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

CCNR Submission to CNSC : Transport of Radioactive Steam GeneratorsThe Canadian Coalition for Nuclear Responsibility was founded 35 years ago.CCNR believes that the Canadian population and Canadian politicalleaders deserve to be told the unvarnished truth about the dangers as wellas the benefits of nuclear technology. We do not believe that this is beingdone at present by the nuclear industry or by CNSC, the regulatory agency.Creative efforts are needed to demystify difficult scientific concepts andclarify the nature of the genuine risks that are associated with radioactivity,nuclear reactors, uranium mining, radioactive wastes, and the dangers ofthe inadvertent proliferation of nuclear weapons through the spread ofcivilian nuclear technology. Frankness and honesty are indispensable.To foster a truly democratic decision-making process, and to ensure thatthe nuclear enterprise is politically accountable, we need an agency that isdedicated wholeheartedly to the public interest – not only protecting thehealth and safety of the public and the environment, but assisting us all tounderstand the nuclear issues from a public interest perspective.We believe that the CNSC shouldn’t be facilitating the nuclear industry tocarry out actions which are not demonstrably in the public interest. We areopposed to the transport of 1600 tonnes of radioactive waste to Sweden forthe purpose of recycling radioactively contaminated metal into scrap that isintended for unrestricted use, and the subsequent return of some 400tonnes of the most radioactively contaminated portions overland to Bruce.The CNSC has ample technical and procedural reasons for withholdingpermission for this shipment. First and foremost, the shipment exceeds themaximum recommended limits for radioactivity in any single shipment. It isour understanding that this would be the case even if the steam generatorswere shipped one at a time. This being so, the CNSC is not obligated togrant a licence to Bruce Power, and, in our view, should not do so.Part 1 of our submission gives other reasons why a licence should not begranted to Bruce Power for this export of radioactive waste from Canada.Part 2 provides a critique of the CNSC presentation to Owen Sound CityCouncil on the subject of the proposed transport of 16 steam generators.1

Part 1: Reasons for refusing to grant Bruce Power a licenceOn behalf of the Canadian Coalition for Nuclear Responsibility, I call uponthe CNSC to refuse to issue a licence to Bruce Power for the overlandtransport of 16 radioactive steam generators from the Western WasteManagement Facility to Owen Sound, and for the shipment of those same16 steam generators from Owen Sound to Sweden. CNSC staff admit thatthe proposed transport exceeds the radioactive limits for a single shipment.Other reasons for refusing the licence are:

(1) No justification has been given for the transport in terms of reducingradioactive exposure to workers or the public or to the environment.In fact the transport will invariably increase all three types ofexposure, given the fact that the metal in the steam generator will bedisassembled, sand-blasted, and melted in order to bring aboutsome slight economic benefits for the two companies involved.The Canadian Nuclear Safety Act establishes the CNSC as a protector ofthe public interest and not as an adjunct of the nuclear industry. Allunnecessary exposures to ionizing radiation are to be avoided unless thereis some clear societal benefit. It is not the job of CNSC to help the industrymake money at the expense of increased radiation exposures.The following description of the benefits of Studsvik’s services is taken fromStudsvik’s web page. Those benefits are expressed almost entirely interms of saving money and improving public relations for the industry.Waste Volume Reduction at Studsvik Nuclear AB January 2010http://www.winsverige.se/arsmotet_2009/2010-01%20Studsvik%20Waste%20Treatment.pdf

CCNR Submission to CNSC : Transport of Radioactive Steam Generators• Waste Volume Reduction & Recycling of valuable materials reducesenvironmental burden• Creategood public impressionof the nuclear industry• Long term sustainable strategy• Waste volume reduction will prolong repository life time andreduce costThe sole environmental consideration in this list of benefits is the claim that“volume reduction and recycling of valuable materials reducesenvironmental burden,”but this claim is not justified.If the process of volume reduction requires atmospheric radioactiveemissions during melting, radioactive dust and liquid effluents from the useof various decontamination methods, and radioactive residues ending up inconsumer goods from the still-contaminated scrap metal for unrestricteduse, then the environmental burden has been increased, not reduced.

(2) There is an alternative plan for the steam generators which was laidout by Bruce Power in its 2006 Environmental Impact Statement forthe Refurbishment of the Bruce A reactors and approved by theCNSC following the publication of the Screening Report in 2007. Noreason has been given for deviating from this plan, other than thehighly questionable assertion that Bruce Power will “reduce itsenvironmental footprint” (by making it a global radioactive footprint?)BPEA page 3-30 Waste Handling:

CCNR Submission to CNSC : Transport of Radioactive Steam Generators(3) Neither the Canadian Government nor the CNSC has ever adopted apolicy that allows for the export or import of radioactive waste to orfrom another country. This licence would establish a precedentwhich could be used to justify further imports or exports ofradioactive waste within a policy vacuum.Indeed, the contract between Bruce Power and Studsvik calls for thetransport of 32 radioactive steam generators, so this licence is just the firstin a series of licence requests having to do with the export and import ofradioactive waste.Both Bruce Power and the CNSC have previously confirmed that the steamgenerators are in fact radioactive waste:BPEA Pages 3-28 & 3-29

CCNR Submission to CNSC : Transport of Radioactive Steam GeneratorsIn a 2002 press release on used steam generators by the US Dept ofEnergy, describing a report entitledShield design guide developed forconstruction of old steam generator storage facilities,we read:"In order to properly store decommissioned steam generators,mausoleums or storage vaults are designed to minimize theradiation release and exposure to plant personnel and thepublic. The focus of the design guide is to reduce the gammaradiation exposure through the use of concrete walls, floors androofs. The guide also addresses the more difficult problem oflong-range skyshine dose rates, or the radiation escaping thestorage vaults and scattered in the atmosphere, and thenreflected back to personnel at ground level.”DOE News Release, July 30, 2002,http://newsdesk.inl.gov/press_releases/2002/07-30steam_generator.htm

The lack of any such discussion in the Bruce Power application and in theCNSC staff document, combined with dismissive statements made publiclyabout the radiation levels from the steam generators by representatives ofthe licensee, do not inspire confidence. CNSC should not grant a licencewhen the safety culture of the licensee is clearly inadequate. This is thecompany that last year exposed over 200 workers to alpha contaminationwhich they did not take the trouble to measure until it was too late.

