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.

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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.

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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.

 

Bruce Nuclear Waste Repository: The Wrong Place at the Wrong Time – Part II Technical

Continuing from the previous post let’s look at the technical issues introduced in the just completed round of hearings on OPG’s plan to construct a Deep Geological Repository (DGR) to bury low-level wastes from the normal operations of reactors (those of both OPG and Bruce Power) and used reactor parts with long-lived radioactivity arising from the refurbishment and decommissioning projects of both entities.

Dr. Frank Greening, a retired OPG expert, pointed out that the radioactivity levels in the reactor parts to be stored in the Bruce DGR were a factor of 100 to 600 higher than OPG had claimed in its original safety case. OPG initially dismissed this as unimportant because essentially it didn’t make any difference but later they included it in a revised safety case. This failure of institutional professional expertise was unsettling and raises serious questions about the competence of those who wrote the safety case and especially the CNSC staff who reviewed and approved it.  During the hearings I would have liked to hear someone from OPG or CNSC say something like “we’re sorry we screwed up on this and we’ll try to do better in future” Instead all we had from them was smoke and obfuscation around this point.  Greening later left his wheelhouse ( as the current cliché goes) and made other accusations whose validity I’m unable to judge.

The Waste Isolation Pilot Project (WIPP), an underground nuclear waste facility near Carlsbad New Mexico, was held out as a model in the 2013 OPG submissions for the Bruce DGR as the only one comparable to it. The facility has been operated for fifteen years by the US Department of Energy (DOE) to store low level waste from nuclear weapons development work done decades ago at the Los Alamos National Laboratory (LANL). On February 14 this year there was a fire at WIPP during which thirteen workers were mildly exposed to radiation with elevated radiation levels detected in the air around it. The cause of the accident is still unknown and WIPP will not reopen until it is fully understood which may take some years.  (The DOE safety case for WIPP calculated that the odds of a radiation accident were one in 10,000 to one in 1 million per year of operation.) Paraphrasing the OPG response at the hearings, it was argued that a similar accident couldn’t happen at the Bruce DGR because OPG’s waste is different and OPG is more careful/smarter/safety conscious than LANL, DOE and the WIPP operators. Both argument s are hard to sustain when the cause of the accident remains a mystery.  If WIPP is a model for the Bruce DGR then a fire or leak deep underground would be a much greater burden on future generations than any other option.  In my opinion the WIPP accident may ultimately kill the Bruce proposal.

The report of the so-called Independent Experts Group (IEG) was supposed to demonstrate that the risks of the DGR were less than leaving the waste above ground or depositing it in a giant granite boulder (pluton) in the Canadian Shield far from any significant body of water. The Panel wanted the IEG to use the well documented DGR prototype that AECL originally developed based on data from experiments in its Underground Research Laboratory (URL) in Manitoba just for purposes of a comparison. Instead the IEG used a hypothetical pluton located on the Bruce site beside the Great Lakes.  This misses the Panel’s point entirely. When challenged by the Panel, IEG members made several unconvincing excuses for this serious gaff. For example, they said they couldn’t consider the URL for comparison because Manitoba had a law against depositing nuclear waste in the province and AECL had declared none would be buried there.  Why either of these circumstances would rule out using the data purely for comparative purposes wasn’t clear.  In my opinion considering the fictional Great Lakes pluton came across as rather foolish.  Any numbers that could have been included from the AECL work for example were avoided in their written report which was purely subjective.  It used simple two-axis log plots that reminded me of the kind used in business schools and while reading it I expected them to discover a “cash cow” at some point in their deliberations. To say the report was highly qualitative is an understatement.

One point the IEG did make with which I fully agree is that nothing needs to be done with the waste in question for at least a hundred years. In effect they argued that there’s absolutely no need for a Bruce DGR at this time which I assume was not what OPG hired them for.

This again raises the critical argument for me. Namely is the DGR proposed for Bruce really needed?

