Letter to Mark Carney ~ Pour une gestion transparente et responsable des déchets radioactifs

December 12, 2025

English version follows below.

Towards a transparent and responsible management of radioactive waste

December 2 2025

Several political parties and civil society organizations are dismayed to learn thatCanadian Nuclear Laboratories (CNL) has decided to consolidate radioactive waste (forwhich the federal government is responsible) at the Chalk River Laboratories site. This decision was made without consultation with First Nations or the public, and without parliamentary debate. Canadian Nuclear Laboratories (CNL) is only a private contractor,not a government agency.

For the population, there is no public accountability and concern is growing. Why concentrate everything at Chalk River? CNL is not intending to permanently store high- or intermediate-level waste at Chalk River. Those wastes will likely be moved again. Chalk River is an unsuitable location for radioactive waste consolidation because it islocated on the Ottawa River and the area is prone to seismic tremors.

Used nuclear fuel has the highest level of radioactivity; it is being transported to ChalkRiver from nuclear reactors in Manitoba, Ontario and Quebec for interim storage pending the construction of a proposed deep geological repository (DGR). CNL intendsto have the same used fuel eventually transported to the DGR. But such a repositorystill does not exist and may never be licensed or approved. Whether the DGR isultimately built or not, issues surrounding the transportation of radioactive waste have to be addressed.

There are increased risks and costs of transporting used fuel twice: first from thenuclear power plants to Chalk River, and then from Chalk River to a second destination.This leads to extra safety risks and a waste of public money. The government is justmoving the waste around at great expense and added risk without solving the problempermanently, as there is still no proven safe solution despite 45 years of effort.

The proposed transportation of intermediate-level waste to Chalk River from thedecommissioning of nuclear reactors is similarly ill-advised.

Public concern was heightened by the news of the secretive transport of tonnes of usednuclear fuel from Bécancour, Quebec, to Chalk River during the summer of 2025, alongpublic roads and bridges, without any explicit authorization or opportunity for publicconsultation or even proper notification.

• We call on the federal government for a moratorium on the shipment of Canadianradioactive waste to Chalk River because of the increasing risk of radioactivecontamination and the lack of an acceptable due process.

• We call on the federal government to ban all imports of radioactive waste from othercountries, including disused medical sources, discarded tritium light sources, or usednuclear fuel.

• We call on the Minister of Environment and Climate Change to conduct a strategicassessment of the transportation of high- and intermediate-level radioactive waste onpublic highways, in accordance with section 95 of the Impact Assessment Act. Theresults of this assessment would contribute to future impact assessments of nuclearfacilities. The goal would be to examine, for example, the cumulative impact at ChalkRiver and to provide a framework for upcoming environmental assessments of nuclearpower plants and reactor decommissioning projects.

Patrick Bonin, M.P.Bloc Québécois critic for the Environment and Climate Change

Elizabeth May, M.P.Green Party of Canada

André BélangerFondation Rivières

Alain BranchaudSNAP Québec

Ginette Charbonneau Physicist and spokesperson for le Ralliement contre la pollution radioactive

Et al….

Updated list of First Nations and Municipal resolutions against CNLs plans for radioactive dumps on the Ottawa River

updated July 2023

The Assembly of First Nations and more than 140 municipalities including Ottawa, Gatineau and Montreal have passed resolutions of concern or opposition to the proposed radioactive waste facilities on the Ottawa River.

NEW resolution by the Assembly of First Nations July 2023

Resolution by the LA COMMUNAUTÉ MÉTROPOLITAINE DE MONTRÉAL 28 Avril 2022

Assembly of First Nations resolution is here: http://www.ccnr.org/AFN_Resolution_2017.pdf

Example d’une resolution municipale en français:

qc-mrc-collines-de-loutaouais-Download

Example resolution in English:champlain-resolution-2019-160april-2019Download

Montreal Municipal Council’s unanimous resolution (press release and full resolution): https://cmm.qc.ca/communiques/depotoir-nucleaire-a-chalk-river-la-cmm-soppose-au-projet/

This is the latest list, last updated on March 14, 2022. Click on the blue hyperlink below the box to view the pdf in your browser without downloading.

