The Great Canadian Nuclear Waste Saga-volume Four, 1998-2008

Volume 4 of the Great Canadian Nuclear Waste Saga MOX When Phyl and I moved from Québec to Kingston, Ontario, in March of 1997, I wondered if my long stint as an anti-nuclear activist had finally come to an end. I kind of hoped so. Kingston seemed to be free of nuclear issues. Also, as my uncle Sam in Ann Arbor, Michigan, was fond of saying: "We're not getting any younger." Having entered my seventh decade that year, Sam's observation seemed particularly apropos. I settled in to produce the third and final volume of The Great Canadian Nuclear Waste Saga which brought the manuscript to March, 1998, at which time the Canadian Federal Government released the Environmental Assessment Review Panel's final report on Atomic Energy of Canada's (AECL's) underground waste burial concept. After a few unsuccessful forays at publishing houses, I decided to complete the writing anyway, and place it, and the earlier two volumes, on this internet web site "for posterity." Having done that, I could concentrate on more traditional retirement pursuits, e.g., model railroading and folk music. But I could not resist the temptation to continue to monitor nuclear events, especially on the computer e-mail network operated by the Campaign for Nuclear Phaseout, (CNP). Some of these e-mail messages revealed details of the 1997 U.S. Department of Energy (DOE) draft environmental assessment (EA) of it's Parallex Project Fuel Manufacture and Shipment. That document described a proposed "...dispositioning of weapons-usable plutonium as a mixed oxide (MOX) fuel in a re-engineered heavy-water-moderated reactor, such as a Canadian Deuterium Uranium (CANDU) reactor. MOX reactor fuel would be made by mixing weapons-usable plutonium in oxide form with uranium dioxide and pressed into dry fuel pellets. These pellets are then loaded into fuel rods. DOE must test and demonstrate the feasibility of burning MOX fuel in CANDU reactors as part of its ongoing mission to evaluate the disposition of surplus weapons-grade fissile materials. The ability to successfully reengineer and operate heavy-water-moderated CANDU reactors with MOX fuel cycles has never been demonstrated on any industrial scale." The transportation section in the EA really caught my attention! DOE would ship, by truck, a quantity of MOX from it's facility at Los Alamos, New Mexico, to AECL's Chalk River, Ontario nuclear research station for the feasibility tests. DOE selected three possible U.S.Canada border crossings for the shipments: Pembina, North Dakota (Emerson, Manitoba), Port Huron, Michigan (Sarnia, Ontario), and Watertown, New York, across the 1000 Island Bridge into Canada (near Kingston!) In Volume 3 of the Great Canadian Nuclear Waste Saga, in the "Homecoming" chapter, I relate some events at a Fall, 1994 nuclear waste activists' meeting in Washington, D.C., which Phyl and I attended. During that meeting several conferees told us that they were aware of a scheme to export weapons grade plutonium into Canada to use as fuel in CANDU reactors. I later confirmed with a very reliable source, that AECL had actively lobbied the U.S. Government for MOX-CANDU contracts, and that closed meetings on the subject had been held in the Canadian Embassy in Washington.

DOE started sponsoring MOX-CANDU studies in 1994. They were conducted by AECL Technologies (AECL's U.S. office). The researchers included staff from AECL, Ontario Hydro Nuclear, and various U.S. and Canadian companies. The first report was submitted to DOE in July, 1994, and it identified options for the consumption of 50 to 100 tonnes of weapons grade plutonium over a 25 year period, using reactors at the Bruce nuclear station on Lake Huron, in Ontario. A follow-up 1996 study produced "enhanced fuel designs" which would presumably increase the amount of plutonium throughput and thereby decrease the amount of time required to "burn" it in the reactors. All this activity was related to the fact that the US and Russia had reached agreement on the reduction of the inventory of weapons plutonium, now that the cold war was over. They decided that each would declare 50 tonnes of their plutonium as "surplus." But specifically, how to deal with this surplus was a big question. The prestigious U.S. National Academy of Sciences had identified three options for dealing with the plutonium: vitrification or immobilization using fission products to provide an intense radiation barrier; (2) "burning" of MOX fuel in power reactors whereupon the spent MOX fuel will offer a similarly intense radiation barrier; (3) injection of plutonium in deep bore-holes drilled into the earth. It quickly became obvious that the dying nuclear establishment preferred the MOX option. In my view, this is because it desperately needed something to revitalize itself, and it saw the MOX program, and its potential commercial benefits, as an essential component of its survival plan. The other options could not do as much for the future of the industry. But it would not be long before the industry invented an even better survival option for itself; “global warming”. But more about that later on this website. In early March, 1998, Irene Kock of the Nuclear Awareness Project, near Oshawa, Ontario said that she hoped Phyl and I would get directly involved with the issue in the eastern region of the province, (around Kingston). She, Elizabeth May, and others in the Canadian nuclear waste caucus were amused by the fact that wherever Phyl and I moved, some sort of nuclear crisis quickly emerged; the nuclear waste project in eastern Manitoba, the Slowpoke reactor in Québec, and now plutonium traffic in eastern Ontario! I must admit, It is rather strange. Irene's group was already at work around Port Huron-Sarnia alerting folks that their Blue Water Bridge crossing was one of the three border points mentioned in the DOE document. Irene's campaign quickly and effectively gathered momentum on both sides of the border crossing. I had no problem joining in on this particular issue, given my long-standing concern about the use of and conversion of plutonium into a marketable, commercial product. My initial awareness of a man-made substance called plutonium came about during those fateful days in early August, 1945. Sitting on the edge of my bunk in my barracks at the Scott U.S. Army Air Corps base near East St. Louis, Illinois, I heard the radio report that a powerful new bomb had been dropped on the Japanese industrial city of Nagasaki, with devastating consequences.

Our unit was nearing completion of its training and expected to be transported to the Pacific theater of action in the near future. We assumed that we would be part of an eventual invasion of Japan, because, as trained communications specialists, our skills would be needed for such an effort. It was widely believed that the invasion itself, would result in massive casualties. The two atomic bombs changed everything. The war in the Pacific ended soon thereafter. In November of 1945, I was shipped to the east coast and eventually found myself in the eastern Canadian arctic at a remote weather observation station, where I served as a highspeed morse code radio operator for about 9 months before finally being discharged back to civilian life in December, 1946. (That "remote" base is now Iqaluit, the Capitol of the Canadian Territory of Nunavut ). The abject horror of the effects of the bombs on the civilian population in Japan (the plutonium bomb killed 70,000 people and many more died later from radiation poisoning) did not fully register on myself and the rest of the group of mostly 18 year old kids destined for shipment to the Pacific war zone. I suspect most, as I did, experienced some degree of relief that the war had come to an end when it did. I did not really begin to appreciate the magnitude of those weapons until years later, while watching some of the classified films of U.S. hydrogen bomb tests in the Pacific islands. During the late 1950's, I was able to view such films as a staff member of the U.S. Atomic Energy Commission (AEC) headquarters at Germantown, Maryland, north of Washington, D.C.. While employed at AEC (for about two and a half years), the more I learned about nuclear weapons, and plutonium in particular, the greater was my respect for, and, yes, rational fear of its incredible destructive power and toxicity. I am sure that many of the AEC headquarters staff felt as I did about these weapons and about the plutonium for which our Commission was responsible. In the 1950's, plutonium was reserved for weapons, and weapons alone. Although it was later used for other purposes on a limited basis (e.g., as an energy source for some space satellites), it was never intended for use as a nuclear reactor fuel. Incidentally, the use of nuclear power in satellites also had it's down side. On January 24th, 1978, a Soviet Cosmos satellite crashed and widely dispersed radioactive material in a remote area of Canada's Northwest Territories. The cost of the three month search, detection and cleanup operation was estimated at ten million Canadian dollars. That a new generation of politicians, scientists, technocrats and others, would be using plutonium as a fuel to power nuclear reactors, was a truly appalling notion for me. To convert plutonium into a substance of value, traffic in it, transport it, expose it to the world of commerce, not to mention the world of terrorists and rogue states....?? Was it already too late? Reactor grade plutonium was already being used to power nuclear plants in Belgium, France, Germany and Switzerland. Could plutonium proliferation be stopped in North America, and especially in the "peaceable kingdom" of Canada? It was worth a try! Phyl and I chose Campaign STOP (Stop Trafficking of Plutonium) as the identification of our organizing effort in the Kingston area. Phyl produced a splendid computerized

