:
Thank you, Mr. Chairman.
[Translation]
Mr. Chairman, Members of the Committee, good afternoon.
I am pleased to be here today to address the Commission’s decision.
[English]
There's been a significant amount of misinformation circulating about this shipment. I hope you will find the following technical presentation useful.
I always appreciate the opportunity to provide clarity on a nuclear file, particularly given that our mandate is to actually disseminate some objective information.
[Translation]
We represent the Canadian Nuclear Safety Commission.
[English]
We were established in May 2000 under the Nuclear Safety and Control Act, which replaced the AECB that was established in 1946.
Some of you may not realize we are now celebrating our 65th anniversary. We're not planning to retire any time soon. We are very proud of our safety culture and our safety record, which I would like to argue is second to none.
We are a quasi-judicial administrative tribunal. All our commissioners are independent.
[Translation]
The Commission’s hearings are public and broadcast over the Web. Our decisions are transparent and science based.
[English]
Let me start by trying to be very clear. Canada has a clear radioactive waste policy and all applicants to the CNSC must comply with that particular policy. It is based on the environmental principles of reduce, reuse, and recycle. There is a very well-defined international framework that explains what those words mean. There are domestic regulations and policies, and we've listed all the policies and documents that can shed light on this idea that there is no policy.
[Translation]
It is important to note that Canada has a clear policy on nuclear waste.
[English]
How is the transport of nuclear substances regulated?
First of all, all nuclear substances are governed by the International Atomic Energy Agency, which is governed by the international maritime dangerous goods code. There is a CNSC regulation for the packaging and transport of nuclear substances. There is a Transport Canada regulation for the transportation of dangerous goods. In the steam-generated case, you need a Swedish and a U.S. authority.
By the time anybody can comply with all those regulations, this would be the safest shipping of any hazardous material that I can think of.
There are many dangerous goods that are regularly transported in the St. Lawrence Seaway. There is a list, and if you look at the last item, it includes yellowcake uranium. They're shipped in and out every day of the year.
By the way, none of that shipping requires a municipality authorization to go through. It is routine business.
No precedent is being set. Millions of shipments of nuclear substances in Canada are transported every year. In Montreal alone, each year there are over 9,000 shipments that pass through the Montreal Trudeau Airport, over 1,000 shipments through the Port of Montreal, and over 50,000 medical isotopes. It is a routine activity, with no safety issues.
Why are there no safety issues?
[Translation]
We do not have problems because we use pre-approved packages.
[English]
We use internationally pre-approved transport packages. They are internationally approved, and therefore, when you package radioactive material in those packages, there is no need for any further approval. It gets shipped like any other commodity.
Let's turn to steam generators on slide 9. What's different about steam generators? It's their size. They do not fit in a pre-approved package, and therefore they require what is known as special arrangements. It does not mean they get a kind of “wink, wink, we'll approve it”. It means there is no approved package; therefore, we have to look at the safety case on a case-by-case basis.
I just point out to you that there are four grams of radioactive material. If we could put all of this in a pre-approved package, we wouldn't be appearing in front of you. This would have gone routinely through the system.
So what's inside those steam generators? If you look at slide 10, you will see that there are 65 kilometres of inner tubes. In those tubes, that's where water gets circulated and turned into steam. Over the 25 years of the life of the steam generator, there is a minute amount of radioactive deposit on the inside of those tubes.
It's important to understand that the outer shell is five centimetres of clean steel. I was trying to give you a scale. Do you see the little black box on the right? The width of the shell is five centimetres. This is not an aluminum cooking pot. This is a significant clean steel that provides safe package for the amount of nuclear material inside it. That explains why there's such low radioactivity on the outside.
If you look at slide 11, we actually compare some of the radioactive detection, the dose rate, beside the steam generator, and you can see its equivalent is less than the medical isotope boxes in which we ship all medical isotopes across the world.
If you look at slide 12, you will see that it compares the radioactive dose with background radioactivity and medical procedures, and you can see this is a really small amount of radioactive material.
On slide 13 there is one more kind of analogy, that the total amount of radioactivity inside a steam generator is less than the amount of radioactivity in a pacemaker.
Okay, so let's turn now to le processus de la commission. We held public hearings on September 28 and 29, 2010; 78 interventions appeared in front of us. It was two days of hearings, 22 hours of public hearings.
[Translation]
Several Quebec stakeholders had the opportunity to present to the Commission.
[English]
We've been accused of not allowing Quebeckers to participate.
[Translation]
We have included the list of all the witnesses that appeared before the Commission. It was a comprehensive public consultation process.
