The Bruce DGR: unnecessary and harmful to Canada’s nuclear industry.


Don’t let the facts interfere with the truth

 –Farley Mowat

In spite of the very high probability of being ignored, I decided to bite the bullet and submit a comment to the Environmental Assessment of the Bruce DGR. If I didn’t submit I’m sure my conscience would bother me when this outrageous boondoggle goes forward. My submission is reproduced below.


The proposed Bruce DGR is technically unnecessary and potentially harmful to Canada’s nuclear industry. 

Canada’s strategy for the disposition of nuclear waste can be summarized in terms of four basic points:

  • High Level Waste (HLW) – Highly radioactive long-lived used nuclear fuel would be stored in a Deep Geologic(al) Repository (DGR) at depths of 500 m or more, designed to last for at least 100,000 years,
  • Low Level Wastes (LLW) – Low radioactivity short-lived wastes from reactor operations (tools, overalls, paper towels, and the like) is stored in near surface facilities to decay for a few 100 years and then go into engineered landfills.
  • Intermediate Level Wastes (ILW) – Mainly from reactor refurbishment and decommissioning (mostly low volatility metal structures) and small volumes of special wastes from operations (ion exchange resins) are stored in engineered surface facilities (concrete trenches, wells and similar facilities) with the possibility that small volumes needing special handling could be stored in the futures DGR for HLW.
  • Historical (Legacy) – Large volumes of wastes from uranium/radium mining and refining have relatively low radiation levels but are long lived, frequently occurring at defunct operations in remote areas and are dealt with generally using varied shallow land burial schemes involving excavation and covering with non-contaminated earth.

The Bruce DGR plan represents an abrupt departure from the above strategy in proposing that Low Level reactor operational wastes be treated in the same manner as High Level used nuclear fuel i.e. burial in a DGR. This is not only an unnecessary and uneconomic plan but it also sets a new and unrealistic standard for Low Level Waste disposal ultimately harmful to Canada’s nuclear industry. 

There is no operational need for the Bruce DGR.

  • The existing facilities for Low and Intermediate Level Waste surface storage at the Bruce site have proven satisfactory with an excellent safety record in terms of environmental, public and occupational health. These facilities serve all the Ontario reactors. There has been no technical or other development requiring a change to these arrangements.
  • The current Low Level waste stored in these facilities (volumes exceeding 200,000 m3) will decay naturally to radiation levels allowing their burial in engineered landfills after a few 100 years. Therefore, it is not necessary to isolate Low Level wastes from the public and the environment in a DGR for thousands of years as is the case for HLW.
  • The protections against such hazards as glaciation, human intrusion and loss of institutional controls provided by deep burial (~ 680m for the proposed Bruce DGR) while needed for used nuclear fuel repositories are not required for Low Level waste storage.

The Bruce DGR is not consistent with best international practice.

  • No other country is proposing to treat Low Level nuclear waste in the same way as used nuclear fuel. Such a strategy is considered by other nations as not only unnecessary but prohibitively expensive.
  • Sweden (Forsmark), Finland (Olklluoto) and Russia (Novouralsk) have opted for what one might call Shallow Geologic Repository (SGR) approach to store Low Level Wastes at depths of 60m, 70-100m and 7m respectively. These are essentially sub-surface storage facilities where surface storage buildings have been replaced by drive-in caverns. They are qualitatively very different than mine-like DGRs.
  • The US WIPP (Waste Isolation Pilot Plan) facility, often cited in discussions about the Bruce DGR, is designed to hold wastes from nuclear weapons development containing significant amounts of plutonium and other transuranics. It is at a depth of 600m in a salt formation. The wastes stored at WIPP are neither Low Level nor short-lived wastes. Therefore, WIPP is not comparable to the proposed Bruce DGR. There is no US plan to store Low Level waste in DGR type facilities.

The Bruce DGR would probably not result in increased public safety and environmental benefits.

