Canada’s nuclear regulator gets spanked by the Federal Court

A recent Federal Court of Canada decision found that the license issued by the CNSC to construct two new reactors at Darlington was invalid because the required environmental assessment was incomplete.

First a little background might help. In 2008 the Ontario government was actively seeking to construct new reactors but hadn’t decided on what type of reactor to choose or on how many to build. Nonetheless they wanted to start environmental assessments right away and so they opted for a scheme that apparently some consultant convinced them had worked in the US.  This idea was to do a generic assessment in which the number or type of reactor to be built is not specified but based on keeping emissions to the environment, accident characteristics, and other factors within certain boundaries, later called a Plant Parameter Envelope (PPE) approach presumably to give it more technical credibility.

OPG (Ontario Power Generation) enthusiastically endorsed this concept. However, it was obvious even then that Ontario had again opted for political expediency over science.  In evidence I offer this quote from a post on this blog dated May 16, 2008:

“Generic environmental assessments of the new Ontario reactors to be located at the existing Bruce Power and Darlington nuclear sites are being organized.  The value of these assessments is questionable when the number and type of the reactors to be considered is unspecified. However, in an even more bizarre turn of events initial indications are that these reviews will be conducted by commissioners of the Canadian Nuclear Safety Commission (CNSC) who will in effect be reviewing their own licensing process. “

The Canadian Environmental Law Association (CELA) eventually took the CNSC to Federal Court after they granted a license to OPG to build two new reactors at Darlington based on a PPE-based generic environmental assessment (EA). The resulting court ruling of May 14, 2014 can be found at

http://decisions.fct-cf.gc.ca/fc-cf/decisions/en/item/71634/index.do

Interestingly, the Court did not find the EA to be flawed because of the PPE method per se but ruled that it failed to take into account differences in waste emissions, disposal of used fuel types and aspects of accident mitigation measures. As the Court pointed out the EA could be remade to be acceptable if it were revised to address these issues.

Like many other nuclear types this development surprised me. I suppose I’d always pictured the CNSC as all powerful in the nuclear field meaning “its word is law”.  Apparently this is not the case at all. On the contrary as this judgment shows CNSC decisions can be successfully challenged in court. Understanding what this means is well worth considering since it will have major consequences for the nuclear industry down the road.

At first sight some industry observers said the ruling didn’t matter since last October (2013) Ontario finally decided not to build any new reactors (after wasting a great deal of money and many people’s time). I think claiming this makes the ruling “moot” is a naïve reaction.

The main impact is that the Court has severely undermined the credibility of the CNSC and opens up its future licensing processes to protracted litigation. Precedent is a powerful concept in law. If you don’t believe that, just look through the ruling linked above which seems to refer to lots of what previous judges have said about EAs. From this time on important decisions of the CNSC (the significant ones involving an EA) will be questioned by law suits. The suits will probably start out by noting this ruling that effectively says the “CNSC blew an EA” with the implication it may well screw up others.  With this victory the courts have now become the new battleground for anti-nuclear groups and the only limitation I can see is how much money (or legal volunteers) these organizations have for legal work.

In recent years I have noted with dismay in this blog the CNSC’s increasing inclination to agree with most schemes proposed by OPG including the not-so-clever PPE approach. The tendency has been for them to come down full bore on small firms that use radioactive sources to show they are tough regulators but to essentially agree with anything OPG suggests however dumb presumably in a  “go along to get along” spirit. This may well be, as I’ve suggested in previous posts, because the CNSC has become the main promoter of nuclear power in Canada.  I think it’s high time the CNSC reconsider its too close relationship with OPG because this ruling in part resulted from that attitude.

Only a short time ago the federal government gave the CNSC full authority to conduct its own EAs of nuclear proposals only referring when needed to Environment Canada and other federal entities such as Fisheries and Oceans and Health Canada.  That had no sooner been done when this ruling made the CNSC look incompetent after one of its licences was bounced by the Federal Court because of a bungled EA.

To be slapped down by the Federal Court constitutes a severe embarrassment to the CNSC, itself a quasi-judicial federal tribunal.  I believe it’s time for far-reaching reforms at the Commission including a weeding out of its senior management.

 

Let’s have the nuclear pill at last

Acknowledging the need for easy public access to potassium iodide (KI) pills is a further acceptance of the reality that nuclear accidents could happen in Canada.

Until the Fukushima accident the policy of Canada’s nuclear industry to KI pills was that they shouldn’t be distributed to populations near reactors because it might unnecessarily alarm people and give credence to charges that nuclear power was dangerous.  Similar opinions were held on alerting siren systems, online real time radiation data, evacuation rehearsals, and other accident mitigation measures, all then regarded as talking points for ant-nuclear critics. Thankfully, these opinions of the DOUGS (Dumb Old Utility Guys) had been fading since the Chernobyl accident and have basically disappeared since Fukushima.

