Thank you, Madam Chair and Members of the Panel. And I’d also like to thank the Saugeen Ojibway Nation for allowing us to have these hearings on their land.
OPG, I feel, is to be commended for finally bringing the discussion of what to do with our nuclear wastes to the people of Ontario.
It has, however, failed to submit a plan that addresses many important concerns including the ones I will report here.
I am requesting that you deny the application on the grounds that it is woefully incomplete and fails to address the very serious health, socio-economic, and safety issues relating to the DGR project.
Perhaps more than any other resident in Inverhuron, we have suffered mightily from the legally sanctioned operations of the Bruce nuclear site.
Moreover, none of the impacts of these harmful effects have ever been acknowledged or mitigated by OPG, the industry, or regulators.
The impacts on our farm have been so severe, the Ontario Municipal Board recognized that our property was stigmatized by the operations of the Bruce heavy water plant, and awarded us a reduction in assessed property value of 35 percent.
While I understand that the historical operations of the Bruce site are outside the scope of OPG’s proposal, I believe that an understanding of the site geography is important to be able to determine whether the DGR should be situated at this location.
The physics of the region doesn’t change with each new project, and it has been the failure to address the conditions described by air physics that have led to the incidents described below.
These are very likely to be repeated with the construction and operations of this project. Experience with this neighbour has demonstrated that we have our very right to be fearful of future impacts.
Industrial contaminants from the Bruce site have routinely fumigated our property, sometimes in highly toxic concentrations.
The first known incident to affect us was some flare stack emissions in 1985 when hydrogen sulphide was burned at the site and flared to atmosphere. I was almost knocked out as I walked into a low lying region by the river, getting a massive headache and nauseous.
We knew about the dangers because Ontario Hydro annually visited us -– visited all residents to give us these warning things.
Eventually the MOE agreed with my consulting meteorologist, Professor John L. Lumley, of Cornell University. He demonstrated that we could be exposed to 100 parts per million of hydrogen sulphide when the MOE monitor recorded instantaneous peak concentrations of 20 parts per billion, 5,000 times as much.
You have heard Keith Mombourquette, on Saturday night, when he talked about the strong safety culture at the Bruce site. Sadly, that strong safety culture seems to stop at the site boundary.
He was a shift supervisor at the heavy water plant during this period of steady fumigation of hydrogen sulphide.
I had changed our farming operation from a confinement system to a pasture management one, and in confinement we would lose between 3 and 5 percent generally, at lambing time. Following this incident and for the next 12 years until the heavy water plant was shut down, we lost between 25 and 35 percent of our lambs annually.
The following graph demonstrates the impact on our farm animals, on newborn lambs.
On another occasion our entire flock of sheep on pasture went blind temporarily and we discovered this only because they would walk into the fence — the electric fence. That’s something sheep avoid whenever possible.
Although I’d begged and pleaded with Ontario Hydro, either to change the time of year when it engaged in this routine flaring, or if it must do so then, to inform us when it would be happening so I could keep our sheep in, and stay out of harm’s way myself.
Ontario Hydro steadfastly refused to do either, leaving us at the mercy of our local air, wind and weather patterns. It’s as if Ontario Hydro — now called OPG — had few to no concerns about the impact of its operations on the surrounding community.
In 1988 I was affected a second time, as was my 11 year old daughter who was outside at the time. It was late April and I had pastured our ewes on the grass around our orchard and garden just beside our house.
On this occasion it was as if somebody came up from behind me and banged me on the head with a large piece of wood. The pain was just that intense.
I was temporarily blinded, seeing bright lights and stars. My daughter who was playing on a pile of hay mulch became suicidal in the aftermath writing her last will and testament.
As might be imagined this is an unfortunate and terrible event for any parent to experience.
My symptoms at the time were so severe that our GP sent me to the Occupational Health Clinic at McMaster University. There Dr. Hanes referred me to Dr. Carbotte, a psychiatrist who had conducted a series of tests.
These demonstrated that I suffered from a central nervous system deficit that had to have been caused by some noxious agents such as hydrogen sulphide.
Although the deficit was unknown at the time to the Sulphide Research Network in Alberta, who were helping me, subsequent tests on new knockdown patients there invariably found it.
I was tested again six months later and showed marked cognitive improvements, thereby confirming that my symptoms had been caused by hydrogen sulphide, this environmental assault.
