Micro Modular Reactor Project

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Attachment From Maritime Aboriginal Peoples Council to the Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Maritime Aboriginal Peoples Council
  • Reference number: 70
  • Submitted: 2019-11-12 - 12:10 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • From Maritime Aboriginal Peoples Council to the Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River
  • Attachment included
  • Maritime Aboriginal Peoples Council 3DHIN 20190CT25®32 . tU- oA FILE 3k:DOSSIER REFERRED TOm REFEREA The Maritime Regional Aboriginal Leaders Intergovernmental Council of Aboriginal Peoples Continuing to Reside onTraditional Ancestral Homelands September 13, 2019Forums CNSCccSNLeaders Congress O MAPC Commissions/Projects MAARS Secretariats IKANAWTIKET SARA MAPC Administration Airaee Rupert Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046 Station B Ottawa, ON KIP 5S9 ' Doc# ^BLrnent MAPC Regional Adininisfcrafcive Office 172 Truro Heights Road Truro Heights, Nova Scotia 88L 1X1 " RE: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River (No*: CRP- LIC-01-001, Rev. 2) 90&895-29B3 S02-895-3844 1-855-858-7240 frontdesk@mspcorg.ca Tel; The Maritime Aboriginal Peoples Council is opposed to the project described in the Project Description for the Micro Modular Reactor Project at Chalk River (No.; CRP-LIC-01-001, Rev, 2, dated 2019/07/08) proposed by Global First Power. Maritime Aboriginal Peoples Council is the intergovernmental leaders forum of the Native Council of Nova Scotia, New Brunswick Aboriginal Peoples Council, and the Native Council of Prince Edward Island, collectively advancing the Aboriginal and Treaty rights and interests of the Section 91.24 Indian Mi’kmaq/Maliseet/Passamaquoddy/Aboriginal/ Indigenous Peoples continuing to reside on Traditional Ancestral Homelands and Territories (off-reserve) throughout modem day Nova Scotia (42,145 persons), New Brunswick (21,920 persons), and PEI (3,485 persons) (2016 Census Canada Aboriginal Identity numbers). Fax: Tall Free; Email: Governmental APRQ Councils The Native Council of Nova ...

Attachment From Algonquins of Ontario to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Algonquins of Ontario
  • Reference number: 68
  • Submitted: 2019-09-25 - 8:06 AM
  •  Please see the attached correspondence.   Janet Stavinga Executive Director _____________________________________________ Algonquins of Ontario Consultation Office
  • Attachment included
  • Algonquins of Ontario _____________________________________________________________________________________________________ 31 Riverside Drive, Suite 101, Pembroke, Ontario K8A 8R6 Telephone: (613) 735-3759 Fax: (613) 735-6307 Website: www.tanakiwin.com E-Mail: algonquins@tanakiwin.com September 23, 2019 Aimee Rupert Environmental Assessment Officer Canadian Nuclear Safety Commission Government of Canada P.O. Box 1046, Station B 280 Slater Street Ottawa, ON K1P 5S9 BY EMAIL ONLY cnsc.ea-ee.ccsn@canada.ca Dear Ms. Rupert, Subject: Submission of Preliminary Written Comments on the Micro Modular Reactor (MMR™) Project by Global First Power at the Chalk River Canadian Nuclear Laboratories Site (Our File CF 48-25) We are writing to provide the Canadian Nuclear Safety Commission (CNSC) and the Impact Assessment Agency of Canada (IAAC – formerly CEAA) with our comments and recommendations on the Project Description Summary for the Global First Power Micro Modular Reactor Project. On behalf of the Algonquins of Ontario (AOO) thank you for the opportunity to provide our views and preliminary comments on the Micro Modular Reactor (MMR™) project by Global First Power (GFP) at the Canadian Nuclear Laboratories (CNL) site in Chalk River. The Project is located within the unceded Algonquin Traditional Territory. The AOO assert unextinguished and constitutionally protected Aboriginal rights and title the unceded Algonquin Traditional Territory in Eastern Ontario (referred to as the “ AOO Settlement Area”) and are currently in negotiations towards a modern-day Treaty with the governments of Ontario and Canada. The IAAC is currently undertaking a federal ...
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Attachment From Kerrie Keith to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Kerrie Keith
  • Reference number: 67
  • Submitted: 2019-09-24 - 4:01 PM
  • Good afternoon Ms Rupert,   My apologies for the delay, but I, too, would like to comment on the environmental impact of the Micro Modular Reactor Project at Chalk River.    As someone who cares deeply about sustainability, it is clear that nuclear energy is not only not sustainable, it is also dangerous, expensive and includes several embedded carbon and radioactive costs.  Nuclear energy is not carbon-free as it has materials that are not only generated at huge carbonic costs but also transported and maintained on a regular polluting basis to support its existence.    As we all know, nuclear energy expends a frightening waste product and it also transfers its radiation to its surrounding environment.  Radiation is not cheap nor easy to contain and it persists for tens of thousands of years.  Nuclear energy is dirty and dangerous in and of itself even before considering any potential accidents that may occur.   As of 2014, there have been more than 100 serious nuclear accidents and incidents from the use of nuclear power. Fifty-seven accidents have occurred since the Chernobyl disaster, and about 60% of all nuclear-related accidents have occurred in the USA. Serious nuclear power plant accidents include the Fukushima Daiichi nuclear disaster (2011), the Chernobyl disaster (1986), the Three Mile Island accident (1979), and the SL-1 accident (1961).   My hope is that for the existing 450 nuclear reactors in the world, there will be no accidents.  But there will still be waste.  In order to address the waste from these reactors, one must employ some deep time thinking.  The present day accepted solution is ...

