** Cheater alert: even trying to explain this study (& its implications, knowing what I know about CNSC (Canadian Nuclear Safety Commission), OPG (Ontario Power Generation) and provincial nuclear emergency planning) is tedious and time-consuming. Near the end of the post there are sections called Summary & Take-Aways. You might be tempted to skip to the end section if all the ins & outs drive you up the wall. It’s hard to know quite where to begin describing this CNSC (Canadian Nuclear Safety Commission) “Study of Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures” report.

This severe accident study that is NOT a severe accident study. It all begins to go off the rails quite quickly.

You can find the study here. Severe Accident Study. (Request a pdf version &/or a hard copy by writing to info@cnsc-ccsn.gc.ca & requesting one.) ** see note at bottom of post for new (corrected?) version of study.

I tried to make a chart, as I find that charts can be very helpful for organizing unruly thoughts or task lists … using the categories of Absurdities, Assumptions, Circular Reasoning, Contradictions, Failures to be Upfront, Lies, Manipulations, some examples of Whoa … really?? And Whhhhhhhat??? and inevitably some memorable/telling quotations … & a Summary with Take-Aways. (Topic headings not covered: unscientific “science”; misusing the phrase “conservative assumptions”; patronizing the public; & misleading topic headings, e.g. ‘How emergency plans are assured of being robust and successful’ with no content whatsoever of any applicability to the heading, etc.)

But as you can see, the sheer # of categories really got away on me. This represents my next best attempt to rassle this … “study” into some coherence. Not that the study itself can be made to be coherent; it can’t. But I need to be able to at least describe it coherently. Perhaps only semi-coherently. Let’s proceed:

Background: At a CNSC hearing on Darlington in 2012, many groups & individuals – our group, DNA, included – called on the CNSC (Canada’s federal nuclear “regulator”) to carry out a study that would dig into what would happen in the event of a serious nuclear accident at the Darlington Nuclear Generating Station (DNGS). Many of us were very concerned post-Fukushima disaster (which began on March 11/11, just before the Darlington new build EA hearing) that emergency planning measures were/are not sufficient to protect the public of Durham Region (& Toronto/the Greater Toronto Area) in the event of a serious accident here.

We were aware of the Joint Review Panel Recommendations from the New Build hearing in March/April 2011. Specifically Recommendation # 46 (Section 6.3):

Given that a severe accident may have consequences beyond the three & 10-kilometre zones evaluated by OPG, the Panel recommends that the Government of Ontario, on an ongoing basis, review the emergency planning zones & the emergency preparedness & response measures, as defined in the Provincial Nuclear Emergency Response Plan (PNERP), to protect human health & safety.

After the Darlington 2012 hearing, the CNSC tribunal directed CNSC staff to do a study. Staff did do a study & put it out for public comment (June 2014). Many of us commented (by last August) that the study was clearly not a severe accident study.

Greenpeace found out through an Access to Information request that indeed a serious accident (Level 7 on the INES, International Nuclear Event Scale) had been studied, but that what was found was … well, a bit inconvenient to the nuclear industry, shall we just politely say, & was being said (behind closed doors) to be expected to be used “malevolently” at a hearing – so staff were asked to re-do … but with a less severe accident.

This Request for Ruling Aug.2015 explains how Greenpeace, DNA and six other groups have called on the CNSC to “release the results of the uncensored Darlington accident study by September 15th so that the public intervenors who requested this study in 2012 can consider and incorporate the study’s findings in their written submissions due on September 28th, 2015.”

Okay. To the study …

Assumptions / Absurdities

1. Some questionable assumptions were made about cancer in the area, about a 30-year old male representing the adult population & about KI pill ingestion being 100% effective. (Annex 4, pg. 111-13 of the report.) Oh dear. Not good to start right off the top with questionable assumptions…

2. No immediate release of radionuclides. (This is one of those cooperative, convenient kinds of “severe accident,” I guess?)