  • Proponents of the Bruce DGR claim it will be have a greater margin of safety than the existing surface arrangements but no evidence to support this claim has been offered.
  • The hard rock mining involved in constructing a DGR is likely to be a much more hazardous activity in terms of worker injuries and fatalities than constructing extra building to house waste on the surface.
  • The thirty years or more of emplacement activities involved in filling up the facility with the large volumes of Low Level wastes would require workers be exposed to hazards typical of deep underground operations such as gas/dust explosions, cave-ins and tunnel collapses.
  • As the WIPP fire of 2014 showed fighting a fire underground in a DGR was difficult to locate and extinguish. The resulting contamination took about three years to clean up. It may well be that immediate access to a fire in a surface facility might limit damage and contamination.

Approval of the Bruce DGR would be harmful to the development of nuclear energy in Canada.

  • Requiring such extreme cautionary treatment of Low Level wastes as exemplified by placement in a DGR would raise unfounded and exaggerated fears of small levels of radiation in the public mind and hence, add credibility to anti-nuclear critics who make the false and alarmist claim that any amount of radiation however small is dangerous. By approving the Bruce DGR the CNSC would in effect appear to be endorsing this nonsensical point of view.
  • Implementing the Bruce DGR would set the precedent that Low Level wastes would henceforth have to be stored in unnecessary and expensive DGRs resulting in increased overhead costs for all reactor systems now and in the future. This could further discourage future investment in nuclear power.
  • Communities with Historical/Legacy Wastes could reasonably deduce from the Bruce DGR model the unrealistic expectation that their nuclear wastes should also be stored in DGRs. This might well provoke a strong reaction for fair and equal treatment from First Nations in whose lands much of the historical wastes are located.
  • The much more stringent treatment of Low Level waste from uranium mining and refining implied by the Bruce DGR would put another damper on the struggling Canadian uranium industry.
  • Fears have been expressed that the Bruce DGR with minor modifications could also be made to hold used nuclear fuel. Assurances have been given that this will not be allowed and this would require a true loss of institutional control.

The main reason given for OPG’s bizarre about face on the technology of Low Level Waste storage is simply that a DGR is the stated preference of the local municipalities. Thus, its rationale is based on a “social license” justification and not a technical one. Given this, it is not surprising the project has been debated on social, political, economic grounds rather technical ones. However, as argued above the unrealistic attitudes it fosters on Low Level waste are likely to have a negative impact on the future of the nuclear industry in Canada.

Therefore, it is concluded that the proposed Bruce DGR is technically unnecessary and potentially harmful to Canada’s nuclear industry.




The only leader in Canada’s nuclear program departs

Duncan Hawthorne’s watch has ended

Canada’s nuclear industry shows signs of circling the drain with bad news on many fronts. However, for me the most negative recent development is the retirement of Duncan Hawthorne after fifteen years at the helm of Bruce Power.

Duncan was the only true leader in Canada’s nuclear industry. (Using the past tense refers to his time at Bruce although he is still very much alive.) Leader is a word used casually in many contexts to simply mean the person in charge. Authentic leadership, the ability to motivate, unite and inspire people to accomplish set objectives, is a rare quality.  Duncan was able to do that very successfully in building and operating Bruce Power.

Duncan had a vision of where he wanted to take his company and he was able to convince his employees to buy into it by among other means bringing unionized workers in as profit-sharing partners in the corporation rather than their usual role as opponents to management.

He knew the names of most of his people and managed by continually walking around his facilities. He was approachable and encouraged employees to come to him with their ideas and problems. He was very good at this because he had come up through the ranks of the UK nuclear industry himself and so had a rapport based on understanding of all levels of the organization.

Duncan had a charismatic personality. He had a great sense of humor and with his distinctive accent was a very entertaining speaker. One of his best bits I remember was his story about how he knew he had arrived in management in the UK when the phone in his new office had “lots of buttons on it”. He was also adept at interacting with the media and was the only credible spokesman for the Canadian nuclear industry because he actually knew what he was talking about.