letterhead logo, which included a graphic of a truck on the highway. A strike out line went through the radiation symbol on the side of the truck. The logo was perfect, as transportation issues and nuclear waste storage were among the major considerations in our efforts to try to prevent the shipment of MOX fuel from Los Alamos and from Russia to the Chalk River, Ontario, Research Station. But how would we organize a campaign in a region into which we had recently moved and where we had no contact base? When we had moved from Winnipeg to the Eastern Townships of Québec in 1987, we had some prior contact with social and environmental activists, some of whom were already getting involved in the Slowpoke reactor issue in Sherbrooke. In Kingston, we would need all the help we could get, just to get started. What I thought would be an obvious source of help, the Kingston Green Party, did not materialize. We attended a few of their meetings and we brought the issue to their attention. But we soon realized that they were completely pre-occupied with electoral politics and development of a broad-based political platform. Both the Campaign for Nuclear Phaseout and the Nuclear Awareness Project provided us with lists of organizations and individuals in the area. It did not take long for the MOX issue to pique the interest of such groups as the Kingston Chapter of Raging Grannies, the Public Interest Research group at Queens University, members of the local chapter of the Council of Canadians, the Kingston Environmental Action Project, and others. Before long, we were sharing information with some of these folks and meeting and networking locally. At the same time, we were in close computer contact with the larger network of organizations concerned with the MOX issue in Canada, the U.S. and elsewhere. We began acquiring information and fact sheets, and preparing our own materials for the STOP campaign. Our first major strategy was to request anti-MOX transportation resolutions from local and regional municipalities. Several such resolutions had already been passed by Councils in the Sarnia-Port Huron area. We enlisted the help of Jim Purdie, a social activist from Gananoque, who quickly proceeded to acquire resolutions from rural municipalities near the 1000 Island Bridge route. These resolutions were forwarded to appropriate politicians in Ottawa. I signed up to make a five minute presentation and to request a resolution from the Kingston City Council at its' regular meeting on October 6, 1998. As prearranged, Matt Silburn of the Kingston Environmental Action Project brought some members of his group to the meeting, complete with anti-MOX signs. They stood silently at the back of the hall with the signs raised, which gave the TV camera operators much joy. However, Kingston Mayor Bennett was anything but joyful.. He told the protestors that they were "hurting their cause" by their actions and would not let me speak unless they took their seats. It was very tempting to make a short statement about the virtues of peaceful protest in a democratic society, and walk out of the hall, but I needed to get the message across to these councillors who were totally unaware that their city was very near a designated transportation corridor for MOX fuel. At my gesture, Matt and his friends put their signs down, seated themselves, and I proceeded to deliver my prepared five minute

talk. One of the key points I was able to make was that the 1000 Island Bridge was now one of only two of the three possible border crossings mentioned by the DOE. On October 2, 1998, I had learned via e-mail that the Port Huron, Michigan (Sarnia, Ontario) crossing had been withdrawn by U.S. Energy Secretary Richardson. His action was in response to a letter of protest from the powerful Democratic Whip, Michigan Congressman David Bonier who did not think it was safe to ship MOX over that bridge. I posed the obvious question to the Kingston Council: Why then would it be safe to ship it over the 1000 Island Bridge? After my presentation, the Mayor asked his Emergency Measures Officer (EMO), if the City would be able to deal with radioactive releases from a MOX truck accident. The EMO assured the Councillors and the Mayor that his Department was fully capable of handling any such emergency. I was troubled by that glib response. But it was obvious that the Council and Mayor were somewhat reassured by it. Kingston Council did not pass a resolution that evening, nor did it ever, during the course of the MOX issue in the region. Dr. Rosalie Bertell, in her book "No Immediate Danger?" states that "Plutonium is an alpha emitter, and no quantity has been found to be too small to induce lung cancer in animals." If there is a bad accident and the stuff gets into the air, and the winds pick it up, and any amount inhaled can do that kind of damage, what sort of emergency measures could possibly be effective? My contact with New York Congressman McHugh's office also produced no results. His constituency covered a large area in upper New York State, including Watertown, and the U.S. side of the 1000 Island Bridge. His executive assistant was surprised when I told him about the possible transportation route through his District. He checked with his Washington contacts who led him to believe that Canada was backing away from the MOX project. (which was not the case). We got one bit of good news, when, on November 17, 1998, the Council of the Town of Gananoque, near the entrance to the 1000 Island Bridge route, passed a strong resolution opposing the proposed MOX shipment. During this period of time, local media coverage of the issue increased to the point that Campaign STOP became known to AECL. The Crown Corporation's Manager of Corporate and Media Relations, Larry Shewchuk visited Kingston on November 18, to meet with media and city officials. His purpose was to assure them that the MOX shipments would not pose a threat. But the very presence of a top AECL official in Kingston had a perversely positive impact on the credibility of Campaign STOP's contention that the 1000 Island Bridge route was a high- priority choice for the transportation of the MOX shipments. In addition, a November 20th Kingston Whig Standard article reported Shewchuk as saying "within seven years, the shipments may become regular." I don't think the prospect of regular shipments of plutonium over several decades was a pleasant one for most people, regardless of AECL's efforts to minimize the risk factors.

AECL's position that the MOX fuel would pose minimal threat, was, to put it mildly, a highly controversial one. Although the statistical probability of the test shipments running into trouble was remote, continuous shipments over several decades was another matter. Safety and security were primary concerns. In a November 28, 1998, Kingston Whig Standard article the Crown Corporation was reported as estimating that ..."a total of about five ounces of plutonium would come across (the border) in the four test shipments, and because the plutonium would be ground up and mixed with uranium, it could not be extracted for use in weapons ." Also, in the December, 1998 issue of Kingston's monthly alternative newspaper, Pic Press, AECL's Larry Shewchuk was reported as saying that "...when the MOX fuel is `spent' in a reactor, the weapons plutonium is rendered useless as a nuclear weapons material." As for transportation safety and security, the MOX would be well guarded and that the "solid, ceramic- like material, encased in zirconium alloy tubes which are packed in a special shipping container... can not spill, nor can it ignite or explode." The contention that the MOX fuel could not ignite flatly contradicted the 1997 draft Environmental Assessment (EA) document prepared by the U.S. Department of Energy. In it, "...two credible (italics supplied) transportation accident scenarios were analyzed for the shipment of MOX fuel to the Canadian border. One accident involved the release of radioactive materials" The document went on to state that"The first accident relates to an event that leads to the MOX fuel package container breaking open, igniting (italics supplied), and releasing plutonium dioxide particles into the air ." Nor did everyone agree with AECL's opinion that the plutonium in the fresh MOX fuel could not be extracted and used in weapons. According to a 1998 Nuclear Control Institute (NCI) document, "MOX presents a security risk in that the fresh fuel lacks a radiation barrier, and if stolen, weapons-grade plutonium could be separated from this MOX by straightforward chemical means". After it is "spent" in a reactor, is the weapons plutonium really "...rendered useless as a nuclear weapons material?" NCI points out that in June 1994, U.S. Energy Secretary Hazel O'Leary declassified details of a 1962 test of a nuclear device using reactor grade plutonium, which successfully produced a nuclear yield. It had become fairly well known that atomic bombs could be constructed with fairly small amounts of reactor grade plutonium. The MOX controversy raged into Winter of 1998-99, but Campaign STOP and all of the Canadian anti-MOX forces got a tremendous boost from a December 9, 1998 release of a report by the all-party, House of Commons Foreign Affairs Committee. Entitled Canada And The Nuclear Challenge, the report covered a wide range of issues related to disarmament. Having heard many opinions on the subject, the Committee turned thumbs down on the MOX option with the following words: "The Committee recommends that the Government reject the idea of burning MOX fuel in Canada because this option is totally unfeasible, but that it continue to work with other governments to address the problem of surplus fissile material." Campaign STOP quickly endorsed the recommendation in a December 11, 1998 letter to Prime Minister Jean Chretien. But it was Chretien who was largely responsible for Canada's involvement in the MOX program. Indeed, it was one of his pet projects. He had made

public statements supporting the idea of Canada's participation in the weapons plutonium disposition effort, and in a letter to U.S. President Bill Clinton, had even underscored Canada's willingness to assist. As an avid supporter and advocate of nuclear energy, how would Mr. Chretien react to the Parliamentary Committee's "nix MOX" recommendation? Time would tell! Our friends across the border were also busy trying to plug up the MOX "pipeline." Kyle Rabin of Environmental Advocates, based in Albany, New York, informed us of the resolution adopted December 29, 1998 by the Common Council of the City of Buffalo, New York. The city was on the likely route from Los Alamos to Canada. The public profile of the MOX issue escalated again in March, 1999 when a 1997 AECLOntario Hydro transportation feasibility study, obtained by CTV News, suggested that, for safety reasons, the Russian MOX be transported by ship, rather than airplane. The study identified Montreal, Halifax, Québec City, Sarnia, Ont., and Churchill, Man., as possible ports of entry. In all those locations, the issue became big news overnight. More municipal resolutions were passed, especially in Québec along the St. Lawrence Seaway. Local public officials flooded the media with statements of concern.

