Darlington Comments

Comments to the Panel on the proposal to build nuclear reactors at Darlington

February 18, 2011

The proponent has given me no reason to believe that the objective of producing 4500 megawatts from new nuclear reactors at Darlington cannot be met over the same, or shorter, time frame and for less cost from the accelerated development of alternative renewable sources of energy and from significant conservation efforts.

With the political will, Ontario should be able to produce at least that much electrical energy from green alternatives and conservation rather than from highly polluting sources such as nuclear and coal. Especially, since the construction of a full-scale nuclear power reactor can take as much as a decade or more to complete.

However, let’s do it right. What Ontario needs is a serious, comprehensive and unbiased comparative analysis which includes projections of the full range of benefits and costs of new nuclear construction vs. those from a realistic spectrum of green energy sources and conservation.

Without such a study, any conclusions drawn regarding the efficacy of proceeding with a highly centralized, extremely expensive nuclear option at this point would be meaningless and could do a great disservice to the people of Ontario.

It should be noted that a recently released study (January 27, 2011) by Mark Jacobson and Mark Delucchi of Stanford University concludes that the world can be electrically powered by alternative energy from wind, water and sunlight within 20 to 40 years. Nuclear energy is ruled out as an option particularly on the basis of potential terrorism threats, weapons proliferation, carbon emissions, and radioactive waste issues.

Significant developments in alternative energy are underway which must not be brushed aside and ignored within the narrow boundaries of a typical environmental assessment process on one particular mode of energy.

It should also be noted that the UN Environment Programme (UNEP) and the International Energy Agency-backed Renewable Energy Policy Network for the 21st Century (REN21) project, declared that, for the second year in a row, the quantity of “newly installed capacity” of renewable energy in Europe and the U.S. outpaced that for fossil fuels and nuclear. The report

suggests the same outcome is likely on a global basis this year.

The ongoing Darlington environmental assessment must be amended to encompass a comparative analysis which also includes the negative features and consequences of nuclear energy, (many of which are frequently overlooked).

As a reminder, following is a summary of some of those “down-sides:”

Significant cost overruns are not confined to CANDU reactor nuclear power development in Ontario. A current case in point is the development and construction of the Olkiluoto reactor in Finland by the French based AREVA company. According to Stephen Thomas, professor of energy policy at the University of Greenwich, "Olkiluoto has become an example of all that can go wrong in economic terms with new reactors.” Areva and the utility involved "...are in bitter dispute over who will bear the cost overruns and there is a real risk now that the utility will default"

According to the Stop Darlington coalition “This (Darlington) plan will divert billions of dollars that should be invested in cheaper and cleaner green energy sources. Expanding our use of green energy to replace Darlington would create thousands of decentralized jobs, save rate-payers money and end the production of radioactive waste.”

According to the Ontario Clean Air Alliance (OCAA), energy conservation and efficiency per kilowatt-hour costs from 2.3 to 4.6 cents, while the re-build of Darlington would be as high as 19 to 37 cents. OCAA also points out that “... every single nuclear project in Ontario’s history has gone over budget and the actual costs of Ontario’s nuclear projects have been 2.5 times greater than the original cost estimates.”

According to John Parsons, director of the energy and environment program at the MIT Sloan School of Management, nuclear is increasingly seen as uncompetitive with natural-gas-fired plants as gas prices fall and global construction costs soar. In 2009, MIT doubled its forecasted construction costs of new nuclear plants, while the U.S. Energy Information Administration increased its 2009 estimate by 37 per cent just this past December.

.No publicly acceptable solution for the permanent disposition of irradiated reactor fuel waste as yet exists in Canada

According to the Canadian federal environmental assessment panel (Seaborn) report released in March, 1998 after an eight year intensive public process "... the (AECL) concept in its current form for deep geologic disposal does not have broad public support, and does not have the required level of acceptability to be adopted as Canada's approach for managing nuclear fuel wastes."

.Canada's nuclear industry-based Nuclear Waste Management Organization (NWMO,) in November, 2005, after a three year study, continued to endorse the permanent underground burial of irradiated nuclear fuel wastes

According to Elizabeth May, former Executive Director of the Sierra Club of Canada and currently leader of the Green Party of Canada, "...the NWMO has taken its mandate and skewed it to allow them to make decisions that are industry-biased, and not based on health, safety and security measures."

.If all of Canada's current nuclear waste is transported to a centralized location for storage or permanent burial, shipments by rail, highway and waterway, would be continuous, and over many years, possibly decades

According to Nuclear Waste Watch, (a network of thirty environmental, social and other groups across Canada) "the potential recipient and transport route communities should all have veto power, and should receive funding from proponents for independent research and community education."