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Attachment From Anishinabek Nation to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Anishinabek Nation
  • Reference number: 66
  • Submitted: 2019-09-24 - 3:57 PM
  • Good afternoon Aimee   Attached please find AN submission – Micro Modular Reactor at Chalk River   Thank you     ________________________________________ Lynn Bowerman Executive Liaison, Political Office Anishinabek Nation
  • Attachment included
  • September 23, 2019 Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa, Ontario KIP 5S9 Dear Miss Rupert, Re: Micro Modular Reactor Project at Chalk River-Comments Invited on Global First Power's Project Description Thank you for extending the opportunity for the Anishinabek Nation to provide comments on the project description prepared by Global First Power for its proposed Micro Modular Reactor Project at Chalk River. Review of the Project Description developed by Global First Power has resulted in the Anishinabek Nation having additional questions and comments regarding this project. Our comments are organized by section as follows: a) Detailed Comments b) General Comments Detailed Comments Introduction The document states "MMR technology will have the potential to provide Canada with economic benefits related to developing a domestic supply chain as well as export opportunities". Question: What regulations govern the export of nuclear products to other countries, and to the import of nuclear products into Canada? Project Name, Nature and Location The three potential sites described for the project are poorly mapped and their relative sizes are not described. It is unclear what minimum area is required to construct the facility. ……./2 Micro Modular Reactor Project at Chalk River-Comments Page 2 Description of Communication Activities The document states "On On February 15, 2019, CNL announced that GFP’s proposal had advanced to Stage 3 of the review process”. Is Global First Power the only company that has advanced to Stage 3 of the review process? ...
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Attachment From Algonquins of Pikwakanagan First Nation to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Algonquins of Pikwakanagan First Nation
  • Reference number: 65
  • Submitted: 2019-09-24 - 3:55 PM
  • Good afternoon Aimee,   Re: Comments Invited on Global First Power’s Project Description   Please see attachment, from the Algonquins of Pikwakanagan First Nation.   Thank you,   Amanda Two-Axe Kohoko Consultation Coordinator, Economic Development Algonquins of Pikwakanagan First Nation
  • Attachment included
  • <Personal Information Redacted>

