May 8, 2017 Johanna Echlin <Personal Information Redacted> Old Fort William Cottagers’ Association Fort William, Municipality of Sheenboro, Quebec Ms. Nicole Frigault, Environmental Assessment Specialist Canadian Nuclear Safety Commission P.O. Box 1046 Station B 280 Slater Street Ottawa, Ontario K1P 5S9 Via e-mail: [email protected] Dear Ms. Frigault, Re: Comments on CNL’s Proposal for a Near Surface Disposal Facility (NSDF) at Chalk River Laboratories (EIS March 2017) On behalf of Old Fort William Cottagers’ Association (OFWCA), I am sending the CNSC our comments regarding CNL’s proposal and draft environmental impact statement (EIS). We appreciate having this opportunity to voice our concerns and objections which are in Appendix A. Opposition resolutions passed by OFWCA and a number of Municipalities along the Ottawa River are in Appendix B. Our unanswered questions can be found in Appendix C. Appendix D and E contain correspondence with CNL and the CNSC respectively. We trust that CNSC will consider our views seriously. Our community is just downriver from Chalk River. For two major reasons, CNL’s proposal should not be allowed to proceed as it now stands. Both the location and the type of facility are seriously in question. 1. A disposal facility for radioactive waste should never be placed a kilometre away from the Ottawa River. Alternative locations at least 25 km from the river must be researched. !1 2. Radioactive waste with long-lived radionuclides should never be disposed of in a landfill or in a near surface facility and this is CNL’s intention. This is entirely unacceptable and does not follow international guidelines. Alternatives for disposal or for storage need to be investigated. Only radioactive waste with very short half-lives, in another location, would be acceptable in the proposed engineered containment mound. The classification system that CNL uses does not conform to international standards. Very hazardous radioactive materials with long half-lives are hidden in waste types (such as “demolition waste” and “soil”). Their system only confuses and makes evaluation nearly impossible. CNL must comply with International Atomic Energy Agency classifications. CNL’s plan to bring all of Canada’s federally owned radioactive wastes from other areas of the country to Chalk River for disposal or storage is unacceptable. Our community and a number of municipalities are completely in opposition to any radioactive waste coming to Chalk River, either for storage or disposal, from any other location. Good options for the legacy wastes now in interim storage at Chalk River must be determined. Placing them in the Engineered Containment Mound, which is the equivalent of a municipal landfill, is not a suitable plan and does not meet international standards. CNL’s approach to “informing” local communities about their proposal has been insufficient. CNL dismisses concerns. They have not answered our questions sent to them in January. They have provided Quebec with an EIS in English. Their ads and interviews are deceptive. CNL’s strategy is to persuade their audience that all is proven and safe. We rely on the CNSC to act as an independent watchdog. CNSC must protect our environment and all the people living along this river from a disastrous situation in the future. This could devastate a huge area of the country for generations. A rigorous environmental assessment is required. We count on the CNSC to do the right thing. Sincerely yours, Johanna Echlin !2 Table of Contents Old Fort William Cottagers’ Association Covering Letter to CNSC Pages: 1-2 Appendix A: Comments, Objections and Concerns Pages: 5-18 Appendix B: Resolutions List of Resolutions Pages: 20-21 Resolutions Pages: 22-31 Appendix C: Additional Questions with Respect to the Proposed Activities at the Chalk River Laboratories Site - January 24, 2017 (never answered by CNL) Pages: 32-41 Appendix D - 1: Correspondence Between OFWCA & CNL List of Correspondence 2016 Page: 42 Correspondence Pages: 43-64 Appendix D - 2 Correspondence Between OFWCA & CNL List of Correspondence 2017 Pages: 65 Correspondence Pages: 66-97 Appendix E: Correspondence Between CNSC & OFWCA List of Correspondence 2017 Page: 98 Correspondence Pages:99-105 !3 Appendix A Old Fort William Cottagers’ Association Comments, Observations, and Concerns A.1 Resolutions Pages: 5-7 Opposition OFWCA’s resolution Municipal resolutions Petawawa Point Cottagers’ Association opposition A.2 Public engagement Pages: 7-9 Unanswered questions - OFWCA requests answers to all questions submitted CNL information sessions insufficient CNL information deceptive CNL announced decisions without any public engagement A.3 Engineered containment mound (ECM) Pages: 9-12 ECM comparable to a landfill Identification