Algonquin First Nations oppose giant radioactive waste mound beside the Ottawa River on their unceded territory
OTTAWA, June 20, 2023 — Today Chiefs of two Algonquin First Nations and the Grand Chiefs of the Algonquin Anishinabeg Nation Tribal Council (AANTC) and the Algonquin Nation Secretariat (ANS) – representing 10 of the 11 Algonquin First Nations – called on the federal government to abandon the current plan for a massive, aboveground radioactive waste dump on unceded Algonquin territory near the Ottawa River or Kichi Sibi. The chiefs were joined by Elizabeth May, Leader of the Green Party of Canada and MP for Saanich-Gulf Islands, who strongly urged the government to respect Indigenous Rights in its dealings with Algonquin First Nations.
The Chiefs of Kebaowek and Kitigan Zibi Anishinabeg First Nations made public their Indigenous-led assessment of the radioactive waste proposal and the project’s impact on their culture, land, water and wildlife.
“The Kichi Sibi is sacred to our peoples and at the heart of our unceded homeland,” said Chief Lance Haymond, of Kebaowek First Nation. “The Algonquin peoples never consented to the Chalk River site being used for over 75 years for nuclear reactors and research, and now being the site for a permanent radioactive waste dump. Consultation was far too late and inadequate, and we reject the plan.”
Algonquin Nations will present their conclusions about the Near Surface Disposal Facility (NSDF) to a hearing of the Canadian Nuclear Safety Commission (CNSC) on August 10. Chief Haymond and Chief Dylan Whiteduck of Kitigan Zibi Anishinabeg First Nation say the CNSC has failed to fulfill the duty to consult. Consultation occurred too late in the process, and CNSC’s staff treated the NSDF as a foregone conclusion.
Both Chiefs point to Article 29(2) of the UN Declaration on the Rights of Indigenous Peoples, to which Canada is a signatory, and which says there must be free, prior and informed consent by First Nations to storage or disposal of radioactive waste on their lands or territories.
“We have found very severe potential impacts to our Indigenous rights and interests from the radioactive waste mound,” said Chief Whiteduck. “To have any meaning, the consultation has to start back from the very beginning of project planning. Meaningful consultation will have to allow Kitigan Zibi Anishinabeg free, prior, and informed consent.”
He added that the First Nations are very concerned about the location of the proposed facility, and no justification was offered for putting a radioactive waste facility so close to the Kichi Sibi. “We have received no satisfactory explanation for why other sites well away from the river were not considered.”
According to Grand Chief Savanna McGregor of the AANTC, representing seven Algonquin First Nations, “The radioactive waste dump plan follows a long history of assimilation and oppression since European arrival. We have faced intergenerational trauma, displacement from our unceded territory, and historical exclusion from decision-making at the Chalk River Laboratories site.”
“As leaders and as people here today, it is our responsibility to preserve and protect Mother Earth for future generations. We cannot risk the destruction of land and water, which sustains life for all beings,” said Grand Chief Lisa Robinson of the ANS, who is also Chief of Wolf Lake First Nation.
ADDITIONAL QUOTES:
“When it comes to respecting UNDRIP and its requirement for ‘free, prior and informed consent,’ governments at all levels prefer to coerce and bribe Indigenous peoples. Indigenous concerns are only honoured when they are consistent with the government’s plans. On behalf of the Green Party of Canada, we call on the federal government to respect the calls from the Algonquin Anishinabeg Nation Tribal Council and the Algonquin Nation Secretariat to reject a toxic radioactive waste site on the Ottawa River.” – Elizabeth May, Leader of the Green Party of Canada and MP for Saanich-Gulf Islands
“The Canadian Coalition for Nuclear Responsibility does not presume to speak on behalf of Indigenous peoples, but as Canadian citizens we wish to state clearly and unequivocally that if CNSC approves the NSDF despite the lack of free, prior and informed consent from the Kebaowek and Kitigan Zibi First Nations, we will consider this act as one that dishonours Canada and all Canadians.” – Dr. Gordon Edwards, President, Canadian Coalition for Nuclear Responsibility
“The NSDF would fail to meet the most basic requirement for a radioactive waste facility — to contain and isolate waste. We greatly appreciate the stand taken by Kebaowek and Kitigan Zibi First Nations to protect their land and water for the good of all life in the Ottawa River watershed.” – Dr. Ole Hendrickson, President, Ottawa River Institute, and Researcher, Concerned Citizens of Renfrew County and Area
“We are asking all allies to show their support for free, prior and informed consent by the Algonquin Peoples in the coming weeks. This is just the latest example of a history of colonialism and lack of consent for development on Indigenous lands.” – Vi Bui, Regional Organizer, Council of Canadians
The final written submissions from Kebaowek First Nation and Kitigan Zibi outline serious concerns about the effects the radioactive waste dump will have on Kichi Sibi (the Ottawa River), future generations and Indigenous rights.
