CELA submission--Comments on DNNP EA Applicability to BWRX-300 Tech
17 November 2023
Even though it has yet to be determined by the Commission as to whether the DNNP EA is even applicable to the selected technology, this timeline combined with CNSC staff’s conclusion that “the BWRX-300 reactor technology is bounded by the EA, and that the EA remains applicable for this reactor technology”,10 members of the public are given the impression that the outcome for the January 2024 Heari. [...] Section 9 of the NSCA sets out the objects of the CNSC: 9 The objects of the Commission are (a) to regulate the development, production and use of nuclear energy and the production, possession and use of nuclear substances, prescribed equipment and prescribed information in order to (i) prevent unreasonable risk, to the environment and to the health and safety of persons, associated with that deve. [...] In the alternative that the CNSC deems the BWRX-300 reactor design to be consistent with the parameters of the PPE and EIS (which the intervenors submit it is fundamentally different), we submit that before a licence to construct (LTC) process commences, the aforementioned issues must be resolved in order to bring the selected reactor technology within the approved parameters of the EIS and PPE. [...] The intervenors submit that due to the vastly different state of land use in the region along with the increase in population in Durham Region and beyond, compared to the date of the original EA, the siting of up to four BWRX-300 reactors at the Darlington site would be inappropriate, and a new environmental assessment is required to determine what would be an appropriate site for this selected te. [...] As summarized by staff, the EA had concluded that “…despite possible changes to the climate in the future, there were no climate parameters that would influence the proposed physical structures or systems of the DNNP, resulting in a risk to either the public or the environment.”42 After reviewing the EA, the EIS Review and supporting documentation, CNSC staff have concluded that the BWRX-300 deplo.