5 avril 2023

January 16, 2023

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.

December 23, 2022

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.

According to the Government Electronic Directory Services there are 360 staff in the Agency.

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.

June 7, 2022

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 four 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.

Table 5.7.6-2 is excerpted from CNL’s Environmental Impact Statement pages 5-698 – 5-699

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?”

Junes 2 is a special day at the hearings for the Chalk River Mound.

It is the day the Commission will consider Indigenous issues. Five Algonquin First Nations delegations will address the tribunal. The Five Algonquin First Nations intervening are; Algonquins of Pikwàkanagàn First Nation, Kitigan Zibi Anishinabeg, Kebaowek First Nation, Wolf Lake First Nation, Mitchikanibikok Inik Algonquins of Barriere Lake. All five of the Indigenous delegations are coming to Pembroke to make their interventions. The Indigenous presentations will begin at 9:00 am. One Non-Indigenous delegation, The Kitchisippi Ottawa Valley Chapter of the Council of Canadians will also intervene.

Here is the schedule for tomorrow:

9:00 Smudging Ceremony9:30 Algonquins of Pikwakanagan First Nation

10:45 Kitigan Zibi Anishinabe (Elder Verna McGregor)

Lunch

Drumming (Mitchikanibikok Inik Algonquins of Barriere Lake)

Kebaowek First Nation, 

Wolf Lake First Nation, 

Mitchikanibikok Inik Algonquins of Barriere Lake.

Kitchisippi Ottawa Valley Chapter of the Council of Canadians

Please join us in the hearing room for part or all of the day, if you can!

We are suggesting that you bring a piece of paper with FPIC on it for Free Prior Informed Consent, which refers to the requirement under the UN Convention on the Rights of Indigenous Peoples for states to ensure that no storage or disposal of hazardous materials shall take place in the lands or territories of indigenous peoples without their free prior and informed consent. 

We may hold up our signs at certain points during the hearing. The aim is to quietly and respectufully show our support for our Indigenous friends and allies. Some of us will put signs with FPIC on our cars while they are parked at the hotel.

If you can’t join us in person, please send one or more messages to decision makers to let them know that five Algonquin First Nations say they have not been adequately consulted and do not support the proposal to build the giant radioactive waste mound on their unceded territory. For more info and sample messages start here.

Photo below of Kitchi Sibi September 20. 2019

More information about the No Consent Day of Action here.

Sample email message

Dear (add the name of your elected official)

I would like to request your urgent attention to licensing hearings for a giant radioactive waste mound on traditional unceded Algonquin land alongside the Ottawa River upstream of Ottawa-Gatineau and Montreal.

These licensing hearings are being held by the Canadian Nuclear Safety Commission, widely perceived to be a captured regulator and in need of reform. The hearings are proceeding despite serious problems with the dump proposal and specific requests by four Algonquin First Nations that the hearings be suspended.

The First Nations in question say they have not been adequately consulted or in some cases not consulted at all and are not prepared to give their consent to the project.

Please do what you can to ensure that the proposed radioactive waste facility does not receive a license at this time, and that the rights of Indigenous communities are respected.

Yours sincerely,

Sample tweets

Support Algonquin Nations’ rights on #NoConsent Day. Tell feds no #nuclearwaste on First Nations lands! Here are words of 5 First Nations who do not consent to #ChalkRiver dump: concernedcitizens.net/2022/05/28/algonquin-nations-do-not-consent/   @JustinTrudeau @MarcMillerVM @PattyHajdu @Rvelshi @CNSC_CCSN @GGCanada

Protect Kitchi Sibi Ottawa River and Mother Earth! Send messages of support to Kebaowek, Barriere Lake, Wolf Lake and Algonquins of Pikwàkanagàn First Nations here: bit.ly/3wY5B0u #NoConsent

#NoConsent to nuclear waste on Algonquin lands! @CNSC_CCSN hearings today must listen to First Nations. Free prior and informed consent. @MarcMillerVM @PattyHajdu @Rvelshi @SophieChatel1 @JonathanWNV @s_guilbeault @GGCanada @Laurel_BC @kyleseeback @ElizabethMay @m_pauze #cdnpoli

MPs: #FirstNations do not consent to #ChalkRiver nuclear dump @SophieChatel1 @GregFergus @stevenmackinnon @Yasir_Naqvi @anitavandenbeld @DavidMcGuinty @MonaFortier @mflalonde @AryaCanada @JennaSudds @Francis_Drouin @PierrePoilievre @cherylgallant @seblemire @stephanelauzon5 #CNSC

