pertaining to the emergency response required in the event of a plutonium fuel accident.

According to Dr. Grenier the new data show that in the event of an accident the zone of contamination would be much greater than AECL has stated previously and may require an evacuation plan affecting residents within several kilometers of an accident (See: Normand Boivin, “Transport du MOX; Les spécialistes contredisent les données”Le Quotidien, September 15, 2000, page 3, attached)

We request that Transport Canada make this new data publicly available, ensure independent evaluation of the data and accordingly extend the deadline for public comment on AECL’s ERAP.


5. Conclusion

Given the Chrétien government’s ongoing efforts to prop up Canada’s nuclear industry at every opportunity, there is undoubtedly enormous pressure at the Ministerial level on Transport Canada to approve AECL’s emergency plans. In spite of this, Transport Canada should listen to the wishes of Canadians and to the evidence it has received from independent experts such as Dr. Ed Lyman and deny AECL permission to transport plutonium fuel from Russia by air. The risks to the environment and human health simply do not warrant Transport Canada’s complicity with the project.

On behalf of the Canadian Environmental Law Association, Sierra Club of Canada, Mouvement Vert Mauricie, Canadian Coalition for Nuclear Responsibility and the Campaign for Nuclear Phaseout, I have appended as part of this submission a news release dated September 14th.

Please publish this submission along with our previous one on the subject dated August 25th.

August 25, 2000

MOX Comments Officer
Transport Dangerous Goods Directorate
Transport Canada

Campaign for Nuclear Phaseout Comments on

Atomic Energy of Canada’s Emergency Response Assistance Plan Emergency Response Assistance Plan (ERAP) for MOX Fuel Shipment from Moscow to Chalk River, Ontario (PARALLEX Project 100-37000-TD-007, Revision 0)

Introduction

The Campaign for Nuclear Phaseout is opposed to the Chrétien government’s plan to import weapons plutonium fuel into Canada. This project will only serve to prop up Canada’s flagging nuclear industry. Rather than importing weapons plutonium and supporting an environmentally and economically unsustainable energy source, Canada should be phasing out nuclear power and moving towards green energy alternatives.

We object to the federal government’s faulty logic and ongoing insistence that this project will contribute to nuclear disarmament and non-proliferation. In fact, the use of plutonium fuel will contribute to the increased circulation of plutonium within civilian economies thereby increasing the risk of the diversion of plutonium and nuclear proliferation.

The goals of nuclear disarmament and nonproliferation are laudable. However, the impetus for the idea of burning plutonium in reactors comes not from the peace and disarmament community, but from the nuclear power establishments of Russia, the US and Canada —all of whom would like to see their aging reactors running for another 25 years or more.

Type “B” Shipping Container: Inadequate for Air Transport

AECL’s plans for the shipment of plutonium fuel call for the use a Type B(U)F container (AECL’s July 2000 ERAP, page 6 ). There is no credible scientific evidence that a Type B container can withstand an air crash. (See: Ed Lyman, “Inadequacy of the IAEA’s Air Transport Regulations:The Case of MOX Fuel”. See: http://www.nci.org/ib102497.htm, a copy is attached.)

The transport of plutonium fuel by air is illegal in the United States precisely because there is no container that has been deemed safe enough. Even a Type C container, as currently envisaged by the International Atomic Energy Agency (IAEA), would not be secure enough to meet US standards. Why are Canadians being asked to accept less rigorous safety standards than in the US?

Indeed, the US Department of Energy’s “Environmental Assessment for the Parallex Project Fuel Manufacture and Shipment” (January 1999) specifically ruled out air shipment of plutonium fuel within the US for the pilot project. The US environmental assessment states that “…air transport is considered to be more hazardous than ground shipment due to the potential for greater distribution of radioactive materials in the event of a major air accident.” (p. 17). AECL’s ERAP does not acknowledge the US DOE’s findings. Transport Canada should require that AECL explain this major oversight. Is the double-standard a result of Canada’s lesser experience with plutonium?

