Comments on the proposed airlift
of plutonium fuel from Russia
August 25 2000
MOX Comments Officer
Dangerous Goods Directorate
I am writing on behalf of the Canadian Coalition for Nuclear Responsibility (CCNR) to comment on the Emergency Response Assistance Plan (ERAP) of Atomic Energy of Canada Limited (AECL) relating to the planned aerial transport of a sample of weapons-plutonium-based mixed oxide fuel (MOX) from Moscow to Chalk River, Ontario, as an integral part of the Parallex Project. The sample consists of 528 grams of plutonium-239 incorporated into 17 kilograms of MOX fuel.
CCNR is a federally-incorporated non-governmental organization with a mandate for education and research on nuclear issues. CCNR has been actively researching plutonium-related issues since its inception in 1975.
CCNR was an active participant in Transport Canada's 1999 public comment period. CCNR also submitted comments to the US Department of Energy relating to its earlier Environmental Assessment on the Parallex Project.
CCNR requests that the current comment period be extended until the end of September, as many individuals and organizations in Quebec and elsewhere who wish to comment on these plans were unable to do so at the height of the vacation period. Our organization, for example, routinely avoids scheduling meetings in August because of the difficulty of finding a time when everyone is available to meet.
CCNR urges Transport Canada not to approve AECL's plans for the air transport of weapons-plutonium-based mixed oxide fuel (MOX) from Russia to Chalk River Ontario for the reasons indicated in this document.
CCNR would utilize the extension period to explore issues of air transport, credible accident scenarios, and emergency response in greater depth.
Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility
Regroupement pour la surveillance du nucléaire
CCNR believes that Transport Canada
should not approve the air transport of
fuel for the following reasons:
- Approval of AECL's air transport plan will expose Canadians to unnecessary risks, and will seriously damage the credibility of Transport Canada's Dangerous Goods Division as an entity concerned with protecting public safety first and foremost.
1.1. Transport Canada has already approved a surface transport plan for the Russian MOX fuel in November 1999, and at that time and in that context, assured Canadians that neither the US MOX nor the Russian MOX would be flown, for good and sound safety reasons:
Excerpt from Transport Canada's 1999 Approval Document:
''H. Safety of MOX FuelAs the planned shipment involves 528 grams of weapons-grade plutonium, there is a theoretical potential for many human lung cancers -- an absolute maximum of 19 million -- if the material were disseminated into the atmosphere in a respirable form, such as a fine dust, following a severe accident.
''H.2 [ Public comment, paraphrased by Transport Canada ]
This material is very carcinogenic. Only need to inhale 27 micrograms of plutonium dust to cause lung cancer in a human adult.
[ Response to public comment by Transport Canada ]
Because it has the potential for damage if inhaled, the material will not be flown and will be contained in a Type B container to ensure there is no rupture, crushing and subsequent release of any dust.''
Transport Canada should stick to its previously announced decision and not allow the air transport of plutonium.
1.2 Transport Canada has publicly indicated that air transport of MOX is riskier than surface transport. As there has been no safety-related rationale offered by AECL for abandoning the surface transport plan, Transport Canada should refuse to approve the new, riskier, air transport plan:
Excerpt from Transport Canada's 1999 Approval Document:
''H. Safety of MOX Fuel
''H.9 [ Public comment, paraphrased by Transport Canada ]
''MOX fuel is not a regular dangerous good. Accident consequences are far reaching.
[ Response to public comment by Transport Canada ]
''A very severe and highly unlikely accident could result in the release of a heavy dust. Because it has the potential for damage if inhaled, the material will not be flown and will be contained in a Type B container to ensure there is no rupture, crushing and subsequent release of any dust.''
Since the half-life of plutonium-239 is about 24,000 years, any dust releases of plutonium will remain in the environment for a period of time that far exceeds the span of recorded human history.
In fact, if 528 grams of plutonium-239 were released to the environment and never recovered, there would still be over 280 milligrams of plutonium-239 remaining in the environment after a quarter-of-a-million years -- and that residual amount is enough to cause 14,000 human lung cancers (in addition to countless other cancers that may have been caused during the intervening millenia).
Transport Canada should not approve the air transport of plutonium because while the probability of a severe accident may be small, the consequences of such an accident are sufficiently far-reaching and long-lived that the risk is not worth taking.
