CCNR is a federally-incorporated not-for-profit corporation with a mandate to conduct research and education on issues of public concern related to nuclear power, nuclear weapons, uranium mining, radioactive
materials, and alternative non-nuclear options.  CCNR has been active on nuclear issues in Canada since its establishment in Montreal in 1975.  On behalf of the Board of Directors, CCNR submits the following comments
on the proposed restart of Bruce Nuclear Plant "A" Units 3 and 4.

The CCNR maintains that the restart of the two specified nuclear reactors should not be authorized without a full Environmental Assessment Review, with public hearings and intervenor funding.  We urge the CNSC to recommend this course of action to the federal government.

The CNSC has already determined that Bruce Power's proposal to restart Bruce "A" will require an amendment to the Bruce "A" operating licence.  This amendment, in turn, triggers the need for an Environmental
Assessment (EA) under the Canadian Environmental Assessment Act (CEAA). Previously, the CNSC has stated that the appropriate level of environmental assessment is the screening level. 

The CCNR urges the Nuclear Safety Commission to reconsider their position vis-à-vis the proposed Bruce "A" restart, and to recommend that a full-scope environmental assessment process with full public hearings would be more appropriate under the existing circumstances.  Those circumstances include the uncertain financial position of British Energy, the radically altered perception of security risks in the aftermath of the 9/11 disaster of last year, the strategic location of the Bruce Nuclear Complex on one of the most spectacular fresh-water systems in the world, the upsurge in expressions of legitimate concern by residents on both sides of the border, the lack of a full probabilistic risk analysis for the Bruce "A" reactors, the decision not to the retube the Bruce "A" reactors nor to replace their steam generators prior to restart, the lack of a complete and detailed plan for the ultimate dismantlement of the reactor structures, and the inherent uncertainties in re-starting nuclear reactors that have
experienced premature aging of materials and components and operating those reactor for many more years.

The Commission need not be reminded that once these reactors have been restarted, radiation levels will not return to their present low levels for a very long time into the future.  If, indeed, additional work on the core or the steam generators or the safety systems may be required in the next five or ten years -- work which may go well beyond the plans now put forward by Bruce Power -- or if certain safety-related design changes could have been included in the Bruce "A" configuration but have not yet been properly identified, it would be a shame to restart the reactors without attending to such important matters first. 

(The history of CANDU regulation in Canada has revealed some notable examples of inadequate designs going undetected for decades -- such as the serious inadequacies in all CANDU Emergency Core Cooling Systems
discovered in the late 1970's. and the unsuspected danger of steam lines rupturing and potentially killing all control room staff in CANDU 6 designs -- a defect that was discovered only in the 1990's.)

CCNR is well aware of the limited resources that are available to the CNSC in order to fulfill its mandate of protecting the public and the workers from unintended radiation releases in the event of a serious
reactor malfunction.  In a submission to the Treasury Board of Canada dated October 16, 1989, by the Atomic Energy Control Board -- the predecessor agency of the CNSC -- we read:

   2.  An outline of the deficiencies that exist in the regulation of nuclear reactors, radioisotopes, and several other    specific areas is presented. (...)

   3.  The conclusion of this analysis is that the Atomic Energy Control Board (AECB), the federal agency                responsible for nuclear regulation since  1946  under the Atomic Energy Control Act, does not have the                resources to regulate major sections of the nuclear industry with the thoroughness and effectiveness that is            needed to ensure industry is meeting its safety obligations, and that the Canadian public would expect. (...)

   6.  When modern nuclear power plants were being designed in Canada two decades ago, their complexity and    potential for catastrophic consequences were recognized. The plants were designed to high standards, and          special safety systems were incorporated to prevent or reduce the consequences of malfunctions. Reactor            designers and owners adopted a relatively simple process for evaluating plant safety. "Worst credible" accident    scenarios were investigated to ensure that their consequences would be acceptably low. It was then assumed        that the consequences of less severe but more likely accidents would be acceptable.

