General on Expanding Bruce Site

I have been involved in the nuclear business for nearly 50 years, and have components of my design in both Bruce A and B, as well as all other CANDU plants and PWR plants as well.  I have worked at Bruce as recently as 2018, in the steam generator replacement programs. I am currently teaching at Conestoga College in areas like Advanced Energy Management, including long=term energy planning.   I applaud Bruce Power, the Government snf OPG for starting this journey.  I agree with the IESO assessment that a significant increase in Ontario's nuclear energy is warranted.

Regarding Bruce C, several things should be addressed:

1. What is the long term plan for Bruce A and Bruce B?  The reason I point this out is that starting in 2041, about the time Bruce C would be coming on-line, Bruce A will be running out of refurbished life (30 years from return to service date of 2011 for Units 1&2).  Is it the plan to refurbish these units again?  If yes, what is the plan regarding transmission lines from the site?  Increased capacity would be required.  This could be more impactful than the nuclear plant itself.

2.  The IESO decarbonization plan calls for a significant use of hydrogen by 2050.  There is no real plan for generating all of this hydrogen.  An ideal opportunity might be to generate "pink hydrogen" using the new Bruce C nuclear plant.  This could be a very effective sideline, much as the medical isotopes business has become an effective sideline at the Bruce site already.  It has not been clearly identified how or where all of the new hydrogen in IESO's plan will be used, but possibly it can be used and distributed as ammonia (NH3).  China is rapidly ramping up hydrogen and ammonia production in part to "over-fire" their coal-fired plants with ammonia, in order to meet a Government decree to cut emissions by half.  India has started exporting "green ammonia" to Japan.  Hydrogen production has started in an experimental program at the Prairie Island nuclear plant in Minnesota.  It works very well given the high temperature and purity of the waer available.  It should be at least addressed in the planning of Bruce C.  This is potentially a whole new business for Bruce County, and another way to "sell" the project to the public.

3.  I understand that the present planning is technology neutral, but in terms of "impact", the technology source could be very important.  MONARK is supposedly a CANDU derivative, probably the old CANDU 9 concept modernized, but still using heavy water and unenriched fuel.  If MONARK is selected, where is the heavy water coming from?  The fact that the Heavy Water Plant at the Bruce site no longer exists says a lot about future plans.  However, if Bruce A is to be phased out as Bruce C comes on line, the heavy water from Bruce A could be used in Bruce C.  Otherwise a plan is required, especially if new heavy water production is required.  We could continue to produce our own fuel with this option.  All other options listed are light water reactors using low enriched fuel.  Although Canada has lots of :Uranium, we have no capacity to enrich and must therefore import all fuel.  If we are embarking on a major light water reactor program in Ontario, it might make sense to consider a fuel enrichment program. The BWRX-300 reactors planned for Darlington will use low-enriched fuel, which will come from North Carolina.  It would be difficult and expensive to develop enriched fuel capability, but could have very big market potential, selling enriched fuel into the US.  Prior to the war with Ukraine, the Russians were supplying nearly 30% of the enriched fuel used in the US.

4.  One of the issues we have dealt with over the years at Bruce has been associated with direct lakewater cooling of heat exchangers, where leakage results in direct leakage of radiological contaminants into the Great Lakes.  This was always a bigger issue in Lake Ontario (Pickering, Darlington) but could be avoided altogether if the new reactors have intermediate cooling loops.  This is easier said than done, especially with gradually rising lake temperatures.  However, it will likely be demanded by the various Environment Ministries.  It should be addressed right from the planning stage, and advertised as a commitment to zero tritium emission in the lake water as a requirement of the contract.

