If safe operation would not be possible, the design should not be approved

1986 Space Shuttle Challenger Disaster
For the last 30 years of his life, Bob Ebeling never recovered from his feelings of guilt for the 1986 disaster in which seven crew members of the Space Shuttle Challenger died. He was an engineer working for Morton Thiokol Incorporated, who provided the Solid Rocket Boosters for the Space Shuttles. He knew that the O-rings sealing the Solid Rocket Booster segments would not adequately seal after the unusally cold night before the January 28, 1986 launch. He did everything he could to have the launch cancelled but was overruled by the decision-makers both within his company and in NASA.

The next year he told an interviewer: “I have headaches. I cry. I have bad dreams. I go into a hypnotic trance almost every day”. Earlier this year, recounting that he couldn’t get the launch cancelled, he told an interviewer: “I think this was one of the mistakes that God made. He shouldn’t have picked me for that job.” You can read his obituary, as published April 12, 2016 in the Globe and Mail here.

Disasters would be prevented by decision-makers acting on the warnings they  receive.
Unfortunately, there are many good-intentioned people who refuse to accept the extreme dangers the proposed generating station would create. These people are the bureaucrats and political staff in both the Ministry of Natural Resources and the Ministry of the Environment, the Councillors of the Township of Muskoka Lakes who are facilitating the proposed construction, and the proponent and those that would finance them.
These people now have the choice to act on the responsibility we all have to do what we can to make the world safer for others. Or they can be troubled for the rest of their lives knowing that they could and should have done more to prevent a tragedy.

On-going Takata Air Bag Crisis
To reduce the cost of the propellant used to inflate their automotive air bags, in 1999 the Takata Corporation changed to using ammonium nitrate – despite warnings from their internal design staff. More detail is in the cover story of the June 12, 2016 issue of Bloomberg Businessweek magazine (click for graphic pdf, text text pdf, or video summary, or click below to hear an interview with the author). A graphic showing the increasing quantity and models of cars recalled over the past eight years is here.

The result has been deaths, lawsuits, and a recall of more than 60,000,000 cars worldwide – the largest recall ever, which will take years to complete, so until then these people’s own cars could kill them due to a minor collision where the air bag inflates (Transport Canada’s response is here).

One of the complexities is that the situation is worse for cars; used in high humidity areas (such as the southern US) and which are exposed to greater temperature fluctuations – as after several years these factors cause the propellant to break into a powder, which has more surface area and therefore reacts faster, causing too great an explosion and the air bag’s metal inflator tube fractures into shards that slice into the people in the car as a bomb’s shrapnel would. That is, the inflator design is too dangerous for the environment in which it would be used. While the danger is during the operation of the car, the fault and liability rests with those that approved the design.

The US National Highway Traffic Safety Administration found that: “Takata provided inaccurate, incomplete, and misleading information to regulators for nearly a decade. Had they told the truth, Takata could have prevented this from becoming a global crisis.”  Shigehisa Takada, after becoming CEO due to his father passing away, in 2015 said: “The company that should be offering the safety to the users ended up hurting them. It grieves me most deeply.”  The recall will cost much more than the 80-year-old company has.

Trying to save lives using air bags can kill people if the design is not suitable for the environment.
Trying to reduce the cost of a design can bankrupt a company if the design is too dangerous.
Trying to reduce global warming using hydro-electric power generation will drown nearby people.
In all cases, the intention was good. But in the complex world we live in, ignoring important details can kill people.

Design Approval Includes Confirming Safe Operation is Possible
Safe operation is only possible if the design considers the operating environment. In Bala, the operating environment is that people have and will continue to be in the water:

• That is their right as it is a navigable waterway.
• As required by Section 3 of the Public Lands Act, this public access must be maintained.
• There are both public and private docks, directly adjacent and both upstream and downstream, to the area to facilitate this access.

This public access is important to the area’s economy. Indeed part of the MNR’s mandate is “supporting outdoor recreation opportunities”.

We simply ask, how would the public be informed of the extreme dangers that would be created by the proposed generating station – which would:

• Start without warning at about noon on summer days.
• Have more than ten times the flow of the nearby Wilson’s Falls generating station and the treacherously turbulent water from its tailrace caused the drowning of a 16-year-old boy in 2008.

The MNR’s Best Management Practices publication Public Safety Around Dams states:

• On the second page that the MNR’s legislative authority includes governing the operation of hydro-electric generating stations.
• That the proponent must prepare a Public Safety Plan and this: “requires addressing both the physical structure and the dam’s operation, particularly as it relates to discharging water” and must include the: “operating practices and control measures that will be taken to either eliminate or mitigate the public exposure to the hazard”.

Unfortunately the MNR is attempting to claim they have no responsibility to ensure that the proposed Bala generating station could be operated safely, as they state: “SREL will be responsible for ensuring appropriate public safety measures are in place as they relate to the structures and resulting flows and levels. MNRF has no regulatory approval role related to public safety measures on dams.”

This is unacceptable since the approval from the MNR which the proponent still needs before constructing their proposed generating station (Plans and Specifications approval, under the Lakes and Rivers Improvement Act) must be issued by the Ministry Engineer who must be a Professional Engineer and licenced to practice in the province of Ontario. Professional Engineers have an obligation to the public, including to: “take all reasonable steps to protect the interests of parties that might be affected … before an incident occurs.” And it is required they will have: “identified all actual or potential hazards to the interests of the client, employer or public associated with the work” and “communicated the risks to all affected parties.” (PEO Professional Engineering Practice Guideline, January 2012).

Summary
The facts are:

1. The proponent has committed in their Environmental Assessment that swimming and boating could safely continue outside of their safety boom area.
2. The MNR has not yet approved the design of the proposed Bala generating station.
3. The MNR has a direct responsibility to identify potential hazards and risks to the public.
4. The proponent must provide a Public Safety Plan.

Before any further approvals are provided, we request that the MNR require the proponent provide an acceptable Public Safety Plan.