3. Emergency plans/prep/response have already kicked in. Putting the cart before the horse? (This may also qualify under Circular Reasoning; take your pick.)

4. KI pills are already delivered/ingested out to 12 kilometres. (This really boggles the mind, since the Primary Zone only goes out to 10 K & most people in that 2 K between the pre-distribution area of 10 K & 12 K likely won’t have KI handy, & btw, you actually have to ingest it BEFORE exposure to receive 100% benefit from it. Four hours before No, I am not making that up.)

5. People in the 3 K “contiguous zone” have already been evacuated.

6. No evacuation beyond 12K would be necessary (this kind of gives away the fact that it’s really not a severe accident, doesn’t it? Compare to Chernobyl & Fukushima realities, with evacuations as far out as 30 K (Chernobyl) & 40 K (Japan, when the plume went northwest instead of southwest, as predicted by computer modelling).

7. On page 9 it is explained, “The underlying goal has been defined in terms of avoiding undue public disruption, in the case of the large release of Cs-137, to avoid long-term relocation. It is a release of this magnitude that was examined in this study. The release of a greater magnitude is practically eliminated in light of the improvements emanating from the Fukushima Task Force.” (This one likely also qualifies under the categories of Whoa! Really?? “We’re modelling a ‘severe accident’ – but one that won’t really inconvenience anyone.” Really?? Let’s move ahead now to circular reasoning, shall we?)

Circular Reasoning

The federal government (in the form of the CNSC) is in charge of licensing & supervising operations of the nuke plants. Off-site nuclear emergency planning is a provincial, regional & municipal responsibility (the province is overall in charge; municipalities or regional governments are in charge of carrying out evacuations).

There is this sort of eerie, circular thing going on here that I find challenging to articulate.

The feds are saying the Province is in charge of mop-up if an accident happens. That the PNERP (Provincial Nuclear Emergency Response Plan) will look after us & help safeguard our health.

“From a risk acceptability perspective, the ability of the PNERP to effectively reduce the health risk, combined with the very low likelihood associated with severe nuclear accidents given Fukushima enhancements (i.e., such an event will be practically eliminated), allows these risks to be effectively managed to an acceptable level in alignment with international risk and radiological frameworks.” [pg. iv of “Extended executive summary”]

The report also says (on pg. 2) “Though the study results are useful in support of other initiatives, they are not meant to represent specific reactor accident scenarios, nor be part of the actions emanating from the Fukushima Action Plan or activities being undertaken by other parties (e.g., updating of nuclear emergency response plans).”

So this seems to be saying that whatever the Province gets up to with the PNERP (currently under review, behind closed doors, all indications being that there is no plan whatsoever to change the planning basis; my apologies; you may have to read the previous post to really grasp this planning basis business), this study is about this study & does not mean or intend to inform that updating of the PNERP.

Yet. I happen to know that the Province is indeed leaning on this study. In a letter to DNA from the Minister of Community Safety & Correctional Services in June 2015, the Minister said, & I quote “OPG and the Canadian Nuclear Safety Commission have collaborated on developing “The Study of Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures” as a result of a Commission direction during the Environmental Assessment of the refurbishment and continued operation of the Darlington Nuclear Generating Station. This study, which is one of several technical studies and reviews that have been undertaken since the Fukushima emergency, is informing the PNERP planning basis review.” (Letter from Mr. Yasir Naqvi, Minister of Community Safety and Correctional Services, dated June 3, 2014.)

So CNSC says the feds are counting on the PNERP, & the Province is saying (it seems) “We don’t think the planning basis needs to be changed because the feds/OPG are studying up on what to do in the event of a serious accident.”

Isn’t there some kind of painful circular reasoning at work here?

DNA has learned from experience that this provincial nuclear emergency plan review, which we and two other groups called on the Minister for in August 2013, is taking place very much behind closed doors. Prying information out of that Ministry is a chore involving the necessity for endless FOI (Freedom of Information) requests.

