This submission provides comments on Bruce Power’s relicensing application to continue operating the eight nuclear units at Bruce A and B for a 5-year period. These facilities are located at the Bruce Power Nuclear Generating Station (BNGS) in Tiverton Ontario, on the shores of Lake Huron.
The focus of this submission is health and safety and the well-being of the local community located in the vicinity of the BNGS, including that of the workforce (nuclear energy workers and contract workers). We are particularly concerned that there is not at present any scientifically valid means of determining what the long-term effects, if any, on public health in general are. Thus, we are proposing a design for a community health study that we hope will assist us as we acquire the baseline database that will allow us to examine potential health effects in the community that may have resulted from the long-term operations at the Bruce Power Nuclear Generating Station. We have identified a variety of distinct communities in this study, including workers at the facility, both contract and nuclear energy workers, each of which presents a separate challenge for the industry if it wants to make the simple claim: Bruce Power’s operations are safe and have not caused ill-effects in the communities within which it operates.
Areas of Concern
A major component of our submission is related to safety and the degree to which “safety culture” is actually practiced by Bruce Power and the CNSC. Thus, our submission includes a review of accidents that have occurred at Bruce Power and were reported to the CNSC. In particular, we analyse two cases which led to serious exposures of workers to radiation. We will review critically the responses by Bruce Power and the CNSC relating to the causes of these accidents, their impact on the affected workers, and what measures should have, or could have, been taken into account that may have prevented them.
We will also examine waterborne and airborne emissions as reported by Bruce Power over time. In addition, we will address numerous other pertinent issues, including operational matters, such as the lifetime of pressure tubes, issues related to fuel defects and issues related to extending the life of an aging fleet of nuclear reactors.
Many of these units have operated for approximately 30 years, even with the number of lengthy shutdowns that have occurred. Yet the CNSC and Bruce Power have argued that six of these 8 units (Units 3-8) be allowed to operate beyond the end-of-life of the pressure tubes for which they were originally designed.
We would argue that these units are past their prime and question future plans to refurbish them, especially in light of the many issues that have developed during the past refurbishment of Units 1 and 2 of Bruce A. These have been very costly (well over estimated budget), run into several delays and have been highly dangerous to a community of workers and perhaps to the public-at-large, and come with no guarantee that the life of a reactor could be extended safely by twenty-five to thirty years.
Our findings indicate that there appears to be, and to have been for an extended period of time, a degraded safety culture, both at Bruce Power and at the CNSC.
As a result, we recommend that Bruce Power’s license to operate these reactors be withdrawn and not renewed until such time as Bruce Power demonstrates conclusively that it is concerned about the impacts on public health from its operations and is prepared to take all the steps necessary to mitigate any such harm as may be discovered.
How the industry has impacted Inverhuron residents
As this Commission well knows, there have been numerous incidents, beginning in 1985, that have impacted seriously on our personal health, beginning with the operations of the Bruce Heavy Water Plant and the Fire Training Facility. In addition to these episodes of high concentrations of toxic chemical fumigation, radiological releases from Bruce operations have been persistent and pernicious. Since field testing began, there has never been an instance when unwanted radiological chemicals were not found in abundance in our vegetables, soil and agricultural products, as well as in our urine and that of our flock animals whenever tested.
Both Bruce Power and CNSC staff insist on using models that are known to fail to estimate airborne emissions and their concentration correctly. At no point has Bruce Power or CNSC been willing to test the assumptions used in these models to predict events. A clear and simple instance of this presented itself at the DGR Hearings held in 2013 and 2014 when tritium concentrations in our green leafy vegetables were reported to be more than 50 times higher than any other sample measured, including at a location nearest to the source. At these Hearings, I asked both OPG and CNSC staff whether either would be willing to back-test their model assumptions to determine whether the models each uses for airborne emissions would predict this seriously anomalous situation. Each declined to do so. A strong safety culture would, of course, seek to leave no stone unturned in attempting to account for known data and the root causes of these data. CNSC staff, however, cannot be bothered even to back-test its assumptions, leaving the public exposed to unknown concentrations of dangerous chemicals.
