Thank you very much, Mayor Lapointe.
Chair Benoit, and distinguished members of the committee, thank you very much for this opportunity to speak today.
The second major concern we have is that the shipment exceeds the International Atomic Energy Agency safety standards for total amount of radioactivity allowed on a single ship. The CNSC’s February 4, 2011, decision acknowledges the shipment would exceed the safety standards by a factor of six, which is why the special arrangements that include compensatory measures are necessary.
These IAEA standards are set for a reason—to protect public health and the environment. It is the large amount of radioactive waste exceeding the safety standards on a single ship that leads directly to our next concern.
We do not believe that the environmental review was adequate to characterize the risk presented by the shipment. The risk increases as the steam generators are moved from secure storage onto trucks, transported over land to a port, unloaded on a ship, and moved through three Great Lakes, the St. Lawrence River, and a system of locks and narrow channels.
The risks to Canadian and U.S. citizens and waters are not adequately characterized, quantified, or differentiated, based on the various conditions present in open lakes, locks, flowing rivers, and channels. If there were an accident, the seriousness of the accident is not adequately quantified, except that an assumption—a very rosy assumption of 1% of the radioactive waste from one of the 16 generators—is made.
The next step in assessing the risk is to determine what happens to the released material. The review essentially concludes that there is so much water in the lakes, rivers, and channels that the problem can be diluted away. Our review indicates that a release as the result of an accident could exceed drinking water standards in Canada. Places with the smallest volume of water are the most vulnerable.
Our fourth concern is that the shipment sets a precedent that could lead to many more shipments. This shipment is not routine. To our knowledge, no shipment of this large a number of nuclear steam generators containing radioactive waste has ever occurred on the Great Lakes or the St. Lawrence. Yes, there are shipments of other hazardous materials, but those are beyond the scope of this matter.
With Bruce Power alone having 64 nuclear steam generators that may be shipped, and with the amount of additional radioactive waste from nuclear plants along the Great Lakes, the potential for many more shipments is very real. This shipment certainly should be viewed as precedent-setting.
To address the concerns we have raised, we recommend that a thorough, rigorous, comprehensive environmental review be performed of the entire proposed shipment, and be subjected to full public scrutiny and review. If that risk is above levels acceptable under Canadian law and policy, either the shipment should not be made or additional measures should be required to reduce the risks to acceptable levels.
Thank you very much again for this opportunity to speak.