Darlington New Nuclear Plant Project

Darl. Hearings: Dr. Baker (PGS) ~ Final Submission

NOTE to anyone who got here by querying "health effects in Elliot Lake" or similar queries: you may want to consider also having a look at the posting 'Uranium: Got 46 minutes?' ***************************

** Dr. Baker's submission printed here w. her permission, of course! Her first submission is here Lots of Darlington-related postings listed here

Once again I would like to thank you for the opportunity of having presented my submission to the panel.

You have heard from a number of physician, scientists and other citizens who are deeply concerned about the risks of expanding nuclear power. As presented in my submission, numerous scientists and physicians, including myself, have extensively reviewed the scientific literature and have come to the unwavering conclusion: there is no safe level of radiation exposure. The vast literature that I have personally reviewed includes the report theHealth Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2.”

The National Research Council panel found a linear dose curve, meaning that the higher the dose, the greater the likelihood of developing cancer. However they also recognized that “a single radiation track (resulting in the lowest exposure possible) traversing the nucleus of an appropriate target cell has a low but finite probability of damaging the cell’s DNA.”

Cumulative exposure increases the risk. There is no safe level of radiation exposure. The interpretation of the BEIR report given by Patsy Thompson, a toxicologist working for CNSC, was biased and misleading at best and not supported by a large number of the scientific community.

The evidence of increased risk to children living near a nuclear reactor of developing leukemia is also overwhelming and irrefutable. An analysis of the data presented by Rachel Lane, an epidemiologist for CNSC, and Patsy Thompson on March 31, which denies this connection, is both circular and flawed. Not expecting an outcome does not negate an outcome. Furthermore, finding other clusters of children with leukemia is completely irrelevant. In a world riddled with carcinogenic toxins, this too is expected and should be addressed. This does not negate the evidence that children living near a nuclear reactor are at higher risk of developing leukemia.

Ms. Lane also referred to studies done in Canada and stated “there is no substantive evidence that there are any adverse health effects related to environmental radiation exposures from these facilities.” In fact the studies are minimal, and lack medical collaboration, but do suggest possible health risks which require further study and improved design. There is no substantial evidence that environmental radiation exposures from these facilities are safe.

Additionally we are still discovering the devastating consequences of the Chernobyl disaster to human health and life. This nuclear disaster resulted in contamination of a large area of land, numerous deaths and many suffering from illnesses including thyroid cancer, leukemia, brain tumours, congenital defects and mental deficiencies. The data that Ms. Lane presented to the panel on March 31 on Chernobyl is not consistent with a recent report published by the New York Academy of Sciences. Russian and Ukraine physicians state that there have been almost one million people who have died as a result of the Chernobyl disaster. Ms. Lane claimed the “official” death count as 4000. Where the numbers are so far apart, there is good reason to doubt the accuracy of what we are being told.

The health dangers of radiation are clear. All the processes in the mining, milling, refining, and enriching uranium - and running the nuclear reactor - increase exposure to radiation, even when using Canadian standard precautions. Nuclear tailings and waste are also a particular risk to the environment. Nuclear technology increases individual exposure and the global burden of radiation. This will increase the incidence of cancer and other diseases linked to radiation exposure. Risks include cancer, genetic damage, birth defects, immune system dysfunction, diabetes and heart disease.

According to the Ontario Diabetes Database, there is a higher incidence of diabetes in the Central East Local Health Integrated Network, LHIN 9, than in Ontario in general. The incidence was particularly high in the region near Pickering. Diabetes is becoming a global pandemic and there is much blossoming evidence that radiation exposure, including from nuclear reactors, is contributing to this. While there is not substantial evidence to conclude that the nuclear reactors at Pickering and Darlington are responsible for this local increase, there is sufficient evidence to conclude that there might be a risk. It is consistent with evidence that the local population is exposed to increased levels of radiation and that that radiation is causing negative health effects. Based on the “Precautionary Principle,” this, alone, is substantial evidence to call for a moratorium on nuclear expansion.

The Precautionary Principle states that if there is a possibility of harm to a population or the environment from an action, we should not proceed with that action.

In my own practice as a Palliative Care Physician, I have seen a number of patients with cancer, particularly breast and lung cancer, who were living either in the area of the Bruce Nuclear reactor or in the Pickering/Darlington/Port Hope region at the time of their diagnosis. Just as smokers often quit smoking after they are diagnosed with lung cancer, many of these people left the area that they felt contributed to the etiology of their cancer. I have also had patients who spent many years in Elliot Lake and later developed lung cancer, colon cancer, pancreatic carcinoma or lymphoma. I know firsthand that there are no studies identifying, tracking, reporting or investigating any of these people.

There is cost to human health and to the taxpayer. The reactors at Darlington were almost $10 billion over the original budget. We spend well over $100 million a year in just protecting nuclear reactors in Ontario. We are squandering tax dollars on private armies. Investment in safe forms of sustainable technology pale in comparison. If health concerns were not enough to make using nuclear energy to boil water unacceptable, financial concerns should surely bring the industry to a halt. Every dollar wasted on expanding and protecting nuclear technology is a dollar diverted from the development of renewable, sustainable green energy.

We cannot continue to live in denial of the possibility of a significant accident happening in Canada. We have had numerous accidents.

There was a significant meltdown of a reactor in Rolphton, Ontario, Chalk River, in December, 1952. At that time the core was damaged. There was also an accident at Chalk River on May 24, 1958 in which fuel was damaged.

A severe nuclear event occurred in Pinawa, Manitoba in November, 1978. The reactor which was cooled by a type of oil, terphenyl isomer, experienced a major coolant leak as one of the pipes developed a hole and 2,739 litres of oil escaped.

It took several weeks for workers to find and repair the leak. Much of the leaked oil was then discharged into the Winnipeg River. According to Dr. Agnes Bishop of the Atomic Energy Control Board, (later the CNSC), the fuel reached high temperatures.

Although the temperature did not hit the meltdown level, it did result in three fuel elements being broken, with some fission products being released. The accident, which many consider significant especially to the health and safety of the people of Manitoba, was not reported for several years.

An attempt was made in 2000 to have the full report from this accident made public, but Atomic Energy of Canada refused, and labelled it “Protected.”

We may never know what radioactive carcinogens were vented or released into the air and water. There has been no systematic medical response to investigate or follow potentially affected workers or the local population.

On 9th August 1989, at the Pickering reactor an accident resulted in a mechanic being exposed to six times the yearly industry accepted radiation limit. Another worker who was standing nearby was also exposed. The workers were replacing a radioactive control rod, which is moved in or out of a reactor to control the nuclear process, when a radiation detection device one of the men was holding went off scale. It was later discovered that the equipment being used by the men was designed for training and did not contain lead, which provides workers with some shielding from radiation.

In early October of the same year, 1989, human error resulted in operations workers mistakenly putting Tritium-contaminated heavy water into the heat transport system of the Unit 2 reactor at the Darlington nuclear station.

Of interest, a significant accident was reported at Fukushima, Japan that same year.

Additionally, as many as 217 workers were exposed to radioactivity at the Bruce nuclear power station while refurbishing a reactor in November 2009. Again, no details have been released and there has been no systematic medical response to investigate or follow these workers.

Accidents and leaks continue. On March 16 of this year 73,000 litres of demineralised water were released into Lake Ontario when a pump seal failed at the Pickering Nuclear Power Plant. While this accident is considered by the industry to be small, it is a significant health risk and demonstrates once again that the Canadian system is not perfect.

Frequent leaks of contaminated water have also been a significant health risk at uranium mines and tailing sites. One example occurred in November 1989, when there was a 2-million litre spill of radioactive water at Rabbit Lake, Saskatchewan, due to a faulty pipe burst. The spill remained undetected for 14 hours even though there were Atomic Energy Control Board inspectors on site.

Moreover the current tragedy in Fukushima, Japan is of great importance. Already people have died; food, water and air have been contaminated. Every day we are hearing more about the impact of the local crisis and international consequences. We still have more to ascertain. This disaster has permanently increased the global burden of radiation and must not be repeated. Ontario has recently been found to have increased levels of radiation. The origin and significance of this must be evaluated. If governments and industry refuse to learn from history, it will repeat itself.

While it appears that the risk of terrorism is small, based on the amount we spend defending nuclear reactors, it is not negligible. The very technology which prevents the need for opening fuel cells has also been equated with an increased risk of theft, diversion and terrorism. Fuel can be removed from CANDU reactors at any time without shutting down the reactor, and the fuel elements are substantially smaller and more portable than is the case for LWRs (Light Water Reactors). In a LWR, the entire reactor core is a single large pressure vessel containing the light water, which acts as moderator and coolant, and the fuel arranged in a series of long bundles running the length of the core. In CANDU the pressure and the fuel bundle are contained in much smaller and lighter, easier to fabricate tubes. The CANDU technology has its own significant risks.

An accident or terrorist event in the Toronto vicinity would be devastating. A Public Health response is not ready for such a catastrophic occurrence. In medicine we do not perform a procedure unless we are prepared for the worst possible outcome of that procedure. We are not prepared for a nuclear accident.

In order to promote unbiased scientific method and uphold the principle of democracy, we desperately need studies in Canada on the health risks of nuclear power that are not in the control of the nuclear industry. We need to respect and value differing scientific opinion, not just those of nuclear physicists and industry representatives.

The nuclear industry has provided the Review panel with interpretations of data from their perspective. The scientific and medical communities are not in consensus with their biased and narrow-focused opinions. While CNSC and OPG officials have attempted to minimize the risks, they have not proven safety. The “Precautionary Principle” must be implemented. We need to invest in safe, sustainable, renewable energy now. The hunger for power does not justify leaving a toxic, radioactive inheritance for generations to come.

Nuclear technology must be phased out, not expanded.

Respectfully submitted,

Sharon Baker, MD, MCFP

Physicians for Global Survival


Darl. Hearings: Dr. Baker-Physicians for Global Survival (April 4th)

Good to hear a medical perspective! April 4th transcript here Audio here

Physicians for Global Survival

Darlington New Nuclear Power Plant Project Joint Review Panel

Good morning Mr Chairman, panel members, ladies and gentleman. My name is Dr. Sharon Baker. I have with me two young people and a community member who are also deeply concerned about the future of our planet: Justin and Shawn Hertwig and Don Baker.

Thank you for the opportunity to speak to you today. I am here as a member of Physicians for Global Survival. I have been a physician in Ontario for 26 years. I currently work as a Palliative Care Physician Consultant and Site Chief at University Hospital – London Health Sciences Centre. This includes a position as an assistant professor in the Schulich School of Medicine and Dentistry at the University of Western Ontario. I also served for 10 years as an acting Medical Officer of Health in Elgin County.

Physicians for Global Survival is an organization concerned about global health.