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Attachment From Métis Nation of Ontario to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Métis Nation of Ontario
  • Reference number: 64
  • Submitted: 2019-09-23 - 1:09 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Hello Aimee,   Please find attached MNO comments.   Thank you for the extension.   Sincerely,   Jesse Fieldwebster, M. Eng. Manager, Nuclear Energy Lands Resources & Consultations Métis Nation of Ontario
  • Attachment included
  • Métis Nation of Ontario Lands, Resources and Consultations 311 – 75 Sherbourne Street | Toronto, ON M5A 2P9 | Tel: 416-977-9881 | metisnation.org 14 September 2019 Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046 Station B 280 Slater Street Ottawa ON K1P 5S9 BY ELECTRONIC MAIL Dear Aimee Rupert: Re: Global First Power’s proposed Micro Modular Reactor Project at Chalk River The Métis Nation of Ontario (MNO) would like to thank the Canadian Nuclear Safety Commission (CNSC) for providing the MNO with the opportunity to comment on the project description for Global First Power (GFP)’s proposed Micro Modular Reactor Project at Chalk River. On behalf of the MNO, which represents the rights and interests of Ontario’s regional rights-bearing Métis community, please accept the following comments concerning the project description for GFP’s proposed Micro Modular Reactor Project (the ‘Project’) at Chalk River as provided to the MNO by the CNSC on 15 July 2019. The Métis Nation has Aboriginal rights in the lands, waters and natural resources within the area where the Cultural Heritage Resources noted above are located. The rights are held as collective rights, by the regional rights-bearing Métis community, as represented by the MNO. As you know, the Métis are one of three distinct Aboriginal peoples in Canada, whose rights, interests and way of life are constitutionally protected under section 35 of the Constitution Act, 1982. Accordingly, the Crown has the duty to consult with the Métis before making a decision, taking an action or issuing an approval that could impact the rights, ...
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Attachment From David J. Winfield to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of David J. Winfield
  • Reference number: 62
  • Submitted: 2019-09-23 - 1:02 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • TO: Aimee Rupert Please find my comments for CEAA Reference Number 80182. David J. Winfield Point Alexander, Ontario
  • Attachment included
  • 1 Comments on the Project Description (PD) for the Micro Modular Reactor™ Project at Chalk River, Reference Number: 80182. Two noteworthy findings of the CNSC’s Phase 1 Pre-Licensing Vendor Design Review (VDR) Executive Summary for the MMRTM, February 7th 20191 were to request additional information to confirm: • the adequacy of the R&D activities to substantiate MMRTM safety claims and the fuel qualification program, including the role of a first-of-a-kind reactor, and • the applicability of the operating experience data from previous high-temperature gas-cooled reactors to the MMRTM design and safety analyses. The importance of just these two sample CNSC requests suggest to this reviewer that the PD was insufficiently complete and that releasing the PD for public comment at this stage was premature. Comments below provide specific examples, relevant to these requests, where the reviewer believes inadequate design information and other examples of fundamental project information are lacking in the PD. The PD provides no evidence of any agreement or assurance from AECL of an MMRTM site at CNL. Such evidence should be a prerequisite, prior to the Phase 1 PD release. Regardless, on March 20, 2019, Global First Power submitted an application for a licence to prepare the site for the MMRTM on AECL property at CNL2. Phase 2, Pre-Licensing Assessment for Any Potential Fundamental Barriers to Licensing3 however, requires further details needed to identify any fundamental barriers to licensing the vendor's design in Canada. Submitting a licence application for site preparation before Phase 2 thus does not appear to be a logical step of a licensing process. Moreover, CNL is ...
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Attachment From National Council of Women of Canada to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of National Council of Women of Canada
  • Reference number: 61
  • Submitted: 2019-09-23 - 1:00 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  •   Ms. Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission     Dear Ms. Rupert, As per my phone call just now, attached is a very  slightly edited  National Council of Women Brief, which was sent to you by NCWC  President, Patricia Leson on September 14th , regarding Global Power’s Project Description for a Micro Modular Nuclear Reacto. I have : 1) corrected  the reversal in the project title, 2) added background reference material for reference # 7, and,  3) corrected the reference list alignment. We would appreciate it very much if this  corrected version of our brief could be substituted for the original one. Regards, Gracia Janes 1st VP NCWC, with responsibility for our  environmental issues
  • Attachment included
  • 1 Canadian Nuclear Safety Commission Aimee Rupert Environmental Assessment Officer Cnsc.ea.ccsn@canada.ca September 14th 2019 Re: 80182 Global Power “Project Description” for Proposed Micro Modular Nuclear Reactor at CNL Chalk River Site The National Council of Women of Canada (NCWC) has strong precautionary policy regarding the many dangers of nuclear power to public health and safety and the environment, and we are recently on record with the Canadian Environmental Assessment Agency as supporting full Environmental Impact Assessments for small modular nuclear reactors, under the 2019 Impact Assessment Bill C-69 .1. Therefore, NCWC is extremely concerned that Global Power’s micro-modular nuclear reactor “project”, the first of its kind to get to this stage of CNSC’s application process , and therefore a precedent-setting one, is instead subject of a CNSC “review” , and “assessment” under the much weaker 2012 Canadian Environmental Assessment Act. Given CNSC’s guidance to the nuclear industry and promotion of micro nuclear reactors as the next generation of electricity providers across Canada , NCWC doubts the impartiality of this process. 2. Nevertheless, in the public interest NCWC raises the following issues of great concern regarding Global Power’s nuclear micro reactor, as this project :  is the first reactor of its kind to use extremely dangerous enriched uranium as fuel and this raises concerns about nuclear proliferation 3.  Is likely to experience the same types of accidents , and failures of similar reactors in the USA and Europe. 4.  may fail commercially, as these types of reactors have not been ...
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Attachment From Canadian Coalition for Nuclear Responsibility to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Canadian Coalition for Nuclear Responsibility
  • Reference number: 59
  • Submitted: 2019-09-23 - 12:52 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Comments on Global First Power's Inadequate Project Description for the Micro Modular Nuclear Reactor Project at Chalk River  To whom it may concern,   The Canadian Coalition for Nuclear Responsibility (CCNR) considers the MMR 'project description’ to be totally inadequate, as it does not address in any meaningful way the decommissioning of the facility at the end of its useful lifetime, nor the ultimate disposition of the various waste streams. It also fails to discuss the behaviour of the core under any specific accident scenarios. The proposed reactor will generate post-fission radioactive wastes of all kinds, from high-level waste (irradiated nuclear fuel) to a wide variety of low and intermediate level wastes. All of these waste streams will involve many varieties of human-made radioactive poisons including fission products (like radioactive cesium, radioactive iodine, and radioactive strontium) and/or transuranic actinides (like plutonium, americium, neptunium and curium) and/or activation products (like tritium, carbon-14, radioactive varieties of iron and nickel isotopes, and many more).   Since the proposed reactor is intended to serve as a prototype for eventual deployment in many isolated locations in Canada, the details of dismantling the radioactive structure, protecting the workers, preventing the spread of long-lived radioactive dust (i.e. particulates of carbon-14 and/or alpha-emitting plutonium and other actinides) in the community, as well as packaging the wastes and shipping them off-site, must all be spelled out.  In particular what roadway or railbed requirements will be required to accommodate the transport ...
  • Attachment included
  • CCNR Comments on the Project Description of the MMR (Micro Modular Reactor) proposed to be constructed and operated at the Chalk River site. 1 The Canadian Coalition for Nuclear Responsibility (CCNR) has concluded that the existing Project Description is extremely simplistic and entirely unsatisfactory, amounting to little more than a cursory overview of the project in a very superficial manner. Measurements and dimensions of the fuel and details of the core geometry are absent, quantification of pressures, temperatures, and rates of flow are missing, even the level of enrichment of the fuel is unspecified. There are few details given regarding the construction of the MMR, when it is non- radioactive, but there is no detail at all provided for the much more challenging job of dismantling the radioactive structure without benefit of a decades-long cooling-off period that has been advocated by Canadian utilities such as Ontario Power Generation, Hydro Quebec and NB Power, prior to the dismantling of their reactors. The Project Description also fails to discuss the behaviour of the reactor core under any specific accident scenarios. A far more detailed project description should be required by the CNSC, along the lines of the 2009 CNSC regulatory document entitled CONSTRUCTION LICENCE APPLICATIONS FOR NUCLEAR POWER PLANTS: GUIDELINES dated June 2009. There should unquestionably be a thorough environmental assessment of this MMR, the first reactor of its kind ever proposed for Canada or indeed anywhere. Given the paucity of information in the wholly inadequate Project Description, CCNR will limit is comments at this time (pending a more detailed Project Description) to some general comments ...
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Attachment From Tony Reddin and Marion Copleston to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Tony Reddin and Marion Copleston
  • Reference number: 58
  • Submitted: 2019-09-23 - 12:49 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To whom it may concern, This 'project description' is inadequate; our comments are attached. Thank you,  Tony Reddin & Marion Copleston, Bonshaw PEI [Address Redacted]
  • Attachment included
  • Comments on Global First Power's Inadequate Project Description for Micro Modular Nuclear Reactor (MMNR) Project at Chalk River - September 14, 2019 To whom it may concern, This 'project description' is inadequate; our comments are below. Thank you, Tony Reddin & Marion Copleston, ------ 1. There is inadequate description of activities to be performed in relation to the project : a) use of enriched uranium fuel - a description of fuel fabrication activities should be part of a complete project description. b) waste management- a description of any gaseous wastes being produced during plant operation; and details on plans for packaging, storage, transport, and disposal of Low and Intermediate Level Waste should be part of a complete project description. c) decommissioning- a complete plan to deal with irradiated graphite waste and concrete should be part of a complete project description. 2. The project description does not acknowledge that this novel MMNR reactor type is likely to entail high and uncertain decommissioning costs, and does not explain how these costs would be estimated. 3. The project description does not acknowledge financial support that federal authorities are, or may be, providing to the project. 4. If the CNSC decides to proceed to a scoping of an environmental impact statement for this project, despite these deficiencies, the scoping decision should be made by the full Commission and should include a public hearing with advance notice. In past, the Commission has made environmental assessment scoping decisions at one-member hearings held with no public notice. In one case, this hearing took place only a matter of days before release of an ...
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Attachment From Sunil Nijhawan to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Sunil Nijhawan
  • Reference number: 56
  • Submitted: 2019-09-23 - 12:46 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa ON  K1P 5S9   Hello Ms. Rupert:   I attach my comments on Global First Power's Small Modular Nuclear reactor proposed for Chalk River.   Regards,   Sunil Nijhawan, Ph.D, P.Eng  
  • Attachment included
  • 1 Invited Public Comments on 'Project Description for the Micro Modular Reactor project at Chalk River Submitted by Sunil Nijhawan, Ph.D, P.Eng, Toronto As a nuclear engineer with over 35 years of experience in design evaluation, safety assessments and licensing certification of a number of US, Russian and Canadian power and research reactors, I am in shock at certain CNSC staff declaring such a project description document acceptable. Any university professor of engineering , like I was once, would not have given this group 'report' even a low passing grade. The students would have been encouraged to a complete redo or choose failing or withdrawing from the course. I am a 'pro-nuclear' engineer specializing in power and research reactor safety who insists on demonstrably safe nuclear options and would have liked to see a much better document in order to do a preliminary assessment of the technical viability and potential environmental impacts of the whole cycle of activities associated with such a project. Unfortunately I have been well exposed from within the industry to a growing trend in obfuscation and a collapse of safety culture especially at the bureaucratic top. I am disturbed as much by what I see in this document as by what I do not see. I still wish the proponents good luck in their endeavors and encourage them to make a more serious submission. Being a specialist in the history and science of severe nuclear reactor accidents, I am painfully familiar with the failures in small 'modular' nuclear reactors of the past that have contributed horrifically to significant yet in many cases unreported environmental damage. I am aware of the institutional and technical failures that lead to those accidents and ...

