e-docs-#3840038-cmd 11-h12.33 written submission from the ccnb action saint john fundy chapter

8/3/2019 E-DOCS-#3840038-CMD 11-H12.33 Written Submission From the CCNB Action Saint John Fundy Chapter

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CMD 11-H12.33

File / dossier : 6.01.07Date: 2011-11-14Edocs: 3840038

Oral Presentation

Submission fromCCNB Action, Saint JohnFundy Chapter

In the Matter of

New Brunswick Power Nuclear

Expos oral

Mmoire duCCNB Action,section Saint John Fundy

lgard de

nergie nuclaire du Nouveau-Brunswick

Request for Approval to Reload Fuel andRestart Point Lepreau Nuclear GeneratingStation, and Application to renew the PowerReactor Operating licence for the PointLepreau Generating Station

Demande concernant lautorisation de rechargerle combustible et redmarrer la centralenuclaire de Point Lepreau, et demandeconcernant le renouvellement du permisdexploitation dlivr pour la centrale nuclairede Point Lepreau

Public Hearing Day Two

December 1 and 2, 2011

Deuxime jour de laudience publique

Les 1er et 2 dcembre 2011


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Submission on Relicensing of Point Lepreau Nuclear Generating Station andapplication to reload fuel

To the Canadian Nuclear Safety Commission

CNSC

Date Submitted: 14 November 2011

By CCNB Action, Saint John-Fundy Chapter

Public Hearing Day Two/

Scheduled for:

Dec. 1-2, 2011

Request for a Licensing Decision:

Regarding:

Point Lepreau Nuclear Reactor

Submitted by:

CCNB Action, Saint John-Fundy Chapter, Intervenor


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Point Lepreau Operating Licence and permission to refuel

[CMD Number] i [Date Submitted]

TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................ 1

1.0 INTRODUCTION .................................................................................................. 3

1.1 Background ........................................................................................................... 3

1.2 Summary of Intervention ....................................................................................... 4

2.0 BUSINESS PLAN ................................................................................................ 5

3.0 SAFETY AND CONTROL AREAS (SCAS) ......................................................... 7

3.1 Management System ............................................................................................ 7

3.2 Human Performance ............................................................................................. 8

3.3 Operating Performance ......................................................................................... 8

3.4 Safety Analysis ...................................................................................................... 9

3.5 Physical Design ................................................................................................... 35

3.6 Fitness for Service ............................................................................................... 35

3.7 Radiation Protection ............................................................................................ 40

3.8 Conventional Health and Safety .......................................................................... 40

3.9 Environmental Protection .................................................................................... 41

3.10 Emergency Management and Fire Protection ..................................................... 41

3.11 Waste Management ............................................................................................ 43

3.12 Security ............................................................................................................... 43

3.13 Safeguards .......................................................................................................... 44

3.14 Packaging and Transport .................................................................................... 45

4.0 OTHER MATTERS OF REGULATORY INTEREST .......................................... 45

4.1 Environmental Assessment ................................................................................. 45

4.2 Aboriginal Consultation ....................................................................................... 45

4.3 Other Consultation .............................................................................................. 46

4.4 Cost Recovery ..................................................................................................... 46

4.5 Financial Guarantees .......................................................................................... 46

4.6 Other Regulatory Approvals ................................................................................ 46

4.7 Licensees Public Information Program ............................................................... 46

4.8 Nuclear Liability Insurance .................................................................................. 47


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[CMD Number] 1 November 14 2011

EXECUTIVE SUMMARY

In this intervention we have tried to show from top down bottom up that there are manyissues with restarting Point Lepreau. Our position is that the refurbishment should be changed

into decommissioning. In light of the Fukushima accident there have been many lessons learned.We feel that NB Power and the recommendation from the CNSC staff to be given a license andapplication to refuel, have not fully addressed the seriousness of the Fukushima accident, and forthis reason no licence should be granted.


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1.0 INTRODUCTION

1.1 Background

The group we are representing is CCNB Action SJ Fundy Chapter.

Our Vision:

CCNB believes the future of all life depends on bringing human activity in balance withecological limits.Our Mission

CCNB is a citizens' action group that creates awareness of environmental problems andadvocates solutions through research, education and interventions.

This intervention and the research behind it have mostly been done by just a few peoplein our chapter. They have been working in their spare time and even taken time off work toaddress this very serious matter. In trying to fully understand the problems with Point Lepreauwe had discussions with many people who have been trying to shut down this White Elephantsince its conception. We would like to thank the many people who have taken their time to giveus their history regarding Point Lepreau, and talk about the white elephant in the room. We hopethat today we can finally get everyone in the room to recognize Pointless Lepreau for what itreally is and start discussions on how dangerous it really is.


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1.2 Summary of Intervention

We would like too clearly state that we request that the licence to operate and permissionto refuel not be granted, and the project steered towards decommissioning. We will provideinformation and ask some very tough questions in almost all of the areas of the licence to show

why we take this stance.

Specifically the topic of the Probabilistic Safety Analysis based Seismic Margin Analysiscovered under section 3.4 questions the reliability of the work done in regards to this veryimportant topic in light of the Fukushima accident. It may even suggest that misinformationmight have knowingly been given to the CNSC staff. This alone should question any work thatbeen submitted by NB Power as well as the CNSC staffs recommendation to approve this

licence and request to refuel.

Almost all of the reference material used in this intervention has come from either theCNSC or NB Power. Other documents that have been used are industry documents. We havedone our best to use the best available data and provide it in an understandable contextual waythat corresponds to the licencing of Point Lepreau. We have taken head to information on theCNSC website and have used the template document provided. We have also familiarizedourselves with the rules of proceeding for the Day 2 hearings.

It is also important to note that the core of this intervention has come from a few peopleworking in their spare time, two meetings with NB Power and a tour of the plant. If a couple ofpeople who are not from the industry can find this many serious problems, it might suggest thatthis is only the tip of the ice burg. Also we would like to state that we do not feel comfortablethat we have been able to review everything necessary due to time constraints.

We encourage the commissioners to take this and all of the interveners concerns very

seriously when making your decisions on this very serious matter. One of the major lessonslearned from the Fukushima accident is the problems with industry and the regulators having tooclose of a relationship. We truly hope that this is not the case for this hearing.


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2.0 Business Plan

It is important for us to not be short sighted in our intervention and consider the economicplan for Point Lepreau to a decommissioning phase instead of an operational phase. Inconversations about the hearings with the public a lot of the questions raised are how can they

spend all that money and not operate the plant, and what about jobs lost. We would like to putforward our thoughts on this very important topic.

In 2002 New Brunswicks own Public Utilities Board came to the conclusion after weeksof testimony from NB Power and the interveners, that it was not in thepublics interest. Evenback in 2002 the project was not economical. Despite the warnings from the PUB NB Powerwent ahead with the refurbishment. Many of the risks that where brought out, in the PUBhearings have come to light, as well as many more. These are all upfront cost to therefurbishment. We would like to show that regulatory risk will continue throughout the rest ofthe life of the plant if operated. When looking at these risks especially in light of Fukushmaaccident at any time the CNSC can impose new rules and regulations which could be a huge

financial risk to NB Power. One of the other major risks is that not all of the plant has beenrefurbished, there is a lot of very expensive equipment that might have to be replaced if the plantis continued to run.

When the plant was shut down in 2008 the cost to produce a kWh of electricity at PointLepreau was around 11 cents a kWh. Our residential rate is around 9.5 cents a kWh. Its not hardto see why the PUB advised us to decommission instead of refurbishment. This has not changedand with all the new rules and regulations that have been implemented for refurbishment wouldsuggest the cost of operating the plant will only get worse.

Could NB Power comment if the costs of operating the plant will have increased sincethe time of the PUB hearings.

