Waterkeeper's presentation to the CNSC, Darlington Refurbishment hearing

On December 3, 2012, the Canadian Nuclear Safety Commission initiated a four-day hearing into the Darlington Nuclear plan refurbishment project. Lake Ontario Waterkeeper was one of the first public presenters to speak. Our presentation notes are below (check against delivery).

Good afternoon Members of the Commission; Mr. Chair.

I’m Joanna Bull, Counsel for Lake Ontario Waterkeeper.

I’m here today because OPG wants to refurbish and operate Darlington for another 40 plus years. Instead of upgrading to modern cooling technology, OPG wants to keep using its outdated once-through cooling system. There is a long list of problems with OPG’s proposal, but we only have 10 minutes today and so I’m going to get right to the point.

Darlington kills fish - lots of them - and it doesn’t have to. If it continues to kill fish for the next forty years, it will only be because you chose to let it.

When Darlington was built in the 1980’s, once through cooling technology was already out of date. The last time it could have been described as “cutting edge” was in the 1940’s when it was first built to cool a Canadian reactor in Chalk River. When it came to building Darlington, OPG only made minor changes to the design, keeping to once-through cooling and the status quo. Now, it’s 2012, and they tell us they want to do the same thing again. By the time a refurbished Darlington is decommissioned in 2055, once-through cooling technology will be more than 100 years old and wildly out of step with modern standards.

Darlington is one of the largest nuclear power plants in North America. The plant has an outdated open cycle, or “once-through” cooling water system. It’s the most destructive cooling technology option available. It kills fish and it wastes water.

• The system at Darlington pumps so much water that it can drain an Olympic swimming pool in 15 seconds.
• Continuously pulling that much water out of Lake Ontario kills tens of millions of fish, larvae and eggs every year.
  • The number of fish impinged and entrained by Darlington is going up rapidly and dramatically.
  • This include swarms of small fish that are the foundation of the lake’s food chain, endangered species like the American eel, and commercially important and ecologically vulnerable species like the round whitefish.
  • After all that water is used only once, instead of cooling it and reusing it, it is wasted. It’s spit back out into the lake. What’s more, it goes out at a higher temperature, harming more fish and destroying more habitat in the process.

There is no need for all this waste. We’ve provided extensive independent evidence that shows OPG can install modern cooling water technology at Darlington. They would save up to 95% of fish and use a fraction of the water.

You have reports in front of you from Dr. Peter Henderson, Bill Powers, and Sharon Khan that show once-through cooling is out of step with modern industrial cooling standards, that the massive fish kills at Darlington are unnecessary, and that the choice to stop killing fish is yours.

This has been well-established in the United States for decades. Super Law Group in New York was integral to that country’s transition to modern standards. Edan Rotenberg from Super Law is here to speak to what’s accepted practice on the other side of our Lake and throughout the rest of North America.

Edan Rotenberg:

It is very easy to not kill fish.

The current standard for industrial cooling systems is closed cycle.

By the 1980s, building closed-cycle cooling systems into new power plants was already a standard industry practice. Voluntarily, the power industry almost completely stopped building new power plants with once through cooling systems. In 2001, the US EPA made it official; by law, closed-cycle cooling was deemed to be the best technology available for virtually all new power plants.

What about older power plants like Darlington?

Since 2004, the power industry trend toward closed-cycle cooling has been accelerating. When older power plants reach decision points where their owners need to make massive capital investments, U.S. regulators have been requiring those investments to include a conversion to closed-cycle.

The most recent such decisions include:

Brayton Point and Mirant Canal in Massachussetts; Merrimack in New Hampshire; E.F. Barrett and Indian Point in New York; NRG Indian River Unit 3 in Delaware; and Oyster Creek in New Jersey.

The California State Water Resources Control Board has a policy that will phase out the use of once-through cooling systems at the state’s 19 coastal power plants.

New York adopted a similar policy in 2011. The policy “identifies closed-cycle cooling or the equivalent as the performance goal for each plant".

It is environmentally beneficial and very cost effective to protect fish.

The benefits of using a closed-cycle system are clear: It is better for the environment and it is better for the reliability of the power system.

We have long known that cooling towers save a lot of fish. Closed cycle cooling reduces water use by around 97.5%. It saves 97.5% of fish. Nothing else is this effective, nothing else even comes close.

While deep offshore intakes, like those at Darlington, provide some reduction in fish kills compared to a shoreline intake like the one at Pickering, cooling towers are 3 times more effective than deep offshore intakes at reducing fish kills.

Darlington kills about 18,000,000 fish of all life stages.

Some of the fish species that would benefit from decreased fish kills at Darlington are extremely vulnerable at the moment. These species include the sculpin, the round whitefish (a species of concern to EC and the Ontario government), and the threatened American eel.

Not only does closed cycle cooling save fish and water, it increases the reliability of our electricity system.

Power plants with once-through cooling are vulnerable in extremely hot weather, and not just in drought stricken areas. This August, the Millstone nuclear power plant in Connecticut had to shut down a reactor because the once-through cooling system couldn’t handle the summer heat.

Because of climate change, that kind of extreme heat and seasonal warming effect is expected to become increasingly common over the planned lifetime of the Darlington reactors.

Darlington is a very strong candidate for a closed-cycle cooling retrofit. The report before you from Power Engineering shows that a closed-cycle cooling system would be effective at Darlington, technically feasible, and cost-effective:

• Darlington has ample space to build cooling towers, even if the new build goes ahead.
• The refurbishment will require multi-year outages at each reactor, so a closed-cycle cooling retrofit would have no impact on power output.

There is no need for Darlington to kill fish; replacing the existing once-through cooling system with a closed-cycle cooling system that saves millions of fish, including endangered and vulnerable species, is affordable and entirely feasible.

Joanna Bull:

OPG and CNSC Staff agree that readily available technology would save fish on Lake Ontario. Yet, when Waterkeeper asked for a more thorough review of the proposal; when we asked OPG and CNSC staff to seriously consider closed cycle cooling, our request was denied. The CNSC said no to a full hearing, based on science, with testimony from experts under oath and public participation. Instead, we got these 10 minutes.

We asked you to look seriously into closed cycle cooling at Darlington. You chose not to.

We stepped in and did that review for you. We brought you facts, based in science and expert evidence. CNSC staff say they would rather wait and see.

How bad does it have to get before you decide to act?

OPG and CNSC Staff cannot bury their heads in the sand and pretend they don’t understand the choice and what’s at stake here. The choice is simple: Kill fish and waste water at Darlington - or don’t.

If a major refurbishment happens, it’s easy to bring Darlington into the modern age by installing closed cycle cooling. Now is the time to do it, but it’s a small window of opportunity. If you fail to act now, when it’s easy, what are the chances you’ll shut the whole plant down to fix the problem later?

The truth is, if you approve a plan to refurbish Darlington without updating the cooling water system, we will be stuck with outdated technology that kills fish on Lake Ontario for decades. This isn’t the 1940’s. No one will say you didn’t know any better. No one will say you didn’t have the means to save water and fish; only that you didn’t have the will.