He skillfully steered Bruce Power through the continual incompetent screw ups of Ontario’s energy policy and managed to navigate around its openly corrupt “cash-for-access” government. In the end he got an agreement from them that will enable Bruce Power to refurbish its remaining reactors so ensuring its long-term future. To say the least he kept his shareholders happy.

Duncan believed in his community and contributed a lot to the quality of life in the areas surrounding the plant.  I think it is fair to say that he was very highly regarded by the people there. So much so that a regional clinic was recently named after him.

Another thing I very much respect him for was his announced decision to become a Canadian citizen.  I’m not sure whether this actually happened but knowing him it probably did. His commitment to the country is in stark contrast to the motley assortment of mercenary twits imported for higher management in other components of our nuclear enterprise.

I’m sorry to see Duncan go for many reasons. On a personal level although I didn’t agree with some of his ideas, I found him a good person to deal with. On a professional level, he was the true leader of our nuclear industry and we are now effectively leaderless – a bad position particularly in tough times like the present.

Camera Atomica

If people had been introduced to electricity by the electric chair, they wouldn’t have accepted it so easily.

This is a remarkable exhibition at the Art Gallery of Ontario of photographs, posters and other artifacts from the beginning of the atomic age in the 1940’s up to present times that should interest everyone in the nuclear industry. I would highly recommend it and you can see it until November 15, 2015.

More information can be found at

As one would expect the show touches in some way on every nuclear issue and I’ll make only my own observations on a few of them.

We have just marked the 70th anniversary of the two nuclear bombings in Japan in 1945 that ended World War II. There is a continuing debate about whether nuclear weapons should have been used but the show has no balance on this point. It shows pictures of the terrible injuries and devastation caused by the bombs but it does not show the fanaticism of Japanese militarism of that era when Japan’s armed forces committed atrocities in Asia as horrible as those of their Nazi allies in Europe. The issue is whether the nuclear bombings ultimately saved lives by ending this madness and avoiding a bloody invasion of Japan. The exhibit contributes little to this debate.

A consequence of the war ending “atomic” bombs was that everything atomic became fashionable in the US and Canada. There is a photo of a model at the 1952 Toronto Sportsman’s show posing with a radiation monitor and even more bizarre one of a US Navy admiral and his wife cutting a cake in the shape of a mushroom cloud. People loved all things nuclear for the first and perhaps only time in history. Then it was assumed that a nuclear war was survivable and therefore, people should build home fallout shelters where they could wait out the fallout from the war to subside. A sample shelter is illustrated in the exhibit. School children were advised to crouch under their desks and the basements of public buildings were designated and equipped as shelters. As time went on the number of weapons held by the nuclear powers grew into the thousands, too many for an exchange to be survivable, and the shelter concept went out of fashion.

The end of the honeymoon period of the first atomic age came from two sources. The first was the large number of nuclear weapons tests that dragged on from the late 1940s into the 1990s. There is a computer screen in the exhibit that blinks with each test year by year. I had forgotten that more than 2,000 tests actually took place during this period; about half were done by the US with the USSR, France, UK, making up most of the remainder. One can legitimately ask whether the US and the USSR really needed that many weapons tests and it would appear that the intense competition between these powers drove the test numbers to much higher than necessary levels. Whatever the reason the atmospheric fallout from weapon tests was significant and gave rise to the first anti-nuclear movement aimed at baning atmospheric nuclear tests particularly for the sake of developing children.

A second source of public discontent with nuclear weapons was the MAD (Mutually Assured Destruction) posture adopted by the US and USSR. If one of them attacked the other then it would retaliate with a weight of weapons sufficient to completely annihilate the attacker. Truly a nuclear exchange involving large numbers of weapons would be an Armageddon “end of the world” scenario. The classic 1964 movie Dr. Strangelove depicted an unintended nuclear war set off by a mad general. People who grew up during that era had a fear of world ending nuclear war. The reaction to that overhanging reality was the “ban the bomb/nuclear disarmament” movement that persists in many forms today.

