Author: hendricksonjones

Dumping of toxin-laced water into the Ottawa River by Canadian Nuclear Laboratories should be stopped immediately, says expert report

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(Ottawa, Ontario, March 21, 2018) Sixteen thousand litres of water contaminated with radioactive tritium, PCBs and other toxins – at levels hundreds and thousands of times greater than Ontario and Canadian surface water quality standards – were dumped directly into the Ottawa River in 2015 from a non-operating nuclear reactor 200 km northwest of Ottawa, says a report by an expert hydrogeologist. From 1997 to 2015, an annual average of 26,000 litres of radioactive water were discharged into the Ottawa River from the Nuclear Power Demonstration (NPD) reactor in Rolphton, Ontario.

The report by Wilf Ruland notes that releases of contaminated water into the Ottawa River “appear to have been ongoing for decades and continuing to the present day.” Ruland analysed test results published by Canadian Nuclear Laboratories, which operates the site, and concluded that “regulatory guidelines for surface water quality were vastly exceeded in the contaminated water being dumped untreated into the Ottawa River from the NPD facility in 2015.”

Ruland is a specialist in groundwater and surface water contamination and has served as an expert witness before the Canadian Nuclear Safety Commission (CNSC) and various environmental tribunals. His report was prepared for the Algonquin Anishinabeg Nation Tribal Council and submitted to the CNSC as an independent review of hydrogeological issues related to the Nuclear Power Demonstration (NPD) Closure Project. His report acknowledges that the contaminated water will have been “steadily diluted” as it flows down the Ottawa River, but nonetheless expresses disappointment “to learn that this practice is occurring at a Canadian nuclear facility in the modern day.” He urges that dumping be discontinued immediately.

“Radioactive substances, PCBs and toxic metals are accumulating in the Ottawa River,” said Norm Odjick, Director General of the Algonquin Anishinabeg Nation Tribal Council.  “Millions of Canadians drink this water, including the residents of Ottawa and Montreal.  It’s shocking that these releases are being allowed to continue.” 

Levels of radioactive tritium in the contaminated water, at 4,100,000 Becquerels per litre, were 586 times higher than Ontario’s Provincial Water Quality Objective for surface water quality (PWQO) in the 2015 releases. The Becquerel is a measure of how radioactive a substance is, that is, how many radioactive particles per second it emits.

The contaminated water also contained 5,450 nanograms per litre of PCBs — while the Ontario PWQO is only 1 nanogram per litre. Polychlorinated biphenyls (PCB) are pollutants that accumulate in the environment and that cause cancer in animals and probably humans.

The water also contained mercury, cadmium, copper and lead at levels up to 1,720 times higher than the regulatory guidelines contained in the Canadian Council of Ministers of the Environment (CCME) Environmental Quality Guidelines for surface waters.


The Rolphton Nuclear Power Demonstration (NPD) Reactor is owned by the federal government. Located about 100 metres from the Ottawa River, it was shut down in 1987 and has since been maintained in “long-term storage.” All federal nuclear sites are run by Canadian Nuclear Laboratories (CNL), which in September 2015 was transferred to a private-sector consortium of U.S., U.K. and Canadian companies, including SNC Lavalin.

The data on contaminated water are contained in the draft environmental impact statement  (EIS) on the NPD Closure Project.  In September 2017, CNL submitted a proposal to “entomb” the NPD reactor in concrete to the Canadian Nuclear Safety Commission (the federal agency that regulates the nuclear industry). The EIS shows the number and volume of releases of contaminated water into the Ottawa River back to 1997.

“Reactor entombment wouldn’t stop groundwater from penetrating cracks in the concrete walls of the reactor vault, then re-emerging and transporting contaminants down to the river,” says Dr. Ole Hendrickson, a researcher for the Concerned Citizens of Renfrew County and Area.  He adds, “The entombment proposal is problematic for many reasons and is definitely not a solution to the leaking of contaminated water.”

CNL is also proposing to build a landfill-type nuclear waste disposal facility at Chalk River to contain at least 1 million cubic metres of radioactive and toxic waste. The Canadian Nuclear Safety Commission is expected to make decisions this year about both proposals.

Both proposals have been criticized by former professional staff members of the two sites (then managed by Atomic Energy of Canada Limited), including a former director of safety engineering and senior scientists. Environmental groups say that the proposals will increase Canada’s liability for radioactive waste cleanup in the future and could contaminate the drinking water of millions of people along the Ottawa River and the St. Lawrence River into which it flows.

Citizens groups, First Nations and nuclear scientists decry plan to entomb a nuclear reactor beside the Ottawa River, endangering drinking water

