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To: The Canadian Nuclear Safety Commission (CNSC)
Commission Operations Officer
E-mail: interventions@cnsc-ccsn.gc.ca
Fax: (613) 995-5086

From: The Canadian Coalition for Nuclear Responsibility (CCNR)
c/o Gordon Edwards, President
E-mail: ccnr@web.ca
Fax: (514) 489-5118

Date:  April 19 2005

Re:  Environmental Assessment Guidelines re Bruce A Refurbishment for Life Extension and Continued Operations Project

CCNR is saddened but not surprised by the fact that CNSC staff has dismissed all intervenors' comments and recommendations regarding possible improvements to the environmental assessment guidelines for the Bruce A Refurbishment for Life Extension and Continued Operations Project.

Many of these comments related to the extraordinarily high radiation fields and the unusual degree of radioactive contamination in the environment to which workers will be exposed in order to achieve the goals of the corporation.

Many of the comments related to the meager opportunities for citizens and non-governmental organizations to undertake a meaningful review of this gargantuan project, due to the CNSC Staff's intention to deny any opportunity for an independent panel hearing, consequently the absence of intervenor funding, combined with the CNSC Staff's determination to roll several large projects (the refurbishment of units 1 and 2, the eventual retubing of units 3 and 4, and the switch from natural uranium fuel to slightly enriched fuel) into one low-level environmental screening review.

It has been the experience of CCNR and other organizations that independent environmental assessment panels often do a much more thorough job of investigating the prospects for off-site environmental impacts and listen more attentively to alternate points of view and to analyses presented by non-proponents than is the case in a low-level screening review.  Environmental panels often issue recommendations that incorporate information derived from a close and detailed scrutiny of the proponent's plans by other intervenors in the hearings process.  Members of the public and non-governmental organizations are able to address themselves more assiduously to the task of developing responsible critiques when they know that the panel is open to entertaining such critiques and when funding is available to finance a small but meaningful amount of independent research on the dossier. None of these conditions apply to the CNSC screening review process.

Despite the fact that workers will be carrying out a mini-decommissioning job without the benefit of the 30 to 40-year "cooling-off" (dormancy) period universally recommended for the final decommissioning of a CANDU reactor ; despite the fact that the pressure tubes and calandria tubes will be more radioactive for a greater period of time than any other waste materials ever removed from the Bruce NGS (other than irradiated fuel) ; despite the fact that the four massive steam generators, with 5000 radioactively contaminated  pipes inside each one, have never before been removed from a CANDU reactor;  despite the fact that steam generator removal will require a major breach of the containment envelope of the plant, thereby posing an unprecedented risk of environmental contamination; despite the fact that there are as yet no acceptable facilities for the long-term (i.e. permanent) management of such radioactive waste materials (pressure tubes, calandria tubes, steam generators, etc.) ; despite the fact that the longevity of the toxicity of these wastes exceeds the entire span of recorded human history; nevertheless there is no recommendation from the CNSC staff for a full independent panel review of the project.

CNSC Staff seems to take a "business as usual" attitude which is wholly inconsistent with the enormity of what is being proposed. To maintain that such extraordinary activities carried out in such exceptional circumstances are already covered by the normal operating licence of the station appears to us to be stretching credibility to the breaking point.

As stated in the Preliminary Decommissioning Plan for the Gentilly 2 Nuclear Generating Station prepared for Hydro-Quebec by TLG Services, Inc. in April 2001 (Document No. H08-1374-003, Rev. 0):

"Decommissioning work is inherently different from operating a nuclear power station.  By its very nature, decommissioning activities tend to create dispersible contamination and break down the safety and confinement barriers that were engineered into a power plant's design.  As such, . . . planning must account for this and incorporate alternate methods to control these hazards...."  [sec. 6, p. 14]

We are quoting from the G-2 Preliminary Decommissioning Study because it is close at hand.  We are certain that similar comments would apply to the Bruce reactors.

