MPU, Alm.del - 2010-11 (1. samling) - Bilag 544: Henvendelse af 27/4-11 fra Canadian Coalition for Nuclear Responsibility (CCNR) om Transport of 16 Radioactive Steam Generators from Canada

Public TrustThe nuclear enterprise depends in large measure on the trust of the population,and the legitimacy of the regulatory agency depends on good governance. When apublic agency is seen to be serving private interests rather than the public good,both trust and legitimacy are called into question.If nuclear regulations are treated as merely suggestions that have no bindingforce, or that can be easily re-interpreted or dispensed with whenever it isconvenient for the licensee to do so, then those regulations are seen as weak andthe regulatory process itself is seen as lax.The CNSC staff readily admits that the normal IAEA regulations cannot besatisfied by the proposed shipment of 16 steam generators from Bruce Power toStudsvik in Sweden, because there is no certified container and because the totalamount of radioactivity in the 16 steam generators exceeds the maximum amountof radioactivity normally allowed in a single shipment by at least a factor of six.Thus a Special Arrangement is required if the shipment is to proceed.According to the IAEA regulations, the licensing authority is not obliged toauthorize a Special Arrangement for a radioactive shipment, but may do so if thesituation warrants.The concept of a Special Arrangement is based on the notion that if a certainshipment of radioactive materials must be carried out for some over-ridingpurpose, and the ordinary regulations cannot be met for some good reason, then aSpecial Arrangement may be made by the regulator in order to allow the shipmentto go forward. But such a Special Arrangement is not obligatory; it is anextraordinary measure for special circumstances.In the case of the Bruce A Steam Generators, CCNR believes that there is noover-riding purpose to be served by the shipment of the Steam Generators toSweden, and therefore the CNSC should not grant permission for a SpecialArrangement.Lack of Space?Bruce Power has already testified that the shipment isnot required due to a lackof storage spaceat the WWMF – in fact there is ample room to accommodate allthe Bruce A Steam Generators – and all the steam generators from the other OPGreactors as well, according to the OPG documentReference Low and IntermediateWaste Inventory for the DGRfound athttp://www.nwmo.ca/uploads_managed/MediaFiles/539_ReferenceLowandIntermediateWasteInventoryfortheDGR.pdf.

There is no urgencyto address the ultimate disposition of the Steam Generators-- not in the next few months, years, or even decades. According to the 2006Environmental Assessment, the Steam Generators are to be stored at the WWMFon the surface until 2043, and then segmented by OPG in preparation for long-term underground storage.So on a practical level, there is no strong rationale to support the case that thesesteam generators have to be shipped halfway around the world in the near future.Thus the shipment of 16 Steam Generators to Sweden, as proposed by BrucePower, should not be given a transport licence by the CNSC. Why make aSpecial Arrangement to bypass standard transport regulations when there is nodemonstrated need to make the shipment in the first place?

The Right Thing To Do?In fact the only rationale advanced by Bruce Power to justify the transport of theSteam Generators is that “It’s the right thing to do”.This is a remarkably flimsy and subjective rationale for sending radioactivewastes halfway around the world and back again, especially when there arehundreds of municipalities, non-governmental organizations and aboriginalcommunities on record as saying that it is not the right thing to do at all.The CNSC should not be granting licences or authorizing Special Arrangementson the basis of highly debatable moral pronouncements by a profit-making privatecompany or by any other licencee.

