SECTION 2

Hazards associated with the Cernavoda 2 NPP that may have transboundary significance, but which are not adequately treated in the ICIM Cernavoda 2 Environmental Impact Summary.

By Gordon Edwards, Ph.D., President
Canadian Coalition for Nuclear Responsibility on behalf of the International Fact-Finding Mission on Cernavoda 2
(January 2003)

The present paper has been submitted to Dipl. Eng. Manoela Georgieva, Deputy Minister of Environment and Water of Bulgaria on March 10th, 2003, as requested by her office during a meeting with representatives of Campagna per la riforma della Banca mondiale in Sofia on January 18th, 2003. The submission to the Bulgarian government meant to contribute to its evaluation of the environmental information about the controversial Cernavoda-2 NPP project made available to it upon explicit request by Romanian authorities under the provisions of the UN/ECE Espoo Convention on EIA in a Transboundary Context. The paper has been transmitted, along with other NGO submissions, to Romanian authorities in April 2003.

CANDUS and Catastrophic Accidents

First and foremost, it is important to note that CANDU reactors are by no means immune from the threat of catastrophic accidents.  In what follows, we call your attention to several official Canadian documents dealing precisely with this point.  In the event of such an accident, large quantities of radioactive materials can be released into the atmosphere and can travel for many hundreds of kilometers, contaminating land, buildings, food, and water supplies through radioactive fallout.

Since 1978, when the first of these official documents was published in Canada (A Race Against Time, the report of the Ontario Royal Commission on Electric Power Planning dealing specifically with Ontario's nuclear reactors), there have been no new orders for nuclear reactors anywhere in Canada, nor are there any plans for building more CANDU reactors by any public utility in any of the provinces or territories of Canada.

Potential for Transboundary Effects

Members of the International Fact-Finding Mission on Cernavoda-2, which visited Romania in January 2003, were stunned when told by officials of the Environmental Protection Agency that they considered transboundary impacts from the Cernavoda-2 reactor to be impossible.  At the same meeting, the head of the Romanian nuclear regulatory agency insisted that transboundary effects are not relevant because, he said, "we have a containment structure; we have a one-kilometer exclusion zone."

The naiveté of these comments is chilling.  Contrast them with the published findings of the Ontario Royal Commission of Inquiry Into Electric Power Planning: "All operating nuclear reactors accumulate in their cores, as we have indicated, a large quantity of radioactive material. For the most part this is made up of fission products, many of which are short lived and usually very radioactive, and the actinides (e.g. plutonium-239) which are very long lived and highly toxic substances.

"By definition, a major reactor accident would lead to the severe overheating, and subsequent melting, of the nuclear fuel, which would give rise to a substantial quantity of radioactive material escaping, after breaching several formidable barriers, into the environment.

"The major health and environmental threat would be due to the escape of the fission products to the atmosphere. The most important of these are caesium, ruthenium, tellurium and the fission gases, iodine, krypton and xenon.

"... If a substantial quantity of radioactivity were to be released to the atmosphere, the radioactivity would collect in a "cloud" and would be carried down wind.

"... At distances of two or three kilometres depending on wind velocity, the cloud would begin to disperse (the dispersal zone could extend to distances of several hundred kilometres) and radioactive materials would be deposited on the ground. In consequence, both prompt and latent cancers would be produced.

"... When we talk about the safety of a nuclear reactor, we are referring essentially to how effectively the fantastic amount of radioactivity contained in the reactor core can be prevented from escaping into the ground and atmosphere in the event of major malfunctions.

"Clearly, if a major release of this accumulated radioactivity occurred, as discussed in the previous section, the consequences would be extremely serious and could involve several thousand immediate fatalities and many more delayed fatalities."

A Race Against Time, pp. 73-76
Ontario Royal Commission on Electric Power Planning, 1978

Evidently, severe accidents in CANDU reactors -- which by definition are fuel-melting accidents -- do carry with them a potential for serious transboundary effects.

In answer to direct questioning from members of the Fact-Finding Mission, Romanian officials confirmed that the six cases of "severe accidents" listed on page 133 of the ICIM EIA Summary do involve fuel melting.  Nevertheless, there is no acknowledgment or discussion of transboundary effects -- nor, for that matter, even of local environmental contamination resulting from such accidents.

Attitudes and Perceptions

Following the Three Mile Island (TMI) accident, the Select Committee on Ontario Hydro Affairs -- an all-party committee of the Ontario Legislature -- held public hearings on the hazards of CANDU reactors. From its 1980 Report on this matter:

"It is not right to say that a catastrophic accident is impossible.... The worst possible accident . . . could involve the spread of radioactive poisons over large areas, killing thousands immediately, killing others through increasing susceptibility to cancer, risking genetic defects that could affect future generations, and possibly contaminating large land areas for future habitation or cultivation."

The Safety of Ontario's Nuclear Reactors, pp. 9-10, Select Committee on Ontario Hydro Affairs, 1980.

None of the Romanian officials we met recognized these threats as credible in the context of the Cernavoda 2 NPP.  Indeed, they seemed bewildered that we would even raise such questions.  In effect, they were telling us that catastrophic accidents are impossible.  Such an attitude of denial, based on ignorance or not, is dangerous.