(5) Both Bruce Power and the CNSC staff seem to misrepresent theradioactive contents of the steam generators, by adopting a slap-dash unscientific approach when characterizing the radioactiveinventory. Numerous important radionuclides are completely absentfrom the tables, and there is no indication of the very large errorbands associated with the activities in the inventory in Table 1.Not only does Table 1 fail to list any of the four uranium isotopes, but it alsoomits any mention of such important nuclides asniobium-95 (present to the tune of about 33,000 becquerels),ruthenium-106 (responsible for about 70,000 becquerels),plutonium-241 (representing as much as 100,000 bequerels),yttrium-90 (responsible for another 47,000 becquerels)These four isotopes alone, if added to CNSC’s list of nuclides in a Unit 1steam generator, would almost double the estimated radioactive inventory.5

CCNR Submission to CNSC : Transport of Radioactive Steam Generators(The figures in the previous paragraph were all derived from Bruce A datain the table on page 50 of OPG’s August 2008 Report entitled “ReferenceLow and Intermediate Level Waste Inventory for the Deep GeologicRepository”http://www.nwmo.ca/uploads_managed/MediaFiles/539_ReferenceLowandIntermediateWasteInventoryfortheDGR.pdf)The point is that nobody really knows the radioactive inventory of the steamgenerators. Bruce Power and CNSC staff do themselves no credit by givingguesstimates without any methodology or error bands or disclaimersattached.In the absence of any reliable radioactive inventory, it is of courseimpossible to know what percentage of that inventory is ultimately returnedto Bruce Power by Studsvik. The difference between the radioactiveinventory sent to Sweden and the radioactive inventory returned to Brucerepresents the amount of radioactive waste that has been dispersed intothe air, into the water, into the workers, or into consumer goods – but noone will ever know what that amount is. In the worst-case scenario, onemight say that it’s the perfect crime.CNSC would be remiss in its duty to the population of Canada and theworld, and CCNR believes it would be derelict in its duty as a regulatoryagency, to licence such an unquantifiable release of radioactive wastematerial. If Bruce Power believes that there is non-radioactive metal inthose steam generators that can be safely and hygienically recycled, letthem do the separation on-site so that all of the radioactive waste materialremains isolated, contained, and managed properly for the long term, andonly non-contaminated metal is removed from the site.CNSC Page 75Some of the waste is directly recyclable; however, the largest waste quantitiesare associated with the pressure-tube/calandria-tube replacement andsteamgenerator replacement, since the replaced components cannot be recycled andmust be disposed of at the WWMF….

CCNR Submission to CNSC : Transport of Radioactive Steam GeneratorsFrom the Executive Summary of a 2006 United Nations publication entitled“Recommendation on Monitoring and Response Procedures forRadioactive Scrap Metal”, we read:Radioactive substances can become associated with scrapmetal in various ways and if not discovered they can beincorporated into steel and non-ferrous metals through themelting process. This can cause health hazards to workers andto the public as well as environmental concerns and it can alsohave serious commercial implications. Numerous incidents haveoccurred in recent years involving the discovery of radioactivesubstances in scrap metal and, in some cases, in metal from themelting process. These incidents have proved to be very costlyin relation to the recovery and clean-up operations required butalso in terms of the potential loss of confidence of the industry inscrap metal as a resource.Here is what the Steel Manufacturer’s Association has to say aboutradioactively contaminated scrap metal – taken from the following :http://www.steelnet.org/public_policy/public_policy_environment.html

No Contaminated Scrap fromDecommissioned FacilitiesFor the past 25 years the US Department of Energy (DOE) has maintaineda policy of “free release” of obsolete equipment and materials at weaponsproduction and research facilities across the country. Free release meansthat the material is cleaned, and if necessary, declassified, and thenreleased into the stream of commerce for unrestricted use.In the past, the amount of such material released was not significant.Following the end of the Cold War, DOE is decommissioning anddismantling several facilities across the nation and expects to releasehundreds of tons of scrap metal from these facilities for recycling at steelcompanies without any dose-based clearance standards.SMA member companies have not, and will not, accept scrap that is knownto be radioactively contaminated.SMA members would be the primary intended recipients of this scrap,much of which is radioactively contaminated, and stand to suffer seriouseconomic injury from this policy. SMA members are trying to keep

CCNR Submission to CNSC : Transport of Radioactive Steam Generatorsradioactivity out of their mills and therefore oppose free release. DOE’spolicy is simply inequitable and shortsighted and could develop into apublic policy disaster.Free release of radioactive scrap could adversely affect the marketability ofsteel products made from recycled scrap. The public perception is that anylevel or type of radioactivity is unsafe. Metal recycling industries haveworked hard to build public confidence in the safety and utility of productsmade from recycled metal. This confidence would be lost if the public,rightly or wrongly, perceives such products to be unsafe. For this reason,SMA member companies have not, and will not, accept scrap that is knownto be radioactively contaminated.Furthermore, the unrestricted release of radioactively contaminated metalfrom nuclear facilities for recycling would tarnish the image of recycling,and potentially lead consumers to avoid products made of steel, especiallythose with a high recycled scrap steel content.DOE should adopt a policy of restricted release of scrap, provided thescrap meets specified health-based standards. Restricted release shouldbe specifically limited to either of the proposed eligible uses:Recycling or recovery at a dedicated, licensed facility for use only atan NRC-licensed fuel cycle facility or at nuclear facilities operatedby the DOE where the use of low level radioactive material is not anissue; orDisposal into licensed radioactive waste landfills, or into municipalor industrial landfills, as long as the material meets the specifiedhealth-based levels. If these levels are met, the landfill need not belicensed as a radioactive waste landfill.DOE should not authorize any release of material from nuclear facilitiesuntil it establishes health-based standards that reflect sound science. NRCis currently evaluating whether and how to establish dose-based clearancelevels that will adequately protect health and safety. It is expected that DOEwould follow NRC’s standards. It is prudent public policy that material notbe released until firm, publicly accepted standards and procedures forattaining and measuring compliance are developed through the standardsetting process.

