August 31, 2001

Submission to the Canadian Nuclear Safety Commission (CNSC)



From:
Ziggy Kleinau, Citizens For Renewable Energy (CFRE)
Greg Allen, Energy Action Council of Toronto (EnerACT)
Norman Rubin, Energy Probe
Martin Herzog, Liverpool West Community Association (LWCA)
David Steele, Pickering Ajax Citizens Together for the Environment (PACT)
Irene Kock, Sierra Club of Canada - Nuclear Campaign

Re: Ontario Power Generation (OPG) request for licence amendment
to restart the Pickering “A” nuclear generating station (October 3 meeting)


Pickering “A” Closure

In 1997, Ontario Power Generation (then Ontario Hydro) announced the closure of its Pickering “A” and Bruce “A” nuclear stations in order to remedy “longstanding management, process and equipment problems” across its nuclear stations. In the case of Pickering “A”, the closure on December 31, 1997 coincided with the unmet deadline for a mandatory shutdown system upgrade – a significant and longstanding safety issue. Resources were to be focused on improving performance and safety at the remaining 12 reactors at Pickering “B”, Bruce “B” and Darlington. The utility stated that performance would need to be world class before resources were diverted to bring the older “A” stations back into service. In the mean time Ontario Power Generation has leased both its Bruce nuclear stations to British Energy-controlled Bruce Power, while maintaining responsibility for ongoing operations at Pickering “B” and Darlington.


NAOP / IIP

The Nuclear Asset Optimization Plan (NAOP) was launched by Ontario Hydro in 1997 to try to raise nuclear station performance levels. It has since been reworked to incorporate various regulatory commitments, and renamed the Integrated Improvement Program (IIP). In 2000 the program was two years behind schedule, and, with the apparent blessing of the CNSC, is now not slated to be completed until December 2004. While the IIP work remains behind schedule and world class performance has yet to be achieved at Pickering “B” and Darlington, Ontario Power Generation is nevertheless proposing to take on the further challenge of Pickering “A” restart. It has been suggested by CNSC staff that it will now be sufficient that IIP work on Pickering “A” be at the same stage of completion as IIP work at Pickering “B” and Darlington, in order for Ontario Power Generation to succeed in obtaining CNSC approval to restart Pickering “A”. Overall safety at all three stations may be compromised by stretching resources to accommodate the Pickering “A” restart workload. The promised improvements in overall management and safety (including the crucial areas of longstanding station maintenance backlogs) may never be achieved as a result. Numerous similar improvement programs in Ontario Hydro’s past have failed.


Environmental Assessment

The CNSC’s Environmental Assessment of the Pickering “A” restart proposal concluded that “taking into account the mitigation measures described in the Screening Report [Pickering “A” restart] is not likely to cause significant adverse environmental effects”. However, the CNSC staff refused to include key topics within the scope of the Environmental Assessment, including the environmental, human health and economic consequences of a severe nuclear accident involving widespread radioactive contamination. The Ontario Nuclear Emergency Plan states that severe nuclear accidents, while having a low probability, will have huge long-term consequences such as the requirement for abandonment of contaminated properties, relocation of displaced people and extensive environmental restoration, with unknown human health and economic costs. The failure to review severe accidents, and to consider the adequacy of the Ontario Nuclear Emergency Plan and the federal Nuclear Liability Act as potential mitigating measures, prevented a fair assessment of the risks of restarting the Pickering “A” station.

It is assumed by the Canadian Nuclear Safety Commission and Ontario Power Generation that the reactor safety systems will work as designed, preventing a catastrophic nuclear accident, despite the fact that reactor safety systems, including containment, are not ‘fail-safe’. In fact, CANDU safety systems have a past record of problems which shows that these systems may not operate properly during an accident. Furthermore, the single fast emergency shutdown system at Pickering “A” is substandard, even with the planned ‘enhancement’, compared to other nuclear plants in Ontario which have two fully separated fast reactor shutdown systems. The CNSC claimed in its Reason for Decision on the Environmental Assessment that “the CEAA [Canadian Environmental Assessment Act] does not require the Commission [CNSC] to consider all conceivable accident events”. However, CNSC and the federal Minister of Environment had a moral obligation to consider at least one example of a severe nuclear accident with containment failure. The existing Environmental Assessment on Pickering “A” restart is a whitewash of important nuclear safety issues at Canada’s oldest commercial nuclear power station.

Another key topic excluded from the review was the need and cost to restart Pickering “A” and other alternatives for electricity supply and demand management. This would have determined whether the risk of restarting Pickering “A” and operating the roughly 2,000 megawatt station for another 10 to 15 years is justified. This is a crucial aspect of how decisions involving projects that may cause significant harm are to be made under the Canadian Environmental Assessment Act. Clearly, other energy options are readily available which pose a lower risk, such as conservation and efficiency programs and high efficiency natural gas turbines. Presently in Ontario there is no regulatory mechanism available to review the electricity demand and supply situation, or the business planning practices of the publicly-owned utility – Ontario Power Generation. Even though the opening of Ontario’s competitive electricity market has been repeatedly delayed, our utility and the CNSC are claiming that the marketplace has somehow made this decision for us.

