Comments on the proposal to build nuclear reactors at Darlington February 18, 2011 To: Panel Secretariat, Darlington New Nuclear Power

Plant Project Joint Review Panel, Ottawa, Ontario, Canada 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 s ame, or shorter, time frame and for less cost from the accelerated development o f alternative renewable sources of energy and from significant conservation effo rts. With the political will, Ontario should be able to produce at least that m uch electrical energy from green alternatives and conservation rather than from highly polluting sources such as nuclear and coal. Especially, since the constru ction 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 un biased comparative analysis which includes projections of the full range of bene fits and costs of new nuclear construction vs. those from a realistic spectrum o f 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 wou ld 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 Jac obson and Mark Delucchi of Stanford University concludes that the world can be e lectrically powered by alternative energy from wind, water and sunlight within 2 0 to 40 years. Nuclear energy is ruled out as an option particularly on the basi s of potential terrorism threats, weapons proliferation, carbon emissions, and r adioactive waste issues. Significant developments in alternative energy are underway which must not be br ushed 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 Interna tional 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 “n ewly 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 c omparative analysis which also includes the negative features and consequences o f nuclear energy, (many of which are frequently overlooked). As a reminder, following is a summary of some of those “down-sides:” .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 energ y source combines the generation of as wide a range of conventional pollutants a nd waste streams-including heavy metals, smog-and acid-rain precursors and green house gases. It notes that " greenhouse gas emissions associated with ur anium mining, milling, refining, conversion and fuel fabrication in Canada are e stimated at between 240,000 and 366,000 tonnes of CO2 per year."

.Harmful emissions from the nuclear industry will continue to increase as suppli es of rich uranium ore decrease According to scientists Jan Willem Storm van Leeuwen and Philip Bartlett Smith, " 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 co nventional 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 c arbon dioxide from mining and treating its ore as it saves from the so-called cl ean 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 favo urable conditions, approximately one-third as much carbon dioxide emission as ga s-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, " (nuclear) would be putting more energy into the proce ss 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 f uels rather than their replacement." In my view, Fleming’s comments translate into more and larger dangerous uranium ta iling ponds with all of their health and safety issues. The Stop Darlington coa lition says “there are currently over 200 million tonnes of uranium tailings in On tario and Saskatchewan. This waste remains a hazard for thousands of years and c ontains carcinogens, such as radium, radon gas, and thorium among others.” .Nuclear reactors routinely emit other noxious substances, one of the worst of w hich is radioactive tritium into the environment According to Dr. Gordon Edwards of the Canadian Coalition for Nuclear Responsibi lity, "Tritium poses an ever-present radiological hazard to CANDU (reactor) work ers. It is also an environmental contaminant which pollutes the drinking water o f many communities situated near CANDU reactors. In addition, atmospheric emissi ons 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, suc h as the Great Lakes According to Lake Ontario Waterkeeper, the lake has a “fragile” ecosystem. Since mi llions of people depend on this lake for basic physiological needs, it is my vie w that the plan to place additional large-scale nuclear reactors on the lake cou ld enhance that fragility and is, therefore, a highly questionable undertaking. .New nuclear reactor design problems can delay or even terminate large scale, ex pensive 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 re actor, 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 t he so-called “new generation” of large nuclear reactors.

.The Canadian taxpayer is footing much of the bill and incurring much of the nat ional debt, for Atomic Energy of Canada Ltd s (AECL s) nuclear expansion. The e conomics of nuclear energy are not sustainable According to a 2006 Energy Probe study, federal subsidies to AECL since its ince ption in 1952 amounted to $74.9 billion of Federal Government debt (about 12 pe r 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 de bt from building reactors in the 1970s...” This “debt retirement charge” continues to appear on Hydro One billings. Significant cost overruns are not confined to CANDU reactor nuclear power develo pment in Ontario. A current case in point is the development and construction o f 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 w ill bear the cost overruns and there is a real risk now that the utility will de fault" According to the Stop Darlington coalition “This (Darlington) plan will divert bil lions of dollars that should be invested in cheaper and cleaner green energy sou rces. Expanding our use of green energy to replace Darlington would create thous ands of decentralized jobs, save rate-payers money and end the production of rad ioactive waste.” According to the Ontario Clean Air Alliance (OCAA), energy conservation and effi ciency per-kilowatt-hour costs from 2.3 to 4.6 cents, while the re-build of Darl ington would be as high as 19 to 37 cents. OCAA also points out that “... every s ingle nuclear project in Ontario’s history has gone over budget and the actual cos ts of Ontario’s nuclear projects have been 2.5 times greater than the original cos t 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 w ith natural-gas-fired plants as gas prices fall and global construction costs so ar. In 2009, MIT doubled its forecasted construction costs of new nuclear plants , while the U.S. Energy Information Administration increased its 2009 estimate b y 37 per cent just this past December. .No publicly acceptable solution for the permanent disposition of irradiated rea ctor fuel waste as yet exists in Canada According to the Canadian federal environmental assessment panel (Seaborn) repor t 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 broa d public support, and does not have the required level of acceptability to be ad opted as Canada s approach for managing nuclear fuel wastes." .Canada s nuclear industry-based Nuclear Waste Management Organization (NWMO,) i