Attachment From Marilee DeLombard and Deb Powell to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Marilee DeLombard and Deb Powell
  • Reference number: 55
  • Submitted: 2019-09-23 - 12:40 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • TO: Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046 Station B, 280 Slater Street Ottawa, ON  K1P 5S9 Email: cnsc.ea-ee.ccsn@canada.ca (mailto:cnsc.ea-ee.ccsn@canada.ca)   Subject:  Global First Power Project's Description for the "Micro Modular Reactor" to be constructed and operated at Chalk River     In this document we are offering our comments regarding Global First Power Project's Description for the "Micro Modular Reactor" to be constructed and operated at Chalk River.    There are troubling omissions in the Project Description.   These omissions cover important financial matters and scientific concerns.    In the project description the proponent does not indicate a plan for the disposal of the nuclear waste that will be generated by the project.  This missing factor is a critical concern because no secure, effective method of disposal of nuclear waste exists to date.     The proponent's submission lacks information about financing; specifically the amount required from federal funds.   The enormous cost of nuclear power plant construction is only overshadowed by the long-term cost of waste management.  In the case of nuclear power, the waste management lasts for hundreds of thousands of years.   Canada would be further ahead to invest in existing, proven renewable energy technologies.   The proponent's submission does not indicate the source of the fuel for the "Micro Modular Reactor".  Dealing with enriched uranium fuel ...

