Dr. N. Rubin
Public Hearing
June 20, 1996

DR. RUBIN: My name is Norman Rubin, I am representing Energy Probe. I will not be going through my written submissions, which are still the written submissions made in earlier phases which covered both technical and generic issues.

My first question is, on what basis do we now believe it might be sensible to stop the regulatory modelling assessment at ten to the fourth, or 10,000 years as AECB designed some nine years ago in the R-104 Regulatory document, and as we have been reminded so often by, among others, AECL.

I have on the overhead slide what I believe are the relevant quotes from R-104 justifying the cut-off of quantitative modelling assessment at ten to the fourth years.

My reading of these passages are that they are dominated by an understanding that uncertainties will increase as the period of prediction increases. I can paraphrase this by saying that there was a general concern at the time of R-104, and I believe in C-104 before it, that any attempt to predict what will happen between 10,000 years in the future and a million years in the future would be so mathematically flaky, that no serious weight should be given to it.

R-104, as you may have noticed on the first slide, does refer to justification of the cut-off also from two other factors; the characteristics of radioactive waste, and the options for their disposal.

The quote is:
“Taking into account the characteristics of radioactive wastes, the options for their disposal, and the uncertainties in long-term predictions, it is considered — (by which of course they mean AECB considers in its wisdom) — that 10,000 years is a reasonable maximum period for assessments of individual risk.”

I might comment in passing, I can certainly understand why it’s appropriate for a regulatory authority to designate and stipulate a minimum assessment period, it is less clear to me, even in principle, why a regulator might want to specify a maximum assessment period.

But that said, in my view R-104 does not explain how either the characteristics of radioactive wastes, which of course include materials that will be around for tens of millions of years, or the options for their disposal, which are somewhat open and under discussion, contribute to the choice of 10,000 years or support it.

They do indicate, as the quotes indicate, some justification for thinking that increasing uncertainties in long-term predictions would justify such a cut-off.

In this hearing I believe we have evidence that AECL’s model, at least of the post-closure assessment of the reference case in the EIS, finds no such increasing uncertainties in long-term predictions. In fact, my understanding of an exchange I had with Dr. Goodwin and what he said before our exchange is, from his graph from their model runs, the uncertainty generated by the model actually decreases, the upper 95 percent and the lower 95 percent converge as one approaches a million years.

Well, this we are told is a flexible and iterative process. It seems that AECB may have limited the regulatory scrutiny of model output to 10,000 years for reasons that are not valid.

Further, I have indicated here that the AECB’s decision was made at a time when public input was not considered as essential as it now, when the public was seen as a vessel for wisdom that came from experts. We’ve learned a lot since then, the AECB has learned something since then, and the panel, in brief, which is having a far more broad based and participatory and wisdom-seeking process than the AECB had, should not hesitate for a moment to impose its wisdom, that is your wisdom — hopefully our wisdom — on the AECB and recommend very clearly what the limits, if any, of regulatory scrutiny should be into the future. And I would suggest, and have suggested here, that the concept and any future planned repository should be shown to meet the panel’s criteria for safety and acceptability, not necessarily AECB’s, for either as long as the wastes remain hazardous, or at least for as long as we expect the hazardous releases to increase.

I want to deal next briefly with an issue that has troubled me throughout this process, and that is the issue of flexibility and responsiveness.

AECL assures us that they plan to be both flexible and responsive, and a number of reviewers have indicated what a good thing it is for an implementing organization, and indeed a research organization, to be both flexible and responsive.

Ironically, a number of other reviewers, and perhaps even some of the same reviewers, have complained bitterly about the May 10th submission from AECL suggesting that it was neither flexible nor responsive, and I would support a number of those comments.

And I would suggest that one of several issues that perhaps can show this problem is the issue of exclusion criteria. And AECL, I believe ironically, has justified its general refusal to set exclusion criteria on the basis that it would be good for everybody for the implementing organization to maintain flexibility, and I say that that’s ironic because I believe the refusal to do so after so many parties from so many parts of this process, including the panel and its guidelines, have urged AECL to specify exclusion criteria, shows a lack of flexibility.