   Since that time, experience in Canada and the rest of the world has demonstrated that this approach to safety is    too simplistic. It is recognized now that, through the combination of a series of comparatively common failures      which, on their own, are of little consequence, accidents can develop in a myriad of ways (as demonstrated          most vividly at Three Mile Island and Chernobyl). This makes the calculation of consequences of potential            accidents very difficult, research to simulate accident consequences is often incomplete, and, perhaps most          significant, human errors are an unquantifiable element.

   As a result, there is a legacy of unresolved safety issues that should be addressed further. (...)

   7.  AECB's review of safety has also been too simplistic. Spot checks of a fairly small number of the key areas    were thought to be sufficient. These spot checks have uncovered enough safety problems to demonstrate that      more thorough review is essential, since the risk posed by nuclear power plants may be higher than once              believed.

   8.  The size and complexity of the task of ensuring and demonstrating the safety of nuclear power plants has not
   increased suddenly -- it has been building up for the last decade. It has led reactor designers, operators and
   regulators around the world to demand far more thorough analyses which are far more complex, and a far more
   detailed understanding of how a plant can malfunction, than was required in the past.

   The task is overwhelming the AECB. It does not have the resources to analyze and understand this increased      level of knowledge and information. (...)

   10.  Reports of significant events that have occurred in Canadian reactors show that human error plays a part in
   more than  50  percent of all such events. Both the nature and the probability of human error is difficult to              quantify, and hence the probability of serious accidents which are a combination of system failure and incorrect    human response is difficult to predict. To understand the contributions of human error to accidents, and ensure      they are factored into plant design and operators' training so that accidents like Three Mile Island can be              avoided, cannot be done with current resources.

   11.  The consequences of a severe accident can be very high. The accident at Chernobyl has cost the Soviet        economy about  $ 16  billion including replacement power costs. The accident has generated anti-nuclear            sentiment in the USSR and throughout the world. Three Mile Island has cost the USA  $ 4.8  billion even            though the Three Mile Island accident had essentially no radiation impact on the public. The accident was a          major contributor to the public distrust of nuclear power in the USA.

   12.  The years of successful accident-free operation which are a hallmark of the Canadian nuclear program are    not, by themselves, proof of adequate safety. Canada has amassed about  170  years of operation of large          reactors, compared with  480  years in the US and  270  years in the USSR at the time of Three Mile Island       (1979) and Chernobyl (1986) respectively. The likelihood of serious accidents cannot be judged from statistics    such as these, and CANDU plants cannot be said to be either more or less safe than other types. (...)

   The AECB has concluded that operation of the Bruce A station during 1987 was only marginally satisfactory        and that significant improvements were necessary. Ontario Hydro has accepted this conclusion and is now            increasing operating and maintenance staff levels at all of its plants.

   These observations clearly indicate that a strong regulatory agency is essential to ensure industry meets its
   obligations to operate safely.

   14.  Despite the problems discussed in this document the AECB still concludes that nuclear power plants are        acceptably safe. However "safe" does not mean "risk-free". It means that, on balance, the benefits of                    generating electricity with nuclear power plants outweigh the risks. This is a judgment by the AECB based on      its technical evaluations and inspections.

   Given the potential consequences of severe accidents everything possible should be done in order to increase       the confidence in the AECB's judgment by improving the depth and breadth of its technical evaluations and           inspections. The AECB considers that the scope and depth of the reviews on which it makes its judgments           currently is insufficient. The resources needed to ensure that licensees are taking all possible measures to               prevent accidents and for the AECB to take enforcement action when they do not are also currently                     insufficient.

The CCNR believes that both the CNSC and the Canadian public would benefit by having a full environmental assessment of the restart of the Bruce "A" reactors.  It is entirely possible that public questioning of the proponent's plans and the regulator's interventions may bring to light hitherto under-appreciated safety problems.  It is also possible that the limitations in the resources available to the CNSC may be identified and subsequently addressed. 

