Submission to the Canadian Nuclear Safety Commission regarding Darlington Nuclear PlantAs submitted by Louisette Lanteigne on October 15, 2012 700 Star Flower Ave., Waterloo Ontario N2V 2L2 519-885-7619 firstname.lastname@example.org
Land-Use PlanningTraditionally, the underlying belief of planning is thatcollective rationality can be brought into the way ourcities are built rather than leaving it up to individualsin the marketplace where inefficiencies may prevailespecially with respect to long-term thinking(Makuch, 2004).
Land-Use Planning And Private Development BiasPlanning is a highly charged financial process -development or redevelopment can mean big bucksfor private individuals.Private interests may have deleterious implicationsdespite the benefits they may bring about and thusmust be reconciled with the interests that the publichas for appropriate development that takes intoconsideration other values such as environmentalprotection and not overburdening municipal services(Swaigen, 1993).
What Needs To Be AddressedThe technology, laws and regulations, and practicesfor containing, responding to and cleaning up spillslag behind the real risks and associated costs.
Nuclear Systems are leakingRadioactive tritium has leaked from three-quarters ofU.S. commercial nuclear power sites, often intogroundwater from corroded, buried piping, anAssociated Press investigation showsTritium, has leaked from at least 48 of 65 sites,according to U.S. Nuclear Regulatory Commission.Source: Ageing Nukes: A four-part investigative series by Jeff Donn, Associated Press http://www.ap.org/company/awards/aging-nukes
Many Leaks Have HappenedUS based nuclear sites have suffered more than 400 accidental radioactive leaks during their history.Source: Union of Concerned Scientists. September 2011http://www.ucsusa.org/nuclear_power/nuclear_power_risk/safety/nrc-and-nuclear-power-safety-annual.html
Remediation Can Be Very ExpensiveThe new price tag for completing the remainder of Hanford nuclear reservation cleanup, plus some post- cleanup oversight, is $112 billion. Source: The Tri-City Herald article New Cost for Hanford Clean Up by Annette Car Feb. 9 2012 http://www.mcclatchydc.com/2012/02/09/138402/new-estimate-of-hanford-cleanup.html#storylink=cpy
Is Remediation Even Possible?Many contaminated aquifers cannot not be reclaimedbecause fixing the damage is “too costly” or “technicallyinfeasible.”
Complacency To Monitoring Poses Risks Its assumed that the monitoring rules and requirements are in place and are protective but nobody knows for sure unless someone gets sick or complaints are issued.
First Nations Paid the Price for Ontarios Lack ofReasonable Monitoring regarding Mercury Dumping58.7% of Grassy Narrows and White Dog FirstNations people have been poisoned by Mercury.33.7% have been diagnosed with Minimata Disease. Contamination violated Aboriginal Treaty Rights.
Long Term Data is LackingOnce waste is underground, there are few ways to track howfar it goes, how quickly or where it winds up. There is plenty oftheory, but little long term data to prove how well thesesystems actually works. Bedrock aquifers and bedrockfractures exist but risks of these are often underestimated.
Unreasonable economic burdenThe actual costs to monitor and maintain long termnuclear storage for the required 10,000 to millions ofyears, needs to be based on sound science and areasonable economic model to insure funding will bethere to complete the set tasks to avert public risks forfuture generations.Is the financial scheme to support this project, based oncurrent proven need or is this based on projected needsanalysis on the premise that Ontario will actually want touse nuclear power in the future? We need an energy plan in place first!