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(Ottawa, Ontario, March 20, 2018) Retired nuclear scientists, citizens’ groups and First Nations are shocked by plans to “entomb” a defunct nuclear reactor, by covering it with cement and grout, beside the Ottawa River at Rolphton, Ontario. The site of the proposed “entombment” is upstream of Ottawa-Gatineau and Montreal, and directly across from the Province of Quebec. The so-called “Nuclear Power Demonstration (NPD) Closure Project”, advanced by a multinational consortium, was roundly criticized during a recent public comment period on the draft environmental impact statement for the project.
“NPD will remain a radiological hazard for tens of thousands of years …It is absurd to conclude that cement grout, a reinforced concrete cap above the reactor vessel, and an engineered barrier…over the building footprint will protect the public for that period of time” according to a retired senior manager from Atomic Energy of Canada Limited, Dr. J. R. Walker, one of several retired nuclear scientists who submitted detailed briefs during the recent public comment period.
According to Dr. Ole Hendrickson, researcher for the group Concerned Citizens of Renfrew County and Area, “entombment” is only supposed to be used in emergencies according to the International Atomic Energy Agency.  “If approved, this project would set a very bad precedent” Hendrickson said.
First Nations raising concerns about the NPD entombment project include the Algonquin Anishinabeg Nation Tribal Council, the Métis Nation and the Algonquins of Ontario. A review of the hydrogeology in the vicinity of the proposed site, done on contract for the Algonquin Anishinabeg First Nation Tribal Council, is highly critical of the field investigation of the surrounding fractured bedrock, calling it “rushed” and “woefully inadequate”.
“This is a crazy proposal,” according to Johanna Echlin of the Old Fort William (Quebec) Cottagers’ Association. “Proposing to abandon long-lived radioactive toxins 100 metres from a drinking water source for millions of Canadians is unbelievably irresponsible,” Echlin said. “It’s totally out of alignment with international guidance and the radioactive waste treaty that Canada signed in 1998.  These types of long-lived radioactive wastes are supposed to be kept in stable rock below the surface and away from water bodies”.
Federal agencies and the Ontario environment ministry submitted over 200 comments noting inconsistencies and missing information in the environmental impact statement. Additional concerns raised by public commenters are that the Ottawa River is a major fault line; lead, mercury, dioxins and PCBs may enter the river; the inventory of radioactive waste is deficient; and that entombing the defunct reactor will make it more costly and difficult for future generations to fix problems that may arise in the future.
The Environmental Assessment process will continue with internal discussion between the proponent and the Canadian Nuclear Safety Commission (CNSC), widely perceived to be a “captured regulator”.  A CNSC decision whether to approve and license the project is expected in December 2018.
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The crazy plan to “entomb” a nuclear reactor beside the Ottawa River

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The multinational consortium that brought us the plan for the giant radioactive “Chalk River Mound” now wants to entomb a defunct nuclear reactor right beside the Ottawa River at Rolphton, Ontario, 200 km upstream of Ottawa-Gatineau. Essentially “entombment” means to cover over with cement and grout and hope for the best.

This plan is just as crazy as the mound, if not more so, since it would be situated a mere 400 meters from the Ottawa River. The International Atomic Energy Agency (IAEA) says “entombment” is not a decommissioning strategy and should only be used in the case of a severe accident.

Cement and grout, in the Upper Ottawa Valley climate with freeze-thaw cycles and abundant precipitation can only last a small fraction of the time during which the witches’ brew of toxic man-made radioactive substances, contained in the defunct reactor, will be hazardous to all life. IAEA says such materials need to be kept out of the biosphere for as long as the hazard persists which is more than 100,000 years.

Do you have a half hour to help prevent this crazy plan from going forward? If so, your assistance would be greatly appreciated!

Comments are needed on the Environmental Impact Statement for the project. The deadline is February 13, 2018 at midnight. So far there are only 13 comments posted on the public registry. We need more comments from concerned citizens and groups to show that we will not stand by silently and allow such irresponsible abandonment of nuclear waste beside the Ottawa River.

If you can help, step one would be to read some background materials (see below) and step two would be to write a short letter outlining your concerns and send it to: Lucia Abellan, Environmental Assessment Officer, Canadian Nuclear Safety Commission Email: cnsc.ea-ee.ccsn@canada.ca. The subject line of your email should read ” Comments on the EIS for the Nuclear Power Demonstration Closure Project”

Key points to mention are 1) retired nuclear scientists such as Dr. J. R. Walker  have raised very serious concerns about the proposal (you could include one or more quotes from the  Walker submission) and 2) that you would like remind/urge the regulator to insist that long-lived radioactive wastes be stored in state-of-the art facilities, well away from drinking water sources, to ensure that they are kept out of our air and drinking water for as long as they remain hazardous.

Here are some useful background documents:

1) Nine quick facts on the crazy plan to “entomb” a nuclear reactor beside the Ottawa River

2) NPDRolphton ~ overview of important information and links produced by the Old Fort William Cottagers’ Association

3) Submission by Dr. Gordon Edwards on the Whiteshell 1 reactor (a similar “entombment” on the Winnipeg River)

Thanks everyone for your ongoing support. Please get in touch if you have any questions or comments!

www.concernedcitizens.net

https://www.facebook.com/RadWasteAlert/

Environmental Petition 413 to the Auditor General of Canada: Environmental Assessment of Nuclear Projects

hendricksonjones 5 Comments

January 29, 2018

Petition summary on the OAB website here: https://www.oag-bvg.gc.ca/internet/English/pet_413_e_43085.html

Environmental Assessment of Nuclear Projects

This petition is being submitted to the Office of the Auditor General of Canada in accordance with section 22 of the Auditor General Act by the Concerned Citizens of Renfrew County and Area (CCRCA) and the Old Fort William Cottagers’ Association (OFWCA).  We note that the concerns highlighted in this petition and the answers sought are also matters of importance to our colleagues in other organizations including the Canadian Coalition for Nuclear Responsibility, Pontiac Environmental Protection, the Greenspace Alliance of Canada’s Capital and Friends of the Earth Canada.

Purpose of Petition

This petition concerns an important issue for our country in the coming decades: the environmental assessment of nuclear projects, including those for managing Canada’s large volumes of radioactive waste.  To inform this issue we review the ongoing discussion of how Canada’s environmental assessment processes can regain public trust and how to ensure that decisions serve the public’s interest.  We draw upon the report of the Expert Panel, Building Common Ground: A New Vision for Impact Assessment in Canada (1); on the Minister of Environment and Climate Change Mandate Letter (2); and on the federal government’s Environmental and Regulatory Reviews: Discussion Paper (3).  We then pose questions for the various Ministers involved in the environmental assessment review and reform process, with a specific focus on how this process should address nuclear projects.

