CCNR Comments to CNSC on Darlington Refurbishment and Continued Operation
----- Original Message -----
From: Gordon Edwards
Sent: Wednesday, August 24, 2011 1:52 PM
Subject: CCNR Comments to CNSC on Darlington Refurbishment and Continued Operation
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To: Andrew McAllister, Environmental Assessment Specialist
Environmental Assessment Division,
Directorate of Environmental and Radiation Protection and Assessment
Canadian Nuclear Safety Commission
P.O. Box 1046, Station B
Ottawa, ON K1P 5S9 Email:
EA@cnsc-ccsn.gc.ca
August 22, 2011
Dear Mr. McAllister:
Re: Refurbishment and Continued Operation of the Darlington Nuclear Generating Station Draft Scoping Information Document CEAA Registry #11-01-62516
http://www.newswire.ca/en/releases/archive/
August2011/25/c6175.html
Please find attached (below) comments from the Canadian Coalition for Nuclear Responsibility (CCNR) regarding the Draft Scoping Information Document for Ontario Power Generation's application to refurbish and continue operations of the Darlington Nuclear Power Plant in Clarington, Ontario.
If you have any questions concerning this submission you may contact me at (514) 489 5118 [office] or at (514) 839 7214 [cell] or by e-mail at
ccnr@web.ca.
Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility.
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The Canadian Coalition for Nuclear Responsibility (CCNR) is disheartened to learn that the Canadian Nuclear Safety Commission (CNSC) is unwilling to call for a full Panel review of the EA for the refurbishment and continued operation of the existing four Darlington Nuclear Reactors.
We have seen how accommodating the CNSC can be when it comes to requests for special treatment from its licensees.
Thus Bruce Power had no difficulty in getting a CNSC licence to ship 16 steam generators on a single vessel, even though the total estimated amount of radioactivity on that shipment far exceeds the maximum amount allowed by IAEA regulations. All it took was a Special Arrangement from the CNSC to get around that regulation - a kind of latter-day version of the papal dispensation.
Similarly Hydro-Quebec had no difficulty in getting a five-year extension of its operating licence for the Gentilly-2 nuclear reactor, even though the key Safety Document required for this licensing action has not yet been produced and will not be produced until many months after the licence extension is granted. All it took was a CNSC decision to suspend the regulation in order to indulge the delinquent licensee.
But when it comes to the Environmental Assessment associated with rebuilding the cores of four huge nuclear reactors sited on the shore of one of the most important Lakes in North America, the CNSC finds itself unable to grant the request of a large number of responsible public interest organizations to have a more thorough review process.
Since law does not require a Panel Review, there cannot be one. Rules are rules, the CNSC seems to be saying, and exceptions are intended to benefit only the nuclear industry - not those who are profoundly concerned about how that industry may endanger the health and safety of citizens and cripple the environment.
This is particularly disheartening in light of the ongoing Fukushima disaster. That terrible event goes a long way towards demonstrating that the proponents of nuclear power, including the regulatory agencies, have been wrong in asserting that nuclear power is safe.
That assertion - that Nuclear Energy is Safe - boldly adorns the cover of the most recent CNSC Annual Report, where it is even described as a 'FACT'. The same assertion is trumpeted on the CNSC web site with a grandiose fanfare of triumphant music. Do the CNSC Commissioners and Staff believe that just saying it makes it true?
The Fukushima disaster is a grim reminder that every nuclear reactor is potentially very dangerous indeed. Each reactor contains an inconceivably large inventory of radioactive poisons that - under unanticipated accident conditions - is able to render large areas of land uninhabitable, contaminate enormous volumes of water and soil, and sow financial and political chaos.
Fukushima is a warning that no responsible individual or agency should ignore. Fukushima demands that we rethink the most fundamental assumptions about nuclear safety. Yet institutional inertia is hard to resist, and there is an almost overwhelming temptation for things to go on as before without any profound rethinking or reassessment.
The multibillion-dollar reconstruction of the cores of four of Canada’s largest power reactors should not be seen as a trifling matter, and treated as if it were just a maintenance outage that is somewhat lengthier than usual. It raises fundamental questions about whether to refurbish these reactors at all, or at the very least, how to rebuild the reactors so as to correct some of the errors of the past that have been overlooked a result of unquestioned assumptions about reactor safety.
