SG / CNSC Interventions…# 1

As referred to in the post Radioactive Cutlery, Anyone? I’ve been working on a nuclear issue of late. Bruce Power & the Canadian Nuclear Safety Commission staff are keen to send 16 radioactive steam generators [hence, the acronym SG in the title] through the port of Owen Sound, Ontario & along a route (thanks for spelling all this out, Mike!!) through Lake Huron, down the St. Clair River, across Lake St. Clair, down the Detroit River, across Lake Erie, down the Niagara River, across Lake Ontario, down the St. Lawrence River, across the Atlantic Ocean, finally arriving at Studsvik, Sweden on the Baltic Sea.  (Studsvik is also the name of the metal processing corporation that is supposed to recycle the radioactive steam generators; this company currently plans to increase radioactive materials processing in Tennessee & the United Kingdom as well.) I must also point out that this shipment would be merely the first of many. Bruce Power is running out of space for its retired steam generators, apparently. There are 16 more ready to go after this first lot...

The Canadian Nuclear Safety Commission – CNSC – held a hearing about this matter for 2 days in Ottawa, Ontario, this past week (Sept. 28th & 29th). They held a public hearing on this somewhat gargantuan proposal only because there had been a very great deal of squawking about it on the part of concerned citizens, groups, municipalities & First Nations communities. [Note: Webcast of the hearing can be found here.]

This proposed shipment would be precedent-setting, in that it would represent a new policy on the part of the Canadian government – allowing Canada to start shipping its nuclear wastes across the world, & thereby contributing to the growing worldwide problem of metal (& consumer goods) becoming contaminated with radioactive waste.

I’ve got plenty to say about this issue – this is my 2nd post about it, & there will be more to come.

All I’m doing here is introducing the issue, & now I’m going to paste in the “intervention letter” I sent to the CNSC on September 13th, notifying them of my concerns & my intent to “intervene” in person on the day of the public hearing.

(After this I’ll also post the remarks I made in person to the CNSC on September 29th.)

Here goes:

September 13, 2010.

Ms. Louise Levert

Secretariat - Canadian Nuclear Safety Commission

280 Slater Street, P.O. Box 1046

Ottawa, Ontario K1P 5S9.

Dear Ms. Levert:

Re: Planned Shipment of Steam Generators from Bruce Power to Sweden –

Hearing Date: Sept. 29, 2010.

I have a number of concerns about this matter:

1. Why have Bruce Power (and the CNSC) changed the plans made and laid out in an Environmental Assessment in 2005? These generators were to remain at the Bruce site, having been declared nuclear waste and, as such, not fit for recycling. They are to be stored on-site as radioactive waste in the Western Waste Management Facility (WWMF).

2. Sending large shipments of nuclear waste via critical waterways is a phenomenally bad idea. Far too many risks involved, at all stages.

3. There is a global problem involving the contamination of scrap metal with radioactive material. This worldwide dissemination of radioactive wastes is bad for the environment, bad for workers and bad for consumers. This is the focus of my intervention.

According to a magazine article from the Bureau of International Recycling, following a conference held in 2009 in Düsseldorf, Germany, ELG Haniel Metals Chairman/Director Michael Wright warned that “Radioactive scrap is a global problem that affects every recyclable metal.”

Furthermore, it was reported that, “Worldwide, governments lose track of 200 to 400 orphan sources each year.”

And, that governments are “not accepting their responsibility” for these orphan sources.

A 2009 newspaper report from Germany states, “The German government has become increasingly concerned over the last six months by the incidence of stainless steel products exhibiting radioactive contamination. In total, some 10 tons of material have been identified so far, spread across a wide range of material forms, from stainless steel wire wool, to bars, valves, castings and flat products.”

I myself have only recently become aware that scrap metal companies, scrap dealers and steel mills must now routinely use scanning equipment to detect contaminated scrap – but as anyone with any imagination can readily surmise, there are not sufficient funds nor staff hours for every dealer to scan every single piece of metal being transported around the world.

The International Atomic Energy Association has reported that there may be more than 1 million missing radioactive sources worldwide.

Paul de Bruin, radiation safety chief for Jewometaal Stainless Processing in Rotterdam, the Netherlands (the world’s largest stainless steel scrap facility), has stated “The world is waking up very late to this.”

Indeed.

In recycling the “leftovers” from nuclear uses, the smelting process contaminates both recycled metal being used in the manufacture of new products, and the furnaces that process the material.

Of course, it also exposes workers to hazardous materials, thus endangering their health.

In the U.S., the Steel Manufacturers Association is very concerned about this, and has a very clearly enunciated policy regarding radioactive scrap. Zero tolerance is the best way to describe the organization’s policy.

In 2006, the United Nations produced a report called “Recommendations on Monitoring and Response Procedures for Radioactive Scrap Metal.” This came out of a meeting of an “International Group of Experts” from the Economic Commission for Europe. In the report’s introduction, after spelling out that “the economic and financial consequences of such incidents [i.e., incidents involving detection of radioactive contamination] for the metal processing industry are always very serious,” (usually involving the closure of the facility and expensive clean-up action), it states, “In addition, such incidents can lead to a loss of trust in the recycled metal industry and the associated products since consumers do not wish to have unnecessary radiation emanating from their purchases” (italics mine).

I would call that a considerable, if somewhat ironically amusing, understatement.

The report goes on to predict a rise in the occurrence of such incidents, due to the “ever-increasing use of scrap to produce processed materials, the wider application of radiation monitoring procedures and the ever-increasing effectiveness of radiation detection equipment.”

This lengthy report then spells out the various individuals and organizations with responsibilities for scrap metal and lays out recommendations for dealing effectively with the problem.

Bruce Power and the Canadian Nuclear Safety Commission are clearly implicated with responsibility for their role in proposing to contribute to the already-serious problem of radioactive metals circulating in our world.

To cut right through all the complexities involved with this scheme of Bruce Power (and enthusiastically backed by CNSC staff), I would like to remind us all of the very old maxim, “An ounce of prevention is worth a pound of cure.”

Since the IAEA itself has reported that “there may be more than 1 million missing radioactive sources worldwide,” it seems crystal clear that our federal nuclear regulator – and indeed our own federal government – really have no choice but to put this plan on the shelf.

There are many people who oppose this plan, from politicians to citizens to environmental organizations and First Nations communities. Workers do not wish to be exposed to radioactive contamination in scrap metal, and citizens certainly do not wish to become unwitting consumers of products contaminated with radioactive materials.

Our already-seriously affected waterways cannot possibly be subjected to any more unnecessary insults.

I call on you to ensure that this plan is shelved.

Respectfully submitted,

Janet McNeill