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.