We need to understand what KI pills are and what they do.  The thyroid gland in the neck regulates many important functions of our bodies such as “how quickly the body uses energy, makes proteins, and controls how sensitive the body is to other hormones” (quote from Wikipedia).    To function properly, the thyroid needs iodine which is taken up from various food sources or, in places where sufficient iodine isn’t available in the local diet, from iodized table salt. Not surprisingly adequate iodine is also essential for the normal intellectual development of children.The iodizing of salt by adding compounds such as KI to it has proved a very cheap and effective public health measure in most countries of the world.

In a nuclear accident radioactive iodine is released as a gas which can readily be inhaled and so taken up in the thyroid and then can eventually cause thyroid cancer especially in children. By taking KI pills you can load up your thyroid with harmless (non-radioactive) iodine so when exposed to the radioactive type your already iodine-saturated thyroid won’t absorb it. For this to work you need to take the KI pill before any significant release of reactor iodine gets to you. This means you have to have pills on hand and ready to use as soon as you know an accident is happening.

KI pills are very good for protecting thyroids and preventing thyroid cancer in children – both very worthy objectives.  However, they should not be viewed as a preventative or a cure-all for all types of radiation sickness as some uninformed people believe.

KI pills should be distributed to all homes within, say a 20 km radius, of reactors. Not as has been the case for example at Pickering where in a compromise scheme KI pills were stock piled in drugstores. Presumably, you go to your local pharmacy in case of a nuclear accident. There were also pills at local schools but I suppose if there were an accident outside of school hours you have to send your kids to the drugstore. Not only should the pills be in homes but there must also be an effective warning system that tells people living near reactors to take their KI pills.

The regulator and our nuclear utilities are finally considering doing exactly that after knowing since the 1950’s that it was feasible and done in other countries. There can be no excuse for any more foot dragging in providing KI pills to homes around Canadian reactors.

Canada’s nuclear industry needs leadership

Strong leadership will be needed for our nuclear industry to survive the coming decade.

The problems of the nuclear industry are often portrayed by its members as originating in public fear fanned by hostile critics and the media. Certainly there’s some truth in that but in my opinion that neglects the main reasons for its decline namely a lack of influential politicians willing to go to bat for the industry and the fact that there are very few nuclear leaders in Canada.

Dr. David Keyes was one such leader. During the world’s first major nuclear accident at Chalk River’s NRX reactor in 1952, Keyes stood at the lab’s gatehouse calmly smoking his pipe and greeting workers by name as they evacuated. As the leader of the lab, his actions damped down any panic that could have occurred and in fact he remained on site for most of the accident. Although Keyes had long departed by the time I arrived in the late 1960’s, old-timers still remembered “daddy Keyes” with respect and affection as an avuncular but strong leader.

Other industry leaders emerged in the years after Keyes who developed the CANDU reactor and pioneered its adoption by the utilities. We had politicians both federal and provincial that backed nuclear energy and pushed its growth in spite of the objections of anti-nuclear organizations as is now happening in places like Korea, Taiwan and India but that’s all gone now in Canada.

The privatization in 2001 of eight nuclear reactors of the former Ontario Hydro to form Bruce Power has proved very successful, achieving excellent performance primarily based on the strong effective leadership of Duncan Hawthorne. He has transformed the former corporate culture of Ontario Hydro to a profitable business model, has driven its high safety record, has earned the loyalty and respect of his employees and brought the unions in as partners instead of adversaries all the while keeping his shareholders happy. Although I certainly don’t agree with some of his moves, overall he remains the only credible spokesperson for the nuclear industry in Canada and its only real leader.

On the other hand the nuclear component of OPG (Ontario Power Generation) is badly in need of leadership. To be fair OPG operates in a public service environment where leadership is only the prerogative of politicians advised by legions of know-nothing fart catchers who qualified for their jobs by putting up signs and handing out literature during the minister du jour’s election campaign. Unlike Bruce Power OPG can’t lobby politicians or advertise at Maple Leaf games. Also different is the domination of OPG by rapacious unions resulting in lavish salaries and many redundant jobs. The OPG hierarchy gives me the impression of being transient and mercenary. For example, how many of the OPG imported brass have shown a commitment to this country by becoming Canadian citizens?