[English]
We listened in the first round of hearings to some of the issues. We took an additional amount of time to study some of the issues and allowed everybody additional time to provide further information. We carefully considered all the presentations given by all interveners, our staff, and everybody else in the analysis.
The hearing was widely disseminated both in Ontario and Quebec. In addition to this, CNSC staff made numerous presentations to city councils, mayors, and aboriginal councils. Anybody who wanted to know about this file and asked got a visit from our staff, who made a technical presentation about what was involved.
The next slide tries to explain the kind of analysis and science undertaken. CNSC staff totally evaluated the following safety areas, as listed here. It's important to understand that in doing this evaluation, they took into account all the presentations that were put in front of us.
On packaging and transport, all careful measures were taken into this proposal. The transport vehicle will not go faster than 30 kilometres per hour. The ship is a specialized nuclear qualified ship. It's only loaded at 25% of its capacity, and the crew is very well trained. The conclusion is that the packaging and transport comply with national and international regulations.
We've been accused of not doing environmental assessments. I have to tell you that we had legal opinions that there was no trigger under the CEAA for an environmental assessment. I know this is being contested now in front of a judicial review. But I have to tell you that we do such environmental assessments routinely on practically every project we do, from uranium mines to nuclear approval. It's the same CNSC staff who are doing the environmental assessments.
The staff evaluated some multiple worst-case scenarios, and the bottom line is that the risk for the environment....
[Translation]
In the worst case scenario, the danger to the environment and human health would be negligible.
The finding was the same for protection measures. We concluded the following:
[English]
The dose to the workers and members of the public would be less than 0.1% of the limit for members of the public, which is negligible.
We reviewed Bruce Power's emergency response plan and the International Maritime Organization regulations, and the commission concluded that the emergency measures are adequate.
You can imagine that there are a lot of organizations involved in sharing security, including Transport Canada, the Marine Security Operation Centre, the RCMP, the Coast Guard, the Ontario Provincial Police, and la Sûreté du Quebec.
[Translation]
We concluded that the safety measures were adequate.
[English]
In conclusion, the commission is satisfied that the transport can be completed safely and that the risk to persons and the environment is negligible. The shipment meets all Canadian and international regulations and requirements, and Bruce Power is qualified to carry out the plan.
Overall the plan is good for the environment. It's recycling clean steel. It's good waste management practice--it reduces the volume of waste by 90%--and it is safe.
I'd just like to remind everybody about our battle cry, if you like: The commission will never compromise safety.
[Translation]
We will never compromise safety. Thank you very much.
Good afternoon ladies and gentlemen.
I, like other ordinary people, have a lot of questions about this initiative. I have here a copy of the resolutions against the shipping of nuclear waste passed by 61 municipalities, including Montreal and Quebec City, and by five Regional Municipalities. The Minister of Développement durable, de l'Environnement et des Parcs du Québec, Pierre Arcand, has criticized the way you operate. Do you not think that you have failed to provide people with sufficient information?
Bruce Power failed to inform people. It appears to me, that given the scale of the project, you were pretty cursory in your efforts. Minister Pierre Arcand pointed out to you in a letter that Quebeckers would feel the impact of any potential accident. To my mind, it is only natural that there be a public outcry. People are wondering why you authorized this shipment.
The public has always thought that waste should be dealt with where it is produced. Ontario chose nuclear power. It opted to operate nuclear power stations and, as a result, should dispose of its waste at home.
You contend that you are not setting a precedent. However, you are indeed creating a precedent in terms of the size of the generators. People are also concerned that other plants may be decommissioned and that the Saint Lawrence may become a nuclear waste highway. That would be quite simply unacceptable.
No matter your arguments about the small quantity of radioactive material and the low risk, the fact remains that there are dangers. People are worried. Why did you agree to conduct the assessment and authorize the project?
I really fail to understand. It seems to fly in the face of everything the Canadian Nuclear Safety Commission is supposed to stand for.
Good afternoon, everyone, and thank you for the invitation.
I'll start by apologizing to the translator, because my accent normally causes a bit of interest, but I'll try my best.
Voices: Oh, oh!
Mr. Duncan Hawthorne: Obviously I've listened with interest to the searching questions the committee has already asked of the regulator, so I don't intend to reprise all of that. Let me start by introducing what Bruce Power is. I'm sure you may be aware of some of these facts.
We are Canada's only private sector nuclear operator on the shores of Lake Huron and we operate North America's largest operational nuclear facility. As this topic brings about, we are in the process of refurbishing and returning to service 1,300 megawatts of nuclear plant that was retired from service some 15 years ago.
