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Urgent Action Alert: Plutonium airlift comments due August 25

August 16, 2000


Urgent: Send Your Comments to Transport Canada by August 25, 2000


On July 28, 2000 the Chr้tien government announced its plan to fly 
weapons plutonium fuel (MOX) from Russia to Chalk River, Ontario. 
Transport Canada also announced a 28 day public comment period in 
connection with the "emergency response" part of this plan.

Transport Canada's review of AECL's "Emergency Response Assistance 
Plan" (ERAP) is the only opportunity for public input at an official 
level. Because these public comments are printed and circulated, it 
is critical that as many groups and individuals as possible take the 
time to state what they think of the plutonium airlift and of the 
project in general.


The Friday, August 25,2000 deadline established by Transport Canada 
for receiving public comments is fast approaching. Please write, even 
if only a few sentences.

In particular, CNP suggests that you emphasize that:

a) you are opposed to the plutonium fuel airlift from Russia;
b) you demand that the whole plutonium fuel import scheme be scrapped;
c) you want Transport Canada to serve the public interest and refuse 
permission to fly plutonium;
d) it is illegal to transport plutonium fuel by air in the United 
States because there is no container that has been deemed safe 
enough.  Even Transport Canada admits there is no MOX container 
qualified to survive all credible air accidents.
e) that rather than foster nuclear disarmament and nonproliferation, 
the plutonium fuel scheme will encourage the use of plutonium in the 
civilian economy and prop up a declining nuclear industry in Canada 
and internationally.

(Note: A detailed list of suggested comments follows below)


The Campaign for Nuclear Phaseout (CNP) urges you to write to:

- Transport Canada by August 25th (mailto:mox@tc.gc.ca);
- Your Member of Parliament
   (see the web page 
http://www.parl.gc.ca/36/senmemb/house/ProvinceList.asp?Lang=E for 
contact info);
- The Prime Minister (fax: 613-941-6900 or mailto:pm@pm.gc.ca), to 
express your concerns.

You can make your submission to Transport Canada by:

e-mail:        mailto:mox@tc.gc.ca

fax:           MOX Comments Officer
                Transport Dangerous Goods Directorate
                Transport Canada

regular mail:  MOX Comments Officer
                Transport Dangerous Goods Directorate
                Transport Canada
                9th Floor, Tower C
                330 Sparks Street
                Ottawa, Ontario
                K1A 0N5

IMPORTANT: Be sure to tell Transport Canada in writing that you want 
your comments published/made public so others can read them. It is 
important that public opposition to the plutonium import scheme be 
recorded at an official level. Transport Canada can be reached 
toll-free by telephone at 1-888-758-9999.

Please also forward a copy of your submission to CNP (e-mail: 
cnp@web.net or fax: 613-241-2292).

We also suggest you write to President Bill Clinton because the US 
Government is paying for this entire exercise and it is illegal to 
fly plutonium fuel under US law. Tell President Clinton how 
unacceptable the plutonium import plan is to Canadians, and about the 
lack of democratic process on this issue. In addition, ask him why 
the US Government would allow air transport through Canadian air 
space when it would be illegal in the US.

William J.  Clinton
United States of America
Washington D.C.
202-456-6703 (fax)


For more information on plutonium and weapons plutonium fuel (MOX) see:


Transport Canada's main MOX page for Russian air transport is: 

AECL's Emergency Plan (ERAP) can be viewed at 
(note: file is in Acrobat PDF format)

Thank you.

Kristen Ostling
National Coordinator
Campaign for Nuclear Phaseout



• The announcement of a 28 comment period during the height of the 
summer vacation period is inadequate.

Many Canadians are "out of touch" during this time, many institutions 
of higher learning are not in session, and many non-governmental 
organizations do not meet during the month of August.

Transport Canada should extend the comment period until at least the 
end of September.

• In November 1999, Transport Canada approved AECL's plan to 
transport the US weapons plutonium fuel by truck, and the Russian 
weapons plutonium fuel by land and sea, stating not once but five 
times that the plutonium would not be flown for safety reasons.

Then, at the last minute, in January 2000, AECL was granted 
permission by Transport Canada to fly the plutonium fuel from Sault 
Ste. Marie to Chalk River by helicopter, in complete secrecy.

Transport Canada should have a care for its credibility and for its 
responsibility to the Canadian population by acting in a manner 
consistent with its original judgment not to allow weapons plutonium 
fuel to be flown.

• Transport Canada should not approve AECL's plan to airlift 
plutonium (MOX) from Russia to Canada, since even Transport Canada 
admits there is no MOX container qualified to survive all credible 
air accidents.

In its November 1999 report, Transport Canada stated "the material 
will not be flown" because a severe transportation accident "could 
result in the release of a heavy dust [which] has the potential for 
damage if inhaled." Noting that AECL would be using a Type B 
container (rather than a Type C container or better, as required by 
US Law for air transport), Transport Canada was firm that the MOX 
test samples could not be flown: "Not until there were a container 
deemed safe enough to survive all credible airplane accidents."