In 2002, our farm was fumigated by Bruce Power during its fire training activity with the result that everyone present was sickened by the event. Over the course of the next 9 months, my staff and I met regularly with Bruce Power personnel to develop a protocol that would allow it to conduct and engage in activities that are necessary to operate the nuclear power station safely and to protect innocent members of the public from high concentrations of toxic chemicals. We did develop just such a protocol and it worked effectively until May, 2008 when Bruce Power unilaterally abrogated this agreement without notice or warning. Predictably, our property was fumigated again, making my wife very ill. When we asked how this had happened, Bruce Power’s staff said he had no explanation because he believed we had an agreement not to operate the fire training facility under these meteorological conditions. Not to be deterred, Bruce Power once again in June conducted a major burn under adverse meteorological conditions, and once again affected my wife’s health severely.
At this time, unknown to us, Ann was developing ovarian cancer. With her weakened state caused by these exposures, the cancer was allowed to grow unchecked until it was removed by surgery the following year. Bruce Power’s response to our concerns about being fumigated was to send an email letter to Siskinds, the law firm that was assisting us in our intervention for the DGR Hearings. It threatened to sue us if we were to talk publicly about having been fumigated by it. CNSC staff supported Bruce Power in this action with the result that, when a meeting was finally convened at the direction of Commissioner Barnes, Ken LaFreniere of CNSC opened it by stating unequivocally that, as far as CNSC is concerned, this matter is closed.
In 2008 my wife participated in a study of eastern European Jewish women who are considered to be more likely to carry the BRCA 1 or 2 gene mutation that could lead to ovarian cancer. It was found that she did not carry this gene mutation and nor does anyone else in her family. Nonetheless, she did develop ovarian cancer. 4 years later she developed breast cancer. Women who get both breast and ovarian cancer are likely, at the 95% confidence level, to have some genetic mutation that will have allowed these cancers to develop in them and the genetics lab at Victoria Hospital did conduct a full DNA sequencing analysis to discover these mutations. She had none and nor is there any history in her family of either of these cancers, except in very old age (late 80s to early 90s).
Our air and food are consistently poisoned with radioactivity and other hazardous substances from Bruce Power’s operations. CNSC staff, even as it is unwilling to review the airborne models it uses to estimate the concentrations here, claims that the concentrations to which we are exposed are safe. It does so without citing any supporting evidence. While this same staff acknowledges that there are no known safe levels of exposure to radionuclides, it nonetheless, in the face of direct health evidence to the contrary, states that these concentrations are safe. Both it and the Bruce-Grey Medical Officer of Health have stated publicly that it is impossible, given the current lack of baseline data, to conduct an appropriate epidemiological study to determine the nature of the impacts on human health of Bruce operations.
Bruce Power’s application for relicensing seeks approval for any number of uncertain conditions, most of which will be unforeseeable because the conditions under which these reactors will operate have never before been observed. Both it and CNSC staff have had years to conduct the appropriate surveys and to collect the necessary baseline data to demonstrate that these operations are safe. Nonetheless, neither has seen fit to do so.
Without this baseline data, it is impossible and improbable to make a claim that these facilities have operated safely and will in the future operate safely. Since, as we demonstrate in this analysis of known safety failures on the part of both Bruce Power and CNSC staff since the last relicensing hearing, neither is prepared to acknowledge unsafe and harmful conditions until after innocent individuals have been unnecessarily exposed. Even then, neither has seen fit to follow the medical history of these exposed workers over the course of time it would take for disease to develop. This degraded safety culture does not warrant our good faith and, until a robust and detailed plan to collect this baseline data for our various communities has been put in place, Bruce Power should have its license to operate the Bruce nuclear site revoked.