Background

Nuclear projects include construction and operation of new facilities such as uranium mines or nuclear reactors, refurbishment of existing facilities, decommissioning of facilities whose useful life is over, and management of wastes arising from activities such as mining, nuclear research and development, and nuclear power generation.

Managing nuclear wastes is a particularly challenging issue.  Nuclear waste has been accumulating in Canada for seven decades. Long-lived man-made radionuclides such as iodine-129, nickel-59, niobium-94, plutonium-239, plutonium-240, technetium-99, uranium-234 and zirconium-93 will be toxic to all life for many millennia. Facilities must be planned and built to look after the wastes in the best and most responsible manner possible, to keep them out of the biosphere for as long as they remain hazardous. 

Environmental assessment will be a key part of the process of establishing the necessary facilities. The best quality environmental assessment will be necessary in order to minimize pollution, protect the health of Canadians, protect ecosystems and avoid placing undue burdens on future generations.

Currently in Canada, under the Canadian Environmental Assessment Act, 2012 (CEAA), the Canadian Nuclear Safety Commission (CNSC) is the sole responsible authority for the environmental assessment of nuclear projects.

After conducting extensive hearings across Canada, the Expert Panel on Environmental Assessment Reform issued its final report In April 2017.  It recommends that an independent assessment authority replace the CNSC as responsible authority for nuclear projects (1). The Panel accepted the arguments made by hearing participants that “industry-specific regulatory agencies are more focused on technical issues than they are on the planning process that is fundamental to a thorough IA [impact assessment],” and that issues “were being put off to the post-decision regulatory phase.”   

The Expert Panel’s recommendation that the CNSC be replaced as responsible authority also reflects the widely held view that the CNSC is a “captured” regulator.  The Panel report states that “The term “regulatory capture” was often used when participants described their perceptions” of the CNSC. ()

The Minister of Environment and Climate Change Mandate Letter (November 12, 2015)

Identifies environmental assessment reform as one of the Minister’s “top priorities”:

Supported by the Ministers of Fisheries, Oceans and the Canadian Coast Guard, and Natural Resources, immediately review Canada’s environmental assessment processes to regain public trust and help get resources to market and introduce new, fair processes that will:

  • restore robust oversight and thorough environmental assessments of areas under federal jurisdiction, while also working with provinces and territories to avoid duplication;
  • ensure that decisions are based on science, facts, and evidence, and serve the public’s interest;
  • provide ways for Canadians to express their views and opportunities for experts to meaningfully participate; and
  • require project advocates to choose the best technologies available to reduce environmental impacts. (2)

The Expert Panel addressed in detail the first part of this priority – review of environmental assessment processes to regain public trust.  With regard to CNSC-led environmental assessments, the Expert Panel said:

…the erosion of public trust in the current assessment process has created a belief among many interests that the outcomes are illegitimate. This, in turn, has led some to believe that outcomes are pre-ordained and that there is no use in participating in the review process because views will not be taken into account. The consequence of this is a higher likelihood of protests and court challenges, longer timeframes to get to decisions and less certainty that the decision will actually be realized – in short, the absence of social license. (1)

The Expert Panel went on to explain the difference between regulatory licensing – in which the CNSC has considerable experience – and assessment: 

… regulation and assessment are two quite distinct functions that require different processes and expertise. Regulatory licensing typically focuses on determining the technical acceptability of a proposed project against the requirements set out in a governing piece of legislation, with a consequent emphasis on technical expertise and a tendency for the regulator and the regulated industry to be in regular contact and discussions. Assessment is a planning process which considers both technical and non-technical matters and engages in public review to select the best options. The scope of assessment is much broader and requires more diverse expertise, especially in consideration of the sustainability approach being proposed by the Panel. (1)

A June 2017 discussion paper outlines the changes to environmental and regulatory reviews being considered by the Government of Canada in response to the Expert Panel’s advice as well as additional inputs to government directly (3).  The Government is proposing that the new agency responsible for impact assessment would jointly conduct impact assessments of nuclear projects with the CNSC.  For non-designated projects the CSNC would continue to have sole decision-making authority, while noting that the Government would review the Regulations Designating Physical Activities.

This proposed sharing of authority between the new agency and the CNSC may be problematic from a procedural standpoint, and may impede the goal to regain public trust in environmental assessment, including of nuclear projects.

A close look at how the CNSC is conducting environmental assessments of three projects involving the permanent disposal of federally-owned radioactive waste is instructive and helps to illustrate why this agency may not be the appropriate responsible authority for environmental assessment of nuclear projects. These three projects are:

1) the so-called “Near Surface Disposal Project” a proposed mound for one million cubic metres of “low level” and long-lived radioactive waste beside the Ottawa River on the property of the Chalk River Laboratories in Chalk River, Ontario;

2) the NPD Closure Project, a controversial “in-situ decommissioning” of the prototype CANDU reactor beside the Ottawa River at Rolphton, Ontario; and 

3) the equally controversial “In Situ Decommissioning of the Whiteshell Reactor #1”, beside the Winnipeg River at Pinawa, Manitoba.

The CNSC allowed these three projects to go forward to the Environmental Assessment stage, despite the fact that all three are clearly at odds with international guidance and do not use best technologies available for responsible management of radioactive wastes. 