Current Cost of Power per Kilowatt Hour in Ontario Source: Brochure titled Lets Cut Some Real Wastes as published by Ontario Clean Air Alliance, theCanadian Association of Physicians for the Environment & Canadian Federation of Students-Ontario.Energy conservation and efficiency: 2.3 to 4.6 centsWater power imports from Quebec: 5.8 centsWind : 11.5 centsNuclear – new and re-build 19-37 cents* *These numbers do not include the costs of decommissioningold reactors, long term storage of wastes or risks of accidents.For further information view: Toronto Star, Nuclear power too costly, Ontario Clean Air Alliance argues, JohnSpears, Business Reporter March 20 2012http://www.thestar.com/business/article/1149273--nuclear-power-too-costly-ontario-clean-air-alliance-argues
Chloride Levels in Waterloo illustrates how water is drawn to wells regardless of surface topography. Currently watersheds are onlydelineated based on surface topography not draw down influences. Does the data for Darlington have regard for this?.http://research.ires.ubc.ca/projects/ISM/include/Torontopdfs/Stone_ISM_May2008.pdf
Topography does not prevent aquifer connectivity as shown in thiscross section of Waterloo Moraine. Clay is not impervious either: It only slows rate of infiltration. What kind of sediment layer is under this plant currently? .
Modflow has its flaws: Use more geologyMany hydrology firms use Modflow programs to studyaquifers but the program assumes aquifers are self containedand this poses a risk.Data input is often subjective which is why mandatory testingstandards and methods are needed to clarify processes toexplain where the numbers came from and how they came tothe results. Make sure the data being used is current.Modflow works better when supported with localizedgeological data including sediment type to better understandactual hydrological connectivity.
Bore Hole Data isnt Enough!Often times bore hole testing does not go deep enough tomonitor for potential impacts to aquifer systems and holes aretoo widely spaced.Test times often fails to have regard for seasonal variantsincluding spring thaw data and with climate change, year toyear modeling is needed to properly assess delta water levelsbecause trends from one year no longer apply to the followingyear. Trends in Waterloo Region Weather station indicatedrought year/ flood year scenariosUsing bore hole data, outwash till formations can appear toreflect consistent clay coverage but this poses a serious risk toaquifer systems.Ground Penetrating radar profiles can help mitigate the risks byillustrating the sediment distribution of outwash till areas
Example: The Arkell Research Station in Guelph • Using standard bore hole testing, this area appears to be covered in a consistent clay layer. • GPR profiles identifies this area as a shallow outwash aquifer. The clay is discontinuous. They are like shingles with many spaces of infiltration in between. • This area gathers up to 7% of Guelph’s potable water supply and it recharges cold water trout streams. • The GPR profiles for the Arkell Research Station were provided by the Canadian Geological Survey of Canada.
International Joint CommissionIt is clear that human and ecosystem healthin the Great Lakes basin cannot be protectedwithout protecting ground-water resources. http://www.ijc.org/rel/news/2011/110308_e.htm
REGARDING ENGINEERING FIRMSThere is no money in discovering bad geology...or is there?
Problems With Engineering Firms Engineering firms are not held liable for their work in creatingenvironmental impact studies after theyve signed off on it. Therisk transfers to the firm who purchased their data. If issuesarise due to poor environmental studies, they are not heldliable for any of the the work they did.Firms like this stand to profit from remediation if things do gowrong. There is no reasonable incentive for engineering firmsto do a the job right to prevent long term risks. Rubber Stamps are not enough. If there is a lack of fiscal accountability there is no guarantee of good work!Why not hold a check worth the value of their services and if issues happen due to the poor EA: Cash it!
Engineering Firms Continued:Studies for this Nuclear Power Storage facility appear tobe limited to a rather specific layer where the boreholeswere lucky enough to go through some solid chunks. Arefindings consistent with alternative geological data?(Geologic Survey of Canada, USGS etc.)Currently there is no mandatory criteria for whatconstitutes as a reasonable test times or methods tosecure best management practices are reasonablyapplied. Are test times and methods used reasonable ordo they reflect biased, outdated data and/or unclearformulas? Will this data be peer reviewed?
If monitoring and peer review data costs extra hold industry accountable to those costs. Place a levy on these firms to cover for additional costs associated with long term independent monitoring as a way to protect the public interest. Make sure the monitoring is done by an independent firm rather that the company itself to make sure the science they are using is non biased and reasonable.
