Indeed, it was the reactivation of six CANDU reactors that provided 90% of the ultra low emissions power needed to phase out coal from our grid. This has been called the greatest greenhouse gas reduction measure in North America. Ontario’s electricity emissions dropped by 80% compared to 2005, and smog days declined from 53 in 2005 to zero in 2014 thanks to nuclear.

The great tragedy for Jack Gibbons and the Ontario Clean Air Alliance (OCAA), which received substantial donations from Enbridge and Union gas in the early 2000’s, seems to be that the coal phaseout was accomplished with nuclear instead of natural gas.

As the chairman of the OCAA, Jack Gibbons has taken some positions that seem contrary to the stated goal of his organization. For example, the OCAA lobbied for natural gas as the “transition fuel” to replace coal. When residents of Oakville protested natural gas plants being built in their backyards, Gibbons, the champion of clean air, gaslighted them. He explained that “Exhaust stacks are typically high enough to disperse pollutants beyond the immediate area and it makes sense to generate power as close as possible to where it is consumed.”

Since winning their battle against coal, the OCAA has turned its sights on nuclear energy in Ontario. They argue that it should be replaced by wind, solar, and hydroelectricity from Quebec. Beyond the lunacy of making our province dependent on the whims of Quebec, there simply isn’t enough power in Quebec during the winter months. Quebec heats with electricity and routinely imports Ontario electricity during its cold snaps to stay warm.

Gibbons argues that costs for wind and solar are outcompeting natural gas. It seems that he doesn’t know Jack about the grid. Solar in Ontario produces about 15% of the time, wind 30%. Both are out of sync with our peak summer air conditioning season. They produce erratically at the whim of mother nature and as a result require natural gas backup, which dramatically increases their emissions profile.

We are in agreement on one point Jack Gibbons makes. SMRs and advanced nuclear, while vitally important for decarbonizing smaller sized grids in Canada, and providing emissions free process heat to industry, are too small and too far off to achieve net zero emissions on a meaningful timescale alone. Thankfully we have a readily available solution to fill that gap!

Ontario has existing, extremely well functioning, large modular reactors. We have CANDUs, like those at Pickering whose 3 billion watt output produces enough energy to power the city of Toronto. We are doing the right thing by refurbishing our CANDU fleet at Darlington and Bruce. Unfortunately, refurbishment plans for Pickering have been sidelined and it is now scheduled to be closed in 2024.

Gibbons wants to blanket Ontario with tens of thousands of industrial wind turbines and millions of solar panels, and rely on Quebec to attempt to fill in the resulting daily and seasonal gaps in electricity.

We want the Ontario government to commit to maintaining and refurbishing Pickering Nuclear. To anyone genuinely concerned about clean air and the climate, it should come as a tragedy that its output will otherwise be replaced with natural gas.

According to the Ontario Chamber of Commerce, 7590 direct and indirect jobs providing $747 million in wages are at stake if we let Pickering close.The CANDU supply chain and its highly skilled workforce is 95% based in Ontario. Every dollar spent on Pickering’s refurbishment stays in Ontario, providing us with the dignified high paying jobs in science, technology, engineering and the skilled trades that sustain our economy. The same cannot be said for low paying temporary jobs installing “made in China” solar panels.

Refurbishing Pickering has all the ingredients of a truly green recovery. Environmental organizations like the OCAA need to come to terms with the fact that Ontario has some of the cleanest and lowest carbon electricity in the world thanks to nuclear. Let’s keep it that way.

Chris Keefer MD, ER Physician

Christopher Adlam, Network Engineer, IT Director

Jules Besseling, Nuclear Technologist

Steve Aplin, Energy Analyst

Tom Hess, former IESO NERC Certified System Operator

Mohammed Mahdi, Nuclear Engineer

Ike Bottema, Network and IT Consultant

We read with dismay your statement on Small Modular Reactors. We are a group of pro-nuclear environmentalists and labour activists who believe that Nuclear Energy must continue to play a vital role in climate mitigation and should be the backbone of a green recovery in response to the twin challenges of climate change and COVID.

The science is settled. In 2018 the IPCC made it clear that the world will need to dramatically increase our nuclear energy infrastructure to meet our climate goals. All four of the decarbonization pathways examined by the IPCC involve an increase in nuclear power by 98-501% by 2050. Canada is well positioned to be a leader in this field as a pioneer in nuclear energy with our invention of the CANDU reactor, our skilled nuclear workforce and our experienced regulatory agencies.