And of course we can discuss whether it is in the public interest for somebody in a great position of authority to be flexible or not, and that is in the eyes of the beholder, and it certainly depends on whether you think that flexibility is going to lead to responsiveness. If that flexibility is the flexibility of a despot, to put it bluntly, since despots usually have great flexibility, they just don’t use it in responsiveness, that is bad flexibility, and we are hoping for some other kind of flexibility.

So I have done a job here of taking a page out of the SRG’s book and I have concluded that, in principle — underlined “in principle” — giving an implementing organization flexibility to respond to future circumstances as it deems appropriate could lead — “could” underlined — to a better handling of waste and increased empowerment of a potential host community. It could also easily do the opposite, by making it easier for an implementing organization to maintain its original plans, site, models, or ideas despite indications that they are inadequate or second-best.

In the circumstances, we doubt that unfettered flexibility will be in the public interest. Please, restrict the implementing organization’s flexibility.

I have also been troubled by many comments that have been made in this process, both in writing and orally, suggesting that people know where the burden of proof lies in the process. And I believe we have heard a range of statements that cover the gambit from A to Z, and I have described A to Z as “A” being; the concept is innocent until proved guilty, safe until proved unsafe; or, on the other hand, the concept must be clearly proved to be safe and acceptable beyond some reasonable level of doubt.

And I would suggest that many reviewers, in separating their criticisms of the reference case study, and after telling us that they don’t believe that that reference case study has been proved safe, then make a distinction and say, “Aha, the concept, on the other hand, seems hunky-dory,” have applied an extremely weak burden of proof on the proponent of the concept, innocent until prove guilty, and I believe I can paraphrase that — or perhaps this is unfair — but in my view the burden of proof could be characterized as saying that a safe and acceptable repository might be built using this concept, it’s conceivable that something good could come out of this.

Another way of saying it is, that the EIS doesn’t rule out the possibility of success. I would maintain that that is clearly an inadequate test of acceptability or safety for this panel; we must demand some level of proof that what has been done will lead to success and not failure.

A concept we talked about a great deal in Phase I and that has sometimes vanished in Phase II is prudence, and I would like to give my view of what it is that brings me here and what I believe must motivate us all. There is enough nasty stuff that we’re planning some day maybe to put down a hole, that it could be very bad if it doesn’t stay more or less where it’s put for quite a long time. In other words, what we are after here is disaster avoidance, or prudence.

I compare that exercise to the exercise of buying insurance or making an emergency response plan. The object is not to forecast the most likely outcomes, or to maximum society’s mathematical expectation, or to satisfy linear cost benefit analysis. Indeed, good insurance policies and good emergency response plans typically fail those tests. Those that pass those tests are generally not as useful as those that fail, that fail the job of insurance or the job of emergency response; in other words, the job of avoiding nasty outcomes. It’s the consequences. “Stupid” as an earlier speaker said.

There are key research gaps which must be filled if we are going to do a good job at disaster avoidance. One is, we must study failures. And I have noted a number of times in questions there has been a systematic lack of study of failures; that includes geological containment failures. We must know where the ore bodies have leached out, not just where the successes have been. This isn’t a job of pointing to somewhere where God succeeded and then claiming success. I don’t want to be anywhere near a repository that was designed by an optimist.

We must understand failed engineered systems; most of which were proved safe before they failed. I need not the list the numbers of them.

And finally, we must understand institutional failures that created the failed engineered systems.

I have made these slides available. Uncertainty in this field is always bad, never neutral. You have heard it being described as “neutral” a few times. And irreversibility and lack of monitoring are generally scary in disaster avoidance.

