Comment on Ontario Power Generation s Application to Renew and Merge the Power Reactor Operating Licences for the

Transcription

1 Comment on Ontario Power Generation s Application to Renew and Merge the Power Reactor Operating Licences for the Pickering Nuclear Generating Station Ref H-03 Submitted to the Canadian Nuclear Safety Commission by Northwatch May 2013

2 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 一

3 1. Context Ontario Power Generation (OPG) has applied to renew and to merge the operating licences for the Pickering Nuclear Generating Stations (NGS) A and B located in Pickering, Ontario. The current licences authorize OPG to operate the Pickering NGS A and B which consist of eight nuclear reactors and their associated equipment, which were designed to produce electrical power. Six of the units are operational and two units have been placed in a safe storage state. As set out in their application and Day One testimony before the Canadian Nuclear Safety Commission (CNSC or the Commission ), Ontario Power Generation has decided to not pursue approval for the refurbishment of the Pickering station as had been their previous intention, but is instead seeking Commission approval to extend the operating life of the Pickering 5, 6, 7 and 8 7units by approximately five years beyond the normal assumed design life. Ontario Power Generation had submitted an Environmental Assessment in 2007 which included more than 4,000 pages of documentation outlining their rationale and supporting arguments for the refurbishment of the Pickering units. According to the EA Study Report refurbishment would allow PNGS B to continue to operate safely and efficiently for another 25 to 30 years (to approximately 2060 for the last of the four units). Consequently, the proposed project is called the Refurbishment and Continued Operation of Pickering B Nuclear Generating Station (hereafter called the PNGS B Project or Project ). PNGS B has produced base-load electrical power for distribution through the provincial grid since The continued operation of PNGS B will be an important contribution to stable electricity supply for industrial, commercial and residential consumers in Ontario. 1 Pickering is one of the world's largest nuclear generating facilities consisting of the Pickering A and Pickering B plants. Pickering A has two operating Candu reactors and Pickering B has four operating Candu units. Together these plants have a total output of 3100 MWe. Pickering A - the first four of the Pickering reactors - went into service in 1971 and continued to operate until 1997 when the plant was placed in voluntary lay-up as part of what was then Ontario Hydro's nuclear improvement program. In September 2003, following refurbishment, unit 4 was returned to commercial operation. Unit 1 was returned to service in November 2005 after also being refurbished. Units 2 and 3 remain in a safe shutdown state. Pickering B - units 5, 6, 7 and 8 - was brought into service in They have a combined capacity of approximately 2100 MWe. OPG had considered refurbishing the units at Pickering B in order to extend their operating lives until Source: 1 Refurbishment and Continued Operation of Pickering B Nuclear Generating Station Environmental Assessment, NK30-REP , Prepared for Ontario Power Generation by Senes Consulting, 2007 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 1

4 In January 2009, the Canadian Nuclear Safety Commission (CNSC) concluded the refurbishment and continued operation of Pickering B is not likely to cause significant adverse environmental effects, taking into account the identified mitigation measures. 2 In February 2010, Ontario Power Generation announced that it will invest C$300 million ($287 million) to ensure the "continued safe and reliable performance" of its Pickering B plant for some ten years, i.e. that it would not be pursuing the refurbishment of the Pickering units. 3 In July 2012 Ontario Power Generation applies to the Canadian Nuclear Safety Commission for a renewal of the Pickering A Power Reactor Operating License (PROL), a renewal of the Pickering B PROL and the merger of the two licenses into a single operating license, for a period of five years, expiring on June 30 th, An important aspect of the OPG application is the utility s request to continue to operate the reactors beyond their design life, i.e. the period of time for which the reactors and reactor components were expected to be able to function according to design specification. According to OPG testimony, the Pickering Units 1 and 4 pressure tubes have been replaced and will remain fit for service until the Pickering five to eight units are shutdown. Detailed analysis, followed up by thorough inspection campaigns has been and will continue to be performed to ensure the life limiting plant components fuel channels have plenty of margin through the licence period and through to H2.1 / 13-H2.1A Oral presentation by Ontario Power Generation Inc. by Glenn Jager, Day One hearing Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 2

