The News That Matters about the Nuclear Industry

On both sides o f USA-Canada border, opposition grows to transport of nuclear wastes

radiation-truckOpposition growing to cross-border nuclear shipments,, Opposition is brewing on both sides of the U.S.-Canada border about plans to move dozens of shipments of nuclear waste from a plant in Chalk River, Ontario, to a plant in South Carolina.

Buffalo Congressman Brian Higgins has been very vocal in his opposition. He is being joined by opposition in Canada.   Dean Allison is the member of Parliament for Niagara West, which includes the QEW, a potential route for some shipments. The Conservative Allison says the shipments pose real problems for first responders because they are not being told anything about the shipments or how to prepare for the highly radioactive material.

“I’ve understood from talking to some of the people with the Canadian Coalition for Nuclear Responsibility that it’s almost 17,000 times more toxic and more radioactive than when it first started and when it was first shipped, originally,” Allison says. “So our first responders need to have some kind of idea what it is because, more than likely, they will be the ones on the road, on the scene should anything happen.”

The material started in the United States and has been made far more radioactive in Canada because of research and developing nuclear materials for medical use. Higgins has long been demanding information about the shipments and their routes.

Beamsville resident Allison says he is trying to set up a meeting in his district to bring together residents, first responders and shipments officials to talk about what is going on.

“We’re going to try to get some of the key players down,” Allison says. “I don’t anticipate they’re going to give us more information but we’re going to certainly press and see if we can get anything that may be helpful to our first responders.”

February 22, 2017 Posted by | Canada, safety, USA | Leave a comment

Ontario public has a month to comment on plan for nuclear waste dump near Kincardine.

it’s “absolute madness” to “dig this hole beside the drinking water source for 40 million Canadians and Americans.”


Bruce NGS Great Lakes Lake HuronOPG identifies most of Ontario as alternate ‘location’ to bury nuclear waste: Ontario Power Generation was asked by the federal government to identify “actual locations” as alternates for its plan to bury nuclear waste. It’s now up to the minister as to whether they’ve done that. The Star, By , Jan. 10, 2017..……The hunt for an appropriate site for a Deep Geologic Repository (DGR) to house waste from Ontario’s nuclear facilities is not a subject to be taken lightly. Everything from mops to materials close to the reactor core, such as ion exchange resins that bear a “significant amount” of Carbon-14, a radionuclide that has a half life of more than 5,700 years, is slated for permanent burial.

………. A report recently released by OPG cites Ryden’s GPS co-ordinates as one of the plot points in one of two contemplated alternate locations for the DGR. Equally curious, the co-ordinates for the second alternate include a stately two story brick home in Chaplin Estates, near Yonge St. and Davisville Ave.

This is worth digging into.

On Dec. 28, Ontario Power Generation submitted the results of its federally mandated assignment to present technically and economically feasible alternate locations for the DGR — alternate, that is, to OPG’s preferred strategy to inter the waste from the Bruce, Darlington and Pickering nuclear power plants at Bruce Nuclear near Kincardine.

The Canadian Environmental Assessment Agency will take until Jan. 16 to determine “whether OPG’s information is complete and that it conforms to the Minister’s information request.” A 30-day public comment period will follow.

When the federal Environment Ministry requested the study, 11 months ago, it sought details as to “specific reference to actual locations.” While OPG responded in April that it intended to assess two feasible “geological regions” in the province, “without providing specific reference to actual locations,” it says now that in this document and the main submission it is using specific references to actual locations.

The common reader may see the word “location” to mean, as it is conventionally defined, a particular or exact place.

OPG has provided something quite different and Environment Minister Catherine McKenna now must decide whether the power giant has come up with an evaluation that is good enough.

Let’s remember that the proposed Bruce site will be dug nearly 700 metres deep in limestone host rock a distance of 1.2 km from Lake Huron. The town of Kincardine is on side. Opposition voices on both sides of the border have been loud, particularly as it concerns protecting the Great Lakes.

The dominant question: is Bruce the best spot? And a corollary: wasn’t granite — the Canadian Shield in northern Ontario — discussed long ago as potentially the appropriate geology for toxic waste? The issue may pertain not just to low and intermediate waste, but ultimately the disposal of spent fuel rods, a headache for the generations that has yet to be effectively addressed………..

