Featured post

3 Editorials from Reactor Community Newspapers

There have been three editorials from nuclear reactor community newspapers that really stand out (two recent & one from two years ago), and that citizens & politicians in Durham Region need to keep in mind.

All three reference the need to plan appropriately for nuclear emergencies in Durham, home to not just one, but two gigantic nuclear generating stations.

Here are the editorials, with the most recent at the top:

1. May 28, 2014   [Durham Region. Com] – from Pickering News-Advertiser May 28/14.

Getting the message out in Durham on nuclear safety

If a sampling of residents is any indication, there would be chaos in Durham Region in the unlikely chance of a serious nuclear incident in Pickering or Darlington.

The news comes amidst a multi-agency mock nuclear emergency exercise taking place over three days this week to test preparedness among those responsible for dealing with an emergency.

It also comes just a few weeks after a new nuclear emergency kit — featuring easy-to-read binder pages and a pinpoint LED flashlight — was distributed to more than 200,000 households (at a cost of $3 each) within a 10-kilometre radius of Durham Region’s nuclear plants.

But the results of an Ontario Power Generation focus group obtained by Greenpeace Canada clearly indicate that despite efforts at outreach and community engagement by Durham’s nuclear operator, a frightening number of the region’s residents remain completely unaware of what they should do in a worst-case nuclear scenario. The report concludes there are “very low levels of awareness” among residents living closest to Durham’s two nuclear generating stations.

One resident indicated she would try to get to Toronto in a nuclear accident; a mother in Pickering said she would want to retrieve her children from school.

Each of those, depending on the circumstance, might be precisely the wrong thing to do, based on protocols laid out in established monitoring and evacuation directives.

This study shows rather clearly that even though OPG has lived up to its obligations to regularly provide information related to nuclear incidents, it hasn’t had much success in ensuring that the information it provides is being retained, let alone perused by residents. It is on this basis that OPG must move to develop a mechanism to more effectively measure and manage the success and retention of such important information for residents. Residents, too, have a responsibility to become informed, for their own and their family’s sakes.

Nuclear power is here to stay as a source of energy generation in Ontario and OPG has a solid record of safely and professionally operating its reactors in Durham Region. But there are well known and serious risks associated with accidents.

The lesson here is that it’s not enough to assemble, package and distribute important information without accompanying oversight and follow up with the recipients. Durham Region, as the entity responsible, is obliged to ensure that the information it provides is meaningful to residents, that they are aware and informed, and that they know their role in an emergency.

– Metroland Media Group Ltd., Durham Region Division … Editor’s note: The story was amended May 29 to note that Durham Region is responsible for emergency preparedness.

2. May 21, 2014
Nuclear ruling presents an opportunity in Durham — Clarington This Week

A federal court ruling that orders more environmental study before new nuclear reactors can be built at Darlington must be viewed positively.

The ruling is a victory for Greenpeace and other environmental organizations that challenged a separate federal review panel’s earlier recommendation for approval of the new build at Darlington. The May 14 ruling by Justice James Russell orders more study of hazardous substance emissions, the proper handling of nuclear waste and more detailed analysis of how the site’s operators would deal with a severe accident.

Referred to by Greenpeace’s Shawn-Patrick Stensil as a “common-sense ruling”, it effectively puts the ball back in play for Ontario Power Generation to determine its next steps. OPG’s Neal Kelly said the company must first fully review Justice Russell’s ruling before deciding how to proceed.

It’s not likely that OPG will simply abandon its plans for the new build at Darlington. A huge investment of time, money and human resources have already been spent in preparing the site for the environmental assessment approved by the federal panel. Additional study will cost more, certainly, but will also dig deeper into identifying methods and processes to address the areas flagged by Justice Russell in his ruling.

In the aftermath of the Fukushima disaster in Japan, manageable plans for nuclear emissions, waste storage and, especially, the emergency response to a severe accident are vitally important to Durham Region residents.

So, though the legal ruling represents a setback for advocates of the new build who have been working hard in recent years to see it move forward, it also represents for the larger community one more hard and close look at ways to mitigate the impact on the natural environment and more detailed response plans should the worst happen.

We call on OPG to accept the ruling and work quickly to address the gaps Justice Russell has identified in the existing environmental assessment, move forward in creating detailed plans for emergency response and clear this vitally important step.

The new build isn’t going to happen any time soon given Ontario’s current long-term energy plan. Still, addressing all the issues identified today will allow OPG officials to hit the ground running when the decision comes.
– Metroland Media Group Ltd., Durham Region Division

3. Hoping for the best, preparing for the worst in Clarington
Clarington This Week editorial [September 20/12]

http://www.durhamregion.com/opinion/editorial/article/1504692–hoping-for-the-best-preparing-for-the-worst-in-clarington [link is now defunct]

Be prepared.

That universally recognized motto of the Scout movement must also guide nuclear experts as they work towards extending the life of Clarington’s Darlington Nuclear Generating Station to 2055.

A federal environmental assessment is currently underway as part of the long-term nuclear refurbishment program at Ontario Power Generation’s Darlington site and members of the public are encouraged to take part in some upcoming hearings to share their views.

As part of the ongoing process, some local groups, led by the Canadian Environmental Law Association, have raised timely concerns about the site’s and the community’s preparedness should a nuclear emergency occur.

Specifically, CELA is calling for a much wider scope of preparation for a large-scale nuclear emergency, unlikely as that may be. Theresa McClenaghan, executive director of CELA, noted recently that most nuclear emergency response plans at Darlington are based on site-contained incidents that wouldn’t pose a threat beyond the nuclear facility.

And the spectre of Japan’s Fukushima nuclear emergency and evacuation following the earthquake and tsunami continues to cast a shadow on nuclear power generation around the world. Though our geology differs and there is a minuscule chance of a similar occurrence in Durham Region, the point of preparedness is to have a response plan in place for multiple emergency scenarios.

In that context, CELA’s call for a detailed emergency plan for potential incidents such as a large radiation release that would require evacuation in a 20-kilometre radius makes sense.

It doesn’t mean that there is an expectation that such an incident would occur, but would provide a more robust and effective emergency plan for OPG officials, municipal leaders and everyday citizens to respond.

For their part, OPG officials say the current focus is on “credible” disasters, those that would be expected here at home. That is as it should be, at a minimum. But there is no harm in examining and preparing for less “credible” emergency incidents.

Any resistance to such a notion is akin to automotive manufacturers in the past resisting the installation of seat belts in automobiles lest they be viewed by consumers as unsafe.

The human and economic cost of an uncontained nuclear incident would be exponentially greater if there are no processes or plans in place for the unlikely, for the unexpected, for the incredible emergency.

A plan that explores and prepares for the widest possible spectrum of potential emergencies must be assembled.

Featured post

Emergency Planning: DNA Letter to Durham Regional Council

<DNA Logo>

May 27, 2014.

Re: Emergency Planning in Durham Region

Durham Region Councillors & Regional Chair:

We are deeply concerned that Durham Region is unprepared to adequately protect its citizens in the event of a major accident at the Pickering or Darlington nuclear stations.

Durham Nuclear Awareness (DNA) asks you as our regional representatives to take action to actively engage the citizens of Durham Region to ensure that our off-site nuclear emergency plans are designed to:

• protect the public in the event of a major accident
• meet international best practices, and further and very importantly
• be understood by the citizens of Durham Region.

As you may know, Ontario Power Generation (OPG) is cooperating with an array of regional, provincial and federal agencies to conduct a three-day emergency exercise at the Darlington Nuclear Generating Station between May 26th and 28th.

While somewhat useful, we worry this may be used as a public relations exercise to paper over the lack of public review of our nuclear emergency plans since the Fukushima accident in 2011.

DNA members have been calling on our federal, provincial and municipal authorities to publicly update our off-site nuclear emergency plans since 2012.

We have repeatedly stated that the planning basis for current off-site emergency plans addresses only small-scale accidents. This leaves Durham Region unprepared for a major accident at Darlington or Pickering.

To be better protected, we need to update the planning basis of our off-site emergency plans to address major accidents. Changing this key assumption will impact the scale and scope of the protective measures that need to be in place.

