Critic Slams CNSC Regulations for lack of guidance

This is a link to my recent comments on the Fukushima Omnibus regulations.

Chris Rouse Second Round Fukushima Omnibus Regulation comments Rev 1

After I sent it to the consultation department of the CNSC I also forwarded it as well as additional comments to the CNSC commissioners in the email below.

 

Good Morning Mr. Leblanc
 
I would like the commissioners to be sent a copy of my comments for the second round of consultations of the Fukushima omnibus project, and a copy of this email as well. Essentially I point out that there is no guidance for REGDOC-2.4.2 Probabilistic Safety Assessment (PSA) for Nuclear Power Plants. This is the only regdoc that does not have any guidance either included in the regdoc or in a separate regdoc. This is unacceptable especially for a regdoc that has been around since 2008. This poses a huge amount of regulatory uncertainty for the licencee’s. As well the current version of the document is very vague and unclear, and as it stands will continue to put the commissioners in precarious positions at public meetings and hearings. The CNSC staff has not taken the commissioners advice on showing the crosswalks to other regulatory documents in this current version. It is my recommendation that proper guidance be added to the regulatory document and then one more round of consultations before the commissioners are asked to approve it.
 
Thanks
 
Chris Rouse

Event Report Missing?

After the complaint to the CNSC and NB Power about NB Power being late in  posting it’s event reports, I was given a copy of the event reports from NB Power. After I had reviewed the event reports I discovered that their was one missing and not posted on the NB Power Website. This is the email that was sent to NB Power and the Canadian Nuclear Safety Commission regarding the missing report.

Hi Kathleen
 
Thank you for a copy of the event reports yesterday. I have reviewed them and have a concern with the event report ERD-00583-1302-028-A-00 “Report Not Submitted by due date”. This was to report another event report of a Problem Identified by Research Finding(PIRF), S-99 section 6.3.2.3, that was not submitted on time. According to this event report the PIRF report was submitted four days late. I do not see any reference to any event reports for a PIRF. Can you please figure out what PIRF ERD-00583-1302-028-A-00 is referring to and update the event list posted on NB Powers website, and as well as send me a copy of the PIRF report.
 
I have also noticed that several of the event report used form # PL-0864 Rev 1 2013-05-24 for events that happened before the revision date of the form. Can you explain this?
 
Regards
 
Chris Rouse
New Clear Free Solutions

Natural Resources Canada “A Preliminary Tsunami Hazard Assessment of the Canadian Coastline”

A report by Natural Resources Canada released in Oct 2012.

A Preliminary Tsunami Hazard Assessment of the Canadian Coastline

The independent investigation into the causes of the Fukushima accident concluded that the accident was clearly “man made”. Fukushima Diet Report One of the main reasons for this conclusion was that they knew of a tsunami around 800 years ago that was much larger than the plant was designed for, but did nothing about it. Less than 100 years ago in 1929 there was a very large tsunami that hit the Burin Peninsula. It had wave runup of 13 meters. This kind of wave runup would flood Point Lepreau just as the tsunami wave did in Fukushima.

In April 2012 there was a swarm of 15 earthquakes on the edge of the continental shelf of the coast of Point Lepreau.

Earthquake Swarm April 2012

Some Highlights of the NRCan Study:

“The only historical landslide-triggered tsunami documented on the east coast of North America occurred in November 1929 and resulted in 28 deaths in Newfoundland, Canada (Table 1). An Ms 7.2 earthquake at the edge of the Grand Banks south of Newfoundland (Fig. 12) triggered a large submarine landslide-turbidity current on the continental slope that broke 12 seafloor telegraph cables (e.g., Heezen and Ewing, 1952). The landslide triggered a tsunami that traversed the continental shelf to strike southern Newfoundland; most damage and all fatalities occurred on the Burin Peninsula, where wave amplitudes of 3-8 m and runup up to 13 m were documented (e.g., Ruffman, 2001; Fine et al., 2005). Future submarine landslides along the Atlantic continental slope may also trigger destructive tsunamis; mapping has revealed that mass 28 failures much larger than the 1929 slide have occurred in the past (e.g., Piper and Ingram, 2003; Piper and McCall, 2003; Mosher et al., 2010).”

 “Continental slope failures similar to the 1929 Grand Banks event also present a significant hazard to the Atlantic coast. Our assessment involves a number of simplistic assumptions that need to be tested with modelling and with the collection of more data. These assumptions include: (1) the size-frequency relationship of failures in Orphan Basin can be applied to other parts of the margin; (2) the threshold volume of tsunamigenic failures is 40 km

“Analysis of the Atlantic coast tsunami hazard (Table 23; Fig. 21) indicates that far-field subduction zone sources may be very significant, but the hazard is poorly constrained. Tsunami modelling is critically needed to identify which sections of coastline are at risk from each potential source”

“Mosher et al. (2010) tested two scenarios for their impact on Halifax, Nova Scotia, located ~200 km north of the source across the continental shelf. In the first scenario, only the 117 km 3 slump portion is modelled, resulting in a maximum wave amplitude of 13 m (above the state of tide) at Halifax; modelling of a simultaneous 862 km3 failure incorporating both the slump and debris flow produces a 25 m wave at Halifax. However, the use of instantaneous vertical displacements may have overestimated the amplitudes.”