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Making Waves

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Analysis of Canadian water politics by the Council of Canadians' national water campaigner.

Why the Canadian Nuclear Safety Commission should stop Bruce Power's radioactive shipments through our Great Lakes

| November 29, 2010

Bruce Power has applied for a licence at the Canadian Nuclear Safety Commission (CNSC) to ship 16 radioactive steam generators through the Great Lakes and St. Lawrence Seaway to Sweden. City mayors, US Senators, environmental groups, First Nations communities and other civil society groups have raised many important concerns about this shipment. Nearly 80 groups provided written submissions and half of them intervened at a public hearing on Sept. 28-29, 2010. The CNSC extended the deadline to Nov. 22 for supplementary submissions and is now poised to make a decision by Dec. 22, 2010.

Bruce Power's plan

As part of Bruce Power's refurbishment project, 64 steam generators were transferred to the Western Waste Management Facility to make space for new steam generators. Bruce Power plans to recycle 90% of the 16 steam generators by contracting Swedish company Studsvik to ship, decontaminate, melt down and sell the metal on consumer markets. Studsvik will return 10% of the most radioactive parts to Bruce Power. Bruce Power currently has a contract with Studsvik to ship and recycle 32 steam generators.

The special licence from the Canadian Nuclear Safety Commission

Bruce Power has applied for a special licence because they are unable to meet the packaging requirements set out in the CNSC's Packaging and Transport of Nuclear Substances Regulations. The total radioactive level also exceeds the legal limits set out in International Atomic Energy Agency's Regulations for the Safe Transport of Radioactive Material by 6 times.

Radioactivity levels in the steam generators are 90% plutonium

Based on Bruce Power's estimates, the radioactivity levels in the steam generators are approximately 90% plutonium. In particular, the levels are approximately 64% plutonium-239. According to the US Environmental Protection Agency, plutonium-239 has a half-life of 24,100 years. They have noted that "internal exposure to plutonium is an extremely serious health hazard. It generally stays in the body for decades, exposing organs and tissues to radiation, and increasing the risk of cancer. Plutonium is also a toxic metal, and may cause damage to the kidneys."

Civil society concerns about the plan

The Great Lakes holds nearly 20% of the world's freshwater and 95% of North America's freshwater. They provide drinking water to 40 million people in surrounding areas. The Lakes are a public trust and a commons (a shared entity). There are several significant flaws with the plan that could impact our largest freshwater source:

-- It could set a dangerous precedent for regularly shipping radioactive waste that exceeds legal limits through the Great Lakes. Since there are 64 steam generators, this shipment could give the green light for the shipment of all 64 steam generators.
-- The International Institute of Concern for Public Health (IICPH) has noted that radionuclides found in the Great Lakes, including tritium, carbon-14, cesium and long-lived iodine-129, pose a serious health hazard even at low levels. An accident on the Great Lakes would further contribute to radioactivity and pollution in the Great Lakes.
-- Some First Nation communities and municipalities were not adequately consulted.
-- There has been inadequate public consultation on critical issues raised by this shipment.
-- Bruce Power's emergency response plans and the CNSC's accident scenarios are inadequate. Bruce Power's application did not include a response plan for a sinking ship. As noted by the IICPH, if all generators were damaged and "opened," the radioactivity far exceeds even Health Canada's Action drinking water level for intervention in a nuclear emergency.
-- The radioactive metal will be recycled and sold back into consumer markets. The metal will be used to make consumer goods such as cutlery, toasters and dental braces.

The incomplete environmental assessment

In 2006, an environmental assessment (EA) was conducted on the Bruce A refurbishment project. Under this 2006 EA, Bruce Power had proposed to leave the steam generators on-site. In a presentation to the Saugeen Ojibway Nations, Bruce Power had even stated that "much of the waste, and particularly low and intermediate level waste containing radioactivity cannot be recycled for safety and environmental reasons." Although Bruce Power has altered their plans, CNSC staff have "determined that this proposal does not change the environmental assessment that was conducted on the Bruce A refurbishment project." Without providing a rationale, CNSC staff have also concluded that this shipment does not fall within the definition of a project under the Canadian Environmental Assessment Act.

The 2006 EA appears to be incomplete. The Canadian Environmental Assessment Agency website states:

A follow-up program to verify the accuracy of the environmental assessment and/or determine the effectiveness of any measures taken to mitigate the adverse environmental effects is considered appropriate for this project. The estimated start and end dates of the follow-up program are October 2, 2006 and Dec. 31, 2010, respectively.

Although the 2006 environmental assessment is listed under completed assessments on the CNSC website, there is no completion date. The CNSC should not be making a decision until the follow-up program is completed. Since the original project has been altered, the 2006 EA is no longer accurate.

Why more public debate is needed

This shipment raises several significant issues that should be open to public debate including:

1. Do we want radioactive waste that exceeds legal limits or even radioactive waste in general to be shipped through national (and international) waters? Since water flows and does not respect national or provincial borders, polluted water outside of Canadian borders can return to Canadian rivers and lakes. As well, with growing water scarcity and water stress around the world, do we want to threaten dwindling water resources?
2. How much weight should be given to the positions of First Nations communities? Although the Saugeen Ojibway Nation has opposed trucking the steam generators through their traditional territory, Bruce Power and CNSC have disregarded their positions and are moving forward with the necessary steps to ship the generators to Sweden.
3. Although the scrap metal will remain in Sweden, it may return to Canadian markets as manufactured goods. Do we, as a nation, want to contribute to the circulation of scrap metal from radioactive sources given the health risks of long-term exposure?
4. Even if it does not return to Canadian markets, what legal and moral obligations do Canadians have in contributing to scrap metal that causes illnesses or health risks in other countries?

These are critical issues that need to be explored. The Great Lakes are a public trust and a commons (a shared entity). The CNSC should not allow this shipment to proceed without further consulting Canadians and First Nations on these critical issues affecting our Great Lakes.

The CNSC's decision is expected by Dec. 22, 2010

Many facets of Bruce Power's project threaten the environment and the Canadian public. CNSC's mandate is to protect the health, safety and security of Canadians as well as the environment. City mayors, US Senators, environmental groups, First Nations communities and other civil society groups await to see whether the CNSC fulfills its mandate to the Canadian public or whether it will bow to corporate pressure. If they bow to corporate pressure, it will call into question the legitimacy of the CNSC and its ability to protect Canadians.

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