Rod McLeod’s view is that it’s “absolute madness” to “dig this hole beside the drinking water source for 40 million Canadians and Americans.”

OPG insists that, at least according to its own social media analysis, Ontarians aren’t bothered. “The topic is not a popular one, nor is it generating large volumes of curiosity,” the report states, adding that interest in the DGR has “flatlined.”

The public now has little more than a month to change that perception, should it care to.

January 16, 2017 Posted by | Canada, wastes | Leave a comment

Thirty years later, Blackfoot tribes see environmental win on sacred grounds

U.S. officials on Tuesday announced the cancellation of the final two oil and gas leases in a wilderness area bordering Glacier National Park that’s sacred to the Blackfoot tribes of Montana and Canada. Christian Science Monitor, Matthew Brown Associated Press JANUARY 10, 2017 U.S. officials on Tuesday announced the cancellation of the final two oil and gas leases in a wilderness area bordering Glacier National Park that’s sacred to the Blackfoot tribes of Montana and Canada, more than three decades after the tribes said the leases were illegally sold…….

January 13, 2017 Posted by | Canada, indigenous issues, USA | Leave a comment

Canada’s government releases carbon pricing plan

climate-changeGovernment of Canada releases carbon pricing plan by IDEA Industry News

ReNew Canada reports that The Government of Canada has proposed its pan-Canadian approach to pricing carbon pollution. Under the new plan, all Canadian jurisdictions will have carbon pricing in place by 2018. In order to accomplish this, Canada will set a benchmark for pricing carbon emissions—set at a level that will help Canada meet its greenhouse gas emission targets, while providing greater certainty and predictability to Canadian businesses.

Provinces and territories will have flexibility in deciding how they implement carbon pricing: they can put a direct price on carbon pollution or they can adopt a cap-and-trade system.

Pricing carbon pollution will give Canada an edge in building a clean-growth economy; it will make Canadian businesses more competitive; it will bring new and exciting job prospects for middle class Canadians; and it will reduce the pollution that threatens our clean air and oceans.

“Pricing pollution is one of the most efficient ways to reduce greenhouse gas emissions and to stimulate innovation,” said Catherine McKenna, minister of Environment and Climate Change. “Already 80 percent of Canadians live in a province where there is pollution pricing. We want to continue this trend and cover the final 20 per cent.”

Pricing will be based on greenhouse gas emissions and applied to a common and broad set of sources to ensure effectiveness. The price on carbon pollution should start at a minimum of $10 per tonne in 2018 and rise by $10 a year to reach $50 per tonne in 2022. Revenues from carbon pricing will remain with provinces and territories of origin.

Provinces and territories will use the revenues from this system as they see fit, whether it is to give it back to consumers, to support their workers and their families, to help vulnerable groups and communities in the North, or to support businesses that innovate and create good jobs for the future.

The overall approach will be reviewed in 2022 to ensure that it is effective and to confirm future price increases. The review will account for actions by other countries.

January 7, 2017 Posted by | Canada, climate change | Leave a comment

Cry from soldier, unrecognised victim of depleted uranium radiation

Depleted uranium, used in some types of ammunition and military armour, is the dense, low-cost leftover once uranium has been processed….

A high-ranking official from Veterans Affairs says a handful of vets mistakenly believe their bodies have been damaged by depleted uranium…..

the Federal Court of Canada has found depleted uranium to be an issue.  The court ruled the Veterans Affairs Department must compensate retired serviceman Steve Dornan for a cancer his doctors say resulted from exposure to depleted uranium residue.

text-from-the-archivesPoisoned soldier plans hunger strike at minister’s office in exchange for care, Montreal Andy Blatchford, The Canadian Press, 30 Oct 11,  MONTREAL — An ex-soldier who says he was poisoned while serving overseas is planning to go on a hunger strike outside the office of Canada’s veterans affairs minister until he gets medical treatment.

Or until he dies.

Continue reading

December 26, 2016 Posted by | Canada, depleted uranium, health, PERSONAL STORIES, Uranium | Leave a comment

Indigenous leaders excluded from Canada’s climate talks

Indigenous leaders shocked, again, by repeated exclusion from Trudeau’s climate talks, National Observer  December 16th 2016 After excluding them from a critical discussion on indigenous people and climate change earlier this year, both the Native Women’s Association of Canada (NWAC) and the Congress of Aboriginal Peoples (CAP) hoped it was a mistake Prime Minister Justin Trudeau would not repeat.

