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Sept. 24, 2003
Re: Bruce Nuclear’s application for a five year license extension for the Bruce A and B reactors.
CNSC President and Commissioners,
Thanks for allowing me to address both Bruce A and B reactors at the same time, and for allowing me to take part by telephone.
My name is Kevin Kamps. I serve as nuclear waste specialist at Nuclear Information and Resource Service in Washington, D.C. NIRS is the information and networking center for citizens and environmental organizations concerned about nuclear power, radioactive waste, radiation, and sustainable energy issues. On behalf of our members in both the U.S. and Canada as well as in First Nations who would be impacted by another five years of operations at the Bruce A and B nuclear reactors, I submit the following testimony.
Before the Bruce A and B reactor licenses can be extended for another five years, the following should be done:
An independent, objective, third party, comprehensive study prior to the re-licensing of Bruce A and B reactors to determine what health impact on humans and other life forms is due to the radioactive activation of toxic chemicals, such as chlorine and many others, released during the routine operations of the Bruce reactors. By this I do not mean the radioactive contamination of toxic chemicals (which also should be examined much more thoroughly), but the actual radioactive activation of toxic and other chemicals released regularly by Bruce, including metals. The human health and ecological impact of these activation product and radioactively activated toxic chemicals is inadequately understood, woefully so, and must be studied thoroughly before Bruce is permitted to operate for another five years.
A similar study on the thermal pollution emitted by the Bruce reactors into the Great Lakes, and the mitigation that can be expected from installing cooling towers. Such mitigation should be installed prior to re-licensing Bruce for five more years of operations.
An evaluation of the ecological harm done to the Great Lakes and its constituent organisms by entrainment of Great Lakes life forms at Bruce, and mitigation actions that can and should be taken prior to re-licensing, including the installation of cooling towers.
Whereas the International Joint Commission on the Great Lakes has identified preventing invasive species as a top priority, an evaluation of the contribution to the problem of invasion by foreign species into the Great Lakes due to the thermal discharges and other ecological harms emitted by the Bruce reactors, and mitigation actions that can and should be taken prior to re-licensing.
A similar study on the human health and ecological impacts of the large-scale releases of tritium from the Bruce reactors, and an investigation on filtering mechanisms, which then should be installed, to eliminate such large-scale tritium discharges into the Great Lakes. Of special concern is the health impact upon fetuses in the mother's womb of women who drink water or eat food contaminated with tritium from the Bruce reactors, on both the Canadian and U.S. sides of the Great Lakes, as well as among First Nations' women. Also of special concern are health impacts upon fisheries, especially First Nations' fisheries, of fish which incorporate tritium into their bodies and are then consumed by humans and other life forms. A comprehensive comparison to U.S. Environmental Protection Agency limits on tritium in drinking water should be made, and an explanation provided by the Canadian authorities as to why "allowable" tritium levels are so much higher under Canadian regulations. Is it that Canadians are just better able to withstand the negative health impacts from tritium than residents of the United States?
A study of the recent power outage in Northeastern and Midwestern North America, and the special dangers presented by nuclear power reactors, specifically at Bruce A and B, in terms of the danger of overheating and meltdown in the reactor cores and waste storage pools if backup generators fail. Lessons learned should lead to the strengthening of safeguards against such potential catastrophes.
An evaluation on whether the risks to health and safety from accident and terrorist attack on the Bruce reactors, as well as the high economic costs of running them, are worth another five year license, or whether the reactors should simply be shut down permanently and the Bruce work force redirected to cleanup of the severe contamination already present on the shore of the Great Lakes.
An evaluation on the waste that would be generated from another five years of operations at Bruce, and whether it wouldn't be a better idea just to not generate that forever-deadly waste in the first place. Of special concern is the likelihood that First Nation or other rural, low income, or politically disadvantaged communities will, most likely, be targeted for the eventual dumping of high level radioactive wastes generated at and by Bruce. Targeting such communities for the dumping of some of the most toxic poisons ever generated by humankind is a blatant form of environmental racism and environmental injustice that is unacceptable.
An evaluation on the harm to civil liberties in both the U.S. and Canada from the operation of Bruce and the generation of its waste.
An evaluation of the risk to the Great Lakes from continued waste generation, storage, incineration, and disposal on the shore of the Great Lakes at Bruce, and mitigation actions that can and should be taken prior to re-licensing, including the option of permanent shut down to avoid those risks. This should include an evaluation of the terrorist threat to Bruce, one of the largest single nuclear power complexes in the world, site of vast quantities of harmful radioactivity.
A study of infant mortality rates around the Bruce reactors, comparing infant mortality rates during the operation of the reactors to the infant mortality rate when the reactors were shut down.
An evaluation of energy efficiency, energy conservation, and renewable energy sources (such as the wind turbines recently installed by Bruce Power next to the reactors) that could do away with the need for the reactors, and then a decision to go with those alternatives instead of re-licensing Bruce for another five years.
I would like to echo Mr. Martin’s caution about placing nuclear industry profit over public safety. The fiasco at FirstEnergy Corporation’s Davis-Besse reactor on the Lake Erie shoreline near Toledo, Ohio is a clear warning. The U.S. Nuclear Regulatory Commission, according to its own Inspector General’s office, placed industry profit over public safety. This led to a runaway corrosion hole in the reactor vessel head, leaving only 3/10ths of an inch of bulging and cracking stainless steel between the inside of the reactor and the containment building, suffering from serious faults of its own. This was the closest thing to a major radiation release to the environment since the Chernobyl and Three Mile Island disasters. This near disaster threatened Lake Erie, the drinking water supply of tens of millions downstream in the U.S., Canada, and First Nations. Thus far, “fixing” Davis-Besse has cost $500 million (U.S.). No such short cuts on safety should be allowed at Bruce. The Great Lakes region and its inhabitants’ safety hang in the balance.
Thank you.
Sincerely,
Kevin Kamps
Nuclear Waste Specialist
Nuclear Information and Resource Service
1424 16th St. NW Suite 404
Washington, DC 20036
ph. 202.328.0002 ext. 14
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