Finally the issue of timing, which I believe is one of the cruxes here, because those of us who want to see storage for a while — we’re not totally sure how long, whether we mean forever or whether we mean a hundred years or just for now — and those who want to throw it in the ground as fast as possible can be said to differ really only in timing, and that therefore turns out to be an extremely crucial decision.

Nonetheless, we haven’t seen any attempt to optimize that decision. Here are some inputs to that optimization:

The risks of monitored retrieval storage are not zero. We are probably all glad those who first made the wastes did not feel the responsibility to dispose of them as fast as possible.

We have brought some important information in the last seventeen years for half a billion dollars; some of that information has come at the last minute, some of it still hasn’t come in. And we’ve heard reference to a number of “emerging fields.” I list a number that have been acknowledged in the emerging fields.

And then I bring myself to two final points still under this optimization. One is, in the real world, institutions building multi-billion dollar facilities don’t change their mind. Focusing on whether it’s physically possible to dig the stuff out of the vault after you have been putting it in for fifty years, as far as I’m concerned, shows a misunderstanding of how things work. That’s why we have Darlington.

Even the choice of repository site, once made, must be viewed as at least semi-irreversible; in principle reversible, in reality heroically impossible to reverse.

And finally I just point out that AECL itself, another branch of AECL at Chalk River now has designed and is seeking regulatory approval from the AECB for what they call “IRUS”, the Intrusion Resistant Underground Structure which AECB describes in a two-week old document as “a near-surface disposal facility for radioactive wastes with hazardous lifetimes of 500 years or less.” I am not suggesting that we are dealing with wastes that are hazardous for 500 years or less, but I am suggesting that if there is a feasible technology that could solve some of the surface storage problems for up to 500 years while we make sure we’ve done first things first, it should be on the table and this panel should have those documents before it to see how attractive it is, and whether that technology can be used near reactor sites for example.

Thank you.

THE CHAIRMAN: Thank you, Mr. Rubin.

Questions first from the panel for Mr. Rubin? Dougal McCreath.

DR. McCREATH: Thank you, Mr. Rubin. You notice I did not say “Dr. Rubin.” I may be slow to learn, but I get there.

I just wanted to touch on one point to be sure that you and I have read the same thing from previous presentations by the proponent. You noted that their model shows decreasing uncertainty at long enough time periods, a million years or beyond, curves converge.

I thought that what I heard from that presentation is that that was driven by the fact that in long enough time periods all the canisters fail so there is a release of inventory, so there is no longer uncertainty about how much inventory is released, all of it is released in long enough time frames.

I did not hear that there was increasing certainty about all the other elements of the model; how many people live there, what are the pathways, what happens to glaciation, climate, et cetera. Is that a fair observation?

DR. RUBIN: The regulatory criteria which AECL has followed, of course, paid no attention to how many people live there in terms of that has … I mean, the difference between three and four people sucking out of the well matters, but the number of people who live in the general area basically does not affect them because they are calculating only doses to the critical group.

But what I was talking about was the final output of the model in terms of dose to the average member of the critical group, and that was the context in which the discussion happened. So I believe that while there is certainty about the release from the first barrier or two, and you’re right about that, it is through the entire multi-barrier system and out to the critical group that that line appeared, that Dr. Goodwin and I described, where the uncertainties converge, so it incorporates both the certainty that the zirconium and the titanium will have failed, but also, as I believe I pointed out then, something like 99.98 percent of the waste still hasn’t reached the critical group, or still hasn’t reached the biosphere.

DR. McCREATH: Well, help me with this. If we currently have a lot of uncertainty about many of the processes and connections in that model today, why would running that model for a million or a billion years increase our certainly in those processes and connections?

DR. RUBIN: Well, perhaps I’m being disingenuous here. I still have trouble believing the answer that AECL gave me. All I’m saying is, they can’t have it both ways; either we’re in cloud cuckoo land in claiming to know anything about the future, 50,000 or 100,000 or 500,000 years from now, as AECB feared we would be, and as a result told licensees not to analyze this, or not to think of it as a regulatory criterion, or we do know what’s going to happen in the far future and therefore might as well optimize it, might as well try to do as little harm as possible. I haven’t totally reconciled those two opposing views.

