Letter to Treasury Board from women leaders across Canada re small nuclear reactors

September 21, 2020

The Hon. Jean-Yves Duclos, President

The Hon. Joyce Murray, Vice-Chair

The Hon. Bardish Chagger, Member

The Hon. Catherine McKenna, Member

The Hon. Chrystia Freeland, Member

The Hon. Jonathan Wilkinson, Member

Dear Mr. Duclos and Members of the Treasury Board:

We write to you as women community and Aboriginal leaders in science, medicine, law and environmental protection to request your urgent attention to the need for Canada to uphold its legal obligation, as a party to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, to minimize generation of radioactive waste.

Radioactive waste is dangerous, poses risks to all living things and must be kept out of the biosphere for as long as it poses a radioactive hazard (many tens of thousands of years). Article 11 of the Joint Convention states that parties shall “ensure that the generation of radioactive waste is kept to the minimum practicable”. 

Small modular nuclear reactors, currently under consideration for taxpayer-funded development in Canada, would produce long-lived hazardous nuclear waste as part of normal operations. These reactors are proposed for Northern, remote and First Nations communities in some of Canada’s most fragile and globally important ecosystems. UNDRIP principles of free prior, and informed consent with indigenous communities have not been respected. 

Production of plutonium and other fuels for small modular nuclear reactors would create long-lived hazardous nuclear waste. Small modular nuclear reactors would themselves become hazardous, long-lived nuclear waste; too hot to handle after their short lifespan of a few decades, and too costly to transport, they would likely be abandoned in place leaving permanently contaminated, radioactive exclusion zones, a few hectares in size, everywhere they were deployed.

Low-carbon alternatives to nuclear technology for electricity generation are readily available, faster to deploy, much less expensive and do not generate radioactive waste. They also create more jobs. Small nuclear reactors are therefore not a useful or necessary climate change mitigation strategy.Canada can much more easily, cheaply and quickly get to net zero carbon with a combination of energy conservation and renewables. For details please see Environmental Petition 419 to the Auditor General of Canada.

Small nuclear reactor proponents tout the notion that small reactors will use existing nuclear waste for fuel. This is a dangerous fantasy. In reality, “recycling” radioactive waste creates more radioactive waste, passing the buck to future generations. Worse, reactor technologies that use recycled fuel require extraction of plutonium, creating serious national security risks associated with nuclear weapons proliferation. 

We submit that federal support and funding for development of small modular nuclear reactors would constitute an abnegation of Canada’s international commitment to minimize generation of radioactive waste. 

We urge you to bring this matter to the attention of your Cabinet colleagues, and cease all government support and taxpayer funding for small modular nuclear reactors.

Yours sincerely,

Anne Lindsey, MA, O.M., Winnipeg, Manitoba

Brennain Lloyd, North Bay, Ontario

Candyce Paul, English River First Nation, Saskatchewan

Dr. Cathy Vakil, MD, Kingston, Ontario

Dr. Dale Dewar, MD, Wynyard, Saskatchewan

Dr. Dorothy Goldin-Rosenberg, PhD, Toronto, Ontario 

Eva Schacherl, MA, Ottawa, Ontario

Ginette Charbonneau, Physicist, Oka, Quebec

Gretchen Fitzgerald, BSc, Halifax, Nova Scotia

Johanna Echlin, M.Ed., Montreal, Quebec

Dr. Judith Miller, PhD, Ottawa, Ontario

Dr. Kathryn Lindsay, PhD, Renfrew, Ontario

Kerrie Blaise, MSc, JD, North Bay, Ontario

Lynn Jones, MHSc, Ottawa, Ontario 

Dr. Martha Ruben, MD, PhD., Ottawa, Ontario

Pippa Feinstein, JD, LLM, Toronto, Ontario

Dr. Susan O’Donnell, PhD, Fredericton, New Brunswick

Civil society groups condemn plan to exempt nuclear reactors from Bill C-69 impact assessment

FOR IMMEDIATE RELEASE

Ottawa, May 7, 2019 — The Government of Canada is proposing that the “project list” for Bill C-69, the Impact Assessment Act, exempt many nuclear reactors from any environmental assessment.  Civil society groups are condemning the exemption from environmental assessment under Bill C-69 and demanding that all new nuclear reactors be subjected to formal environmental assessment, as is now the case.

The federal government’s discussion paper, released on May 1, proposes that all nuclear reactors that produce less than 200 megawatts of thermal power be excluded from the Impact Assessment Act, as well as nuclear reactors built on existing nuclear sites that produce up to 900 megawatts of thermal power. 

