MPU, Alm.del - 2010-11 (1. samling) - Bilag 543: Henvendelse af 27/4-11 fra Bruce Peninsula Environment Group vedr. Bruce Power's radioactive shipment to Sweden

Chair and members of the Commission,thank you for the opportunity to present our concerns and recommendationson Bruce Power’s project proposal.My name is Siegfried Kleinau, this presentation is made on behalf of theBruce Peninsula Environment Group (BPEG), incorporated as a not-for-profit corporation, founded by Lynda Hoita and myself 21 years ago. BPEGhas a membership of over 200 families and individuals living along theshores of Georgian Bay and Lake Huron.This active organization has been holdingmonthly meetings in Lion’s Head, 70 km north of Owen Sound, since itsinception.I have reviewed CMDs 10-H19, 10-H19.1 and 10-H19.2.The Steam Generators in BPs requested licence are from Bruce A units 1 &2 and originate from Ontario Power Generation’s (Ontario Hydro) powerproduction from 1972 to 1997.Bruce Power never brought them into service.This clearly constitutes that these SGs are historical radioactive waste andare owned by OPG. Bruce Power has only detached them from those units,transported them to OPG’s Western Waste Management Facility (WWMF)and there OPG has taken possession of its own waste components.Bruce Power has no jurisdiction over the further disposition of these SGs!Therefore the Commission should reject BP’s application due to a matter ofownership and jurisdiction.Should the Commission continue to deal with BPs request, we contend thatthere is no evidence of lessening the environmental footprint by thisproposed project. The shipment is classified as Surface ContaminatedObjects (SCO-1), having radioactive material distributed on those surfaces(10H-19, 4.1.2) No matter how staff twists and turns in describing thisclassification, radioactive emissions will be present during transportation,loading and shipping, spreading dangerous effects along the whole land andsea route. And in Sweden the radioactive contamination will be even morepronounced with the scrapping and melting operations. Selling the so-calleddecontaminated scrap into the open market for consumer goods is the heightof unethical behaviour!It is all about maximizing profit, which was well amplified by BPs CEO ontheir web site.We are curious why BP wants to ship those huge radioactive crates 90 kmnorth to the Port of Owen Sound on Georgian Bay, making the shippingroute much longer and treacherous, instead of choosing the deep watercommercial Port of Goderich on Lake Huron, only a 60 km drive straight

south down HWY. 21. Must have something to do with their friendlyconstituency in Bruce and Grey Counties.Further to staff’s conclusion “ that the environmental and human health risksfrom a release due to a credible accident would be very low”we refer tothe prominently displayed logo on the front page of CNSC’s web site. Therewe read: “WE WILL NEVER COMPROMISE SAFETY”.BP has contracted Studsvik from Sweden to oversee the proposed projectfrom the point of leaving the Bruce site. Studsvik’s submission 10-H19.2describes only their waste processing procedures and in no way refers to thehandling of this project. Studsvik engages 4 third party contractors – hasCNSC staff even bothered to look into their backgrounds, their safetyrecord?? WMG doesn’t even disclose what the 3-letter acronym stands foron their website ! WE WILL NEVER COMPROMISE SAFETY!!??Staff keeps working with BPs calculation of Dose Rate Estimates,comparing them to CNSC’s Regulatory Limits of 1 mSv to the public,stating that people driving or walking by the SGs in transit would receiveless than 1 % of that limit.Numerous recent studies have found that low doses like that can havedetrimental effects on peoples’ health, yes, it needs special mention thatthose regulated limits are based on the model of a 154 pound Caucasianmale 20-30 years old and 1,70m tall. No consideration is given to thedifferent body characteristics of women, the rapid development of childrenand of fetuses. The BEIR VII report (2006) of the National Academy ofSciences shows a substantial cancer incidence risk for women from radiationexposure compared to men.The Bruce-Grey Medical Officer of Health in her comments assuring thesafety of BPs project is quoted as comparing any exposure to the public to achest X-ray, mentioning gamma and beta radiation. She does not seem toomuch informed about the effects of breathing in alpha particles. In thiscontext we are questioning the ability of the Owen Sound Hospital ofdealing with large numbers of radiation victims. This accreditation must bepart of any Emergency Response Plan and so must be the certification oftraining of all first responders! WE WILL NEVER COMPROMISESAFETY!!??Contracting a vessel flying the flag of the Antigua and Barbuda West IndiesShipping Company would raise suspicions regarding training and security ofthe crew handling radioactive cargo. To ferry a dangerous load through thechannels and locks of the Great Lakes and the Seaway a rigid evaluationmust be performed by CNSC staff. Pilots have to be taken on board, are theyprotected?

Maritime disasters are more common than widely known. Collisionscenarios and fires on ships like the one travelling the Welland Canal havenot been included in the accident lists. WE WILL NEVER COMPROMISESAFETY!!??There is barely a mention of the return shipment of highly concentratedradioactive waste, which apparently would be covered by the requestedlicence. How is the transport being evaluated? This must be publicknowledge and discussion! We will never compromise safety!!??The Environmental Assessment conducted and approved by the CNSCunder CEAR Ref.# 04-01-8081 clearly laid down the handling and storageactivities regarding the Steam Generators.If the Commission decides to keep deliberating Bruce Power’s request thismust be classified as a new project , subject to an EnvironmentalAssessment, despite staff’s denial, and, because of the myriad risks involvedin this scheme the Precautionary Principle must be applied as constitutedunder the Canadian Environmental Protection Act (CEPA 1999), and needsto be referred to the Minister of Environment for an Independent Panelreview EA.We urge the Commission to seriously consider our concerns and accept ourrecommendations in light of fairness and transparency to validate thisRegulator’s commitment NOT TO COMPROMISE SAFETY!!Thank you for your time, we will attempt to answer your questions.