Following the Three-Mile-Island (TMI) accident in 1979, US President Jimmy Carter ordered a special Presidential Inquiry into the causes of the TMI accident.  The Commission found that attitudes of denial on the part of the regulators and operators of nuclear power plants, preventing them from appreciating the danger,  was one of the most important factors contributing to the severity of the accident.

"OVERALL CONCLUSION

"In announcing the formation of the Commission, the President of the United States said that the Commission 'will make recommendations to enable us to prevent any future nuclear accidents.'  After a six-month investigation of all the factors surrounding the accident and contributing to it, the Commission has concluded that:

"to prevent nuclear accidents as serious as Three Mile Island, fundamental changes will be necessary in the organization, procedures, and practices -- and above all -- in the attitudes of the Nuclear Regulatory Commissi         on and, to the extent that the institutions we investigated are typical, of the nuclear industry."  [emphasis in original]\

"... the belief that nuclear power plants are sufficiently safe ... must be changed to one that says nuclear power is by its very nature inherently dangerous, and, therefore, one must continually question whether the safeguards already in place are sufficient to prevent major accidents."

The Need For Change - The Legacy of TMI, pp. 7 and 9,
Report of the President's Commission on the Accident at Three Mile Island, 1979.

Positive Void Coefficient of Reactivity

There is one outstanding feature of the Cernavoda 2 design that makes it particularly vulnerable to serious accidents, including meltdowns.

Instead of containing all the nuclear fuel in one large vessel, CANDU reactors house the fuel in hundreds of separate "fuel channels" each enclosed in its own individual "pressure tube".  In this regard, CANDU is similar to the Chernobyl reactor design.

It is well known that such "pressure tube" reactors all share a dangerous characteristic known as "positive void coefficient of reactivity".  In plain English, the positive void coefficient means that whenever there is a loss of coolant in one or more channels of the reactor core, there is an immediate power surge.  This compounds the accident, for if the power surge is not immediately  dealt with -- within seconds -- the core could self-destruct quite violently, and the resulting energy release could breach the containment, providing a pathway for radioactivity.

The world's first severe nuclear accident took place in Chalk River Ontario in 1952, when the Canadian NRX research reactor (a precursor of the CANDU ) suffered a loss-of-coolant.  It was accompanied by a power surge, due to the positive void coefficient, and the control rods were unable to stop the fission reaction.  This precipitated a series of explosions (either steam explosions or hydrogen gas explosions, no one is certain) powerful enough to fling the four-ton gasholder dome through the air and destroy the core of the reactor.  The damaged NRX reactor core is buried somewhere on the Chalk River site.

In 1969, in Switzerland, the Lucens reactor -- another pressure tube design -- exploded inside a rocky cavern when a loss-of-coolant accident (LOCA) provoked an uncontainable power surge; the reactor was totally destroyed.

The pressure-tube design of the ill-fated Chernobyl reactor was an important factor contributing to the sudden surge in power and heat -- brought on by the positive void coefficient -- that led to the melting of the core and the explosive penetration of containment in the accident of 1986.

The positive void coefficient of reactivity is a generic design flaw of all pressure tube reactors; it is one of the worrisome characteristics of the Cernavoda 2 reactor.

Probability of Meltdown in CANDU Reactors

On page 133 of the ICIM Cernavoda 2 NPP Environmental Impact Summary, one reads of "severe accidents that are not considered in the design because their probability is lower than 10-7 events per year."  Thus ICIM claims that severe accidents in CANDUs would occur less than once in 10 million reactor years!

These probability estimates are simply not credible.

In 1974, the US NRC (Nuclear Regulatory Commission) published its 12-volume Reactor Safety Study (commonly known as "The Rasmussen Report") .  The report concluded that the probability of a complete core meltdown is about  1  in  20,000  per reactor per year.  That is already  500  times greater than the ICIM estimate for the probability of a "severe accident" at Cernavoda 2 with (according to ICIM) no serious environmental consequences worth mentioning.

One of the major findings of the Rasmussen Report was that small pipe breaks, rather than large pipe breaks, are the most significant contributors to the probability of a core meltdown in a nuclear reactor.  Because of its "pressure tube" design, the CANDU reactor has a great deal more small piping -- even in the primary cooling system -- than other reactor types.  Thus the probability of a small pipe break in a CANDU reactor is significantly higher (one or two orders of magnitude more) than the probability of a small pipe break in an American light-water reactor.

Thus the probability of a core meltdown in a CANDU reactor such as Cernavoda 2 may well be higher than the probability of such an accident in an American Light Water reactor.  Indeed, that was one of the conclusions reached by the Ontario Royal Commission on Electric Power Planning in its 1978 Report about Nuclear Power in Ontario, as seen in the following excerpt:

"During normal operation, not only is a great deal of radioactivity created in the reactor core but also a great deal of thermal energy.  If the shutdown system fails to operate in response to a fuel temperature rise, caused by a major rupture in the primary coolant circuit, a rapid escalation of heat and temperature would occur. The purpose of the ECCS  [Emergency Core Cooling System]  is to remove the heat from the core as rapidly as possible.

"If, however, both primary coolant and emergency coolant fail there would probably be partial or complete melting of the reactor core.  An uncontained complete core meltdown would almost certainly give rise to a large release of radioactivity, the consequences of which were discussed previously....

