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To:
Guy Riverin
Environmental Assessment Specialist
PFTS Division
Canadian Nuclear Safety Commission (CNSC)
280 Slater St., P.O. Box 1046
Ottawa , Ontario K1P 5S9
Canada
E-mail: ceaainfo@cnsc-ccsn.gc.ca
Fax: (613) 995-5086
From:
Kevin Kamps
Nuclear Waste Specialist
Nuclear Information & Resource Service (NIRS)
1424 16 th Street, N.W., Suite 404
Washington , D.C. 20036
U.S.A.
September 30, 2002
NIRS is an information and networking center for citizens and environmental organizations concerned about nuclear power, radioactive waste, radiation, and sustainable energy issues. NIRS has members on both sides of the border throughout the Great Lakes Basin. On behalf of our members, NIRS submits the following comments on the proposed restart of Bruce Nuclear Plant “A” Reactors 3 and 4.
TERRORIST THREAT
It is most ironic that the “Environmental Assessment Start Date” for the Bruce A reactors 3 and 4 restart was September 11 th, 2001 (Canadian Environmental Assessment Agency, FEAI Reference Number 29271). Amidst fears of radiological “dirty bombs,” and a recently reported interview with al Qaida leaders stating that the original targets for the Sept. 11 th, 2001 terrorist attacks upon the United States may have been nuclear facilities, restarting the Bruce A reactors 3 and 4 would aggravate an already high concentration of nuclear risk on the shoreline of Lake Huron. With nine reactors and the high-level radioactive wastes from them, plus extensive on-going incineration and disposal of “low” and “intermediate” level radioactive wastes from reactors across Ontario, Bruce is among the largest and most concentrated nuclear complexes in the world. Restarting the reactors would generate yet more atomic waste and enlarge the radioactive bull’s eye in the heart of the Great Lakes that the Bruce nuclear power complex already represents. The threat of a catastrophic terrorist attack upon the Bruce nuclear complex extends to eastern Michigan, just 50 miles across Lake Huron from Bruce, and to Detroit and other U.S. cities downstream which depend on Lake Huron for drinking water, fishing, tourism, recreation, industrial, and other uses. Altogether, over 30 million people depend upon the waters of the Great Lakes. Given the inestimable value of the Great Lakes and the heightened terrorist threat, restarting the Bruce A reactors is unwarranted.
HUMAN, ECOLOGICAL, AND ECONOMIC COSTS OF A CATASTROPHE
How much would it cost to recover from a catastrophic radiation release at Bruce A reactor 3 and/or 4? How much would it cost to replace the lands and waters downstream and downwind? The 1986 Chernobyl nuclear catastrophe, which has shown clearly that radioactivity does not respect national borders, has cost the governments of Ukraine, Belarus, and Russia over $350 billion ( U.S.). That is approximately $575 billion ( U.S.) in year 2002 dollars. Even that huge an amount has proven woefully inadequate to address the human suffering and ecological ruination still on-going in the aftermath of Chernobyl. Harmful radioactive contamination extends out many hundreds of miles from the destroyed Chernobyl reactor, a distance well beyond what is considered in the Bruce Power Environmental Assessment Study Report (EASR) and the CNSC EA Sreening Report. Radioactive contamination of the food supply in regions suffering Chernobyl fallout will persist for centuries, again well beyond the time period considered in the EASR and Screening Report.
The coverage of the Bruce A reactors 3 and 4 by the Canadian Nuclear Liability Act is a tacit acknowledgement that Chernobyl-like catastrophes are possible on the Lake Huron shoreline. In the event of an accident, Bruce Power and its insurance companies would only have to pay, at most, the first $75 million (Canadian) to injured families and businesses in Ontario, Michigan, and beyond. Any damages above that, up to hundreds of billions of dollars, would have to be paid by Canadian taxpayers, through an act of Parliament. Such compensation is very unlikely.
It should also be pointed out that it wouldn’t take an accident or terrorist attack for the Bruce A reactors to have significant environmental and public health impacts. Even routine releases from “normal” operations at the Bruce A reactors will have harmful human health and ecological consequences. Tritium routinely released into Lake Huron, for example, would be ingested by humans in their drinking water. Tritium can replace natural hydrogen anywhere in the human body, right down to the level of DNA, where it can cause genetic damage. Although the Bruce Power EASR executive summary states “the project provides the opportunity to avoid 100 million tonnes of carbon dioxide emissions compared with other electricity generating options,” it fails to acknowledge the harm caused to human health and the environment from uranium mining and processing, toxic and radioactive releases from routine reactor operations, and atomic waste generation.
BRITISH ENERGY’S FINANCIAL MELTDOWN
Bruce Power’s majority owner is in economic free fall. The British government has agreed to prop up British Energy’s shaky house of cards to the tune of well over a billion Canadian dollars. But even this astronomical bail out may not be enough to stop British Energy from plunging into bankruptcy. This is not a solid foundation upon which to restart additional reactors at Bruce (nor to open perhaps the world’s largest dry cask storage facility for high-level radioactive waste next to the waters of the Great Lakes, which would receive wastes from the Bruce A reactors). The danger is that major short cuts on safety will be taken in order to save money, such as cutting safety staff levels to the bone (as has been documented at British Energy atomic reactors in the UK by the UK Nuclear Installations Inspectorate) and not performing needed repairs and maintenance. For example, Atomic Energy of Canada, Ltd. recommends that CANDU reactors be retubed after 20 years of operations. The Bruce A reactors are 25 years old, yet Bruce Power plans to restart units 3 and 4 without retubing them. Desperate financial pressures for electricity production, combined with age-related degradation and short cuts on safety, would result in potentially catastrophic risk-taking.
U.S. CITIZENS AND OFFICIALS EFFECTIVELY KEPT IN THE DARK
Bruce Power’s EASR executive summary claims that it conducted extensive public consultation, and that “stakeholders were identified using a systematic process.” Yet Bruce Power, and the CNSC, have utterly failed to involve – or even notify -- concerned citizens and elected officials in the United States whose communities would be significantly impacted about the Bruce A restart proposal and decision-making process. A Screening Report is woefully inadequate to address the very significant environmental impacts that the restart of the two reactors at Bruce would represent for U.S. citizens downwind and downstream. A Full Independent Panel Environmental Assessment is very much in order. The public in the U.S. should be fully involved in the decision-making. Official and complete public hearings should be held in the U.S.. Full intervenor status and funding should be provided by the Canadian government to concerned U.S. citizens. Otherwise, legitimately concerned U.S. citizens will inevitably lack the expertise, time, and resources to adequately evaluate the Bruce A restart proposal. Because Bruce Power and CNSC failed to inform concerned citizens in the U.S., the public comment deadline should be extended at least 60 days past Sept. 30 th.
ALTERNATIVES TO THE RESTART OF BRUCE “A” REACTORS 3 AND 4
The vast monies being wasted on attempting to revive the moribund nuclear industry must be redirected to safeguarding reactors and on-site wastes against terrorist attack and wear-and-tear, age-related degradation accidents. Now is the time for an orderly phase out of atomic electricity, and a transition to conservation, efficiency, and cleaner, cheaper, safer, renewable sources of electricity. Such a transition would create a large number of new jobs which, along with the decommissioning and clean up activities at the Bruce site, would keep the workforce employed. The brand new wind turbine soon to be installed on the Bruce peninsula is a beacon pointing the way to the future.
CONCLUSION
Bruce Power and CNSC’s conclusion that there would be no significant effects of the restart on the environment is false. There would be significant effects, downwind and downstream, in both the U.S. and Canada, throughout the Great Lakes basin.
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