Letter to Prime MinisterJustin Trudeau requesting urgent attention to nuclear safety gaps in Canada

April 3, 2020

The Right Honourable Justin Trudeau

Prime Minister of Canada

Dear Mr. Trudeau,

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 [1], released in Canada on February 18, identified numerous deficiencies [2] 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  [3], “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General of Canada in June 2019, identified numerous serious problems in Canada’s nuclear governance regime, including outdated and inadequate legislation, lack of government oversight, no checks and balances, a federal policy vacuum on nuclear waste and nuclear reactor decommissioning,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  [4], 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.

Prime Minister Justin Trudeau, Canadian Press photo


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 [5] 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 [6] “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.

Yours truly,

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 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

Contact Information:

Links

  1. REPORT OF THE INTEGRATED REGULATORY REVIEW SERVICE MISSION TO CANADA, International Atomic Energy Agency https://www.iaea.org/sites/default/files/documents/review-missions/irrs_canada_2019_final_report.pdf
  2. International Peer Review Finds Deficiencies in Canada’s Nuclear Safety Framework. Concerned Citizens of Renfrew County and Area, February 2020. https://concernedcitizens.net/2020/03/07/international-peer-review-finds-deficiencies-in-canadas-nuclear-safety-framework/
  3. 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 and full text of petition: https://concernedcitizens.net/2019/11/30/environmental-petition-nuclear-governance-problems-in-canada/
  4. National Research Council. 2006. Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2. Washington, DC : The National Academies Press. https://www.nap.edu/catalog/11340/health-risks-from-exposure-to-low-levels-of-ionizing-radiation
  5. Letter to IAEA Director General Rafael Grossi, March 12, 2020. http://ccnr.org/Letter_IAEA_2020_e.pdf
  6. Environmental Petition 419 to the Auditor General of Canada, November 2018. Petition summary: https://www.oag-bvg.gc.ca/internet/English/pet_419_e_43275.html and full text of petition: https://tinyurl.com/Env-Petition-419

Environmental Petition 419 to the Auditor General of Canada ~ Concerns about investment in “new” nuclear technologies

November 4, 2018

Summary of petition on the Office of the Auditor General Website: https://www.oag-bvg.gc.ca/internet/English/pet_419_e_43275.html

Purpose of Petition

The Government of Canada is presently investing millions of dollars in early stage development of “new” nuclear technologies. This may not be a prudent use of federal funds. In September 2018 the World Nuclear Industry Status Report noted that nuclear electricity generation is being rapidly outpaced by renewable technologies that are faster to deploy and less expensive than nuclear reactors. (1) The same month, a report published by the accounting firm Deloitte stated that “renewable energy is rapidly becoming a “preferred”, mainstream energy source”. (2) 

In early October 2018, the International Panel on Climate Change (IPCC) called for rapid, far-reaching, and unprecedented efforts worldwide to reduce greenhouse gas emissions and limit global warming to less than 1.5 C (3), and to prevent what scientists now call a near-term risk of dangerous to catastrophic levels of global warming (4). 

This petition seeks to determine whether the Government of Canada will re-evaluate its investment in “new” nuclear technologies in light of the IPCC’s clarion call for an urgent transition to a low carbon future and the availability of much faster-to-deploy and cheaper alternatives for electricity generation.

Background

“New” nuclear reactor concepts are often referred to as “Generation IV” or “small modular reactor” (SMR) technologies.  These include unconventional designs that employ liquid rather than solid fuels, and scaled-down versions of conventional reactor designs.  Recent activities in support of SMRs include:

  • Natural Resources Canada (NRCan) support for an International Conference on Generation IV and Small Modular Reactors, November 6-8, 2018 in Ottawa 
  • NRCan hosting of a Small Modular Roadmap Secretariat and grants to the Canadian Nuclear Association to develop “Canada’s SMR Roadmap” 
  • NRCan support for a Nuclear Innovation: Clean Energy Future “NICE Future” initiative launched under the Ninth Clean Energy Ministerial (CEM) in May 2018 and plans to promote “NICE Future” at the Tenth CEM Ministerial (May 2019, Vancouver)
  • Canadian Nuclear Safety Commission regulatory frameworks, workshops, consultations and presentations on “SMR readiness” 
  • Canadian Nuclear Laboratories (CNL) solicitation of SMR proposals, delivery of workshops and development of SMR promotional materials; with a stated goal of siting an SMR at a federally-owned nuclear facility by 2026.  CNL is privately owned but receives approximately $1 billion each year from Canadian taxpayers. 
  • Sustainable Development Technology Canada’s $5.74 million grant to Terrestrial Energy Inc. and Caterpillar Inc. for a reactor concept that uses nuclear fuel dissolved in molten salt.

