Comments on the Initial Project Description on the proposed NNW

Say NO to New Nuclear at Wesleyville, build renewables instead.

My comments are made based on my lived experience a resident of Durham Region which houses about half of the used nuclear fuel in Ontario and significant quantities of low and intermediate level radioactive (RA) waste. I have followed the activities of Ontario Power Generation and its proposals to expand both nuclear generation and to build/expand nuclear waste management operations for 25 years. I also worked on energy and nuclear policy as it affects host municipalities for over 20 years. In that role, I observed how the Canadian Nuclear Safety Commission (CNSC) largely ignores local concerns about financial, and social impacts of their operations on the local communities.  In Durham, they have brushed off concerns about the ongoing, growing, so-called “interim” storage of used fuel and other RA wastes at the two nuclear generating sites at Pickering and Darlington. Environmental assessment documents of the past, for example for the new nuclear project at Darlington, focused on mitigation of the impacts of site prep and construction, and operations. They inevitably laud the economic “benefits” of the project most of which accrue to the federal and provincial governments in payroll and corporate taxes.  Actual costs and benefits to local communities to deal with the effects of construction, rapid growth and related demand for services, and the stagnant (since 1968) contribution to property taxes on generating assets are inevitably barely considered. The really long-term configuration of these generating facilities including ongoing additions of onsite radio-active waste “interim” storage is barely identified to communities at the outset of the project. Somehow most of these issues are deemed out of scope for the EA. At CNSC hearings, these concerns are typically described as “not within the CNSC’s authority” to regulate.

This preamble is intended to raise the consciousness of the public, the Impact Assessment Agency of Canada (IAAC) and the potential host communities of the fine points and pitfalls that never appear in the cut and pasted, consultant-produced formal process documents like this initial project description (IPD). It's a segmented check list approach that does not connect the dots across the various processes or enormous time spans involved in such projects. Citizen concerns are swept aside by politicians focused on the next election, eager to support a complex mega project that will bring jobs and investment (at any cost) to their jurisdiction.

Not coincidentally, another recent IAAC posting presents an Initial Project description, over 1000 pages long, for the creation of the NWMO’s Deep Geological Repository (DGR). Seems like the nuclear sector has decided to “flood the zone” hoping to overwhelm citizens who might care to respond. As a resident of a community that seemingly stands to benefit from NWMO project, I should be unreservedly in favour of it. It would finally remove the radioactive waste from so called “interim storage” in my community. While I do believe that the DGR is really the only option for long term storage of used fuel, I doubt that I will live to see a single used fuel bundle moved from Durham to this DGR.

This is a cautionary tale for any community considering becoming a host community. In the context of my life, “interim storage” in my home Region has been “permanent storage”. Prospective future nuclear host communities such as Port Hope should prepare to be saddled with the resulting burden of nuclear waste indefinitely. They should demand a time-limited definition of “interim” after which a monetary penalty per bundle on site is applied.

Why? Because the federal government and CNSC continue to allow nuclear generators to pretend they have a solution for long-term management of nuclear waste. It's true that much study and investigation has been done. NWMO has drilled boreholes and designed storage casks and emplacement methods. But 20 plus years have passed and they are still just planning a DGR. Despite the fact that no used fuel has left an existing nuclear station in Ontario (perhaps all of Canada), the feds and CNSC, backed by the brain trust at Queen's Park, are now entertaining applications for new and refurbished reactors at Bruce, Pickering and Wesleyville.

The DGR planned for Ignace is not a sure thing for waste from existing stations. It will NOT be a home for the new waste that will be generated if Ontario’s nuclear ambitions are fulfilled, but I suspect most Ontarians are unaware of that. Do they know that the NWMO has just launched a process to site a second DGR? Who would like it sited in their hometown? Can NWMO find another willing host? Or will they just reconsider second-place South Bruce on Saugeen Ojibway Nation lands where informed consent was lacking?

In the meantime, Ontario Power Generation (OPG) and the other nuclear generators (who constitute the NWMO) will, in their IAs and new licence applications point to the ongoing “process” of siting this second DGR as if the solution is right around the corner. The CNSC will say “that’s fantastic, you have a plan, go ahead!” For me, this consistent unsupported result from Joint Panels and CNSC hearings on new nuclear facilities has completely undermined their credibility as regulator. It suggests a cozy relationship with the industry rather than an “independent” regulator. The career crossovers among OPG, CNSC, NWMO and various involved consultants is pretty stunning.

If any community should be aware of a legacy of nuclear waste, one would think Port Hope would be it! Current citizens should read the history of the battle their community had to have the old Eldorado wastes, that were spread all over town, remediated and relocated. They had to fight their own federal government for years to get their properties cleaned up and health studies done.

I hope that Port Hope and surrounding communities are aware of the history of waste storage at the current nuclear stations next door in Durham and at the Bruce station. At these sites, municipal property tax collected on generation facilities is governed by a statutory rate that hasn’t changed since 1968. This means that the property taxes paid on the reactor facilities fall further and further behind over time. The generators will tell the town that “property taxes are a provincial matter; so take it up with them”. But, in Ontario, municipalities “get no respect” from the province. So, potential host community, check the tax treatment of this new nuclear generating plant. Make sure you get a better deal from the Province or a long-term, indexed and increasing financial contribution from OPG included your community benefits agreement. Put some of that money in a reserve annually to soften the blow of the end of operations of the plant, which will eventually happen, and diversify your economic opportunities in advance.

