Campaign for Nuclear Phaseout

version française

August 16, 2000
(with revisions, Sept. 2000)

CNP ACTION ALERT
WEAPONS PLUTONIUM FUEL

Urgent: Send Your Comments to Transport Canada
 
 

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 deadline established by Transport Canada for receiving public comments is fast approaching. Please write, even if only a few sentences. (Update: Please note date extension information at the top of this page)

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 scheme 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 before the deadline (e-mail: 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 e-mail to: pm@pm.gc.ca), to express your concerns.

You can make your submission to Transport Canada by:

e-mail:
mox@tc.gc.ca

fax:
MOX Comments Officer
Transport Dangerous Goods Directorate
Transport Canada
613-993-5925 (fax)

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:

www.cnp.ca and 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/erap1.asp (note: file is in Acrobat PDF format)

DETAILED LIST OF SUGGESTED COMMENTS
 

• 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.
   

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