Waterkeeper's initial response to Cameco Vision 2010 draft EIS
Cameco Corporation has released a draft Environmental Impact Statement for its proposed "Vision 2010" project. The project would see the demolition and new construction of buildings on the site, and the removal of contaminated soil and material.
Lake Ontario Waterkeeper has received funding from the Canadian Environmental Assessment Agency to participate in the Comprehensive Study process. We have retained a hydrogeologist and an aquatic biologist to help us review the EIS in detail. In the meantime, we sent the following initial comments to the CNSC:
VIA EMAIL
Caroline Ducros
Environmental Assessment Specialist
Canadian Nuclear Safety Commission
280 rue Slater Street
P.O. Box 1046 Station B
Ottawa, ON, K1P 5S9
Email: caroline.ducros@cnsc-ccsn.gc.ca
March 3, 2011
Re: Cameco Corporation
Proposed Port Hope Conversion Facility Vision 2010 Project
Environmental Impact Statement, CEAA Registry # 06-03-22672
Dear Ms Ducros:
Lake Ontario Waterkeeper is a funded intervenor in the environmental assessment of Cameco’s proposed Vision 2010 project. Our focus with respect to this EA is on potential hydrogeological and aquatic biology impacts.
Waterkeeper has received a copy of the EIS prepared by Cameco and intends to review the document in detail. We have shared copies of the EIS with our expert consultants, who will provide us with comments and recommendations respecting the project. Following this review, Waterkeeper will submit a detailed report to CEAA, Cameco, and the CNSC. We hope to coordinate the submission of this report with the open house planned for late spring or summer 2011.
While our detailed comments are pending, Waterkeeper has identified a major concern based on a preliminary review of the draft EIS. The EIS states that no project-specific hydrogeology, surface water, or sediment quality studies were conducted:
- “The... characterization of hydrology, surface water and sediment quality is based on a review of previous studies for other proposed undertakings located in the near vicinity of the Cameco site. Since there are no liquid effluent discharges from the construction and operation of the project, the characterization is essentially a “desktop” study. No project-specific field sampling or measurements were conducted” (at 5-59).
Complete hydrogeology and biological studies should be completed as part of the EA process in order to a) document the existing site conditions, and b) facilitate the choice of the best possible remediation techniques and technology for this specific site. A “desktop study” based on investigations unrelated to this project is not sufficient to fulfill the requirements of the CEAA. Cameco should be required to undertake site specific hydrogeology, surface water, groundwater, and sediment quality studies in order to complete the EIS before the environmental assessment process proceeds.
If you have any questions or comments about Lake Ontario Waterkeeper’s participation in the Vision 2010 environmental assessment, please do not hesitate to contact our Counsel, Joanna Bull, at (416) 861-1237.
Sincerely,
Mark Mattson
Waterkeeper & President
View the draft EIS here. Note that the Appendices document is too large to upload at this time.