CCNR urges the Commissioners to call for separate consideration of the steam generator removal operation from start to finish, including the stabilization of the 5000 or more radioactively contaminated tubes inside each steam generator, the breach of containment required to lift the steam generators out through the roof, the restoration of the containment shell to its original state, and the packaging and storage of the steam generators once they have been removed.  This part of the assessment should also consider accident scenarios such as dropping a steam generator.

Radiation fields and radioactive contamination levels are highest for the pressure tubes and calandria tubes than for any other components in the core area of the reactors or in the Primary Heat Transport system.  Immediately after shutdown, these radiation levels are about 100 times greater than they would be after a 40-year "cooling-down" (dormancy) period as recommended for a full decommissioning job.  In terms of worker exposure, the G-2 Preliminary Decommissioning Study states:

"Hydro Québec has chosen the deferred removal decommissioning strategy to minimize both the occupational radiation dose to the decommissioning staff and any potential exposure of the public. The radiological hazards encountered during the decommissioning of the reactor would principally be caused by radionuclides produced during operation.  The majority of this radioactivity at station shutdown will be short-lived radionuclides such as H-3 [tritium], Fe-55 [radioactive iron], Nb-95 [radioactive niobium], Zr-95 [radioactive zirconium], and Co-60 [radioactive cobalt].  These radionuclides will decay with time.  If dismantling is delayed for a sufficient period, dismantling crews will be exposed to lower radiation fields.  Cobalt-60, a strong gamma emitter, will become the dominant radiation source after about four years of shutdown. With radiation fields from Cobalt-60 decreasing by about a factor of two every 5,26 years, a 34-year dormancy period will reduce the radiation levels to which decommissioning workers will be exposed by a factor of about 88."  [Sect. 4, page 1]

"The AECL study ... estimated the occupational radiation exposure that would be incurred by decommissioning a generic [ CANDU 600 ]  plant with 50 and 100-year dormancy periods.... However, the Gentilly decommissioning work is envisioned to commence after a dormancy period hypothetically assumed to be about 30 years.  Therefore, the estimated radiation exposure for the work performed after the dormancy period would require adjustment  [upwards]  to reflect a larger radioactive inventory and the resulting higher radiation fields ...." [Sect.6, page 15]

CCNR urges the Commissioners to recommend a full and independent panel review of this project because of the magnitude and import of the work itself, because of the intensity of the external radiation fields confronted by the work force, because of the extraordinarily high level of radioactive contamination involved (including radioactive dust and corrosion products), because of the unusual opportunities for spreading contamination through the segmenting and volume reduction operations, and because of the lack of detailed plans for the long-term management of the refurbishment wastes, which will remain dangerously radioactive for tens of thousands of years.

In terms of environmental impact, contamination of the atmosphere and the workers themselves with radioactive dust and corrosion products is one of our major concerns.  We recall the circumstances in which workers at Pickering (during a retubing operation) tracked radioactive carbon-14 dust home over a period of weeks before it was detected.   When the contamination was discovered, bedsheets and furniture had to be confiscated from those homes and disposed of as radioactive waste.  Recently (December 2004, during an unusually extended maintenance outage) three contract workers were radioactively contaminated at Gentilly-2. We understand that there will be hundreds of contract workers employed during the Bruce refurbishment.   They will not be working in a normal operational environment, but one with much greater opportunity for inadvertent contamination As the G-2 Preliminary Decommissioning Report states:

"Ambient radiation levels need to be as low as possible to prevent false-positive indications of contamination and/or contamination masked due to degraded detection sensitivity. Additionally, it is important to eliminate any potential of recontaminating a decontaminated area by first removing all other sources of contaminants.  This will reduce occupational radiation exposure and minimize the need to rework, which can prolong worker exposure to radiation and risk of industrial type accidents...."  [sec. 6, p. 14]

CCNR urges the Commissioners to reflect on the legislative mandate of the CNSC which is to regulate the nuclear industry so as "to prevent unreasonable risk to the environment and to the health and safety of persons".  We believe that great attention must be paid to the prevention of inadvertent radioactive contamination of persons and of the environment.