CCNR Submission to CNSC : Transport of Radioactive Steam Generators(7) The risks of accidental releases from radioactive steam generatorshas not been adequately assessed. In the original 2006 EA, theCNSC identified the dropping of a steam generator as one of the twocredible scenarios that could result in on-site and off-site radiationexposure to workers, the public and the environment. Given themuch more ambitious plan now before the CNSC, anotherenvironmental assessment would be required to adequatelycharacterize the risks of this operation – which would have to extendto the Baltic Sea area and include the Studsvik operations.BPEA Page 3-37

A transportation-related accident during the transfer of . . . the old steamgeneratorsbetween Bruce A and the WWMF may occurleading to a radiologicalcontamination that could reach on-site workers and members of the public….Materials present as a gas or as very fine powders are more likely to escape….Carbon-14is the most abundant radionuclide and would probably be presenteither as a gas or as a very fine particulate….BPEA Page 3-18[box 3 in middle column]CNSC Page 25[box 6 in right column]

(8) The characterization of the steam generators as “low levelradioactive waste” and therefore suitable for decontamination andrecycling is misguided and dangerously unrealistic. In fact, the verylong-lived high-toxicity alpha emitters present inside the steamgenerators, all of them transuranic actinides, require that the SGs beclassified as TRU [transuranium-contaminated wastes] or at least asGTCC [Greater than Class C] radioactive wastes. Such wastes aresuitable only for isolation and perpetual storage under strict control.9

CCNR Submission to CNSC : Transport of Radioactive Steam GeneratorsAccording to CNSC data (Table 1), about 15 percent of the radioactivitycontained within each Steam Generator is due to transuranic isotopes.These are all high-toxicity man-made alpha-emitters whose atomicnumbers are greater than 92, the atomic number of uranium.The majority of these transuranic isotopes have exceedingly long half-livesand therefore constitute a potential long-term threat to the environment:TransuranicElementAmericium-241Americium-243Curium-244Neptunium-237Plutonium-238Plutonium-239Plutonium-240Plutonium-242Megabecquerels(for all 16 SG)234 40027274 5601362 48084 800120 640122=======577 287

The activities given above are calculated for all 16 steam generators-- 8 from Unit 1 and 8 from Unit 2 -- using the figures given by CNSC.In terms of disintegrations per second, the transuranic isotopes correspondto 577 287 megabecquerels; that is 15.7 percent of the total activity in all16 Steam Generators, given by CNSC as 3.67 terabecquerels.Each alpha disintegration is much more energetic -- usually by about oneorder of magnitude -- than a gamma disintegration [e.g. 5 MeV per alphaparticle compared with 500 keV for a gamma photon or beta particle]. Thusthe transuranic isotopes in the Steam Generators represent about twice asmuch ionizing energy as that of all the gamma and beta emitters combined-- 577 287 x 5 = 2 886 435 Mev of ionizing energy from alpha emitters,compared with 3 092 713 x 0.5 = 1 546 360 Mev of ionizing energy fromgamma and beta emitters. In fact, the transuranics represent about two-thirds of the total ionizing energy inside the steam generators.10

CCNR Submission to CNSC : Transport of Radioactive Steam GeneratorsIt is also well known that, per unit of ionizing energy deposited in livingtissue, alpha particles are about 20 times more biologically damaging thangamma rays or beta particles. Thus, in terms of risks to human health andto the environment, the alpha-emitting contents of the steam generators arethe predominant risk by far.For this reason, we believe that these steam generators should not beclassified as low level radioactive waste or as SCO-1 wastes, but as TRUwastes -- Transuranium Contaminated Wastes -- unsuitable for anythingbut permanent storage at a designated waste storage site. Such wastesshould not be recycled and sold as scrap metal for unrestricted use. Norshould they be transported through the Great Lakes for that purpose.=====================================================http://www.epa.gov/rpdweb00/docs/radwaste/402-k-94-001-tru.html

"Transuranic" refers to atoms of man-made elements that are heavier(higher in atomic number) than uranium. The most prominent element inmost TRU waste is plutonium.Some TRU waste consists of items such as rags, tools, and laboratoryequipment contaminated with radioactive materials. Other forms of TRUwaste include organic and inorganic residues or even entire enclosedcontaminated casesin which radioactive materials were handled.Some TRU waste emits high levels of penetrating radiation; this typerequires protective shielding. However,most TRU waste does not emithigh levels of penetrating radiation but poses a danger when smallparticles of it are inhaled or ingested.The radiation from the particles isdamaging to lung tissue and internal organs. As long as this type of TRUwaste remains enclosed and contained, it can be handled safely.Another problem with TRU waste is thatmost of its radioactive elementsare long-lived. That is, they stay radioactive for a long time.For example,half of the original amount of plutonium-239 in the waste will remain harmfulafter 24,000 years.Disposal must be carefully planned so the waste posesno undue threat to public health or the environment for years to come.11

TRU : Site Selection for Storage and DisposalIn the past, much of the TRU waste was disposed of similarly to low-levelradioactive waste, i.e., in pits and trenches covered with soil. In 1970, theAtomic Energy Commission (predecessor to the DOE) decided that TRUwaste should be stored for easy retrieval to await disposal at a repository.Federal facilities in Washington, Idaho, California, Colorado, New Mexico,Nevada, Tennessee, South Carolina, Ohio, and Illinois are currently storingTRU waste.======================================================