I am sure that many of the people in this room have been affected by cancer, whether directly or indirectly. As a Palliative Care Physician, I care for people every day who are actively dying from this devastating disease. Cancer is largely preventable, with education about healthy lifestyle choices and the elimination of toxic substances from our environment.

As a society, Canadians have raised billions of dollars to find a cure for cancer. We walk, run, relay, ride, and row. While these are noble acts, and I applaud these people, still there is no cure. Albert Einstein defined insanity as doing the same thing over and over again and expecting a different result. The insanity needs to end. Our approach to health care has been seriously flawed. We need to move from treating illness, and turn our focus to prevention. April is cancer awareness month. Cancer can be prevented.

Cancer in general is not caused by just one thing - it is multi-factorial. It is the result of the cumulative exposure to carcinogens over time, referred to as a body burden. Carcinogens often work synergistically with one another, to produce cancer. Therefore, the more carcinogens to which a person is exposed over time, the more likely cancer is to develop.

In order to decrease rates of cancer, exposure to known carcinogens must be decreased, period. This is a societal choice.

Radiation is a known carcinogen. This is not debatable. Madame Curie, in her research, taught about radiation, including its potential to be fatal. Exposure to radiation is accumulative. It builds up in biological organisms, including human bodies; the more exposure – the greater the likelihood of getting cancer¹. Humans are constantly exposed to low levels of radiation in the environment, some that can’t be controlled. Attention needs to be directed to what we can control.

Radiation toxicity is accumulative. There is no safe level of radiation exposure. As physicians, we recognize this. We weigh the risk and benefits when ordering X-rays, mammograms, CT scans and radioisotopes. We try to limit exposure to decrease the risk of cancer or genetic defect.

The assignment of “acceptable risk” is completely arbitrary. This approach has more in common with a game of chess, or rolling a dice, than actual science.

Increasing the global burden of radioactivity increases the incidence of cancer. Nuclear technology increases humanity's collective exposure to radiation. The increased risk is not limited to emissions from nuclear reactors themselves. It is also the culmination of all the risks of exposure from processing uranium, the mining, milling and the handling and the management of toxic wastes from all these processes.

Choosing to expand nuclear technology and thus the global burden of radioactivity is like determining that it is acceptable that some people are expendable. That person might be your neighbour, someone in this room or an impoverished aboriginal that you will never meet. Choosing nuclear power puts the sweep of the pen to someone’s or some people’s death sentence. I would not want to live with that responsibility.

The negative impact that uranium mining has upon the environment is gargantuan. The fossil fuel requirements for the mining, milling, refining, enriching and transport of uranium ore are enormous. However, I will only discuss the health risks of radioactivity here.

Uranium miners are exposed to multiple types of excess radiation. This includes a radioactive gas called Radon 220 which is a decay product of uranium. When this is inhaled, it increases the risk of lung cancer.

In the early 20th century, a number of people, primarily women, were employed to paint numbers on watch dials with radium-enriched paint so the numbers would glow in the dark. The women would lick the brushes so that the numbers would be precise. They believed what they were doing was safe. However, many developed painful bone cancers called osteosarcomas, or leukemia, from this radioactive material. This same Radium is also in mines and can be ingested via the dust with the same resulting cancers these watch-makers faced.

The mining of uranium ore results in a destabilized radioactive environment. When mines are abandoned, the water that has been pumped out often re-enters the mine, contaminating the ground water. Milling - extracting uranium from ore - results in further risk of exposure and production of radioactive waste products. These toxic waste products, or tailings, require safe isolation from the environment. In the post-World War II era, in Canada, this sludge was often deliberately dumped directly into our lakes, contaminating the groundwater. Accidental dumping also occurs, as in the 1984 spill of 100 million litres of contaminated liquid at Key Lake, Saskatchewan. Currently, industry is experimenting with ponds and hoping the experiments don’t fail. These tailing ponds will be radioactive, essentially forever. We cannot let our hunger for power be used to excuse leaving a toxic mess for our children to inherit.

The uranium mining industry has still not effectively addressed the issue of contamination that resulted from mines that have been abandoned. For example, contamination remains a problem in the rural community of Deline in the Dene Nation of the North West Territories, and El Dorado at Uranium City in Saskatchewan.

Developing more uranium mining when the unconscionable contamination of the past has not been addressed is a travesty to social justice.

An extensive amount of uranium mining and milling in Canada is done on Aboriginal land, usually without consultation. This a health issue, a human rights issue and a native rights issue.

The nuclear reactors themselves are not innocuous. They are a risk factor for increasing background radiation. Workers are exposed to low dose radiation. The arbitrary figure that has been chosen by many nuclear power facilities as acceptable for worker exposure in one year is equivalent to 400 chest X-rays.

The issue has been studied extensively in Europe. A 15-country collaborative study among workers in the nuclear industry demonstrated that this type of low-dose radiation exposure resulted in a risk of developing cancer that was equal to or greater than the risk of the survivors of the atomic bomb in Japan.

Furthermore, living near a nuclear reactor has been shown irrefutably to increase the risk for children of developing leukemia2. This has been studied extensively in Germany. The closer children live to a nuclear reactor, the more likely they are to develop leukemia before the age of five. There are other toxins in the environment which can cause Leukemia, such as pesticide exposure. Observing clusters of children who have suffered from other toxic exposures does not negate the dangerous effects of living near a nuclear reactor. In fact, the findings of an increase incidence of childhood leukemia are expected. Their parents are more likely to work in the reactor. The chronic radiation levels they are exposed to can affect their sensitive germocytes, resulting in genetic damage. In addition, water containing tritium is released by nuclear power plants into the environment both by planned events and accidentally. On March 16 of this year 73,000 litres of demineralised water was released into Lake Ontario when a pump seal failed at the Pickering Nuclear Power Plant. Tritium is dangerous. It binds with oxygen in water. For biological organisms, including humans, this radioactive water is indistinguishable from normal water, and it becomes incorporated in every cell of the body. Tritium has a half-life of 12 years, meaning it can do damage over a long period of time. Moreover, industry data shows spikes in the local measurements of radioactivity when reactors are opened for refuelling.

Nuclear power generating plants also produce radioactive waste that must be stored and guarded essentially forever. Again, the need and greed for power does not justify leaving a radioactive inheritance for generations to come.

While my focus today has been on cancer, we must not forget that accumulative exposure to radiation also causes other illnesses. It contributes to genetic damage, birth defects, immune system dysfunction, diabetes and heart disease.

This issue cannot be addressed effectively without mentioning the possibility for human error. Accidents happen! With all of the marvellous fail-safes and back-up plans, planes still crash, the Space Shuttle Challenger disintegrated, and patients die from human errors. While accidental leaks of radioactive water are relatively common, serious accidents also happen. There was a significant meltdown of a reactor in Rolphton, Ontario in December, 1952. We have also experienced very serious accidents at Three Mile Island in Pennsylvania in 1979, Chernobyl in 1986, and Tokaimura Japan in 1999. And now our hearts go out to the people of Japan. The accident in Fukushima that began on March 11 is devastating. It humbles us to realize that nature can be relentless and that man-made fail safes can and do fail. People have already died because of this nuclear disaster. Many more will become ill and die. The global burden of radioactivity has increased forever.

While I conclude that the serious risks to Public Health and human life from nuclear technology is indisputable, if doubt did exist we would still be ethically required to follow the “precautionary principle.” The precautionary principle states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action. You have seen that there are many scientists who conclude that nuclear power is unacceptably dangerous. We must implement the precautionary principle. Nuclear power must be phased out. This is the same approach that lead to banning cosmetic pesticides in Ontario and many other provinces.

Beyond error, particularly since 9/11, we have lived with the fear of a terrorist attack. This raises a seldom-mentioned point - the astronomical costs of security. It doesn't take a rocket scientist, or a nuclear physicist, to do the math.

Guarding nuclear reactors and nuclear waste costs society enormously more than protecting wind towers and solar farms.

The risk of a terrorist attack is low; nevertheless, over $100 million is spent annually in this province on special weapons and tactical forces to protect nuclear power plants and the valuable nuclear bomb-making materials contained within.

The nuclear power plant at Darlington is protected by the Nuclear Division of the Durham Regional Police Force. This plant, as Pickering was in January 2010, is to be transferred to the Ontario Power Generation Nuclear Security Branch.

The Bruce Nuclear Generating Station is protected by a privately owned and operated highly trained tactical force larger than the police force of many large Ontario cities.

These tactical team salaries, the extensively high level of training, and the expensive equipment, result in costs that are exorbitant.

The extreme cost of military presence cannot be justified when no other form of power generation requires even a fraction of this defence cost. While the probability of a terrorist attack on a nuclear reactor may be low today, the future is unknown. Public funds are better allocated to health care, education and employing people to fix and repair existing environmental problems. Every dollar wasted on expanding and protecting nuclear technology is a dollar diverted from the development of true green energy.

In conclusion, nuclear power is costly. It is costly to human health, the environment and the taxpayer. Nuclear power is a cancer on society. It increases the global burden of radioactivity and human exposure to radiation. Radiation causes cancer. Developing nuclear power will contribute to untimely deaths. Now is the time to turn our attention to prevention.

Nuclear power should be phased out, not expanded.

Thank you.

Respectfully submitted,

Sharon Baker MD, MCFP


This reference list is incomplete; a complete list can be submitted upon request.

1) BEIR VII (U.S. Academy of Science report on the Biological Effects of Ionizing Radiation) unequivocally states that “no low level of radiation exposure is safe.”

2)Kaatsch P., Kaletsch U., Meinert R., Michaelis J. An Extended Study on Childhood Malignancies in the Vicinity of German Nuclear Power Plants. Cancer Causes Control 1998; 9: 529-33

Hofmann W., Terschueren C., Richardson D. B., Childhood leukemia in the Vicinity of the Geesthacht Nuclear Establishments near Hamburg, Germany. Environmental Health Perspectives 2007; 115: 947-52

Spix C., Schmiedel S., Kaatsch P., Schulze-Rath R., Blettner M. Case-Control Study on Childhood Cancer in the Vicinity of Nuclear Power Plants in Germany 1980-2003. Eur. Journal of Cancer 2008; 44:275-284

Kaatsch P., Spix C., Schulze-Rath R., Schmiedel S., Blettner M. Leukemia in Young Children Living in the Vicinity of German Nuclear Power Plants. Int. J. Cancer 2008; 1220: 721-26

American Cancer Society. Radiation and Cancer. 2010. http://www.cancer.org/Cancer/


"Annual General Assembly Resolution No. 17/2008." Assembly of First Nations. 17 July 2008. Web. 21 Feb 2011. <>

Caldicott, Helen. Nuclear Power is Not the Answer. New York: The New Press, 2006. Print.

