From Brad Blaney to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

Canadian Nuclear Safety Commission
Aimee Rupert, Environmental Assessment Officer
P.O. Box 1046 Station B, 280 Slater Street
Ottawa ON K1P 5S9

Email: cnsc.ea-ee.ccsn@canada.ca

September 13, 2019

Re: SMR Consideration for approval by CNSC

Dear Ms. Rupert and CNSC Members,

Please consider the following in consideration of your review of this matter:

   How will Mr. Binder and the CNSC ignore the past and recent history of SMR safety?

Specifically;

1. There are proven dangers and risks associated with the use of metals or liquid sodium for a heat sink. Please reference;  the 1995 liquid sodium leak/cover up and the subsequent 2010 restart accident at the Monju Sodium FB Reactor in Japan; the SMR explosion at the Russian missile site in July 2019 releasing large amount of isotopes ; and the SMR turbine fire in aRussian research submarine in June 2019 resulting in the deaths of 15 senior nuclear technicians beneath the Arctic Ocean. Since this is new technology with a very expensive/sad service history, what experience does the Commission have to examine SMR’s?   
2. Will the CNSC review include evaluating the financial stability, and/or evaluating criminal investigations underway into suppliers/partners in the construction of the  SMR (i.e. SNC Lavalin and General Electric/Fluror corp/Babcox etc)? Does the Commission even take such issues into consideration when evaluating the integrity of suppliers?
3. Why has the CNSC failed to provide any review/reports on its web site regarding the recent SMR accidents in Russia, even when it is now undertaking the assessment of the safety of the SMR which has the same/similar design?
4. Is the CNSC capable of objectively preparing a competent risk assessment of the use of highly explosive coolant alternatives? What experience does this CNSC have in this field. Or, will the crew from the Fisheries and Oceans dept give their best efforts to guess what could happen when there is a (high pressure) coolant leak?
5. Additionally, is the CNSC able to provide a disaster response when there is a breach of the heat sink?  History demonstrates that the CNSC has paid lip service  to risk assessment in favour of the OPG agenda.
6. Finally, what are the circumstances under which the CNSC WOULD NOT approve the SMR proposal by OPG?

In conclusion, the fact that the CNSC has accepted a lobbyist for this project, named Ultra Safe Nuclear Limited, raises questions about the integrity, independence and competence of the entire Commission. Nuclear power may be many things; but “ultra safe” it cannot/will not be – not safe for human beings, ever.

Awaiting your reply,

Mr. Brad. Blaney