Policy and Political Action

Policy & Political Action

RNAO Submission to the Canadian Nuclear Safety Commission on the Application to Renew the License of the Pickering Nuclear Generating Station

Good morning President Binder and members of the commission. My name is Beatriz Jackson, and I am a board member of the Registered Nurses' Association of Ontario (RNAO). I represent RNAO's Region eight, an area that includes Durham Northumberland and the nuclear reactors at Pickering and Darlington. I have lived in Pickering for 22 years now, just 10 kilometers from the nuclear plant. With me today are Susan Munro, representing RNAO's Ontario Nurses for the Environment Interest Group, and Kim Jarvi, RNAO's Senior Economist.

We thank the Canadian Nuclear Safety Commission for this opportunity to respond to the renewal application for the Pickering Nuclear Generating Station's operating licence. The issue of nuclear power matters a great deal to nurses because of its potential health implications and because nurses would be heavily involved in any disaster responses. RNAO is here to speak to the commission's mandate to regulate the nuclear industry to prevent unreasonable risk to the environment and to human health.

We urge the commission to adopt a precautionary approach that prioritizes human health and public safety.

A precautionary approach is warranted because the Pickering nuclear plant is just five km east of Toronto. If there was a major accident, evacuating an area of 20 kilometres around the Pickering plant would affect 1.3 million people. And if you extended that evacuation zone to 30 kilometres, 2.2 million residents in the Greater Toronto Area would be affected.

To put this into perspective, there were only 160,000 people evacuated as a result of Japan's Fukushima disaster, even though there was a 20 km evacuation order and voluntary evacuation in the area 20-30 km from the plant. To offer further perspective, the Chernobyl Exclusion Zone covers about 2,600 square kilometers – over four times the area of the city of Toronto.

As the GTA population continues to grow, so too will the numbers of people at risk in the event of a nuclear accident. We know the risk of nuclear accidents is not zero: there are only about 450 operable nuclear reactors in the world, and already one blew up in Chernobyl and three reactors sustained major damage at Fukushima. There have been a number of other partial meltdowns.

The effects of an accident extend far beyond the immediate and long-term effects of exposures to radiation. The World Nuclear Association cited over 1,000 deaths directly attributable to the inadequately planned evacuation around Fukushima, particularly for vulnerable communities. Within 30 km of Pickering, there are about 22 hospitals with 7,399 beds, and 82 nursing or retirement homes with 9,368 beds. In Ontario, there are approximately 30,000 hospital beds. In area of 30 km, over 7000 beds is equal to almost one fourth or a quarter of all Ontario beds. So if we take 7000 beds out of circulation, and need then to accommodate 7000 displaced patients, up to one half of patients could need to be displaced. Where and how? Excellent disaster planning is essential and will greatly reduce the risk of illness and death from evacuation, but it cannot eliminate it.

Furthermore, a major Pickering release could compromise the drinking water from Lake Ontario – and that is the source of drinking water for almost half of all Ontarians alone, not to mention for many residents of New York State.

Finally, a major release would contaminate hundreds of square kilometers of this densely populated area and would cause huge economic cost and dislocation for decades or longer. That will have enormous health consequences.

When weighing the renewal of the Pickering licence, the following must be considered:

  • the risks of a disaster at an aging nuclear plant are not diminishing,
  • Pickering continues to produce nuclear waste, which must be stored in perpetuity
  • In 1971, the Pickering station was designed to last until 2001 and is far past its designed life span,
  • Ontario has surplus generation capacity which leads to curtailment of wind generation, and finally,
  • as the Environmental Commissioner of Ontario noted, the province largely abandoned renewable energy options in favour of nuclear power without any apparent long-run cost advantage,

RNAO questions whether the power from Pickering is even necessary, and if so, whether some or all of it is necessary until 2024.

We ask whether Pickering power generation can be justified on an economic basis, when one includes the costs of maintenance and repair, and of adequate nuclear emergency preparedness. There are renewable and conservation alternatives, as the Environmental Commissioner noted. Most importantly, we ask whether it makes sense to continue to operate an aging nuclear plant adjacent to a large and growing population, when the expiry of the current, much-extended licence would solve that problem. RNAO urges a precautionary, health-based approach to the commission review.

With the health of so many people at stake, and having witnessed how wrong things can go when accidents happen as they did at Chernobyl and Fukushima, a precautionary approach to emergency preparedness is also a must as long as Ontario continues to operate nuclear reactors. Nurses want to know the system is fully prepared in the event of a disaster, because we would play leading roles in any disaster response. RNAO welcomes Toronto's requests to the province of Ontario and to the commission to strengthen Ontario's nuclear emergency preparedness. RNAO calls on the commission to use any tools at its disposal to ensure that, for all nuclear power plants in Canada, all emergency preparedness measures are world class and are designed to meet the need imposed by a Fukushima-scale disaster. It will be very important to include RNs and nurse practitioners in that planning process.

In summary, we are not persuaded that extending the licence is the most cost-effective way of meeting Ontario's electrical power needs, and a precautionary approach to health leads us, in the interests of preventing unreasonable risk, to advise against extending the operating licence beyond what is necessary to safely decommission the plant. As Fukushima and Chernobyl have shown, nuclear power is an unforgiving technology. But so long as any nuclear power plants continue to operate in Ontario or elsewhere Canada, we urge the commission to ensure that all nuclear emergency preparedness measures are designed to deal with major disasters. This should include imposing licence conditions on Ontario Power Generation to address inadequacies in Ontario's nuclear emergency response plans. The detailed recommendations numbers 13 through 31 to the commission on emergency preparedness from the Canadian Environmental Law Association provide the kind of precautionary approach we seek. Those recommendations include: comprehensive planning in greatly expand nuclear emergency zones to respond to major radiation releases; ensuring protection of vulnerable populations, which would include predistribution of KI pills to guarantee quick access; and public awareness campaigns to support the above measures.

Thank you for this opportunity to present the concerns of Ontario's RNs, NPs and nursing students. We would be pleased to answer any questions.

Resource Type: 
Speaking Notes