DNA members have raised this concern with the Canadian Nuclear Safety Commission (CNSC) – both during the public review of OPG’s proposal to extend the life of the Darlington nuclear station in 2012 – and again at the relicensing hearings of the Pickering nuclear station in 2013, but our concern has not been addressed.

Notably, a federal court has recently validated DNA’s concerns. The Toronto Star reports that Justice James Russell found the federal panel that reviewed OPG’s proposal to build new reactors at Darlington “…should have done more analysis of the possibility of an unlikely but catastrophic accident at the nuclear site…The accident risk should be weighed while the decision is still in the hands of the politicians, he ruled, not left solely to regulatory authorities.”1

Judge Russell’s ruling highlights an important weakness of emergency preparedness in Durham Region: OPG and government agencies have for too long failed to consider the impacts of major accidents. As a result, public and elected officials are deprived of the information necessary to make the decisions needed to better protect the public.

All this is to say, DNA is concerned that our government authorities have become complacent. We write to you now because we feel these authorities require firm direction and scrutiny from Durham Region’s democratically elected representatives.

DNA has also repeatedly raised concerns about inadequate emergency planning at meetings of the Durham Nuclear Health Committee (DNHC), but have seen no meaningful response.

Citizens in Durham Region (and the surrounding Greater Toronto Area, which also stands to be much affected in the event of a serious accident at either of Durham’s nuclear plants) deserve reassurance that plans for a nuclear emergency in the shadow of Pickering and Darlington will be reviewed and meet international best practices.

We should not pretend a major nuclear accident cannot happen here.

As Toshimitsu Homma of the Japan Atomic Energy Agency stated at an April 2013 international conference on Emergency Management held in Ottawa, the most important lesson of Fukushima was that before the accident, “There was an implicit assumption that such a severe accident could not happen and thus insufficient attention was paid to such an accident by authorities.”

DNA urges you to publicly review and consult on the adequacy of our off-site nuclear plans by engaging Durham citizens in a public discussion on these matters affecting public health and safety. DNA members would be happy to meet with any of you to discuss this further.

Respectfully submitted,

Janet McNeill
On behalf of Durham Nuclear Awareness (DNA)

1 Cited in John Spears, “New reactor plan needs more work, court tells OPG,” the Toronto Star, May 15, 2014.

Cc.
• All municipal Councils in Durham Region
• Durham Emergency Management Office (DEMO)
• Durham Nuclear Health Committee (DNHC)
• Emergency Management Ontario, Ministry of Community Safety & Correctional Services
• Provincial MPPs
• Joe Dixon (Ajax-Pickering)
• John O’Toole (Durham)
• Helena Jaczek (Oak Ridges-Markham)
• Jerry Ouellette (Oshawa)
• Tracy MacCharles (Pickering-Scarborough East)
• Bas Balkissoon (Scarborough-Rouge River)
• Christine Elliott (Whitby-Oshawa)

Featured post

Emergency Planning in Durham Region: Media Summary

It’s been quite the week for media coverage of the Durham Region nuclear scene & the nuclear industry’s emergency planning (or lack thereof) for the Pickering & Darlington nuclear generating stations.

Here is a summary of the coverage I have seen. Most recent is at the top. If you want to read them chronologically, read from the bottom up.

Nuke you, Toronto
With new reactors on hold, it’s time to address the lack of a safety plan in case of a Fukushima-like event

Blog Posting from CELA – Canadian Environmental Law Association Nuclear Emergency Planning Exercise at Darlington Message to Public: Trust Us

Getting the Message Out in Durham on Nuclear Safety

Darlington nuclear plant undergoing drills that doesn’t involve public | CityNews

Durham site of large nuclear emergency exercise — More than 50 federal, provincial, regional, local organizations involved

Awareness of emergency plans near Pickering, Darlington nuclear plants ‘very low’ — Ontario Power Generation under pressure to provide more information to residents as three-day mock emergency begins Monday

Featured post

Pickering Relicensing Hearing: 7 Key Submissions

** Important! The transcript of the hearing is now available on the CNSC (Canadian Nuclear Safety Commission) Web site, here.

7 Heavy-Duty Submissions to Canadian Nuclear Safety Commission Pickering Relicensing Hearing (May 7/14.)

** Click on each person’s name to see her/his submission.

Dr. Gordon Edwards of the Canadian Coalition for Nuclear Responsibility (CCNR) warns the Great Lakes could be seriously contaminated by a Pickering nuclear accident, given the problems with enormous volumes of radioactive water leaking from Fukushima. He cites Hydro-Québec President Thierry Vandal’s 2013 testimony in Québec’s National Assembly: “I would no more operate Gentilly-2 beyond 210,000 hours than I would climb onto an airplane that does not have its permits and that does not meet the standards. So, it is out of question for us to put anyone – i.e. us, the workers, the public, or the company – in a situation of risk in the nuclear domain. So this deadline of 210,000 hours, this is a hard deadline.’’ Dr. Edwards remarks that at public hearings CNSC senior staff always seems to support the licensee, never asking them hard questions: “It almost seems like a tag-team effort – whatever one party says, the other party promptly reinforces.” Edwards also deplores the fact that the CNSC disregards constructive suggestions aimed at reducing the nuclear risk by Dr. Sunil Nijhawan and Dr. Frank Greening, nuclear reactor specialists with over 20 years of experience in the nuclear safety field.

Dr. Michel Duguay holds a PhD in nuclear physics from Yale University and is a professor in the Department of electrical and computer engineering at Laval University. Duguay argues that OPG and CNSC staff are not in full compliance with Article 9 of the Nuclear Safety and Control Act (NSCA) of 1997. On 1 August 2013, in a letter to Honorable Joe Oliver, Duguay and 15 cosigners argued that the annual probability of a severe accident in the greater Toronto area is 100 times larger than the probability of a frequent flyer dying in a commercial airline flight. This situation does not comply with article 9(a) of the Act. Moreover article 9(b) is not complied with because OPG and CNSC do not inform the public in an objective scientific manner about the uncertainties that accompany their calculations of reactor accident probabilities. Duguay points out that OPG & CNSC do not have all the necessary information. For example, many of the hundreds of high-pressure “feeder pipes” have not been inspected, although it is known that corrosion could cause them to rupture, triggering a nuclear emergency. Neither OPG nor CSNC can give scientific information on those non-inspected feeder pipes because they do not have it.

Dr. Frank Greening senior research scientist retired from OPG, explained in his submission that OPG has used fault-tree software to carry out its “Probabilistic Risk Assessments (PRAs),” but has failed to disclose the methodology used to estimate the numerical inputs, to validate the computer programs and to quantify the many large uncertainties in the analysis. Moreover OPG did not disclose its new PRAs (obtained with post-Fukushima enhancements) until 29-30 April, seven days after the deadline for public intervention, and seven days before the May 7 public hearing. This is clearly unacceptable to anyone outside OPG who wishes to provide input into an informed decision on the continued operation of Pickering NGS – and this evidently includes the Commissioners themselves – thereby undermining the rationale for holding Public Hearings.

Theresa McClenaghan, representing the Canadian Environmental Law Association (CELA), filed her May 2013 paper titled “Emergency Planning at the Pickering Nuclear Generating Station.” She argues that previous experience with the Chernobyl and Fukushima nuclear catastrophes shows that wide-ranging measures must be taken by municipalities and by the Province of Ontario in order to protect the health of citizens in case of a severe nuclear accident releasing large quantities of radioactive elements. Both OPG and the CNSC now acknowledge that such accidents could take place. CELA argues that the combined population of Pickering and neighboring cities, including Toronto, is so huge that a large-scale evacuation could not be carried out quickly enough to ensure adequate protection of men, women and children. Theresa McClenaghan states: “CELA recommends to the CNSC that it deny its operating licence to operate the Pickering reactors beyond their design life unless and until serious, capable, detailed offsite emergency planning for catastrophic accidents is finally in place.”

Chris Rouse, representing New Clear Free Solutions, is an Engineering Technologist with a keen eye for details. He argues that the PRA methodology used by OPG and accepted by CNSC Staff is not following best practice, or even the guidance documents referenced in OPG’s licence. He says OPG is dodging its responsibility for making a number of important safety improvements, such as installing a filtered vent – as other Canadian reactors have done – capable of filtering out 99% of the radioactivity in the event of a severe accident. As Rouse notes, Canada has an international obligation under the UN Convention on Nuclear Safety to either make improvements or shut the reactors down when safety limits are not met. Rouse highlights safety culture issues within CNSC and OPG similar to the institutional deficiencies that led to the Fukushima disaster.

