“The CNSC is the sole authority in Canada to regulate the development, production and use of nuclear energy, and the production, possession and use of nuclear substances, prescribed equipment and prescribed information in order to prevent unreasonable risk.

CNSC (Canadian Nuclear Safety Commission) Regulatory Fundamentals

What constitutes unreasonable risk? Does manufacturing fuel pellets in an urban area using huge quantities of explosive hydrogen gas constitute unreasonable risk?

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The BWXT facility in Toronto. The white tank shown is approximately 12m in length. It contains 9000 gallons of liquid hydrogen, which is the equivalent of approximately 29, 000, 000 litres of hydrogen gas at 21 degrees C and 1 atmosphere of pressure.

Hydrogen gas is used in the pelleting process to reduce the uranium during the sintering process.

Hydrogen is an explosive gas! "If hydrogen gas mixtures enter confined regions, ignition is very likely and can result in flame acceleration and generation of high pressures capable of exploding buildings and throwing shrapnel."

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This is a closeup view of the liquid hydrogen tank at BWXT Toronto

From the CNSC staff report of Dec 20, 2019 “In January 2017, BWXT reported a minor fire in the Toronto facility. The minor hydrogen jet fire was immediately controlled and extinguished.” How could a fire involving 29 million litres of explosive hydrogen be minor?

Uranium dioxide is also flammable when it is in a powdered form. Fires involving uranium dioxide powder have occurred at nuclear processing facilities before. A fire involving explosive hydrogen and a flammable radioactive powder is an unreasonable risk in a residential area and should never be termed “minor”.

 
In a spectacular accident at an industrial site in Hanau, Germany, the catastrophic failure of a tank with pressurized hydrogen occurred. The 100 m3 cylindrical pressure vessel with a total height of 16 m, a diameter of 2.8 m and a wall thickness of 22 mm was operated with a cyclic change of the inner pressure between 1.5 (“empty”) and 4.5 (“full”) MPa. At the time of the accident, the tank was filled with with 370 kg of H2. The failure of the vessel was caused by a fatigue rupture near a longitudinal welding seam due to accelerated crack growth from H2 embrittlement. The explosion resulted in severe damage within a radius of 1 km
— Safety Considerations on Hydrogen, Karl Verfondern, 2008

A Science Demonstration

The video to the right shows what happens when a few litres of hydrogen and pure oxygen are exposed to an ignition source.

Hydrogen is very explosive - especially when exposed to oxygen.

 
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Hydrogen Explosion at a power plant during delivery

This image shows the damage caused at an Ohio coal fired power station. “The explosion occurred during a routine delivery of hydrogen when a hydrogen relief device failed, which allowed the contents of the hydrogen tank to escape and be ignited by an unknown source.” “The explosion fatally injured the vendor’s driver and also injured 10 others who had been working nearby. The explosion caused significant damage to the unit’s service building, turbine room, and steam generator building.”

Large scale accidents involving hydrogen have happened before. Could this happen in Toronto? If BWXT’s license is granted, could it happen in Peterborough? Is this unreasonable risk?

 
I was after them for 3 or 4 years about the lunch room. We were eating lunch right beside the uranium dioxide pellets in a space with paper thin walls. Finally a guy who worked upstairs in engineering got cancer. They put our lunch room in a portable and lead shielding on the ceiling.
— Jim Dufresne, Union Steward at GE Hitachi Peterborough - a CNSC regulated facility.
 

This video below shows Fukushima Power Station Reactor 3 exploding after hydrogen accumulated and exploded inside the building surrounding the reactor following an earthquake and resultant tsunami. This video should not be conflated with a “hydrogen bomb” and the relationship to nuclear power is coincidental. However, it does demonstrate what happens when engineers fail to design for risks - both known and unknown.

In response to the Fukushima disaster, the CNSC completed a review of safety protocols at nuclear facilities. “CNSC staff also concluded that Class I major nuclear facilities, as well as uranium mines and mills licensees, have demonstrated a strong commitment to nuclear safety. Reviews and safety assessments post-Fukushima demonstrate that these facilities are safe and do not pose any significant risk to the health and safety of Canadians or to the environment.”

Putting a Class I nuclear facility in a densely populated residential area next to a huge hydrogen tank and beside uranium dioxide powder in barrels does not pose any significant risk?

 
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Uranium dioxide powder is finer than flour.

What would happen in the event of an explosion? Could we have a “dirty bomb” in downtown Toronto or Peterborough?

My understanding is that the BWXT facility is continuously monitored and is up to the highest safety standards. I have also been assured that there are no plans to move their pelleting operations to this plant.
— Diane Therrien, mayor of Peterborough - Dec 3, 2019

Why is it necessary for BWXT to manufacture fuel pellets in densely populated areas? Why not manufacture pellets in areas where risks can be minimized?

