Policy and Political Action

Policy & Political Action

RNAO’s submission to the Canadian Nuclear Safety Commission

RNAO is pleased to respond to the consultation by the Canadian Nuclear Safety Commission (CNSC) on the draft terms of reference of its Potassium Iodide (KI) Pill Working Group. RNAO welcomes the commitment to form a working group to "provide clarity on the existing plans and associated responsible authorities to distribute KI Pills (in the Ingestion Planning Zone, within a 50-km radius) in the event of an emergency at the Pickering Nuclear Generating Station."

To be clear, RNAO opposed keeping the Pickering plant open on health and cost grounds. But so long as the plant remains open, Ontario Power Generation (OPG) must prepare against the possibility of a disaster similar to the one that happened at Fukushima in Japan. The CNSC has identified distribution of KI pills within a 50-km radius as one such prudent measure in its written decision on the Pickering nuclear licence renewal application: "The Commission directs that a KI working group between CNSC staff, OPG, the OFMEM [Ontario Officer of the Fire Marshal and Emergency Management], the MOHLTC [Ontario Ministry of Health and Long-Term Care], other stakeholders, and which would allow for the participation of intervenors in these proceedings, be established as soon as practicable. The Commission is of the view that this working group should establish clear and detailed plans for the distribution of KI pills throughout the IPZ [Ingestion Planning Zone – a 50-km radius around the plant] in the event of an emergency at the PNGS [Pickering Nuclear Generating Station]."

While KI pills only protect the thyroid gland against radioactive iodine releases (and not against other radioactive isotopes), this is still an important precaution to take. The pills must be taken before or soon after exposure to offer protection, so they must be pre-distributed within the Ingestion Planning Zone. Particular attention must be paid to ensuring access for the most vulnerable populations, including children, youth and pregnant women.

The language on the need to adequately prepare in the event of a nuclear emergency is appropriately very strong in the CNSC Record of Decision on the Pickering Nuclear licence renewal application.

RNAO believes that the terms of reference for the KI Pill Working Group must be strengthened to reflect that unambiguous language.

Recommendation 1:
Rewrite the first sentence of the mandate to mirror the language in the CNSC Record of Decision:
"The mandate of the CNSC Potassium Iodide (KI) Pill Working Group (the Working Group) is to establish clear and detailed plans for the distribution of KI pills throughout the Ingestion Planning Zone."

Recommendation 2:
Include in the mandate section (1.) and the deliverables section (4.) acknowledgement of the CNSC directive to the KI Working Group to examine the feasibility of pre-distribution of KP pills to all schools within the Ingestion Planning Zone.

Recommendation 3:
Include in the mandate section (1.) and deliverables section (4.) the expectation that the KI Working Group develop credible plans on how KI pills are to be delivered in a timely way to all vulnerable communities, including pre-school children and pregnant women.

Recommendation 4:
Include in the mandate section (1.) and deliverables section (4.) acknowledgement of the CNSC advice to the KI Working Group to expand nuclear emergency awareness activities throughout the IPZ.

Recommendation 5:
Modify the terms of reference to allow representatives from health and civil society groups (including nurses) to make submissions and to participate in the KI Working Group.

Recommendation 6:
Include in the terms of reference a paragraph on transparency and accountability. The minutes of the KI Working Group must be publicly available, as must any submissions received and any analysis or studies the Working Group relies on.

Resource Type: 
Submission