To answer this question it’s important to emphasis that OPG has opted to build a DGR. This is purely a matter of choice and no convincing arguments have been advanced by OPG to show that a DGR is a necessity. In fact, most of the world’s reactor operators have opted to continue to store these wastes above ground as has been done in Canada to date.  In the 2013 round of hearings OPG admitted they had selected the DGR option primarily based on local support or a “social license” by the local communities given that they own the Bruce land and much of the waste is already at Bruce. A “business case” and a geological argument were later constructed to support the plan. No additional technical rationale for the necessity of the proposed DGR was presented at the hearings and therefore, I conclude it is not needed.

The answer to the key question is “no” we don’t need the Bruce DGR. .

In the next post the social license issue will be discussed.

 

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.

 

The Hearings on the Deep Geological Repository at Bruce

These hearings which concluded at the end of October 2013 concerned Ontario Power Generation’s plan to build a Deep Geological Repository (DGR) at its Bruce nuclear site to bury low level (LLW) and intermediate level (ILW) nuclear waste.

The story we are asked to believe is that Bruce area municipal politicians approached OPG in 2004 with their own plan to build this DGR. The motivation was that their towns needed money and the locals were nuclear friendly. OPG, the ever benevolent organization that it is, decided that it would like to have a DGR and agreed to pay the surrounding municipalities some $35M over a similar number of years. OPG then discovered much to its surprise and delight that the local geology was suitable even if the DGR would be built very near Lake Huron. They then applied to the CNSC which in turn set up a panel to hear the environmental arguments pro and con.

Why does OPG want to build the DGR at Bruce so near the Great Lakes? Why do they need to build it now given they have lots of room to safely store the waste for decades? I find it rather cute that the answer to both of these key questions is the same namely that local municipalities want it. In my opinion there is no need for a DGR for decades and when the time comes for one the Bruce site isn’t an appropriate place for it.

One of the local mayors is the preferred media spokesman for the DGR rather than an OPG executive presumably in order to maintain the script. I don’t think anyone is buying this story but on the plus side we should give OPG credit for not using “once upon a time” in their media releases.

To put it kindly the issue of what’s going to be buried in the DGR has evolved with time. At first it was just LLW and ILW (200,000 cubic metres) from routine reactor operations in proportions of 80% and 20% respectively.

As far as the stuff OPG said originally that they are going to bury I wouldn’t personally be upset if the whole lot was dumped off a pier into the lake at Bruce. The level of activity per unit volume is very small and the dilution factor is so huge that I wouldn’t expect more than a miniscule increase in the total radioactivity of the Great Lakes water I drink. Heaven knows there are numerous other chemicals and pharmaceutical residues already in the water. However, I wouldn’t want to see old overalls or mop heads floating around and I would hope OPG reduced such items to ashes prior to them going into the repository.

OPG has now started talking about putting the waste from refurbishment of the Darlington reactors and presumably also from decommissioning the Pickering reactors in the DGR up to another 200,000 cubic metres. This “mission creep” for the DGR is a huge step beyond from the original plan of waste from reactor operations and several intervenors pointed that out at the hearings.

Human nature being what it is, in a decade or so I would expect OPG to start talking about this DGR as a repository for high level (used fuel) waste. It’s easy to imagine the type of arguments that would be made: we already have a DGR and we don’t need to spend the extra money building another one; the Bruce DGR is working well and the locals accept it; adding the used fuel would only mean a relatively small expansion to the existing DGR; and, it’s proven too hard to get anyone else to take the used fuel and the Bruce DGR is now the only option. I don’t believe I’m being overly cynical in predicting that the Bruce DGR could well become the one and only DGR for Canada. The CNSC says that this would be illegal. This is true under current legislation but, as we have seen recently with environmental assessments, laws can easily be changed by Parliament.