"Assuming absolute independence of the process and safety systems, the probability of a core meltdown per reactor at Pickering is said to be in the order of  1  in  1,000,000  years....

"However, two well-informed nuclear critics who participated in the hearings, Dr. Gordon Edwards and Ralph Torrie, have argued that the probability of a dual failure could be about  100  times higher than the theoretical levels.  This estimate is based on failure rates in the high pressure piping of the primary heat transport system being  10  times higher than has been assumed, and also on the fact that the availability of the Pickering  ECCS  has been demonstrated to be  10  times lower than postulated by the designers.

"We believe that the Edwards/Torrie estimate  [of  1  in  10,000  per reactor per year]  is more realistic than the theoretical probability, not least because the Rasmussen Report has concluded that the probability of an uncontained meltdown in a light water (U.S.) reactor is  1  in  20,000  per reactor per year.  It has been suggested, moreover, that this figure could be out by a factor of  five either way.

"Assuming, for the sake of argument, that within the next forty years Canada will have  100  operating reactors, the probability of a core meltdown might be in the order of  1  in  40  years, if the most pessimistic estimate of probability is assumed...."

A Race Against Time - Nuclear Power in Ontario, pp. 78-79,
Report of the Royal Commission on Electric Power Planning, 1978.

Thus in Canada, independent assessment of the CANDU industry's probability figures by a credible and responsible body has shown those estimates to be highly suspect.  The same can be said of the unsupported probability figures for "severe accidents" at Cernavoda 2 quoted by ICIM.  Hence the industry's low probability estimates do not constitute a valid reason for refusing to address the transboundary health and environmental consequences of severe accidents at Cernavoda 2 NPP.

Unavailability of Safety Systems

Reactor designers have provided special safety features to deal with anticipated emergencies: containment systems, emergency core cooling systems, fast shut-down systems, emergency electrical supply systems, and so on.  Unlike most other reactor types, each CANDU reactor has two fully independent fast shut-down systems.  This redundancy was prompted by the need to cope with the sudden surge in power following a loss-of-coolant, due to the positive void coefficient.  The cost of adding a second fast shut-down system was justified by the fact that "loss-of-regulation" accidents -- those which may require the use of a fast shut-down system -- were occurring about a hundred times more frequently in Ontario's CANDU reactors than predicted by the industry's probability calculations.

In operational situations, however, CANDU safety systems are often partially or completely unavailable.  In some cases, CANDU emergency cooling systems have been unavailable for months at a time.  CANDU fast shut-down systems are also unavailable at times.  Just recently in Canada, for example, CANDU workers mistakenly installed a neutron detector backwards, so that the second fast shutdown system would have been unavailable during an emergency.

Such unavailability episodes are usually not discovered by plant operators or regulators until long after the fact -- possibly during a maintenance shutdown, and sometimes not even then.

Likewise, CANDU containment systems have suffered impairments for long periods.  The kind of problem outlined below is not an isolated instance:

" . . . a leak was discovered in the wall of the Pickering unit 2 reactor building in June, 1974, and may have existed for  1 and  1/2 years -- this leak 'would have reduced the ability of the containment system to limit radioactive release after any unit 2 accident since the beginning of 1973'. . . .  As Ralph Torrie has pointed out, the 'Pickering  unit 2  containment would have to operate within target levels for  500  years before the average annual availability would be back within the bounds of the annual regulatory limit'.

"In assessing the legitimacy of the above limits it should be stressed that no study similar to the Rasmussen study has been undertaken in Canada to assess the reliability of the reactor system as a whole and the consequences of major CANDU reactor accidents."

A Race Against Time - Nuclear Power in Ontario, p. 79, Report of the Royal Commission on Electric Power Planning, 1978.

The  Cernavoda 2 reactor will be subject to similar problems of unavailability.  On page 133 of the ICIM Report, for example, five of the six accident scenarios involve "impairment of the pre-existing containment envelope", while the remaining scenario involves "late containment failure due to steam over-pressurization".   Given the hypotheses of impaired containment at Cernavoda 2, it is a mystery why ICIM believes that radiation releases will not continue beyond 24 hours.

In the event of a pipe break in the primary cooling system at Cernavoda 2, the superheated cooling water will flash into steam, instantly pressurizing the interior of the containment building and driving radioactive gases and vapors into the outer atmosphere if there is any impairment of the containment envelope.  Such impairment of containment can occur in many different ways -- for example, by failure of ventilation dampers to close properly, by failure of personnel air-lock doors to seal correctly, or by means of undetected leaks around any of the hundreds of penetrations through the containment wall.  As long as steam is being generated by the heat of the crippled core, radiation releases would be expected to continue.

Compared with the CANDU reactors in Ontario, leaks in the containment wall of Cernavoda 2 could have more serious health and environmental consequences in the event of a major reactor accident.  This is because, at Cernavoda, there is no "Vacuum Building" as there is at every operating CANDU reactor in Ontario.

A "Vacuum Building" is a separate large structure connected to the reactor, designed to "suck up" all the radioactive steam and vapors released from the reactor core during a major accident.  CANDU export models, like Cernavoda 2,  have been re-designed without a Vacuum Building in order to reduce over-all costs.