The coming refurbishments of ten reactors (six at Bruce and four at OPG’s Darlington station) will entail intense competition for limited resources that I called the “choke point” in a previous post. My bet is Bruce power will run rings around OPG in the contest. OPG’s reaction is the great refurbishment plan exercise by OPG documented elsewhere on this blog, an exercise in bureaucracy that proves my point that OPG management is only able to administer rather than lead. The coming refurbishments will require a high degree of cooperation and coordination that simply won’t happen between competing nuclear entities. By the way it was just announced that the plan is already more than $200 million over budget before implementation even starts in 2016

The shutdown of the six other reactors at Pickering by 2020 will cause massive layoffs that even the OPG unions with the greatest possible degree of splitting existing jobs into multiple new ones (“feather bedding”) will be unable to avert. In most cases the axed employees will not have the skill set or experience to contribute to the refurbishments. For the good of the industry one would like to see the best employees retained but this can only happen in a nuclear entity combing both Bruce Power and OPG. After 2020, OPG with four reactors will be the tail to Bruce Power’s dog with eight

For all of these reasons the only practical solution I can see to avoid future chaos is to merge the nuclear parts of OPG into Bruce Power by leasing the four Darlington reactors to them. This should have been done years ago and whether the politicians can overcome their ideological differences enough to do it remains to be seen

Warning to the nuclear industry: beware the gasman

If there are any problems with refurbishment, gas is waiting in the wings ready to replace nuclear generation.

I gave a talk on the status of nuclear power at the CERI Natural Gas conference in Calgary this week and learned a lot about the situation of the Natural Gas (NG) industry. Frankly I hadn’t realized the world had changed so much in a few short years.

The development of increasingly sophisticated and effective technologies for the fracking extraction of gas has led to a profound revolution in gas markets. There are now vast reserves of gas available at low prices. As one person at the conference said “we are awash in cheap gas”. For example, just the state of Pennsylvania has gone from producing about 0.7 Bcf/day (billion cubic feet per day) in 2009 to almost 10 Bcf/day in 2013, a production level similar to that of Alberta. That state has gone from an importer of gas to a major exporter in a few years.

Such rapid and dramatic changes have come about from the fracking exploitation of large areas of gas deposits (“plays” as the gas people like to call them) such as the Marcellus and Utica plays in the US northeast just to the south of lakes Erie and Ontario. Consequently the geography of gas markets has shifted. The gas now used in Ontario is increasingly imported from US Marcellus producers rather than from Alberta.

In the last few years, very large gas deposits exploitable by fracking comparable in size to the Marcellus formation have been identified in north east British Columbia and Alberta notably the Montney and Horn River Basin plays. The BC government is encouraging the export of this gas via pipelines to the coast and then by LNG (Liquefied Natural Gas) tankers to Asian markets. However, this plan requires a big capital investment for new pipelines and LNG terminals and several years to obtain permits for their construction. Until then, this gas is stranded.

Therefore, Canadian producers are looking hard for new markets for large amounts of cheap gas. Electricity production is one possibility. Alberta will likely replace its current coal-fired generators with combined cycle gas generation but this would make only a small dint in the available supply. Replacing Ontario’s nuclear generators with gas-fired generation would consume a lot more gas. One panelist at the conference openly expressed the view that if refurbishment failed (with the implicit hope that it would) then a significant opportunity for gas would arise.

In the nuclear industry, we’ve always been told gas wasn’t a feasible base load generation option for Ontario because there wasn’t enough gas and it would cost too much. The revolutionary changes in gas supply and pricing mean that neither statement is true any longer. Now it would be possible to negotiate long (say 30-50 year) attractively priced gas contracts to generate electricity at rates competitive with today’s nuclear plants. Combined cycle natural gas generating plants can be built rapidly (about 2 years from green field) at low capital cost (about $ 1 billion for 800 MW) for electricity at similar wholesale or lower rates to nuclear plants. It appears to me that such a transition from nuclear to gas would now be feasible. I would imagine this issue is discussed in the Bruce Power board since it is partly owned by Trans Canada, a major player in gas and gas transmission.

Of course, nuclear generation still has the advantage that unlike gas generation it doesn’t produce green house gas emissions. However, if the refurbishment projects start to incur large cost overruns and schedule slippages, I’m not sure how well the climate change argument would hold up with politicians and the public. Incidentally, it seems Quebec hydroelectric exports to the US north east are declining making another a source of “green” electricity available.

The refurbishment projects must be delivered on time and on budget for Canada’s nuclear industry to survive. Complacency based on past attitudes such as “they need the reactors back on line so they’ll pay anything” would be fatal with the gasman watching so closely.

Nuclear Power in Ontario – The Approaching Choke Point

Returning from one of the frequent boat rides (cruises) that I indulge in, I decided to check out the CNSC (Canadian Nuclear Safety Commission) hearings for the licence extension of the OPG (Ontario Power Generation) Pickering reactors for a further five years to 2018. OPG announced they will shut down all six Pickering reactors by 2020. I’ve gone over the transcripts of the hearings and was encouraged by several improvements compared to the Darlington hearings which I intend to discuss in future posts. In this post I want to step back and consider the nuclear picture in Ontario to the end of this decade.

The key strategic issues for OPG are as follows.

Refurbish the four Darlington reactors over the period 2014 to 2018. If all goes well, by 2018 OPG will have four refurbished 880 MW(e) reactors capable of operating for another 25-30 years for a total of about 3,500 MW(e). This plan looks solid in spite of a few mutterings by politicians.

