Canadian Coalition
for Nuclear

Regroupement pour
la surveillance
du nucléaire


submitted to




April 18, 1997

A strong conviction that something must be done
is the parent of many bad measures.

-- Daniel Webster

For every complex problem,
there is a solution that is simple, neat, and wrong.

-- H. L. Mencken

If a problem is too difficult to solve,
one cannot claim that it is solved
just by pointing to all the efforts made to solve it.

-- Hannes Alfven,
Nobel laureate in Physics,
writing of the problem of nuclear safety.

Table of Contents

  • Plutonium and Reprocessing

  • Safe on the Surface?

  • Siting, Safety and Acceptability

  • Probability and Predictability

  • Containers and their Contents

  • Ominous Oversights

  • No Consensus on the Concept

  • The Rhetoric of Retrievability

  • The Supremacy of Science

  • The Partiality of the Process

  • The Canadian Coalition for Nuclear Responsibility is a federally-incorporated not-for-profit organization. It was founded in 1975, and incorporated in 1978.

    The CCNR has played an active role in the debate on high-level radioactive waste (irradiated fuel) from nuclear power reactors from the very beginning....

    Whatever the panel might recommend in the way of further study of the geologic disposal concept, or other interim or long-term management concepts for nuclear fuel waste, or questions of political process or nuclear policy, CCNR maintains that the panel would not be justified in concluding (on the basis of today's knowledge) that AECL's concept of permanent geologic disposal of high-level radioactive wastes in the Canadian Shield is safe, or (on the basis of what Canadians have communicated to the panel) that the concept is acceptable.

    Plutonium and Reprocessing

    • At every public hearing, in every public document, AECL has made it clear that the concept of geologic disposal could involve post-reprocessing waste -- the result of plutonium separation -- rather than unreprocessed fuel bundles. It is therefore imperative that the panel make recommendations on the subject of the safety and acceptability of plutonium reprocessing, especially since AECL indicates that reprocessing would likely be carried out on the same site as the waste repository. ("If retrieval was intended to provide used fuel for future reprocessing and recycling, it would be desirable to select a site for centralized storage and disposal that was also suitable for a reprocessing facility." [EIS, p. 333])

    Safe on the Surface?

    • The objective of geologic disposal is not to make things safer underground, but on the surface. However, if nuclear power expands, the amount of unburied radioactivity on the surface will continue to grow at the same rate as the nuclear power program, even if geologic disposal is implemented to perfection. In a "steady-state" nuclear power program, even with geologic disposal, the amount of unburied waste will remain constant at an alarmingly high level -- more than 90% of the total activity produced during half a century will remain at the surface. It follows that the concept of geologic disposal is completely unacceptable without a nuclear phaseout.

    Siting, Safety and Acceptability

    • The government (and the nuclear industry) have chosen to have an environmental assessment of the concept of geologic disposal because, they say, they will not proceed to site selection until the concept has been found to be both safe and acceptable.

    • Site selection can only be seen as a first step in implementation of the concept. The nuclear industry here and abroad, as well as the relevant governments, will not later decide that the concept is unsafe or unacceptable -- by then the investment of time, resources, prestige and political will, will have been too enormous.

    • Accordingly, panel members should not recommend proceeding to site selection unless they are convinced beyond any reasonable doubt that the concept is both safe and acceptable. Of necessity this must include a conviction

      1. that no other conclusion could have been reached even if the proponents were not pro-nuclear, and

      2. that the Canadian population is willing to believe that too.

    Probability and Predictability

    • Probabilistic methods in geology are still quite new, and most of the probability models used to predict post-closure behaviour of the repository have not been validated against reality. Meteorological models are much more advanced, yet they are still notoriously fickle and unreliable except for short periods of time.

    • Probability models used by the nuclear industry in the past to predict energy demand and reactor safety have been found to be unreliable as a basis for policy decisions.

    Containers and their Contents

    • Containers may last for a long time without safeguarding their contents. The Egyptian pyramids are still there, very impressive long-lived containers, but their contents are gone.

    • If containers can be designed that are sufficiently sturdy and reliable, then geologic disposal may be unnecessary, as surface containers may be sufficiently resistant to external forces.

    Ominous Oversights

    • The study carried out by the proponent is designed to show how things can go right, not to imagine how things could go badly wrong. Major disasters may result from minor oversights. The Three Mile Island accident involved a partial core meltdown and billions of dollars in damage -- because a blocked valve was overlooked during reactor startup, and a stuck valve was disregarded for two days. The Titanic sunk, it appears, not because of a massive hole in its side, but because of a few rather small gashes. AECL's analyses are too general and simplistic to give adequate assurances of safety.

    No Consensus on the Concept

    • Except for nuclear proponents -- including representatives of industries and governments that are committed to nuclear power -- we see no consensus concerning the wisdom or the morality or even the feasibility of AECL's concept of permanent, unmonitored geologic disposal. Even section 3.6.5 of AECL's Environmental Impact Statement notes that up to 51 percent of northern Ontario residents believe perpetual monitoring would be necessary -- despite coaxing from nuclear industry people to adopt a different point of view. To many, if not most, AECL's fundamental concept of a "walk-away" disposal scheme is simply not acceptable.

    The Rhetoric of Retrievability

    • The proponents claim that the waste would be retrievable. But the only event which would plausibly precipitate a retrieval operation would be a massive failure of the repository. Under those circumstances, the underground contamination would be so severe as to preclude any effective retrieval operation. Retrieval of the intact waste would do little to mitigate the leakage of waste that had already escaped. In effect, the damage would already have been done.

    The Supremacy of Science

    • Most scientists and engineers take great pride and delight in the powers of science to predict and control natural events. There is consequently a widespread belief -- which is, in itself, not truly scientific, but which is akin to religious belief -- that science and technology can solve any problem, no matter how difficult. CCNR considers that the recommendations of the AECB and the Scientific Review Group to proceed to siting is based largely on the belief that the problem will be solved because it must be solved, despite the fact that the scientific evidence is not at all conclusive, convincing, or complete. In expressing such beliefs, we feel that these experts are going well beyond their expertise.

    The Partiality of the Process