1.3 In November 1999 Transport Canada indicated, correctly, that Type ''B'' containers -- such as the one that AECL plans to use for the air transport of the Russian MOX -- are not qualified to withstand all credible air accidents:
Excerpt from Transport Canada's 1999 Approval Document:
''I. Mode of Transport
''I.1 [ Public comment, paraphrased by Transport Canada ]
''The Government could change air regulations. Could fly over less populated areas.
[ Response to public comment by Transport Canada ]
''Not until there were a container deemed safe enough to survive all credible airplane accidents.''
It is well-known, and acknowledged by Transport Canada, that it is illegal in the United States to transport MOX fuel by air in a Type ''B'' container such as the one chosen by AECL, because such containers do not meet the standards of toughness required by US law.
Type ''B'' containers are currently still allowed in Canada for the air transport of MOX because new standards for Type ''C'' containers -- designed to be more suitable for air transport -- are currently under development by the International Atomic Energy Agency (IAEA).
It is our understanding that the Canadian Nuclear Safety Commission (formerly the Atomic Energy Control Board) bases its standards for transport containers on recommendations of the IAEA.
It is our understanding that even the accident-resistance specifications currently under consideration for a Type ''C'' container would not meet the far more stringent requirements of US law -- requirements which must be satisfied by any proposed container before it may be considered for use for the air transport of plutonium in US air space.
In the absence of a container able to withstand severe air accidents, AECL's air transport plan should not be approved.
1.4 AECL has not been forthcoming in its discussion of accident scenarios. Nowhere does AECL point out that MOX pellets, when heated in the presence of oxygen, chemically react -- they expand, increasing volume by as much as 30 percent, and crumble into dust.
Experiments conducted at the Fraunhofer Institute in Germany indicate that oxidation and pulverization of ceramic MOX fuel pellets is most severe at temperatures considerably below 800 degrees Celsius -- the lowest temperature mentioned in the ERAP, and the temperature at which the Type B and C regulatory tests are conducted.
After 30 minutes exposure at 400 degrees Celsius, MOX pellets were found to have completely pulverized in the laboratory, with scarcely any coarse pieces and considerable production of fine powder. However at 800 degrees Celsius, the pellet shapes were still recognizable.[H.Seehars and D.Hochrainer, ''Durchfuhrung Experimenten zur Unterstutzung der Annahmen zur Freisetzung von Plutonium bei einem Flugzeugabsturz,''
(in German), Fraunhofer-Institute, SR 0205A, March 1982.]
AECL routinely uses a temperature much below 800 degrees Celsius to pulverize ceramic fuel pellets in its DUPIC process. It is a mystery why AECL does not describe this phenomenon, or even refer to it, in discussing accident scenarios and consequences, given the importance of pulverization from a public health perspective due to the extraordinary toxicity of inhaled plutonium dust.
Production of respirable particles (aerodynamic diameter less than 10 micrometres) is also greatly enhanced at the lower temperature -- 1.87 percent of the initial mass of MOX pellets was converted to such a form after only 15 minutes at 400 degrees Celsius in air, as compared to 0.01 percent at 800 degrees Celsius.
Type B casks are designed so that they will lose only a specified fraction of their contents if they are exposed to accident conditions equivalent to an impact of 13.2 meters per second [that is, 47.5 kilometers per hour or 30 miles per hour] on an unyielding surface, followed by a fire with a flame temperature of 800 degrees Celsius for 30 minutes.
But if the package is damaged and the cladding of the fuel rods is damaged, so that oxygen can get at the MOX fuel pellets inside, then -- even at temperatures much lower than 800 degrees Celsius -- the remainder of the cladding may burst as the pellets swell in size, and considerable production of fine particles of dust may result.
Transport Canada should not approve AECL's air transport plan because the emergency response measures are not adequately described or delineated. In particular, there are no specific routes provided, no potentially affected communities identified, and no decontamination procedures outlined in adequate detail.
2.1 Communities along the flight path should be prepared and know how to respond in the event of a radiological emergency.
This is especially true for the Eastern Canada portion of the flight, where (according to the ERAP) it may take from 3 to 6 hours for the RAT (Radiological Assessment Team) to reach the scene.
But there is no discussion in the ERAP of instructional materials provided to communities whose emergency services, including hospitals, may be tested by such a radiological emergency.