Shawn-Patrick Stensil, spokesman for Greenpeace, filed a paper entitled “An Inconvenient truth: Pickering Exceeds Safety Limits.” Last year Stensil and other interveners convinced the CNSC Commissioners to suspend consideration of OPG’s request unless a convincing safety case can be presented at the May 7 Hearing. One year later, Stensil argues that OPG is still unable to satisfy basic safety criteria and strongly underestimates the probability of a severe nuclear accident that would release large amounts of radioactive elements into the environment. He urges the Commissioners to act in a precautionary manner by not allowing these six reactors to operate beyond the 210,000 hours that had been previously established as a safety limit.

Anna Tilman, representing the International Institute of Concern for Public Health (IICPH), in a paper reviewed by Dr. Gordon Albright, documents several technical problems of the CANDU reactors that could initiate a severe nuclear accident if the 210 000 hour limit is exceeded. Corrosion problems plague the many kilometers of pipes needed to cool the reactors. IICPH points out that OPG’s probabilistic risk assessment (PRA) calculations are of dubious validity because of the large uncertainties associated with corrosion. The paper concludes: “Ignoring the potential risks of a major accident is contrary to the precautionary principle, which requires a project to err on the side of caution, especially where there is a large degree of uncertainty, or the risk of very great harm. To risk the mass destruction of people, property, and the natural environment that a serious accident at Pickering would cause, is completely unacceptable.”

** note: Dr. Edwards has issued an amended statement:

Opposition Grows to ‘Nuclear Gambling’ at Pickering
Correction re. Argentina’s “Embalse” reactor

In a recent CCNR e-mail posting on May 6, 2014, entitled “Opposition Grows to ‘Nuclear Gambling’ at Pickering,” it was stated that “CANDU reactors around the world — those at Bruce (8), Quebec (1), New Brunswick (1), Korea (4) and Argentina (1) — have been required to shut down permanently” before reaching 210,000 hours of full-power operation unless far-reaching safety improvements are made first, including the total replacement of all small-diameter pipes in the core cooling system.

It turns out that one of the 15 CANDU reactors referred to — the one at Embalse in Argentina — has been given permission to operate up to 220,000 hours before shutting down for a complete safety makeover (“refurbishment”), including replacing all its degraded pipes and tubes. So the sweeping statement that was made in the May 6 CCNR e-mail about ALL CANDU reactors being limited to 210,000 hours for safety reasons was incorrect; there is, in fact, one exception.

Note, however, that the extra 10,000 hours allowed to the Embalse Reactor’s operation amounts to less than one and a half extra years (actually it is one year and five months) if we assume an 80% capacity factor. And it is also important to note that complete refurbishment of the Embalse reactor is still required, and still planned, even if it is delayed by about one and a half years.

The situation is quite different with the four Pickering B reactors just outside of Toronto.

Ontario Power Generation (OPG) is asking for permission to operate these geriatric Pickering reactors until 247,000 hours, without EVER doing a refurbishment — not now, and not in the future. That extra 37,000 hours, beyond the 210,000-hour safety limit, corresponds to an extra 4 years and 3 months of full-power operation, or 5 years and 3 months of operation at 80% capacity.

OPG does not deny that a Core Damage Accident at one or more of these reactors is possible, and that a Large Release of Radioactivity in such an event is also possible, but they argue that the “probability” of such a disaster is sufficiently low that it should be permissible to “roll the dice”. (In mathematical probability theory, any probabilistic event can be simulated by rolling a sufficiently large number of dice.)

During the May 7, 2014, hearing before the CNSC, however, OPG experts were unable to demonstrate that the probability of such a disaster is actually low enough to satisfy the regulations that have been laid down for such events. Astonishingly, OPG’s experts told the Commissioners that they are confident that the probability does in fact meet those regulations, even though they are unable to carry out any analysis to verify that such is the case. Evidently OPG is drifting from a science-based approach to a hunch-based belief system. It remains to be seen whether the CNSC will allow such wooly thinking to prevail.

So the question remains. Is it worth gambling with the long-term viability of Toronto and the Great Lakes just so that OPG can keep operating these aging Pickering reactors for another few years, when there is plenty of surplus hydro-power in Quebec and Manitoba that could be purchased at less cost?

Featured post

May 7th Pickering Relicensing Hearing: details

The May 7th hearing at CNSC headquarters in Ottawa, at which Canadian Nuclear Safety Commission (CNSC) tribunal members will hear from proponent Ontario Power Generation (OPG) and CNSC staff, will not allow for members of the public to speak.

Only written submissions from the public, at this public hearing.

You can watch the hearing live, via Webcast. Go here. Agenda here.

To see the submissions from the approximately 50 individuals and organizations that have taken the time to “intervene” on this hearing, you may go to this page on the CNSC Web site, & request that submissions be sent to you via email (or in hard copy).

There are many excellent submissions, some of them from individuals whose technical understanding of nuclear complexities is both extensive and impressive.

Featured post

DNA Supplementary Submission

April 30, 2014.

Secretariat

Canadian Nuclear Safety Commission
280 Slater St., P.O. Box 1046

Ottawa, Ontario K1P 5S9.

Members of the CNSC Tribunal:

This is a supplementary submission from Durham Nuclear Awareness (DNA) regarding the Ontario Power Generation (OPG) proposal to allow the reactors at the Pickering Nuclear Generating Station to continue running beyond their planned design life.

DNA has recently learned that OPG has submitted plans to the Ontario Energy Board (OEB) regarding plans to run the Pickering reactors not just beyond 210,000 hours and up to 247,000 EFPH (Effective Full Power) hours, but up to 261,000 hours.

And, in a recent statement to a Pickering newspaper, OPG Director of Nuclear Regulatory Affairs Robin Manley stated that the pressure tubes could probably run to 300,000 hours.(1)

It appears that Ontario Power Generation has been anything but transparent about its actual plans for the aging Pickering reactors.

Not transparent with the public, who must resort to Freedom of Information requests to obtain information. Not transparent with the Council of the City of Pickering.

Perhaps not transparent with the Canadian Nuclear Safety Commission?

There is a colloquial German expression about slicing salami. Does OPG intend to keep coming back, over and over again, for another 5-year “slice?”

How far and how long will OPG staff go to keep milking this cash cow, before being reined in?

DNA Objections

We have reviewed many of the submissions CNSC has received from members of the public.

It is not “merely” “uninformed” members of the public with vague fears about the possibility of a nuclear accident on the eastern border of the City of Toronto.

CNSC has received a host of submissions that lay out a plethora of safety-related problems with the current and projected operations at the Pickering Nuclear Generating Station.

We need not repeat here the arguments about deficiencies with Probabilistic Safety Assessments, or the many technical problems and potential problems with the PNGS that have been very well and thoroughly laid out for you by technically knowledgeable members of the public.

While DNA does not profess to possess technical expertise, many intervenors do possess such knowledge. We are thankful to them for helping to further our own understanding.

And then, to repeat, there is the issue of OPG’s credibility and transparency. Or lack thereof.

Notable Comments from Other Experts

Former CNSC tribunal head Linda Keen attempted to ensure that emergency preparedness at the PNGS be closely studied and improved upon.(2) Ms. Keen was fired for her efforts to protect Canadians.

Toshimitsu Homma, a member of the Japanese delegation from the Japan Atomic Energy Agency, stated at an international conference in Ottawa in 2013 that the most notable lesson from the Fukushima disaster is that, before the accident, “There was an implicit assumption that such a severe accident could not happen and thus insufficient attention was paid to such an accident by authorities.”(3)

It is imperative that all nuclear operators and regulators learn from this experience!