DescriptionLeast hazardous - short & long-livedwaste that will not endanger inadvertenthuman intruder beyond 100 yearsMore hazardous - short-lived wastes thatwill not endanger inadvertent intruderbeyond 100 yearsMore hazardous short and long-livedwastes that will not endanger inadvertentintruder beyond 500 yearsMost hazardous of LLRW - dangerous toinadvertent intruder beyond 500 years.Must be disposed in geologic repositoryunless alternate method proposed byDOE and approved by NRC

Foreword:Bruce Power plans to transport 16 Radioactive Steam Generators (eachweighing more than 100 tonnes) overland to Owen Sound, and then by shipthrough Georgian Bay, Lake Huron, Lake St-Clair, Lake Erie, Lake Ontario,the St. Lawrence River, the Atlantic Ocean and the Baltic Sea to Sweden.The objective of this operation is to have 90 % of the contaminated metalmelted down and sold as "clean" scrap metal for unrestricted use incommercial products of all kinds. Such an operation is not authorized inNorth America, but it is taking place in three countries: Sweden, Ukraineand Russia, where the regulations are more lax.In its 2005 Environmental Assessment of the Bruce A ReactorRefurbishment Project, Bruce Power states that the old steam generators areradioactive waste, not suitable for recycling, and as such they will be storedon site as radioactive waste in the Western Waste Management Facility(WWMF) owned by Ontario Power Generation (OPG), a provincially-owned crown corporation which is also the owner of the Bruce reactors andthe old steam generators.The Canadian Nuclear Safety Commission made a presentation to the OwenSound City Council on Monday, July 26, 2010, about the proposedtransport of radioactive steam generators.The following critique of the CNSC presentation is intended to help citizensunderstand some of the important issues surrounding the transport of thesecorroded radioactive boilers (the steam generators) through our preciousfresh-water and marine waterways.I take full responsibility for any errors and will be happy to correct them ifthey are pointed out. Feel free to disseminate this document or to quote fromit. No special permission is required.Gordon Edwards, Ph.D., August 6 2010.13

Oversight #1. Lack of Context.Mr. Jammal does not mention that CNSC conducted an EnvironmentalAssessment in 2005-2007 related to the refurbishment of the Bruce Anuclear reactors. In the EA documents Bruce Power states that old steamgenerators are classified as low level radioactive waste, and as such willnot be transported off site but will be moved along on-site roads to OPG’sWestern Waste Management Facility (WWMF) for permanent storage.[See EA documents athttp://www.brucepower.com/pagecontentU12.aspx?navuid=3041.]In those same EA documents, Bruce Power maintains that only non-radioactive materials are suitable for re-use or recycling, and thatradioactive components -- such as old steam generators -- can not berecycled “for safety and environmental reasons”.[See Appendix 1.]It is a matter of record that CNSC concurred with those statements byBruce Power and approved the plan laid out by Bruce Power at that time.Bruce Power’s current plan to transport the old steam generators alongpublic roads to Owen Sound, then ship them to a plant in Sweden nearlyhalfway around the world, where 90 percent of the contaminated metalwould be recuperated and released as scrap metal for unrestricted use –this represents a radical departure from Bruce Power’s previous plans andcontradicts some of Bruce Power’s previous statements in the official EA.

Oversight #2. Incomplete Description of CNSC Mandate.In slide #2, Mr. Jammal’s presentation accurately describes two of the threeresponsibilities of the CNSC as laid down in the Nuclear Safety Act: toprotect the health, safety and security of persons and the environment, andto respect Canada’s international commitments vis-à-vis nuclear energy.However, the law also requires CNSC “to disseminate objective scientificinformation” on the nature of the hazards associated with facilities,materials and activities licenced by the CNSC. This responsibility is notreferred to anywhere in the CNSC presentation.The Canadian Coalition for Nuclear Responsibility (CCNR) has found thatthe CNSC is often deficient in fulfilling the latter obligation. In our judgment,little or no objective scientific information has been disseminated or madereadily available to the public by the CNSC about the specific hazardsassociated with radioactive materials such as the nuclear contaminantsinside the old steam generators.On July 14, I addressed the following questions to the CNSC, asking for aprompt reply:(1) who is the designated officer that will rule on the licence applicationof Bruce Power to ship the old steam generators to Sweden?(2) what other shipments of radioactive steam generators have beenmade from North America to Sweden?(3) what radionuclides are contained inside the steam generators, andhow many becquerels of each are there in the most contaminated ofthe steam generators, including alpha-emitters and beta-emitters.On July 15, I asked the CNSC to provide CCNR with the maximum surfacecontact dose (radiation dose) from the most contaminated of the 16 steamgenerators that Bruce Power wishes to ship this fall.It is now more than two weeks since I first asked these questions. Morequestions were posed by me the following week, based on excerpts fromthe 2005 EA. There are no replies to any of my queries as of July 30.Does CNSC accept its duty to disseminate objective scientific information?15

