CANDU or CANDON’T: Competing values behind Canada’s nuclear sales

Duane Bratt
The Nonproliferation Review
April 1, 1998

 

Duane Bratt is a lecturer in the Department of Economics and Political Science at Mount RoyalCollege(Calgary, Alberta, Canada). He has written several articles and newspaper editorials on Canada’s nuclear policy, including “Is Business Booming? Canada’s Nuclear Reactor Export Policy,” International Journal (Summer 1996) and “The Future of CANDU Exports,” Canadian Institute of Strategic StudiesStrategic Datalink (October 1997).

States often pursue contradic­tory policies internationally. On one level, states may seek to promote a good reputation for themselves by supporting interna­tional regimes. Yet, on another level, they may also seek to pursue nar­rower, self-interested policies for the benefit of their populations or do­mestic industry, thus calling into question the strength of their “inter­nationalist” commitments. Canada has been an active participant in many international security and non-proliferation regimes. It has played a leading role in a variety of inter­national peacekeeping operations; it provided innovative ideas (such as the “strengthened review” process) that led to the indefinite extension of the Treaty on the Non-Prolifera­tion of Nuclear Weapons (NPT) in 1995; and it led the fight to create


an international treaty (the Ottawa Treaty) banning anti-personnel land mines in the fall of 1997. Despite these significant contributions to in­ternational security and nonprolif-eration efforts, however, Canada has also pursued narrower, self-inter­ested policies in its export of prolif­eration-risky Canadian Deuterium Uranium (CANDU) reactors. It has also frequently stretched its own en­vironmental laws to the limit in waiving restrictions on these exports to countries with questionable envi­ronmental safety records and capa­bilities.

This article examines the history of Canada’s CANDU reactor sales (see Figure 1) and the clash between Canada’s “internationalist” prin­ciples and its narrower domestic pri­orities. In doing so, the study makes the argument that the latter set of


domestic concerns has tended to dominate Canadian decisionmaking in sales of CANDU reactors, despite Canada’s reputation as a champion of “internationalist” values. Consis­tent with this argument, the article also presents new evidence that Ca­nadian policy may now be chang-ing—to one less favorable to CANDU exports—but precisely for domestic reasons. That is, recent public revelations about hidden costs behind CANDU exports have made justifying reactor sales more and more difficult at home. At the same time, recent evidence of environ­mental problems and lowered eco­nomic efficiency in the operation of CANDU reactors in Canada have thrown the alleged benefits of CANDUs (compared to other reac­tors) into question in the eyes of for­eign purchasers. Such concerns and

Click on this link to continue reading a pdf version of the full article: http://cns.miis.edu/npr/pdfs/bratt53.pdf

 

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White lightning: Ethanol and Iogen: Patrick Foody’s 20-year ethanol itch pays off. Finally

Pauline Tam
The Ottawa Citizen
March 19, 1998

It was an unremarkable concoction, this mealy mush of wood bits cooked in steam. Pulpy, brown bog was what it looked like. But the American scientist immediately understood the significance of Patrick Foody’s discovery.

Mr. Foody, a civil engineer and budding financier from Montreal, had stumbled upon a key step to making renewable energy.

The mystery was this: How could forestry and farm waste — essentially straw, grass or wood bits that would otherwise be useless — be turned into alcohol fuel for cars? Could this cheaper, cleaner fuel replace gasoline?

It was 1978 and scientists were racing to beat back global fears of an oil shortage. Ethanol made from waste fibres was seen as one possible solution, but most people were betting on the success of other fossil fuels, such as methanol made from coal. They were also counting on offshore and northern oil exploration to bolster fuel supplies.

Not Patrick Foody. After that first meeting with a leading U.S. energy researcher, he was convinced energy from waste fibres would be revolutionary, not just as fuel for cars, but as electrical power as well. The ethanol puzzle sparkled with the promise of a scientific challenge as well as a business opportunity. He decided to throw his innovation — and his millions –behind what he believed would be a sure and fast moneymaker. He called it “a major industrial opportunity.”

Twenty years later, Mr. Foody is still trying to prove himself right.

Today, Iogen Corporation, the biotechnology company in Ottawa that Mr. Foody founded, is a world leader in the sale of industrial enzymes, with annual revenues estimated at between $10 million and $20 million. The enzymes, a form of protein, have the look of dark apple juice when they are sold as a liquid, and a powder detergent when they are sold as a solid. They are used mainly in the pulp and paper sector to reduce the use of bleaching chemicals, and in the textile industry to “stonewash” blue jeans.

Together with waste fibres that have been cooked in steam, these enzymes can also be used to make ethanol cheaply, without adding pollutants to the environment. Corn and wheat are currently used to refine ethanol fuel, but they are more costly than waste fibres.

Last November, Iogen announced it was on the verge of mass producing ethanol from enzymes and waste fibres — something no one else in the world has yet been able to do. It has not been a cheap or easy venture. Of the $40 million Iogen has spent on ethanol research since the 1970s, more than half of the investment capital has come directly from Mr. Foody.

“It was something I thought was neat,” he explained recently, grinning often as he spoke. “It was an expensive hobby, but I always felt I could do it. I always felt I could win. Getting my six kids through the best schools was a bigger problem. I could stop and start this hobby of mine whenever I liked, but those kids had to get through school. One year, my university fees were a quarter of a million dollars.”

Chasing his hobby made more than a few people — including his wife — question Mr. Foody’s business instincts. He had other investment interests through his Montreal-based holdings company, Techcapital Group, and was one of the original financiers of the Ottawa high-tech firm, SHL Systemhouse Inc. Yet renewable energy remained Mr. Foody’s pet project.

Virtually all of Iogen’s enzymes are derived in some way from the knowledge the company accumulated while researching ethanol-related technology. But the goal of mass producing ethanol from waste has always been the company’s core ambition.

The privately-held firm on Hunt Club Road, which employs a staff of 65, is run by two of Mr. Foody’s six sons: 38-year-old Brian, Iogen’s president, who oversees all the company’s research efforts, and 36-year-old Patrick Jr., Iogen’s sales and general manager. “The battle is now in the hands of the next generation,” Patrick Sr. says with satisfaction.

While he has never run the company himself, Mr. Foody is, without a doubt, the guiding presence behind Iogen. The vigorous 68-year-old says he is trying, without much success, to retire from engineering, even as he continues to take an active interest in Iogen’s future.