Ottawa/Gatineau #water comes 100% from the #OttawaRiver. Listen to #Indigenous allies: Algonquin First Nations are saying #NoConsent to #radioactivewaste next to a major river. #WaterIsLife @CNSC_CCSN @RVelshi @JonathanWNV @s_guilbeault @Laurel_BC @ElizabethMay @m_pauze #cdnpoli

Where to send your emails and tweets

Twitter Tags for Decision-makers and MPs
Canadian Nuclear Safety Commission	@CNSC_CCSN
President and CEO of CNSC Rumina Velshi	@RVelshi    Email: rumina.velshi@cnsc-ccsn.gc.ca
Minister of Natural Resources Jonathan Wilkinson	@JonathanWNV Email: minister.ministre@nrcan-rncan.gc.ca
Environment Minister Steven Guilbeault	@s_guilbeault  Email: ministre-minister@ec.gc.ca
Minister of Crown-Indigenous Relations Marc Miller	@MarcMillerVM  Email: marc.miller@rcaanc-cirnac.gc.ca
Minister of Indigenous Services Patty Hajdu	@PattyHajdu   Email: MinistreSA-MinisterIS@sac-isc.gc.ca
Prime Minister Justin Trudeau	@JustinTrudeau   Email: pm@pm.gc.ca
Governor General of Canada Mary Simon	@GGCanada
Opposition Critics in Parliament
Laurel Collins – NDP Critic for Environment and Climate Change	@Laurel_BC
Richard Cannings– NDP Deputy Critic for Natural Resources	@CanningsNDP
Charlie Angus – NDP Critic for Natural Resources	@CharlieAngusNDP
Kyle Seeback – Conservative Shadow minister for Environment and Climate Change	@kyleseeback
Greg McLean – Conservative Shadow Minister for Natural Resources	@GregMcLeanYYC
Elizabeth May, MP, Green Party of Canada	@ElizabethMay
Monique Pauzé, Députée et porte-parole de l’environnement pour le Bloc Québécois	@m_pauze
Tag your Member of Parliament	Regional (Eastern Ont./West Que.) MPs
Sophie Chatel	@SophieChatel1
Greg Fergus	@GregFergus
Steven MacKinnon	@stevenmackinnon
Yasir Naqvi	@Yasir_Naqvi
Anita Vandenbeld	@anitavandenbeld
David McGuinty	@DavidMcGuinty
Mona Fortier	@MonaFortier
MFLalonde	@mflalonde
Chandra Arya	@AryaCanada
Jenna Sudds	@JennaSudds
Francis Drouin	@Francis_Drouin
Pierre Poilievre	@PierrePoilievre
Cheryl Gallant	@cherylgallant
Sébastien Lemire	@seblemire
Stéphane Lauzon	@stephanelauzon5
Email addresses – Members of Parliament and Ministers	The standard Parliamentary address is: FirstName.LastName@parl.gc.ca  Or you can look up your MP here: https://www.ourcommons.ca/Members/en/search

May 28, 2022

Five Algonquin First Nations are saying they have not been adequately consulted about the NSDF or not been consulted at all.

Kebaowek First Nation (KFN)

The Kebaowek First Nation’s letter to the CNSC  (Jan. 31, 2022) states that the CNSC’s decisions “pose significant and long-term impacts [to] Kebaowek’s constitutionally protected Aboriginal rights,”  and that “The CNSC as yet, has not discharged its duty to consult nor undertaken consultation with Kebaowek before deciding to proceed with the licensing and EA hearing for the NSDF.”

From KFN’s supplementary submission to the CNSC April 28, 2022:

“United Nations Declaration of the Rights of Indigenous Peoples

Although the mandate of the CNSC does not mention a mandate to examine the relationship between the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the NSDF, the Committee should be reminded of your government’s adoption of UNDRIP at the UN assembly and incorporate the “minimal standards” developed by States and Indigenous peoples from around the world with respect to the protection of waters used and valued by Indigenous people. 

Article 32 of UNDRIP recognizes the right of Indigenous Peoples’ to control development of their traditional territories and resources. Among that development is the exploitation and use of water resources. In fact, States such as Canada should be engaged in good faith processes with Indigenous peoples affected by development projects in their territories in order to obtain the free, prior and informed consent prior to the approval of any project affecting Indigenous water resources.

KFN takes the position that the CNSC has not engaged in consultation via a good faith process intended to obtain the free, prior and informed consent of our community with respect to the Environmental Assessment (EA) of the NSDF. We further take the position that the duty to consult and accommodate has been eliminated and/or seriously reduced.