Supplementary Comments: Proposed Transport of Steam GeneratorsSo why is it “the right thing to do” according to Bruce Power? And why is CNSCstaff so eager to insist that this proposal represents “best practice” in dealing withbulky radioactively contaminated equipment? More to the point, how is thepublic interest served by this proposal?The public and the Commissioners have been told that the proposed shipment andconsequent volume reduction will “reduce Bruce Power’s environmentalfootprint” by reducing the volume of wastes to be put in long-term storage.But the environmental footprint associated with radioactive wastes is not based onmass or on volume. It is based on radioactivity. The proposed shipment doesnothing whatsoever to reduce the radioactivity associated with the steamgenerators. Does it?In theory, all of the radioactive material in the steam generators is to be returnedto Bruce Power, in which case the environmental footprint is completelyunaltered. It’s exactly the same long-term environmental burden in a differentpackage. It may save Bruce Power a bit of money, by reducing OPG’s storagecharges, but it doesn’t alter the environmental challenge associated with theradioactive waste itself, which still must be stored in perpetuity. So is this wholeexercise just to save Bruce Power a bit of money?In the real world, of course, we know not all of the radioactive material will bereturned to Bruce Power; some of it will not be coming back at all. Theenvironmental footprint will in fact be enlarged, not reduced. The environmentalfootprint will span an ocean.Some of the radioactivity (such as the cesium isotopes) will be released as gasesor vapours or radioactive dust (in the case of carbon-14) during the Studsvikprocess of disassembling, sand-blasting, crushing and melting the metal in thesteam generators. Inevitably, some fraction of the radioactive contamination willfind its way into the local Baltic environment. Some of it, no doubt, will end upin workers’ bodies. And some of it will end up in the scrap metal that iseventually to be sold on the open market as if it were normal, non-radioactivescrap metal. Indeed, it will be blended with “clean” scrap metal to furtherdisguise the fact that it contains man-made radioactive contaminants from theBruce A nuclear power plants.I guess we could all reduce our environmental footprint somewhat by taking ourgarbage cans around the neighbourhood and just discreetly dropping a bit hereand a bit there, on other people’s driveways and sidewalks. By the time we gotback home we would have achieved a slightly reduced environmental footprint,and everyone else would have an ever-so-slightly increased environmentalfootprint. Is this what CNSC staff considers “best practice” for radioactivewastes? Is this what the Commissioners regard as their public duty to facilitate?

Supplementary Comments: Proposed Transport of Steam GeneratorsSo some of the radioactive contamination from the Bruce Steam Generators willundoubtedly be staying in Sweden, and some will be exported around the world incountless metal products made from the “recycled” scrap metal, which is nowradioactively contaminated. And how is this to be seen as a noble undertaking?Bruce Power has failed to identify a single commercial retailer who wouldwelcome or agree to purchase even mildly contaminated radioactive scrap metals.The Steel Manufacturers’ Association puts its position quite plainly:Steel companies are confronted each day by the possible presenceof radioactive materials in scrap. These materials are usually in theform of sealed radioactive sources, typically installed inmeasurement gauges used in manufacturing operations or inhospital equipment; scrap from decommissioned nuclear powerand USDOE facilities; and imported scrap.For the past 25 years the US Department of Energy (DOE) hasmaintained a policy of “free facilities across the country. Freerelease means that the material is cleaned, and if necessary,declassified, and then released into the stream of commerce forunrestricted use.In the past, the amount of such material released was notsignificant. Following the end of the Cold War, DOE isdecommissioning and dismantling several facilities across thenation, and expects to release thousands of tons of scrap metalfrom these facilities for recycling at steel companies without anydose-based clearance standards.SMA members would be the primary intended recipients of thisscrap and would stand to suffer serious economic injury, as muchof this material is radioactively contaminated. SMA members aretrying to keep radioactivity out of their mills, and therefore opposefree release.For this reason, SMA members have not, and will not, accept scrapthat is known to be radioactively contaminated.Furthermore, the unrestricted release of radioactively contaminatedmetal from nuclear facilities for recycling would tarnish the imageof recycling, and potentially lead consumers to avoid productsmade of steel – especially those with high recycled scrap steelcontent.http://www.ccnr.org/SMA_Radioactive_Scrap.pdf

Supplementary Comments: Proposed Transport of Steam GeneratorsMany organizations are deeply concerned about the growing contamination of themetal supply with man-made radioactive contaminants such as plutonium fromthe nuclear power industry and the nuclear weapons complex.Does CNSC assume that what’s good for Bruce Power is also good for the world?Does CNSC want to send out the message that radioactive waste is no longerintended to be sequestered from the environment or from articles of commerce?If contaminated metal were to be recycled onyx within the nuclear industry,instead of being dumped onto unsuspecting consumers, some of the odiousness ofthis proposal would be mitigated. The transportation would still be an issuehowever.Perhaps there is a distinction to be made between NORM = Naturally OccurringRadioactive Materials and FORM = Fission-Origin Radioactive Materials. Theformer class of radioactive materials is ubiquitous in nature, usually in very smallconcentrations, and hence may be impossible to eliminate altogether in somerecycled goods -- whereas the latter is made up of man-made radioactive poisonsthat are being deliberately added as contaminants to otherwise “clean”materials. There is no justification for such a practice.

