Urgent Deadline – November 19, 2008
Action Alert – Demand a credible environmental review of new nuclear reactors at Darlington
The federal government is pushing ahead with an environmental review on Ontario Power Generation’s (OPG) proposal to build new nuclear reactors at Darlington that will exclude significant environmental impacts, such as radioactive waste, significant accidents. Worse, it will not consider environmentally friendly alternatives to nuclear power, such as renewables and conservation.
How can you help?
Please tell the Canadian Environmental Assessment Agency (CEAA) it is unacceptable to exclude the significant environmental impacts from the environmental assessment on new nuclear reactors at the Darlington nuclear station. Tell CEAA that any credible review should assess more environmental friendly alternatives to building nuclear plants, such as renewables and conservation.
How? Below you will find additional background and a draft letter you can use to make your submission.
When? The deadline for making submissions to CEAA is November 19th.
How? Send submissions to Darlington. Review@ceaa-acee.gc.ca
If you have any questions, or want to know how to stay involved please contact:
Peter Aulich – email@example.com – 416-597-8408 x3072.
Background: Why should I be concerned?
Ontario Power Generation (OPG) wants to build four nuclear reactors on the shores of Lake Ontario at its Darlington site. The federal Ministry of the Environment and the federal Canadian Nuclear Safety Commission (CNSC) are conducting environmental assessment of this project as a “joint review panel”. This panel will decide whether the project passes the environmental assessment.
Historically, the federal government has allowed the nuclear industry to exclude significant environmental effects, such as radioactive waste and nuclear accidents, from environmental reviews on nuclear projects. This has allowed environmental reviews to come to the false conclusion that nuclear reactors pose no threat to the environment.
The draft environmental assessment guidelines for the Darlington New Build Project would allow OPG to again exclude significant environmental impacts from its environmental assessment report.
You can find the draft environmental assessment guidelines on CEAA’s website here: http://www.ceaa.gc.ca/050/DocHTMLContainer_e.cfm?DocumentID=28688
Darlington New Nuclear Power Plant Project
Canadian Environmental Assessment Agency
160 Elgin Street, Ottawa, Ontario K1A 0H3
Re: Comments on the Draft Environmental Assessment Guidelines for the Darlington New Nuclear Power Plant Project
To whom it may concern,
I am deeply concerned that the environmental assessment guidelines regarding Ontario Power Generation’s (OPG) proposed construction of new reactors at the Darlington nuclear station excludes significant environmental hazards of public concern.
The following are my high-level comments on the guidelines.
Purpose, Need, and Alternatives to the Project
The current draft guidelines do not require OPG to provide important key information regarding the purpose, need, and alternatives to the project.
Specifically, the draft guidelines only require OPG to outline the purpose and need for the project from OPG’s own perspective. OPG should instead be required to explain the purpose and need of the project in terms of the public interest.
The draft guidelines only require OPG to provide information on alternative “methods of producing electricity.” The guidelines should instead require OPG to examine potential alternatives of meeting electricity demand, including demand management and conservation.
The draft guidelines expressly state that “provincial energy policy” cannot be addressed and that alternatives “contrary to Ontario’s formal plans or directives” need not be examined. This part of the guidelines is unacceptable and should be removed.
OPG should be required to describe the long term potential adverse environmental effects of creating this nuclear waste.
Under the present proposal, however, OPG is only required to describe “at a conceptual level” how used nuclear fuel waste will be managed, because another organization is “expected” to manage that waste.
The time horizons of the assessment must be extended beyond the abandonment phase. The potential adverse effects of used nuclear waste should also be assessed in the post-abandonment phase and when considering malfunctions, accidents and malevolent acts.
If OPG fails to assess this, it will have failed to consider some of the most important environmental effects of the project.
Application of Ontario’s Environmental Assessment Act
Provincial environmental assessments must be carried out where the project is undertaken “on behalf of” Ontario.
OPG was directed to undertake this project by the Ontario Ministry of Energy in June of 2006 and therefore it appears that Ontario should formally participate in this environmental assessment as a signatory to the Joint Review Panel Agreement or else conduct its own assessment.
The draft guidelines themselves recognize that this project is on behalf of Ontario when they say on page 9 that “The Province of Ontario is considering a range of reactor designs.” Therefore this issue should be more thoroughly reviewed and explained.
OPG should be required to undertake a provincial environmental assessment, and if it doesn’t, it should be required to explain in its EIS why it thinks Ontario’s Environmental Assessment Act does not apply.
Cost overruns and financing
In the draft guidelines OPG is only required to look at regional economic impacts, such as impacts on the job market. OPG should instead be required to provide information on the costs of the project and its alternatives, including the likelihood and liability for cost overruns.
This information is necessary to adequately compare the project to its alternatives. It is also necessary to quantify the project’s effects on taxpayers and ratepayers who could end up footing the bill, as they did with the current fleet of nuclear reactors. As it stands, OPG is not properly examining the costs and financing of the project and its alternatives.
Accidents, Malfunctions, & Malevolent Acts
The draft guidelines exclude a range of possible nuclear accidents and malfunctions from the scope of the environmental assessment. This is unacceptable given that OPG is legally protected from paying the costs for such events beyond a certain level.
OPG should be required to identify and assess all potential adverse environmental effects of all realistic malfunctions, accidents and terrorist events.
The Darlington site is also home to four reactors as well as a spent fuel storage facility. OPG should be required to assess the cumulative impacts of accidents and malfunctions affecting each nuclear power plant and spent-fuel-storage facility as part of the environmental review.
The EIS guidelines do not require OPG to explain who would pay for clean up and compensation in the event of an accident, malfunction, or malevolent act. The EIS Guidelines should require OPG to detail 1) the extent of all potential cleanup and compensation costs arising from each possible nuclear accident, malfunction, and malevolent act, 2) whether persons in Canada and the United States would be fully compensated, 3) who would pay for the cleanup and compensation, and 4) how this compares to the system of nuclear liability in the United States.
Thank you for considering my comments.