5 2. Northwatch s Interest Northwatch is a public interest organization concerned with environmental protection and social development in northeastern Ontario. Founded in 1988 to provide a representative regional voice in environmental decision-making and to address regional concerns with respect to energy, waste, mining and forestry related activities and initiatives, we have a long term and consistent interest in the nuclear chain, and its serial effects and potential effects with respect to northeastern Ontario, including issues related to uranium mining, refining, nuclear power generation, and various nuclear waste management initiatives and proposals as they may relate or have the potential to affect the lands, waters and/or people of northern Ontario. Northwatch has a dual mandate that includes public interest research, education and advocacy to promote environmental awareness and protection of the environment, and support and promotion of public participation in environment-related decision-making. Northwatch is interested in Ontario Power Generation's proposed approach to nuclear waste management and containment over various time frames. Northwatch's issues and concerns relate to the generation and management of the nuclear wastes that will result from this project. Ontario Power Generation s proposed approach for the management of operating (low and intermediate level) wastes generated through operation of their fleet of nuclear reactors is to continue transporting these wastes to the Bruce Nuclear Generating Station for incineration and/or above ground storage and eventually (as proposed by OPG) burial adjacent to Lake Huron in a limestone rock formation. This is of interest both because of its precedent setting nature and because of its close proximity to Lake Huron, and the potential for adverse effects on the North Channel and North Shore of Lake Huron, Manitoulin Island, and the broader Great Lakes ecosystem. The incineration of low-level wastes is also of concern because of the close proximity to Lake Huron and the North Shore. Ontario Power Generation s proposed approach to the long term management of nuclear fuel waste generated by OPG owned and operated reactors is to transfer responsibilities for these highly radioactive and chemically toxic waste materials to a third party, namely the Nuclear Waste Management Organization. The Nuclear Waste Management Organization is currently investigating twelve communities in northern Ontario (twenty one in total, including six in Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 3

6 southwestern Ontario, 12 in northern Ontario and three in northern Saskatchewan) as possible burial locations for nuclear fuel waste, which makes the long term management of these radioactive materials of significant concern to Northwatch. Northwatch s objectives in this licencing review were to: undertake a review of Ontario Power Generation s proposed approach to the management of the highly radioactive nuclear used fuel waste that will be generated as a result of its proposal to renew its Nuclear Power Reactor Operating Licence (PROL) for the Pickering Nuclear Generating Station (NGS) in Pickering, Ontario and extend operations for an additional five years, and examine OPG's proposed preliminary decommissioning plan with respect to their proposals for the management of the used fuel in the post-operations period, and will include a preliminary review of OPGs proposed management of decommissioning wastes. Unfortunately, Ontario Power Generation has provided only piecemeal information about their Preliminary Decommissioning Plan, so a detailed review of this important aspect of OPGs proposed approach to the management of radioactive wastes generated by the operation and then decommissioning of the Pickering Nuclear Generating station will not be possible. General comments are provided in later sections of this submission, based on the very general description provided by Ontario Power Generation of their decommissioning intentions in their Application documents. In Northwatch s review of Ontario Power Generation s proposed approach to the management of the used fuel (also referred to as irradiated fuel, spent fuel, or high level nuclear waste in various documents referenced in within this report) the priority area of focus for this license application is on the safe management and containment of the waste after it has been out of the reactor core for a period of ten years or more. This focus builds upon reviews done by Northwatch in the Darlington relicencing during which Northwatch focused on the security of the irradiated fuel while in wet storage. In particular, effort has focused in the following areas for this review of OPGs application to renew the operating licence and extend operations at the Pickering Nuclear Generating Station: Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 4

7 the timetable for removing the used fuel from the irradiated fuel bays and placing it into dry storage the effectiveness of the dry storage casks and the robustness of the dry storage system over time, and the interplay between the OPG management approach during the operating life of the Pickering NGS and the decommissioning stage and post-operations period. longer term approaches to the storage of used fuel waste, as evidence in the international literature The generation of nuclear wastes as a result of the refurbishment the resulting extensions to the operating life of the reactors at the Pickering Nuclear Generating Station are key issues in this review, and warrant careful attention by the Commission. Similarly, the potential for the aging effects - effects that will only increase with extended operations on the long term integrity of the fuel bundles are serious considerations, with consequences that could play out over very long periods of time, far beyond the proposed 2020 shut-down date. Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 5

8 3. Ontario Power Generation s Application In July 2012 Ontario Power Generation applied to the Canadian Nuclear Safety Commission for a renewal of the Pickering A Power Reactor Operating License (PROL), a renewal of the Pickering B PROL and the merger of the two licenses into a single operating license, for a period of five years, expiring on June 30 th, An important aspect of the OPG application is the utility s request to continue to operate the reactors beyond their design life, i.e. the period of time for which the reactors and reactor components were expected to be able to function according to design specification. The Project will, in the short term, generate electricity. But it s larger and longer term function will be the generation of several classes of radioactive wastes. As a result of the extension of operations for an additional five years, the Project will generate an estimated additional 200 m 3 per reactor unit per year 5 in low-level wastes (following various minimization initiatives), an additional 67 m 3 of intermediate level wastes per year 6 and an additional 16,000 irradiated fuel bundles 7 per year of operation. The challenge of isolating these materials from the environment and from people, including both nuclear energy workers and the public, now and for generations to come will be demanding of resources, scientific understanding, technical abilities and the regulatory framework. While Ontario Power Generation is either proponent or partner in current proposals for a longer-term dispatching of both low and intermediate level radio-active wastes and high level nuclear fuel waste to an underground location, neither of the proposals for geological repositories are designed, reviewed or approved. As similar proposals advance internationally, debate will continue over the technical and social aspects of these proposals. Singly or in combination, the scientific uncertainties with geological repositories, the uncertainty of ever securing the necessary local and regulatory agreements and approvals to ever proceed to operations of these burial proposals, and the likelihood that any associated transfer of the wastes 5 Reference Low- and Intermediate-Level Waste Inventory for the DeepGeologic Repository, Ontario Power Generation, Page 49 6 Reference Low- and Intermediate-Level Waste Inventory for the DeepGeologic Repository, Ontario Power Generation, Page 49 7 Inventory of Radioactive Waste in Canada, March 2012, LLRWMO Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 6

