Date: Feb 13, 2018

From: Party of ()

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

By email: [email protected]

Subject line: Comments on the Draft Environmental Impact Statement for the Nuclear Power Demonstration Closure Project

CEAA Reference number: 80121

Comments:

CEAA Reference number: 80121

Dear Ms. Abellan,

Please find attached comments regarding the Proposal for a Nuclear Power Demonstration Closure Project.

Thank you,

Mike Schreiner Leader, of Ontario

Lucia Abellan Environmental Assessment Officer Canadian Nuclear Safety Commission P.O. Box 1046 Station B 280 Slater Street Ottawa, ON K1P 5S9 Telephone: 613-995-7265 or 1-800-668-5284 Fax: 613-995-5086 Email: [email protected]

RE: Nuclear Power Demonstration Closure Project CEAA Reference number: 80121

Dear Ms. Lucia Abellan,

We have reviewed the Draft Environmental Impact Statement (EIS) for the Nuclear Power Demonstration Closure Project and have found the draft to be inadequate in many respects.

Recognizing the Nuclear Power Demonstration Closure Project is clearly in the federal jurisdiction, we are commenting on behalf of the citizens of Ontario.

The ’s position it that the CNL draft EIS be significantly revised and re-submitted. We propose the following plan requirements:

1. To be relatively certain that there are no environmental risks, the proposed containment structure must be replaced with a structure that meets international standards or redesigned and moved to another location. a. According to the International Atomic Energy Agency (IAEA), “entombment” is not a decommissioning strategy. IAEA guidance clearly states that “entombment”, whereby waste is encased in concrete and grout, should only be used in exceptional circumstances (e.g., following a severe accident). b. The Canadian Nuclear Association states because the NPD reactor systems are within an underground structure with thick concrete walls, based in bedrock, it provides enough reinforcement to permit an “entombed” containment structure.

PO Box 1132 Station F , ON M4Y 2T8 416 977 7476 | [email protected]

The case has not been made. That there are two examples of this technique does not prove the point. That something has been effective for the last 20-30 or 50 years means very little in the long run. c. The Canadian Nuclear Association also states that in-situ decommissioning is a proven technique that has been used in multiple sites in the United States. i. Multiple sites does not equate to a valid sample size. More information is needed, including: 1. What do the sites contain – low level, intermediate level waste etc.? 2. What did they entomb – reactors, reactor components? 3. What radioactive isotopes do they contain and at what levels? 4. What is their proximity to rivers, streams, aquifers population centres? 5. Are these sites viewed as short term, intermediate term or permanent remedies? 6. Etc. 2. To be relatively certain that there are no environmental risks, the decommissioning plan and containment structure must be better than those that have failed in other countries. This is particularly important since some members of the coalition owning CNL have been involved in sites that have not yielded satisfactory results. 3. The draft EIS states that “the use of grout to fill the structure is expected to slow down the release of contaminants to groundwater and subsequently to the Ottawa River.” What is meant by slow down? What contaminants will be released over what time period? What if the release of contaminants occurs more rapidly than predicted? 4. The EIS must adequately address concerns about the long-term maintenance of a concrete tomb. Cement ages and cracks. It will not necessarily last a century, let alone for the thousands of years that will be required. 5. The EIS must address the burden on future generations arising from the abandonment of significant quantities of long-lived radionuclides and non-radioactive wastes such as lead, asbestos, PCBs and in a near- surface facility 120 meters from the Ottawa River. 6. The proposal must explain why storing the radioactive materials and other contaminants below ground in a geological repository is not a

PO Box 1132 Station F Toronto, ON M4Y 2T8 416 977 7476 | [email protected]

better, lower risk option.

Granted, it is likely that this option would be more expensive, but it would significantly reduce the risk of contamination of bodies of water; the risk of site degradation; and damage from catastrophic events such as an earthquake.

The draft EIS should be re-submitted with clear and transparent definitions and acknowledgements of the risks associated with this project.

Regards,

Mike Schreiner Leader, GPO

PO Box 1132 Station F Toronto, ON M4Y 2T8 416 977 7476 | [email protected]