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?