RED ALERT ~ CNL tells CNSC it has current plans to put “intermediate level waste” in above ground mounds

July 2019

In October 2017, Canadian Nuclear Laboratories (CNL) announced that it would not put Intermediate Level Waste (ILW) in a proposed above-ground mound.

CNL incorrectly calls this mound a “Near Surface Disposal Facility” (NSDF). International Atomic Energy Agency (IAEA) safety requirements state that a near surface facility should consist of in-ground vaults or trenches, and is suitable only for Low Level Waste.

In March 2019, the Canadian Nuclear Safety Commission (CNSC), Canada’s captured nuclear regulator, released a draft “Regulatory Document” on waste management for comment. The CNSC’s proposed language on ILW was that it “generally requires” greater isolation than would be provided by near surface disposal.

Putting ILW above-ground would go against common sense. Because of its long-lived radionuclides, the IAEA requires that ILW be disposed of “at least a few tens of metres below ground level.”

In June 2019 CNL submitted its comments on the draft RegDoc. CNL asked CNSC to further weaken its wording on ILW, saying “There are current plans to place ILW in aboveground mounds.”  CNL wanted the language on ILW changed from “generally requires” to “may require” greater isolation.

CNSC’s final version of the Regulatory Document, published February 2021, retains the original language of “generally requires”.

This could allow CNL to dispose of long-lived, intermediate-level radioactive waste in its proposed above-ground mound, the so-called NSDF.

Why did CNL say in October 2017 that it would not put ILW in the NSDF, but tell CNSC in June 2019 that there are “current plans to place ILW in aboveground mounds”?

From the IAEA Specific Safety Requirements No. SSR-5, Disposal of Radioactive Waste, page 4:

(b) Near surface disposal: Disposal in a facility consisting of engineered trenches or vaults constructed on the ground surface or up to a few tens of metres below ground level. Such a facility may be designated as a disposal facility for low level radioactive waste (LLW)

(c) Disposal of intermediate level waste: Depending on its characteristics, intermediate level radioactive waste (ILW) can be disposed of in different types of facility. Disposal could be by emplacement in a facility constructed in caverns, vaults or silos at least a few tens of metres below ground level and up to a few hundred metres below ground level. It could include purpose built facilities and facilities developed in or from existing mines. It could also include facilities developed by drift mining into mountainsides or hillsides, in which case the overlying cover could be more than 100 m deep. 

From the IAEA Specific Safety Requirements No. SSR-5, Disposal of Radioactive Waste, page 55:

Intermediate level waste (ILW): Waste that, because of its content, particularly of long lived radionuclides, requires a greater degree of containment and isolation than that provided by near surface disposal.  

From CNL updates NSDF Waste Inventorydated October 26, 2017:

Canadian Nuclear Laboratories (CNL) announced today that it has re-evaluated its proposal for the Near Surface Disposal Facility (NSDF) at Chalk River Laboratories, and has made the decision to only include low-level radioactive waste in the NSDF…. Intermediate level waste will continue to be managed in interim storage at Chalk River Laboratories until a long-term disposal solution for this category of radioactive waste has been developed and approved. 

From CNSC REGDOC-2.11.1, Volume I, Management of Radioactive Waste, March 2019 draft, section 6.1, Waste Classification, bullet 4, page 4:

Due to its long-lived radionuclides, ILW generally requires a higher level of containment and isolation than can be provided in near surface repositories.

From Canadian Nuclear Laboratories Comments on Draft Regdoc-2.11.1, Volume 1: Management Of Radioactive Waste, page 11 of 25, comment #13 on section 6.1, dated June 27, 2019: 

The 4th bullet is a potentially misleading or biasing statement. There are current plans to place ILW in aboveground mounds. 

Amend 4th bullet to read, “Due to its long‐lived radionuclides, ILW generally may require a higher level of containment and isolation than can be provided in near surface repositories.