In order for a more profound assessment of these questions to take place, a more elaborate Environmental Assessment process is needed - one that will allow and encourage citizens to play a much more significant role in challenging those assumptions which have become ingrained in the minds of nuclear engineers and nuclear analysts, both in the utilities and in the regulatory agency.
For example, we must begin to seriously address the potential consequences of catastrophic accidents at nuclear reactors in Canada. We must stop using 'low probability' as an excuse for not thinking of and not planning for such events.
Is the vacuum building at Darlington NGS capable of handling a multi-unit meltdown accident, such as happened at Fukushima Dai-ichi? Following such an accident, how long will it take, realistically speaking, before radioactive emissions will have to be pumped into the environment in order to maintain negative pressure?
Can the vacuum building be redesigned or rebuilt to correct any weaknesses that it may have in coping with multi-unit meltdowns? Should this not be required by the CNSC as part of the refurbishment plans?
Given the huge volumes of contaminated water that were flushed through the cores of the crippled Fukushima reactors, much of it dumped into the Pacific ocean, what degree of contamination of the Great Lakes and the St. Lawrence River might result from a similar accident at the Darlington NGS?
Should there not be an enormous reservoir constructed at Darlington so as to collect the enormous quantities of contaminated water that would result in the event of a multi-unit meltdown, so as to prevent massive radioactive contamination of the Great Lakes, which serve as a source of drinking water for tens of millions of people? Should this not be required by CNSC as part of the refurbishment plans?
These are not academic questions, they are realistic ones. Calculated probabilities are mathematical fictions having no power over actual events. In terms of nuclear safety, probability is basically a quantitative expression of our ignorance and our expectations. While the probability of the Fukushima disaster would have been calculated to be virtually zero by nuclear analysts before the accident took place, we can now see in retrospect that the probability of that disaster, given the actual circumstances, was 100 percent.
Probabilistic assessments do have a useful role to play - in comparing competing engineering designs, for example - but probabilistic assessments cannot and should not be used to deny the possibility of a disaster, or to ignore the consequences of such a disaster. The misuse of probability in this way is scientifically and morally wrong.
In Japan, months went by after the Fukushima disaster before there was any effective monitoring of the food supply. As a result, significant amounts of beef contaminated with radioactive cesium were sold and consumed before the degree and extent of the beef contamination was documented. There was similarly little or no effective monitoring of the extent of contamination of milk by iodine-131 and iodine-132 (produced by the rapid decay of tellurium-132) in the early months following the accident. Mushrooms, rice, green tea, seaweed, even wild boars are additional examples of foodstuffs that acted as vehicles for radioactive contamination from Fukushima to enter the bodies of men, women and children in Japan.
What procedures are in place to ensure that there will be rapid and comprehensive monitoring of food following a potential disaster at Darlington? Shouldn't the elaboration of such procedures be a licence requirement before any 'continued operation' of the Darlington reactors is authorized by the CNSC?
It is universally acknowledged in the nuclear community that passive safety features are preferable to safety features that require active intervention. Yet the two independent fast shutdown systems in the Darlington reactors are included in the design in order to compensate for the positive void coefficient of reactivity, endemic to the CANDU design and to the Chernobyl reactor that exploded in the Ukraine over 20 years ago. The positive void coefficient of reactivity was also a characteristic of the NRX reactor at Chalk River, which exploded in 1952, and the Lucens reactor in Switzerland, which exploded in 1969.
Essentially, the positive void coefficient of reactivity is an undesirable feature because it means that a sudden loss-of-coolant accident will be accompanied by a rapid surge in reactivity. Unless this surge is quickly terminated by the intervention of fast shutdown systems, the core will 'disassemble' - a polite word that implies massive damage to the core of the reactor, possible accompanied by explosions, possibly leading to a full or partial core meltdown.
In light of the Fukushima disaster, which took place in one of the most industrially advanced nations in the world, a nation which is world famous for its superiority in advanced technology, surely the CNSC should examine the wisdom of CANDU reactors continuing to rely on the intervention of fast shutdown systems rather than on the redesign of the fuel or the core of the reactors so as to drastically reduce or maybe even eliminate the positive void coefficient altogether. Shouldn’t this be a high-priority requirement for the approval of any refurbishment plans?