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Attachment From M. V. Ramana to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of M. V. Ramana
  • Reference number: 54
  • Submitted: 2019-09-23 - 12:20 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To   Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa ON  K1P 5S9   Please find attached a letter in response to the Canadian Nuclear Safety Commission’s (CNSC) Updated Public Notice dated August 9, 2019, inviting comments on the Project Description of Global First Power’s Micro Modular Reactor (MMR) Project at Chalk River. I am happy to offer any further information.   Thank you for this opportunity to offer my input, Ramana     ------------------ M. V. Ramana Professor and Simons Chair in Disarmament, Global and Human Security Director, Liu Institute for Global Issues School of Public Policy and Global Affairs University of British Columbia [Phone number redacted] https://sppga.ubc.ca/profile/m-v-ramana/
  • Attachment included
  • 14 September 2019 SUBMISSION TO THE CANADIAN NUCLEAR SAFETY COMMISSION REGARDING THE PROJECT DESCRIPTION FOR GLOBAL FIRST POWER’S MICRO MODULAR REACTOR I am submitting this letter in response to the Canadian Nuclear Safety Commission’s (CNSC) Updated Public Notice dated August 9, 2019, inviting comments on the Project Description of Global First Power’s Micro Modular Reactor (MMR) Project at Chalk River. I have expertise and many years of experience in analyzing the safety and environmental impacts of nuclear power related facilities including Small Modular Reactors (SMRs). I have published several peer reviewed papers and reports on the topic. For a selection of my works, please see https://sppga.ubc.ca/profile/m-v-ramana/ Global First Power (GFP), the Project proponent, is proposing a Small Modular Reactor (SMR) project using MMR technology. There are several reasons to be concerned about a High Temperature Gas Cooled Reactor (HTGR) of the kind that GFP is proposing. Below, I describe two key issues: a history of poor performance and persistent problems in HTGRs that have been constructed and operated; and the potential for severe accidents that could result in the release of radioactive materials from the reactor and adversely affect the environment. The project description does not include any discussion of these problems. Finally, I list some key issues that are inadequately addressed in the proposal. Therefore, there should be a rigorous and comprehensive environmental assessment, and the public and independent inputs into the assessment should be sought, before the proposal moves any further. History of Poor Performance and Persistent Problems There is ...

Attachment From Brad Blaney to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Brad Blaney
  • Reference number: 53
  • Submitted: 2019-09-23 - 12:18 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Canadian Nuclear Safety Commission Aimee Rupert, Environmental Assessment Officer P.O. Box 1046 Station B, 280 Slater Street Ottawa ON K1P 5S9 Email: cnsc.ea-ee.ccsn@canada.ca September 13, 2019 Re: SMR Consideration for approval by CNSC Dear Ms. Rupert and CNSC Members, Please consider the following in consideration of your review of this matter:    How will Mr. Binder and the CNSC ignore the past and recent history of SMR safety? Specifically; There are proven dangers and risks associated with the use of metals or liquid sodium for a heat sink. Please reference;  the 1995 liquid sodium leak/cover up and the subsequent 2010 restart accident at the Monju Sodium FB Reactor in Japan; the SMR explosion at the Russian missile site in July 2019 releasing large amount of isotopes ; and the SMR turbine fire in aRussian research submarine in June 2019 resulting in the deaths of 15 senior nuclear technicians beneath the Arctic Ocean. Since this is new technology with a very expensive/sad service history, what experience does the Commission have to examine SMR’s?    Will the CNSC review include evaluating the financial stability, and/or evaluating criminal investigations underway into suppliers/partners in the construction of the  SMR (i.e. SNC Lavalin and General Electric/Fluror corp/Babcox etc)? Does the Commission even take such issues into consideration when evaluating the integrity of suppliers? Why has the CNSC failed to provide any review/reports on its web site regarding the recent SMR accidents in Russia, even when it is now undertaking ...