Low Level Waste?Throughout this licence application, in public pronouncements and in formaltestimony, both Bruce Power and the CNSC staff have insisted on describing theradioactive contents of the steam generators as “low-level radioactive wastes”.To an unsuspecting public, this terminology would seem to imply a very lowinherent risk – a degree or type of radioactive contamination posing such a limitedbiological hazard that it would be foolish to even be concerned about it.The fact of the matter is that these categories of radioactive materials haveextremely simplistic definitions which do not reflect the toxicity or the longevityof the materials in question. To rely on such crude terminology in an attempt toforeclose public debate or allay public concern is tantamount to chicanery.How many members of the public realize that the term “high-level radioactivewaste” is reserved for irradiated nuclear fuel and nothing else? Thus no matterhow intensely radioactive a pressure tube or a sealed source may be, any fool inthe nuclear industry can glibly say, “Well, you know, that’s not really high-levelradioactive waste.” This terminology may be useful within the industry, but thepublic is entitled to a more intelligent description of the radioactive material.Indeed, the CCNR believes that such misleading terminology in connection withthe steam generators does not serve the public interest at all, and is not compatible

Supplementary Comments: Proposed Transport of Steam Generatorswith the role of the CNSC as a protector of public health and safety. Why is thereno discussion at all of the toxicity of these materials?It is worth noting that Studsvik, on its web site, describes the “tube bundle” insidea decommissioned steam generator as “highly radioactive”. Without the outershell of the steam generator as a shield, just how radioactive is the tube bundle?Does the CNSC staff know? Do the Commissioners know?For in truth, Bruce Power is maintaining that the outer shell of the steamgenerator is the packaging, and the real radioactive cargo inside that packaging isthe tube bundle. So – is the tube bundle also described as “low level radioactivewaste”? Or not?And if the tube bundle is in fact low level waste and therefore not worth worryingabout, why doesn’t Bruce Power just remove the tube bundle on site and send the(supposedly) non-radioactive shell for recycling? Why send all that radioactivejunk across the ocean and back again if the shell is all that is wanted forrecycling?If Bruce Power doesn’t know how to perform this operation (removing the tubebundle from the shell), it has several decades to learn. There is no hurry. And thegamma radiation will steadily diminish with time, making the job ever easier.And the hazards ever more trivial, if we are to believe Bruce Power’s rhetoric.

Plutonium, Anyone?According to CNSC staff documents, approximately 90 percent of the mass ofradioactive material inside the steam generators is plutonium. Indeed, two-thirdsof the mass of radioactive material listed is plutonium-239, with another 24percent of the mass made up of the four other isotopes of plutonium.Plutonium is not a material to be handled carelessly or treated lightly. It is a verydangerous radioactive material with a very long hazardous lifetime. NeitherBruce Power nor the CNSC staff does itself any credit by trying to inculcate acontrary impression among the public.For plutonium-239, the maximum permissible body burden for an atomic workeris 0.7 micrograms. According to Bruce Power’s and CNSC staff’s figures, thereare about 36.8 grams of plutonium-239 inside the 16 steam generators (about twothirds of the total mass of radioactive materials). Simple arithmetic shows thatthis is enough, in principle, to give 52 million atomic workers their maximumpermissible body burden of plutonium-239. This is hardly a trivial quantity.Now in all honesty, how does it serve the public interest to describe this materialas “the size of a tennis ball”, as Bruce Power does (with the apparent blessing of6

Supplementary Comments: Proposed Transport of Steam Generatorsthe CNSC). Is such language meant to inform, or to trivialize? To enlighten, or topropagandize? To edify, or to mystify?Because of the toxicity of alpha-emitting materials such as radon, radium,polonium, and plutonium, the radioactive risks for such materials cannot bereduced to measurements of penetrating gamma radiation. Uranium tailings arehazardous for hundreds of thousands of years, mainly because of the alphaemitters. Irradiated fuel is hazardous even after thousands of years, mainlybecause of the alpha emitters.Because the USA has had a nuclear weapons program for many decades,American nuclear authorities have come to realize that plutonium-contaminatedwastes are not to be regarded or treated as low-level wastes. They have to behandled with almost as much care as high-level radioactive wastes.If the density of the plutonium contamination is high enough, the plutonium-contaminated waste is classified as TRU waste and considered as a candidatematerial for a deep geologic repository. If the density is lower, the waste maystill be classified as GTCC (Greater Than Class C) which requires unusuallystringent measures for isolation from the environment over very long timeperiods.It would be more accurate, and helpful, to define the radioactive contaminationinside the steam generators as primarily plutonium, with a number of otherradioactive materials mixed in. Such a description is more useful than the “lowlevel radioactive waste” epithet.