Historically nuclear reactors for electricity production were a spin-off of a very large nuclear military industry. In the US in particular civilian applications grew out of nuclear naval propulsion. For many years up to the 1970s nuclear power was a side show but with its roots in nuclear defence activities.

The exhibit also touches on many nuclear issues including reactor accidents, uranium mining, nuclear proliferation, and radioactive waste that continue to feed the public fear and mistrust of nuclear power. The historical photographs are an impressive record of how these attitudes came about. The electric chair quote at the beginning of this piece sums up the problem the nuclear industry of today has in counteracting a negative nuclear history. Anyone seriously interested in nuclear power should see this exhibition.

Small Modular Reactors II: No Product to Sell

The Road not Taken

Even if you had the necessary funds, you couldn’t buy an SMR simply because there isn’t one developed for commercial deployment. This is not surprising because as argued in the previous post there is no significant market for SMRs. Developing a product for which there is no market only succeeds if you can create a market for something consumers didn’t know they needed (for example home computers, cell phones and many other devices). However, SMRs are not consumer products and we have to look elsewhere for motivation.

In my opinion the push for SMRs arises from many factors the most important being that there is little going on in conventional nuclear activities. The nuclear industry is in decline in most places in the world.   China, India, Russia and a few countries with new nuclear programs are the only places building reactors.

The tag line on this post is the title of a poem by the American poet Robert Frost about a walker in a wood who has to choose a path to take. The last lines are:

Two roads diverged in a wood,

and I—I took the one less traveled by,

And that has made all the difference.

Proponents of SMRs in essence say the “road not taken” is the source of nuclear power’s current decline. They claim that the wrong choices were made early in the commercial development of nuclear power and it was these mistakes that ultimately caused today’s decline. They want to reboot the nuclear industry by reverting to earlier reactor concepts especially the Molten Salt Reactor (MSR) developed at Oak Ridge National Laboratory in the 1960’s subsequently dropped in favour of the light water reactors that now make up the bulk of today’s reactors.

MSRs are touted to offer advantages in safety, economic s and reduced waste production. In terms of safety it is claimed that there are inherent safety features in the MSR concept – in my opinion there isn’t enough operating experience to prove this claim. Since SMRs would have powers in the order of a few 100 MWe, another argument is that these smaller reactors than would result in smaller accidents than the typical 1,000 MWe water reactor. This might resonate better with the public than the inherently safe claim since there are few if any believers in absolute nuclear safety since Fukushima.

Building 10 SMRs of 100MWe in place of a single 1000 MWe reactor clearly flies in the face of economy-of-scale which proponents admit. Some propose building reactor factories to turn out cookie-cutter SMRs that would avoid this disadvantage but I personally find this dubious. There is also a social economy-of-scale type problem namely that one would have to convince the public in 10 localities to obtain for each of the SMRs a social licence compared to the single one needed for the single large reactor. This would probably be much more difficult and thus, time consuming and costly. SMRs are unlikely to have any economic advantage.

In order for MSRs in particular to produce less nuclear fuel waste would require a fuel recycle with reprocessing probably at the reactor site. This could be very complicated and even, if achieved, a Deep Geological Depository would still be needed for long-lived isotopes that could not be totally consumed in the reactor. This possible advantage is unclear as is its non proliferation claim.

Notwithstanding the reality of SMRs, the presence of many colorful and successful entrepreneurs makes today’s SMR scene lively and interesting. I’ve noted a dozen or more novel nuclear schemes, some driven by business magnates such as Bill Gates, Elon Musk and Jeff Bezos. While I very much respect their business acumen, I’m not impressed by their nuclear expertise. Nevertheless, the motivation of people of that stature seems to be to altruistic i.e. to benefit the world by developing novel sources of cheap clean nuclear energy rather than to make even more money. On the crasser side there are some places that hype SMRs because they see manufacturing them as a local economic opportunity (“Podunk, SMR capital of the world”) and of course national nuclear labs who see SMR research as a source of contract research income even if they don’t  buy into the concept.