December 21, 2016 Posted by | Canada, indigenous issues | Leave a comment

Cheap and dangerous nuclear cleanup in Winnipeg?

Cheap nuclear ‘cleanup’ dangerous By: Dave Taylor 12/15/2016  Just as Manitobans were beginning to think the toxic mess at Whiteshell Laboratories in Pinawa would soon be moved off-site and the lands returned to their natural state, we now learn the federal government has given the Canadian Nuclear Labs (CNL) free rein to cheap out on the cleanup.

The most striking part of the plan to entomb the defunct WR1 reactor is that the cement or grout they are developing to seal it will break down well before the rotting hulk is safe. According to CNL officials who have relied on international research findings, “initial chemical degradation of grout is modelled to begin around 350 years,” well short of the thousands of years for which this sarcophagus will be toxic to all living things.

Since CNL are just the contractors responsible for the immediate decommissioning, long-term monitoring is beyond the scope of their work and it will ultimately be left to future Manitobans. Sure, it would cost the federal government four times as much to dismantle it now, but imagine the costs for our distant descendants who will have to deal with radioactive groundwater leaking into the Winnipeg River from a crumbling block of poisonous concrete several generations in the future.

Due to a very serious accident at the reactor in 1978, it is likely far more radioactive than it would normally be. The radiological report on that accident has not been made public, but when a pump failed, the geiger counters were going off at 3 million counts-per-minute, and a worker in protective clothing using a safety rope had to descend through a hatch to close valves with a hand-wheel as the fuel rods in the core of the reactor became damaged. It is an accident that remains shrouded in secrecy. This has become part of the unsustainable 50-year legacy that the nuclear industry has left us.

Two decades ago, Canada’s nuclear crown corporation, Atomic Energy of Canada Ltd., conducted similar “grout” research for the purpose of disposing of high-level radioactive waste in the Canadian Shield and started building a “test facility” at Lac du Bonnet called the Underground Research Lab. The objective of this plan was to seal off huge mine shafts with “bentonite grout” and entomb high-level radioactive waste from reactors across Canada and potentially from around the world. The lab leaked like a sieve as groundwater poured into the shaft, confirming that groundwater is almost unstoppable. Manitobans realized the folly in this idea and lobbied for the enactment of the High Level Radioactive Waste Act, which is still the law in our province.

And just where does our provincial government sit on this ill-conceived plan? Local politicians have remained incredibly silent on this issue, yet the act clearly states that any radioactive waste with levels comparable to spent fuel cannot be disposed of in this province, period. It also states clearly that in the case of a corporation, “a fine of not more than $1,000,000 for each day that the offence continues” will be levied.

Cathy Cox, our minister of sustainable development, has a responsibility to get the straight goods on how tainted this reactor is and to enforce the laws of our land, because, as the saying goes, “we do not inherit the earth from our ancestors; we borrow it from our children.”

Dave Taylor is an instructor at the University of Winnipeg, and has been a watchdog of the nuclear industry for over 40 years.

December 19, 2016 Posted by | Canada, safety, wastes | Leave a comment

A high school protest led to stopping Quebec’s uranium industry

How a high school student helped block Quebec’s uranium industry Financial Post, Damon van der Linde, Dec. 15, 2016, MISTISSINI, Que. — Hunting grouse on a snowy road that cuts through the forest north of his home in the Cree community of Mistissini, Justice Debassige reflects on why, as a 17-year-old high school student in 2012, he started a petition against a uranium exploration project 215 kilometres away.

“I read research on how it damages the land and the water, so that was what drew me in,” he said, while searching for birds down the road towards the now-shuttered site owned by Boucherville, Que.-based Strateco Resources Inc. “It’s something to really think about when we’re out here.”

Debassige said he couldn’t have imagined at the time that his petition would be the catalyst for a complete moratorium against exploration of the radioactive mineral across Quebec, result in a $200-million lawsuit by Strateco Resources against the government and pit the federal nuclear safety agency against a provincial environmental commission.

But it did, and The Matoush Project — named after the Cree family that traditionally use the land for hunting, fishing and trapping — in northern Quebec’s Otish Mountains has lost its glow…….