Concerns expressed by many groups opposed to nuclear waste transportation include property value losses along the transportation corridor, the routine radiation exposure during handling and transit, worst case scenario radiation exposure, health and environmental costs, and more potential for accidents and terrorist acts resulting from greater shipment frequency and duration of shipments.

The proposal to build reactors at Darlington could obviously eventually add considerably to the potential for transportation risks

.No safe level of ionizing radiation exists

According to a 2005 report of a US National Academy of Sciences panel (Biological Effects of Ionizing Radiation-BEIR VII), investigating the dangers of low energy, low-dose ionizing radiation, "..it is unlikely that a threshold exists for the induction of cancers... Further, there are

extensive data on radiation-induced transmissible mutations in mice and other organisms. There is therefore no reason to believe that humans would be immune to this sort of harm."

The nuclear industry frequently attempts to minimize the impact of low-dose radiation by a misleading comparison with natural “background” radiation. In the early 1980's, the Government of Manitoba conducted scientific tests of background radiation found in many water wells in the eastern part of the province. As a result it was necessary to condemn many of these wells due to radiation readings in excess of the so-called “allowable” limits for clean drinking water health and safety.

It is possible that the lack of safe levels of low dose radiation results in an increase in various forms of cancer in areas surrounding nuclear reactors. For instance, in a 2008 study published in the European Journal of Cancer Care, it was reported that leukemia death rates in U.S. Children near nuclear reactors rose sharply (vs. the national trend) in the past two decades.

.Terrorists could use nuclear reactors and nuclear waste as weapons of mass destruction and for the development of “dirty bombs.”

We live in increasingly dangerous times.

According to journalist Jeffrey St. Clair, shortly after the September 11, 2001 terrorist attacks on the U.S., it was widely reported that al-Qaeda had given serious consideration to crashing commercial aircraft into several nuclear plants on that day. In his September 14, 2002 Counterpunch article (The Fire Next Time), he reports that al-Qaeda operatives Ramzi bin al-Shaibah and Khaled al-Sheikh Mohammad told Al-Jazeera interviewer Yosri Fouda, that future attacks on Western nuclear facilities could not be ruled out.

But the real Achille's heel at a nuclear plants is the adjacent spent fuel facility, which contains major concentrations of highly radioactive material. They lack the heavy duty containment safeguard provided for the reactor, and could be considered "sitting ducks" for disastrous terror attacks.

Large explosions, along with major fire resulting in radioactive release from spent fuel would have serious health, social and economic consequences for people in the surrounding geographical area. It should be noted that many of our nuclear facilities are in close proximity to the Great Lakes. Any ecological disaster resulting from terrorism could affect water quality in both Canada and the United States.

As long as reactors are operating, much of their irradiated fuel waste must remain at the reactor sites in pools of water and/or dry casks for long periods of time, as they simply are too “hot” to handle–even if “out of sight-out of mind” central permanent storage facility were available. The Darlington proposal would provide even more security concerns. In my view, nuclear phase-out is necessary in order to stop the production of irradiated fuel wastes.

.More nuclear reactors can lead directly to greater nuclear weapons proliferation

According to Dr. Helen Caldicott, as a result of the projected so-called "...renaissance of the nuclear power industry, twenty-five countries and consortia will have access over a period of two decades to Generation IV reactors fueled by plutonium." In her book, Nuclear Power is Not the Answer, Dr. Caldicott reminds us that "Canada supplied India with a CIRUS heavy water reactor for making nuclear energy. . . It was this reactor that gave India the plutonium it used in its first 1974 nuclear weapons test."

One negative consequence often leads to another. A decade ago, few would have expected North Korea to have developed atomic weapons. What will a nuclear armed world look like a decade from now.

Nuclear power is the ultimate conceiver of nuclear weapons.

The above outline covers some of the problems associated with the development and use of nuclear energy to produce electricity. This outline of nuclear energy down-sides is by no means complete. For example the woefully low insurance amounts for nuclear liability would not begin to cover the damages from large scale nuclear accidents; the contemplated use of irradiated fuel reprocessing in North America and the associated pollution issues that we have been witnessing in France and the U.K.

I am confident that green renewable energy and conservation can meet Ontario’s electrical energy requirements. However, I urge that a comparative analysis be undertaken which includes projections of the full range of benefits and costs of new nuclear construction and operation vs. those from a realistic spectrum of green energy sources and conservation, including possible hydro electricity import from neighboring provinces. In the meanwhile, all work on the Darlington projects should be stopped.