No Danger?Last year, over 200 workers inhaled a fine plutonium dust in the workplacebecause they were told by Bruce Power that there was no risk, and therefore noneed to wear protective equipment. In that exposure incident, which wentundetected for weeks, the Bruce Power representatives revealed a remarkabledegree of ignorance and irresponsibility, and now over 200 men have come awaywith a small body burden of plutonium which will remain with them for years.Yet to the best of our knowledge, there has been no fine or penalty assessed bythe CNSC against Bruce Power, nor was anyone at Bruce Power fired or demoted,or relieved of duty, nor was there any determination of criminal negligence ordereliction of duty at the higher levels of the CNSC or Bruce Power.The only ones who suffered any ill consequences were the workers, and their onlymistake lay in trusting the CNSC and Bruce Power to tell them the truth and toprovide them with a safe workplace environment. Yet most of those workers hadnever even been informed of the existence of alpha radiation, let alone the extra-7

Supplementary Comments: Proposed Transport of Steam Generatorsordinary dangers of internal alpha contamination. Those in charge of the workerswere, apparently, completely unaware of the dangers of plutonium in the piping.Does anyone assume responsibility here? Is anyone held accountable?Now Duncan Hawthorn has assured us (during the September public hearing) thatBruce Power is fully and completely aware of the radioactive inventory inside thesteam generators (even if it occasionally leaves out an isotope or two) – and by itsown published figures, that radioactive inventory is 90 percent plutonium.So let’s see now – how exactly did the plutonium get into the steam generatorsunless it passed through the pipes leading from the core of the reactor to the steamgenerator? And if that is the case, then how can Bruce Power claim that it did notknow there was plutonium in the feeder pipes at the time of the tragic andunnecessary exposure of 200 men to inhaled plutonium dust?During the public hearings on September 28-29, 2010, Duncan Hawthorn wasasked by one of the Commissioners about an open letter sent out by Dr. FrankGreening, dated February 17, 2010, advising Bruce Power, and anyone else whowould listen, of the presence of plutonium contamination in the “feeder pipes,pressure tubes, and steam generator components”. That letter by Dr. Greeningformed a part of our CCNR submission, submitted on September 13, 2010.In his recorded testimony at the CNSC hearing, Mr. Hawthorn misrepresented thecontents of Dr. Greening’s letter shamelessly, and nobody on the CNSC staff didanything to set the record straight. Mr. Hawthorn implied that Dr. Greening wassimply musing in retrospect, after the plutonium-contamination event hadhappened, that there might have been some reason to suspect the presence ofplutonium in the pipes if only anyone had thought about it ahead of time.But that’s not what Dr. Greening was saying, and Mr. Hawthorn – who is so fondof insisting on dealing with “the facts” – knows that that is not what Dr. Greeningwas saying. Moreover, the CNSC staff should also know perfectly well that thatis not what Dr. Greening was saying.Here is what Dr. Greening actually wrote:I trust that Bruce Power is not claiming that such feeder pipecontamination was unexpected because OPG and AECLhave been well aware of this issue for many years and it’snot long ago that Bruce Power nuclear reactors wereoperated by OPG.I discovered alpha contamination on Pickering feeder pipeand pressure tube samples many times during my 23 -yearcareer at OPG. Thus, in the early 1980s I reported surface8