In April 1999, the International Association of Firefighters called for a moratorium on plutonium fuel imports because of uncertainty as to whether their members would be able to handle an accident involving plutonium. The Mayor of Sarnia predicted "civil disobedience" in his city if it were selected as the port. Would not this outpouring of public opposition to the MOX import plan give the Government of Canada some pause to rethink the project? Quite the contrary! On April 19, 1999 we learned from the CNP that the Government had rejected the Parliamentary Committee Recommendation to scuttle the MOX plan. The release stated that "The Government does not consider there are sufficient grounds to justify abandoning the possibility of using MOX fuel in Canadian reactors as a means to reduce proliferation risks from weapons plutonium being declared surplus to defense needs in the USA and Russia." No big surprise! To add to the Springtime "merriment," Greenpeace, Canada, on April 25, 1999, announced it was launching a bus tour of the routes to be used to ship plutonium, bound for use at Atomic Energy of Canada's (AECL) experimental reactor in Chalk River. Kingston and the 1000 Islands Bridge would be one of the stops on the route. I agreed to help Greenpeace with the arrangements and activities in the Kingston area. The big Greenpeace bus, festooned with anti-MOX banners, pulled up in front of Kingston's city hall in the morning of Monday, June 7, 1999. We had a small but dedicated contingent there to meet them. A few local media people were present, as were representatives of several of the groups that had become part of Campaign STOP. A few passerby tourists from the U.S. were quite horrified when they heard from us about the MOX shipment plan. Over the previous several months, I had been in contact with Jean Kessner, a journalist with TV Station WIXT, in Syracuse, New York, who had been looking for an opportunity to

cover the issue. She and her cameraman made the trip to Kingston that morning. Her program ran that evening. At the 11 A.M. press conference, Greenpeace campaigner Michael Khoo told the assembled group that the MOX plan was a very bad idea for Canada. I reiterated one of my main themes, that importing MOX "...sets a dangerous, dangerous precedent and opens the door for Canada to become a nuclear garbage dumping ground for the world." A half-dozen Raging Grannies, led by Rose Deshaw, sang some of their growing repertoire of anti plutonium songs, and City Councillor, Don Rogers said he would bring more information on the issue to the council. After lunch, Phyl and I next joined the Greenpeace bus campaign augmented by Kingston supporters, at one of the entrances to the 1000 Island Bridge that joins Canada and the U.S. By the time we arrived, climbers had already scaled the bridge and were trying to secure a large anti- MOX sign onto the side of the span against a strong wind. It was a token ceremonial effort, as Greenpeace intended to use the banner at the Parliament Building in Ottawa, the following day. Members of the 1000 Islands Bridge Authority made it known that they were not overly thrilled with the climbers or the sign on the bridge. Late that afternoon, in the town of Gananoque, while the bus was parked in the large lot adjacent to the 1000 Island tourist cruise boat landings, we all walked up and down the main street handing out anti-MOX leaflets. The Summer of 1999 was somewhat of a letdown for Campaign STOP after all the activity over the previous Winter and Spring. However, pro and anti-MOX forces continued to wage a war of words and the Government of Canada continued it's intransigence in the face of overwhelming opposition. Some of that opposition came from unlikely sources. "Fission Impossible" was the title of a July 21, 1999 Time Magazine article. It was all about efforts by North Carolina Senator Jesse Helm's efforts to scuttle the MOX-CANDU initiative. The Time article went on to state that "Senate Foreign Relations Committee chairman Helms is campaigning against a Washington plan to convert plutonium from U.S. nuclear warheads into civilian reactor fuel. If he wins, he will doom one of the most ambitious and controversial Canadian foreign policy initiatives since the end of the cold war." Helms, in response to one of Canadian Foreign Minister Lloyd Axworthy's many naive and ill-advised pro-MOX pronouncements, retorted that "The MOX option will undercut our decades-long non proliferation policy," My sentiments exactly! I never thought I would see the day that I would be on the same wave length on an issue as Jesse Helms. The relatively quiet Summer of 1999 was the calm before the storm. On September 2, 1999, the news on the wire services effectively put Campaign STOP out of business. The Government of Canada announced that "Subject to Transport Canada's approval, the MOX fuel shipment from the United States would enter Canada by truck at

Sault Ste. Marie, Ontario, while the Russian shipment would arrive at Cornwall, Ontario by ship. Both shipments would then proceed by truck to Atomic Energy of Canada Ltd.'s (AECL) research laboratories at Chalk River. " The announcement went on to state that the public would have 28 days in which to comment on AECL's proposed transportation plan and its emergency response assistance plan. The 1000 Island Bridge route, the main rationale for the existence of Campaign STOP, was no longer a designated border crossing point for the test shipments of MOX fuel! Reaction to the announcement in Sault Ste. Marie and Cornwall was swift. According to the Canadian Press, Cornwall Mayor Brian Sylvester stated that "...in my view, Cornwall must not be the port of entry for this substance." Stephen Butland, mayor of Sault Ste. Marie, said that he had received no advance notice of the decision and had requested a briefing by federal officials. He wanted to know why the Sault Ste. Marie route was chosen over others. So did I! Knowing that DOE and AECL were not really going to tell us why the two of the original remaining designated crossings were dropped in favour of Sault Ste. Marie, I could only surmise. Perhaps the words of Vernon Roote, Grand Council Chief of the Anishinabek Nation as reported in an article in the September 3, 1999, Hamilton Spectator, provide a clue. Roote pointed out that "...the proposed route for transportation to the Chalk River facility cuts through the heart of the Robinson-Huron Treaty area and we have not been asked or consulted on the transportation process." "...There are no less than 8 First Nations that this material will either pass directly through or through areas immediately adjacent to the reserves. This is the traditional territory of our people. Once again, the north is being affected by circumstances we had no control over, with no benefits accruing to our people, only risk." The Grand Chief went on to ask the logical questions: "If this material is so safe, why don't the governments of Michigan or New York want it transported through their states? Why isn't it brought through southern Ontario?" And finally, "Surely the United States of America has the technology and resources to properly dispose of this material. Maybe they should assist their old enemies." Although Campaign STOP lost its' primary raison d'être, Phyl and I decided to do what we could to support the anti-MOX forces at the Sault and at Cornwall. During September, 1999, with full knowledge that the Government of Canada would pay absolutely no attention to them, we drafted our comments on the AECL transportation plan, simply to go on the record. Flaws in the plan were no more difficult to find than the gaping holes in the entire MOX initiative. By the end of September, the municipal councils of Sault Ste. Marie and North Bay Ontario, had both passed motions calling for "meaningful and thorough" public hearings before the MOX shipments could travel along the highways. At the same time Mayor Verna

Lawrence of Sault St. Marie, Michigan was quoted as saying "We don't have `stupid' written on our foreheads...Keep it away from our Great Lakes." and that if the MOX shipments were allowed, she personally will stop the trucks from passing through that city! Things were jumping on both sides of the border! Not content with simply writing comments, Phyl and I decided to get a little taste of the action. As a result of an e-mail from our Michigan activist friend, Kay Cumbow, we traveled in our camper van to Lansing. After a short visit with my brother Larry and his family, we attended an October 5 community forum at the Peace Education Centre in downtown Lansing, organized by Anabel Dwyer. The gathering featured Chief Earl Commanda of Ontario's Serpent River First Nation. Commanda made it clear that the Government must set up a process so that the people could be heard. Then we headed north to Sault Ste. Marie, Ontario, to attend an October 7th public meeting organized by Mayor Butland. One of our long time nuclear waste caucus colleagues, Brennain Lloyd of Northwatch, persuaded Mayor Butland to add me to the speakers list. (Northwatch is the regional coalition of environmental and citizen organizations and individual members in northeastern Ontario). I used a copy of my comments on the AECL transportation plan as the basis for my short statement. The Canadian Federal Government representatives at the meeting were less than enthusiastic about the tone of my remarks, which pleased me no end.