Every week, he makes the 1 1/2-hour drive to Ottawa from his riverfront home in the tiny town of Hudson, west of Montreal, and spends three days at Iogen, overseeing the most critical expansion yet for the company.

On the fringes of the Ottawa airport, outside an old hangar that has been converted into Iogen offices, Patrick Foody surveys the scruffy lot in front of him and the gray fields stretching beyond it.

For now, the heart of Iogen’s enzyme operations is a three-acre site that holds a low-slung brick building with a barn-like annex painted white and green — the company colours. Five-storey distillery tanks squat next to the compound.

But a landmark deal with Petro-Canada, signed last November, will add at least 10 more acres to the Iogen property by 1999. On it will sit a $15-million to $30-million ethanol test plant, designed by Mr. Foody. The demonstration facility, funded almost equally by both firms, will represent the first known attempt at making alcohol fuel from converted waste fibres on an industrial scale.

“Iogen has European and American competitors when it comes to making industrial enzymes, but I haven’t heard of anyone else getting to the point where they’re going to build a demonstration plant for ethanol using the enzyme method,” said John Henning, an agricultural economist at McGill University.

If the demonstration plant is a success, Petro-Canada will have a licensing option to build a full-scale ethanol refinery.

It isn’t the first time Iogen has partnered with other oil or biotechnology firms in an attempt to commercialize their ethanol research. But energy analysts say Iogen’s enzymes are now so superior compared to those of their competitors, as well as those made 20 years ago, that the company has a good chance at mass production.

If that is the case, the Petro-Canada alliance could make the two companies leaders in the race to replace gasoline as transportation fuel. They may also arrive on the market in time to capitalize on increasing public and government interest in reducing greenhouse gases, caused mainly by burning fossil fuels, which can lead to climate changes.

“Other technologies could come along, but (Iogen and Petro-Canada) have a really good shot,” says Tom Adams, executive director of Energy Probe, a Toronto group that studies alternative energy sources. “There’s tremendous potential here because of three factors — the technology uses existing surplus materials, it doesn’t represent a big environmental problem, and it doesn’t require consumers to change their patterns of behaviour.”

On a recent afternoon, Mr. Foody, an affable man who speaks with a gentle Irish lilt, settled behind an office table with the engineering plans for the test plant unfurled before him.

Next to the plans were eight pages of simple flowcharts, diagrams and written descriptions neatly charting company findings over the years. Not all of it is original scholarship, and his company is by no means the only contributor to ethanol research. Still, when Mr. Foody first got interested in the field, converting waste fibres into something useful was a relatively new science.

The idea, born of a widespread belief that worldwide starvation was looming and global energy sources were running out, first nagged at Mr. Foody in 1973. If the world wasn’t producing enough grain or corn to feed both humans and animals, he figured, maybe food starch could be found somewhere else.

He compared the chemical fingerprints of wood and starch, and found remarkable similarities. What if the coarse, brittle fibres in surplus wood chips could be softened somehow and made into easily digestible animal feed?

When he wasn’t running Techtrol Limited, his successful Montreal engineering firm, Mr. Foody spent his spare time wrestling with this cryptic puzzle. His professional specialty was designing and building grain elevators, not biochemistry. But his farming clients in the U.S., and some American academics, were concerned that a worldwide population explosion, combined with limited crop yields, could spell mass famine.

Mr. Foody, a self-made man who had emigrated from Ireland in 1952, saw the animal-feed business as a potentially lucrative spinoff of his engineering empire. In 1974, he formed Iotech Corporation. (The name was a play on words: Techtrol Ltd., Mr. Foody’s engineering firm, was pressed into service as Iotech’s financier, hence “I owe Tech.”)

The company began with three employees working out of an industrial warehouse on Montreal Road, trying to solve the fibre problem.

Several years later, Iotech perfected a solution. In method, it was nothing more complicated than making popcorn. Wood chips were put in a vat and pressure-cooked with steam until the chips exploded. The trick was to control the temperature, pressure and acidity of the steaming process.

Yet the company never gave any thought to making alcohol fuel until 1978. That year, Mr. Foody met Henry Bungay, then head of a research program on alcohol fuel at the U.S. Department of Energy. Mr. Bungay was also a professor of chemical engineering at Rensselaer Polytechnic Institute in Troy, New York, where Mr. Foody’s second son studied.

On a Christmas visit home, Michael Foody had told his father about Mr. Bungay’s contact with American researchers who cultivated a tropical fungus. It was first discovered during the Second World War. American soldiers stationed in the Pacific jungle of Guam had noticed that their canvas tents and cotton uniforms were falling apart and rotting away.

The fungus, called trichoderma, gnawed on fibrous plants and secreted an enzyme that allowed it to break down logs, cotton, grass or lumber, converting it into useable sugar.

Mr. Bungay and other university researchers believed that if there was a way to make the fibres more easily digestible to the fungus, it would speed up what was basically a rotting process. Once the enzyme converted the fibres to sugar, it could be fermented with yeast and distilled into alcohol fuel. The world would have cheap ethanol for the first time.

When he heard about the fibre problem, Mr. Foody perked up. “I told Michael to go back down to school and tell them that his daddy knew how to do this,” he recalled.

Mr. Bungay recognized Mr. Foody’s innovation when he saw it. Iotech’s steam explosion method was efficient because it did not require heavily powered machines to break up the fibres. He quickly introduced Mr. Foody to the leading university researchers working in the enzyme field, as well as other U.S. oil and biotechnology companies investing in enzyme research. Mr. Bungay also offered Mr. Foody research money and scientific advice.

“He went rapidly from the industrial world to the academic world and I put him in touch with the best minds in the enzyme field,” said Mr. Bungay. “The Foodys are awfully good learners.”

As it turned out, university and government labs across North America were also trying to solve the ethanol puzzle. But the research into ethanol made from waste was far from complete.

Not enough was known about the habits and moods of the fungus that produced the enzyme, and caused the starchy rot. Making ethanol in a flask was one thing; making ethanol for gasbars was another. The idea was to speed up the rotting process so that what might normally take nature weeks or months to do could be done in days. For this to happen, researchers had to devise a complex, delicate equation for coaxing the fungus, a fuzzy green mold when it first begins life, to make more enzyme. Even with more lab work to do, Mr. Bungay believed ethanol made from the enzyme method was only three years away from reaching the marketplace.