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Attachment From Canadian Environmental Law Association to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Canadian Environmental Law Association
  • Reference number: 51
  • Submitted: 2019-09-23 - 12:11 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To whom it may concern,   Please see attached for the submission of the Canadian Environmental Law Association pertaining to the Project Description for Global First Power's small modular reactor at Chalk River.   Regards,   Kerrie ---   Kerrie Blaise Northern Services Counsel Canadian Environmental Law Association 55 University Avenue, Suite 1500 Toronto, ON M5J 2H7     cela.ca (http://cela.ca/) Twitter: @KerrieABlaise (https://twitter.com/KerrieABlaise) @CanEnvLawAssn (https://twitter.com/CanEnvLawAssn)
  • Attachment included
  • Canadian Environmental Law Association T 416 960-2284 • 1-844-755-1420 • F 416 960-9392 • 55 University Avenue, Suite 1500 Toronto, Ontario M5J 2H7 • cela.ca SUBMISSION BY THE CANADIAN ENVIRONMENTAL LAW ASSOCIATION TO THE CANADIAN NUCLEAR SAFETY COMMISSION REGARDING THE PROJECT DESCRIPTION FOR GLOBAL FIRST POWER’S MICRO MODULAR REACTOR September 14, 2019 Prepared by Kerrie Blaise, CELA Counsel I. INTRODUCTION The Canadian Environmental Law Association (CELA) submits this letter in response to the Canadian Nuclear Safety Commission’s (CNSC) Updated Public Notice dated August 9, 2019, inviting comments on the Project Description of Global First Power’s Micro Modular Reactor Project at Chalk River (herein, “small modular reactor” or “SMR”). While CELA requests the CNSC not proceed with the proposal nor expand Canada’s fleet of nuclear reactors, in the event Global First Power’s project description does advance within the environmental assessment (EA) process, we provide the following comments to the CNSC: • A federal environmental assessment per the Canadian Environmental Assessment Act, 2012 (CEAA 2012) must be conducted in this case; • The CNSC, as an authority to conduct environmental assessment, should not conduct this review as it lacks the requisite independence and expertise; • The project description is incomplete and fails to (1) meet the prescribed information requirements set out in Regulations pursuant to CEAA 2012; (2) consider proliferation risks accompanying SMRs; and (3) consider the environmental, social, intergenerational and ethical impact of creating new sources of radioactive wastes; and • The ...
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Attachment From Joanne Murray to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Joanne Murray
  • Reference number: 50
  • Submitted: 2019-09-23 - 12:10 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To the attention of Aimee Rupert, Environmental Assessment Officer for the Canadian Nuclear Safety Commission. Please consider my comments in the attachment to this email. sincerely, Joanne Murray, a concerned citizen in Renfrew County
  • Attachment included
  • I am submitting “ Comments on Global first Power’s Project Description for the Micro Modular Reactor to be constructed and operated at Chalk River.” I strongly oppose the plan to construct and operate such a reactor at Chalk River. It is known that these small nuclear reactors are only in the early design stage .and that they will need years to develop. In a time when global warming and all the challenges related to this are pressing let us instead concentrate on increasing renewables and focusing on reducing greenhouse gases. We know that these SMRs produce toxic and long lived radioactive waste that ( must ) be kept safely for milennia. We do not have the right to burden our future generations with the ongoing costs and dangers that are associated with these Micro Modular Reactors. Our record shows ( sadly and glaringly ) that we have not come up with satisfactory ways of dealing with the wastes already produced by our nuclear industry. I along with many others note serious problems with this current project description. The following are the most glaring: -Lack of a plan to manage the waste generated by the project. -Missing details on $ support by federal authorities. -Where will the enriched fuel come from fro this project -Lack of risks of proliferation and terrorism associated with the use of enriched fuel. Respectfully submitted by Joanne Murray

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Attachment From Environment North to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Environment North
  • Reference number: 48
  • Submitted: 2019-09-23 - 12:04 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Please find attached our letter from Environment North from Ms. Dodie  LeGassick  and Mr. Graham Saunders.
  • Attachment included
  • Submissions of Environment North to the Canadian Nuclear Safety Commission Regarding the Micro Modular Reactor Project at Chalk River September 14, 2019 This is the submission of Environment North and also a letter in support of the submission received by the Canadian Environmental Law Association regarding the project description for the Micro Modular Reactor Project at Chalk River (herein, “MMR” or “SMR”). Since 1972, Environment North has functioned as a regional non-governmental environmental organization.1 Through research, education and community advocacy we promote sustainable communities and conservation of our resources. Based in Thunder Bay, our goal is to benefit the community by protecting the environment and increasing the public's understanding of the environment. Our comments on the project description are as follows. First, because of the use of thresholds introduced in the Project List under the Impact Assessment Act, this will be Canada’s first and last SMR to undergo a federal environmental assessment. While we have requested the rationale for this threshold-approach to be explained and supported by scientific evidence, this request remains outstanding. We reiterate our concern about this threshold approach. For instance, an electricity generating facility of 199 MW could supply a small city such as Kingston and can have significant impacts to the environment. Also, by way of example, from 2002 to 2005 Environment North and others had considerable concerns over a proposal by Synfuel Technologies to build a 199 MW power generation facility in Thunder Bay. The method was by gasification of petroleum coke and export to the Midwest ...

Attachment From Janet Graham to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Janet Graham
  • Reference number: 47
  • Submitted: 2019-09-23 - 12:03 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Dear Ms. Aimee Ruperty,   Please post the comments below on "comments received/responses" relating to the Micro Modular Reactor Project at Chalk RIver, Ontario Reference # 80182.   Thank you, Janet Graham   The project description is woefully lacking, with multiple deficiencies.  It does not meet requirements to provide citizens with basic understandings of the project, its scope, or potential environmental impacts.  The fuel itself is also not adequately described, nor are the characteristices of the radioactive wates that will be generated or how they will be managed over very long periods of time.  Transparency and public trust in the process, are among monumental issues at stake in this process.    The focus of descriptions of context and objectives of the project should be on the interests of the publc and the environment, rather than rather than on the narrow, short-term interests of"comercial viability of the MMR technology to prospective customers".   Descriptions of the physical works relating to the project, including their purpose, size and capacity are also inadequate.  More precise, detailed descriptions (including the scope of the project) are required.     In addition, the activities to be performed in relation to the project require more precise, full descriptions.  Commercialization of reactors with high U-235 ...

