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To: Hon. Catherine McKenna, MP
Date: Wed, May 17, 2017 at 8:31 AM
Subject: Near Surface Disposal Project – your urgent attention required
Dear Ms. McKenna,
We are writing to express our growing concerns about the proposed Near Surface Disposal Facility (NSDF) at Chalk River, Ontario. We request your urgent attention and efforts along with those of your cabinet colleagues to put a stop to the NSDF Project.
It has become very clear that the landfill type technology proposed for this project is entirely inappropriate and flouts the International Atomic Energy Agency safety standard (IAEA safety standard SSR-5 Disposal ofÂ RadioactiveÂ Waste, Section 1.14) on how to manage radioactive wastes. This international standard states that landfills can only be used for “Very Low Level” radioactive wastes, such that the wastes decay to a harmless state before the liners and covers break down. The international consortium now running AECL, Canadian Nuclear Laboratories (CNL), is proposing to place one million cubic meters of “Low Level” and “Intermediate Level” radioactive waste in the NSDF landfill. No mention is made in the proponent’s Environmental Impact Statement (EIS) of “Very Low Level” radioactive wastes, the only classification of radioactive waste that would be considered suitable for disposal in a landfill by the IAEA.
The proponent’s EIS clearly states their intention to dispose of ALL of the radioactive wastes from decommissioning at the Chalk River facility and Whiteshell Labs in Manitoba in the NSDF landfill. This includes many highly-toxic and long-lived radionuclides that will be hazardous for thousands of years. The relevant section of the EISÂ may be viewed (here). Some of these radioactive wastes are also mixed with toxic heavy metals such as lead, cadmium and arsenic; and with persistent organic pollutants such as dioxin and PCBs. To propose to dispose of and ultimately abandon such materials in a landfill beside the Ottawa River is brazen and scientifically indefensible.
This proposal should never have reached the Environmental Assessment stage given that from the outset it clearly proposed to violate IAEA standards on management of radioactive waste. Canada’s gutted Environmental Assessment process and Canada’s policy vacuum on the long-term management of non-fuel radioactive wastes are two factors contributing to this potential debacle, which have negative implications for all projects involving the governance of radioactive waste in Canada. We are preparing a petition to the Auditor General that will request an investigation into these and other problems that have allowed this colossal waste of taxpayer dollars to get as far as it has.
Our group is actively participating in the flawed Environmental Assessment process for this project. Our comments on the initial and revised project descriptions are posted on the CEAA website and we recently submitted a detailed list of serious deficiencies in the EIS for the project.
We note that CNL and CNSC officials have signed an “Administrative Protocol” with an Appendix that includes several “federal review” phases. We request that you ensure that officials in your department are reviewing this project, that you provide them with this letter, and ask them to inform you about the review comments that they have provided or will be providing to CNSC.
In case you are not already aware, Bloc Quebecois Leader, Martine Ouellet, recently gave an excellent speech on the threat posed by the NSDF to Quebecers. Here is a link to her speech to the Quebec National Assembly’s Commission des Transports et de l’Environnement on May 3, 2017.
The NSDF must be stopped or, at minimum, be put on hold until Canada’s Environmental Assessment Process can be repaired according to the recommendations in the Report of the Expert Panel, which recommends sole decision making authority not reside with the Canadian Nuclear Safety Commission on projects such as this. We would be happy to meet with you to provide any additional information that you require in order to take appropriate action.
Concerned Citizens of Renfrew County and Area
Jim Carr, Minister of Natural Resources
Elizabeth May, Green Party Leader
Tom Mulcair, NDP Leader
Rona Ambrose, Conservative Party Leader
Linda Duncan, NDP Environment Critic
Martine Ouellet, Bloc Quebecois Leader
Monique Pauze, Bloc Environment Critic
Ed Fast, Conservative Environment Critic
StÃ©phane Bergeron, MNA for VerchÃ¨res
David McGuinty, MP for Ottawa South
Will Amos, MP for Pontiac
Cheryl Gallant, MP for Renfrew-Nipissing-Pembroke
Jim Watson, Mayor of Ottawa
Denis Coderre, Mayor of Montreal
Marc Demers, Mayor of Laval
Maxime Pedneaud-Jobin, Mayor of Gatineau
Bob Sweet, Mayor of Petawawa
Joan Lougheed, Mayor of Deep River
Mike LeMay, Mayor of Pembroke
Kathleen Wynne, Premier of Ontario
Phillippe Couillard, Premier of Quebec
Jennifer Murphy, Warden of Renfrew County
Raymond Durocher, Warden of Pontiac County
Julie Gelfand, Environment Commissioner, Office of the Auditor-General