This discussion paper was prepared by Dr. Ole Hendrickson with input from many colleagues including former senior scientists and managers at Atomic Energy of Canada Limited.
Civil society urges suspension of decisions involving radioactive waste after international body finds Canada’s nuclear waste policy deficient
Ottawa (May 19, 2020) – Over one hundred civil society organizations and prominent scientific experts from across Canada have called on the federal minister of Natural Resources (Hon. Seamus O’Regan) to suspend all decision-making involving radioactive waste disposal until Canada has a sufficient radioactive waste policy in place.
In February 2020, it was reported by the International Atomic Energy Agency that Canada’s Radioactive Waste Management Policy Framework “does not encompass all the needed policy elements nor a detailed strategy” necessary to provide a national strategy for long-term radioactive waste management in Canada. In the letter, signatories request that the development of Canada’s radioactive waste policy and associated strategy must be based on “meaningful consultation with Indigenous peoples and strong public engagement from the outset.”
Signatories underscored the urgency of their request as Canada’s nuclear regulator, the Canadian Nuclear Safety Commission, presses ahead with regulatory licence decisions on a number of radioactive waste projects. Fearing Canada’s deficient radioactive waste framework will imprint itself on decisions affecting the health and safety of future generations and the environment, signees urged Canada to provide leadership, and establish sufficient guidance and federal policy.
Other commitments requested by signees included that Canada establish objectives and principles to underly a nuclear waste policy and strategy. They also requested Canada identify the problems and issues posed by existing and accumulating radioactive waste.
The full text of the letter sent to the Minister, may be found on the Nuclear Waste Watch website here: “Canada Needs a National Radioactive Waste Policy” May 15, 2020
Links:Find the letter to Minister Seamus O’Regan and the media release in English and French here: https://nuclearwastewatch.weebly.com/May2020Mai.html
A full list of deficiencies in Canada’s nuclear safety framework, identified by the IAEA, is available here: “International peer review finds deficiencies in Canada’s nuclear safety framework”
This study, by staff of the Canadian Nuclear Safety Commission purports to show that radioactive emissions from nuclear power plants in Ontario are not harming Canadians. It may in fact show the opposite. We offer the following observations about this study:
The Pickering results are suspect. The authors should have noted that emissions of nuclear substances from the six, 500-megawatt operating reactors at Pickering over the period of the study were less than from the four, 900-megawatt reactors at Darlington or the eight, 800-megawatt reactors at Bruce. But they did not.
Inclusion of Pickering skews the study. The very large population living within 25 km of the Pickering facility would be subject to many other influences on cancer incidence, including positive factors.
The authors should have looked at a smaller radius around Pickering – say, 10-15 km. In general, the study would have been much stronger had they done variable radii around all three reactor sites.
Also, the positive associations between cancer incidence and proximity to the Bruce and Darlington reactors are much stronger that the weak (and spurious) negative association in the Pickering data.
From the study:
“However, the number of cases varies considerably between the three
NPPs due to the large differences in population size of people living
within 25 km of Pickering, Darlington and Bruce NPPs (1,580,000;
380,000; and 24,500 respectively, based on the 2006 census year).”
(quote from p. 893).
Table 10, Bruce – 9% significant increase in incidence of all
cancers, 17% significant increase in incidence of lung cancer, 17%
significant increase in incidence of colon and rectal cancer. Total
observed cancers – 2570. Total expected cancers – 2362. Excess
cancers – 208 out of a population of 24,500.
Table 9, Darlington – 8% significant increase in incidence of all
cancers, 12% significant increase in incidence of lung cancer, 7%
significant increase in incidence of colon and rectal cancer, 8%
significant increase in incidence of thyroid cancer, 19% significant
increase in in incidence of bladder cancer, 26% significant increase
in in incidence of leukemia. Total observed cancers – 24,707. Total
expected cancers – 22,853. Excess cancers – 1,854 out of a
population of 380,000.
Excess cancers at Bruce and Darlington – 2,062 over an 18-year
period in a population at the end of that period of 404,500 – more
than a 0.5% increase of cancer.
Table 8, Pickering – The much larger population (1,580,000) within 25
km of the Pickering NPPs – which includes portions of Scarborough,
Ajax and Whitby – showed a lower overall cancer incidence than the
Ontario average, although incidence of thyroid cancer was
significantly increased (by 41%).
