Sustainable Energy Group
C/O Sam Arnold
110 College Street
Woodstock, N.B. E7M 1K6
506-328-9420
November 14, 2011
Secretary of the Commission
C/O Louise Levert, Sectretariat
Canadian Nuclear Safety Commission
280 Slater Street, P.O. Box 1046
Ottawa ON, K1P 5S9
interventions@cnsc-ccsn.gc.ca
Re: Submission to Day 2 Point Lepreau Hearings
December 1 and 2, 2011
Request both written and oral presentations
Dear CNSC President Binder:
The Sustainable Energy Group would like to bring your attention to two concerns that we have with the re-licensing application by New Brunswick Power Nuclear (NBPN) for the Point Lepreau Generating Station, and to offer a solution to what we consider to be unsafe and very risky nuclear power.
1. Risk and Safety. There is risk in everything we undertake. Insurance companies and risk managers in business analyze risk logically in terms of potential financial costs. They consider the odds of something disastrous happening in relation to the cost of possible consequences. If the risk of a venture is greater than the expected monetary gain, then the venture is not worth underwriting. No insurance company will insure a nuclear power plant because the cost of the potential damage from catastrophic failure cannot be projected with any degree of accuracy. The scale of potential damage and the length time over which such damage will continue simply cannot be calculated. There is no rational framework for underwriting this risk.1
New Brunswick Power Nuclear’s re-licensing application for the Point Lepreau nuclear generating facility comes with this kind of incalculable risk. We understand that each nuclear power plant in Canada is required to carry a token liability insurance of $75 million through a pooled arrangement.2 Beyond that, governments – i.e. taxpayers – are on the hook for the incalculable cost of plant failure.
Even without considering the potential costs of failure, re-licensing the Point Lepreau plant is not a rational undertaking. The plant has very little equity and will be unlikely to bring in sufficient earnings to meet operating costs over the next 30 years – if it will even be able to operate that long. It operated only 23 years of the expected 30 before requiring refurbishing.
Experience with nuclear power has now given us the basis on which to project the likely incidence of plant failures. Approximately 450 nuclear power generation facilities have been constructed worldwide and three have catastrophically failed – Three Mile Island, Chernobyl and Fukushima. The odds of nuclear plant failure is, therefore, about 3 in 450, or 1 in 150. One failure in 150 multiplied by the magnitude of the consequences is an unacceptable risk for nuclear energy – a risk that no insurance company can cover, and that the governments of New Brunswick and Canada can’t afford either.3
The consequences of those three failures have varied from extremely expensive to unimaginable. Three Mile Island was contained without exorbitant human or environmental damage, so the main consequence was a multi-billion dollar cleanup lasting 14 years, and damage to the reputation of the nuclear industry.
Chernobyl, on the other hand, took directly at least 31 human lives in the short term, plus hundreds of related deaths and thousands of serious health conditions through cancer and birth defects over the next twenty-five years. This disaster also made a large area virtually useless for human habitation, agriculture or industry. Twenty-five years after this human caused accident the final report is still far away from being written. However, the financial cost has been estimated to be well over $235 billion US dollars with an incalculable cost in lost lives, lost health and lost land.
With the Fukushima disaster it’s still far too early to determine all of the consequences associated with it. Present indications point to the consequences being similar to that of Chernobyl, but perhaps far worse, due to high levels of nuclear contamination for many humans and all other life forms in densely populated Japan, and for marine life in the Pacific Ocean.
This has brought into sharp focus what the potential need for Point Lepreau is to the province, versus the possible risk. Over the past two years NB Power has managed to meet its electricity requirements very well without Point Lepreau operating. NB Power probably can continue importing power at a lower cost than it will incur by operating the plant, making the need to re-start Point Lepreau highly questionable. The cost of imported power from Quebec and Maine today is around 5 cents per kwh, less than the cost of power produced at Point Lepreau. The need for the plant can’t therefore be justified on either economic or rational risk assessment grounds.
The lessons of Fukushima and Chernobyl must now be included, along with all the other criteria used in the CNSC re-licensing application, to determine if Point Lepreau should be re-licensed for service. In addition to meeting all the other safety requirements, the CNSC must carefully consider whether today nuclear power represents a risk that is too great for the people of New Brunswick, New England, and Canada to continue living with.
