Presentation to the Canadian Nuclear Safety Commission, Darlington Refurbishment Hearings

Good afternoon Members of the Commission; Mr Chair.
My name is Mike Schreiner, I’m leader of the Green Party of Ontario.
I appreciate the opportunity to express my concerns with Ontario Power Generation’s (OPG) plans to refurbish and keep the Darlington nuclear reactors running until 2055.
I believe the Environmental Assessment report has failed to properly address a number of concerns regarding the risks of continued operation of the Darlington nuclear station. I do not believe that approvals for the refurbishment of Darlington should be granted until these concerns are satisfactorily addressed.
1. My first concern is with risks associated with Public Safety and short and long-term Environmental Damage 
I am deeply concerned that OPG has inadequate plans in place to protect human health or the environment.
Significant nuclear accidents are happening around the world about once per decade. It is essential that Canada require the highest level of risk assessment and safety protocols, especially since reviews of nuclear accidents at Three Mile Island, Chernobyl and Fukushima demonstrate that institutional failures and human error are contributing factors. 
OPG’s Darlington Nuclear Generating Station Risk (DNGS) Summary Report indicates that accidents involving large radiation releases are a realistic, though remote, possibility. 
Given the catastrophic risks associated with nuclear accidents, especially on the doorstep of Canada’s most populated region and on the shores of Lake Ontario, I am deeply concerned about insufficient emergency planning procedures at Darlington. 
It is irresponsible and unacceptable that the worst-case accident examined by OPG in its application for the overhaul would involve a release of radiation traveling about three kilometres from the plant.  History demonstrates that this is insufficient and puts the public at risk. 
Governments must act to ensure that public safety is a top priority. A more thorough and rigorous analysis of risks and emergency planning should take place before proceeding with any approvals for Darlington. 
Further complicating this issue is that OPG is not held financially accountable for the full cost of a nuclear disaster. 
The Nuclear Liability Act (NLA), means that in the event of an accident OPG would not pay more than $75 million for environmental clean-up or victim compensation. 
Failure to hold the nuclear industry accountable for risks misrepresents the economics of nuclear power and is a disincentive to creating rigorous risk avoidance policies.  
Before OPG is allowed to proceed with their proposal to rebuild Darlington, OPG and its suppliers should assume full financial responsibility for accidents and mistakes.
In addition to taking action to protect the public from disasters, OPG must also take steps to mitigate environmental damage from the ongoing operations of Darlington.
Darlington uses Lake Ontario as a source of cooling water and a dump for its waste water. It is also a major source of thermal and chemical pollution in the lake. This causes significant harm to aquatic ecosystems, killing millions of fish and damaging fish habitat.
Before receiving any approvals to proceed, OPG must have plans in place to mitigate thermal and chemical pollution, fish kills and storm water discharge in Lake Ontario. 
Additional public safety and environmental risks exist because the nuclear industry has not finalized a comprehensive plan for dealing with nuclear waste. Meanwhile, the amount of dangerous nuclear waste continues to grow. OPG is unfairly placing the burden to monitor this waste on future generations. 
As the risks and costs associated with waste management and decommissioning skyrocket, it is unacceptable and irresponsible to grant approvals to proceed with refurbishment until proper storage and decommissioning plans are in place.
2. My second concern is with Financial Risk.
No nuclear project in Ontario’s history has come in on budget or on time. The existing Darlington reactors were supposed to cost $4 billion, but came in $10 billion over budget.
In 2007 the Ontario Power Authority said it would cost $6 billion to build two new reactors at Darlington. The McGuinty government suspended the purchase of new reactors in 2009 when the cost estimates came in at $20 billion more than the original estimate.
I realize today’s hearing are about refurbishment, not new build. However, the financial record for refurbishment is just as bad.
The recent refurbishment at Bruce nuclear is at least $2 billion over budget and 3 years behind schedule.
The estimated cost of rebuilding CANDU reactors has ballooned over the past decade from approximately $800 million per reactor in 2002 to $2.5 billion per reactor today. 
Ontario rate payers are still paying for the debt associated with previous nuclear projects. It is unacceptable and irresponsible that the Ontario government has no plans in place to protect ratepayers or taxpayers from further nuclear cost overruns, including overruns associated with this project.
It is inconceivable that the Ontario government has not conducted an independent review of nuclear costs. The cost estimate to refurbish Darlington vary widely from $8 to $14 billion. 
Just last week Standard and Poor Rating Service’s downgraded OPG’s credit rating from to stable to negative. In part because of the risk of cost overruns due to the Darlington refurbishment.
Approvals for Darlington should not be granted before a transparent and independent review of costs takes place.
3. My third concern is the failure to Mitigate Safety, Environmental and Financial Risks by Examining Alternatives
It is irresponsible to proceed with the Darlington Refurbishment until a thorough review of alternative solutions takes place.  It is inconceivable that over the past 7 years the Ontario government has prevented any public reviews of the need for, or alternatives to, nuclear power at Darlington.
This project fails to consider that the cheapest and greenest source of electricity is the power that we don’t use in the first place. Although Ontarians have done a good job of reducing total electricity consumption by 10% since 2005, our electricity consumption per person is still 27% greater than in New York State. Ontario still has huge untapped energy efficiency potential. 
Estimates are that we can retrofit 2.3 million homes in Ontario to save the same amount of energy that Darlington would produce — at half the cost.
Alternative sources of generation exist.  Made-in-Ontario water power, wind power and bio-energy are all lower cost and lower risk sources of electricity than re-building Darlington. 
The cost of importing water power from Quebec is less than one-third of the cost of the proposed Darlington Re-Build. Power from Quebec can replace more than 75% of the electricity coming from Darlington using existing transmission lines. 
Nor has the government considered the economic implications that the Darlington refurbishment will have on job creation and business development in new and emerging sectors.
This project will effectively nuke Ontario’s emerging renewable energy industry by removing grid capacity for new renewables.
The city of Guelph alone has 60 MW of renewable energy applications awaiting approval by the Ontario Power Authority. This is just the tip of the ice berg of what’s possible if we empower communities to generate electricity and jobs, instead of proceeding with mega projects, that have mega risk, requiring mega capital costs, and generating mega amounts of waste.
The responsible course of action is for the Ontario government to conduct a thorough review of safer, cheaper and cleaner alternatives before proceeding with the Darlington refurbishment.
In Conclusion,
I am deeply concerned with OPG’s plans to refurbish the Darlington nuclear reactors. 
The risks and costs of nuclear are too high to justify.  
More affordable, reliable and safer alternatives exist. The Darlington refurbishment should be halted until the need for, alternatives to, and public safety and environmental effects of nuclear are fully and independently considered. 
Thank you for your time and consideration.