Mr. Foody brought the microbe back to Ottawa. In 1982, he put his eldest son, Brian, in charge of a 12-member research team to examine the fungus and the enzyme it produced. For the next few years, the Foody team worked with leading scientists at several American universities. They learned to grow the fungus in large fermenters where they could control levels of acidity and temperature. They also began to genetically breed, select and alter the wood-rotting fungus.

“We looked at issues like how can we talk it into making more enzyme and making it faster? What are the decisions that it makes and what controls those decisions? Can we affect the way it makes its decisions?” Brian Foody explained.

“In a way, (the microbe) is like you or me. It breathes air. It needs carbohydrates, vitamins and minerals. And what you do is feed it in a way that causes it to do what you want. You want to give it just enough food so that when they’re on the brink of starvation, they make more enzyme.”

At the time he began researching enzymes, Brian was 23. Two years earlier, he had graduated from the Massachusetts Institute of Technology with two undergraduate degrees in civil and mechanical engineering, and one masters degree in mechanical engineering. He spent four years on the three degrees.

“I did very well in school. I’m from a pretty high-achieving family,” he says, grinning in the easy manner of his father. His brother, Michael — now 37 and head of the Montreal company, Visual Edge Software Ltd., another Foody family enterprise — also completed three degrees in four years, while Patrick Jr. earned two degrees over the same length of time.

In his modest, cluttered office, located in an old Transport Canada building about a kilometre east of Iogen’s enzyme plant, Brian Foody recalled the turbulent ’70s, when energy policy was a major political issue. In Canada, the federal government created Petro-Canada to boost oil and gas exploration, and later implemented the controversial National Energy Program to gain greater control of the Canadian energy industry.

During his student years at MIT, Brian felt the effects of a national gas-rationing policy in the U.S. The unprecedented rise in the world price of crude oil, particularly in 1979, had created a nationwide fuel shortage. “They had rules that you could only buy gas on odd or even days depending on whether your license plate ended in an odd or even number.”

Once, on a road trip from Washington, D.C. to Boston, he and some classmates ran out of gas on a day when filling up was illegal. They ended up draining fuel from a car belonging to a friend’s mother. “The world’s perception was that oil prices would rise forever, that we had a 10-year supply of oil and that life would have to change,” said Brian.

Even in such times, his father’s idea for an ethanol research business was not popular with investors, said Brian. “Probably 99.9 per cent of the world thought that he was crazy. Even today, pursuing renewable energy is hardly a mainstream business strategy.”

For that reason, said Mr. Foody, he never raised money publicly by listing Iogen on the stock market. “There wasn’t a public market at the time because nobody believed in it so I couldn’t have gone public even if I had wanted to.”

The company persisted, instead, with funding from Techtrol, Mr. Foody’s engineering firm. They also formed whatever strategic alliances they could with oil or other biotechnology companies. Most were in the U.S., where there was more interest in ethanol research.

In 1983, the Foodys unveiled a $7.8 million pilot plant that, on a small scale, demonstrated the complete process of making ethanol from waste. That included breaking down waste fibres using Mr. Foody’s patented steam explosion method; using enzymes to convert the fibres into sugar; fermenting the sugar with yeast; and, finally, distilling the ethanol. The project received $2.7 million from what is now Natural Resources Canada — the first time the Foodys received government funding in Canada.

Mr. Bungay recalls chartering a small airplane from Albany, New York, so that he and a U.S. public television crew could fly to Ottawa and tour the Foodys’ plant. “It was very exciting. After the story aired on public television, old girlfriends from all across the country called up the Foody boys.”

But a sharp reversal of fortune followed. In 1986, the world’s crude oil prices plummeted in the space of a week, and while car owners rejoiced at cheaper gas, government and corporations quickly withdrew their support of renewable energy research. Suddenly, the Foodys found themselves with a lot of know-how but no marketable product to sell.

“It came in an immediate, swift blow,” Brian remembers. “We ran out of money for what we were doing, we had to lay off half of our 20 or so staff and figure out how we could make something of what we had.” Iogen Corporation, still financed by Techtrol, eventually emerged from the remnants of Iotech. The new company worked quickly to secure government research contracts for possible industrial applications of the company’s enzyme technology.

“We looked at everything from glues for plywood to non-caloric sweeteners,” said Brian.

It wasn’t until six years later that Iogen introduced its first commercial product: a general-purpose enzyme that was sold to help clarify apple juice. By 1994, two other types of enzymes were developed: one to reduce the amount of bleaching chemicals used to whiten paper, another to soften the denim fabric of blue jeans. For a time, they also supplied European farmers with enzymes that made animal feed more easily digestible to pigs and chickens.

Iogen quickly made a name for itself as a leading supplier of enzymes for industrial uses, but it still hadn’t commercialized its ethanol work. On the other hand, the company was finally posting sales revenues — the first time since its predecessor, Iotech, was founded in 1974. That’s 20 years of R&D, sweat equity and personal investment.

“If you were to look at what I did from an investment point of view, it was dumb,” said Mr. Foody with a laugh. “It was really dumb, but it was my hobby. People play golf. It’s dumb but it’s their hobby.”

If you ask Patrick Foody why he continues to pour money into renewable energy after all these years, he will admit to a few stubborn, prickly views.

Mostly, they relate to what he believes has been government mismanagement of Canada’s energy policy over the last two decades. He contends that from an economic point of view, the government has largely ignored the considerable merits of renewable energy. Instead, he opines, the energy crisis of the ’70s and ’80s spawned ill-conceived mega-projects such as the Hibernia offshore exploration of oil, and nuclear power plants.

“There was a lot of very bad analysis done at the time. For instance, Canada didn’t have an energy policy. Canada had a nuclear policy, and an oil and gas policy. They never really looked at energy,” says Mr. Foody.

“In fact, the energy crisis was not an energy crisis. It was a shortage of transportation fuels. But when it happened, everyone jumped on the bandwagon and there was money thrown at nuclear, there was money thrown at coal, there was money thrown at gas. Stationary sources of energy like electricity were completely adequate, and yet the nukers were the ones that got an enormous amount of money when really, it was only transportation fuels that suffered a shortage.”

His is not a flippant claim. “When you compare the amount of government research money that went to renewable energy compared to the nuclear industry, it’s enough to make you cry,” said Mr. Henning, the agricultural economist at McGill University. “Pat and I have complained about this on a few occasions.”