Transport Canada should demand detailed proof that the chosen 
container can withstand all credible air crashes. According to our 
research, there is no such proof - see 

• In an August 2nd Canadian Press article, John Read, director 
general of the Transport Dangerous Goods Directorate of Transport 
Canada, stated that AECL must show how it would "effectively respond" 
to the worst accidents, including the release of plutonium dust. He 
is quoted as saying: "If they can't, they don't ship."

When heated in the presence of oxygen, ceramic MOX pellets 
spontaneously swell (increasing their volume by as much as 30 
percent) and crumble into dust. In 1982, a German Laboratory reduced 
a MOX pellet to a fine powder by heating it at 400 C for just 30 
minutes. That's not very hot - about the temperature of a kerosene 
fire. (AECL has used the same technique, at about the same 
temperature, to pulverize nuclear fuel pellets in its "DUPIC" 

If the package is damaged in a severe air crash, allowing oxygen to 
get to the MOX fuel, then fire - even at relatively low temperatures 
- could release a fine plutonium-bearing powder into the atmosphere. 
Once released, such radioactive dust is extremely difficult to 
control, locate, or clean up. That's why the USA has a strict law 
which effectively prohibits the air transport of plutonium, given the 
extraordinary toxicity of inhaled plutonium dust.

There is no indication that AECL or Transport Canada has seriously 
addressed this kind of accident scenario. Hence permission for air 
transport should not be given.

• Tranport Canada has not been sufficiently diligent in requiring 
AECL to delineate and demonstrate exactly how it would respond to the 
dispersal of a fine plutonium dust into the atmosphere.

Last year, two Chalk River employees were over-exposed to respirable 
plutonium dust even though they were wearing protective equipment. 
Charges have been laid against AECL by the Nuclear Safety Commission 
(formerly known as the Atomic Energy Control Board) in connection 
with this incident.

Although AECL has many years of experience in dealing with other 
types of radioactive materials and radioactive spills, it appears 
that AECL is not experienced in dealing safely with releases of 
alpha-emitting powder into the atmosphere in a respirable form, as 
the above episode illustrates.

Transport Canada should not approve the emergency plan in the absence 
of detailed plans from AECL for identifying, locating, controlling 
and retrieving an atmospheric dispersal of plutonium-bearing dust, 
and dealing with plutonium-contaminated casualties.

• Tranport Canada has a responsibility to potentially affected 
communities. Yet in AECL's emergency plan for air transport of 
weapons plutonium, there are no routes delineated and no potentially 
affected communities specified.

Has Transport Canada contacted all of the emergency services in all 
of the potentially affected communities, including municipal 
governments, emergency responders and hospitals along the route?

The communities potentially affected by an accident have a right to 
know that they are on the flight path. Transport Canada should not 
approve AECL's emergency plan as it lacks this essential information.

• Approval of AECL's plan to transport plutonium fuel (MOX) by air 
using an inadequate "Type B" container, would set a dangerous North 
American precedent.

The International Atomic Energy Agency (IAEA) has, since 1996, been 
formulating standards for a stronger "Type C" container, intended for 
transporting radioactive materials by air. The only reason "Type B" 
casks are permitted at present by IAEA is because the new standards 
have not yet been adopted.

It is illegal to transport plutonium fuel by air in the United States 
because there is no container that has been deemed safe enough. Even 
a Type C container, as currently envisaged by IAEA, would not be 
strong enough to meet US standards.

Approval of air transport of Russian MOX using a Type B container 
would be a North American first and could be seen as establishing a 
dangerous precedent, especially since it is a high visibility 

Transport Canada should not allow itself to be used in this way; it 
should not approve the controversial air transport plan, especially 
as there is an alternative transportion plan it has already approved.

• AECL and Minister Goodale have told Canadians that it is virtually 
impossible for plutonium to be released in a respirable form under 
any conceivable accident scenario. Yet the US Department of Energy, 
in a 1997 environmental assessment document, states:

"Two credible transportation accident scenarios were analyzed for the 
shipment of MOX fuel to the Canadian border . . . .

"The first accident relates to an event that leads to the MOX fuel 
package container breaking open, igniting, and releasing plutonium 
dioxide particles into the air. The public is assumed to be near 
enough to the accident to breathe air contaminated with plutonium 

The report makes it clear that this scenario, while unlikely, has "a 
reasonable probability of occurrence". (Section 5.2 "MOX 
Transportation Accidents")

Moreover, in the previous AECL Emergency Plan for land and sea 
transport, AECL identified 4 out of 8 categories of accidents where 
the container would be completely destroyed. But in the new plan, 
there are no discussion of accident scenarios at all.

Transport Canada should not approve the emergency plan because the 
Canadian public, and Transport Canada itself, appears to have been 
misled about the possible consequences of credible accident 
scenarios. AECL should be required to publish its detailed accident 
analyses and subject them to independent public scrutiny.

• The "Parallex Project" was originally intended to lay the 
groundwork for a parallel, symmetric reduction in the excess weapons 
plutonium stockpiles of the USA and Russia.