As part of the process, of course, we do have very clear regulatory guidelines governing everything we do, frankly, but as we went through the decision-making on the return to service of these units, we did go through the environmental assessment process that preceded our project, which commenced for real in late 2005.
The first slide gives a bit of background. When you turn to slide 2 you can get a sense of the magnitude of the activity that represents this refurbishment project. We are replacing many of the major life-cycle components, including all the reactor core material where we are dismantling all the reactor pressure tubes and calandria tubes and all the reactor internals. We are cutting them into small pieces and storing them on site.
One of the unique features of this project is that each of our reactors has eight steam generators. If you consider the picture you're looking at on slide 2, the four square blocks equate to the four reactors. Units 3 and 4 are in operation, and if you notice the third one from the left, you see a large crane parked outside unit 2. It was through the use of this crane that my colleague, Patrick Lamarre from SNC-Lavalin, took on board the project to remove these steam generators from their location and to replace them with new ones.
As was mentioned previously, of course, many elements of this project went into the planning phase. Everything we do in the industry is governed by two things: first, a commitment to meet our regulations; and second, to seek continuous improvement.
Dr. Binder mentioned the whole principle of “as low as reasonably achievable”, the ALARA principle. It's one that I'd say governs the very safe operation of Canada's nuclear industry. We should recognize that we have an industry with a stellar safety record, and it compares very well with the nuclear community internationally. I can say that because, as my accent would let you detect, I started my 40-year career in this industry in a different place, so I know what U.K. standards look like, I know what U.S. standards look like, and I know what Canadian standards look like. So I'm able to give some degree of objectivity to how the Canadian nuclear industry compares with others.
On slide 3, we're trying to give a principle here. As I said, I'm not trying to talk about the half life of radioactive isotopes, because, as was just pointed out, I can tell you the difference between heavy and light water reactors too and eat up an entire hour of this committee hearing. This can be a very complicated subject, or it can be a simple subject based on good practice and principles.
This diagram here we call “The Right Thing to Do”, but this is not a Bruce Power diagram. This comes from international standards and procedures. This is the internationally accepted mandate that all of us have to minimize our environmental footprint. It's true in domestic waste today where we consider what our standards looked like 20 years ago when we did not segregate our domestic waste, and look at where we are today: we separate plastics, we recycle, we turn plastic water bottles into chairs. We do many things to reduce our environmental footprint. No surprise then that the same obligation is placed on the nuclear industry.
As we continue to evolve our thinking, we all have an obligation to reduce our environmental footprint. So when we talked about the possibility of storing these steam generators--and to answer the question someone will ask, if we refurbish all these units on our site, there will be 64 steam generators: eight times eight. We've done two, so that gives us 16 steam generators.
Our intention would be to refurbish all of these units as part of Ontario's long-term energy plan. A critical part of securing the extra life will involve replacing all 64 steam generators over the next 20 years.
Clearly one of the issues we have is whether it is environmentally responsible. Is it the best option we can think of to build 64 buildings, which look very similar to the size of this room, for the sole purpose of storing these steam generators? For within that environment, we are more than aware that there are four grams of radioactive isotope material inside a 100-tonne vessel, which has to be secured and looked after for a very long time.
That was the option open to us. That was the bounding option and our planning assumption for environmental assessment.
But none of us can be satisfied that's the best we can do. As we looked to international practice, we saw a number of utilities facing the same timetable as us, the same requirement to replace many of their aging components. And we started to see a change occur. Rather than store things for the long term, people developed techniques and strategies and approaches.
In fact, Studsvik is a world leader in this, both in their place in Sweden and also in the U.S., where they're going through a very sound environmental practice. As we look at that, this is not about commercial gain; it's about the right thing to do.
Would I like this facility to be right next door? Sure, I would. But that's not the case. It's a unique facility, created for a special purpose, to manage a high volume of these sorts of activities. When we understood exactly what their process looked like—we saw their international standards and the regulations they operate in—it became a credible option for us.
The next thing we had to do was consider how we move these steam generators from their place on Lake Huron to the facility in Sweden. How do we do it safely and responsibly? It was mentioned previously that the regulations are mature in this regard; they're not new regulations created for this purpose. They are regulations that have been in place for a very long time. They are tested regularly, and they are enacted and enforced regularly.
The difference, of course, in this situation is that we cannot fit steam generators into the standard packaging. This has been said already here today, and it was clear in the regulatory hearings. Were it possible to fit a slab steam generator in an approved standard package, that would have occurred and it would have gone. Actually for Bruce Power, the same activities that we undertook would also have occurred.