Meaningful consultation with the Algonquin First Nations has been lacking since the environmental assessment for the project was first announced in 2016.
The NSDF would leak radioactive and hazardous materials into a nearby wetland and the Ottawa River during operation and after closure. It is expected to eventually disintegrate through a process of “normal evolution.” It could also contaminate the river through the effects of earthquakes, wildfires, flooding and extreme weather events. Not only is the Kichi Sibi sacred to the Algonquin peoples, the Chalk River site is also near Algonquin sacred sites at Oiseau Rock and Pointe au Baptême.
In 2017 the Assembly of First Nations passed a resolution stating that the CNSC and Canadian government had failed their constitutional duty to consult and accommodate First Nations with respect to the NSDF. The Anishinabek Nation and Iroquois Caucus made a Radioactive Waste Joint Declaration stating that “we need to protect the lands, waters and all living things for future generations” and calling for no abandonment of radioactive wastes, keeping them away from major water bodies, and no imports or exports of radioactive waste.
In addition to the Algonquin First Nations’ opposition to the project, more than 140 Quebec and Ontario municipalities, including Gatineau and Montreal, and other civil society voices oppose the NSDF plan, while the City of Ottawa passed a resolution of concern in 2021.
NOTE: Kebaowek and Kitigan Zibi’s Indigenous NSDF Assessment and final submission can be found here: http://www.kebaowek.ca/NSDF.html
Two Algonquin First Nations, Kebaowek First Nation (KFN) and Kitigan Zibi Anishinabeg (KZA), are opposed to the giant nuclear waste dump (NSDF) and have not given their consent. Their joint final submission says:
the duty to consult has not been fulfilled;
there is insufficient information to assess the NSDF’s environmental effects or, in the alternative, the NSDF is likely to cause significant adverse environmental effects and the question of whether the adverse environmental effects are justified in the circumstance must be referred to the Lieutenant [an error] Governor in Council as required under the Canadian Environmental Assessment Act, 2012 (“CEAA 2012”);
there is insufficient information to determine that CNL will “make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed”, as required under the Nuclear Safety and Control Act (“NSCA”); and
approving this project would violate the United Nations Declaration on Rights of Indigenous People (“UNDRIP”), which is a universal human rights instrument with application in Canadian law.
The Algonquins of Pikwakanagan First Nation (AOPFN) have given their consent to construction of the “NSDF” radioactive waste dump at the Chalk River Laboratories on the Ottawa River. Pikwakanagan is situated on the shores of Golden Lake and the Bonnechere River in Renfrew County, Ontario.
“Since 2020, AECL and CNL have participated in extensive engagements with the AOPFN. As a direct result of this process, CNL has made improvements to the project to address concerns raised through these engagements. With those changes in place and other AOPFN conditions and commitments met by CNL, the organizations have reached agreement on the NSDF project, and the AOPFN will provide its consent to CNL and the Canadian Nuclear Safety Commission (CNSC) to move forward with the construction of the proposed facility. “[emphasis added]
The CNL announcement says “The agreement “resolves and addresses key areas of concern identified by the AOPFN, including environmental protection, radioactive waste management, cultural protection and promotion, and, the pursuit of collaborative economic and business opportunities.” It quotes Pikwakanagan Chief Greg Sarazin as saying “this agreement is the best path forward as we seek to protect mother earth and ensure the safety of future generations.”
In public hearings in June 2022, five Algonquin First Nations, including KFN, KZA and AOPFN told the Canadian Nuclear Safety Commission that they did not consent to the licensing of the NSDF and hadn’t been adequately consulted.
KFN and KZA will speak at a final (virtual only) CNSC hearing on the NSDF Project. The hearing was recently rescheduled from June 27 to August 10. It is unclear if AOPFN will also speak at the hearing.