I would suggest that the only type of undertaking that would guarantee that no used fuel (and if desired no decommissioning/refurbishment wastes) could be buried in this DGR would be a treaty with the Saugeen Ojibwa Nation (SON). SON has been a key player during the hearings questioning many of the issues mentioned above. Treaties with First Nations are very sensitive and, unlike in the past, are hard to break in today’s social context. More generally this could be an opportunity for First Nations as a group to demand from the federal government a comprehensive treaty covering all aspects of radioactive materials in and around the Great Lakes (Remember Bruce Power’s attempt to ship its steam generators via the lakes.) Such a document would serve to clarify future relations between the nuclear industry and First Nations to the benefit of both parties. There’s lots of time to do this because there is no urgency whatever for the DGR.

One development at the hearings I found very disturbing. Prior to the hearings the Ontario police came to the homes of some intervenors who opposed the DGR and telephoned others in order to “maintain order” although there was never any prospect of even mild public protests. They also stationed plain clothes police in the hearing rooms to discourage protests. I realize that the readers of this blog are from some 70 countries outside of Canada and may not understand or care about what is politely called “asymmetric policing” in Ontario. In a nutshell this means the OPP, the Ontario provincial police, take positions on public issues as ordered by the Ontario Liberal Party ruling the province. They then selectively enforce existing laws ignoring those that do not conform to the party’s position. The OPP has this in common with other infamous police forces that I won’t name here to avoid excessive drama.

This psychological intimidation and harassment of hearing witnesses by the police was appalling. I don’t agree with much of what the intervenors said or would have said. Nevertheless it was their democratic right to have free speech without police threats. I was unpleasantly surprised that the Panel would continue the hearings after police interference was proved. In this respect the Panel did a poor job of preserving the integrity of the process. It would have been much better to have an experienced judge in charge to ensure fairness rather than an amateur Panel chair. For this reason I feel the hearings were badly flawed and the Panel’s conclusions should be considered as tainted.

Pushing the Limits of CANDU Pressure Tubes

The basic issue at the Pickering hearings was the request of OPG to operate the four Pickering B reactors beyond the previously assumed lifetime of their pressure tubes. The lifetime was set in the past to be 210,000 hours (more accurately Effective Full Power Hours) and running Pickering B to 2018/2020 would according to OPG push the lifetime to 247,000 hours. With 8,760 hour/year and a capacity factor of 0.8 we get roughly 7,200 hour/year. At this rate 216,000 hours is about 30 years and 37,000 more hours amounts to an extra 5 years. With the exception of reactor number 8 which will reach the limit around 2015, it looks to me that the other three Pickering B reactors will be at the 210,000 hour limit in 2014.

This issue has wider implications and indeed could be the most critical issue for Canada’s CANDU program. For example, the six Bruce Power reactors will need refurbishment soon if the resources are available. Once again rough calculations indicate that some of them are already within a year or two of 210,000 hours in part due to their very high capacity factors in recent years. So what will the CNSC do when confronted with the same issue at Bruce? Cancelling the Bruce licenses just isn’t feasible and so one can safely assume that sometime in the period 2014-15 we will see ten reactors (four Pickering B, two Bruce A and four Bruce B) all operating with pressure tubes past the 210,000 hours mark.

It is already well-known and observed phenomenon that CANDU pressure tubes deform as they age. This is due to an effect known as radiation-induced ‘creep’, the latter meaning the metal becomes like a very slow flowing plastic driven by the heat generated by fission in the uranium fuel. An American colleague of mine used to call CANDU reactors “the world’s largest creep experiments”. Creep arises on the atomic level from the displacement of metal atoms by high energy neutrons (before they are slowed down by the moderator) and by the embedding (ingress) of hydrogen isotope atoms in the metal forming hydrides which further degrade the metal’s macroscopic properties.