Debassige and two other classmates collected about 200 signatures from students and staff in opposition to the project, which caught the attention of Shawn Iserhoff, Mistissini’s youth chief at the time. He raised the concerns with the Mistissini Band Council and in the spring of 2012, Strateco arranged two days of hearings in the community………

“The traditional Cree way of life is based on the land,” said Thomas Coon, former president of the Cree Trapper’s Association, in an office that has a map showing how the entire vast territory is covered by family trap lines that are passed down through generations.

“As much as possible we try to avoid any dangerous, damaging project. With uranium, it’s damage that can never be repaired.”…….

As Strateco’s stock plummeted, anti-uranium activism grew in both the Cree and environment organizations. A group of Cree youth garnered media attention in late 2014 by walking 850 kilometres from Mistissini to Montreal and the movement also drew support from the global anti-nuclear activists. ……. the MiningWatch Canada advocacy group argues uranium’s current lack of social acceptability is based on the long-term risks of storing millions of tonnes of the radioactive mining waste.

“If the industry can show that they can handle the waste with a risk factor that is acceptable, maybe the social acceptability will change in the future, but at the moment it’s not there,” said Ugo Lapointe, spokesperson for MiningWatch in Quebec………

Debassige, now 22, won a Nuclear-Free Future Award in 2015 on behalf of the Mistissini youth for his efforts against uranium development on Cree land. Today, bringing home two birds he shot for his family’s dinner, he still doesn’t think the potential economic benefits of uranium mining are worth risking what he and his community already have.

“There’s vast open space where I can possibly one day teach my children what my father taught me: how to survive out on the land,” he said. “We’re connected to the land spiritually, physically, mentally and emotionally.”

December 16, 2016 Posted by | Canada, indigenous issues, opposition to nuclear | Leave a comment

No need for a nuclear reactor to produce medical isotopes: Canada shows the way.

14 September 2016. A consortium of institutions led by TRIUMF, Canada’s national laboratory for particle and nuclear physics and accelerator-based science, is granting sole rights for its proprietary technetium-99m (Tc-99m) production technology to ARTMS™ Products, Inc (ARTMS). Technetium-99m is used in over 80% of all nuclear medicine imaging procedures and is vital to patient care in areas such as cardiology, oncology, and neurology. …

text Medical isotope production

Typically sourced from an ageing global reactor fleet, Tc-99m has been subject to significant supply disruptions in recent years. ARTMS’ production technology promises to provide a reliable, cost effective, and safe supply of this critical medical isotope. The license includes all the required products and procedures for the production of Tc-99m using common hospital-based and commercial cyclotrons, through the bombardment of a high-energy proton beam against specific chemical ‘targets’. ….

“The ARTMS production technology offers many advantages, and that is why we believe our technology is truly disruptive and that it will gain widespread adoption,” Dr. Schaffer added. “Not only does the ARTMS production technology provide regional supply security of Tc-99m, it also offers favourable economics, and aids to eliminate the need for highly-enriched uranium, which is currently used by nuclear reactors to produce this isotope.”

“This agreement represents the culmination of six years of hard work by a dedicated team from across Canada, including TRIUMF, the BC Cancer Agency, Lawson Health Research Institute, and the Centre for Probe Development and Commercialization,” said Dr. Jonathan Bagger, Director of TRIUMF. “Today marks the completion of a major milestone as we move to commercialize a decentralized, green, and Canadian-made, technology that can produce Tc-99m daily at hundreds of hospital-based cyclotrons around the world. This licensing agreement marks the beginning of a new era in Tc-99m production and supply security.”

More information on the recent global isotope shortages, Tc-99m, and the story of ARTMS can be found in this media backgrounder and more information on medical isotopes and cyclotrons can be found in this FAQ.

December 2, 2016 Posted by | Canada, health, radiation, Reference | Leave a comment

Savannah River Site could be stuck with stranded nuclear wastes from Canadian research reactor

stranded“We are concerned that DOE is planning to bring more HEU-related waste to SRS over the coming years, with no plan for their removal from South Carolina and without the public being properly informed about these waste-imports and long-term storage and disposition plans,”

Shipments of nuclear material to Savannah River Site could continue 
By Thomas Gardiner Nov 18, 2016 

Spent fuel from a research reactor at the University of Alberta in Canada could soon be en route to South Carolina’s Savannah River Site.

