What am I for and what I know
I'm for the selection of the safest spot for DGRs based upon facts including all the risks for long term storage of nuclear waste. It's too important an issue to be derailed.
Further, I don't care where it goes as long as it is the best site geologically and strategically with risk minimized. There are no scientific breakthroughs required.
Written for Canadian Community News by Mike Sterling
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The Joint Review Panel's transcripts on the low and intermediate DGR are fascinating and rich with information.
Canada should be proud of the hearings. The process is well designed and working.
The hearings were open to input from world experts and those who knew very little. There was equal opportunity for fact and fiction with fact winning going away. The fiction was recognized and dealt with politely.
To anyone paying any attention at all, it became apparent that some witnesses and interveners added no value to the panels goal except the depth of misinformation. Most were sincere, but their testimony came to nothing.
I'll illustrate this using an interesting expert hired by the Joint Review Panel and a couple anti-DGR citizens who were not familiar with the subject matter. They and the expert's testimony illustrate the value of the hearings quite well.
In the end it was important to know what the expert had to say and so I'll give you my take on his testimony and responses using his words for the most part. I add something too from personal experience. The testimony was difficult to follow, so caution is a good thing.
The panel was business-like, and did not indulge in too many questions by weak spokespersons, at least in a single session. All were free to get ask questions on the record after each speaker's presentation.
Many took advantage by repeating the same thing again and again with a slightly different slant couched in a hoped to be inciteful question. They were giving speeches. This did not escape the Panel. Sometimes they teased a question out of a speech, sometimes they just shut off the opinions.
The real subject I tried to understand deals with Dr. Peter Duinker's testimony. But first a couple of questions from the audience should be illustrative of how some listeners missed the subject altogether.
"QUESTIONS BY THE PUBLIC: MR. MANN:
"Thank you, Dr. Swanson. I wonder if I could have leave for the following question to Mr. Duinker? I call it the cart-before-the-horse syndrome. Does Dr. Duinker agree that, for a cumulative effects assessment to have any reliability, any credibility and any trustworthiness, you must include the high level nuclear waste in the investigation? For instance, will the high level nuclear waste stay on site aboveground or will it eventually go in the foothold DGR for low and intermediate nuclear waste in Kincardine, or will it travel and be transported through our community offsite to a second DGR a few kilometres away or hundreds of miles away? Thank you."
"Mr. Mann, Dr. Duinker was not contracted by the JRP to consider those particular aspects. I think you’ve already heard his -- and read, his comments regarding the methodology that was used for this cumulative effects assessment.
The Panel has already made itself clear with respect to our response to your request for ruling on the inclusion of used fuel and we do not think we need any more evidence in that regard at this time. Did you have any further questions?"
What is the rush to build the low and intermediate but I -- in light of your ruling Doctor, I will let that go. Thanks.
The Panel's patience was wearing a bit thin, but they were always polite.
Some times the question/viewpoint was so off the mark on facts that the panel would try to clarify for the audience. The panel would explain and try to clear the air and then they would move on to the next questioner.
Here is another interchange by SRASOS spokesperson Ken Robertson.
THE CHAIRPERSON: Mr. Robertson?
"Thank you, Madam Chair. Ken Robertson here. My first -- I have two questions, first one for Dr. Duinker. During the last three weeks, members of the public who have attended these hearings have observed what we believe is a real problem. And the problem that we have observed is what we believe is tunnel vision by the leadership of OPG, as far back as 2001.
Now, some of the symptoms that we’ve observed are this; a lack of consultation with the public being sold as public relations -- or public relations being sold as consultation; a lack of consideration of alternate sites for this DGR or alternate processed to the DGR; expenditures of millions of dollars in support of a host agreement as far back as ’05.
So my question to you, Dr. Duinker, is this, could the problems you have observed in your review be another symptom or the result of tunnel vision by the Proponent?"
"Mr. Robertson, Dr. Duinker is here as our contracted expert in cumulative effects and also the significance of adverse effects. So if you would like to rephrase your question so that it is pertinent to the subject, then I might be able to direct it to Dr. Duinker."
"If I shorten it -
I guess how I could phrase it, Madam Chair, would be this. He’s obviously reviewed, it sounds like, many, many environmental assessments, and I think his comments were “This one was different than others”. Could he explain perhaps a potential for what we call tunnel vision? I guess bias could be the same thing."
