Open Letter To:
Justin Trudeau, Minister of Intergovernmental Affairs and Youth; Carolyn Bennett, Minister of Crown-Indigenous Relations and Northern Affairs; James Carr, Minister of Natural Resources; Catherine McKenna, Minister of Environment and Climate Change
Dear Justin Trudeau, Carolyn Bennett, James Carr and Catherine McKenna,
We learned recently that the Canadian Nuclear Safety Commission is proposing massive changes to the license for the Chalk River Laboratories, site of a proposed radioactive megadump, including removal of 28 conditions of the license itself and removal of several hundred “compliance verification criteria”. We are appalled at this radical move toward deregulation to benefit the multinational consortium, Canadian National Energy Alliance, whose Canadian partner, SNC Lavalin, is currently debarred from the World Bank for ten years and facing criminal charges in Canada for fraud, bribery and corruption.
Our two groups along with First Nations, scientists, municipalities, individuals, and the Quebec Ministry of Environment and Sustainable Development are very concerned about the consortium’s plan to emplace and eventually abandon one million cubic meters of radioactive waste in a giant mound on the side of a hill, next to a swamp, less than one kilometer from the Ottawa River at Chalk River, Ontario in unceded traditional Algonquin territory. As we and many others have stated, in comments on the environmental assessment for this misleadingly named “Near Surface” Disposal Facility, the proposed giant mound flouts international guidance, would exceed public dose limits for radiation for 100,000+ years and would contaminate the Ottawa River, Canada’s most recently designated Heritage River, which provides drinking water for millions of Canadians downstream all the way to Montreal.
We and many others believe that the Canadian Nuclear Safety Commission should not have decision-making authority for the environmental assessment of this or any other nuclear project. We concur with the expert panel on environmental assessment reform, the final report of which reflects the widely held view that CNSC is a captured regulator with no independence from the industry it regulates. We note that House of Commons e-petition 1220 requesting suspension of the environmental assessment for the Chalk River megadump and replacement of CNSC as decision maker for nuclear projects has been signed by more than 2,000 Canadians from coast to coast to coast in all ten provinces and three territories.
We are also very concerned by the Auditor General report that Atomic Energy of Canada Limited, owner of the Chalk River Laboratories and other federal nuclear facilities, has experienced a “significant deficiency in board renewal”, has “not met its statutory obligation to hold public meetings” since 2009, and lacks “a formal, systematic process for monitoring and reporting on risks” among its facilities.
Legal experts we have consulted have stated that CNSC’s proposed changes to the Chalk River site license would greatly reduce CNSC oversight and render important safety requirements unenforceable. For example, the following license conditions are among those planned for removal:
4.2 New Nuclear Facilities: The licensee shall only carry out construction and/or operation activities of any new nuclear facility at the CRL site with the prior approval of the Commission. [GONE!]
4.4 Nuclear Facilities Undergoing Decommissioning Activities. The licensee shall only decommission a nuclear facility, or any part thereof, at the CRL site in accordance with documented decommissioning plan(s) and procedures, and with the prior approval of the Commission to proceed with the decommissioning. [GONE!]
12.3 Nuclear Legacy Liabilities The licensee shall ensure that nuclear legacy liabilities at the CRL site are addressed. [GONE!]
We believe this radical move towards deregulation must be stopped immediately. CNSC’s proposal appears to confirm the widely held view that Canada’s nuclear regulator is more interested in supporting the nuclear industry than in protecting health and the environment, its primary mandate under the Nuclear Safety and Control Act.
The Government of Canada urgently needs to overhaul nuclear governance in this country to ensure responsible handling of radioactive waste. Consultations with the public and First Nations must be an essential part of this process.
Lynn Jones, Concerned Citizens of Renfrew County and Area
Johanna Echlin, Old Fort William (Quebec) Cottagers’ Association
