Submission to the CNSC, May 2013
Sierra Club Canada and the Ontario Chapter have submitted a detailed report on the Pickering Nuclear Station request for permit extension to the Canadian Nuclear Safety Commission. Our research has identified several reasons why closure of the plant should begin immediately.
Some key points from the report:
- Pickering Nuclear caused a nearly 20 percent increase in collective worker radiation exposure in 2012.
- OPG admits that planned outages, opening of radioactive systems for maintenance work and decommissioning operations will increase the exposure of workers to tritium.
- CNSC’s staff view an environmental assessment of this proposed activity is not required under the current Canadian Environmental Assessment Act, 2012. That Act came into force on July 6, 2012, yet OPG’s application is dated July 4, 2012. The OPG Application is therefore subject to the more comprehensive 1992 Act in force at the time.
- The 2012 Ontario Energy Board report states: “the Pickering A and B plants have among the worst, and on some measures the worst, operating measures” among nuclear generating stations worldwide.
- OPG admits that measures to mitigate aging reactor components, with adverse impact on safety margins and reactor operations, are not always available or are too costly. Without being able to identify committed mitigation measures, the CNSC would be remiss in its legislative duty to approve the application.
- Pickering’s concrete aggregates require reexamination: Pickering’s concretes were designed back in the 1980s, similar to the when Seabrook Station in the United States (where ASR occurred due to its original aggregates from construction) was built as well. ASR damage to concrete containment structures may lead to radiation leakage to the atmosphere and water.
- Incomplete VBO inspection: In the event of a rupture in the piping in any of Pickering’s reactors, steam from the break would be automatically sucked into the Vacuum Building and condensed into water – preventing the release of emissions and other damage due to steam pressure build-up. Incomplete VBO inspection raises concerns in structural safety and unforeseen concrete degradations. Only 2 out of 8 areas were fully inspected for the underwater concrete integrity of the common intake duct structures. Concrete degradation has already been discovered at Unit 7.
- CNSC’s radiation protection standard for tritium is two to three times less protective than what is achievable in other jurisdictions.
- Canadian health agencies and radiation regulators consider the public dose limit of 1 mSv tritium per year is not dangerous, despite the science.
- While Sierra Club Canada maintains there is no safe exposure to tritium, the Canadian exposure limit should be tightened by a factor of 3 to reflect current scientific evidence.
- 2009 UK studies show all children receiving about 1 mSv of gamma radiation from background radiation each year results in their leukemia risk being increased by 12%.
- Despite the growing body of scientific evidence, CNSC and its staff act contrary to the public interest by not acknowledging this evidence and by failing to apply the precautionary principle in the regulation of radiation limits.
- A growing body of evidence in Ontario recommends the tritium limit in drinking water be set at 20 Bq/L.
- The best way to avoid unnecessary and unreasonable exposure to tritium is to begin the early and orderly decommissioning of Pickering Nuclear now.
- The last Environmental Assessment was done in 2007 and failed to consider Pickering Nuclear as a source for transboundary pollution and the possible application of the 1991 Canada-US Air Quality Agreement.
- Should the CNSC approve the application, Canada may be out of compliance with the Agreement for failing to provide notice and to conduct an EA.
- SCC is calling on the International Joint Commission to reestablish the Nuclear Task force to produce a report on nuclear issues, including on comparative radiation protection standards, and an inventory of all proposed licensing applications.
View the slide presentation
Read the full report