CCNR had direct experience with the health effects of radioactive contamination in the person of Bjarnie Hannibal Paulson, who was one of 80 RCAF instructors to be sent to Chalk River to supervise some 600 raw Canadian army recruits from Camp Petawawa in the radioactive cleanup of the NRU reactor building which was contaminated with airborne and surface radioactivity following an accident in 1958.

Corporal Paulson wore protective clothing and a charcoal respirator during his time inside the contaminated area, but -- despite being sent back to the showers three times to get rid of contamination detected by the monitors -- he ended up years later with a medically inexplicable pattern of hundreds of skin cancers all over his body, including his anus and peri-anal region, which medical specialists are quite certain was caused by radiation exposure.  A well-known skin pathologist at the Jewish General Hospital in Montreal, Dr. Herb Srolowicz, found strong evidence of radiation damage in Mr. Paulson's hair follicles, some of which were enlarged by as much as a factor of 50 over a normal-sized hair follicle.  When Dr. Srolowicz showed the slides of Mr. Paulson's skin abnormalities to other skin pathologists at international conferences, it was evident that none of them had ever seen anything like it before.

Dr. Karl Morgan, known as the father of Health Physics and an ex-officio member of the ICRP for many years, came to Montreal to testify in Mr. Paulson's case.  He was of the opinion that mote-like radioactive particles may have been trapped in Mr. Paulson's hair follicles for a considerable period of time, escaping detection from the monitors and yet causing thousands of rems of exposure to Mr. Paulson's basal cells.  He demonstrated to the three judges in the tribunal hearing Mr. Paulson's case, using a geiger counter and a radioactive source, that even a conscientious scanning of Mr. Paulson's body with a hand-held monitor could easily miss the residual radioactive contamination that likely caused his skin cancers.

Mr. Paulson had to endure seven separate hearings before he was finally awarded compensation for his radiation injuries -- but only after the case went to the Federal Appeals Court.  In all that time, there was absolutely no effort on the part of AECL (Atomic Energy of Canada Limited, owner and operator of the NRU reactor) or the AECB (Atomic Energy Control Board, the regulating agency at the time) to talk to Mr. Paulson or his doctors, to examine Mr. Paulson's unusual skin damage or his medical records, or to monitor the health of the other 679 people who had been exposed to unusual radioactive contamination levels during the 1958 cleanup.

CCNR recommends that the Commissioners require the licensee to conduct a thorough life-time medical follow-up of all contract workers and employees engaged in the refurbishment operations, correlated with as much information as possible on the radiation exposures and possible radioactive contamination episodes associated with each individual worker.

As the recent CERRIE Report from Britain (Committee Examining Radiation Risks of Internal Emitters, October 2004) indicates, there is still a lot of uncertainty  about the health effect of radiation, and the appropriate risk factors may in some cases be underestimated by a factor of 10, especially in cases of radioactive contamination. Without collecting data on the actual subsequent health problems of exposed individuals, there is no way that one can come to any realistic appreciation of what those risks truly are.  Health risks are neither detected nor prevented by mathematical calculations carried out by health physicists.

During the bygone days of the Atomic Energy Control Board, CCNR and many other external commentators and non-governmental agencies lamented the incestuous relationship between the regulatory agency and the industry that it was supposed to be regulating.  The fact that most of the AECB staff came from the very corporations that were supposed to be regulated by the AECB, and the fact that AECB often operated in a secretive fashion, seemingly in collusion with the nuclear industry, was a distressing reality.  More often than not, the AECB seemed to reinforce the industry's litany of bland reassurances as to the "minimal" health and environmental impacts of radioactive contamination or the radiation exposure of persons.  As long as such exposures or such contamination were within regulatory limits, the implication was that there was no rational basis for concern.  This, despite the existence of a great deal of clear scientific evidence that such regulatory limits offer no absolute protection whatsoever against various life-threatening and non-life threatening ailments.