According to documentation provided by the Nuclear Regulatory Commission, shipping casks for the transfer are being reviewed and a planned shipping route has been approved.

radiation-truckThe exact route through the U.S. begins at the Sweet Grass, Montana, border crossing, and ends near Aiken County at the Savannah River Site. According to Nuclear Regulatory Commission spokesperson Roger Hannah, actual routes are not publicized because of security concerns. However, the journey from Sweet Grass to Aiken County is close to 2,300 miles along major U.S. highways, depending on which cities the route goes through.

The spent fuel is U.S.-origin, highly-enriched uranium. It was used for research in a reactor called a “safe low-power kritical experiment,” or SLOWPOKE reactor. In the documents related to the shipping cask review, the SLOWPOKE reactor core is also included in the review.

The Department of Energy has shipped SLOWPOKE reactor cores in the past, with one now residing at Savannah River Site’s L-Basin.

Tom Clements, director of SRS Watch, said in a release, “In September 2015, a SLOWPOKE core was shipped from Jamaica to SRS, where it is now stored with no long-term disposition plans.”

The new material also would be destined for L-Basin. However, with the scrapped Yucca Mountain project and the backlogged waste isolation pilot plant, or WIPP, it is unclear what pathway exists to get the material back out of South Carolina. In multiple conversations about nuclear material coming into the Palmetto State, Gov. Nikki Haley has repeatedly said she refuses to let South Carolina becoming a nuclear dumping ground.

“We believe it is prudent to halt to shipment of HEU-bearing waste to SRS until such time as a plan is presented for removal of such waste from the site,” Clements said.

“We are concerned that DOE is planning to bring more HEU-related waste to SRS over the coming years, with no plan for their removal from South Carolina and without the public being properly informed about these waste-imports and long-term storage and disposition plans,” he said.

According to NRC documents, cask approval could come in March 2017. If that approval is issued, the material could hit the road in 2018. That timeline matches up with presentation given to the Citizens Advisory Board early this year, that showed shipments from Alberta, Canada, expected in 2018.

The route was approved Nov. 9 and won’t expire until Dec. 31, 2021.

November 23, 2016 Posted by | Canada, USA, wastes | Leave a comment

Canadian government to review plan to dump nuclear waste close to Great Lakes

“No matter what process is followed, burying and abandoning radioactive nuclear waste in the Great Lakes Basin will always be a bad idea”  “The Trudeau government’s environmental credibility is on the line.” 


Ottawa to hold public review of new material on proposed nuclear waste dump
OPG to submit information to Canadian government in December 
By Jim Bloch For The Voice, 20 Nov 16  Next month, Ontario Power Generation will submit to the Canadian government new information about its proposed Deep Geological Repository for low- and intermediate-level nuclear waste.

The Canadian Environmental Assessment Agency announced the submission goal in October.

“OPG has stated that it intends to submit the requested information in December 2016,” said the CEAA in a public announcement on Oct. 25.

 OPG’s submission will contain new details about alternative locations for the DGR, an analysis of the cumulative effects the dump could have on the environment and an updated list of OPG’s commitments to reduce “each identified adverse impact” of the DRG.

Canadian Minister of the Environment and Climate Change Katherine McKenna had been expected to make a decision on the dump, proposed for the shore of Lake Huron in the Ontario municipality of Kincardine, by March 1 of this year. Instead. McKenna made her request for more information on Feb. 18……. Continue reading

November 21, 2016 Posted by | Canada, politics, wastes | Leave a comment

Canada’s navy to investigate object found off B.C. coast -Lost Cold War nuclear weapon?

UFO? Lost Cold War nuclear weapon? Canada’s navy to investigate object found off B.C. coast  Army records indicate diver may have found bomb lost by the U.S. Air Force in 1950

Lost Nuke: The Last Flight of Bomber 075 book trailer

By George Baker, Andrew Kurjata, CBC News Posted: Nov 04, 2016 The Royal Canadian Navy is sending a ship to determine if a diver has discovered “the lost nuke” — a Mark IV bomb that went missing after a U.S. bomber crashed off B.C.’s North Coast in the early days of the Cold War.

Sean Smyrichinsky found the mystery object during a recent diving trip near Banks Island. “I got a little far from my boat and I found something that I’d never ever seen before,” he recalled. “It resembled, like, a bagel cut in half, and then around the bagel these bolts molded into it.”

