Waterkeeper files concerns in new Darlington nuclear plant assessment
For decades, nuclear power plants and fuel manufacturers have dotted the Lake Ontario shoreline. They have been responsible for massive fish kills and groundwater contamination. Their industrial footprint has contributed to the overall decline of Lake Ontario, which now has the worst coastal wetland health on the Great Lakes.
With an estimated cost of close to $20-billion and a multi-year licencing process, the proposed Darlington New Nuclear project will be a major commitment for Ontarians. Its environmental, economic, and cultural impacts will alter the Lake Ontario community for generations to come.
On November 19, 2008, Lake Ontario Waterkeeper and Trustee of Lake Ontario Gord Downie filed our first official submission on the Darlington New Nuclear Power Plant Project with the Canadian Environmental Assessment Agency (CEAA). The submission provides feedback on two draft documents: the Environmental Impact Statement Guidelines and the Joint Review Panel Agreement. The comments were accompanied by expert reports and a summary of our first public survey results.
At this time, Lake Ontario Waterkeeper is concerned that the Joint Review process is flawed. While the environmental assessment proceeds by way of a "review panel", the proposed process does not resemble a traditional, independent review by a panel. Waterkeeper is also very concerned about the potential impacts on fish and fish habitat, and highlighted these issues in our review of the possible environmental impacts.
Background
The Darlington Nuclear Generating Station is owned and operated by Ontario Power Generation (OPG). It is currently a four-unit station with a total output of 3,524 megawatts (MW) and is located in the Municipality of Clarington in Durham Region, 70 km east of Toronto. It provides about 20 per cent of Ontario's electricity needs, enough to serve a city of two million people.
On August 17, 2006 OPG wrote to the CNSC stating its intent to construct and operate up to four new nuclear reactors at Darlington, Ontario with the capacity to produce 4800 MW of power. OPG has not yet chosen a reactor technology or a company to construct the reactor units.
OPG’s submission to the CNSC triggered the federal Environmental Assessment process. In March 2007, the federal Minister of the Environment referred the project to a review panel. The Environmental Assessment process is proceeding under the Canadian Environmental Assessment Act. Public feedback was sought in regards to two documents: the Draft Guidelines for the Preparation of the Environmental Impact Statement; and the Agreement to Establish a Joint Review Panel.
Lake Ontario Waterkeeper's Submission
The Darlington New Nuclear project represents a long-term commitment to nuclear power generation along the shores of Lake Ontario. Lake Ontario Waterkeeper's comments draw from the opinions of the public - the organizations, businesses, and individuals who have a stake in the future of the Darlington plant. Public comments were accepted through an online survey designed by Waterkeeper to solicit opinions on the Environmental Assessment process.
In addition, Waterkeeper hired a number of experts to assist with the review of the documents submitted by OPG. Their work helped to inform both the EIS and JRP submissions. The experts include:
Wilf Ruland - Hydrogeologist
Pisces Conservation - Cooling Water Experts
David Dillenbeck - Fish Biologist
Peter Faye - Energy System and Legal Authority
Joint Review Agreement
Read Lake Ontario Waterkeeper's original comments on the draft Joint Review Panel Agreement here.
As part of the Environmental Assessment process, the Federal Minister of the Environment has referred the project to a Joint Review Panel. In Waterkeeper's submissions, we argue that the current draft Joint Review Panel Agreement must be abandoned for several reasons:
The federal Minister of the Environment has several responsibilities that must be executed as part of an Environmental Assessment. Under the proposed Agreement, the Minister is relinquishing that authority to the CNSC.
As part of the approval process for this new nuclear project, there are four decision-making bodies that should conduct an Environmental Assessment: the Department of Transportation, the Canadian Transportation Agency, and the Department of Fisheries and Oceans and the CNSC. Under the current Agreement, only the Ministry of the Environment and the CNSC are included.
The Ontario Ministry of the Environment will have to issue several permits before a new nuclear power plant can operate. The Ministry should be included in the process now, to prevent a more lengthy and costly approvals process than is necessary.
Environmental Impact Statement Guidelines
Read Lake Ontario Waterkeeper's original comments on the draft Environmental Impact Statement Guidelines here.
As part of the Environment Assessment process, OPG is required to prepare an Environmental Impact Statement - a report that outlines the project's predicted environmental effects. In Waterkeeper's submissions, our comments largely reflect those of the expert reports:
Cooling water systems have the potential to destroy millions of fish each year, with potentially devastating impacts on Lake Ontario.
The Province can and should be involved in reviewing the potential environmental impacts of the project, including the Ontario Ministry of Natural Resources and the Ontario Ministry of the Environment.
The 'confidentiality clause' of the Guidelines is so broadly worded that it may allow important information to be excluded from public scrutiny.
The contact information and qualifications of any person(s) hired to prepare the EIS should be listed on the document. Any professional that contributes material should sign and stamp their work.
While the scope of the Environmental Assessment needs to remain broad, several specific details should be added to the ensure a complete review.
Questions regarding the justification and alternatives to the project should be added.
The effects on the existing environment at the site should include factors such as commercial fisheries, groundwater flow and a record of tritium testing on the ground and surface water.
Add limits according to federal and provincial standards wherever possible in order to define what is not an acceptable impact.
The effects of climate change on Lake Ontario and the surrounding environment must be part of the report.
The concept of "shoreline fumigation" must be considered in atmospheric modeling.
The term "follow-up" should be replaced by "monitoring", to better describe the active role OPG must play in protecting the environment before, during and after construction.
What the Public Says
Lake Ontario Waterkeeper's submissions also reflect the feedback we received from public consultation. An online survey was designed to gather a variety of opinions surrounding the Darlington New Build. These include:
Public participation in, and understanding of, the Environmental Assessment and Joint Review Panel processes.
Ongoing media coverage of the Darlington New Build.
Concerns surrounding the nuclear facility.
The response shows that people across Ontario felt their voices mattered on the Darlington project. The survey also revealed key points about how organizations, busniesses and individuals felt towards the process. In particular, many respondents felt that:
They didn't understand the processes involved, including environmental assessments and review panels.
They did not realize there was a body (the CNSC) dedicated to the oversight of nuclear power in Canada.
They did not feel there was a place for the public to participate.
Their concerns would not be addressed.
The Darlington New Build will have some kind of impact on the environment and human health, in particular the water quality of Lake Ontario, and fish habitat and population.
Updates
The Canadian Nuclear Safety Commission released its final EIS Guidelines and Joint Review Panel Agreement March 12, 2009.
Lake Ontario Waterkeeper applies for funding to retain the same roster of experts for Phase II of the environmental assessment July 20, 2009.