Shortly after our return to Kingston, we learned that the Akwesasne Mohawks and Greenpeace, Canada, were planning a rally and speeches on the grounds of the Cornwall, Ontario, Civic Centre on November 4th. After a two hour drive east from Kingston, on highway 401, we joined with several hundred people, mostly from the Mohawk First Nations in protesting the planned Russian shipments of MOX fuel through the St. Lawrence Seaway through aboriginal territory. It was a terribly cold and windy November day on the shore of the St. Lawrence River, but that did not dampen the enthusiasm and determination of those assembled. Children, parents, and grandparents focused on the bandstand and the array of speakers, including Phil Fontaine, the Grand Chief of the Assembly of First Nations. Television cameras were everywhere. Speaker after speaker roundly condemned the MOX plan, and periodically the chant: "NO MOX" would be taken up by the crowd. "What part of the word 'NO!' don't they understand?" asked one speaker in reference to the authorities responsible for the decision to take the plutonium through First Nations territory. The main theme: We shall stop this, with whatever it takes! It was clear that they really meant business. We were not hearing hollow rhetoric. We

realized that, if all else fails, the Mohawks would, unquestionably, attempt to physically block a MOX shipment, be it on the seaway, or on the land. Less than two weeks later, Prime Minister Chretien's pet MOX initiative suffered a serious setback. The November 15th National Globe and Mail headline read: "Shipping plutonium to Canada rejected. Protests persuade U.S. to destroy own waste." The test shipment would go through, but the Americans would burn their surplus plutonium in their own reactors. However, the article also stressed that the U.S. "...reserves the right to reconsider the action." My immediate thought was that if anti-MOX protests succeed in the U.S., DOE will be back knocking at Ottawa's door. In view of this development, why should the Chalk River tests proceed? One report suggested that the U.S. was worried that the Russian support for disarmament might wane if the experiment didn't proceed. Pretty lame reasoning! The anti-MOX coalition did not let down it's guard. Michigan politicians and activists continued their battle against the planned test shipments, even in the courts. On December 7, 1999, the U.S. District Court judge in Kalamazoo, Michigan, issued a ten day restraining order on the test shipment destined for the border crossing at Sault Ste. Marie. The suit was brought by a Michigan environmental group and six people living near the route. Unfortunately, the court victory was short-lived. On December 17, the judge declined to order a full injunction against the shipment on the grounds that, doing so would represent judicial interference in the U.S. Federal Government's foreign policy jurisdiction. I managed, with some difficulty, to put the MOX issue on the back burner over the Christmas holidays and the millennium new year celebrations. There were no more comments to write, no more rallies to attend. But the Feds on both sides of the border were not relaxing over the holidays. They were quietly cooking up a scheme that was to profoundly rattle the sensibilities of everyone involved in the MOX issue. The big headline in the Globe and Mail on January 15, 2000 read: "Plutonium flown over Canada: Surprise shipment via helicopter sparks anger from environmentalists and community leaders." Anger is too mild a word.. Why, I could almost hear our "clutch `em by the throat, pepper spraying" Prime Minister giving the order to "fly it over their heads, but get it here!" followed by "heel clicking salutes" from Canada's "MOX establishment" (Atomic Energy of Canada, Ltd., Atomic Energy Control Board, Department of Natural Resources and Transport Canada). No matter that the U.S. had to use a truck to ship the plutonium from Los Alamos, N.M., to Sault St. Marie, Ontario, because it's regulations consider it too unsafe to ship the MOX by air! Canada had no such requirement. The entire clandestine operation was conducted with the precision normally associated with a military police state. Outrage soon turned to purposeful action. By mid-February, 2000, Michigan environmentalists joined by six Canadian native and anti-nuclear organizations, were preparing to file suit in an attempt to block the Russian shipment. Terry Lodge, an

attorney for the plaintiffs in the Michigan case cut to the crux of the issue in a few words: "The use of MOX creates more bomb possibilities around the world, not fewer. Instead of rolling plutonium up in two-ton glass logs and disposing of it under heavy guard, our government instead wants to show the world how to fuel low-security civilian nuclear plants with it. There will be lots of scary new members to the 'Nuclear Club' if we do this." Nevertheless, the Michigan case was dismissed by the Federal District Court in April, 2000, again on jurisdictional grounds. Canadian environmentalists and anti-nuclear activists also vowed to pursue a judicial review unless the government changed its plans to import Russian fuel. The legal brief, prepared by the Canadian Environmental Law Association (CELA), charged that Transport Canada broke the law by approving the movement of plutonium by helicopter. As I had anticipated, "at the end of the day" the Canadian legal intervention would have no impact on the final result. By the end of July, 2000, Transport Canada issued, for public review, a revised AECL Emergency Response Assistance Plan for air transport of the Russian MOX to a Canadian Forces base. Again, it was easy to poke holes in what was an incredibly amateurish document. But it was very difficult to get "cranked up" to review and comment on another fait accompli Government plan. I commented anyway. On Sept 25, 2000, a shipment of Russian MOX fuel samples from Moscow arrived by commercial air carrier at Canadian Forces Base Trenton, where it was transferred to a helicopter for the trip to Chalk River Laboratories. At long last AECL had its hands on the two batches of MOX fuel, one from the U.S. and one from Russia. The big question remains: why? In view of all of the opposition and the waning enthusiasm of the other parties involved, why would the Government of Canada and AECL persist in this folly? Why bother testing the MOX fuel for CANDU use at all? Could the answer simply be that Mr. Chretien could not bring himself to back-off an agreement he made with U.S. President Clinton? Maybe! His ego needs are large. But now there is a new President! Well, sort of! Perhaps the answer is simply "inertia." A lot of time and money had already been spent on the MOX-CANDU option, and, after all, there is a contract with DOE. AECL needs the money! What other reasons can there be? The U.S. Government decided to take care of it's own surplus plutonium. But, perhaps the Government of Canada and AECL still hold out hope that Washington will change it's mind. There is plenty of opposition to the building of a MOX fabrication plant in the U.S. The public kept a proposed MOX production facility out of Hanford, in Washington State. In August of 2001, concerned that the weapons plutonium being shipped to his state for MOX fabrication or immobilization, would be permanently stored there, South Carolina Governor Jim Hodges threatened the use of highway roadblocks to prevent the U.S. Feds from shipping in the stuff. Perhaps, after enough domestic opposition,

someday, the Americans will rekindle their interest in the CANDU-MOX option. Back in 1994, Ontario Hydro, the Provincial nuclear utility, was a major player in promoting the MOX-CANDU option. After all, it was it's reactors that would be used to burn the surplus MOX. But it clearly lost enthusiasm for MOX over the past several years. Hydro has been beset with financial, management and technical problems in it's nuclear program, and MOX worked its way down on the priority list, and now, may not even be on it. In the December, 1998 issue of Pic Press, Mike Williams, Hydro's Director of Nuclear Public affairs, is reported as actually denying an interest in the program. But, perhaps the Government of Canada and AECL still hold out hope that, if the Chalk River tests succeed, and if the plan makes sense from a business standpoint and if regulatory hurdles can be cleared, (if....if), then maybe, someday, Ontario Hydro or it's successor, will rekindle the MOX option. What about the Russian MOX? Maybe the Government of Canada and AECL hold out hope that the Russians will send all its' portion of surplus plutonium, as MOX, to Canada for CANDU reactor consumption (for a large fee?). Possibly! However first the Russian Government needs lots of financial help from the West, including Canada. to build up its' own MOX infrastructure. Anyway, the Russian Government loves plutonium so much, it might just use it all up in it's own reactors and reprocess the spent fuel to make more MOX, or whatever! Someday, I suppose AECL will announce the CANDU-MOX test results. But as of Spring, 2008, I have not heard a word about those MOX test shipments. Whatever the finding is, the questions will still remain: What is the best way to deal with weapons plutonium, or, reactor grade plutonium, or, for that matter, high-level nuclear waste? "Immobilizing" weapons plutonium, guarding it, not producing any more of it, along with a world wide ban on MOX production, would be a great step forward for everyone's safety and security. But it is not a permanent solution as long as these substances exist. The same holds true with spent fuel from nuclear reactors. Perpetual maintenance and security of nuclear waste at the reactor-sites, while not producing any more of it, would also be a great step forward. Again, it is not a permanent solution as long as these substances exist. Unfortunately there is no law that says the existence of a problem guarantees a good, acceptable and permanent solution.

