Environment and Climate…

Environment and Climate Change Canada (ECCC) has reviewed the Province of Ontario’s proposed changes to its nuclear emergency response plan and has the following comments based on its review of the proposed response plan:

1)There is very little involvement of Federal Departments mentioned in the PNERP (beyond Health Canada and the Canadian Nuclear Safety Commission) as Federal actions are meant to be channeled through, and covered under, the FNEP (Federal Nuclear Emergency Plan). The FNEP has regional annexes in regions where there are nuclear power plants and there is an Ontario Annex that has been under development. ECCC is not aware as to whether the Ontario Annex has been signed and approved as part of the FNEP. In the grand scheme of things the Ontario Annex of the FNEP is supposed to match up with the PNERP and be a bridge between technical expertise matching between the federal and provincial governments. As the Ontario Annex has not yet been made public to the best of ECCC’s knowledge, we are unable to assess whether all the federal resources have been matched in the PNERP. We would like to recommend that the above be considered to ensure that there is consistency in the expectations of the Federal Departments across the PNERP, FNEP and the Ontario Annex of the FNEP.

2)It would be helpful if the revised PNERP contained a figure showing the overlap of the traditional planning zones (i.e., contiguous zone, primary zone and secondary zone) with the proposed contingency planning zone, as well as the actions that would occur in the zones. There is some seeming duplication of activities outlined so it would be helpful if clearer considerations for each zone were outlined, and possibly compared/contrasted.

3)ECCC’s MSC Emergency Response group at CMC in Dorval are part of the Health Canada TAG (Technical Advisory Group) for scientific dispersion modeling under the FNEP. While it is not explicitly outlined in the PNERP, Health Canada would be called on to assist in dispersion modeling as part of a PNERP response, and as such, Health Canada would call upon ECCC for this support. This is well understood in the FNEP, operationally, but not reflected in the PNERP. Weather information, in general, is not reflected in the PNERP and we recommend considering explicitly adding this to the PNERP. It is one thing to evacuate people on a nice warm, clear spring day but an entirely different thing to have to do it in cold winter weather during a snowstorm. It is not clear where the province would draw weather information from – would this information be requested from ECCC?

4)First Nations community planning. There is no indication in the PNERP, and ECCC is not aware as to whether this is fully covered under the FNEP - specifically how the Federal government would become involved for response actions involving First Nations. The Mississaugas of the Scugog are within 50km of Darlington Nuclear, and the Chippewas of Nawash and Saugeen First Nation communities are within 50km of Bruce Nuclear. There does not appear to be anything in the PNERP specific to those communities. Coordination between the provincial and federal government would be required in these situations. As such, we would recommend ensuring that actions involving these communities are, indeed, covered through the PNERP/FNEP.

[Original Comment ID: 210625]