In any event, it is seems to be certainly the case that this will be the last opportunity for a very long time for the Canadian public to have an opportunity to participate in the decision-making process regarding nuclear power plant licensing.  The credibility of the CNSC and of the nuclear regulatory process in Canada has suffered from its chronic lack of transparency.  The fact that Ontario Hydro chose to shut down seven of its reactors, not because of regulatory intervention, but because of recommendations made by an American consulting firm that was brought in for the purpose, does not stimulate a sense of confidence in the Canadian regulatory process.  The fact that one of the Bruce B reactors was shut down last summer for an extended period because of an accident
that perforated a pressure tube and a calandria tube, and was apparently not reported to the Ontario government, is just one of a myriad examples that serve to undermine the public's confidence. 

Given the potential consequences of a catastrophic or near-catastrophic accident at the Bruce A nuclear power plant, surely there is ample reason to recommend a full environmental assessment.  This is especially the case when the planned actions prior to restart include work on "the nuclear steam supply system; the turbine generator system; the electric power systems; the nuclear safety systems; ancillary systems; facilities and systems for maintaining the security of the site (excluding prescribed [sic] information); and all on-site maintenance and materials and waste handling activities associated with the Bruce A licence." [Executive Summary, EA Study Report]

Several of these systems could result in serious environmental consequences if they were to malfunction at a crucial moment.

Again, Bruce Power "plans to implement a comprehensive program of improvements ... in safety, environmental, plant condition and other performance areas."  Are these not worthy of full public review, when it is the public that is asked to accept whatever off-site risks there may be? 

As for the "existing environmental conditions or baseline" (Section 4.0 of the EA Study Report) ,  are the existing baseline data really sufficient to determine at some future date what the effects of the restart have actually been?  Without proper baseline data, determining subsequent environmental performance may be next to impossible.  Again, the public has an absolute right to participate in such determinations.

Section 5.0 purportedly evaluates "nuclear accident scenarios, including major accidents involving severe damage to the core ....  The evaluation demonstrated that for a wide range of postulated accidents, the resulting radiation doses were within applicable regulatory limits."  Has the public no right to question the assumptions and limitations involved in such proponent-conducted evaluations?  Did any of the accident scenarios involve a breakage of feeder pipes or headers at both ends of the core simultaneously, thereby impeding the flow of emergency coolant through the core?  Such an accident scenario could potentially be precipitated by earthquake activity during refuelling, for example.  Did any of the accident scenarios involve simultaneous loss of on-site
and off-site power?  Did any of the accident scenarios involve simultaneous ruptures of pressure tubes and the calandria vessel?  The desirability of public scrutiny involving such serious accident scenarios should, it seems to CCNR, be  unquestioned.

We note that in the Executive Summary of the EA Study Report, listed under "Other likely adverse effects for which mitigation measures are not identified or practicable", is the "effect on human health from a
severe nuclear accident."  The public, which must bear these risks if the restart is authorized, must have the right to a full public hearing.  The costs of such a hearing are minute in comparison with the subsidies that are given by the government to promote nuclear power and to deal with its adverse side-effects -- viz. the several hundred millions of dollars accorded to AECL to investigate the permanent unmonitored geological storage of high-level radioactive wastes produced by reactors very much like those that Bruce Power wishes to restart.

Finally, in the section entitled "Effects of Environment on the Project", Bruce Power states that "The project provides the opportunity to avoid 100 million tonnes of carbon dioxide emissions..." without even mentioning (in this context) the cumulative tritium and carbon-14 emissions from the project as proposed, or the quantities of high level radioactive waste that will remain a public liability for countless generations into the future, nor the plutonium inventory that will remain a potential proliferation threat for tens of thousands of years into the future, nor the thousands of truckloads of radioactive rubble that will result from total dismantlement of the plant structures, much of which will remain environmentally threatening for many millennia, nor the significant quantity of other radioactive and non-radioactive wastes generated by the project.  This casual one-sidedness in describing the risks and benefits of the project does not speak well for the integrity of the environmental analysis that has been carried out by Bruce Power.