My daughter didn’t fare as well, because the psychiatrists in London believed that the maximum peak concentrations to which we were exposed was 25 parts per billion, as stated by the MOE. She was treated with a wide range of drugs used for schizophrenic patients that were inappropriate for her and did not help.
It took us four years before she was reassessed by a team at Sunnybrook Hospital in Toronto where it was decided that she didn’t suffer from schizophrenia at all, but now had a personality disorder caused in part by her medical treatment.
They recommended Luther Wood in Waterloo an institution that assists children overcome their anger and resentment. Again, no one at Ontario Hydro seemed to care enough about the impacts she’s suffered even to inquire about her well-being or the impacts of their operations on our family.
Fire training activities present another source of fumigation on our farm. In those days Ontario Hydro burned Bunker C oil at the facility onsite. The plume from this was highly visible as a black smoke. It would ascend to the bottom of the thermal internal boundary layer where it would meander along windward, dropping to the ground with descending thermals.
One such incident was witnessed in 1992 by an employee while he and I were working at the barn. We rushed home and I failed to make it on time, dropping to my knees as the edge of this plume overwhelmed me.
Watson Morris wrote about this and sent a certified report to the AECB, MOE, and Ontario Hydro at the recommendation of Professor Lumley. This report was never acknowledged by any of these bodies, nor did I receive a response.
Ontario Hydro did however, modify the times and places when it engaged in big burn fire training, so we did not experience similar events again until 2002.
I wasn’t home then. Bruce Power had changed the fuel used so that the smoke was no longer visible. It now used a product called TekFlame, a type of jet fuel.
This plume descended on our store and warehouse driving our customers home and making my wife and staff ill. Sherry, our staff member, described the experience as like gulping down diesel.
My wife who has a disability pension from teaching, due to chronic fatigue syndrome, took longer to recover. Following this incident, Sherry and I met over a nine-month period with Bruce Power staff and developed a protocol for fire training activity that we believed would protect us.
Unfortunately, without warning or notice Bruce Power abrogated that agreement by engaging in fire training, first in May, and then in June of 2008. Again, my wife was badly affected because at first she hadn’t recognized what was happening.
We sincerely believed at the time that Bruce Power was operating differently than Ontario Hydro did, and this incident fully caught us by surprise.
I emailed Dan McArthur, my contact at Bruce Power who emailed back and said that he didn’t think that they were supposed to do this at those times either. Bruce Power on the other hand didn’t agree.
The second incident in June 2008, a month later, happened as I was baling hay with my employee. While we didn’t notice the fumes from fire training activity, each of us felt ill at the time and mutually decided to stop work at mid-day because of how we felt. And my wife who was in our store with the windows open was very distraught and disoriented. It was Sherry who recognized the symptoms for what they were and brought Ann to a higher location in our house and safety.
Bruce Power’s response was to instruct its employees not to talk to us and with a letter to Siskinds, our law firm, threatened to sue us if we were to talk about how it had fumigatedour house and property, harming my wife.
In the spring of the next year, I suffered a heart attack without knowing I’d had one. However, Ann’s pain in the gut, which we talked about with Bruce Power went undiagnosed until it was discovered in September of that year that she had ovarian cancer. Bruce Power continues to deny without any supporting evidence that its activities fumigated our house and farm.
We are also constantly fumigated with radioactivity from this site. EIS 03-88 describes the radiological environmental monitoring program data for 2009, the year Ann had surgery for ovarian cancer. In it, our leafy vegetables contained a very high 1,736 becquerels per litre of tritium.
Six other locations in the LSA were sampled; these values ranged from 24.1 to 69.1 becquerels per litre. Clearly our farm location appears to be a magnet for airborne pollutions from the Bruce site. This is most likely caused by our location below the escarpment and our very local wind and weather patterns.
Bruce Power accounts for these anomalies by referring to the restart of Bruce A and local meteorological conditions. Baie du Doré, right next door to Bruce A did not have values remotely close to the ones recorded on our farm. Despite this information, the impacts on our farm continue to be ignored.
Our experiences have led us to be extremely fearful of airborne pollutants. They have been life-threatening. We are now in old age, we have much less resilience to fend off future attacks.
Our experience with both the industry and the regulator have taught us two things. The first is that the industry will do whatever the regulator allows it to do. The second is that the regulator will defend the industry’s right to do what it is doing.