We would also like to mention some details about the cost over runs at Point Lepreau.The contract for the refurbishment was a fixed price contract; therefore most of the cost overrunshave been paid for from the Federal Government through AECL. Most of the cost overruns thatNB Power talks about are for replacement power and the costs associated with payingemployees to work at a plant that is not operational. Currently NB Power is buying cheap cleanhydro power from Hydro Quebec. They are then selling it at a profit, so any of the so calledreplacement power cost overruns would not be true, they are actually substantially helping NBPower in gaining revenue. This year NB Power actually made a profit of around 60 milliondollars much of this is associated with the cheap power they are getting from Quebec. If NBPower is allowed to restart the reactor we will be no longer buy this cheap clean power from

Hydro Quebec but will be supplying power from a nuclear reactor and selling it for cheaper thanit is produced.

We would like to note that Point Lepreau has been out of service since 2008 and wehavent experienced any shortages of power, so therefore it is not needed.


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I think this would satisfy the question of how they can spend all that money and notoperate the plant. You can see that it hasnt been as much money provincially as it appears on the

surface, as well it would seem that it would be cheaper for us not to run the plant but to buycheap clean power from Quebec. Throwing good money after bad is never a good idea.

Now to address the question what about the jobs. A lot of the jobs for the refurbishmenthave been contractor jobs, which will soon come to an end. The contractors in the area havegotten more than double the amount of work than originally planned, so all these people willsoon be looking for work.

NB Power is required by law to have enough money in the bank for decommissioning.They currently have approximately $500 million in the bank for decommissioning. This ismoney that does not have to be borrowed for the decommissioning but already paid for. Somemight question if this is even enough money for decommissioning as the nuclear industry inCanada has a bad habit of underestimating costs. The one thing that is really important to all thisis that most of the highly radioactive materials from the reactor has already beendecommissioned for the refurbishment.

Could NB Power Please comment on the costs associated to dismantle and store all thewaste from the refurbishment? It has been noted that there has been a lot more waste from therefurbishment than originally expected, so it would seem that there must be cost overrunsassociated with this. What portion the $500 million decommissioning fund would have been usedfrom these real life costs of decommissioning?

Turning the project into a decommissioning would in fact create more work for the localcommunity using funds already in place. A lot of the NB Power employees would still beworking as a result of decommissioning for quite some time.


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3.0 Safety and Control Areas (SCAs)

3.1 Management System

Although NB Powers management system looks good in the nice flow chart that theyprovided on Day 1, I think it is best to look at their decisions and track record as a more accuratedescription of how effective it is. NB Power has a history of making bad decisions that are not inthe publics best interest.

One example was the Coleson Cove Orimulsion conversion fiasco. Against the advicegiven by the public, and without a contract in hand for the cheap dirty fuel they intended to burn,they spent a billion dollars to convert the plant to a fuel that no longer existed by the time theplant was ready to operate. NB Power ran Coleson Cove for approximately 11 days last year,because it is too expensive to run on oil. How many cents per kw hour does it cost to runColeson Cove for 11 days a year after spending all that money?

At the public hearing last year it was stated that the Public Utilities Board gave the goahead for the refurbishment of PLNGS. This is however untrue. The PUB in 2002 made it clearthat it should be decommissioned and that it wasnt in the publics interest to refurbish thenuclear plant. NB Power however went ahead anyway knowing the many risks of this first of akind project. Pretty much all of the risks that were known then, came to life, as well as manymore. One of the major risks that they took was the regulatory risk, which will continue on forthe rest life of the plant as new rules and regulations are implemented. This should be of highimportance to New Brunswickers in light of the Fukushima accident, as this may put NewBrunswickers at more financial risk.

The project has had huge cost overruns. One of the inexplicable actions of management

was to continue to install the calandria tubes after they found they were leaking. Once they hadinstalled all the tubes, they had to take them all out again. We would like to note that the Koreanrefurbishment stopped as soon as they knew there was a problem, unlike NB Power.

No one in NB Power management has taken responsibility for the bad decisions that willbe costing ratepayers and taxpayers so much money, and no one has been fired as a result of abillion dollar mistake.

NB Power has around 5 billion dollars in debt. This is definitely a sign that the company ismismanaged.

During a meeting this summer with Paul Thompson, Derreck Mullen and KathleenDuguay we expressed our concerns about the review level earthquakes for the PSA based SMA.We told them about the Open file 2929 report during that meeting. Our concerns are expressed indetail under section 3.4 of our intervention. There seems to be no mention of any potential gapsin NB Powers submissions about this, which would indicate they did not take this safetyconcern of ours seriously.


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Also covered under section 3.4 it appears that NB Power may have providedmisinformation about reviewing the RLEs against 2010 NBCC in response to the CNSC aboutUSNRC generic action GI-199.

Please see below the CNSC staffs comments on PLNGSs self-assessment.

E-DOCS-#3792135-CMD 11-H12 CNSC Staff Submission on Point Lepreau

Although prior to refurbishment activities, PLNGSs self-assessment programwas well implemented and closely followed, CNSC staff found that during therefurbishment outage, the application of the program had deteriorated in certainareas relating to corrective actions. This has resulted in CNSC staff issuing adirective to NBPN requesting improvements to its self-assessment program.NBPN acknowledged the performance gaps and put in effect an action plan to

augment its capability for self-assessment

Given the above mentioned management issues we have, as well as the CNSC staffrecognizing issues with self-assessment, it would be very hard to guarantee the safety of thepublic and environment, in light that there may be many other unknown issues due to thedeteriorated performance in this matter.

3.2 Human Performance

Human performance has been implicated in most nuclear accidents. There is no

reason to believe that Point Lepreau personnel can handle an accident scenario any betterthan anyone else. Especially in light of them getting a below expectations in theemergency management and fire protection, would suggest that even before there hasbeen an accident that they are failing this really important part of operating a nuclearpower plant.

3.3 Operating Performance

The operating performance of Point Lepreau in the past has not been great. Theyhave had to shut the plant down early and go through this expensive and riskyperformance early in the lifecycle of the Plant. Because this is a first of a kindrefurbishment the operating performance in the future will not likely be optimal.


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3.4 Safety Analysis

PSA based SMA

From the below email from Lisa Love-Tedjou please see the brief but well

described method and functions of the Point Lepreaus Level 1 and Level 2 PSA basedSMA

Email Correspondence with CNSC Staff

A Seismic Margin Assessment (SMA) establishes the capability of the plant to

successfully shutdown and cooldown following a seismic event. The output of a SMA isa plant value expressed as Peak Ground Acceleration (PGA)(g) with High Confidenceand Low Probability of Failure (HCLPF). A Probabilistic Safety Assessment (PSA) basedSMA utilizes the PSA model to establish the system functions and components that arerequired in order to achieve a safe shutdown and cooldown and to quantify the limitingearthquake magnitude that the plant will be able to survive. A PSA based SMA does not

quantify the risk of core damage or large release outside containment.The process starts by performing a walkdown to screen out robust equipment andstructures (SQ @ 0.5g, NSQ @ 0.3g) in accordance with EPRI-NP-6041. Equipment,which is not screened out by this walkdown, requires a fragility analysis to be performed.This analysis will establish the HCLPF value (as per EPRI-TR-103959) for eachequipment and structure model in the PSA. A seismic fault tree is then developed, whichis based on the internal events fault tree, in order to add HCLPF values to eachcomponent/equipment. Furthermore, a primary seismic event tree is developed in order toestablish the consequential accident type (Seismic Induced Initiating Events) resultingfrom an array of seismic magnitude events. For each of these primary sequences,secondary event trees are then developed to detail the mitigation of each seismic initiator

until they are properly mitigated or severe core damage has occurred. From thesesecondary event trees, cutsets are generated from which the HCLPF value of the plant iscalculated by using a Min/Max method using only the pure seismic cutsets. This HCLPFplant value is then compared to the selected Review Level Earthquake (RLE).