In any case, AECL’s ERAP offers no explanation as to why it felt compelled to change the transport plans for the Russian shipment. Given that authoritative sources acknowledge that the transport of plutonium fuel by air is riskier than ground transport , and that Transport Canada’s November 1999 review of AECL’s transport plans ruled out air transport (see attached copy of “Transport of Weapons Plutonium by Air, Statements by Transport Canada , the Atomic Energy Control Board, the U.S. Department of Energy and other”, CNP, February 2000) why is AECL now pursuing this option? There is tremendous opposition in Canada and internationally to the use and transport of plutonium fuel. Is AECL trying to bypass opposition on the ground by flying plutonium over Canadian airspace?

In an attempt to legitimate the use of the Type B container for the air transport of plutonium fuel from Russia, AECL describes tests in the 1970s on shipping containers “similar to the one selected for the Russian MOX shipment” (AECL’s July 2000 ERAP,p.6, emphasis supplied). Tests done three decades ago on a shipping container “similar” to the one to be used for the Russian shipment is an inadequate measure and non-comparable.

Approval of air transport of Russian MOX using a Type B container would set a North American first and establish a dangerous precedent, especially since the shipment is a high visibility one. Transport Canada should not legitimate this risky practice by allowing AECL to go forward with its airlift of weapons plutonium fuel from Russia. It may well be that AECL wants to set this precedent in order to ensure that further plutonium fuel air transport is allowed by Transport Canada for the full-scale commercial plutonium fuel project.

Lack of Effective Emergency Response to a Plutonium Fuel Accident

In an August 2nd Canadian Press article, John Read, director general of the Transport Dangerous Goods Directorate of Transport Canada, stated that AECL must show how it would “effectively respond” to the worst accidents, including the release of plutonium dust. He is quoted as saying: “If they can’t, they don’t ship.” This position is well-advised and based on AECL’s inadequate description of its emergency response, Transport Canada should refuse AECL permission to transport of plutonium fuel by air from Russia.

AECL’s emmergency response plans read more like a public relations excercise than a concrete exposition of how they will clean up after a serious accident involving plutonium fuel. How will AECL respond if plutonium becomes airborne?

The reality is that if the shipping package is damaged in a severe air crash, allowing oxygen to get to the MOX fuel, then fire —even at relatively low temperatures—a fine plutonium-bearing powder could be released into the atmosphere. Once released, such radioactive dust is extremely difficult to control, locate, or clean up. That’s why the USA has a strict law which effectively prohibits the air transport of plutonium, given the extraordinary toxicity of inhaled plutonium dust.

AECL and Minister Goodale have told Canadians that it is virtually impossible for plutonium to be released in a respirable form under any conceivable accident scenario. Yet the US Department of Energy, in a 1997 environmental assessment document, states:

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

“The first accident relates to an event that leads to the MOX fuel package container breaking open, igniting, and releasing plutonium dioxide particles into the air. The public is assumed to be near enough to the accident to breathe air contaminated with plutonium dioxide.”

The report makes it clear that this scenario, while unlikely, has “a reasonable probability of occurrence”. (Section 5.2 “MOX Transportation Accidents”)

AECL’s emergency plans states that “AECL decontamination practices are employed in the event of the spread of radioactive material onto roadways or the surrounding area” (AECL ERAP, July 2000, p. 15. Tranport Canada has not been sufficiently diligent in requiring AECL to delineate and demonstrate exactly how it would respond to the dispersal of a fine plutonium dust into the atmosphere.

Last year, two Chalk River employees were over-exposed to respirable plutonium dust even though they were wearing protective equipment. Charges have been laid against AECL by the Canadian Nuclear Safety Commission (CNSC, formerly known as the Atomic Energy Control Board) in connection with this incident.

Clearly, AECL is not experienced in dealing adequately with releases of alpha-emitting powder into the atmosphere in a respirable form, as the above incidence illustrates. Moreover, how can the Canadian public trust AECL’s decontamination practices when its own facility at Chalk River has not been properly cleaned up?

