proposed relicensing of the Chalk River Laboratories of AECL

September 5, 1996

Dear Dr. Bishop:

We appreciate receiving communications from the AECB related to the proposed relicensing of the Chalk River Laboratories of AECL. On July 2, 1996 we were sent the schedule for initial and final consideration of the license (September 12, and October 24, respectively), and the AECB Staff Annual Report on Chalk River Laboratories during 1995. On August 27, we were sent the draft site license and the accompanying Canadian Environmental Assessment Act Screening Report.

We would like to briefly note five points that may help inform your initial consideration of the license on September 12.

1. We ask that you review carefully the proposal to de-list from the site license facilities that are in preliminary stages of decommissioning. For example, although the NRX reactor is no longer in active operation, it continues to pose significant radiological hazards, and only a conceptual decommissioning plan has been prepared to date. Licensing provisions under the Atomic Energy Control Regulations (e.g., posting of warning signs) remain relevant. Furthermore, AECL should continue to maintain security measures for protecting this facility, and should submit regular reports detailing any changes in its status and personnel radiation exposures associated with it. We are uncomfortable about the prospect of this and other facilities not in active use at the Chalk River Laboratories falling into a regulatory void. We believe that Facility Authorizations should be prepared until detailed decommissioning plans are approved by the AECB.

2. The AECB communication of July 2 to us noted that a revision of AECL-7243, "Derived Release Limits (DRL's) for Airborne and Liquid Effluents from the Chalk River Laboratories during Normal Operations" (Palmer 1981), "is undergoing AECL internal review prior to submission to the AECB". These DRLs, which are a key document in AECL's license (Appendix B), are out of date and do not reflect changes since 1981 in international radiation standards. Revisions could have a major impact on protection of public health and the environment. We request that you put in place a mechanism for thorough AECB review of the revised DRLs, including comments by external agencies and the public. We also suggest that a provision be put in condition 5 of the new site license that revised DRLs will take effect as soon as they are finalized.

3. The 1995 AECB Staff Annual Report (p. 3) refers to an AECB request to AECL for revised documents on "reviewing and reporting of unplanned events". AECL had not submitted these revised documents by the end of 1995. The public must be assured that AECL will make prompt and complete reporting of any unplanned events. We urge you to ensure that appropriate policies to this end are in effect before AECL's site license is renewed.

4. The screening report for the license renewal conducted under the Canadian Environmental Assessment Act (CEAA) makes a distinction between emissions from "Section 7 facilities" and "Section 9 facilities". As noted in the report (p. 3), "continued operation of nuclear facilities licensed under Section 9 [of the Atomic Energy Control Regulations] is not triggered under CEAA". The report also notes (p. 13) that Emissions from the Section 7 facilities represent a small fraction of the total emissions from the CRL site since the inventories of radioactive material and chemicals in these facilities are smaller than the more significant facilities at CRL which are licensed under Section 9.

The distinction between Section 7 and Section 9 facilities is artificial and confusing. We support the "cumulative effects" approach taken in the screening report: assessing environmental effects due to emissions from both Section 7 and Section 9 facilities. We suggest that you communicate to the federal government the need to include Section 9 of the Atomic Energy Control Regulations within the CEAA Law List Regulations.

5. The screening report (p. 3) also states that "AECB is the sole Responsible Authority for conducting the screening", as "no other federal departments or agencies would be involved by way of granting the use of federal lands or funds for the project". However, the Department of Natural Resources Canada (NRCan) is providing about $180 million in funding to AECL, and is therefore also a "Responsible Authority" under CEAA. At minimum, there should be some written agreement between AECB and NRCan as to how responsibilities for the screening are being fulfilled.

Thank you for your attention to these comments. We hope that they are helpful in your initial consideration of the renewal of the site license for AECL's Chalk River Laboratories. We will be providing more detailed comments prior to the October 24 meeting.

Sincerely yours,

Ole Hendrickson

Researcher, Concerned Citizens of Renfrew County