ATW--Modern Day Alchemy But I still had hopes that some technological solution could be found to deal with nuclear waste. Could ATW be that solution. In the final two chapters of volume III of the Great Canadian Nuclear Waste Saga, I included a number of references and comments about the technology of Accelerator Transmutation of Nuclear Waste (ATW). In 1998 I added a specific ATW page to this web site (which this text replaces). I argued that ATW should be investigated sufficiently to determine it's viability as an option for the final and permanent destruction of high-level

nuclear waste and weapons plutonium. ATW is a process in which long-lived radioisotopes are converted to short-lived ones and inert substances by neutrons from an accelerator. For a variety of reasons, ATW was, for many years, relegated to the backwaters of scientific research. It did not emerge as a popular nuclear waste management option, either inside or outside of the nuclear establishment. The preferred option inside the establishment was clearly geological isolation. In 1980, when I got involved in the underground research controversy in Manitoba, it was apparent that the problem of nuclear waste "disposal" had virtually become the exclusive domain of the geo-scientific community. Other scientific disciplines had been relegated to the sidelines. The underground burial advocates took control of substantial public resources and became the principle influence on public policy in nuclear waste generating countries. Some of the early Canadian reports and studies I read, perfunctorily dismissed non-geological options (transmutation among them), and went on to extol the virtues (as well as prejudging the success) of geological isolation of nuclear waste. That the geological option was seized upon by the world's nuclear establishment is easily explained in that it promised a relatively quick fix for the mounting stockpiles of high-level nuclear waste at the reactor sites. The waste would soon be out of sight, out of mind, a situation which could facilitate the development of more nuclear energy. Or so it was thought. Even the U.S. National Research Council in a 1996 study presented a rather lukewarm analysis of ATW. That study concluded that the state of the art of any transmutation process was insufficient to justify a delay in the opening of the first nuclear waste repository. As for Canada, the nuclear establishment was not involved with ATW research. And, as I discuss in the final two chapters of volume 3 on this web site, the Canadian Environmental Review Panel on nuclear waste, avoided ATW "like the plague." Not only did the main scientific and nuclear establishments take a dim view of ATW, some of my favourite and most highly respected U.S. nuclear watchdog organizations, rendered rather harsh judgements of the technology. In December, 1999, Amy Shollenberger, senior policy analyst for Public Citizen's Critical Mass Energy Project said that The U.S. Department of Energy (DOE) "... should not continue to spend money researching the Accelerator Transmutation of Waste (ATW) system because it will not offer a viable solution to the nuclear waste problem facing the United States." In the March/April 2001, Bulletin of the Atomic Scientists, Arjun Makhijani, President of the Institute for Energy and Environmental Research (IEER), citing many scientific and technical problems, suggested that transmutation research had been "driven by political forces intent on propping up the nuclear power enterprise." In a May 24, 2001 statement, Edwin Lyman, Scientific Director of the Washington based Nuclear Control Institute (NCI) said that "implementing DOE's ATW concept would vastly increase the environmental, safety and proliferation risks from nuclear power, cost

taxpayers a fortune and almost certainly fail to achieve its primary purpose, which is to simplify nuclear waste disposal. The U.S. nuclear watchdog groups were, in part, reacting to Sen. Pete Domenici's, (R-N.M.), March, 1999 initiative to breath life into the fledgling ATW program, by securing funds for further research. In FY 1999, in the Energy and Water Appropriation Act, the U.S. Congress directed DOE to conduct a study of ATW and to prepare, a "road map" which would forecast needed research areas, time table, costs and schedule. Released November 1, 1999, the road map, with considerable international scientific input, described in detail, a five year, $281 million project. By July, 2001, DOE's advanced accelerator application (AAA) grants were being distributed to some of the major U.S. universities. Why, in 1999, did ATW suddenly emerge from it's position of relative obscurity? The simple explanation is that it was now being clearly linked to facilitating the Yucca Mountain nuclear waste repository program and to the future of nuclear energy. As stated in the DOE news release " If ATW technology could be successfully implemented to overcome all technical issues, it could potentially facilitate the long-term management of a repository system." And in the words of DOE official, Dr. Stan O Schriber, "ATW holds the promise of making nuclear power more acceptable to the general populace by minimizing the amount of material that has to be stored in a repository and by reducing the length of time over which a geologic repository must be licensed." (As for the length of time, in one of his reports, Los Alamos scientist Francesco Venneri stated that "The goal of the ATW nuclear subsystem is to produce three orders of magnitude reduction in the long-term radiotoxicity of the waste sent to a repository, including losses through processing. If the goal is met, the radiotoxicity of ATW-treated waste after 300 years would be less than that of untreated waste after 100,000 years.") The DOE and the U.S. nuclear industry underground burial advocates have neatly coopted ATW to their own ends. They have concluded that some day they might need it to help them justify and sell Yucca Mountain as well as more nuclear energy development to a skeptical U.S. public. But would it? It seems that the nuclear energy and underground waste burial advocates will stop at nothing to get their waste repository "up and running." Why should the public more readily accept the garbage dump, simply because it is augmented by a 5 year ATW research project? Suppose the ATW research does not pan out? Then, the repository full of dangerous nuclear waste and plutonium would eventually be sealed up with all of the risks that would entail.

Even Canada’s (industry dominated) Nuclear Waste Management Organization (NWMO) weighed on the issue. In its final report, it rejected ATW, blithely ignoring some of the facts presented to it by its own consultants. It dismissed the ATW option of transmuting nuclear waste to low-grade or even inert substances because it "...is not yet sufficiently advanced for implementation and long-term management of the residual materials would still be required." It cites a report from French nuclear authorities that "industrial implementation of transmutation

cannot be seen until the years 2040-2050 at best." And yet, NWMO is perfectly willing to wait some three hundred years before a dubious underground repository is permanently closed. But, in NWMO Background Paper: 6.5 Technical Methods: Range of Potential Options for the Long-Term Management of Used Nuclear Fuel, by Phil Richardson & Marion Hill, Enviros Consulting, it is stated that "It is recognized internationally that the possibility that P&T (partitioning and transmutation) could become a readily available and very attractive treatment option in several decades time, (and) could be a reason for choosing storage rather than disposal." Furthermore, in NWMO Background Paper: 6-1 Technical Methods: Status of Reactor Site Storage Systems for Used Nuclear Fuel, by SENES Consultants Limited, it is stated that the dry storage facilities of irradiated fuel at Canada's nuclear power sites currently have a design life of 50 years and that "...the actual life of dry storage containers is thought to be 100 years or more." Put two and two together, and you have a compelling case for continued on-site storage, with augmented security, coupled with some serious research and development into transmutation technologies, (which to my knowledge, no one in Canada is pursuing). I've referred to some of the risks of underground burial throughout the first three volumes of the Great Canadian Nuclear Waste Saga. One of the greatest concerns now, is that reactor-grade plutonium, including that produced by the "burning" of MOX (weapons plutonium) fuel, would be sitting in nice, neat underground vaults, just waiting for extraction by future terrorists, rogue states or other disaffected members of society. Reactor grade plutonium can be used to manufacture a crude but highly destructive nuclear weapon. Other concerns about a repository include nuclear waste transportation accidents, human intrusion, repository failure and environmental contamination, stemming from a wide variety of possible causes. ATW should not be used as an adjunct to an underground repository program, to help promote future nuclear energy development. I believe that ATW research should proceed on it's own merits, it's main purpose being a clear determination as to whether or not the technology can safely eliminate weapons grade plutonium and high-level nuclear waste without the need for additional management processes, i.e., underground repositories. I understand the concerns of the anti-nuclear organizations. I realize that any scenario that removes nuclear waste as a “problem” for the industry could lead to a change in public perceptions, which would benefit its reactor expansion hopes and dreams. But I still would rather see the waste destroyed than buried to the potential detriment of future generations. But, now, it is difficult to determine just how much progress, if any, is being made on ATW technology. My internet searches in 2007 revealed very little contemporary information on the subject. I assume that some work must be going on in various universities and laboratories. But I get the distinct impression that the "hell bent for underground burial establisment" pretty well put ATW out of business, at least for now.