n November, 2005, after a three year study, continued to endorse the permanent u nderground burial of irradiated nuclear fuel wastes According to Elizabeth May, former Executive Director of the Sierra Club of Cana da 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 locati on for storage or permanent burial, shipments by rail, highway and waterway, wou ld 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 commun ities 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 includ e property value losses along the transportation corridor, the routine radiation exposure during handling and transit, worst case scenario radiation exposure, h ealth and environmental costs, and more potential for accidents and terrorist ac ts resulting from greater shipment frequency and duration of shipments. The proposal to build reactors at Darlington will obviously 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 (Biologica l Effects of Ionizing Radiation-BEIR VII), investigating the dangers of low ener gy, low-dose ionizing radiation, " is unlikely that a threshold exists for t he induction of cancers... Further, there are extensive data on radiation-induce d transmissible mutations in mice and other organisms. There is therefore no rea son to believe that humans would be immune to this sort of harm." The nuclear industry frequently attempts to minimize the impact of low-dose radi ation by a misleading comparison with natural “background” radiation. In the early 1980 s, the Government of Manitoba ckground radiation found in many water wells in . As a result it was necessary to condemn many readings in excess of the so-called “allowable” th 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 r ose sharply (vs. the national trend) in the past two decades. .Terrorists could use nuclear reactors and nuclear waste as weapons of mass dest ruction 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 se rious consideration to crashing commercial aircraft into several nuclear plants on that day. In his September 14, 2002 Counterpunch article (The Fire Next Time)


conducted scientific tests of ba the eastern part of the province of these wells due to radiation limits for clean drinking water heal

, 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 facil ity, which contains major concentrations of highly radioactive material. They la ck the heavy duty containment safeguard provided for the reactor, and could be c onsidered "sitting ducks" for disastrous terror attacks. Large explosions, along with major fire resulting in radioactive release from spent fuel would have ser ious health, social and economic consequences for people in the surrounding geog raphical area. It should be noted that many of our nuclear facilities are in clo se proximity to the Great Lakes. Any ecological disaster resulting from terroris m could affect water quality in both Canada and the United States. As long as reactors are in at the reactor sites ime, as they simply are manent storage facility operating, much of their irradiated fuel waste must rema in pools of water and/or dry casks for long periods of t too “hot” to handle–even if “out of sight-out of mind” central per were available.

The Darlington proposal would provide even more security concerns. .More nuclear reactors can lead directly to greater nuclear weapons proliferatio n According to Dr. Helen Caldicott, as a result of the projected so-called " naissance of the nuclear power industry, twenty-five countries and consortia wil l have access over a period of two decades to Generation IV reactors fueled by p lutonium." In her book, Nuclear Power is Not the Answer, Dr. Caldicott reminds u s that "Canada supplied India with a CIRUS heavy water reactor for making nuclea r energy. . . It was this reactor that gave India the plutonium it used in its f irst 1974 nuclear weapons test." One negative consequence often leads to another. A decade ago, few would have e xpected 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 an d 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 amou nts 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 Fra nce and the U.K. I am confident that green renewable energy and conservation can meet Ontario’s ele ctrical energy requirements. However, I urge that a comparative analysis be un dertaken which includes projections of the full range of benefits and costs of n ew nuclear construction and operation vs. those from a realistic spectrum of gre en energy sources and conservation, including possible hydro electricity import from neighboring provinces. In the meanwhile, all work on the Darlington projec ts should be stopped. Many thanks for the opportunity to comment on this proposal. Walter Robbins Kingston, Ontario, Canada


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