Shareholder residents — stakeholder residents, it would appear, are simply collateral damage in any environmental anomalies. We can’t afford that luxury anymore.
Ann has been in and out of surgery for the past four years related to her ovarian cancer. While I have more or less recovered from my heart attack, my breathing as a result of flare stack emissions has become very laboured whenever I do strenuous work. I had to sell our sheep flock last year.
Ann has a persistent cough following her last set of chemotherapy treatments. Without question, our concerns about small particulate matter is paramount.
We know fully that OPG will do whatever you, as a Panel, permit it to do, as a result of this application. We need you, Madam Chair, we need you to stand up for us, the innocent victims of this industry and regulatory nonchalance.
After 25 years and regular appearances before the AECB and CNSC hearings, Commissioner Barnes finally demanded that the regulator convene a meeting with us relating to our experiences of fumigation at the Bruce site. This was to be the very first time we had been given an audience.
Ken LaFreniere of the CNSC was Chair of the meeting with CNSC and MOE staff present. MOE had specialists and legal staff were present by phone from London, while CNSC legal and compliance staff were present by phone from Ottawa.
Our lawyer from Siskinds, Paul Scott, was present by phone and Ann and I were present. It was Ann’s first trip out of the house following her surgery and chemotherapy although she was still taking chemotherapy and susceptible to infection.
Mr. LaFreniere opened the meeting dramatically by clapping his hands together forcefully and stating unequivocally that as far as the CNSC is concerned, we have closed the book on this subject. I ignored his insensitivity and went on to present as carefully as I could why both regulators ought to have been concerned. Our pleas fell on deaf ears.
Dr. Barnes never followed up.
Bruce Power does not account for the excessively high radioactivity in our garden vegetables directly but states that variances are due in part to our local meteorology.
It’s correct to have made this observation. As with everything else, flying dust particles will find their way to our home as well and possibly in devastating concentrations. We won’t know until it happens and then, assuming we survive the assault, we will get to travel the regulatory merry-go-round yet again and it doesn’t need to be this way.
In our submissions, I have submitted pointed questions about how industrial pollutants that are dispersed through air can be measured and modelled. MOE has confirmed for the Panel that these models can be back tested for known events. This would confirm their validity.
As you also heard, neither OPG nor the CNSC are concerned to do so. I provided some robust model variables to be considered. I’m still waiting for answers.
The same is true for noise. In 2005 and 2007 — is a long time ago — and that is when empirical data was last collected. It seems however that empirical analysis can create embarrassing circumstances for OPG, so it just rests on its laurels.
Instead, it chooses to adopt World Health Organization standards for noise of 45 decibels A for ignoring that our night noise is probably 15 decibels or less. Perhaps if it only makes two trips an hour at nighttime, it won’t disturb the hourly averages even as it destroys the needed sleep of those of us who are old and recovering from illnesses.
OPG claims to follow Kincardine’s 2008 noise bylaw, but it doesn’t. This bylaw states in part: “It may not operate any equipment in connection with construction during certain hours.” (As read) That is this bylaw.
We in this community have lost significant values in our properties. I have raised this first with the submission pointing out the flawed analysis OPG uses to deny stigma effect, and secondly, following the Inverhuron Committee tour of the site when Scott Berry and Gordon Sullivan requested that I show them my result.
Apparently, OPG didn’t check the CEAA registry. The very same data — the very same data — they sent back the very same data they put in their EIS. It shows that Kincardine’s property values have fallen behind Port Elgin’s property values between 2009 and 2012 by some $33,600 for a total of $160 million that we resident stakeholders have lost in our property value.
In any event, that’s not the sort of stigma that concerns OPG. It’s concerned about a stigma that’s caused directly by radioactivity from the DGR and its activities. It is property evaluation, the losses from this source alone that would trigger the property value protection plan and the hosting agreement if any resident were foolish enough to take on this facility.
No resident stakeholder could make this claim though because in EIS 05-214, OPG states bluntly that it’s impossible to identify radioactivity on the basis of its source. Happily for OPG, it holds the upper hand in all negotiations.
No resident stakeholder was given funding to help understand or prepare for this hearing. Frank King, in response to a question from Dr. Muecke on October the 3rd stated that “you can’t expect anyone to go through all this material on their own without expert help”.
But the Inverhuron community doesn’t rank high enough on OPG’s VECs of concern to receive any funding whatsoever. Even worse, with Bruce Power’s threat of suing us and OPG’s threat to recover its cost awards from the IDRA, it’s very dangerous for us to intervene.
