by Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility
December 19, 2020
Civilian nuclear and military nuclear have always been friendly room-mates, members of a “mutual admiration” society. In today’s announcement of an SMR Action Plan, Natural Resources Minister Seamus O’Regan said that nuclear power in Canada is a “home-grown” technology and referred to C. D. Howe’s role in this connection. In fact C.D. Howe arranged for all Canadian uranium extracted from Canadian mines to be sold to the US military for use in tens of thousands of nuclear weapons from 1945 to 1965. C D Howe was also on the Committee that met in Washington DC in 1944 to approve the first nuclear reactors to be built in Canada (at Chalk River) as part of the ongoing effort to produce plutonium for use as a nuclear explosive. Mr. Howe approved of the policy of selling plutonium produced at Chalk River to the US military for weapons use, a practice that continued until 1975 and beyond. Plutonium from Chalk River was sent to Britain (it was the first sample of plutonium that Britain had ever obtained) just a few months before Britain detonated its first A-Bomb in the Monte Bello Islands off Australia.
To the best of my knowledge, no civilian nuclear power agency – not the Canadian Nuclear Association, nor the Canadian Nuclear Society, nor the Canadian Nuclear Safety Commission, nor Atomic Energy of Canada Limited, nor Canadian Nuclear Laboratories, NOBODY – has ever issued a clear statement denouncing nuclear weapons or even calling for a nuclear weapons free world. Most nuclear scientists and engineers feel a strong kinship and camaraderie with those who are in the nuclear weapons business. The same goes for those in the nuclear division of Natural Resources Canada. I remember on one occasion (prior to the exchange of nuclear tests between India and Pakistan) I expressed alarm at the fact that both neighbours are developing a nuclear war-fighting capability and a couple of senior civil servants said “Would that be so bad? Maybe that’s just what the world needs. More deterrence. Creates stability”
Despite regular denials from our puppet masters that civilian nuclear has nothing to do with military nuclear, it is clear that civilian nuclear (including the frankly discriminatory provisions of the NPT) has adopted an appeasement policy that will never succeed in bringing about a nuclear weapons free world. Why does Canada continue to sell uranium to countries that are in the process of investing hundreds of billions to improve and modernize the nuclear arsenals in utter defiance of the NPT, knowing that the vast bulk of Canadian uranium that is rejected from enrichment plants as DU end up as the raw material for producing plutonium for Bombs, and that the lion’s share of the explosive power – and the overwhelming share of the radioactive fallout – of every H-bomb comes from the fissioning of DU atoms that are freely accessed by the military even if they are the leftovers of “peaceful” fuel production for nuclear power plants?
“The indigenous UK supply chain that supports defence nuclear programmes requires significant ongoing support to retain talent and develop and maintain capability between major programmes. Opportunities for the supply chain to invest in new capability are restricted by the limited size and scope of the defence nuclear programme. A UK SMR programme would increase the security, size and scope of opportunities for the UK supply chain significantly, enabling long-term sustainable investment in people, technology and capability.
“Expanding the talent pool from which defence nuclear programmes can draw from would bring a double benefit. First, additional talent means more competition for senior technical and managerial positions, driving excellence and performance. Second, the expansion of a nuclear-capable skilled workforce through a civil nuclear UK SMR programme would relieve the Ministry of Defence of the burden of developing and retaining skills and capability. This would free up valuable resources for other investments.”
As noted in the recent Hill Times op-ed by Eva Schacherl, Political Opposition Growing to New Reactors, both small modular nuclear reactors AND the high-level fuel waste they produce are EXEMPT from environmental assessment in Canada
From the op-ed:
“The Impact Assessment Act was intended to create “greater public trust in impact assessment and decision-making.” But there will be no federal assessment of nuclear reactors up to 200 thermal MW in size, nor of new reactors built at existing nuclear plants (up to 900 MWth). Yet new tidal power projects, as well as offshore wind farms with 10 or more turbines, need an assessment under the regulations, as do many new fossil fuel projects.”
“Also exempted from federal assessment is the “on-site storage of irradiated nuclear fuel or nuclear waste” associated with small modular reactors. This will make it easier for SMRs’ radioactive waste to be potentially left in the northern, remote, and First Nations communities, where they are proposed to be built.”