The Environmental Assessment process was problematic from the beginning, with Ontario Power Generation involved in closed door negotiations with CNSC staff over what topics would be included in the scope of the Screening Report. The CNSC and Ontario Power Generation were criticized for their apparent excessive level of collaboration throughout the Environmental Assessment. The Screening Report even failed to adequately cover the issues within its limited scope. The ‘160+ issues’ which were identified in an earlier public process have not been addressed in a systematic, integrated fashion, as suggested by key participants in the original process. The independent Peer Review Team hired by the City of Pickering with funding from Ontario Power Generation concluded that the Screening Report relied on incomplete data to draw conclusions which in some cases could not be supported. The Peer Review Team noted that the responses to their technical comments on the draft Screening Report were selective and incomplete. In addition, the ‘Follow-up and Monitoring Program’ ordered as a condition of the Environmental Assessment approval does not fully address what measure will be taken to reduce harm, if future monitoring shows that the predictions made in the Screening Report underestimated the environmental harm caused by restarting Pickering “A”.

Public concern about the proposed restart of Pickering “A” was misrepresented in the Screening Report, with the statement that only “a few individuals” will be affected by “reduced feelings of personal security and levels of satisfaction with the community”. In direct contrast to this conclusion, the public attitudes poll conducted for Ontario Power Generation showed that over 8,000 families in the 10 kilometre radius around the Pickering nuclear station would likely move away if Pickering “A” is restarted. Neither these findings, nor their significance were discussed as part of the Screening Report.


Nuclear Emergency Planning

Emergency planning for accident consequences outside of the nuclear station fence is a provincial responsibility. The current Provincial Nuclear Emergency Plan is an interim document, yet to be approved in accordance with the Emergency Plans Act. Several outstanding issues are apparently under revision including the crucial problem of how to effectively notify the public in the 10 kilometre radius ‘primary zone’. In reality the evacuation planning zone should be in the order of a 30 kilometre radius area. Even those in the 3 kilometre ‘contiguous zone’ around the Pickering station are not assured of prompt notification under the current telephone dialing system, which was last tested in November 2000. Changes to alerting methods in the contiguous zone are being developed after years of discussion, but have yet to be implemented. Proper public education about the emergency plan is lacking, including failure to regularly publish the relevant details in local newspapers, as well as failure to post signs to mark the evacuation routes. In the case of a sudden radiation release under severe accident conditions, the public may not have adequate access to stable iodine tablets, which only protect the thyroid gland from radio-iodine if taken before or immediately after exposure to radio-iodine. Stable iodine is stockpiled at schools and institutions, but homes and businesses should be provided with this product as well, at no cost, for prompt use during a serious emergency. Unfortunately the CNSC has not acted on repeated calls to require that the off-site nuclear emergency plans be fully implemented and tested as a nuclear station licensing condition. Additional improvements to the emergency plan, including expansion of the evacuation planning zone, effective and prompt public alerting, and distribution of stable iodine are urgently needed.


Conclusion

Ontario Power Generation should not be licenced to restart the Pickering “A” nuclear station at this time. There has been a disturbing trend evident in the operation and regulatory review of the Pickering “A” plant. Serious outstanding concerns remain unresolved about the ability of the plant to be restarted and operated in a manner that ensures new safety concerns or increased public risks will not arise:

  • delayed implementation of improvements and delayed reduction of maintenance backlogs, as contained in the IIP

  • failure to address inadequacy of the nuclear emergency response plans

  • willingness to allow Pickering “A” to meet reduced standards that are inferior to the requirements that are applied to all similar but newer nuclear facilities.

As a result of these trends, restarting Pickering “A” will expose the people and ecosystems in the Great Lakes region to unnecessary risk, including the risk of a severe nuclear accident with widespread radioactive contamination. The consequences of this type of accident, including the effects on the environment, human health and the economy, were not reviewed under the Environmental Assessment. The current Nuclear Emergency Plan is not sufficiently developed or implemented to cope with a serious nuclear accident at Pickering. There appears to be undue haste to proceed with restarting Pickering “A”. The focus should be on resolving all of the outstanding issues and deficiencies prior to entertaining any restart applications.


September 25, 2001


Supplementary Submission to the Canadian Nuclear Safety Commission


From: Sierra Club of Canada - Nuclear Campaign


Re: Additional organizations endorsing August 31, 2001 submission on Pickering “A” restart licence amendment from Citizens for Renewable Energy, Energy Action Council of Toronto, Energy Probe, Liverpool West Community Association, Pickering Ajax Citizens Together for the Environment, Sierra Club of Canada - Nuclear Campaign (Commission Member Document 01-H17.8)



The following organizations have endorsed the above noted submission:

Canadian Coalition for Nuclear Responsibility

Canadian Environmental Law Association

Canadian Institute for Environmental Law and Policy

Durham Action Network

Greenpeace

Ontario Voice of Women

Toronto Environmental Alliance

Women’s Healthy Environments Network