It is important to note that the understanding of risk that New Brunswick accepted when Point Lepreau was first licensed in 1982 was prior to the two very serious accidents named above. Careful consideration must therefore be given to the lessons now being learned, and the price being paid, for those two catastrophic nuclear disasters. Both the Chernobyl and the Fukushima disasters have proven that unanticipated natural events combined with human miscalculations and operational errors makes nuclear power far too dangerous and costly regardless of its safety record. Even one more such accident is too many, and more are likely to occur.
Point Lepreau provided only about 30 per cent of the electricity in New Brunswick, when operating, and even with subsidized funding it’s output still cost almost 11 cents per kwh prior to refurbishment. Nuclear power therefore can no longer be justified as being economical or worth the risk.
The New Brunswick Energy and Utilities Board recommended quite correctly in 2002 that “there is no significant economic advantage to the proposed refurbishment” of Point Lepreau and that “it is not in the public interest.” Indeed, Point Lepreau has never been in the public interest because it can’t be brought within a rational risk assessment framework, and it has never been cost effective.
These two realities have never been made transparent to the citizens of New Brunswick, even though we are on the hook for subsidies and the potential costs of nuclear plant failure. If the Lepreau plant is re-licensed, these realities will again be glossed over and both the safety of citizens and the fiscal security of the province will be placed at unnecessary and incalculable risk.
2. Backup generators. Another imminent safety concern comes from NASA4 and a number of scientists, who have calculated the emergence of super solar storms with unprecedented levels of magnetic energy in 2012 to 2013, right after Point Lepreau is scheduled to return to service. The solar flares could potentially destroy key transformers in the grid, thereby knocking out electric power for a prolonged period of time in affected regions. This could be a catastrophic event for everyone and everything requiring electricity.
It is possible that a situation similar to Fukushima could occur at Point Lepreau if electric power is lost for a considerable period of time and the backup generators fail, or if they run out of reserve diesel fuel. Nuclear reactors require external electricity to operate and they automatically shut down when a power failure occurs at the plant. The backup generators must start up immediately to keep the reactors and the spent fuel storage bays from overheating. However, oil refineries also require electricity to operate. If refineries fail and grid infrastructure goes down – on which the transportation of stored fuels depends as well – the back up systems required to keep the reactors cooled may be unable to function.
This, admittedly, is a nightmare scenario. No one in the nuclear industry ever thought it could happen. But it did happen at Fukushima and it is still not under control. Industry leaders have openly admitted the technology to deal with what is happening at Fukushima simply doesn’t exist and may not even be possible to create. No one ever imagined the need for it.
The worst having now happened, we must obviously understand, it could happen again. The solar flare scenario is not far-fetched. It can be argued that the odds of such an event are very long. But the question is, is the risk of what could happen to nuclear plants in this situation worth taking? After Fukushima, the answer is clearly, “No!” The risk is too great.
Our question for the CNSC is this; what contingency plans are presently in place should there be a major electrical power interruption lasting weeks, or months, at any and all of the nuclear power plants in Canada?
3. Alternative Energy. There are far safer, cleaner and more affordable alternatives to nuclear power. The world must earnestly begin to slow down global warming and the accelerating rate of climate change resulting from the mining and burning of fossil fuels by developing safer and sustainable renewable energy sources. It has become urgent that both nuclear and fossil fueled power plants be replaced as soon as possible. This can be achieved by a) developing locally generated, decentralized, and distributed renewable energy, b) by reducing electricity use through energy efficiency, and c) by eliminating wasteful use. This is what the Sustainable Energy Group argued for in our submissions to the provincial government’s Energy Policy Commission earlier this year concerning the future of NB Power.
We asked that research and development money be redirected from the nuclear and fossil fuel industries into renewable decentralize energy in order to give New Brunswick, and other jurisdictions, greatly improved odds against fiscal and ecological ruin in the next two to three decades. Many of the jobs that will disappear if Point Lepreau is decommissioned will be offset by many new high skilled jobs in renewable energy. Both private and public funds must be channeled into renewable energy soon. These need to be transparent and have effective mechanisms to prevent waste and corruption from gaining any advantage.
To conclude, nuclear power is not safe, not sustainable, not economically viable, and is not affordable in New Brunswick, or anywhere for that matter. In the interest of healthier and safer lives for everyone in the future we ask that Point Lepreau be denied a license to operate by the CNSC. Instead, we ask that the decommissioning process of the power plant begin as soon as is safely possible. Point Lepreau will have to be decommissioned sooner or later anyway, so there’s no advantage in putting it off and continuing to run the risk of safety and fiscal catastrophe when there is no energy supply or economic argument to be made for it. Decommissioning Point Lepreau would be a big step in the direction of safer and cleaner energy in New Brunswick.