Anyway. Throughout this (alleged) Severe Accident study, provincial (and regional/municipal) responsibilities are referenced. As I say, it seems a bit eerie the way the feds/nuke operators are counting on the Province to look after Ontarians if the you-know-what hits the fan. Yet the Province is counting on the feds to assist in their planning basis deliberations.

This report repeats several times that the PNERP is “flexible.” I guess this means that it will respond well in the event of even the most serious accident. But … many of us are skeptical. If you don’t really plan for a serious accident, how can you be prepared for one? (We do know from media reports & conversations/meetings with both local residents & Durham politicians that most people in the Region actually haven’t a clue about what to do in the case of a serious accident.)

More Circular Stuff:

The claim is made (Pg. 73) that Canadian nuclear power plants are safe. Now, we know they were said to be “safe” before the Fukushima accident, & before all the “Fukushima enhancements” were made (after the Fukushima accident). So they were safe, & now they are safe , & … I guess we are to believe that no accident can happen here (‘though if one happens elsewhere, & this is occurring at the rate of about 1 every 10 years, I suppose more study will be done, & more enhancements might be made, and then the plants will be … safe. Again. Still?? Safer?)

Contradictions or just … things that seem a bit confusing to me

“The results of the study provide insights that are useful for the purposes of emergency planning and response. Most importantly, it informs the public and other stakeholders of the possible consequences of a hypothetical severe nuclear accident, the effectiveness of emergency planning, and the inherent safety of Canadian nuclear power plants.” [pg. 1]

“Though the study results are useful in support of other initiatives, they are not meant to represent specific reactor accident scenarios, nor be part of the actions emanating from the Fukushima Action Plan or activities being undertaken by other parties (e.g., updating of nuclear emergency response plans).” [pg. 2; emphasis mine]

“As such, the study is of a theoretical nature, and uses hypothetical severe accident scenarios with a number of conservative assumptions. It is not meant to reflect the state of readiness of Canadian nuclear power plants, its operators or responsible jurisdictions when it comes to addressing the potential for accidents or their consequences.” [pg. 19]

Oh dear. I’m getting a bit dizzy here.

“Emergency planning is inherently flexible and consideration of sensitive receptors such as children in emergency planning is an integral part of federal and provincial emergency decision making. In the event of an actual accident with this level of predicted risk, decision makers could further mitigate the risk in those areas most likely to be affected through the administration of KI pills or by evacuation. [pg. iii in “Extended executive summary.”] The weirdness of this will become apparent in the Summary/Take-Away sections. When it is revealed that what really seems to be the plan, if a serious accident happens, is to have the Province tell everyone to “shelter in place.” I.e,. stay in your house with the windows & doors closed, people (use some tape maybe, eh?).

 “Canadian nuclear power plants are safe. Following the Fukushima accident, the CNSC Task Force recommendations further strengthened each layer of defence built into the Canadian nuclear power plant design and licensing philosophy to ensure that the likelihood of accidents with serious radiological consequences is extremely low, with an emphasis on severe accidents. In this study, had all of the plant-specific design features, operator actions and other Task Force recommendations been fully credited/realized, the likelihood of a severe accident would have been lowered and the release of radioactive material considered would have been significantly reduced. It means that a severe accident would be extremely unlikely to arise or practically eliminated.” [pg. 73]

Communications: Being Upfront

Now, this comes up a lot! Repeatedly, actually.

“Psychosocial effects would be anticipated for all scenarios and could include fear of radiation exposure, anxiety, and stress. Clear, credible and regular communication from responsible parties before, during and after the emergency would help to minimize these effects. In addition, these effects would be expected to decline rapidly once the affected population returns to their normal life patterns. For non-human biota, like birds and mammals, no acute effects would be expected.” [iii of “Extended executive summary.” Italics mine]

 (Return to normal life patterns after a serious nuclear accident; really??)