Moving large components in our community creates the risk of distorting traffic flow and affecting a small rural community. When we embarked on this project, we treated that as being the issue. That was the disruption we were going to create in our community. We treated it in the same way when we moved the new steam generators in. The reason for that was because we were already comfortable that the radioactive nuclides met all of the regulatory standards.
Of course, when you begin that consultation, you run the risk of attracting other attention, for different reasons and different intent. I can tell this committee that our purpose was to look at this triangle of environmental footprint and try to move up the pyramid. That's the right thing to do.
When I talk about our activities, I can say we're obviously not at all immune to the public sentiment. We're not idiots. We know what's happening. We can see a number of important things. Firstly, very responsible elected officials are expressing concern, which is entirely what they're elected to do. It's not just in this room but in every municipality along the route. I have no problem with that—none whatsoever. The problem we do have, and the problem we have run into, is that it's always easier to alarm than it is to inform.
We have tried manfully to inform. We have issued documents like this: “The Right Thing To Do”. We've explained exactly what we do. We have set up websites. We've had mailshots. We've held open house meetings. We have tried our best to deal with those issues. I don't suggest for a moment that we can be everywhere and we can convince every person. I've been in the industry a long time, and I never expect unanimous consent. It will never happen.
The question we have to answer is whether we have done all that's reasonable given the actual intent of our activity.
As I say, if you start on the basis that this is a low-level radioactive activity with marginal risk, then the amount of consultation is affected by that. We have gone far and beyond that as an attempted response to the sentiment.
As I say, I fully understand. Some very well-regarded public figures have expressed concern. I get that. I do understand that. But I would hope—it's always been my hope—that Canadians have comfort in the strong regulatory body that exists. Just because the CNSC agrees with us doesn't mean I've got my hand up their back. It's never been the case, and it never will be the case. A good licensee always needs a strong regulator. It's always been so. It gives the public confidence. It gives us the confidence that we know where the benchmarks are. Good regulations do that for us.
As I say, I can talk at length about the half-life of isotopes, but I don't think I'd be doing a service to the committee. All of those things were fully dealt with in a commission hearing.
I'm very open to answering any questions and concerns that people have. If you want to talk about the science, we can do that too.
I want to reassure you that the basis of what we're doing is grounded in good environmental policy. You could not enact good environmental policy while putting Canadians at risk in the process.
We have reassured ourselves of our ability to seal these steam generators, to characterize them, to transport them, and to deal with them in a responsible way. That's what I believe we were tested on in the regulatory proceedings. I believe we passed that test.
Thank you.
:
There are probably three questions in there—
Hon. Denis Coderre: You can do it, I'm sure.
Mr. Duncan Hawthorne: —so let me start with the first one.
We did consult, but it was against a framework, as I said earlier, of what we intended to do. Later this commission will hear from mayors in the municipality of our facility, and those people were consulted through many of our normal activities. We went to county council. We explained what we're doing. We asked for advice from their roads engineers in terms of what the best route might be. We asked for assistance in terms of picking the right time that would be of least disruption—and this is really for road transport. You have to remember that we are all engineers and scientists, so we look at this as good science. We meet all the regulatory standards, but we don't want to disrupt our communities. We consult with them more about the movement of large loads through their community. That was the nature of our consultation. I'm sure the mayors themselves will establish that.
Once it became obvious, however, that there were concerns about the shipment itself and the seagoing part of it, then we started to recognize there was a broader communication challenge for us. Frankly, we believed that much of that communication challenge would be met by the pretty unusual, I should say, CNSC one-day hearing, because that wouldn't have been typical either. The nature of the package would have required the signature from a designated officer. I'm not sure that came across particularly in Dr. Binder's presentation, but had it not been for your public sentiment and other things, there would never have been a one-day hearing, which became a two-day hearing. And really, that was in response to this public concern and anxiety, and as I said earlier, I understand that.
You know, we sought to go out and engage people, and the way we did that is we used polling; we did our website. Latterly, to be honest, we used someone who has a better French accent than me and my chief nuclear officer, Norm Sawyer, to go and speak to French-speaking people so that he could explain in a better manner than I could exactly what we're all about. Did we go everywhere? No, we didn't.
In terms of our facility locally, one of the things you have to recognize is there are two groups at work here. Firstly, we don't have enough business in ourselves to create a facility that would manage this, because although you see these large units, there isn't a lot of activity to be dealt with. It's a small amount of work, so it wouldn't be reasonable for someone to set up a business to do that.
Secondly, you're actually not taking the benefit of all of the best practice and industry experience. There is a facility in Sweden that has actually done this for lots of different types of steam generators. It has developed an expertise. So to start again from the beginning would ignore all of that added value.
For those reasons we chose to do this.