Many thanks for the opportunity to comment on this proposal.

Walter Robbins

Kingston, Ontario, Canada

Nuclear energy is responsible for the release of large quantities of greenhouse gasses and other noxious emissions

According to a December 14, 2006 report by the Pembina Institute, no other energy source combines the generation of as wide a range of conventional pollutants and waste streams-including heavy metals, smog-and acid-rain precursors and greenhouse gases. It notes that "...total greenhouse gas emissions associated with uranium mining, milling, refining, conversion and fuel fabrication in Canada are estimated at between 240,000 and 366,000 tonnes of CO2 per year."

.Harmful emissions from the nuclear industry will continue to increase as supplies of rich uranium ore decrease

According to scientists Jan Willem Storm van Leeuwen and Philip Bartlett Smith, "...at the present rate of use, worldwide supplies of rich uranium ore will soon become exhausted, perhaps within the next decade. Nuclear power stations of the future will have to rely on second-grade ore, which requires huge amounts of conventional energy to refine it. For each ton of poor-quality uranium, some 5000 tons of granite that contain it will have to be mined, milled and then disposed of. This could rise to 10,000 tons if the quality deteriorates further.

At some point, and it could happen soon, the nuclear industry will be emitting as much carbon dioxide from mining and treating its ore as it saves from the so-called clean power it produces thanks to nuclear fission." The researchers estimate that "The use of nuclear power causes, at the end of the road and under the most favourable conditions, approximately one-third as much carbon dioxide emission as gas-fired electricity production."

.Nuclear power production could well go into energy deficit as rich Uranium ore quantities are consumed

According to energy writer David Fleming in Prospect magazine on the subject of rich ore depletion, "...it (nuclear) would be putting more energy into the process than it could extract from it. Its contribution to meeting the world's energy needs would become negative! The so-called reliability of nuclear power, which its proponents enthuse over, would therefore rest on the growing use of fossil fuels rather than their replacement."

In my view, Fleming’s comments translate into more and larger dangerous uranium tailing ponds with all of their health and safety issues. The Stop Darlington coalition says “there are currently over 200 million tonnes of uranium tailings in Ontario and Saskatchewan. This waste remains a

hazard for thousands of years and contains carcinogens, such as radium, radon gas, and thorium among others.”

.Nuclear reactors routinely emit other noxious substances, one of the worst of which is radioactive tritium into the environment

According to Dr. Gordon Edwards of the Canadian Coalition for Nuclear Responsibility, "Tritium poses an ever-present radiological hazard to CANDU (reactor) workers. It is also an environmental contaminant which pollutes the drinking water of many communities situated near CANDU reactors. In addition, atmospheric emissions of tritium are readily inhaled - and also absorbed directly through the skin - by residents living near CANDU reactors."

.Nuclear reactors can have an adverse impact on surrounding bodies

of water, such as the Great Lakes

According to Lake Ontario Waterkeeper, the lake has a “fragile” ecosystem. Since millions of people depend on this lake for basic physiological needs, it is my view that the plan to place additional large-scale nuclear reactors on the lake could enhance that fragility and is, therefore, a highly questionable undertaking.

.New nuclear reactor design problems can delay or even terminate large scale, expensive projects

One example of this phenomenon in which I was personally involved, can be found in Atomic Energy of Canada’s failed effort to develop a promised 10 mw Slowpoke reactor, even while attempting to market it in Canada and abroad. The 2 mw pilot version at the Whiteshell Nuclear Research Establishment in Manitoba was finally shut down as it failed to reach its full capacity.

Many concerns have been expressed about the technical problems associated with the so-called “new generation” of large nuclear of large nuclear reactors.

.The Canadian taxpayer is footing much of the bill and incurring much of the national debt, for Atomic Energy of Canada Ltd's (AECL's) nuclear expansion. The economics of nuclear energy are not sustainable

According to a 2006 Energy Probe study, federal subsidies to AECL since its inception in 1952 amounted to $74.9 billion of Federal Government debt (about 12 per cent of the entire outstanding amount).

According to Shawn-Patrick Stensil, Greenpeace nuclear analyst. “Ontario consumers spent nearly $2 billion (in 2009) on their electricity bills to pay down the debt from building reactors in the 1970s...” This “debt retirement charge” continues to appear on Hydro One billings.

Volume Two -

update: 1984-1988-

The growing prospect of nuclear waste dumps on both sides of the U.S.-Canadian border intensifies the controversy

Volume Three -

update:1988-1998

Federal Environmental Panel concludes that Atomic Energy of Canada Ltd.'s permanent underground nuclear waste burial concept lacks public acceptability.