Is the Darlington Nuclear System sitting on KARST?Map from a presentation by Dr Derek Ford, Professor Emeritus from McMaster University, Environmental Geography and Geology, February 2012 :http://www.couchconservancy.ca/ONCWebsite/htm/Among%20ourselves.htm
Quarries in Karst Increases Earthquake & Contamination risks How many pits in proximity to this project? Source: pubs.usgs.gov/of/2001/ofr-01-0484/ofr-01-0484so.pdf
Regarding MegathrustsThere are fault zones that have severe implicationson the seismic hazard of nuclear facilities located onthem, as well as deep geological waste repositoriesincluding this proposed nuclear storage project.More effort should be undertaken to properly mapthese megathrusts, mainly by processing theavailable seismic data in Lake Huron.
These cold-joint megathrusts are clearly visible in deep seismicreflection data. The leading one is the Grenville Front (GF) fault, themiddle one is the Central Metasedimentary (CM) fault, and the thirdis the Elzevir (EL) fault.
Current Seismic Risks shows dots in proximity to Nuke plant .
Recommended Reading Negative impacts of grouting on the underground karst environment Ognjen Bonacci, Sanja Gottstein, Tanja Roje-Bonacci For more information outlining various ways man made earthquakes can be created, please visit this link: http://www.wired.com/wiredscience/2008/06/top-5-ways-that.
The frequency of tornadoes in Ontario is expected toincrease with climate change. Are we planning for it?
Nuclear Energy = Carbon Emissions- Huge amounts of diesel fuel is used to extract, process and transport uranium products creating significant carbon emissions while creating serious ecological risks by way of tailings ponds etc.- Uranium comes from Saskatchewan, a province which relies heavily on coal energy to process the uranium.- Energy still must be spent running nuclear plants and transporting and storing nuclear materials for the long term. What will power those aspects? Nuclear power is neither clean nor is it carbon free!
The Biggest Risk of All:Political Interference hampering sound science.Prime Minister Harper mandated 2 year approvalsfor environmental assessments by the CanadianNuclear Safety Commission."There is no analysis or rationale that can be produced by the government to defend the two-year arbitrary time line," Liberal Natural Resources critic David McGuinty
Political Interference continued:Two-thirds of recent environmental assessments bythe Canadian Nuclear Safety Commission, includingthose involving storage of radioactive waste, havetaken more than two years to complete, say newnumbers released by the agency.Most nuclear reviews dont meet Harpers two-yearlimitSource: MIKE DE SOUZA, POSTMEDIA NEWS JUNE 1, 2012 http://www.canada.com/Most+nuclear+reviews+meet+Harper+year+limit/6716437/story.html
Harper fired Linda KeenSource: CBC NEWS Nuclear safety watchdog head fired for lack of leadership: minister http://www.cbc.ca/news/canada/story/2008/01/16/keen-firing.html When the chief of the Canadian Nuclear Safety Commission suggested that one shouldnt run nuclear plants without necessary safety equipment, she was fired.
Political Interference Continued:With Bill C-311, the Nuclear Safety Control Actundermined. Environmental assessments will bemoved to the Canadian Nuclear SafetyCommission, which is a licensing body not anassessing body -- so there is a built-in conflict.
A reasonable approach to avert risk is to stop generating nuclear wastes.
HAVE REGARD TO CANCER RATES.A 1983 study done in the United Kingdom showeda higher than expected rate of childhood leukemiain those living near the Sellafield nuclearreprocessing plant.http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1662601/
A Parliamentary Review found elevated cancer rates in Pickering and Ajax Similarly, a study carried out by the AECB in 1991 compared the rate of childhood leukemia in the province of Ontario as a whole with rates in communities near nuclear power stations. The study showed a higher than average rate in Pickering and Ajax. Source: Federal Parliament CANADAS NUCLEAR REACTORS: HOW MUCH SAFETY IS ENOUGH? Interim Reporthttp://www.parl.gc.ca/Content/SEN/Committee/371/enrg/rep/repintjun01part1-e.htm
Our acceptable MSV levels are killing people. Acceptable background radiation exposure in Ontario is 2.4 MSV 1.0 MSV is acceptable for public level exposure per year For nuclear power workers, 100 MSV/5 years or max 50MSV/year is deemed acceptable. Nuclear workers have 3.2 excess deaths than public. With more exposure there is always more harm. There are no reasonable “safe” limits but industry prefers to look at yearly values instead of considering the harm that could be created by “spikes” from exposure.