Diehl, Peter. Uranium Mining and Milling Wastes: An Introduction.

2010. http://www.wise-uranium.org/indexu.html.

Environmental Protection Agency. “Understanding Radiation: Health Effects.” 2009. www.epa.gov/radiation/understand/health_effects.html.

Goncharova, Roza. "New insight into cancer risks." Institute of Genetics and Cytology: Belarus, IPPNW World Congress. 2010. Web. http://www.ippnw2010.org/fileadmin/user_upload/


Harding, Jim. Canada's Deadly Secret: Saskatchewan Uranium and the Global Nuclear System. Winnipeg, ON: Fernwood Publishing Company, 2007. Print.

London Police. "2011 Budget." Web. police.london.ca/Headlines/Images/2011LPSBPublic.pdf.

McKay, Paul. Atomic Accomplice: How Canada deals in deadly deceit. 2009. Print.

National Research Council of the National Academies. "Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2. 2006."  www.nap.edu/openbook.php?record_id=11340.

"OPG’s Commitment to Security - Safe Station, Safe Community." Ontario Power Generation. Darlington Nuclear Neighbourhood Newsletter, Dec 2010. Web. <http://www.opg.com/community/activities/newsletters/DN%202010-12.pdf>

Tufts, Heather. 2010. “‘Canada, O Canada!’ Uranium Mining and Indigenous Communities: The Impacts of Uranium Mining on Indigenous Communities.” Native Unity Digest.

"Radiation Exposure Information and Reporting System (REIRS) for Radiation Workers." U.S. Nuclear Regulatory Commission. 12 Feb 2008. Web. <http://www.reirs.com>.

Zielinkski, et al. "Low dose ionizing radiation exposure and cardiovascular disease mortality." Low dose ionizing radiation exposure and cardiovascular disease mortality. Study based on Canadian national dose registry (NDR) of radiation workers. Ottawa, ON, 2010.

[27-33] Web. <http://www.ippnw2010.org/fileadmin/user_upload/Plenary_presentations /Plen4_behar_slides_CHRONIC%20LOW%20DOSE%20RADIATION.pdf>

** Dr. Baker's final Darlington submission can be found here

Darl. Hearings: Louis Bertrand (April 1st)

Been meaning to post 3 more presentations from the Darlington hearings. Here they are, finally - starting with this one, Louis Bertrand's on April 1st. Most of us don't understand the limitations of computer software - but Louis sure does!! Btw, you can find the April 1st transcript here (audio here )

Concerns with software based instrumentation & control systems


Mr. Chairman, members of the panel, good morning.

My name is Louis Bertrand. I am a professional engineer and I live in Bowmanville. My engineering experience is in electronic product design including embedded software as well as information technology and information security

M. le président et membres de la commission, je vous souhaite bonjour. Je m’appelle Louis Bertrand. Je suis ingénieur professionel et j’habite Bowmanville. Mon experience en génie comprend le design de produits électroniques, ainsi que l’informatique et la sécurité des données.

My presentation this morning will deal with my concerns regarding the safety and reliability of instrumentation and control systems based on embedded microcontrollers and the software running them.

Ma présentation ce matin traite de mon inquietude au sujet de la securité et de la fiabilité des systemes de saisie de données et de controle a base de logiciels pour microprocesseurs imbriqués. A cause des termes techniques, je dois continuer ma présentation en anglais mais si on me pose une question en francais, j’essayerai dans la mesure du possible d’y répondre pareillement.

The New Nuclear Darlington Environmental Impact Statement section 7 submitted by the proponent considers the mitigation and effects of accidents, malfunctions and malevolent acts. It is my observation that the language used to describe these potential events shows that the designers consider them highly unlikely. However, the increased complexity and failure characteristics of software based instrumentation and control systems (I&C) leads me to ask whether or not some new scenarios for accident initiating events have been overlooked or underestimated.

The EIS and additional responses provided by the proponent make reference to several software quality assurance standards such as CSA N290.14 (Qualification of Pre-Developed Software) and CSA N286.7-99 (Quality Assurance of Analytical, Scientific, and Design Computer Programs) as well as AECB draft regulatory guide C-138(E) (Software in Protection and Control Systems). However, the guidance in those documents is prescriptive and they cannot provide the level of detail and completeness currently required to develop safety critical software and firmware systems.

Coffee Mug (c. 1982)

Weinberg’s Law: If builders built buildings the way programmers wrote programs, then the first woodpecker that came along would destroy civilization.

It also concerns me that an article on forensic engineering, the discipline of failure analysis, in January/February 2011 edition of Engineering Dimensions, the magazine of Professional Engineers Ontario, does not mention software as a potential factor in failures (Mastromatteo).

Yet software failures occur on a regular basis and occasionally lead to serious injury or death, as the 1986 Therac-25 accidents demonstrated (Leveson, 2006).

An Investigation of the Therac-25 Accidents

Author(s): Nancy G. Leveson and Clark S. Turner (abstract by Philip D. Sarin)

The Therac-25, a computerized radiation therapy machine, massively overdosed patients at least six times between June 1985 and January 1987. Each overdose was several times the normal therapeutic dose and resulted in the patient's severe injury or even death. Overdoses, although they sometimes involved operator error, occurred primarily because of errors in the Therac-25's software and because the manufacturer did not follow proper software engineering practices.

Overconfidence in the ability of software to ensure the safety of the Therac-25 was an important factor which led to the accidents. The Therac-20, a predecessor of the Therac-25, employed independent protective circuits and mechanical interlocks to protect against overdose. The Therac-25 relied more heavily on software. Moreover, when the manufacturer started receiving accident reports, it, unable to reproduce the accidents, assumed hardware faults, implemented minor fixes, and then declared that the machine's safety had improved by several orders of magnitude.

The design of the software was itself unsafe.

Obviously, since that series of tragic accidents, the discipline of software verification and validation has made great strides. However, regulatory agencies are still required to maintain oversight of providers of safety critical software, as occurred in a recent case of radiation therapy equipment malfunction (Bogdanich).

April 8, 2010

F.D.A. Toughens Process for Radiation Equipment


The Food and Drug Administration said Thursday that it was taking steps to reduce overdoses, underdoses and other errors in radiation therapy by strengthening the agency’s approval process for new radiotherapy equipment.

In a letter to manufacturers, the F.D.A. said its action was based on a recent analysis of more than 1,000 reports of errors involving these devices that were filed over the last 10 years.

The F.D.A. will no longer allow new radiotherapy equipment to enter the market via a streamlined approval process that sometimes involved the use of outside, third-party reviewers, Dr. Alberto Gutierrez, the F.D.A.’s director of in vitro diagnostic device evaluation and safety, said in an interview. That process, he said, was instituted in the 1990s to reduce the agency’s workload and speed approval time.

Most of the reported problems — 74 percent — involved linear accelerators, computer-controlled machines that generate high-powered beams of radiation that target and destroy cancer cells.

Problems with computer software were most frequently cited as a cause for the errors, according to the letter sent Thursday by Dr. Jeffrey Shuren, director of the agency’s Center for Devices and Radiological Health.

Software quality assurance standards promoted by CSA, the US DOE and other public safety agencies are part of the requirements for safety critical software. Nonetheless, it is reasonable to ask if current methodologies have kept pace with increasing complexity.

The problem of identifying postulated initiating events (PIE) has been considered as a key issue in the safety of new nuclear reactors (TSO, section 4.3). Since the PIEs drive the design and acceptance criteria, it is important to identify as many of them as possible. Chapter 7 of the EIS details several postulated accident scenarios but they involve physical accidents or mechanical failures, not software or firmware malfunctions.

Since 1993, when the Darlington NGS was completed, software and computer technology has blossomed to provide us with a globe-spanning Internet, mobile devices and new integrated circuit technology. The complexity of software systems is ever increasing, as is the pace of change in the platforms for development and operation.

Safety approaches in the nuclear industry has been to make cautious incremental changes in design and operating procedures.

(Nancy G. Leveson, 2003)

“Although the terminology differs between countries, design basis accidents for nuclear power plants in the U.S. define the set of disturbances against which nuclear power plants are evaluated. Licensing is based on the identification and control of hazards under normal circumstances, and the use of shutdown systems to handle abnormal circumstances. Safety assurance is based on the use of multiple, independent barriers (defense in depth), a high degree of single element integrity, and the provision that no single failure of any active component will disable any barrier. With this defense-in-depth approach to safety, an accident requires a disturbance in the process, a protection system that fails, and inadequate or failing physical barriers. These events are assumed to be statistically independent because of differences in their underlying physical principles: A very low calculated probability of an accident can be obtained as a result of this independence assumption. The substitution of software for physical devices invalidates this assumption, which has slowed down the introduction of computers (although it has increased in the last few years).”

The entire support system for the software operating devices and systems in the generating station, including the physical hardware, networking environment, operating system and development tools, is in itself a complex system that must be examined as an extension of the generating facility itself. The development tools include editor, compiler, testing suite as well as the library of pre-existing modules necessary to support the actual programs. Those library modules, which may be developed by third parties, provide communication, user input, display and computation for the control software, as well as device drivers.

Taken together, this collection of hardware, software and network components is at least as complex as the operation of a nuclear reactor, the generating apparatus and their auxiliary systems. I believe there is cause for concern about the specification, design, validation and verification, and long term maintenance of this collection of systems.

2.Dealing with complexity and the potential for software errors

2.1.Hardware and soft errors

Integration densities are such that entire microprocessor systems can be built on a single system on chip (SOC). However, constantly shrinking integrated circuit geometries and lower operating voltages mean that these systems are more susceptible to soft errors caused by ionizing radiation and electromagnetic interference. This should be flagged as a common cause risk that could potentially affect any software-hardware system or device.

Contemporary SOC microcontrollers integrate CPU, EPROM to store the program binary code and control coefficients, sufficient RAM to run the program as well as necessary peripheral devices: analog-to-digital converters, timers, digital inputs and outputs and communication interfaces. The level of integration comes from reducing the geometry of transistors and interconnects on chip, as well as reducing the power dissipation of individual transistors by lowering the supply voltage to 3.3 volts or lower. These operating voltages are significantly lower than earlier standards.

With smaller IC geometries and lower voltages, the risk of soft errors caused by ionizing radiation is increased. A single event upset (SEU) occurs when an ionizing particle injects a current in a transistor sufficient to change the state of a memory element (Baumann, 2004). There are two modes for a soft error to occur. The first involves the direct change of a binary memory element (flip-flop, static or dynamic RAM cell) to its opposite state (“zero” to “one”, or vice versa). In the second, the ionizing radiation causes a combinational circuit to exhibit a transient incorrect output. If the transient persists across a clock edge, this transient state can be latched by a memory element and becomes an SEU. The higher the system clock frequency, the more likely the transient will be clocked in by a memory element.