The RLE for Level 1 is 0.3g The calculation of the Point Lepreau plant HCLPF for the

level 1 PSA shows a result of 0.3g, and that of level 2 shows a result of 0.42g. The resultsdemonstrate a HCLPF of 0.3g for prevention of severe core damage frequency, an eventthat has a frequency of occurrence of 1/10000 years, and a HCLPF of 0.42g forprevention of large release of fission products from containment, an event that has afrequency of about 1/100000 years.


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We verified with the CNSC staff with respect to the RLE

Yes.

Andrei

-----Original Message-----From: Chris R [mailto:[email protected]]Sent: Friday, October 28, 2011 10:38 PMTo: Love-Tedjoutomo, LisaCc: Blanger, Pierre; Akl, Yolande; Karouni, Jaafar; Blahoianu, AndreiSubject: Re: Answer to Question Two

Just to be clear, I am asking about the Review Level Earthquake. Is the RLEfor severe core damage a earthquake with a probability of 1 in 10000 years?And the RLE for large early release a earthquake with a probability of 1 in100000 years.

Thanks

ChrisSent on the TELUS Mobility network with BlackBerry

-----Original Message-----From: Love-Tedjoutomo Lisa Date: Sat, 29 Oct 2011 01:13:20To: Cc: ; ;; Subject: RE: Answer to Question Two

No I believe it is a comparison to events, likely internal, that lead toeither severe core damage or large release; however, I will have the expertsconfirm on Monday along with the source.

Cheers,

Lisa

-----Original Message-----From: Chris R [mailto:[email protected]]Sent: Friday, October 28, 2011 9:05 PMTo: Love-Tedjoutomo, LisaCc: Blanger, Pierre; Akl, Yolande; Karouni, Jaafar; Blahoianu, AndreiSubject: Re: Answer to Question Two

Thank you Lisa. I'm sorry but may I ask just a few more questions? Are thetwo events mentioned in the last paragraph, with a frequency of 1 in 10000years and 1 in 100000 years, earthquakes? I am assuming yes but just want toclarify. If so how was this determined. Could you tell me what report thisinformation came from and when this report was done?


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So in laymens terms so it is easily understood basically what they have done isfigured out what Structures Systems and Components are needed to prevent Severe CoreDamage and Large Early Release of radiation and have figured out what the HCLPF(HighConfidence Of Low Probability of Failure, This will be discussed later) of the equipment, this ismeasured in g units and is compared to the RLEs (Review Level Earthquake) for Level 1

(Severe Core Damage) and Level 2 (Large Early Release of radiation). Any of the equipmentthat was determined to have a HCLPF lower than the RLE had to have seismic upgrades to meetthe appropriate RLE.

Quote From E-DOCS-#3794617-v1-CMD_11-H12_1

For the PSA-Based Seismic Margin Assessment, the limit corresponds to theReview Level Earthquake (RLE), and is a pass or fail threshold against which theresulting plant seismic capacity is compared. In this case, a HCLPF value higherthan then the one listed below is satisfactory.

Our problem is that the information that the 1 and 10,000 year RLE or .3g and the 1 in 100,000

year RLE .4g came from a seismic study done in 1984, and that the CNSC and NB Power bothhave had access to much newer and better understood information but it was not used todetermine the RLE Levels.

Attached with our intervention we have submitted a document obtained from the NRCan websitecalled Open File 2929. We will be using this document, which was used as expert witness in1993 in a civil case against the Attorney General of Canada, in which at that time the rules forPoint Lepreau were different.


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From Open File 2929

Please Note that NB Powers Name is on the report. We find it quite hard to believe that they didnot know about this or if they just chose not to use this.

Also from a document obtained from the CNSC website acknowledging that the regulator waswell aware of this document, and even did a study to attest to the reliability of the document.Please see below.

From INFO-0656

The new seismic hazard data, as reported by Weston Geophysical Corporation, indicates that thecoefficient of variation of the seismic load effect associated with Eastern Canadian reactor sites


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is in the range of 2 to 7 (compared to the value of 12 used in the previous study). Re-evaluationof the containment failure probability estimates obtained using the new coefficients of variationindicates that the load factor-return period combinations suggested in the previous study (e.g.,a load factor of 1.0 applied to a 500-year load effect for elastic limit states and a load factor of2.5 applied to a 2500-year load effect for ultimate limit states) are adequate. The lack of change

in the recommended load factors, despite the significant reduction in the estimated seismic loadeffect coefficient of variation, is primarily due to the fact that containment reliability estimatesare relatively insensitive to coefficient of variation values in the range of 7 to 12.

Question:

Did anyone in this room from NB Power or the CNSC Staff have prior knowledge of this

document?

If SO, why was it not used to determine the PSA based SMA level 1 and level 2 ReviewLevel Earthquakes?

If NOT why was there not a new one done instead of using the old report from 1984?


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From Open File 2929

Please note the reference above about the longer-term value of the report, which it seems, hasbeen ignored.

Because the rules are different for Point Lepreau now, then when they were back thenwe would like to keep our intervention in context by pointing some of these differences. Whenthis report was done the NPPs had to be able to withstand an earthquake with a probability of 1in 1000 years the DBE or Design Based Earthquake. The new rules as you have seen above statethat they must have certain parts of the plant able to withstand a 1 in 10,000 earthquake and a 1in 100,000 earthquake for the Level 1 and Level 2 PSA based SMA for Point Lepreau.


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From Open File 2929

With respect to the first paragraph for Point Lepreau there has been seismic margin

studies done for the SSC for Point Lepreau for the PSA based SMA. As from the E-Mail abovefrom the CNSC staff, the SSC are seismic qualifications are done to HCLPF not to the normallyrobust engineering standards, so the first paragraph would not apply any more to Point Lepreau.Just for reference the HCLPF means that there is a 95% chance of not exceeding a 5% chance offailure.

With respect to the second paragraph above acceptable risk has been determined for

Point Lepreau. This is done with the two Review Level Earthquakes for the Level 1 and Level 2PSA based SMA.

Now to the differences between the RLE levels used by NB Power and apparently

reviewed and accepted by the CNSC staff, and what the RLE levels would be using this reportand the methods used in regards to this report from the report INFO-0656 a CNSC document.

There is another probabilistic seismic hazard report that has been done for Gentilly-2 byWeston Geophysical called INFO-0637 another CNSC document that uses OPEN FILE 2929 asa reference. In this report it summarizes the data from open file 2929 for the 5 plants that thestudy was done for. For Point Lepreau two seismic source models were used and two attenuationmodels for a total of 4 results. Please note that the probabilities of these results only go up to an


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annual exceedance probability of .0001 which is an earthquake with a probability of 1 in 10,000years the same probability as the RLE for the level 1 PSA based SMA. We will address the 1 in100,000 year RLE later in our report.

CNSC Document INFO-0637


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As you can see the results for the probability of 1 in 10,000 earthquakes are assummarized below. Also note that the results above are in cm/sec2. The conversion factor for thisis to divide the result by 980 to get the g units that we have been using.

Attenuation and Model PGA

Nuttli & Newmark Model 4 .38 g

Nuttli & Newmark Model 5 .46 g

McGuire Model 4 .29 gMcGuire Model 5 .35 g

As you can see the results vary but that 3 out of the 4 the results are higher than the RLEchosen by NB Power and Accepted by the CNSC staff. Having set the precedent in INFO-0656,a CNSC document, they take the results from the different seismic source models and attenuationmodels and take the average of them and that is the number they used.


