Mémoire présenté lors de l’audience de la commission d’examen conjoint sur le projet de stockage dans des couches géologiques profondes d’Ontario Power Generation

Mémoire présenté par Peter Poruks, responsable des affaires réglementaires, Association nucléaire canadienne
lors de l’audience de la commission d’examen conjoint sur le projet de stockage dans des couches géologiques profondes d’Ontario Power Generation
le 12 septembre 2014

Good afternoon, panel members and members of the public.

My name is Peter Poruks.  I am the Manager of Regulatory Affairs of the Canadian Nuclear Association.  My colleague is Malcolm Bernard, Director of Communications for the CNA.

We are here to speak with you on behalf of the 60,000 Canadians who work directly or indirectly in the nuclear industry.  These men and women mine and mill uranium, manufacture fuel, design and build nuclear reactors, generate clean electricity, and advance medicine through life saving diagnostics and therapies.

We appeared before this panel last September to express our confidence in OPG’s proposal, and the extensive safety case that has been put forward.  This detailed document is the outcome of many specialists from a wide variety of disciplines.  It was reviewed in detail by Canadian Nuclear Safety Commission staff and experts from other independent regulatory bodies.

Today I wish to provide clarifying information on two subjects that are part of these focused additional hearings.  First, I will speak to the methodology used to determine the significance of adverse environmental effects. Second, I will address the analysis of the relative risks of alternate means of carrying out this project.

I would like to begin by considering the assessment for adverse environmental effects.

The central issue is risk management: Has OPG identified and assessed the risks associated with this project? As well, has OPG sufficiently provided for their mitigation?

Clearly, if the DGR poses an unacceptable risk, it should not proceed.

That test applies not just to the DGR, but also the entire Canadian nuclear industry. Our member organizations, their employees and suppliers, have all placed safety above any other aspect of decision-making. All of us understand an unsafe opportunity must not be pursued.

At the same time, if it can be shown that all of the risks have been properly identified and assessed, and that their probability of occurrence is sufficiently low, then an opportunity should not be denied. And if it offers benefits, then it should proceed.

In the case of the DGR, OPG used what it considered to be the best analytical approach – a decision-tree model. For each criterion set out in the guidelines to environmental impact statements, OPG evaluated the consequences of its decisions as well as their probability of occurrence. It concluded that the DGR was not likely to cause significant adverse environmental effects.

In order to underpin the safety case with even more rigour, two other approaches were used. In both these approaches, evaluators reached the same conclusions as OPG.

The Canadian Nuclear Safety Commission used a weight-of-evidence approach to look at all criteria collectively. This rigorous scientific approach has been used in the analysis of many major environmental issues over the past several decades. It led the CNSC to the same conclusion as OPG – that this project is not likely to cause significant adverse environmental effects.

Madam Chair, these varied approaches have reached the same conclusion: this project is not likely to cause significant adverse environmental effects.

Moreover, objective parties have gone over the analytical work in these assessments. Three federal departments and the independent nuclear regulator have all reviewed OPG’s work and shared in its conclusion – that this project is not likely to cause significant adverse environmental effects.

To put it into simple terms: if we did math by just counting on our fingers, we’d reach a result. We might believe it to be accurate, or we might not. If we do the same math again using a calculator, we should have more confidence in the result. If we plug all the numbers into a computer spreadsheet, again reaching the same result, our confidence should rise even further. And, anyone could look over our work and verify that it has been done properly.

That is exactly what is happening here. Different analytical approaches, independently verifiable, have reached the same result.

OPG has more than satisfied the need to assess properly the risks posed by the DGR.

Now, let me take up the other matter that brings me here today – the relative risk assessment of four waste-management options.

Of these options, two require storage above ground, and two below ground. As the review by a panel of independent experts has shown, all four options can be carried out safely and securely. They differ in the burden that our generation would transfer to our children and their descendants.

The options for above-ground storage would rely on on-going institutional controls and intervention.  This would include activities such as regular maintenance of the buildings, environmental monitoring, and regular testing of fire and security alarms. In contrast, the options for below-ground storage do not include these on-going active management responsibilities.

As we see in the environmental assessment, all four options result in safe and secure storage. Any one of them would do. Thus assured on safety, we can turn to the next question, which is whether storage above ground is the better choice.

The answer finds its roots in our sense of moral responsibility. Our generation benefitted from the use of nuclear-generated electricity. Nuclear energy gives us a safe, reliable and affordable source of electricity – the bedrock of a modern economy. It provides stable, durable employment for thousands of Ontario residents. And nuclear energy gives us clean electricity that is entirely free of carbon dioxide and other greenhouse gases.

While we have enjoyed the benefits of nuclear energy, we also bear responsibility for the waste. Whether we should manage this responsibility ourselves, or transfer it to future generations, is a central question.

Responsibility rests with us, not our grandchildren. The Deep Geologic Repository provides a way to manage our responsibility safely and securely.

Madam Chair, let me sum up by saying that Ontario Power Generation has safely managed these low- and intermediate-level waste materials for years. We can all be confident that it will continue to do so for as long as it is required.

In seeking to construct and operate a Deep Geologic Repository, OPG, with the support of the surrounding community, has proposed a permanent management solution for these materials.  This speaks to the proactive and responsible environmental management to which all members of the Canadian Nuclear Association are committed.

The careful consideration of the environmental and alternative means assessment methodologies reinforces our confidence. The application of such transparent, defensible and repeatable methodologies should provide the public with sufficient reassurance to allow OPG to proceed.

Thank you for considering our submission. I would be pleased to take questions.