Oversight #3. Lack of Transparency.In slide #4, Mr. Jammal claims that the CNSC operates as a quasi-judicialtribunal with independent Commission members and public hearings thatare webcast. In the view of many Canadians, the independence of theCommission was destroyed when its chair, Linda Keen, was fired in 2008for enforcing safety regulations enshrined in licensing documents. At anyrate, for this particular licence application, there has been no quasi-judicialpublic process, nor have the Commission members deliberated on thematter, nor has the process included public hearings that are webcast.The decision to approve Bruce Power’s licence application, we have beentold, will be delegated to one person: the Designated Officer (DO). Thelicensing process in such a case would be far from transparent. The CNSCshould have realized beforehand that the transport of radioactive waste –even low-level radioactive waste – is an issue of great public concern, not aroutine matter to be settled quietly behind closed doors.In the 1990s, a decision to transport radioactively contaminated soil froma Scarborough subdivision to a military base met with an opposition sostrenuous that the plan had to be abandoned.The decision to transport low-level radioactive waste from Port Hope to awilling Ontario host community led to the formation of a federal agencycalled the Siting Task Force, which spent three years and millions oftaxpayer dollars in a vain attempt to move wastes away from Lake Ontario.Over $250 million has now been allocated to consolidate and store thosewastes close by Port Hope, with minimal transport of radioactive materials.Given this history, and recognizing the precedent that would be establishedby transporting radioactively contaminated reactor wastes through the GreatLakes for the first time, we believe the CNSC has failed to learn from thepast by not setting up a suitable public process to address the Bruce plan.Bruce Power’s plan could impact not only citizens of Ontario, Quebec, theMaritimes and the U.S.A., but also First Nations and Tribes along thetransportation route, as well as Swedes and others concerned aboutpotential contamination of the Atlantic Ocean or the Baltic Sea -- especiallysince Bruce Power will transfer to Studsvik all responsibility (and liability foraccidents?) for the steam generators, once loaded on an ocean-going ship.16

Oversight #4. Competency in Health Matters.No doubt the CNSC employs many highly qualified personnel (slide #6)including lots of professional engineers. But the health sciences are notstrongly represented in CNSC. Even though the health of people and theenvironment is its central mandate, CNSC has no Health Department.The nuclear industry has always been dominated by engineers andphysical scientists, and the same appears to be true for the regulatoryagency. Expertise in engineering is essential, but there is cause for con-cern when health considerations and health expertise receive short shrift.Recently, hundreds of workers involved in the refurbishment of the Bruce Areactors were internally contaminated with alpha radiation by inhaling aninvisible radioactive dust coming from the corroded pipes. Many were toldthey needed no protective clothing or other safety equipment for the jobbecause measured levels of radioactivity were considered insignificant.The supervisors evidently did not understand that alpha-emitting radioac-tive materials are among the most radiotoxic materials known, althoughthey give off non-penetrating radiation and are often difficult to measure.The family of alpha-emitting materials includes radon gas, one of the mostpowerful carcinogens on earth; radium, which killed hundreds of peoplelong before the first reactors were built; polonium-210, used to murderAlexander Litvinenko and considered responsible for up to 90 percent ofthe deaths attributed to cigarette smoking; and plutonium, which has afearsome reputation as a highly toxic radioactive substance.According to reports, most of the workers at Bruce and even most of thesupervisors knew little or nothing about alpha radiation as a threat duringrefurbishment. As a result, hundreds of men are internally contaminatedwith long-lived radioactive materials -- a body burden for years to come.This incident has an eerie resemblance to an earlier one, where workers atPickering were contaminated with radioactive carbon-14 dust and trackedthe contamination into their homes for weeks before anybody noticed. Bed-clothes and furniture were removed from homes and disposed as radwaste.17

In both these cases, the harmful radioactivity was not detected by ordinarymonitoring equipment. Alpha rays have very short tracks, and the same istrue of the weak beta rays from carbon-14., so both are easily missed by themonitors. Inside the body, however, alpha rays are about 20 times moreeffective in causing cancer and other diseases, per unit of energy deposited,than either penetrating gamma rays or intermediate level beta rays.Moreover, the alpha emitters found in a nuclear reactor generally have verylong half-lives. Plutonium-239 has a 24,000 year half-life; neptunium-237has a half-life of two million years. Even carbon-14, a beta-emitter, has a6,000 year half-life, and it can enter freely into the chemical structure oforganic molecules including DNA molecules.These are among the materials that one might find in the primary coolingcircuit of a nuclear reactor, and it is highly likely that they would be found aswell inside an old steam generator. But the presence of these materialsinside cannot be detected by measurements made from outside.

Oversight #5. Contamination Levels.The Canadian Coalition for Nuclear Responsibility believes that citizens areentitled to know the facts about radioactive contamination, and that CNSChas a responsibility to provide those facts in an objective scientific manner.It is not truly objective or scientific to say (slide #16) that the contaminationlevels in a used steam generator are “low”. Low compared to what? Com-pared to a kitchen counter in a normal household? Compared to pressuretubes from the reactor core that must be shielded and stored for centuries?On page 3-37 of Bruce Power’s 2005 EA document, we read the following:Accident Scenario:A transportation-related accident during thetransfer of . . . the old steam generators between Bruce A and theWWMF may occur leading to a radiological contamination that couldreach on-site workers and members of the public….Materialspresent as a gas or as very fine powders are more likely to escape….. . . and on page 3-38 of the same EA document, we read:18

Although the steam generator is a potential source for release ofsome radioactivity due to a seal rupture, several factors limit theamount of radioactivity that would be released. Since there will be novolume reduction step, the majority of radioactivity will remain in atightly sealed adherent film, which is spread out over the internalsurfaces. Therefore, the size of the steam generator will limit theamount of radioactivity that would be released if a seal fails.The CNSC is supposed to represent the interests of people at risk morethan the interests of the nuclear industry. Shouldn’t they be explaining thenature of the radioactive contamination inside the steam generators?Aren’t there dozens of different radionuclides involved? Is there a list? Canwe be told which ones emit alpha, or beta, or gamma, or neutron radiation?Or which ones can be released as a gas or as a powder? Or which onesare sealed in an “adherent film” – and how can we tell that theyaresealed?Citizens should be told that some radioactive materials emit non-penetratingradiation that cannot be detected from outside the steam generator, but arebiologically harmful when inhaled, ingested, or absorbed through the skin.CNSC should give the Becquerel count (disintegrations per second) foreach radioactive contaminant, or else admit that they do not know the exactlevel of contamination in the 5000 tubes inside each vessel. [See appendix 2.]