A key takeaway from this briefer is that because they use unenriched uranium as fuel, Canadian nuclear reactors produce roughly ten times more radioactive waste per unit electricity generated, than US nuclear reactors.
Background: In 2017, civil society groups were trying to understand how three irresponsible radioactive waste projects (the giant Chalk River mound and two legacy reactor entombments), could be undergoing environmental assessment in Canada. The lack of a substantive federal radioactive waste policy was noted as a serious problem that had allowed the projects to proceed. The policy vacuum was brought to the attention of the IAEA, the Prime Minister, the Auditor General and many other Canadian officials. In September 2019, an international peer review team from IAEA flagged Canada’s lack of a radioactive waste policy as a serious problem. In response, Natural Resources Canada began a review process which took place from 2020 to 2023. The review included extensive involvement from civil society groups and concerned individuals across Canada. The new policy, released in March 2023, is a huge disappointment to many people who, in good faith, worked hard to provide many valuable suggestions only to find their input virtually ignored by the captured bodies (CNSC and NRCan) that developed the policy. In the words of our Quebec colleagues at Ralliement contre la pollution radioactive, the policy is “a fiasco and a slap in the face to democracy.” What follows is a detailed analysis of the many serious failings of Canada’s new “modernized” radioactive waste policy.
***
Natural Resources Canada (NRCan) uses “ensure” in its various forms 28 times in the final version of its new radioactive waste policy, up from 14 times in the draft.
Use of “ensure” in a policy context represents an empty promise – a promise that is not associated with any specific action and that lacks a verifiable, measurable, time-bound target. Reliance on such language indicates an intent to avoid further discussion.
For example, NRCan’s claim that Canada could “ensure nuclear non-proliferation” if plutonium reprocessing were to be allowed (and plutonium-fueled reactors were to be exported to other countries) demonstrates the policy’s superficial and specious nature.
The closest thing to a target in the policy is found in one of the “vision” statements:
By 2050, key elements of Canada’s radioactive waste disposal infrastructure are in place, and planning is well under way for the remaining facilities necessary to accommodate all of Canada’s current and future radioactive wastes.
This begs the questions, “What are those “key elements?” and “What are the remaining facilities?” To achieve this rather weak and vague vision:
The federal government accordingly ensures… that responsibility for maintaining institutional controls over the long term, including the preservation of records and knowledge management of radioactive wastes, is assigned, in an open and transparent manner, to an appropriate entity.
It appears that the federal government is unprepared to accept responsibility at this time for managing radioactive waste, even the waste that it has generated. The federal government created the nuclear industry and generated a massive (~ $16 billion) waste liability through R&D work carried out by the crown corporation Atomic Energy of Canada Limited (AECL) over the past 75 years. AECL continues to receive annual appropriations exceeding a billion dollars.
The policy only promises that at some indefinite time in the future the government will “ensure” that an “appropriate entity” is created to maintain institutional controls over the long term. This side-steps the key issue of governance. A public entity to oversee radioactive waste management is urgently needed. Hundreds of submissions on the draft policy called for the government to establish an independent oversight body now.
Although the policy gives the nuclear industry free rein in managing its waste, with no oversight, it assigns no real responsibility to the industry, either. It calls upon the industry to develop “conceptual approaches” and to submit an “Integrated Strategy for Canada’s radioactive waste to the federal government for review and consideration.”
An International Atomic Energy Agency (IAEA) report prompted the government to undertake a radioactive waste policy review. The IAEA specifically recommended that the government “enhance” the principles contained in its previous Radioactive Waste Policy Framework. The most important principle was “polluter pays”:
The waste producers and owners are responsible, in accordance with the principle of “polluter pays”, for the funding, organization, management and operation of disposal and other facilities required for their wastes.
Rather than being enhanced, this principle was deleted from the new policy. This opens the door to subsidies from the federal government for management of radioactive wastes produced by non-federal entities.
The policy lacks acceptable language regarding assessment of radioactive waste management facilities. NRCan rejected the following civil society proposal:
Amend the Physical Activities Regulations under the Impact Assessment Act to include construction and operation of new nuclear reactors, decommissioning of nuclear reactors, and all phases in the development, operation and closure of long-term waste management facilities.
