CNA in support of Wesleyville

CNA comments on the drafts of the Integrated Tailored Impact Statement Guidelines and Public Participation Plan for the Wesleyville New Nuclear Project

The Canadian Nuclear Association has over 115 members, representing more than 89,000 Canadians employed directly or indirectly in exploring and mining uranium, generating electricity, advancing nuclear medicine, and promoting Canada’s worldwide leadership in nuclear science and technology innovation.   

The Canadian nuclear industry acknowledges the importance of rigorous environmental assessment where safety and environmental stewardship are nonnegotiable priorities. The documents currently offer flexibility for proponents to propose alternative or improved assessment and data collection methods, avoiding overly prescriptive requirements that risk limiting innovation. However, where specific guidance documents are referenced, such as SACC and its associated technical guidance, the versions to be applied should be defined and fixed for the duration of the Impact Assessment process. This would provide a stable regulatory baseline without restricting the ability to propose methodological improvements.

The purpose of the integrated review process is to achieve “one project, one review”: to align the requirements of the Impact Assessment Act with those of the Canadian Nuclear Safety Commission’s licensing process under the Nuclear Safety and Control Act. The potential to decrease duplication is significant. However, it remains unclear from IAAC’s documents to date how IAAC and the CNSC are collaborating to integrate requirements under this initiative. The drafts do not clearly demonstrate this collaboration, leaving proponents to determine on their own how to address overlapping clauses across the guidelines, which creates uncertainty and confusion. The guidelines themselves acknowledge that “not all License to Prepare Site criteria are incorporated in the Integrated Guidelines” and that the proponent remains separately responsible for addressing CNSC requirements. CNA urges that the License to Prepare Site be maintained as a distinct and separately articulated write-up to ensure it comprehensively addresses the requirements set out in REGDOC-1.1.1. The condensed treatment of site evaluation requirements in the draft TISGs (for example, in Section 2.3) risks significantly expanding the scope of when independent verification is recommended compared to the full REGDOC-1.1.1 language in Section 3.8, with potential consequences that have not been adequately considered. The PPP confirms that IAAC will eventually transfer the lead role for public engagement to the CNSC in the post-decision phase, with the CNSC administering its own separate Participant Funding Program for future licensing processes. Participation, like information requirements, will therefore occur in two distinct streams across the project lifecycle. Compounding this, IAAC’s current process includes a duplicative review step: the Agency and CNSC review the Impact Statement against the TISG and hold a comment period, and then the Review Panel reviews the same Impact Statement again during the Impact Assessment phase. This is a sequence that risks introducing new scope and creates additional uncertainty for proponents.

OPG is proposing use of the Plant Parameter Envelope as a practical response to the reality that reactor technology selection is not yet finalized. However, the guidelines impose extensive requirements around the PPE that substantially increase rather than reduce the analytical burden. OPG must not only derive and justify bounding parameters across all technologies under consideration, but also map effect pathways for each technology separately, describe how different technologies differ in their environmental impact across every project phase, and submit plain-language summaries to IAAC no later than six months before the Impact Statement submission. The cumulative effect of these requirements on a multi-technology bounding analysis is a level of complexity that may set a precedent that discourages future proponents from pursuing new build projects in Canada altogether. The CNA recognizes that IAAC and the Nations are actively working through how these additional PPE requirements will be met, and urges that the outcome of that collaboration be reflected in revised, practicable guidance before the Impact Statement phase commences.

The Wesleyville project is an important test of whether Canada's regulatory system can support the energy transition that will enable future development, and the CNA is confident that these minor changes will set a global precedent for regulatory efficiency and safety.