For example, in 1978 CCNR published a simple analysis showing that the AECB maximum permissible levels of radon gas in new homes in the Elliot Lake area (0.02 WL), if experienced over a lifetime in a large number of homes, would be expected to lead to a 31 percent increase in lung cancer rates.  That translates into an additional 17 lung cancer deaths per thousand (over a lifetime), additional to the 54 lung cancer deaths per 1000 (over a lifetime) which was the published Ontario norm at that time.  The AECB refused to credit these calculations, despite its lack of expertise in this area.

In 1980, the British Columbia Medical Association published a lengthy (500 page) document in which the authors (Robert Woollard, M.D., and Eric Young, M.D.) supported the CCNR figures with additional calculations from other experts leading to much the same conclusion as the CCNR's.  The BCMA was so disdainful of AECB's unscientific assertions to the contrary that they entitled Chapter 22 of their report, "AECB : Unfit to Regulate".

Subsequently, the AECB hired an independent epidemiologist at McGill University, Duncan Thomas, Ph.D., to do a thorough review of existing epidemiological evidence from several different countries including Canada, and come up his best estimate of the lung cancer risk factor for radon gas in homes. His report indicated that the 0.02 WL standard for new homes would be expected to lead to about a 40 percent increase in lung cancer rates.  The Duncan Thomas report also showed that the permissible level of radon exposure for uranium miners, 4 WLM/year, could lead to a quadrupling of lung cancer rates if every worker experienced that level of exposure over a working lifetime.  This is hardly a "safe level" of exposure! Dr. Thomas' findings were fully confirmed in subsequent publications of the US BEIR Committees.

CCNR urges the Commissioners to ensure that all workers employed in refurbishment activities are fully informed about the health risks associated with radiation exposure; in particular, that to ensure that they are made to understand clearly that regulatory guidelines do not provide any assurances that such health effects as cancer may not subsequently be experienced as a result of radiation exposure.

When the Nuclear Safety Act was proclaimed, it was stated in Canadian Law for the first time that the primary function of the regulatory agency was to regulate the nuclear industry so as "to prevent unreasonable risk to the environment and to the health and safety of persons", in addition to the over-riding goal of safeguarding national security.  The original Atomic Energy Act made no specific mention of the safety of persons or of risks to the environment.

CCNR was initially hopeful that an agency truly committed to fulfilling this legislated mandate would begin to regard its true constituency as being, not the technologists in the nuclear industry and the bureaucrats who promote nuclear power, but the workers and citizens that might be adversely affected by this industry, along with the plants, animals, birds, fish, and other life forms that might be forced to live in an increasingly contaminated environment.

This is apparently not the case with the Canadian Nuclear Safety Commission, judging by the dogged determination of CNSC staff to keep public input at a minimum, pro forma, unfunded level, and to overwhelm the meager resources of non-governmental intervenors by rolling several large and complex projects involving enormous inventories of radionuclides into one low-level environmental screening process.

According to the G-2 Preliminary Decommissioning Report, referring to an AECL Conseptual Decommissioning Study published some years earlier:

"The AECL study estimated a total of  851 TBq [ = 851 terabecquerels = 851 trillion becquerels = 851, 000, 000, 000, 000 disintegrations per  second] of long-lived activation products in the reactor components and nearby structures at shutdown...."

"The total estimated inventory of long-lived fission products to be present within the HTS and auxiliary systems was  9,24 TBq " [ that's 9 trillion 240 billion becquerels = 9, 240, 000, 000, 000 disintegrations per second ] ....

"The HTS and moderator systems will be filled with heavy water at the time of reactor shutdown in 2010.  The most significant radioactivity contained in this water will be tritium....  This represents a total Tritium inventory of  6,03 E8 GBq." [ i.e. 603 quadrillion becquerels = 600, 000, 000, 000, 000, 000 disintegrations per second]  [Sect. 3, pp. 2-3]

CCNR requests CNSC Staff to determine and to report the corresponding radioactive inventories associated with the Bruce 1 & 2 reactors prior to refurbishment, and those associated with the Bruce 3 & 4 reactors prior to retubing them.

CCNR recommends that the Commissioners disentangle the different projects from one another and to insist on a separate environmental assessment process for each one; viz. the refurbishment of Units 1 and 2 ; the retubing of Units 3 and 4; and the eventual use of  Slightly Enriched Uranium Fuel.

