James and Brenda Preston

MR. PRESTON: My name is Jim Preston; I’m a recently retired CA and CEO. My wife Brenda is a retired nurse. We are Canadians that have lived in St. Louis for the past 20 years. We have a seasonal residence at Inverhuron where we now reside five months per year.

My family built a second cottage at Inverhuron in 1904. Brenda’s family immigrated to Inverhuron in 1863 as farmers and fishermen. Today over 100 of our family members come to Inverhuron and have over 20 properties.

We speak today as lay people to bring our concerns to the Panel. Unlike most of the presentations ours is relatively non-technical but hopefully provides some insight into the perspective of very vested stakeholders.

We would like to talk to the listed topics that we believe can be broadly classified around health concerns.

The World Health Organization definition of health reads as follows:
“…a state of complete physical, mental and social well-being and not merely the absence of disease [and] infirmity.”

Inverhuron is our history and our home. It is fundamental to our ability to balance careers with the importance of a healthy family lifestyle.

Young Jim Preston
Please note, this picture was taken at Douglas Point in 1954. Yes, the young man is me.

Let me share a little information about Inverhuron. It is the second largest community in the Municipality of Kincardine. It is the community in closest proximity to Bruce Energy, Western Waste Management Facility, and the proposed DGR. It is home to permanent and seasonal residents, many of whom, like us, also have multi-generational ties at Inverhuron.

Based upon legacy alone, it is not an option for us to simply uproot and move to another location away from the proposed DGR. Inverhuron is a huge contributor to our, our children and our grandchildren’s physical, mental and social well-being.

Lake Huron
Some people would say our position is based on NIMBYism, not in my backyard. This is a picture of our backyard. It’s taken from our cottage deck. We are here today to protect it not just for ourselves but for the tens of millions of people who enjoy and depend on our backyard.

The numbers are staggering when you look at the people and their dependence on the Great Lakes Basin. Freshwater is quickly becoming the world’s most precious resource. Can there be anything more fundamental to our health? This project places 21 percent of the worlds freshwater at risk. The toxic life of some of the intermediate level waste is over 100,000 years. What will be our freshwater requirements over this period of time? Can we accept that risk? We say no.

Lake Huron shoreline with heavy water towers visible behind treeline.
Now we would like to address the physical and stress issues of living next to the construction zone if the proposed licence is granted. I would draw your attention to the heavy water towers that are clearly visible above the tree line on the current slide.

Bruce Power has been our neighbour for over 50 years, Western Waste Management Facility for 40. We have learned to live with them but they already have a significant effect on our ability to enjoy a healthy life. Remember, there is no economic benefit derived by most of the property owners in this community from having a nuclear energy facility next door. They have never asked for our approval nor sought our input about the initial site selection for Bruce Power, the positioning of the Western Waste Management Facility, nor the proposed DGR.

We believe there will be visual blight on the landscape composed of rubble and towers arising over the tree line. The proposed mitigation of planting trees will not mask this blight unless it is going to be a redwood forest.

Health Canada in its filing indicated the following chemicals will be brought to the surface and can be airborne as particulate matter and dust. These include nitrogen oxide, sulphur dioxide, carbon monoxide, volatile organic compounds, polycyclic aromatic hydrocarbons. There are no specific details of the mitigation of these chemicals or dust. What will be the impact if the DGR is expanded to hold 400,000 cubic metres of nuclear waste or even more? How can they not have an impact on the health of a community 3 kilometres downwind from this site?

We are also told not to expect any significant sound interference. We currently experience background noise from the Bruce Power Western Waste Management site which can be heard across Inverhuron Bay. As we know, sound transmission is assisted over water.

We expect to hear additional noise during preparation, construction and decommissioning of the DGR. In fact, on Monday the 16th, Hardy Stevenson told us to expect an additional five decibels.

Local residents have noted that the duration of the construction licence is 10 years and that we are told that work will be performed 24/7, 365 days per year. This is not a minor irritant.

We also noted that EIS Section under Explosions states:
“An on-site explosion may occur during the site preparation and construction phase. Effects would likely be restricted to the Bruce nuclear site. However, this scenario is advanced for further consideration. […] some nearby individuals could be startled by sudden loud noise associated with an explosion. […] an explosion on the Bruce Nuclear Site may have an effect on people’s feeling of well-being and sense of safety or security.”


We are not aware of any detailed satisfactory mitigation of safety plans to address these non-radiation concerns. We continually read not likely to, not expected to, therefore it is not expected that, based on this it can be estimated, OPG does not believe. What are the certainties?