I mean, I would have intuitively expected a realistic model to have diverging uncertainties as we get farther in the future. Wherever I’ve seen models before that have converging uncertainties in the future, and I think specifically of Ontario Hydro Load Forecast models, those models have not done well in predicting reality.

DR. McCREATH: Thank you.

THE CHAIRMAN: Any other questions from the panel? Louise Roy?

Sorry. Louis La Pierre first.

DR. LA PIERRE: Mr. Rubin, thank you for the presentation.

How confident are you that wastes could be stored on site for some time?

DR. RUBIN: Well, I must say, every time one of my friends from another NGO says “We just have to leave it at the reactors forever,” I say “Do you want to sign off for responsibility for that?” Because I don’t; I don’t want to sign off for responsibility under any of the branches of this tree, and unfortunately we all have to make a decision, including those of us who cautioned against creating these materials in the first place. We are still not absolved of responsibility to try to find the least bad out.

I can relatively easily construct scenarios, as AECL has attempted to do, in which we’ll be sorry that we’ve left it in canisters at the surface near nuclear generating stations. Serious warfare would be one; sabotage is easy; total collapse of society.

I believe, and I think we’re back into Phase I where many of the important decisions are really going to be made, I believe that the progress that has been going on has been fast enough, and that the cloud of doubt and uncertainty and ignorance that still surrounds the performance of this repository over the next million years is so great, that the gains that we are sure to get in the next hundred years or thereabouts, in my mind, outweigh the acknowledged risks of putting this where we can keep our eyes on it, and I’m open to compromise solutions, for example, following the lines of shallow geological burial so that perhaps aerial bombardment, or casual intrusion, or stick-em-up, give me your spent fuel, you know, certain scenarios become incredible that might have to be considered credible if they just sit in the same kinds of storage canisters that some of the wastes are already in.

THE CHAIRMAN: Louise Roy.

MS. ROY: Let my try to see if I understand your reasoning, Mr. Rubin. Am I correct in saying that you are assuming that we will someday to go to disposal … let me just continue. Then what you’re saying is that we should now, in the meantime, try to optimize the decision of the best timing to go to disposal, and then at least compare the risk of keeping the waste at the surface in or near underground close to the surface facility that could be quite safe for a certain number of years while we are pursuing research to make sure that when we will go to disposal, or — well, this I’m not sure — if we go to disposal, we will maximize our chance of having a real safe facility that will be able to keep the waste there for many, many, many, many, many years? Am I right?

DR. RUBIN: I think you are exactly right in summarizing the presentation I made today. It makes me nervous that … I mean, your first statement makes me realize that I gave a rather incomplete presentation.

One of the things we might learn over the next hundred years is something better than deep geological disposal. Transmutation .. I mean, the whole category of imponderables … I mean, there are imponderables on both sides of the technological question. We may discover bad things about deep geological disposal. Fleischman and Ponds(phoen) may come up with a magic disposal method that works; the inventors of cold fusion, that is.

I don’t know what information we will have available a hundred years from now. If I did, I would probably be a much better investor than I am. But I believe that it is counter-intuitive … the burden of proof is on anybody who says that the historical trends are suddenly going to reverse and we are going to know less, and I think also the burden of proof is on anybody who says that we can, in the near term, find a site and poise the drill bit over the mark on the ground and still maintain complete flexibility to change our mind. We can drill the hole, excavate, put the … I mean, there have been a number of suggestions from intelligent people here suggesting that we should do all of the characterization of the repository, excavate it, fill it, perhaps even buffer it and backfill it, and then wait and be flexible.

I don’t consider that realistic, because I don’t think anybody will take advantage of that flexibility in the real world.

MS. ROY: Okay. Then could you summarize what, in your views, are the best steps or the best way to go in the next future?

