Lake Ontario Waterkeeper's Comment Re: Cameco Corporation - Proposed Port Hope Conversion Facility Vision 2010 Project. CEAA Registry # 06-03-22672

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April 11, 2008

Liana Ethier Environmental Assessment Officer Canadian Nuclear Safety Commission Delivered via email: CEAAinfo@cnsc-ccsn.gc.ca
 Re: Cameco Corporation - Proposed Port Hope Conversion Facility Vision 2010 Project. CEAA Registry # 06-03-22672

Dear Ms. Ethier,

Please find enclosed Lake Ontario Waterkeeper's comments on the above-mentioned matter.

If you have any questions or comments, please do not hesitate to contact me at any time: (416) 861-1237.

Yours truly,

Mark Mattson Waterkeeper & President

BACKGROUND

Cameco's Vision 2010 project involves a comprehensive redevelopment of Cameco's Conversion Facility located in Port Hope, Ontario. The project consists of decommissioning and demolishing approximately 20 old or underutilized buildings, removing contaminated soils, building materials and stored historical wastes, and constructing new replacement buildings. Three of the 20 are Class 1B nuclear facilities used to refine or convert uranium with a capacity of more than 100 tonnes per year (See Notice of Commencement).

The project is located at the heart of one of Lake Ontario's most historic and environmentally vulnerable harbours. For nearly a century, nuclear-related industrial pollution has affected water quality and the natural environment. For generations, controversy related to this industry has affected the local community. More recently, Port Hope Harbour was identified as an “Area of Concern†on the Great Lakes; it is known to be one of the most contaminated freshwater harbours in all of North America.

Waterkeeper views the Cameco Vision 2010 project as an important opportunity to remediate long-contaminated lands and to begin the process of restoring the waterfront for the community. The importance of this decommissioning project cannot be understated; it represents a turning point for the community and for Lake Ontario. Done well, Vision 2010 could begin to restore some of the area's lost natural wealth.

We are still early in the environmental assessment process. Waterkeeper offers specific comments on the scoping document below. Waterkeeper has also submitted a funding application to help our charity contribute expertise to Vision 2010 that will help the proponent and the Responsible Authority meet their stated objectives.

THE SCOPING DOCUMENT

Scope of the Project (Section 2.1)

At this time, Waterkeeper is comfortable with the characterization of the general scope of the project; that is, the decommissioning and demolition of buildings, site remediation and restoration, as well as constriction of new buildings and infrastructure.

At some point in the assessment process, it may become a matter of concern that the construction of new buildings and infrastructure are being considered along with decommissioning and remediation. Waterkeeper (and presumably other community organizations) may, for example, support certain decommissioning or remediation efforts but remain concerned about future or current operations of the Cameco facility. What currently appears to be a decommissioning process may in fact become a life-extension for one of the oldest nuclear facilities in the country. Combining decommissioning with redevelopment may lead to confusion and conflict within the community, particularly if there is any lack of transparency or access to information during the process.

Factors to be Considered (2.2.1)

Waterkeeper has no objections or concerns regarding the list of factors to be considered in the Comprehensive Study, given that they are similar to the general list contained in the Canadian Environmental Assessment Act.

Waterkeeper supports the requirement that the need for the project and the benefits of the project; and consideration of traditional and local knowledge where relevant be considered.

Proposed Scope of the Factors (2.2.2)

Waterkeeper encourages the use of real-world data, rather than risk assessments, wherever possible during the environmental assessment process. This is particularly relevant with regard to the description of the existing environment. Waterkeeper strongly recommends that a thorough analysis of the existing environment be conducted in order to help strengthen the project.

The description of the existing environment should include a thorough description of the contamination currently affecting Cameco's operations. Contaminated soil and groundwater have affected the plant's ability to operate and raised significant concern within the community. To the extent that this remediation process overlaps with the Vision 2010 process, Waterkeeper encourages transparency on the part of the proponent and flexibility and responsiveness on the part of the regulators. If new information or a change in circumstance results from the current contaminated soil remediation effort, Waterkeeper and the community may require increased scrutiny of this environmental assessment.

Regarding temporal boundaries, Waterkeeper supports recommendation that the timeframe include “operation of the proposed new buildingsâ€. This timeframe may become particularly relevant if the operations of the new buildings become contentious or concerning during the assessment process.

Public Concerns

The Cameco property is one of the most controversial industrial developments on Lake Ontario. Its age, its sector, and its legacy of pollution have cast a shadow over the Port Hope community. That said, Waterkeeper observes that there is a shared belief that Port Hope can and should be a vital community on Lake Ontario. With proper remediation and implementation of best practices, the Port Hope Harbour could once again be a place of pride, particularly in light of the fame of the Ganaraska River fishery and the beauty of the area.

At this time, Waterkeeper accepts that a Comprehensive Study is an appropriate process with the understanding that the Responsible Authority is acting in good faith and will make every effort to be sensitive to the community's needs. The legacy of contamination in the Port Hope Harbour, the concerns about health impacts, the degraded natural environment, and the pervasiveness of low-level radioactive waste throughout the community all fuel public concerns about any decommissioning, remediation or construction project in the area. As more information about the extent of contamination on the Cameco process emerges and the various parties become more engaged in this environmental assessment process, it may become clear that a review panel or mediator are required to address concerns and to protect the environment.

Waterkeeper is supportive of hearings that bear the hallmarks of administrative fairness, including independent adjudication, the ability to question witnesses, and so forth. We would support the Minister should he elect to pursue such a process at this time; we may also submit a request for such a process later in the environmental assessment.