When he got back to the ship he tried to describe the object to his crew.

“I came out from the dive and I came up and I started telling my crew, ‘My god, I found a UFO. I found the strangest thing I’d ever seen!'”

The ‘lost nuke’

Smyrichinsky started asking around and was told the story of Convair B-36B, a U.S. Air Force bomber that crashed off B.C. in 1950. In a book published earlier this year, historian Dirk Septer traces the story of that flight, summarizing it in publicity documents as a Cold War drama:

“Just before midnight on February 13, 1950, three engines of a US Air Force B-36 intercontinental bomber caught fire over Canada’s northwest coast. The crew jumped, and the plane ditched somewhere in the Pacific Ocean. Almost four years later, the wreck of the bomber was found accidentally in a remote location in the coastal mountains of British Columbia, three hours’ flying time in the opposite direction of where it was supposed to have crashed.

“After years of silence, the United States finally admitted to losing its very first nuclear bomb; the incident was its first Broken Arrow, the code name for accidents involving nuclear weapons. But was the bomb dropped and exploded over the Inside Passage, or was it blown up at the aircraft’s resting place in the mountains?”

The lost bomb was a Mark IV. As soon as Smyrichinsky looked it up on Google Images, he recognized it as the object he had found.

“It was a piece that looked very much like what I saw,” he said. “The plane that was carrying the bomb, it crashed 50 miles south of where I found that object.”

“What else could it possibly be? I was thinking UFO, but probably not a UFO, right?”

Probably not nuclear

Major Steve Neta of the Canadian Armed Forces confirmed the location of Snyrichinsky’s find does coincide with the site of the 1950 crash.

Neta also said records indicate the lost bomb was a dummy capsule, and so there is little risk of the object being a nuclear weapon.

“Nonetheless, we do want to be sure and we do want to investigate it further,” he said. To hear Sean Smyrichinsky describe finding the object, click on the audio labeled ‘A discovery off B.C.’s north coast possible missing relic of Cold War‘.

November 5, 2016 Posted by | Canada, weapons and war | Leave a comment

Canadian nuclear safety official in bed with nuclear industry?

in-bedflag-canadaCritics accuse nuclear safety official of acting as industry cheerleader GLORIA GALLOWAY OTTAWA — The Globe and Mail, Oct. 12, 2016 Opposition politicians and environmentalists are questioning the priorities of the man responsible for nuclear safety in Canada after a string of incidents in which he publicly defended the industry and was dismissive of concerns about potential hazards – a stance that runs contrary to his mandate at the Canadian Nuclear Safety Commission.

October 14, 2016 Posted by | Canada, secrets,lies and civil liberties | Leave a comment

Canadian Nuclear Safety Commission Finds Flaws in Canada’s Nuclear-Safety Practices

Watchdog Finds Flaws in Canada’s Nuclear-Safety Practices Audit recommendations focus on documenting and on conducting site inspections WSJ, PAUL VIEIRA Oct. 4, 2016  OTTAWA—Canada’s nuclear-safety regulator is facing criticism from the country’s environmental watchdog for failing to prove it conducted adequate power-plant inspections and falling short on staffing levels.

The shortcomings were highlighted in an independent audit released Tuesday by the Canadian Nuclear Safety Commission, which is tasked with ensuring the country’s nuclear power plants are operating safely……

Canada’s commissioner of the Environment and Sustainable Development looked at the nuclear agency’s operations over a two-year period ended March 31, 2015, and focused on whether the regulator adequately managed its site inspections.

“We concluded that the (Canadian Nuclear Safety Commission) could not show that it had adequately managed its site inspections of nuclear power plants,” Commissioner Julie Gelfand wrote. The audit issued five recommendations for the regulator to improve operations, focused largely on documenting and conducting site inspections……

October 5, 2016 Posted by | Canada, safety | Leave a comment

Forest fire risk in Canada much greater due to climate change

wildfire-nukeChanging climate is raising forest fire risk, says NRCan annual report, Vancouver Sun BRUCE CHEADLE September 28, 2016 OTTAWA — A new government report says that by the end of this century, a changing climate is expected to at least double the area burned each year by forest fires in Canada.

September 30, 2016 Posted by | Canada, climate change | Leave a comment