Build some 2,000 MW(e) of new reactors at Darlington. This plan has had many ups and downs over the last five years or so and in fact was what started me writing this blog. The current status seems to be that proponents of the enhanced CANDU 6 (EC6) and the Westinghouse AP1000 have each submitted bids paid for by OPG. The process has been highly secretive since the beginning and the decision to build what if any new reactors will be purely political and various politicians have supported both sides of the issue. It’s not at all certain (50-50?) that new reactors will be built.

Don’t refurbish the Pickering reactors but run them to 2018/2020. The Pickering station was built as two adjacent clusters of four reactors separated by a vacuum building common to all eight reactors. The first cluster, Pickering A, now consists of two operating reactors (numbers 1 and 4) that completed refurbishment in 2005 and 2003 respectively. These refurbishments ran way over budget and schedule and OPG decided not to refurbish reactors number 2 and 3. The four Pickering B reactors are essentially clones of the Pickering A reactors but built a few years later. By and large the Pickering reactors are not performing very well and the B reactors are at the point they need refurbishing. However, OPG has decided them to push the B reactors beyond their pressure tube design limit to around 2020 and then close all six Pickering reactors permanently. This request to push the pressure tube limits was the main issue of the Pickering hearings. The timing is so that the Pickering reactors could provide back-up power in case of delays in the Darlington project. Closure will entail a total loss of some 3,000 MW(e) of nuclear capacity.
Thus, by 2020 or earlier OPG will have between 3,500 and 5,000 MW(e) of nuclear power depending on whether the new reactors are built.

The key strategic issues for Bruce Power are the following.

Refurbish the remaining two reactors in Bruce A. The Bruce plant consists of two widely separated clusters of four reactors each. In the Bruce A group the reactors numbers 1 and 2 completed refurbishment last year and should be good for another 25 years or so (let’s say to 2040). Reactors number 3 and 4 were restarted in 2003 and 2004 but did not have their pressure tubes replaced. However, both of these reactors were shut down for about seven years which makes their pressure tubes roughly comparable in degradation to the Bruce B reactors that came into service in the years 1984 to 1987.

Refurbish the four Bruce B reactors. The Bruce reactor reactors, both the A and B ones, are more advanced, of higher power and perform much better than the ones at Pickering. Therefore, it’s almost a no-brainer to refurbish the Bruce B reactors and also the two in Bruce A. This is really the only way to maintain the more than 50% share of Ontario electricity now generated by nuclear power. With all eight reactors now in production the total capacity of the Bruce station is 6,3000 MW(e) which makes it the largest nuclear power installation in the world. The Bruce reactors are now performing very well with high capacity factors but the time for refurbishment is fast approaching given that the Bruce reactors are even older than the Darlington reactors. The experience of refurbishing Bruce reactors numbers 1 and 2 was that the time needed to complete both was about five to seven years at a total cost for both of around $4.5 billion. Extrapolated to the six reactors needing refurbishment this means a huge investment of about $14 billion. The project should be started immediately if the refurbished reactors want to operate much beyond 2018. No doubt softening up investors and government for this very large undertaking is the reason for Bruce Power’s publication this week of its blurb on a Vision for 2040.

Let’s summarize: between now and 2020 OPG will refurbish its four Darlington reactors, Bruce Power will need to refurbish six of its reactors and OPG may even host the construction of two or more new reactors. In my opinion there is no way that the Canadian nuclear industry is capable of doing all of this work before 2020. There are simply not enough highly skilled people available to perform these formidable engineering tasks, the supply chain will not able to support this level of effort and the $30-40 billion investment required is probably not there. This decade will see a huge and probably insurmountable choke point in nuclear activity in Ontario. I can’t see how all these tasks can be successfully accomplished in the time remaining and how nuclear will be able to retain its current share of Ontario’s electricity after 2020.

Darlington: Final thoughts on the hearings

The Darlington hearings gave a good snapshot of the current state of issues important to Canada’s nuclear industry. The CNSC decision to proceed with the Darlington refurbishment was made some time ago and can be best summarized by the following imaginary but typical dialogue.

There’s a thunder storm outside the hearing room. An intervenor points out that it’s raining but OPG staff denies it. CNSC staff says that rain is beyond the scope of the hearing: the Commission agrees and from then on ignores the rain issue.

The CNSC report on its decision that the refurbishment won’t harm the environment is similar in tone to those problems in elementary logic courses that start with “A always tells the truth, B always lies…” In this case A is OPG and B is all the 690 intervenors who participated. If the CNSC was smart, it would throw an occasional bone to the intervenors but they don’t because as we have seen their public communications skills are seriously underdeveloped. Maybe a better analogy would be to a highly stylized Kabuki play that must be presented every time when major nuclear decisions are to be taken.

Don’t get the wrong idea from my comments. Personally I’m happy that the refurbishment will proceed since it will preserve our nuclear expertise and keep our nuclear experts busy for at least a generation at which time we’ll probably know where the nuclear industry is headed. A few last thoughts on the hearings are in order here but no doubt I’ll return to some of these topics in future posts.

