Regional Assessment of Radioactive Waste Disposal in the Ottawa Valley (IAAC Registry Ref. # 81624)

The Honourable Jonathan Wilkinson
Minister of Environment and Climate Change
200, Sacré-Coeur Blvd, 2nd Floor
Gatineau, Quebec K1A 0H3 Canada

Via e-mail: Jonathan.Wilkinson@canada.ca

Cc: Impact Assessment Agency of Canada
        IAAC.OttawaValley-ValleeOutaouais.AEIC@canada.ca

Re: Regional Assessment of Radioactive Waste Disposal in the Ottawa Valley
        (Impact Assessment Agency of Canada Registry Ref. # 81624)

Date: July 26, 2021

Dear Minister Wilkinson,

On May 3rd, 2021 you received a letter from Ottawa City Council requesting a Regional Assessment of Radioactive Waste Disposal in the Ottawa Valley. Concerned Citizens of Renfrew County and Area, which has been working for 40+ years to prevent radioactive pollution in the Ottawa Valley, would like to take this opportunity to suggest why it would be wise to agree to this request.

We are copying the Impact Assessment Agency of Canada (IAAC), which is advising you on this request (IAAC Registry Ref. # 81624), The IAAC anticipates that your decision, with reasons, will be made by July 30, 2021.

A regional assessment, if appropriately designed, would provide a "big picture review" of the eight billion dollar federal liability associated with the several hundred thousand tonnes of radioactive waste created by the past 75 years of federal nuclear research and development. It would address radioactive waste from future nuclear projects. It would help tackle the Government of Canada’s largest environmental liability and be a keypart of a broader federal effort to address the issue of cumulative effects nationally.

The government contracted private companies in September 2015 to deal with the federal nuclear liability. The companies want to build two new permanent radioactive disposal waste facilities on unceded Algonquin territory on the Ottawa River (IAAC Ref. #s 80121 & 80122). The proposed new facilities (a million-cubic-meter radioactive waste mound and entombment of the first CANDU-type reactor) have been criticized as ill-conceived, inadequate, and inconsistent with international standards.

The waste mound (“NSDF”) project (IAAC Ref. # 80122) is nearing approval by the Canadian Nuclear Safety Commission. If it proceeds, it will not only permanently contaminate the Ottawa River, but will also be a colossal waste of taxpayer dollars, leaving nearly all the eight billion dollar liability unaddressed.

First Nations and civil society groups are calling for a half to both projects. The project assessments being carried out under the former Canadian Environmental Assessment Act ignore the cumulative impacts of related activities such as cleaning up existing leaking radioactive waste sites, decommissioning five other shut-down federal reactors, or managing wastes from a proposed small modular reactor (IAAC Ref. # 80182).

Dealing in a modern, thoughtful, comprehensive, and transparent manner with the eight billion dollar nuclear liability on federal lands in the upper Ottawa Valley is exactly the sort of thing for which a regional assessment is well suited.

The consortium, which owns “Canadian Nuclear Laboratories”, has recently initiated related radioactive waste projects (IAAC Ref. #s 81139, 81177, 81178, 81375, 81389, 81403 & 81443) at the Chalk River Laboratories. Some of these projects involve receipt, processing and temporary storage of intermediate- and high-level level radioactive waste – including used reactor fuel – from Quebec, southern Ontario and Manitoba.

A regional assessment would produce a broad-based analysis of the federal radioactive waste disposal problem, address risks and costs of transporting federal radioactive waste for temporary storage, enable transparency by making environmental and costing data publicly available, and incorporate Indigenous knowledge and priorities.

Dealing with the federal nuclear liability in a responsible manner is not just a local Ottawa Valley issue. Quebec-based municipalities and civil society groups are concerned about the fate of the Ottawa River. The consortium’s new waste projects are linked to the federally-owned, shut-down Gentilly-1 reactor, and to the radioactively contaminated waste heavy water that in past was shipped from Chalk River to the Laprade facility in Becancour, Quebec.

This is an excellent opportunity to make good use of the “regional assessment” provision in the Impact Assessment Act to inform and optimize management of federally-owned radioactive waste. We are counting on you to make a decision that respects Indigenous rights and reflects the best interest of all Canadians.

Sincerely yours,

Ole Hendrickson, Ph.D.
Researcher, Concerned Citizens of Renfrew County and Area
http://www.concernedcitizens.net

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IAAC Reference Numbers for Radioactive Waste Projects in the Ottawa Valley

80121 Nuclear Power Demonstration Closure Project
80122 Near Surface Disposal Facility Project
80182 Micro Modular Reactor Project at Chalk River
81139 Canadian Nuclear Laboratories Cask Facility Project
81177 Canadian Nuclear Laboratories Intermediate Level Waste Storage Area
81178 Canadian Nuclear Laboratories Bulk Storage Laydown Area
81375 Canadian Nuclear Laboratories Building Demolition Project
81389 Canadian Nuclear Laboratories Waste Management Area Modification Project
81403 Canadian Nuclear Laboratories Heel Storage Removal Project
81443 Canadian Nuclear Laboratories Multi-Purpose Waste Handling Facility