Waterkeeper is a grassroots environmental charity that uses research, education, and legal tools to protect and restore a swimmable, drinkable, fishable Lake Ontario. Waterkeeper has extensive experience working on issues related to the nuclear industry. We have worked in and around the Pickering community for more than eleven years, and have knowledge of the local environmental, social, and cultural matters related to the Commission’s licensing decision. Waterkeeper has presented our research findings to the Commission on a number of occasions in writing and in person, including with respect to the Pickering A and B NGS, Cameco’s Port Hope operations, and nuclear waste management at Port Granby and Welcome. We were a funded participant in the Darlington New Build Environmental Assessment [EA] and the Darlington Refurbishment EA.
Waterkeeper’s concerns with the licensing of Pickering NGS focus on the plant’s impacts on the integrity of Lake Ontario as aquatic and fish habitat, a place for recreation, and a source of drinking water for millions of people. Our specific concerns are summarized in the attached comment and will be presented by our Counsel, Joanna Bull, to the Commission on May 29, 2013.
The most signiﬁcant adverse impacts of the Pickering NGS on Lake Ontario are directly related to operating the reactors: ﬁsh are killed by the cooling water system and
contaminants (including thermal and chemical pollution) are discharged with cooling water.
The CNSC should not issue a licence to OPG unless these impacts will be addressed without delay, so as to minimize the harmful effects of the plant over its remaining seven years of life. The signiﬁcance of these impacts is currently being downplayed because the remaining life of the plant is short relative to its entire lifespan, but operating Pickering NGS for seven more years without additional ﬁsh kill mitigation will result in the entrainment death of approximately 434 million ﬁsh eggs and larvae, and the impingement death of approximately 1.12 million ﬁsh.
Accordingly, Waterkeeper makes the following recommendations:
OPG should make emissions data available to the public in a timely and accessible manner.
OPG should be required to keep its ﬁsh barrier net in place year round.
OPG should be required to meet the feasible targets for reducing entrainment set by the CNSC in 2008. Short of meeting this feasible target, the plant should be required to cease operations prior to 2020 to avoid killing millions of ﬁsh eggs and larvae.
OPG should be required to address the aquatic impacts of operating Pickering NGS rather than wait out the remaining years of the plant’s life.
For more information, please read Waterkeeper's official submission.