DNA Letter to Pickering Council

DNA hand-delivered this letter to the members of Pickering Council on March 17/14.

March 17, 2014.

Dave Ryan, Mayor The Corporation of the City of Pickering One The Esplanade, Pickering Ontario, Canada L1V 6K7.

Re: DNA concerns about operating the Pickering reactors beyond their design life

Dear Dave Ryan [each member of Council received her/his own persoalized copy of the letter]:

We are sending you this letter in order to register the concerns of Durham Nuclear Awareness (DNA) regarding Ontario Power Generation’s request to run the Pickering nuclear station beyond its design life, and to make some recommendations to you as a Council.

DNA is a group of concerned citizens who work to raise awareness about nuclear issues and risks facing the people and communities of Durham Region.

As you are probably aware, the Canadian Nuclear Safety Commission (CNSC) is holding a hearing on May 7, 2014 in Ottawa to discuss OPG’s request to run the aging Pickering B reactors beyond their design life.

While OPG and CNSC staff’s input on this matter has yet to be published (expected availability of their reports: sometime after March 21st), we wish to raise some issues now.

The first Pickering reactor reaches the end of its design life this summer. To our knowledge, continuing to operate a CANDU reactor beyond its design life is unprecedented.

DNA is very concerned about the risks of running the Pickering reactors beyond their design life and the lack of information disclosure and public participation available at the May 7th meeting.

DNA encourages Pickering Council to raise similar concerns with the Commission by making a written intervention by April 22.

The following summarizes DNA’s concerns and recommendations.

Public Transparency and Participation

The CNSC typically provides financial support for organizations and individuals to hire expert technical advice to enable their intervention in re-licensing hearings. It is not doing so for this hearing despite the importance of the decision.

In 2013, DNA received $16,000 to hire American nuclear risk expert Arnie Gundersen to review and evaluate OPG’s safety case for running the Pickering reactors beyond their design life. Ironically, the key observation of Mr. Gundersen’s analysis was that OPG had failed to provide a full safety case for running the reactors beyond their design life in time for the hearings.

Because of this total lack of key information, DNA and other environmental organizations formally requested the CNSC to deny OPG the right to operate the station beyond its design life without a full safety case first being considered at another hearing of the Commission.

In its final decision in August 2013, the Commission granted OPG its requested 5-year licence renewal, but partially agreed with DNA and other groups in requiring OPG to present its full safety case at the upcoming hearing this May.

However, DNA is concerned that the public’s ability to meaningfully scrutinize this key safety issue has been significantly constrained. The CNSC will only be accepting written submissions at this hearing, and is not providing financial support for third-party reviews of OPG’s safety case.

It should be underlined that DNA sought funding last year to review OPG’s safety case for running the station beyond its life because we viewed this as a key risk to Durham Region. Because OPG failed to provide a full safety case, we are now effectively holding another re-licensing hearing, yet with reduced levels of public participation and without the ability to hire a third party to vet OPG’s safety case.

DNA feels that such an unprecedented decision should be taken in full public view, with input from the community and third-party reviewers.

DNA encourages Pickering Council to articulate concerns to the CNSC regarding the reduced level of public participation and transparency in any potential submission you may make on behalf of the City of Pickering.

Pickering’s Closure and a Just Transition for the Station Closure

DNA believes there must be open and public discussion on how to plan for the Pickering nuclear station’s closure. DNA encourages Pickering Council to ensure that such debate happens well before Pickering’s closure.

Without such a discussion, our community could undergo unnecessary negative social and economic impacts. When Quebec closed its Gentilly-2 nuclear station in 2012 without such a debate or a transparent plan, it caused considerable stress in the community.

In the CNSC’s relicensing decision last year, it directed OPG to provide a draft decommissioning plan for the Pickering nuclear station by 2017 – three years before what was then understood to be Pickering’s final closure date.

Since that time, the government of Ontario released a new Long Term Energy Plan, which states:

“The Pickering Generating Station is expected to be in service until 2020. An earlier shutdown of the Pickering units may be possible depending on projected demand going forward, the progress of the fleet refurbishment program, and the timely completion of the Clarington Transformer Station.” (Long Term Energy Plan, December 2013, p. 47.)

It is thus possible that the Pickering station will be closed down completely or in part well before 2020. DNA believes the City of Pickering must be prepared for such a scenario.

As discussed, DNA believes our community needs a transparent and accepted transition plan as it ends its 40-year experiment with nuclear power. As seen with recent experiences in Quebec, the failure to develop such a transition plan can have negative impacts on the community.

DNA thus encourages Pickering Council to request that the Canadian Nuclear Safety Commission require OPG to move up the submission date for its draft decommissioning plan from 2017 to 2015.

We also believe that whatever plan OPG submits should be subjected to a public consultation to determine whether such a plan is environmentally sound and in the public interest. We would be happy to discuss the nature of such a public consultation at a later date. Conclusions

To conclude, DNA is concerned about the risks of running Pickering beyond its design life. We encourage Pickering Council to call for higher levels of public transparency if it suggests the life-extension of the Pickering reactors be approved by CNSC.

DNA is also deeply concerned that our community has no transition plan for closure of the Pickering nuclear station, which could occur well before 2020. We request Pickering Council ask the CNSC to require a draft decommissioning plan be published by 2015 instead of 2017.

Thank you for your attention in these matters.

Please don’t hesitate to contact our group if you have any questions.