In operating CANDUs various measures are taken to control the dimensional changes of the aging pressure tubes, for example, the ends of expanding tubes may be selectively clamped to encourage uniform growth in both directions. The tubes also sag and swell as they age changing the geometry of the nuclear assembly thus affecting both its thermal and neutronic aspects. How much of this degradation a reactor can take before it becomes unsafe to operate? This is a very complex issue and a great deal of R&D has been done on this subject since the inception of the CANDU concept. The reason was that in order for a natural uranium/heavy water reactor to work (achieve criticality) its metal structure has to be minimized to avoid excessive neutron losses. Therefore, the pressure tubes had to be thin and it was acknowledged from the outset that creep would be a problem in CANDUs.

The history of CANDU pressure tubes was bumpy at the beginning. In 1974 leaks were discovered near the rolled end joints in some tubes in Pickering A reactors. This problem was attributed to delayed hydride cracking which arose from how the joints had been fabricated and was corrected by replacing the faulty tubes. In August of 1983, a pressure tube ruptured in Pickering A reactor number 2, some twelve years after it began operation. There was no leak-before-break in this case which caused dismay since it was always touted as a safety feature. This failure was attributed to friction damage caused by spacers around the tube and also to the alloy the tube was made from. This accident required the re-tubing of first two Pickering A reactors with tubes made of a better alloy. (AECL also lost the royalty it had on the electricity produced which was the start of its unremitting financial woes.) This event resulted in even more R&D on pressure tube degradation from which a target limit of 210,000 hours was set.

So what has happened to change this limit? What is the scientific basis for extending the lifetime of the pressure tubes? To me this is the critical question. In the first place it is reassuring that not much negative has happened in the pressure tube field for many years which would indicate that at least 210,000 hours is a reasonable limit. However, in my opinion OPG hasn’t done a very good job of informing the public of the science behind their request to go to 247,000 hours. The Pickering hearing transcript offers little in the way of evidence that a change is justified. OPG talked about a research program started in 2009 that produced some eighteen reports submitted to the CNSC. I haven’t been able to find copies of these reports on the CNSC or OPG website. Comments made about this program at the hearings didn’t convince me of its validity.

More significantly I can’t find any mention of this work in international journals such as the Journal of Nuclear Materials or Metal Physics. Maybe I’m not looking in the right places? A result with such high impact on reactor operation and safety should be peer reviewed by refereeing for publication in a high quality publication and preferably presented at widely attended international conferences. To me it is ironic that the CNSC stressed the need for peer reviewed publication of the epidemiology work showing no increased cancers near nuclear stations but not for the pressure tube program, the main topic of the hearings. By peer review I don’t mean sending the results to a few foreign experts for their opinion – this isn’t anything like proper peer review. I’m afraid that the CNSC too often does that because it buys into the nuclear industry’s unhealthy obsession about propriety information to the detriment of any realistic quality control over the science involved.

In the final analysis it boils down to the old British expression “suck and see” meaning inspections at reactor outages to see how the tubes are doing; the reactors have indeed become “creep experiments”. Sudden (without leak-before-break) failure of any one pressure tube could be handled by the existing safety systems as the 1983 accident showed. I suspect that’s the basis of the CNSC granting OPG a limited license extension to operate reactors up to the 210,000 hour limit. However, I doubt one would want to continue to operate any of the Pickering B reactors after one tube failed. What would that do to the continued operation of the six at Bruce? The nuclear enterprise in Ontario has entered perilous waters where the failure of just one pressure tube could sink it.

More on the fate of Chalk River labs

If it wasn’t already in trouble enough, the media reported a “near miss” at the Chalk River Laboratory (CRL). It seems an operator at the NRU reactor erroneously shut off a cooling system but the error was immediately corrected by a manager who happened to be in the control room at the time. The only consequences were the doubts that this incident created about operator training and the overall safety culture at CRL.