The following images show some pellet manufacturing facilities around the world. The images are all shown in approximately the same scale. CARN members have been unable to find any other examples of fuel pellets being manufactured so close to residential areas, schools, and hospitals. Can you tell which nuclear regulatory agencies put safety at the forefront?

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Fromatome fuel manufacturing facility in Romans, France. For security, google images are blurred. The areas to the left and above the plant appear to be industrial.

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Westinghouse has a manufacturing facility in rural Britain. Despite its rural location, the Springfields location does have a school nearby. Oakfield House School grounds appear to be more than 200 metres from any buildings that may be associated with fuel production - the distance to Prince of Wales school in Peterborough to BWXT is only 25 metres.

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This fuel manufacturing site in Juzabado Spain clearly demonstrates ENUSA Industries’ commitment to risk abatement.

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Kurihama, Japan - GE- Hitachi’s manufacturing site. In its description of the plant, GE-Hitachi seems to be almost embarrassed that the plant is surrounded by development; “Over the past several decades the area around the plant has transitioned from primarily farmland to a diverse, industrial, mixed-use community with the plant as an important economic engine for the area and region.

The mixed use zoning of this site is evidence of nuclear regulation that was widely discredited after the Fukushima disaster. However, it is worth noting that Japan has one of the highest population densities in the world. Canada has one of the lowest.

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The Swedish version of risk abatement. Unlike the CNSC’s vision of safety, the Swedes put this Westinghouse Vasteras Sweden facility in an industrial park at the edge of town.

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There are three LEU (Low Enriched Uranium) pelleting plants in the U.S.. This GE- Hitachi facility is in Wilmington North Carolina. Almost all of this image is the 1500 acre site dedicated to nuclear manufacturing. GE - Hitachi proudly indicates that putting its facility on 1500 acres is the responsible thing to do; “Also home to our global headquarters, our Wilmington site is nestled on over 1,500 acres.

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Citizens of Columbia, South Carolina are probably grateful that this Westinghouse nuclear fuel plant follows the ALARA principle by locating it responsibly in a remote area. This plant has “a history of leaks, spills and other mishaps.

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Framatome in Richmond, Washington

This is the final image of three U.S. facilities manufacturing Low Enriched Uranium pellets. The U.S. Nuclear Regulatory Commission has required that all pelleting facilities be placed in non -residential areas.

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The CONUAR SA manufacturing plant in Argentina - located in an area dedicated to nuclear facilities.

“We sent three of our best guys to Argentina to work on CANDU fuel and they were all dead of cancer within a year and half.” Jim Dufresne, former Union Steward at GE Hitachi Peterborough - a CNSC regulated facility.

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Cameco’s Port Hope operation - with lots of empty space around, residential housing still abuts this property.

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Toronto BWXT’s plant is located in a densely populated area. Row housing, high rise condominiums and apartment towers surround the site on 3 sides. On the west side, phases 6 and 9 of the “Davenport Village” development will bring over 1000 new residences to this area. Another 2000 units are to be completed across the railway tracks. The CNSC has been oblivious to this changing urban landscape.

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BWXT Peterborough - Future site of fuel pellet manufacturing? The area to the West of the plant is a brownfield caused by toxins dumped during GE’s operations in this city.

Note the dense residential areas around this plant and Prince of Wales Public School junior playground just 25 metres from this facility.

 

Does BWXT need to manufacture uranium dioxide pellets in residential areas? No!

Should BWXT manufacture uranium dioxide pellets in residential areas? No!

...while MP Monsef continues to monitor the re-licensing proceedings intently, it is important to note that neither the Minister of Natural Resources nor the Governor in Council has a role in the CNSC’s decision making or the power of appeal. Its decisions are reviewable only by the Federal Court of Canada
— The office of Maryam Monsef, Member of Parliament for Peterborough, as reported in "The Arthur" Nov 28, 2019

This is not true. Ms Monsef and other Peterborough community leaders have conveniently forgotten the role politicians have played when an “undesirable” decision was rendered by the CNSC. Prime Minister Stephen Harper fired CNSC president Linda Keen when she put safety ahead of any other considerations. She was fired one day before she was scheduled to give testimony before a parliamentary committee about safety issues at a medical isotope production facility. Mr. Harper turned the “independence” of the CNSC into a lie.

It’s time for politicians to tell the CNSC what other nuclear regulators already know - nuclear processing facilities don’t belong in urban settings.

There’s one room - they call it the beryllium room or something. That’s the death sentence. You work in there, you’re dead.
— Roger Fowler, former GE worker describing beryllium braising at GE Hitachi Peterborough - a CNSC regulated facility. CBC Town of Widows