Lane et al. dismiss radiation as an explanation for the elevated
cancer incidence around Bruce and Darlington because “public doses
from environmental releases of radionuclides from Ontario NPPs
represent a very small fraction of natural background radiation (1.338
and 2.02 mSv/year) in the regions where the NPPs are located.” Based
on their “dose” calculations, they say that “Therefore, on the basis
of current radiation risk estimates and the supporting epidemiological
literature, radiation is not a plausible explanation for any excess
cancers observed within 25 km of any Ontario NPP.”
In fact it would appear that there is clear evidence of excess
cancers within 25 km of the Bruce and Darlington nuclear reactor
sites, but that the authors dismissed radiation as a cause of these
cancers because that would conflict with “current radiation risk
For immediate release (Montreal, April 8, 2020) Three independent organizations — the Canadian Association of Physicians for the Environment, the Canadian Coalition for Nuclear Responsibility and the Ottawa River Institute – have written to the Prime Minister saying that Canada’s nuclear safety standards and nuclear governance are failing to adequately protect Canadians from dozens of dangerous radioactive pollutants from nuclear facilities.
An April 3rd letter to Prime Minister Justin Trudeau cites serious deficiencies in Canada’s nuclear safety framework and nuclear governance that require urgent attention by government. The authors draw on the contents of a recent report to the government by the International Atomic Energy Agency (IAEA) on nuclear safety in Canada.
The IAEA review of Canada’s nuclear safety framework found that “CNSC regulations do not comprehensively cover all IAEA Fundamental Safety Requirements.” The report confirmed several concerns raised previously by Canadian public interest groups.
- Canada’s regulator is considering allowing future nuclear facilites (such as small modular reactors) and old radioactively contaminated nuclear reactors to be entombed and abandoned on site, a practice that is explicitly rejected by the IAEA;
- The IAEA found “no evidence… of a governmental policy or strategy related to radioactive waste management”;
- Canada’s nuclear legislation does not require justification of radiation risks from nuclear facilities; the IAEA says for nuclear facilities and activities to be considered justified, the benefits must be shown to outweigh the radiation risks to which they give rise;
- Canada’s system for managing the transport of radioactive materials does not align with IAEA regulations;
- There are problems in the ways that Canada authorizes radiation releases from nuclear facilities;
- Canada’s current and proposed regulations don’t adequately protect pregnant workers, students, and apprentices from radiation risks; eg. they allow four times higher radiation doses for pregnant nuclear workers than IAEA standards.
“These deficiencies concern us very much,” said Dr. Éric Notebaert of the Canadian Association of Physicians for the Environment. “We feel strongly that Canada is failing to adequately protect Canadians from dangerous radioactive substances that are known to cause cancers, serious chronic diseases, birth defects, and genetic damage that is passed on to future generations.”
The letter to the Prime Minister points out that these gaps in Canada’s nuclear safety practices, identified by the IAEA and others, leaves Canada vulnerable to unwise decisions on investment in new nuclear technology.
“Canada’s rush to promote and invest in small modular nuclear reactors is ill-advised” said Dr. Gordon Edwards, president of the Canadian Coalition for Nuclear Responsibility, “especially when these reactors have been exempted from environmental assessment. Such reactors will produce radioactive wastes of all varieties, yet there is no policy for their safe long-term disposition. With no need to “justify” the radiation exposures from such new reactors, entrepreneurs and provinces can proceed without any explicit consideration of faster, cheaper and lower risk energy alternatives to reduce carbon emissions.”
The letter also draws attention to nuclear governance problems cited in Environmental Petition 427 to the Auditor General of Canada. These include (1) outdated and inadequate legislation, (2) inadequate government oversight, (3) lack of checks and balances, (4) a federal policy vacuum on nuclear waste and nuclear reactor decommissioning, and (5) the problem of regulatory capture on the part of the Canadian Nuclear Safety Commission.
The authors of the letter support the recommendation in Petition 427 for the creation of a high-level, interdisciplinary, multi-stakeholder task force to advise the government on the needed reforms to nuclear governance in Canada.
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Letter to the Prime Minister, April 3, 2020:http://ccnr.org/Letter_Trudeau_03_04_2020_e.pdf
Environmental Petition 427 to the Auditor General of Canada, June 2019. Petition summary:https://www.oag-bvg.gc.ca/internet/English/pet_427_e_43421.html Full text of petition: https://concernedcitizens.net/2019/11/30/environmental-petition-nuclear-governance-problems-in-canada