The terms “near surface disposal project” and “landfill” have specific meanings in guidance documents developed by the International Atomic Energy Agency (IAEA).  Although the proponent uses the term “Near Surface Disposal Project”, this project would actually involve the permanent disposal of long-lived radionuclides and relatively high activity wastes in an above-ground landfill-type facility.  According to the IAEA, such a facility is only suitable for very low level radioactive waste with “low concentrations or quantities of radioactive content,” “very limited concentrations of longer lived radionuclides,” and which does not need a “high level of containment and isolation”. (4)

Similarly, two “in-situ” reactor decommissioning (or “entombment”) projects appear to violate guidance in IAEA document Decommissioning Strategies for Facilities Using Radioactive Material, which states that “Entombment is not relevant for a facility that contains long lived isotopes because these materials are not suitable for long term surface disposal;” adding that “The disadvantages of entombment include: (a) Unsuitability for facilities with long lived radionuclides; (b) Cost of long term monitoring and institutional controls; (c) Public acceptance of creation of a near surface waste disposal site.” (5)

With regard to the proposed entombment of the Whiteshell Reactor #1, a submission to the CNSC from Dr. Leonard Simpson (Former Mayor of Pinawa and retired AECL Director of Reactor Safety Research) reflects IAEA’s warnings about public acceptance and the cost of institutional controls:

… none of the senior members of the AECL Waste Management Program who are enjoying their retirement in Pinawa were consulted in the preparation of the proposal. The general level of community consultation of the CNL activities has been abysmal in spite of the fact that this is where we live and are expected to support an entombed site under institutional control effectively for ever. (6)

Concerns about costs were also raised by Dr. Michael Stephens, another former AECL employee at Whiteshell Laboratories: 

The stated objective of the project is to ensure “the prompt reduction of Canada’s long- term nuclear legacy liabilities”. If the entombed reactor is not licensable as a near-surface disposal facility because of the long-lived nuclides or hazardous substances, then this project does not reduce the long-term liabilities – it increases them because it will be more difficult and expensive to retrieve them for disposal later. (7)

Despite these serious criticisms, the CNSC scoping decision for the WR-1 project (which was combined with the decision for the other two other nuclear waste disposal projects) required no changes to the project description. (8)

The CNSC’s scoping of the Near Surface Disposal Project (NSDF) was equally flawed

The combined scoping decision was made nine days before the draft environmental impact statement (EIS) for the NSDF project was released.  The CNSC allowed the proponent to conduct environmental impact studies before the project scope was determined.  The scoping decision ignored many serious criticisms of the NSDF project description.  It was released by a 1-person “Panel” comprised solely of the CNSC President.  The public was not apprised of the “Panel” hearing, which may never have actually taken place.

The CNSC has not ensured sufficient engagement of First Nations 

In response to concerns about the WR-1 decommissioning project raised by The Brokenhead Ojibway Nation, CNSC staff said “The Commission is the CNSC’s decision-making body that makes EA and licensing decisions for all major nuclear projects. Decisions made by the Commission are not subject to any governmental or political review, nor may they be overturned by the Government of Canada.” (9) The CNSC’s “independence” from the Government of Canada is a serious impediment to proper engagement of Aboriginal peoples in the environmental assessment process.

The CNSC did not require the NSDF proponent to translate documents into French, despite a clear potential for adverse environmental impacts in the Province of Quebec

The closest residents to the NSDF project site are in Quebec.  Lack of access to French language documents led to a complaint from a Quebec citizen and a decision by the Commissioner of Official Languages to require translation of the draft EIS.

The CNSC allowed the NSDF proponent to make a major change to the project – elimination of “intermediate” level waste – without requiring revision of the draft EIS.

The proponent, under significant pressure due to highly critical submissions from many individuals and groups, including the Quebec Ministère du Développement durable, de l’Environnement et de la Lutte contre les changements climatiques (10), announced a major change to its plan for the NDSF in October 2018, two months after the closure of the public comment period on the draft EIS. The proposed change renders key parts of the draft EIS inaccurate, including the waste inventory, the waste acceptance criteria, and the assessment of alternative means of carrying out the project. CNSC, while acknowledging this change (11), did not require the proponent to prepare and release a revised draft EIS.  

The CNSC has delayed or refused outright to provide access to documents referenced in the draft EIS for the Near Surface Disposal Project. 

A footnote on page 3-14 of the draft EIS (12) states that “The Safety Analysis Report demonstrates that even after failure of some of the design features, the wastes do not present a risk to the public and environment.”  However, the Safety Analysis Report was not released until after the public comment period on the draft EIS ended.  Key portions of this document (such as section 4.2.1.3 on “Nuclear Criticality Safety”) were redacted. 

CNSC staff are proposing to remove references to CEAA from the licensing documents for the Chalk River Laboratories (CRL).  

The Regulations Designating Physical Activities under CEAA require environmental assessment of new nuclear reactors, new facilities for the long-term management or disposal of nuclear waste, or expansion of existing long-term waste facilities by 50% or more. The current CRL licence handbook (13) says “A determination of the applicability of the CEAA must be made” with regard to i) changes to the CRL site, ii) modifications of existing nuclear facilities, iii) nuclear facilities undergoing decommissioning, and iv) construction of new nuclear facilities.  CNSC staff have removed these references to CEAA from their draft CRL licence handbook for the next licence period (14).

The CNSC’s own “Environmental Assessment” reports, which the agency conducts for non-designated projects, illustrate the agency’s lack of understanding of CEAA. 

The EA report attached to the CNSC staff document prepared for the January 2018 CRL site licence hearing (14) does not even mention the physical activities that the licensee intends to carry out during a 10-year licence period.  These activities include construction of a small modular reactor, construction and operation of a nuclear waste disposal facility, and decommissioning of the NRU reactor and other CRL facilities.  CNSC’s EA report merely describes the current state of the environment at the CRL site.