"Dr. Duinker, I think I heard in there that Mr. Robertson felt that your report showed that this EA was different from others and that it was too narrow. If you would help the Panel with that, please?"
"No environmental assessment is exactly like the last one, especially for big projects. They’re all unique. I have no comment about tunnel vision. My review of the environmental assessment on the topics of methods and approach to cumulative effects assessment and significance suggest to me that many improvements could have been made in the environmental assessment on those topics
I am not prepared to make any statement on any other topic in the environmental assessment. And I am also, at this point, probably wise to reiterate that the conclusions of the environmental assessment are not necessarily at fault because the methods were at fault. That can only be determined by a process of going through the methods, through better methods, to see if it comes up with the same conclusion"
"Just one short comment I think it’s the same with public trust; we could have ended up with ---"
"Mr. Robertson, please, I keep saying this every morning. Just questions. Thank you."
The panel was alert to misinformation masquerading as fact and speeches instead of questions. They were alert to a layperson interpreting technical information to suit their views. We've written about this [See the architect's graph puzzlement ].
As I went through or tried to go through all the questions that were asked by the anti-DGR people, I got the impression that they were reaching into an anti-DGR bag of bad questions and selecting at random.
But for the most part the Panel let people talk and some for extended periods of time. As the hearing went on into many days, nights and weeks, the Panel tried to shorten the speeches that the questioner hoped to be insightful in some way, but lacked a question mark or relevance.
Dr. Duinkert was of particular interest to the Panel. He was hired as an expert by them. He was carefully chosen, I'm sure. He did not just show up. He was not an anti-person coming from afar to repeat what had been alleged many times.
It was good to see the different approaches that were used by Duinker, OPG and CNSC.
Dr. Duinker's testimony attracted the attention of the uninformed and they made much of it by saying that he disapproved of this and that in the proponents argument. Let's see what happened.
But first here is an important fact about what went on relative to Professor Peter Duinker.
What the audience was exposed to was a partial peer review of a difficult topic. It was kind of any overview of methods. A topic in which the methodology is not familiar to laypersons. It was method that Duinker was talking about and not conclusions as you can see from the above response to Robertson.
There were a lot of definitions that Duinker wanted to put labels on and line up categories. This caused some confusion for the non-experts. It also caused some confusion for the proponent, panel and CNSC.
This is the way peer review works, but usually not before microphones with court recorders. There are views and opinions, references and back and forth. Statements of fact backed up by real references. There is added information used to clarify. No rubber stamps are used.
To those who have never followed scientific peer review it looks like controversy, but it is not at all. It is not contentious or angry. It's full of trying to get to the facts. In the process of making a point the expert makes his/her points and conclusions strongly and the rebuttal is powerful too.
So we should pay close attention to the issues and what the panel wanted from Duinker and what they received.
This testimony and the responses by OPG and CNSC were technical and interesting. They were full of jargon so a lay person audience had a hard time following what was going on and therefore a few rushed to conclusions that were not in the testimony either totally or by implication.
It appeared to me like the old black and white movie of the 1930's where people rush out of a crowded court room and queue up before a bank of old black phones to send in the latest sensational news for an extra edition. "Mabel, this is Al.... hold the presses!!!" You remember the scene with the boy on the street corner shouting "EXTRA, EXTRA, READ ALL ABOUT IT"
First you have to remember that the hearing was about the low and intermediate DGR to be developed at the Bruce site. Sometimes the anti-folks blurred that distinction as you can see in Mann's question/statement of opinion. He's always had difficulty with that distinction and the reasons for the 3 categories.
The Panel was interested in the ecosystems nearby. Examples of fish, water and red cedar stands were used as 'for instance' topics.
The panel heard Duinker's testimony and the proponents answers to it. They also engaged CNSC (Canadian Nuclear Safety Commission) in the discussions.
As a result Druinker and CNSC were asked to perform undertakings in written form to enlighten the Panel. They were given time to do this and their responses are now available.
That is, the Panel said: Go away and study this again and get back to us. What's been said so far needs amplification and clarification, the Panel claimed.