Nuclear Waste Management Organization The perceptive reader may now be wondering, whatever happened to that Seaborn panel environmental assessment report which occupied so much space in the third volume of my Great Canadian Nuclear Waste Saga? Did the Government of Canada do anything about it? Did it just sit on the shelf gathering dust somewhere in the basement of an Ottawa government building? Have I been avoiding the subject? I think I made it crystal clear in volume three that I was not overjoyed with the final Seaborn report. And, I had some mixed feelings about its conclusions. But, after what we went through in Manitoba, I certainly hoped for some rational decision which would be enshrined in legislation and would call for a truly independent agency to oversee the management of nuclear waste in Canada. And so it came to past. But not in the way I had hoped. Under federal legislation (Bill C-27-Nuclear Fuel Waste Act, assented to 13th June, 2002), the nuclear industry corporations established their Nuclear Waste Management Organization (NWMO). The main function of the NWMO was to propose to the Government of Canada approaches to the long-term management of nuclear fuel waste and thence to implement the selected approach(s). Every nuclear energy corporation became members and/or shareholders in the NWMO (i.e., Ontario Power Generation Inc., Hydro-Québec, New Brunswick Power Corporation, and Atomic Energy of Canada, Ltd.) The NWMO Board of Directors became a “Who’s Who” of the Canadian nuclear establishment. Thus, the biggest fatal flaw in the Act was its failure to establish a completely independent, arms-length-from-industry-organization. With the nuclear industry holding the reins of power, the NWMO can rightly be viewed as no more than a tool of that industry. Thus, nothing much has changed since the late 1970's when Ontario Hydro and AECL banded together to launch its now legendary assault on unwary communities throughout the Canadian Shield in Ontario and eastern Manitoba. The Act required that within three years of its coming into force, the NWMO submit a study to the Minister of Natural Resources, Canada, with a recommendation as to which of three proposed approaches should be adopted, i.e., deep geological "disposal" in the Canadian Shield, based on the AECL underground burial concept, storage at nuclear reactor sites and centralized storage, either above or below ground. The NWMO was required to provide a detailed technical description of each proposed approach and specify an "economic region" for it's implementation. Another fatal flaw is the lack of provision for either parliamentary or public input at the critical point in the process; i.e., immediately subsequent to the NWMO final recommendation to the Minister. There is no provision for full scale federal environmental assessments (EA) of the various options specified in the legislation. One option, the AECL underground burial option, has been subjected to a comprehensive process-indeed, over many years. The other options have not been so assessed, nor could they be during a short three year time frame. Furthermore, the owners of the nuclear waste have recently suggested modifications to the AECL concept in their reports which rightly should evoke an additional EA for the

underground burial option. In the absence of such EA's there can be no balance, no fairness, no equity in this process which means that the final NWMO recommendation would lack credibility. The various background and other papers solicited by the NWMO, along with other measures it has been taking, such as its interactive web site, polling and group meetings, hardly substitute for the kind of searching inquiry inherent in the EA processes. But the NWMO was required to have its report completed and submitted to the Minister sometime in the Fall of 2005. Deeply conscious of the deficiencies in the legislation and the resulting NWMO, some of the Canadian activists, including myself, banded together during 2003 to establish a new cross-Canada network: Nuclear Waste Watch (NWW), which would monitor the work of the NWMO. About thirty environmental and social organizations signed on to the final network position statement. Currently (April, 2008), that statement is available on the web at http://www.cnp.ca/nww During May and June of 2004, Phyl and I took a five week trip in our camper van to parts of western Canada. We made a stop at Lac du Bonnet, Manitoba, to visit with our good friends, the Ylonens. George Ylonen, who is mentioned frequently throughout my Great Canadian Nuclear Waste Saga, gave us a tour of the rural municipality of Lac du Bonnet. It was our first visit there since we left Manitoba back in 1987. Over that long period of time, much had changed, especially in the village itself where old buildings had been torn down and new ones stood in their place. We had already discovered that the people who had bought our 160 acres and our hybrid log cabin-cedar house, had replaced it and all the outbuildings with a more conventional dwelling. But, it was great visiting with George and some members of his family and to talk about the old battles and to speculate over possible future ones concerning the nuclear waste issue. At the very end of the tour, George drove us a few miles down a dusty road and up over a hill, in sight of the grey tower head frame of AECL's undergound nuclear waste test facility. That quick view simply reinforced my conviction that we, as a society, must not permit the permanent underground burial of irradiated nuclear fuel, and that I, for one, will continue to do what I can to try to prevent it from happening. During the balance of 2004 and into 2005, I adopted a very low key approach to the nuclear waste issue as it was unfolding at the NWW and the NWMO. Phyl and I attended one NWMO information meeting in Kingston in early 2005, which was very poorly attended. The staff nearly outnumbered the public. But it did give us a chance to acquaint the NWMO consultants with some of our strong negative feelings toward the industry that they were representing. As a member of the NWW steering group, I did participate in several conference calls designed to reach agreement on various policy positions and strategies. I also waded through the NWMO discussion papers and put some of my thoughts on this web site about several of them. I was particularly concerned about the papers dealing with the relationship between nuclear waste and potential terrorist attacks in a post September 11,

2001 world. My concern was not fanciful. Shortly after the September 11, 2001 terrorist attacks on the U.S., it was widely reported that al-Qaeda had given serious consideration to crashing commercial aircraft into several nuclear plants on that day. According to journalist Jeffrey St. Clair, in his September 14, 2002 Counterpunch article (The Fire Next Time), al-Qaeda operatives Ramzi bin al-Shaibah and Khaled al-Sheikh Mohammad told Al-Jazeera interviewer Yosri Fouda, that future attacks on western nuclear facilities could not be ruled out. While it is true that nuclear reactors are housed in buildings that are among the most durable modern structures in existence, and have been designed to (hopefully) withstand the force of earthquakes, no one had ever conceived of a direct impact from a large commercial aircraft full of aviation fuel or from some other similar massive explosive assault. Some authorities state that the consequences would be truly catastrophic. But the real Achilles heels at nuclear plants are the adjacent spent fuel facilities, which contain major concentrations of highly radioactive material. They lack the heavy duty containment safeguard provided for the reactor, and could be considered "sitting ducks" for disastrous terror attacks. Large explosions, along with major fire resulting in radioactive release from spent fuel would have serious health, social and economic consequences for people in the surrounding geographical area. It should be noted that many of our nuclear facilities are in close proximity to the Great Lakes. Any ecological disaster resulting from terrorism could affect both Canada and the United States. Unfortunately, none of the discussion papers commissioned by the Nuclear Waste Management Organization (NWMO) deals forthrightly and directly with the need to "harden" existing spent fuel facilities at reactor-sites to better protect them from such an attack. Some of the discussion papers deal with nuclear waste security, but in rather general and overly reassuring terms. In my view, the NWMO discussion papers (with the exception of the final one by Ed Lyman of the Union of Concerned Scientists), do not truly come to grips with the growing threat of extremist Islamic terrorism in the world, and how spent nuclear fuel could be used to further that threat. Perhaps one reason for this is that Canada, unlike many other countries, has not (at this writing) been subjected to these barbaric attacks. Another possibility is that Canadian authorities are actually working on the problem, but prefer to keep their efforts quiet----for security reasons. In any event, none of these papers directly identify, in any degree of detail, possible kinds of terrorist scenarios and how Canada could develop plans to deal with them. Mostly, the papers hide behind administrative requirements and regulations of the Canadian Nuclear Safety Commission, almost as if somehow the rule book itself provides a wall of protection. 1 Transportation of spent nuclear fuel: Several discussion papers emphasize that there have been no attacks on spent fuel shipments anywhere in the world. But, some also point out that there have been relatively few spent fuel shipments. If spent fuel is to be moved from reactor sites to any centralized

locations, shipment frequency would increase dramatically over decades. It is hard to imagine that such a change would escape the notice of terrorists who are becoming increasingly sophisticated with their information networks and their technology for destructive acts. Lauding past performance is not a comforting response to the potential threats of the future. Assertions to the effect that attacks upon spent fuel shipments would fail, or produce very limited negative consequences, or that safeguards in the present security system are adequate, minimize the fact of the rapid advance of destructive technologies now is use or potentially available to those who wish to do us harm. And, as Mr. Bin Laden has indicated, all of us who are not in his camp, can be considered "infidels" and fair game. Are contemporary spent fuel transportation casks on trucks or trains sufficiently "robust" to withstand a major, high yield type of attack? Many nuclear watchdog groups and others, point out that governments have not undertaken the kinds of full scale tests required, and therefore, the question cannot be reliably answered. As one paper points out, other transported substances might be more easily used by terrorists. Perhaps, but that overlooks the essence of the terrorist mentality and objectives; i.e., to terrorize the public. The large scale psychological impact on the public from damage, destruction and disperal of a nuclear source (as contrasted with any other substance) should never be underestimated. Any contemplated large-scale, long-time period movement of spent nuclear fuel from reactor sites to some centralized storage or repository site, is, for me, truly a "non-starter." Furthermore, I am fully confident that communities along nuclear waste transportation routes would veto any such plan. 2 Security of the storage options themselves: In spite of the reassuring words about security of the various options in some of the discussion papers, no concrete evidence has been presented that any one of the nuclear waste management options is really secure from large scale terrorist attacks. The onus has been placed upon current regulatory standards which were produced for a bygone age. Nowhere (with the exception of Ed Lyman's paper) have some of the key technical issues surrounding terrorism even been identified. Nowhere in these papers has the central issue of the need for securing and "hardening" on-reactor-site storage facilities against contemporary terrorist methodology, been addressed. As long as the reactors are operating, there will always be at least a ten year (cooling off) inventory of high-level nuclear waste at the reactor sites, even if the older waste is moved somewhere else. The technical problems surrounding the security of that on-site waste must be addressed. That they have not been adequately addressed in the NWMO discussion papers dealing with the subject of security, is a very serious deficiency; one which makes the selection of a final nuclear waste management option, a dubious exercise at best. Outside of a general recognition of need, specific security problems and protections for the centralized (above or below ground) storage option were not mentioned. Both a centralized storage facility and an underground repository facility share some of the same security risks; i.e., transportation to them, as well as vulnerability of protracted surface exposure at the destination, including loading and unloading, repackaging, and movement to the