DR. RUBIN: Avoid irreversible steps, and those include steps that are institutionally irreversible; I think that is the heart of prudence. And I believe that means that we focus on increasing our knowledge, while not taking any steps … I don’t believe it makes sense … I’m not persuaded that it makes sense to move the wastes from the general places where they are now until we know where they’re going, and until we have confidence we know where they’re going.

I would suggest a siting moratorium, in effect, of something on the order of a handful of decades, fifty years before we start talking to communities and say “Do you want it?”

Let me hasten to add; during that time we have to find the bag with the money in it, and we have to make sure it’s full. Those criteria have not been met. That is extremely important.

But in terms of committing ourselves to a plan … I mean, I think I’m coming out exactly opposite to what the Gang of Five said earlier. As frustrated as they are that we still don’t have a site and a hole in the ground, I am relieved and fearful that we will soon have a site and a hole in the ground that will commit the thought processes, the institutions, the research, the decide and defend process, the institutional atherosclerosis, hardening of the arteries, so that no further re-examination will be possible.

Heck, what Ken Hare did, and Archie Aiken, and the other gentlemen in 1977 has, as far as I’m concerned, prevented an open look, a real look at this. I mean, that was a three-month quickie. We are now talking about starting to spend the $13 billion while staying flexible. Again I don’t think that’s in the cards.

MS. ROY: Okay. So you would pursue the generic research, if I can call it like this, while trying to, I would say, consolidate, if it’s possible, or render safer the installation that we already have on site to keep the waste there?

DR. RUBIN: Yes. I’m not sure that optimizing the monitored retrievable storage necessarily means moving it from the kinds of concrete canisters they are in at the reactor sites. I think some consideration has to be given to what you do after Bruce A shuts down, which is going to be the twinkling of an eye compared to the life of these wastes, and the other reactors will … presumably all those stations will be shut down before fifty years is up, so some thought has to be given to that. It might still be the best of those monitored options is concrete canisters. If not, shallow burial is a friendly amendment.

I leave that to you. You haven’t heard much evidence on any of that. That’s too bad. But I think that’s where wisdom and prudence lie in my mind. Thank you.

MS. ROY: Mr. Chairman, can I ask AECL if it could be possible for them to table this document Mr. Rubin referred to, the Chalk River … what’s the title?

DR. RUBIN: Well, it would be AECL’s documentation on the IRUS. I was just citing an AECB quick reference to it.

DR. DORMUTH: I think it is a very large document. I could check on its availability —

THE CHAIRMAN: Would you see if at least there is an executive summary of it, and that might be for starters to give us some idea of what was in that and what were the considerations put forward?

DR. DORMUTH: Yes, I will check on that, and I will check on the availability.

THE CHAIRMAN: Thank you. Pieter Van Vliet.

MR. Van VLIET: Thank you, Mr. Chairman.

I would like to pursue the issue of flexibility. You sort of implored the panel not to give unfettered flexibility to the implementing organization.

DR. RUBIN: Yes.

MR. Van VLIET: I might not exactly have put it that way. But is it not so that flexibility given to an implementing organization would result in better engineering, better examination of options?

For instance, the results from the Hare Report gave out a specific direction and recommendation as to where this process should go, and this was followed by AECL; the end result was that a rather limited number of choices were examined.

Doesn’t that boil down to an issue of trust of the implementing organization, or is this, on the other hand a strong desire to impose our views on the organization, how they should go in the future? I see the two opposing views in there, and if I can pursue that with you.

DR. RUBIN: Yes. I have no qualms in saying that giving me flexibility is in the public interest, and I have great qualms in saying giving the nice folks from Atomic Energy of Canada Limited great flexibility may not be in the public interest.

