August 16, 2000

ACTION ALERT

WEAPONS PLUTONIUM FUEL

Urgent: Send Your Comments to Transport Canada by August 25, 2000

1) SUMMARY

On July 28, 2000 the Chrétien government announced its plan to fly

weapons plutonium fuel (MOX) from Russia to Chalk River, Ontario.

Transport Canada also announced a 28 day public comment period in

connection with the "emergency response" part of this plan.

Transport Canada's review of AECL's "Emergency Response Assistance

Plan" (ERAP) is the only opportunity for public input at an official

level. Because these public comments are printed and circulated, it

is critical that as many groups and individuals as possible take the

time to state what they think of the plutonium airlift and of the

project in general.

2) WHAT YOU CAN DO

The Friday, August 25,2000 deadline established by Transport Canada

for receiving public comments is fast approaching. Please write, even

if only a few sentences.

In particular, CNP suggests that you emphasize that:

a) you are opposed to the plutonium fuel airlift from Russia;

b) you demand that the whole plutonium fuel import scheme be scrapped;

c) you want Transport Canada to serve the public interest and refuse

permission to fly plutonium;

d) it is illegal to transport plutonium fuel by air in the United

States because there is no container that has been deemed safe

enough. Even Transport Canada admits there is no MOX container

qualified to survive all credible air accidents.

e) that rather than foster nuclear disarmament and nonproliferation,

the plutonium fuel project will encourage the use of plutonium in the

civilian economy and prop up a declining nuclear industry in Canada

and internationally.

(Note: A detailed list of suggested comments follows below)

3) WHERE YOUR COMMENTS CAN BE SENT

The Campaign for Nuclear Phaseout (CNP) urges you to write to:

- Transport Canada by August 25th (mailto:mox@tc.gc.ca);

- Your Member of Parliament

(see the web page

http://www.parl.gc.ca/36/senmemb/house/ProvinceList.asp?Lang=E for

contact info);

- The Prime Minister (fax: 613-941-6900 or mailto:pm@pm.gc.ca), to

express your concerns.

You can make your submission to Transport Canada by:

e-mail: mailto:mox@tc.gc.ca

fax: MOX Comments Officer

Transport Dangerous Goods Directorate

Transport Canada

613-993-5925

regular mail: MOX Comments Officer

Transport Dangerous Goods Directorate

Transport Canada

9th Floor, Tower C

330 Sparks Street

Ottawa, Ontario

K1A 0N5

IMPORTANT: Be sure to tell Transport Canada in writing that you want

your comments published/made public so others can read them. It is

important that public opposition to the plutonium import scheme be

recorded at an official level. Transport Canada can be reached

toll-free by telephone at 1-888-758-9999.

Please also forward a copy of your submission to CNP (e-mail:

cnp@web.net or fax: 613-241-2292).

We also suggest you write to President Bill Clinton because the US

Government is paying for this entire exercise and it is illegal to

fly plutonium fuel under US law. Tell President Clinton how

unacceptable the plutonium import plan is to Canadians, and about the

lack of democratic process on this issue. In addition, ask him why

the US Government would allow air transport through Canadian air

space when it would be illegal in the US.

William J. Clinton

President

United States of America

Washington D.C.

202-456-6703 (fax)

4) WHERE YOU CAN GET MORE BACKGROUND INFORMATION

For more information on plutonium and weapons plutonium fuel (MOX) see:

http://www.cnp.ca/

and

http://www.ccnr.org/

Transport Canada's main MOX page for Russian air transport is:

http://www.tc.gc.ca/tdg/en/mox/russian_mox.asp

AECL's Emergency Plan (ERAP) can be viewed at

http://www.tc.gc.ca/tdg/en/mox/erap.pdf

(note: file is in Acrobat PDF format)

Thank you.

Kristen Ostling

National Coordinator

Campaign for Nuclear Phaseout

====================================================================

DETAILED LIST OF SUGGESTED COMMENTS

̣ The announcement of a 28 comment period during the height of the

summer vacation period is inadequate.

Many Canadians are "out of touch" during this time, many institutions

of higher learning are not in session, and many non-governmental

organizations do not meet during the month of August.

Transport Canada should extend the comment period until at least the

end of September.

̣ In November 1999, Transport Canada approved AECL's plan to

transport the US weapons plutonium fuel by truck, and the Russian

weapons plutonium fuel by land and sea, stating not once but five

times that the plutonium would not be flown for safety reasons.

Then, at the last minute, in January 2000, AECL was granted

permission by Transport Canada to fly the plutonium fuel from Sault

Ste. Marie to Chalk River by helicopter, in complete secrecy.

Transport Canada should have a care for its credibility and for its

responsibility to the Canadian population by acting in a manner

consistent with its original judgment not to allow weapons plutonium

fuel to be flown.

̣ Transport Canada should not approve AECL's plan to airlift

plutonium (MOX) from Russia to Canada, since even Transport Canada

admits there is no MOX container qualified to survive all credible

air accidents.

