August 15, 2017

From: Valerie Needham

To: Nicole Frigault, Environmental Assessment Specialist Canadian Nuclear Safety Commission

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

Submission Letter to CNSC re: EIS CNL’s Proposal for NSDF at Chalk River, Ontario

CEAA Reference number: 80122

cc: The Hon. Catherine McKenna, MP, Minister of the Environment cc: The Honourable James Gordon Carr, MP, Minister of Natural Resources

Dear Ms. Frigault,

I am a property owner on the Ottawa River near Sheenboro, Quebec and I attended the meeting on July 15, 2017 at the Hotel Pontiac with representatives from Canadian Nuclear Laboratories. I listened most carefully to their responses to questions asked. I was disappointed in the level of discourse that occurred at that meeting. Questions and concerns were dismissed, requested information was not provided and I came away with the sense that our legitimate concerns were not being taken seriously. I have read the documents provided at that meeting carefully and continue to have concerns.

I am writing to express my opposition to the Near Surface Disposal Facility as it is currently proposed by Canadian Nuclear Laboratories at the Chalk River site for the following reasons:

a) The proposed facility is NOT a Near Surface Disposal Facility as described by the International Atomic Energy Agency (a point acknowledged by a representative of CNL at a meeting at the Hotel Pontiac on July 15, 2017). It is an above surface land-fill style mega dump complete with a plastic liner that is NOT “proven technology” in the context of the – 35 to - 40 degree C temperatures of the Canadian winter. In addition, the institutional controls that have been proposed do not meet IAEA Standards for the Disposal of Radioactive Waste (Vienna, 2011) in that “such waste requires robust isolation and containment for periods of up to a few hundred years.” CNL proposes oversight for a few decades, at which point they say that it becomes the responsibility of the government, nowhere near the few hundred years cited above. Canada is a member of IAEA and as such, has an obligation to follow their standards and protocols.

b) The proposed facility will contain 1% intermediate level nuclear waste (ILW) . IAEA states that ILW “because of its content, particularly of long lived radionuclides, requires a greater degree of containment and isolation than that provided by near surface disposal… ILW may contain long- lived radionuclides, in particular alpha emitting radionuclides, which will not decay to a level of activity concentration acceptable for near surface disposal during the time for which institutional controls can be relied upon. Therefore, waste in this class requires disposal at greater depths, in the order of tens of metres to a few hundred metres. ” It is of great concern that ILW is being considered for this site when it should be disposed of tens to hundreds of metres below grade in a geologically stable zone. Although it will be 1% of the total, it is, in fact, 10,000 cubic metres, a very large volume of waste.

c) The proposed facility is located in the Western Quebec Seismic Zone. Natural Resources Canada states that between the years 1980 and 2000 there were 16 earthquakes stronger than a Richter 4.0 in that Seismic Zone, with many more of a lesser magnitude. The zone averages about one seismic event every FIVE days. The proposed site also sits between the Mattawa and Petawawa Faults in the Ottawa Bonnechere Graben and is therefore at risk if a major earthquake event were to occur. Again, IAEA states that proposed facilities must consider “characterization of the geological aspects has to include activities such as the investigation of: long term stability, faulting and the extent of fracturing in the host geological formation; seismicity,…”. CNL claims that the mound will be engineered for earthquakes up to 6.0 on the Richter Scale. However, seismic events far greater than this are possible in the next few hundred years as shifting continues between tectonic plates.

d) The proposed facility is situated less than one kilometre from the Ottawa River, which supplies the drinking water for municipalities downstream including Pembroke, Ottawa, Gatineau and Montreal. Radioactive leakage from the site into the Ottawa River would jeopardize the safety of the water supply, a key responsibility of municipalities and also of CNL. CNL claims that the water treatment plant would catch and treat any leachate. How would this be possible if the contaminated water leaks into the ground below grade? It is simply not possible to guarantee that no contaminated water would make its way into the Ottawa River. I am appalled by the tepid and irresponsible response of the City of Ottawa and the Medical Officer of Health of Ottawa to this proposal in which they ask to be informed in a timely fashion of a disaster, with no consideration to advocate for a plan that would PREVENT a disaster.

e) The plans for the proposed facility are vague around if and how the site would be covered during its 50 years of operation until it is ‘sealed’. This is of grave concern. High velocity wind events would cause debris from the site to become airborne and carried vast distances, endangering people living in the path of the storm. On July 15, 1984, a tornado travelled from Deep River down the Ottawa River past Fort William where it veered inland to Nicabeau (Nicabong, below). From the National Research Council of Canada: (http://nparc.cisti-icist.nrc- cnrc.gc.ca/eng/view/accepted/?id=6fb913d4-1c66-4d99-bda8-b2c92a930e1a)