This is how OPG manufactures consent. That’s what makes us a willing host community with individuals being intimidated by Bruce Power’s and the OPP’s threats.
Without funding, these monies have had to come directly from our pockets to pay for legal and expert advice. Not only do we as resident stakeholders have to contend with falling property values in light of the DGR, we have to dig into our retirement savings simply to intervene.
The CEA staff said to me early on in the process that we didn’t have to have legal advice and protection. But if we should happen to have said anything that OPG or any of them disagreed with, we would need that protection.
Do you, Members of the JRP, believe that innocent resident stakeholders who are the frontline victims of this DGR project should bear the weight of financial ruin merely to participate fully and meaningfully in this environmental assessment?
OPG has distributed many millions of dollars to others to assist them in their investigation. Why did we get nothing, particularly in light of Frank King’s comments?
Groundwater in Inverhuron has been contaminated by radiological leaks — radioactive leaks from RWOS1. OPG stated as much in a letter to Mary MacKenzie when it told her that the tritium in her well did not come from either the air or the lake, since each was different than the levels found in her water — her well.
A Board Member Document of the AECB at the time observed that these would be resolved as, indeed, it was when OPG and AECB staff said things were resolved.
When members of the community asked for empirical evidence to support that view, when I asked for this evidence in a submission for these hearings, CNSC staff merely stated that “tritium standards around the world vary”.
Is this what Dr. Binder means when he refers to the CNSC as a science-based decision-making unit? It must be, because these are his staff that make these opinions.
OPG fails to identify what it means by “community” in the EIS.
I raised these concerns in one of my very first submissions to the CEAA registry. Our local community has felt excluded, as have many in the broader local one, as well as the community at large.
Notwithstanding this, OPG maintains that we have had community consultation. That means OPG has told us what to think and refuses to engage in dialogue, meaningful or otherwise.
If we should happen to have thoughts different from the ones OPG requires us to have, we are simply vocal dissidents.
Although it has spent some 12 years promoting this concept here, the Panel has heard time and again no one seems to have been informed about the DGR project. Polls excluded certain members like me, who lives here full-time, and seasonal residents.
When the Inverhuron Committee was struck last September, the founding members were, on the whole, shocked and dismayed to have learned about this only at the very last moment. It was struck because the IDRA was hamstrung by OPG’s threats and so could not, itself, intervene freely.
The Inverhuron Committee could and has intervened freely, but it has taken our members a long time to learn just how potentially harmful this DGR is to our collective and individual interests.
OPG claims to follow best international practices with respect to waste storage and repositories. However, every other peer group international jurisdiction separates siting hearings from licensing hearings.
Seventy-five (75) percent of these separate long-lived wastes from short-lived ones.
The IAEA defines high level waste as long-lived radioactive waste according to the reference Marie Wilson provided us. Nonetheless, as if by fiat, she insists that high level wastes must be both heat generating and long-lived.
OPG, in its submissions to the record, states otherwise. In EIS 04109, it states the word “hot” refers to radioactivity.
Contrary to the hosting agreement that OPG signed with Kincardine, OPG is using the DGR to store what it acknowledges in this response to be high level wastes and — except that it now prefers to call them refurbishment wastes.
It also states it will not be — it will be storing fuel fragments in the DGR. Presumably fuel fragments are not used fuel because they’re called fuel fragments.
Both of these are high level radioactive wastes because both are long-lived and hot. Both are to have been excluded as identified by the hosting agreement, but each is included in the DGR.
We still don’t know what wastes are going to be stored in the DGR. It appears to be whatever we can get away with.
In the open houses and community meetings leading to the EIS, 95 percent of the waste by volume was to be low level waste, with 5 percent intermediate. Now, it’s 80 percent low and 20 percent intermediate.
Will it be 20 percent low and 80 percent intermediate tomorrow? What size will the DGR be?
OPG stated it would be 200,000 cubic metres in the EIS, then it said it could be doubled in size, and then that could be doubled in size if it changed the site footprint.
An environmental assessment is meant to be a planning tool. How is it possible for us to use it as a planning tool when we don’t know what wastes are intended to be placed in the DGR?
When we asked how the shaft would be sealed at the NGO site tour, OPG stated it hadn’t decided yet. Can’t we wait to approve this environmental assessment until OPG has some definite and definitive plans?