In the 1980s, Mr. Foody went so far as to prepare a study on the future of Ontario Hydro, which he presented to what was then the federal Department of Energy, Mines and Resources. “I said if Ontario kept building nuclear power plants, it will go broke. It was completely predictable. They should have known. I demonstrated this with their own information. Then I brought it to EMR and they said, `Oh, you’re just anti-nuclear’,” he recalls, somewhat bemused.

Tom Adams, the Toronto-based analyst at Energy Probe and a frequent critic of the provincial utility, remembers helping Mr. Foody build his case.

“One day, I got this phone call from this weird guy with a strange name and he was giving me this lecture on how Ontario Hydro was going to go bankrupt. I said, `Yes, I already published that.’ It was very unusual for someone outside the moral argument surrounding the production of energy to be involved in this discussion.”

From then on, the two men corresponded regularly and met whenever Mr. Foody visited Toronto. “He would call me a couple of times a year, every time a great disaster happened to Ontario Hydro,” said Mr. Adams. “He’d call me up and say, `We were right, weren’t we?’ And I’d say, `Yeah, Pat, we were right.”’

At the time of his initial contact with Mr. Adams, Mr. Foody was convinced that if he could solve the ethanol puzzle, he could use converted waste fibres not just to make liquid fuel, but to sell electricity as well. His calculations are charted in company research. They show that once the fibres are broken down to mush by steam, the glue that holds the fibres together can be harvested. This glue, called lignin, can then be used not only to provide steam and electrical power for the rest of the ethanol-making process, but to generate surplus electricity as well

. “The Foodys were years ahead in terms of realizing that you sell everything you make and not just one thing,” said Mr. Bungay of Rensselaer Polytechnic Institute. “That’s the strategy behind all the research and development dollars they have put into Iogen.”

Today, Mr. Foody believes that producing enough electrical power from waste fibres for mass consumption is probably just another generation away.

That scenario could be bolstered by a waning public appetite for nuclear power, said Mr. Adams. “I think his instinct is right. I think we are going to a renewable energy future and he has sketched out a path that looks extremely attractive.”

This time, however, Mr. Foody is convinced the environmental risks of greenhouse gases such as carbon dioxide, and mounting public support to reduce such harmful emissions, will finally make ethanol a credible alternative.

From a conservation point of view, ethanol made from corn or wheat is not a long-term solution because they require fertilizers and production processes that use polluting fossil fuels. They also divert feed for humans and animals.

Ethanol from farm and wood waste, by comparison, would make production cheaper because it uses surplus materials. And because fibres are converted into sugar using steam and enzymes, there are no pollutants to worry about. As a result, when fibre-based ethanol is burned as fuel, it simply recycles carbon dioxide back into the atmosphere. Carbon dioxide is necessary for plants and trees to breathe, but dangerously high levels can trap heat and affect climate. The main advantage of ethanol from waste is that it does not produce any more carbon dioxide than nature can use.

Mr. Foody believes the green benefits of fibre-based ethanol, and its relatively low cost of production compared to gasoline, will make alcohol fuel attractive for consumers. Analysts estimate that while the production costs for conventional gasoline average 25 cents a litre, ethanol from waste and enzymes could cost about 10 cents a litre before taxes.

“The government is going to have to deal with how to make a level playing field for people who say to consumers, `you don’t have to cut back on fuel, you just have to change fuels,”’ said Mr. Foody. “That’s going to be the field that Brian fights on. The battle will be fought on the equality of opportunities to enter the market if you’re a new fuel.”

Characteristically, the Foodys are proceeding with restraint toward their goal of mass-producing ethanol, even though their multimillion deal with Petro-Canada represents their best chance yet.

A tour of the thriving, no-nonsense Iogen plant produces few signs of executive frills. Both Brian Foody and his father drive recent model Honda Accords. At the company’s corporate headquarters, the president’s office (drab, gray, concrete walls) competes for space with cramped research labs. Along with the construction of a demonstration plant, Patrick Foody has plans to build a large research centre and finally consolidate all of Iogen’s operations on a single site. But that is still more than a year away. Mr. Foody says he is also content to continue to keep Iogen a family concern, at least until the commercial success of ethanol is proven.

“It looks to me like the Foody family believes that having the trappings of success before you prove it is not the way to win the game,” said Mr. Adams. “The approach that they appear to take is you go through all these logical steps and you don’t skip steps. And they are sticking to this plan in defiance of most high-tech companies who go public and want immediate benefits. They (the Foodys) wanted to maintain control of this project, and going public would represent a loss of control.”

Mr. Foody is, as usual, more pragmatic. “It’s the wrong time (for an IPO). There will be a right time to go public, when the science is proven and the drums are beating.

“You get more money for the sizzle than you do for the steak. So we’re waiting for the sizzle.”

 

Posted in Renewables | Leave a comment

Government releases report of panel studying the disposal of nuclear fuel waste

Press release
March 13, 1998

Ottawa – March 13, 1998 – The federal panel studying the long-term management of nuclear fuel waste and the safety and acceptability of Atomic Energy of Canada’s concept to bury nuclear waste deep within the rock of the Canadian Shield has recommended a step-by-step approach to managing nuclear wastes. Accordingly, the eight-member panel is recommending that the search for a specific site not proceed at the present time. The panel’s report was made public today by Minister of Natural Resources, Ralph Goodale and Minister of the Environment, Christine Stewart.

“The panel has undertaken an exhaustive review and consultation on a very complex issue. Its report will permit the government to come to an informed and balanced response,” said Environment Minister Christine Stewart.

The panel, over its eight-year mandate, carefully examined the criteria by which the safety and acceptability of any concept for long-term waste management and disposal should be developed. It reached two conclusions:

• Broad public support is necessary in Canada to ensure the acceptability of a concept for managing nuclear fuel wastes; and

• Safety is a key part, but only one part, of acceptability. Safety must be viewed from two complementary perspectives: social and technical.

Applying these criteria to Atomic Energy of Canada’s disposal concept, the panel arrived at the following conclusions:

• While the safety of the AECL concept has been adequately demonstrated from a technical perspective, from a social perspective it has not.

• The AECL concept in its current form for deep geologic disposal does not have broad public support, and does not have the required level of acceptability to be adopted as Canada’s approach for managing nuclear fuel wastes.

The panel has also recommended the creation of a nuclear fuel waste management agency to assume responsibility for managing and co-ordinating the full range of activities required to deal with nuclear fuel wastes in the long term.

“This panel report raises key issues which the government will give consideration to in its response. This will set the stage for the next steps regarding the long-term disposal of nuclear fuel waste in Canada,” said Minister of Natural Resources Ralph Goodale.