The Canadian Coalition for Nuclear Responsibility is firmly of the opinion that these nuclear power plants should not be authorized to restart, that the ultimate costs will totally dwarf any short term economic advantages, that the outdoor accumulation of high-level radioactive waste in the Bruce Dry Storage Facility will become an
increasingly attractive target for terrorists, and may even become a de facto permanent repository which could hardly be sited in a more irresponsible way, and that even the proximate costs -- especially given
the bankruptcy of British Energy -- may overshadow any perceived benefits in the near future.  We should not forget that even the mighty Ontario Hydro sank under the weight of its own nuclear debt.

The phasing out of nuclear power should be given detailed attention and analysis.  It will have to be done sooner or later anyway; elementary prudence would dictate that it be done in an orderly rather than a chaotic fashion.  This will not happen as long as those in the nuclear power industry and in the regulatory agency scrupulously avoid thinking about it.

In the meantime, the Canadian public should at least have the opportunity for a full, open decision-making process re, the proposed restart of the Bruce A reactors.  This can be expedited by holding a full-scope
environmental assessment with public hearings.

Thank you for considering these views.

On behalf of the
Canadian Coalition for Nuclear Responsibility
and its Board of Directors

Gordon Edwards, Ph.D.,
CCNR President.

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The following comments are made on behalf of Citizens for Alternatives to Chemical Contamination, a statewide Michigan environmental group dedicated to a clean environment since 1978. These comments are on the Draft
Screening Report of the proposed restart of units 3 and 4 of Bruce A nuclear reactors.

Throughout every report sent me by Bruce Power and the Canadian nuclear safety commission there was overt repetition of how you both attempted to reach stakeholders. You included every letter, every postcard, every ad in every paper to record how you reached every stakeholder!!

However, you have made no attempt to reach Michigan residents, including Native Americans living in Michigan, who share International Boundary Waters in Lake Huron, who live directly across these waters from Canada,
and who bear with Canadian residents the burden of protecting these waters not just for ourselves, but for all who live downstream and downwind of Lake Huron, all of the wild creatures, insects, plants that inhabit the
Great Lakes, and for every generation to come, since radiation and many radionuclides can affect not only health,  but can help produce birth defects and changes in DNA.

I personally have many unanswered questions, and am sure that every Michigan community, especially those lining the shores of Lake Huron, or that receive drinking water from Lake Huron, have many unanswered questions.

U.S. citizens and Native Americans and anyone who even visits Lake Huron or who lives downstream of Lake Huron have/has the right to know what is going into this Lake, and what kind of risks are being taken by the Canadian government with this Lake. I and many others believe you should hold hearings in the state of Michigan at least in Detroit and the Saginaw Bay area, Alpena and Port Huron.
 
We are also requesting to have a baseline health study done in at least a 50 kilometre radius of the reactor. This study should be of workers, of residents, especially children, and should also include farm animals. There
should be a health registry, and every attempt should be made to follow persons for their lifetimes, as cancers usually take a few decades to show.

Does Ontario have a birth defects registry? A reproductive health registry, a cancer registry? Does this registry include where people live?

The Bruce nuclear complex is considered one of the largest nuclear complexes on the face of the Earth, by the International Atomic Energy Agency. If there was a major nuclear accident there, it is VERY possible
that Lake Huron would not support fish without cancers or water that communities could drink safely. MANY Michigan municipalities take their drinking water from Lake Huron, including (but hardly limited to) Port Huron, Detroit and Flint. Fishing and tourism, would suffer a huge blow if there were a major accident that contaminated Lake Huron. Industry would also suffer greatly, as there might well be a large exodus of people, especially young people, from Michigan past a big accident.

There are not only 9 reactors there, but at the Western Waste Management Facility, on land adjacent to the Bruce reactors, are also graveyards for low-level nuclear waste and medium-level nuclear waste. There will now be the added risk of high-level nuclear waste storage, 18,000+ tons. This is all built right on the shores of Lake Huron, in the very heart of the Great Lakes!! An accident or a terrorist strike here could damage not just Lake
Huron, but give the cities of Detroit and Windsor a terrible economic blow, and could potentially cause economic and environmental damage to the entire Great Lakes watershed, potentially forever.