This SMR fuel waste exemption was a last-minute insertion in the Impact Assessment Act regulations. It is found in section 28 of the Physical Activities Regulations (the so-called ‘project list’ for the new Impact Assessment Act and reads as follows:
28 The construction and operation of either of the following:(a) a new facility for the storage of irradiated nuclear fuel or nuclear waste, outside the licensed boundaries of an existing nuclear facility, as defined in section 2 of the Nuclear Safety and Control Act, other than a facility for the on-site storage of irradiated nuclear fuel or nuclear waste associated with one or more new fission or fusion reactors that have a combined thermal capacity of less than 200 MWth;
As far the fuel waste from the proposed SMR (the “MMR Project“) at Chalk River is concerned, there is another exemption in section 28 – the phrase “outside the licensed boundaries of an existing nuclear facility” allows it to be kept on site at Chalk River, a licensed nuclear facility.
The nuclear industry and Liberals have not only been laying the groundwork for government funding. It appears they have been ensuring that the framework for nuclear energy in Canada gets even more accommodating.
Natural Resources Minister Seamus O’Regan has been hyping so-called next-generation reactors for months, portraying the industry as a future utopia. The Hill Times photograph by Andrew Mead.
Many Canadians are anxious to see what our energy future will be. Politically, it’s a question that stirs passions from Alberta’s oil patch to Ontario’s cancelled wind farms.
That would mean opportunities lost for those dollars to build many times the amount of zero-emission energy with renewables and energy-efficiency projects. The latter would not create toxic radioactive waste for future generations to contend with.
It seems inevitable that the Liberal action plan will soon be launched with generous handouts for the nuclear industry, whose aspiring players in Canada today include SNC-Lavalin and U.S. corporations like Westinghouse and GE-Hitachi Nuclear Energy. Few Canadians are aware that “Canadian” Nuclear Laboratories (CNL) is owned by a consortium of SNC-Lavalin and two U.S. firms, Fluor and Jacobs.
In recent years, the nuclear industry and Liberals have not only been laying the groundwork for government funding. It appears they’ve also been ensuring that the framework for nuclear energy in Canada gets even more accommodating.
The biggest step was exempting most new reactors from the Impact Assessment Act, which, in 2019, replaced the Canadian Environmental Assessment Act. This was deemed so important to the nuclear industry’s future that the Canadian Nuclear Safety Commission (CNSC) lobbied the Liberal government to exempt small reactors—and won. So much for the CNSC, the regulator that’s supposed to oversee the industry, being seen as objective and “world class.”
The Impact Assessment Act was intended to create “greater public trust in impact assessment and decision-making.” But there will be no federal assessment of nuclear reactors up to 200 thermal MW in size, nor of new reactors built at existing nuclear plants (up to 900 MWth). Yet new tidal power projects, as well as offshore wind farms with 10 or more turbines, need an assessment under the regulations, as do many new fossil fuel projects.
Also exempted from federal assessment is the “on-site storage of irradiated nuclear fuel or nuclear waste” associated with small modular reactors. This will make it easier for SMRs’ radioactive waste to be potentially left in the northern, remote, and First Nations communities, where they are proposed to be built.
The nuclear regulator has also been responsible for introducing a suite of “regulatory documents” on reactor decommissioning and radioactive waste that environmental groups have called “sham regulation.”
Meanwhile, the bureaucrats at the CNSC have been busy signing a memorandum of cooperation with the U.S. Nuclear Regulatory Commission on Small Modular Reactors. This agreement means that Canada can recognize U.S. reviews of reactor designs in order to “streamline the review process.”
CNSC has also outlined its plan in a document called Strategy for Readiness to Regulate Advanced Reactor Technologies. In a nutshell, the document says that regulations for new reactor designs will have to be flexible. It notes that CNSC regulated the earlier generation of water-cooled reactors (such as CANDUs) at first based on “objectives” in the 1950s and ‘60s. Then, as experience with these reactors evolved, regulations became more detailed and prescriptive. It says the same may have to happen with the new next-gen reactor designs.
In the 1950s, there were indeed few “prescriptive requirements” for the newfangled reactors. In 1952, the NRX reactor at Chalk River, Ont., had a meltdown. It was the first large-scale nuclear reactor accident in the world and took two years to clean up—which, by 1950s standards, included pumping 10,000 curies of long-lived fission products into a nearby sandy area. Then in 1958, the NRU reactor at Chalk River—a test bed for developing fuels and materials for the CANDU reactor—had a major accident, a fuel-rod fire that contaminated the building and areas downwind. It took 600 workers and military personnel to do the top-secret clean-up.