“The CNSC Integrated Action Plan applies to all operating nuclear facilities and the CNSC. The areas for continuous improvement that emerged from the Plan are:

• strengthening defence in depth

• enhancing emergency response

• improving regulatory framework and processes

• enhancing international collaboration

• enhancing communications and public education” [Pg.9; emphasis mine]

“Dissemination of information and raising awareness regarding emergency planning through various means by those organizations with emergency planning responsibilities is done on an ongoing basis. In the event of an actual incident, effective, coordinated communication amongst responsible organizations is essential before, during and after the actual incident.” [pg. 32, emphasis mine]

“Ineffective communication and/or coordination of measures to protect the populations at risk will have a similar consequence. These effects are likely to extend to residents in the Secondary Zone [listen up, Torontonians!], who are likely to be less familiar with the plant and associated emergency plans, if they feel they are not receiving the information or assistance they need in a timely way. [pg. 67, in section 6.4 on Psychosocial effects; quite interesting!; emphasis mine]

“Clear, credible and regular communication from responsible parties before, during and after the emergency would help to minimize these effects as would transparent decisions (e.g., based on health-based limits and other factors) for the return of residents to their homes and daily lives.” [pg. 67]

 ** I am pretty sure the citizens of Durham Region/Toronto will be very happy to hear CNSC being so encouraging of wide-open communications. Because in Durham Region, citizens received an emergency brochure in Fall 2012 in which the word “nuclear” was not even mentioned! [AreYouReady] Durham Region residents do not feel they are being openly communicated with. Because they are not. Being openly communicated with. Just saying.  

In DNA we’re aware that this sentiment is also expressed at the international nuclear agency level. The IAEA (International Atomic Energy Agency) has stated in their Publication “Lessons Learned from the Response to Radiation Emergencies (1945 – 2010),” (IAEA, August 2012) a comment in the chapter “providing information and issuing instructions and warnings to the public,” about the importance of providing information to the public on protective actions to be taken in event of an emergency in advance of any emergency for threats such as Nuclear Power Plants. They state “This will engender confidence – the knowledge that the officials have their interest at heart – and, by doing so, improve compliance with protective action recommendations in the event of a real emergency. In addition, there will be a better understanding of the systems used to warn them of an emergency.” [emphasis mine]

The ICRP (International Commission on Radiological Protection) backs up this IAEA advice; note their comment in ICRP Publication 109, which recommends engagement with stakeholders and discussions of the plans, including with members of the public. The rationale is that “Otherwise, it will be difficult to implement the plan effectively during the response. The overall protection strategy and its constituent individual protective measures should have been worked through with all those potentially exposed or affected, so that time and resources do not need to be expended during the emergency exposure situation itself in persuading people that this is the optimum response.” (at 42; again, emphasis mine.)

Seems like the big nuclear agencies are really big on open communication lines. Well, talking about them, anyway.

** Now we just have to make sure that OFMEM (Office of the Fire Marshall & Emergency Management in the Ontario Ministry of Community Safety & Correctional Services) and DEMO (Durham Emergency Management Office) personnel get the memo!

We need to get that review of provincial nuclear emergency plans out from behind those (very) closed doors.

Minimization/Lies

The severity of the impacts of the Chernobyl & Fukushima disasters is not only minimized throughout this report, I have to state categorically that there are outright lies about health impacts from these two INES Level 7 nuclear disasters.

I suggest readers check the claims made on pg. 65 of the study (link at top of post). These can be immediately identified as pure nonsense.

Simply outrageous. Please refer to past posts on this blog about Chernobyl and Fukushima (which contain many useful links). Health effects go far beyond merely thyroid cancer, ‘though we have learned that the thyroid cancers suffered by the children of Ukraine, Belarus and Russia were numerous as well as aggressive. (The CNSC study conveniently mentions the country where KI was pre-distributed, and leaves out the ones where it was not!)