The panel was appointed in October 1989 under the Environmental Assessment and Review Process Guidelines Order and is the last panel to report under that Cabinet directive. The panel, chaired by Mr. Blair Seaborn conducted its review in five provinces: Saskatchewan, Manitoba, Ontario, Quebec and New Brunswick. Public hearings were held in 16 communities, including three Aboriginal communities, over three phases from March 1996 to March 1997. Phase I focussed on broad societal issues; Phase II on technical issues; and Phase III on the safety and acceptability of the disposal concept. Overall, the panel heard 531 registered speakers and received 536 written submissions.

– 30 –

For more information:

Guy Riverin Panel Manager Canadian Environmental Assessment Agency

Tel: (819) 997-2244 E-mail: guy.riverin@ceaa.gc.ca

The complete report is posted on the CEAA Internet site, at http://www.ceaa.gc.ca

Ottawa – March 13, 1998 – The federal panel studying the long-term management of nuclear fuel waste and the safety and acceptability of Atomic Energy of Canada’s concept to bury nuclear waste deep within the rock of the Canadian Shield has recommended a step-by-step approach to managing nuclear wastes. Accordingly, the eight-member panel is recommending that the search for a specific site not proceed at the present time. The panel’s report was made public today by Minister of Natural Resources, Ralph Goodale and Minister of the Environment, Christine Stewart.

“The panel has undertaken an exhaustive review and consultation on a very complex issue. Its report will permit the government to come to an informed and balanced response,” said Environment Minister Christine Stewart.

The panel, over its eight-year mandate, carefully examined the criteria by which the safety and acceptability of any concept for long-term waste management and disposal should be developed. It reached two conclusions:

• Broad public support is necessary in Canada to ensure the acceptability of a concept for managing nuclear fuel wastes; and

• Safety is a key part, but only one part, of acceptability. Safety must be viewed from two complementary perspectives: social and technical.

Applying these criteria to Atomic Energy of Canada’s disposal concept, the panel arrived at the following conclusions:

• While the safety of the AECL concept has been adequately demonstrated from a technical perspective, from a social perspective it has not.

• The AECL concept in its current form for deep geologic disposal does not have broad public support, and does not have the required level of acceptability to be adopted as Canada’s approach for managing nuclear fuel wastes.

The panel has also recommended the creation of a nuclear fuel waste management agency to assume responsibility for managing and co-ordinating the full range of activities required to deal with nuclear fuel wastes in the long term.

“This panel report raises key issues which the government will give consideration to in its response. This will set the stage for the next steps regarding the long-term disposal of nuclear fuel waste in Canada,” said Minister of Natural Resources Ralph Goodale.

The panel was appointed in October 1989 under the Environmental Assessment and Review Process Guidelines Order and is the last panel to report under that Cabinet directive. The panel, chaired by Mr. Blair Seaborn conducted its review in five provinces: Saskatchewan, Manitoba, Ontario, Quebec and New Brunswick. Public hearings were held in 16 communities, including three Aboriginal communities, over three phases from March 1996 to March 1997. Phase I focussed on broad societal issues; Phase II on technical issues; and Phase III on the safety and acceptability of the disposal concept. Overall, the panel heard 531 registered speakers and received 536 written submissions.

For more information:

Guy Riverin Panel Manager Canadian Environmental Assessment Agency

Tel: (819) 997-2244 E-mail: guy.riverin@ceaa.gc.ca

The complete report is posted on the CEAA Internet site, at http://www.ceaa.gc.ca

Posted in Nuclear Safety | Leave a comment

Cndn Government releases report of panel studying the disposal of nuclear fuel waste: backgrounder

Canadian Environmental Assessment Agency
March 1, 1998

In a 1978 joint statement, the governments of Canada and Ontario directed Atomic Energy of Canada Limited (AECL) to develop the concept of deep geological disposal of nuclear fuel wastes. A subsequent joint statement in 1981 established that disposal site selection would not begin until after a full federal public hearing and approval of the concept by both governments.

In September 1988, the federal Minister of Energy, Mines and Resources referred the concept, along with a broad range of nuclear fuel waste management issues, for public review. He made this referral under the federal Environmental Assessment and Review Process Guide-lines Order. On October 4, 1989, the federal Minister of the Environment appointed an independent environmental assessment panel to conduct the review.

The panel’s mandate was unusual compared to that of any other federal environmental assessment panel in that it was asked:

• to review a concept rather than a specific project at a specific site;

• to review a proposal for which the implementing agency was not identified;

• to establish a scientific review group of distinguished independent experts to examine the safety and scientific acceptability of the proposal;

• to review a broad range of policy issues; and

• to conduct the review in five provinces.

AECL describes its concept as a method for geological disposal of nuclear fuel wastes in which

• the waste form is either used Canada Deuterium Uranium (CANDU) fuel or the solidified high-level wastes from reprocessing;

• the waste form is sealed in a container designed to last at least 500 years and possibly much longer;

• the containers of waste are emplaced in rooms in a disposal vault or in boreholes drilled from the rooms;

• the disposal rooms are between 500 and 1000 metres below the surface;

the geological medium is plutonic rock of the Canadian Shield;

• each container of waste is surrounded by a buffer;

• each room is sealed with backfill and other vault seals; and

• all tunnels, shafts and exploration boreholes are ultimately sealed in such a way that a disposal facility would be passively safe—that is, long-term safety would not depend on institutional controls.

Such a facility would cost an estimated $8.7 billion to $13.3 billion in 1991 dollars, depending on the amount of waste to be disposed of.

The Panel conducted its review in Saskatchewan, Manitoba, Ontario, Quebec and New Brunswick. To develop guidelines to help AECL prepare an environmental impact statement (EIS), the Panel held scoping meetings in autumn 1990 in 14 communities. It also held a workshop on Aboriginal issues and met with members of Canadian Student Pugwash. The Panel then prepared draft guidelines, released them for public comment in June 1991, and issued them in final form on March 18, 1992. On October 26, 1994, AECL submitted an EIS, supported by nine primary reference documents. The period for public review of the EIS began on November 8, 1994, and ended on August 8, 1995.