Sincerely,
The Sustainable Energy Group – Carleton Chapter
References
1. www.pittsburghlive.com/x/pittsburghtrib/business/s_734814.html (Link unavailable November 2018)
The cost of a worst-case nuclear accident at a plant in Germany has been estimated to total as much as $11 trillion, while the mandatory reactor insurance is only 3.7 billion.
“The 3.7 billion will be just enough to buy the stamps for the letters of condolence,” said Olav Hohmeyer, an economist at the University of Flensburg, who is a member of the German government’s environmental advisory body.
The insurance in Germany costs utilities $0.015 cents per kilowatt hour of electricity, a tiny part of the final cost for customers of about 33 cents, according to Bettina Meyer of think tank Green Budget Germany in Berlin. But insuring the full risk would amount to a prohibitive extra cost of about $3 per kilowatt hour.
“If you take all external costs into account, the conclusion is inevitable: Nuclear power is not economically viable,” Hohmeyer said. “The risk is only bearable if you externalize it on the wider society.”
But Dieter Marx, of Germany’s Nuclear Forum, an industry lobby, says no industry has prices reflecting all of its risks, adding that the risk of a meltdown was very low.
“Ultimately, it comes down to the question of how big a risk the society is ready to bear,” he said.
The majority of Germans and the political parties have concluded that the potential damage outweighs the benefits, and the country now stands alone among industrialized nations in its determination to overcome nuclear power.
In Canada the Nuclear Liability and Compensation Act is also in line with the international conventions and establishes the licensee’s absolute and exclusive liability for third party damage. Suppliers of goods and services are given an absolute discharge of liability. The limit of C$75 million per power plant set in 1976 as the insurance cover required for individual licensees was increased to $650 million in the Act’s 2008 revision, though this has not yet passed. Cover is provided by a pool of insurers, and claimants need not establish fault on anyone’s part, but must show injury. Beyond the cap level, any further funds would be provided by the government.
3. The Economics of Nuclear Power (PDF)
Pat McNamara: As nuclear reactors cannot be insured, taxpayers are responsible for all accident costs over $75 million. Sandia Laboratory estimated 50,000 deaths and $666 billion (2007 dollars) in damages from a worst-case nuclear accident. Homeowner insurance does not cover nuclear accidents.
4. www.telegraph.co.uk/science/space/7819201/Nasa-warns-solar-flares-from-huge-space-storm-will- cause-devastation.html (Link unavailable November 2018)
NASA warns solar flares from ‘huge space storm’ will cause devastation. Senior space agency scientists believe the Earth will be hit with unprecedented levels of magnetic energy from solar flares after the Sun wakes “from a deep slumber” sometime around 2013, The Daily Telegraph can disclose.
In a new warning, NASA said the super storm would hit like “a bolt of lightning” and could cause catastrophic consequences for the world’s health, emergency services and national security unless precautions are taken.
Scientists believe it could damage everything from emergency services’ systems, hospital equipment, banking systems and air traffic control devices, through to “everyday” items such as home computers, iPods and Sat Navs. [satellite navigation]
Due to humans’ heavy reliance on electronic devices, which are sensitive to magnetic energy, the storm could leave a multi-billion pound damage bill and “potentially devastating” problems for governments.
“We know it is coming but we don’t know how bad it is going to be,” Dr Richard Fisher, the director of NASA’s Heliophysics division, said in an interview with The Daily Telegraph.
“It will disrupt communication devices such as satellites and car navigations, air travel, the banking system, our computers, everything that is electronic. It will cause major problems for the world.
“Large areas will be without electricity power and to repair that damage will be hard as that takes time.”
Dr Fisher added: “Systems will just not work. The flares change the magnetic field on the earth that is rapid and like a lightning bolt. That is the solar affect.”
A “space weather” conference in Washington DC last week, attended by Nasa scientists, policy-makers, researchers and government officials, was told of similar warnings. While scientists have previously told of the dangers of the storm, Dr Fisher’s comments are the most comprehensive warnings from NASA to date.
Dr Fisher, 69, said the storm, which will cause the Sun to reach temperatures of more than 10,000 F (5500C), occurred only a few times over a person’s life. Every 22 years the Sun’s magnetic energy cycle peaks while the number of sun spots – or flares – hits a maximum level every 11 years.
Dr Fisher, a NASA scientist for 20 years, said these two events would combine in 2013 to produce huge levels of [ electromagnetic] radiation.