Why must we continue to prop up failing industries with the potential to destroy a whole region?  Nuclear accidents are unforgiving and last generation after generation. We cannot consider the terrorist risk to the Bruce reactors without looking at the whole nuclear complex there, including the large risk encompassed by the Western Waste Management Facility. Terrorist accidents were not looked at in the Screening for a possible major accident, yet a terrorist accident at the Bruce nuclear complex could have wide impact on the environment  of the Great Lakes, and especially Lake Huron.

Because Michigan residents have not had any notification of the restart of these aging reactors that were shut due to serious safety problems - and because of the large amount of highly technical material given out for us to read in less than a week in most cases -  and because most Michigan communities (especially along the Lake Huron shoreline) are at this time completely unaware of the controversial restart of these reactors - we in Michigan look to you, the Canadian Nuclear Safety Commission to grant at the very least a 30 day extension, that Michigan communities may inform themselves and so decide themselves if this is a risk they deem acceptable.

In Bruce  Power’s Study Report, there are MANY pages, where the print is so small, that it is not legible. Therefore it is impossible to even read those pages in an understandable way. This in itself should be reason to extend the comment period. Bruce Power should be required to reprint those pages, so that they are completely legible and reissue them to the public.

On September 13th, 2002, there was a hearing on the proposal of the Western Waste Management Facility being declared a nuclear installation, for the purpose of insuring under the Canadian Nuclear Liability Act. It is my
understanding that at this hearing, the Canadian Nuclear Safety Commission were asked if First Nation/Native Americans were covered under the Nuclear Liability Act, and that they did not have an immediate answer, and had to defer to another organization for a definitive answer. - This is especially insulting when it is First Nation communities who have suffered so greatly from the environmental and health devastation from uranium mining.
 
However, it is not just a nuclear accident that causes environmental damage. CANDU reactors routinely  release radionuclides into the air and water,  (many of which meet the International Joint Commission’s (IJC) definition of persistent toxin and many of which bioaccumulate in the food chain. Many also concentrate (like DDT) in the food chain. We as human beings are at the top of this food chain.   We understand in the past that there have been large accidental spills into the lake, as well as regular planned emmissions.  We are concerned about the reporting and potential consequences of these emmissions. These reactors also use huge amounts of chlorine,  a persistent toxin targeted for zero discharge in the Great Lakes biosystem by the IJC.

The reactors at Bruce send out a large plume of hot water into the Lake, reportedly 11 degrees hotter than the Lake water. However, there have been aerial photos showing the thermal plume going from the reactor all the way to Lake Erie. Once the plume enters the St. Clair River, there are other industries to contribute to this plume. However, before it reaches the St. Clair River,  is another question. How much does this thermal plume disrupt
and change biosystems, and aquatic life in Lake Huron? How does it affect our weather?  How large is this plume? Is it always there? How much greater will it be with 2 additional reactors online? Does the Lake ever freeze by the Bruce nuclear complex?

Why are not the environmental costs of mining uranium counted? (Uranium mining in the Serpent River area and uranium refining in the Blind River area have devastated the environment and the health of the people there.
Contaminated water from the Serpent River flows into Lake Huron.  Why are the environmental costs of producing uranium  fuel not counted?  Is it because First Nation peoples are expendable?

Tritium is considered a critical pollutant by Michigan’s Dept. of Environmental Quality. It is considered a persistent toxin by the IJC. Why are we not phasing out any industry that creates this persistent toxin?
Water is said to stay an average time of 22 years in Lake Huron. However, water can be evaporated, and taken up into clouds, and the rain may fall hundreds of miles away. Tritium can become part of the body, and part of a
person’s DNA, and so help to produce birth defects. Who follows each drop of water? Who keeps track of tritium, so that it doesn’t enter people’s drinking water? Who keeps the fish from drinking tritiated water or water
with cesium, or iodine. 

