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Prepared on Friday, October 29, 1999
by Kevin Kamps
Nuclear Waste Specialist
Nuclear Information and Resource Service
1424 16 th Street, N.W.
Washington , D.C. 20036
Ph. (202) 328-0002; Fax (202) 462-2183;
e-mail: kevin@nirs.org, Web site: http://www.nirs.org
Nuclear Information and Resource Services (NIRS) is a non-profit safe energy organization with members in all of the States affected by this proposed Parallex Project. NIRS challenges the finding of no significant impact, and demands an extension of at least 30 days to the public comment period. Countless citizens in States all along the proposed transport routes have not been alerted to this environmental assessment, nor to their right to comment. This environmental assessment is dated January, 1999, but seemingly was not released to the public until September, 1999. How and when was the public informed about the existence of the EA? How and when was the public informed that they had the opportunity to comment on the EA? For how long was the comment period set? When does the comment period expire? Try as I might within the EA itself and on the DOE Office of Fissile Materials Disposition web site, I could not find the end date for public comments. How was I to know by what date to submit my comments? How are people much less familiar than I am supposed to participate in this process? How will the public’s comments be used? The DOE did not adequately inform the public that there was an environmental assessment to request and upon which to comment.
NIRS demands that DOE hold public hearings in communities across the U.S. along the proposed transportation routes. At this point, only four Michigan communities have been granted public meetings with DOE. This excludes not only other Michigan communities also on the route, but excludes countless communities in other States also on the proposed routes. Also, even these four meetings in Michigan are not formal hearings. NIRS demands that formal hearings be held.
Below, please find listed a number of reasons we feel that the Parallex Project does pose a significant threat to the environment and to public health, and that no action alternatives exist that preclude Parallex from even going forward.
How can DOE claim no impact to the environment from a shipment of one of the deadliest, most carcinogenic substances on Earth?
Despite its high-tech sounding description in the Project Parallex Environmental Assessment (Section 2.1.3, “Transportation of MOX Fuel,” p. 12 to 14 - see also Figure 5, p. 13), the shipping container is little more than a standard 55 gallon drum. The urathane foam cushioning material that will pack the barrel is highly flammable. This is quite disconcerting, because burning plutonium is highly hazardous to human health. Even extremely microscopic quantities of plutonium inhaled into the human lung will initiate lung cancer. If there is a transportation accident that involves a fire that breaches the container and burns the plutonium inside, emergency responders and residents downwind will be in harm’s way. The vaporized plutonium would make for a literally deadly smoke: although it might take years for the lung cancer to unfold, the death warrant would be sealed. Yes, the proposed shipment would contain only 4.5 ounces (120 grams) of plutonium. But as Dr. Helen Caldicott (founder of Physicians for Social Responsibility, which won the 1995 Nobel Peace Prize) has said, just one pound of plutonium, if divided up and placed into the lungs of each and every human being on Earth, would be enough to induce lung cancer in 6 billion people. Plutonium, one of the deadliest substances known to humankind, is appropriately named after Pluto, the Greek God of the Dead. So, even a quarter of a pound of plutonium - which would be contained in the Parallex shipment across the continent -- is not to be taken lightly.
The fact that there is no analysis of the human health or economic impact from a transport accident seems a fatal flaw in the EA. The Department of Energy studied the effects of a hypothetical transport accident involving high-level nuclear waste. Assuming only a small fraction of the radiological inventory was released (1,380 curies) in a rural setting, the DOE projected that a 42 square mile area of land could be contaminated, which would require 460 days and $620 million to clean up. Of course, an accident in an urban setting would be much worse. Why was no such analysis applied to the Parallex shipment in this EA? Would the Parallex shipment contain 1,380 curies, or more? Would the same projections apply to an accident with this shipment that expelled the entire radiological inventory? Of course, the Chernobyl catastrophe also demonstrates the impossibility of completely cleaning up – once the genie is out of the bottle, there’s no putting him back in. Even in places in Chernobyl that were the focus of intense and expensive clean up efforts, radioactive contamination – sometimes quite high – is still detectable.