Instead, NRCan said:
The Policy recognizes and is aligned with federal legislation, particularly the Nuclear Safety and Control Act, the Impact Assessment Act and the Nuclear Fuel Waste Act, as well as other legislation, associated regulations, and other policy tools that further support radioactive waste management,
adding that
These policy tools are regularly reviewed and updated by the federal government, as required, to ensure they remain relevant and effective.
This is a dubious claim, given that the government had not reviewed or updated the previous waste policy “framework” for 27 years, and has not reviewed or updated the Nuclear Safety and Control Act for 26 years.
Stating that the new policy “is aligned with” the Impact Assessment Act fails to mention that the Physical Activities Regulations under this Act exempt decommissioning of reactors and other nuclear facilities, new radioactive waste storage facilities, fuel waste reprocessing facilities with an annual production capacity of less than 100 tonnes of plutonium per year, and construction and operation of small modular reactors (and management of their wastes).
Hence, nearly all major nuclear activities are exempted from assessment.
Most current nuclear decommissioning activities are occurring on federal lands owned by AECL. In theory, impact assessment is required for all projects occurring on federal lands under section 82 of the Impact Assessment Act.
AECL, despite being a federal authority under the Act, ignores decommissioning projects, and delegates the determination of the significance of other waste-related activities (such as a new intermediate-level waste storage facility) to its private contractor, Canadian Nuclear Laboratories. This is not allowed under the Act.
With regard to health, safety and environmental aspects of radioactive waste management, NRCan rejected the following civil society suggestions on the policy draft:
Radioactive waste will be contained and monitored to ensure it remains isolated from the accessible biosphere for the time frame relevant to the category of waste;” and “Prioritize the health, safety and security of people and the environment by requiring that radioactive wastes are kept contained and isolated from the biosphere.”
These suggestions were based on the International Atomic Energy Agency (IAEA) safety standard for radioactive waste disposal. The IAEA says:
The specific aims of disposal are:
(a) To contain the waste;
(b) To isolate the waste from the accessible biosphere and to reduce substantially the likelihood of, and all possible consequences of, inadvertent human intrusion into the waste;
(c) To inhibit, reduce and delay the migration of radionuclides at any time from the waste to the accessible biosphere;
(d) To ensure that the amounts of radionuclides reaching the accessible biosphere due to any migration from the disposal facility are such that possible radiological consequences are acceptably low at all times.
The new policy does not contain the words “biosphere”, “isolation”, “migration” or “intrusion”, instead substituting vague phrases such as “ensure protection of the environment”. The policy’s failure to commit to isolating waste from the biosphere allows the nuclear industry to use the environment – particularly water bodies – as a way of diluting and disposing of its radioactive waste.
The policy’s failure to commit to isolating waste from the biosphere allows the nuclear industry to use the environment – particularly water bodies – as a way of diluting and disposing of its radioactive waste.
Dilution is the strategy employed by the “NSDF project”, announced by a consortium of multinational companies immediately after the Harper government contracted them to deal with the 75-year accumulation of radioactive waste at AECL’s nuclear sites across Canada. The NSDF would be Canada’s first permanent disposal facility for radioactive waste from nuclear reactors – a million-cubic-meter mound of waste next to the Ottawa River, including a pipeline that would discharge partially-treated leachate from the mound into a lake that drains into the river. It would set a terrible precedent for future facilities.
First Nations have expressed serious concerns about the NSDF project and two other permanent disposal projects that involve entombing AECL prototype reactors in concrete and grout and abandoning them next to the Ottawa and Winnipeg Rivers.
After the public comment period on the draft policy, a new section was added entitled “Canada’s commitment towards building partnerships and advancing reconciliation with Indigenous peoples.” It calls for “early, continuous and meaningful engagement” in future radioactive waste projects. However, the policy is silent on the question of whether the current disposal projects – announced without that early engagement – could be approved without the free, prior and informed consent of First Nations. Nor does the new policy commit to First Nations “consent” for future projects.
Another new section, entitled “Scope of the Policy,” adds confusion about reprocessing and fails to address Canada’s experimental work with plutonium fuels. The language on reprocessing says:
Reprocessing, the purpose of which would be to extract fissile material from nuclear fuel waste for further use, is not presently employed in Canada, and so is outside the scope of this Policy.