When the US announced earlier this year that they have no intention 
of sending any more plutonium to Canada, the stated rationale for the 
Parallex Project collapsed. Yet the Project still proceeds as if 
nothing has changed.

In fact, Russia is now sending four and a half times more plutonium 
than the U.S. There is no parallelism left any more, even for the 
test phase of the plutonium import program.

Transport Canada should not approve the emergency plan until a 
consistent new rationale for the project has been submitted.

• Importing weapons plutonium to Canada will not serve the interests 
of nuclear disarmament or nonproliferation.

Like the House of Commons Standing Committee on Foreign Affairs and 
hundreds of Canadian municipalities, we are opposed to the 
transportation of plutonium fuel by air, land or sea, and to Canada's 
"approval in principle" of a weapons plutonium import program.

The use of plutonium fuel in civilian reactors will encourage the 
circulation of this dangerous nuclear explosive material in the 
civilian economy, not only in Canada and the US, but also in Russia, 
and possibly in other countries with Canadian-designed reactors such 
as India, Pakistan, Taiwan, Korea, Argentina, and Romania.

Canada's plutonium import program could seriously undermine the 
non-proliferation objectives of policies first adopted by the Carter 
Administration in the late 1970s and supported by every subsequent US 
administration, to discourage the widespread civilian use of 
plutonium - in order to minimize the global spread of nuclear weapons 
materials and capabilities.

Instead of approving the flawed emergency plan submitted by AECL, 
Transport Canada should recommend to the Government of Canada that 
public consultations be held with Canadians on the rationale and 
non-proliferation implications of the proposed plutonium import 

• The impetus for the idea of burning plutonium in reactors comes not 
from the peace and disarmament community, but from the nuclear power 
establishments of Russia, the US and Canada - all of whom would like 
to see their aging reactors running for another 25 years or more. 
This raises many legitimate public safety concerns.

When a CANDU reactor is fueled with MOX, the radioactive inventory in 
the reactor core ends up being four to five times greater than if the 
same reactor were fueled with natural uranium. Therefore, the harmful 
consequences of a reactor accident involving fuel damage will be 
correspondingly much greater if MOX fuel is used.

MOX fuel is also more reactive than natural uranium fuel, making 
greater demands on the control and shut-down systems of a CANDU 
reactor fueled with MOX. Therefore, the probability of a serious 
reactor accident is correspondingly increased if MOX fuel is used.

Instead of approving the flawed emergency plan submitted by AECL, 
Transport Canada should recommend to the Government of Canada that 
public hearings be held on the entire range of reactor safety 
implications associated with the use of MOX fuel.

• When a CANDU reactor is fueled with MOX, the irradiated fuel ends 
up being four to five times more radioactive than if the same CANDU 
had been fueled with natural uranium. The plutonium content of the 
spent fuel is also correspondingly greater in the MOX case.

These characteristics of irradiated MOX fuel will introduce 
additional complications in the long-term storage of high level 
radioactive waste because of increased heat generation, increased 
concentration of fission products, and increased probability of 
accidental criticality (whereby the residual plutonium in the 
irradiated fuel spontaneously undergoes a nuclear chain reaction).

Instead of approving the flawed emergency plan submitted by AECL, 
Transport Canada should recommend to the Government of Canada that 
public hearings be held on the safety, security, and cost 
implications of the long-term storage of irradiated MOX fuel.

• Instead of promoting an initiative which will serve to prop up a 
dying nuclear industry, Canada should be phasing out nuclear power 
and calling for the end of the production of plutonium.

It is time for Canada to get serious about the global plutonium 
problem and promote an international initiative to halt the 
production of new plutonium, to oppose the separation of plutonium 
from irradiated fuel for any purpose whatsoever, and to take existing 
separated plutonium out of circulation, treat it as a dangerous waste 
product and guard existing weapons plutonium stocks under a strict 
international security r้gime.

Instead of approving the flawed emergency plan submitted by AECL, 
Transport Canada should recommend to the Government of Canada that 
public hearings be held on alternative methods for dealing with 
excess weapons plutonium and other stockpiles of separated plutonium, 
including vitrification and other immobilization options.

• The manner in which the weapons plutonium fuel issue has been 
managed in Canada has been fundamentally undemocratic.

During the Fall 1999 comment period on AECL's emergency plans, 96 
percent of the submissions made to Transport Canada were opposed to 
the project.

In 1998, after parliamentary hearings, the Standing Committee on 
Foreign Affairs and International Trade recommended that the 
plutonium import project be scrapped because it was found to be 
"unfeasible" in terms of non-proliferation objectives.

First Nations communities along with hundreds of municipalities, 
including 167 municipalities in Quebec, have passed resolutions 
against this project. In addition, the Federation of Canadian 
Municipalities passed a resolution against the project, as well as 
the Conference of Great Lakes Mayors. Firefighters and Police 
associations have recommended that the project not go forward.

It is time for the federal government to listen to the wishes of 
Canadians. Transport Canada should recommend that the Government 
either withdraw the project, or failing that, hold broad public 
consultations - including full public hearings - to allow meaningful 
public input on Canada's plutonium policies before the project goes 
any further.
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