You claim that the “negative environmental effects of nuclear energy are well documented.” All energy sources come with environmental impacts, however, the secret to the case for nuclear energy’s environmental benefits is in its energy density.

Nuclear fuel contains a million times more energy than its fossil fuel counterparts. As a result nuclear requires only a tiny fraction of the mining, processing and infrastructure compared to every other source of energy including renewables. This energy density also means that the amount of waste created is very small. All of the spent nuclear fuel produced in Canada would fit inside 3 hockey rinks piled up to the boards and has been securely stored without harm to people of the environment.

Nuclear Energy in Canada has also been incredibly effective at displacing fossil fuels from the electricity grid. Just look at Ontario. Nuclear energy provided 90% of the power needed to replace coal in Ontario which has been called the single greatest greenhouse gas reductions measure in North America. This was accomplished by starting up 6 CANDU reactors at the Bruce and Pickering generating stations. Smog days dropped from 53 in 2005 to zero in 2014 at the end of the coal phaseout dramatically improving public health.

It’s time to spread this success story with high emitting provinces like Alberta and Nova Scotia. Small modular reactors in particular will have a vital role to play in decarbonizing grids in less populated provinces and replacing air polluting diesel generation in rural and remote communities as well as sectors like mining.

Beyond ultra low emissions electricity our reactors have played a vital role in fighting the pandemic. Cobalt 60, a medical isotope made in CANDU reactors, has sterilized 24 billion surgical gloves and 40% of the world’s single use surgical instruments in 2020.

Finally nuclear energy provides high paying jobs in science, technology, engineering and the skilled trades to over 60,000 Canadians. From our state of the art uranium mining to the skilled trades people working in our supply chain and nuclear generating stations our nuclear sector is 95% made in Canada.

Canada finds itself at a crossroads as it emerges from the economic devastation of COVID into the ongoing slow motion crisis of climate change. We have a highly effective made in Canada solution with a demonstrated track record of rapid and deep decarbonisation. It’s time to embrace Nuclear energy and SMRs as a vital part of our climate change response.

Sincerely,

Whereas:

• Canada is a party to the Paris Agreement whose goal is to keep global average temperature below 2°C and has agreed to reduce GHG emissions by 30% below 2005 levels by 2030;
• The IPCC in its four decarbonization pathways calls for an increase in nuclear power by 98-501% to meet our climate goals and avoid catastrophic climate impacts;
• Nuclear Energy in Canada has provided the ultra low emissions energy needed to permanently replace fossil generation as in Ontario where the restart of 6 CANDU reactors provided 90% of the power needed to permanently remove coal from the grid; 
• Nuclear Energy is the most environmentally friendly form of energy generation due to the energy density of its uranium fuel which contains a million times more energy than its fossil fuel counterparts and as a result requires only a tiny fraction of the mining, processing and infrastructure compared to every other source of energy including renewables;
• Uranium mining in Canada conforms to the highest environmental and health and safety standards in the world;
• Nuclear is the only form of energy that fully accounts for and contains its waste and that all of the spent nuclear fuel produced in Canada would fit inside 1 hockey rink piled 28 feet or less than 1 telephone pole high; 
• Nuclear Energy in Canada plays a vital role in combating the COVID pandemic by producing the majority of the world’s Cobalt-60 which is used to sterilize 40% of the worlds single-use medical devices including PPE like masks and gloves;
• Nuclear Energy in Canada provides high paying jobs in science, technology, engineering and the skilled trades to over 60,000 Canadians with a supply chain that is 95% made in Canada; 

We, the undersigned, citizens and residents of Canada, call upon the Government of Canada to:

1. Uphold its commitments as a signatory to the Paris Agreement by maintaining and expanding its CANDU nuclear reactor fleet; and

2. Support the export of CANDU technology to aid our allies in their decarbonisation efforts; and

3. Continue to fund research and deployment of small modular nuclear reactors in Canada and abroad.

Canada Written Intervention
Scope of the Environmental Assessment for the Global First Power Micro Modular Reactor (MMR)
June 1^st, 2020

Chris Keefer MD, CCFP-EM
Emergency Physician
Lecturer Department of Family and Community Medicine University of Toronto
Director Doctors for Nuclear Energy
Doctorsfornuclearenergy.org

Chris Keefer, for the record.

I would like to begin by expressing my gratitude to the Canadian Nuclear Safety Commission (CNSC) for the opportunity to provide a written intervention on the scope of the environmental assessment (EA) for the Micro Modular Reactor (MMR) project being proposed by Global First Power (GFP). 