Let’s hope today’s regulators and lawmakers can learn from history. Does Canada really need or want to be the “leading-edge” testing ground for new experimental nuclear reactors? Canadians should have their say in a referendum—or at the ballot box.
Eva Schacherl is an Ottawa-based environmentalist.
Dear Mr. Duclos and Members of the Treasury Board:
On September 21, 2020 we wrote to you as women who are Indigenous and non-Indigenous community leaders in science, medicine, law and environmental protection to ask you to stop funding new nuclear reactors. Canada is a member of an international nuclear waste treaty and has a legal obligation to minimize generation of radioactive waste. Federal funding for new nuclear reactors would be an abnegation of this treaty obligation.
Today we are joined by women colleagues from all provinces and territories in Canada and several Indigenous communities. We strongly urge you to reject new nuclear reactors, called “SMRs.” They are being promoted to your government as a silver bullet to address the climate emergency. This is a false notion.
Solar and wind power are already the cheapest and fastest-growing electricity sources in the world. A 2018 Deloitte report, “Global Renewable Energy Trends: Solar and Wind Move from Mainstream to Preferred” concluded: “Solar and wind power recently crossed a new threshold, moving from mainstream to preferred energy sourcesacross much of the globe”. The report noted that solar and wind power enhance electrical grids. It also pointed out that intermittency is no longer a concern owing to rapid advances in storage technology. Canada should fund much wider deployment of solar and wind power.
More funding for energy efficiency and energy conservation would also be a much better use of tax dollars than handouts to the nuclear industry. The 2018 report presented by the Generation Energy Council to Canada’s Minister of Natural Resources found that: “Canada’s greatest opportunities to save money, cut greenhouse gas emissions and create jobs can be found in slashing energy waste. Fully one-third of our Paris emissions commitment could be achieved by improving energy efficiency.”
We urge you to say “no” to the nuclear industry that is asking for billions of dollars in taxpayer funds to subsidize a dangerous, highly-polluting and expensive technology that we don’t need. Instead, put more money into renewables, energy efficiency and energy conservation. This will create many thousands of jobs and quickly reduce greenhouse gas emissions.
We must never forget that the main product of nuclear reactors — in terms of planetary impact — is deadly radioactive poisons that remain hazardous to all life on earth for hundreds of thousands of years. The electricity they produce for a few short decades is but a minor by-product. There is no proven safe method for keeping radioactive waste out of the environment of living things for hundreds of thousands of years.
Please see Environmental Petition 419, submitted to the Auditor General of Canada in November 2018, for more detail on why Canada should refuse multibillion dollar handouts to subsidize the nuclear industry.
We urge you to bring this matter to the attention of your Cabinet colleagues, and stop all government support and taxpayer funding for so-called small modular nuclear reactors.
Alma H. Brooks, Wolastoqew and Eastern Wabanaki (New Brunswick)
Chief April Adams-Phillips, Mohawk Council of Akwesasne (Quebec)
Candyce Paul, English River First Nation (Saskatchewan)
Ellen Gabriel, Mohawks of Kanehsatà:ke (Quebec)
Eriel Deranger, Member of the Athabasca Chipewyan First Nation, Treaty 8 (Alberta)
Hilu Tagoona, BA, Qairnimiut Inuk, (Nunavut)
