SG / CNSC Interventions…# 2

I’ve been talking about the steam generators from Bruce Power in Ontario, & the Canadian Nuclear Safety Commission (CNSC) hearing held in Ottawa this past week on Bruce Power’s plan to ship 16 radioactive steam generators through a multitude of waterways to Studsvik, Sweden [note: Webcast of the hearing can be viewed here.] My previous post, SG/CNSC Interventions…# 1, gave some background info & also included my “intervention letter” to the Canadian Nuclear Safety Commission.

This post contains the remarks I prepared ahead of time & took to Ottawa with me. This is what I intended to say.

Then, life had its way with me, the hearing had its way, & I had to re-write my remarks (which will be in the next post).

Here is what I originally intended to say:

CNSC Tribunal members, CNSC staff, fellow intervenors:

It is awkward & perhaps a bit impolite for me to say so, but I always get the sensation at CNSC hearings that, like Alice in Alice in Wonderland, I’ve inadvertently gone down a rabbit hole.

As I began to read the CNSC staff CMD 10-H19 [CMD = Commission Member Document] on this matter, I experienced that sensation right away.

In the Executive Summary (page 1), the generators are described as “Surface Contaminated Object,” then a paragraph later are described as having no surface contamination.

It didn’t take long to fall down the rabbit hole!

Something else that comes up every time I delve into CNSC materials is that I always find myself being thoroughly underwhelmed by the language used in CNSC documents & public statements.

This is an organization – & a staff – that purport to be very “scientific.” Yet the staff always uses language such as:

  • Small (spills of heavy water at Chalk River & the Bruce are ALWAYS small)
  • Low (risks of any activity put forth by nuclear proponents are invariably low)
  • Acceptable (the nuclear proponent’s plan is ALWAYS acceptable)
  • Adequate (the nuclear proponent’s “proposed security measures” are invariably adequate.

A person might suppose from the language being used that we were dealing with baking cookies, or child’s play of some sort.

When in fact we are dealing with substances & wastes that are not merely toxic & carcinogenic, but substances & wastes that will remain highly dangerous for decades, centuries, & in some cases thousands & tens of thousands of years.

Do the CNSC Tribunal members & staff not think that in dealing with such dangerous substances it might be a little more reassuring for the public to hear language that has a little more oomph & conviction?

I for one am not at all reassured about CNSC & nuclear industry plans when they are described in the weak & utterly un-scientific language I am always hearing used in CNSC documents.

Not reassured at all.

Nor am I reassured by the assertion of Bruce Power, which “believes it has met all the requirements” & is making “adequate” provision. Pretty mingy language.

My intervention is focused on the issue of radioactive materials having become a serious problem globally. The nuclear industry’s idea of “free release” means we are all now free to buy consumer goods containing nuclear waste. Ah, freedom…

Only recently have I become aware that I – along with consumers all over the world, I assume – am now at risk of going to a store to purchase a new toaster & bringing home a lot more than I bargained for.

And this is not mere fluke. It appears the nuclear industry is doing this quite deliberately!

Nuclear facilities are being dismantled & “recycled” into consumer goods.

Citizens around the world have become unwitting recipients of this “largesse” from the nuclear industry.

Shocked & appalled would be a good way of describing my own reaction to this recent realization.

(And btw, the person who pointed this out to me works for the Steel Manufacturers Association in Washington. The industry he works for has a policy – basically, “zero tolerance” for radioactive materials. Members of the steel industry don’t want it – from a worker health perspective & of course, from a consumer perspective. I’d be happy to share their policy statement with you.)

I myself went shopping very recently to look for a wedding shower gift for my daughter.

I wanted to buy her a set of cutlery, I suppose because I recall being given a very nice set of cutlery 35 years ago, before my own wedding.

As I looked over the many consumer goods on the store shelves, I noticed that all their cutlery offerings were “Made in China.” Buying products from China has become almost inevitable, but carries some…uncertainties, lately, shall we say...

So I stood in the aisle, looking at the cutlery, wondering “Gosh. Now I have to wrestle not just with the issue of whether it is really ethical to buy products made by people who are being exploited, but whether I might also unwittingly be introducing radioactive cutlery into my daughter’s home.” Egad.

Having a social conscience is … well. It makes life complicated, doesn’t it?

Martin Luther King said “Our lives begin to end the day we become silent about things that matter.”

I’d say keeping silent about having radioactive waste made into consumer products is something I wouldn’t be at all happy with myself about as the years go by. My eventual grandchildren might not be too happy with me either. As they chow down with their toxic knives & forks. “A little plutonium with your Cheerios, Susie?”

The 2006 United Nations report “Recommendations on Monitoring & Response Procedures for Radioactive Scrap Metal” is quite informative on this subject. Its introduction spells out that the financial consequences for any metal processing facility that winds up with an incident involving the detection of radioactive scrap metal are very serious – often closure of the facility & an expensive clean-up. The comment is made “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.”

Yikes. I guess so!

As we all know very well, prevention is always the best way to keep a bad problem from happening. And, in this case, to keep a serious problem from growing worse.

Now, Bruce Power (a company with the unfortunate acronym of BP – an acronym none of us will soon be able to forget) expects us to “trust” them – that their plan to ship radioactive steam generators to Sweden is a safe & prudent one.

Bruce Power is known most recently for exposing its workers to alpha radiation, so the issue of trust there is not exactly straightforward, is it?

There are in fact so many reasons to oppose this plan of Bruce Power’s that it’s hard to know where to begin.

I’ve read the interventions you have received.

One intervenor calls it an insane plan. Another says it is nothing short of madness.

I have to agree with these assessments.

For starters, there was already a plan in place. What happened to that?

For another, what’s the big rush? These steam generators have been mothballed since 2007. Why the sudden rush to ship them out? Without due process, no less?

Whatever happened to the precautionary principle?

This seems more like a Ready, Fire!! …. Aim project.

It seems to me the nuclear industry (& CNSC staff) have not prepared for all possible contingencies, & simply expect the public to go along with their plans, unquestioningly.

There is tremendous opposition to this proposal, & from many quarters. Especially with the other BP’s disaster so fresh in our minds. I would remind you that the other BP assured the U.S. Department of the Interior in 2009 that an oil spill at the Deepwater Horizon site was “unlikely.” An environmental impact study was therefore waived.

I implore the CNSC to put this plan on the shelf.

At the very least, if there is interest in having this plan go forward, there must be an Environmental Assessment, as the terms of this new, recently-hatched plan represent a huge change from the original plans put forward by Bruce Power & approved by CNSC.

30 days is an utterly inadequate time frame in which to expect the public to scrutinize such a huge undertaking, & in which to review such voluminous & complex materials & respond with expert testimony.

Finally, of course, intervenors have been provided with no resources & have had to scramble, rendering this process unfair, undemocratic & unreasonable.

It seems to me this plan must be shelved.

For reasons that are numerous & that take in

  • legal
  • procedural
  • moral & ethical
  • safety &
  • scientific

grounds, it seems to me the CNSC Tribunal has no choice but to put this plan on the back burner.

Thank you for the opportunity to share my views on this matter.