It seems that the Darlington plant is a Cuisinart for fish in the same way that a wind turbine is a Cuisinart for birds. The reactor cooling water channels suck in lake water containing fish and so ensure their demise. In fact this was purported to be the single serious environmental impact of the Darlington plant. So much handwringing over the fate of the fish by several intervenor groups didn’t make want to picket my local fish market. Personally I don’t like to eat fresh water fish. In my opinion salt water fish are far tastier although I’ll concede trout are pretty good. I can’t imagine eating a fish from Lake Ontario – a “round whitefish”, a “goby”, a “sculpin” or some other loathsome creature. However, if I heard correctly, there is at least one commercial fishing operation on the lake. It was opined that a $20k a year payoff would be sufficient to compensate the local fishing industry for the Darlington fish massacre which the head guy from OPG allowed they were willing to shell out. Suggesting that cooling towers should be used was anathema to the OPG types and the number of “independent” studies against them increased every time they were mentioned. In this case CNSC staff tried to hint that cooling towers weren’t the only choice for avoiding lake water cooling but OPG didn’t want to hear about it. Nothing was achieved and I gather this is a standard bit long familiar to audiences of CNSC hearings.

The anti-radiation types were out in full force drawing their usual foolish conclusions from the discredited Linear No Threshold (LNT) model of radiation effects which I like to think of as the “every little bit hurts” concept. The LNT is nonsense because it ignores the body’s DNA and cell repair mechanisms that are our defence against the background radiation from natural sources we are unavoidably exposed to. Without these defenses many species including humans might have long vanished from the earth as a result of cumulative radiation damage. Much stress was placed on tritium by those opposed to Darlington. With only tiny natural production from cosmic rays and the much larger amount dumped into the atmosphere by nuclear weapons tests in the 1950’s and 1960’s decaying by half every twelve years, it’s true that most of the tritium for example detected in drinking water originates from reactors. CANDU reactors are relatively large tritium producers compared to other reactor types but even so the tritium levels in local drinking water are minuscule and unlikely to have any health effects.

Radiation monitoring is a fiasco in the making because the Ontario Ministry of Labour, Health Canada, OPG, Natural Resources Canada and perhaps some local authorities were monitoring emissions from Darlington but none of them was able or willing to publish results in real time and none was trusted by the public. The guy from Health Canada even said the “politics” was the reason that their measurements weren’t available on line in real time. What happens in cases when the measurements of the agencies involved don’t agree for routine emission or particularly in an emergency? The CNSC solution was that they were going to get into monitoring because (don’t laugh yet) the public would trust them over other institutions. We should have in Canada as system at least as good as the one in France. If you are interested take a look at:
http://sws.irsn.fr/sws/mesure/index

Finally a really important topic that actually was beyond the scope of the hearings was OPG’s capability to successfully carry out the refurbishment. Their track record on such projects has been poor as has that of Canada’s nuclear industry as a whole. For example, I couldn’t believe that OPG was not going to replace the steam generators in the Darlington reactors because their corrosion measurements showed they would last for another 20 years or more. This decision has a high potential for disaster if they discover part way through refurbishment that steam generator replacement is in fact needed. This is a topic I plan to return to in other posts.