Dr. Imelda Perley Opolahsomuwehs, Neqotkuk First Nation (New Brunswick)
Joan Scottie, Inuk, Nunavut Makitagunarngningit, Baker Lake, Nunavut
Lorraine Rekmans, member of the Serpent River First Nation (Ontario)
Dr. Lynn Gehl, PhD, Algonquin – Pikwakanagan First Nation (Ontario)
Mary Alice Smith, BA, Metis Cree, Robinson-Superior Treaty area, Longbow Lake (Ontario)
Mary Lou Smoke, Anishinawbe Kwe, Bear Clan
Neecha Dupuis, Ojibway Nation of SAUGEEN Indian Tribe No. 258 Savant Lake (Ontario)
Renee Abram, Oneida First Nation of the Thames (Ontario)
Serena Kenny, Lac Seul First Nation (Ontario)
Stefanie Bryant, BA, Lac Seul First Nation (Ontario)
Alexandra Hayward, BSc, JD Candidate, St. John’s, Newfoundland and Labrador
Angela Bischoff, Toronto, Ontario
Anna Tilman, BA Physics, MA Medical Biophysics, Aurora, Ontario
Ann Coxworth, MSc, Saskatoon, Saskatchewan
Ann Pohl, MEd, Killaloe, Ontario
Anne Lindsey, Order of Manitoba, MA, Winnipeg, Manitoba
Dr. Auréa Cormier, PhD, Order of Canada, Moncton, New Brunswick
Dr. Barbara Birkett, MDCM, FRCPC, Oakville, Ontario
Beatrice Olivastri, Ottawa, Ontario
Betty L. E. Wilcox, BA, BEd, Stanhope, Prince Edward Island
Brenda Brochu, BA, BEd, Peace River, Alberta
Brennain Lloyd, North Bay, Ontario
Carole Dupuis, Saint-Antoine-de-Tilly, Québec
Carolyn Wagner, MEd, Fredericton, New Brunswick
Catherine Cameron, BSc., MBA, Perth Ontario
Dr. Cathy Vakil, MD, Kingston, Ontario
Dr. Cecily Mills, PhD Microbiology, Edmonton, Alberta
Chantal Levert, Montréal, Québec
Dr. Charlotte Rigby, PhD, Gatineau, Quebec
Chris Cavan, BEd, Almonte, Ontario
Dr. Dale Dewar, MD, Wynyard, Saskatchewan
Dr. Darlene Hammell, MD, Victoria, British Columbia
Deborah Powell, BA, BEd, Bristol, Quebec
Diane Beckett, BES, MA, Churchill, Manitoba
Diane Fortin, Gatineau, Québec
Dr. Dorothy Goldin Rosenberg, PhD, Toronto, Ontario
Elizabeth Logue, Wakefield, Quebec
Elssa Martinez, MSW, Montreal, Quebec
Emma March, MA, JD candidate, Kingston, Ontario
Dr. Erica Frank, MD, MPH, FACPM; Nanoose Bay, British Columbia
Eva Schacherl, MA, Ottawa, Ontario
Evelyn Gigantes, BA, former MPP, Ottawa, Ontario
Gail Wylie, Fredericton, New Brunswick
Gini Dickie, BA, Toronto, Ontario
Ginette Charbonneau, Physicist, Oka, Quebec
Gracia Janes, Ontario Medal for Citizenship, Niagara-on-the-Lake Ontario
Gretchen Fitzgerald, BSc, Halifax, Nova Scotia
Janet Graham, MA, Ottawa, Ontario
Dr. Janet Ray MD, Victoria, British Columbia
Dr. Janice Harvey, PhD, Fredericton, New Brunswick
Jean Brereton, Golden Lake, Ontario
Jean Swanson, Order of Canada, BA, City Councillor, Vancouver, British Columbia
Dr. Jeannie Rosenberg, MD, Huntingdon, Quebec
Jessica Spencer, Moncton, New Brunswick
Joann McCann-Magill, MA, Sheenboro, Quebec
Joanne Mantha, MA, Gatineau, Quebec
Jocelyne Lachapelle, Framton, Québec
Johanna Echlin, MEd, Westmount, Quebec
Julie Reimer, MMM, Kingston, Ontario
Dr. Judith Miller, PhD, Ottawa, Ontario
Kathrin Winkler, BA, Halifax, Nova Scotia
Dr. Kathryn Lindsay, PhD, Renfrew, Ontario
Kay Rogers, BA, MA, MSc, Perth Ontario
Kerrie Blaise, MSc, JD, North Bay, Ontario
Kim Reeder, MEM (Environmental Management), Saint Andrews, New Brunswick
Dr. Kringen Henein, PhD, Ottawa Ontario
Larissa Holman, BSc, MREM, Gatineau, Quebec
Dr. Laure Waridel, PhD, Order of Canada, Montréal, Québec
Lenore Morris, BA, MBA, JD, Whitehorse, Yukon
Liette Parent-Leduc, B.A.A., D. Fisc, Saint-Robert, Québec
Lisa Aitken, MEd, HRM, Winnipeg, Manitoba
Dr. Louise Comeau, PhD, Keswick Ridge, New Brunswick
Canada Re-enters the Nuclear Weapons Business with SMRs
Natural Resources Minister Seamus O’Regan is expected to announce within weeks his government’s action plan for development of “small modular” nuclear reactors (SMRs).
