Date: Feb 12, 2018

From: Joann McCann

To: Lucia Abellan, Environmental Assessment Officer Canadian Nuclear Safety Commission

By email: cnsc.ea-ee.ccsn@canada.ca

Subject line: Public Submission re Rolphton NPD Decommissioning Attn: Lucia Abellan, Environmental Assessment Officer, Canadian Nuclear Safety Commission

CEAA Reference number: 80121

Comments:

February 12, 2018

Joann McCann Canadian Nuclear Safety Commission Ottawa, Ontario Attention: Lucia Abellan, Environmental Assessment Officer e-mail: [email protected]

Dear Ms. Abellan, Re: Comments on CNL’s EIS for the Nuclear Power Demonstration (NPD) Closure Project at Rolphton, Ontario

I am writing the CNSC concerning the CNL’s proposal and draft environmental impact statement (EIS) for NPD Closure Project at Rolphton, Ontario. I appreciate having this opportunity to voice my objections. I grew up in Petawawa, cottage in Downey’s Bay, Sheenboro and I am a member of the Old Fort William Cottager’s Association (OFWCA) and I am a River Watcher with the Ottawa River Keeper.

I strongly concur with the eloquent submissions from the following individuals and organizations regarding both the in-situ decommissioning at Rolphton and at Whiteshell in Manitoba: J.R. Walker, William Turner, Michael Stephens, Dr. Gordon Edwards, Northwatch and Canadian Environmental Law Association.

I also concur with the reasons behind OFWCA’s vehement objections to the proposal at Rolphton:

1. Entombment just below surface of radioactive materials that will be hazardous for hundreds of thousands of years and abandonment after only 100 years is unacceptable and is against International Atomic Energy Agency standards. 2. Entombing and abandoning these same radioactive materials as well as other toxic mixed wastes within a few hundred metres of the Ottawa River, where all surface water and groundwater migrates to that river, is totally unacceptable.

OFWCA calls on the CNSC to stop this project as well as the equally hazardous “NSDF” proposal for Chalk River. CNL is not entitled to a ten-year license based on these flawed proposals. If the CNSC should approve these proposals or the ten-year license, the CNSC will lose any remaining credibility.

The CNSC must require that CNL begin again and design a state-of-the-art facility for the safe, long-term care of long-lived radioactive wastes. This facility must be in compliance with IAEA standards to ensure that radioactive wastes are kept out of the air and drinking water for as long as they remain hazardous. CNSC must insist that any facility be located away from any major body of water.

Also, I add my own concerns about the NPD proposal, it is situated too close to the Ottawa River/Kitchi Sibi and it does look like it is located 100 metres vs. 400 metres from the river. I vehemently oppose any entombment that close to the river. Finally, I end with this quote: “The problem with nuclear power is that it’s alright until it isn’t,” says Gordon Edwards. Also, Arnie Gunderson adds: "This is a technology that can turn on you overnight. It’s 40 good years and one bad day. And the one bad day wipes out everything that went before it.”

In addition, I grew up in Petawawa and AECL, as a government agency, never sponsored one sports event or charity. I learned at the CNSC hearings into the 10-year license that the CNL (including United Way donations from their staff) gave $400K to charities in Renfrew County. Is that being a good GoCo citizen or is that pork barrelling or greasing palms? Also, since I left to attend university in 1981, there have been very few new large industries in the Ottawa Valley, I feel politicians in the Renfrew County will not criticize a major employer though many municipalities down-river on the Quebec-side question their plans especially the NSDF.

I also add that many people do not know about the NPD proposal. Do you publish in local papers about EIS and hearings? If not, I would suggest that you do so. Many local people do not check your website.

Another aspect makes me concerned, in Ottawa, a contractor used the incorrect concrete for a pedestrian bridge. See http://www.cbc.ca/news/canada/ottawa/airport-parkway-pedestrian-bridge- opens-after-several-delays-1.2854904

At the CNSC hearings in January, your officials kept citing regulations but when this proposed entombment is to be built, who would ensure that it is built to the standards in the project description? I heard about inspections, but would inspectors be there every day checking the type of materials? The longevity of concrete and grout concern me especially situated so close to the Ottawa River.

Finally, I do not trust the present-day consortium especially SNC Lavelin. What happens if the other companies change ownership and management?

I also ask the Liberal government to do their due diligence and take the GoCo model back to the AECL. The Conservatives handed this responsibility over with public engagement and I, as a Canadian citizen, should have had say over the management of nuclear facilities.

Respectfully submitted,

Joann McCann