9 particularly the irradiated fuel wastes off-site for disposal would not be within the next several decades at the earliest are sufficient reason to require that Ontario Power Generation have a longer term strategy for managing wastes in a safe and secure manner on-site. In addition to the above noted issue of continued waste generation contributing to a larger stockpile of radioactive wastes which must be managed into perpetuity, the proposal to extend the reactors operation beyond their design life raises concerns specific to the fuel wastes. These concerns appear to have not been identified or addressed by Ontario Power Generation in their application or supporting documents. Effect of Aging on Reactor Station Performance In Attachment 3 to the OPG application the Applicant describes the analysis undertaken with respect to system aging to evaluate the impact of aging on safety margins. The analysis identifies the major effects of aging as being potential for earlier onset of dryout, feeder corrosion and roughness, and boiler tube fouling. 8 Ontario Power Generation does not present any information or provide any indication that they have analyzed the potential effect of these aging reactor components on the integrity and long term performance of the fuel bundle. In the application s discussion of criticality safety, OPG discusses two instances where the neutron poison (used The potential for reactor aging to adversely impact on safety margin and reactor operation (e.g. which could lead to unit derating) has been recognized for many years In 2001, a comprehensive study was undertaken by Ontario Power Generation to assess the overall impact of reactor aging mechanisms on its nuclear generating stations (Reference 1). This study concluded the following: In terms of impact on nuclear safety margins, it was noted that Heat Transport System (HTS) Aging would have the largest impact on safety margins, and that the potential reduction in safety margins might require operational and/or design changes to maintain adequate safety margins. The major HTS aging mechanisms were - pressure tube diametral creep (PTDC) due to the effects of fast neutron flux, - decreased heat transfer through the steam generators due to various fouling mechanisms, and - erosion and deposition effects leading to increased roughness in feeder pipes and boiler tubes. The above mechanisms could have an impact on HTS coolant flow and flow distribution in fuel channels. The "most affected" Design Basis events from the Safety Report are - Slow Loss of Regulation (SLOR, also referred to as NOP) due to reduced effectiveness of the NOP trip, - Electrical failures leading to Loss of Flow (LOF), and - Small Break Loss of Coolant Accidents (SBLOCA). These findings were recently confirmed by a recent updated review of reactor aging in OPG reactors (Reference 2) and submitted to CNSC in January 2009 Progress Report on OPG Heat Transport System Aging Safety Analysis, N-CORR , Application Attachment 2 8 Attachment 3 to OPG Letter, G. Jager to M. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence,CD# P-CORR , page 61 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 7

10 to maintain the units in a sub-critical state) were deposited out of solution, but does not clarify the degree to which if any these incidents may be as a result of aging. Given that both incidents were due to leaks in one case through a calandria tube and in the other from the moderator cover gas compressor discharge line it seems at minimum to be at least a reasonable likelihood that these incidents were aging related more likely were a direct outcome of the aging effects on the system - and should have been addressed as such. 9 Two other serious incidents were discussed only very briefly in the application, both involving leaks of tritiated water to groundwater. According to the brief descriptions, the presence of tritium in groundwater in the Units 5-8 Irradiated Fuel Bay B (058 IFB) area was due to the bay sumps not operating as designed, allowing tritium to escape to groundwater, beginning in 2005 and first noted in Also in 2007, chronic leaks of active water to inactive Unit 6 Reactor Building foundation drainage sumps were identified as the cause of elevated tritium in groundwater. 10 It is not clear if the two above noted incidents were as a result of station aging or were failures that should be attributed to more general failures in either design or maintenance, but it is reasonable to expect that incidents of this type are more likely to increase as the station goes beyond its design life. While beyond the scope of Northwatch s waste-related review of the Pickering extension application, we were particularly struck by the reckless flavour of the discussion of the potential for vibration seemingly thought to be possible as a result of loose fitting gear springs to cause cracking of the calendria tube: The CTs in Pickering Units 5 to 8 are expected to be acceptable for operation to240 kefph. However, Pickering Units 5 to 8 is the only station in OPG which has loose fitting GSs installed in the fuel channels that could be susceptible to P7A13 type component wear in GSs, PTs, and CTs. There is a small possibility that a vibration mechanism, coupled with a fuel channel resonant condition, which is thought to have caused the CT crack, is present in other Pickering Units 5 to 8 reactors. This is believed to be low probability based on OPEX. Therefore, the strategy will mainly focus on how to manage the potential for CT degradation and component wear from risk mitigation point of view through in-reactor inspections, rather than perform additional analysis to 9 Attachment 3 to OPG Letter, G. Jager to M. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence,CD# P-CORR , page Attachment 3 to OPG Letter, G. Jager to M. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence,CD# P-CORR , page 117 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 8