I am a Toronto based Emergency Physician and Simulation Educator and the director of Doctors for Nuclear Energy. We are an international group of physicians from a variety of specialties ranging from Family Practice, Emergency Medicine, Radiology, Radiation Oncology and Molecular Immunology. We advocate for nuclear energy as a vital tool to combat the health impacts of climate change and air pollution. The evidence right here in Ontario clearly demonstrates that nuclear energy can replace fossil fuel sources like coal and dramatically improve air quality which locally has dropped our number of “smog days” from 54 in 2004 to zero in 2014 when the coal phaseout was completed. This was accomplished by bringing online additional reactors from the Bruce and Pickering Nuclear stations. A 2005 study by Ontario’s Ministry of energy estimated that Ontario would annually avoid 25,000 emergency room visits and 20,000 hospital admissions from the phaseout of coal. The clinical experience of myself and my colleagues has borne this out with a marked reduction in severe asthma and emphysema exacerbations over this same period. 

I personally spent 5 years working in the Yukon territory much of it in remote work camps and small outpost communities. These camps were powered by fuel that was flown in on bush planes at enormous carbon and economic cost. There were many leaks of this fuel into the delicate tundra environment. I was also well acquainted with the abysmal air quality of Whitehorse when a move was made towards government subsidy of wood burning. The strong inversions of the Yukon River valley trapped the woodsmoke in the city and made air quality a serious public health concern. 

I am familiar with the unique challenges faced by Northerners when it comes to access to clean, reliable energy. The benefits of the MMR are multiple. It can provide clean, abundant energy for heating, food growing, telecommunications, process heat for mining and energy for all the other modern amenities every Canadian should have access to. There is no reason why Northerners should have a lower quality of life or energy then their southern counterparts. Despite Northern communities being remote places local air quality can be seriously impacted by burning diesel or biomass. This is a very real public health concern particularly as we understand to a greater degree the health impacts of particulate matter 2.5 (PM2.5) air pollution which go far beyond respiratory disease to include cardiovascular disease like heart attacks and stroke. Worldwide the World Health Organization (WHO) estimates that 7 million people die every year from air pollution. Many millions more are sickened or disabled by it. Nuclear energy offers a very real solution. 

Environmental assessments are a vital part of any project development and should be thorough and appropriate in their scope. The MMR due to its incredibly small size and power output and passive safety design requires a footprint no larger than its site boundary as its Emergency Planning Zone (EPZ). This will minimize disturbance for surrounding ecology. Unlike light water reactors this technology does not rely on water as a coolant which decouples this technology from any impact on local marine ecology. The fuel is designed in such a way as to last the entire lifespan of the reactor which unlike fossil or biomass energy technologies will mean less transportation emissions and noise. Unlike wind and solar which due to their intermittency require back up firming, which at this point in Canada is almost exclusively natural gas, the MMR requires no fossil fuel inputs.

The MMR is a unique opportunity for the project site and Canada at large, especially the North. It has the capacity to decarbonize and provide air pollution free energy to rural and remote communities as well as mines and industry. 

We are at a crucial decision point in human history. We must decide whether we continue with the combustion age which allowed our species to evolve and flourish but is ultimately threatening a sixth mass extinction or whether we embrace decarbonisation technologies like fission. The MMR is a step in the right direction. Its energy density means that there are less raw material inputs and a much lower land footprint compared with all  alternative low carbon technologies. Its lack of intermittency means that it can truly be independent of fossil fuel back up. Its complete lack of particulate air pollution can safeguard the health of surrounding people and animals. 

I urge you to help this project progress through the environmental assessment process with the necessary checks and balances but without excessive burdens imposed by anti-nuclear activists based on the poor understanding of the relative risks of radiation versus air pollution. The risk benefit ratio to the local environment and the world at large in my opinion is highly favourable to the MMR. 

Thank you for your consideration,

Chris Keefer MD

Back in the 1950’s while the US and the rest of the world were hotly pursuing atomic weapons, Canada, who had no desire for nuclear arms, saw the power of the atom as a way to produce abundant and inexpensive electricity. Atomic Energy Canada Limited (AECL) was the Federal thinktank comprised of brilliant engineers whose goal was exactly that: come up with a nuclear reactor that didn’t require enrichment (we didn’t have enrichment capability because we didn’t have a nuclear arms program) and whose purpose was to be used for power generation.