Please also note that even for this non-severe accident study, with all the KI & evacuations conveniently being done before the study kicks in, & all of the assumptions being “conservative,” child thyroid cancer is projected to go up.

“Although the results of this study indicate what appears to be a large increase in the risk of incidence of thyroid cancer in children, this would not equate to a large increase in the actual number of thyroid cancers. With rare cancers any additional risk appears to be a large increase above the baseline.” [pg. 60] Two comments: # 1. I can’t make sense out of that. # 2. I call it minimization.

Report Conclusions (from the Executive Summary, pg iii)

QUOTE Emergency planning is inherently flexible and consideration of sensitive receptors such as children in emergency planning is an integral part of federal and provincial emergency decision making. In the event of an actual accident with this level of predicted risk, decision makers could further mitigate the risk in those areas most likely to be affected through the administration of KI pills or by evacuation. [emphasis mine]

In summary, this study has responded to the Commission’s request to evaluate the human health and environmental consequences due to radiation exposure from a severe nuclear accident. The study is of a theoretical nature, using hypothetical severe accident scenarios. Overall, while conclusions point to a non-detectable increased health risk for most of the population, the theoretical increased childhood thyroid cancer risk findings in relatively close proximity to the DNGS further strengthens the continued importance of considering sensitive receptors (i.e., children) in emergency planning, such as KI pill administration.

From a risk acceptability perspective, the ability of the PNERP to effectively reduce the health risk, combined with the very low likelihood associated with severe nuclear accidents given Fukushima enhancements (i.e., such an event will be practically eliminated), allows these risks to be effectively managed to an acceptable level in alignment with international risk and radiological frameworks. END QUOTE from study; all underlining is mine.

Summary

1. The study seems to be telling us that all will be well. “It can’t happen here.” The plants are safe & we can rely on the provincial nuclear emergency response plan to protect our health if a serious accident happens (the response to the nuclear accident will protect us; we need not worry about what the plant spews into the air & the water. Hmmmm; does this make sense to you??)

2. The study is characterized by circular reasoning, faulty logic, contradictory claims & in some cases, outright lies (there are even things I’ve left out because this posting would go on forever. Please read it for yourself & see).

3. But! Open communications about emergency plans are roundly encouraged & emphasized over & over & over again.

4. It still seems eerie the way this circular thing is going on with CNSC relying on the Province, knowing that the Province seems to be relying on the CNSC, and knowing what I know about how the Nuclear Emergency Management Coordinating Committee (NEMCC) operates; namely, behind very closed doors (no minutes provided, even if one has attended one of these meetings, as an NGO person, by invitation) & with heavy attendance from all levels of the nuclear industry itself. Too many fingers in that messy pie (all listed here) to leave me with any confidence in the ability of emergency response to proceed seamlessly if the you-know-what hits the fan (so many cracks for things to fall between, it is almost literally dizzying).

5. Even this study seems to acknowledge that KI pre-distribution will not protect us from a serious accident (not that a serious accident is what was being studied or reported on; it isn’t). *** see Accidents Scenario Table-Greenpeace

6. The CNSC has tons of faith in the PNERP (Provincial Nuclear Emergency Response Plan) to look after us all in the case of a nuclear accident. In fact, it almost seems to suggest that the emergency plan itself will keep us safe & healthy! Which really doesn’t make any sense at all, & seems more than just a little bassackward, but then … whatever. (I think I am repeating myself here. Sorry. This just really boggles my mind).

7. “It can’t happen here” is still very much the mantra of the nuclear industry (previous post explains the history of this assumption, as well as the issue of the planning basis that nuclear emergency plans are … planned around).