Nuclear expert Arnie Gundersen recently commented in an interview, “…What part of Fukushima don’t you understand? If you don’t make the modifications [regarding safety & emergency planning] you run the risk of destroying the fabric of a country. It happened at Chernobyl, and it’s happening right now in Japan…”(4)

Finally, in the book Flirting with Disaster, author Marc Gerstein stated “… reasonable people, who are not malicious, and whose intent is not to kill or injure other people, will nonetheless risk killing vast numbers of people. And they will do it predictably, with awareness … They knew the risks from the beginning, at every stage … The leaders chose, in the face of serious warnings, to consciously take chances that risked disaster … Men in power are willing to risk any number of human lives to avoid an otherwise certain loss to themselves, a sure reversal of their own prospects in the short run.”(5)

CNSC Tribunal’s Responsibility

Members of the CNSC tribunal have been asked publicly, at a public hearing, whether any of you live near a functioning nuclear generating station. Apparently, none of you do. Does this mean that tribunal members are able to view the possibility of a nuclear accident as merely “academic”?

To the people of Durham Region, of nearby Toronto, of the entire Greater Toronto Area, in fact, such concerns are anything but academic.

The outcome for millions of people, and the drinking water supply of millions on both sides of the Canada/U.S. border, are simply unthinkable.

The dangers of pushing aging nuclear reactors beyond their design life have, as previously stated, been thoroughly laid out for you in an impressive stack of thorough, well-thought-out submissions.

Conclusion

If Hydro Québec(6), CANDU creator Atomic Energy of Canada Ltd.(7), and a long list of articulate and knowledgeable intervenors in this hearing process agree that pushing reactors beyond 210,000 hours of operational life is simply too much of a gamble, Durham Nuclear Awareness can only concur – and so must CNSC.

We reiterate our request from our original, April 22nd submission.

CNSC must act to shut down the Pickering reactors now – before there is a nuclear disaster in the Greater Toronto Area.

Sincerely,

Janet McNeill, spokesperson for
Durham Nuclear Awareness

FOOTNOTES:
1. Pickering News-Advertiser April 29/14.
2. Toronto Star March 18/11.
3. CELA Submission May 3, 2013. Page 18.
4. Interview on Fairewinds Energy Education Web site.
5. Quoted in the Greenpeace report Lessons from Fukushima, on-line here
6. “When we shut down the plant, we were almost there, within a few hours, having run the plant for 198 000 hours since the very beginning. These are the hours of operation at full power. It is a measure of ageing, if you will, of the plant components. So for how many hours could we continue to operate from a safety point of view? I can tell you that Hydro Quebec’s management in no way would have considered to go beyond 210 000 hours even if it was made possible. I would no more operate Gentilly-2 beyond 210 000 hours than I would climb onto an airplane that does not have its permits and that does not meet the standards. So it’s out of question for us to put anyone, i.e., us, the workers, the public and the company in a situation of risk in the nuclear domain.” — Thierry Vandal, Jan. 29/2013, head of Hydro Québec, quoted in Michel Duguay submission to Pickering NGS relicensing “hold point” hearing, Pg. 14.
7. Frank Greening submission to Pickering NGS relicensing “hold point” hearing, March 5, 2014, Pg. 6.

Featured post

DNA Submission on Pickering “Hold Point” Hearing

April 22, 2014.

Secretariat

Canadian Nuclear Safety Commission
280 Slater St., P.O. Box 1046

Ottawa, Ontario K1P 5S9.

Members of the CNSC Tribunal:

This is the written submission from Durham Nuclear Awareness (DNA) regarding the Ontario Power Generation (OPG) proposal to allow the Pickering Nuclear Generating Station reactors to continue running beyond their planned design life.

Durham Nuclear Awareness

    DNA is a small Durham Region citizens’ group that works to help fellow Durham Region residents understand issues surrounding the continued operation of Durham’s nuclear generating stations. DNA has made interventions at CNSC licensing hearings for both Pickering and Darlington NGS, and also on the Deep Geologic Repository project proposed for the community of Kincardine, on Lake Huron.

    Pickering Relicensing Hearing – 2013

    In 2013 DNA received funding from CNSC and hired as an expert Fairewinds Associates Chief Engineer Arnie Gundersen to review OPG’s proposal for the relicensing of the Pickering reactors.

    Mr. Gundersen laid out in detail the challenges and problems inherent in the design and operations of CANDU reactors. He quoted at some length Canadian nuclear scientist Dr. F.R. Greening, who has stated “CANDU was destined to run into difficulties due to the complexity of its design.”(1) Further, “The CANDU reactor was always an experimental venture; it has had its successes and was probably a worthwhile undertaking because it added to our understanding of nuclear science and engineering. However, it is time to declare the CANDU experiment over, and move on to something simpler, something proven, something better.” (2)

    In addition, Gundersen explained the issue of the “positive void coefficient of reactivity,” a feature of CANDU reactors that is similar to that of the Chernobyl RBMK reactor in presenting extra risks in the event of an accident involving loss of coolant. He adds that this means the CANDU cannot “meet international expectations for a
more passively safe nuclear reactor design.”(3)

    The report commissioned for DNA details many risks and failings in the plans made by OPG to keep Pickering’s aging reactors running past their time.

    Mr. Gundersen concludes in his report “Given the potential risk to the Toronto area and the 4 million people residing there, it is my expert opinion that the ongoing operating uncertainties are significant and do not warrant substantially risking public and safety in order to extend the life of old and outdated reactors like those at the Pickering Nuclear Generating Station. Quite simply, nuclear plants like those at Pickering should not be allowed to operate based upon mysterious unfounded calculations or operating confidence levels as low as 70%. While both OPG and CNSC claim that extending the life of the Pickering Nuclear Generating Station is based upon hard data and pure scientific analysis, it appears that there is a considerable amount of guesswork underlying each organization’s calculations.”(4)

    In August 2013 CNSC released its Record of Proceedings, granting OPG the requested 5-year license, but establishing a “hold point” requiring OPG to produce important information establishing reactor safety.

    Pickering Relicensing Hearing – 2014

    Now the time for the “hold point” hearing has come. CNSC has chosen to downgrade the level of public participation and transparency for this hearing. There is no funding for third-party experts to assess OPG’s submission and claims, and the May 7th hearing, to take place in Ottawa, is for written submissions only. It is challenging for members of the public to perceive the tribunal as being genuinely interested in assessing as much information and input as possible, given the limitations that have been placed on the hearing process.

    DNA Demands Denial of License

    For the following reasons, Durham Nuclear Awareness demands that the Canadian Nuclear Safety Commission deny Ontario Power Generation its request to push these aging reactors beyond the limits for which they were designed.

    1. Aging reactors are inherently at much higher risk of breakdown. These reactors are among the oldest operating nuclear reactors on the planet.
    2. CANDU reactors by design have limitations that ensure the impossibility of making any kind of airtight assurances about safety.
    3. The multi-unit design of the Pickering reactors makes them more vulnerable to radiation releases than the Fukushima reactors, a simply unacceptable state of affairs at any time; even more so as the reactors enter previously dangerous, uncharted territory due to their advanced age.
    4. The proximity of the PNGS to Canada’s largest city and primary economic engine makes the idea of continuing to run these aging reactors unacceptable.
    5. The lack of adequate emergency planning is by itself alone sufficient reason to close the PNGS immediately. To even contemplate the possible evacuation of vast numbers of citizens in the Greater Toronto Area – for uncertain and perhaps indefinite lengths of time – is beyond the ability of rational human thought – or indeed, existing plans.
    6. Lake Ontario provides drinking water to millions of Ontarians. The quality of Lake Ontario water is already severely compromised by agricultural, industrial and nuclear activities. A nuclear accident would however leave millions with no safe source of drinking water at all. This is unthinkable.
    7. The energy produced by the Pickering reactors is not even required. Excess energy is currently being sold off at a loss.
    8. Ontario Power Generation has failed to produce the revised risk assessment and revised accident report that CNSC demanded. The attitude of OPG appears to be that the public must simply trust their intention to make plans for “concept-level methodology” and “an estimated timeline for detailed methodology and the whole-site PSA.” While this response has apparently satisfied CNSC staff (who say they find this “acceptable” and that risks to the public are “reasonably low”) what it amounts to is saying to the public, “Just trust us!” This is utterly unsatisfactory.

    Conclusion

    Each of the eight reasons outlined above is sufficient justification by itself to shut down the Pickering reactors. Collectively, they render the conclusion inescapable that the Canadian Nuclear Safety Commission must act decisively, as its mandate demands, “to protect the health and safety of Canadians, as well as our environment.”