Supplementary Comments: Proposed Transport of Steam Generatorsconcentrations of Pu-238, Pu-239, Am-241, Cm-242 andCm-244 (in the nCi/mg range) in the oxide scale on severalPickering Unit 2 inlet feeder pipes -- see Ontario HydroResearch Division Report 84-262-K issued August 13, 1984.I request that this information be passed on to the CNSCstaff who are looking into this incident and ask them toplease ensure that health physicists at Bruce Power aremade aware of the level of alpha contamination that is to beexpected on feeder pipes, pressure tubes and steamgenerator components removed from CANDU reactors herein Canada.The incompetence and dishonesty displayed by both Bruce Power and CNSC staffin covering up the possibly criminal negligence on the part of certain individualsat Bruce Power in the context of the plutonium contamination of over 200workers last year is shocking.And the willingness on the part of CNSC staff to allow the transcript of CNSCpublic hearings to be contaminated with distortions and untruths from a licenceewithout any effort to set the record straight is also shocking.These are among the reasons why CCNR has no confidence in the assurancesgiven by Bruce Power and CNSC staff that there is “no danger” in the shipmentof 16 plutonium-laden steam generators through the Great Lakes and St.Lawrence River en route to Sweden.We do not believe that Bruce Power or CNSC staff has any accurate knowledgeof the radioactive inventory of the steam generators. We believe that there is anenormous amount of guesswork involved, based on clever but highly questionablemethodologies. We believe that the data base is extremely limited given the lackof homogeneity of the radioactive contamination, the small number of pipes thatwere studied, and the impossibility of measuring all of the radioactive species.We do not believe that Bruce Power or CNSC staff has any accurate knowledgeof how much of the internal contamination is ‘fixed’ and how much is ‘loose’.These steam generators have been dry and corroded for a long time now, andmuch of the contamination that may have been fixed originally could have easilyflaked off and become loose, especially due to the rotation, manipulation andtransportation of the steam generators. If plutonium dust can escape from feederpipes to contaminate the lungs of 200 workers, why should we believe that such isnot also the case with the plutonium contamination in the steam generators?

Who Owns the Waste?CCNR has discovered that up until October of last year, the steam generatorswere owned by Ontario Power Generation (OPG) which is a crown corporationwholly owned by the Government of Ontario.The following excerpts from a letter from OPG to the Ontario Energy Boardconfirms the fact that, some time in October 2009, OPG transferred “title andpossession” of the steam generators to Bruce Power so that BP could proceedwith the proposed shipment to Sweden:November 3, 2009.VIA EMAILMs. Kristen WalliBoard SecretaryOntario Energy BoardP.O. Box 23192300 Yonge Street, Suite 2700Toronto, ON M4P 1E4Dear Ms. Walli:****STATUS REPORT TO THE ONTARIO ENERGY BOARDAgreements pursuant to the Bruce Lease TransactionDate of Report: November 3, 2009Changes from October 1, 2009 to October 31, 2009Category 2 – Amended Agreements (includes amendments,replacements or extensions)The Amending Agreement provides for the return of possessionand title of waste Bruce A Unit 1 &2 Steam Generators (SGs) fromOPG to Bruce Power. The SGs are currently in OPG storage, andBruce Power will prepare and ship them to Sweden for volumereduction and processing. Residual radioactive waste will beshipped back to Canada to be stored by OPG as low/intermediatelevel radioactive waste. OPG will refund to Bruce Power fundspreviously received to process the waste SGs for disposal in10

Supplementary Comments: Proposed Transport of Steam Generatorsexchange for the refund. OPG will be discharged of its obligationto Bruce Power for future processing and disposal of waste SGs.This discovery raises a number of interesting questions.First of all, why is OPG not a party to this proposal of Bruce Power’s, since OPGis the ultimate owner of all the radioactive waste that is produced by the BruceReactors?Secondly, why is it not OPG rather than Bruce Power that is applying for thislicence on its own behalf? In other words, why is this proposed shipment a BPinitiative and not an OPG initiative?Thirdly, why is OPG not at the very least a participant in the CNSC licensingprocess, by submitting written testimony or by sending an OPG representative tothe September hearing in order to document and to answer questions about therole of OPG in all of this?Fourthly, according to the existing licence that OPG has from the CNSC foroperating the Western Waste Management Facility (WWMF, where the steamgenerators are currently stored), would OPG be prohibited from exporting thesteam generators to Sweden?Fifthly, if OPG is in fact not permitted under its CNSC licence to exportradioactive wastes from WWMF to other jurisdictions, then how is it permissiblefor Bruce Power to be enabled by OPG to do what OPG is forbidden to do?Sixth, would the Commissioners be concerned to learn that a licence requirementis being circumvented by using a third party to assume temporary ownership andresponsibility for that express purpose?There is a degree of speculation in these questions to be sure. CCNR is not certainthat OPG is forbidden to import or export radioactive waste from the WWMF,although that is our belief. Some years ago, when Hydro Quebec stated that itwould be sending its refurbishment wastes (from Gentilly-2) to Ontario PowerGeneration’s WWMF, CCNR and other groups challenged that assumption, andHydro Quebec recanted. We were informed at that time that WWMF did not havethe authority to import radioactive wastes from another province.Here is an excerpt from a 2006 CNSC transcript, which seems to confirm this:http://www.suretenucleaire.gc.ca/eng/commission/pdf/2006-03-17-Decision-OPG-WWMF-e.pdf