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CNSC Document INFO-0656

When the four results are averaged the result ends up being approximately .37 g. With 3out of the 4 results being above the NB Powers RLE for the level 1 PSA based SMA and whenyou take the approach that was taken from INFO-0656 we can clearly see that the level chosenby NB Power and accepted by the CNSC staff is too low.

A request was made from us to get a copy of the 1984 probabilistic seismic hazard thatwas used to determine the RLEs for the PSA based SMA. We were not allowed to get a copy of

the document but NB Power did print a copy of it for us and let us review it at their office. Wewere allowed to take notes. We did not have time to fully review this document but some notesfrom it are summarized below.

There appeared to be 3 seismic source models used in this study with one attenuationmodel, but the one attenuation model was done using 3 different inputs to it. One of the 3 seemedto give unrealistic number significantly lower than the other two, and the other two gave similarresults to Open File 2929. Below is a summary of the notes we took for the g levels for aprobability of 1 in 10,000 year earthquake.

Model A Result 1 0.28 g

Model A Result 2 .36 g

Model A Result 3 .13 g

Model B Result 1 0.32 g

Model B Result 2 .43 g

Model B Result 3 .14 g

Model C Result 1 0.26 g

Model C Result 2 .3 g

Model C Result 3 .14 g

If the Result 3 from the chart above is not taken into account you end up with 3 of the 6remaining being above the NB Power RLE for the Level 1 PSA based SMA and if you take theaverage of them the result is .33 g. Even using the document NB Power used it would suggestthat the RLE should be set higher than .3 g.

. Now to discuss the RLE for the level 2 (Large Early Release) PSA based SMA. NBPower has chosen .4g for an earthquake with a probability of 1 in 100,000 years. We will showbelow using information from the OPEN FILE 2929, NRCan Data, the 1984 report that NBPower used as well as information from an email from Greg Rzentkowski to show that thisnumber is grossly underestimated.


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We will begin with the NRCan Data, but, to keep it in context, the NRCan website does not giveprobabilities as low as 1 in 10,000 years or 1 in 100,000 years but does give a way to extrapolateit to lower probabilities. We will also use this method for the data from Open File 2929 and the1984 report used by NB Power. Please see below from the NRCan Website.

From NRCan Website

Low probability hazard and the National Building Code ofCanada

The determination of 1/5,000 or 1/10,000 year (0.0002 or 0.0001 per annum) seismic hazard is

normally required only for special facilities such as nuclear power plants or dams which have a

large consequence if they were to fail. These low probabilities are beyond the scope of the

current National Building Code of Canada (NBCC), which is intended to be used for standard

structures at a probability of 1/2475 years (0.000404 p.a.). Extrapolation of the hazard model to

lower probability results is mathematically possible, but represents an uncertain extrapolation of

the model, and may be unreliable due to (for example) the crudeness of the seismic source

zones used in the model.

Having said that, we give some guidance by providing the 10%/50 year (1/475 year or 0.0021

per annum probability) values from the 4th Generation seismic hazard model in addition to the

2%/50 year 2005 or 2010 NBCC probability values. You can determine the seismic hazard at

these two probabilities for any point in Canada by using our seismic hazard calculator. You can

then plot these two sets of values on a log-log scale and extrapolate them out to the 1/10,000

year return period, with the understanding that we cannot vouch for the validity of these

extrapolated values at your particular site. We believe that for most sites in Canada, these

extrapolated 1/10,000 year values will be slightly conservative compared to the precise 1/10,000

year values calculated directly from our model (though precise, the values may be inaccurate).

These values can be used as a screening tool to determine if a site-specific seismic hazard

assessment is warranted.

If your project requires it (because of the consequences of failure), a site specific hazard

assessment developed by consulting engineers would be required to determine the

1/10,000 year hazard. They would have to perform detailed investigations of the local

earthquakes and nearby earthquake sources and/or faults in order to better determine the very

low probability hazard for the site.
http://earthquakescanada.nrcan.gc.ca/hazard-alea/interpolat/calculators-eng.phphttp://earthquakescanada.nrcan.gc.ca/hazard-alea/interpolat/calculators-eng.php


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Sample extrapolation of 0.0021 p.a. and 0.000404 p.a. hazard values to a 0.0001 p.a. value, to

be used for screening purposes only to determine if a site specific seismic hazard

assessment is warranted.


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The .0021 p.a. for Point Lepreau using the NRCan calculator and applying the hard rock factor tothe number results in .05g and .14g for the .000404 p,a. The extrapolated data to the .00001 p.aor the probability of 1 in 100,000 year earthquake is approximately 1.2 g. This is 3 times thelevel NB Power used and the CNSC staff accepted.

AnnualProbability

PGA


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See below from NB Powers Response to the Fukushima lessons learned to the CNSC.

2011-07-28 PLGS Response to CNSC Fukushima Task Force

Using the methodology from the NRCan website on how to screen for low probabilityearthquakes we show above approximately 1.2 g for the 1 in 100,000 year earthquake. It appearsthat NB Power might have knowingly provided misinformation in their response to the CNSCFukushima Task Force. As well, it appears that the CNSC staff did not review the content of thereport. This is totally unacceptable and for this reason alone NB Power should not be given alicence to operate or allowed to refuel. This should question all of the other work that has beendone, and its review process with the CNSC staff.

Because the OPEN file 2929 report does not show the PGA value for a 1 in 100,000 yearearthquake we will apply the methodology used by NRCan. For this though we will plot all thepoints given on the log to log graph. Below are extrapolated .0001 per annum graphs for the 4different results from OPEN file 2929 plus a graph of the averaged results. Please note that wehave even taken into account the slight curve in the log to log graph.


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MODEL 4, Nuttli &Newmark

Annual Exeedance Probability

PGA

This shows and extrapolated PGA value of approximately .75g for the 1 in 100,000 yearearthquake.


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Model 4 McGuire

Annual Exceedance Probability

PGA

This shows an extrapolated PGA value of approximately .65g for the 1 in 100,000 yearearthquake.


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Model 5 Nuttli & Newmark


PGA



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Model 5 McGuire


PGA



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Average of all four results from Open file 2929


PGA


As you can see from the 5 graphs above that the PGA for an earthquake for a probabilityof 1 in 100,000 years is substantially above the RLE level that NB Power has chosen and theCNSC staff approved.


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Now we would like to discuss the 1984 report that NB power used to determine the RLEfor large early release. In this report it did not extend the probabilities to the 1 in 100,000 yearearthquake, but when we were there we extended the seismic hazard curve and got the followingtwo results from the document. One was approximately .65 g and the other was approximately.8g. Again you can see that the RLE of .4g that NB Power has selected and CNSC staff approved

is substantially lower than even the information from the report they used.

Also in our brief look at the PSA based SMA one other thing that we noted was that theraw service water intake and outtake tunnels were not considered as part of the SSC. These arevery critical parts of the plant to maintain cooling. Why were they not considered in the PSAbased SMA?


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PSA Level 1 and Level 2

IAEA-TECDOC-1511 Determining the quality ofprobabilistic safety assessment(PSA) for applications in

nuclear power plants

4.1. Main objectivesThe initiating events analysis is a highly iterative, multi-purpose task, which providesthe basis for the PSA and ensures its completeness. The risk profile can be incomplete anddistorted if important initiating events (IEs) are omitted or incorrectly included in the IE

Above is excerpt from an IAEA document that is referenced in the licence conditions forthe PSAs as a guidance document. It shows the importance of looking at all the proper initiatingevents. Please note as well that because a PSA based SMA was done instead of a PSA forearthquakes that the core damage frequency and large early release numbers do not take intoaccount the true level of safety for the plant.

We would like to note that Hurricanes should have not been screened out of the PSAs.Below is a section from PLGS Response to Fukushima Lessons Learned.