Are emergency responders across the nation prepared to deal with a radiological emergency involving plutonium? Do they have the training and equipment needed to handle an accident this autumn, which is the DOE’s proposed timetable. Do they have alpha radiation detectors? Plutonium is an alpha radiation emitter. Alpha radiation is much more difficult to detect than beta and gamma radiation, and really requires special radiation monitors to detect adequately. Will DOE provide such special monitors to emergency responders across the U.S. – and Canada for that matter -- through whose jurisdictions the Parallex shipment will pass? What about protective gear, such as radiation suits and respirators, to protect emergency responders against deadly plutonium smoke? Are there evacuation plans in place in the event of a fiery accident that would put downwind communities at perilous risk? The recent nuclear accident in Japan shows how perilous it is for communities to be unprepared. Schoolchildren were trapped in schools away from their parents for many hours as dangerous gamma rays blasted through walls and radioactive gases escaped the accident site. Ambulance personnel were contaminated as they rescued the injured nuclear plant workers. The Japanese nuclear authorities missed scores of contaminated victims because their radiation monitors and radiation monitoring procedures were not adequate for the situation - the error was not discovered for weeks, and the total number of contaminated victims had to be almost doubled, from around 50 to 90.
What about the hazards to be encountered on the proposed routes? All of the northern routes selected could present treacherous road conditions in the winter months. Last New Year’s, due to heavy blizzards and severe ice conditions, driving on Midwestern Interstate highways turned deadly. The Dakotas, Michigan, upstate New York, and Ontario all offer treacherous winter driving. The Mackinac Bridge, spanning Michigan’s upper and lower peninsulas across Lake Michigan/Lake Huron, is a case in point. One of the longest bridges in the world, it suffers from dangerous cross winds (which are powerful enough to lift small cars such as Yugo’s off the bridge, sending drivers to their deaths). What kind of vehicle is to be used for this shipment? How would it handle such winds on the Mackinac Bridge? Combined with icy conditions, blizzard white outs, and who knows what else, should the DOE attempt to truck Parallex across during such adverse winter conditions?
What about the danger of terrorism? On page A-42 in the appendix, the Environmental Assessment states “Because of the small amount of plutonium and the form of the plutonium the MOX fuel shipments would have little value for terrorists. The analysis in the EA does not consider terrorist acts or hijacking the shipments because of the low probability of an incident (given the very low proliferation value of the MOX fuel and the security associated with MOX fuel shipments).” But this assumes that terrorists would want to hijack the shipment to build a nuclear bomb. What about terrorists who simply want to strike terror into the hearts of the community by causing a disaster? In the past year, members of the Michigan militia movement were convicted of conspiring to attack Interstate 94 with explosives. This is the very route that Parallex would take through Michigan. Of course, the Parallex route through Oklahoma City passes the very site where the worst terrorist attack in U.S. history took place -- the federal building bombing in 1995 which killed 168 people. Unfortunately, a plutonium shipment makes an ideal target for terrorists seeking to terrorize citizens in the U.S. and Canada along the proposed transport routes. What is more terrifying than the release of invisible, deadly carcinogens such as plutonium, which can poison the very air we breath?
What security would accompany the shipment to protect it? Armed guards? What if terrorists attack with a mobile rocket launcher or other high explosives? What precautions could be taken against this? To fully protect against such terrorist attacks would require a police state or martial law measures - such as closing the highways to any other traffic, or even evacuating and patrolling the route -- that is contrary to our democratic traditions as a nation.
On p. 15, the Environmental Assessment states “In the Proposed Action, the MOX fuel would be transported to Canada in up to three shipments. For each shipment, one of the seven routes must be used and the exact route would be chosen by the freight company.” That the route would be chosen by the freight company seems to contradict communications from the DOE that it had chosen the exact route. So who is the freight company? What is their safety record? What is their insurance? What about their emergency response capabilities? What is their hazardous materials shipping experience? How well do their maintain their vehicles and equipment? What are their drivers’ qualifications? What training have their drivers received? What route will they choose? Will they wet their finger, stick it in the air, and decide “Thatta’ way!”?
Perhaps even more significant than this single test shipment is what it may herald for residents of the Great Lakes region, the U.S. Southeast, and other regions of the U.S. in the future. This long-delayed, strongly-resisted shipment may be the opening salvo for a full-blown plutonium economy. One proposal would involve the shipping of tens of tons of plutonium fuel from the U.S. and Russia to be "burned" at the Bruce nuclear reactors in Ontario, just 75 miles across Lake Huron from Michigan. The EA states in its Executive Summary (p. ix) that “The Proposed Action would result in the fabrication of additional MOX fuel at Los Alamos National Lab and its delivery to the Atomic Energy of Canada Ltd. Nuclear Research Universal test reactor in Canada [at Chalk River]. A successful MOX fuel test could lead to the disposition of surplus weapons-grade plutonium from the U.S. and Russia by irradiation in CANDU reactors.” (emphasis added) Both Russia and the U.S. each possess about 50 tons of surplus weapons-grade plutonium. The Bruce nuclear reactors are CANDU reactors. Thus, tens of tons - not fractions of pounds - of plutonium could one day be shipped throughout the United States and Canada, to be used in nuclear reactors in the Great Lakes region. The DOE’s own press release of 9/2/99 entitled “Agreement Reached on Joint Non-Proliferation Experiment” states that “This effort [the Project Parallex shipment and test burn at Chalk River] is part of…a project to obtain…the technical information that would become part of potential international agreements that use Canadian Deuterium Uranium (CANDU) reactors to help dispose of Russian weapons-grade plutonium.” Is this an admission that the Bruce nuclear reactors in Ontario, less than 100 miles from the Michigan shoreline across Lake Huron, could be used to “burn” tens of tons of MOX fuel? If so, what routes would be used to transport those tens of tons of MOX fuel to the Bruce reactors?