However, the federally-owned Recycle Fuel Fabrication Laboratories have been conducting plutonium fuel research for many years. Furthermore the government has given a private company $50.5 million to develop a commercial reprocessing facility under the guise of waste “recycling”.
Despite thousands of letters requesting a ban on plutonium reprocessing in the policy and noting the dangers of this technology for nuclear weapons proliferation, the word “plutonium” appears nowhere. Claiming that reprocessing is “outside the scope” of a radioactive waste policy is irresponsible. Furthermore, a new phrase in section 1.7 of the final policy encourages “recycling and reuse of materials.” This could be read as promoting “recycling” of used fuel to extract plutonium.
Also highly problematic is the following phrase in the new policy:
The government of Canada remains deeply committed to the 1970 Treaty on the Non-Proliferation of Nuclear Weapons (NPT), which remains the only legally binding global treaty promoting nuclear non-proliferation and disarmament.
The Treaty on the Prohibition of Nuclear Weapons (TPNW) entered into force on 22 January 2021. State Parties to this treaty “undertake never under any circumstances to… Develop, test, produce, manufacture, otherwise acquire, possess or stockpile nuclear weapons or other nuclear explosive devices.”
While Canada may refuse to acknowledge the existence of the TPNW, this does not alter the fact that the international community has acted to ban nuclear weapons.
The section on “Scope of the Policy” also contains contradictory and confusing wording on naturally occurring radioactive material (NORM). The IAEA says NORM is “Radioactive material containing no significant amounts of radionuclides other than naturally occurring radionuclides.” The IAEA definition explicitly includes “Material in which the activity concentrations of the naturally occurring radionuclides have been changed by a process.”
In contrast, the new policy defines NORM as “material found in the environment that contains radioactive elements of natural origin.” This would appear to exclude from the policy the waste that is created when NORM is extracted from the environment and then processed.
The CNSC regulates many facilities that process NORM (using the internationally agreed definition): uranium mines, Cameco’s processing facilities in Blind River and Port Hope, fuel fabrication facilities, etc. The new policy also says:
“this Policy does not address NORM other than those associated with the development, production or use of nuclear energy or technologies and those associated with the transport and import/export of nuclear substances.”
This statement is both grammatically incorrect (NORM refers to “material”, not “materials”) and does not adequately address the contradiction inherent in defining NORM in a manner that excludes the many processing activities occurring in Canada, and the wastes they generate.
The terms “process” and “processing” appear nowhere in the policy. Even the word “uranium” is absent from the policy, further illustrating the superficial nature of the new policy.
Also problematic is the reference to “an independent nuclear regulator that makes decisions using inclusive, open, and transparent public hearings.” Self-serving promotion of the Canadian Nuclear Safety Commission does not belong in a radioactive waste policy. Claims of transparency and openness do not match reality. The real issue is that the CNSC invariably dismisses public input in making its decisions.
Public input has also been dismissed in this new policy. It reads as if it was written by the CNSC, which may be true. The CNSC is widely considered to be completely “captured” by the nuclear industry, with a revolving door between CNSC, the nuclear industry, and Natural Resources Canada.
The policy rejects the demand by civil society organizations for a ban on imports of radioactive waste from other countries. It says that the federal government:
is committed to the principle that radioactive waste generated in other countries are [sic] not to be disposed of in Canada and radioactive waste generated in Canada will be disposed of in Canada, with the exception of certain radioactive wastes subject to return arrangements.
The policy lists as exceptions the “repatriation of disused sources to Canada.” It adds that “radioactive sources that were not from Canada may be brought to Canada.”
This is a clear admission that Canada is importing radioactive waste from other countries and intends to continue doing so. The ownership of this waste is eventually transferred to the Government of Canada, and the waste is stored at the federally owned Chalk River Laboratories of AECL.
The financial arrangements involved in these waste transfers are completely non-transparent. In this way, the waste imports could be adding to the liabilities recorded in the Public Accounts of Canada. Canadian taxpayers may be subsidizing not only Canada’s own nuclear industry, but the nuclear industry of foreign nations as well.
by Dr. Gordon Edwards, president of the Canadian Coalition for Nuclear Responsibility
There are two kinds of proliferation of nuclear weapons – vertical proliferation, whereby a nuclear weapons state expand its nuclear arsenal or its nuclear weapons delivery capabilities, and horizontal proliferation, whereby a non-nuclear weapons state acquires a nuclear weapons capability.
