Waterkeeper's submission to participate in Darlington's relicensing process

The Darlington Nuclear Generating Station on the shores of Lake Ontario. (Photo via Greenpeace Canada)

On September 28, 2015, Lake Ontario Waterkeeper submitted a request to intervene during the Day 2 Relicensing Hearing for the Darlington Nuclear Generating Station (DNGS). You can see our entire submission below, but here is a quick summary of our main findings:

1. The Darlington nuclear station kills a lot of fish  

Darlington uses vast quantities of water from Lake Ontario to keep its reactors cool. Essentially, it works like this: there is a giant pipe on the bottom of Lake Ontario that sucks in water, draws the water into the station, passes through the reactors, and discharges the water back into the lake.

There are large screens that cover the intake pipe. As water is sucked in, fish are killed because the current crushes them against the screens. In 2011, Darlington killed almost 275,000 fish in this manner. Fish eggs and larvae are too tiny to be caught by the screens so they are sucked into the pipe and pass through the reactors. Most of the eggs and larvae sucked into the pipe die as they pass through the reactors (due to turbulence and heat). Each year millions of eggs and larvae are killed in this manner.

For more info on Darlington’s fish kills, see pages 17-20 of our submission below.

2. The DNGS does not comply with the Fisheries Act

The Darlington plant has failed to comply with the Fisheries Act since it began operating in the early 90s. In June 2015, Darlington received permission from Fisheries and Oceans Canada to kill a certain quantity of fish each year. The idea was to make sure that Darlington started complying with the Fisheries Act. However, by Ontario Power Generation’s own estimates (OPG owns Darlington), they may kill up to 10 times the quantity of fish they are allowed to. In other words, Darlington continues to violate the Fisheries Act.

For more info on DNGS not complying with the Fisheries Act, see pages 22-30 of our submission.

3. The DNGS does a poor job reporting the impact it has on Lake Ontario

Darlington only reports the number of fish the plant kills every couple years. OPG has asked that in the future they only be required to report how many fish Darlington kills once or twice per decade.

Monitoring the number and type of fish that are killed is really important. Lake Ontario is changing and it is important for the public (and future decision makers) to know what toll Darlington takes on the the lake. If there is no regular monitoring, we won’t know how many fish Darlington kills. Nor will we know whether Darlington continues to kill endangered species, like the American eel.

For more info on DNGS’s poor reporting, see pages 30-32 of our submission.

4. Darlington’s stormwater runoff is polluted

Stormwater can dissolve contaminants that are on the ground and whisk them away into nearby lakes or streams. The rainwater that falls on the Darlington site is collected in ditches and channels that empty into Lake Ontario. It is not treated.

In Ontario, the government has set water quality targets that are call Provincial Water Quality Guidelines (PWQOs). These guidelines are not legally binding, but they are important because they are intended to protect human and aquatic health. In 2010/2011, stormwater samples taken from Darlington exceeded PWQOs for boron, iron, cadmium, copper, hexavalent chromium, lead, molybdenum, toluene, vanadium, and zinc on one or more occasions.

For more info on Darlington’s stormwater runoff, see pages 33-37 of our submission.

5. Stormwater runoff from the DNGS is not regularly monitored

Even though the stormwater that runs off of the Darlington site into Lake Ontario can be highly polluted, it is not regularly monitored. Based on documents submitted to the CNSC, it appears as though over the past two decades stormwater at Darlington was only monitored in 1996, 2001 and 2010.

For more info Darlington monitoring its stormwater runoff, see page 36 of our submission.

Waterkeeper’s Recommendations

The Canadian Nuclear Safety Committee (CNSC) is in the process of deciding whether or not to relicense Darlington. OPG would like the CNSC to issue a 13 year license that would also allow Darlington to refurbish its four reactors so the plant can operate until 2055.

Based on the findings above, Waterkeeper does not think a 13 year license is appropriate. We also believe that before OPG asks to refurbish Darlington, it should address the issues we’ve highlighted.

We have recommended that if the CNSC does relicense Darlington, it should be for one year at most. One year would give Darlington time to:

• Figure out how to comply with the Fisheries Act;
• Research options for reducing the number of fish it kills;
• Start monitoring the number of fish it kills; and,
• Start monitoring the stormwater that is being released directly into Lake Ontario.

Waterkeeper will present our recommendations to the CNSC during the Day 2 hearing, which will be take place from November 2nd-5th. If you’re interested in learning more about our submission, you can look through it below.

Download Waterkeeper’s submission without appendices (2.7 Mb)

Download Waterkeeper’s submission with appendices (7.8 Mb)

Submission by Lake Ontario Waterkeeper for the Darlington Nuclear Relicensing Day 2 Hearing from LOWaterkeeper