A further dimension to the SMR story is added by the vociferous and aggressive thorium lobby that sees a rebooted nuclear industry with reactors fueled by thorium instead of uranium. Once again various advantages are claimed from making this substitution. Who knows it might have been better to use thorium from the beginning of commercial nuclear power? However, today’s nuclear industry has too much momentum in investment, research, experience and expertise to ever radically change its direction. A nuclear industry reboot is not going to happen.

My feeling is the nuclear community should persist with evolutionary initiatives such as Generation IV, to improve reactor safety, lower cost and reduce nuclear waste rather than to cram nuclear generation into an inappropriate niche as part of a futile attempt to reboot the industry.

In terms of SMRs the road not taken should remain not taken.

Small Modular Reactors I: There is no market for SMRs


Small is Beautiful

This is the title of the influential book published in 1973 by the economist E.F. Schumacher. He promoted appropriate technologies meaning technologies that can be applied locally on a small scale to address the important needs of the inhabitants in a sustainable manner. This philosophy applied to localized energy generation is often used as a justification for renewable energy sources. For example, homes, farms and even whole communities could be electrically self sufficient, generating their own electricity by solar panels and wind turbines in contrast to drawing from a large power grid and thus, supporting an “off-the-grid” life style.

The wide commercial availability of solar panels and wind turbines of all sizes at affordable prices make this possible. Granted some aspects of this life style may not be easy or convenient nevertheless a significant number of individuals in developed countries have achieved this for a variety of environmental, ideological and personal reasons.

In many developing countries, off-the-grid is not a choice but a fact of daily life. About 1.5 billion people in these areas have no access to grid electricity. Schumacher’s ideas of local power sourcing would appear have the best application in such less developed areas. The tendency is to use solar panels, wind turbines and biofuels in those places as appropriate technologies for power supply.

The SMR (Small Modular Reactor) applies Schumacher’s basic idea to nuclear energy field. The concept would be to have many smaller reactors in locations where they are needed rather than a few large nuclear stations together with other electrical power sources feeding a central electrical grid from which all locations draw their power.  This centralized model is typical of Ontario and most other jurisdictions in the industrialized world.

There are many species of SMRs being pushed by entrepreneurs and companies. These designs are claimed to have superior safety, to minimize nuclear waste, to have excellent economics, to have high sustainability, to resist proliferation, and overall to be much better than existing reactors.  Development of these SMR concepts to the point of commercial deployment looks like it will cost a few billion dollars for each.

According to a 2014 report by the United Nations, about 85% of the populations of Canada and the United States live in urban areas.  Using SMRs in these urban areas would appear iffy to say the least. Even the most enthusiastic SMR fans wouldn’t propose several small reactors scattered throughout an urban area in preference to a few large reactors outside the area generating power for a grid. The increasing urbanization of populations is precisely the reason for the present model of relatively few large generation stations supplying a grid is so prevalent in North America and Europe.

Most of the 15% of the North American population living outside large cities in agricultural areas are connected to a power grid of some sort. The only places on this continent where an SMR might be considered are remote communities in northern Canada and perhaps Alaska.  This has been tried in the past.

In the late 1970’s AECL (Atomic Energy of Canada Ltd) pushed tried to market the Slowpoke Energy System (SES), an outgrowth of its successful Slowpoke research reactor. The Slowpoke is designed so that any increase in the pool temperature decreases the fission reaction rate and so it is self regulating.  This high degree of inherent safety and relatively low power (20 kW) make unattended operation feasible. Most of the Slowpokes from the 1970’s continue to provide valuable service as research tools.

The SES, essentially a 10MWe Slowpoke-based SMR, proved to be a technical failure. A prototype at AECL’s Whiteshell lab was never completed and at the time of its development (around 1980) it was rumoured within the company to have many fundamental design problems. (In retrospect, that shouldn’t be surprising in view of AECL’s subsequent Maple reactor fiasco.) Be that as it may, it was heavily marketed among other applications as a heat source for Arctic communities.  Fortunately, there were no takers because there was no product to deliver.