If krypton 85 is released (one of the noble gases), it can affect lightning in storms, as it ionizes the air, and can spread the effects of the lightning far beyond its usual range. How many lightning strikes does the
Bruce complex sustain in a year?

TRITIUM is a radionuclide with a half life of 12.5 years. It can be inhaled, ingested and absorbed. It is possible for tritiated water to go through a human body in 10-12 days, (irradiating cells as it passes through). However if the tritium becomes organically bound (O.B.T.), it may stay in the body for a year or two or longer. Babies in utero  and children are more susceptible to any radiation due to the fact that they have more growth, thus many more cells dividing at any one time and those cells may be damaged by radiation. People with lowered immune systems and older people also have more susceptibility to radiation and radioactive materials.

 Pigs fed with tritiated food themselves became tritiated, as did their offspring. The blood, heart, and kidneys of the piglets were more tritiated than the food they were fed. This is taken from M.Van Heeyes et al
"Retention in Young Pig of O.B.T. given during pregnancy and Lactation" from Radiation Protection #1-2 DOS, 16 1971 p. 123-126.

We also believe that British Energy’s financial condition must be considered in this environmental assessment, for it is very doubtful they will have funding to do the  necessary safety measures to restart these reactors. It  is highly doubtful they will monitor the environment adequately. If these aging reactors are not retubed, and an accident
occurs, it can have a major effect on the environment. By the amount of money British Power is spending to refurbish these reactors, it is apparent that they will not retube these two Bruce A reactors, even though they were built with Inconel 600, an alloy that has been shown throughout the nuclear industry worldwide to embrittle and age prematurely. To not retube these reactors, built in the 1970s, is to ask for early cracking and rupture of
the tubes.

Also, we have seen a stark picture of reactor safety being thrown out the window in the former Soviet Union, when workers at reactors were not paid for weeks at a time. This picture may become grim reality if British Energy becomes insolvent, not too-far fetched at this moment in time. Lack of funds may also affect other safety and worker issues. You may remember that British Energy was audited by the British Government a few years back and found to be cutting costs by cutting workers and gutting safety, and was endangering the health and safety of residents throughout the United Kingdom. They had to  promise not to do that here!!

But what is there to guarantee their promise to not cut safety corners in the interest of short-term gain, should British Energy fail completely financially? What is there to protect the residents of the Great Lakes? Who
will guarantee the electricity supply? Is it not smart to encourage electric conservation and the use of energy efficient appliances? Is it not smart to begin planning for sustainable energy? Which community can safely
take high level waste and take responsibility for the groundwater for virtually all time? For 20-40 years of very expensive electricity (with costs hidden as huge government subsidies), we have essentially condemned
every generation following us to watching this waste and repackaging it when it leaks, a dangerous and expensive job, that MUST be done if we and they are to protect groundwater. What a legacy for our grandchildren!!

Bruce Power’s Environmental Study Report has stated that Chernobyl had no containment. This, as we now know, and knew a few days after the Chernobyl accident, was not true. Chernobyl had state of the art containment, and James Aseltine, a U.S. Nuclear Regulatory Commissioner at the time, stated
this within a few days of the Chernobyl accident. The fact is, that any nuclear accident is unforgiving. There is, for the most part, no way to take back radiation or radiactive substances released in an accident. Any clean up that does ensue is costly, not just in terms of money, but in terms of exposure to workers involved in the clean up. How much would it cost to clean up a Great Lake? How many years before people could fish in Lake Huron? Or swim? Or drink the water? What kind of cost would it take to haul in water to irrigate farmland? Or assuage the thirst of Detroit?

If there are leaking tubes, as occurred on a regular basis before the "A" reactors were shut down, how can the estimates for releases be accurate?

There should also be an assessment of the potential environmental costs of using MOX fuel. We were told the Bruce A reactors were the safest reactors to use with MOX, and therefore the only ones considered for the use of MOX. Jean Chretien, the Canadian Prime Minister,  has stated he would like to see Russian MOX used in CANDU reactors as part of the ill-conceived Swords into Ploughshares project  that would see aged weapons plutonium, mixed with uranium oxide and used as nuclear reactor fuel, a dangerous option that would subject workers producing MOX to much higher radiation and contamination scenarios,  and would essentially make the plutonium difficult to quantify, as some can be easily lost in the processing. MOX is very desirable by terrorists, and easy for terrorists to use.