11 attempt to further understand the vibration mechanism or eliminate the underlying source behind the root cause. (colour added) 11 Ontario Power Generation goes on to describe their response strategy as being to review the data, and then if any callandria tube is identified as being susceptible, the channel in question would then be given consideration for selection of SFCR candidates and then, if selected, it would be inspected. 12 This response strategy is, to say the least, underwhelming. It carries with it more the sense of considering whether to check the oil on an automobile prior to the warning light coming on that it does denote a prudent approach to the safe operation of a nuclear power reactor station. Comments on the potential effects of aging on fuel integrity can be found in Section 4 on the interplay between operational and post-operational periods. Additional Comments We note that there is no personnel identified as being responsible for waste management in the Pickering Nuclear Organizational Chart included in Attachment 7 to the OPG licence application, or in the Pickering Nuclear Organizational Chart found on page 16 of CMD 13 H2.1, and are interested by the number of positions that have changed in the intervening months. Additional comments on the OPG Application with respect to decommissioning can be found in Section 7 of this submission. 11 "Reactor Components & Structures Life Cycle Management Plan, N-TMP R010, , page "Reactor Components & Structures Life Cycle Management Plan, N-TMP R010, , page 28 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 9

12 4. Effect of Reactor Aging in Post-Operational Periods In general, one of the most noteable points of interplay between the operational period of a nuclear generating station and the post-operational period is the legacy of radioactive wastes which were generated during operations but then must be managed into perpetuity. In the case of an aging reactor station, such as the Pickering Nuclear Generating Station, there could be effects of aging that make this perpetual care even more challenging. As outlined in Commission Member Documents 13 and Ontario Power Generation documents related to their application 14 and discussed in the Day One hearing 15 black deposits are being regularly observed on fuel discharged from Pickering A, with size and frequency of the deposits increasing over the last three years. OPG reported in December 2012 that they had discovered a fuel bundle with significantly larger deposits than previously seen 16 CNSC have indicated that they have concerns regarding the black deposits, and have imposed a penalty of a 3% reduction from full power to preserve the safety margins and until there is a better understanding of the cause and effects of the deposits. Staff also indicated that they are not sure of the underlying root cause and were not sure about the trends in the formation. They did not indicate why a 3% penalty was adequate, or the basis for applying the 3% penalty versus a larger reduction or a shutdown for investigation. The deposits have been described by CNSC staff as being mostly magnetite and presumed to be corrosion products eroded from the outlet feeder pipes. Staff has also shared with Commission members during Day One a speculation that the deposits are due to limitations in the Pickering end units which led to less than optimal outage temperature control and indicated that the deposits could potentially impact the heat transfer properties of the fuel. Ontario Power Generation s response has been in to increase the ph level and request that they be allowed to return to full power. OPG asserts that there is no impact on cooling CMD 13-H2, CMD 13-H2.B, CMD 13-H2.1B 14 Reactor Components & Structures Life Cycle Management Plan, N-PLAN February 20th, 2013 Transcript Day One Hearing, pages 33-35, 53,56, 57, 174, 175, CMD 13-H2, page CMD 13-H2-1B, page Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 10