Finally, with regard to peace of mind, there is no acceptable property value protection plan in place and it won’t be put in place until after the licence is granted. We note with concern that the scales of fairness in negotiations are not evenly weighted if the formula is not set until after the licence is granted. Believe me, these create stress for our friends and relatives.

The Canada Privy Council stated the process we are engaged in today was to provide a framework for the application and precaution in science-based decision making about risk, including: “…a high degree of transparency, clear accountability, and meaningful public input…”

Inverhuron is the closest community to the proposed DGR site, yet we weren’t asked to be involved, we weren’t surveyed. As seasonal residents, we don’t get local mail service so didn’t receive any of the glossy brochures. We aren’t here in October for the local fall fairs where information booths were erected. Even the Information Centre in Kincardine was only open from November to February.

Our names and addresses are listed in the municipal tax roll and files of Bruce Municipal Telephone which is owned by the Municipality. We are accessible through mail. In 2004, the basic framework for the proposed project was set out in the Golder report. It states the: “…vaults will have a total capacity of 130,000 [cubic metres] and are expected to handle 115,000 [cubic metres] of low level waste…”

The public would therefore believe the contents are 90 percent low level waste, 10 percent intermediate. The study found that all three long-term management options are technically feasible and may be safely constructed and operated at Western Waste Management Facility. The public would also believe that there are multiple, safe storage options.

Low level waste is openly described by OPG as mops and brooms. And the Golder report described these items as being ones where: “…the total amount of radioactivity associated with [low level waste] will decay to approximately 1/10th of the original amount after 50 years.”

The public survey was then held with a question. Do you support the establishment of a facility for the long-term management of low and medium level waste at the Western Waste Management Facility?

As we have stated, we were not surveyed. But if we were, we would have had difficulty interpreting the question as anything other than providing a long-term solution to deal with a lot of low level waste that will have little radioactivity left in 50 years and there were three safe storage options.

The results of this survey were reported to be positive. So wouldn’t a prudent person conclude they were supporting a low level waste facility?

After digging through EIS 09-463 13 we find the new capacities and contents spelled out in detail. Two hundred and four thousand (204,000) 15 cubic metres of waste storage with 20 percent intermediate level waste. The size and the scope of the project had changed dramatically. In short, the size of the hole in the ground was doubled and intermediate level waste was tripled.

The proposed DGR is now far larger and more toxic than the one described at the time of the survey. This is not the project that was taken to the community.

Now, EIS 10-494, Section 8.1 1 states that:
“The potential to expand the DGR to accommodate up to 400,000 [cubic metres] of waste within the proposed infrastructure has been assessed with the conclusion that this could be done. It is likely that the DGR capacity could be expanded beyond a factor of two.”

What does this mean? If OPG expands to 400,000 cubic metres there are only two additional sources of waste that could possibly go in the DGR; they are decommissioned waste and high level waste.

OPG’s estimate for the decommissioning waste is an additional 135,000 19 cubic metres of intermediate level waste. Now, by my math, the DGR would be 52 percent intermediate level waste and 337,000 cubic metres in capacity.

To again show the lack of transparency of intent, I would ask the Panel to remember that in a public letter from Larry Kramer to John Mann on February 19th, 2013, posted on the Panel’s website he states:
“Another point that does not appear to have registered in your public communication is that the agreement reached between Kincardine and OPG anticipates us hosting the eventual waste generated through the decommissioning and dismantling of Ontario’s existing nuclear generating stations.”

From 100,000, to 200,000, to 335,000 cubic metres in capacity, from 10 percent, 15 to 20 percent, to 52 percent intermediate level waste; if you were us, how would you feel about transparency and honesty?

The scope of the project that the Joint Review Panel is being asked to prove has changed dramatically from the Golder Report. We do not know the final size. We do not know the radioactivity of the final contents. We do not know the future of the decommissioned waste or the radioactivity of its contents. Our conclusion is that if a licence is recommended by the Joint Review Panel, as requested, there is 100 percent certainty that the decommissioned waste will be entombed in this DGR.

The public, not just the 5 Municipality of Kincardine, should have all of the information and hold a public referendum before being called a willing host. We understand and appreciate the need of the municipalities to generate jobs and tax revenue; however, the willing host designation should not be assigned to municipalities that receive money on condition they will support the project. This stifles critical review and open discussion. The jobs and the money last 50 years while the toxic waste lasts over 100,000.

The Joint Review Panel should have the results of a new and complete referendum, including all of the citizens of the Great Lake Basin, not simply a few thousand residents of the Municipality of Kincardine dependent on the nuclear industry for their livelihood. The impact of the decision stretches far beyond our community.