8. Evacuations are messy & potentially dangerous, you see (so this report points out on pg. 69) so the Province might well just suggest that everyone kind of uh, you know, sit tight in their houses if one of the plants blows. They call this “sheltering in place.” My take on this study is that the odds are good if push comes to shove, we’ll all be advised to tape up windows & doors & hunker down & sit it out. This flies in the face of those big international nuclear agencies (IAEA & ICRP) that have pointed out that most North American homes are not suitable for sheltering in. IAEA Guide GS-G-2.1 points out “typical European and North American homes and their basements may not provide adequate protection.” ICRP Publication 109 states that buildings constructed of wood or metal (as opposed to solidly constructed buildings) are “not generally suitable for use as protective shelters against external radiation, and buildings that cannot be made substantially airtight are not effective in protecting against any exposures.”

Take-Aways:

1. The nuclear industry pays considerable lip service to the need to communicate openly & ahead of time. Then they throw the ball to provincial “authorities” to do the mop-up & decide on whether to evacuate people or let them rot in their houses.

2. Good lip service about protecting children – but again, toss the football to the provincial authorities to actually do this.

3. It may not be a very good idea to place our trust in the “authorities” to “look after us” if a serious nuclear accident occurs. But then, I doubt you’ll be surprised to hear me say this after all of the above.

4. While the nuclear industry pays excellent lip service to the notion of communicating openly, I am very skeptical about these claims. But let’s the rest of us communicate openly, shall we? Let’s speak up!

5. Reports like this one from the nuclear industry are time-consuming & headache-inducing to spend time on – but you know what? They are NOT rocket science, & anyone with a reasonable level of intelligence is quite capable of reading & making sense of them. No, I’m not saying they’re enjoyable; they make my head hurt. But I can read between the lines, & we all need to be able to do that … don’t we?

6. And then, speak up. (see # 4)

1 more thing: get this!

I read the Fukushima – the story of a nuclear disaster book again this summer.

Mind-blower of a book, that’s the truth (posting about it here).

Guess what TEPCO (the utility that owns/runs the Fukushima plant & believe it or not, is doing fine financially even though the costs of the accident are probably in the process of bankrupting the country?) said at one point?

They blamed the nuclear regulator for not regulating them!

I think we ought to keep this in mind here. Our “regulator” here is not really regulating either. And our provincial authorities seem to be fine with this. This could lead to some catastrophic results.

Which maybe they will blame on us, for not paying close enough attention; who knows?

Collusion among nuclear industry/regulators/government departments is not only a Japanese phenomenon; not at all. It is a global problem, & frankly, it is in evidence right here in Durham Region / Ontario / Canada.

So sorry to be the bearer of uncomfortable news, dear Reader. They do say the truth will set us free.

Resources

• American Thyroid Assoc-2014 (great info about how far out pre-distribution of KI is recommended for, including by WHO – World Health Organization – as well as info on “aggressive” post-Chernobyl thyroid cancers among children in Ukraine, Belarus, Russia; “region of “excess risk” extended up to a 200 mi radius from Chornobyl.”)

• 4 common elements to Three Mile Island, Chernobyl, Fukushima accidents (that link provides 18 minute video/audio; this one 4 Lessons from Nuke Accidents provides the powerpoint presentation by a person who worked for the nuke industry at TMI (Three Mile Island accident time).

• Darlington: it’s not worth the risk

• How Harper turned a nuclear watchdog into a lapdog

• Quotations about emergency planning & the causes of the Fukushima disaster

Recent Relevant Postings on this Site

• It can’t happen here!/Severe Accident Study?/It’s the planning basis, Stupid!

• Severe accident study: Not

• Refurbishment: things you need to know

• Fukushima: what really happened?

• Fukushima: Emergency Planning? Failing Grade

• Pssst. Secret nuclear health deal in 1959

• Former high-profile nuke supporters now anti

** a message from the CNSC on Sept. 21/15 reads: “Further to the August 2015 version of the study that was made available on request, the CNSC has corrected figures in tables A1.1 and A1.2. These changes do not impact the conclusions of the report.” Severe Accident Study-Sept’15