Public hearings were held in 16 communities over three phases beginning March 11, 1996 and ending March 27, 1997. Phase I focused on broad societal issues related to managing nuclear fuel wastes; Phase II focused on the safety of the AECL concept from a technical viewpoint; and Phase III focused on the public’s opinions of the safety and acceptability of the concept. During all three phases, the Panel heard from a total of 531 registered speakers and received 536 written submissions, as listed in Appendix F. Participants were also allowed to submit brief closing statements in writing by April 18, 1997. The Panel considered all written and oral information received in the period from its appointment to the end of the hearings, as well as the closing statements, in preparing this report.

Among other activities, the Terms of Reference directed the Panel

• to examine the criteria by which the safety and acceptability of a concept for long-term waste management and disposal should be evaluated; and

• to prepare a final report addressing whether AECL’s concept is safe and acceptable or should be modified, and the future steps to be taken in managing nuclear fuel wastes in Canada.

CRITERIA FOR SAFETY AND ACCEPTABILITY

The Panel examined the criteria by which the safety and acceptability of any concept for long-term waste management should be evaluated (Chapter 4 of the report). In doing so, it came to the following key conclusions.

Key Panel Conclusions

• Broad public support is necessary in Canada to ensure the acceptability of a concept for managing nuclear fuel wastes.

• Safety is a key part, but only one part, of acceptability. Safety must be viewed from two complementary perspectives: technical and social.

On this basis, the Panel defined the safety and acceptability criteria as follows:

To be considered acceptable, a concept for managing nuclear fuel wastes must

• have broad public support;

• be safe from both a technical and a social perspective;

• have been developed within a sound ethical and social assessment framework;

• have the support of Aboriginal people;

• be selected after comparison with the risks, costs and benefits of other options; and

• be advanced by a stable and trustworthy proponent and overseen by a trustworthy regulator.

To be considered safe, a concept for managing nuclear fuel wastes must be judged, on balance, to

• demonstrate robustness in meeting appropriate regulatory requirements;

• be based on thorough and participatory scenario analyses;

• use realistic data, modelling and natural analogues;

• incorporate sound science and good practices;

• demonstrate flexibility;

• demonstrate that implementation is feasible; and

• integrate peer review and international expertise.

SAFETY AND ACCEPTABILITY OF THE AECL CONCEPT

After applying these criteria to the AECL disposal concept, the Panel arrived at the key conclusions listed below. The rationale for them, and an elaboration on the technical and social perspectives of safety, are documented in Chapter 5 of the report.

Key Panel Conclusions

• From a technical perspective, safety of the AECL concept has been on balance adequately demonstrated for a conceptual stage of development, but from a social perspective, it has not.

• As it stands, the AECL concept for deep geological disposal has not been demonstrated to have broad public support. The concept in its current form does not have the required level of acceptability to be adopted as Canada’s approach for managing nuclear fuel wastes.

FUTURE STEPS

The Panel considered the steps that must be taken to ensure the safe and acceptable long-term management of nuclear fuel wastes in Canada (in Chapter 6 of the report). It arrived at the following key recommendations.

Key Panel Recommendations

A number of additional steps are required to develop an approach for managing nuclear fuel wastes in a way that could achieve broad public support. These include

• issuing a policy statement on managing nuclear fuel wastes;

• initiating an Aboriginal participation process;

• creating a nuclear fuel waste management agency (NFWMA);

• conducting a public review of AECB regulatory documents using a more effective consultation process;

• developing a comprehensive public participation plan;

• developing an ethical and social assessment framework; and

• developing and comparing options for managing nuclear fuel wastes.

Taking into account the views of participants in our public hearings and our own analysis, we have developed the following basic recommendations to governments with respect to a management agency:

• that an NFWMA as described in Chapter 6 of the report be established quickly, at arm’s length from the utilities and AECL, with the sole purpose of managing and co-ordinating the full range of activities relating to the long-term management of nuclear fuel wastes;

• that it be fully funded in all its operations from a segregated fund to which only the producers and owners of nuclear fuel wastes would contribute;

• that its board of directors, appointed by the federal government, be representative of key stakeholders;

• that it have a strong and active advisory council representative of a wide variety of interested parties;

• that its purposes, responsibilities and accountability, particularly in relation to the ownership of the wastes, be clearly and explicitly spelled out, preferably in legislation or in its charter of incorporation; and

• that it be subject to multiple oversight mechanisms, including federal regulatory control with respect to its scientific–technical work and the adequacy of its financial guarantees; to policy direction from the federal government; and to regular public review, preferably by Parliament.

Until the foregoing steps have been completed and broad public acceptance of a nuclear fuel waste management approach has been achieved, the search for a specific site should not proceed.

If the AECL concept is chosen as the most acceptable option after implementation of the steps recom-mended above, governments should direct the NFWMA, together with Natural Resources Canada and the AECB or its successor, to undertake the following: review all the social and technical shortcomings identified by the Scientific Review Group and other review participants; establish their priority; and generate a plan to address them. The NFWMA should make this plan publicly available, invite public input, then implement the plan.

 

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Plant wearing out, says report

David Young
Times Globe
February 20, 1998

Point Lepreau is going to be a huge drain on the finances of NB Power into the next century, warns a provincial report.

The plant will not last as long as expected and must either undergo a costly refurbishing or be shut down before the debt is paid off, says Electricity in New Brunswick Beyond 2000, prepared by the Department of Natural Resources and Energy to assess the Crown corporation’s ability to meet deregulation.

“NB Power currently has an inappropriately high level of debt,” says the report, released today. That’s partly due to the corporation’s effort to build so much in the last two decades. Among those construction projects was Point Lepreau.

The report said the plant’s “poor performance has a major financial impact on NB Power” because Point Lepreau supplies 30 per cent of the power for the province and the corporation must pay up to $450,000 a day to replace the power when the nuclear plant is shut down. Because of problems at the plant, including crucial pipes that are thinning four times faster than expected, it has not been operating successfully.

“Preliminary indications are that Point Lepreau will not be able to operate until the year 2014 as planned without a major refurbishment somewhere between the time period of 2005 to 2011.” NB Power had been counting on Lepreau operating until the year 2014.