    CNSC must act to shut down the Pickering reactors now – before there is a nuclear disaster in the Greater Toronto Area.

    Sincerely,

    Janet McNeill, spokesperson for
    Durham Nuclear Awareness

    FOOTNOTES:

    1. Fairewinds Associates, Inc. submission to CNSC, April 29/13. Page 8
    2. Page 8
    3. Page 4
    4. Page 11

Featured post

Pickering Council Motion – April 22/14.

The Council of the City of Pickering passed the following motion unanimously on April 22, 2014:

WHEREAS the Pickering B reactors located at the Pickering Nuclear Generating Station will reach the end of their design lives this year; however Ontario Power Generation (OPG) have applied to operate them until 2020; AND

WHEREAS Durham Nuclear Awareness (DNA) acquired funding to hire Arnold Gundersen of Fairewinds Associates to analyze OPG’s safety case for Pickering in 2013. Mr. Gundersen concluded there was insufficient information to approve the life-extension of the Pickering B nuclear reactors.

WHEREAS the Canadian Nuclear Safety Commission (CNSC) approved a 5-year operating license to OPG, but required that it submit a full safety case for a public hearing before it could run the station beyond its design life; AND

WHEREAS Durham Nuclear Awareness maintain that the studies and information requested of OPG to provide at the 2013 CNSC relicensing hearings, have yet to be released to the public for review.

NOW THEREFORE BE IT RESOLVED that City of Pickering Council request the CNSC and OPG to provide a higher level of transparency when discussing the potential for extended operations at the Pickering Nuclear Generating Station past its end of life design. This includes (but not limited to) proactively releasing to the public in a timely fashion, any and all studies and documents providing OPG’s safety case to extend the operation in Pickering.

AND that OPG is required to hold annual public meetings to report on the safety of the facility, where the public has an opportunity to ask questions and be provided with appropriate responses. And that prior to these annual public meetings being held, all relevant reports and depositions from the CNSC and OPG in relation to the safety of the plant until the year 2020 be provided to the public in advance.

AND that CNSC requires OPG to send a draft Decommissioning Plan to the City of Pickering for consultation by year-end in 2015.

AND that a copy of this resolution is submitted to the CNSC forthwith.

AND that a copy of this resolution be sent to Durham Region, all Durham Regional local municipalities, Hon Kathleen Wynne, Premier of Ontario, Hon Tracy MacCharles, MPP Pickering-Scarborough, MPP Joe Dickson, Ajax-Pickering, Hon Chris Alexander, MP Ajax-Pickering, MP Corneliu Chisu, Pickering-Scarborough East.

** You can find Pickering Council minutes & agendas here

Featured post

DNA Letter to Pickering Council

DNA hand-delivered this letter to the members of Pickering Council on March 17/14.

March 17, 2014.

Dave Ryan, Mayor
The Corporation of the City of Pickering
One The Esplanade, Pickering
Ontario, Canada L1V 6K7.

Re: DNA concerns about operating the Pickering reactors beyond their design life

Dear Dave Ryan [each member of Council received her/his own persoalized copy of the letter]:

We are sending you this letter in order to register the concerns of Durham Nuclear Awareness (DNA) regarding Ontario Power Generation’s request to run the Pickering nuclear station beyond its design life, and to make some recommendations to you as a Council.

DNA is a group of concerned citizens who work to raise awareness about nuclear issues and risks facing the people and communities of Durham Region.

As you are probably aware, the Canadian Nuclear Safety Commission (CNSC) is holding a hearing on May 7, 2014 in Ottawa to discuss OPG’s request to run the aging Pickering B reactors beyond their design life.

While OPG and CNSC staff’s input on this matter has yet to be published (expected availability of their reports: sometime after March 21st), we wish to raise some issues now.

The first Pickering reactor reaches the end of its design life this summer. To our knowledge, continuing to operate a CANDU reactor beyond its design life is unprecedented.

DNA is very concerned about the risks of running the Pickering reactors beyond their design life and the lack of information disclosure and public participation available at the May 7th meeting.

DNA encourages Pickering Council to raise similar concerns with the Commission by making a written intervention by April 22.

The following summarizes DNA’s concerns and recommendations.

Public Transparency and Participation

The CNSC typically provides financial support for organizations and individuals to hire expert technical advice to enable their intervention in re-licensing hearings. It is not doing so for this hearing despite the importance of the decision.

In 2013, DNA received $16,000 to hire American nuclear risk expert Arnie Gundersen to review and evaluate OPG’s safety case for running the Pickering reactors beyond their design life. Ironically, the key observation of Mr. Gundersen’s analysis was that OPG had failed to provide a full safety case for running the reactors beyond their design life in time for the hearings.

Because of this total lack of key information, DNA and other environmental organizations formally requested the CNSC to deny OPG the right to operate the station beyond its design life without a full safety case first being considered at another hearing of the Commission.

In its final decision in August 2013, the Commission granted OPG its requested 5-year licence renewal, but partially agreed with DNA and other groups in requiring OPG to present its full safety case at the upcoming hearing this May.

However, DNA is concerned that the public’s ability to meaningfully scrutinize this key safety issue has been significantly constrained. The CNSC will only be accepting written submissions at this hearing, and is not providing financial support for third-party reviews of OPG’s safety case.

It should be underlined that DNA sought funding last year to review OPG’s safety case for running the station beyond its life because we viewed this as a key risk to Durham Region. Because OPG failed to provide a full safety case, we are now effectively holding another re-licensing hearing, yet with reduced levels of public participation and without the ability to hire a third party to vet OPG’s safety case.

DNA feels that such an unprecedented decision should be taken in full public view, with input from the community and third-party reviewers.

DNA encourages Pickering Council to articulate concerns to the CNSC regarding the reduced level of public participation and transparency in any potential submission you may make on behalf of the City of Pickering.

Pickering’s Closure and a Just Transition for the Station Closure

DNA believes there must be open and public discussion on how to plan for the Pickering nuclear station’s closure. DNA encourages Pickering Council to ensure that such debate happens well before Pickering’s closure.

Without such a discussion, our community could undergo unnecessary negative social and economic impacts. When Quebec closed its Gentilly-2 nuclear station in 2012 without such a debate or a transparent plan, it caused considerable stress in the community.

In the CNSC’s relicensing decision last year, it directed OPG to provide a draft decommissioning plan for the Pickering nuclear station by 2017 – three years before what was then understood to be Pickering’s final closure date.

Since that time, the government of Ontario released a new Long Term Energy Plan, which states:

“The Pickering Generating Station is expected to be in service until 2020. An earlier shutdown of the Pickering units may be possible depending on projected demand going forward, the progress of the fleet refurbishment program, and the timely completion of the Clarington Transformer Station.” (Long Term Energy Plan, December 2013, p. 47.)

It is thus possible that the Pickering station will be closed down completely or in part well before 2020. DNA believes the City of Pickering must be prepared for such a scenario.

As discussed, DNA believes our community needs a transparent and accepted transition plan as it ends its 40-year experiment with nuclear power. As seen with recent experiences in Quebec, the failure to develop such a transition plan can have negative impacts on the community.

DNA thus encourages Pickering Council to request that the Canadian Nuclear Safety Commission require OPG to move up the submission date for its draft decommissioning plan from 2017 to 2015.

We also believe that whatever plan OPG submits should be subjected to a public consultation to determine whether such a plan is environmentally sound and in the public interest. We would be happy to discuss the nature of such a public consultation at a later date.

Conclusions

To conclude, DNA is concerned about the risks of running Pickering beyond its design life. We encourage Pickering Council to call for higher levels of public transparency if it suggests the life-extension of the Pickering reactors be approved by CNSC.

DNA is also deeply concerned that our community has no transition plan for closure of the Pickering nuclear station, which could occur well before 2020. We request Pickering Council ask the CNSC to require a draft decommissioning plan be published by 2015 instead of 2017.

Thank you for your attention in these matters.

Please don’t hesitate to contact our group if you have any questions.

Featured post

Pickering: Time to Shut It Down

In May last year the Canadian Nuclear Safety Commission (CNSC) held a hearing into Ontario Power Generation’s request for a further 5-year license, to run the Pickering reactors beyond their “design life” of 210,000 hours.