Darlington: Management of Nuclear Accidents

After Fukushima it became impossible to deny that serious nuclear accidents will occur from time to time and that more attention must be paid to mitigating their effects. In particular an important problem is how to effectively and efficiently evacuate the people likely to be affected by the radiation produced in the accident.
I should declare a bias at the start of this piece. In the 1960’s, as a young naval reserve officer, I did a two week course at the now-defunct Canadian Civil Defence College in Arnprior, Ontario. The College was an excellent school with all manner of training aids including simulated collapsed buildings for hands-on training in rescue, facilities for mass feeding of evacuees, demonstrations of how to set up casualty clearing stations, radiation monitoring and decontamination stations and so forth back in the day when it was believed that a nuclear war was survivable. From that brief experience I certainly didn’t become an expert in emergency planning but I did gain a lasting appreciation for what would be involved in assisting the victims of a nuclear accident. It is indeed a formidable task best left to experts and the key to success is a flexible well-established Command and Control structure that can deal with the accident situation as it evolves.
The point is that the population affected by an emergency need to feel there is a strong and capable authority in charge. This means there must be a good alerting system and very good communications as the accident unfolds. I used to show my nuclear engineering students the 1999 PBS documentary Meltdown at Three Mile Island. In the film politicians, media, engineers and local residents were brought together twenty years after the accident to share their experiences including the confusion over what was happening at the plant and the contradictory orders to evacuate. Jimmy Carter, then President of the United States, and Dick Thornburgh, then Governor of Pennsylvania, were both unable to get clear information on the accident and local municipal officials were left completely in the dark.
Similarly in the documentary Battle of Chernobyl Mikhail Gorbachev, leader of the USSR at the time, says he couldn’t find out what was happening in the first two days and in the end he had to resort to asking the KGB, the secret police, to find out for him the situation at Chernobyl. The reports on the Fukushima accident show that some authorities didn’t share information with others on radiation and in fact some people were evacuated to areas of higher radiation. The organizations operating all three reactors were more of a hindrance than a help and mainly confined themselves to issuing soothing reassurances to the public. For example, Gorbachev was told on the first day of the accident that the Chernobyl reactor was so safe it could be placed in Red Square with no resulting harm. Met Ed, the TMI utility and TEPCO, the Fukushima operator, were notoriously poor at communications not only with the public but also with government and the media.
What comes across strongly in all these accidents is the overriding importance of effective communications and the need for a centralized authority to coordinate and implement all aspects of dealing with the accident. It was clear at the Darlington hearings that OPG and the CNSC in particular had little understanding of how the existing organizations in place to deal with emergencies would operate. Representatives of the Durham Emergency Management Office and Emergency Management Ontario were called upon to be questioned at the hearings but my observation is that the Commission was unable to understand their message. At one point the CNSC president was asking the cool disembodied voice of an EMO official present by teleconference if he could give him “a plan he could hold in his hand” – I expected the song Call me maybe to start playing in the background.
My first recommendation is that the Emergency Management organizations have absolute control of the response to nuclear emergencies with offsite consequences. Otherwise there are too many other organizations and politicians that would meddle in the situation to create a total fiasco. I would further recommend that much more funding be invested in EM organizations particularly in areas around the reactor sites. This is a “no regrets” option since a higher level of preparedness would also have a positive impact on non-nuclear disasters.
In an on-site emergency the accidents to date have taught us that it was the fire fighters and local plant staff who fought to bring their reactors under control. The troop of lavishly paid suits power companies trot out for public performances only gave bogus public reassurances. Much is owed to the courage of the firemen of Chernobyl and the fifty men who stayed at Fukushima. I would strongly recommend that the OPG types stop drawing circles around their reactors based on dubious PSA calculations and instead put their efforts and their money into preparing and supporting the boots on the ground that will have to deal with an emergency.
Emergency management is far too important to be neglected because an accident is thought to be improbable.

Darlington: More Safety Related Issues

Three more significant topics related to nuclear safety came up at the hearings.

The first concerns the population near the Darlington reactor complex. The higher the surrounding population the more impact an accident would have. The Darlington station is about 70 km from downtown Toronto. The Pickering Nuclear Generating Station with its six operating and two dormant reactors is even closer to Toronto. As I understand it, the plan is to extend the life of the four Pickering B reactors until around 2025 and then close down the two remaining Pickering A reactors at the same time. If this goes as planned, all the Pickering reactors would be shut down in twelve years. Significant nuclear activity including decommissioning and used fuel storage would still remain at Pickering but the potential for a reactor accident with far reaching consequences would disappear.
On the other hand the four Darlington reactors as refurbished will operate until 2060 and perhaps two more new build reactors will be added to bring the total to six. With Pickering closed down one might want to reconsider whether it is a good idea to build new reactors so close to the major population centre of southern Ontario or indeed whether the continued operation of the current Darlington reactors after refurbishment is a good idea. New reactors could be built at willing communities such as the Bruce site, in the upper Ottawa valley and Nanticoke on Lake Erie. Indeed, why not share the economic wealth that the boosters love so much? I know that this is not going to happen but I strongly suspect that if we had it to do all over again we’d keep the reactors as far away from large populations as possible.
A second issue concerns reactor operation when the safety systems are unavailable. According to the Darlington hearings presentation of the Canadian Coalition for Nuclear Responsibility (CCNR), a venerable ant-nuclear group, reactors are sometimes operated with one or more of the safety systems unavailable. Not only that but the CNSC (and its predecessor the AECB) used to annually publish “statistics” on the unavailability of the safety systems but no longer does so even though OPG still provides them to the CNSC. The CCNR wanted to see them published again.
This became a classic case of the miscommunications that plague the nuclear industry. The CCNR would have us believe that the operators would in effect say “Doesn’t matter if all the safety systems are working, let’s start up the reactor”. On the other side the CNSC and OPG vehemently denied that reactors are ever operated without any of the four main safety systems available. As usual the truth is somewhere in between. CANDU reactors can operate for weeks and months without ever shutting down. At various times during continuous operation the safety systems are tested and sometimes one or more are temporarily unavailable. The number and duration of such outages comprise the statistics in question. It seems that both sides of the issue deliberately chose to misunderstand each other. The original question (i.e. why doesn’t the CNSC still publish the statistics) was never answered.
A third issue is the multi-unit nature of the Darlington station. All four reactors share a common control room, a large cavernous room (“area zero” as I recall), with a separate console area for each reactor. This makes the control area very vulnerable to accidents and malevolent actions. Both the Three Mile Island and the Chernobyl reactors involved in the accidents were in multi-reactor clusters. In both cases the neighboring reactors undamaged by the accidents continued to operate for years afterward. The key was that the other reactors had their own control rooms isolated from the damaged reactors so that for example radiation in or damage to the control room of one didn’t affect the others. In the case of Fukushima four reactors were involved and the problem there was the whether the reactors could be remotely operated from a secondary control room. Multi-reactor/single control room issues are being reconsidered internationally. I feel that intuitively one would prefer a separate control room for each reactor which is not the case at Darlington.
As for malevolent acts I personally doubt, with no particular knowledge for believing so, that any armed terrorist gang would attempt to fight its way into the common control room area but if they were successful all four reactors would be in danger. The actions of mentally disturbed workers including those with drug or alcohol problems are more likely to be the source of attacks on the shared control room area. The CNSC has been discussing mandatory drug and alcohol testing of reactor operators but as far as I can determine no regulations are yet in place. The good news is that a cyber attack, a technique that has already been used against nuclear facilities elsewhere in the world, does not appear to distinguish between control room configurations. Various comments on these matters were made by intervenors but in this case it is clearly in everyone’s interests to keep all the details of security arrangements secret.
I believe the first and third of the above problem areas arose from an overly optimistic attitude to nuclear safety on the part of Darlington’s designers stemming from a desire to save money by minimizing transmission loses and by having the reactors share common facilities.