“Excluding nuclear energy projects from impact assessment means there will be no credible sustainability-based assessment of the environmental, health, economic or social impacts of new, expanded or refurbished nuclear energy projects before they proceed,” says Theresa McClenaghan, Executive Director and Counsel for the Canadian Environmental Law Association. “In our view, giving the nuclear power industry a free pass under the Impact Assessment Act is the antithesis of sound and precautionary environmental planning, and should not be countenanced by Parliament.” 

“It is shocking that the federal government expects nuclear projects to go ahead with no impact assessment,” says Dr. Ole Hendrickson, a retired Environment Canada scientist and board member of Sierra Club Canada Foundation. “This may benefit the nuclear industry, but at the expense of the environment, public health and safety and the rights of Indigenous communities.”

In November, federal Minister of Natural Resources Amarjeet Sohi launched a “roadmap” at a nuclear industry conference in Ottawa that outlines plans to build Small Modular Reactors (SMRs) in Indigenous and northern communities and at remote mining sites across Canada. The Roadmap’s recommendations included comments suggesting that SMRs should be exempted from Bill C-69. 

The discussion paper for Bill C-69 regulations says that the effects from SMRs are “well known” and “share core characteristics” with existing conventional reactor technology. However, all proposed SMRs would employ new and untested designs, or technologies, some involving liquid metal and molten salt coolants that caused serious accidents in early prototype reactors, and some using controversial fuels never commercially allowed in Canada before, based on plutonium, thorium, or enriched uranium. 

“People in northern and Indigenous communities where the nuclear industry wants to build these reactors have a right to know what the risks are,” says Hendrickson. “A formal impact assessment with public disclosure is essential to identify these risks, including radioactive emissions and long-lasting contamination of soil and groundwater, especially due to malfunctions or accidents.”

Impact assessment of SMRs became a focus of media attention last November when it was revealed that Canada’s nuclear regulator, the Canadian Nuclear Safety Commission (CNSC), had been secretly lobbying the Government for the reactors to be exempted from environmental assessment. The Globe and Mail reported that CNSC encouraged the government to exempt small modular reactors from the list of designated projects (see Federal nuclear regulator urges Liberals to exempt smaller reactors from full panel review – November 6, 2018).

The discussion paper also does not include decommissioning of nuclear reactors and facilities on the project list for Bill C-69.   Decommissioning includes cleaning up, dismantling and removing contaminated nuclear facilities; storing the resulting radioactive waste; and returning the nuclear sites back to public use. This is despite the environmental risks of these activities and direct requests from host communities.  

Remediation of contaminated nuclear sites, new radioactive waste storage facilities at existing nuclear sites, and nuclear waste transport are also not identified for impact assessment in the discussion paper.

The federal government is giving Canadians until May 31 to submit comments on the discussion paper regarding the Bill C-69 Project List at the following address: impactassessmentregulations.ca    

ABOUT CCRCA

The Concerned Citizens of Renfrew County and Area was formed in 1978 to research and advocate about nuclear waste and other pollution issues in Eastern Ontario and the Ottawa River watershed. The group works closely with other civil society groups to promote responsible management of radioactive wastes and protection of the environment.

ABOUT CCNR
The Canadian Coalition for Nuclear Responsibility is a not-for-profit organization, federally incorporated since 1978, dedicated to education and research on all issues related to nuclear energy, whether civilian or military, especially those pertaining to Canada.

ABOUT SIERRA CLUB CANADA FOUNDATION

Sierra Club Canada Foundation is a national and grassroots non-profit organization committed to empowering people to protect, restore and enjoy a healthy and safe planet.

ABOUT RALLIEMENT CONTRE LA POLLUTION RADIOACTIVE

The mission of the Ralliement contre la pollution radioactive (RCPR) is to act voluntarily and collectively to promote responsible solutions for the management of radioactive waste that are safe for the environment and for the health of the population.

ABOUT CELA

The Canadian Environmental Law Association is a public interest law group founded in 1970 for the purposes of using and enhancing environmental laws to protect the environment and safeguard human health. CELA lawyers represent low-income and vulnerable communities in the courts and before tribunals on a wide variety of environmental and public health issues.   

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Media contacts:

Theresa McClenaghan
Executive Director and Counsel, 

Canadian Environmental Law Association

theresa@cela.ca

416-960-2284 ext.7219

Lynn Jones 

(to arrange an interview with Dr. Ole Hendrickson of SCCF or Dr. Gordon Edwards of CCNR)
Concerned Citizens of Renfrew County and Area
hendrickson.jones@gmail.com 
613-234-0578

Ginette Charbonneau

Ralliement contre la pollution radioactive

ginettech@hotmail.ca

514-246-6439

Federal nuclear regulator urges Liberals to exempt smaller reactors from full panel review

Globe and Mail article

SHAWN MCCARTHY GLOBAL ENERGY REPORTER

OTTAWA

PUBLISHED NOVEMBER 6, 2018 UPDATED 2 HOURS AGO

FOR SUBSCRIBERS

COMMENTS

Canada’s nuclear regulator has urged the federal government to allow smaller nuclear reactors to avoid lengthy impact assessments, a move that would create an easier and faster path for commercialization of the technology.

