Steam Generators: The CNSC Environmental Assessment

February 23, 2011

The CNSC has the responsibility to regulate nuclear activities in a manner that protects the environment and the health and safety of people. This responsibility comes from the Commission’s statutory mandate under the Nuclear Safety and Control Act (NSCA). The Commission may not issue a licence under subsection 24 (4) of the NSCA unless it is satisfied that adequate measures will be taken to protect the environment.

Some projects may also require that the Commission fulfill the requirements of the Canadian Environmental Assessment Act (CEAA) before making any licensing decision under the NSCA. In the case of the proposed transport and packaging of 16 steam generators, an environmental assessment (EA) under CEAA was not required because the activity does not qualify as a “project” as defined by the CEAA – one of the key criteria for conducting an EA.

However, as required by the NSCA, CNSC staff conducted a thorough evaluation of the potential effects of this activity on the environment and on the health of workers and members of the public. This evaluation was as rigorous as what would have been looked at under the CEAA. Whether the assessment is conducted under the CEAA or the NSCA, the technical and scientific information and the assessment methods and models are subjected to the same level of scientific scrutiny.

The evaluation conducted by CNSC staff was considered by the Commission in rendering its decision.

To help illustrate the comparable nature of the two legislations, the following compares the requirements of the CEAA with the assessment conducted by CNSC staff under the NSCA for the proposal to package and transport 16 steam generators.

The CEAA requires that the environmental effects of the project be considered.

CNSC staff considered all possible releases to the environment that could occur during the transport of steam generators. Specifically, these releases are potential radiation hazards. CNSC staff considered the protection of both workers and the public from these radiation hazards. In addition, CNSC staff reviewed the potential for physical hazards that could occur during transport of the steam generators across Ontario’s roadways. The CNSC’s analysis met all the requirements of the CEAA.

The CEAA requires an analysis of the environmental effects of malfunctions or accidents that may occur in connection with the project.

CNSC staff considered multiple potential accident and malfunction scenarios under the NSCA that, however unlikely, could occur as a result of transporting the steam generators. These scenarios included accidents and malfunctions during surface transport, equipment loading, and at sea. The analysis of consequences of accidents and malfunctions conducted by CNSC staff went beyond the requirements of the CEAA. To address public concerns about the consequences of potential accidents on drinking water supply plants, even extremely unrealistic situations were assessed. In none of the situations assessed was there a significant risk to the environment or public health.

The CEAA requires that any cumulative environmental effects that are likely to result from the project be taken into consideration.

A cumulative effects assessment involves consideration of effects of the activity (i.e. the transport of the 16 steam generators) together with other projects and activities in the area. These other projects can be existing, planned and reasonably foreseeable during the lifetime of the project. Because the shipment of the steam generators is not likely to have adverse environmental effects, no cumulative effects are anticipated. This same conclusion would be reached under the CEAA or the NSCA.

The CEAA requires a determination of the significance of the effects of the project on the environment.

In a CEAA process, the first step in deciding upon the significance of effects is determining whether a project's environmental effects are adverse. If they are adverse, criteria such as magnitude, geographic extent, frequency, reversibility and ecological context help determine their significance.

Under the NSCA, CNSC staff followed a similar process. For Bruce Power’s proposal, it was determined that, with mitigation measures, the activity would have no adverse environmental effects under normal or expected circumstances. However, CNSC went beyond the CEAA requirements to consider accidents on land, at various locations along the marine route, and during the loading on board the ship in Owen Sound. Staff found that the risks posed by accidents and malfunctions are not expected to have significant impacts on the existing environment or to people. CNSC staff found that there is an abundant safety margin for very low-probability accidents.

The CEAA requires the consideration of comments from the public.

Public engagement and consultation are very important to the Commission. In considering Bruce Power’s application, the Commission convened a public hearing on September 28 and 29, 2010 that enabled 77 members of the public to express their views. In addition, the Commission allowed additional time for members of the public to comment. An additional 32 written submissions were submitted by members of the public on November 22, 2010. The ability for the public to comment on Bruce Power’s application, and the Commission’s consideration of these comments, exceeded the opportunities that are typically granted for members of the public under the CEAA for activities that are not expected to have significant impacts (i.e. screening level assessments).

The CEAA requires the consideration of mitigation measures that are technically and economically feasible.

Under the NSCA, the Commission considered Bruce Power’s plans to mitigate or eliminate potential releases under normal conditions, and in the case of accidents or malfunctions. Mitigation measures included sealing the steam generators with welded steel plates to contain the radioactive material, as well as radiation protection programs and emergency management programs. In all cases, the mitigation measures for the transportation of the steam generators are considered adequate for the protection of people and the environment.

Conclusion

Under the NSCA, CNSC staff conducted a thorough evaluation of the potential environmental effects of the packaging and transport of 16 steam generators. CNSC staff’s assessment, which was taken into consideration by the Commission in making its decision under section 24 of the NSCA, considered all the factors required for an environmental assessment under the CEAA. The public hearing process followed in considering this licence application also included an opportunity for public participation, as is the case for some EAs under the CEAA. In summary, the assessment conducted under the NSCA for this proposed activity is equivalent to an assessment that would have been done under the CEAA.

In its decision, the Commission indicated that it is satisfied that the CEAA does not require an EA of the proposal to package and transport steam generators. The Commission also concluded that the environmental review under the NSCA provides sufficient treatment of the potential adverse environmental impacts of the conduct of the proposed activity.