Regulatory Concerns About CANDU Safety

In 1989, the Atomic Energy Control Board (AECB) -- the Canadian nuclear regulatory agency -- submitted a report to the Treasury Board of Canada.  This report echoed the conclusion of the Ontario Royal Commission on Electric Power Planning cited earlier by re-asserting that there is no basis for believing that CANDU reactors are safer than any other type of reactor.  It also added the important perception that safety problems seem to multiply as time goes by and the plants get older:

"When modern nuclear power plants were being designed in Canada two decades ago, their complexity and potential for catastrophic consequences were recognized. The plants were designed to high standards, and special safety systems were incorporated to prevent or reduce the consequences of malfunctions. Reactor designers and owners adopted a relatively simple process for evaluating plant safety. 'Worst credible' accident scenarios were investigated to ensure that their consequences would be acceptably low. It was then assumed that the consequences of less severe but more likely accidents would be acceptable.

"Since that time, experience in Canada and the rest of the world has demonstrated that this approach to safety is too simplistic.  It is recognized now that, through the combination of a series of comparatively common failures which, on their own, are of little consequence, accidents can develop in a myriad of ways (as demonstrated most vividly at Three Mile Island and Chernobyl).  This makes the calculation of consequences of potential accidents very difficult, research to simulate accident consequences is often incomplete, and, perhaps most significant, human errors are an unquantifiable element.

"As a result, there is a legacy of unresolved safety issues that should be addressed further. This issue is particularly important as twelve of Canada's largest reactors are close to Toronto.

"AECB's review of safety has also been too simplistic. Spot checks of a fairly small number of the key areas were thought to be sufficient. These spot checks have uncovered enough safety problems to demonstrate that more thorough review is essential, since the risk posed by nuclear power plants may be higher than once believed.
"The size and complexity of the task of ensuring and demonstrating the safety of nuclear power plants has not increased suddenly -- it has been building up for the last decade. It has led reactor designers, operators and regulators around the world to demand far more thorough analyses which are far more complex, and a far more detailed understanding of how a plant can malfunction, than was required in the past.

"The task is overwhelming the AECB. It does not have the resources to analyze and understand this increased level of knowledge and information. Three examples will illustrate the problem....

"The consequences of a severe accident can be very high. The accident at Chernobyl has cost the Soviet economy about  $ 16  billion including replacement power costs. The accident has generated anti-nuclear sentiment in the USSR and throughout the world. Three Mile Island has cost the USA  $ 4.8  billion even though the Three Mile Island accident had essentially no radiation impact on the public. The accident was a major contributor to the public distrust of nuclear power in the USA.

"The years of successful accident-free operation which are a hallmark of the Canadian nuclear program are not, by themselves, proof of adequate safety. Canada has amassed about  170  years of operation of large reactors, compared with  480  years in the US and  270  years in the USSR at the time of Three Mile Island (1979) and Chernobyl (1986) respectively. The likelihood of serious accidents cannot be judged from statistics such as these, and CANDU plants cannot be said to be either more or less safe than other types....

"Given the potential consequences of severe accidents everything possible should be done in order to increase the confidence in the AECB's judgment by improving the depth and breadth of its technical evaluations and inspections. The AECB considers that the scope and depth of the reviews on which it makes its judgments currently is insufficient. The resources needed to ensure that licensees are taking all possible measures to prevent accidents and for the AECB to take enforcement action when they do not are also currently insufficient."

Report to the Treasury Board of Canada, Atomic Energy Control Board, 1989.

In 1997, seven of Ontario's CANDU reactors were voluntarily shut down by the owner.  Ontario Hydro, because of an inability on the part of Hydro management to cope with the huge backlog of safety-related maintenance issues:

"Long standing management, process and equipment problems in Ontario Hydro Nuclear (OHN) plants are well known but have not been aggressively resolved. . . . Immediate attention is needed to improve performance. .
. .

"OHN staff at every level are reluctant to ask difficult questions of themselves and others.  Failure to establish a questioning attitude is a primary cause of the reduction in the "defense-in-depth" concept. There is no real independent evaluation of proposed operations by people not directly involved in formulating the planned actions (e.g. is this the safest way to accomplish an operation? Are the operators challenged unnecessarily by the proposed change? Will all required structures, systems and components remain capable of performing their intended functions for their day-to-day mission and all credible accident scenarios?)"

Executive Summary,  Findings and Recommendations of the IIPA/SSFI Evaluation , A Report to Ontario Hydro Management, June 1997.

Those seven Ontario reactors are still shut down today, six years later.  Although plans are underway to restart some of them, the combined cost of doing so -- currently estimated at about three billion dollars -- may prove prohibitive.

If Ontario Hydro, despite its wealth of experience with CANDU technology and its stable of well-paid professionals, cannot manage to keep CANDU reactors operating safely, it is not unreasonable to ask how Societata Nationala Nuclearelectrica (SNN) will manage to do so with Cernavoda 2. Yet SNN officials seem completely unfazed by the challenge, perhaps because they do not yet grasp the complexities of the problems.

