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To:
Interventions
Canadian Nuclear Safety Commission (CNSC)
280 Slater St., P.O. Box 1046
Ottawa , Ontario K1P 5S9
Canada
E-mail: interventions@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.
December 12, 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
Earlier today, accident scenarios with probabilities of one in a million or one in ten million chance of occurrence were discussed. We cannot know the probability of a terrorist attack upon the Bruce nuclear plant, but it is certainly significant to address the threat. It is remarkable that terrorist threats to the Bruce nuclear reactors have been arbitrarily determined to be outside the scope of the Environmental Assessment we are discussing today. Yet, those very terrorist threats are the elephant sitting in the middle of the room which we are supposed to ignore and not talk about. 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). Recent news articles highlight the danger of terrorist attacks upon nuclear reactors and radioactive waste storage depots. In June, threats of radiological “dirty bombs” grabbed headlines after the arrest of an alleged Al Qaida “dirty bomber” about to begin his scouting mission. In September, an interview with al Qaida leaders revealed that the original targets for the Sept. 11 th, 2001 terrorist attacks upon the United States may have been nuclear facilities. On Nov. 6, the New Brunswick Telegraph-Journal reported that Mounties protecting the Point Lepreau reactor were 'burnt out'; this begs the question, what is the state of security at Bruce? The most recent al Qaida taped threat, aired on the Arab satellite television network Al Jazeera a month, recorded Osama bin Laden's voice explicitly naming Canada as a potential target for future terrorist attack. Also in mid-November, on the eve of U.S. Secretary of State Colin Powell’s visit, Canada’s National Post reported on a leaked U.S. government document listing 22 potential terrorist targets in Canada, including the Pickering, Point Lepreau, and Chalk River nuclear facilities; Bruce was conspicuous by its absence. Just yesterday, the Calgary Herald ran the headline “Terrorists Will Target Canada: RCMP Fears Retaliation If U.S. Attacks.” And in recent days, headlines announced that US troops would be allowed to enter Canadian territory to counter a terrorist strike. Thus, to the “cost” column for nuclear power must be added loss of sovereignty and police state tactics.
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. Electricity conservation, electricity efficiency, and renewable sources of electricity are not vulnerable to catastrophic terrorist attack. They are also safer, cheaper, cleaner, and more reliable than restarting two more reactors at Bruce.
HARMFUL CONSEQUENCES OF CATASTROPHES AND EVEN ROUTINE RELEASES
It’s quite incredible that the EA claims that even a major reactor accident would have no long-lasting significant impact on the environment or public health. Just look at a real world nuclear catastrophe, Chernobyl. The woefully inadequate attempts to deal with Chernobyl have cost hundreds of billions of dollars but have barely scratched the surface of what is needed. The extent of human suffering and ecological ruination still on-going in the aftermath of Chernobyl is a story that goes largely untold to this day, not altogether unintentionally. 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 and the CNSC EA Screening 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 EA Screening Report.
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 and food grown in the area. Tritium can replace natural hydrogen anywhere in the human body, right down to the level of DNA, where it can cause genetic damage. Tritium has a 12 year half life, meaning it retains its hazard for decades into the future.
Although Bruce Power claims nuclear power is environmentally friendly, 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. Such releases of toxins and radioactivity into Lake Huron flies in the face of the International Joint Commission’s call for virtual elimination and zero discharge of persistent toxic emissions into the Great Lakes.
First Nations often bear the brunt of the harmful consequences of nuclear power. Uranium mining at Serpent River First Nation is an example of that. Bruce Power’s EA has ignored the fact that the First Nations near Bruce have a traditional diet that makes them even more vulnerable to harm from radiation than other populations. The claim from Bruce Power’s representatives, that impacts on First Nation health will be looked at during the EA follow-up program, is simply unacceptable. It amounts to nuclear experimentation on the health of human beings.
To add to the earlier discussion of impingement, entrainment, thermal pollution, etc. and the effects on fisheries, I would like to enter into the official record a copy of a report prepared by my organization, Licensed to Kill. This report documents how the nuclear reactors destroy aquatic wildlife and habitat, and how regulatory agencies allow it to happen. This report can shed some more light on the impact of the Bruce restart upon First Nation fisheries in Lake Huron.
BRITISH ENERGY’S FINANCIAL MELTDOWN/BRUCE POWER’S UNCERTAIN FUTURE
Bruce Power’s majority owner, British Energy, is still is desperate financial straits. BE is now in a rush to off-load its share in Bruce Power as quickly as possible. Companies that may take over the operations of Bruce Power include a uranium mining firm and a pipeline firm, none of which have experience running reactors. 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. Given the current chaos, the rush towards restart, and the validity of assumptions about Bruce Power’s operations, should be seriously reconsidered.
MERIT OF PROPOSAL, OR LACK THEREOF
Has the Bruce restart been driven by an ill-conceived effort to export profits to Great Britain and electricity to the United States? Our organization recently learned of a proposal, called Lake Erie Link, to run electricity transmission lines from Ontario to the U.S. A spokesman for the proposed Link admitted that over 50% of the electricity would originate from Ontario’s nuclear reactors.
U.S. CITIZENS GROUPS SYSTEMATICALLY PLACED AT SEVERE DISADVANTAGE
Bruce Power’s representatives earlier bragged about their extensive outreach to members of the public. Such efforts completed ignored and neglected the public on the U.S. side of the border, leaving us in the dark. For its part, the CNSC has not offered to fund the efforts of concerned U.S. citizens groups to hire technical experts to analyze the proposed restart’s environmental impacts. Quite to the contrary, the CNSC even refused to extend the public comment period 60 days. It seems that Bruce Power’s bottom line is driving this process at very high speed.
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. For these reasons, the EA should be subjected to a full panel review independent of Bruce Power and CNSC.
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