Although the major concern about radiation exposure is for military or space based systems (satellites, probes), exposure at ground level is expected from background radiation as well as cosmic rays. Operation inside a nuclear facility increases the likelihood of soft errors (National).

The reduced size of transistors, lower operating voltages and increased CPU clock frequencies can increase the probability of soft errors in embedded microcontrollers powering mission critical devices. A system in which many similar devices with the same microcontroller type, or even the same semiconductor process technology, could be vulnerable to common cause failure due to the internal operation of the microcontroller.

2.2.Software complexity

As the number of microcontroller based instruments and control systems increases, so does the complexity of the software operating each one. The need to validate and verify the software becomes more important while at the same time becoming more difficult.

The first challenge is validation, which asks if the software correctly models the desired behaviour (Kelly, 2008). Subsequently, the challenge is to verify that the software is developed to the specifications required by the model.

The validation challenge involves subject matter experts in nuclear operations communicating their requirements to software developers, and the software developers in turn successfully translating those requirements into correctly operating programs.

Testing requires several concurrently applied techniques (Kelly, 2008; AECB, 1999):

·Regression testing: over time, tests and procedures are developed that test for the resolution of known problems and defects. The collection of tests is systematically applied to new versions to ensure that previous issues were not inadvertently re-introduced by the latest modifications;

·Code inspection: the source code is verified by others independent of the original programmers;

·Formal methods: methods to prove correctness such as those used by David Parnas in the control software for the existing Darlington NGS (Kelly, 2008);

·Randomized testing: a randomly selected sequence of inputs is presented to the software under test in an effort to flush out the most likely failures.

However there is no guarantee that these methods will detect and prevent all potential initiating events due to software defects.

2.3.Network complexity

An unforeseen consequence of networking safety critical systems with other systems was discovered as a result of a SCRAM incident at the Browns Ferry 3 reactor (NRC, 2007). Excessive network traffic caused a variable-frequency drive controller for a pump to malfunction. The abnormal network traffic was due to the failure of another device, a condensate demineralizer, on the same network that flooded the network with packets.

A word about how network devices operate. When a device receives a data packet, it must read the packet from the network and examine the destination address to decide whether or not it is the intended recipient and if it should receive the packet. If not, the device simply discards the packet. Even though most of the network traffic was not intended for the VFD controller, it had to devote some processing time to examine each incoming data. The extra processing load overwhelmed the controller and caused it to become unresponsive. The VFD controller was thus unable to process a command to increase the flow of cooling water and the control room procedure called for a manual SCRAM.

The problem was resolved by partitioning the network with firewalls to isolate the safety critical systems from the rest of the network and limit the amount of traffic the device could see on its wire. However, it's only in hindsight that the solution at Browns Ferry 3 seems obvious. It is standard practice to compartmentalize networks using firewalls and routers to isolate subnets within an organization to limit the spread of computer worms and automated attacks.

This begs the question, what about the future? What network problems will arise in new networks as more data is transferred over IP networks instead of discrete wiring? What happens to realtime requirements with more diverse traffic? Networks nowadays can carry voice and video, in addition to the traditional instrumentation and control data streams. The number of networked devices is far greater, multiplying the number and nature of networked interactions between software based devices.


Programmable logic controllers (PLC), ubiquitous in process control applications, are not immune to the ramping up of software complexity. Most now use embedded microcontrollers to execute programs compiled from on-screen representations of ladder logic networks. The ladder logic compiler used by the designer must meet the criteria set out in standards for design programs (for example, CSA N286.7-99). In addition, there must be assurance that PLC firmware will execute the compiled program correctly. A common cause fault in the PLC firmware that executes the simulated ladder logic diagram could cause all controllers with similar firmware to fail under the same circumstances. PLCs are networked with dedicated embedded microcontrollers as well as control consoles and data recorders, bringing an additional level of risk to their operation.

2.5.Maintenance over the life cycle of the station

The operating span of the NND is expected to be 60 years before decommissioning. 60 years ago, stored program computers were experimental oddities mostly powered by vacuum tubes.

Programmers in the 1970s would have scoffed at the idea that their COBOL programs would still be in use a quarter century later and causing anxiety at the possibility of programs suddenly finding themselves in the year 1900 the day after December 31, 1999. The point is that the pace of technological change is so fast that the current design would have to be "future proof", an impossible task.

Another serious issue is maintaining the development system for the devices in use at the generating station over the lifetime of the devices themselves if any maintenance, bug fixes or other modifications to the running program are required. The woes of maintaining obsolete hardware and operating systems are compounded by the need to maintain the programming environment virtually frozen in time. The development knowledge of the original programmers must also be captured as part of the development environment.

3.Threats and attacks

The common cyber-attacks reported on the news would not be expected to affect safety critical systems as it is assumed that they are isolated from the Internet, an elementary precaution.

However, the possibility of a successful attack, though remote, cannot be dismissed as a “not credible”. Several factors could enable such an attack:

·Increased availability of small wireless personal devices (smart phones, wireless PDAs and tablets). As those devices become smaller yet more powerful, it is not unrealistic to postulate an attack from inside mediated by a wireless access point unwittingly installed against network management rules.

·Ubiquitous small portable memory devices able to introduce malicious programs (a.k.a. viruses) into the protected network environment

·A successful “publicity” attack on a non-safety related computer (e.g. air sampling beyond the fence line) could damage the proponent's reputation for safety. Any protestation that the system in question was of trivial importance would be lost in the noise resulting from a newspaper headline that screams “Nuke plant computer hacked”.

3.1.Future threats and attacks

Cryptographic protocols that depend on computationally expensive attacks for their security must not only offer protection against current attacks, but those expected in the future, when exponentially faster processors become available. A recent development is widely distributed computing over the Internet, as pioneered by the SETI@Home project (SETI@Home). Thousands of otherwise idle computers could be harnessed to recover encryption keys for secured communications, for example those that enable virtual private networks (VPN) access internal networked computers over the Internet.

3.2.Malevolent acts

Although the proponent has spelled out mitigation measures for various accident, malfunction and malevolent act scenarios, the use of expressions like "not credible" or "beyond design basis" would make an information security expert cringe. Such language gives the impression that events will unfold in an orderly and predictable manner, and generating station personnel only need to refer to their training scenarios to respond to any foreseeable emergency.

Software faults don't follow obvious rules. A soft error in a critical section of code can have an unpredictable effect. A common cause error triggered by a rare combination of inputs could affect a number of devices running similar hardware or firmware.

Attackers don't follow rules. Actually, they deliberately break the rules. Computers have given them the tools to make complicated attacks easy by automating the procedures into attack scripts. The Internet has made it easy to attack any other computer on the Internet since they are all virtually next door to each other (Schneier). Isolating safety critical networks from the Internet is a natural precaution but there can be no guarantee that the supporting systems are sheltered from attack.

It is not sufficient to test for expected conditions because security flaws are often in code that is rarely executed, or conditions that never naturally arise.

3.3."What if" thinking

The only way to identify postulated initiating events (PIE) due to malicious software is to change one's frame of mind from "not credible" to start asking open ended stimulating questions like, “if it were to happen, how could it start?”

"What if" thinking requires designers to put themselves in the roles of attackers, similar to what penetration testing professionals do to audit network security for their clients.

This kind of thinking is creative, playful and hopes to break rules. By engaging in this kind of exercise, the mind is freed of pre-conceived notions of what's possible and what's not. "One-in-a-million" events can suddenly become more probable, or links between apparently unrelated events and conditions can be seen as part of a larger chain of causality that could potentially lead to an accident.

To illustrate this, let me describe a commonplace programming error known as the buffer overflow attack, so called because it causes a data to be copied beyond the allocated bounds for a string of text characters. The text characters copied beyond the bounds are likely to overwrite data that belongs to another part of the program, unrelated to the text buffer itself. This behaviour is what makes software errors difficult to analyze, and with consequences even harder to predict.

Our hypothetical programmer expects that passwords are never more than a hundred characters long. For safety, he allocates 1,000 characters for his buffer. The attacker asks "what happens if the password contains more than 100 characters?" The program is safe up to 1,000. But what happens when the attacker supplies 10,000 characters? Attackers break rules.

This technique has been one of the most prevalent attacks on the Internet and it is devastatingly effective, often leading to a complete takeover of the system by the attacker (Schneier,P.207). Conventional testing would not detect this error. In normal operation, a reasonable length password is presented and either accepted as valid or rejected. It's only when absurd input is provided that the program fails.

What if the compiler on a software developer's workstation was compromised to inject malicious code in all programs processed by the compiler? At the binary code level, the effects of the change would be hard to detect because the code is not human readable.

It is important to attempt to foresee all possible attacks because, as defender, all defenses must be impenetrable. For the attacker, the job is simpler: only one attack needs to succeed.

4.Conclusion and recommendations

My submission presented concerns that I believe are credible and realistic considering the current state of the art of software development, the complexity of embedded operating systems and control programs, and ubiquitous networking.

Therefore I strongly recommend that this panel reject the proponent's application unless the proponent can supply a realistic and practicable plan for safety critical software and firmware that:

·Tests the finished software or firmware against unusual or absurd input conditions or states, in order to flush out hidden defects that could be exploited by a malicious attacker.

·Runs probabilistic tests to simulate soft errors due to single event upsets caused by ionizing radiation in low power, high integration digital integrated circuits.

·Detail the threat and risk assessment methodology to identify software based postulated initiating events.

·Outlines the management approaches that would be in place to ensure that the configuration of software and firmware based devices and that of the network itself as documented and that changes to individual components and network topology are managed through a suitable review and deployment process.

·Maintains the software development tools throughout the lifecycle of the software itself, and that future replacement software be developed respecting the original requirements and any additions or adjustments thereto. If the development tools are upgraded or migrated to a newer development platform, the plan should detail how the upgraded tools will be tested to produce correct binary code.

Some final thoughts

There are some people in this province who have convinced themselves of some pretty remarkable things. Some have convinced themselves that nuclear is unquestionably safe, while others have reviled wind power as harmful to health and the environment. Beliefs such as these stand reality on its head.

Without presuming what this commission will decide or how, I would ask that a critical look be applied to the unspoken assumptions that the nuclear industry has thought of all the threats and risks.

Risk Assessment

The discipline of risk assessment itself should come under scrutiny. To my understanding, in its simplest form, risk assessment attempts to model the likelihood of a harmful event and the consequences of such an event. It’s a simple multiplication. The result is then balanced against the potential benefits to society and provides the basis for a go / no-go decision, or the expense and effort of additional mitigation.