The Commission is not in a position to make either of the determinations required in order to approve CNL’s application. The CNSC has not fulfilled the DTCA with KFN and consequently, it cannot satisfy itself that the requirements under the CEAA or the NSCA have been met. The Commission has no option at this point but to either deny CNL’s application or defer its decision to allow for the proper fulfillment of its DTCA. Proceeding otherwise would result in the Commission’s violation of the Crown’s constitutional obligations and potentially the greater and unknown impacts to both the environment and our inherent and projected rights.”

Mitchikanibikok Inik, Algonquins of Barriere Lake (ABL)

The Algonquins of Barriere Lake state in their letter to the CNSC (April 1, 2022) that: “it appears to us that your Agency’s approach to fast tracking the NSDF hearing without fully and meaningfully consulting affected Algonquin Anishinaabeg communities is unreasonable and falls considerably short of fulfilling the Crown’s duty to meaningfully consult.”

From ABL’s submission to CNSC (May 4, 2022):

“We have lived in the Kishi Sipi watershed from time immemorial…The Algonquin Nation have been on the territory for over 8000 years…Never once was ABL directly contacted or consulted by the CNSC or CNL…ABL has always taken on our role as protectors of the land and resources on our traditional territory seriously.”

“ABL submitted a request for ruling to the CNSC on April 1, 2022, in accordance with rule 20 of the Canadian Nuclear Safety Rules of Procedure in favour of an adjournment of this public hearing for a period of 12 months. We made this request on the basis that we are extremely concerned about the NSDF project’s and its potential impacts and considering our community’s deep-seated ecological and environmental knowledge, acquired through a long and intimate association with the Kitchi-Sibi, as we know the Ottawa River, and surrounding sites are not reflected in the baseline studies conducted by CNL. We also took issue with the aggressive timeline that has led to the negotiation of participant funding agreements being undertaken in an informational vacuum. Despite this, the Commission determined that an adjournment was not merited and that it would be premature to adjourn the proceedings at this time…”

“While the CNSC staff have recommended that the Commission determine that the NSDF project is not likely to cause significant adverse environmental effects referred to in the CEAA and conclude pursuant to the NSCA that CNL’s application with respect to the NSDF should be approved, the Commission cannot make this determination and fulfill its DTCA absent ABL’s input and engagement with this process. The Commission simply does not have any of the information it needs to make these determinations. Both ABL’s lack of opportunity to provide this input and CNSC’s resulting inability to consider and address this information mean that the DTCA has not been met.”

“The Commission is not in a position to make either of the determinations required in order to approve CNL’s application. The CNSC has not fulfilled the DTCA owed to ABL, in fact it has not engaged with us at all and consequently it cannot satisfy itself that the requirements under the CEAA or the NSCA have been met. The Commission has no option at this point but to either deny CNL’s application or defer its decision to allow for the proper fulfillment of its DTCA through the creation of an engagement framework that properly recognizes ABL as an equal jurisdiction in this matter. Proceeding otherwise would result in the Commission’s violation of the Crown’s constitutional obligations and potentially the greater and unknown impacts to both the environment and our inherent and projected rights.”

Kitigan Zibi Anishinabeg(KZA)

The Kitigan Zibi Anishinabeg, in its submission to the CNSC (April 11, 2022) stated: “we do not give our consent for this project in its current form. . . . As mentioned above we also do not consider that we have been adequately and meaningfully consulted and especially not accommodated on this project.”

Wolf Lake First Nation (WLFN)

The Wolf Lake First Nation, In its  recent submission to the CNSC dated May 4, 2022, states: “We do not agree with the NSDF disposal mound proposal on our Title territory alongside the Ottawa River. We view this alarming situation as clearly inconsistent with the federal objective of advancing reconciliation. Moreover, the commission bypassing our and other Algonquin communities’ participation in the CEAA 2012 environmental assessment ignores our rights under section 35 of the Constitution Act, 1982 and the Crown’s duty to consult and accommodate WLFN’s concerns.”

Algonquins of Pikwakanagan First Nation (AOPFN)

AOPFN say they are not ready to provide their free prior and informed consent (FPIC).

Here are some excerpts from this AOPFN submission to the CNSC May, 19, 2022: 

“Engagement on critical issues – the location of the facility, planning for management of wastes,importation of wastes, respect for AOPFN’s consent requirement, and what impacts are likely should the Project proceed – has been superficial or dismissive and has not led to reconciliatory actions”

“AOPFN has never been engaged by AECL or CNL in site planning activities to date.”

