Exploring a Coal-to-Nuclear Transition: Repurposing of Legacy Coal Assets to Locate Small Modular Reactors in Alberta

Climate change mitigation and the search for alternative energy are spurring a growing interest in repurposing decommissioned coal power plants into sites for small modular nuclear reactors (SMRs) which produce minimal greenhouse gas emissions. With power ranging between 10- to 300-megawatt electric, SMRs take up a fraction of the size and have approximately one-third of the generating capacity of a conventional large-scale nuclear reactor. Saskatchewan plans to locate its first SMR on the site of a combined coal-fired power station near Estevan, and it is inevitable that SMRs will eventually be proposed for Alberta. These small reactors offer greater efficiency, safety and flexibility of deployment compared to large nuclear plants; however, uncertainty surrounds the regulatory framework that must be in place before any proposals are made to site SMRs in Alberta. Both the provincial and federal governments have jurisdiction over coal-to-nuclear transition projects and given the current lack of a nuclear regulatory framework in Alberta, this paper discusses the rules, regulations and procedures that will be required for approvals. Instead of building from scratch, repurposing of decommissioned coal-fired power plants using the existing infrastructure — water storage systems, desalination plants and wastewater treatment systems — and improved technology, offers a way to streamline the approval process. Any SMR proposal would first require an impact assessment which would consider the project’s social, environmental and economic effects as well as waste management, safety and other factors, culminating in the question of whether the project would be in the public interest. Coal plant owners and the owners of extant infrastructure such as transmission lines would need to be consulted, along with Indigenous people and other area residents. Among the regulatory agencies tasked with various stages of the approval process are the Canadian Nuclear Safety Commission and the Impact Assessment Agency of Canada at the federal level and Alberta Environment and Protected Areas and the Alberta Utilities Commission at the provincial level. Given the inevitable complexities inherent in a lengthy approvals process, this paper argues that, despite the fact no coal-to-nuclear transitions are on the Alberta horizon, a regulatory framework for nuclear energy generation must urgently be established in the province. Best practices can be gleaned from the processes Ontario and New Brunswick used to collaborate with the federal government on their proposed nuclear reactor sites and strategies for Alberta can be developed from lessons learned in those provinces. Proceeding with a coal-to-nuclear transition means that harmonizing the key regulatory players and their respective processes — including public participation and determinations as to the public interest — is a priority. Laying the groundwork for nuclear energy generation in Alberta can begin now by preparing a detailed scoping of potential coal-fired power plant sites, including an inventory of the technical infrastructure that can be repurposed for SMRs. Power plant owners and owners of infrastructure such as transmission lines will need to be consulted about siting nuclear power plants on their properties with regard to future environmental and decommissioning liabilities, licence transfers and site closures, because those processes would likely be carried out by a different owner/operator. With potential sites located, a regulatory framework in place and a streamlined approvals process, Alberta would stand ready to benefit from nuclear energy’s ability to mitigate the effects of climate change and provide a stable, affordable supply of energy.

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