The reason you  must assess the environmental effects of using MOX in the Bruce "A" reactors, units 3 and 4, is that MOX, whether civilian or military, would be very tempting  financially to Bruce Power. As you well know, there are huge subsidies available for utilities willing to experiment with MOX. With high level nuclear waste in  storage next door, Bruce Power may well be thinking about reprocessing civilian fuel. Of course, any accident at a nuclear reactor with MOX would  be much more dangerous, and do more damage.

We, as Michigan residents in the Great Lakes Basin strongly urge the Canadian Nuclear Safety Commission to refer this project assessment to the Minister of the Environment for an Independent Review Panel Environmental
Assessment pursuant to section 25 of the Canadian Environmental Assessment Act. (CEAA).

Make no mistake. This is an issue of utmost concern to Michigan communities. Michigan residents feel strongly about the health and safety of  their children, of the Environment, and especially the health and safety of  the Great Lakes. Reopening reactors with serious aging and safety problems with an operator who is financially compromised is an experiment that Great Lakes inhabitants (especially those who live along
the shores of Lake Huron) should  not be exposed to.

We appeal to you as Nuclear Safety Commissioners to protect the health and safety of the inhabitants of the Great Lakes Basin instead of the failing health of the big corporations who only care about their bottom line - not
ours, nor the Lakes - and who have thrown safety and common sense out the window. The atomic age has made us all guinea pigs and has destroyed every vestige of democracy and fairness that exist. We appeal to you as
Commissioners to allow Michigan citizens a voice in the restart of these unsafe, aging nuclear reactors in the heart  of the Great Lakes.
 
I would hope you will consider our requests and act upon them in the interest of binational cooperation and respect for these living waters.
 
Respectfully,
Kay Cumbow
Board Member,  Citizens for Alternatives to Chemical Contamination
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The Coalition for a Nuclear Free Great Lakes respectfully submits our request to intervene and testify at the hearings regarding the restart of the Bruce Nuclear Reactors.

The Coalition strongly urges the Canadian Nuclear Safety Commission to refer this project assessment to the Minister of the environment for an Independent Review Panel Environmental Assessment pursuant to section 25 of the Canadian Environmental Assessment Act. (CEAA).  
 
The Coalition stands in protest of the inadequacy of the truncated period to review voluminous documents pertaining to the restart of Bruce Nuclear Units and the hearing process.  We request an extension of comment period of 60 days beyond  September 30, 2002.

We will be testifying to the following concerns:

The necessity to fully explore alternative power generation other than restart of the Bruce 3 & 4 units must be examined.  This examination must utilize principles of full cost accounting in assessing the cost / benefit of returning Bruce 3 & 4 to power production. 

The conservation programs conducted in the mid 90's had such great success that Ontario Hydro squelched them.  In the opinion of many, termination occurred  because these conservation efforts threaten the rational for
continued reliance on Bruce, Darlington, Pickering.   These conservation programs should be revisited. 
 
In the early 90's a call went out from Ontario Hydro to assess availability of electricity from co-generation.  response of 2,000 MW was expected.

What Ontario Hydro received in response was nearly 9,000 MW of electricity could be developed from co-generation.  These programs should be revisited and counter weighed against restart of Bruce units 3 & 4.

Because of the additional generation of Tritium and the impact on the Great Lakes Watershed.  Independent monitoring must be established which will be accessible to routine public inspection. In conjunction with radiological monitoring there is a need for baseline health studies and the monitoring of health for radiological impacts.

