From Janet Graham to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

Reference Number
47
Text

Dear Ms. Aimee Ruperty,

 

Please post the comments below on "comments received/responses" relating to the Micro Modular Reactor Project at Chalk RIver, Ontario Reference # 80182.

 

Thank you,

Janet Graham

 

The project description is woefully lacking, with multiple deficiencies.  It does not meet requirements to provide citizens with basic understandings of the project, its scope, or potential environmental impacts.  The fuel itself is also not adequately described, nor are the characteristices of the radioactive wates that will be generated or how they will be managed over very long periods of time.  Transparency and public trust in the process, are among monumental issues at stake in this process.

  

The focus of descriptions of context and objectives of the project should be on the interests of the publc and the environment, rather than rather than on the narrow, short-term interests of"comercial viability of the MMR technology to prospective customers".

 

Descriptions of the physical works relating to the project, including their purpose, size and capacity are also inadequate.  More precise, detailed descriptions (including the scope of the project) are required.  

 

In addition, the activities to be performed in relation to the project require more precise, full descriptions.  Commercialization of reactors with high U-235 enrichment will create security and nuclear weapons proliferation risks.  A description of fuel fabrication activities should be part of the complete project description.  Fuel fabrication should be considered in the context of the "cumulative environmental effects that are likely to result from the designated project in combination with other physical activities that have been or will be carried out" (para 19(1)(a) of the Canadian Environmental Assessment Act, 2012). 

 

This is an important time when we are at a cross-roads in Canada.  In terms of rational decision-making: humans have not yet developed the knowledge to deal with the extremely long-lasting radioactive waste from nuclear energy, but at the same time there is a strong pro-nuclear lobby promoting products such as MMRs and there is a willing market seeking short-term profits (e.g. from Canada's fragile northern environments).  These prospective customers have business ventures expecting to provide short-term (e.g. 30 year) viability and employment, yet they will leave behind radioactive waste for the foreseeable future... and beyond for the generations to come.  

 

I urge you to take the longer-term view by considering future generations, and the importance of the Ottawa River (e.g. as the source of drinking water for millions of Canadians, for tourism industry, fishery, and necessity for diverse forms of life in an extremely large area.  It is not worth it to despoil the natural environment and souce of water of the majestic Ottawa River (virtually in perpetuity), merely in order to provide cheaper energy for a few short-lived commercial interests.  Although pro-lobby groups are powerful, as future generations and the environment do not have a voice it is incumbent upon those who have decision-making power to take a long-term and wider view, rather than bending to short-term commercial interests.  Moreover, it must also be considered that the location of Chalk River is at the base of a geological fault line, which is prone to earthquakes.  It is difficult to quantify the invaluable benefits of clean water for the present and future generations of humans and the natural environment. However, it is easy to know that this is far more valuable than the more easily quantifiable short-term profits and relatively brief employment benefits of commercial interests that support MMRs.

 

I urge you to decide not to allow the MMR Project at Chalk River to go forward. 

Submitted by
Administrator on behalf of Janet Graham
Phase
N/A
Public Notice
Updated Public Notice (August 9, 2019): Public Comment Period Extension (Project Description)
Attachment(s)
N/A
Date Submitted
2019-09-23 - 12:03 PM
Date modified: