Waterkeeper comments on the Draft Environmental Assessment Screening Report - Refurbishment and Continued Operation of the Darlington Nuclear Generating Station

Ontario Power Generation (“OPG”) is seeking approval to refurbish the Darlington Nuclear Generating Station in Clarington, Ontario (“DNGS”). Built in the 1980’s, DNGS is one of the largest nuclear power plants in North America and in the top 25 globally. With the authorization of the Canadian Nuclear Safety Commission (“CNSC”) and the Department of Fisheries and Oceans Canada (“DFO”), OPG intends to extend the plant’s life to 2055.

OPG formally notified the CNSC of its intention to refurbish Darlington in April 2011, and a screening level environmental assessment process began. The “screening” assessment is the lowest level of environmental assessment available under Canadian law, offering the least scrutiny, public participation, or expert review. When members of the public, including Lake Ontario Waterkeeper, called for a more thorough assessment last year, the CNSC denied the request. The Commission did note in its October 28, 2011 Decision that it may make such a referral at any time during the course of the EA process if warranted.

Lake Ontario Waterkeeper submits that referral to a review panel is warranted at this time.

Our review of the Draft Environmental Assessment Screening Report – Refurbishment and Continued Operation of the Darlington Nuclear Generating Station (the “Report”) examined the project’s potential impact on fish, fish habitat, and water quality. We focused primarily on the plant’s cooling water system, which has a significant impact on the ecology of Lake Ontario through fish impingement and entrainment, thermal pollution, and the emission of a variety of contaminants (both radioactive and non-radioactive) to the lake.

Waterkeeper retained the services of four experienced advisors with the help of the Participant Funding Program, in order to better inform the environmental assessment process:

• Dr. Peter Henderson of Pisces Conservation is an experienced fisheries biologist and a leading expert on cooling water intake structures. He has previously provided information as part of Waterkeeper’s submission to the environmental assessment process for the New Nuclear Darlington (NND) project;
• Bill Powers is a pollution control engineer with considerable experience in the design and evaluation of cooling towers for the power industry. He has provided engineering testimony in numerous regulatory proceedings, drafted portions of policy notes related to cooling towers for the Edison Power Research Institute, a leading energy-industry body, and advised on the feasibility of cooling tower retrofits at a large number of existing industrial facilities;
• Sharon Khan is an economist with expertise in economic valuation of aquatic ecosystem services. Sharon launched the Clean Water Economics Initiative with Waterkeeper Alliance, researched ecosystem services for the Ocean Foundation’s Coastal Ocean Values Center, and produced guidance related to the economic value of ecosystem services for the United Nations Environment Programme; and,
• Super Law Group has unique expertise regarding cooling water systems regulation and policy. In 2011, SLG was lead drafter of public comments on American environmental regulations governing cooling water systems at 1200 existing facilities. SLG’s principal, Reed Super, is recognized as the U.S. environmental community’s foremost expert on this subject. SLG provides state-of-the-art information, analysis, and perspective on cooling water intake impacts and mitigation best practices.

After reviewing Report and supporting technical documentation, we have come to the following conclusions:

1. Operating the Darlington Nuclear Generating Station’s once-through cooling system for the next 40 years will have significant adverse environmental effects on aquatic habitat in Lake Ontario, including:

• killing endangered fish;
• threatening the reproductive efforts of other vulnerable species;
• killing increasingly large numbers of the forage fish that sustain Lake Ontario’s trophic system; and,
• further degrading nearshore habitat in a severely stressed and polluted segment of Lake Ontario’s northern littoral zone.

2. These adverse environmental effects could be largely mitigated through the use of closed-cycle cooling (cooling towers).

3. The Report utterly fails to consider alternatives to once-through cooling.

4. Had OPG performed a proper analysis, it would have discovered that installation of cooling towers is both technically and economically achievable. The installed cost is less than 5% of the cost of the planned refurbishment, and is affordable relative to OPG’s revenues and profits.

Lake Ontario Waterkeeper alerted OPG and the Responsible Authorities to the problems with once-through cooling early on in the environmental assessment process. The CNSC responded to our concerns in its scoping Decision by explicitly instructing OPG to evaluate mitigation measures and trade-offs. This was not done. Despite the fact that Waterkeeper alerted authorities to the potential impacts of OPG’s proposal and the wide availability of information about technically and economically achievable mitigation measures (such as closed-cycle cooling), neither OPG nor the Responsible Authorities have adequately considered the environmental impacts of Darlington’s once-through cooling system.

There is irrefutable evidence that once-through cooling water systems are harmful to fish and fish habitat. There is a vast amount of research confirming that closed-cycle cooling is >95% more protective than once-through cooling. Even though OPG, the CNSC, and DFO have all been presented with information detailing the environmental decline of the Great Lakes, the potential resurgence of the watershed, and the complicating effects of climate change, these issues are completely ignored or minimized in the Report. Instead, the project proposal blithely embraces cooling water technology that was outdated even before original Darlington facility became operational.

The weaknesses and omissions contained in the Report cast a shadow over the entire environmental assessment process. Neither the EIS nor the Draft Screening Report provides a reasonable or credible basis for evaluating the environmental effects of Darlington’s once-through cooling system. The Report demonstrates that OPG, the CNSC, and DFO are either unwilling or unable to mitigate harm to fish and fish habitat on Lake Ontario. In light of these failings, Waterkeeper submits that a legitimate, reasonable, and informed decision is impossible without an independent, thorough review panel process.

Read our full submission by clicking here.

Appendix 1 - Biological Report by Dr. Peter Henderson

Appendix 2 - Engineering Report by Bill Powers

Appendix 3 - Economic Report by Sharon Khan

Appendix 4 - EPA Supporting Document for Stated Preference Survey

Appendix 5 - Analysis of EPA Stated Preference Survey by Dr. Frank Ackerman

Appendix 6 - Economic feasibility Analysis of Cooling Tower Retrofit of Delaware City Refinery

Appendix 7 - Aquatic Report by Dr. Peter Henderson

Appendix 8 - Hydrogeologic Report by Wilf Ruland

Appendix 9 - Water Quality Monitoring Report by David Dillenbeck