Dear Editor,

We understand that the economic contribution of CNL to the Ottawa Valley is significant and that our local municipal representatives are therefore inclined to support CNL’s request for a 10 year license. We would like to draw your readers’ attention to serious concerns about both the 10-year term and the content of the new proposed license for the facility.

Eighty-eight interventions for the upcoming public hearing in Pembroke, January 23-25, 2018 can be viewed on the website of the Canadian Nuclear Safety Commission at this link:

Approximately two-thirds of these interventions express serious concerns about the length of the proposed license, extensive deletion of license conditions, weakening of regulatory oversight, and other matters. Here are some highlights:

Three former senior AECL scientists highlight instability in CNL management, lack of knowledge of key regulations and international obligations, and lack of open and transparent public engagement. The submission concludes as follows:

“This evaluation raises questions as to whether CNL “… is qualified to carry on the activity that the licence will authorize the licencee to carry on…” and “We respectfully submit that a decision by the Commission to grant a 10-year licence to CNL would be an unsafe and unsound decision.”

Prepared by Dr. Ole Hendrickson, and supported by intervenor funding from the CNSC, this submission provides a detailed analysis of proposed deletions from the site license and license condition handbook. Asks “Why do the proposed CRL licence and license condition handbook contain sweeping changes that would reduce regulatory oversight, and why do CNSC staff provide no information about these changes, or their implications?”

Filed in support of the CCRCA submission. Notes that half of current license conditions are proposed for deletion. States “the level of generality and vagueness being introduced into the text of this legal instrument, and the accompanying licence condition handbook, is an open invitation for non-compliance”. Requests that the CNSC issue an order rejecting the CNL site licence renewal application as submitted by CNL and endorsed by CNSC staff.

States “This is definitely not the time for the CNSC to modify, eliminate, or substantially weaken any of the current regulations…All reporting and record keeping requirements should be maintained…” and “A 10-year license has not been granted before for CRL. OFWCA questions why it would even be considered now. Why would the license be longer than CNL’s contract which comes up for renewal in three years – in 2021? … We strongly urge CNSC to limit a new license to a maximum of three years or to extend the current license for a maximum of three years ending in 2021”.

Warns that some proposed licence changes may be “intentional to enable the NSDF,” citing the example of “the removal of the prohibition of controlled liquid waste releases to the ground,” adding that “Ottawa Riverkeeper is not supportive of the plans to collect, treat and release polluted water from the NSDF into the groundwater table.”

Points out that the lead Canadian member of the consortium that owns CNL, SNC Lavalin, is currently debarred from the World Bank for 10 years and facing charges in Canada for fraud, bribery and corruption, and that the consortium member CH2M has been convicted in the United States of fraud. Mr. Unger suggests the existing licence be extended for a short period, and a longer license period only be considered if and when SNC Lavalin is cleared of any criminal wrongdoing.

In view of the many serious concerns that have been raised by these and many other intervenors, we feel it would be prudent for no new 10-year license to be granted to CNL for the Chalk River Labs site. The alternative that we and many others suggest is for the current CRL site license to be extended for a short period of time so that the concerns can be adequately addressed before considering a longer license. We hope that our municipal officials will reconsider their support for a 10-year license and recommend a shorter license period instead.

Sincerely,

Lynn Jones

Johanna Echlin