Duinker was asked in undertaking #52 the following:
"Instruction for the Undertaking
“Provide guidance regarding how the cumulative effects assessment could have included an ecosystem-based conceptual model showing linkages among existing and future activities and from the activities to possible effects on ecological structure and function. The conceptual model could be used, in turn, to assist in the identification of VECs that would have the best potential to indicate interactive effects, including synergistic, additive or antagonistic effects of multiple stressors as well as indirect and delayed effects.”
The Response by Duinker
"The literature abounds with classifications of types of cumulative effects, among them mine (unpublished) that posits cumulative effects of additive, synergistic, antagonistic, and masking types. These may be helpful as a back-of-mind framework to help assessors understand the outcomes they find in systems analysis of interactions between a set of stressors and a set of valued ecosystem component (VECs).
However, I would not expect impact analysts to begin their search for cumulative effects with the aim to ferret out those that are additive, those that are synergistic, those that are antagonistic, and so on. A discussion of these types of cumulative effects can be useful as an educational tool, and might be instructive after a cumulative effects analysis is accomplished; the types are probably not useful as an a-priori guide in the search for cumulative effects."
By the way, Duinker does not argue against the conclusions drawn by the proponent. [see response to Robertson] He was talking about these classifications again.
What he is calling for is more scenarios to use at a certain time. Get the classes right and he believes that clarity would be the result.
In one part of his testimony he used the phrase "back of the mind" to indicate that these ideas should be a backdrop for investigation. He wants these to be used as they deal with effects and most importantly, stressors and cumulative and synergistic interactions. These classifications became hard to follow. Things like additive and cumulative needed some crisp definitions.
Keep in mind that this Environmental Assessment is not a scientific document nor is the discipline strictly speaking scientific, but it is a methodology that is developing to insure safety. The science and engineering are contained not in the methodology, but in the items investigated.
"In my view, a sound approach would be to abandon all those constraints, choosing the VECs [Valued Ecosystem Component] wisely, which I do not discredit the Proponent for, look at all the potential stress agents, natural as well as human, in projects as well as other actions.
There is no guidance that says it’s only assessable projects that need to be considered, all other human actions that may have an effect. Combine those stress agents in sensible ways and predict how the valued ecosystem components might respond and then to contextualize those effects and predictions in the significance criteria and reason out a logical conclusion."
This he asserts will allow a richer view of the project and result analysis. That's the heart of it.
So the panel was interested in his testimony and asked him to come up with some advice and explain himself in a more concise manner. It is a good thing and it is helpful.
In his testimony he used the word illogical. What he meant is: I would not do it that way. He's dealing in more peer review here.
I was mildly interested in the reaction of the anti-proponents in the room and beyond. They responded in lock step as usual. It's fun to watch. Just like the 30s movie. They would be better served, however, to carefully read the testimony and the undertakings and stay for the finale and credits.
So what was the response to this by CNSC, who were charged in undertaking 53?
It may be difficult to read all that, but if you have time it's quite clear. It is also very impressive. I don't know if Duinker had all that information available to him during or before the hearings.
CNSC conclusions summarized by them:
"CNSC staff’s determination of significance of risk with respect to each of the environmental aspects considered here concluded that the EA was fit for purpose. It provided the necessary planning information for a framework for prevention or mitigation of adverse environmental effects. Where a few potential effects were brought forward in the EA or through independent review, staff made best use of available information using a precautionary approach to assess the weight of evidence for the need for further analysis, monitoring, or mitigation.
Overall, CNSC staff’s assessment supports the EA conclusion that site preparation, construction, and operation of the DGR will not result in significant adverse effects on the environment.
Detailed follow-up and operational environmental monitoring of potential impacts will be incorporated into a licence to facilitate adaptive management. Hence, project impacts will be overseen by CNSC staff through technical review, on-site inspections, and as required, through independent environmental monitoring by the CNSC laboratory."
Here are some things that Duinker's testimony spans. They are technical so if anyone is not interested in them, then they will be leaving behind the heart of the discussion.. It's hard to sort things out unless you do try to read what was said.. Stand back for a jargon attack, however.
Duinker talked and wrote about:
What Duinker really wants is to have a kind of a forum of experts in the environmental assessment come to some agreement about the composition and range of the what ifs. He wants things in categories that he defines. His view is too many scenarios are not possible. Too many outside influences are also not possible. Just keep adding them. They may interact one with another. They may trigger a thought process that is useful. Interaction is what he is worried about.