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Attachment From Bonnechere River Watershed Project to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Bonnechere River Watershed Project
  • Reference number: 46
  • Submitted: 2019-09-23 - 12:00 PM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Re:  Document Number CRP-LIC-01-001     Comments in attached.     Please acknowledge receipt.   Regards,   Kathryn Lindsay, Ph.D (Wildlife Ecology) Renfrew, ON chair@BonnechereRiver.ca [Redacted]   Bonnechere River Watershed Project 73 Renfrew Ave. E, Renfrew, ON  K7V 2W7 Website: www.BonnechereRiver.ca (http://www.bonnechereriver.ca/) Facebook : www.facebook.com/bonnechereriver (http://www.facebook.com/bonnechereriver) Email:    info@BonnechereRiver.ca   "Helping Ourselves to a Healthy Environment"
  • Attachment included
  • Bonnechere River Watershed Project 73 Renfrew Ave. E, Renfrew, ON K7V 2W7 Email: info@BonnechereRiver.ca Website: www.BonnechereRiver.ca Facebook : www.facebook.com/bonnechereriver “Helping Ourselves to a Healthy Environment” Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046 Station B, 280 Slater Street Ottawa ON K1P 5S9 Telephone: 613-943-9919 or 1-800-668-5284 Fax: 613-995-5086 Email: cnsc.ea-ee.ccsn@canada.ca Submitted (via email): 14 September 2019 Subject: Comments on Global First Power's “Project Description for the Micro Modular Reactor Project at Chalk River” Document No: CRP-LIC-01-001 On behalf of the Bonnechere River Watershed Project, I would like to express our concern about Small Modular Nuclear Reactors and the Global First Power proposal to construct and operate the first SMR in Canada at the Canadian Nuclear Laboratories property in Chalk River, Ontario. Our particular concerns about SMRs include: - SMRs are only in the early stage of design and will take many years to develop; unlike the operating reactors in Canada, the designs are largely untested; - SMRs are not commercially viable and cannot be developed without large tax subsidies; - Reactors similar to the one being proposed by Global First Power have been constructed in the United States and Germany; these have had a poor track record and a history of accidents and failures; the wastes are highly radioactive; - accidents will be even more challenging to deal with given the intention to deploy SMRs in mine sites, small and/or remote and Northern communities; - SMRs produce toxic, long lived radioactive waste that must be ...
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Attachment From Valerie Needham to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Valerie Needham
  • Reference number: 45
  • Submitted: 2019-09-23 - 11:58 AM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • Mme. Rupert,   Please find attached my signed letter regarding the GFP Proposal for MMR Project at Chalk River (CEAA Reference number 80182).   My address: [Redacted]   My telephone number: [Redacted]   I trust that this submission is in time.   Regards,    Valerie Needham
  • Attachment included
  • September 14, 2019 Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046 Station B 280 Slater Street Ottawa ON K1P 5S9 Dear Mme. Rupert, Re: Comments regarding in Global First Power’s (GFP) Project Description (PD) for a Micro Modular Reactor (MMR) Project at Chalk River, Ontario CEAA Reference number 80182 I am writing to express my dismay at the lack of specificity and the danger of the entire concept in Global First Power’s (GFP) Project Description (PD) for a Micro Modular Reactor (MMR) Project at Chalk River, Ontario. Thanks to the CNSC for this opportunity to comment and I appreciate that the comment period was extended until September 14th. More generally, I have grave concerns about the utility and safety of Small Modular (should read Nuclear) Rectors and their proposed use across northern Canada. There are many unanswered questions around the cost of their development, the safety of their installation, the shortness of their lifespan and the details around their decommissioning, disposal of their radioactive waste and their site abandonment. The issues of ongoing security, monitoring and disposal of SMRs throughout the north has not been addressed. SMRs are described as being a source of ‘clean’ energy when, in fact, they are filthy with the radioactive legacy that they will leave behind. (“The MMR technology will replace their current reliance on costly and greenhouse emitting fossil fuels with a clean and reliable nuclear- powered energy source.” p.16) Have SMRs been exempted from a full Environmental Review in Bill 69? If so, this is a travesty. Global First Power’s (GFP) Project Description (PD) for a Micro Modular ...

Attachment From Jeff Brackett to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Jeff Brackett
  • Reference number: 44
  • Submitted: 2019-09-23 - 11:54 AM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To: Aimee Rupert,  Environmental Assessment Officer, Canadian Nuclear Safety Commission     I am writing to comment on the Global First Power’s proposed Micro Modular Reactor (MMR) at Chalk River. I strongly urge that this proposal be subjected to a full environmental assessment including a hearing with an independent panel and participant funding.   I suggest that if the proposal to move forward with small nuclear reactors is approved it will lead to a proliferation of under regulated nuclear reactors popping up across the country with very little community involvement, increased public exposures to routine emissions of ionizing radiation, and no real workable plan for clean up, decommissioning and waste management.    Thank you,   Jeff Brackett