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Hormesis as a biological hypothesis

E J Calabrese and L A Baldwin
Environmental Health Perspectives
February 1, 1998

Abstract

A comprehensive effort was undertaken to identify articles demonstrating chemical hormesis. Nearly 4000 potentially relevant articles were retrieved from preliminary computer database searches by using various key word descriptors and extensive cross-referencing. A priori evaluation criteria were established including study design features (e.g., number of doses, dose range), statistical analysis, and reproducibility of results. Evidence of chemical hormesis was judged to have occurred in approximately 350 of the 4000 studies evaluated. Chemical hormesis was observed in a wide range of taxonomic groups and involved agents representing highly diverse chemical classes, many of potential environmental relevance. Numerous biological end points were assessed; growth responses were the most prevalent, followed by metabolic effects, longevity, reproductive responses, and survival. Hormetic responses were generally observed to be of limited magnitude. The average low-dose maximum stimulation was approximately 50% greater than controls. The hormetic dose-response range was generally limited to about one order of magnitude, with the upper end of the hormetic curve approaching the estimated no observable effect level for the particular end point. Based on the evaluation criteria, high to moderate evidence of hormesis was observed in studies comprised of > 6 doses; with >  3 doses in the hormetic zone. The present analysis suggests that chemical hormesis is a reproducible and relatively common biological phenomenon. A quantitative scheme is presented for future application to the database.

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Hormesis as a biological hypothesis

(Feb. 1, 1998) A comprehensive effort was undertaken to identify articles demonstrating chemical hormesis. Nearly 4000 potentially relevant articles were retrieved from preliminary computer database searches by using various key word descriptors and extensive cross-referencing. A priori evaluation criteria were established including study design features (e.g., number of doses, dose range), statistical analysis, and reproducibility of results. Evidence of chemical hormesis was judged to have occurred in approximately 350 of the 4000 studies evaluated.

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Letter on legislative change requirements for natural gas deregulation

Thomas Adams

January 25, 1998

 

Minister Jim Wilson, M.P.P
Minister of Energy, Science and Technology
900 Bay St., 4th Fl
Toronto, Ontario
M7A 2E1

<!–

by fax: 327-6754 (five pages)

–>

Dear Mr. Minister:

The following remarks are in response to your letter of December 19, 1998 about the Ontario Energy Board’s “Advisory Report to the Minister of Energy, Science and Technology on Legislative Change Requirements for Natural Gas Deregulation”.

Energy Probe supports the continued evolution toward a more deregulated market for natural gas in Ontario. Since 1985, natural gas deregulation has saved Ontario consumers billions of dollars. Given the environmental attractiveness of natural gas relative to competing fuel sources, natural gas deregulation in Ontario has been environmentally beneficial. This province’s ground breaking gas deregulation initiative is now a model for North American energy markets.

Energy Probe supports legislative changes to:

  • enable gas commodity title transfers in Ontario,
  • continue regulation of the monopoly storage, transportation, and distribution functions of the local distribution companies,
  • enable the OEB to actively promote customer protection and customer education,
  • permit the Board to choose the most appropriate and costs effective means of regulating monopoly services including performance-based regulation,
  • replace the obligation to sell for utilities with an obligation to deliver, and
  • give the Ontario Energy Board a duty to promote competition. 

We have addition proposals for legislative changes in the conclusion section of this letter.

Customer Protection

Energy Probe shares the OEB’s concerns about problems caused by some gas marketers selling to homeowners. Some marketers are asking customers to sign long term contracts at prices well above current prices, and although it is conceivable that market prices might rise, leaving these customers better off than they might be otherwise, it is more reasonable to assume that a more fully competitive market would result in much lower contract prices.

The deficiencies of some of the retail offerings now in the natural gas market place could be reduced if customers had better information about gas costs and what they are actually paying for on their gas bills. The root cause of much of the customer confusion that exists is not adequately addressed in the OEB’s report. We believe that the root cause of this confusion is a history of inappropriate regulation of gas rates. The only information homeowners on system gas received on their bills was based on inherently inefficient and confusing cost calculations- the weighted average cost of gas (WACOG) and the purchase gas variance account (PGVA). Ordinary customers have virtually no way to figure out what they really pay for gas. In future, if regulated rates include gas costs, customers should receive clear price information so that they can compare prices with the offerings of competitors.

Replacing of System Gas

All of the customer and system services now served by system gas can be replaced by an expanded, Ontario-based physical spot market in gas. This market has not developed because of legislative impediments. Energy Probe has prepared several papers on this subject, including “Proposed Gas Independent System Operator in Ontario” (Energy Analects, June 9, 1998).

Regulating Market Power

The Ontario Energy Board does not have experience with monitoring and controlling market power. The OEB will have to develop this capacity and should coordinate with the federal Bureau of Competition Policy.

Market Design Taskforce

Energy Probe supports the formation of a market design taskforce to assist in making the transition to a more fully deregulated gas market.

Licensing

 

Energy Probe urges the government to ensure that licensing does not represent a barrier to entry into the competitive gas market. Large brokers and utility affiliates will have little difficulty going through the administrative procedures to acquire licenses. The government should focus on the needs of small marketers and prospective new market entrants so that these groups can help discipline the market place.

Licensing should only by administered through OEB and not delegated to other groups. Industry groups lack the independence that should be a prerequisite for licensing.

If licensing is to be introduced, very tight definitions of conditions should be required to make the adjudication process as predicable and objective as possible.

Regulatory Process: Powers

The Ontario government should grant the Ontario Energy Board the power to order divestiture of non-monopoly enterprises and functions. The OEB has proposed that it be granted the power to order either the removal from regulation, or redefinition of, current LDC services. This proposal is good as far as it goes but should go further. The OEB would be better able to meet the requirements of its mandate if it had the power in the new legislation to order divestiture of utility affiliates operating in non-monopoly businesses if this divestiture is found to be necessary to promote competition and to prevent cross subsidies. The Board may not have to exercise this power often, but having this power is likely to improve the Board’s ability to influence utilities in the public interest.

The future regulatory regime should enshrine the principle that the costs of regulation, whether for the regulated enterprise, the regulator or intervenors, should be internalized within regulated enterprises and borne by beneficiaries of regulation The OEB should retain the power to allow or deny the recovery of costs by utilities and intervenors.

The Ontario Energy Board should be required to monitor and regulate not just the cost of service to customers but also the quality of that service so that customers are protected from any utility efforts to cut costs at the expense of service.

Regulatory Process: Maintaining Adjudicative Regulation

The recommendation at page 44 of the Board’s report on legislative change suggests that the Ontario Energy Board should emerge from the adjudicative model of regulation and pursue

rulemaking powers in response to emerging markets and the need for prospective, flexible, and participatory rules.