It information technology, if I have a web server that services 100 clients, and I know that the probability of a successful attack is one per year, and I also know that it costs me $10,000 in staff time and compensation to my clients for downtime for each attack, I can quantify this risk into a dollar amount and use that to estimate the worth of prevention or mitigation measures: in this case, $10,000 / year is my cost. It would make sense to buy a backup tape drive for $5,000 if I knew it would mitigate by restoring my server faster. Could I justify spending $20,000 on a firewall and intrusion detection system?

With nuclear, the calculation goes off the rails. The probability of an accident is admittedly very low. The consequences would not only be tragic, but extremely costly to the station, the surrounding area and to the economy of the province and of Canada. The simple multiplication no longer applies. You are multiplying infinitesimal probabilities with enormous damages to get an intermediate number. However, because of the difficulty in estimating either factor, the result is meaningless.

At a presentation to Clarington Council in 2009, Dr. Chris Olsson (Stantec) told the council in response to a question that “Risk assessment is not the science to tell you that it is safe”.

A Word About Fukushima

In the news, there is talk about the 50 (or is it 300) nuclear workers who are desperately battling to restore the failing systems in the damaged reactors. Their families are justifiably concerned for their health and safety.

To me this personalizes the nebulous side effects of nuclear power. We know that someone, somewhere will get sick because of radioactive emissions, but we can’t tell whether or not a particular case affecting a specific person was caused by nuclear power.

In the case of Fukushima, the causes and effects are tragic and my heart goes out to those workers and their families.

The accident also demonstrates that we are playing with forces that, if they escape the normal control parameters, are clearly beyond our ability to control - especially with something as fragile as computer software.

Mr. Chairman, members of the panel, I thank you for your attention and welcome your questions.

M. le president, commissionaires, je vous remercie de votre attention et j’acceuille bien vos questions.


AECB - Atomic Energy Control Board. "Software In Protection And Control Systems", Draft Regulatory Guide C-138 (E), October 1999

Baumann, R.C. "Soft Errors in Commercial Integrated Circuits", International Journal of High Speed Electronics and Systems, Vol.14 No.2 (2004) 299-309 (In Schrimpf, R. D. and D. M. Fleetwood, "Radiation effects and soft errors in integrated circuits and electronic devices", World Scientific, 2004 - ISBN 981-238-940-7

Bogdanich, Walt. "F.D.A. Toughens Process for Radiation Equipment", The New York Times, April 9, 2010, on page A12 of the New York edition. http://www.nytimes.com/2010/04/09/health/policy/09radiation.html?_r=1 (Viewed Feb. 19, 2011)

CSA N286.7-99, "Quality Assurance of Analytical, Scientific, and Design Computer Programs for Nuclear Power Plants", Canadian Standards Association, March 1999 (Cited by Kelly, 2008)

Leveson, Nancy G. "White Paper on Approaches to Safety Engineering"April 23, 2003 http://sunnyday.mit.edu/caib/concepts.pdf (Viewed Feb 20, 2011)

Leveson, Nancy G. and Clark S. Turner (abstract by Philip D. Sarin), "An Investigation of the Therac-25 Accidents" Online Ethics Center for Engineering 2/16/2006 National Academy of Engineering http://www.onlineethics.org/Resources/Cases/therac25.aspx (Viewed February 20, 2011)

Kelly, Diane and Rebecca Sanders. "Assessing the Quality of Scientific Software" , First International Workshop on Software Engineering for Computational Science and Engineering, Leipzig Germany, May 2008.

Mastromatteo, Michael. "Engineering detectives go to the heart of the matter," Engineering Dimensions, Professional Engineers Ontario, January/February 2011

OPG Response, EIS IR 54 (Resubmission) and IR213:Regulatory Documents, Codes and Standards, Appendix 1B to Attachment A, File name: "9 July 2010a.pdf"

Regulatory Documents

·C-138(E) Software in Protection and Control Systems (October 1999)

Codes and Standards

·CSA N290.14 Qualification of Pre-Developed Software for use in Safety-Related Instrumentation and Control Applications in Nuclear Power Plants

·CSA N286.7-99, Quality Assurance of Analytical, Scientific, and Design Computer Programs for Nuclear Power Plants, Canadian Standards Association, March 1999 (Also cited by Kelly, 2008)

National Semiconductor, "Radiation Owners Manual" Undated http://www.national.com/analog/space/rad_ownersman (Viewed Feb 20, 2011)

NRC - Nuclear Regulatory Commission, "Effects of Ethernet-Based, Non-Safety Related Controls on the Safe and Continued Operation of Nuclear Power Stations", US NRC Information Notice 2007-15, April 17, 2007.

Schneier, Bruce. "Secrets and Lies: Digital security in an networked world", John Wiley & Sons 2000 ISBN 0-471-25311-1

SETI@Home project "About SETI@Home", undated, http://setiathome.berkeley.edu/sah_about.php (viewed Feb 20, 2011)

TSO "TSO Study Project on Development of a Common Safety Approach in the EU for Large Evolutionary Pressurized Water Reactors", 2001, EC EUR 20163

Darlington Hearings Over!!

Friday, April 8th was the last day of the 3-week hearings into the proposed building of 4 new nuclear reactors at the Darlington Nuclear Generating Station near the town of Courtice, outside Toronto, Ontario.

Hallelulia!! I’ve been blogging about these hearings for weeks, & still have a few items I intend to add to the special section on the hearings, but my overall feeling is … relief!!

That, “OMG it feels good to stop bashing my head against a brick wall” feeling…you know what I mean??

There was an almost holiday atmosphere in the hearing room on Friday afternoon – among both those of us intervenor types who attended more of the hearings than is surely really good for a person’s mental health, &, pretty clearly, also among JRP (Joint Review Panel) members & CNSC (Canadian Nuclear Safety Commission) staff who must all have been just about going nuts to be away from their families & homes for so long.

I have said repeatedly that the hearings have felt quite surreal. An escalating nuclear crisis has been taking place in Japan throughout the hearing process, & to many of us, the prospect of entertaining the idea of expanding nuclear capacity at this time is, well, foolhardy, to say the very least (absurd, actually).

Anyway. It’s been quite the slog, to put it mildly, & my own only intermittent access to the Internet has made it all doubly & triply challenging for me personally.

So…I’m greatly relieved the hearings are finally over, & while I have no faith in the impartiality of the panel to put a stop to this proposed nuclear expansion, I do hope & believe my own mental health will improve somewhat now that life can return to … “normal” – not that “normal” is what it used to be, given the ongoing nuclear crisis in Japan.

Here in Canada we are simultaneously well into a federal election campaign, &, given the character of our political situation, this too seems surreal.

I guess maybe surreal is … “the new normal.”

I do look forward to blogging about some more, shall we say “ordinary” things in the days ahead.


‘Quote of the Day’ with this post: “After last year’s oil spill in the Gulf of Mexico & now the Fukushima Daiichi ‘‘gempatsu shinsai,’’ people must realize that business as usual is not an option. To claim that nuclear energy has a future represents a colossal failure of our collective imagination—a failure to imagine the risks involved & a failure to imagine how we could do things differently. If future generations are to say that there was a silver lining to the cloud of the Fukushima Daiichi disaster, it will be because human beings now looked beyond their recent history and chose to build a society that was not subject to catastrophic risks of human making.” – Philip White Tokyo-based Citizens’ Nuclear Information Center

*** Lots of good nuke-related quotes/resources here


Darl. Hearings – Last Day, Final Awards

April 8 – Day 17 & the last day of the Darlington New Nuclear dog & pony show:

  • CNSC = Canadian Nuclear Safety Commission
  • JRP = Joint Review Panel
  • NWMO = Nuclear Waste Management Organization
  • OPG = Ontario Power Generation

Also note: You can go here to find transcripts & audio & Webcast of the hearings.

Holy smokes! (I am repeating myself…)

The day began with a review of the “undertakings” that the JRP has … ordered undertaken during the panel hearings to dig up relevant reports & things. Most of the undertakings seem to be relatively meaningless, in that one doubts seriously that panel members will pay any attention to anything that doesn’t serve their agenda anyway, and/or when CNSC staff pass along whatever they’ve turned up, they bafflegab it so severely that everyone has fallen asleep by the time they’ve finished bafflegabbing it, or is quietly banging her/his head on a brick wall to staunch the pain of having to listen to so much meaningless CNSC staff nonsense/nukespeak.

More awards I feel are due…

CNSC Staff

Not ENOUGH Cancer award to CNSC staffer Patsy Thompson, who read a long statement in response to one of the aforementioned “undertakings.” She appeared to be saying, more or less, “Yes, it is true that radiation causes cancer. But how much cancer does it cause?” I guess what she meant was that her paycheque rests on the assumption that the nuclear industry doesn’t really cause enough cancer for them to own up / give a rat’s ass.

ALARA / ALARM award to aforementioned Patsy Thompson for reassuring us all that nuclear plants work hard to emit as little as possible. After all, they try hard to adhere to their ALARA principle. (Their ALARA principle, btw, stands for "As Low As Reasonably Achievable, economic & social factors taken into account." Needless to say, the economic interests considered are those of the nuclear industry, not that of the public, or public health). I believe the ALARA principle, as defined by the nuclear lapdog…oops, I mean watchdog, really ought to be re-named the ALARM principle. For sure, we cannot trust the nuclear industry to really look out for us, & we should ALL be alarmed at their cavalier attitude toward routine nuclear emissions, spills, public health, potential accidents, & long-lived nuclear waste for which no secure containment exists except in the fuzzy minds of nuclear industry personnel whose paycheques depend on this naïve, ill-placed, childlike & highly un-scientific, utterly baseless faith.

ROBUST LANGUAGE awardif we just repeat the word “robust” often enough, then apparently, this will make it so! Members of the nuclear industry say it a lot, so I guess it must be so!! It’s a robust industry; the reactors are robust; safety measures are robust…right. (For sure, we do know that nuclear waste itself is robust – very, very robust!!! It’s gonna be around FOREVER!)

WAITING…WAITING…WAITING award to the nuclear industry, that keeps ever so patiently waiting & waiting & waiting for a “solution” to the problem of long-lived nuclear wastes, & keeps expecting all of us to also keep waiting & waiting & waiting for a solution to these wastes that will be in their merest infancy in all of our lifetimes & will remain dangerous for my grandchildren’s grandchildren’s grandchildren’s grandchildren…& beyond.

JRP Panel Members:

DISPOSABLE PEOPLE award to Mme. Beaudet for her “sensitive” response to a local person’s heartfelt query as to “Where do we go?” in the case of a potential nuclear accident at Darlington. I will try to find the part in the transcript to get her exact words, but she seemed to be saying more or less “Don’t worry, be happy!” Or basically “Hey, dude, I’m sure you can find a friend to go & live with!”