When you trust industry to police themselves, things like this happen: According to a Canadian Environmental Law Association, CELA, media release, Shield Source has “recalculated its tritium emissions for the years 2010 and 2011 at five to nine times the levels previously reported”, adding, “The new levels are more than twice the release limits allowed by the CNSC licence.” Joseph Castrilli, legal counsel at CELA is acting on behalf of a local citizen’s group, SAGE, Safe and Green Energy Peterborough, in the matter.
Accidents happen. These ones are just a few examples of Canadian Nuclear incidents. December 12 1952: The NRX accident. Explosions occurred in the reactor core.The worlds first major nuclear reactor accident at Chalk River. May 24, 1958 Fuel rods in the reactor overheated and ruptured inside the reactor core. A rod caught fire and broke when removed, then dispersed fission products and alpha-emitting particles at Chalk River. November 1978 LOCA Major loss of coolant accident. 2,739 litres of coolant oil leaked, most of it into the Winnipeg River. August 1 1983 LOCA Major loss of coolant accident. Catastrophic pressure tube rupture. Tube that holds the fuel rods ruptured. March 1986 LOCA Major loss of coolant accident. Catastrophic pressure tube rupture. Tube that holds the fuel rods ruptured. On March 14, 2011, Ontario Power Generation has notified Canadas federal nuclear regulator about the release of 73,000 litres of demineralized water into Lake Ontario at the Pickering A nuclear generating station.
There are no guarantee safe storage options.There is no moral ethical or scientifically validevidence to show that we can reasonably monitor ormanage the safe disposal of radioactive wastes for10,000 to millions of years.It is unreasonable to assume we could design sucha system without flaws or adverse consequences tofuture generations when current evidence showssystems are failing in less than 100 years at analarming rate.
Green Energy is Do-able Now“Renewable energy sources, accessed with commercially available technologies, could adequately supply 80% of total U.S. electricity generation in 2050 while balancing supply and demand at the hourly level.”National Renewable Energy Lab US:http://www.nrel.gov/analysis/re_futures/The expected resource potential of Canada, electricity generated bygeothermal energy could replace approximately 10 nuclear powerplants and provide up to 10% of Canadas current total electricitygeneration.Canadian Geological Surveyhttp://www.globe-net.com/articles/2011/september/16/canada-is-awash-with-clean-geothermal-energy-resources/
If you think there is a lack of public support for nuclear power today,,,
...how will public perception change when this arrives?
In ConclusionDarlington sits in proximity to Karst, along aquifers, farmlands,the Great Lakes and fault lines. This location is not reasonable.With the unreasonable, non-scientific 2 year deadline forapprovals, as mandated by Harper Government, its notreasonable to assume such a short review period can securethe prevention of long term ecological, sociological oreconomic risks associated with this proposal.
Conclusion Continued:In the absence of a National Energy Strategy, it is premature tocommit Ontario taxpayer dollars to a venture like this whenthere is no proven need or proven plan in place to show thatthis project is economically feasible or beneficial for theprovince over the long term.Data shows cheaper, cleaner energy options exist that createmore jobs and more economic prosperity for residents. This isoutlined in numerous reports including Tide Canadas A NewEnergy Vision for Canada found online here: http://tidescanada.org/energy/newenergy/Why are we spending so much in tax payer dollars supportinga private firm using an antiquated system of energy supply thatbinds Canadians to have to store toxic wastes in perpetuity? Itis not reasonable. Time to simply cut bait and drop nuclear. Itscheaper in the long run.
For this project at this location: Just say no.