David Prentice To
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August 15, 2017 From: David Prentice To: Nicole Frigault, Environmental Assessment Specialist Canadian Nuclear Safety Commission By email: [email protected] Submission Letter to CNSC re: EIS CNL’s Proposal for NSDF at Chalk River, Ontario CEAA Reference number: 80122 To: Nicole Frigault, CNSC Cc: The Hon. Catherine McKenna, MP, Minister of the Environment Cc: The Honourable James Gordon Carr, MP, Minister of Natural Resources Dear Ms. Frigault, Attached is my submission regarding CNL’s proposal for the NSDF at Chalk River. Thank you. Sincerely, CNSC Submission re CNL’s Proposal for NSDF at Chalk River From David L. Prentice Preface I am the nearest full-time downriver neighbor of the Chalk River Laboratories. I am 69 years old and have been coming to this property on Pointe Malin in Sheenboro, Quebec, purchased by my great- grandfather Walt Malin in 1920, since I was two years old. It was a fishing camp, an old log house (originally built a bit upriver on the Ontario side but moved here when the land was purchased for the military base) with outbuildings put up by my forebears from Ohio, Arizona, and Connecticut. Malin’s Point Camp wasn’t much, which is probably why we all loved it. During every summer, and later on university breaks and whenever I could pull it off, I came up to “Camp.” It was becoming more to me than a great place to go in the summer: a lot of reading during my years of higher education were slowly convincing me that the urban business life I was tracking towards was not going to work out. I began to make a plan. In 1971, I moved from my native Connecticut to New York City, and in 1973 to Toronto, and on to Pembroke and then to this wonderful property (and a new house) by 1998. A cottage neighbor and Toronto friend told me when I moved to Pembroke that “something in your soul wants you to be up there.” She was right, and most of my neighbors around here have felt the same way. I feel so much a part of this place that I realized some time ago that I have long been capitalizing the word River every time I refer to our Ottawa, to show my appreciation and respect for it. I became a Canadian citizen and was on Sheenboro Council for ten years. I have been a founding and Executive- Committee member of the Old Fort William Cottagers’ Association for 26 years, and I have worked with our CNL committee since it was formed last summer. My emailed bulletins to 250 cottagers and neighbours often end with, See you on the River. Without the River, none of us who are from elsewhere would likely ever have come here in the first place. I have introduced dozens of friends from the States and from Canada to the River. Most of them marvel over the fact that this area is so untouched, so pristine, so big, so quiet, and so relaxing. Over beers on the deck, they have endlessly joked over the booming sounds from Garrison Petawawa and chided me on turning a glowing green from the nuclear facility just up the River. I laughed it off. The Base was actually sort of fun, with loud noises and great powerful pieces of machinery. The nuclear plant was a bit creepy, and my learning about the meltdown did not help, but I took it all in stride. Until now. The NSDF I was always confident that the Chalk River Plant was being well managed. The meltdown was in 1952, and the world is much smarter now. After SL-1, TMI, Chernobyl, Fukushima Daiichi, and more, nuclear engineering has come a long way, and the world has learned a lot. Haven’t we? The CNL plan distresses me in many ways. The CNL plan addresses the wrong objectives. The Harper government contract specifies that the plan for the storage of waste had to be cheap and fast. There was no mention of long-term guarantees of safety. How about something better than an unproven plastic-bag solution? Why isn’t this disposal facility underground, surrounded by rock? These objectives are absurd. The disposal facility is in the wrong location. Built on a swamp, within a kilometre of one of Canada’s most historic rivers, source of beauty, fitness, recreation, the world’s best sunsets, commerce, and drinking water for millions of Canadians and tourists — and they want to build a nuclear-waste dump there? In an earthquake zone? With a string of dams up the River? And who’s looking out for the Blanding’s turtles? This plan is a technical and public relations disaster. The plan depends on a technology that can be compromised in many different ways. The worst has to be the extreme likelihood that the liner is never going to outlast the long life of some of the wastes that it will be required to contain. The leachate collecting system seems to me to be an afterthought patch on a system that inevitably will leak and that will quite possibly be disturbed by burrowing critters, excessive precipitation or flooding, seismic activity, chemical deterioration, or even things no one has even thought of — which is of course why we have pipeline leaks, nuclear disasters, tank-car explosions, and other such regular events in this complicated world. CNL’s Environmental Impact Statement even admits there will be leaks! This is mind-boggling. And the EIS does not consider any effects on the River, boldly stating that the water “lies outside the boundary of the assessment.” That’s nonsense, absolute rubbish. Again, why are we even talking about this plan? The plan meets no Canadian standards, because there aren’t any (a travesty in itself), and does not meet internationally accepted safety standards. It doesn’t even qualify as a “near-surface” facility as it is being built above the surface. The IAEA’s Safety Standards for Disposal of Radioactive Wastes calls for a “stable geological environment” for the storage of even intermediate-level wastes (which will be in the mix), and CNL is going to put plutonium and other high-level wastes into this plastic container. Why has the plan made it even this far? The contract runs for ten years and places the responsibility on a consortium of profit-seeking companies. Profit goes with nuclear disposal about as well as it does with healthcare. Drag the profit motive into the scene, and you’ve got a recipe for secretiveness, cost-cutting, coverups, and weasel-filled annual reports, statements, and press releases. I worked for an advertising agency; I’ve witnessed examples of using half-truths or gloss to direct people to what you want them to hear. And what happens when ten years are up? Or 50 years? When the consortium is dissolved? When the crap hits the River? It’s obvious, of course: It all becomes Canada’s problem, and thus it’s the problem for all of us as a major Canadian river becomes a disaster scene that is hundreds of kilometres in length. This is what cheap and fast can lead to. If CNL had been given an unlimited budget, what would it have recommended? And how much profit would they have tacked on top of that? This is Canada’s job, not right for a bunch of corporate types with green eyeshades who will do whatever it takes to make the numbers work. CNL’s information/communication efforts have been woefully inadequate. The company is charged with notifying the public about its plan to build the NSDF. We are learning from our own discussions that too many people say they have heard nothing about it. (Their reactions are shock, followed by anger.) My conclusion is that CNL runs a few ads and checks off that item on their to-do list. They certainly are not truly involved with their public, nor have they shown any sign that they are listening to us. This is rural Canada. Many people read no newspapers, and even the free ones are likely not read by a significant number. I did see one advertisement, a two-page spread that struck me as being very simplistic in its content. CNL should have used direct mail, and it certainly needed more public meetings, which should have had better advance notice than the ones we knew about. There were four meetings in Sheenboro and three upriver in des Joachims, but very few others on the entire downriver section of the Ottawa — and no others were held in Quebec, which is inexcusable. Those meetings were all (except for the last one at Fort William–Sheenboro) walk-about sessions with different aspects of the plan on easels at different stations around the room. There was no formal presentation, and people learned only individually or in small groups, and what they learned was from well-presented scripts and from any questions from those who may or may not have been knowledgeable enough to know what to ask. The OFWCA is aware of efforts by an independent researcher to quantify the lack of knowledge and understanding among the public. Where Do We Go From Here? I find only one compelling reason for faith in this entire story. When the CNSC was in Sheenboro, we were offered a wide range of freebies and tchotchke. I remember looking at all of those things as being unnecessary, even thinking the word bribe, but nevertheless, I grabbed a small thumb drive, a squeezable watchdog for a neighbor kid (though its dark glasses to me suggested blindness much more than awareness, clarity, and reassurance), and a high-quality vinyl shopping bag that I threw them into.