While there was tremendous opposition & an incredible amount of negative testimony brought forward in the 3-day hearing, CNSC did grant OPG the 5-year license, but with a “hold point” one year in, to present its full safety case for continuing to run the reactors.

DNA had hired Fairewinds Associates Chief Engineer Arnie Gundersen to study OPG’s proposal & present his findings at the May 2013 hearing.

His full submission can be found here.

You can also watch a 3-minute interview with Mr. Gundersen. It’s a succinct summary of why it would be a big mistake to run the Pickering Nuclear Generator Station (PNGS) beyond its design life.

Another hugely important element of the case against Pickering is the lack of adequate emergency & evacuation plans, should there be an accident involving a large radiation release.

A 2-minute interview with the Canadian Environmental Law Association (CELA)’s director Theresa McClenaghan speaks to this. (Her full presentation can be found here )

On May 7th 2014, CNSC will hold a 1-day hearing in Ottawa (accepting written submissions only this time) to review submissions on the OPG proposal to keep the PNGS going for at least 4 more years.

This site has plenty of information on how to take part in the hearing. Please do!

In January 2013 Thierry Vandal, the head of Hydro-Quebec, said when asked if he would run the Gentilly-2 nuclear station beyond its design life, “I would no more operate Gentilly-2 beyond 210,000 hours than I would climb onto an airplane that does not have its permits and that does not meet the standards. So, it is out of question to put anyone, i.e., us, the workers, the public, and the company, in a situation of risk in the nuclear realm.”

Why continue to endanger the cities & citizens of Pickering & Toronto & the entire Greater Toronto Area?

It’s time to shut down Pickering.

Featured post

DGR Hearing: DNA Presentation (Sept. 24/13)

* DGR = Deep Geologic Repository

* DNA’s written submission can be found here

Good afternoon, members of the Joint Review Panel, OPG and CNSC staff, fellow intervenors, members of the public and those who are watching the proceedings via Webcast.

My name is Janet McNeill, and I’m here today representing the group Durham Nuclear Awareness, or DNA for short. As explained in our written submission, we are a group of concerned citizens who volunteer our time and energy to raise public awareness of nuclear issues in the Regional Municipality of Durham.

We have a steering committee – this is where I’m going off-script to answer the specific questions that you [Panel Chair Stella Swanson] have asked. We have a steering committee of eight people who meet regularly to host public events, attend Durham Nuclear Health Committee meetings, contact politicians, and so on. I’d like to say we have a huge membership – documented membership, and the fact is we’re not sophisticated enough to have the – what would you say, the infrastructure to create that sort of thing.

We’re all volunteers. We don’t have the time to pursue doing newsletters, pursuing a whole bunch of members, taking in memberships, and so on. I’m going to say something a little more about the history of the group below that was already in my remarks.

We’re from the area east of Toronto that is host to not one, but two gigantic nuclear generating stations. We have neighbours, friends and acquaintances who work for the nuclear industry, and like them we live with crossed fingers, essentially, in the hope that Durham Region will never be host to a nuclear disaster like Three Mile Island, Chernobyl, or Fukushima.

The DNA group, in fact, originally came together after the Chernobyl nuclear accident that took place on April 26th, 1986. While I was not an active member of the group in its earlier incarnation, I’m aware of the group’s impressive work and achievements under the leadership of Irene Kock and Dave Martin, two activists whose efforts continue to bear a huge impact on the nuclear awareness that our group’s name speaks to. These activists won widespread respect for their technical understanding, tireless activism and educational efforts. It’s an honour to continue the work of the DNA group that they gave birth to.

The DNA group’s name indicates right up front that our concerns are not just about those of us alive today, but also all future generations whose lives stand to be unavoidably affected by the heavy burden this industry has placed on every single human being and every living thing on the planet.

The group had a dormant period and then came together once again after the Fukushima nuclear disaster that began on March 11th, 2011. We’ve intervened recently at the Darlington refurbishment hearing in December 2012, and then a few months ago in May at the Pickering re-licensing hearing.

I myself have taken part in a number of CNSC hearings over the past three & a half years. However, I think it was not until I attended a nuclear waste conference in 2011 (six months into the Fukushima disaster) that I really began to grasp the true gravity of the crisis the human race now faces with the 5 or 6 decades’ worth of nuclear wastes that are building up at reactor sites around the globe.

I’m going to share with you a number of things I learned at that conference, since they are quite relevant to the project under discussion here.

Just before I do, I want to reiterate that DNA is a group of volunteers. None of us is an “expert.” None of us receives any financial remuneration whatsoever for the work we do. Our work is done on our own time, on our own dime, in the “spare” time we might otherwise use to watch TV, or do whatever it is that people who are not volunteers spend their spare time doing.

So. First I will share with you some interesting things that came out of my attendance at a nuclear waste conference held 2 years ago now, then I’ll comment on the DGR project in a general way, & finally, I’ll provide a list of 10 reasons why DNA feels this project cannot possibly be permitted to move forward.

Nuke Waste Conference – Sept. 2011

So the Nuclear Waste Conference, September 2011. This was an industry conference on “waste management, decommissioning, and environmental restoration for Canada’s nuclear activities.” It was not a conference organized by and for activists, but a conference of nuclear industry people, hundreds of them from all over, gathered in Toronto from September 11th to 14th, 2011, exactly, as it turned out, exactly six months into the ongoing Fukushima disaster.

Now, I’ve mentioned that until I attended this conference, I really didn’t begin to grasp the deep seriousness of the nuclear waste problem we now face on Planet Earth.

& this is true.

It is also true that 6 months earlier, in March-April 2011 – when the Fukushima nuclear disaster was in its earliest days – I had attended many days of the Joint Review Panel hearing into the Darlington New Build project.

In preparing my remarks for this hearing, I looked over the notes I took at the New Build hearing, & was reminded of my reaction at hearing OPG staff reveal how little is apparently really understood about how to safely & securely store nuclear waste for the really long-range periods of time it needs to be safely & securely stored.

“We are looking into containers,” allowed one OPG staffer at the Darlington New Build hearing.

“Oh my God,” I recall thinking. “These people are responsible for safeguarding unbelievably dangerous nuclear wastes for 1000s or even 100’s of thousands of years. They apparently have no idea what they are talking about, & they have just admitted that containers would likely last 50 years or ‘maybe 100 with maintenance.’”

Yet they are arguing in favour of building MORE new reactors – along with re-building the old ones!”

I have to tell you that I was genuinely shocked at what I was hearing. Horrified, actually.

But back to the nuclear waste conference & some things I heard while I was there.

Things I Heard at the Nuke Waste Conf.

Frank Doyle, President of the Canadian Nuclear Society, allowed right in his introductory remarks that Canada has “significant nuclear legacy liabilities” – a nuanced way for a nuclear industry person to admit that there is quite a bit of nuclear waste to deal with in Canada.

Joan Miller from AECL [Atomic Energy of Canada] revealed that some things had been “left in the environment for storage” at the Chalk River Laboratories site back before anyone knew better. She used the phrase “things that were probably thought to be pretty clean in the 1960s.”

A number of speakers referred to re-categorizing or “re-characterizing” nuclear waste, so that it can be dumped in regular landfill sites &, in nuclear industry parlance, “free-released.”

In a workshop entitled “New CSA Guideline for the Exemption or Clearance from Regulatory Control of Materials that Contain, or Potentially Contain, Nuclear Substances,” CSA or AECL spokesperson (I am still confused as to which), M. Rhodes spoke in a manner that was extremely dense in jargon & acronyms, & very hard to follow, about new regulation N292.5, this “Guideline for the exemption or clearance from regulatory control of materials that contain, or potentially contain, nuclear substances.” The phrases “abandonment” & “unconditional clearance” were used. And since, as I have mentioned, I found Mr. Rhodes difficult to follow, I can’t say a great deal more about his workshop. But the words “abandonment” and “unconditional clearance” raised some red flags in my mind.

When asked how the public consultation had been conducted (following closed-door sessions attended almost exclusively by nuclear organizations), Mr. Rhodes replied, “It was posted on the CSA Web site.”