5.  It will be important to understand, from an "Impact" point of view, exactly what the arrangement is for this contract.  Bruce Power currently leases the site from OPG, so OPG, and by extension the Government of Ontario owns the site and everything on it, although Bruce Power is the licensed operator.  Is the arrangement going to be the same for Bruce C?  Who has what say in the final technolgy decision?  What factors are being evaluated?  Who is taking what risk?  What guarantees are being provided by the reactor vendors in terms of performance, delivery schedule, sticking to the price once construction is underway, etc.  Who is responsible for providing the trained operating staff once the plant is ready?  The plant in Georgia basically bankrupted Westinghouse, but they are now owned by Brookfield of Canada.  What risk is Brookfield ready to take on a project like this?  A project in Finland (and one in France) basically bankrupted Framatome, who were put under the care of EdF.  Is EdF ready to fully underwrite this project?  To what degree are the vendors required to commit to using Canadian content?  Westinghouse had all major compoents for the Georgia reactors made in Korea.  Atkins Realis' (formerly SNC-Lavalin).CANDU Energy Division was formerly owned by the Government of Canada, and hence their activities were underwritten by Ottawa.  This is no longer the case and if a project "went South" on Atkins Realis, to what extent would they be able to cover the risks?  Atkins-Realis would certainly have an edge in Canadian content, but would need a complete plan, including where the calandrias would come from.  Licensing of MONARK should be much easier for CNSC than any of the light water options, but CNSC is already dealing with the BWRX plants, and Westinghouse has the fully approved AP1000 licensing packages from Georgia.  GE-Hitachi might be in a better position, but would definitely limit their liabilities, including nuclear liability.  They have never liked Canada's Nuclear Liability laws.  The old Ontario Hydro from the time of buiilding Pickering, Bruce and Darlington had their own Construction Division, and hence any cost or schedule over-runs during Construction were their own problem to sort out.  This is no longer the case.  How will the nearly inevitable schedule and cost over-runs during construction be dealt with?  Westinghouse at least has a track record from the recently completed Georgia reactors to use as a benchmark.

The Westinghouse experience from Georgia should be seen as a big positive from an evaluation point of view for them.  If their Georgia program is reviewed in detail, it will show exactly where the problems occued and what can be learned from them.  This can lead to significantly improved performance her in Ontario.  From my own experience in the PWR business in the US, including work with some of the largest US nuclear operating Utilities, IF WE IN CANADA WERE TO FIGURE OUT HOW TO BUILD WESTINGHOUSE 4-LOOP REACTORS ON A COMPETITIVE AND DEPENDABLE PRICE AND SCHEDULE, WE COULD POTENTIALLY SELL NEARLY 100 NEW REACTORS IN THE US!  I mean this quite seriously.  The US Utilities see Westinghouse 4-loop reactors (which the AP-1000 is) as their "dependable workhorse" reactors.  The US Government has recently stated that they need to double nuclear capacity and have even gone so far as to say (Janet Yellin) that they need "98 new reactors of the type recently completed in Georgia".  I was very successful selling major components from Canada into US PWRs, and found no resistance from the US Utilities bo buying from Canada.  If we are fully qualified, and have the best technology at the best price, and comprehensive warranties to back it up, selling into the US was no issue.  If we could also bring high volume hydrogen and ammonia technology, with the Chinese concept of over-firing coal-fired plants with ammonia, it might help the US to "smooth the transition" away from coal firing.  Coal firing is gradually being reduced in the US, but immediate elimination is a very difficult political issue.  Continued operation with reduced emissions might be an attractive alternative.  OPG should also be looking at the technology cholce as a model for their own future requirements.  For example, what about 4 reactors on the Nanticoke site?  Transmission lines for 4000 MWe  already exist.  Intake and outflow lines already exist.  If you were going to do this, would it not make sense to use the same technology as what Bruce selects?

In conclusion, I strongly support what you are contemplating at Bruce, with the Bruce C package.  Given that this is already a qualified nuclear site, I doubt that there would be a showstopper argument about negative impact, except possibly if extensive new transmission lines are required.  Looking at the considerations above might help guide the program to an outcome of very high value to Ontario.