“The importation of radioactive waste from other facilities, is opposed to the AOPFN’s nuclear sector principles and the Anishinabek Nation and Iroquois Caucus (2017) Declaration on Nuclear Wastes which calls for ‘no imports or exports’ of nuclear wastes”

“The Project as proposed is not ready”

“The AOPFN is not ready to provide its FPIC due to Project uncertainties and lack of evidence of adequate mitigation and accommodation, and that consent is paramount”

“Further work is required to: 

• Confirm with impacted parties this is the best location for CRL waste storage

• Remove incoming waste streams from the Project plan

• Show that impacts on rights are properly predicted, minimized and accommodated for 

• There is no emergency requiring immediate action; Canada and its contractor should take the time it takes to develop a Project acceptable to impacted parties

• The CNSC can play a key role in this by requiring additional work be done prior to making a decision or deeming the Project is not ready to proceed as proposed”

A multinational consortium plans to pile up one million tonnes of radioactive and hazardous wastes in a gigantic landfill beside the Kitchi Sibi / Ottawa River in unceded traditional Algonquin territory.

The proponent’s own studies show that the giant mound would leak and disintegrate long before radioactive components like plutonium decayed to a harmless state. 

Staff of Canada’s captured nuclear regulator, the Canadian Nuclear Safety Commission, are recommending that the license be approved.

On Thursday June 2, 2022 the commission will hear oral interventions from five Algonquin First Nations who say they have not been adequately consulted about the plan and DO NOT CONSENT to the licensing of the facility at this time.

Everyone with concerns about the plan for the giant leaking radioactive dump is invited to support the Algonquin First Nations in a “NO CONSENT” Day of Action on Thursday, June 2.

HERE IS HOW YOU CAN SUPPORT and STAND WITH our Algonquin friends and allies on June 2:

IN PERSON

~ Come to the hearings at the Best Western Hotel in Pembroke and sit in the hearing room while the Algonquin First Nations make their presentations to the tribunal (roughly 11 am to 5 pm)

~ Wear a racing bib (piece of paper pinned to your clothing) that says “NO CONSENT” or “FPIC” for “Free Prior and Informed Consent”

~ While your car is parked at the hotel, decorate it with a “NO CONSENT” or “FPIC” sign

ONLINE

~ Send messages to decision makers: MPs, councillors, Mayors etc. (sample messages here and see twitter tags below the photo)

~ Spread the word to your family, friends, neighbours and colleagues and encourage them to participate

~ Make a NO CONSENT sign, and share photos of it on social media, using the #NOCONSENT hashtag; be sure to tag elected officials and the Canadian Nuclear Safety Commission

~ Send a note of encouragement or thanks to our Algonquin allies on the NO CONSENT DAY of ACTION Facebook Page. https://fb.me/e/1HiCMydeY

Twitter Tags for Decision-makers and MPs

Canadian Nuclear Safety Commission
@CNSC_CCSN

President and CEO of CNSC Rumina Velshi
@RVelshi

Minister of Natural Resources Jonathan Wilkinson

@JonathanWNV

Environment Minister Steven Guilbeault

@s_guilbeault

Minister of Crown-Indigenous Relations Marc Miller 

@MarcMillerVM

Minister of Indigenous Services Patty Hajdu

@PattyHajdu

Prime Minister Justin Trudeau

@JustinTrudeau

Governor General of Canada Mary Simon

@GGCanada              

Opposition Critics

Laurel Collins – NDP Critic for Environment and Climate Change

@Laurel_BC

Richard Cannings– NDP Deputy Critic for Natural Resources

@CanningsNDP

Charlie Angus – NDP Critic for Natural Resources

@CharlieAngusNDP

Kyle Seeback – Conservative Shadow minister for Environment and Climate Change

@kyleseeback

Greg McLean – Conservative Shadow Minister for Natural Resources

@GregMcLeanYYC

Elizabeth May, MP, Green Party of Canada

@ElizabethMay

Monique Pauzé, Députée et porte-parole de l’environnement pour le Bloc Québécois

@m_pauze

Tag your Member of Parliament.  Regional (Eastern Ont./West Que.) MPs:

Sophie Chatel

@SophieChatel1

Greg Fergus

@GregFergus

Steven MacKinnon

@stevenmackinnon

Yasir Naqvi 

@Yasir_Naqvi

Anita Vandenbeld

@anitavandenbeld

David McGuinty

@DavidMcGuinty

Mona Fortier

@MonaFortier

MFLalonde

@mflalonde

Chandra Arya

@AryaCanada

Jenna Sudds

@JennaSudds

Francis Drouin

@Francis_Drouin

Pierre Poilievre

@PierrePoilievre

Cheryl Gallant

@cherylgallant

Sébastien Lemire

@seblemire

Stéphane Lauzon

@stephanelauzon5