AFFABLE GRANDAD award to JRP Chair Alan Graham who, after listening to the incredibly articulate & feisty young intervenors (who won the “Out of the mouths of babes” award; see below) & after hearing his fellow panel members bat some dumb questions back & forth, assured the young folks that they too can grow up & work in “the industry” (i.e., the nuclear industry). He said this twice & then corrected himself to broaden his language to “industry,” but Mr. Graham pretty clearly assumes it is the fond wish of ALL young people to grow up & work in the nuclear industry (I guess the money must be really REALLY good, eh??)

“It is difficult to get a man to understand something when his salary depends upon his not understanding it” (Upton Sinclair) award overall to all members of the Joint Review Panel & all OPG & CNSC staff & all participants in the nuclear nonsense for their apparently very thick skulls & impervious brains.

I DON’T GET IT / WE LIKE TO PAY LIP SERVICE if not any actual real concern award to JRP member Mme. Beaudet for her very imperfect grasp of the meaning of the precautionary principle. Mme. B. is invited to generously share this award with everyone in the nuclear industry for talking about how they buy into the precautionary principle & then go right on barging ahead making more nuclear waste that we have no reasonable solution or even reasonable assurance of ever properly safeguarding.

THAT OLD ENGINEERING MINDSET award to JRP member Pereira, who asks a group of young pro-nukers (all of whom work for OPG) – & with a straight face, btw, how they will safeguard nuclear waste created by the proposed new reactors at Darlington (as though these young folks know any better than the older ones how anyone can possibly promise to keep nuclear waste safe for a million years. No one on the planet can do that, so why long-time engineer dude Pereira would ask a bunch of engineers still wet behind the ears how they can do it…. Well. The mind boggles, hmmm? Magical thinking, perhaps…).

THE BIG DYSFUNCTIONAL FAMILY award to the Joint Review Panel members for their apparent assumption that, if a local mayor & a business organization & … whoever else… say the idea of nuclear expansion is great, they therefore represent everyone in the area. (This puts me in mind of my own birth family – highly dysfunctional, like so many, hmmm? Just ‘cos my Dad might have claimed “Our family all agrees everything is cool here” sure doesn’t mean it was so…you know??)


IT ISN’T ALWAYS WINDY & IT ISN’T ALWAYS SUNNY (& nuclear waste is FOREVER but I ain’t gonna worry my pretty little head about THAT) award to the intervenor who makes his income from nuclear energy & wants to be sure that the new build will move ahead (this person also commented “nuclear leads the way when it comes to safety,” giving him runner-up position for today’s Cognitive Dissonance award; see below).

CREATIVE LANGUAGE award to the young engineer who has such overwhelming confidence in nuclear energy & the ability of the nuclear industry to find a “willing host” community to host a deep geological repository for long-lived nuclear wastes that he has staked a career on it. After all, he asserted, they have a “conceptual study” of the possibility of properly minding nuclear wastes for a million years. (Wow!! Then I guess the problem is solved………right???? It’s all about those “conceptual studies,” eh??)

COGNITIVE DISSONANCE OFF THE CHARTS AWARD to the young nuclear engineer who says he is relying on the NWMO (a creation of the nuclear industry, btw) to safeguard current & future generations. Tied with the contractor who looks forward to lotsa cash in the future, for saying “nuclear leads the way when it comes to safety.” (Have I not been saying for weeks now that the proceedings here are SURREAL?????????) I dunno how many people get killed making solar panels & wind turbines – but I am betting not too many!?!? No million-year wastes, either, hmmm?

OMG SHE JUST SAID “TRUST PERMEATES THE ORGANIZATION” award to a young nuclear engineer whose naivete is very touching indeed…if very very very severely – not to mention dangerously – misplaced.

NO JOBS ON A DEAD PLANET award to the young nuclear engineers & also to the local provincial Member of Parliament who touts the 3200 jobs that will be created by the Darlington New Nuclear project. While a nuclear crisis in Japan escalates, the impacts of which will affect all human beings on the planet for many-many decades to come, all these folks can think about is jobs, jobs, jobs. (None of these dudes seem to be able to “get” that investment in conservation & efficiency & renewable energy strategies/projects has tremendous potential to create new jobs that are sustainable jobs – not jobs that negate even the very possibility of a future!)

BINGO award to the other young engineer who stated that he is not aware of any “willing host community” that has volunteered to take the high-level, long-term waste that already exists, never mind the potential waste of 4 new reactors at Darlington.

I DIDN’T RUN SCREAMING FROM THE ROOM award to me once again, for listening to the young engineers talk confidently about their ability to safeguard nuclear wastes for a million years, having clearly not heard OPG staff’s UNDERWHELMING testimony on the day waste was discussed, with their confident, strong assertions that “We are looking into containers” & “We are learning as we are going along.” Egad…

THE NUCLEAR EMPEROR HAS NO CLOTHES / OUT OF THE MOUTHS OF BABES award to the young (very young!! High school age) & feisty intervenors who told the panel that, contrary to assertions by OPG that the public has been consulted, they have indeed not been consulted, & since they are the ones who will wind up having to pay all of their lives for the high costs/ongoing debts of nuclear power & be saddled with the-waste-that-is-forever, & also bear the health impacts, NO THANKS to any more nuclear reactors!! Hats off to these young people; what an inspiration!

CAN’T WE JUST START TELLING THE TRUTH?? award to the various citizen intervenors who pointed out that we humans need to dispense with our “technological optimism” & adopt the precautionary principle & the polluter pay principle & acknowledge the deadly risks of nuclear energy & the permanence of nuclear wastes & the reality of already-existing nuclear wastes leaking into Lake Ontario & rising cancer rates & the very real possibility of more nuclear accidents (& the fact that there have been many un-reported “near-misses” at nuclear plants) & that accidents by their very nature occur when we least expect them & finally, the utter immorality of an industry that does so much damage at every stage from uranium mining to refining to nuclear energy creation to routine emissions & finally, the waste-that-is-forever.

I could probably go on with awards forever, readers gentle & otherwise, but…enough already!!


p.s. For example, I should no doubt have handed out a “Shit happens!” award to the nuclear industry. That is perhaps their overall explanation…excuse…rationale...for all the harm their industry causes. Or maybe “Shit happens; suck it up, suckers!!” Or…. “Give Your Head a Shake.” I dunno. I am shaking my head…

Some Quotes for Today:

“It is difficult to get a man to understand something when his salary depends upon his not understanding it” – Upton Sinclair

“No degree of prosperity could justify the accumulation of large amounts of highly toxic substances which nobody knows how to make “safe” and which remain an incalculable danger to the whole of creation for historical or even geological ages. To do such a thing is a transgression against life itself, a transgression infinitely more serious than any crime ever perpetrated by man. The idea that a civilisation could sustain itself on the basis of such a transgression is an ethical, spiritual, and metaphysical monstrosity. It means conducting the economic affairs of man as if people really did not matter at all.” – E.F. Schumacher

“29 years after passage of the Nuclear Waste Policy Act, 36 years after the repository search began, 54 years into commercial nuclear power, and 69 years after Fermi first split the atom during the Manhattan Project, the U.S. still has no safe, sound, permanent storage plan for high-level nuclear wastes.”Kevin Kamps from Beyond Nuclear

“Authorizing construction of new nuclear reactors without first constructing a radioactive waste disposal facility is like authorizing construction of a new Sears Tower without bathrooms.” ~ Dave Kraft, director of Nuclear Energy Information Service

“Telling the truth is like making oxygen.” – Joanna Macy

** Lots of great quotes in a variety of categories in the ‘Quotation Central! section. Nuke quotes here

Darl. Hearings: Carrie L. (March 31st)

I presented my remarks to the Darlington New Nuclear Plant  Project Joint Review Panel right after Carrie Lester last Thursday evening. Her remarks were so ... heartfelt...so moving...so articulate, I prefaced my own remarks to the JRP by saying I felt Ms. Lester had said it all & there wasn't much left for me to say. Thanks, Carrie, for letting me post your presentation!


~The Burden of Truth~

Greetings to the members of the Darlington New Nuclear Power Plant Project Joint Review Panel, and audience members,

My name is Carrie Lester, from Toronto. I am “Onkwehonwe” which is the Bearfoot Onondaga from Six Nations.

In regards to Nuclear Energy, as simply a human being of this planet, my Mother Earth, your Mother Earth, I am going to address the Burden of Truth as it applies to our health all of our health. My health; the health of my family and friends; the health of your relations, and my relations; the health of the soil, the air, the water in and around Lake Ontario, where I live, and where my ancestors on my mother’s side have lived for thousands of years.

Segoli – Ga’un’ghwa Desa’na:sga’qua gia:jih,

Ogwai Osida niwa geh seh dehn,

Onondagaega niwa go wehn jyoh dehn

(That’s my name, my clan, and my nation).

There was a time when there was no cancer sickness here on Turtle Island. It arrived with the settling of the newcomers, and their need to do things faster, better, more ‘efficiently’, but that detached from the connection to Mother Earth, with the continued industrialization of the land, as was being practiced on the other side of the world.

Toxic waste from industry has infiltrated our world, from so many different sources, that we here in an urban setting find it difficult to be able to pinpoint exactly where each industrial toxin has come from, and what each toxin will do to us; however, the people from places like Fort Chippewa in Alberta know exactly where their cancerous poisons are coming from: the Tar Sands.

I recently attended a funeral for a friend; no, let me correct that: I attended TWO funerals ... for friends of mine whom I had got to know through my children, their school, and after school activities. After attending both funerals, I discovered that there were two other funerals that same day, from the same neighbourhood. I also learned of three other deaths of parents whom I had only briefly known, but who had also died recently ... within the past two years. All of them were parents in their late forties / early fifties with children in their late teens / early twenties. They all died from cancer. They all had raised their families in that same neighbourhood for those twenty years.

This neighbourhood was not in Clarington, or Bowmanville, or Darlington; but it was in Toronto. It had been an industrial area during the Second World War, but had since become a rather prestigious neighbourhood, with many tear-down bungalows becoming two-story million dollar homes.

Just before hearing of the deaths of these friends, I had attended a film screening / book launch of Sandra Steingraber’s story called “Living Downstream”, which, if you are not familiar with, is the story of, in general, how we are ALL now living downstream from some pollutant, and in particular, it is Sandra’s story of her survival with cancer, and wondering when it will come to get her again. It is also a story of discovery for Sandra, as she begins to question her cancer, and other cancers in her neighbourhood, and then the clusters of cancers throughout her state, and neighbouring states, and finally that of the whole of America, with a brief look at Canada and then how it can be applied to any community throughout the world.

I had also been to another book launch right after the Living Downstream film / book. This one was called 'Sea Sick', and was about the condition of the earth’s ocean the one ocean that is surrounding us, and what we have to the lifeblood of our Mother, the Earth.