In the past, Canada has contributed to both vertical proliferation by selling uranium and plutonium to the USA for weapons use and horizontal proliferation by giving India the technology needed to produce and extract plutonium for weapons use.
Canada is not in a position to contribute to vertical proliferation except in very indirect ways, and no nuclear weapon state wishing to expand its nuclear arsenal would be depending on Canada for that purpose,
However there are many non-nuclear-weapons states that have a desire to acquire a nuclear weapons capability. Canadian technology and nuclear materials could play a key role in helping them to acquire that capability.
Canada could play a very important role in horizontal proliferation by making plutonium production and its extraction that much easier.
If Canada develops nuclear reactors that depend on producing and extracting plutonium as fuel, (e.g. Moltex or ARC) and proceeds to sell those reactors to other countries around the world (as is the intention), then those countries that acquire the Canadian technology will be very much closer to building an arsenal of nuclear weapons.
By far the most difficult part of building a nuclear weapons is simply acquiring a sufficient quantity of nuclear explosive material.
Building a nuclear explosive device, once the necessary weapons-usable explosive material is available, is not nearly as difficult as people think. The best testimony to this fact comes from men who were directly involved in building nuclear weapons themselves, such as the people who expressed their concerns in the TV program whose transcript is found here: www.ccnr.org/Peaceful_Atom.html
Giving a commercial value to plutonium as a fuel, as proponents of “small modular” nuclear reactors want to do, makes it virtually inevitable that it will fall into criminal hands.
Unlike uranium, all plutonium is weapons-usable; no “enrichment” is required as is the case with uranium.
There is a great danger in making plutonium into a commercial fuel because anything that is commercially traded will end up, to a small but significant extent, in the hands of criminals and/or terrorists. We cannot keep drugs, money, guns or diamonds out of the hands of criminals, and there is no reason to think that we can keep plutonium out of the hands of criminals either.
It is entirely credible for a subnational group to make a devastatingly powerful nuclear explosive device that could be delivered in the trunk of a car parked on a downtown city street and detonated by remote control.
In the meantime, as more states acquire nuclear weapons materials, they will also build nuclear arsenals and then any military conflict in any part of the world can turn into a nuclear war. It is foolish to think that a country that is losing a conventional war will refuse to use the most powerful weapon in its arsenal.
~~~~~~~~~~
The photo below by Japanese military photographer Yosuke Yamahata shows the extent of the devastation of Nagasaki, one day after the plutonium bomb was dropped on it by the United States.
Concerned Citizens of Renfrew County and Area supports the Campaign to Ban Plutonium Reprocessing in Canada. Visit the campaign website for more information and suggestions for adding your voice to the campaign.
Update December 2025 ~ THE CPDP appears to have been replaced by CNL with a document called The Overview Decommissioning and Cleanup Plan (ODCP). The ODCP does not appear to qualify as a preliminary decommissioning plan. It seems to be more of a public relations document. CNL has deleted information about actual quantities of radionuclides in the different waste management areas.
Original post January 15.2023
This document, dated 2014 is the current version of the plan developed over many years for decommissioning and cleanup of the Chalk River Laboratories property. It is a requirement under the Nuclear Safety and Control Act that licensed nuclear facilities have decommissioning plans in place.
The plan was developed as part of the multimillion dollar “Nuclear Legacy Liabilities Project” prior to privatization of CRL in 2015. The work outlined in this plan will cost billions of dollars, possibly close to $16 billion which is a recent government of Canada estimate for the cost of cleaning up its federal nuclear legacy liability, the bulk of which is at Chalk River.
Interestingly, the CPDP includes no mention of a “Near Surface” disposal facility, aka the giant Chalk River Mound that has caused so much consternation on the part of Indigenous communities, downstream municipalities, and civil society groups over the last six years.
The private sector consortium that owns Canadian Nuclear Laboratories (CNL) and is now running Chalk River Laboratories and other Canadian federal nuclear facilities, does not appear to be following this CPDP, and the plan is not publicly accessible on the CNLwebsite.
We are posting the CPDP here because it is an important document that should guide decision making about Canada’s largest federal environmental liability and we believe it should be publicly available.
There is a Canadian Nuclear Safety Commission requirement (in REGDOC 2.11-2, Decommissioning) that a Preliminary Decommissioning Plan shall include… a public consultation plan. The IAEA also says that planning for decommissioning includes activities for public consultation in accordance with national requirements.
