The Ontario government…

ERO number

013-0560

Comment ID

2366

Commenting on behalf of

Individual

Comment status

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Comment

   The Ontario government should recognize public expectations for public safety, including putting in place measures to protect the public in the event of a Fukushima-scale accident.

  Ontario should commit meet or exceed international best practices for nuclear emergency response planning and preparedness wherever feasible.

  Post Fukushima the Ontario government must be ready to protect Ontarians in the event of a worst-case nuclear accident on the Great Lakes.

  Ontario should match the best practice set by Switzerland and put in place emergency plans to protect the public in the event of an a level 7 accident on the International Nuclear Event Scale (INES).

  Switzerland is preparing plans for large-scale evacuations and the need to care for evacuees for long periods of time.  Ontario should too.

  Ontario should be able to protect drinking water supplies in the event of a nuclear accident at any of the twenty-five reactors that line the Great Lakes.

  Ontario’s nuclear emergency response plan should be reviewed regularly and transparently.

  • The government should publish modelling on the

  impacts of a Fukushima-scale accident before it

  provides final approval for its plan to continue

  operating Pickering in 2018.

  • The government should develop the capacity to

  independently model nuclear accidents in order to

  ensure the ongoing adequacy of offsite plans.

  Emergency plans need to be adapted to meet the special needs of vulnerable communities, such as the elderly or hospital patients.

  Planning for major accidents means Ontario needs to expand emergency planning areas.  Ontario should expand its evacuation zones to at least 20 km around each nuclear station to match real-world experience and the best practices set by other countries, such as Switzerland.

  The government should require provincial and

  municipal authorities to inform residents and

  businesses in the 50 km Secondary Zone of the

  availability of potassium iodide and the desirability

  of including it in their home or institutional

  emergency kit.

  • The government needs to require those

  authorities to conduct detailed planning to ensure

  that evacuation can effectively be carried out in

  the full newly proposed contingency planning zone

  as well as into the secondary zone, especially for

  vulnerable communities.

 The government should study and publish

  modelling of drinking water source contamination

  in the areas around the Bruce, Darlington and

  Pickering nuclear plants in the event of a major

  accident, examine appropriate response

  measures, and develop a plan to ensure that

  contingency drinking water supplies will be

  available in the case of such an accident.

  • The government should use its drinking water

  protection jurisdiction to ensure that the Great

  Lakes and other sources of water are protected by

  requiring contingency plans including

  contaminated water storage and isolation.

 The government needs to study and propose

  guidelines for land recovery and return before

  2018, when the Pickering Nuclear Generating

  Station is due for another federal safety licensing

  review.

 The government should ensure all meetings and

  consultations with industry on nuclear emergency

  matters can be scrutinized by the public.

  • A revised nuclear emergency plan should make

  public consultation and pro-active disclosure

  mandatory on a rigorous and regular schedule,

  with updated information including population

  density and land use.

  I call on the provincial government to ensure nuclear emergency response plans are in

  place to:

  • Protect people from Fukushima-scale accidents;

  • Protect vulnerable communities;

  • Protect drinking water;

  • Ensure transparency and public participation;

  • Meet or exceed international best practices.

  The Ontario government recently committed to run eighteen aging reactors at the Darlington,

  Bruce and Pickering stations well beyond their original operational lives. Ten of these aging

  reactors are in the Greater Toronto Area (GTA) – creating risks for millions of nearby residents.

 Aging reactors in the United States at the Fermi, Davis-Besse, Perry, Ginna, Fitzpatrick and Nine

  Mile Point nuclear stations also put Ontarians and our drinking water at risk.

  In light of these risks, the Ontario government should protect public safety and prevent

  needless risks to health and society by making Ontario’s nuclear emergency plans the most

  robust in the world.

 TO PROTECT PEOPLE THE ONTARIO GOVERNMENT SHOULD:

  • Use a Fukushima-scale radioactive release as the baseline “reference accident” for

 determining offsite protective measures, such as alerts, evacuation, and potassium iodide

  (KI) pre-distribution.1

  • Regularly publish modelling on Fukushima-scale accidents at the Bruce, Pickering,

  Darlington nuclear stations to confirm the adequacy of offsite emergency response.

  • Expand emergency planning areas to align with the impacts of Fukushima, including at least

  a 20 km evacuation zone.

  • Ensure all municipalities within 100 km of a nuclear station, including American reactors,

  develop and maintain nuclear emergency response plans.

  TO PROTECT VULNERABLE COMMUNITIES, ONTARIO’S NUCLEAR EMERGENCY

  PLANS SHOULD:

  • Identify vulnerable groups, such as people with disabilities, babies, children, pregnant

  women, people residing in retirement homes, and hospital patients who may need to be

  evacuated in the event of a Fukushima-scale accident.

  • Require clear plans to assist vulnerable groups before and after evacuation, including

  support from health care practitioners.

  • Acknowledge that operating reactors in densely populated areas like the Greater Toronto

  Area (GTA) will complicate emergency response in the event of a major reactor accident and

  require detailed plans for large-scale evacuation in the short-term and the accommodation

  of large populations in the long-term.

  • At a minimum, pre-stock potassium iodide (KI) pills in all schools within 100 km of all nuclear

 stations in or near Ontario.

  TO PROTECT DRINKING WATER, ONTARIO’S NUCLEAR EMERGENCY PLANS SHOULD:

  • Provide alternative sources of drinking water for residents whose drinking water is sourced

  from any of the Great Lakes on which a nuclear power plant is located.

  • Ensure alternative drinking water sources are identified, and that logistical plans to supply

 the impacted population with these alternative sources are in place to last indefinitely.

  • Model and publish Fukushima-scale accidents at nuclear stations on the Canadian and

  American sides of the Great Lakes to assess impacts on drinking water supplies and

  aquatic ecosystems.

  TO PREVENT COMPLACENCY AND ENABLE PUBLIC PARTICIPATION,

  THE ONTARIO GOVERNMENT SHOULD:

  • Apply the government’s Open Government policy to nuclear emergency planning and

  require detailed government information on nuclear emergency planning be available by

  default, including accident modelling.

  • Require regular five-year reviews and detailed consultations with the public and affected

  communities as to continuous improvement of both the planning basis and emergency

  response measures.

  JURISDICTIONS AND REFLECTING THE EXTREMELY HIGH POPULATION DENSITY IN THE

  VICINITY OF 10 OF THE OPERATING REACTORS IN THE GREATER TORONTO AREA, THE

  GOVERNMENT SHOULD:

  • Require nuclear emergency response measures meet or exceed international best practices.

  • Regularly review and publicly report on international developments and best practices in

  offsite nuclear emergency planning as well as on plans to adjust and improve Ontario’s plan

  to meet or exceed the best practices in other OECD jurisdictions.

[Original Comment ID: 210224]