13 While CNSC staff reported in the Day One hearing that there is no sign of under deposit corrosion (page 34) the black deposits are acknowledged to be corrosion-related. Indeed, there are numerous references to aging-related corrosion throughout the documents related to the license review. Of additional note is that the December 2012 S-99 Preliminary Report Inspection Results Show a Thicker Black Deposit on a Slightly Bowed Fuel Element than Previously Seen included a comment from the inspector that at least one of the elements was slightly bowed out. Analysis over several years has determined that the major effects of aging are on dry-out predictions as a result of Pressure Tube Creep, which leads to earlier onset of dryout. 18 Taken singly or in combination, the above noted phenomena corrosion deposits on the fuel sheath, a bowing out of the fuel structure, early onset of dryout are all in evidence in the aging Pickering reactors, and have the potential to seriously reduce fuel integrity. And as CNSC staff have acknowledged in CMDs prepared for this license review, fuel defects are a precursor to public dose. 19 Fuel cladding has two primary purposes: to maintain the geometry of the fuel, and to act as a container. Fuel cladding is the first physical barrier between the irradiated fuel pellets and the environment. Changes that alter the physical structure and mechanical properties of a fuel bundle can cause damage. For example, oxidation of the cladding weakens its mechanical properties and decreases its thermal conductivity. In-reactor corrosion can also lead to embrittlement. Any of the just described phenomena can lead to damage or even failure of the fuel cladding. 20 Over longer periods of time, even micro-defects in fuel bundles which effectively become waste containers after removal from the reactor core have increasingly more significant potential consequences. Long term storage either dry storage on site or some form of centralized storage rely on a multiple barrier approach. The weakening of the first barrier by any means corrosion, dryout, temperature fluctuations can potentially lead to cladding 18 OPG Application Attachment 3, page CMD 13-H2.1B, page 1 20 Evaluation of the Technical Basis for Extended Dry Storage and Transportation of Used Nuclear Fuel, United States Nuclear Waste Technical Review Board, December 2010 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 11

14 failure. This, in turn, may lead to or hasten the release of radioactive materials into the storage container or even, ultimately, into the environment. CNSC staff assessment of the black deposits appears to be fully focused on the question of safety and safety margin during the operating period, i.e. the current period. We found no analysis by CNSC staff with respect to the bowing of the fuel element(s), which is also described in the December 2012 report on the largest of the observed black deposits. The cause of the element deformation / bowing is likely to be thermally driven, with bowing generally attributed to uneven temperature distribution. Non-uniform heat transfer and generation leads to temperature gradients. 21 The bowing could cause stress-cracking in the element, which could in turn contribute to cladding failure. While it is appropriate that safe operations be first and foremost in determining the response to situations such as the unexplained black deposits or the bowed fuel elements, the operating periods taken into account should not be limited to just the current operating period, but should include the very long term storage period that will of necessity follow. While the reactor may continue to operate without a severe incident in the present tense - although that is not by any means guaranteed any phenomena which are likely or possibly going to adversely affect the duration and effectiveness of future efforts to isolate the wastes should be examined through a much longer time scale than the next few years that OPG had requested a license for extended operation of the Pickering reactors. 21 J. Veeder, M.H. Schankula, Bowing of Pelletized Fuel Elements: Theory and In-Reactor Experiments, Nuclear Engineering and Design, 29, pp , 1974 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 12

15 5. Dry Cask Storage Northwatch retained Dr. Ross Landsman to evaluate the effectiveness of the dry storage casks and the robustness of the dry storage system in place at the Pickering Nuclear Generating Station. Dr. Landsman reviewed numerous documents describing the dry storage containers and the storage conditions at the Pickering Nuclear Generating Station, but generally found that the documents lacked the detail required to undertake a technical evaluation. In the course of his document review he shared the following observations: None of the available documents describe with sufficient detail and clarity how site preparation for the Waste Management Facility, including such fundamentals as fill removal, removal of upper till, replacement of any removed fill or upper till, soil compaction criteria to be applied to any backfill there is no description of the foundation for the storage building There is no description of the inspection/qc/qa for the manufacture of the dry storage casks, or the means by which it is verified that the cask is built as designed In very general terms, the cask design overall appears to be sound, but does raise a question as to why the design uses carbon steel on the interior instead of stainless steel, as per US design specifications There is no indication that the manufacturers or operators must demonstrate that the cask can be unloaded, as is the requirement in the U.S. The received documents all reference other documents for details A list of documents reviewed by Dr. Landsman is included in Appendix 1. Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 13