of radioactive wastes needed ECM unacceptable for hazardous materials with long-lived radionuclides CNL must adhere to international radioactive waste classifications CNL must provide comprehensive inventory Basic questions need answers A.4 Alternative disposal and storage options must be investigated Page: 12 A.5 Chosen location cannot be justified Page: 12 A.6 Radioactive and other contaminants will end up in the Ottawa River Pages: 13-15 Leaks inevitable CNL must answer many questions A.7 Alternative locations must be investigated Page: 15 A.8 Impact on Employment and economic prosperity Page: 15-16 A.9 Study required re: cancer and birth defects Pages: 16-17 A.10 Concerns about GoCo model Page: 17 A.11 Conclusion: Page: 18 A message from OFWCA to CNL, CNSC and the nuclear industry !4 Appendix A Old Fort William Cottagers’ Association Comments, Observations, and Concerns Old Fort William Cottagers’ Association (OFWCA) at Fort William, in the Municipality of Sheenboro, Pontiac, Quebec is about 15 kilometres downriver from Chalk River. OFWCA includes both seasonal and year round residents. At the July 2016 annual general meeting of OFWCA, our members first learned of CNL’s (Canadian Nuclear Laboratories) March 2016 proposal for a Near Surface Disposal Facility (NSDF) for radioactive waste. The proposed facility, to be located on the Chalk River Laboratories (CRL) site, is to permanently dispose of one million cubic metres of radioactive wastes. CNL’s plans include bringing radioactive waste from other places in Canada for disposal in this facility in addition to the waste already in interim storage on the site. OFWCA formed a sub-committee with the mandate to investigate CNL’s proposals. As Fort William and Sheenboro are the first communities, downriver from CRL on the Quebec side, we are particularly concerned about any and all proposals, plans and activities that are taking place and are being considered for the future. Our community is legitimately worried about any potential impacts to our health, safety and wellbeing. Past, present, and future activities affect our community as the Chalk River site is next to the Ottawa River upon which our community depends. Resolutions Opposition to Chalk River becoming a radioactive waste dumping ground for nuclear waste from other sites We know from CNL that at least 5% of the radioactive waste destined for this disposal facility will come from Whiteshell, Manitoba and from NPD in Rolphton, Ontario. Another 5% will come from other locations outside of Chalk River. Radioactive waste will come from Port Hope and Douglas Point, Ontario and Gentilly 1, Quebec and from CNL’s future decommissioning activities. Radioactive waste will also be accepted for disposal in the Engineered Containment Mound (ECM) on a commercial basis, including from universities and hospitals (CNL Responses Dec.16/2016 p.58 & EIS 3.2.1.1 & 2.3). At least 10% of one million cubic metres of radioactive waste and other mixed wastes will come from outside Chalk River for disposal. 10% is 100,000 cubic metres. This is no small quantity - even though CNL repeatedly tries to present it to everyone as just a small amount. (100,000 cubic metres is like a 15 storey building or 40 Olympic swimming pools.) In fact, it has been !5 confirmed to OFWCA by experts reading CNL’s draft environmental impact statement (EIS) that CNL intends to bring all of Canada’s federally owned radioactive wastes (excluding radioactive wastes that have been disposed of in-situ at Whiteshell and Rolphton) to Chalk River for disposal in the ECM. CNL also plans to transport high-level fuel waste from Whiteshell to Chalk River for storage (not disposal). (EIS 3.2.1.1 & 2.3.) OFWCA and a number of Municipalities are completely against this plan to import waste for permanent disposal or for storage from other areas outside Chalk River. These communities want to prevent this from happening. We all say “no more waste coming to our river!” Not from Whiteshell, not from Rolphton, not from any other location. Radioactive waste should be dealt with locally and not transported. If it must be transported it should not be sent to a location on a major body of water. OFWCA members fully understand that Canada must adopt a long-term plan for the radioactive waste that has accumulated on the Chalk River site for more than half a century. We in no way suggest sending it somewhere else. But we find it unacceptable either to store or to permanently dispose of radioactive material from other parts of the country next to the Ottawa River. OFWCA voted upon and adopted the following resolution in July 2016: OFWCA strongly objects to Chalk River (CNL) receiving and accepting radioactive waste and any other waste from another site outside the Chalk River