A tornado followed a path about 150 km long from near Deep River, Ontario, to near Mont Laurier, Quebec, causing severe damage at Nicabong (pop. 90) and Blue Sea Lake (pop. 280), Quebec, and also caused damage at Lac Cayamant (pop, 260) near Blue Sea Lake. One person died and thirty were injured at Blue Sea Lake, eight people were injured at Nicabong and two at Lac Cayamant. There was approximately $2 million damage. Maximum wind speeds of 160 km/h were estimated by Environment Canada. Roughly three tornadoes a year occur in the Eastern Qntario/Western Quebec region. Approximately once every two years, these tornadoes cause extensive property damage, injuries and sometimes loss of life.

f) Microbursts are also a lived reality for property owners along the river. Many have experienced loss of trees and cars and damage to buildings from severe storms in 1999, 2006 and 2013. It took days after each of these storms for Hydro Quebec to restore power and millions of dollars of damage resulted from the storms. a. On the night of July 4-5, 1999, a severe storm (derecho: a line of intense, widespread, and fast-moving windstorms and sometimes thunderstorms that moves across a great distance and is characterized by damaging winds) moved rapidly from the northern US through Ontario into Quebec, causing significant property damage at Fort William. Winds reached over 100 kilometres per hour.

b. From Environment and Climate Change Canada: https://www.ec.gc.ca/meteo- weather/default.asp?lang=En&n=50846A4B-1

On July 17, 2006, a series of powerful storms ripped from Manitoulin Island to North Bay and Mattawa, then on to Deep River and into Quebec. The hot, moist air mass that had been baking residents for days lifted as a cold front approached. The atmosphere exploded, firing off a myriad of wild winds - funnel clouds, straight-line winds, microbursts and tornadoes. The fast-moving, well-organized storm dealt a large swath of damage nearly 400 km long. While intermittent, a Warning Preparedness Meteorologist in Ontario stated the storm tract was one of the longest in Ontario's history. The storms scythed across the province, splintering trees, snapping hydro poles and downing power lines. The combination of strong winds, lashing rain and thousands of lightning strikes left many communities in chaos, prompting several municipal leaders to declare states of emergency. At the end, two people had been killed and 250,000 people were without power. c) From the CBC:http://www.cbc.ca/news/canada/ottawa/microburst-likely-cause-of-petawawa-storm- damage-1.1411563: This storm that came downriver from Chalk River, wreaking havoc along the Ottawa River at Fort William.

July 19, 2013: Uprooted trees and other damage in the Petawawa, Ont., region during Friday's storm was likely caused by a fast-moving column of air called a microburst, according to an Environment Canada investigator. Much of eastern Ontario and parts of west Quebec were under a tornado watch Friday as the storm front rolled through the region. But Peter Kimbell said his preliminary investigation showed most of the trees damaged or uprooted appear to have all fallen in the same northeast direction, suggesting a large microburst, and not a tornado. A microburst is a column of sinking air that can come down at speeds over 100 kilometres per hour.

We can expect MORE of these major weather events in the future as climate change progresses. CNL claims that debris from high winds would not puncture the permanent cover, but they do not clarify how radioactive waste in situ would be contained in the event of a severe storm and high winds before the final cover is put in place in 50 years.

g) The proposed facility is located at 160 metres above sea level, which, according to CNL, places it above the computer modelling for flooding in the event that either or both dams upriver burst. However, water will find its own path in pathways of least resistance. Torrents of water cascading at vast speeds downstream can be expected to overwhelm meanders and can be expected to envelop and flood the NSDF since it is placed so close to the Ottawa River and is situated along the chain of water courses surrounding Chalk River. The response of CNL to this concern is passive and poorly thought out. They seem to assume that the water will rise evenly and gently in the event of the dam(s) being breached. Events in Quebec show this to be a naïve position.

CNL is a consortium whose purpose is to maximize profits. They do not take the long view. This ill- conceived proposal smacks of hubris. The well-founded concerns and objections of scientists and others are on the record for the future when a disaster occurs.

I implore the Canadian Nuclear Safety Commission to: 1. act wisely and responsibly for the protection of millions of Canadians and cancel this project as it is currently conceived. 2. take the grave concerns regarding this proposed facility SERIOUSLY. Careful and considered objections have been submitted by worried lay people and appalled scientists. Their questions and legitimate concerns are well articulated in the many submissions posted on the Canadian Environmental Assessment Agency website. 3. require CNL to take steps to PREVENT a disaster rather than merely informing municipalities and the populace when a disaster has occurred. 4. honour the motions passed by the Old Fort William Cottagers’ Association on July 22, 2017.

Respectfully,

Valerie Needham