A common thread running through promotional materials and press releases for these federally- funded activities is that new nuclear reactors represent a form of clean energy that will be a key element of Canada’s greenhouse gas reduction strategy. 

Recent developments call into question the wisdom of investing in new nuclear technology as a strategy for reducing greenhouse gases in Canada

IPCC report

On October 8, 2018, the United Nations Intergovernmental Panel on Climate Change released its report “Global Warming of 1.5°C”.  The report warns that global warming is likely to reach 1.5°C as early as 2030 “if it continues to increase at the present rate.” The report calls for “rapid and far-reaching transitions in energy, land, urban and infrastructure (including transport and buildings), and industrial systems.”  The report adds that such transitions “are unprecedented in terms of scale, but not necessarily in terms of speed, and imply deep emissions reductions in all sectors, a wide portfolio of mitigation options and a significant upscaling of investments.”  (3)

Deloitte Report 

A recent in-depth report by the Deloitte Centre for Energy Solutions highlights rapid changes in the landscape for solar and wind power.  It concludes:

Solar and wind power recently crossed a new threshold, moving from mainstream to preferred energy sources across much of the globe. As they reach price and performance parity with conventional sources, demonstrate their ability to enhance grids, and become increasingly competitive via new technologies, deployment obstacles and ceilings are dissolving. Already among the cheapest energy sources globally, solar and wind have much further to go: The enabling trends have not even run their full course yet. Costs are continuing to fall, and successful integration is proceeding apace, undergirded by new technologies that are bringing even greater efficiencies and capabilities. (2)

The old argument against wind and solar, their intermittency, has become irrelevant owing to advances in storage technology.  Solar and wind can enhance the grids they are connected to, according to Deloitte:

Once seen as an obstacle, wind and solar power are now viewed as a solution to grid balancing. They have demonstrated an ability to strengthen grid resilience and reliability and provide essential grid services. Smart inverters and advanced controls have enabled wind and solar to provide grid reliability services related to frequency, voltage, and ramping as well or better than other generation sources. When combined with smarter inverters, wind and solar can ramp up much faster than conventional plants, help stabilize the grid even after the sun sets and the wind stops, and, for Solar PV, show much higher response accuracy than any other source. (2)

The global electricity generation landscape has shifted dramatically in the last few years. The Government of Canada would get faster, greater and more far-reaching reductions in greenhouse gas emissions for Canadians by investing in wind and solar technologies.  

Government of Canada funding for energy efficiency, energy conservation and intelligent design, rather than new nuclear technology, could help accelerate the transition to an affordable, sustainable energy future

According to a June 2018 report presented by the Generation Energy Council to Canada’s Minister of Natural Resources:

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, which will also make our businesses more competitive internationally and leave more money in consumers’ pockets (5)

There is a huge, untapped potential in this arena. For inspiration the Government of Canada could look to the “One Less Nuclear Power Plant” initiative launched in 2012 by the City of Seoul, Republic of Korea. The target of this initiative was to cut energy consumption by two million tonnes of oil equivalent (TOE), equivalent to the annual energy generation of one nuclear power plant (corresponding to the output in 2017 of the six remaining Pickering reactors) by directly engaging citizens in energy-saving, energy efficiency and renewable energy generation. 

This target was exceeded in June 2014, six months ahead of schedule, as Seoul had reduced the city’s energy consumption by 2.04 million TOE. (6)  Reallocating funds from development of Generation IV/SMRs to energy saving, energy efficiency and renewable energy generation would yield much faster reductions in greenhouse gas emissions for Canadians.

Government of Canada investment in new nuclear technology reduces Canada’s ability to rapidly reduce its greenhouse gas emissions

By tying up funds that could otherwise quickly and effectively reduce greenhouse gas emissions (such as through energy efficiency, energy conservation and intelligent design, wind and solar electricity), investing in Generation IV/SMRs reduces Canada’s ability to respond to the IPCC call for rapid, far-reaching, and unprecedented transitions.

Canadian Nuclear Laboratories (CNL) is a privately-owned corporation that manages federal nuclear facilities under contract to the crown corporation Atomic Energy of Canada Limited. Earlier this year, CNL issued an Invitation for SMR demonstration projects from nuclear businesses around the world. Reporting in June 2018 on the results of its request for proposals, CNL stated that it had set a goal to site an SMR on one of the sites it manages by 2026. (7)

Given that the year 2026 is the most optimistic projection for siting a demonstration SMR at a Government of Canada nuclear facility managed by CNL, it is clear that SMR deployment cannot be part of the “rapid, far-reaching” transitions called for by the IPCC by 2030. By 2026, two thirds of the short time window identified by the IPCC in which to drastically reduce emissions will have already elapsed.