And yes, that is related to trust, and we could give them great flexibility in making presentation

s, in trying to import mixed oxide fuel for CANDU reactors, or fabricating the fuel in the United States, or which countries they sell reactors to. Our society has limited their flexibility in some of those areas, not so much in others. I would suggest, wherever we have limited it, their flexibility has been in the public interest, and in many of the areas where we haven’t limited their flexibility, they have not demonstrated that they have used that flexibility to be responsive to public values, needs and desires.

If there were another implementing organization in the wings that had a totally different history, not at all was Rip Van Winkle that has just woken up after forty years of sleep, perhaps that would be a solution. In Phase II, despite Ken Dormuth’s frequent protestations that AECL is not — I forget exactly how he phrases it, maybe he can help me — but is not … he didn’t say “in the running”, but, you know, hasn’t put itself forward, I believe he said, as the implementing organization, I haven’t seen much discussion about alternative implementing organizations, and I’ve heard lots of people say what a wonderful thing it is we have assembled this team, and this knowledge base, and these computers, and this facility, and what a crying shame it would be if we lost it. So the Phase II momentum, as I stick my finger up in the wind, would suggest that you’re not going to have much documentation or much thought given to anybody other than AECL, and yes, their flexibility worries me just because I don’t see a track record that suggests that they used their flexibility to answer my questions.

MR. Van VLIET: So your conclusions are based entirely on your assumption that AECL may or may not … may be the implementing organization?

DR. RUBIN: Not entirely, in the sense that whatever happens at a siting and a site selection negotiation phase, I fear is going to be a negotiation between an elephant and a mouse. And I have already cautioned the panel on the kinds of things that I think have to assured in order for that negotiation to be a negotiation and not a one-way information flow before we give you the wastes.

But if there is going to an imbalance, the implementing organization is going to have a mandate to implement. Whoever it is, if they don’t drill the hole, if their mandate is to drill the hole, they will have failed. So the pressures on that organization are going to be to get to “yes”, and under those circumstances … and a number of technical reviewers have commented as well, including the previous speaker, saying that “We can do whatever we want. We’ll find a good site. Okay, we got a bad site; we’ll compensate. Okay, the container isn’t going to last; we can adjust.” You know, “We can move people away from the discharge area.” I mean, there is always ways of justifying the status quo in a probabilistic kind of argument; we’ve seen this in reactor safety. Those usually show up as alternatives to actually making the thing safer, or actually fixing the weakest link. And I think whoever the implementing organization is going to be, you have to be afraid of that kind of technical approach that we see in safety licensing. It’s a natural response.

It’s cheaper to argue that what you’ve already done is safe enough than it is to improve its safety; that’s an economic fact of life.

THE CHAIRMAN: A final question, I believe, from the panel. Denis Brown.

DR. D. BROWN: Mr. Rubin, you compared the whole exercise, including building the repository, to taking out a good insurance policy, I believe.

Well, I would just suggest to you that if you have a need for a good insurance policy, it is not a good idea to delay taking it out for a hundred years, or even several tens of decades just in case a better insurance company is available at the end of the road.

DR. RUBIN: Yes, I appreciate that. As I re-read the slides, had I still been at my keyboard, I would have struck the parenthesis; it jumped off the page at me, but it was already printed, and I won’t tell you what hour of last night it was.

And, I mean, ultimately the choice of a repository, if we choose to site a repository, must be done on these prudence, insurance-buying, contingency plan bases. Whether moving from monitored retrievable storage to a repository is comparable to buying an insurance policy or not, depends on whether it decreases the worst outcome or decreases our risk, and that’s precisely where this timing and the potential for alternatives and more alternatives fifty years from now comes into play, and that’s where I would have the optimization.

DR. D. BROWN: Thank you.

THE CHAIRMAN: Before I open to any further questions from any quarter, I would like to remind all present of two facts.

One, there are still on the schedule for this afternoon two AECL responses, and we have been urging AECL to make responses to things which we have raised earlier and could not get earlier responses to. I am told that each of those is fairly detailed, a fifteen to twenty-minute response, something of that sort. That, therefore, will take time.