Fundamental to OPG’s final internal decision to locate a DGR in Kincardine should have been a rigorous review of the various site alternatives. We cannot believe that the final site selection and storage options were made on the recommendation of the Mayor of Kincardine. No huge corporation would approve a multi-billion dollar project without looking at all of the alternatives.

Why would you bury all of the radioactive waste on the site of the world’s largest nuclear facility; convenience, cost, certainly not safety.

Low level waste has a radiation life of 300 years and an indicated volume of 80 percent of the total of the proposed DGR, as detailed in the EIS documents. It is presently stored and can continue to be stored safely in surface concrete vaults above grade according to the Golder Report. According to the CNSC, the monitoring or civilization life of a project in the computer projections is 300 years. We can safely monitor this low level waste for its entire radioactive life without burying it in a DGR. According to Golder, it is also less expensive than a DGR solution.

This leaves the intermediate level waste which needs a longer-term solution. A DGR might be the optimum solution but there are undoubtedly others. Why not in the Cambrian shield which is even identified as a preferred destination since the 1970s.

The indicated volume is 40,000 cubic metres, yet the decommissioning waste is 135,000 cubic metres. Proportionately the biggest part of the problem has yet to be dealt with. This waste has radiation life over 100,000 years. Where was the critical assessment and open discussion?

We would now like to comment on the gravity of radiation impacts on our health. We would again remind the Panel that we are not experts but have attempted to thoughtfully read available materials to gain perspective.

The precautionary approach calls for us to demonstrate that all aspects of the project have been examined and planned in a careful and precautionary manner in order to ensure that they do not cause serious or irreversible damage to the environment and/or human health of current or future generations. We also believe that the review and considerations of the stochastic health effect of radiation was improperly minimized.

There are many recent articles that suggest exposure to low levels of ionizing radiation may cause serious health issues, including genetic and transgenerational mutation. The safe allowable doses are continually being revised and reduced.

Let me quote a 1981 article:
“AECL spokesman Hal Tracey explained that the nuclear industry in Canada accepts the theory that there is no safe threshold limit for radiation exposure. Hence, it must also be accepted that any dose at all has the potential for harm and that eventually there will be some evidence of this harm.”

Our knowledge is evolving as to the cumulative impact of low dose of radiation. We are concerned for the health impact on our children and future generations from this impact.

There are some startling examples of nuclear waste storage gone wrong. Remember, at the time of burial they were the best practices.

In my opening remarks I stated that for the past 20 years Brenda and I have lived in St. Louis, Missouri. Let me tell you about Cold Water Creek. It is an emerging story of a disaster created by the improper storage of nuclear waste. The health issues are a litany of pervasive and rare cancers, autoimmune diseases and birth defects caused by low dose level radiation. All of this occurred in 50 years and impacted three generations, not 100,000 years. The negative health impacts of exposure to chronic low dose radiation is alarming. St. Louis is not isolated. Disposal issues dot the United States, and the globe.

We find it very worrisome that to our knowledge the nuclear industry never initiated a health study to monitor long-term effects of exposure to chronic low dose radiation in the local community when the first Bruce nuclear reactor was built in the mid-1960s, nor was one begun in the 1970s when the Western Waste Management Facility was started.

The health impacts of these two facilities, coupled with a proposed DGR, are cumulative. In addition, there is no tracking across the National Registry within today’s mobile society of the health impact that was created by these sources.

The sun is about to set. Decision time is fast approaching.

Madam Chairman, our conclusions are simple. We believe that low level waste does not need a DGR solution due to its short radioactive lifespan. A DGR may be a solution for storage of intermediate level waste and decommissioned waste if in the Cambrian Shield, away from the population centres and agriculture, and especially the Great Lakes Basin. Open, transparent dialogue and analysis are essential. Honesty, trust and respect are required.
We leave you with this thought. A healthy man has many wishes, a sick man only one.


MR. PRESTON: We request that the Joint Review Panel recommend the rejection of the application of OPG to construct a DGR on Lake Huron, or anywhere within the Great Lakes Basin.

We thank the Panel for their time and efforts and thoughtfully considering our submission. Grandma would now like to say a few words.

Preston grandchildren
MS. PRESTON: My name is Brenda Preston. These beautiful little souls are three of our grandbabies. They are the reason we are speaking with you today. Their future is in our hands. They deserve from our generation the act of stewardship, in that the decisions made by us today are in their best interests.

Are we solving the problem by burying nuclear waste beside their drinking water or simply passing an even greater problem on to them?

Sometimes the best planned ideas on paper do not translate well into real time. Sometimes the heart knows better than the intellect. My heart tells me this is just wrong. Thank you.

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