Citizens Against Radioactive Neighborhoods (CARN) organized an intervention workshop on January 7, 2020, which had 150 people in attendance. This regarded BWXT’s application for the flexibility to manufacture uranium pellets in Peterborough, which is currently already done in Toronto. The workshop was hosted by CARN and Kerrie Blasie of the Canadian Environmental Law Association (CELA) at the Beth Israel Synagogue. CELA is an environmental law firm that receives funding through Legal Aid Ontario, and operates across Ontario on national and provincial issues. Blasie stated that some funding was received from the Canadian Nuclear Safety Commission (CNSC) for an intervention. An important deadline for making an intervention is January 27, 2020, when written interventions and requests for oral submissions are due. Oral interventions will be made at Peterborough’s Holiday Inn on March 5 and 6, as well as on March 2 and 3 in Toronto.
CELA provides access to environmental justice, which is defined as benefits and burdens being distributed evenly among communities. At the workshop, it was noted that negative environmental impacts are often greatest on poor and racialized communities. Some barriers to justice include broad discretion on how regulators operate, a lack of a right to a clean, healthy environment, and poor access and ability to write injunctions.
Before the workshop began, I was shown a map surrounding the BWXT plant showing two kilometres around the plant. Almost immediately outside BWXT is the Prince of Wales Public School, and it covers Peterborough’s Liftlocks in a residential neighborhood, including about 11,800 properties. This is problematic because citizens, children, and gardeners could be exposed to the chemicals associated with uranium pelleting, such as beryllium and uranium, which would increase if uranium pelleting came to Peterborough. This is even more harmful if ingested.
While there are already small amounts of radiation emitted, there is a concern that these amounts will become harmful as they could accumulate. Attendees at the event were concerned about hydrogen tanks that would be used at the site, and the economics of uranium pelleting and historic issues with pollution associated at the former General Electric site. Other concerns included worker safety, and As Low as Reasonably Achievable regulations. An environmental assessment was not required for BWXT, which would have addressed some of the economic and social concerns.
During the meeting it was also pointed out that small nuclear reactors would also not be subjected to an Environmental Impact Assessment. A good podcast to listen to is Pints and Politics Edition #76: “Why is there community resistance to nuclear fuel manufacture in Peterborough?” to understand further concerns about potential pelleting in Peterborough.
Blasie made it clear that anyone with an interest or expertise with nuclear reactors is able to intervene in this case, including the public as the impacts are locally felt. An intervention could be as simple as writing out a list of questions; you do not need to be an expert. A few guidelines for an intervention was the inclusion of names addresses and phone numbers. Only your name will be made public, to show that there is an interest. Whether you would like to present orally, and where you would like to present is up to you. During oral presentations it was pointed out that there is no cross examination, meaning you can’t ask questions to the CNSC although they can ask questions to you, so it is a good idea to reference sources. Before starting the Intervention there are three key documents:
- BWXT Licence Application from BWXT submitted to Canadian Nuclear Safety Commission
- CNSC Staff Commission Member Document
- BWXT Commission Member Document
In addition to this, a document that may be helpful is a workplace exposure study on General Electric from 1945 to 2000 by Robert and Dale DeMatteo. As each document is rather long, control F, or the search function, is helpful in finding relevant information.
Oral Interventions are 10 minutes long if requested, and slide presentations are generally due one week before the hearing date which is in March.
Interventions can be emailed to cnsc.interventions.ccsn@canada.ca or filed online by clicking here. Questions can be asked about interventions to cnsc.interventions.ccsn@canada.ca. CARN has information on their Facebook page. Information requests can be directed to Dave Snopeck of BWXT by emailing nacutler@bwxt.com and CNSC.Info.CCSN@canada.ca.
The overall message of the evening was that you don’t need expertise in the nuclear industry to make an effective intervention and that it is an important part of access to environmental justice.