These are only a few of the questions that can and should be raised during the Environmental Assessment of the proposed refurbishment and continued operation of the Darlington Nuclear Reactors. Other questions involve the need to calculate the integrated population dose from both external and internal radioactive sources in the event of a major accident, and mitigation measures to prevent the transport of radioactive contaminants on shoes, skin, clothing, and hair.
There are also questions related to the ongoing operations of the Darlington nuclear reactors after refurbishment. Surely a high priority should be given to drastically reducing the emissions of radioactive tritium into the environment, given the fact that two independent scientific advisory committees have already recommended greatly reducing the permissible levels of tritium in drinking water, and the inexorable buildup of tritium levels in Lake Ontario may well become a source of international displeasure in the foreseeable future. Should not the CNSC be demanding the incorporation of technologies that will drastically reduce tritium emissions as part of the licensing requirement for any continued operation of the Darlington reactors?
Should this not be part of the CNSC regulatory requirement for the acceptance of any refurbishment plans?
Or is the ALARA principle just a meaningless slogan designed to confuse the public [CNSC literature routinely states that all exposures to radiation are to be kept "As Low As Reasonably Achievable". This principle is referred to as the ALARA principle.]
Consideration should also be given to public risks involved in the road transport of highly radioactive retube materials from the Darlington site to the Bruce site over provincial highways, as well as the ultimate disposition of the bulky and very long-lived refurbishment wastes from the Darlington reactors.
The Canadian Coalition for Nuclear Responsibility urges the CNSC to reconsider its decision.
We strongly recommend a full Panel review.
- - - - -
Darlington New Nuclear Power Plant Project Joint Review Panel Submits Environmental Assessment Report
http://www.newswire.ca/en/releases/archive/
August2011/25/c6175.html
News Release
OTTAWA, August 25, 2011 – The Joint Review Panel for the Darlington New Nuclear Power Plant Project today announces that it has submitted its report to the federal Minister of the Environment.
The report follows a review of the environmental impact statement prepared by Ontario Power Generation (OPG), a public hearing held over seventeen days in March and April 2011, and an in-camera session to address security matters held in May 2011.
During the review the Joint Review Panel received submissions and heard presentations from OPG, Aboriginal groups, federal and provincial governments, local governments, environmental groups, individuals and organizations interested in the potential effects of the Project. The Panel thanks all those who participated in this review. The information that was submitted and presented was appreciated by the Panel and given careful consideration.
The Panel concludes that the Project is not likely to cause significant adverse environmental effects, provided the mitigation measures proposed and commitments made by OPG during the review and the recommendations in the Joint Review Panel Environmental Assessment Report are implemented.
In this report, the Panel highlights actions that are required to address the effects of the Project on aquatic and terrestrial biota and habitat, health, waste management, emergency preparedness and the consequences of a severe accident, nuclear liability insurance, and land use.
Subject to the Government of Canada response to the report, the Joint Review Panel may then proceed to make a decision on OPG’s Application for a Licence to Prepare Site.
A summary of the Joint Review Panel Environmental Assessment Report is available on the Canadian Environmental Assessment Registry at
www.ceaa-acee.gc.ca and on the Canadian Nuclear Safety Commission Web site at
www.nuclearsafety.gc.ca . The Panel report will be posted on these Web sites once it has been translated into French.
The Panel report is available upon request through the panel secretariat at
Darlington.Review@ceaa.gc.ca or
JRP-OPG-Darlington@cnsc-ccsn.gc.ca .
The project is a proposal by OPG for the site preparation, construction, operation, decommissioning and abandonment of up to four new nuclear reactors at its existing Darlington Nuclear site located along the north shore of Lake Ontario, in the Municipality of Clarington. The project is expected to generate up to 4800 megawatts of electricity for delivery to the Ontario grid.
The Joint Review Panel for the Darlington New Nuclear Power Plant Project is an independent body, mandated by the Minister of the Environment and the President of the Canadian Nuclear Safety Commission to assess the environmental effects of the proposed project and consider the Application for a Licence to Prepare Site.
Regards,
Julie Bouchard
Tribunal Officer/ Agente de tribunal
Secretariat/Secrétariat
Canadian Nuclear Safety Commission/
Commission canadienne de sûreté nucléaire
613-995-1703