Ah. Public consultation, hmmmm? Only thing missing? The public.

I was flabbergasted to hear speakers from the nuclear industry say with straight faces that they are “leaving an honorable legacy” in Port Hope. An honourable legacy. This was said more than once.

It was confirmed for me that the way nuclear waste is categorized is pretty much arbitrary, and in any case, that the categories are created by the nuclear industry for its own convenience. Most members of the public are almost certainly not aware, for example, that low level does not mean low risk.

That decommissioning nuclear reactors costs simply shocking amounts of money – & not only that, is far from being a well-understood phenomenon or set of practices even within the industry.

Charles Hickman from Point Lepreau in New Brunswick conveyed the information that Canadian nuclear waste is being sent to Tennessee for incineration there – because there was just a great deal more of it than anyone had anticipated, during the refurbishment project, & that they needed to get rid of it.

Incineration of nuclear waste. This was something I was blissfully unaware of, before the conference.

François Bilodeau from Hydro Quebec conveyed that the Quebec experience with refurbishment had established that 5 times more waste than anticipated was being created with the refurbishment of Gentilly-2. (Of course, since that time Gentilly-2 has been shut down – due to these various shockingly over-the-top costs.)

In other words, what I was learning was that we cannot count on the so-called “experts” to predict the quantities of nuclear waste involved in refurbishments & decommissioning, nor what is to be done to “handle” or “dispose” of them safely & properly.

As Dr. Binder, CNSC President & CEO pointed out in his opening remarks at the conference, “Public confidence is waning.”

Yes indeed. Public confidence is very low, & it is ever waning. In the face of the ongoing disaster at Fukushima & the almost-daily shocking revelations there (still), it is quite safe to say that trust in the nuclear industry has reached historic lows.

I noted down quite a few memorable quotations that I would like to share with you, as they too are quite revealing in a variety of ways. I should perhaps remind you that this conference was industry talking to industry. The level of candour was considerably greater than would likely have been the case had it been industry talking to the public, or industry talking to activists, or to journalists.

Memorable Quotations Recorded at the Conference:

Mark Corey – who was then (and may still be; I’m not sure) – Assistant Deputy Minister for the Energy Sector, Natural Resources Canada, shared his palpable excitement about Canada’s great fortune to possess the tar sands, & referred to the need for nuclear energy as a “crucial part of our energy mix” … but admitted that in a few areas of the country (e.g. Bancroft, Ontario & the northern route that uranium followed to get to Port Hope, Ontario) some “things” had been found that hadn’t been quite expected. He was referring to nuclear waste.

He was quite excited about some fences that had been erected in the Bancroft area (where there were “some areas that had some real activity” – radioactivity, he meant). And I guess the fences are there to protect the people & the wildlife & the local environment from mine tailings – the latter being, one supposes, some of the “things” that hadn’t been quite “expected.”

CNSC President & CEO Michael Binder commented that “the March 11th event in Japan was a wake-up call,” and made the claim “We are not going to tax future generations” (with nuclear activities or waste). Another remark that took me greatly by surprise, since I didn’t detect any sign of an effort to phase out nuclear power – the only possible solution that exists for putting an end to the production of long-lived nuclear wastes!

Later on Dr. Binder stated that “We have tended to be secretive” & that “most of our conferences are us talking to ourselves – not the public, not the press.”

I was struck by his use of the word “we.” The CNSC lays claim to being an “arm’s length” regulator, & always vigorously denies being “embedded” in the industry. I would suggest to you that with this remark at the conference, Dr. Binder firmly established CNSC as an integral arm of the nuclear industry.

Tom Mitchell, Ontario Power Generation’s exceedingly well-paid President & CEO, referred to the Fukushima nuclear accident (6 months in, as you will recall) as a “humbling experience.” He admitted that it proved “The unthinkable might happen.”

He also downplayed the impact of nuclear waste, while at the same time emphasizing that the DGR planned for low & intermediate-level waste would be REALLY deep. “This stuff isn’t dangerous,” he seemed to be saying – but we’re going to bury it REALLY deep…. I should also mention that he pointed out that, with refurbishments, quantities of nuclear waste on the planet are growing. Something he seemed to be suggesting ought to be viewed as an economic opportunity.

NASA staffer Keith Peecook described the $230 million project to decommission the Plum Brook Reactor Facility in Ohio. He was candid about a number of things. He was candid about something called “blending” (the more you “blend” nuclear waste, the less you have to send to a specially engineered waste facility; “blending” is being examined by the Nuclear Regulatory Commission, presumably so as to enhance this tactic for the future).

He was candid about faking sincerity with the public liaison group. He said & I quote: “Once you learn to fake sincerity, you can do anything.”

He was candid in his comment that the public advisory committee in that Ontario – oh, pardon me – Ohio community, was undoubtedly more receptive to industry activities & staff, uh, explanations, than might be the case in a California one.

When asked how much it had cost to build the reactor that cost $250 million & 1.68 million “man-hours” to decommission same, he replied “$5 million.” $5 million to build, $250 million to decommission. This was bracing information … & very informative.

CNSC staffer Don Howard gave a talk on the CNSC’s regulatory framework. (Parenthetically, by the way, that CSA N292 regulation came up.) Mr. Howard said more than once that decommissioning & long-term planning have not been considered in the past as much as they ought to have been. And that “strategies of minimization” (including “the use of clearance levels”) must be used. He seemed to think that it was a revelation to state that it is necessary to think about waste all the way through, not just “at the end.” He also had it in his presentation that “Generation of radioactive waste cannot be prevented.”

Of course many of us would suggest that ending the use of nuclear energy would be an excellent and the most effective (and only) way to prevent any further creation of radioactive waste!?

Pauline Witzke of the Nuclear Waste Management Division, OPG, spoke about the DGR plans. She said that it is necessary to find a long-term solution for the waste that already exists – a solution, she added, that is “acceptable to the community.” She acknowledged that “Transportation risk is quite high.” This was a – I thought an interesting thing to hear somebody from the nuclear industry admit. You won’t often hear that being admitted.

Okay. And it’s important to note finally that I was not able to attend all the sessions at the conference that I would have liked to attend, because there were tons of things going on. Certainly some important themes emerged.

I’ve summarized, I guess, 10 things that I learned at the conference.

1. The nuclear industry isn’t quite as “expert” as they would have us all believe.
2. There are now daunting quantities of nuclear waste all over the planet. “Regular” citizens would be shocked to know how much & in how many different locations in Canada, for starters, & all over the world. Not always handled responsibly, I might add, of course, was something I learned at that conference.
3. Phrases like “waste characterization” & “blending” & “legacy liabilities” & “historic wastes” & “Integrated Waste Planning” are used to cover up a lot of reality that is what can reasonably be termed seriously dangerous reality.
4. Refurbishments & decommissioning create very, very significant quantities of waste; so significant that sometimes here in Canada, we ship our waste to the U.S. for burning … & then receive back the ash. One can just imagine how toxic that ash must be if the folks in Tennessee don’t want to keep it down there where they are doing the burning.
5. There are very significant amounts of money to be made in the nuclear industry. One might almost say “staggering” amounts of money. And of course the industry experts & the regulator all have a piece of that large pie.
6. It is the Canadian public that is on the hook for so-called “legacy” or “historic” wastes at Chalk River & Port Hope, & also all the waste at Darlington, Pickering & the Bruce. Taxpayers are left responsible for the waste that is created by the nuclear industry – the industry that is profiting hugely from its activities.
7. We need not count on the industry to own up to its leaks and spills and disasters and explosions and emissions. It seems we must continue to count on members of the public to ferret out this kind of information. I could say quite a great deal more on this topic, but time does not permit…
8. We cannot count on the nuclear industry or our government to protect us from dangerous radioactivity or nuclear waste, because regulations about these things are discussed & changed behind closed doors on occasions that we, the public, are neither invited to, nor welcome at.
9. Conclusions about the Fukushima accident had not yet been reached, it was then still so new. Later on, the word “collusion” became part of the necessary vocabulary in discussions about the Fukushima disaster. At this conference in the fall of 2011, it seemed to me that very strong indicators were given of a surprising amount of cooperation among the industry, the federal government and Canada’s so-called regulator.
10. By the end of the conference I felt genuinely sickened. I honestly did. I’m not exaggerating. I felt sickened by the deep gravity & intractability of the issues surrounding nuclear waste. I concluded that all nuclear energy facilities need to be shut down immediately. And that all of the industry’s very considerable resources need to be directed from here on in to responsible decommissioning of all nuclear facilities everywhere, including, of course, the safe & responsible handling of the very considerable quantities of waste that already exist … never mind making any more.