In its November 1999 report, Transport Canada stated "the material

will not be flown" because a severe transportation accident "could

result in the release of a heavy dust [which] has the potential for

damage if inhaled." Noting that AECL would be using a Type B

container (rather than a Type C container or better, as required by

US Law for air transport), Transport Canada was firm that the MOX

test samples could not be flown: "Not until there were a container

deemed safe enough to survive all credible airplane accidents."

Transport Canada should demand detailed proof that the chosen

container can withstand all credible air crashes. According to our

research, there is no such proof - see

http://ccnr.org/lyman_casks.html.)

̣ In an August 2nd Canadian Press article, John Read, director

general of the Transport Dangerous Goods Directorate of Transport

Canada, stated that AECL must show how it would "effectively respond"

to the worst accidents, including the release of plutonium dust. He

is quoted as saying: "If they can't, they don't ship."

When heated in the presence of oxygen, ceramic MOX pellets

spontaneously swell (increasing their volume by as much as 30

percent) and crumble into dust. In 1982, a German Laboratory reduced

a MOX pellet to a fine powder by heating it at 400 C for just 30

minutes. That's not very hot - about the temperature of a kerosene

fire. (AECL has used the same technique, at about the same

temperature, to pulverize nuclear fuel pellets in its "DUPIC"

process.)

If the package is damaged in a severe air crash, allowing oxygen to

get to the MOX fuel, then fire - even at relatively low temperatures

- could release a fine plutonium-bearing powder into the atmosphere.

Once released, such radioactive dust is extremely difficult to

control, locate, or clean up. That's why the USA has a strict law

which effectively prohibits the air transport of plutonium, given the

extraordinary toxicity of inhaled plutonium dust.

There is no indication that AECL or Transport Canada has seriously

addressed this kind of accident scenario. Hence permission for air

transport should not be given.

̣ Tranport Canada has not been sufficiently diligent in requiring

AECL to delineate and demonstrate exactly how it would respond to the

dispersal of a fine plutonium dust into the atmosphere.

Last year, two Chalk River employees were over-exposed to respirable

plutonium dust even though they were wearing protective equipment.

Charges have been laid against AECL by the Nuclear Safety Commission

(formerly known as the Atomic Energy Control Board) in connection

with this incident.

Although AECL has many years of experience in dealing with other

types of radioactive materials and radioactive spills, it appears

that AECL is not experienced in dealing safely with releases of

alpha-emitting powder into the atmosphere in a respirable form, as

the above episode illustrates.

Transport Canada should not approve the emergency plan in the absence

of detailed plans from AECL for identifying, locating, controlling

and retrieving an atmospheric dispersal of plutonium-bearing dust,

and dealing with plutonium-contaminated casualties.

̣ Tranport Canada has a responsibility to potentially affected

communities. Yet in AECL's emergency plan for air transport of

weapons plutonium, there are no routes delineated and no potentially

affected communities specified.

Has Transport Canada contacted all of the emergency services in all

of the potentially affected communities, including municipal

governments, emergency responders and hospitals along the route?

The communities potentially affected by an accident have a right to

know that they are on the flight path. Transport Canada should not

approve AECL's emergency plan as it lacks this essential information.

̣ Approval of AECL's plan to transport plutonium fuel (MOX) by air

using an inadequate "Type B" container, would set a dangerous North

American precedent.

The International Atomic Energy Agency (IAEA) has, since 1996, been

formulating standards for a stronger "Type C" container, intended for

transporting radioactive materials by air. The only reason "Type B"

casks are permitted at present by IAEA is because the new standards

have not yet been adopted.

It is illegal to transport plutonium fuel by air in the United States

because there is no container that has been deemed safe enough. Even

a Type C container, as currently envisaged by IAEA, would not be

strong enough to meet US standards.

Approval of air transport of Russian MOX using a Type B container

would be a North American first and could be seen as establishing a

dangerous precedent, especially since it is a high visibility

shipment.

Transport Canada should not allow itself to be used in this way; it

should not approve the controversial air transport plan, especially

as there is an alternative transportion plan it has already approved.

̣ AECL and Minister Goodale have told Canadians that it is virtually

impossible for plutonium to be released in a respirable form under

any conceivable accident scenario. Yet the US Department of Energy,

in a 1997 environmental assessment document, states:

"Two credible transportation accident scenarios were analyzed for the

shipment of MOX fuel to the Canadian border . . . .

"The first accident relates to an event that leads to the MOX fuel

package container breaking open, igniting, and releasing plutonium

dioxide particles into the air. The public is assumed to be near

enough to the accident to breathe air contaminated with plutonium

dioxide."

The report makes it clear that this scenario, while unlikely, has "a

reasonable probability of occurrence". (Section 5.2 "MOX

Transportation Accidents")

Moreover, in the previous AECL Emergency Plan for land and sea

transport, AECL identified 4 out of 8 categories of accidents where

the container would be completely destroyed. But in the new plan,

there are no discussion of accident scenarios at all.

Transport Canada should not approve the emergency plan because the

Canadian public, and Transport Canada itself, appears to have been

misled about the possible consequences of credible accident

scenarios. AECL should be required to publish its detailed accident

analyses and subject them to independent public scrutiny.

