NFU-O Nuclear Emergency Preparedness and Response Consultation Letter

Re: REGDOC-2.10.1: Nuclear Emergency Preparedness and Response Consultation

The National Farmers Union – Ontario is writing to the Canadian Nuclear Safety Commission (CNSC) to express its concern over the absence of any specific protocols to deal with nuclear contamination to agricultural land and groundwater within the revised “REGDOC-2.10.1 Nuclear Emergency Preparedness and Response, Version 3 – Draft for Consultation.”

The National Farmers Union of Ontario (NFU-O) is an accredited farm organization representing thousands of sustainable farmers in Ontario and has advocated for farmers across Ontario since 1969. NFU-O policy calls on all levels of government to enact and follow transparent, rational planning guidelines, regulations, and bylaws to ensure fairness to all citizens, to protect farmland and ecologically sensitive areas from development, and to prevent the further privatization of public lands.

The need for emergency preparedness and response protocols in relation to agricultural contamination following a nuclear disaster at one of Canada’s four operating nuclear plants (Bruce, Pickering, Darlington in Ontario and Point Lepreau in New Brunswick) should be obvious. The impacts on human health, food security, and the natural environment in direct relation to agricultural nuclear contamination would be profound. In Durham Region – where Pickering and Darlington nuclear power plants are located – a nuclear emergency – depending on the size of the radioactive fallout – could impact over $413 million in annual farm revenue; while a nuclear disaster at the Bruce power plant would threaten over $896 million in annual farm revenue in Bruce County alone. If a disaster were to occur, animals would need to be culled and disposed of and our finite prime agricultural soil would be contaminated and, if not removed, the land will be unsuitable for crop production for a minimum of 30 years (the half- life of caesium), if not longer.

Almost 35 years after the Chernobyl tragedy, scholars are still finding radioactive isotopes – including strontium 90 and/or caesium 137 – above official safe limits in almost half the samples, while dairy in parts of the Ukraine continues to contain radioactive levels five times over the official safe limit. Over 52,000 square km of farmland was contaminated around Chernobyl in 1986 – or over 6.5 times the size of Ontario’s Greenbelt.

After the Fukushima-Daiichi nuclear reactor accident in 2011 an exclusion zone of 30 km around the Japanese power plant remains in place, 80% of this land is either agricultural, forest, or meadow. Affected Japanese farmers received little information regarding how the disaster would impact their operations or what to do to minimize contamination. Japanese dairy cattle over 160km from the nuclear power plant who were fed on silage grown during the disaster were found to produce milk that contained radionucleotide contamination, crops – especially those growing during the fallout – contained high levels of radioactive contamination, and the crucial 2-3 cm top level of soil was found to be impossible to decontaminate without chemical treatment. Even though Japan publicly inspected beef for nuclear contamination and ensured that beef products were below radioactive regulation levels, consumers did not feel safe purchasing beef from the Fukushima prefecture, and beef producers suffered as a result.

The NFU is opposed to any new nuclear facilities due to the environmental risks related to nuclear energy production and storage, and would prefer to see the decommissioning of existing nuclear plants in favour of the promotion of alternative renewable electrical power generation. However, in the absence of a plan to decommission our nuclear power plants, we believe it is crucial to have a robust nuclear emergency preparedness and response policy that includes specific provisions and supports for farmers to deal with agricultural contamination. This should include, among others:

• The immediate cessation of all field work and evacuation of all agricultural workers
  within the Emergency Planning Zone (EPZ) or affected areas;
• Plans to remove and replace a minimum of 3cm of agricultural topsoil within the EPZ or
  affected areas as soon as it is considered safe to do so;
• Full compensation for all farmers for loss of income, health expenditures, or any costs
  associated with the nuclear disaster and/or response efforts;
• Continually updating education materials for farmers to inform them of best practices to
  mitigate contamination (for instance, some studies have indicated that liming and using
  organic fertilizers can reduce strontium 90 by almost half); and
• Full and transparent public testing of all possibly contaminated agricultural products to
  ensure public health, safety, and consumer trust.

The government’s “Nuclear Emergency Preparedness and Response” needs to take into account the proximity of our nuclear power plants to essential farmland. To not do so endangers public health, the soil and water required for agricultural production, food security, and the safety of our agricultural producers. In the instances of both the Chernobyl and Fukushima nuclear disasters, the authorities lacked the preparedness to mitigate farmland contamination and/or protect food producers and the food system; we cannot afford to do the same.

Sincerely,

Max Hansgen, President
National Farmers Union – Ontario