final resting place. Advocates of "permanent" underground burial in a deep geological repository have long insisted that their option is virtually completely secure; from theft, terrorism, accidents, etc. As indicated above, the permanent burial option is still subject to the security risks of transportation and the exposed surface destination. Nor does burial solve the problem of the "hot" waste that must remain at the reactor sites for at least a decade before being moved. Can geological repositories really remain secure for thousands, or even hundreds of years? Some scientists think not and suggest that such facilities could become "plutonium mines" of the future. An underlying premise of the burial concept is that the waste would not only become irretrievable, but the waste repositories themselves, would require "no institutional controls." Given the advance of science and technology, there is absolutely no reason to believe that a sealed-up underground facility would need any fewer institutional controls than an aboveground one. It would be prudent to assume that those in the future who might want to extract the contents of an underground nuclear burial place, will have the capabilities to do so with whatever technologies, and for whatever purposes they may then have. In any event, by now it should be crystal clear that this "out-of-sight-out-of-mind" approach was not embraced by a public which was confronted with the spectre of permanent geological burial. Atomic Energy of Canada, Ltd., (AECL) discovered this in the 1980's while trying to implement such a program in the Canadian Shield rock in Manitoba and Ontario. More recently, media accounts of an NWMO commissioned study (Citizens' Dialogue on the Long-term Management of Used Nuclear Fuel, July, 2004) reported that "Canadians want the radioactive waste from their nuclear reactors stored within reach, not dropped down holes deep into the rocky Precambrian Shield and forgotten. And they don't trust government, industry or existing regulators with the job." In the U.S., the Commission studying the circumstances that led up to the tragic events of September 11, 2001, pointed to a "lack of imagination" on the part of the intelligence community. I note a singular lack of imagination in most of the NWMO discussion papers that deal with the subject of security and nuclear waste. There is an unmistakable aura of smugness and complacency in some of these writings which I find disquieting. They convey the message "Don't worry, we have it all under control." Anytime I hear that kind of message on a subject of this gravity--I do indeed worry. And so should we all! Things started heating up again in the Spring and Summer of 2005 when, finally, the NWMO released a draft of its final report for public comments. The final report was submitted to the Government of Canada in the fall of 2005. You have got to hand it to the Canadian Nuclear Industry. It doesn't give up easily. Having failed to gain access to a site for a permanent underground nuclear waste dump in the late 1970's and early 80's, it is getting ready to take another kick at the can using its NWMO as its agent. In its draft final report, Choosing the Way Forward, the NWMO concluded that the growing stockpiles of irradiated nuclear fuel from Canada's reactors should ultimately wind up in a deep rock underground tomb. What a surprise!

We were back to square one. NWMO has taken us right back to the late 1970's. There appeared to be only two significant changes in the NWMO report as compared with the earlier effort spearheaded by Federal Crown Corporation, Atomic Energy of Canada, Ltd.(AECL). The first is an expansion of the kinds of geological rock formations deemed suitable for the dump. AECL initially restricted its dump site search and research to special "plutonic" granite formations. Much scientific hoopla was touted for this choice. But, later, after disrupting many communities in the Canadian Shield in its pluton search effort, AECL announced that a dump could go into any type of granite rock formation. Now the NWMO has gone a step further by including so-called "Ordovician Sedimentary" rock, which can be found in many parts of Canada, including Ottawa, Kingston, and the Bruce Peninsula in Ontario. Such locations are now considered suitable candidates for potential irradiated nuclear fuel waste dumps. Such an expansion of potential sites would vastly increase the chances of NWMO finding some needy community willing to sell its soul and its safety to the nuclear industry for big bucks. To the best of my knowledge, the NWMO did not "assess" this new geological concept. Where is the science behind this decision? Where are the extensive geological and engineering studies that would support placing any kind of radioactive waste in such rock formations? Where are the volumes and volumes of information concerning the nature and integrity of "Ordovician Sedimentary" rock? In short, where is the proof that, say, limestone formations (as found in many parts of Canada), are scientifically suitable for such a crucial facility? The new motto should be "Any old rock will do -- just let us in!"

The other change is the establishment of a longer time line for the upcoming effort. NWMO's time frame could extend as far as three hundred years for final closure of an underground dump, whereas AECL thought that goal could be achieved in a much shorter time period. As with all good bureaucracies, NWMO is taking out a nice long insurance policy on its own survival as an organizational entity. The so-called "Option 4 'Adaptive Phased Management' (APM)" discussed in the NWMO final report is simply a dressed-up version of AECL's original nuclear waste burial program. Option 4 combines elements of the on-reactor site option, the centralized storage option and the underground burial option. In fact, nearly all the elements of APM can found in an October 1978 AECL publication, Management of Radioactive Fuel Wastes: The Canadian Disposal Program, J. Boulton (Editor), numbered AECL-6314. The Boulton report encompassed "Pre-disposal Technologies, including wet and dry storage at reactor sites, as well as the possibility of the need for a central storage facility.” That report stated that "A central storage facility could be located at the site of a generating station or at a fuel management site which may also include immobilization and disposal facilities." These "pre-disposal" storage options would be needed for "several decades." And for the final disposition, the Boulton report described the ultimate underground dump in grim detail. As expected, the NWMO rejected the option for continued on-reactor-site storage of the waste. Expected, because such a decision could be fatal to the nuclear industry. It would be tantamount to a declaration that there is no solution to the nuclear waste problem (which at present happens to be true!). The industry's efforts to promote more nuclear

energy, with the resulting production of more nuclear waste, would undoubtedly meet with more than a little skepticism from the Canadian public if the waste remained at the reactor sites indefinitely. So, NWMO's recommendations are quite in sync with the nuclear industry's current aggressive reactor marketing schemes. In effect, the NWMO recommended a lengthy process that leads up to deep rock permanent underground burial of Canada's irradiated nuclear reactor fuel. How would the Government of Canada react to the final report of the NWMO? We found out on June 14th, 2007, when Gary Lunn, the Minister of Natural Rsources of Canada, announced that the Government of Canada had accepted the NWMO recommended approach for managing irradiated fuel wastes. I had hoped that the new minority Conservative government would have had enough sense to refer the NWMO approach to the Canadian parliament as a whole for consideration before moving ahead; it would have been the right, moral, and democratic thing do, given the seriousness of (pardon the expression) the undertaking. But the upside of the decision is that the die is finally cast and the public will know exactly what it is facing---no more fudging and misleading people with "it is only research," "it is only a concept," "we have no plans to emplace waste here," etc. NWMO is presumably officially looking for an actual site for its underground nuclear waste dump; likely the first of several such sites if the industry gets its way on nuclear energy expansion. Furthermore, with the new rather unscientific "virtually any old rock will do" approach, communities in Ontario, New Brunswick, Québec and Saskatchewan are now potential nuclear waste dump sites. Hey, Toronto, Ottawa, Montreal, Québec City, Fredrickton, Regina, Saskatoon---are you ready? How about under the CN tower? Manitoba is NOT on the short list; (at least not yet). Our efforts back in the 1980's may have had something to do with that fact, in that the Manitoba legislation prohibiting the import and disposal of nuclear waste is still on the books, as of 2008. But political parties and laws can change over time. I would never rule out Manitoba, but I have a strong suspicion that NWMO may be taking a close look at some other options. Although NWMO loves using the terms “open and transparent” regarding its activities, any serious possibility it may have for a final resting place for Canada’s irradiated nuclear fuel waste will likely remain a “state secret” until all the basic “spade work” is accomplished behind the scenes, and the foot is truly in the door.

BRUCE 2002 was a busy year for Ontario Power Generation(OPG) on the nuclear waste front. Not only did it participate in establishing the Nuclear Waste Management Organization (NWMO), it also entered into an agreement with the Municipality of Kincardine at the Bruce nuclear facilities to “...develop a plan for the long-term management of low and intermediate level radioactive waste.” The plan was for a deep geological repository on the Bruce site, which is situated on the shores of Lake Huron.