̣ The "Parallex Project" was originally intended to lay the

groundwork for a parallel, symmetric reduction in the excess weapons

plutonium stockpiles of the USA and Russia.

When the US announced earlier this year that they have no intention

of sending any more plutonium to Canada, the stated rationale for the

Parallex Project collapsed. Yet the Project still proceeds as if

nothing has changed.

In fact, Russia is now sending four and a half times more plutonium

than the U.S. There is no parallelism left any more, even for the

test phase of the plutonium import program.

Transport Canada should not approve the emergency plan until a

consistent new rationale for the project has been submitted.

̣ Importing weapons plutonium to Canada will not serve the interests

of nuclear disarmament or nonproliferation.

Like the House of Commons Standing Committee on Foreign Affairs and

hundreds of Canadian municipalities, we are opposed to the

transportation of plutonium fuel by air, land or sea, and to Canada's

"approval in principle" of a weapons plutonium import program.

The use of plutonium fuel in civilian reactors will encourage the

circulation of this dangerous nuclear explosive material in the

civilian economy, not only in Canada and the US, but also in Russia,

and possibly in other countries with Canadian-designed reactors such

as India, Pakistan, Taiwan, Korea, Argentina, and Romania.

Canada's plutonium import program could seriously undermine the

non-proliferation objectives of policies first adopted by the Carter

Administration in the late 1970s and supported by every subsequent US

administration, to discourage the widespread civilian use of

plutonium - in order to minimize the global spread of nuclear weapons

materials and capabilities.

Instead of approving the flawed emergency plan submitted by AECL,

Transport Canada should recommend to the Government of Canada that

public consultations be held with Canadians on the rationale and

non-proliferation implications of the proposed plutonium import

program.

̣ The impetus for the idea of burning plutonium in reactors comes not

from the peace and disarmament community, but from the nuclear power

establishments of Russia, the US and Canada - all of whom would like

to see their aging reactors running for another 25 years or more.

This raises many legitimate public safety concerns.

When a CANDU reactor is fueled with MOX, the radioactive inventory in

the reactor core ends up being four to five times greater than if the

same reactor were fueled with natural uranium. Therefore, the harmful

consequences of a reactor accident involving fuel damage will be

correspondingly much greater if MOX fuel is used.

MOX fuel is also more reactive than natural uranium fuel, making

greater demands on the control and shut-down systems of a CANDU

reactor fueled with MOX. Therefore, the probability of a serious

reactor accident is correspondingly increased if MOX fuel is used.

Instead of approving the flawed emergency plan submitted by AECL,

Transport Canada should recommend to the Government of Canada that

public hearings be held on the entire range of reactor safety

implications associated with the use of MOX fuel.

̣ When a CANDU reactor is fueled with MOX, the irradiated fuel ends

up being four to five times more radioactive than if the same CANDU

had been fueled with natural uranium. The plutonium content of the

spent fuel is also correspondingly greater in the MOX case.

These characteristics of irradiated MOX fuel will introduce

additional complications in the long-term storage of high level

radioactive waste because of increased heat generation, increased

concentration of fission products, and increased probability of

accidental criticality (whereby the residual plutonium in the

irradiated fuel spontaneously undergoes a nuclear chain reaction).

Instead of approving the flawed emergency plan submitted by AECL,

Transport Canada should recommend to the Government of Canada that

public hearings be held on the safety, security, and cost

implications of the long-term storage of irradiated MOX fuel.

̣ Instead of promoting an initiative which will serve to prop up a

dying nuclear industry, Canada should be phasing out nuclear power

and calling for the end of the production of plutonium.

It is time for Canada to get serious about the global plutonium

problem and promote an international initiative to halt the

production of new plutonium, to oppose the separation of plutonium

from irradiated fuel for any purpose whatsoever, and to take existing

separated plutonium out of circulation, treat it as a dangerous waste

product and guard existing weapons plutonium stocks under a strict

international security régime.

Instead of approving the flawed emergency plan submitted by AECL,

Transport Canada should recommend to the Government of Canada that

public hearings be held on alternative methods for dealing with

excess weapons plutonium and other stockpiles of separated plutonium,

including vitrification and other immobilization options.

̣ The manner in which the weapons plutonium fuel issue has been

managed in Canada has been fundamentally undemocratic.

During the Fall 1999 comment period on AECL's emergency plans, 96

percent of the submissions made to Transport Canada were opposed to

the project.

In 1998, after parliamentary hearings, the Standing Committee on

Foreign Affairs and International Trade recommended that the

plutonium import project be scrapped because it was found to be

"unfeasible" in terms of non-proliferation objectives.

First Nations communities along with hundreds of municipalities,

including 167 municipalities in Quebec, have passed resolutions

against this project. In addition, the Federation of Canadian

Municipalities passed a resolution against the project, as well as

the Conference of Great Lakes Mayors. Firefighters and Police

associations have recommended that the project not go forward.

It is time for the federal government to listen to the wishes of

Canadians. Transport Canada should recommend that the Government

either withdraw the project, or failing that, hold broad public

consultations - including full public hearings - to allow meaningful

public input on Canada's plutonium policies before the project goes

any further.