16 6. Management of High Level Nuclear Fuel Waste Ontario Power Generation's proposed approach to the management of the high level nuclear (fuel) waste in the short and medium term time frames, as outlined in their documents is to keep the fresh fuel in pools for approximately ten years, and then move it into dry storage at site. As outlined in the report Comments on Draft Screening Report on Environmental Assessment of Refurbishment & Continued Operation of Darlington Nuclear Generating Station prepared by Dr. Gordon F. Thompson on behalf of Northwatch for the review of the proposal to refurbish the Darlington Nuclear Generating Station, the radiological risk arising from the storage of spent nuclear fuel (SNF) in irradiated fuel bays (IFB) has been extensively studied in the context of SNF discharged from light-water reactors (LWRs) but similar studies have not been done for SNF discharged from CANDU reactors, as are used at DNGS. Nevertheless, the CNSC s Fukushima Task Force has acknowledged that the uncovering of SNF stored under water, at stations such as DNGS, could lead to a substantial release of radioactive material. Ontario Power Generation regards dry storage on-site of irradiated fuel (high level radioactive waste) as an interim measure, and intimates via their assertions in the very preliminary decommissioning plan (Attachment 5) that the irradiated fuel waste will be transferred off-site. Interestingly, OPG does not provide a description of their proposed method of managing (that) waste in the Application, despite the CNSC licence requirement to do so. The assumption of off-site transfer relies on the perpetuation of the illusion that a convincing technical case has been made for geological disposal, and the ability of a geological repository even as part of a multi-barrier approach to effectively isolate and contain the wastes for a sufficient period of time. In point of fact, there is currently no operating geological repository for used fuel, and for more than 20 years several countries have been depicting themselves at various times as being on the brink of operating a geological repository for used fuel, and yet none have, despite decades of effort and untold sums of public funding. 22 Canada, for one, is now further away from opening day of a geological repository than the nuclear industry considered it to be fifteen years ago. The U.S. equally so. 22 Wasting the Future, Australia, Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 14

17 As outlined in several international reports, there are a host of technical deficiencies of the geological disposal concept, and numerous unresolved technical issues, including the longevity of the containers, the availability of rock formations of the size and quality required, and the reliability of all of the computer predictions being made, to name a few. 23 In addition to not having made the technical case for the geological disposal of used nuclear fuel, neither the OPG nor their alternate persona the NWMO have made the social case for geological disposal. This was a matter of great significance during the 10 year federal review of Atomic Energy of Canada Limited s geological disposal concept. In the end, the Panel concluded that broad public support was necessary in Canada to ensure the acceptability of a concept for managing nuclear fuel wastes and that the AECL concept for deep geological disposal had not been demonstrated to have broad public support, and the concept did not have the required level of acceptability to be adopted as Canada's approach for managing nuclear fuel wastes. 24 In Canada, there are many indications that social acceptability will continue to elude nuclear fuel waste repository proponents, as has been the subject of several academic papers. 25 While the NWMO is currently engaged in a siting process through which they intend to contract a community to become the recipient of geological repository for nuclear fuel waste, the process is in its very early stages and the outcomes are wholly unknown. To rely on such a conceptual notion as the NWMO s Adaptive Phased Management approach for the long term management of the nuclear fuel wastes that the Pickering Refurbishment and Extended Operation project will generate is equivalent to saying that no plan is needed whatsoever. 23 "Rock Solid? A scientific review of geological disposal of high-level radioactive waste", Dr. Helen Wallace, GeneWatch UK, September 2010, as foundo online at 24 Seaborn Panel Report for Nuclear Fuel Waste Management and Disposal Concept, 1998, as found online at 3DD8DA4DE486&toc=show 25 For example, see "Nuclear Waste Management in Canada: Critical Issues, Critical Perspectives", Darrin Durant and Genevieve Fuji Johnson, 2010, details at Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 15

18 7. Decommissioning Plans The Canadian Nuclear Safety Commission has requested that OPG prepare a comprehensive plan on decommissioning strategies as part of the application for a one-site Pickering licence. By any reasonable assessment, the three pages provided by Ontario Power Generation in Attachment 5 of their application falls extremely short of comprehensive. 26 According to Day One testimony by Ontario Power generation, OPG has already prepared initial decommissioning plans and plans for the long-term management of radioactive waste. During the next licence period OPG will be submitting more detailed plans describing the processes which will follow the end of electricity production in In Attachment 5 of their application, Ontario Power Generation sets out their very general plan for the eventual decommissioning of the Pickering Nuclear Generation Stations. OPG describes their approach as one of deferred decommissioning, comprised of 30 years of safe storage following final shut down, and sets out a nominal time line which is for planning purposes only in Table 1. Northwatch makes the following observations and comments on this very, very preliminary decommissioning plan: The assignment of the activity identify decommissioning and waste disposal facilities and methodologies to the year 2030 is illogical, in that it delays for a further decade and a half the development of a decommissioning plan which the CNSC directed OPG to prepare as part of this license application and which OPG claims to have already commenced the preparation of The identification of 2035 as the in-service date for Adaptive Phased Management (APM) and Deep Geological Repository (DGR) is uninformative; in the case of the former, it tells little to nothing of OPGs decommissioning plans and approach given that 2035 is simply a very optimistic estimate on the part of the Nuclear Waste Management Organization of a potential date for commencement of operations for an as-yet un-sited and un-designed and certainly un-approved deep geological repository for high level 26 Attachment 5 (page 1 of 9) to OPG Letter, G. Jager to M.A. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence, CD# P-CORR , pages H2.1 / 13-H2.1A Oral presentation by Ontario Power Generation Inc. Glenn JAGER, Transcript Page 21 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 16