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NB Power are making some very dangerous assumptions that offsite power will not belost at winds below ones that will be sustained greater than 175 km/h. With the effects of globalwarming and the fact that the maximum wind data they are using is coming from the original

Environmental Assessment done in the 70s the actual data they are using is dangerous. We havealso learned from Fukushima that long term heat sinks are needed and that just shutting down thereaction does not put the plant in a safe state.

Also plant flooding has been screened out of the PSAs. Again there have been some very

dangerous assumptions made.


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We would like to point out that the data for rainfall more than likely came from theEnvironmental Assessment done in the 70s. With global warming the increase in magnitude and

probability of storms has increased using this old information could pose unacceptable risk to the

public.

They also mention that it is assumed that the capacity of the drainage system will beexceeded. What they dont take into account is that the capacity of the drainage system will belowered due to plugging or ice build-up etc. In the event that the drainage system is reduced theexternal flooding scenario can become worse. It is important to note that emergency generatorscould become flooded during this type of scenario.

It also mentions the maintenance of building sump pumps. Our Members asked duringthe site visit if these pumps were on emergency power supplies and were told that they were not.

From the site visit our members went on it was noticed that the plant is surrounded byhigher elevations which would put the plant at risk to external flooding especially with reduceddrainage and the sump pumps not being on an emergency power supply. Please see below a


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picture of Point Lepreau to get feel for this.

We would also like to point out that the PSAs were developed for the plant u nder full

power. It was brought up in the Day 1 hearings that the electrical output of the plant will beincreased by 100MW. 25% of this is due to generator efficiencies, but the other 75% will have tocome from additional reactor power. How can the PSAs be deemed appropriate when they usedthe old reactor power rating before refurbishment? It was also noted that the PSAs were basedon the pre- refurbishment plant configuration, again without the new PSAs being done how canwe know if it is within the limits set for safe operations?

All of the above statements would also hold true for the Safe Operating Envelope asPoint Lepreau does not have any operating experience operating at this new level of reactoroutput and current plant configuration.


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RD-360 Life extensions of Nuclear Power Plants

Please see below a reference from RD-360

RD-360

The ISR should include:

1. Conformity reviews that confirm that the NPP meets and will continue to

meet the current plant-specific licensing and design basis;

2. A review against modern standards and practices to assess the level of

safety compared to that of modern NPPs (any shortcomings against these

modern standards and practices are identified and their safety

significance determined);

3. Any modifications that are necessary to improve the level of safety; and

4. A global assessment of plant safety for long-term operation in view of each

of the ISR safety factors.

We would like to note that in the CMD by either NB Power or the CNSC staff that there

is no comparison of Point Lepreau to modernNPPs. During a meeting with NB Power we asked

if Point Lepreau would meet new build standards and were told point blank no that it would be

practically impossible. How can the commission possibly make a decision based on the CMD

documents without knowing the gaps between the refurbished reactor and a new or modern

reactor? Also in the spirit of the Nuclear Safety and Control Act, why was this scientifically

objective information not disseminated to the public?

Pickering ISR Rejection

In 2008 the Pickering ISR report was rejected by CNSC. We would like to see NB Power

or the CNSC staff to comment on each individual section ofE-DOCS #3232348 / 2.01 andexplain why each does not apply to Point Lepreau, what measures have been taken to addresseach of these issues. We are not looking for the usual answers that it is safe. Please providedetails and backup information.


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Category 3 Candu Safety Issues

In 2007 a report came out on the Category 3 Candu Safety Issues. In reading the AnnualCNSC Staff Report on the Safety Performance of the Canadian Nuclear Power Industrysince2003 we can see that many of the safety issues are still not resolved. Some of these issues havebeen known since 1995. 16 years later and dates for resolve of these issues being not met showsthat the resolve of these issues is not easy. This does not give us any confidence that these issueswill be resolved in a satisfactory way any time soon. 16 years is around half of the life of aCANDU NPP, this is not a reasonable time frame for resolving serious safety issues. We wouldlike to note for the rest of the public that the positive void coefficient is the same design issuethat caused the Chernobyl accident as well as one of the first meltdowns that occurred in 1952 Atthe NRX reactor in Chalk River Ontario.

We would like to also note that in the reports as well as the CMD documents for thislicencing hearing state that many of the original issues are closed. There is no mention of whatwas done to close these issues. Can NB Power or the CNSC staff please address each issueindividually and explain each issue to us and the public and what has been done to resolve eachof the closed issues? Please provide details and backup information on each.

Location of Steam Pipes

It has been noted many times that there could be issues if there is a main steam piperupture; that it could render the control room inoperable. In talking with NB Power about this wewere told that they have done pipe support upgrades, have leak before break technology on the

pipe, and now man the secondary control room at all times. During our site visit we noticed thatthe main steam line leaving the reactor building is also over the secondary control room. It ishowever up quite high, but this is a large pipe and if it were broken and fell down could alsorender the secondary control room inoperable. We also asked what kind of automatic shutoffthere was to shut the steam off in the event of a leak. We were told there wasnt any and that itwas all manual intervention. Would the operators have enough time to react to the leak beforethe line did break? Steam is a very powerful source of energy and can do a lot of damage veryquickly. This problem has also been a Generic Action Item for CANDU plants, specifically highenergy line breaks. The fact that NB Power has not rerouted the steam line shows their lack ofregard for the safe operation of the plant.

Emergency Vault Make up water

We would like to discuss the new emergency vault makeup water line that was added forthe refurbishment. Is there not an emergency return water line as well so that water can becirculated? If not where does all of the water go that is added? In light of the Fukushima accidentwhen all normal heat sinks are lost and emergency water from the sea had to be added to thecontainment. There has been a lot of radiation release in the form of contaminated water from


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Fukushima due to these emergency cooling scenarios. This does not appear in any of the CMDdocuments and we would like to suggest that this is a gap that has not been addressed.

3.5 Physical Design

We have no comment on this issue as we did not have enough time to do anyresearch on the matter.

3.6 Fitness for Service

Stress Corrosion Cracking(SCC)

We would like to address the problem of SCC in regards to Point Lepreau. With thereferences we sent with our intervention a document with regards to stress corrosion cracking atPoint Lepreau.

Risk-Reduction Strategies used to Manage Cracking of Carbon Steel

Primary Coolant Piping at the Point Lepreau Generating StationJohn P. Slade1, Tracy S. Gendron21New Brunswick Power Nuclear, Point Lepreau Generating Station, P.O. Box 600, Lepreau, New Brunswick, E5J 2S6

2Atomic Energy of Canada Ltd. Chalk River Laboratories, Chalk River, Ontario, K0J 1J0

We would like for the commissioner to please read this document.

After reading this it is apparent that there are many unknowns and risks associated withSCC at Point Lepreau. It is noted that yes some of the primary heat transport system has beenreplaced in the refurbishment but there is substantial amount of it that has not been replaced i.e.steam generators.

We would also like to point out something that was mentioned in Day 1 hearings that anew type of harder material has been used for some of the piping. This material has not beentested and it seems should help with Flow Accelerated Corrosion but this will not necessarilyhelp with SCC.

Another point we would like to make is that chemistry plays an important part in SCC.The heavy water for the primary heat transport system is going to be reused, so they are puttingthe same chemistry back into the system with new the new and old piping. What if there issomething specific to the heavy water at Point Lepreau that is causing SCC that is not currentlymonitored, measured and controlled through their chemistry control program?

As well we would like to point out that it says the amount of cold/hot work on the pipingcan be a mechanism for SCC. With the fact that all the tubes have been put in then taken out


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repaired and then put back in would suggest that the amount of cold/hot work on the pipingsystem has increased.

We dont feel that NB Power has fully addressed this very serious problem.