Conclusion

The CNSC’s performance as responsible authority for environmental assessment of nuclear projects is problematic.  Public interest and public trust may not be well served by allowing the CNSC to continue in this role, nor by assessments conducted “jointly” by the CNSC and a new agency.  Fortunately, an excellent alternative exists, as outlined by the Expert Panel: creation of a new federal authority that would be empowered to decide whether a project would make a positive contribution to Canada’s future well-being and, on that basis, approve or deny a project application.

Questions

For questions 1, 2, 3, 4, 8 and 9 we are seeking responses from the Minister of Environment and Climate Change.  For questions 5 and 9 we are seeking responses from the Minister of Natural Resources. For questions 6 and 9 we are seeking responses from the Minister of Crown-Indigenous Relations and Northern Affairs.  For questions 7 and 9 we are seeking responses from the Minister of Fisheries, Oceans and the Canadian Coast Guard.  For questions 8 and 9 we are seeking responses from the Minister of Science.  We also request that the petition be sent to the Minister of Intergovernmental Affairs as a matter of information.

1) Given the evidence presented here of serious weaknesses in CNSC’s approach to environmental assessment, and the government’s commitment to new, fair environmental assessment processes, would the Minister please explain how she intends to regain public trust in the environmental assessment of nuclear projects?  

2) Noting the Expert Panel recommendation that an independent agency should replace the CNSC as responsible authority for environmental assessment of nuclear projects, why does the June 2017 Environmental and Regulatory Reviews: Discussion Paper propose that the twoagencies jointly conduct impact assessments?  How would this work in procedural terms?  How would project approval decisions be made?  Would the Minister be willing to reconsider this proposal in light of the evidence presented in this petition?

3) As stated in the Expert Panel report, “Assessment is a planning process which considers both technical and non-technical matters.”  What steps will the Minister take to ensure that planning aspects are addressed in environmental assessment?  How does the Minister intend to balance technical and non-technical matters (such as the sustainability approach emphasized by the Panel) in assessing potential impacts of nuclear projects?

4) The Expert Panel expressed the view that “assessment processes must move beyond the bio-physical environment to encompass all impacts likely to result from a project, both positive and negative.”   The Panel added that what is now “environmental assessment” should become “impact assessment”.  What is the Minister’s view on the need for a broader “impact assessment” approach?  Specifically, how should socio-economic considerations be addressed in the assessment of nuclear projects?

5) Your mandate letter calls upon you to work with your Cabinet colleagues to introduce new, fair environmental assessment processes, including to “provide ways for Canadians to express their views and opportunities for experts to meaningfully participate, including provisions to enhance the engagement of Indigenous groups in reviewing and monitoring major resource development projects.”  What actions have you taken, or will you take, in this regard?

6) Your mandate letter calls upon you to collaborate with your Cabinet colleagues “to ensure that environmental assessment legislation is amended to enhance the consultation, engagement, and participatory capacity of Indigenous groups in reviewing and monitoring major resource development projects.”  What actions have you taken, or will you take, in this regard?  Are specific measures needed to enhance the participation of indigenous groups in the assessment of nuclear projects?

7) Your mandate letter calls upon you to collaborate with your Cabinet colleagues to introduce new, fair processes that will, inter alia, restore robust oversight and thorough environmental assessments of areas under federal jurisdiction; ensure that decisions are based on science, facts, and evidence, and serve the public interest; and provide ways for Canadians to express their views and opportunities for experts to meaningfully participate. What actions have you taken, or will you take, in this regard?  

8) What actions have you taken, or will you take, to ensure that environmental assessment decisions are based on science, facts, and evidence?  How can science, facts and evidence be brought to bear in choosing the best technologies available for projects involving the long-term management of nuclear wastes?

9) Noting the apparent deficiencies in the CNSC-led environmental assessments of three projects involving permanent disposal of federally-owned radioactive wastes, how will you ensure that decisions taken regarding these projects serve the public interest?

References

  1. Building Common Ground: A New Vision for Impact Assessment in Canada. The final report of the Expert Panel for the Review of Environmental Assessment Processes. April 2017. https://www.canada.ca/en/services/environment/conservation/assessments/environmental-reviews/environmental-assessment-processes/building-common-ground.html
  2. Minister of Environment and Climate Change Mandate Letter, November 12, 2015.  https://pm.gc.ca/eng/minister-environment-and-climate-change-mandate-letter
  3. Environmental and Regulatory Reviews: Discussion Paper. June 2017. https://www.canada.ca/en/services/environment/conservation/assessments/environmental-reviews/share-your-views/proposed-approach/discussion-paper.html
  4. Disposal of Radioactive Waste. Specific Safety Requirements No. SSR-5.  International Atomic Energy Agency, Vienna.  2011.  http://www-pub.iaea.org/MTCD/publications/PDF/Pub1449_web.pdf
  5. Decommissioning Strategies for Facilities Using Radioactive Material. Safety Report Series #50. International Atomic Energy Agency, Vienna. 2007.  http://www-pub.iaea.org/MTCD/Publications/PDF/Pub1281_web.pdf
  6. CNL’s Proposal for WR1. Leonard Simpson. July 3, 2016.  http://www.ceaa-acee.gc.ca/050/documents/p80124/114864E.pdf
  7. Comments on the “Project Description for the in Situ Decommissioning of the WR-1 Reactor at the Whiteshell Laboratories Site”. Michael Stephens. June 30, 2016.  http://www.ceaa-acee.gc.ca/050/documents/p80124/114855E.pdf
  8. Decision on the Scope of Environmental Assessments for Three Proposed Projects at Existing Canadian Nuclear Laboratories’ Facilities.  CNSC.  March 8, 2017.  http://suretenucleaire.gc.ca/eng/the-commission/pdf/Record of Decision – CNL Scope of EA Factors 2017.pdf
  9. Disposition Table of Public and Aboriginal Groups’ Comments on Project Description – In Situ Decommissioning of Whiteshell Reactor #1 Project.  CNSC.  March 8, 2017. http://www.ceaa-acee.gc.ca/050/documents/p80124/118863E.pdf
  10. Questions et commentaires sur le projet d’une installation de gestion des déchets près de la surface sur le territoire des Laboratoires de Chalk River en Ontario proposé par les Laboratoires nucléaires canadiens. Ministère du Développement durable, de l’Environnement et de la Lutte contre les changements climatiques.  September 15, 2017. http://www.ceaa-acee.gc.ca/050/documents/p80122/120514F.pdf
  11. Near Surface Disposal Facility – Recharacterization of Waste. November 2, 2017.  http://www.ceaa.gc.ca/050/document-eng.cfm?document=120908
  12. Near Surface Disposal Facility Environmental Impact Statement.  Canadian Nuclear Laboratories. March 17, 2017.  http://www.ceaa-acee.gc.ca/050/documents/p80122/118380E.pdf
  13. Licence Conditions Handbook for Chalk River Laboratories(CRL Handbook).  CNSC e-Doc 4937963.  December 12, 2016.
  14. A Licence Renewal.  Canadian Nuclear Laboratories.  Chalk River Laboratories.  CNSC CMD 18-H2. http://nuclearsafety.gc.ca/eng/the-commission/hearings/cmd/pdf/CMD18-H2-SubmissionfromCNSCStaffforCRLLicenceRenewalJanuary2018.pdf