If the government is considering empowering the OEB with rulemaking powers, it is essential that these new powers are designed so as to compliment the continuing role that the adjudicative model must continue to play. The quasi-judicial role of the OEB has served gas customers well as a serious opportunity for informed decision making. Rulemaking has the potential for reducing the independence and impartiality of the Board and reducing the opportunity for public interest organizations to participate as intervenors in quasi-judicial proceedings, with opportunities for cross examination, evidence, and costs.

The major challenge for the government is to understand the competing roles of the rulemaking and adjudication in regulating modern markets. While rulemaking is often necessary as a result of a maturing market, there remains a central and continuing role for adjudication. The judicial or quasi-judicial process continues to function as the most effective means of “searching for the truth” in complex and factual adversarial matters.

In Ontario, parts of the electrical and gas markets are being opened to competition, while other parts of the business will remain within the monopoly business. In the past, the OEB has regulated the natural gas monopoly rates through a quasi-judicial adjudicative model. The model worked very well at keeping gas rates competitive. The deregulation of functions that are naturally competitive and no longer in need of regulation raises new problems

In contrast, Ontario Hydro is subject to quasi-judicial hearings regarding rate increases but not subject to binding decisions. Until now, OEB Hydro rate hearings have been elaborate notice and comment processes similar to the current process for approving federal legislation. The weakness of the current oversight of Hydro belies any move to replace the OEB’s current adjudicative model for regulating gas rates with a rulemaking notice and comment procedure. If the evidence underlying the Board’s decisions is not tested in an adjudicative process, with rights to cross examination, opportunity to lead evidence, and binding decisions, the OEB moves closer to the model that Ontario Hydro has operated under in the past and away from the model that has regulated natural gas. This would be an unfortunate circumstance.

The challenge for the government will be to protect the OEB’s traditional adjudicative function, while at the same time empowering it with rulemaking powers to regulate the emerging markets. An example is that rulemaking powers are needed to respond to the serious concerns over

unregulated agents, brokers and marketers that are now beyond the scope of the OEB’s regulatory powers while continuing to adjudicate general rate applications.

The choice between adjudication or rulemaking, as an appropriate means of controlling and structuring discretion is an important one that requires a balanced view of the competing paradigms. There is no more public and accessible regulatory process in Ontario that carries as much authority as the OEB does in setting gas rates. The challenge now is for the OEB is to adopt rulemaking powers to include greater public consultation, prospective rulemaking, and regulation to meet the challenges of a maturing gas and newly opening electricity markets without weakening needed, continuing adjudicative regulation over monopoly services.

Conclusions

In addition to the bullets at the beginning of this letter outlining powers for the OEB, Energy Probe recommends that the new OEB legislation make provisions for the following:

  • the power in the new legislation to order divestiture of utility affiliates operating in non-monopoly businesses if this divestiture is found to be necessary to promote competition and to prevent cross subsidies
  • The future regulatory regime should enshrine the principle that the costs of regulation, whether for the regulated enterprise, the regulator or intervenors, should be internalized within regulated enterprises and borne by beneficiaries of regulation The OEB should retain the power to allow or deny the recovery of costs by utilities and intervenors. 
  • The Ontario Energy Board should be required to monitor and regulate not just the cost of service to customers but also the quality of that service so that customers are protected from any utility efforts to cut costs at the expense of service. 

We apologize the our delay in filing our remarks.

Sincerely,

Thomas Adams
Executive Director

c. Marie Rounding, Chair, Ontario Energy Board

 

Posted in Natural Gas Utility Regulation and Commodity Deregulation | Leave a comment

Safety attitude at nuclear plant comes under fire

Mike Hawkins
Times Globe
January 21, 1998

WATCHFUL EYE: Incidents at the Lepreau are becoming all too common for the Atomic Energy Control Board, which warns that the quality of work must improve.

SAINT JOHN – A spokesman for the Atomic Energy Control Board says a Dec. 9 accident at the Point Lepreau Nuclear Generating Station is yet another example of a poor safety attitude at the plant.

“This latest incident is just another one in a line of similar-type incidents that indicate a need to improve the quality of the work at the station,” Bob Potvin said in an interview from the AECB office in Ottawa yesterday.

The AECB outlined the incident in a routine report to the government on nuclear generating operations. As reported to the regulatory board by NB Power, a manway leading inside a water heater was left open and a water pump was switched on, causing a powerful burst of water to damage the heater.

The accident happened in a non-nuclear part of the plant on Dec. 9, 1997. No one was in the vicinity of the heater when it happened and no one was injured.

Rod White, NB Power vice-president nuclear, was quoted as saying the damage was minimal and will not affect the station’s repair schedule currently under way.

The incident did, however, reignite the AECB’s concerns about the plant.

“There is probably a way to go before we’re entirely happy with the operation,” Mr. Potvin said, adding that the plant’s licence is up for renewal in April and warning that it could be faced with a limited licence if improvements are not implemented soon.

“What we have done in Ontario, for example, at the Pickering station, we have reduced the term of the licence. At one point last year, we only granted a six-month licence – sort of shortened the lease if you like – and required them to make significant improvements.”

Last June, AECB issued a scathing report to NB Power, owners of the Lepreau plant, criticizing a general lack of concern for safety.

“We indicated very clearly there were a number of areas where we wanted to see some significant improvements made,” Mr. Potvin said.

“Nothing that in the short term compromised the safety operation of the station,” he added, “but an unsatisfactory quality of work that could, before long, lead to situations where the plant’s safety may be somewhat compromised.”

Greg Byrne, Minister of State for Energy and Mines, was asked about the incident during question period at the Provincial Legislature yesterday afternoon.

Mr. Byrne downplayed the incident as a part of a problem that was already in the process of being fixed.

“This was primarily a communication problem and so procedures are being reviewed,” he said. “For some time, there has been a performance improvement program that has been instituted to review both the safety culture and operational procedures at the site. But I think this incident indicates there’s a need to conduct a thorough review to ensure that incidents of this nature are kept to a minimum.”

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Ethics of DuPont’s CFC strategy: 1975-1995

Brigitte Smith
Journal of Business Ethics
January 1, 1998

The ethics of DuPont’s CFC strategy are analyzed using a Potter’s Box framework. This approach includes an examination of relevant facts, prioritization of stakeholder loyalties, selection of a mode of ethical reasoning, and a world view. DuPont’s approach to ethical reasoning reflects changing facts and a changing interpretation of the facts, a focus on shareholders as the primary and most important stakeholder, and ends-based reasoning, which views creating shareholder value as the primary end.

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