The important lesson from the SES parable is this SMR proved impossible to sell or more accurately to give away to any community in the Canadian Arctic. Northerners would rather import thousands or indeed millions of barrels of diesel to generate electricity and provide heat.  They were strongly opposed to the idea mainly because they felt it to be inappropriate in Schumacher’s sense.  I doubt whether their  fear of nuclear technology has lessened in the intervening years since Chernobyl and Fukushima. One might to convince them by pointing out the climate change effects on the Arctic from burning fossil fuels but their fuel represents only a miniscule fraction of Canadian greenhouse gas emissions.   In my opinion, the only SMRs that will be seen in Canada’s Arctic in the foreseeable future are those on passing Russian icebreakers and US nuclear submarines.

In Canada, I suppose SMR proponents could try to breathe life into the moribund reactors-for-the- oil- sands pipe dream that has proven a perennial non-starter for many years and is even less likely to succeed now that the oil sands industry is in so much trouble.  Heat for industrial purposes could also be produced at industrial sites by SMRs but what manufacturer would want one? There don’t seem to be any other obvious markets for SMRs in Europe, Japan and other countries in the industrialized world.

The SES was only one of many failed attempts to sell SMRs over the past few decades.  In fact I can’t find any case of an SMR up and running in North America, excluding naval propulsion reactors.  I not aware of a practical SMR operating anywhere else in the world but I suppose there might be a few in Russia supplying remote military bases.

I haven’t heard that remote localities in Africa and other less developed regions are clamoring for SMRs.  For many obvious reasons of safety, security and maintenance off-the-grid nuclear reactors are an inappropriate technology in those places.  Present scenarios involve solar and to a lesser extent wind. If one is going to use nuclear power, it’s a much better to use larger reactors in a centralized model and expand the grid where necessary, as countries such as South Africa are doing.

I conclude there is no obvious market for SMRs, no matter how “beautiful” any particular type may be.

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Bruce Nuclear Waste Repository: The Wrong Place at the Wrong Time – Part IV Economic & Political

When you find yourself in a hole stop digging.

People get so wrapped in their own activities that they don’t see the wider picture. We are all guilty of that to some extent.  Scientists and engineers in the nuclear industry tend to view situations in terms of technical problems and this is true of the Bruce DGR project. However, the decision to proceed will be made primarily for political and economic reasons as it should be.

Let’s consider economics first. How much will this DGR cost? We’ve haven’t built one in this country yet. The Nuclear Waste Management Organization (NWMO) has been conducting a well-planned transparent process eventually leading to establishing a DGR for the burial of used nuclear fuel but construction is still decades in the future. Funding for this DGR has been and will continue to be raised over many years by a small added charge to electricity rates.

The Bruce DGR is another matter. It will be funded by additional taxes and/or electricity charges to Ontarians o is let’s try to estimate its costs. The used fuel DGR planned by NWMO has an estimated cost of $18 billion but $10 billion of that is for transportation giving construction, closure, monitoring costs of about $8 billion.  OPG estimated about $2.1 billion for its DGR in a 2012 letter based on a consultant’s estimate from 2004. Multiplying by pi (Blackett’s rule of nuclear estimates) gives $6.6 billion. The recent Niagara tunnel excavation was completed in 2013 only four years behind schedule and only 50% over budget but this OPG project was hydroelectric and not nuclear.  The US experience also may help. Building the US Yucca Mountain DGR planned for used nuclear fuel cost $15 billion to when work was stopped although it may be restarted. Estimates indicate that WIPP, the US DGR that OPG held up as an example until its accidents earlier this year, has burned up about $5.5 billion to date and total costs are estimated around $9 billion far exceeding its original estimate of $440 million. Based on the foregoing, my nominal estimate for the Bruce DGR is $6-8 billion. That’s a lot of money for an optional project.

