Summary of CCNB Action Saint John Fundy Chapter Intervention Part 2 The CCNB Action SJ Fundy Chapter’s Intervention contains 2 parts. One is a scan of most of the aspects of the license to operate using NB Power’s own form with special focus on seismic and safety issues. The other is a report called “The Potential Impacts of Climate Change and Seismicity in Relation to the Point Lepreau Nuclear Generating Station”. This is the report summary. The whole report with all references available upon request is online on the CNSC’s website. Seismic studies, nuclear power and climate change have a lot in common when examining the Pt. Lepreau generating station. They share many known uncertainties and are somewhat better understood now than 30-40 years ago. During the refurbishment however, the uncertainties, new knowledge and better understood information was known but not properly interpreted, legislated, funded or implemented. We consulted 2 of the professionals that NB Power has engaged over the years to research and justify their seismicity confidence and design and asked them for their expert opinions on seismicity in the Lepreau area and in relation to the plant including a request to update seismic data. We also contacted a professor of nuclear physics from Montreal and asked him how seismicity might affect different systems in a nuclear plant and what are the dangers? Finally, we asked a climate change expert for a “best practices” document regarding climate change adaptation and precautionary best practices. After analyzing our expert’s reports and email conversations, the CCNB SJ Fundy chapter is of the opinion that the uncertainties, concerns and risks that exist surrounding the safety of Pt Lepreau Nuclear generating plant far outweigh the adaptation, precaution and regulation that have been taken to mitigate the hazards from happening. This paper shines a light on the red flags, new knowledge and in the case of climate change, recommendations that came up in our expert’s submissions. All the experts share concerns about best practice, newer knowledge that has not been used in studies and a concern for the lack of oversite or responsibility taken regarding Pt Lepreau and their field. We are of the opinion that when the experts that do the research that is used to protect the health and safety of the citizens and the environment are concerned and raise red flags, society should listen. One of the NB Power experts even made the case that the accident in Fukushima was forewarned and the experts did nothing to mitigate the disaster. He believes something similar may be happening here. It is time to act responsibly and decommission Lepreau before it’s too late. Section 1-Ken Burke-New Seismic data and uncertainty New Information: The data base for earthquakes within 200 km of Pt Lepreau for 2002-Oct 8, 2011 has been updated. In his report, he points to: 2008 research that identifies a previously unmapped thrust fault with a NNWSSE strike and a dip of about 45 degrees W as being the causative feature; previously unlisted seismic events; location changes of seismic events; acknowledgement of a 2006 study which describes the results of a high sensitivity marine magnetic survey where a magnetic anomaly crosses the fault in the Passamaquoddy Bay; a link to the Ocean Mapping Group at UNB which is investigating the Passamaquoddy Bay pockmarks; a reference to a 2006 marine magnetic survey which suggests a 220m post-upper Jurassic offset of the Oak Bay fault and similar offsets of NW trending faults in Passamaquoddy Bay. Red Flags: The concerns, uncertainties and issues that come to light in the correspondence and report from Professor Burke are as follows: -He points out that not all potentially active earthquake source locations in New England may have been found -He explains that Neotectonic investigations have continued in Passamaquoddy Bay, but much of the work is still in progress or incomplete. -He notes that seismicity in the Passamaquoddy Bay region may be explained by movements along NW trending faults. -He notes that the origin of the Passamaquoddy Bay pockmarks continues to be a subject of investigation -He wrote that to his knowledge, there has been little work done on neotectonics in southern New Brunswick - He wrote that “From my experience, research is never finished and there are always new scientific ideas to test and validate. I think NB Power have to demonstrate they are at least up to date in what is known.” - He wrote that he thought an up to date seismic hazard assessment would be required for Pt Lepreau - He wrote that “It is surely the responsibility of NB Power to prepare a full environment assessment report and I assume this has already been done by a consulting company, similar to Jacques Whitford.” - He explained that he is “ a seismologist, and not an earthquake engineer. I do the front end of the seismic hazard studies; in other words study the previous earthquake history in regions of interest and try to determine their cause.” (Editors note: this is an important distinction. An earthquake engineer would need to use Burke’s data, rather than simply taking it as a stand alone piece of science that they base their earthquake ready confidence