r amn 2020JflN28t»33 Minister w Ministre of Natural Resources HtW des Ressources naturelles Ottawa, Canada K1A 0E4
CNSC-CCSN JAN 2 4 2020 ~ ( U I O a5 HO FILE Doc# N° de DOSSIER & 3 t> Mr. Peter Storck 1 docuiuent l - - REFERRED TO peterl.storck@ mnail.com REFfenfeA
Dear Mr. Storck:
Thank you for your letter of August 12, 2019, addressed to my predecessor, the Honourable Amarjeet Sohi, regarding micro modular reactors and nuclear waste in Canada. Please accept our apologies for the delayed response.
The Government of Canada recognizes the important role of nuclear energy innovation, leveraging Canada’s long-standing leadership in nuclear science and technology and the pioneering work that has been led for more than 60 years by our nuclear laboratories and full-spectrum nuclear industry.
In 2018, our government convened provinces, territories, industry, Indigenous communities, and civil society organizations to develop a Small Modular Reactor (SMR) Roadmap that charts what a path forward for the commercialization of SMR technologies in Canada could look like. The SMR Roadmap concluded that SMRs could help Canadians achieve a low-carbon future, and provide for the emergence of a new industrial subsector that could create jobs and economic opportunities across Canada.
The Canadian Nuclear Safety Commission (CNSC) is responsible for regulating the use of nuclear energy and materials in Canada. Any proposed project to build and operate an SMR would require licensing from the CNSC.
The CNSC received Global First Power’s project description on July 12, 2019, for the issuance of a licence to prepare the site for a micro modular reactor at the Chalk River Laboratory site, located in Renfrew County, Ontario. In order for the project to proceed, CNSC authorization in the form of a licence is required under subsection 24(2) of the Nuclear Safety and Control Act.
Before the CNSC can consider a licensing decision regarding Global First Power’s proposal, an environmental assessment (EA) conducted under the Canadian Environmental Assessment Act, 2012 is required. The purpose of an EA is to identify the possible environmental effects of a proposed project, and determine whether these effects can be mitigated and whether there are any remaining significant adverse environmental effects before the project is allowed to proceed. Canada - 2 -
The EA will consider all licensing phases, including site preparation, construction, operation and decommissioning. Furthermore, the Canadian Impact Assessment Registry is currently conducting a public participation period for Global First Power’s proposed project, and 1 invite you to submit your comments in this process. Updates regarding the process and public submissions can be accessed online at https://bit.lv/37tiiFa.
I also appreciate you sharing your concerns about radioactive waste management. Currently, all radioactive waste, including used nuclear fuel, is managed at sites licensed by the CNSC. To learn more about CNSC licensed radioactive waste management facilities, I encourage you to read Canada’s sixth report to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. It is available online at https://bit.lv/35fCNQ8.
With respect to the long-term management of used nuclear fuel, the Nuclear Waste Management Organization (NWMO) is currently working extensively with communities to find a safe and suitable host community for Canada’s Deep Geologic Repository. This would include the long-term management of spent fuel generated by future SMRs. Site selection is guided by a series of principles, foremost among them is that the chosen host community is informed and willing.
The site selection process has been underway since 2010. From an initial list of 22 interested municipalities and Indigenous communities, the NWMO announced, in November 2019, that they had narrowed their site selection to two potential areas. The NWMO is considering the Municipality of South Bruce and the Township of FIuron-Kinloss, and the Township of Ignace, where they will continue to perform site studies. For more information, I invite you to visit the NWMO website at https://www.nwmo.ca.
Once a site has been identified, the Impact Assessment Agency of Canada will undertake a rigorous impact assessment of the project with further opportunities for stakeholder engagement. The International Atomic Energy Agency has identified the use of deep geologic repositories for the long-term management of nuclear fuel waste to be an international best practice.
Again, thank you for your engagement on these important issues.
Yours sincerely,
The Honourable Seamus O’Regan, P.C., M.P. c.c.: Distribution 1
DISTRIBUTION
The Honourable Jonathan Wilkinson, P.C., M.P. Minister of Environment and Climate Change
The Honourable Navdeep Bains, P.C., M.P. Minister of Innovation. Science and Industry
Ms. Aimee Rupert Environmental Assessment Officer Canadian Nuclear Safety Commission 1
f MINISTER’S OFFICE, Justin Trudeau, Prime Minister of Canada To: PA Catherine McKenna, Minister of the Environment and Climate Change ASJB Amarjeet Sohi, Minister of Natural Resources AQUT it 2 2019 Navdeep Bains, Minister of Innovation, Science and Economic Development 3HS7 / 'i tcMH WE CSODBB s««ces ecvC3«e?cs8c3C Docket # * * Ms Aimee Rupert Environmental Assessment Officer File # Canadian Nuclear Safety Commission August 12, 2019
I’m writing in opposition to the proposal by Global First Power (GFP) to build a Micro Modular Reactor (MMR) on the Chalk River Laboratories (CRL) property in eastern Ontario (Global First Power document CRP-LIC-01-001, dated 07/08/2019). Global First Power is the proponent of the project, with two partners: Ultra Safe Nuclear Corporation (Seattle), as the technology supplier (owner of the design and intellectual property for MMR reactors) and Ontario Power Generation, as the licensed operator.