19 nuclear fuel wastes, and by even the NWMO s estimates any transfer of the fuel wastes from reactor stations to a centralized facility would take place over a 35 year period; in the case of the latter, it is practically irrelevant, given that the operating wastes that are generated at the Pickering stations are moved to the Western Waste Management Facility on an ongoing basis and that Ontario Power Generation has stated elsewhere in its application that decommissioning wastes will be going to an unidentified facility at an unidentified location that is central to OPGs operations, and therefore is not the DGR being referred to. 28 In the description of the very preliminary Storage and Surveillance Plan, OPG indicates that All L&ILW generated in this stage will be considered safe storage waste and handled/disposed of at the current licensed facility, Western Waste Management Facility (WWMF) ; Ontario Power Generation has repeatedly stated that low and intermediate level wastes sent to the Western Waste Management Facility for storage will eventually be placed (according to OPG) in their proposed Deep Geological Repository; wastes from a Safe Storage phase of operations have not been identified as being included in the inventory of wastes that Ontario Power Generation has inventoried as those they would seek to place in the proposed deep geological inventory 29 Ontario Power Generation persistently states that spent fuel waste is kept in the irradiated fuel bays for 8-10 years and is then moved into dry storage, and through these repeated statements over many years it can be assumed that a public expectation has formed that this is their standard operating procedure; however, in the very preliminary description of the Storage and Surveillance Plan (SSP) in Section 2.2 of Attachment 7, OPG states that the SSP will commence in 2024, is expected to cover a 30 year period, and will be divided into two sub-stages, and that it is only in the second sub-stage that the irradiated fuel will have been removed from the wet storage, meaning not until after 2029, or 20 years after the end of operations and so after all of the fuel waste has been in wet storage for at least twenty years and some or most of it potentially for several decades (depending on the removal schedule, which is not described or provided). 28 Attachment 5 (page 1 of 9) to OPG Letter, G. Jager to M.A. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence, CD# P-CORR , page 5 29 Reference Low and Intermediate Level Waste Inventory for the Deep Geologic Repository, December 2010, Prepared by: Ontario Power Generation, Inc., REP R003 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 17

20 Ontario Power Generation states that Decommissioning low and intermediate level waste (LLW and ILW) will be disposed of at a regional disposal facility located in Ontario, approximately equidistant from OPG s five nuclear stations ; 30 this is an astonishing statement, given that no such facility has ever been publicly identified, and it is not known publicly what plans or intentions if any Ontario Power Generation has underway to develop such a facility, or what kind of facility it would be; in April 2013 Northwatch communicated to Ontario Power Generation via their dedicated public information address a request for that OPG identify which facility is being referred to and where that facility is located; no response has been received to date. Ontario Power Generation has made a very preliminary estimate that their actual decommissioning work will commence in approximately 2051 ; they include in their very preliminary plan an assumption that Under the Nuclear Waste Management Organization s Adaptive Phased Management (APM) program, the long term disposal facility for used-fuel is expected to be in service by the year 2035, at which time, used fuel will be transferred from the interim storage location at OPG to the APM Deep Geologic Repository (DGR). Therefore, when the D&D decommissioning work begins at Pickering, it is expected that most of the fuel will have been removed from the site, as Northwatch has previously indicated, 2035 is simply a very optimistic estimate on the part of the Nuclear Waste Management Organization of a potential date for commencement of operations for an as-yet un-sited and un-designed and certainly unapproved deep geological repository for high level nuclear fuel wastes, and by even the NWMO s estimates any transfer of the fuel wastes from reactor stations to a centralized facility would take place over a 35 year period We note with interest that OPG s rationale for a delayed or deferred decommissioning strategy includes allowing time for the development of a used fuel disposal facility and time for the development of a decommissioning waste disposal site 31 ; given the very speculative nature of the APM date and the lack of even a concept for a decommissioning waste disposal facility to date, it is reasonable to conclude that the OPG 30 Attachment 5 (page 1 of 9) to OPG Letter, G. Jager to M.A. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence, CD# P-CORR , page 5 31 Attachment 5 (page 1 of 9) to OPG Letter, G. Jager to M.A. Leblanc, Application for Renewal of Pickering Nuclear Generating Station Power Reactor Operating Licence, CD# P-CORR , page 7 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 18

21 decommissioning timeline will stretch to a date long after the 2064 milestone included in their very preliminary decommissioning plan Ontario Power Generation is proposing a staged or piecemeal approach to the development of their Decommissioning Plans and associated strategies, despite the Commission having instructed them at the time of the last licensing review to prepare a comprehensive preliminary decommissioning plan for examination during this re-licensing period. Ontario Power Generation should be required to provide a comprehensive decommissioning plan one that has been subject to public and Aboriginal consultation as a condition of this license review. Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 19

