International Institute of Concern for Public Health (IICPH)

1. International Institute of Concern for Public Health (IICPH) Oral Presentation onOPG’s Application for the Renewal of the Operating Licence for Pickering A and B for a five-year term May 30 2013

2. Overview of Presentation • OPG’s Plan • Key Issues • Pickering - Its History and Legacy • Safety • The Economics • Emergency Preparedness • Concluding Remarks

3. OPG’s Plan... • Continue commercial operations of six reactors until the end of 2020 • Critical components in Pickering B’s fuel channels will reach their designed end-of-life from 2014-16 • OPG plans to exceed the designed end-of-life of these critical components

4. Key Issues • The oldest and costliest nuclear station in Canada – history of poor performance, frequent breakdowns • No assurance that exceeding the designed lifetime of the pressure tubes is safe or even possible! • The rupture of any pressure tube would be catastrophic • Just 32 km from Toronto, six million in the GTA • Inadequate and incomplete emergency plans • A disaster waiting to happen!

5. The History and Legacy Pickering A • After only 12 years of operation: • Metre-long pressure tube rupture (Unit 2) • All units were shut down for re-tubing • Other significant incidents (1983-97): • Loss of coolant (near meltdown), tritium releases, flux tilts, malfunctioning of emergency cooling system, etc.

6. The History and Legacy (cont’d) • 1997: All four units shut down – safety issues • Re-tubing required again.. • Expected restart 2001, but • Unit 4 re-started in 2003, shut down again in 2005 for major repairs • Unit 1 re-started only in 2005 • Due to costs and safety concerns • Units 2 and 3 were taken out of service • Decision not to refurbish Pickering B

7. Inadequate Safety Systems • Only one fast emergency shutdown system (unique in the western world) • All eight reactors share the containment system and cooling injection system • Emergency coolant can be provided for only one accident at one reactor • Multiple reactor accidents cannot be dealt with by this system

8. Aging Pressure TubesCreeping, Sagging and Corroding • Prone to aging from weight of fuel bundles, high temperatures, pressure and radiation fields • Over time, tubes increase in length and diameter (creep), walls thin out and sag, and can contact outer calandria tube • Embrittlement of metal walls due to corrosion • Increased chance of rupturing • Steam Generators • Feeder Tubes

9. Pressure Tube Safety • OPG plans to exceed the fuel channel design life of 210,000 EFPH for Pickering Units 5-8 by ~ 18% • There is no guarantee that this is safe. • As stated by the CEO of Hydro-Québec: “I would no more operate Gentilly-2 beyond 210,000 hours than I would climb onto an airplane that does not have its permits and that does not meet the standards. So, it is out of the question to put anyone, i.e. us, the workers, the public, and the company, in a situation of risk in the nuclear realm.” Thierry Vandal, January 2013

10. Further Safety Issues • Steam Generators • Subject to corrosion from pitting • Have never been replaced • Feeder Pipes • Susceptible to wall thinning at outlets (Pickering A in particular) due to decontaminating agents • Removal and replacement of just one feeder pipe would cost ~ $1 million – and could take a year.

11. Health & Safety • Increased exposure of workers to ionizing radiation from increased frequency of repair work and monitoring • Cumulative, synergistic, long-term effects • Potential effects on families, communities • Exposure Limits: allowing 3.2 excess cases of fatal cancer per 100 workers over 40-year career is an unfair burden • “Collective worker dose” obscures the exposure of individual workers

12. Economic Issues • Estimates are always far too low • Hidden costs – breakdowns, replacement power, human health & environment, lengthy delays • Experience with Pickering A alone: • Initial retubing cost more than building the station • Retubing Unit 1 again cost $1 billion – double the estimate • Restarting the reactors – despite a five-fold cost overrun to $4 billion, only two of four reactors were restarted. Long delays caused electricity shortages and increased coal generation.

13. Probabilistic Risk Assessments • Impossible to foresee everything that could cause a serious nuclear accident (human error, malfeasance). • Impossible to determine probabilities of all accident scenarios that are foreseen. • As CNSC staff have acknowledged, a probability has no predictive value for a single event.In a single case anything can happen at any time. No matter how small the probability of a serious nuclear accident, it provides no guarantee of safety.

14. Malfunctions and Accidents • A serious nuclear accident will cause a major disaster – affecting thousands and even millions of people – Chernobyl, Fukushima. • Since Pickering cannot operate without creating this unacceptable risk, which is greater and greater as its plants are pushed beyond their designed lifetimes, public safety requires that it be shut down.

15. Emergency Preparedness If a worst-case scenario accident happened today, are essential emergency measures in place? • Are public alarm systems adequate and fully functioning? • Are evacuation plans able to handle the safe removal and sheltering of possibly millions of people? (A 10 km radius is grossly inadequate) • Are there adequate provisions to provide safe food and water, health care and compensation?

16. Emergency Preparedness • The current state of emergency preparedness is far from adequate, because the danger of a nuclear accident is not being taken seriously. • A lesson from Fukushima: “There was an implicit assumption that such a severe accident could not happen and thus insufficient attention was paid to such an accident by authorities.” Toshimitsu Homma, Japan Atomic Energy Agency IAEA Regulator`s Conference Ottawa, April 2013

17. “Governments and agencies responsible for sanctioning nuclear operations have made a rather odious gamble with human life – potentially resulting in millions of cancer deaths and similar nonfatal afflictions to innocent bystanders, many of whom have not even been born. This is discounting the value of an untold number of human lives. Future generations will be forced to take man-made risks that have nothing to do with their well-being.” Benjamin Goldman “Discounting Human Lives”

18. ConcludingRemarks To keep Pickering going by exceeding designed safety limits is not an option. It is very dangerous, extremely costly, and totally unnecessary. It prevents the use of safer, cleaner energy. IICPH urges the Commission to reject OPG’s proposal for a 5-year renewal and instead, issue a temporary licence with instructions to prepare for closing Pickering by the end of 2014.