Have medical personnel been told the proper precautions to take in handling radioactively contaminated casualties, since plutonium contamination can't be detected by a standard radiation meter such as a geiger counter?
Presumably, much of the air transport will take place over native land. Even if an accident occurs far from any town or village, there may be trap lines and/or hunting or fishing grounds affected.
Yet there is no discussion in the ERAP of special precautions that should be taken by native trappers, hunters, or fishers who may find themselves in the vicinity of a potential radiological emergency, nor is there any discussion of instructional materials -- do's and don'ts -- provided to native communities whose members may be affected by such a radiological emergency.
Approval of AECL's air transport plan would be irresponsible since the potentially affected communities have not been clearly identified, properly notified, and instructed in the proper procedures to follow in case of accident resulting in offsite plutonium contamination.
2.2 As there is no adequately detailed plan of action in the ERAP for coping with a radiological emergency following an aircraft accident, the air transport of Russian MOX fuel should not be approved.
The mere availability of trained men and equipment is not sufficient to deal with a radiological emergency, lacking a well thought-out and rehearsed plan of action. This has been demonstrated by recent high-profile nuclear emergencies -- such as the Tokai-Mura criticality accident in Japan and the loss of the ''Kursk'' by the Russian navy.
Within the last two years, two Chalk River employees inhaled an excessive amount of 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 it has much experience in dealing with other types of radioactive materials and radioactive spills, it appears that AECL is not sufficiently experienced in dealing safely with releases of alpha-emitting powder into the atmosphere in a respirable form, as the above episode illustrates.
Atmospheric dispersal of radioactive dust and debris is notoriously difficult and expensive to clean up. Following the disintegration of the Russian COSMOS satellite over the Northwest Territories, Canada embarked on a 3-million dollar clean-up operation which recovered less than 1 percent of the radioactive debris that came to earth.
Plutonium contamination is especially pernicious because of its long-half-life, its ability to escape detection, and its inhalation toxicity. Plutonium dust that has settled can be resuspended in a light breeze, leading to a slow, unremitting geographic spread of contamination.
AECL should be required to estimate what percentage of dispersed plutonium it is thought they will be able to recover, and to provide documentary evidence to justify that quantitative estimate.
Transport Canada should not approve air transport of MOX in the absence of detailed plans from AECL for identifying, locating, controlling and retrieving plutonium-bearing dust that has been disseminated into the atmosphere, including quantitative estimates of anticipated residual plutonium contamination.
Transport Canada should not approve AECL's air transport plan because it will be seen as a violation of public trust. Once public trust has been lost, it is very difficult to restore.
3.1 Transport Canada's secret decision to approve the January 1999 air transport of MOX from Sault-Ste-Marie to Chalk River was seen by many Canadians as a serious breach of public trust.
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.''
The secret manner in which weapons-plutonium-based mixed oxide fuel from Los Alamos was flown from Sault-Ste-Marie to Chalk River by helicopter on January 14, 2000, despite prior promises that it would not be done, was seen by many Canadians as a betrayal of public trust.
CCNR has been advised by lawyers that the January airlift of US MOX was almost certainly illegal since it violated well-established principles of common law -- namely the principles of ''Reasonableness'' and ''Legitimate Expectations'' -- due to Transport Canada's prior actions.
Legal or not, many Canadians regard the January airlift as a shocking act which strikes at the heart of public trust, upon which all legitimate government is based. It is not generally considered acceptable for a democratic government to announce one plan of action, invite public comment on it, and then secretly execute a completely different plan of action without notifying or consulting those potentially affected.
If Transport Canada approves the air transport of Russian MOX, it will further damage its own integrity as an autonomous agency, and will be seen by many Canadians as acting in a manner that is totally subservient to the whims of AECL or the Prime Minister.
3.2 Transport Canada would be setting a regrettable and possibly far-reaching North American precedent by allowing the air transport of plutonium-based MOX fuel in Type ''B'' containers.
Both the IAEA, through its work on Type ''C'' containers, and the United States Government, through its law prohibiting the air transport of plutonium in existing containers, have clearly indicated that there are important unresolved issues relating to the safety of air transport of radioactive materials, including plutonium.