ConclusionGiven the level of public concern over the proposed steam generator shipment,Given that during the 2006 EA both Bruce Power and CNSC staff indicated thatthe steam generators were radioactive wastes that could not and would not berecycled,Given that public trust in the Environmental Assessment process must bemaintained and strengthened if CNSC is to enjoy public confidence when it playsa key role in carrying out such Environmental Assessments in future,Given that the follow-up period for the 2006 EA into the refurbishment of theBruce A Reactor Units 1 and 2 does not expire until December 31 2010,Given that the levels of plutonium contamination inside the steam generators areunusually high,Given that there is no consensus as to what is “the right thing to do”,Given that national and international organizations have expressed opposition tothe free release of metals contaminated with Fission-Origin RadioactiveMaterials,Given that there is no logistical necessity for the transport of the steam generators,Given that a transport licence would require a Special Arrangement to disregardcertain IAEA regulations regarding the transport of radioactive materials,Given that the IAEA requirement for a maximum amount of radioactivity of 10A2for inland water craft and 100 A2for marine craft is based, at least in part, on theimportance of drinking water sources and other usages of inland waterways,Given that the radioactive inventory could be underestimated by as much as afactor of 2 or 3, or even by an order of magnitude,Given that the fraction of radioactive contamination that is fixed and the fractionthat is loose is not known with any certainty,Given the precedent that would be established by authorizing the transport ofradioactive reactor wastes through the Great Lakes and the St. Lawrence River,Given the uncertainty regarding the roles of OPG and Bruce Power in exportingradioactive waste from the WWMF,

Supplementary Comments: Proposed Transport of Steam GeneratorsGiven the likelihood that technology for carrying out all necessary volumereductions on site will be developed in the coming decades,The Canadian Coalition for Nuclear Responsibility urges the Commissioners ofthe CNSC• not to issue a transport licence for the 16 steam generators on the grounds thatthere is no proven necessity for the shipment and therefore no legitimate rationalefor a Special Arrangement; or• to recommend to the Minister that either a new Environmental Assessment beinitiated into the generic question of what policies Canada should have regardingthe transport, import, export, and recycling of radioactively contaminatedequipment and other radioactive reactor wastes (other than irradiated nuclearfuel), or• that the previous 2006 EA be reopened (in fact it is not yet terminated since it isstill in the follow-up period) to take into account that the original refurbishmentproject has been altered in such a way as to potentially affect or concern millionsof off-site people as to potential environmental consequences, whereas theoriginal project, as originally detailed, did not elicit such concerns.Thank you for the opportunity to submit these supplementary comments.Gordon Edwards, Ph.D., President,Canadian Coalition for Nuclear Responsibility.

(Source:CNSC)There are 5 plutonium isotopes present in the steam generators.In addition there are 18 other long-lived isotopes listed.In the 16 Bruce A steam generators (8 from Unit 1 and 8 from Unit 2), the total mass of radioactivematerial is estimated to be about 57.6 grams, of which 52.4 grams is plutonium. So plutoniummakes up 91.0 percent of the mass of radioactive material in the steam generators.Plutonium is extremely dangerous even in minute quantities. The maximum permissible “bodyburden” of plutonium-239 for an atomic worker (for instance, someone working in the nuclearweapons industry) is 0.7 micrograms. Inside the steam generators there are 36.8 grams of thisone particular isotope – enough, in principle, to give over 52 million atomic workers their maximumpermissible body burden of plutonium-239 . If we include all five isotopes of plutonium, the numberof atomic workers who could be overdosed, in principle, is just about doubled.Plutonium isotopes also have very long half-lives, ranging from decades to hundreds of thousandsof years. This means that any accident which resulted in a spill could pose long-lasting dangers.- Gordon Edwards, Ph.D., November 8, 2010

Long-lived (> one year half-life)

Mass of plutonium isotopes only

Percent plutonium