Letter from John Bennett to Canadian Nuclear Safety Commission

Sierra Club Canada agrees with the CNSC on the topic of the transport of the Bruce Power steam generators. There is “value to ensuring both a proper understanding of the scope of this undertaking and presentation of accurate information relating to the health, safety and risk.” It is also important to maintain public confidence in the environmental assessment process and the CNSC.

As a result of the recent changes to the Environmental Assessment Act, the CNSC has additional environmental assessment responsibilities. Sierra Club Canada and numerous other environmental organizations strongly opposed making such fundamental changes to environmental protection within a budget bill. The government, however, assured Canadians the changes will increase and improve environmental protection.  Although skeptical, Sierra Club Canada hopes the changes will make the CNSC a stronger and more responsive agency.

The Notice of Public Hearing dated July 29th, 2010 states, “CNSC staff has concluded that there are no safety significant issues associated with the proposed shipment.” This statement, prior to a public hearing, suggests a bias and has the potential to undermine public confidence. What is the point of a hearing if the CNSC has prejudged the issue?

Sierra Club Canada is concerned because, regardless of its safety issues, the application to transport 1600 tonnes of nuclear waste through the Great Lakes to Sweden and back is a significant change from the approved plan to store it on the Bruce site.

The integrity of the 2005 environmental assessment is being called into question. If Bruce Power is allowed to circumvent the environmental assessment process what is to prevent companies from withholding their real intentions when seeking approval from the CNSC? Once receiving approval, they could proceed in the knowledge that fundamental changes will not be challenged and environmental assessments will not be revisited. Is this a strengthening of the environmental assessment process in Canada?

Sierra Club Canada’s members are requesting an opportunity to present expert testimony on the safety of transportation of 1600 tonnes of nuclear waste and to provide the CNSC with legal arguments on the validity of proceeding with the approval in the manner described in the Notice of Public Hearing.

To do so adequately, Sierra Club Canada requires funding under the CNSC participant funding program to prepare and present expert testimony. We would be more than willing to work with other incorporated non profit organizations wishing to present similar testimony.

The hearing date set by the CNSC is fast approaching. A timely response to this request is needed to avoid postponing it.


John Bennett
Executive Director
Sierra Club Canada

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