I also, if I may, would remind you that a lot of people have been urging this panel to give serious consideration to how it should proceed in the immediate future.

The panel would be delighted to do that if it were given any time in which to do it. And, quite frankly, I’m afraid, given our age and the attention which we are all giving to the hearings as they go on, our chances of starting to have serious discussion on that after five-thirty or six o’clock in the evening on a day which has started at nine o’clock are not very promising.

We had been hoping to be starting an initial discussion of that question, as to where we go from here, this afternoon at four o’clock, which seemed quite reasonable given the timetable we had. I see that possibility slipping away. I am not asking for sympathy, I am merely reminding you that you want us to be doing some work of our own and that requires time and energy.

Are there further questions to be put to Mr. Rubin from the panel? (Laughter)

THE CHAIRMAN: Oh, I have not found that those sort of pleas have had any importance at all; it hasn’t in the least deterred AECL or SRG or the public from putting questions, and I don’t think they will now, but I guess I wanted to get it on the record.

Yes, microphone number 2?

MS. KEIFFER: Susan Keiffer from the Canadian Geoscience Council. I think I can compromise with you by saying I would just like to make two statements, not two questions.

I would just to clarify that when we were talking about long-term monitoring yesterday, we believe that it’s necessary because of the nature of the geological systems at those time scales, and that whether or not we postpone the start of this by fifty or a hundred years, and go through this sequence where Mr. Rubin said to put it all together and sit and wait, we believe you probably have to do that anyhow, even if you gather another century’s worth of data.

And secondly, I did make some comments yesterday on institutional memories, and I would like to clarify that that had nothing to do with the issue of trust, that to date that’s how our society deals with very rare and non-intuitive events. And I think we are getting better at it in geological hazards, for example, but it really was a different issue when I was talking about institutions than these issues of trust. So I just wanted to clarify that.

THE CHAIRMAN: Now, I really must turn the questioning over to AECL in spite of those rather sad remarks which I made a few moments ago.

DR. DORMUTH: No, thank you, Mr. Chairman.

THE CHAIRMAN: Oh, dear. Now I feel guilty.

DR. RUBIN: Mr. Chairman, if I could just comment briefly on Ms. Keiffer’s … I believe the issue of long-term memory in which continuity of institutions is posited points generally in the opposite direction as this institutional inertia or hardening of the arteries that I was talking about; which is especially important the more has been invested in a specific way of looking at things or a specific plan where it just becomes difficult for an institution to change its mind.

THE CHAIRMAN: Thank you.

I don’t dare ask the question, but I don’t see anyone leaping to the microphones.

DR. RUBIN: If I could make one brief announcement?

THE CHAIRMAN: Yes.

DR. RUBIN: This really is brief. I threatened a few days ago to bring with me, for the panel, Draft 6 of the Federal Review of the dichotomies and discrepancies between the chemical cancer-prevention paradigm and approach and the regulation of radionuclides. I have brought it with me. I will give it to the Secretariat for copying. It is my copy. And again I regret that we don’t have Draft 12, but perhaps you will have the final report, perhaps not.

THE CHAIRMAN: Thank you. I would suggest that we really now break for various reasons, including a cup of tea. Would you mind very much, Mr. Shemilt, if we did that?

Have you an extremely … a one-minute question or comment, and a one-minute answer?

DR. SHEMILT: Les Shemilt, McMaster University. As Professor of Engineering and one-time Dean of Engineering, I just wanted to assure Mr. Rubin that his point with regard to the gap in research knowledge with regard to failed engineering systems and materials is not a gap in research knowledge, this is a tremendously active research area, the library shelves are filled with work in this field; certainly nothing need be held up for that. That is the essence of current engineering education.

THE CHAIRMAN: Thank you.

DR. RUBIN: I think my comment was for this panel to review. I have raised the issue several times.

THE CHAIRMAN: Thank you. A fifteen-minute break. I would like you to be back promptly at four o’clock to hear the two responses from AECL.