Oversight #6. Radiation Shielding.Too often citizens are given soothing reassurances that are short on facts.It is true, for example (slide #16) that most of the radioactive contaminationin a steam generator is “confined to the inside”; however it is not true thatthe outside is free of contamination, to the best of our knowledge.A video of the removal of a Bruce A steam generator shows that there isexternal contamination, as workers repeatedly wipe the outside surface toremove as much radioactivity as possible, but the decontamination is notperfect. [Seehttp://www.youtube.com/watch?v=8QnIiUVNdOc&feature=related]Accordingly, on page 3-38 of the 2005 EA we read:

Based on the screening of possible conventional malfunction andaccident scenarios, it was determined that two events are credible,namely a steam generator drop and a refurbishment waste containerdrop, both during loading and uploading operations…. Otherpostulated potential accidents are found to have very limitedpotential to result in radiological consequences….On page 65 of the CNSC Review document, we read that these are theonly two malfunctions or accident scenarios “involving nuclear materials”that are credible during the refurbishment of the Bruce reactors.These accident scenarios are limited to on-site operations only, because,as it is stated on page 3-17 of the EA (and repeated throughout the EA):

Non-radioactive wastes will be re-used or recycled to the degreepossible…. [but] the steam generators will be sealed and transferredto the WWMF.Evidently the current plan to transport the steam generators along off-siteroads, off-load them in Owen Sound, load them onto an ocean-going shipand then sail them through the Great Lakes, along the St. Lawrence River,and across the Atlantic Ocean to Sweden, offers many more opportunitiesfor accidents and numerous potential drop scenarios that were neverconsidered in the original EA or the CNSC Review of that EA.It is sobering to realize that nuclear operators elsewhere are much moreconcerned about the external radiation dose from used steam generatorseven in the absence of any malfunction or accidents. From a 2002 PressRelease of the U.S. Department of Energy we read:20

In order to properly store decommissioned steam generators,mausoleums or storage vaults are designed to minimize the radiationrelease and exposure to plant personnel and the public.The focus of the design guide is to reduce the gamma radiationexposure through the use of concrete walls, floors and roofs. Theguide also addresses the more difficult problem of long-rangeskyshine dose rates, or the radiation escaping the storage vaults andscattered in the atmosphere, and then reflected back to personnel atground level.To what extent the Bruce steam generators resemble the U.S. steamgenerators is unclear, but surely CNSC has an obligation to discuss whatgamma radiation shielding, if any, is considered necessary for the storage,overland transport and shipment of the Bruce steam generators.

Oversight #7. “Safe” Radiation Levels.CNSC refers to its “safe dose limits” (slide 21) that have been adopted fromthe International Commission on Radiological Protection (ICRP) and theInternational Atomic Energy Agency (IAEA), without informing people thatneither of these international bodies believe that those dose limits are safe.We feel CNSC is not giving objective scientific information on this matter.In a 2007 press release announcing the publication of the U.S. NationalAcademy of Sciences Report on the Biological Effects of Ionizing Radiation,(BEIR-VII) we read:

WASHINGTON (June 2007) — A preponderance of scientific evidenceshows that even low doses of ionizing radiation, such as gamma raysand X-rays, are likely to pose some risk of adverse health effects,says a new report from the National Academies' National ResearchCouncil."The scientific research base shows that there is no threshold ofexposure below which low levels of ionizing radiation can bedemonstrated to be harmless or beneficial," said committee chairRichard R. Monson, associate dean for professional education andprofessor of epidemiology, Harvard School of Public Health, Boston.21

ConclusionIt should be a matter of concern that the CNSC, the one agency in Canadaresponsible for protecting citizens and the environment from the potentiallyharmful effects of atomic radiation and radioactive materials, has devotedso much effort in this public presentation to reassuring people withoutinforming them about any of the legitimate concerns that do exist.How does the CNSC view its legal obligation to disseminate objectivescientific information about the nature of the hazards associated withlicenced nuclear facilities and nuclear materials? If the CNSC is content tomerely echo the views of the nuclear industry, then who is responsible foreducating and informing the public about the nature of radioactivematerials, the biological effects of exposure to atomic radiation, and thepotential impacts of nuclear accident scenarios?There are larger questions involved here that go beyond the CNSC’s legalmandate as a regulatory body. They are policy questions -- issues that arefundamentally political in the best and most inclusive sense of the word.Should we be allowing shipments of radioactive waste materials fromdismantled or refurbished nuclear reactors to be transported through theGreat Lakes and St Lawrence Seaway? Should we be allowing thedissemination of radioactively contaminated materials into consumerproducts by releasing contaminated scrap metal for unrestricted use?A growing number of Non-Governmental Organizations, aboriginal groups,political representatives, and ordinary citizens are saying, “No.” These arematters that cry out for public discussion and political debate.Gordon Edwards, Ph.D., Montreal, July 30, 2010.22

Radioactive Steam GeneratorsBruce Power is a privately owned company. It leases eight nuclearpower reactors from Ontario Power Generation, a company that iswholly owned by the Government of Ontario.In 2005, Bruce Power submitted an Environmental Impact Statementto the federal nuclear regulatory agency, the Canadian Nuclear SafetyCommission (CNSC), detailing its plans to “refurbish” two of theBruce nuclear reactors, at a cost of more than five billion dollars.In it Bruce Power describes the 16 used steam generators that havebeen replaced as “radioactive waste” and asserted that these bulkypieces of contaminated equipment will be stored on-site as radwaste.But Bruce Power now plans to send the 16 steam generators, about1700 metric tones altogether, to Sweden, where the radiation-lacedmetal will be melted down and about 90 percent of it will be sold asscrap metal for unrestricted use. The remaining 10 percent will bereturned to Bruce Power for long-term radwaste management.A large and growing public opposition to this plan is based on twomain concerns: that nuclear reactors wastes not be allowed to betransported on the Great Lakes and St. Lawrence River, and thatradioactive wastes not be disseminated into consumer products.Gordon Edwards, Ph.D., President,Canadian Coalition for Nuclear ResponsibilityAugust 201023