The resulting negative media coverage comes at a very bad time. The government is looking for a commercial company to operate CRL. I suggested in a post here almost a year ago that a good solution would be to return the labs to the National Research Council (NRC), their original owner in the 1940’s. However, it turned out that I was wrong being much too optimistic about NRC’s ability to navigate in the troubled waters of the current government’s attitudes towards science, and basic research in particular. I read that NRC has been ordered to be “open for business” and it should serve the needs of industry. This is a depressing mantra of knuckle draggers of all political stripes in response to the issue of basic research. I won’t expiate on this theme any further other to say that right now NRC isn’t a feasible refuge for CRL.

It seems inevitable that we will see a commercial company running CRL. I can’t help being reminded of the recent “sale” of the reactor operation of AECL in Mississauga by SNC-Lavalin. Is there anyone out there that thinks in retrospect that this was a good idea? I’ll just confine myself to this question since there are legal strictures that prevent my commenting on the various accusations made against SNC-Lavalin executives for alleged unlawful activities. These unfortunate developments also make off shore sales of CANDU even more unlikely that they were before.

My understanding is that a company is being sought to operate CRL rather than to buy it. I’m sure there is an ideological component in this decision. The political right, now in power in Canada, believes that only private enterprise can operate businesses correctly whereas the left, of course, believes that only governments can. It’s like assuming that more accountants can ensure accountability but they can only document how much is spent foolishly rather than preventing dumb expenditures.

This model of government ownership with commercial operation has been used at US national laboratories for decades. Most of the R&D funding for them still comes from US federal government departments and agencies. In Canada this should be even more the case than in the US. The source of CRL’s funds will overwhelmingly remain the government of Canada and it’s mainly the magnitude of the annual budget that’s in question. To a large extent (80% or more?) the CRL budget must be labour costs. I hope I’m wrong but the main task of the commercial company would likely be drastic staff reductions. The advantages of doing it this way would be that the government could claim that the reductions were done by arm’s length “experienced” business people rather than by the government itself.

Let’s face it, there’s not much R&D of primary importance going on at CRL through no fault of the employees. There will be even less in the future without a new research reactor after NRU closes for good. CRL is very vulnerable to personnel cuts. One thing that could be done is to find new tenants for some of the lab. Is there any other nuclear-related group that could be located at CRL?

Yes. How about moving a large part of the CNSC (Canadian Nuclear Safety Commission) operation to CRL? They are now mainly located in Ottawa office buildings and I can see no particular objection to them being at CRL. It might even give them more exposure to nuclear than they now have (couldn’t resist the pun).

There are good reasons for doing this. Governments in the past have decentralized federal activities by moving them out of Ottawa for example Revenue Canada to PEI and NRCan’s CANMET labs to Hamilton. Certainly there would be whining about inconvenience and more travel effort on the part of CNSC staff. On the other hand housing would be much cheaper and they wouldn’t be that far from Ottawa. Commission staff is located at Pickering, Bruce, Darlington and Pt Lepreau with as the CNSC claims no “regulatory capture” and they could even arrange to have a small independent group devoted to regulating CRL. With so many “cops” buzzing around the hive it might also improve the safety culture at CRL.

I don’t really see any serious objection to moving most of the 900 CNSC people to CRL. Some wouldn’t want to move and buying some of them out would be an added benefit in reducing the personnel bloat at the Commission.

Think about the CNSC idea and if you like it, contact Cheryl Gallant, the CRL area MP. If Hamilton MP David Sweet could swing the politics of moving CANMET to Hamilton then she would have a good chance of giving a badly needed boost to her constituency by moving the CNSC to Renfrew County. The two MPs should compare notes and I suspect the CNSC move to CRL could be done fairly easily if approved by the PMO.

It’s easy to forecast the response of bureaucrats to the idea. They will try hard to stall any CNSC move to CRL on the grounds that studies of the lab’s future are underway, nothing can be done for years and besides they didn’t come up with the idea. Personally, I doubt that they will come up with any better idea if they continue to deny the need for a new research reactor. The advantage politicians have is they can tell the bureaucrats what the results of the study should be and when it should be concluded. It will be interesting to see how this plays out.

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.