OPG hired Golder Associates to study options for managing low and intermediate level waste. Three options were considered: . Enhanced Processing, Treatment and Long-Term Storage . Covered Above-Ground Concrete Vault . Deep Geological Repository. In 2004, deep geological repository was chosen because it was deemed to have a “larger margin of safety.” Various social, technical and economic analysis were performed by the proponents, along with community consultation, finally resulting in the public release of a 2006 draft “scoping” document on the project. Federal Environment Minister, Hon. Rona Ambrose requested public comments. The intended scope was limited to an internal study process, unacceptable to many of the nuclear watchdog groups which insisted upon a full-scale environmental assessment with a Panel and public hearings. In my comments on the proposal, I made the following points: “The current definition of low and intermediate radioactive waste includes some isotopes that are extremely long-lived (hundreds of thousands of years) and can be considered very serious environmental and public health threats for those aeons of time. Panel hearings must examine in detail all of the interdisciplinary questions surrounding this proposal. For example, to mention a few: . A complete analysis and airing of all relevant health physics and epidemiological data to determine the possible health consequences of human exposure to these substances in the near, intermediate and far term. . The scientific and especially the geologic issues surrounding the choice and the integrity of the specific types of rock formations in the Bruce area, into which such a repository might be placed. . Analysis of the management, techniques, and processes required for successful retrieval of these substances in the event of breach of repository conditions; understanding of the many kinds of conditions that could lead to such a breach and an examination of mitigation strategies in such an event. . Questions surrounding the security and safety of the physical movement and handling of these materials and the potential accessibility of them to both inadvertent and deliberate human intrusion, prior and subsequent to final repository closure. The disposition of such materials would be of more that passing interest to terrorists. . Proposed methodologies for continuous and long-term monitoring of the status of the radioactive substances that would actually be placed in such a deep repository, including

an analysis of governance and institutional capability and stability issues over long time frames. . The environmental assessment should be bi-national in nature, inasmuch as the contemplated site is close to Lake Huron, a body of water shared by both the United States and Canada. It is my understanding that individuals and groups within the United States have already expressed concern over this proposal.”

In his comments to the CNSC, for the October 23, 2006 public hearing in Kincardine, Ontario, Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility, had this to say about the contents of so-called low and intermediate level radioactive waste: “Although the radioactive wastes to be stored in the proposed facility are superficially described as low-level and medium-level radioactive wastes, this terminology is completely inadequate to describe the extraordinarily complex mix of radionuclides of all sorts – fission products, activation products, corrosion products, beta and gamma emitters, alpha emitters, and neutron emitters, with half-lives ranging from years to millennia. Moreover, the physical and chemical forms of the wastes destined to be stored in the proposed underground facility are incredibly diverse and complicated, comprising everything from radioactively contaminated filters, mops and rags, to barrels of radioactive debris, to contaminated and irradiated structural elements such as the highly radioactive pressure tubes and the mammoth steam generators with their thousands of internally corroded radioactive pipes. In many ways, problems of containment integrity, radioactive leakage, chemical interactions and pathways to the environment are as complicated and perhaps even more complicated than in the case of the underground storage of irradiated nuclear fuel.” Happily, the Canadian Nuclear Safety Commission agreed with the critics, to “bump up” the scope of the inquiry to a full scale environmental assessment process. Its announced its decision to “...recommend to the federal Minister of the Environment that Ontario Power Generation Inc.’s (OPG) proposed project to construct and operate a deep geologic repository within the Bruce Nuclear Site in Kincardine, Ontario, be referred to a review panel.” In April, 2008, the Canadian Environmental Assessment Agency released to the public a 106 page environmental impact statement guideline. The purpose of the guidelines is “...to identify for the proponent, Ontario Power Generation (OPG), the nature, scope and extent of the information that must be addressed in the preparation of the Environmental Impact Statement (EIS) for its proposed Deep Geologic Repository (DGR) to store low- and intermediate-level radioactive waste. The proponent will prepare and submit an EIS that examines the potential environmental effects, including cumulative effects, of the site preparation, construction, and operation decommissioning and long-term performance of the project and evaluates their significance. This information will be used by a joint review panel established pursuant to the Canadian Environmental Assessment Act and the Nuclear Safety and Control Act...” As is unfortunately often the case with environmental assessments , a very short period of time was allotted for public comments on the guidelines—due by June 18, 2008.

In that Lake Huron is a crucial body of water which serves both Ontario and the State of Michigan in the U.S. both Americans and Canadians are registering concerns over the proposed project. For example, Michigan Congressman Bart Stupak stated that “...it is a bad idea to put radioactive waste so close to one of the Great Lakes.” The full scale environmental assessment will provide people on both sides of the border the opportunity to speak their minds.

ALMOST ANY OLD ROCK WILL DO

In my thinking, the OPG Bruce low and intermediate level proposal is inexorable linked to the conclusions of the NWMO regarding the expansion of geological formations for burial of high-level irradiated nuclear fuel waste. The NWMO report on this point was a radical departure from everything I have ever read or heard about, concerning possible geological formations for containment of these longlived, highly radioactive substances. This development raises serous questions about the very integrity of the NWMO, its constituent membership, and the government of Canada itself. The Minister of Natural Resources, Canada, certainly should not have approved the NWMO final report without questioning and/or providing some explanation to the public on this point. AECL itself, in its role as an NWMO member, obviously went along with this decision to expand the geological formations, even though it had spent decades studying and extolling the virtues of granite plutonic rock as the best possible natural barrier to retard the ultimate excursion of nuclear waste into the outside environment. And what of limestone, the formation of choice at Bruce? Many people associate limestone with water. And water and radioactive waste simply do not mix. I came across a statement on a University of Florida website regarding aquifers and ground water. The statement described consolidated formations as “...those composed of solid rock with ground water found in the cracks. The amount of ground water in a consolidated formation depends on how many cracks there are and the size of the cracks. For example, consolidated limestone formations often contain caverns with much water in them.” After some test drilling, plutonic granite was touted as “solid rock” with few cracks and fissures, back in 1980 by the nuclear geologists in eastern Manitoba. During the construction of the underground research laboratory, discovery of major water bearing fracture zones certainly put that idea to rest. The Bruce underground facility proposal is an echo of that 1980 granite assessment, as it extols the containment virtues of the host limestone rock formation. I think we have a right to know just what is the real agenda at Bruce. Is there a hidden one? It is not easy to dispel a deep seated suspicion that the planned Bruce low and intermediate repository might just be an ingenious Trojan horse for an ultimate dump for Canada’s growing inventory of high-level irradiated nuclear fuel waste.

I am fully aware of the fact that the OPG proposal states that nuclear fuel waste would not be placed in the new facility, and that the facility was not designed for such a purpose. I recall similar disclaimers back in 1980 regarding the purpose of the underground research laboratory at Lac du Bonnet, Manitoba while AECL officials were quietly stating that it would entertain requests from the municipal councils for the full scale repository. The diagrams I have seen of the Bruce facility do not look all that much different from the original AECL configurations for a full scale repository originally designed for the granite pluton rock formations. Hopefully, some objective geologists can tell us more about the possibility of subsequent modifications to such a design; e.g., emplacement of heat enchangers and container configuration and handling, etc., to accommodate irradiated nuclear fuel waste. It is one heck of a coincidence that both the creation of the NWMO and the Bruce deep geological repository proposal both occurred in the same year: 2002. Was all of this a “set-up” from the start? Was the three year NWMO exercise nothing but a smoke screen to obscure a predetermined decision to use the limestone formations at Bruce, not only for low and intermediate level waste, but as the ultimate destination for all of Canada’s irradiated nuclear fuel? Did the nuclear industry assume that it would be relatively easy to convince the public in the Bruce region to accept a spent fuel waste extension or addition to the low and intermediate level underground repository at some later date? I am certainly not alone in my suspicions and musings over the potential use of the Bruce nuclear complex for the ultimate disposition of reactor fuel waste. Michael Keegan, chairman of the Coalition for a Nuclear Free Great Lakes, said he feared the facility wouldn’t always be limited to low- or intermediate-level waste. ‘‘I think this is the camel’s nose under the tent,’’ said Keegan, of Monroe. ‘‘Once they get this deed done, look for the high-level waste.’’ Kincardine’s mayor Larry Kraemer denied reports that he advocates storing irradiated fuel wastes in his municipality. But he did not rule out the possibility when he said that “...hosting a nuclear waste storage site needs public information and public approval - and is not a decision he can make unilaterally.” ---------------------------------------------------------------------------------------------------And so, another chapter of the Great Canadian Nuclear Waste Saga is unfolding. Another environmental assessment is underway. Although this fourth volume of the Great Canadian Nuclear Waste Saga ends here, it is open ended. My personal account will continue and I plan to update this web site as long as I am able. Stay tuned, Walt Robbins April, 2008