It would be irresponsible for Canada to ignore all of these safety-related considerations and blindly approve the air transport of plutonium using Type ''B'' containers. Such a move could be, and probably would be, interpreted by other parties in other countries as a ''green light'' for using Type ''B'' containers far more extensively than hitherto for the air transport of radioactive materials.
This shipment of Russian MOX to Canada is highly visible and very controversial. Approval of air transport by Transport Canada is bound to take on a significance that extends far beyond this one shipment; it will be seen as a political statement by the Government of Canada about the air transport of MOX fuel in general.
The shipment of 528 grams of weapons-plutonium from Russia, incorporated into 17 kilograms of MOX fuel, may be the first of many, much larger such shipments if the Parallex Project leads to a larger program of plutonium imports, as envisaged by AECL and by Prime Minister Jean Chrétien.
Approval of air transport by Transport Canada at this point in time could therefore have major repercussions for Canada, for North America, and for the world, far into the future.
CCNR believes that such important decisions must not be made lightly, hastily, or blindly. Approval for the air transport of MOX fuel using a container that is not qualified to survive all credible air accidents should not be granted simply for reasons of political expediency -- and it appears that the motive for avoiding surface transport is primarily, if not solely, political (see section 3.3).
3.3 Canadians are increasingly distrustful of the Government's stated motives for importing plutonium at all -- and particularly for moving to the air transport option, which seems to be politically motivated.
According to numerous press accounts, Natural Resources Minister Goodale has stated that the Government of Canada decided to transport plutonium fuel by air because of suggestions to that effect made by members of the public during public hearings last fall.
The rationale offered by the Minister is misleading.
First of all, there have been no officially sanctioned public hearings -- not last fall, not ever -- on Ottawa's decision to import plutonium.
There were a number of hastily-organized ''public information'' meetings held in several communities along the transportation route -- communities that had passed resolutions opposed to the transport altogether or objecting to the Government's selection of routes.
To suggest that those meetings, which in some instances were little more than PR damage-control meetings, were in effect public hearings, is disingenuous at best.
Moreover, to suggest that the Government chose to transport MOX by air in response to the express wishes of Canadians at those public meetings, is an extraordinary thing to say. Although several people asked about flying MOX, many did so sarcastically.
If the Government wanted to respond to the wishes of Canadians as expressed at those meetings, the message should have been crystal clear: ''Don't float it, don't truck it, don't fly it -- just scrap it!''
In Quebec, over 170 municipalities have passed resolutions against the transport of plutonium through Quebec by land, sea or air. These resolutions all call on Ottawa to cancel its plans to import plutonium.
CCNR has concluded that the Government's choice to transport MOX by air is not motivated by any legitimate safety or security considerations, nor by a concern for the wishes of the Canadian public, but by political considerations -- to minimize embarrassing confrontations along the transportation route. This is not a proper reason for Transport Canada to approve AECL's ERAP.
3.4 Many Canadians are unconvinced by the Government's insistence that the Parallex Project is ''only a feasibility test'' and that there is no commitment to a larger program of plutonium imports. The feasibility of using MOX fuel in CANDU reactors has never been in doubt. AECL operated a pilot MOX fuel fabrication facility at Chalk River for decades, by means of which over three tons of MOX fuel were produced. Most of this MOX was tested in Canadian reactors.
A study carried out for the US Department of Energy by AECL and Ontario Hydro in 1994 concluded that using weapons-plutonium-based MOX fuel in the Bruce ''A'' reactors is entirely feasible, and does not require any major modifications to the reactor control systems.
Thus the Parallex Project is not a feasibility test but a pilot project, to allow AECL to measure the physical and chemical characteristics of US and Russian MOX in order to provide technical specifications for the large-scale implementation of MOX fuel use in commercial CANDUs.
The Canadian cabinet has declared on numerous occasions that it favours ''in principle'' the use of weapons-plutonium-based MOX fuel in CANDU reactors. Indeed, it appears that the main reason there is at present no commitment to a larger plutonium import program is that the US and Russian government have not yet consented to it.
Canadians are feeling disenfranchised by the Government's actions. It has been made abundantly clear that they want to have their say about the entire concept of importing weapons plutonium into Canada, and there is every indication that they will never be allowed to do so.