Containment Building

There have been many problems with the containment structure since the original buildof Point Lepreau. There were many problems with the contractors in the original build of PointLepreau, and would suggest that the quality of work done in the original build might not be doneto design. Very early on in its life the containment developed cracks which had to be fixed. The

ring beam has had to have substantial work done on it during the refurbishment. The leak testthat was done in 2004 failed. All these things along with the fact that the containment has been ina harsh Atlantic environment for over 30 years would suggest that it would not be nearly asstrong as it should be.

Below are comments made by CNSC staff with regards to the last leakage rate test done.

E-DOCS-#3792135-CMD 11-H12 CNSC Staff Submission on Point Lepreau withDocumentation Combinedl

In the last leakage rate test report for the Point Lepreau Reactor Buildingsubmitted by NBPN [50] in 2004, it was noted that the leak rate of the Reactor

Building was determined to be marginally below the Operating Policies andPrinciples (OP&P) acceptance criterion of 0.5% vol./day. In July 2009, NBPNrequested an amendment in the licence to postpone the Reactor Building LeakRate Test (RBLRT) from December 31, 2009, to the end of refurbishment outage[51]. The CNSC requirement for the frequency of leak rate testing for CANDU-6containments is every three years in accordance with BMD 96-19 [33]. Anamendment to the licence was subsequently granted to NBPN. A specific sitelicence condition (LC 16.2) requires NBPN to carry out a test to measure the rateof leakage from the reactor building when subjected to full design pressure prior

to the removal of the GSS.

Also please see the License condition 16.2

E-DOCS-#3792135-CMD 11-H12 CNSC Staff Submission on Point Lepreau withDocumentation Combined

16.2 The licensee shall carry out a test to measure the rate of leakage from the reactor building whensubjected to full design pressure at the end of the refurbishment outage and prior to removal of theguaranteed shutdown state, unless otherwise approved in writing by the Commission, or a person


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authorized by the Commission.

Please note that the license condition only states that it has to do a leak rate test, not thatit has to pass a leak rate test prior to the removal of the guaranteed shutdown. This isunacceptable and putting the public and environment at unreasonable risk.

From a document from the CNSC INFO-0584 please see below.

INFO-0584 Reliability of Containment and Safety Related Structures

This suggests that if the containment does not pass a leak test that there may be structuralproblems with the containment which may have problems with enduring earthquakes. This isrelevant to our sub section on the PSA based SMA in section. This is not noted as a potential gapin the CMD documents.

In another document we obtained from Science Direct an article entitled Probabilistic

seismic risk analysis of CANDU containment structure for near-fault earthquakes by In-Kil

Choi , Young-Sun Choun, Seong-Moon Ahn, Jeong-Moon Seo.

It says that the cracking mode for a CANDU containment structure is at .28 g.This is in contradiction to a level of approximately .42g that is given for the containmentbuilding for the level 2 PSA based SMA talked about in detail in section 3.4. This wouldalso suggest not only problems with the determination of the RLEs for the PSA based

SMA but also with the fragility analysis that has been done for the Structures Systemsand Components for it.


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Intake outtake tunnels for Raw Service Water(RSW)

The functionality of the RSW for Point Lepreau is critical to maintaining cooling for thereactor. It worries us that this was not taken into account in the PSA based SMA. Also we wouldlike to point out that during Day 1 the topic of mussels obstructing the RSW came up. It was said

that provisions for up to 1 foot of muscles in the intake and outtake was accounted for. We thinkit would be safe to assume that there are mussels on the intake and outtake tunnels. On our sitevisit we asked NB Power about the tunnels, and they said that they had divers go in and inspectthe tunnels during the refurbishment. How could divers properly inspect the tunnels if they arecovered in mussels?

CSA Standards

In day 1 there were a lot of discussions about the wrong CSA standard being used tocheck for cracks on the pipes. In particular they only talk about the size of the calibrationstandard, and that after they found out about the problem they found that other pipes were beingchecked using the wrong calibration standard. Our question is what are ALL the differencesbetween the old CSA standard that was used and the new one that was supposed to be used. CSAstandards are usually long detailed documents with lots of information in them. Usually theyonly update them when there are substantial changes. In the root cause analysis done for thisissue were all the differences between the two standards looked at to see how the safety of theplant might be affected?


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Old controls and electrical wiring

This section is by one of our members Chris Rouse who is an Industrial ControlTechnologist who has worked in the Electrical and Controls engineering for over 15 years. Heshould be considered as expert witness in this area and is offering his opinion from the brief tour

he went on.

During the first part of our trip when we went to the spent fuel bay I was looking at thisvery old control panel and was amazed that equipment of this vintage was still being used. Oneof the NB Power people saw me looking at it and made the comment Looks hi tech doesnt it?

In my honest opinion I thought that it should be in a museum. Throughout the rest of the tour Iwas shocked to see such old equipment that would have been considered old and obsolete when Iwas attending community college 15 years ago. The control room again I couldnt believe that

most of the Human Machine Interfaces where still push buttons and pilot lights on large consolessurrounding the room. In the event of an earthquake it would be quite possible for some of thepilot lights to burn out and not give proper indication to the operator about importantinformation.

Another thing I noticed was that some of the cable trays where full. In this situation asper the Canadian Electrical Code the ampacity of the cables must be de-rated by as much as 50%to prevent heat up and possible fire. Have all of the cables in the cable trays that are full been de-rated as per the Canadian Electrical Code.

When we visited the secondary control room and the new emergency vent system Inoticed that some of the electrical enclosures used for the emergency vent system room wherenot weather proof boxes and that some of them did not have any kind of environmental

qualification. In this room there were several pipes that if had a leak could and prevent this veryimportant equipment from operating properly or to give the operators key information they needto assess the situation.


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3.7 Radiation Protection

Members who visited the Point Lepreau Nuclear Plant recently noted thatprocedures for dealing with possible contamination were inconsistent. After they went tothe spent fuel bay one of the members had to put his hands in a radiation detector, and it

came up that he was contaminated. NB Power then told him to try again and he passed,and they continued to leave the spent fuel bay area where you have to go through adifferent radiation detector. This time one of the NB power people tested positive forradiation. She was taken back out of the detector and everyone seemed complacent that itwas just static electricity on her pants. They then checked her with a hand held radiationdetector on her pants where she then began rubbing her pants with her hands. Then theychecked again with the hand held device on her pants and it came out negative, but theydid not check her hands where she rubbed her pants. We would like to point out that ourmember was told to just try again when he came up contaminated and was not tested withthe hand held device.

In 2008 and 2009 NBPN were unable to provide evidence that contractoremployees were completing the required dosimetry monitoring prior to leaving the site ontheir last day of employment. This suggests that doses to workers may have beenunderreported. CNSC on page 42 also suggests some workers may have had internaluptakes that were unmonitored. Perhaps this partly explains why NBPNs collective doseperformance was better than Canadian NPP utilities average in 2006 and 2007.

During the refurbishment, nuclear workers were exposed to higher radiation dosesthan predicted. Some workers were exposed to more than 10 milliSieverts per year. Whywas the refurbishment not delayed until the radiation in the plant had decayed to lowerlevels to make it safer for the workers? Why did the workers continue to install calandriatubes after they had been found to be defective? This increased worker exposure by

1.4pSv unnecessarily. This is not in the spirit of ALARA.

Were workers at Lepreau exposed to alpha radiation prior to the implementationof appropriate protective equipment for alpha hazards? If so, have their family doctorsbeen notified so that they can be monitored for future adverse health effects?

3.8 Conventional Health and Safety

We would like to note in NB Powers Submissions that they only talk about losttime accidents. This is only one of the Key Performance indicators for determiningconventional Health and Safety.


