Thomas Adams and Norman Rubin

January 14, 2002

  Energy Probe’s Supplementary Comments on Atomic Energy of Canada Limited’s (AECL’s) Cernavoda Reactor 2
Environmental Assessment Summary

Introduction:

Energy Probe has formally endorsed the elaborate and carefully documented Comments by Non-Government Organizations (PDF file) on Atomic Energy of Canada Limited’s (AECL) Cernavoda Reactor 2 Environmental Assessment Summary (henceforth “NGO Comments”), largely prepared by David Martin and the recently tragically deceased Irene Kock, both of Sierra Club of Canada’s Nuclear Project. In addition, we hereby submit the following supplementary comments on this Environmental Assessment (the EA).

The context of this Environmental Assessment, including “other impacts”:

This EA review is being conducted under a process with outrageous shortcomings – detailed in the NGO Comments and in the comments from our sister organization Probe International. Briefly, these include incomplete disclosure, rushed time lines, and total lack of accountability. Perhaps even more outrageous is the fact that this EA review is apparently the only opportunity for the citizens and taxpayers of Canada and Romania to participate in the decision of their two governments to proceed with this project at taxpayers’ expense and risk.

Obviously, any assessment of whether or not this publicly funded project is worthy to proceed must properly include an Environmental Assessment, but it must also properly include an assessment of the project’s other impacts – both its expected impacts (costs and benefits) and its possible impacts, or “risks.” These other impacts are primarily the commercial costs, benefits, and risks that ordinary, private buyers and sellers routinely consider and weigh in deciding whether or not to proceed in a business transaction. In the case of government-agency transactions like the export of AECL’s CANDU reactors to a foreign country like Romania, the citizens of both countries are entitled to a full assessment of these costs and benefits and risks, not just the predicted impact on the local water temperature, etc. As flawed as this EA process is as an assessment of environmental costs, benefits, and risks (and it is deeply flawed), it is positively worthless as an assessment of the other impacts of this project. The lack of an open assessment of these other impacts – either in Canada or in Romania – renders this EA review an absurdity, especially given the current unwillingness of private buyers and sellers anywhere in the world to begin construction of nuclear generating stations, CANDU or otherwise. That unwillingness suggests prima facie that the non-environmental impacts of this project are likely strongly negative, when fully integrated.

Put bluntly, the level of environmental impact that might be acceptable in return for a least-cost supply of reliable electricity produced at the risk of willing investors, is one thing; the level that might be acceptable in return for a publicly subsidized, unreliable source of electricity (like Pickering-A, Bruce-A, or Point Lepreau, for example) at the continued risk of taxpayers as unwilling investors, is clearly another.

It is important to note that the commercial risks and net costs of CANDU reactors used to be theoretical, but are now painfully real: The two Canadian utilities with significant nuclear investments relative to their size – the former Ontario Hydro and New Brunswick Power – were essentially bankrupted (brought to a state where their liabilities exceeded their assets) by their CANDU reactor investments, despite receiving extensive subsidization and monopoly privileges from their governments. By not expressly addressing the significant likelihood that Cernavoda-2 will also be a drain on public finances and an unreliable source of electricity, this EA does not judge the project’s environmental impacts against the proper standards. And it certainly provides no rational basis for concluding that this project is worthy to proceed.

The EA’s inadequate assessment of the need for Cernavoda-2:

The needs assessment for the reactor in the EA documents is a reflection of classical central planning. There appears to be no consideration of competition as an alternative means of meeting the electricity needs of Romanians. There appears to be no consideration of whether the reactor investment could stand on its own as a private venture – not surprising given the obvious answer to this question. The EA repeatedly assures the reader that the electricity the reactor will produce will be inexpensive – without any supporting figures, assumptions or calculations. Unfortunately, Canadians have no recourse against AECL for similar assurances, now demonstrably false, concerning past reactor projects, and Romanians are presumably no better protected in this project. Such unaccountable assurances from a usually unreliable source have no credibility, in our view. It is ironic that Canadian jurisdictions are generally escaping the very form of central-planning decision-making that AECL – a Canadian corporation – adopts without question in this EA. (Or it may not be ironic, considering how often we have heard Canadian nuclear officials expressing envy of their Soviet counterparts.)

Past Environmental Assessments of Canadian nuclear projects:

The EA report claims that: “The CANDU 6 technology has undergone environmental assessments, both in Canada and internationally, starting with the Canadian panel review of Point Lepreau Unit 1, in New Brunswick in 1977, and including the Chinese environmental assessment of the Qinshan Phase III Project. Each of these projects was approved to proceed.” But the environmental assessment of the Qinshan Phase III Project was secret and not independently adjudicated. The complete Cernavoda-2 EA documents are secret and the EA will not be subject to independent adjudication.