Every few years at the nuclear plant sites in Durham, Ontario Power Generation (OPG) adds another waste storage building or two, a stone’s throw from Lake Ontario (the source of drinking water for millions of Canadians and Americans). Some of the buildings are for used fuel and some are for low and intermediate level waste (LILW) created by maintenance, upgrading, replacement and refurbishment of reactor equipment. The structures are given vague names like “component storage facility” and may be added via a very low key "hearing in writing". In the case of Pickering, which began operating in the 1970’s, in 50 years no used fuel has been moved out of “interim storage” where it lives safely (for the moment) in large dry storage containers housed in six warehouses. If the Pickering reactors 5 to 8 are refurbished to operate another 30 years OPG will need to build more and more of these storage buildings. The construction of SMRs at Darlington will also require more and more radioactive waste storage buildings over time.

Undoubtedly, OPG is reassuring the IAAC and Port Hope and Northumberland County that they will continue to be involved in decision-making processes related the 10 new reactors throughout the life cycle of the plant. This will occur through the various licencing and relicensing hearings. I hope the host communities are aware of the considerable time, attention, legal, policy and scientific effort and expertise they will need to invest to monitor and participate in the various regulatory processes…for the next century at least! Do you have the staff capacity to participate? How will you support the transfer of knowledge among your staff over many decades?

Relying on consultants for many aspects of this work is very unsatisfying and expensive. The consultant you will end up hiring are part of the nuclear sector and been trained in the scope narrowing game. Many of them probably started their careers working for OPG or Bruce Nuclear. They will produce a cookie-cutter response to a cookie cutter impact statement from the proponent. Ask the CNSC how many hearings this will involve as each new reactor or set of reactors is added. As a mitigation to this impact, the IAA process should require that community benefits agreements include conditions to protect the fiscal capacity and ongoing technical ability of the host communities to have meaningful input and effect on those regulatory processes

Potential host communities should be aware that lately, the CNSC sees regular requests by generators to reduce the number and frequency of these hearings and reviews by consolidation of licences, make the duration of the licence increasingly long (used to be 5 years, then 10, and OPG is now asking for 30-year licences). All of this reduces the minimal leverage a host community has over the on-site activities. Some hearings now, to expand waste storage (most recently at Pickering), are not in person, but held as hearing in writing. This is all done quietly, probably in the name of “efficiency” and undoubtedly cost-savings, but who benefits?

OPG’s documents will laud the amazing economic benefits of the NNW project with 1000’s of jobs created, supply chain development and a massive contribution to GDP and federal and provincial payroll taxes. However, on local financial contributions, OPG will resist your requests for clear information. OPG will tell you they pay property taxes to support local services they use. True but, I urge Port Hope and Northumberland to ask OPG to disclose in public documents what the anticipated assessment of the generating assets will be. What will the property tax benefit will be to your local and county governments will be based on the square meters of generating space? Then ask, based on that assessment value how much proxy property tax will be paid to the Province?

Any other industry would pay all their property tax to the local and regional municipalities/counties but Ontario skims off this proxy tax to help reduce the stranded debt from our last round of nuclear building. Then they also have the audacity to add a stranded debt charge to our electric bill. And OPG has recently gone to the OEB seeking a massive increase in our electric rates over the next five years to help finance Ontario’s nuclear power dreams.

Does this initial project description come clean on what the ultimate site plan will look like? Does it show the size and location of the additional waste structures (buildings or perhaps mounds) that will be needed at the point of decommissioning to hold the non-fuel radioactive wastes the plant created over its lifespan? If not, then the host communities are being asked to commit themselves to an unknown future facility. I hope they have built into their host community agreements iron-clad protections and compensation for these eventualities which will continue long after operations of the NNW cease.

A key function of the IAAC process should be to apply conditions to the project to protect the long-term health, safety and wellbeing of communities and regions most affected as well as those working on the project itself.

So the specific deficiencies of this Initial Project Description (IPD) include the following.

1. The 30-day consultation period is insufficient for citizens and affected communities to review and analyze the full IPD document. I have only read the summary document.
2. The IPD attempts to limit the scope of the IAA process limiting it to nuclear as the only technology to be considered for meeting Ontario’s future energy needs.The IESO document that IPD refers as the basis for this decision is not compelling in terms of nuclear as the only choice. It lists many quicker, more cost effective renewable energy alternatives that could be built to meet Ontario’s energy needs. Corporate Knights and other reputable energy analysts have published recent articles and papers on the much higher economic costs and limited benefits of new nuclear development. It simply does not make economic sense to choose nuclear and this will begin to be felt in our electricity bills as soon as next year if the OEB approves the OPG rate application.
3. Until Canada has a fully functional repository for used nuclear fuel and other nuclear wastes, no more nuclear reactors should be built in this country.  We cannot keep pushing this poisonous legacy onto future generations.
4. he Region of Durham and community of Clarington must also be listed as directly affected communities as they are within a couple of kilometers of the NNW site. People in these communities will have to receive Potassium Iodide pills and these communities will be involved in emergency response and planning. They will also be monitoring all of the same approval and licensing stages that Port Hope will. Saying that these citizens are already “well-prepared nuclear communities” does not mean that they are willing or will not be directly affected by having 10 more reactors built on their doorstep.
5. Conclusion: There must be a full impact assessment of the whole project including transportation, with public hearings not just in the that will be affected by the impacts of this project.