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Quote from Telegraph Journal July 18th, 2011

By the end of May 2011, there had been nine "lost time" injuries where an employee was unableto work, 28 "restricted work" injuries where an employee could work but not at the same duties,36 incidents requiring medical aid - not necessarily due to a workplace injury - and 1,125incidents requiring onsite first aid.

There were also 2,963 "near misses" such as when an employee falls but isn't injured and 327incidents of property damage.

As you can see from the above that although the lost time injuries whererelatively low there are a lot of other concerns. Looking at the above there wasfirst aid required just about every day of the refurbishment, and almost 3 nearmisses per day.

WANO uses a metric of Industrial Safety Accident Rate as a performanceindicator.

Question: For the years 2008, 2009, 2010 what is NB Powers Industrial SafetyAccident Rate as per WANOs performance indicator? Please compare themagainst the industry averages for those years.

3.9 Environmental Protection

Tritium releases to air appeared to be increasing prior to shutdown, reaching 200

Terabecquerels in2007 and Carbon-14 0.37 Terabecquerels. There was a large increase inCarbon14 releases to water in 2007and 2008 compared to 2006. Why was this? Therewas also a striking increase in tritium releases to water in 2008, of 2309 Terabecquerels,when the reactor was shutdown, as compared to 2007 at 292 Terabecquerels. What couldhave caused a higher emission rate in a shutdown than an operating reactor? Also whywere tritium levels in surface water at the waste facility so high from 1997-2006, almost1600Bq/L.? If it was due to air emissions being washed out in the rainwater, as it thereport seems to suggest, perhaps people in the surrounding communities should bewarned about going out in the rain, breathing the air, drinking surface water?

3.10 Emergency Management and Fire Protection

CNSC found Emergency Management and Fire Protection to be BE or belowexpectations in 2010, but have allowed the NBPNGS to defer compliance until after startup. In view of the fact that the Point Lepreau Nuclear Generating Station has frequently


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delayed compliance, we urge the CNSC not to issue the licence or allow fuel reload orrestart until the emergency management and fire protection have been brought up tostandard. This is vital for public health and safety.

The public has found the Lepreau Emergency Plan below expectations for 30

years. Many people do not feel they know what to do in an emergency, how they are tobe notified, where they are to go in an emergency, where to evacuate to. What are they todo if telephones are knocked out along with the accident? They have seen the new Esigns on the highway, but these may send them into the path of fallout, like theunfortunate people in the town in Japan who evacuated to a shelter in the path of thefallout.

Past criticisms of the emergency plan were:

Emergency Planning and Nuclear Realities, MEC, 1981

1. Inadequate public notification (defective cold war emergency sirens, which

were later dismantled but what have they been replaced by?)

2. Inadequate size of evacuation zone, not even including Saint John, the largestpopulation centre. The U.S. military recommended 50 mile evacuation zonefor Fukushima, which would include Saint John.

3. Potassium iodide pre-distribution to too small an area, with inadequateprovisn for public health to distribute stockpiled tablets to the rest of thepopulation.

4. Inadequate coordination among agencies required for nuclear emergency

response.( Although fire, police, and hospital emergency personnel are used toworking together in emergencies, a nuclear emergency requires the promptcommunication by nuclear plant staff with government, and rapid deploymentof public health staff, with radiation-monitoring equipment and potassiumiodide tablets, as well as the usual fire, police, and emergency medicalpersonnel.)

A major lesson the public learned from the Fukushima accident in Japan isthat the nuclear culture of secrecy, lack of sharing of information, poorcoordination among government, industry and the scientific community andlack of communication of the facts to the public, and delaying urgent actioncan turn an emergency into a disaster and a disaster into a catastrophe withfar-reaching environmental and health consequences. Measures that couldhave prevented the explosions were not ordered or carried out in time;evacuations, sheltering and administration of potassium iodide were notimplemented in an optimal manner; knowledge of the radiation plume was notgiven to those who needed to know, so that people evacuated into irradiatedareas without shelter.


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In contrast to the Fukushima accident, where mitigating actions weredelayed, the Soviet Union evacuated people, and provided many withprophylaxis against radioactive iodine, mobilized hundreds of thousands ofpeople to creatively and courageously fight the Chernobyl nuclear explosionand fire, and try to clean up the area after the Chernobyl nuclear accident.

Although nearly a million people have died over the 25 years since theaccident, and the economy of the Soviet Union collapsed, it could have beenmuch worse. (New York Academy ofSciences, Compilation of Chernobyl Studies, 2009)

3.11 Waste Management

It has been noted that there has been a lot more waste from refurbishment thanoriginally anticipated. They are now shipping some of the low level waste to the US forincineration and the ashes brought back to Point Lepreau to take up less volume.Apparently there are filters on the incinerator to catch any radioactive materials from

going into the air. While on our site visit we asked if the filters that have radioactivematerials from the incinerator are being brought back. We were told no. NB Powershould be responsible for that waste and should not be left for the US to take care of.

Please see questions and comments to in our Business Plan Section 2.0

3.12 Security

During a visit by a couple of our members we would like to explain a situationthat happened. Our members were told that as visitor we had to be accompanied by anauthorized person at all times. The person responsible for us had to wear a red badge. At

the beginning of our tour one of the people from NB Power had the red badge and wasresponsible for the members. We went outside to look at the new emergency generators.When walking back that person broke away from our group to go inside. When one ofour members noticed this he said are we not supposed to be with her. Then another NBPower person showed us that he now had the red badge and that the other person hadgiven it to him back at the generators. We think it would be important for the visitors toknow when the person that is responsible for them has changed for their own safety incase of something happening at the plant.


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3.13 Safeguards

In NB Powers response to the Fukushima lessons learned it talks about airplane

crashes. Please see below excerpt.


Please note that the act of terrorism was not looked at in this report, but couldimagine that if the plant was designed to handle bigger planes than those smaller onesfrom the SJ Airport, they would have mentioned it. Point Lepreaus containment is

approximately 1 m think. The French nuclear company Areva has publically stated thatcontainment should be at least 2 m think to be able to withstand large airplane crashes.

We would also like to point out that there is no mention of the spent fuel bay inthis section of the plant. As we have learned from Fukushima that one of the mostdangerous parts of a nuclear plant is the spent fuel bay. This area is not within thecontainment structure, and seen as its not mentioned in hear we would have to assumethat this is a gap that hasnt been identified.


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3.14 Packaging and Transport

We have no comment on this issue as we did not have enough time to do any research onthe matter.

4.0 OTHER MATTERS OF REGULATORY INTEREST

4.1 Environmental Assessment

An environmental assessment was not done because it was classed as amaintenance outage. This was a mistake. Because they used old data from the originalEIA, which was 30 years out of date, problems like climate change were not considered.The environment and environmental problems have changed a great deal in the last 30years.

A recent lawsuit brought forward by Greenpeace on an inadequate nuclear reactorenvironmental assessment shows how important doing a proper EIA is.

4.2 Aboriginal Consultation

We are aware that Point Lepreau, on the Bay of Fundy which is now the locationof the Point Lepreau nuclear generating station is located in traditional Passamaquoddyfirst nations territory. Indeed the cove on the immediate west side of the Point Lepreaugenerating station is named Indian cove on both federal navigational charts and bothfederal and provincial land maps. A seasonal and sometimes permanent settlement waslocated within a few hundred meters of the reactor site, and just above the beach in thearea where the pump house now exists. From this location the Passamaquoddy fished andhunted marine mammals processing there catches on the beach.

The area was physically altered and the construction of Point Lepreau wascommenced without consultation or negotiation with the Passamaquoddy. We recognizethe sovereignty of the Passamaquoddy nation and are in full support of their position

regarding this licencing. We are also in full support of the will and desire of thePassamaquoddy first nations regarding any future operation of the reactor at PointLepreau and the storage of radioactive waste and spent fuel.


