Pickering Nuclear: A Cracking Bad Idea

Extending the operations of the Pickering Nuclear plant for up to an additional 10 years beyond its designed life of 2014-2016 is a Cracking Bad Idea. This is the position of Sierra Club Canada’s Ontario Chapter as it participates in the current Canadian Nuclear Safety Commission’s public hearing into the Ontario Power Generation’s application for a renewal of Pickering A and B licenses.  Public hearings begin May 29, 2013 in Pickering, Ontario.

While OPG is confident that its plan provides the technical basis for the continued operation and eventual decommissioning of Pickering B station, Sierra Club is not.  Importantly, the plan is flawed on many levels.  Leaking old pressure tubes, concrete degradation and a 20 percent increase in collective worker radiation exposure in 2012, are just a few of the issues.

An Environmental Assessment is Required

Most troubling is the CNSC’s staff view that an environmental assessment of this proposed activity is not required under current Canadian legislation.  Staff says that because the new Canadian Environmental Assessment Act of 2012 did not list this application as a “designated project” under the Act’s regulation, none is required.

 But that Act and regulation came into force on July 6, 2012; OPG’s application is dated July 4, 2012 and therefore subject to the act in force at the time.  In other words, the more comprehensive provisions of the 1992 Act should apply. The proposed activity concerning extending operations and decommissioning is subject to an environmental assessment under the older and applicable legislation.

When OPG filed in 2006 to refurbish and continually operate the Pickering B nuclear plant, CNSC staff recommended and Commissioners required an environmental assessment under the 1992 Act.  When OPG filed an application to decommission Units 2 and 3 of Pickering A, the CNSC in 2008 also required an environmental assessment. The current OPG application to extend the end of life of and the decommissioning the oldest and most troubled commercial reactors in Canada deserves nothing less. We call for a rigorous and public process and assessment that considers transboundary effects and impacts.

Background

Pickering Units 1-4 are the oldest “commercial” nuclear power facilities in Canada and extending their life for an additional five or ten years of operation requires particular scrutiny.  A 2012 Ontario Energy Board report notes: “the Pickering A and B plants have among the worst, and on some measures the worst, operating measures” among nuclear generating stations worldwide.

The source documents of the application do not include, for example, an update to the 2007 Environmental Assessment (EA) report.  Yet, since 2007, there have been a number of major incidents and leaks of Tritium, a deadly radioactive pollutant, at the plant. Major developments and improvements have been made in assessing the environmental and human health impacts of nuclear facilitates.  Is the Commission taking a sufficiently precautionary approach that the effects of aging and decommissioning will be adequately managed?

We are alarmed that the supporting documents do not include an update to the 2007 EA, which also did not consider likely transboundary air pollution from the proposed activity. It is our position that despite advice received to the contrary, the public interest and the Commissioners would benefit from an updated and comprehensive EA. 

Moreover, a new Radiation and Health Study based on scientific findings since 2008 is necessary. The KiKK (German, 2008) and GEOCAPP (French, 2012) studies which found elevated rates of childhood leukemia in a 5 km radius of nuclear reactors are just two of the studies that need to be part of an ethical, professional, up-to-date, and complete assessment.  (Also see SCC’s report Tritium on Tap.)  The Radiation and Health in Durham Region 2007 study upon which OPG relies, considers all children under the age of 19 years, thus diluting the elevated risk, when the real risk of leukemia is in children less than 5 years old.  The study also fails to consider that while the first Pickering reactor started up in 1971 important data collection only began in 1983: key data on radiation exposure between 1971 and 1983 is missing.  We object that the 2007 Durham radiation study is not intended to be updated despite flaws in the original study and failure to address additional, widely available, scientific research since.

The operation of the Pickering facility has resulted in a number of intended and unintended releases, requiring additional scrutiny in any application to extend the life of these old reactors.  For example, the Commission has raised an important issue about the presence of Tritium in groundwater identified in the Turbine Auxiliary Bay (TAB) inactive building effluent sumps, the TAB foundation drains and near the irradiator fuel bay B (IFB/B) unit. The Commission expressed concern that the accumulated Tritium was being drained directly in the uncontaminated water intake channel and further into Lake Ontario and the release of heavy water as a result of a break in the heavy water moderator transfer system could result in a release of Tritium into Lake Ontario.  Most recently, on March 14, 2011, there was a release of 73,000 litres of demineralized water at the Pickering A nuclear generating station due to a pump seal failure.  Corrosion in the Steam Generator is a primary source of air emissions.

Decommissioning of the facilities will prove to be the most risky cause of radiation exposure and emissions.

The Pickering nuclear plan is a mere 32 km from Canada’s largest population center, the City of Toronto, with a population in the Greater Toronto Area reaching six million souls. The Great Lakes provides the drinking water of over 40 billion people.  We deserve better than a CHSC staff memo saying all is well. We deserve an Environmental Assessment.

Concrete Integrity

While OPG has identified that the fitness for service of Pickering B pressure tubes for both safety-related systems and component conditions is the most significant aging management issue, we are convinced that the issue of compromised concrete is also a key unaddressed concern.  The concrete containment structure is a cause for concern.

As we did in OPG’s application concerning new and rebuilt nuclear facilities in Darlington, Ontario, Sierra Club Canada has raised the new and important issue of concrete integrity both respecting continued operations and decommissioning at Pickering. This issue is particularly important given the age of the facility and that it might operate for an additional ten years. Compromised concrete is a result of alkali-silica reactions in aging nuclear containment structures.  US regulators demand refurbishment projects address the rate of concrete degradation, causing stress, cracking and larger fissure.  CNSC says they do require OPG to demonstrate that concrete in containment structures is safe and in compliance with applicable standards and codes. But where is the evidence of this?

Sierra Club intends to provide an update on the regulatory and legislative developments respecting this issue in general and the examples of this concern at the Seabrook facility in the US and at Gentilly-2 in Quebec in particular. Surely this concern needs to be addressed in order to assure the public and the Commissioners that the structures are safe for current, let alone extended operation.

Transboundary Air and Water Pollution

The concern for intended and unintended releases from this plant is heightened since no new environmental assessment is recommended and, the 2007 EA failed to consider the issue of transboundary pollution and the possible application of the 1991 Canada-US Air Quality Agreement in support of the renewal application. Sierra Club is unique in that it is part of a binational organization, with nine active Chapters around the Great Lakes. Our distinctive concern is with transboundary pollution and the need for a coherent approach to emerging nuclear issues in the context of the regional environment. 

In addition to demanding that the Pickering EA consider and address transboundary pollution, the Sierra Club urges that the International Joint Commission identify comparative regional pollution standards, especially respecting Tritium, for effectiveness and ensure opportunities to conduct meaningful cumulative impact and risk assessment on the Great Lakes related to nuclear issues.  We call upon the IJC to compile a public inventory of regional nuclear-related pollution standards and all proposed licensing applications for new, extended and decommissioned nuclear facilities. This list should be maintained and updated on a public registry because currently it is not possible to conduct comparative, cumulative impact and risk assessment.  This is unacceptable.

Please join us in preparing for and participating in the upcoming public hearing May 29th, 2013 in Pickering Ontario.  Contact the Sierra Club Ontario at 647-346-8744 or ontariochapter@sierraclub.ca.

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