Darlington: The Safety Elephant in the Room

Fukushima has changed our approach to nuclear safety to more emphasis on accident mitigation.

At these hearings the elephant in the room was not Elmer the traffic safety elephant well know to Canadian children but the Fukushima safety elephant. It shook up the way we look at nuclear safety.
The essential lesson from Fukushima is that future reactor accidents are much more probable than what we might like to think. Since then accident mitigation has become an urgent consideration as shown by the emphasis on emergency planning at the hearings.
According to the World Nuclear Association there have been almost 15,000 years of power reactor operation from about 1960 to the end of 2012. During that time there have been three serious nuclear accidents – “black swans” (Three Mile Island, Chernobyl, and Fukushima). This makes the probability of a serious accident about 1 in 5,000 or 2 x 10-4 per reactor year. One can play with this number by changing the number of reactors that melted down (three at Fukushima or not counting TMI as a serious accident) and so on but it’s the order of magnitude of the meltdown probability that is really of interest.
Each of these events occurred in a different reactor types (PWR, RMBK and BWR) in countries with differing nuclear cultures and regulation regimes. Aside from stressing the importance of overriding issues such as human error, institutional failure and design defects, it is difficult to know where to go with the black swan approach in analyzing reactor safety. Although certainly one can draw lessons from them after the fact as is being done for Fukushima, notably compensating measures for the complete loss of electrical power in a reactor plant (“total station blackout”) and further measures to prevent hydrogen explosions.
Contrast this with the traditional approach to reactor safety known as PSA (Probabilistic Safety Analysis/Assessment). This approach tries to examine all possible accident event sequences and figure out the probability associated with each sequence. In practice it’s very complicated and there can be hundreds or even thousands of events and sequences. To give an overly simplified example, let’s consider an accident sequence that starts with event A: a cooling pipe breaks, then B: a sensor fails to indicate the break, then C: the reactor operator doesn’t see the reactor temperature increasing, then D: a switch activating the emergency core cooling system doesn’t work, then E: the operator pushes the wrong button to correct this and F: a core meltdown occurs because the reactor overheats.
This too simple example illustrates some of the key aspects of PSA. The validity of the approach depends on the accuracy of the probabilities assigned to the individual events since the overall accident probability (of event F for example) is obtained by multiplying the probabilities of the individual events in the sequence. Some might be well known; perhaps the B sensor is used in many applications and its failure rate is well documented from experience. At the other end of the scale there are probabilities that one can merely guess at e.g. the initiating pipe break probability might be hard to evaluate. Another very important condition is that the probability of a certain event happening is independent of other events. This may not always be the case: event C implies an incompetent operator and therefore, event E may be more likely. For completeness all possible accident sequences need to be evaluated. There isn’t any way to be sure completeness has been achieved. Unfortunately, there wasn’t an event sequence at Fukushima that started with: “suppose there was a tsunami wave higher than the protective sea wall”.
Safety analysts in Canada and internationally continue to use PSA. In fact people have made whole careers in the nuclear industry putting bells and whistles on the basic PSA framework. While it has proven useless for predicting accident probabilities, PSA is useful for highlighting and correcting potential problems. In the context of the example above, perhaps a more reliable type of switch D could be installed or better training is needed for operators in terms of events C and E. The other important reason for continuing PSA is that there doesn’t seem to be any worthwhile alternative. As CNSC staff pointed out, PSA is still the international standard approach to reactor safety.
The problem is that PSA comes up with accident probabilities of the order of one in a hundred thousand or one in a million or even one in ten million per reactor year that are completely out of whack with the one in five thousand observed accident frequency. At the hearings I was disappointed to hear staff from the CNSC and OPG bandy about terms such as a “10-6 accident”, usually without the “per reactor year” unit giving the erroneous implication that these were realistic accident probabilities. In the best interpretation this could be excused as bad communications using nuclear jargon and in the worst interpretation a dishonest attempt to minimize the probability of an accident.
Much more serious was OPG and the CNSC using PSA as a basis for emergency planning. Statements were made that can be roughly paraphrased as “their (PSA) probability is so low that we don’t consider accidents with offsite consequences more than a few kilometers from the site” and “OPG has identified two catastrophic accident scenarios but their PSA probabilities are in the order of 10-7 and so we can safely ignore them”. Using PSA, discredited by experience as a method of predicting accident probabilities, is unscientific and intellectually dishonest. Thus, in my opinion, the hearings witnessed a disgraceful performance on the part of the institutions charged with our nuclear safety.