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4.3 Other Consultation

It would seem that NB Power and the CNSC staff have missed some veryimportant things. We would suggest that a full peer reviewed technical assessment of thislicence and NB Powers submissions and the CNSC staffs recommendations before any

licence to operate is given.

4.4 Cost Recovery

We have no comment on this issue as we did not have enough time to do anyresearch on the matter.

4.5 Financial Guarantees

We have no comment on this issue as we did not have enough time to do anyresearch on the matter. But we would like to note that the money pit for this white

elephant of a nuclear power plant seems to be bottomless.

4.6 Other Regulatory Approvals

We have no comment on this issue as we did not have enough time to do any research onthe matter.

4.7 Licensees Public Information Program

We would like to thank Paul Thompson and Kathleen Duguay and everyone else at NB

Power for the time they spent with us answering our questions and the information that they gaveus, it has proved to be very useful in our intervention.

But I would like to point out one thing that a lot of the documents that were related to thelicence that we asked for they could only make available in paper copies and not allowed to takethem, only to view them at their office. We realize there is the right to information act, butsometimes this is also a long process. Given the time constraints of the licencing period it makesit hard for regular members of the public to fully review all the things that need be.

We would like to point out that we feel that although we have a pretty thoroughintervention, we would have liked to have more time and better access to information. For the

record we have not reviewed this licence to our satisfaction, due to lack of reasonable time andaccess to information.

Another point that should be made is that Chris Rouse the main author of this documenttechnical researcher has spent hundreds of hour working on this since the Fukushima accident,and has taken plenty of time off work without pay to attend meetings, go on site tour and writethis intervention. Not even half of the participant funding was used, and less than half of themoney we applied for was given to us. In our application we had $10,000 in our intervention for


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him, but he was not approved. We feel this is an unfair financial burned to be put on a concernedcitizen of the public who can bring new information to the commission.

Another point we would like to make is that as a group there were a lot of questionsasked of the CNSC 101 meeting in Saint John. The CNSC were rather rude to us at the meeting.

It was made clear that we wanted these questions answered for our interventions. To date only afew of these questions have been answered and thus a gap in our intervention.

We would also like to share an experience we had at the CNSC 101 meeting with one ofthe CNSC inspectors at Point Lepreau. One of our members called the other just as the meetingwas supposed to be over. She was talking to a CNSC inspector when the other person called andjust put the phone on speaker. The first thing the person calling heard was I dont care about

your safety issues and continued to be very rude in response to her concerns.

4.8 Nuclear Liability Insurance

Private insurance companies have always refused to provide insurance for nuclearaccidents, because the consequences are so severe and costs astronomical. (See yourhouse insurance policy for the exclusion.) To allow the nuclear industry to continue thefederal government limits their liability for an accident by law to a small amount, whichhas recently been made smaller. The taxpayer is required to pay the rest. The Chernobylnuclear accident resulted in the collapse of the Soviet Union, and the former PrimeMinister of Japan stated that he considered evacuating Tokyo after the Fukushima nuclearaccident, but did not, because he feared it would cause the collapse of Japan.


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Report submitted for the CNSC's re-licensing hearings for the

Point Lepreau Nuclear Generating Station

NOTE FROM THE SECRETARIATOF THE COMMISSION

NOTE DU SECRTARIATDE LA COMMISSION

This document is listing several

reference documents; not all of them

are included in the current

submission.

Copies of the references can be

obtained by contacting the

Secretariat of the Commission:

Louise Levert at 1-800-668-5284 or

613-996-9063

[email protected].

Ce document fournit une liste de

plusieurs documents de rfrence.

Ils ne sont pas tous inclus dans le

prsent mmoire.

Pour obtenir une copie des

rfrences, veuillez communiquer

avec le Secrtariat de la

Commission :

Louise Levert au 1-800-668-5284 ou

613-996-9063

[email protected]


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ThePotentialImpactsofClimateChangeandSeismicityinRelationtothePointLepreauNuclearGeneratingStationTableofContents

Introduction

Exec Summary

Section1KenBurkeNewSeismicdataanduncertainty

A)Descriptionofdeliverable

B)Itemizationofdocs

c)summaryofreportsanddocs

d)

New

information

e)RedFlag

f)references

Section2Morequestionsandunknowns AlanRuffmans


B)Itemizationofdocs

c)

summary

of

reports

and

docs

d)Newinformation

e)RedFlag

f)references

Section3 ClimateChangeConsiderationsRaphaelShay


B)

Itemization

of

docs


d)Newandbetterunderstoodinformation

e)RedFlags

f)References


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g)Recommendations

Section4 NewSeismicconsiderationsinConjunctionwithotherNuclearPowerPlantHazardsProfessor

MichelDuguay


B)Itemizationofdocs


d)Newandbetterunderstoodinformation

e)RedFlags

Introduction

ThisreportiscompiledbythechairoftheSaintJohnFundyCCNBActionChapter,SharonMurphyFlatt,

inconsultationandinputfromtheCCNBActionSJFundyChaptermembers.Thecontentisdividedinto

4mainsections,eachdrawingfromtheexpertiseofanexpertintheirfield.

ExecSummary

Thereexists,inthefieldsofseismicstudies,nuclearpowerandclimatechangeacommonlink.They

sharemanyknownuncertainties,betterunderstoodknowledgethathasbeenacquiredovertimeina

learningcurve,andnewdata/knowledgethatwasnotavailableatthetimethePtLepreaugenerating

plantwasdesignedandbuilt.Duringtherefurbishmenthowever,theuncertainties,newknowledgeand

betterunderstoodinformationwasknownbutnotproperlyinterpreted,legislated,fundedor

implemented.

Weconsulted2oftheprofessionalsthatNBPowerhasengagedovertheyearstoresearchandjustify

theirseismicityconfidenceanddesign.WealsocontactedaprofessorofnuclearphysicsfromMontreal

andaskedhimhowseismicitymightaffectdifferentsystemsinanuclearplantandwhatarethe

dangers?Wealsocontactedanunfunded,unsanctionedclimatechangeexpertthatwasbroughtinto

replaceourfundedandsanctionedexpertwhohadtodeclineasourexpertduetopersonalreasons.

Thefunderswereunabletogiveuspermissiontoreplaceourexpert2weeksbeforethereportswere

due(apparentlytooclosetothehearings)andsodeclinedtheresumeofourclimatechangeexpert

(attached).Ourclimatechangeexpertwasaskedtoprovideashortbestpracticesdocumentregarding

climate

change

adaptation

and

precautionary

best

practices.

Inthecaseofseismicity,theuncertaintiesexistsomewhatduetolackoffundedstudies,lackof

responsibleoversight,lackofthegeneralconceptsofwhodoeswhatinthefieldandinonecase,our

expertwonderedaboutconspiratorialbehaviour.

Climatechangeitselfisacertaintyalthoughwhenandhowseverethecomingstormswillbeis

uncertain.Newknowledgecurrentlyexistsregardingbestpracticesandprecautioninthisregard.


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Inthenuclearpowerindustry,thenewandcurrentknowledgethatexistsregardingsafetyand

concurrentaccidentsisrifewithuncertainties,unknownsandrecently,withtheaccidentinFukushima,

lessonslearnedbutnotactedupon.

TheCCNBSJFundychapterisoftheopinionthattheuncertainties,concernsandrisksthatexist

surroundingthe

refueling

of

the

Pt

Lepreau

Nuclear

generating

plant

far

outweigh

the

adaptation

and

precautionthathasbeentakentomitigatesuchissuesfromhappening.

Thispaperwillende

e-docs-#3840038-cmd 11-h12.33 written submission from the ccnb action saint john fundy chapter

Documents