With regard to the use of  SEU (slightly enriched uranium) fuel, CCNR has observed that the term SEU is not used by CNSC staff, who prefer to use the term LVRF (low void reactivity fuel) or "New Fuel".  CCNR requests a specific clarification on this matter, Is LVRF synonymous with SEU, or is it not?  Is it possible that LVRF might refer to any type of "new fuel" that has certain characteristics in common with SEU, and if so, what precisely are those characteristics?  In particular, would the designation LVRF apply to any suitably constituted version of MOX (mixed oxide) fuel, utilizing some isotope(s) of plutonium rather than uranium-235 as the fissile material in the fuel?  Would CNSC staff object to replacing the term LVRF throughout its document with the term SEU. and if so, what would be the nature of the objection?

As for the refurbishment and retubing operations, it is clear tO CCNR that the best way "to prevent unreasonable risk to the environment and to the health and safety of persons" and the best way to keep radiation exposures "as low as reasonably achievable" is to wait for several decades before carrying out the mini-decommissioning activities proposed by Bruce Power.

In terms of regulatory leadership, it is clear to CCNR that these complex refurbishment activities, set in an extraordinarily intense radiation field, should not take place until specific guidelines and regulations have been elaborated by the regulatory agency to ensure that everything possible is done to minimize radiation exposures and prevent radioactive contamination of persons and the environment.

It is also clear to CCNR that it is not responsible for CNSC to allow Bruce Power to produce an entirely new category of radioactive waste -- namely the scrapped pressure tubes, calandria tubes, and other refurbishment wastes, which are second in radioactive intensity and longevity only to the irradiated fuel itself -- before there is any realistic plan to manage these wastes for the indefinite future, bearing in mind that these wastes will remain dangerously radioactive for a period of time longer than the span of recorded human history.

CCNR hopes that in future, the CNSC will develop a superior expertise in the fields of radiation effects (medical effects of radiation exposure) and radio-ecology, given that the primary mission of CNSC is supposed to be "to prevent unreasonable risk to the environment and to the health and safety of persons".  After all, it is intended to be a "Safety" Commission, not an "Industry" commission.  The emphasis on safety as opposed to industrial output is not apparent when the CNSC staff continues to make comments such as this one:

Comment by Shawn-Patrick Stensil, Sierra Club of Canada:

"... rebuilding the Bruce A reactors closely resembles the undertakings and projects listed under CEAA's Comprehensive Study List Regulations for Nuclear and Related Facilities. This evaluation should, then, be a Comprehensive Study. The fact that the current guidelines exclude retubing activities from the scope of the present screening level review is unacceptable."

CNSC Staff response:

"Staff is satisfied that the undertaking is the continued operation of existing reactors for an extended period of time once refurbished. None of the activities identified in the scope of the project would change the original intent or operation of the Bruce A reactors. Further, there is no intent to increase the originally installed net electrical maximum continuous rating of 769 MW for each of the four Bruce A reactors."

Does one need to have a change in the intent of an industrial enterprise in order to have an environmental impact?  Does cutting, removing and compacting thousands of radioactively contaminated pipes, and lifting 50-tonne steam generators out through a hole in the roof of the containment building, not represent a dramatic change in the routine operation of the Bruce A reactors?

Where is the Staff concern for radiation damage to workers or to the public?  Where is the Staff concern for radioactive contamination of the environment?  Are these not the primary concerns that are stated in law as the main justification for the very existence of the Canadian Nuclear Safety Commission? Are these not the concerns that should trigger a comprehensive environmental review?

CNSC staff seems to be acting almost as an apologist for the proponent, running interference for them by blocking efforts to ensure a more thorough level of public accountability on environmental matters.  CCNR wonders what real value there is in even having a regulatory agency if that is as far as it is willing to go in terms of transparency, accountability, and vigilance.

Thank you for considering these comments.

On behalf of the CCNR Board of Directors,

Yours very truly,

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

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