Do you, as a Joint Review Panel, not have a responsibility to all current and future citizens to make sure this process is open and transparent?
OPG claims to have communicated extensively with our Michigan neighbours in the Great Lakes and Cities Initiative according to statements in the impact statements on the CEAA registry.
These folks seem to have had the same difficulties seasonal residents and local stakeholders have had because they don’t seem to recall the discussions either.
Up and down the coast, municipality after municipality is passing a resolution opposing the DGR.
The Michigan State Senate passed a resolution opposing the DGR. School children on both sides of the border plead with us not to bury nuclear wastes in the Great Lake Basin. It’s not a difficult logic to understand.
Over-confident and sloppy engineers and scientists have caused great harm in the past, often with the best of intentions otherwise.
There are no known safe levels of radioactivity. What we do know is that past assumptions of safe levels are continuously revised to more restrictive ones as we learn just how wrong our assumptions have been.
We don’t know what health impacts this radioactivity has caused here because, well, these health impacts haven’t been studied here.
During the hearings, Dr. Thompson asserts that the CNSC has adopted the industry standard of a linear no-threshold model of impacts from ionizing radiation; the lower the concentration, the lower the impact.
This contrasts starkly with jurisdictional bodies like the CERES Commission in England that argues that there is a growing body of evidence suggesting radioactivity bioaccumulates in living tissue and chronic low dose exposures may be more harmful to cells than acute ones.
The tree ring analysis that I submitted from my questions on October the 7th demonstrated that both tritium and carbon-14 bioaccumulate. OPG is not worried.
There’s no need to worry about health impacts from radionuclides in our air, water, ground and food because those impacts haven’t been studied here.
Cumulative effects of exposures is not a concern because OPG uses conservative models. Ask it.
Is this what Dr. Binder means when he claims CNSC as a regulator is science-based? Must be because that’s the standard required of OPG by CNSC staff.
We cannot know now that the Great Lakes will not be compromised in the future by the DGR and, with it, some 21 percent of the fresh water. For what?
OPG has maintained until recently that it’s only for mops and rags. These are waste packages that are safe enough for us to handle without any shielding, stuff that could be used as landfill in the not too distant future – but that story was just a ruse, a teaser to make us believe there was nothing to worry about.
OPG’s sole reason for choosing this site was because the municipality requested it, and no other ones did. Could that be because it was never shopped around?
When it comes to used fuel, there appears to be no end of municipalities wanting to bury it in their back yard, so many that NWMO had to close the door on accepting new applicants.
Other inventors have asked this question, too: why would municipalities that want high level waste not want the mops and rags proposed for the DGR?
OPG claims the geology of this DGR is sound. However, the same bedrock sequence pervades all of Southern Ontario.
When I asked Diane Barker at an open house in 2010 whether this was an ideal site or whether there might be more appropriate ones elsewhere in Ontario, it went unanswered until Scott Berry answered it the week before I wrote this.
Apparently, no other municipality in Ontario requested the DGR. In spite of similar host rock anywhere and virtually everywhere, no other site has been studied.
OPG doesn’t consider the political costs associated with choosing this location in the Great Lakes Basin, yet community after community on both sides of the border in this basin are taking valuable council time to write and pass resolutions opposing the DGR.
They believe, quite correctly, to be part of the affected community by this project yet none of these communities has been adequately consulted, nor have their opinions been sought.
Each of these communities is concerned about its drinking water, which comes from the lake, about agricultural product that is irrigated by it, about the impacts on tourism, about the impacts on enjoyment of property; these are the very same concerns expressed by many of us in the immediate community.
We have a local small business here selling wool that caters to tourism with summer sales generally in the past in the 50 to $60,000 range. Our store used to be very busy. Sales have simply fallen off a cliff and we’ll be lucky — I think we had about $6,000 of sales this summer.
The cottage grocery and restaurant in the middle of Inverhuron tells a similar story. Our garage in Underwood has the same story.
The independent assessment study warned of this that it would affect tourism. It appears to have been a sound warning. OPG doesn’t take responsibility for this. Once again, OPG doesn’t back up its opinion with data.
Please do not fail us, Madam Chair and Members of the Panel. Tell OPG that it must present a plan that addresses all the significant issues and concerns this DGR represents to us, the host community. We have been penalized time and again in this willing host community by OPG. This plan has failed to make its case and must not be allowed to go forward.