One of the daughters of my friend who had died posted a message on her Facebook, asking everyone who has been affected by cancer in one way or another to pass on her message of hope, hope for a cure to come this year so that nobody else has to die from cancer, from how she had seen her mother’s body ravaged with this cancer. And she posted this to all her contacts on her Facebook.

I responded by saying,

“... it's not so much that a cure is needed (although that would be nice) ... it's that we must stop the lifestyle that produces it. We've contaminated our Mother Earth so horribly in only 150 years of the billions of years that this world has been in existence. The Industrial / Chemical / Technological Revolutions have all got us to this point. The toxins are everywhere now ... not just in our water, air and land, but in the cosmetics and hygiene products, our clothes, bedding, paints, plastics, toys, baby products, etc, etc ... a ‘cure’ will not take away all these toxins burdening our bodies ...“

Now, this is the part of my talk in which I was going to list a series of facts about the nuclear industry, such as:

·Radiation is a carcinogen, meaning that it damages DNA

·Tritium is a radioactive isotope of hydrogen, and is a waste product in the nuclear industry

·Canada’s allowable (1) levels for tritium (2)are quite a bit higher than other countries: 7,000 bq/l, compared to 100 bq/l in the EU, and 740 bq/l in the USA.

However, all of those statistics you already know. You have your own panel of (dispassionate – according to me) ‘engineering experts’, and you have been hearing from the (‘passionate’) public for the past week and a half, who are individuals like myself, and non-governmental organizations who just want you all to see where all of this horrible experiment has gone wrong. It doesn’t matter how many allowable ‘bequerels’ or ‘milliseverts’ of this or that are in our water, or air, or soil. What matters is that we just stop putting it there. There is no safe, allowable level of radiation. Period.

We have been contaminating our Mother Earth with this cancerous element ever since ‘engineers’ and physicists learned how to split the atom. And what was it the ‘experts’ said at that time when they saw what they had done?

Well, to quote from Paul McKay’s book called Atomic Accomplice:

Einstein said, “The unleashed atom has changed everything, save our modes of thinking, and thus we drift towards unparalleled catastrophe.”

And Oppenheimer said, “Now I am become Death, Shatterer of Worlds.” – and his military munitions expert who wired the detonators for the Trinity bomb test said, “Now we are all sons of bitches!”

So what should I talk about instead? Well, how about: how we should move on from here? How about if our direction of discussion turns from: how much radiation are we willing to subsidize from an industry that will contaminate our family and friends with; to a life-style without such consequences? How about if we talk about renewable energy sources, and reducing our consumption of energy?

We are creative beings – we don’t have to destroy our Mother in the process. People have already come up with plans to have a 100% renewable energy grid by the year 2027 – that’s probably about the time that a brand new reactor would take to be built and be up and running, but it would be far less costly in financial cost, and in living organism cost. Who are those people? Well, one group that I know of which has well documented plans are the people from the Ontario Clean Air Alliance, another is Greenpeace, and also the Pembina Institute.

We have the technology and the creativity to combine all these different energy systems: Solar, wind, combined heat and power, our own hydro electric plus imports from Quebec.

I work at a school, an elementary school. I am a teacher’s assistant. When I sit in on a science lesson and the topic comes to their Living Things unit, the curriculum states that there are Living Things and Non Living Things – Biotic and Abiotic. And that, my friends, is the problem. In Indigenous cultures around Mother Earth, there are no “non living things”. Everything has life, has spirit. To think otherwise, allows people to disregard the very soil, air and water of our Mother, this planet Earth, and contaminate her, and everything on her, and in her, and around her. I always point this out to the students in the class. The students are our future, but we are their present … and they take direction from us and trust us to do responsible and ethical things.

Mother Earth is NOT a stable, static being. She is continually moving and reshaping herself. She thrusts, and writhes, and twists, and turns. And if I may say so, she farts, and belches, and vomits. She needs to breathe, and stretch and grow. Confining her in cement and asphalt; drilling in to her to remove her organs, and her blood, and her oils and lubricants is the death of us all. She is fighting back at our brainless and thoughtless ‘control’ that too many of us thought that we had over her. She quakes and trembles continuously, all over.

A large seismic eruption may not happen here in ten or twenty or even fifty years. It may take a hundred, two hundred, five hundred years, but this radioactive waste is here forever, and it is a ticking time bomb. Even if we stop using nuclear energy all over the world now, we still have the horrible after effects of what we have built up so far. The thousands of tons of radioactive contamination that has been stored at the 500 or so nuclear plants around the world is still going to be a problem. It wouldn’t take much for those containers to be breached by any number of Mother Earth’s bodily functions, not to mention the decay of the container itself over time.

We need to wake up and stop the nonsense. Stop funding the destruction of our planet. Stop funding the death of your family and friends.

Thank you.

(2) National Network on Environments and Women’s Health, August 2009 – Women and Water in Canada: The Gendered Health Effects of Chronic Low-Dose Exposures to Chemicals in Drinking Water: page 30 – Tritium levels down from 40,000 Bq/L in 1970’s to 7,000 Bq/L in 2000’s.

Darl. Hearings: Angela B. (March 31st)

I'm posting Angela Bischoff's presentation to the Joint Review Panel - with her permission.

Presentation to the Darlington Joint Review Panel - Mar. 31, 2011 – Angela Bischoff

Thank you to the Panel, and all the participants in the room and online for hearing my presentation today. My name is Angela Bischoff and I work with the Ontario Clean Air Alliance. We are a coalition of health and environmental organizations, faith communities, municipalities, utilities, unions, corporations and individuals working for cleaner air through a coal phase-out and a shift to a renewable electricity future.

I organized an event last night at a club in downtown Toronto called Nuclear in the Spotlight. 100 people came out to learn what’s happening now in Fukushima, to share our fears, and quite literally, to celebrate the end of the nuclear age. We learned about how the industry and governments lied to us following the Chernobyl catastrophe, and how they’re downplaying the risks associated with Fukushima. We learned about the contamination of the pacific ocean bordering Japan, and how there is no safe dosage of radiation, meaning that supposedly diluting toxic radioactive elements in the ocean or in the atmosphere is no consolation. And we learned that private investors worldwide are pulling their investments out of nuclear projects, and governments around the world are now questioning their continued massive subsidization of new nuclear projects.

Meanwhile, here in ON, our gov’t continues in its dogged commitment for 50% nuclear, which of course means that green technologies will be relegated to the sidelines, capped. There will be little place on the grid for renewables to grow. This would explain why there has been no public assessment of alternatives to this proposed Darlington new build project. Politics is trumping precaution and even economics. Usually, in environmental assessments, need and alternatives are included the process, but not here. This is unacceptable.

With that, I’m going to proceed to speak to issues of cost and alternatives. I will assert that this project is not about providing Ontarians with cost-effective clean electricity supply, but rather is a desperate attempt to save Canada’s nuclear industry.

Project Cost

In the 60’s thru the 90’s, Ontario Hydro’s profits from its water and fossil power generating stations subsidized the losses of its nuclear reactors. In fact, the cost of producing nuclear electricity was 7 times that of producing water power. In 1999, as a result of the cost overruns and the poor performance of its nuclear reactors, Ontario Hydro was broken up into five companies. All of its generation assets were transferred to Ontario Power Generation (OPG). However, in order to keep OPG solvent, $19.4 billion of Ontario Hydro’s debt or unfunded liabilities associated with electricity generation facilities was transferred to the Ontario Electricity Financial Corporation (an agency of the Government of Ontario) as “stranded debt” or “unfunded liability.”

Since 1999, Ontario consumers and taxpayers have paid almost $20 billion to service that debt (of $19.4 billion), yet we still owe almost $15 billion. This has not proven a good financial investment.

OPG is now proposing to re-build the reactors at its Darlington Nuclear Station. According to OPG, the Darlington Re-Build will have a capital cost of $8.5 to $14 billion. But every nuclear project in Ontario’s history has gone way over budget. On average, the real costs of Ontario’s nuclear projects have been 2.5 times greater than the original cost estimates. Therefore, if history repeats itself, the real cost of the Darlington Re-Build will be $21 to $35 billion, or 19 – 37 cents per kilowatt hour.

Furthermore, and the reason of these hearings, the cost of the proposed new-build projects at Darlington came in at $26 billion for 2 reactors. This gave the Energy Minister “sticker-shock” and the procurement process was postponed. The provincial gov’t then passed the buck to the federal gov’t, asking them for subsidies. In other words, Premier McGuinty is asking taxpayers in Vancouver and Halifax to subsidize new nuclear reactors in Ontario. To their credit, the Harper gov’t hasn’t budged on this request. Indeed they’ve taken it a step further and put AECL up for sale, for which there are no bidders. The future of AECL is at stake with this new-build project, and that’s why I say politics is trumping precaution.


Fortunately, there are numerous less costly, less risky and more sustainable ways to meet our electricity needs. The lowest cost option to meet our energy needs is energy efficiency. By reducing our demand for grid-supplied electricity, energy efficiency investments will make it easier for us to obtain 100% of our grid-supplied electricity from renewable sources.

Since the summer of 2006 our peak demand for electricity has fallen by 7%; and it is forecast to fall by a further 6% in 2011. Nevertheless, our electricity consumption per person is 35% higher than New York State’s. And therefore we still have a huge untapped energy efficiency potential which we must aggressively pursue. At a cost of 2.3 – 4.6 cents per kilowatt hour, energy conservation and efficiency are a bargain.

On the supply-side the lowest cost option to meet our electricity needs is to simply stop wasting natural gas. Virtually every home, building and factory in Ontario uses natural gas to provide just one service, namely, heat. It is much more efficient to use these same molecules of natural gas to simultaneously produce two services, namely, heat and electricity. This is what combined heat and power plants do.

Combined heat and power plants can have an overall energy efficiency of 80 to 90% which is much better than the 33% efficiency of a nuclear reactor. And as a result of their very high efficiency, combined heat and power plants can meet our electricity needs at a cost of approximately 6 cents per kWh. That is, less than 1/3 the cost of a new or re-built nuclear reactor.

In terms of renewable electricity, Ontario’s lowest cost source of renewable electricity is water power imports from the Province of Quebec.

Last year Hydro Quebec’s exports to the U.S. exceeded the total output of our Pickering Nuclear Generating Station. However, our imports from Quebec were miniscule. This doesn’t make sense.

There are two important facts to note with respect to Hydro Quebec’s electricity exports. First, in 2009, the average price of Quebec’s export sales was 6.5 cents per kWh. Second, according to the National Energy Board Act, Ontario has the right to import electricity from Quebec at the same price that the Americans are paying.