Meltdown After A Successful Shut-Down

Cernavoda 2 -- like all large nuclear power reactors -- will contain an enormous inventory of radioactive materials.  About 300 different kinds of radionuclides will be created inside the reactor as an inevitable result of the nuclear fission process.  They all generate heat as a result of radioactive decay.  Most of the heat is produced by the "fission products" -- the broken bits of uranium and plutonium atoms that have been "split".   In addition to the fission products are the "activation products" -- previously non-radioactive materials that have become radioactive as a result of nuclear transmutation -- and the very long-lived and highly toxic "transuranic elements" (the so-called "actinides") such as americium, plutonium, and curium -- heavy man-made elements, created when uranium atoms in the fuel absorb one or more neutrons without splitting.

As previously noted, large releases of radioactivity into the environment may occur whenever the reactor fuel is severely damaged and the containment of the reactor building is impaired.  Moreover, fuel melting can occur in the absence of nuclear fission.  The irradiated fuel will melt spontaneously even though the reactor is completely shut down, if there is inadequate cooling of the core.   During the TMI accident, for example, the reactor was shut down almost immediately, yet fuel melting took place over the next two or three days.

The Cernavoda-2 reactor operating at full power will generate about 2100 megawatts of heat (only one-third is transformed into electricity). Immediately after shutdown, due to radioactive decay, the core will continue to generate about 7 percent of full power heat -- that is, about 147 megawatts of heat.  One hour after shutdown, residual heat generation will still be about 4 percent of full power heat -- that is, 84 million watts of heat.  That is more than enough heat to melt the core of the reactor.  Unless the "decay heat" is removed promptly and continuously, the core will melt.

Moreover, even in the absence of a pre-existing impairment of containment, the course of the accident itself could unleash forces that would end up breaching the containment envelope through over-pressurization, explosions, or melt-through.

The Canadian Department of Energy Mines and Resources published a report on nuclear issues in Canada in 1981; here's some of what they wrote about meltdowns:

"In the absence of relevant Canadian information, the work done by N. C. Rasmussen, as described in the Reactor Safety Study (WASH-1400) issued in 1975 by the U.S. Nuclear Regulatory Commission is used.  The following information borrows extensively from that document and although not strictly applicable to CANDU reactors, does give useful illustrative information on very serious potential accidents.

"The Reactor Safety Study defined two broad types of situation that might potentially lead to melting of the reactor core: a LOCA [Loss Of Coolant Accident] , and transients.

. "In the event of a  LOCA , the normal cooling water would be lost from the main cooling system but core melting would normally be prevented by the action of the ECCS  [Emergency Core Cooling System] .

"However, if the ECCS failed to act, melting of metallic components of the core and eventually of the uranium oxide fuel itself would probably occur.

. "The term 'transient' refers to those situations where there is an uncontrolled increase in reactor power or a loss of normal cooling flow, both of which require the reactor to be shut down. Following shutdown, the decay heat removal systems act to keep the core from overheating.

However, if the reactor fails to shut down or the decay heat removal systems fail, melting of the core would ensue. "The Rasmussen study conservatively assumed that if any melting occurred, then complete core melting would occur. It was then predicted that the molten core, consisting of a mixture of molten uranium oxide, stainless steel, zirconium, and other core structural materials, could melt through the bottom of the  20  cm thick steel reactor vessel and through the  3.69  meter thick concrete base slab of the containment structure.

"The study estimated the time for going through the reactor vessel to be   1  to  1 1/2  hours and through the base slab to be an additional 13  to  28  hours. The molten mass was then predicted to sink into the ground an additional  3  to  15  meters before coming to rest.

"Much larger consequences could be associated with core meltdowns which also cause failures in the containment structure above ground.  If the containment sprays malfunction or are damaged by flying debris (generated by a LOCA or transient) the steam being released from the reactor core would not be condensed.

"This steam, along with various vapors and noncondensible gases, could cause failure of the containment structure due to over-pressurization. Hot zircaloy from the fuel sheaths and steel would also react with water to produce large volumes of hydrogen.  Detonation of this hydrogen (reacting with oxygen) might damage the containment or, if not, the heat of combustion combined with high steam pressure would at least add to the pressure loads on the structure.

"A further contributor to containment pressurization would be the large quantities of carbon dioxide generated as the molten core melts through the concrete base slabs.  Another possibility is one in which the molten fuel falls into the pool of water in the bottom of the reactor vessel with the formation of flying debris which could, in turn, damage the containment structure.  All post-meltdown occurrences which threaten to damage or breach the containment structure can result in the release of substantial amounts of radioactive material to the environment."

Nuclear Policy Review Background Papers,  pp. 210-211,
Department of Energy Mines and Resources (Canada), 1981.

As already noted, ICIM lists six accident scenarios involving fuel melting on page 133 of the EIA Summary (although nothing is said about fuel melting in the text).  In all of these scenarios, the Cernavoda 2 containment is assumed to be impaired (or breached) and "large" (or "significant") radioactive releases are assumed to take place, at least for the first 6 (or 24) hours.  Yet each scenario is allotted only one sentence, and there is not even a definition of terms such as "large" and "significant".  Nor is there any discussion of environmental impacts associated with these scenarios.

Consequences of Severe Accidents

The ICIM EIA Summary makes no mention of how much radioactive iodine, cesium, strontium, or plutonium is expected to be released in each of the six cases of severe accidents listed on page 133.   There is no description of the behavior of the radioactive plume, no discussion of the degree of long-term environmental contamination remaining once the emergency is over, and no mention of possible transboundary effects. The ICIM document simply refuses to deal with such unpleasant realities.