Utilizing deuterium as a moderator, which allowed the use of a fuel with very low fissile content (natural uranium), what would become the foundation for the CANDU was in its infancy. A pressure tube design was chosen as the low fissile content fuel would need to be swapped out frequently, thus it was a requirement that the reactor could be refuelled online.

After a small radiological release incident at Chalk River, it was determined that multiple levels of containment and redundant safety systems would be absolutely necessary. A family of designs was born from this philosophy with safety being the top priority.

After NPD was constructed and successfully demonstrated the CANDU concept the first commercial unit for the purpose of power generation was constructed. This was in the early 1960’s at Douglas Point, now part of the massive Bruce Power site. This ~200MWe unit was a proof-of-concept design and led to the construction of the 4 units at Pickering A in a partnership between AECL, the Federal Government, the Ontario government and Ontario Hydro. Pickering was built instead of a similar capacity (4GW) coal plant.

Pickering was a massive success and by this point AECL had come up with a larger design and Ontario Hydro was keen. This led to the construction of Bruce A whose steam generators were intentionally oversized so the units could produce process steam to run operations on the grounds, such as the massive heavy water plant designed to produce deuterium both for domestic use and export. It was expected that the CANDU would be popular abroad, as we had managed to obtain partnerships and construction contracts with India, Romania, New Brunswick, Quebec…etc. CANDU was going places and we wanted to be ready.

On the heels of Bruce A came Pickering B, now based on the standardized CANDU 6 design, but with some changes on the steam and generation side to make it more similar to the A plant, thus reducing output. Then Bruce B was built, as efforts were made to cement the design for what would be the next export-ready unit, the CANDU 9. This led to the first commercial construct of that unit design: Darlington.

Darlington is probably the best known and most maligned nuclear plant in Ontario’s entire nuclear fleet. Construction started while Bruce B hadn’t even come online yet (similar to Bruce A and Pickering B) and was well underway when disaster struck: Half a world away a massive and unweildly reactor designed to produce weapons-grade plutonium succumbed to operator incompetence and suffered a meltdown. Because it lacked secondary containment found on every CANDU including Douglas Point, a hydrogen explosion resulted in a large radiological release.

Everything stopped.

Construction at Darlington ceased. The world scrambled to reconcile with what happened and the entire nuclear industry, even here in Canada, despite sharing absolutely nothing in common with the Soviet RBMK design at Chernobyl, went back to the drawing board. They had to prove it couldn’t happen here. While this was taking place time, and debt, marched on. Interest rates were soaring, the cost of the Darlington project, despite no actual work being done, was increasing rapidly. By the time the first unit entered commercial service 10 years had passed, a far cry from the 6 years shovel to breaker for the Bruce A units. This led to a construction cost of $14.4 billion. Darlington was a white elephant and thus the B plant was never built.

Darlington was the most mature design in the CANDU fleet. It was, at the time, the epitome of CANDU engineering. Deep water inlet and outlet diffusers, better heat transfer loop design, higher power output…etc. The list goes on.

We never exported CANDU 9.

After Chernobyl the global nuclear industry never recovered. AECL managed to land a few CANDU 6 sales but the 9 went nowhere and it was abandoned. Darlington is the only operating example of the CANDU 9.

Since then, AECL managed to partner with China on the Enhanced CANDU 6, which the Chinese had interest in because as had been demonstrated in various tests in Canada, the high neutron economy and inherently flexible nature of the deuterium pressure tube design meant that the CANDU could run on a huge variety of fuel combinations, something other reactors were simply incapable of. China’s intention for the units at Qinshan was for them to run on the used fuel coming out of their neighbouring American-style light water units, and they do.

When AECL failed to secure the construction contract for the ACR1000’s that were supposed to be built at Darlington B in the 20-teens it was sold off to SNC Lavalin. Ontario had screwed itself with insanely generous fixed-rate contracts for industrial wind and even more highly subsidized solar projects. This drove rates through the roof, leaving no consumer tolerance for a 25 billion dollar nuclear development.

As OPG continues to refurbish Darlington, now on Unit 3, and Bruce Power refurbishes the remaining 6x Bruce units while providing the 2nd lowest cost generation in the province I think it important to note that these things are not widely celebrated. Ontario has one of the lowest emissions grids in the world and that’s mostly due to our massive nuclear fleet. Who knew that before reading this?