Therefore it doesn’t make sense to invest tens of billions of dollars in nuclear power when we can import renewable electricity from Quebec at less than 1/3rd the cost.

I’d like to draw your attn. to the report I’d attached with my written submission called Power Options: A review of ON’s options for replacing aging nuclear plants. It was produced by the OCAA in 2009. It states: Over the next 12 years, ON will need to replace 60.4 billion kWh of electricity produced by nuclear generators that will have reached the end of their productive lives by 2021. This report finds that decreased electricity demand, thanks to increased conservation efforts, could eliminate the need to replace 47% of the nuclear power generation that will have reached the end of its service life by 2021. According the OPA, the cost of reducing demand by investing in energy efficiency is approx. 2.7 cents per kWh.

Wind power when integrated with Hydro Quebec’s hydro-electric generation resources has the potential to provide ON with sufficient firm, reliable renewable electricity to replace 100% of end-of-service-life nuclear power generation by 2021. The cost of electricity from large-scale land-based wind farms in southern ON is 9.6 – 13.5 cents per kWh.

Natural gas-fired CHP plants could also provide 100% of our required replacement power by 2021 at a cost of 6 cents per Kwh.

All these electricity options are compared with new nuclear which comes in well over 20 cents per kWh.

To Conclude

If approved, this nuclear new-build project will lock Ontario into nuclear reliance for decades, denying us the swift and necessary transition to the renewable energy age that this era of climate change and declining resources demands.

The proposed project should not proceed without a full public review and assessment of all project costs against other energy options.

For all these reasons, I request that OPG’s proposal to build additional reactors at the Darlington site be rejected.

Thank you all for your time.

Darl. Hearings – March 29: WASTE Day: Awards (x 2)

I’ve been blogging about the 3-week nuclear hearings now taking place in Courtice, Ontario.

** Note: if you go here, you can find hearing info such as the public hearing schedule, transcripts, Webcasts, etc.

Courtice is a small community east of Toronto; host to the gargantuan Darlington Nuclear Generating Station that is situated right on the shores of Lake Ontario. The hearings are part of the Environmental Assessment process Ontario Power Generation (OPG) & its licensing body, the Canadian Nuclear Safety Commission (CNSC), is required to take part in as they make plans for 4 new reactors at the Darlington site (all of this at the behest of the Ontario provincial government, btw).

Taking part in hearings involving nuclear projects always puts me in mind of going down a rabbit hole, à la Alice in Wonderland. A certain Mad Hatter Tea Party ambience is unmistakable.

I’ve said it many times before: there is really no adequate way to describe what this kind of hearing is like. (I’ve written about CNSC hearings in blog postings listed under the Steam Generator heading up at the top of this blog, & in a posting called ‘Speaking truth to power.’ I’ve been very upfront with CNSC tribunal & staff about my rabbit hole analogy.)

I’ve posted recently about placards & awards during these hearings.

The other day I told some folks in Toronto that the Canadian Nuclear Safety Commission seems to have a somewhat limited vocabulary.

Favourite & very frequently-used CNSC words:

  • SMALL: Spills are always small (even when they’re big!)
  • LOW: Risks of nuclear activities of any sort whatsoever (including spills) are always low.
  • SAFE: Nuclear operations of any kind (including spills & emissions) are always safe & without health risk to members of the staff or public.
  • ACCEPTABLE: Nuclear proponent’s plans are always always always “acceptable.”
  • HIGHLY REGULATED: CNSC always claims the nuclear industry is “highly regulated,” but since they just kind of make up their own rules, I say, “Yeah, sure, right…”

Considering how truly risky nuclear activities genuinely are, I always say CNSC language is pretty goshdarn MINGY. UNDERwhelming…

Ok. A quick review of the placards I’d like to hold up at CNSC hearings (where we are much too polite to actually do so, & of course would get kicked out of the proceedings for):

  • Bafflegab!
  • Bullshit!
  • Obfuscation Alert!
  • Doh!
  • Turn off the lie machine!

And more awards I would like to generously offer after last Tuesday (March 29, 2011)’s presentations, which were focused on the issue of nuclear waste. [Note: transcripts & Webcast of this entire hearing can be found here Please also note that presentations by citizen/NGO intervenors have been amazing!  The Dr. Helen Caldicott one on March 24th was excellent, as was the SAGE (Safe & Green Energy) one by Dr. Ian Fairlie on March 28th. The Lake Ontario Waterkeeper one on March 28th was blow-you-right-out-of-the-water brilliant. First Nations presenters, also on Monday, March 28th, were awesomely articulate & inspiring.] The Northwatch intervention on the nuclear waste issue was also a show-stopper & generated a great deal of discussion (all of which, for my own part anyway, served to illustrate how shockingly shallow the nuclear industry’s understanding of nuclear waste actually is. Genuinely shocking…)

Understatement of the Millenium award goes to Joint Review Panel member Pereira for his brilliant observation “There are a number of challenges to be met” with respect to the proper, safe storage of high-level nuclear wastes that will be generated at the proposed new reactors.

I can’t believe you just said that! award to the OPG staffer who “reassured” panel members & the public with these shining statements about the need for containers that will last a million years: “We are looking at containers” & “We are learning as we are going along.”

OMG! & these are the folks who are “protecting” us from wildly hazardous & preposterously long-lived nuclear wastes!?!?

It leaves a person almost speechless…doesn’t it??

Other awards I recommend:

  • Robot award – multiple possible recipients among both CNSC & OPG staff & heck, let’s be generous here – the 3 JRP panel members too.
  • Lead face award – as above.
  • Asbestos award – ditto.
  • Cognitive Dissonance award to everyone employed in the nuclear industry. And all of the rest of us human beings for pretending the nuclear industry is “looking after us.” And especially to the OPG staffer who had the effrontery to state that OPG does not wish to put the burden of nuclear waste onto future generations. Talk about cognitive dissonance!?!?!?!?!?!?!?!?!?!?!?!?!?!?!
  • Pseudo-science award to CNSC staff for their consistent use of such deeply scientific phrases as “Tritium releases are very low.”
  • Skating on VERY thin ice award – multiple possible recipients (including all of us! Our entire species seems to be skating on mighty thin ice, I’d have to say).

Finally, to the entire nuclear industry:



I even decided to give myself an award:

The “I can’t believe I didn’t run screaming from the room when OPG staffer Laurie Swami used the phrase ‘bounding scenario’ for the 506th time” award.

(I had decided I’d rather stick a needle in my eye than hear her use this ridiculous phrase one more time.

And I’m not really all that much into sticking needles in my eyes…you know??)

Enough for now…


Darlington Hearing: Awards Announced!

(Awards for the nuclear industry, that is...)

Yesterday I attended the opening afternoon & evening sessions of the 3-week “Darlington New Nuclear Plant Project” being conducted by the “Joint Review Panel.” This is taking place in Courtice, Ontario, a few kilometres due north of the already-existing Darlington 4-reactor nuclear facility that’s been in operation for 12 or so years now.

** Note: if you go here, you can find hearing info such as the public hearing schedule, transcripts, Webcasts, etc.

(CELA - the Canadian Environmental Law Association, Lake Ontario Waterkeeper & Northwatch had asked the panel - very eloquently, btw - to delay the hearing, due to recent/current events in Japan, in order to gather relevant information that could then be included in the panel deliberations. This request was refused, as I had rather assumed it would be...)

I wished I’d been wearing a kangaroo suit, to illustrate that these kinds of hearings are mere kangaroo courts. (For any not familiar w. this term, it just means the proceedings are a sham & the conclusion a foregone one. We’s all just wastin’ our time, ‘cos we know darn well what the end result will be…)

Being a “word person” myself, I particularly notice the way the nuclear industry (& its paid minions, Ontario Power Generation or OPG & the Canadian Nuclear Safety Commission or CNSC) employs language.

These folks could teach graduate level courses in obfuscation! How to use fancy language to spew nonsense &, dare I say, bullshit – to make it look like they are “experts” in nuclear matters & have got it all figured out.

Well. As I sat listening to OPG do its bafflegab routine, these are some of the possible award ideas I came up with:

Acronym Creation Award The nuclear so-called “experts” get a gold star for their continual ongoing creation of fancy acronyms! One of the latest is PPE. It stands for “Plant Perimeter Envelope.” The PPE is somehow related to the “bounding framework” that allows the planners to leave out things in their planning that just aren’t convenient for them to consider.

Bore ‘em to Death Award If you can’t convince ordinary intelligent people with actual facts & truth, & can’t even fool ‘em with all your fancy acronyms & technical language, BORE THEM TO DEATH with your monotone recital of boring & unbelievable bullshit. Bleah bleah bleah bleah bleah… (I swear, if there had been a boredom thermometer in the room, it would have burst its containment vessel when OPG presenters were doing their bit. I’m pretty sure I heard the snort of someone caught out snoring…)

Cognitive Dissonance Award for spewing verbal bafflegab that is way-way-way off the charts of anything resembling truth & accuracy – all the while maintaining a straight face as you do it.

Creative Language Creation Award for terms like PPE (see above) & phrases such as “credible accident scenario.” The nuclear industry gets away with what amounts to murder by doing their planning for possible disasters by only considering what they call “credible accident scenarios.” The problem, of course, is it’s always the incredible accidents that actually crop up…

Language Twister Award OPG (& their licensing body, the CNSC) are forever claiming to be “open & transparent” when they are anything but. Here’s a beauty they’re using about the Environmental Assessment process & plan for the proposed new reactors at Darlington: it’s a “technology-neutral” plan. You have to have a law degree & a doctorate in Nuclear Industry Bullshit to understand all this nonsense, btw, & I am very upfront about the fact that I have neither. I personally will never be able to “get” how you can call the planning process for nuclear reactors “technology-neutral.” Oughta be more like morality-neutral, if you ask me…

Robust Language Award for bullshitters who seem to think if you simply call something “robust,” that will necessarily not just make it so, but will also make it believable to the most major skeptic. I guess we are all supposed to fall all over these brilliant planners & “just trust them” & their preposterous claims. Gee. If you say it’s robust, then it must be…eh???

The super-duper VACUUM award goes to all the foot soldiers of the nuclear industry who operate in a complete moral & ethical vacuum. That noisy sucking sound you hear is the sound of all moral & ethical considerations of the real consequences of the creation & use of nuclear energy being sucked right out of the room. The world, actually. And, hmmm….also the sound of millions & billions of taxpayers’ dollars being sucked out of all us unwitting citizens.


p.s. Ah, dear Reader. Just think of what could be accomplished if only all the mental & intellectual & spiritual energy...not to mention all those financial resources...wasted in this deadly & immoral industry...were put to use on finding real solutions to the world’s problems….hmmmm??? Kinda breaks a person’s heart to think about it too much, doesn’t it??