Both phases of the Project will produce radioactive waste. For the purposes ofthe assessment, “low level waste (LLW)“consists of industrial items that havebecome slightly contaminated with radioactivity and are of no further use, but alsoinclude the steam generators, feeder pipes and insulation wastes.BPEAPage 3-31As noted,refurbishment activities are expected to generate LLW [low level waste]and ILW [intermediate level waste] includingpressure tubes and calandria tubes,the old steam generatorsand miscellaneous components.BPEAPage 3-29Thesteam generator replacement will generate LLW[low level waste]and ILW[intermediate level waste],including the steam generators themselves….CNSCPage 101Issue:At what point during the refurbishment will the steam generators be removed?Response:The steam generatorswill be removed about halfway through therefurbishment activities. Theseare considered low level waste.

Thesteam generators will be sealed and transferred to the WWMF….BPEAPages 3-28 & 3-29Following removal, thesteam generators will be temporarily stored on-site,prepared to ensure that they meet OPG’s requirements for acceptance at the WWMF,lifted onto transporters with a temporary gantry systemand then transferred to theOPG’s WWMF.…BPEApage 3-30Waste Handling:This includespreparation of removed steam generators fortransportation . . . loading of old steam generators onto multi-wheeledtransporters; and transportation of steam generators to OPG’s WWMF. There willbe 16 old steam generators in total from Units 1 and 2 refurbishment and another16 from Units 3 and 4 refurbishment. These will be transported and stored at theWWMF following removal….

Quotations from Official Environmental Assessment DocumentsAbout Radioactive Steam Generators from Bruce A Nuclear ReactorsBPEAPage 3-37Accident Scenario:A transportation-related accident during the transfer of . . .the old steam generatorsbetween Bruce A and the WWMF may occurleading to aradiological contamination that could reach on-site workers and members of thepublic….Materials present as a gas or as very fine powders are more likely toescape….BPEAPage 3-38Screening of Postulated Radiological Malfunctions and Accidents

Steam generators will not be movedover sensitive buildings/equipment.Activitieswill not be carried out during inclement weather (i.e. gusty wind conditions)….Althoughthe steam generator is a potential source for release of someradioactivitydue to a seal rupture, several factors limit the amount of radioactivity thatwould be released. Since there will be no volume reduction step, the majority ofradioactivity will remain in a tightly sealed adherent film, which is spread out over theinternal surfaces. Therefore,the size of the steam generator will limit the amountof radioactivity that would be releasedif a seal fails.CNSCPage 101Issue:How will you minimize the amount ofcontamination released to theenvironment when the steam generators are removed?Response:… the removal of steam generators will becompletely segregated fromthe ongoing operations…..BPEAPage 3-18[box 3 in middle column]CNSCPage 25[box 6 in right column]

Radioactive wastes from Bruce A are transferred to WWMF….. Allnon-radioactive, non-hazardous solid waste is transported to the on-site conventionalwaste landfill for disposal or off-site for recycling, processing and/or disposalatfacilities licensed to handle such materials.CNSCPage 75Some of the waste is directly recyclable; however, the largest waste quantities areassociated with the pressure-tube/calandria-tube replacement andsteam generatorreplacement, since thereplaced components cannot be recycled and must bedisposed of at the WWMF….

I have examined the above-cited documents by searching for each andevery occurrence of the phrase “steam generator.Nowhere in these documents is there the slightest indication that the oldsteam generators will ever be transported off-site. On the contrary, bothBruce Power and the Canadian Nuclear Safety Commission repeatedlystate that the old steam generators are a form of radioactive waste, whichwill be transported to the Western Waste Management Facility, on-site.Nowhere in these documents is there the slightest indication that thecontaminated metal of the old steam generators will be considered suitablefor recycling as scrap metal intended for unrestricted use.

Appendix 2: Internal Contamination of Steam GeneratorsThe danger from transport of the old steam generators is not limited to thepenetrating gamma radiation that they give off, which is a temporary andpassing danger -- nevertheless a serious one -- but also includes theradioactive contaminants inside the steam generator vessel that could bereleased into the Great Lakes in the event of an accident.Within the last year some 200 workers at Bruce suffered unanticipatedbodily contamination with alpha-radiation emitting radioactive materialsgiven off as an invisible fine dust from the old feeder pipes that had beendetached from the core of the reactor. The supervisors were unaccountablyunaware that these materials were present in the pipes and they told theworkers they did not need any protective clothing or equipment.Those same materials are present in the old steam generators, as well asother radioactive materials which are beta-radiation emitting or gamma-radiation emitting materials. And it is well known that the alpha-emittingmaterials are among the most dangerous of all radioactive materials onceinside the body, though they are virtually harmless outside the body.That's because alpha radiation has very little penetrating power, but doesabout 20 times more damage (per unit energy) as gamma or beta radiation.Please read the following letter from Dr. Frank Greening to the CNSC backin February of this year. Dr. Greening worked for 23 years at Pickering as aspecialist in corrosion of metallic components in nuclear reactors. You willnote that, in this e-mail, sent to the CNSC, he calls attention to the presenceof alpha-radiation emitting radioactive materials found in "feeder pipes,pressure tubes and steam generator components removed from CANDUreactors here in Canada."To understand his letter, reproduced on the next page, one needs to knowthat Pu, Am, and Cm are chemical symbols for the man-made transuranicelements Pu=plutonium, Am=americium, Cu=curium, all of which aredangerous alpha-radiation emitting materials. These materials are notfound in nature; they are created inside operating nuclear reactors.Gordon Edwards, Ph.D.,July 30 2010.