The DGR Project

Okay. The DGR project. We said quite a bit about this in our written submission.

A great deal of money has been spent & a great many studies have been undertaken to justify this project – which some have come to think of as the DUD – Deep Underground Dump. One sometimes wonders if people in the nuclear industry believe that simply generating 1000’s of pages in voluminous reports & so-called “studies” can take the place of rigorous study & testing of hypotheses.

One wonders whether the people who carry out such studies such as these really believe that computer modelling can ever accurately reflect the deep complexities of ecological reality, which of course encompasses human reality. We are deeply part of ecological reality.

Now, I am always happy to confess right upfront that I am not personally a “technical” person. I’m not scientifically minded & I am not mathematically proficient.

Yet I read the reports generated by the industry (whether for this project or a tritium light facility or a reactor refurbishment or a license extension) & certain things come up again & again.

Fancy language & terms are thrown about.

    Jargon

Studies are referenced.

Many unsubstantiated claims & predictions are made.

Weak language & reassurances predominate.

The use of the word “robust” is repeated endlessly – yet the evidence & the studies & the conclusions cited are always anything but robust.

Weak & unverifiable claims are made – inevitably & repeatedly – about there being no adverse environmental impacts. It doesn’t matter what the project happens to be. Miraculously, no adverse impacts are ever anticipated!

I honestly doubt that most 10-year olds reading these reports would find their concerns for the future of the Earth adequately addressed. Or find the lofty claims being made credible.

Overall, it strikes me that nuclear industry people are most concerned about the costs of waste disposal. Not public or environmental safety. The goal is pretty clearly to get rid of the waste as quickly & as cheaply as possible. While earning vast sums of money for the individuals & corporations involved, of course.

In fact, earning money (and lots of it) for a large number of engineering firms seems to be perceived as almost a moral imperative within the nuclear industry. That it is absolutely not one for the rest of society is something the nuclear industry needs to begin to grasp.

Summary of Reasons the DGR Should Not Be Approved

We have created a list of 10 reasons why the DGR should not be approved.

1. There’s a genuinely – to us – or to many of us, I think – surreal feel to this project. For so many of us, it is simply unbelievable that any reasonable person could find it rational to contemplate abandoning nuclear waste in a glorified hole in the ground within such a short distance of a substantial, irreplaceable body of water – one of Canada & the U.S.’s incomparable Great Lakes. This is simply unfathomable to us!
2. The project is a very graphic illustration of “putting the cart before the horse.” It’s all a case of working backward from a pre-established conclusion agreeable to the industry to find the “proof” that this is a good, solid, reasonable and environmentally sound plan.
3. Inadequate planning, study, rationale, safety case. It becomes apparent from reading the documents associated with this project that no one really seems to know what they are doing! The plans are haphazard, & the reasoning behind most of them circular – all of it un-hindered by any actual basis in reality or scientific study. Nor is OPG being forthright in responding to the public concerns & questions that have been raised about the project.
4. The plan lacks any credibility whatsoever, & as for safety grounds, there are no grounds. It seems to be a case of “We say this will be safe because we say it will be safe, and so it will, of course be safe. Because we say so!”
5. People and communities & the actual likely impacts of this project do not appear to be real to the nuclear community. In reading the report, one senses that people & actual consequences – even the incomparably beautiful Lake Huron! – we only have to walk outside the building here and look down the street to see this gorgeous jewel down there – are mere abstractions to the people formulating these plans. Perhaps because computer modelling is not sufficient to put flesh on the bones of real people, real communities, real natural treasures…& very real risks.
6. There is a gigantic hole in the middle of the plan where ethics & morality ought to be firmly located…but are strangely & entirely lacking.
7. Canada’s so-called nuclear “regulator” is not an arm’s length body; therefore any decisions it makes (about waste characterization, transportation, overall handling of waste, etc. etc.) also lack credibility.
8. There is massive, widespread public opposition to this plan from all levels of society, & on both sides of the border.
9. The failure of this plan and the DGR itself is virtually guaranteed, its far-reaching consequences to be placed on the generations that come after our own.
10. It is completely irresponsible (as well as immoral & unethical) to take such risks with the drinking water of 40 million people! As Maude Barlow of the Council of Canadians has said, “…this is an act of insanity. This would be a crime against future generations. This is a crime against nature.”

I would ask everyone to consider leaking tanks at Hanford, in Washington, & the impacts on the Columbia River. Consider the Asse Mine mess in Germany. Consider leaks, emissions, train &/or truck derailments. Consider the BP oil spill. Boxes of tritium products falling off a truck in Ottawa, necessitating that streets in the surrounding area be cordoned off (that’s SRB products). Consider the Strontium-90 in the Ottawa River as a result of operations at the Chalk River facility. Consider the mess at Dounreay in Scotland. An explosion there because of waste being handled sloppily – & the massive, absurdly expensive means & efforts now necessary to remediate that site. I could mention Port Hope. I could mention a tritium groundwater plume in the town of Pembroke, Ontario. (Again, that’s associated with the SRB facility in Pembroke.)

Large accidents. “Small” accidents.

Fukushima.

Industry people say “Trust us.” But we cannot. How could we possibly??

Concluding Words:

OPG President/CEO Tom Mitchell admitted at the nuclear industry waste conference in September 2011, referring to the (very much still ongoing then and very much still ongoing now) Fukushima nuclear disaster that “The unthinkable can happen.”

For most people, it would be unthinkable to poison the drinking water of 40 million people. Or actually, even to contemplate doing so!

Nuclear activities have already poisoned bodies of water all over the planet. The industry cannot be permitted to ruin the drinking water of all those who rely on the Great Lakes for their drinking water. “Bury it & run” is not an acceptable basis for the responsible handling of nuclear waste.

At the same nuclear waste conference that was such a learning experience for me, Adrian Simper, Strategy & Technology Director for the Nuclear Decommissioning Authority in the UK, spoke about decommissioning activities in Britain. He was upfront about the fact that the so-called nuclear “legacy” there is a major public liability. He also acknowledged that the NDA is spending taxpayers’ money, so it must be done responsibly.

He seems to have a firm grasp of the fact that those of us being saddled with all this nuclear waste must be permitted a say in how it is handled.

Mr. Simper said several rather memorable things. He spoke of clean-up activities at Dounreay in Scotland, where materials are being “recovered” from shafts & silos. That there are no actual records of what is there. “We don’t quite know what will happen,” he admitted.

He also said, referring to activities in the past, “They didn’t always think it right through to the end.”

He said “Risk is the overriding factor.”

That the “# 1 priority is when the risk is intolerable.”

Durham Nuclear Awareness & many others you are hearing from at this hearing agree that, with this project, the risks are quite clearly intolerable.

Nuclear waste must never be abandoned. It must be kept in engineered facilities where it will always be monitored – forever monitored & retrievable, should containment fail.

There must be zero tolerance for the escape of radiation from the storage facility. We have no right to impoverish or imperil the lives of our children and grandchildren and all future generations with any increase in exposure to ionizing radiation.

Dr. John Gofman, Ph.D & also a medical doctor, in the early days of his career as a scientist helped isolate the world’s first milligram of plutonium for the Manhattan Project. He later became a passionate & vocal dissenter from the nuclear project. He said a great many quotable & brilliant things (& he was not only a brilliant man, but also a funny one).

Among his many gems is this one: “I have examined the arguments of the promoters of nuclear energy, and they always boil down to the same absurdity: If everything goes perfectly, then everything will go perfectly.”

Things don’t go perfectly, do they? This scheme is not any more likely to do so than so many others we could name.

And I have just learned evidence in the past 24 hours about some of these other deep geologic repositories that are supposedly great. And they’re not great. They’re not working.

We ask that you deny OPG the right to proceed, & insist that they come up with better-thought-out plans for nuclear waste.