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.

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.

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

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

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.

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.

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

* Note on September 8/14: Another round of DGR hearings! 10 days, starting Sept.9th. Find all the info you need – schedule, location, how to access live Webcast, here.

** 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.

DNA Submission to CNSC on Pickering Relicensing Plans

With a grant received from the Canadian Nuclear Safety Commission (CNSC), DNA hired Fairewinds Associates’ chief engineer Arnie Gundersen to make comments on OPG’s plans for extending the licence of the Pickering reactors.
His report can be found here.

Check it out!

It’s easy & quick to read. Worth your time.

It concludes:

CONCLUSION

In conclusion and in my expert opinion, the license extension beyond the original design life of the Pickering station to 2018 should be denied. If an accident were to occur at Pickering, the plant is unprepared to prevent the release of significant quantities of radioactive materials. Radioactive materials released from nuclear power accidents contaminate the air, the water and the soil, and enter into the water table and food chain. The environmental and health damage created by the release of radioactive materials lasts for decades after any radioactive material release has occurred.

OPG has yet to produce the safety studies required to support its claims that the station’s limiting components can operate reliably and safelty for the next five years, which is past their design life. It would therefore be imprudent for the Commission to approve such a renewal without all the statutorily required technical and safety information.

With six operating nuclear reactors, the Pickering Station is one of the largest nuclear power plants in the world. It is also one of the oldest nuclear power plants and one of the closest nuclear stations to a major population center. These three factors pose a unique risk that would not be deemed acceptible in the United States.
Given the Pickering Station’s already surprisingly high large release frequency, it is imperative to improve emergency preparedness in Toronto and its surrounding area.

The evidence reviewed by Fairewinds Associates makes it clear that both the CNSC and OPG have failed to grasp the magnitude of the essential messages from the Fukushima Daiichi accident. A severe accident could occur at an aging end of design life plant like the Pickering Nuclear Generating Station.

** NOTE: Mr. Gundersen will present his findings to the CNSC Tribunal on Thursday morning, May 30, 2013.

Pickering Hearing – May 29/30/31

#1 – Pickering Licence Extension
OPG (Ontario Power Generation) wants to push the Pickering reactors beyond their 210,000-hour design life.

This could have disastrous consequences for the people of Durham Region (& Toronto!).

Further afield also, since the plant sits on Lake Ontario, the source of drinking water for 40 million people, many of whom live on the U.S. side of the border.

Hearing coming up May 29/30/31st (in Pickering).

Great submissions here if you would like to hear what some of those who oppose OPG’s plans have to say:

***** Listen to this!

Regarding the OPG proposal to run the Pickering reactors beyond their planned design life, it seems the CEO of Hydro Québec did not consider it appropriate or “safe” to run Quebec’s reactors past their 210,000-hour shelf life. He is quoted as having said: “You’ve talked a lot about safety issues, but I can tell you that Hydro-Québec’s management in no way would have considered to go beyond 210,000 hours even if it had been possible according to the design. 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.” (Thierry Vandal, CEO of Hydro-Québec, January 2013.)

(Yet it’s somehow acceptable to do this to Ontarians? With no safety reports on the table?)

And this: Toshimitsu Homma, a member of the Japanese delegation of the Japan Atomic Energy Agency, said at a recent (April 2013) IAEA conference held in Ottawa, 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.” He added that, therefore, insufficient attention was paid to such a severe ‪nuclear accident by authorities before it happened.

Of course we are in exactly the same situation here, now!

# 2 – GREAT PODCAST W. ARNIE GUNDERSEN & GORDON EDWARDS!

Latest podcast on Fairewinds site — of interest re: the upcoming Pickering hearing. ** only 22 minutes long

Podcast here

Gundersen is presenting for Durham Nuclear Awareness, & in this chat with Dr. Gordon Edwards, a # of important topics are covered. As we all know, nuclear energy is very complex.

There is much that “average people” find too technical or difficult to understand (the nuclear industry seems pretty intent on having “the average Jane” feel too stupid, I think).

Gundersen & Dr. Edwards do some very useful de-mystifying. They agree 100%: Pickering needs to be shut down ASAP — no license extension!

Please consider listening to the podcast — it’s important! People in Durham Region & Toronto (& all over Ontario, and down south of us, in the U.S.) are all down or up-wind & up or down lake, whether we like it or not.

# 3 — Brand-new “Nuclear Hotspots Map” has just been released!

Nuclear Awareness Project did the first one, in 1990/91. Now it has been updated & is on the Great Lakes United Web site.

It is a very sobering map to contemplate.

& to contemplate where the nuclear industry is planning to bury dangerous nuclear wastes.

Take a look!!

****** Please share this information w. others you know who need to know it!