Deep Geologic Repository Joint Review Panel Commission dexamen conjoint du projet de stockage dans des couches gologiques profondes

PMD 14-P1.10

File / dossier : 8.01.07 Date: 2014-06-27 Edocs: 4466455

Written Submission from

Frank Greening

In the Matter of

Ontario Power Generation Inc.

Mmoire de

Frank Greening

lgard de

Ontario Power Generation Inc.

OPGs Deep Geological Repository (DGR) Project for Low and Intermediate Level Radioactive Waste

Installation de stockage de dchets radioactifs faible et moyenne activit dans des couches gologiques profondes

Joint Review Panel

September 2014

Commission dexamen conjoint

septembre 2014

To: Dr. S. Swanson, Panel Chair Deep Geologic Repository Project Canadian Environmental Assessment Agency 160 Elgin St., 22nd Floor Ottawa, ON KIAOH3

Dear Dr. Swanson,

June 25111, 2014

Received CEAA NCR

~~ 2 7 2014 Re~u

ACEE RCN

While J am aware that Public Hearings on OPG's proposed Deep Geological Repository are scheduled to be held in Kincardine in September of this year, I have an issue I wish to raise immediately with the DGR Review Panel because it reveals a major problem with the current methodology used by OPG to prepare its safety assessment for the DOR Project.

The issue in question is embodied in Section 4.3 of Attachment B ofOPG's Response to JR-EJS-13-514, that was published in May 2014. This EIS document is itself an addendum to NWMO Report DGR-TR-201 1-07 entitled Malfunctions, Accidenls and Malevolenl Acts Technical Support Document, issued in March 2011.

I would Jike to focus particular attention on the malevolent act described as "Scenario (d)" in Section 4.3 ofOPG's Response to JR-EIS-13-514 in which a TNT equivalent of 160 kg of an explosive or incendiary device is detonated in close proximity to a pressure tube waste container in a DGR. To analyse the consequences of such an event OPG uses the following approach:

The consequence of an explosion may be estimated based on experimental data on the fragmentation of me/a/ from a pressure impulse directed outward through the material. The experimental data correlates lhe airborne release fraction (ARF) and respirable fractio.n (RF) to the ratio of inert mass to the mass of high explosive, specifically, the TNT-equivalent mass, referred to as the mass ratio. The reference data provides estimates for mass ratios up to 24.

This approach and the experimental data used by OPG are taken from the U.S. NRC publication "Nuclear Fuel Cycle Facility Accident Analysis Handboolf', Report No. NUREG/CR-6410, issued March 1998. Unfortunately, OPG fails to recognize that this NUREG Report considers two types of explosive detonations - those involving "reactive" metals such as plutonium, and those involving "inert" metals such as molybdenum. Now as described in the U.S. DOE Handbook 1081-94, certain metals, notably magnesium, titanium, sodium, potassium, lithium, zirconium, hafuium, calcium, zinc, plutonium, uranium, and thorium, are pyrophoric or spontaneously combustible because of the ease of ignition when they reach a high specific area ratio (thin sections, fine particles, or molten states).

T11at zirconium exemplifies this behavior has been amply demonstrated by numerous scr.called .. Spent Fuel Sabotage Tests" carried out at Sandia National Laboratories in the U.S. These tests were designed to quantify and characterize aerosol particles produced in credible sabotage events involving a nuclear waste storage container. Zircaloy-clad fuel was used in many of these tests and the debris produced by the

These omissions of crucial safety-related information make me wonder if the authors, reviewers or approvers ofOPG's Assessment Reports have appropriate qualifications and experience in subject matter areas related to the chemical properties of wastes slated for emplacement in a DGR. Interestingly, it was CEAA's DGR Co-Manager, Ms. Debra Myle~, who posed a similar question to the CNSC in March 2012, namely: "What areas of expertise are needed for a DGR project review?-" The CNSC responded with a list of over seventy subject matter areas of specialization where expertise would be expected. Conspicuous by their absence from CNSC' s list are expertise in organic and inorganic chemistry, polymer degradalion, explosives and energetic materials or chemica/.Joxicology! This is most unfortunate because, in a matter as important to the citizens of Ontario as the Jong-term safety of a nuclear waste repository in Kincardine, we cannot afford to base our safety assessments on the "say-so" of a few engineering graduates and computer modellers who, together with the CNSC, are demonstrably lacking in basic knowledge of the potential chemical hazards lurking in a DGR.

In concluding this letter I feel compelled to comment on the current situation at the Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico, which has often been touted as a role model for a well operated and "safe" nuclear waste repository. In April of this year, the U.S. Department of Energy (DOE) announced that there will be "significant changes" at WIPP after two accidents in February exposed flaws in the site's safety implementation methods. The DOE Accident Investigation Report, issued April 22nd 2014, noted that although the cause of these accidents is yet to be determined, the following preliminary assessment can be made:

The Documenled Safety Analysis and Technical Safety Requirement have several e"ors or omissions Iha/ are indicative of lack of rigorous contractor internal review and independent peer-review processes for lhe development of the safety basis, e.g., quality issues include Documented Safety Analysis and Technical Safety Requirement errors, lack of Documenled Safety Analysis linkage to supporting hazard analysis information, etc.

NWP (fhe Plant Operator) needs Jo commission an independent assessment of the Documented Safety Analysisffechnical Safety Requirement Revision 4 Jhrough corporate assistance or other recognized external resources, and corrective actions implemented that establish appropriate hazard controls and functional classifications.

Dr. Swanson, I certainly hope that the DGR Review Panel will work to ensure that "significant changes" and "co"ective actions" will also be implemented with regard to OPG's safety assessment methods. lam making this request because the present approach, whereby OPG contracts out vitally important safety analyses to its nuclear industry "friends", regardless of their obvious lack of competency in key subject matter areas, reminds me of an old saying from The Upanishad:

"Abiding in the midst of ignorance, thinking themselves wise and learned, fools go aimlessly hilher and thilher, like blind men led by the blind."

Sincerely, '

Dr. F. R. Greening

c.c. Dr. M. Binder, CNSC