SMR developers already control the federally-subsidized Chalk River Laboratories and other facilities owned by the crown corporation, Atomic Energy of Canada Limited (AECL). Canada is now poised to play a supporting role in the global nuclear weapons business, much as it did during World War II.
Canada’s Nuclear Schizophrenia describes a long tradition of nuclear cooperation with the United States: “For example, in the early 1950s, the U.S. Navy used Canadian technology to design a small reactor for powering its nuclear submarines.” C.D. Howe, after creating AECL in 1952 to develop nuclear reactors and sell weapons plutonium, remarked that “we in Canada are not engaged in military development, but the work that we are doing at Chalk River is of importance to military developments.”
In 2015 the Harper Government contracted a multi-national consortium called Canadian National Energy Alliance – now comprised of two U.S. companies, Fluor and Jacobs, along with Canada’s SNC-Lavalin – to operate AECL’s nuclear sites, the main one being at Chalk River. Fluor operates the Savannah River Site, a South Carolina nuclear weapons facility, under contract to the U.S. Department of Energy (DOE). Jacobs also has contracts at DOE weapons facilities and is part of a consortium that operates the U.K. Atomic Weapons Establishment.
Joe McBrearty, the president of the consortium’s subsidiary that operates Chalk River and other federal nuclear sites, was a U.S. Navy nuclear submarine commander and then chief operating officer for the DOE’s nuclear laboratories between 2010 and 2019.
All three consortium partners have investments in SMRs and are ramping up research and development at AECL’s Chalk River facility. Some SMR designs would use uranium enriched to levels well beyond those in current reactors; others would use plutonium fuel; others would use fuel dissolved in molten salt. All of these pose new and problematic weapons proliferation risks.
The article quotes a 2017 Rolls Royce study as follows: “expansion of a nuclear-capable skilled workforce through a civil nuclear UK SMR programme would relieve the Ministry of Defence of the burden of developing and retaining skills and capability.”
The SMR connection to weapons and submarines could hardly be clearer – without SMRs, the U.S. and U.K. will experience a shortage of trained engineers to maintain their nuclear weapons programs.
With the takeover of AECL’s Chalk River Laboratories by SMR developers, and growing federal government support for SMRs, Canada has become part of a global regime linking nuclear power and nuclear weapons.
Canada’s first formal license application for an SMR is the “Micro Modular Reactor” in Chalk River.
CCRCA, and many others provided written interventions to the CNSC on “the scope of an environmental assessment for the proposed Micro Modular Reactor Project at the Chalk River Laboratories” prior to the one-person “Panel of Commission: R. Velshi, President” that rendered its decision on July 26th.
The CCRCA submission noted, in particular, that under the Impact Assessment Act, the proponent would be required to include as a “factor” in the EA ““the extent to which the effects of the designated project hinder or contribute to the Government of Canada’s ability to meet its environmental obligations and its commitments in respect of climate change.”
Somehow, the Record of Decision on the project scope omits any mention of climate change.
The CNSC’s decision on the scope of the MMR project indicates that climate change is not a relevant factor in the consideration of environmental impact of SMRs.
Here’s our take-away:
Reducing GHG emissions is a government priority. This is reflected in the Impact Assessment Act. The Minister of Natural Resources says nuclear power is essential to reduce GHGs (no path to net zero without nuclear)
The CNSC did not include GHG emissions as a factor in assessing its first SMR license application – even when requested to do so – and even when its own “interim strategy for environmental assessments” calls for this.
The CNSC should not lead environmental assessments of nuclear reactors, including SMRs.
The Physical Activities Regulations under the Impact Assessment Act should be changed to remove exemptions for new nuclear reactors.
Commentary by Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility
SMRs are really DDDs and should be called such.
A DDD is a Dirty Dangerous Distraction. It is an acronym much more to the point than SMR.
Nuclear proponents are loathe to even use the N in theiracronym (SMR) for Small Modular Nuclear Reactors (SMNRs)because they want to hide the one aspect – the NUCLEAR aspect – that is the source of all the unmentioned problems with these devices. It is the insidious linages to nuclear waste and to nuclear weapons that are precisely what set these machines apart.But the industry hopes that no one will notice if they leave out the N.It may sound silly or trivial, but it is not silly or trivial. It is deliberate.
SMRs (or SMNRs) are Dirty, Dangerous Distractions. They are DDDs.
