RE: Potential Regional Assessment of Radioactive Waste Disposal inthe Ottawa Valley (Reference # 81624)

Dear Mr. Bonnell

Concerned Citizens of Renfrew County and Area (CCRCA) is an incorporated, non-profit organization that has been working for the clean-up and prevention of radioactive pollution from the nuclear industry in the Ottawa Valley for 40+ years. 

We support the City of Ottawa's request for a regional assessment of Ottawa Valley radioactive disposal projects. (Reference # 81624)

We would like to request that you consider the following points during preparation of your advice to the Minister:

Radioactive waste in the Ottawa Valley is a very large and complex problem. It makes up the lion's share of federally-owned "legacy" radioactive wastes, an $8 billion liability for the citizens of Canada. This federal radioactive cleanup liability exceeds the sum total of 2000 other federal environmental liabilities (https://concernedcitizens.net/2020/10/06/the-government-of-canadas-radioactive-wastes-costs-and-liabilities-growing-under-public-private-partnership/) . As Canada's largest and most complex federal environmental liability, this challenge is worthy of the best and most thorough assessment available under the new Impact Assessment Act.

Proposed Ottawa Valley radioactive disposal projects are substandard, highly controversial, and would NOT address many parts of the needed cleanup. The proposed Chalk River Mound ("Near Surface Disposal Facility") and Rolphton Reactor Tomb ("NPD Closure Project") are low budget, inadequate proposals meant to quickly and cheaply (https://concernedcitizens.net/2020/11/03/aecl-cnl-contract-excerpt-all-wastes/) reduce Canada's federal nuclear liabilities. The two projects were proposed five years ago by a consortium of private companies contracted by the Harper government in 2015. The proposals ignore safety standards of the International Atomic Energy Agency (https://concernedcitizens.net/2020/11/24/several-ex-aecl-scientists-have-pointed-out-that-all-three-of-cnls-proposed-nuclear-waste-projects-fail-to-meet-the-international-atomic-energy-agency-safety-standards-for-radioactive-waste-faciliti/) and have been found wanting in thousands of critical comments submitted by Indigenous communities, municipalities, former AECL scientists and managers, NGOs, citizens' groups and individuals.

The projects are expected to leak radioactive contaminants (https://concernedcitizens.net/2020/11/05/the-chalk-river-mound-and-two-reactor-tombs-would-leak-radioactive-contaminants-for-millennia/) into the Ottawa River for millennia, according to Environmental Impact Statements produced by the proponent. The giant Chalk River Mound is expected to disintegrate (https://concernedcitizens.net/2020/11/04/the-proponents-own-study-shows-that-the-chalk-river-mound-will-disintegrate/) as part of a process of "normal evolution" according to the proponent's "performance assessment" study.

The vast majority of radioactive wastes in the Ottawa Valley would NOT be addressed by these two projects (https://concernedcitizens.net/2020/12/30/the-gigantic-chalk-river-mound-the-so-called-nsdf-would-not-reduce-canadas-radioactive-waste-liabilities-and-could-in-fact-increase-them/).

Environmental assessments of the giant mound and reactor tomb are being badly fumbled. The environmental assessments of the NSDF and NPD closure projects were initiated in 2016 by the Canadian Nuclear Safety Commission. Numerous problems with the CNSC's handling of the EAs were identified in Environmental Petition 413 (https://concernedcitizens.net/2018/01/29/environmental-petition-413-to-the-auditor-general-of-canada-environmental-assessment-of-nuclear-projects/) to the Auditor General of Canada in January 2018. Problems have continued to arise including lack of opportunity for public input, lack of transparency, and lack of firm deadlines for completion of the assessments. The EAs have been ongoing for far longer than is normal or reasonable for such assessments.

The Canadian Nuclear Safety Commission has been identified as a captured regulator (https://concernedcitizens.net/2021/03/12/who-will-fix-canadas-nuclear-governance-gaps-citizens-groups-hill-times/) that promotes the projects it is supposed to regulate (https://concernedcitizens.net/2021/04/12/reforms-needed-at-canadian-nuclear-safety-commission-say-activists/). The CNSC is therefore not an ideal agency to be overseeing assessments of radioactive disposal projects in the Ottawa Valley.

The complex challenge of nuclear waste in the Ottawa Valley is NOT addressed by the assessments that are currently ongoing. Again, the eight billion dollar federal radioactive cleanup liability is the biggest and most expensive federal environmental challenge by far. The vast majority of the wastes comprising this liability are already in the Ottawa Valley at the Chalk River Laboratories. For an indication of the complexity of this challenge at Chalk River see the Ottawa Citizen article by Ian McLeod, Chalk River's Toxic Legacy. (https://ottawacitizen.com/news/chalk-rivers-toxic-legacy) Radioactive wastes not addressed by the mound and the tomb proposals include the three reactor cores dumped in the sand at Chalk River (including one from the 1952 NRX partial meltdown), the highly radioactive solidified medical isotope production wastes (including weapons-grade uranium-235), the tanks of intermediate- and high-activity liquid wastes at the ‘Waste Tank Farm”, the spent fuel from the NRX, NRU and NPD reactors, and the NRX and NRU reactors themselves.

The private sector consortium running Canadian Nuclear Laboratories plans to consolidate (https://concernedcitizens.net/2020/11/04/cnls-integrated-waste-strategy-alarms-downstream-residents/) the federal government's radioactive waste from across Canada in the Ottawa Valley and is already shipping radioactive wastes from Manitoba, Quebec and elsewhere in Ontario to Chalk River. There are serious concerns about consolidating federal nuclear wastes at the Chalk River site, in a seismically-active area, beside a major river (The Kitchissippi/ Ottawa) that provides drinking water for millions of Canadians. Consolidation of federal government nuclear wastes is not addressed by the current NSDF and NPD environmental assessments.

Concerned Citizens of Renfrew County and Area recently learned that the consortium is going ahead with radioactive waste plans such as such as a cask facility to receive shipments of highly-radioactive spent fuel from the Whiteshell (MB) and Gentilly-1 (QC) reactors and a new intermediate-level waste storage facility that would likely contain high-activity commercial wastes. The consortium is making decisions about these activities on behalf of Atomic Energy of Canada with no transparency or public input. There are potentially significant risks and implications of these projects and they should be part of a transparent public process.

The cumulative impacts of all wastes and all current and future projects need to be considered together. A regional assessment could do this.

A regional assessment of radioactive waste in the Ottawa Valley could address all problems noted above and provide many benefits, to communities in the Ottawa Valley and to federal, provincial and municipal governments. A regional assessment could:

• make existing baseline data publicly accessible and produce a broad-based analysis of the problem
• look at cumulative impacts of all the current and proposed management strategies for Ottawa Valley radioactive wastes
• address leaking waste management areas at the Chalk River Labs, radioactive waste imports to the Ottawa Valley and the potential creation of new wastes associated with the proposed new "small modular" reactor research and development
• incorporate Indigenous knowledge and priorities
• look at the big picture including the need to protect drinking water, property values and tourism and provide secure long-term employment opportunities for Ottawa Valley communities.
• provide assurance to the federal government and other levels of government that the largest federal environmental cleanup liability is being properly addressed.

We appreciate the opportunity to comment. We would like to be kept informed about your review of this matter and would like to receive a copy of your advice to the Minister.

Best wishes,

Lynn Jones

Concerned Citizens of Renfrew County and Area (http://concernedcitizens.net)