According to the Rasmussen Report, under the worst conditions, a major nuclear accident could result in:

. about 45,000 cases of radiation sickness requiring  hospitalization, of which about 3300 would die;

. about 45,000 fatal radiation-induced cancers in the thirty-year  period following the accident;

. about 250,000 non-fatal radiation-induced cancers in the  thirty-year period following the accident:

. about 170 genetically defective children born each year to the  population surviving the accident;

. about $14 billion dollars (1974 dollars) in property damage,  mainly due to radioactive contamination of food, water, land,  and buildings.

According to the ICIM EIA Summary, the consequences of severe nuclear accidents at Cernavoda 2 are not even worth mentioning.

There are evacuation plans in the event of a nuclear accident at Cernavoda 2, and officials of the Environmental Protection Agency told the members of the Fact-Finding Mission about an actual rehearsal that was carried out last year.

However, those same officials  revealed that they had never questioned the proponents of the project about possible residual radioactive contamination of the environment after the emergency was over.

If such matters were not raised in the report, members of the Fact-Finding Mission were told, then they were of no concern to the Environmental Protection Agency.  They did not seem to think it appropriate that the Environmental Protection Agency should question the adequacy of the Environmental Impact Assessment presented to them by the proponent.

Seismic Risks

Romania is an earthquake-prone region,  Because of the great depth from which some of these quakes originate, the so-called "sub-crustal" quakes are often less attenuated and more destructive than quakes of comparable magnitude originating in other regions of the world.  These sub-crustal quakes have in the past killed thousands and caused great damage.  In some cases they have been felt as far away as Moscow.  Earthquakes originating closer to the surface ("crustal quakes") are also common in the region, some with epicenters much closer to the Cernavoda site -- including some just across the border in Bulgaria.

Because Cernavoda 2 uses natural uranium rather than enriched uranium, it is a larger and bulkier structure than reactors of different design but comparable power.  Other things being equal, large structures are often more vulnerable to earthquake damage than smaller ones.

Even if the overall structural integrity of the reactor is not challenged, internal damage may occur, possibly affecting the integrity of the containment envelope (e.g. the ventilation dampers) or the special safety systems of the reactor.

As previously mentioned, the Cernavoda 2 reactor will contain proportionately more small piping than most other reactors.  During an earthquake, vibrations may precipitate some pipe breakage inside the reactor building, thereby causing a loss of coolant and a power surge. Electrical supply problems could also become manifest.

If a severe earthquake occurred during on-line refuelling -- an activity which is carried out every day in a CANDU reactor -- it is conceivable that mechanical interaction between the fuelling machine and the pressure tubes could cause breakage of pipes at both ends of the horizontal core.  This would be a particularly serious situation; emergency coolant could not be expected to flow through the core in such a case, due to a lack of the necessary pressure differential.

This safety concern involving a "double-ended pipe break" was identified many years ago by the US Argonne National Laboratory in a short paper on CANDU reactors.  To the best of our knowledge, this concern has never been fully addressed.

In response to direct questions from the Fact-Finding Mission, representatives of the SNN admitted that such accident scenarios, involving  the simultaneous breakage of pipes on both sides of the Cernavoda 2 reactor core, have never been analyzed.

Accelerated Aging of CANDU Reactors

Experience in Canada has shown that as the years go by, CANDU reactors undergo a process of accelerated aging.  In particular, the pressure tubes in the core of the reactor become increasingly brittle, and therefore increasingly likely to crack or split without warning, thus causing a loss-of-coolant accident.  Moreover, the sudden influx of cold emergency cooling water into the hot pressure tubes could cause further breakage because of the embrittlement of the tubes.  At a certain point, the pressure tubes must be replaced for safety reasons.

Retubing the core of a CANDU reactor is a major operation.  The plant has to be shut down completely for one to four years.  The reactor has to be "de-fuelled", the heavy water moderator has to be drained out of the core, and the intensely radio-active pressure tubes must be removed and replaced with new ones.  The materials in the pressure tube walls have become radioactive through "neutron activation", and must now be treated as highly radioactive waste materials.

Currently, in Canada, there are two reactors operating which are based on the same design as the Cernavoda 2 reactor; these are the Point Lepreau reactor in New Brunswick and the Gentilly-2 reactor in Quebec. Both of them have been operating for less than 20 years.  Both of them must be re-tubed if they are to continue operating safely.  The estimated cost of refurbishing the reactors, in both cases, is estimated to be $845 million Canadian (approximately $550 million US).

This is a very large price tag.  So large, in fact, that the Public Utilities Commission (PUC) in New Brunswick last year, after hearings, unanimously recommended against refurbishing the Point Lepreau reactor. In their report, the PUC expressed skepticism that the price of refurbishment would be kept to within the $845 million estimate, since the nuclear industry in Canada has an extensive track record of underestimating the costs of  nuclear engineering projects by factors of 2 to 4.

Given Romania's credit situation, it may prove difficult to borrow the $1690 million Canadian ($1100 million US) that may be needed to refurbish both Cernavoda 1 and Cernavoda 2 when the time comes.  Yet we were informed by the SNN authorities that they have not established a fund to finance such refurbishment projects.