Press conference on Parliament Hill to highlight concerns about Chalk River relicensing hearings

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Norm Odjick, Director General, The Algonquin Anishinabeg Nation Tribal Council

Grand Council Chief Patrick Wedaseh Madahbee Anishinabek Nation

Patrick Nadeau, Executive Director, Ottawa Riverkeeper

Lynn Jones, Concerned Citizens of Renfrew County and Area

Réal Lalande, Stop Oléoduc Outaouais / Ralliement contre la pollution radioactive (RCPR)

 

Letter to the Editor – Proposed new site license for Chalk River raises serious concerns

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Dear Editor,
RE: the upcoming public hearing into renewal of the site license for the Chalk River Laboratories, which is operated by Canadian Nuclear Laboratories, a private multinational consortium, under contract with the government of Canada.
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

 

Government must act to prevent mismanagement of radioactive waste

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Open Letter To:

The Honourable Justin Trudeau, Minister of Intergovernmental Affairs and Youth

The Honourable Carolyn Bennett, Minister of Crown-Indigenous Relations and Northern Affairs

The Honourable James Carr, Minister of Natural Resources

The Honourable Catherine McKenna, Minister of Environment and Climate Change

 

Dear Justin Trudeau, Carolyn Bennett, James Carr and Catherine McKenna,

 

We learned recently that the Canadian Nuclear Safety Commission is proposing massive changes to the license for the Chalk River Laboratories, site of a proposed radioactive megadump, including removal of 28 conditions of the license itself and removal of several hundred “compliance verification criteria”. We are appalled at this radical move toward deregulation to benefit the multinational consortium, Canadian National Energy Alliance, whose Canadian partner, SNC Lavalin, is currently debarred from the World Bank for ten years and facing criminal charges in Canada for fraud, bribery and corruption.

 

Our two groups along with First Nations, scientists, municipalities, individuals, and the Quebec Ministry of Environment and Sustainable Development are very concerned about the consortium’s plan to emplace and eventually abandon one million cubic meters of radioactive wastes in a giant mound on the side of a hill, next to a swamp, less than one kilometer from the Ottawa River at Chalk River, Ontario in unceded traditional Algonquin territory. As we and many others have stated, in comments on the environmental assessment for this misleadingly named “Near Surface” Disposal Facility, the proposed giant mound flouts international guidance, would exceed public dose limits for radiation for 100,000+ years and would contaminate the Ottawa River, Canada’s most recently designated Heritage River, which provides drinking water for millions of Canadians downstream all the way to Montreal.

 

We and many others believe that the Canadian Nuclear Safety Commission should not have decision-making authority for the environmental assessment of this or any other nuclear project.  We concur with the Expert Panel on environmental assessment reform, the final report of which reflects the widely held view that CNSC is a captured regulator with no independence from the industry it regulates. We note that House of Commons e-petition 1220 requesting suspension of the environmental assessment for the Chalk River megadump and replacement of CNSC as decision maker for nuclear projects has been signed by more than 2,000 Canadians from coast to coast to coast in all ten provinces and three territories.

 

We are also very concerned by the Auditor General report that Atomic Energy of Canada Limited, owner of the Chalk River Laboratories and other federal nuclear facilities, has experienced a “significant deficiency in board renewal”, has “not met its statutory obligation to hold public meetings” since 2009, and lacks “a formal, systematic process for monitoring and reporting on risks” among its facilities.

 

Legal experts we have consulted have stated that CNSC’s proposed changes to the Chalk River site license would greatly reduce CNSC oversight and render important safety requirements unenforceable. For example, the following license conditions are among those planned for removal:

 

  • 4.2 New Nuclear Facilities: The licensee shall only carry out construction and/or operation activities of any new nuclear facility at the CRL site with the prior approval of the Commission. [GONE!]
  • 4.4 Nuclear Facilities Undergoing Decommissioning Activities. The licensee shall only decommission a nuclear facility, or any part thereof, at the CRL site in accordance with documented decommissioning plan(s) and procedures, and with the prior approval of the Commission to proceed with the decommissioning.[GONE!]
  • 12.3 Nuclear Legacy Liabilities The licensee shall ensure that nuclear legacy liabilities at the CRL site are addressed. [GONE!]

