Caroline Ducros, Environmental Assessment Specialist
Canadian Nuclear Safety Commission
280 Slater Street, P.O. Box 1046, Station B
Ottawa, ON K1P 5S9
CC: Aldo E. D’Agostino, Project Manager, Vision 2010
Cameco Corporation, Fuel Services Division
1 Eldorado Place, Port Hope, ON L1A 3A1
Tom Smith, Senior Environmental Specialist
Doug Prendergast, Senior Communications Specialist
Cameco Corporation, Fuel Services Division
205 Peter Street, Port Hope, ON L1A 3V6
Email: email@example.com, firstname.lastname@example.org
October 20, 2011
Dear Ms Ducros:
Re: Draft Comprehensive Study Report Cameco Vision 2010, Environmental Assessment 06-03-22672
We are writing with respect to the draft Comprehensive Study Report [CSR] on Cameco’s Vision 2010 project, issued for public comment by the Canadian Nuclear Safety Commission [CNSC] in September 2011.
Lake Ontario Waterkeeper [Waterkeeper] has been involved in the evaluation of the Vision 2010 proposal since it was first announced in 2008. Waterkeeper believes this project represents the opportunity to clean-up one of the most contaminated sites on the Great Lakes; the importance of conducting this project in a way that not only protects the environment, but actually improves water quality near the site, cannot be overstated.
With the support of federal funding from the Canadian Environmental Assessment Agency [CEAA], Waterkeeper retained Hydrogeologist Wilf Ruland and Aquatic Biologist David Dillenbeck to assist in our review of the Environmental Impact Statement [EIS] and CSR.
To be of the greatest assistance possible, Waterkeeper arranged a meeting with Cameco staff and our retained experts to discuss potential issues in the EIS and identify possible solutions. That meeting took place on July 6th, 2011 in Port Hope. It was a productive and helpful meeting for all involved, and we appreciate Cameco’s participation. A number of key issues were clarified during the meeting and were reflected in the recommendations we filed with the CNSC on July 11, 2011.
Upon the release of the draft CSR in September, Waterkeeper was disappointed to see that our recommendations were not addressed or reflected in the report. The only reference to Waterkeeper’s contribution was mention of the funding provided by the CEAA and the fact that we had submitted detailed comments. None of our substantive suggestions or the issues flagged by our expert consultants were reflected in the content of the report. Even improvements agreed to by Cameco staff at our July meeting were not included in the draft.
At an open house held in Port Hope on September 22, 2011, Counsel for Waterkeeper, Joanna Bull, discussed this omission with CNSC staff. Ms Bull was informed that public comments had not yet been incorporated into the CSR, but would be added before the report was finalized and sent to the Minister.
Due to the completion of a draft without incorporation of public comments, Waterkeeper’s initial comments and recommendations have yet to receive a response. As a result, we have no additional comments on the project at this time. We are disappointed that we could not take advantage of this comment period to help further refine the project and potential EA approval, but until our initial concerns are addressed, we have no new information to contribute.
Waterkeeper hopes that our review and detailed analysis, provided to the CNSC in July, can still help to improve the project and ensure that the opportunity to do it well is not lost. Cameco’s plan must ensure the surface water surrounding the Port Hope Conversion Facility is not contaminated in the process of remediating the site. We believe that the recommendations we submitted, in addition to the detailed expert reports provided from Mr. Ruland and Mr. Dillenbeck, can help the CNSC and the Minister achieve this goal.
We resubmit our specific recommendations, summarized below and explained in more detail in the attached July comments, to help Cameco, the CNSC, and the Minister reach the best possible outcome for the area and Lake Ontario. Waterkeeper plans to provide detailed comments to the Minister during the next comment period, once our detailed recommendations have been considered by the CNSC.
Please contact Joanna Bull, counsel for Lake Ontario Waterkeeper, at 416-861-1237 if you have any questions or concerns about this submission.
President and Waterkeeper