As pointed out many times in this blog, the government of Ontario has complete control over OPG. The Liberal party of Ontario has a solid majority mandate to be that government for the next four years. However, in the recent election all the constituencies along the eastern shore of Lake Huron voted for the opposition Progressive Conservative party including Huron-Bruce where the DGR would be located.  It’s inconceivable that the Liberals would allow a tasty multi-billion dollar chunk of make-work pork to go to the Kincardine area simply to please its citizen who voted against them. It just makes no political sense and for that reason alone the DGR project is a non-starter.

The Ontario government is faced with a scary financial deficit.  They’re looking to cut budgets in the face of the pressing needs to replace $400 billion worth of crumbling infrastructure such as roads, bridges, public housing, transit, sewers and a multitude of other essential replacements and repairs.  Although it is not in that category of down-to earth rebuilding, it is arguable that OPG’s Darlington refurbishment project would provide economic stimulus especially to preserve the high-value high-tech nuclear industry.  Most of the companies associated with refurbishment are located in Liberal suburban or urban ridings including Darlington itself.  Personally I think refurbishment keeps the Canadian nuclear industry alive preserving the nuclear option for the future.

It is predictable there will be savings from deep staff cuts at OPG as it goes from the current ten reactors to four by 2020. It is also likely that OPG’s scandalously lavish pension plan (the company contributes four dollars for each employee dollar) will be scaled down. An independent committee on government assets has also just recommended that OPG be split into separate hydroelectric and nuclear parts. The next stage could well be leasing the nuclear part to Bruce Power who would much better manage OPG’s nuclear assets.

The projected cuts at OPG will make it more likely the refurbishment projects (at least the first reactor) will go forward provided they stay on schedule and on budget. The refurbishment budget is in the order of $15 billion an amount, if history is any guide, will be substantially over run. The DGR project would add a further $6-8 billion dollar project (assuming no cost overruns) on top of refurbishment. There’s no way the cash-strapped Ontario government is going to allow that. The taxpayers of Ontario will be made to pay for these additional nuclear program costs either through higher electricity bills (an increasing barrier to attracting new manufacturing to the province) or through higher taxes, both unappealing politically.

OPG senior management claim there is a “business case” for the DGR compared to the costs of continued above-ground storage. (One might question the real-world business experience of OPG senior management?) The documentation around the project shows the DGR advantage is thin even using low-balled construction costs. This margin would completely disappear when the usual overruns appear.  Some may think I’m being too hard on OPG to which I would reply it’s because they have had such an abysmal track record for not being able to bring nuclear projects in on time and on budget.

As explained in a previous post the Bruce DGR is not needed. A feasible solution is to leave the low-level operating waste in above-ground storage where it is now for few a hundred years after which its radioactivity levels will have decayed to a few percent of its initial level. At that point it could be safely placed in a well-designed land fill. The intermediate level waste, consisting mainly of used metal reactor parts arising from refurbishment and decommissioning, could also be left in above-ground storage as it is now or it could be buried in a designated section of the NWMO DGR eventually to be constructed for used nuclear fuel hopefully at a site far from important bodies of water.

My advice to OPG is to stop digging and abandon the Bruce DGR project in the face of the compelling economic and political reasons why it is simply not going to be allowed to happen.


Bruce Nuclear Waste Repository: The Wrong Place at the Wrong Time – Part III Social License

Local support and the sleazy politics used to obtain it were discussed in the Part I post. However, there is a serious issue concerning the social license per se namely whether it should be considered at all by the hearing Panel.