The Coalition is particularly concerned about the need for full retubing of these reactors.  The original engineering design called for retubing of reactors at mid life.  Which was one half of 40 years or 20 years.  These reactors are well beyond the half way point and are beyond the design basis for retubing.  I would point out that the owners of Indian Point reactor in New Your knew that there was a need to retube but deferred the overhaul until a tube ruptured in the year 2000.  For the Canadian Nuclear Safety Commission to willfully allow these plants to operate while it is known that they are in need of retubing, is in the opinion of the Coalition to be criminal action by the Canadian Nuclear Safety Commission and British Energy. 

Full exploration of the retubing / partial, and non-retubing under consideration at the Bruce Nuclear Units must be investigated thoroughly.

The potential of cascading tube failures must be addressed.  The extent to which Inconel 600 (Alloy 600) is in use at Bruce A & B must be disclosed and thoroughly examined under a full Independent Review Panel Environmental Assessment pursuant to section 25 of the Canadian Environmental Assessment Act. (CEAA).  This particular Alloy 600 has been problematic throughout the nuclear industry.  In addition,  these Nuclear Units must be scrutinized for the safety ramifications associated with aging reactors. 

Because the parent company British Energy is financially strained there will be great economic pressure to keep these plants in production and to defer the maintenance and consequently compromise public safety.  Independent oversight is essential to preclude this.  The EA screening does not provide for this. 
 
Recent history indicates that there have been major inadequacies at the Bruce nuclear power station.  In an article which appeared in The Globe and Mail (10/15/01 page A1) Environmental Reporter Martin Mittelstaedt chronicled a long list of problems at the Bruce nuclear power station.  I am submitting this article into the record in it's entirety.  Below is the text of the article:



While World Association of Nuclear Operators (WANO) reviewed the Bruce B facility.  The same level of scrutinization is warranted at Bruce A reactors.  The pretzel logic employed by WANO  "... to keep the records
secret, (WANO) asserted nuclear safety is enhanced if the public is kept in the dark about its findings because nuclear staff are more likely to be honest about mistakes if their remarks are kept confidential." is simply not acceptable.  The recent revelations of concealment of  problems at Bruce B throughout the summer (2002) does not lend itself to trust in British Energy or in the Canadian Nuclear Safety Commission.

Environmental and Economic Impacts of a worst case scenario accident at the Bruce Nuclear Units must be postulated and examined.  As a comparative, I point to the Fermi 2 nuclear power plant southeast of Windsor.  An accident at this plant according to Sandia National Labs would result in $136 billion (U.S. / 1980 $) property damage.  340,000 injuries, 13,000 cancers within one year and 8,000 immediate deaths.  This report was
commissioned by the Nuclear Regulatory Commission.  These findings are considered by the Coalition and other observers to be conservative.  The Bruce nuclear complex is at least 8 fold the potential for such an accident
scenario.

It is the perspective of the Coalition that the process thus far has inadequately identified  the communities which would be impacted from an accident at the Bruce nuclear station.  Michigan, and other U.S. states must be considered.  Drinking water for the entire basin must be considered. Twenty percent of the world's surface fresh water is jeopardized by the operation of the Bruce nuclear complex.  This in itself warrants a Full Review.

The Canadian Nuclear Safety Commission must take into consideration  principles established by the bi-national International Joint Commission calling for phase-out of persistent toxics.  The Coalition recommends adherence to these IJC recommendations cautioning the respective governments and enlisting their cooperation in the pursuit of virtual elimination of persistent toxics.

Finally, the Coalition strongly urges the Canadian Nuclear Safety Commission to refer this project assessment to the Minister of the environment for an Independent Review Panel Environmental Assessment pursuant to section 25 of the Canadian Environmental Assessment Act. (CEAA).   Under an Independent Review Panel  a full exploration of viable alternatives to the generation of electricity from Bruce nuclear units must be conducted.

I look forward to testifying on behalf of the Coalition for a Nuclear Free Great Lakes with member groups in 8 U.S. States and in 3 Canadian Provinces.  Thank you.  Please direct communication to me at mkeegan@foxberry.net

Michael J. Keegan
Chairperson
Coalition for a Nuclear Free Great Lakes
P.O. Box 331
Monroe, MI  48161