Dear Mr. Clarke, Please find enclosed Lake Ontario Waterkeeper's comments on the above-mentioned matter. These comments will be sent by fax and regular mail.
This submission outlines Lake Ontario Waterkeeper's comments and concerns regarding the Draft Environmental Assessment Screening Report (EASR) for the proposed refurbishment of Pickering Nuclear Generating Station B (PNGS B). The Draft EASR became available for public comment on July 24, 2008. The proposed refurbishment encompasses four CANDU pressurized heavy water reactors at PNGS B. If approved, the refurbishment will allow continued operation of the reactors until 2060. Lake Ontario Waterkeeper submits that the proposed refurbishment will cause adverse environmental effects that either cannot be mitigated or will not be mitigated by measures described in the Draft EASR. It is ineffective to considered the environmental impact of these adverse effects in comparison to historic and existing levels of pollution in Lake Ontario, since this does not give a fair impression of the scope of the potential harm. Lake Ontario Waterkeeper submits that the provincial government must be included in the evaluation and regulation associated with this proposal in order to best protect the interests, health and safety of Ontarians.
The CNSC must recognize that there are adverse environmental impacts associated with the refurbishment of Pickering Nuclear Generating Station B that cannot be mitigated by measures included in the proposal.
Historic and existing levels of pollution in Lake Ontario cannot be applied as a baseline level against which new levels of pollution are compared. Instead, the adverse environmental impacts identified in the Draft Environmental Assessment Screening Report must be considered in terms of their independent and cumulative potential to cause harm to Lake Ontario.
The Province of Ontario must take part in regulating the environmental consequences and mitigation choices associated with the PNGS B refurbishment, in accordance with historical precedent and the best interests of Ontarians.
Click here for the the full copy of our submitted comments.