 

We believe this radical move towards deregulation must be stopped immediately. CNSC’s proposal appears to confirm the widely held view that Canada’s nuclear regulator is more interested in supporting the nuclear industry than in protecting health and the environment, its primary mandate under the Nuclear Safety and Control Act.

 

The Government of Canada urgently needs to overhaul nuclear governance in this country to ensure responsible handling of radioactive waste. Consultations with the public and First Nations must be an essential part of this process.

 

Yours sincerely,

 

Lynn Jones, Concerned Citizens of Renfrew County and Area

Johanna Echlin, Old Fort William (Quebec) Cottagers’ Association

 

cc

Perry Bellegarde, Chief of the Assembly of First Nations

Verna Polson, Grand Chief, Algonquin Anishinabeg Nation Tribal Council

Kirby Whiteduck, Chief, Algonquins of Pikwakanagan First Nation

Jean Guy Whiteduck, Chief Kitigan Zibi Anishinabeg

Patrick Madahbee, Grand Chief of the Anishinabek Nation

Joe Norton, Grand Chief, Mohawk Council of Kahnawake, on behalf of the Iroquois   Caucus

Margaret Froh, President, Metis Nation of Ontario

Michael Binder, President, Canadian Nuclear Safety Commission

Ginette Petitpas Taylor, Minister of Health

Kirsty Duncan, Minister of Science

Mélanie Joly, Minster of Canadian Heritage

Mona Nemer, Chief Science Advisor

Elizabeth May, Green Party Leader

Martine Ouellet, Bloc Quebecois Leader

Jagmeet Singh, NDP Leader

Andrew Scheer, Conservative Party Leader

Monique Pauze, Bloc Environment Critic

Linda Duncan, NDP Environment Critic

Ed Fast, Conservative Environment Critic

Stéphane Bergeron, MNA for Verchères

David McGuinty, MP for Ottawa South

Greg Fergus, MP for Hull-Aylmer

Will Amos, MP for Pontiac

Karen McKrimmon, MP for Kanata-Carleton

Cheryl Gallant, MP for Renfrew-Nipissing-Pembroke

Jim Watson, Mayor of Ottawa

Valérie Plante, Mayor of Montreal

Isabelle Melançon, Quebec Environment Minister

Sylvain Gaudreault, Environment Critic, Quebec National Assembly

Sylvain Rochon, Natural Resources Critic, Quebec National Assembly

Marc Demers, Mayor of Laval

Maxime Pedneaud-Jobin, Mayor of Gatineau

Bob Sweet, Mayor of Petawawa

Joan Lougheed, Mayor of Deep River

Mike LeMay, Mayor of Pembroke

Kathleen Wynne, Premier of Ontario

Phillippe Couillard, Premier of Quebec

Jennifer Murphy, Warden of Renfrew County

Jane Toller, Warden of Pontiac County

Chris Ballard, Ontario Minister of Environment and Climate Change

Kathryn McGarry, Ontario Minister of Natural Resources and Forestry

Julie Gelfand, Commissioner of Environment and Sustainable Development

 

Canadian Nuclear Safety Commission plans massive changes to Chalk River site license

hendricksonjones 2 Comments

Canada’s nuclear regulator, the Canadian Nuclear Safety Commission (CNSC), is proposing sweeping changes to the current Chalk River site licence, site of the proposed radioactive megadump.  These changes include extending the licence period to ten years, allowing construction of new facilities or decommissioning of old facilities without Commission approval, weakening decommissioning requirements to enable bulk demolition, deleting language requiring the licensee to “control, monitor and record releases” of radioactive nuclear and hazardous substances, and deleting the current requirement for site-wide groundwater monitoring.

See details on the proposed changes:

Planned changes to the site license for Chalk River Laboratories

Planned changes to the License Condition Handbook

 

Multinational consortium yields to public pressure on nuclear dump plan

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(Ottawa, October 30, 2017) The multinational consortium running Canadian Nuclear Laboratories (CNL) and managing Canada’s federally-owned radioactive waste announced on Thursday (October 26th) that it will remove intermediate-level waste, which requires remote handling, from its plans for a giant radioactive mound beside the Ottawa River at Chalk River, Ontario.

Citizens’ groups who have been working for months to sound the alarm about the CNL proposal hailed the announcement as a partial victory. Over 200 submissions, most highly critical, were sent to the Canadian Nuclear Safety Commission during the public comment period for the project’s environmental impact study that ended in August.

CNL said in a press release October 26th that it was responding to comments from the public and the Canadian Nuclear Safety Commission, and that wastes intended for disposal in the proposed facility will meet guidelines for low level radioactive waste set out by the International Atomic Energy Agency (IAEA).

“We are pleased that our concerns are being heard,” said Johanna Echlin of the Old Fort William Cottagers’ Association, based in Sheenboro Quebec. “We said from the start that the facility should not contain “intermediate level” waste which is supposed to be disposed of in underground caverns according to the IAEA.”

There is still a long way to go before the proposal could be considered acceptable, according to Echlin. She notes that even “low level” radioactive waste is not supposed to be disposed of on top of the ground in a mound according to the IAEA. “It’s only common sense”, says Echlin. “You don’t have to be a rocket scientist or nuclear engineer to understand that radioactive waste should not be placed on plastic liners that will deteriorate long before the waste becomes harmless.”

“Low-level” waste is a misnomer that causes a lot of confusion, according to Dr. Ole Hendrickson of Concerned Citizens of Renfrew County and Area. “Low-level” waste is so named because it can be handled without using robots or special shielding, unlike used nuclear fuel rods which can provide a fatal dose of radiation within seconds to a person standing a few feet away.