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Attachment From David Prentice to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of David Prentice
  • Reference number: 43
  • Submitted: 2019-09-23 - 11:53 AM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To Aimee Rupert, Environmental Assessment Officer Dear Ms. Rupert,   My submission is attached as a PDF file. Thank you.
  • Attachment included
  • Statement for the Canadian Nuclear Safety Commission David L. Prentice Saturday, September 14, 2019 I am writing to express my highest concern over the Small Nuclear Reactor planned for the Chalk River facility. I am the nearest full-time downstream resident to this plant, and I am lately hearing too often of new activities that have me, my neighbours, and many others deeply worried about what CNL and the Canadian Nuclear Safety Commission are up to. The waste dump and the decommissioning of Rolphton were bad enough and still concern us greatly, and now we are having to deal with SMRs. The combination of these three pro- posals in such a short period of time suggests some sort of melodramatic plot to destroy the peace of the Ottawa Valley. SMRs are presented as the latest thing in nuclear technology, safe and inexpensive, but to us they are the next worse thing — new technology heretofore prohibited in Canada, un- tested, and resulting in high-level waste. As the neighbours and the public at large are drawn into these discussions, we continue to be worried when our scientific allies point out significant unanswered questions and draw- backs. It is becoming more apparent to us that we can’t present cogent scientific arguments by ourselves, in our own words. This is highly technical stuff, and we are not likely to add anything new to the discussion. Instead of my trying to summarize the science, I will cite the submission of the Concerned Citizens of Renfrew County and Area (Document 20, August 19). I also fully support the submission from Gilles Provost ((Document 11, August 10). Nuclear science is a lot more complex than our demanding a Stop sign at an accident- prone intersection in our ...
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Attachment From Francis Style to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Francis Style
  • Reference number: 42
  • Submitted: 2019-09-23 - 11:29 AM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • To: Aimee Rupert, Environmental Assessment Officer Canadian Nuclear Safety Commission   By email:  cnsc.ea-ee.ccsn@canada.ca   Re: Comments on Global First Power’s Project Description for the Micro Modular Reactor Project at Chalk River   CEAA Reference Number: 80182     Dear Aimee Rupert, I spend 6 weeks every summer on an island in the Ottawa River, facing the Petawawa military base, only a few kilometers downriver from Chalk River. The Ottawa River has been contaminated by the NRX reactor started up at Chalk River in 1947 and by the more powerful NRU reactor started up in 1957. Since that period, the radioactive waste has not been adequately managed and the public has not been kept aware of the danger, particularly for those living along the Ottawa River below Chalk River. The proposed Micro Modular Reactor, or any other small modular nuclear reactor, represents a huge potential threat. A rigorous environmental assessment is absolutely required. Sincerely, Francis Style

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Attachment From Kenneth Birkett to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Kenneth Birkett
  • Reference number: 41
  • Submitted: 2019-09-23 - 11:26 AM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • TO Aimee Rupert    Environmental Assessment Officer Please consider the points raised in the attached brief to the assessment commission.   Thank you                                  Kenneth Birkett BASc.
  • Attachment included
  • Comments on Global First Power’s Proposal to Build Micro Modular Reactors I am strongly opposed to any project to build reactors of any size anywhere and especially not at Chalk River. There is no plan in the proposal on how to deal with the high level radioactive waste that would be produced and no indication of where the enriched nuclear fuel would come from. The very concept of smaller reactors located all over our country including remote locations means that super radioactive fuel (much more dangerous than that used in Candu reactors) and its high level radioactive waste would be transported all over the country from and to sources or disposal sites. This fact alone means that the exemption from an environmental impact assessment is a mistake with huge potential consequences. How can we expect to manage safety inspections and compliance issues for reactors all over our remote areas where transportation alone is a huge obstacle? How can we even think the fuel supply process and waste storage issues will have solutions when we have not solved these problems after 30 or more years of study on Candu fuel and waste? The answer is of course that there is no good way to dispose of radioactive wastes, especially high level nuclear fuel wastes. I hope that the CNSC and the government of Canada will also see that this proposal would not yield results for many, many years and that renewable energy options are available right now without a huge and ongoing expenditure of tax dollars. In fact, I must conclude that proposals to build new reactors or poorly thought out disposal sites are just ways that this industry can keep on bilking billions of dollars out of our economy. I must ...
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Attachment From Kelly Clune to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

  • Micro Modular Reactor Project
  • Author: Administrator on behalf of Kelly Clune
  • Reference number: 40
  • Submitted: 2019-09-23 - 11:25 AM
  • Participation notice: Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
  • September 10, 2019 Canadian Nuclear Safety Commission Aimee Rupert, Environmental Assessment Officer P.O. Box 1046 Station B, 280 Slater Street Ottawa ON K1P 5S9 Email’d to: cnsc.ea-ee.ccsn@canada.ca Re: Requested license for Micro Modular Reactor Dear Aimee and SNSC employees, At first notice of this proposal I truly thought it was part of a Rick Mercer or SNL (Saturday Night Live) comedy skit.  It had to be a joke, right?!  Canada, after all, already has a serious nuclear waste problem.  Imagine the nightmare that mini nuclear reactors could bring?!! It is concerning that nuclear proponents continue to work on new reactors when so many serious issues are still outstanding with current reactors.  The errors of nuclear energy have left a disgraceful environmental and financial legacy for future generations. Canada’s financial debt, from the nuclear agenda, is devastating!  What guarantees would these corporations, proposing this project, provide to protect public taxpayers - Global First Power, Ultra Safe Nuclear Limited (honestly, who came up with this one “ultra safe”??), and as always, Ontario’s partner in make-work projects (so public funds continue to flow their way), Ontario Power Generation (OPG)? Financial, environmental and social impacts of this proposal need to be examined extensively.  This requires a full environmental review, and a hearing, which must include an independent panel, participant funding and a wide variety of ...

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