Today, as Darlington Unit 1 soldiers on after setting the world record for continuous operation at 963 days of almost zero emissions generation we should be proud of what that stands for: a Canadian design built by Canadians for Canadians for the purpose of peaceful power production. Operated by your fellow Ontarians providing valuable employment in all corners of this massive province and, along with hydro, being one of the only things keeping your rates down after the disaster that was the GEA. This is something we can, and should, all be proud of.”

Christopher Adlam

Pickering Nuclear was constructed in 2 stages. Pickering A was built on experience gained from earlier prototype reactors at Nuclear Power Demonstration (NPD) in Rolphton, and the larger commercial scale Douglas Point reactor. Pickering A Units 1 and 2 employed the same pressure tube alloy used in the forerunner reactors, but Units 3 and 4 were built with the new alloy that remains unchanged to the current generation of CANDU reactor pressure tubes. It was this older alloy that led to the Unit 2 pressure tube failure.

All pressure tubes/calandria tubes (fuel channels) are designed to detect leaks.

Early manufacture of the new alloy tubes led to end fitting roll joint cracking that was originally discovered in Unit 3. This same manufacturing defect was also detected in similar vintage Unit 4, as well as Bruce A Units 1 and 2, but was subsequently mitigated.

The four Pickering A reactors were retubed from 1986-1993, as were Bruce A Units 1 and 2 before their restarts in 2012. Subsequent unit builds at Pickering B employ the same revised pressure tube standards used at Bruce B and Darlington, as well as all CANDU 6 reactors.

Physical Safety Features

Ontario CANDU sites are unique in that they employ an extra level of defence in the event of a reactor mishap causing a release or overpressure in any of the reactor reinforced concrete containment buildings. A site connected vacuum building is designed to expand containment volume by evacuating pressure from any of the eight, now six, operating reactor containment buildings. It is also equipped with a roof mounted douse tank to cool any heated contaminants pulled into the building. No other reactors in the world employ this extra level of protection.

Support systems include normal and emergency power sources, a service water system, a recirculated cooling water system, and an emergency water system. Emergency mitigation equipment and hookup are also in place, a lesson learned from the Fukushima event. Portable generators, pumps, etc. are stored onsite for immediate deployment if needed.

Pickering A

Fuel pellets are encased in a tube called a pencil. Pencils are bonded together to form a fuel bundle which is then inserted in a pressure tube filled with heavy water, encased in a calandria tube that is also surrounded by heavy water within the calandria assembly. The calandria is encased in a vault also housing a dump tank, filled with air, situated in its containment building.

The heavy water heat transport system includes a shutdown cooling system, a heavy water recovery system to recover heavy water, and the emergency coolant injection system for any loss of coolant accident. There is also a boiler emergency cooling system.

Safety systems include a fast shutdown system, a moderator dump tank shutdown system, an emergency coolant injection system, and negative pressure containment system (vacuum building).

Pickering B

Fuel pellets are encased in a tube called a pencil. Pencils are bonded together to form a fuel bundle which is then inserted in a pressure tube filled with heavy water, encased in a calandria tube which is also surrounded by heavy water within the calandria assembly. The calandria is encased in a vault filled with light water, situated in its containment building.

The heavy water heat transport system includes a shutdown cooling system, a heavy water recovery system to recover heavy water, and the emergency coolant injection system for any loss of coolant accident. The calandria heavy water tank may also be utilized as an additional heat sink. There is also a boiler emergency cooling system as well as a shutdown cooling system that can contribute to cooling.

Safety systems include two fast shutdown systems, an emergency coolant injection system, and negative pressure containment system (vacuum building).

Systems are arranged in two physically separated groups, one controlled from the main control room, the other from an emergency control center.

The Pickering B safety features are very similar, almost identical, to those of CANDU 6 reactors deployed within Canada and worldwide. However, the stand-alone CANDU 6 sites do not employ the additional safety feature of a vacuum building that Pickering has.

In 2016, the CNSC issued Pickering the highest possible rating, “Fully Satisfactory” in its Regulatory Oversight Report,26 and the World Association of Nuclear Operators (WANO) reconfirmed for a second time Pickering’s exemplary safety performance.

Irradiated Fuel Handling

Irradiated field is handled the same way it is on all other CANDU reactors. Automated fuelling machines remove the spent fuel bundles from the operating reactor. These spent fuel bundles are moved via a water immersed conveyance system to the spent fuel pool, where they will cool for 6 to 10 years. The bundles are then moved into dry storage casks, which are stored on site. By this point in time, it is safe to move within close proximity to, or stand near, these dry storage containers.

• – Tom Hess