Questions

Canada needs to engage in rapid, far-reaching and unprecedented efforts to reduce greenhouse gas emissions.  A key federal commitment in this regard is to develop a Canadian energy strategy that will provide results such as “greater energy conservation and greater inclusion of clean energy and innovative technologies in Canada’s energy future.”  

Decisions around funding to accomplish this task are of great importance to Canada and Canadians.  We note that the Minister of Finance has mandates to work with:

  • the Minister of Natural Resources to enhance existing tax measures to generate more clean technology investments;
  • the Minister of Environment and Climate Change in creating a new Low Carbon Economy Trust to help fund projects that materially reduce carbon emissions under the new pan-Canadian framework; 
  • the Minister of Innovation, Science and Economic Development to encourage innovation, trade and the growth of Canadian businesses; and
  • all Ministerial colleagues to reduce poorly targeted and inefficient measures, wasteful spending, and government initiatives that are ineffective.

We therefore request the Ministers of Finance, Natural Resources, Environment and Climate Change, and Innovation, Science & Economic Development to respond to this petition. 

We also request that this petition be sent to the Minister of Intergovernmental Affairs for information, given that the Government of New Brunswick has committed $10 million for research and development of SMR technology, and the Government of Ontario has also funded SMR studies; and noting his mandate to support the Minister of Environment and Climate Change and provinces and territories on the implementation of the Pan-Canadian Framework on Clean Growth and Climate Change.

We ask:

  1. Will the Government of Canada re-evaluate its funding for development of Generation IV/SMRs in light of the information presented in this petition? If yes, please explain the timelines and mechanisms for doing so. If no, please provide a detailed rationale for not doing so.
  2. Will the Government of Canada consider re-allocating funding for new nuclear technology to wind and solar electricity, energy efficiency and energy conservation?

References

  1. The World Nuclear Industry Status Report 2018.  Schneider, Mycle et al. Sep. 2018.  https://www.worldnuclearreport.org/
  2. Global Renewable Energy Trends: Solar and Wind Move from Mainstream to Preferred.  Deloitte Centre for Energy Solutions.  Sep. 2018.  https://www2.deloitte.com/insights/us/en/industry/power-and-utilities/global-renewable-energy-trends.html
  3. IPCC Special Report on Global Warming of 1.5 °C. Oct. 2018.  Intergovernmental Panel on Climate Change.  http://www.ipcc.ch/report/sr15/
  4. Well below 2 C: Mitigation strategies for avoiding dangerous to catastrophic climate changes. Xu, Y. and Ramanathan, V. Proceedings of the National Academy of Sciences114(39): 10315-10323.  Sep. 2017. http://www.pnas.org/content/pnas/114/39/10315.full.pdf
  5. Canada’s Energy Transition: Getting to Our Energy Future, Together.  Generation Energy Council Report.  June 2018.  https://www.nrcan.gc.ca/20380
  6. One Less Nuclear Power Plant.  Reframing Urban Energy Policy.  Challenges and Opportunities in the City of Seoul.  Seoul Metropolitan Government. Aug. 2017. http://www.waltpatterson.org/seoulbook.pdf
  7. CNL announces strong interest in siting an SMR demonstration unit.  June 2018.  http://www.cnl.ca/en/home/news-and-publications/news-releases/2018/cnl-announces-strong-interest-in-siting-an-smr-dem.aspx
  8. Mandate Letter Tracker: Delivering results for Canadians.  https://www.canada.ca/en/privy-council/campaigns/mandate-tracker-results-canadians.html

Date: November 4, 2018

Information about Concerned Citizens of Renfrew County and Area (CCRCA)

CCRCA, a volunteer-based citizens’ group, formed in 1978 in response to a 15-year federal-provincial, $700 million study of the feasibility of disposing of high level nuclear waste in plutonic rock.  For more than 20 years, CCRCA has intervened at all licensing hearings on Chalk River Laboratories (CRL) held by the Canadian Nuclear Safety Commission (and prior to the year 2000, by the Atomic Energy Control Board).  Our interventions have highlighted pollution issues such as the plumes from the leaking fuel bays and waste management areas and major safety concerns such as the high level liquid wastes in the “Fissile Solution Storage Tank”. We have expressed support for new CRL facilities that have reduced pollution levels (such as the Liquid Waste Treatment Centre) and that have placed radioactive wastes in more secure, monitored above-ground storage. We have consistently called for greater transparency and openness in monitoring and reporting on the state of the CRL environment.  We believe that our efforts have raised public awareness about risks associated with Canada’s nuclear waste liabilities, and have helped persuade government decision-makers to allocate significant resources to clean-up projects such as the Nuclear Legacy Liabilities Program.