They are DIRTY because they produce radioactive waste of all categories – low-level, intermediate-level, and high-level. It is by farthe most deadly waste byproduct that any industry has ever created.
Every SMR is DANGEROUS because it is not just a machine for generating electricity, it is also a warehouse of radioactivepoisons that can do tremendous damage for centuries to comeif anything happens to disperse those poisons into the environment, such as an act of warfare (e.g. aerial bombardment) or sabotage, or a plane crash or a violent earthquake. Once released, these poisons will contaminate the food we eat, the water we drink, and the air we breathe, and the damage will last for generations.
Some SMRs – those that are called “fast” or “advanced” reactors,those that talk about “reusing” or “recycling” or “reprocessing” irradiated nuclear fuel – pose an even more serious existential danger. Such reactors are predicated upon the extraction of plutonium and other human-made elements that are heavier than uranium to extend the nuclear fuel supply. But plutonium is also the primary nuclear explosive in the world’s nuclear arsenals, and extracting it from irradiated fuel makes plutonium that much more accessible to militaristic regimes, as well as criminals and terrorists, thereby facilitating the proliferation of nuclear weapons. Nuclear weapons are the greatest human-made threat to the survival of human civilization (and most advanced forms of life on Earth).
SMNRs are also a DISTRACTION because they prevent us from dealing with climate change right now, rather than waiting 10 or 20 years to see is SMRs are even going to prove worthwhile. So much can be done through prompt investments in energy efficiency and renewables, where benefits are enjoyed in just one orTwo building seasons, using technology that is already proven and inherently safe. Can anyone imagine a catastrophic situation arising from the failure of windmills or solar collectors? Energy efficiency and renewables can be implemented faster and cheaper than nuclear power, creating more jobs and providing more sustainability at the same time.
SMRs also distract us from realizing that we have no solution to the problem of how to safely keep these radioactive poisons out of the environment of living things for millennia to come, and therefore we should stop creating them. As long as the industry distracts the decision-makers by dangling a charm bracelet of pie-in-the-sky miraculous “clean, safe, cheap nuclear reactors”(All those adjective being demonstrable lies) our political representatives are prevented from focussing on the horrendous radioactive waste problems that we have already accumulated and that will constitute a radioactive legacy forever.
Although we have no cure for the coronavirus, we do have effective methods for limiting its spread and preventing the worsening of the situation. So too we have no way to eliminate or neutralize radioactive wastes or to render them harmless, but we do know how to package them well and repackage them when necessary — as long as we don’t abandon them thereby putting these enormously dangerous materials beyond human control (as some people have abandoned their responsibility to control the spread of the coronavirus). As long as we don’t keep multiplying the sources of radioactive waste (by building a whole new fleet of nuclear reactors called SMRs) we would have a chance of addressing the radioactive waste legacy with some degree of responsibility and maturity.
Nuclear power is the ONLY technology that actually creates hundreds of new toxic elements, most of which were never found in nature prior to 1939. Those elements, once created, cannot be destroyed or rendered harmless. There isno non-nuclear method known to science – heat, pressure, combustion, chemical reactions, NOTHING – that can slow down or stop the rate of atomic disintegration, and those disintegrating atoms will give off the subatomic shrapnel that we call‘“atomic radiation” at a predetermined rate defined by the so-called “half-life”.
I have discovered that every category of radioactive waste associated with theNuclear fuel chain (from uranium mining to reactor operation to decommissioning to waste management) has a significant number of radioactive poisons that will remain a hazard for hundreds of thousands of years. That is true of uranium tailings, of low and intermediate level wastes from reactor operations, of the thousands of truckloads of radioactive rubble from decommissioning a reactor, of the so-called “depleted uranium” stored in the back yards of uranium enrichment plants, and of the irradiated nuclear fuel itself.
Keeping radioactive waste out of the environment of living things for hundreds of thousands of years is an unsolved problem of the human race. We should not be adding to this dreadful legacy, or allowing our attention to be distracted away from dealing with the problem properly (i.e. as best we can!).
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.
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
We are writing to request your urgent attention to a number of serious concerns related to nuclear governance and nuclear safety in Canada.
We recognize that you are dealing with the coronavirus pandemic and that many urgent matters demand your attention at this time. We appreciate your leadership and the actions of your government to date. However, inadequate nuclear safety and governance in the nuclear field entail very serious risks for the health of current and future generations of Canadians. We therefore earnestly urge that the issues raised herein be given their rightful place on the priority list of your government in the coming months.