In the American Southeast, new plutonium processing plants are proposed to be built at the Savannah River Site on the South Carolina/Georgia border. The new MOX fuel would then be trucked to commercial reactors at Catawba on the South Carolina side and McGuire on the North Carolina side of the border, as well as North Anna in Louisa County, Virginia. In addition, the plutonium would need to be shipped across the country from nuclear weapons depots in the West before it could be fabricated into MOX fuel at Savannah River.
Transport accidents, or worse still, reactor accidents involving plutonium in these places would endanger millions of people across country, as shown by the scope of the Chernobyl nuclear catastrophe, which has contaminated an area of land larger than the entire State of Michigan with long-lived radioactive poisons, including plutonium.
It would be remiss to fail to point out that the Bruce nuclear reactors have been closed since 1997 due to gross mismanagement and plant deterioration that seriously lowered the margin of safety. To make matters worse, a new company called Canergen is interested in purchasing reactors at Bruce. Canergen is a Canadian-based merger between British Energy Company and Philadelphia Electric Company (PECO). Amergen is the U.S.-based merger between British Energy and PECO. Amergen recently merged with Unicom/Commonwealth Edison based in Chicago, thus acquiring a number of reactors in Illinois. Altogether, Amergen seeks to own 19 nuclear reactors in the U.S. alone, making it the biggest nuclear utility in the country.
Amergen’s strategy is to run reactors into the ground to make a buck. It has purchased reactors for pennies on the dollar. It is seeking a tax break from the IRS and Congress on even these bargain basement prices. It seems likely that, after it has run reactors into the ground, it will perform a quick and cheap decommissioning on reactors, leaving behind dangerous radioactivity while making off with hundreds of millions of dollars per reactor in the form of the already-collected decommissioning funds, which Amergen inherits when it purchases reactors.
The U.K. Nuclear Installations Inspectorate (their version of the U.S. Nuclear Regulatory Commission) recently slammed British Energy for cutting safety to the bone to save money and stay competitive. British Energy has downsized its workforce at its 11 UK reactors, including safety-related workers. For example, British Energy has retained only one fire inspectors for all 11 plants - he rotates to a different plant every few days, leaving the other 10 plants unwatched. Similarly, there is not a single analyst in charge of guarding against serious accident scenarios. The workforce that remains commonly works 60% overtime, lowering quality of work. The downsizing has caused important maintenance work to simply go undone. British Energy had secret plans to fire an additional 300 workers. All this information comes from a report never intended for public review. The report was leaked to Friends of the Earth UK, who then sent it to Nuclear Information and Resource Service.
The big questions are, will the Bruce reactors be used to “burn” MOX fuel? Will Canergen buy reactors at Bruce? Will Canergen employ the same cost-cutting strategy as British Energy in the UK, leading to seriously reduced safety precautions at its nuclear plants?
An important question to ask is, is “burning” MOX fuel even necessary to keep weapons-grade plutonium out of the wrong hands. Technology exists that would more quickly and inexpensively make weapons-grade plutonium inaccessible to terrorists or rogue nations, by mixing it with deadly high-level nuclear wastes and encasing the mixture in melted glass or ceramic form. Arjun Makhijani, President of the Institute for Energy and Environmental Research based in Takoma Park, Maryland, has amply demonstrated this point in numerous writings. He can be contacted at IEER, 6935 Laurel Avenue, Suite 204, Takoma Park, MD 20912, phone (301) 270-5500, fax (301) 270-3029, e-mail ieer@ieer.org, web site http://www.ieer.org, for further information. Thus, the Parallex Project and proposal to “burn” tens of tons of MOX fuel in commercial nuclear reactors presents unnecessary and costly risks.
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