I think he is correct. I found in the modeling that I have done, that sometimes different stressors interact at different levels and have different impacts. So taking things at their maximum does not always produce the most drastic result due to how things combine. [See Risk Management and Intuition that I wrote ]
Duinker uses the simple example of a two part adhesive. If you apply one part to a surface and go away, you don't see any effect, when you come back. Nothing sticks. If you apply the other tube of goop in the same way later, you again see nothing.
But, if you apply them in the just right mix in the right time sequence by reading those pesky instructions, you see a dramatic effect.
So Duinker wants as many stressors and scenarios tossed in for consideration by the people who are reviewing the environmental impact. The interactions are important. Fair enough.
For example, Duinker might say, what if there is a terrorist attack during the construction of the DGR and this combined with a torrential rain storm causes runoff.
So, will the interaction from a contained terrorist attack that happens to damage some abatement measure like a check valve also influence the cedar trees? If so, how much?
This would be an interaction of two factors, runoff and terrorism, both of which we force to come in the same space, proper mix and time.
It's very important to notice that the terrorist attack might be easily contained, but the damage to a drainage valve might cause a problem with a red cedar stand subjected to a flood. It so happens that it won't, but that's beside the point.
In reality the runoff from the 'rock pile' is not significant. Lake Huron is used to runoff from limestone.
Now that might sound like a way out scenario [which I made up], but Duinker might nod his head, yes. In fact this drainage situation is considered in CNSC's undertaking 53 without the drama of the terrorist attack.
They point out that this drainage from the removed rock would not cause harm to habitat or cedars. It is also true that the drainage is not a long term issue as the DGR will be built, loaded and closed in a relatively short time as compared to the eons of life of the DGR. That's one of the prime reasons for a DGR.
Duinker might think that my scenario should be part of the 'back of the mind' thinking at some point even in model building and desk top review. It might be useful.
There is a lot to say for that position. It might influence the construction of the runoff containment design. It might engender a slightly different security process and response I suspect OPG and CNSC know that and have considered it.
If one only thought of a 100 year rain storm and not a simultaneous terrorist attack, then the design of the water abatement might be insufficient or the response different. The runoff would simply be designed for a 100 year storm, but the minor damage to the drainage system is the key to this valued eco-system.
This is an example and it is somewhat flawed because the damage done to the lake by a 100 year storm would dwarf and runoff from the rock sediment. As CNSC and OPG point out the amount can be easily handled by the volume of water contained in Lake Huron and the stream leading to a large bay.
In essence Duinker is for more scenarios, as many as possible. Dream them up until you drop! Then see how they can be used to test the analysis. Toss them into these categories so that have some context.
CNSC responded with a detailed report on how they viewed and dealt with what if's. Their testimony is not so different than Duinkers and adds some to the understanding. Again, that's peer review. He wanted this type of thing broken out and not assumed.
First everyone pointed out that they are dealing with a very small geographic area. Secondly, they claim that at every point the proponent has taken the most conservative approach.
So those are the base arguments. Notice that Duinker does not question the validity of the project or the stressors that they selected.. He does not even make a laundry list of ones he likes. He does supply categories that caused some confusion in the testimony.
The Panel wanted to know how the proponent and CNSC came up with risk thresholds when the literature is quite new on the subject. Discussions of probability and frequency were clarified to the Panel by OPG and CNSC. They asked questions because they wanted to know and Duinnker would have something to say about methods that he liked.
The Panel's Charge to CNSC for undertaking #53
Provide the results of CNSC staff’s evaluation of significance in sufficient detail to understand key features of the methodology and the criteria used to come to conclusions. For example (but not limited to)How were risk quotients determined for VECs with little or no thresholds available in the literature.
So CNSC did just that in undertaking 53
So that's about it for me on Professor Duinker. I think he did his job well and was a valuable source of information. He was a bit rigid in his categories and that caused some confusion of definition, but they were clarified.
His testimony also pointed out the weakness of the anti-people. Again, they look to me exactly like a 30's or 40's film noir gaggle of actors in a movie. But, they just have not read the script.
They don't need the script, when they know the conclusion they want, I guess
They never answer any question about the safety of above ground vs. 680 m below in rock that is 400,000,000 years old.
Look at the items in undertaking #53 and see what you think. Do you think it's better to do nothing or does the DGR pose the safer solution?
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Sunday, March 02, 2014