The purpose of the MMR would be to “replace most of the greenhouse gas emitting heat and power sources currently employed on the CRL site” over the 20 year life span of the MMR (p. 6, Introduction). Thus, the MMR would have a practical application and also “demonstrate the commercial viability of MMR technology to prospective customers” (p. 16). However, since MMR technology is not entirely fully developed1 - the proposal describes the MMR as “based largely on proven designs” (p. 15, emphasis mine) -the project should also be regarded as experimental and developmental in nature.
Let Us Not Go Down This Road. My first objection is the implied commitment by the federal government to support the development of Micro Modular Reactors, a type of Small Module Reactors; thus continuing into the future a dependance on nuclear generated electrical power at a time when the use of hydro- electric power should be expanded and other renewable sources of electricity funded and developed. Nuclear power is NOT clean energy, as Global First Power asserts, but produces low-, intermediate- and high-level radioactive waste for which there is currently no proven method of permanent disposal, despite the promise of a deep geological repository (DGR) for low- and intermediate-level waste and a second DGR for high-level (spent fuel) waste, and the fact that the safety of DGRs has not as yet been proven anywhere in the world2. The ultimate disadvantage of Micro Modular Reactors (aside from the issue of safety) is that, if built at numerous and isolated locations across Canada (essentially what they are designed for), they will also create nuclear waste - most importantly spent fuel waste - at a multitude of locations, exacerbating the difficulties of managing this dangerous material.
I note in the proposal that spent nuclear will be disposed of in a deep geological repository. No depository has as yet been built in Canada. Although the Nuclear Waste Management Organization is currently designing and searching for a site for a spent fuel DGR, it remains to be seen whether the federal government will approve of such a facility or require alternative methods of disposal. 2
I note also that the discussion of the potential impact of the project on the environment and people, discussed in Section 6 of the proposal, is vague, reliant on past construction work for other projects at the Chalk River Laboratories, narrow in scope and full of assurances that are not documented. Thus, it is difficult to see how the proposal will “assist” the Canadian Nuclear Safety Commission (p. 6, Introduction) in making “an environmental assessment determination” (emphasis mine).
Finally, the proposed practical objective of the Micro Modular Reactor at the Chalk River Laboratories -to replace diesel generated electrical power (3.1.1 Project Summary and Context, p. 15) -is undermined by the fact that abundant hydro-electric power is available from Quebec3; indeed, even if transmission lines would need to be upgraded, the cost-benefit of hydro-electric power at the Chalk River Laboratories (green power with no use-life or end-use waste products and decommissioning costs) would be greater than nuclear power provided by a technology that is still under development.
In conclusion, I believe that the Global First Power proposal is both incomplete and ambiguous. Of greater concern are attempts by the nuclear industry to develop MMRs and by the regulator of the industry, the Canadian Nuclear Safety Commission, to offer a program of “Pre-Licensing Vendor Design Review” for Small Modular Reactors4. These activities are not in the national interest at a time when our reliance on nuclear energy should be decreasing and because of the growing burden of nuclear waste5 on our society and future generations.
I ask the Canadian government to place a moratorium on the development, licensing and installation of Micro/Small Modular Nuclear Reactors. footnotes:
1 Ramana, M.V. 2016 “The Checkered Operational History of High Temperature Gas-Cooled Reactors.” Bulletin of the Atomic Scientists 72 (Issue 3):171-179.
2- Faybishenko, Boris, Jens Birkholzer, David Sassani and Peter Swift, 2016, “International Approaches for Deep Geological Disposal of Nuclear Waste: Geological Challenges in Radioactive Waste Isolation. Fifth Worldwide Review” Lawrence Berkeley National Laboratory and Sandia National Laboratories. Prepared for the U.S. Department of Energy Spent Fuel and Waste Science Technology R&D Campaign.
3 IESO letter of February 1, 2019, asking Hydro One Networks Inc to upgrade transmission capacity to import hydro-electric power from Quebec to the Ottawa area, and ultimately the Ontario Electricity Market.
4- www.nuclearsafety.gc.ca/eng/reactors/power-plants/pre-licensing-vendor-design-review/index.cfm 5- “Inventory of Radioactive Waste in Canada, 2016.” Natural Resources of Canada. ISBN 978-0-660-26339-7. Peter Storck Southampton, Ontario, N0H 2L0 Office of the Minister / Bureau du Ministre (NRCAN/RNCAN)
From: Peter Storck
I'm writing this e-mail to send for your consideration my objections (attached as a Word document) to the proposal to build a Micro Modular Reactor (MMR) at the Chalk River Laboratories.
I'm also requesting the Canadian government to place a moratorium on the development of MNRs and Small Modular Reactors at a time when our reliance on nuclear energy should be decreasing and because of the growing burden of nuclear waste on our society and future generations.
Peter Storck Southampton Ontario
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