From:"Frank Greening" <[email protected]>Date:February 17, 2010 6:57:09 AM EST (CA)To:"Interventions" <[email protected]>Subject: Alpha Contamination at Bruce NGSTo whom it may concern,As a former analytical chemist for OPG I was surprised to hearthat alpha-emitting particulate was "accidently" released to thevault air of Bruce Unit 1 in November 2009 during "routine"refurbishment operations. I was especially concerned when Iread that this release of alpha-activity was caused by "grindingoperations" on feeder pipes. I trust that Bruce Power is notclaiming that such feeder pipe contamination wasunexpectedbecause OPG and AECL have been well aware of this issue formany years and its not long ago that Bruce Powernuclear reactors were operated by OPG.I discovered alpha contamination on Pickering feeder pipe andpressure tube samples many times during my 23 -year career atOPG. Thus, in the early 1980s I reported surface concentrationsof Pu-238, Pu-239, Am-241, Cm-242 and Cm-244 (in the nCi/mgrange) in the oxide scale on several Pickering Unit 2 inlet feederpipes -- see Ontario Hydro Research Division Report 84-262-Kissued August 13, 1984.I request that this information be passed on to the CNSC staffwho are looking into this incident and ask them to please ensurethat health physicists at Bruce Power are made aware of thelevel of alpha contamination that is to be expected on feederpipes, pressure tubes and steam generator componentsremoved from CANDU reactors here in Canada.Sincerely,Dr. F. R. Greening

A nuclear steam generator (these areUSmodels, notCANDUs) is an enormousvessel with steel walls. It is a nuclear "boiler". However, the water from thecore of the reactor (called the "primary coolant") is not allowed to boil; instead,the primary coolant runs through thousands of small tubes that act as heatingelements to boil other water called "secondary coolant". The steam from thesecondary coolant is then used to spin a turbine and generate electricity.The picture on the right shows the thousands of long narrow tubes inside asteam generator. The tubes become corroded and radioactively contaminatedover time; eventually the entire steam generator has to be replaced.Radioactive materials are deposited on the insides of these tubes by the primarycoolant which comes directly from the core of the reactor. And when thesetubes spring leaks the radioactive contamination passes from the "primary side"(inside the narrow tubes) to the "secondary side" (outside those tubes).Gordon Edwards, Ph.D.30

For Scientists / EngineersSymbolHalf-Life AmountAg 108Am-241Am-243C-14Cl-36Cm-244Co-60Cs-134Cs-135Cs-137Eu-152Eu-154Eu-155Fe-55I-129Nb-94Ni-59Ni-63Np-237Pu-238Pu-239Pu-240Pu-241Pu-242Ru-106Sb-125Se-79Sm-151Sn-126Sr-90Tc-99U-234U-235U-236U-238Zr-93TOTALS(y)1.3E+024.3E+027.4E+035.7E+033.0E+051.8E+015.3E+002.1E+002.3E+063.0E+011.3E+018.8E+005.0E+002.7E+001.6E+072.0E+047.5E+049.6E+012.1E+068.8E+012.4E+046.5E+031.4E+013.8E+051.0E+002.8E+001.1E+061 9E+012.1E+052.9E+012.1E+052.5E+057.0E+082.3E+074.5E+091.5E+06(Bq/m3)2.3E+025.9E+073.8E+047.6E+071.4E+041.4E+071.2E+091.9E+062.2E+012.2E+071.8E+061.6E+073.0E+075.8E+096.3E+002.9E+052.0E+052.9E+071.8E+031.0E+071.2E+071.7E+075.5E+081.7E+048.4E+082.1E+077.6E+017.6E+011.2E+021.8E+072.8E+031.9E+043.2E+023.6E+032.4E+043.8E+02

For Citizens / Decision MakersNameHalf-LifeAmount(years)Silver-108130 yAmericium-241430 yAmericium-2437 400 yCarbon-145 700 yChlorine-36300 000 yCurium-24418 yCobalt-605.3 yCesium-1342.1 yCesium-1352 300 000 yCesium-13730 yEuropium-15213 yEuropium-1548.8 yEuropium-1555yIron-552.7 yIodine-12916 000 000 yNiobium-9420 000 yNickel-5975 000 yNickel-6396 yNeptunium-2372 100 000 yPlutonium-23888 yPlutonium-23924 000 yPlutonium-2406 500 yPlutonium-24114 yPlutonium-242380 000 yRuthenium-1061yAntimony-1252.8 ySelenium-791 100 000 ySamarium-15119 yTin-126210 000 yStrontium-9029 yTechnetium-99210 000 yUranium-234250 000 yUranium-235700 000 000 yUranium-23623 000 000 yUranium-2384 500 000 000 yZirconium-931 500 000 y(becquerels per cubic metre)23059 000 00038 00076 000 00014 00014 000 0001 200 000 0001 900 0002222 000 0001 800 00016 000 00030 000 0005 800 000 0006.3290 000200 00029 000 0001 80010 000 00012 000 00017 000 000550 000 00017 000840 000 00021 000 000767612018 000 0002 80019 00032024 00024 000380

According to thisOPGdocument (see the last2lines), in each cubic metre there are over eightBILLIONradioactive disintegrations taking place every second if we consider only the long-livedradioactive contaminants. Each disintegration releases an alpha ray, a beta ray, or a gammaray; so there are more than eight billion of these rays emitted every second. That’s more than31trillion rays per hour – over274quadrillion (274 000 000 000 000 000) rays per year!There are five plutonium isotopes found in the steam generators. In each cubic metre there areabout39million alpha rays given off each second from four of these five plutonium isotopes.One thousand years in the future, if the steam generators were just stored on-site asradioactive waste for that entire period, these plutonium isotopes would still be giving off about27million alpha particles per second, per cubic metre. Sixteen steam generators have acombined volume of about1000cubic metres, so multiply by this factor to get the total.Gordon Edwards,Ph.D.[NWMO= Nuclear Waste Management Organization;OPG= Ontario Power Generation]

Including

Including