So-called “small module reactors,” or SMRs, have been touted as a low-carbon energy option for remote communities. But briefing notes from the Canadian Nuclear Safety Commission (CNSC) show it is worried that protracted impact assessment hearings could be detrimental to the commercialization of the reactors in Canada. The commission told the government it should retain responsibility to conduct environmental reviews when construction projects are proposed, according to documents obtained under access to information laws.

The SMRs represent the nuclear industry’s latest effort to reduce its high capital costs and would have a capacity ranging from 1.5 megawatts to a utility-scale 300 megawatts.

In one briefing document for internal discussions, the regulator notes the nuclear industry’s concerns about “longer regulatory timelines” that would result from passage of the government’s Impact Assessment Act – Bill C-69, which is now before the Senate. The CNSC encourages the government to exempt small modular reactors from the list of designated projects that would receive a full panel review, and warns that lengthy regulatory delays could kill a promising industry. The documents were obtained by Greenpeace Canada.

Proponents argue the small modular reactors could supply a wide range of electricity needs, from replacing dirty, unreliable diesel generation in remote communities, to providing low-carbon electricity for oil sands operations. They paint a vision of impoverished Indigenous communities getting reliable and affordable power from 1.5-megawatt reactors that would replace diesel, or off-grid mines and oil sands plants using larger reactors to provide low-carbon energy to their operations, and of units that would anchor “energy parks” and complement solar and wind generation.

“The future of the nuclear industry, especially for Canadian participants, is dependent on the success of SMRs,” says the April, 2018, note to CNSC’s then-president Michael Binder, who has since retired. “It is very important to get the project list right so that there is a reasonable threshold on what kind of projects require an IA [impact assessment].” Another briefing note also says CNSC is recommending the government adopt thresholds to ensure proposals to build small reactors do not face a full impact review.

Panel members of a full impact assessment would come from a broad cross-section of the public representing various disciplines, appointed by the government.

Greenpeace researcher Shawn-Patrick Stensil argues the CNSC’s preferred approach would prevent a broad-based review of the safety and environmental risks from untested reactor technology that will produce highly radioactive waste.

CNSC spokesman Aurele Gervais said the commission believes there should be a threshold for full impact assessments “based on risk.”

“Regardless, all projects would still be subject to environmental assessments under the Nuclear Safety Control Act,” which is administered by the CNSC, he said.

On Wednesday, Natural Resources Minister Amarjeet Sohi is scheduled to release a “road map” – prepared by industry with support from the federal government – on how Canada can participate in the development of next generations of reactors. “We will make sure that we are looking at every aspect of this industry from safety, from regulation, to the potential for northern communities, the potential of co-generation for large industrial complexes,” he told reporters on Tuesday.

In an interview, Mr. Sohi said the government will consider the industry proposals, but has not committed to providing any support for the commercialization of SMRs. In an Oct. 30 letter to Mr. Sohi and Environment Minister Catherine McKenna, critics representing 25 advocacy groups argue SMRs would be more expensive per kilowatt of power than traditional reactors and would continue to produce radioactive waste with no permanent disposal methods available.

Government-owned Canadian Nuclear Laboratories (CNL) is in talks with several companies that are developing SMRs and is aiming to have several demonstration plants at its site on Chalk River, 200 kilometres northwest of Ottawa, assuming the developers receive a safety licence from the CNSC. Currently, 10 companies have submitted plans to the commission for a “pre-licensing design review” in which the regulator provides high-level feedback on whether their technology would meet with Canadian standards.

CNL is hosting an international gathering of SMR developers in Ottawa this week. That list includes Pittsburgh-based Westinghouse Electric Co., which is now owned by Brookfield Asset Management Inc., and Terrestrial Energy Inc., which has cleared the first stage of the pre-licensing review with the CNSC.

At a presentation on Monday evening, CNL president Mark Lesinski said it is critical for the industry to be able to build demonstration plants at an existing nuclear site like Chalk River, in order to prove and fine-tune its technology before pursuing commercial deals. Industry officials suggest it would likely take five years before an SMR design is licensed in Canada, and another five years before they are sold commercially. However, in their letter to the ministers, the advocacy groups urged the government to refuse any support for new nuclear reactor technology.

“The nuclear lobby’s promises of affordable new reactors able to fight climate change are always conditional on government subsidies, watering down safety and limiting the public’s right to information,” Greenpeace’s Mr. Stensil said on Tuesday. He argued it is inappropriate for the CNSC to lobby on behalf of the industry that it regulates. The commission provided a submission to the government on the Impact Assessment Act, but has refused to release it, he said.