The International Atomic Energy Agency (IAEA) recently reviewed Canada’s nuclear safety framework and its final report , released in Canada on February 18, identified numerous deficiencies  requiring attention by the Government of Canada. Deficiencies include:
failure to establish a national policy and a strategy for radioactive waste management,
lack of alignment with IAEA guidance on nuclear reactor decommissioning,
failure to expressly assign the prime responsibility for safety to the person or organization responsible for a nuclear facility,
failure to explicitly address the principle of justification – a requirement to demonstrate an overall net benefit prior to approval of any new sources of radiation exposure, new nuclear facilities or activities,
inconsistent dose constraints for nuclear facilities,
unsatisfactory transportation management systems for nuclear materials, and
inadequate radiation protection for nuclear workers such as regulations allowing four times higher radiation doses for pregnant women than IAEA standards would countenance
We believe all these failings require urgent attention by the Government of Canada.
Environmental Petition 427 , “Nuclear Governance Problems in Canada, submitted to the Auditor General of Canada in June 2019, identified numerous serious problems in Canada’s nuclear governance regime, including outdated and inadequate legislation, lack of government oversight, no checks and balances, a federal policy vacuum on nuclear waste and nuclear reactor decommissioning, and regulatory capture of the
Canadian Nuclear Safety Commission (CNSC). The petition recommended creation of a high-level, interdisciplinary, multi-stakeholder task force with representation from civil society groups, First Nations and industry to advise on nuclear governance reforms in Canada.
It is our strong conviction that Canada’s nuclear governance and nuclear safety framework are failing to adequately protect Canadians from hundreds of dangerous radioactive substances that are produced by nuclear reactors. Exposure to these radioactive substances can cause serious chronic diseases, birth defects and genetic damage that is passed on to future generations. According to the US National Research Council BEIR VII report , there is no safe level of exposure to ionizing radiation released from nuclear reactors and nuclear waste facilities. We urge you to make it a priority to correct the deficiencies noted by the IAEA peer review and in Environmental Petition 427 to the Auditor General.
We also have serious concerns about the recent appointment of CNSC President Rumina Velshi to chair the IAEA Commission on Nuclear Safety Standards. Our concerns are explained in a letter to IAEA Director General Rafael Grossi  which requests that the appointment be reconsidered. Briefly, we believe the CNSC is a captured regulator with a documented record of disregarding IAEA safety standards or watering down their domestic application; therefore its president – a previous senior officer within Ontario Power Generation – should not chair this IAEA commission.
In the absence of a strong nuclear governance regime and a comprehensive nuclear safety framework, the Government of Canada’s rush to promote and to invest in small modular nuclear reactors is, we believe, ill-advised. In particular, the absence of a requirement in Canada’s nuclear safety framework to justify the increased radiation exposures and increased legacy of radioactive waste of all kinds that would result from developing and deploying SMNRs, is enabling your government to proceed without due consideration of faster, cheaper and lower risk alternatives available for reducing Canada’s greenhouse gas emissions, as documented in Environmental Petition 419 to the Auditor General of Canada  “Concerns about investment in new nuclear technology”.
Finally, we note a fundamental conflict of interest in having the CNSC report to Parliament through the Minister of Natural Resources, who is responsible for promoting nuclear power under the Nuclear Energy Act. This reporting relationship could be changed through an Order-in-Council decision without any change to existing legislation.
We urge you to act swiftly to establish sound nuclear governance and a comprehensive nuclear safety framework in Canada. We respectfully point out that the needed reforms are not only an issue for your Minister of Natural Resources, but also require attention from departments including Justice, Health, Finance, Treasury Board, and Environment and Climate Change.
We look forward to hearing from you.
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
The Hon. François-Philippe Champagne, Minister of Foreign Affairs
The Hon. Seamus O’Regan, Minister of Natural Resources
The Hon. David Lametti, Minister of Justice
The Hon. Bill Morneau, Minister of Finance
The Hon. Patti Hajdu, Minister of Health
The Hon. Jean-Yves Duclos, President of the Treasury Board
The Hon. Jonathan Wilkinson, Minister of Environment and Climate Change
The Hon. Andrew Scheer, Conservative Party of Canada
Yves-François Blanchet, 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