Darlington: CNSC Independence?

Several intervenors at the Darlington hearings expressed views that the CNSC was biased toward the nuclear industry. On the few occasions when he elected to acknowledge these claims the President, Michael Binder, countered by harrumphing “prove it”. With all the cards stacked in its favour I feel the onus should be on the CNSC to prove its independence rather than the other way round since its credibility is its most precious possession.
Any regulatory system always faces the difficult problem of the close relationship of the regulated and the regulators. A kind of Stockholm Syndrome comes into play which some called “regulatory capture” (There was a guy from Greenpeace who seemed so much a part of the current and past proceedings that he may be evidence of “intervenor capture” ) This perception is compounded by the federal government’s cost recovery program whereby OPG pays CNSC to be regulated. It seems that about 70% of the CNSC budget is obtained from the regulated. Similarly the location of many CNSC staff at OPG sites including Darlington increases the perception of a too close relationship. It was admitted that there was no personnel rotation system to prevent CNSC staff from being “captured” by OPG. Some of the high paying jobs at Darlington referred to by boosters are in fact CNSC jobs.
Speaking of jobs the CNSC now seems to have a staff numbering about 850; this is double the 1999 staffing level of 425. It’s difficult to see how the CNSC can justify doubling its staff in a decade of declining nuclear activity or is it just a symptom of empire building?
Even the format of the hearings leads to an impression of bias. The CNSC members sit at a long table as a tribunal with the applicants, in this case OPG, on one side before them with Commission staff on the other. Those who come to give their views to the Commission, the intervenors, are placed in a position between OPG and CNSC staff. It’s almost as if the intervenor is the “accused” in a trial. Several intervenors admitted to being nervous and feeling intimidated by this arrangement. On the plus side, there was often applause from the audience in support of their presentations.
The nature of the hearings is such that CNSC staff and OPG almost always tag teamed to reply to the comments of the intervenors because both sides have agreed on the issues raised in various documents negotiated beforehand. Similarly, what can be discussed and what can’t be (i.e. the scope of the hearings) was predetermined by OPG and the CNSC and often as Inspector Clouseau would say “the old beyond the scope ploy” was used to prevent certain subjects being raised. It was no wonder that Intervenors got the feeling they were being ganged up on by Commission staff taking the side of OPG.
At one point an intervenor directly challenged the CNSC’s distribution of literature promoting the nuclear industry. The President claimed that section 9b of the Nuclear Safety and Control Act of 1997 permitted the CNSC to do so. It’s worth quoting the section:
“[an object of the CNSC is] to disseminate objective scientific, technical and regulatory information to the public concerning the activities of the Commission and the effects, on the environment and on the health and safety of persons..”The crux of argument is not whether the CNSC can legally disseminate information but rather whether the promotional material is “objective” and “scientific”. No useful discussion of this point took place because the President simply deflected the issue via a legalistic argument based on 9b.
Another independence issue raised was that according to the biographies on the CNSC website it appears one Commissioner worked for OPG as recently as 2011. The perception of a potential conflict of interest was possible and in fact this was raised by at least two intervenors. Once again this was sidestepped by the President. While I’m not impugning the integrity of this particular individual, I would say that the “optics” was poor and in my opinion recusal would have been more appropriate for an OPG application.
Speaking of optics perhaps the CNSC should report to Parliament through the Minister of the Environment rather than the present arrangement of via the Minister of Natural Resources. That might help position the Commission as more independent in some minds particularly when under new legislation it can conduct full Environmental Assessments.
The cynical might say that the current President might be more disturbed by accusations of being perfectly objective rather than of being biased. The fate of his predecessor, Linda Keen, who apparently was too objective for the government, must always be on his mind. My impression is that the present incumbent doesn’t realize the Commission’s serious credibility problem and it’s a pity he doesn’t seem willing to do obvious things to fix it.