But there are serious safety implications involved in not refurbishing the reactors.  The older the plants get, and the more embrittled the pressure tubes become, the greater the likelihood of a severe accident having transboundary impacts.

Tritium Contamination from CANDU Reactors

The most obvious difference between CANDU reactors and other power reactors is the use of "heavy water" or "deuterium oxide" (chemical symbol  D2O ) instead or "light water" or "hydrogen oxide" (chemical symbol H2O ) as a coolant/moderator.  Indeed, the word "CANDU" stands for "Canadian Deuterium Uranium".

Heavy water is chemically identical to light water, but it is slightly heavier and very expensive.  Although deuterium (D)  is a naturally occurring form of hydrogen, much time and energy is needed to produce concentrated D2O.  Up to 20 percent of the capital cost of a CANDU reactor is due to its large heavy water inventory. The nucleus of an ordinary hydrogen atom (H) consists of a single proton.  A deuterium atom (D) is twice as heavy; its nucleus consists of a proton and a neutron bound together.  Because deuterium atoms already contain one neutron, they are less likely than hydrogen atoms are to absorb other neutrons -- neutrons that are needed to keep the nuclear fission chain reaction going inside the nuclear reactor.

For that reason, heavy water is far more "neutron-efficient" than ordinary light water.  By using heavy water instead of light water, CANDU technology allows for the use of "natural uranium" instead of "enriched uranium" as a fuel.  Thus the extra cost of the heavy water is offset by the lower cost of the fuel in a CANDU plant.

But there is an environmental price to pay for this technological efficiency.  When a deuterium atom does absorb a neutron, which happens all the time during fission, it becomes a tritium atom (T).  A tritium atom is three times as heavy as a normal hydrogen atom; it consists of one proton and two neutrons bound together.

But tritium is a radioactive form of hydrogen, hence dangerous.  It is a weak beta-emitter with a half-life of 12.3 years.  It is released into the environment in large quantities by every operating CANDU reactor; tritium emissions are at least one or two orders of magnitude greater from CANDUs than from light-water reactors.

Tritium appears most often in the form HTO or DTO ("tritiated water") , both of which are chemically identical to ordinary water.  Consequently tritium is very difficult to control; it cannot be filtered out, for example.  It is given off into the air and the water on a routine basis.  From time to time large spills occur in which tens of thousands of curies of tritium may be released into the environment all at once.

Moreover, tritium is constantly being produced in the "heavy water" that is used as both primary coolant and as moderator in the CANDU reactor design.  Every year, the inventory of tritium in this large volume of heavy water increases, and so the amount released to the environment also generally increases year after year.

For example, in the ICIM EIA Summary, the following figures are given for releases of tritium into  the atmosphere from Cernavoda-1 (Table III.2.5-1) :

 1997  25.57  terabecquerels
 1998  50.67  terabecquerels
 1999  84.89  terabecquerels
 2000  208.03 terabecquerels

[These figures are obtained by multiplying the reported emissions in the last four columns of the table by one percent of the annual derived emission limit given in column 1.   Note that one TBq = 1 terabecquerel = 1 million million becquerels]

Notice that the atmospheric tritium emissions in the table are roughly doubling each year.  Annual tritium emissions to the atmosphere would be expected to continue to increase throughout the lifetime of the plant, unless an expensive  tritium-removal plant is built to remove the tritium from  the heavy water moderator and coolant of the reactor. Such a tritium removal plant was built in Ontario, Canada, for precisely this purpose.

Although tritium is a very weak beta emitter and therefore difficult to detect, laboratory studies have shown that it is more effective in causing cancer, per unit dose, than gamma rays or x-rays.  The "quality factor" (QF) is between 2 and 3.  Tritiated water enters easily into animals, plants and soil just  as ordinary water does.  Also, tritium enters readily into all organic molecules including DNA.  In Canada there has been much controversy over rising levels of tritium in drinking water of communities near CANDU nuclear plants.  There has also been inter-national concern voiced -- by the International Commission on the Great Lakes, for example -- over the rising levels of tritium in the Great Lakes.  This phenomenon is almost entirely due to the CANDU nuclear plants operating on the Canadian side.

Like all radioactive materials, tritium is a cancer-causing agent. However, tritium has also been implicated directly in the production of genetic and teratogenic damage.  Here is a small excerpt from the 1980 BEIR-3 Report (BEIR = Biological Effects of Ionizing Radiation) by the US National Academy of Sciences:

"Because tritium (hydrogen-3) is a potential pollutant from nuclear-energy production, its effect on development  [of unborn babies]  has been the subject of a number of studies.

"Tritiated water (HTO) is a common chemical state of tritium, and it has easy and rapid access to living cells, including those of the embryo or foetus.

"HTO administered in the drinking water to rats throughout pregnancy produced significant decreases in relative weights of brain, testes, and probably ovaries, and increases in norepinephrine concentration, at doses of 10 microcuries per millilitre (estimated at 3 rads per day), and produced weight decreases in a number of organs at higher doses.

"Because the length of the critical period  for various organs is not known, the total damaging dose cannot yet be estimated. Relative brain weight was found to be reduced at only 0.3 rads per day (one microcurie per millilitre of drinking water) when exposure began at the time of the mother's conception.