Transport Canada should not approve the emergency plan in the absence of detailed plans from AECL for identifying, locating, controlling and retrieving an atmospheric dispersal of plutonium-bearing dust, and dealing with plutonium-contaminated casualties.

Moreover, Transport Canada should not approve the emergency plan because the Canadian public, and Transport Canada itself, appears to have been misinformed about the possible consequences of credible accident scenarios. AECL should be required to publish its detailed accident analyses and subject them to independent public scrutiny.

Air Transport of Weapons Plutonium: An Unnecessary Risk

The risk to human health, the environment and security posed by the airlift of Russian plutonium fuel is completely unecessary. If Canada wants to make a meaningful contribution to addressing the problem of weapons plutonium, it should be working at the international level to end the production of plutonium, taking existing plutonium out of circulation and guarding it under a strict international security régime.

Moreover, the US Department of Energy is exploring the option of using a process called “immobilization”. This process involves mixing weapons plutonium with existing liquid high level nuclear waste and converting the mixture into ceramic blocks each weighing one ton. The advantange of this process is that it treats weapons plutonium as a dangerous hazardous waste product rather than an article of commerce. Russia is less favourable to this approach because it views the use of weapons plutonium fuel as a way of stimulating its nuclear power program. However, given the fact that Russia is dependent on funding from western nations to deal with its weapons plutonium problem, Russia could be convinced to use the immobilization option along with western funding and expertise.

Conclusion

The manner in which the weapons plutonium fuel issue has been managed in Canada has been fundamentally undemocratic. During the Fall 1999 comment period on AECL’s emergency plans, 96 percent of the submissions made to Transport Canada were opposed to the project. Nonetheless, Transport Canada approved AECL’s trasnport plans. At the last minute, without consulting the public, Transport allowed AECL to deviate from its original plan and transport plutonium fuel by helicopter.

Transport Canada’s announcement of a 28 comment period during the height of the summer vacation period is completely inadequate. It raises further public concern regarding the special treatment that the nuclear industry is receiving from Transport Canada. Transport Canada should extend the comment period until at least the end of September.

In 1998, after parliamentary hearings, the Standing Committee on Foreign Affairs and International Trade recommended that the plutonium import project be scrapped because it was found to be “unfeasible” in terms of non-proliferation objectives.

First Nations communities along with hundreds of municipalities, including 167 municipalities in Quebec, have passed resolutions against this project. In addition, the Federation of Canadian Municipalities passed a resolution against the project, as well as the Conference of Great Lakes Mayors. Firefighters and Police associations have recommended that the project not go forward.

It is time for the federal government to listen to the wishes of Canadians. At the very least, Transport Canada should not grant AECL permission to tranport plutonium fuel by air from Russia. Given the widespread opposition to the ill-conceived plutonium import plan, Transport Canada should recommend that the Government cancel the project. Transport Canada should not be a party to an initiative that will compromise the goal of non-proliferation, increase the risk of nuclear accidents and perpetuate an unviable means of generating electricity.

Note: The following documents were attached as part of the submission to Transport Canada

1) Edwin S. Lyman, “The Inadequacy of the IAEA’s Air Transport Regulations: The Case of MOX Fuel.” Edwin S. Lyman, Scientific Director, The Nuclear Control Institute

2) Paul Leventhal and Steven Dolley, “Viewpoint: The Plutonium Fallacy: An Update.” , The Nonproliferation Review, Center for Nonproliferation Studies, Monterey Institute of International Studies. Spring-Summer 1999. Volume 6, Number 3, pp75-88.

3) International Physicians for the Prevention of Nuclear War and Institute for Energy and Environmental Research, Plutonium: Deadly Gold of the Nuclear Age, International Physicians Press, Cambridge, Mass, 1992, p. 148

Campaign for Nuclear Phaseout, “Transport of Weapons Plutonium by Air” (Statements by Transport Canada, The Atomic Energy Control Board, the U.S. Department of Energy and others), February 2000.

Please publish this submission in your report.