My response to Norm Rubin, also appearing in the newsgroup run by the Peace and Environment Resource Centre (Ottawa).

April 2, 1998

Norm Rubin ( writes:

> Following is a letter to the editor by AECL CRNL staff person Jeremy
> Whitlock, about the HLW/FEARO report, released 98/03/13. For those
> unfamiliar with Jeremy, he's a Ph.D. physicist who works mainly on
> reactor-control issues (as I recall) [...]

Thanks for the introduction ("reactor-physics issues" actually). For those unfamiliar with Norm, he's an M.A. professional anti-nuclear staff member for Energy Probe. We both call ourselves "nuclear researchers".

> [summary of EA Panel's mandate, and findings, deleted]
> Moreover, it did NOT pass the "Is it SAFE?" test; it flunked -- with
> 50%. That last point was generally missed, but Jeremy understood it --
> and hated it -- when he wrote this letter.

For those who are following this discussion closely, this is my case in point. The nuclear waste technology has "flunked" the safety test, "with 50%", as Norm eloquently puts it. In my previous postings (and in my letter-to-the-editor which Norm quotes) I explain how the technology was found to be sound from a technical point of view, but because the panel reworked the concept of "safe" to include public perception, it -- and Energy Probe -- are able to make the above comments.

> (Incidentally, he pretends
> NOT to understand it AT ALL in the body of his "FAQ" on the subject:
> "The report concluded that the plan for Deep Geological Disposal is
> technically sound, and that nuclear waste would be safely isolated from
> the biosphere, but that it remains a socially unacceptable plan in
> Canada. The report makes several recommendations, including the creation
> of an independent agency to oversee the range of activities leading to
> implementation. The scope will include complete public participation in
> the process." I've searched the report electronically, to see if it
> really says "that nuclear waste would be safely isolated from the
> biosphere". The report never uses the phrase "safely isolated", and none
> of the appearances of the phrase "the biosphere" gives much support to
> the claim -- but that's Jeremy, AECL, etc., for you!)

No Norm, that's called "summarizing the findings". The panel concluded:

"From a technical perspective, safety of the AECL concept has been on balance adequately demonstrated for a conceptual stage of development."

And in Section the panel states that their "overall technical judgement is well reflected in the position taken by the Joint Committee of the Canadian Academy of Engineering and the Royal Society of Canada", which reads:

"With safety as the prime objective, the Joint Committee considers the disposal concept developed by AECL to have good technical integrity, and to be a viable and satisfactory means of managing the accumulation of nuclear fuel waste in Canada."

I think my comments quoted above are a clear summary of this finding.

> [letter from me (J. Whitlock) deleted]
> NR's comments on the letter:
> NB that Jeremy INVERTS the Panel's discussion of SAFE and ACCEPTABLE:
> The report is very clear that "safety", judged from both perspectives,
> is ONE of SEVEN criteria for ACCEPTABILITY. Jeremy suggests that they've
> done it the other way around:
> "[...] the inclusion of this acceptability, by the panel, within the
> definition of "safety".

This semantic mess is not my doing. It is the panel that first declares its mandate of determining SAFETY and ACCEPTABILITY, as two distinct (but related) concepts, and then later merges the two within a single definition of safety:

"Safety must be viewed from two complementary perspectives: technical and social"

...which, of course, is the crux of my criticism.

> He also (intentionally) misunderstands the decision that the Concept is
> NOT SAFE from the social perspective, as follows:
> "The more legally-minded [anti-nukes] have invoked our Charter of
> Human Rights, claiming that radiation dose, no matter how
> insignificant, and regardless of the direct benefits (e.g. clean
> electricity, cancer therapy), should be banned if an individual
> chooses not to be exposed to it, as a matter of personal rights. "
> That "claim" is one I'd admit I'd make, though it's NOT based on the
> Charter, and it's NOT what led the Panel to conclude that the Concept is
> NOT SAFE from the social perspective! I don't think anything like this
> "claim" came up in any of the seven criteria for safety.

This is a misunderstanding of my letter to the editor. In that particular part of the letter, I am providing background to explain why "the position of the EA panel is no fluke." To wit, I state that "for years the more astute anti-nuclear activists [yes, I refer to Norm, among others], having recognized the low risk of nuclear power's operations, have strategically stressed the social factor...", and then the above quoted section follows. The section is not referring to more recent panel presentations, nor the recent panel report. Unlike Norm, I will refrain from calling this misunderstanding "intentional".

> But the "best" part of the letter is surely this:
> "The effect on human and environmental health, now and into
> the future, is a matter of scientific determination. How we may feel
> about those findings is equally important, but another chapter
> altogether."
> To which it's hard to say more than "Wow!" -- but I'll force myself: The
> Panel, like many of us, was pretty clear that all effects "into the
> future" we're talking about -- 100s of 1000s of years into the future --
> is NOT, at least at present, "a matter of scientific determination."
> That's like, kind of, the whole point, eh?

That certainly is the point of the panel's conclusions, yes. Eh.

> And that's why the
> determination comes down to a dispute between "I don't trust the
> forecast, forecaster, etc." and "We've followed [today's] Best
> Professional Practices, and that's the best we can do, so let's drill
> the hole already!"

I agree that the dispute is a matter of trust -- also perception, public credibility, fear, understanding. I've already stated my support for increased public involvement.

But the issue here -- the issue that started this -- is safety. The public thinks air travel is more dangerous than automobile travel. That's perception. Reality -- the safety issue -- asserts that the opposite is true.

In the same vein, the "social" aspects of safety, as outlined by the panel, include things like the average person on the street worrying more about the consequences of a severe catastrophe, than about the low probability (and in most cases, low risk -- since risk = probability X consequence). Sorry, there are many valid names for that, starting with "perception", and there are many highly important socio-economic and democratic issues that stem from that, but it DOESN'T belong in the definition of SAFETY. Especially when the panel establishes at the outset its mandate to determine "acceptability" in parallel with "safety".

The panel believes (Section that "the models [...] are sufficiently well developed to demonstrate that [AECL's] concept of deep geological disposal can be used as the basis for designing a site-specific facility that is likely to meet regulatory requirements. There is general agreement that a final conclusion would require site-specific data and performance analyses that are based on site-specific designs."

This is the basis for the "scientific determination" that I refer to. The rest -- the ACCEPTABILITY -- is another issue. Equally important (or more important), but another issue.

I accept that, for certain special interests, making it "another issue" would be counter-productive.

Jeremy Whitlock
"The Canadian Nuclear FAQ":