“Low-level” radioactive waste can contain very hazardous materials, says Hendrickson. “Man-made isotopes such as plutonium, neptunium, and americium have extremely long half lives. They are highly toxic and will be around for thousands of years. Yet significant quantities are destined for this facility if it gets approved.”

Citizens groups say the proposed technology, an “engineered mound” similar to a municipal landfill, is not acceptable. They would like to see a “state-of-the-art” facility that would keep the radioactive materials out of the air and water for as long as they remain harmful, which could be longer than 100,000 years.  Facilities currently under construction in Finland and France which utilize engineered caverns in stable rock, tens of metres below the surface, would be much safer and could serve as an example for a new Canadian facility.

Dump opponents are also concerned about the site for the facility. “You couldn’t choose a worse site for this dump if you tried,” according to Echlin, “on the side of a hill, that would have to be deforested, and smack in the middle of a wetland that drains into the Ottawa River only a kilometre away”.

Proximity to the river is causing worry about possible contamination of drinking water since the Ottawa River is a drinking water source for millions of Canadians downstream of Chalk River in cities such as Ottawa-Gatineau and Montreal.

Ole Hendrickson of the CCRCA notes that siting was not done according to IAEA guidance that calls for a site that can ensure the environment will be adequately protected during the entire lifetime of the facility. “CNL should explore the 70,000 acres of federal land adjacent to the Chalk River Labs property to find a more suitable location,” Hendrickson said. “With a better location, away from the river and in stable rock, we could all get behind this project and build a facility that Canada can be proud of,” he added.

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Canada setting a terrible example for nuclear decommissioning, citizens’ groups say

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(Ottawa, October 4, 2017) Experts from around the world are meeting in Ottawa this week, October 3-5, to discuss decommissioning and dismantling of nuclear facilities.  Delegates to the meeting of the Nuclear Energy Agency’s Working Party on Decommissioning and Dismantling, cohosted by the Canadian Nuclear Safety Commission (CNSC) and Natural Resources Canada (NRCan) will exchange information about decommissioning policy, strategy and regulations.

Responding to promotional material for the upcoming meeting, Citizens’ groups were quick to point out that Canada is an excellent place to come to see examples of how not to do decommissioning.

Three badly-flawed decommissioning projects are currently on the table in Canada: the widely criticized proposal to construct a giant radioactive landfill at Chalk River, Ontario, and two proposals for “entombment” of old reactor facilities, one on the Winnipeg River and the other on the Ottawa River at Rolphton, Ontario.  According to the International Atomic Energy Agency, “entombment” is only supposed to be employed in exceptional circumstances such as after a severe accident. “Entombment” and above-ground landfilling of long-lived radioactive wastes are being promoted by Canadian Nuclear Laboratories (CNL), a multinational consortium contracted by the previous Conservative government to cut costs for nuclear decommissioning in Canada.

Retired scientists and citizens have slammed CNL’s three proposals for being unsafe, irresponsible, and badly out of sync with international guidance and best practices.

“There is great irony in the hosting of this meeting by CNSC and NRCan, since there is a virtual absence in Canada of polices and strategies for wastes arising from decommissioning” according to Dr. Ole Hendrickson, researcher for the group Concerned Citizens of Renfrew County and Area. On September 21, 2017, Concerned Citizens along with the Canadian Environmental Law Association submitted a petition to the Auditor-General on gaps in policies and strategies for dealing with non-fuel, post-fission radioactive wastes, which are the main challenge in decommissioning nuclear facilities.

A letter sent to Prime Minister Trudeau last month by Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility, also called attention to Canada’s sloppy handling of non-fuel, post fission radioactive wastes. “The absence of any policies or strategies for dealing with these wastes, many of which will be hazardous for more than 100,000 years is a serious problem”, said Edwards. “This must be addressed as soon as possible in consultation with the Canadian public and aboriginal groups.” Edwards’ letter was co-signed by 35 leaders of organizations and First Nations in Canada.

Co-host of this week’s international meeting, the Canadian Nuclear Safety Commission, is presently embattled in its dual role as regulator and environmental assessment (EA) authority for the aforementioned decommissioning proposals from Canadian Nuclear Laboratories, all three of which have set alarm bells ringing and elicited serious criticism from retired scientists, citizens’ groups and First Nations.

A petition to the government of Canada, House of Commons e-petition 1220, asks the government to suspend the EA’s of the three decommissioning projects and strip the CNSC of its decision-making role in environmental assessment as recommended by the Expert Panel on EA reform in April of this year. The Expert Panel noted that the CNSC is not sufficiently independent of the industry it regulates to be responsible for EA decisions about nuclear projects. The e-petition has been signed by Canadians from ten provinces and two territories.

Johanna Echlin of the Old Fort William (Quebec) Cottagers’ Association notes that nuclear decommissioning is faltering badly in Canada at present. “The take-away message for international delegates to this meeting is clear”, said Echlin. “Do not do what Canada has done and hand control of decommissioning and radioactive waste to a multinational private sector consortium, in the absence of policies and strategies that ensure safety. This has been a disaster for us”.

A visit to Chalk River Laboratories, site of the giant proposed radioactive landfill, is on the agenda for the visiting international delegates. “I hope their eyes are wide open and they will not be fooled by this proposed quick, cheap and dirty fix to Canada’s non-fuel radioactive waste” said Echlin.  “Our international guests must know that an above ground landfill is only acceptable for very low-level radioactive waste and entirely inadequate for wastes that will endure for a hundred thousand years”, she added. “The proposed Chalk River mound would contaminate the Ottawa River and drinking water for millions of Canadians downstream for millennia. This is a terrible example to set for the world.”

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