October 6, 2020
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.
The November version incorporates new information on contractor fees and nuclear waste liabilities from the 2020 AECL Annual Report.
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
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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%).
Our comment:
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
estimates”.
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.
Specific deficiencies noted by the IAEA include:
“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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Contacts:
Dr. Gordon Edwards, Canadian Coalition for Nuclear Responsibility514-489-5118 cell: 514-839-7214 ccnr@web.ca
Dr. Ole Hendrickson, Ottawa River Institute613-234-0578 ole@nrtco.net
Links:
Letter to the Prime Minister, April 3, 2020:http://ccnr.org/Letter_Trudeau_03_04_2020_e.pdf
IAEA Report: https://www.iaea.org/sites/default/files/documents/review-missions/irrs_canada_2019_final_report.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
March 12, 2020
Mr. Rafael M. Grossi
Director General
International Atomic Energy Agency
Vienna International Centre
PO Box 100
1400 Vienna, Austria
Dear Mr. Grossi,
The Canadian Nuclear Safety Commission announced on February 25 that CNSC President Rumina Velshi has been named to Chair the International Atomic Energy Agency’s Commission on Safety Standards. We are deeply concerned about this appointment for the reasons explained below.
Firstly, we submit that the head of a national regulatory body with a documented history of failing to meet IAEA safety standards should not chair the IAEA Commission on safety standards. According to the recently released report (1) from the IAEA peer review of Canada’s nuclear safety framework,
A concrete example of the CNSC’s disregard of IAEA safety standards is its decision to allow three nuclear waste disposal plans to proceed to environmental assessment even though all three projects clearly contravene IAEA safety standards.The proposed facilities include: a giant, above-ground mound for permanent storage of one million tons of mixed radioactive and non-radioactive wastes including long-lived radionuclides such as plutonium-239, americium-243, zirconium-93, nickel-59, carbon-14 and many more as well as the planned entombment in concrete of two shut-down reactors beside major rivers that provide drinking water for millions of Canadians.
All three facilities would leak radioactive contaminants into the environment for millennia. The CNSC dismissed warnings from scientific experts about serious flaws in the three proposals during the project description phase of the environmental assessments. Hundreds of substantive concerns about the projects have been voiced by federal and provincial government departments, First Nations, civil society groups, municipalities, retired scientists, and concerned citizens. Nevertheless, the environmental assessments have been in progress for close to four years, far longer than the normal one-year period allowed for non-nuclear projects. The CNSC has changed the timelines more than once to give the proponent extra time to attempt to address concerns, and there are still no clear final deadlines for completion of the assessments. We and many of our colleagues brought our concerns about these proposed projects to the attention of your predecessor in April, 2018. (see letter to Dr. Yukiya Amano ) (2)
The CNSC has also been working to make “in-situ decommissioning” an acceptable strategy for shut-down nuclear reactors despite clear guidance from the International Atomic Energy Agency that the strategy should only be used in emergency situations such as during a severe accident. The recent IAEA peer review said Canada should “revise its current and planned requirements in the area of decommissioning to align with the IAEA guidance”. However the CNSC continues to work to expand the meaning of “exceptional circumstances” and include in-situ decommissioning as an acceptable strategy for “legacy” reactors.
The Canadian Nuclear Safety Commission is widely perceived in Canada to be subject to regulatory capture, as noted by the Expert Panel on Reform of Environmental Assessment in April 2017.* This problem of regulatory capture on the part of CNSC was highlighted in Environmental Petition 427, “Nuclear Governance Problems in Canada”(3), to the Auditor General of Canada, in June 2019. The nuclear industry publication, Nuclear Energy Insider, recently promoted Canada as an excellent place to develop small modular reactors, partly because of Canada’s “benign regulatory environment”. (4)
In our experience the CNSC prioritizes the needs of industry over protection of the public from the adverse effects of man-made ionizing radiation that is routinely released from all nuclear facilities. According to CNSC staff, the CNSC commissioners did not ever refuse to grant a license in the agency’s 17 year history to 2017. (5)
We believe the leader of a “captured” regulatory agency that fails to meet IAEA guidance on nuclear waste management and works to weaken safety standards for nuclear reactor decommissioning in their domestic application should not be eligible to chair the IAEA commission on international safety standards.
We would like to point out that we believe that Ms. Velshi may be in a conflict of interest situation in her current position as President of the Canadian Nuclear Safety Commission. Prior to her appointment as head of the CNSC, Ms. Velshi worked for seven years at Ontario Power Generation, in senior management positions. Therefore she may not qualify as “independent” according to IAEA General Safety Guide No. GSG-12 (Organization, Management and Staffing of the Regulatory Body for Safety), whichspells out in considerable detail the need for independence of the regulatory body in order to ensure that regulatory judgements can be made, and enforcement actions taken, without any unwarranted pressure from interests that may conflict with safety. We submit that Ms. Velshi’s perceived lack of independence from the nuclear industry makes her unsuitable to serve as the chairperson of the IAEA’s commission on safety standards.
Ms. Velshi has stated that she intends to use her chairmanship “to champion the importance of greater harmonization of standards and ensure they support nuclear innovation while never compromising safety”. We fear that Ms. Velshi’s chairmanship could result in the lowering of international standards, with an emphasis on benefits to the industry and support of “innovation” at the expense of public protection. We note that the CNSC successfully advocated for exemption from environmental assessment for small modular reactors in Canada (6); we would not like to see such an exemption become part of the “harmonization” of international standards envisioned by Ms. Velshi.
We value IAEA safety standards; at the moment they are all that is of an official nature standing between Canadians and three nuclear waste disposal projects that would adversely affect the environment and public health in Canada for generations. We urge you to maintain the integrity of IAEA safety standards and to continue to emphasize the vital importance of ensuring independence and objectivity.
Please reconsider the appointment of Rumina Velshi to the chairmanship of the IAEA commission on safety standards.
Yours sincerely,
Gordon Edwards, Ph.D,
Canadian Coalition for Nuclear Responsibility
Éric Notebaert, MD, M.Sc.
Canadian Association of Physicians for the Environment
Ole Hendrickson, Ph.D
Ottawa River Institute
CC:
The Right Honourable Justin Trudeau, Prime Minister of Canada
The Honourable François-Philippe Champagne, Minister of Foreign Affairs
The Honourable Seamus O’Regan, Minister of Natural Resources
The Hon. Andrew Scheer, Conservative Party of Canada
Yves-François Blanchette, Bloc Québécois
Jagmeet Singh, New Democratic Party
Elizabeth May, Green Party of Canada, Parliamentary Caucus Leader
Sylvain Ricard, Auditor General of Canada
Andrew Hayes, Interim Commissioner of Environment and Sustainable Development
* Excerpt from the Expert Panel Report: “A frequently cited concern was the perceived lack of independence and neutrality because of the close relationship the NEB and CNSC have with the industries they regulate. There were concerns that these Responsible Authorities promote the projects they are tasked with regulating. The apprehension of bias or conflict of interest, whether real or not, was the single most often cited concern by participants with regard to the NEB and CNSC as Responsible Authorities. The term “regulatory capture” was often used when participants described their perceptions of these two entities. The apprehension of bias on the part of these two Responsible Authorities eroded confidence in the assessment process.“ https://www.canada.ca/content/dam/themes/environment/conservation/environmental-reviews/building-common-ground/building-common-ground.pdf
Links
Concerned Citizens of Renfrew County and Area 