22 8. Planning for Extended Storage In the late 1950s, the U.S. was one of the first jurisdictions to declare its intention to solve the problem of nuclear waste by what was referred to at the time as land disposal, with the preferred option being to place it in salt mines. The runner up options were solidifying the wastes and placing it in sheds on arid land, or injecting liquid radioactive wastes 5,000 feet below the surface. Canada followed two decades later, with a three month study resulting in the identification of geological disposal as the preferred option, either in the Canadian Shield or salt formations. Almost another three decades have passed, and numerous countries have spent considerable time and research effort in the development of a program to investigate or support deep geological repositories for the disposal of highly radioactive reactor fuel waste, but to date no country has actually implemented a nuclear waste burial program. Increasingly, discussion both in North America and internationally is shifting to an examination of options related to extending on-site storage of nuclear fuel waste into the long or very long term, for periods ranging from 100 to 300 years. There are three primary motivations for this shift: After several decades and a number of failed attempts, there is no geological repository on the near horizon Post 9/11 there are increased security concerns and correspondingly increased security benefits to moving the fuel wastes into more robust conditions Disposal in cavities mined in salt beds and salt domes is suggested as the possibility promising the most practical immediate solution of the problem. Disposal could be greatly simplified if the waste could be gotten into solid form of relatively insoluble character. In the future the injection of large volumes of dilute liquid waste into porous rock strata at depths in excess of 5,000 feet may become feasible. National Academy of Sciences - National Research Council Division of Earth Sciences Committee On Waste Disposal, Report on Disposal of Radioactive Waste on Land, U.S.A., 1977 Following the Fukushima crisis commencing in March 2011, there is growing awareness of the vulnerability of the spent fuel while being maintained in the Irradiated Fuel Bays In addition, in some situations, particularly in the U.S., pools are reaching capacity, and action must be taken in the short term to keep the waste secure over the short, medium and long term. In the U.S., reactors are generally single units, whereas in Canada and particularly Ontario the practice of having multi-unit reactor stations has de facto created centralized storage, with up Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 20

23 to eight reactors operating on a single property. That said, the precise location of the waste management facility within the nuclear generating station boundaries may not be the most appropriate for extended storage that may reasonably be expected to be in place for 100 to 300 years. This will be particularly evident in light of the features of robust storage as described below. Moving to a program of long term at-reactor-site storage will present both opportunities and challenges. Challenges include shifting program momentum after several decades of focus on illusory repository programs, and responding to reactor communities expectations that the waste will be moved off-site, after decades of having been told that this would be the case. Technical challenges include having to potentially manage newer fuels with higher burn-ups, and maintaining technical capacity over the longer term in order to adequately maintain and where necessary upgrade or replace system components. Noteably, these technical challenges will be part of any management scenario. For Canada, an additional challenge is that there appears to have been very little attention given to CANDU spent-fuel management in the international programs. With 10% of reactors world-wide using the CANDU design, this is a gap that should be of concern to more than just Canada. The opportunities include increased security benefits, avoiding the risk of off-site transfer and transportation, and receiving better returns on investment to make storage systems more robust. A necessary first step in the evaluation of the extended on-site storage is the evaluation of how mature current technologies are in their ability to meet storage needs over a year period, and of the regulatory regime to determine the degree to which it can accommodate an extended on-site storage program or the degree to which it would need to be supplemented in order to provide regulatory oversight. In Canada, very little work has been done in this area. A generalized report was prepared for Ontario Power Generation on behalf of Canadian nuclear fuel owners in 2003, discussing conceptual designs for reactor-site extended storage facility alternatives for used nuclear fuel. In comparison, there are numerous reports by U.S. agencies and organizations, some of which include very detailed technical discussions of aging of both fuel and storage system components, Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 21

24 and others which provide detailed discussions of options to increase the robustness of a storage site or system. Unfortunately, we do not have the corollary work done for the Canadian / CANDU context. Three features make spent fuel storage more secure, in terms of potential security threats: Wastes are placed in a condition where it is passively safe, i.e. it does not rely on electrical power, cooling water or active ongoing maintenance The facility is hardened, through layers of concrete, steel, gravel or other materials being placed in various combinations above and around the irradiated fuel waste The fuel wastes are dispersed, with the fuel spread more uniformly across the site rather than concentrated in a single area The feature of passive safety is key in making the waste more secure from human or operational error of natural events. In some situations and designs, dispersal can also be advantageous in keeping the waste secure from human or operational error of natural events. Inarguably, there are benefits to taking a planned approach to extending on site storage, rather than simply have short term or interim storage extend over the long term simply due to program failure. 1 Source: Robust Storage of Spent Nuclear Fuel, Thompson, 2003 Northwatch Comments Pickering NGS Relicensing and Extended Operations Page 22