The photo above is the “active area” at Chalk River Laboratories on June 24, 2022, showing some of the buildings and structures that need to be decommissioned. The NRU reactor, closed in 2018, is the red brick building in the foreground. The Plutonium Tower – the grey structure to the left of the “Molybdenum-99 Stack” – is also visible in the photo,
The ARC-100 reactor is a proposed sodium-cooled “small,” “modular,” nuclear reactor (SMR). It is one of two nuclear reactors comprising a proposed demonstration project at the Point Lepreau nuclear site in New Brunswick along with a Moltex Energy molten salt SMR and spent fuel reprocessing unit.
In July 2022, a coalition of groups from New Brunswick, and other provinces asked environment minister Steven Guilbeault to designate the Small Modular Reactor (SMR) Demonstration Project at the Point Lepreau nuclear site for assessment under the Impact Assessment Act. Small modular nuclear reactors have been on the drawing board for decades. Serious accidents have occurred in prototype reactors. Spent fuel reprocessing is highly controversial due to attendant risks of serious accidents and nuclear weapons proliferation.
Concerned Citizens of Renfrew County and Area provided a letter in support of the designation request, in part because Canadian Nuclear Laboratories in Chalk River is conducting work to produce fuel for the ARC-100 reactor.
On December 22nd Minister Guilbeault denied the request for impact assessment, following an analysis done by the Impact Assessment Agency of Canada.
One must ask: Does the Impact Assessment Agency of Canada do much anything other than recommending not to do impact assessments?
In November 2022 the Agency provided the following information about all its completed assessments under the new Act (which entered into force in August 2019):
Phase or Assessment Type
Highway and Roads
Mines and Minerals
Oil and Gas
Ports and Harbours
Bridges
N/A
Total
Planning
0
6
2
1
2
0
11
IA by Agency
2
2
1
0
0
0
5
IA by Integrated Assessment
0
0
1
0
0
0
1
IA by Review Panel
0
0
1
1
0
0
2
IA by Substitution
0
0
2
0
0
0
2
Regional Assessment
0
0
1
0
0
3
4
Total
2
8.
8
2
2
3
25
So the answer to the question is no, the Agency doesn’t appear to do much in addition to recommending against doing impact assessments. It has completed an average of eight assessments per year since 2019.
As outsiders with a keen interest in seeing the serious impacts of nuclear energy and radioactive waste thoroughly assessed, it appears that the Impact Assessment Agency of Canada might be a tad overstaffed for its underwhelming performance.
Given the numerous serious potential impacts, we find it to be irresponsible that the Agency recommended against an assessment of the Small Modular Reactor (SMR) Demonstration Project at the Point Lepreau nuclear site.
The Agency also recommended in 2021 against a regional assessment of radioactive waste management in the Ottawa Valley, despite a very clear need and a call for one by the City of Ottawa and many civil society groups.
The Impact Assessment Agency of Canada is a disappointment. It appears to be yet another government body prioritizing the needs of industry over the safety and well-being of Canadians and their supporting ecosystems.
Further ~ Dec 24/2022 per the comment added below, the Agency appears to turn down dozens of requests every year, and to ONLY do assessments that are required by the legislation and captured by the seriously flawed project list.
It is clear that The NSDF would not contain and isolate radioactive waste from the accessible biosphere. One only needs to look at the table in the proponent’s Environmental Impact Statement entitled “Maximum concentrations of radionuclides in the treated effluent and east swamp stream.” (reproduced below)
Just above the table is the statement “both aquatic and terrestrial species will be exposed to contaminated surface water and sediment in the East Swamp stream, perch lake, perch creek, and Ottawa River.”
The table lists 29 radionuclides that would be present in the treated effluent. These are the “maximum concentrations” that CNSC expects, and the CNSC license would approve. They include a large quantity of tritium and three isotopes of plutonium. The maximum concentration of Pu 241 increased 50 fold between the draft EIS and final EIS. It would be good to know the reason for that and why the tritium more than doubled.
As Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility said in his intervention at the licensing hearings last week:
“CNSC and CNL may say these levels are negligible, but why should any citizens of Ontario or Quebec be exposed to any amount of plutonium in their drinking water?”
Concerned Citizens of Renfrew County and Area 