January 3, 2007

Louise Levert
Commissions Operations Officer
Canadian Nuclear Safety Commission
280 Slater St.
PO Box 1046
Ottawa ON
Canada K1P 5S9
Via e-mail: interventions@cnsc-ccsn.gc.ca

Subject: Comments on the Environmental Assessment guidelines for the possible life extension of the Pickering B nuclear station.

Dear Ms Levert,

The Institute of Concern for Public Health (IICPH) is very concerned about the Ontario Power Generation’s proposal to rebuild the Pickering B nuclear station in order to extend its life to 2060.

In light of this request, the Canadian Nuclear Safety Commission (CNSC) seems to be considering a “screening review”, the lowest level of environmental review allowed by federal law.

Pickering Nuclear Station is in close proximity to the largest city and most populous area in the country. It is estimated that the present population of around four million will have grown to eight million before 2060.

Therefore, we believe that this proposal on the part of the OPG warrants the CNSC to carry out the most demanding and transparent environmental and safety review possible.

We are asking for a full-scale Panel Review to be carried out as it is the most rigorous under present federal law.

In these times, a terrorist attack on nuclear power plants cannot be ruled out. Neither can a nuclear accident. This review should consider the consequences of either event. The environmental and health effects would be catastrophic for such a very large population but also on farmland and the economy of the whole nation. No preparedness could cope with such a major disaster.

The health effects of the continuation of the production of nuclear waste are a major concern. Our preferred solution is the phase-out of the use of nuclear power as soon as possible. The present health effects of radioisotopes including those produced by nuclear power plants continue to be unrecognized by the nuclear establishment and the government, although well established by scientific research (See Dr. Rosalie Bertell’s presentation to the licensing hearing on SRB Technology before the CNSC on November 27, 2006).

Considering the possible dangers posed by the continuation of the Pickering Nuclear Power Station, Pickering B in particular, we believe there should be a number of consultations in Toronto so constituted that the general public will have ample opportunity to address the issues. We think a full and open discussion on this important issue is necessary. In our view, a full Panel Review is imperative.

Thank you for this opportunity to comment on the draft guidelines for the environmental assessment of the proposed life-extension of the Pickering B station.

Marion Odell
Vice-Pres.