It is understandable but unfortunate that the EA document does not recount the most striking fact about environmental assessment reviews of CANDU reactors in Canada: All recent public environmental assessment panel reviews of planned nuclear expansions in Canada – most notably the federal assessment of the non-existent Point Lepreau Unit 2 and the provincial (Ontario) environmental assessment of the then Ontario Hydro’s so-called “Demand/Supply Plan,” which envisaged the construction of 10 (non-existent) CANDU reactors – contributed to the sensible and beneficial decisions not to construct those reactors. It is also worth noting that the most recent environmental assessment panel review of a nuclear proposal from the author of this EA – AECL – was the federal panel review of AECL’s concept for deep geological disposal of radioactive waste (“spent fuel”). That review was charged with deciding whether or not AECL’s concept was “safe” and “acceptable,” and whether or not it should receive approval to proceed to the next step – selection of an underground disposal site. After nine years of deliberation, that independent panel:

• unanimously concluded that AECL’s concept was not acceptable;

• could not reach agreement on whether or not AECL’s concept was safe; and

• unanimously recommended that approval not be given to AECL to proceed to site selection.

In short, the record of the CANDU reactor and AECL before public, independent EA panel reviews is at best mixed, and the recent record is one of consistent rejection, either during the review or afterwards. This fact sets the context for (a) the inadequacies of this EA and (b) the Canadian government’s decision to leave the Cernavoda-2 decisions in the hands of AECL and EDC, rather than submitting them to an independent panel review.

Cernavoda-2 design flaws:

The Cernavoda-2 design repeats many of the flaws of CANDU designs used in Canada. For example:

• Like all Canadian CANDUs, the station will have open loop service water systems, a design that increases environmental insults compared to closed loop systems. Radioactive waste getting into the service water will be collected and discharged into the environment via the Active Liquid Waste Treatment (ALWT) System. Based on the Canadian experience, we assume that little or no treatment will be applied to the waste before discharge, relying on the obsolete belief that “the solution to pollution is dilution.”

• Similar to the Pickering Station, the cooling water intake comes from a shipping canal, making the station particularly vulnerable to marine security threats – perhaps an understandable oversight, since security threats don’t even exist in the EA (see below)!

• The Emergency Water Supply System is shared between C1 and C2, a safety shortcut that is not permitted by US nuclear regulators. This oversight is also understandable, since the possibility of two-unit accidents at Cernavoda 1 and 2 is dismissed with the wave of a hand in the EA (see below).

The EA’s treatment of decommissioning:

The EA’s claims regarding decommissioning are especially false and misleading: “Canadian experience indicates that decommissioning nuclear facilities can be carried out without significant adverse health and environmental effects. The ICRP 60 occupational dose limit (Section 2.2.4) was not exceeded by any of the 130 workers decommissioning the Gentilly 1 NPP over a two-year period, and the average dose was 0.35 mSv·a¹.” Nowhere in the documents does AECL admit that G1 was a failed prototype reactor that operated for no more than a few hundred full-power hours and therefore contained only a tiny fraction of the radioactive contamination that would be experienced if C2 operates for any significant period of time, nor the fact that the decommissioning is not yet complete, and has not included dismantlement – the activity that most people think of as “decommissioning” (as indicated in the NGO Comments).

The EA’s (non-)treatment of sabotage, terrorism, human malice:

The EA completely ignores the threat of malicious action. There is no indication that even the minimal security enhancement required in Canada after the events of 2001/9/11 are being considered for C2 (or C1). The main summary document contains not a single reference to any grammatical forms of the words “sabotage,” “terror,” or “malice”(!).

Among the many passages displaying accidental or intentional ignorance of the possibility of malicious action are the following:

“For the Cernavoda NPP Site, these potential events included meteorological events, hydrological events (including flooding due to water level variations), earthquakes and human-induced events (such as land, sea and air traffic accidents).” [Most “normal people” understand all too well that “human-induced events” include more than just accidents! Why doesn’t AECL?]

. . .

The definition of abnormal events: “within the context of the environmental assessment, “abnormal events” refer to process system failures, component failures or operational occurrences that result in a release of radioactive or non-radioactive substances. However, abnormal events exclude:

• events in which one of the safety systems is required to limit the consequences of releases from radioactive substances.

• events that result in fuel failure, and

• events where the normal operations regulatory limits are exceeded.

[At least they were good enough to tell us they were leaving out the important categories.]

. . .

Accidents are defined as: “a failure of a process system or component or a procedure which, in absence of a protective or mitigative action either automatic or operator-initiated, could lead to a significant release of radioactive material within and/or outside of the plant.” [But they are assuming that the “protective or mitigative action” always occurs. We wish the real world worked that way.]

. . .

Cumulative or simultaneous abnormal events would be unlikely because the two units [Cernavoda 1 and 2] operate independently . . . There could, however, be exceptional circumstances where accidents could occur at both units with higher than normal releases, doses and effects. Such occurrences, however, would be highly unlikely given the extensive operational experience from western-designed NPPs. [We all used to make similar statements about simultaneous accidents in high-rise office towers, but they sound foolish since 2001/9/11. Given the large but unknown contribution of seismic events to total CANDU accident risk, this didn’t really sound very smart before 2001/9/11, either.]

Conclusion:

Both before and after reviewing this EA summary, Energy Probe does not believe that the costs and risks of this project are acceptable to Canadians, Romanians, or the environment.