"Even lower exposures (0.003 rads per day and 0.03 rads per day) have been implicated in the induction of behavioral damage, such as delayed development of the righting reflex and depressed spontaneous activity. However, because the data fail to show a clear dose dependence, there is some doubt about the validity of this suggestion.

Effects on Populations of Exposure to Low Levels of Ionizing Radiation, pp. 485-486,
U.S. National Academy of Sciences' BEIR-III Committee, 1980
Gneetic effects of tritium were discussed in the 1977 Report of the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR):

[Paragraph 374. ]

"Cumming et al. (128) have completed the first series of experiments on tritium-induced specific locus mutations in mice, providing the only data available on such gene mutations in any mammal.

''In view of possible levels of tritium release, not only from existing nuclear installations but also from contemplated controlled thermo-nuclear reactors, these data are of great relevance.  [emphasis added]

". . . The results demonstrate that beta radiation from the decay of tritium can induce specific-locus mutations in spermatogonia as well as in post-meiotic stages: 16 mutations have been recovered among a total of 20,626 offspring derived from germ cells irradiated as spermato-gonia and 11 in 7,943 offspring from irradiated post-meiotic stages...

[Paragraph 375.]

"Hori and Nakai (233) and Bocian et al. (39) have reported on the induction of chromosome aberrations in human lymphocytes exposed to tritiated water in vitro. Exposures were carried out by the addition of whole blood to the culture medium containing tritiated water...

 [Paragraph 376.]

"The results indicate that with protracted exposures (48 or 53 hours) the  [chromosome]  aberrations produced were mostly of the chromatid type, such as gaps, deletions and fragments, and there were relatively few chromatid exchanges.

"In the concentration range used by Hori and Nakai, the dose-effect curve for the number of  [chromosome]   breaks induced was quite complex at low concentrations. In the work of Bocian et al. and with the range of concentrations they used, the frequency of chromatid aberrations increased linearly with dose...

 [Paragraph 378.]

''Summary and conclusions:  During the past few years, there has been a growing interest in the study of the biological effects of radioisotopes, particularly of plutonium-239 and tritium.

"A number of genetic and cytogenetic studies that have so far been carried out in mice demonstrate that these isotopes are capable of inducing dominant lethals  [i.e. lethal mutations] ,  chromosome aberrations and point mutations  (for the last category, only the effects of tritium have been studied) .

Sources and Effects of Ionizing Radiation,
Annex H, Genetic Effects of Radiation, Topic 2: Tritium; UNSCEAR Report to the U.N. General Assembly, 1977.
For all these reasons, contamination of the North American  environment by tritium and carbon-14 (another weak beta emitter produced in particularly large amounts in CANDU reactors) has become a major        transbounday concern:

"Carbon-14 and tritium are of comparable and special concern for similar reasons.

"First, they each have long half-lives: 5 730 years for carbon-14  and 12.3 years for tritium. Long half-lives allow them to accumulate in the environment around a reactor and in the global biosphere.

"Second, they are easily incorporated into human tissue. Carbon-14 is incorporated into the carbon that comprises about 18 percent of total body weight, including the fatty tissue, proteins and DNA [molecules]. Tritium is incorporated into all parts of the body that contain water.

"Thus the radiological significance of both elements is not related to their inherent toxicity, as each is a very low energy form of radiation, but to their easy incorporation in the body."

The Safety of Ontario's Nuclear Reactors,
Select Committee on Ontario Hydro Affairs, 1980.

The ICIM EIA Summary gives no useful information on health and environmental effects of tritium emissions from Cernavoda 2.  There is no discussion of the gradual buildup of tritium in the environment or the possibility of transbounday impacts.  There is no discussion of carcinogenic, teratogenic or mutagenic aspects of tritium exposure -- or of exposure to ionizing radiation in general.

References

Atomic Energy Control Board.  Submission to the Treasury Board of Canada.  Ottawa 1989.

BEIR III.  The Effects on Populations of Exposure to Low Levels of Ionizing Radiation.  Committee on the Biological Effects of lonizing Radiation.
 National Academy Press. Washington, D.C., 1980.

Energy, Mines and Resources (EMR), Department of.  Nuclear Policy Review
Background Papers.  Government of Canada.  Ottawa 1981.

National Institute of Research and Development for Environmental Protection (ICIM).  Cernavoda 2 NPP Environmental Impact Summary. Bucharest 2002.

Nuclear Performance Advisory Group (NPAG).  The IIPA/SSFI Evaluation ~ Findings and Recommendations.  A Report to Ontario Hydro Management. Toronto 1997.
   [IIPA = Independent Integrated Performance Assessment]
   [SSFI = Safety System Functional Inspections]

Nuclear Regulatory Commission.  Reactor Safety Study (the "Rasmussen Report").  WASH-1400.  Washington DC 1974.

President's Commission on the Accident at Three Mile Island.  The Need For Change : The Legacy of TMI.  Washington DC 1979.

Royal Commission on Electric Power Planning. A Race Against Time: Interim Report on Nuclear Power. Toronto 1978.

Select Committee on Ontario Hydro Affairs. Safety of Ontario's Nuclear Reactors: Final Report.  Ontario Legislature.  Toronto 1980.

United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR).  Sources and Effects of Ionizing Radiation.  New York 1977.
  [Annex H: Genetic Effects of Radiation.]
  [Annex J: Developmental Effects of Radiation.]

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