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are significant and do not warrant substantially risking public and safety in order to extend the life of old and outdated reactors like those at the Pickering Nuclear Generating Station.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.
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.
Janet McNeill, spokesperson for Durham Nuclear Awareness
1. Fairewinds Associates, Inc. submission to CNSC, April 29/13. Page 8 2. Page 8 3. Page 4 4. Page 11