in. ) - He suggested that “NB Power should have retained the services of consulting engineers to make a site specific hazard assessment. I do not have the resources to do this kind of assessment, so can only promise to review the report when it is released.” Section 2-More questions and unknowns- Alan Ruffman New information Professor Ruffman refers to new documents in AR 5 now available by Ken Burke that he believes contain seismicity work that would lead to a larger possible ‘design’ earthquake. He refers to new building code standards in the Passamaquoddy Bay in AR 12. Red Flags The concerns, uncertainties and issues that come to light in the correspondence and docs from Professor Ruffman include: - He was unable to access documents cited in the Lepreau Env Assessment Report to ascertain exactly the data used to set the maximum magnitude earthquake for which the original Lepreau plant was designed. -He was concerned about whether or not the plant was designed to the correct level of earthquake -He has concerns about the CNSC re-licensing process -He was concerned about the use of old data -He was concerned the plant was under-designed seismicity -He stresses the importance of action on new knowledge by including a document that warned of a Tsunami in Japan in 2001. -He suggests that there would have been a more stringent engineering requirement put on the plant design to withstand a somewhat higher seismic hazard. Section 3-New Seismic considerations in Conjunction with other Nuclear Power Plant Hazards-Michel Duguay The report contains sections that pertain but are not limited to Positive void coefficient, pipe ruptures, lessons that should be learned from Fukushima, seismic concerns. New information New information that is brought forward regarding the lessons we should have learned from Fukushima and the aging problems of the high-pressure tubes. Red Flags -He writes that the History and significance of earthquake hazards are a concern. -He points out that the probabilities over a 50-year interval of a serious seismic incident is the same probability of getting two sixes upon the single throw of two dice. -He is concerned about pressure tube aging and large-break loss-of-coolant accidents -He has concerns that large-break loss-of-coolant accidents and the possibility of an earthquake are not analysed together -He points out that with a build-up of uranium oxide fuel damage is possible -He is concerned that aging equipment and structures can lead to accumulated fuel damage Section 4- Climate Change Considerations Raphael Shay New and better understood information In his report, Mr Shay points to several pieces of new knowledge in the climate change field that could affect Pt Lepreau. He presents the fact that we now have data pointing out that the average temperature is rising, climate change is occurring more quickly and with more drastic effects than previously expected, and that warming temperature brings with it increased precipitation, more severe storms and rising sea levels to New Brunswick. Significantly, he points out that “that risks of infrastructure failure will increase worldwide as weather patterns shift and extreme weather conditions become more variable and regionally more intense.” Finally he notes that the worst case scenario of 100cm sea-level rise by 2100 is now likely and worst case scenarios range up to 160cm. Mr Shay explains the much better understood science relating to sea level rise in the Maritimes. We now believe a slower and permanent rise in sea-level is to be expected. Red Flags - Mr Shay is concerned that the claim by certain media and policy-makers that climate science is highly uncertain is not true - He is concerned about the higher emission scenarios that bring with them more significant impacts. - He believes New Brunswick’s infrastructure will be put to the test and that we must be prepared to deal with an increasing amount of severe storms, including hurricanes. - He is concerned that NB’s economy will hinder its ability to adapt and mitigate climate impacts. - Mr Shay noted that the National Roundtable did not consider the risks of a climate induced incident at Pt Lepreau -Mr Shay is concerned that the consequences of a failure at P Lepreau may be too great -He points out that Canada has yet to take appropriate action to adapt to climate change. -Mr Shay noted that climate change is starting to overwhelm our engineered expectations Recommendations -NB must be prepared to deal with an increasing amount of severe storms, including hurricanes - NB should Implement “no regret” adaptation actions on our critical infrastructure as suggested by the International Panel on Climate Change -Engineers should regularly update design values at Pt Lepreau to mitigate climate impacts - Continuous analysis of failures is paramount -NB Power should introduce in codes and standards a “Climate Change Adaptation Factor” to existing design values that reflect the latest understanding of near future changes. - We should all learn from the recent catastrophic events at Fukushima, Japan -design standards need to recognize the fact that the forces of nature lie beyond our engineered expectations
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