The first Canadian commission to consider a DGR was the Seaborn Commission formed in 1989 to do an Environmental Assessment (EA) of AECL’s technical plan developed over the previous twenty years to deposit nuclear fuel waste deep in a granitic rock pluton in the Canadian Shield. There was extensive public consultation with over 500 oral submissions and a similar number of written submissions over the nine year mandate of the Commission.  Its 1998 report concluded that while the technical plan was a sound basis for proceeding, public acceptability of the concept had not been demonstrated. In today’s terminology the proponents weren’t able to prove they had the necessary “social license”.  A few years later, the federal government passed legislation establishing the Nuclear Waste Management Organization (NWMO) with a primary objective of ensuring the social licenses necessary for nuclear fuel waste disposal were in place.

The CNSC has recently stated in the slides from a recent Calgary speech by its president:

“[CNSC’s] Mandate does not include social licence” [but rather] “Commission makes science-based risk informed decisions”

“The CNSC does not make determinations based on social acceptance or economic benefits”

Since it’s acting on behalf of the Commission the Panel reviewing the Bruce DGR according to the CNSC president should have no business assessing social license issues and must stick to technical matters only.  I find it remarkable that they can make this claim in view of the historical precedent of the Seaborn Commission.  However, as the recent Federal Court decision has shown the CNSC doesn’t have a good handle on how to conduct an EA.  This position is also taken in spite of CNSC’s aggressive promotion of the nuclear industry under the guise of providing technical information (personally I’m all in favour of promoting nuclear power but the-should-be-unbiased CNSC is the wrong agency to do it).

At the Panel hearings OPG highlighted the approval of the local community as a major argument for the Bruce DGR and thus, the Panel accepted lots of testimony on this issue. By so doing the Panel now can’t avoid making a pronouncement on whether there’s a social license for the facility. If it doesn’t then that omission alone would be grounds for an appeal to the Federal Court of Canada especially since the Canadian Environmental Assessment Act (CEAA) requires an EA to take into account factors relevant to the social license such as: public comments, purpose of the designated project and alternative means of carrying out the objective of the project. An EA must be conducted in accordance with the CEAA and the opinions of the CNSC president quoted above are totally irrelevant.

During the hearings intervenors noted that some 125 municipalities around the Great Lakes had passed resolutions opposing the Bruce DGR and so OPG’s social license was obtained by dubious means from only 11,000 people in the Bruce area and not the 11,000,000 represented by the resolution s. Clearly, the major reason for the widespread public opposition is that the proposed DGR is at the Bruce site beside the Great Lakes. Thus, ironically the factor most attractive to OPG is exactly why the social license is lacking.

Some nuclear types will fulminate that this is just another instance of “politics” creating opposition to what they believe a good technical solution. This attitude reflects an all too common belief in the industry that the public doesn’t understand the technology and thus, makes wrong decisions based on scientific ignorance implying an educated public would approve all of their actions.  They are mistaken because perception is reality in this case. Most people have a bad gut feeling about storing nuclear waste beside the Great Lakes.  The technical presentations at the hearings could only lay out the physical parameters of the problem but they didn’t convince the public to change its common sense view that the Bruce DGR is dumb.  While some technical idealists may conceive of a perfect world where all decisions are based solely on science, I’m glad I live in a democracy where the politics of public acceptance trumps the opinions of technocrats like me.

I’m afraid that the Bruce DGR may poison the waters for the NWMO’s planned DGR for used nuclear fuel. A negative finding by the Panel on the Bruce DGR or its cancellation by OPG would make it more difficult to secure the social license for the used nuclear DGR sought by NWMO since an inference might be drawn that DGRs in general are undesirable. I would find this distressing since I fully support the need for the used fuel DGR and the process being used by NWMO to find a site for it.

The following statements by Bruce Power chief Duncan Hawthorne quoted in the Kincardine News of February 14, 2013 are worth noting:

“Among them was his belief residents of potential host communities are unable to differentiate between the plans for two DGRs.”You’ve confused the whole community,” Hawthorne said he had written to the NWMO. “We’re looking at something that’s 125 years from now. Go away for a decade.”

He’s got it completely wrong; it’s the Bruce DGR that should go away.

In the last post in this series I’ll discuss the political and economic reasons why the Bruce DGR is unlikely to happen.