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Urgent Action Alert: Plutonium airlift comments due August 25
August 16, 2000
ACTION ALERT
WEAPONS PLUTONIUM FUEL
Urgent: Send Your Comments to Transport Canada by August 25, 2000
1) SUMMARY
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.
2) WHAT YOU CAN DO
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)
3) WHERE YOUR COMMENTS CAN BE SENT
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
613-993-5925
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
President
United States of America
Washington D.C.
202-456-6703 (fax)
4) WHERE YOU CAN GET MORE BACKGROUND INFORMATION
For more information on plutonium and weapons plutonium fuel (MOX) see:
http://www.cnp.ca/
and
http://www.ccnr.org/
Transport Canada's main MOX page for Russian air transport is:
http://www.tc.gc.ca/tdg/en/mox/russian_mox.asp
AECL's Emergency Plan (ERAP) can be viewed at
http://www.tc.gc.ca/tdg/en/mox/erap.pdf
(note: file is in Acrobat PDF format)
Thank you.
Kristen Ostling
National Coordinator
Campaign for Nuclear Phaseout
====================================================================
DETAILED LIST OF SUGGESTED COMMENTS
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
http://ccnr.org/lyman_casks.html.)
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"
process.)
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
shipment.
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
dioxide."
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
program.
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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