Most of the submissions received by Transport Canada during the 1999 public comment period were clearly opposed to importing plutonium into Canada at all, as a matter of principle. Opposition was expressed not just to the surface transport of MOX, but to the entire principle of importing plutonium in any way, shape, or form.
The House of Commons Foreign Affairs Committee unanimously recommended in December 1998 that the entire plutonium import plan be scrapped, yet there have been no subsequent hearing on this.
Many Canadians feel decisions which will affect their children's children are being made without a legitimate democratic process. Transport Canada should beware of being used in this way.
3.5 Many Canadians are ready, willing and able to participate in a full-fledged debate on the merits of the MOX proposal. But Ottawa is confounding the issues by misrepresenting some of the basic scientific facts about the MOX option. Citizens feel cheated when they are misled by men who are claim to be speaking for the Government. A great deal of misinformation has appeared in the media -- much of it attributed to representatives of AECL -- regarding plutonium, MOX, and nuclear weapons.
In most cases, when false information is promulgated, Ottawa does not publish any correction, which many Canadians take to mean that Ottawa tacitly supports a policy of systematic disinformation.
Here is a summary of some of the more important misrepresentations.
3.5.1. ''The purpose of the MOX proposal is to destroy plutonium.''
3.5.2. ''Once it is burned in a reactor, plutonium is unusable for weapons.''
This is untrue. The US Academy of Sciences (1994) reported there is no existing technology to eliminate plutonium. AECL scientists have stated (1997): ''The objective ... is not to destroy the plutonium.... The initial plutonium content is reduced by about one-third....'' Thus, most of the plutonium will become Canadian property in perpetuity.
This is untrue. Powerful, reliable, highly effective nuclear weapons can be made from any grade of plutonium found in any type of nuclear reactor fuel. This point has been made repeatedly by US experts and officials for twenty-five years, most recently in a July 2000 brochure from the US Government Department responsible for the plutonium import plan.3.5.3. ''Fresh MOX fuel is not an attractive target for thieves or terrorists.''
A seminal article on this topic is ''Explosive Properties of Reactor-Grade Plutonium'', written by Canadian-born bomb-maker Carson Mark in 1993. Dr. Mark explains that virtually any mixture of plutonium isotopes can be used to make an atomic bomb.
In its famous 1994 Report on Excess Weapons Plutonium, the US National Academy of Sciences took special pains to explain that the ''lowest yield'' of a crude bomb made from the most inferior grade of plutonium ''would still have a radius of destruction roughly one-third that of the Hiroshima weapon''.
Plutonium can be re-extracted from irradiated nuclear fuel and re-used in nuclear weapons at any time. True, the radioactivity of spent fuel makes extraction difficult, but a similarly effective radiation barrier can be achieved without using reactors, by mixing plutonium with high-level radioactive waste. Both approaches provide equal security.
This is untrue. US weapons experts say that fresh MOX fuel must be guarded as carefully as a nuclear warhead, because the plutonium can easily be extracted for use in a nuclear bomb, or a radiological dispersion device. The latter is an incendiary device that can be used to kill thousands with toxic fumes by vapourizing just a tiny bit of plutonium metal (a spontaneously combustible material).3.5.4. ''Plutonium is so weakly radioactive it poses no health threat.''
Fresh MOX fuel can be stolen, transported and handled without the need for elaborate radiation shielding. Because it emits almost no penetrating radiation, MOX fuel is difficult to detect using standard radiation monitoring equipment.
A report by the Sandia National Laboratory, commissioned by the US Department of Energy Office of Fissile Materials Management, concludes that four men could extract enough weapons-grade plutonium from fresh MOX fuel in a few weeks with only modest resources, to make an atomic bomb.
This is untrue. Like radium and radon, plutonium emits deadly alpha radiation. True, alpha rays cannot penetrate a sheet of paper, so (like arsenic or e-coli) they are not hazardous outside the body. But in contact with living cells, alpha rays are 20 or 30 times more damaging than an otherwise equal exposure to gamma, beta, or x-rays. Inhaled, plutonium is a extremely potent cancer-causing agent, as animal experiments have consistently shown.Many Canadian are challenging the fundamental assumptions underlying the plutonium import plan. They are angry when the facts are misrepresented or when legitimate concerns are dismissed out of hand. The air transport option will minimize opportunities for Canadians to exercise their democratic rights; as such, it should not be approved by Transport Canada.
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