Letter to Trudeau, Obama, and the Great Lakes Executive Committee, about highly radioactive liquid waste
As you probably know, the US Department of Energy has been planning to transport 23,000 litres (6000 gallons) of highly radioactive liquid waste over public roads and bridges from Chalk River Ontario to the Savannah River Site in South Carolina. The transport would involve 100 to 150 truckloads over a period of several years. The liquid waste in question is equivalent to the post-reprocessing high-level nuclear waste stored in hundreds of tanks at Hanford, Washington, but it is about 4 times more radioactive than the Hanford liquid. Such liquid waste has never before been transported over public roads anywhere in North America. It is considered one of the most toxic liquids known to science, containing dozens of radioactive byproducts of the fission process, as well as weapons-grade highly enriched uranium (93 percent U-235).
The accompanying letter was sent to Prime Minister Trudeau and President Obama on Friday, September 30, 2016, with copies to the Great Lakes Executive Committee (GLEC). According to the 2012 Great Lakes Water Quality Agreement between the two countries, notification through GLEC must be given in cases involving the transport of radioactive waste, yet such notification has not taken place to date.
A media conference on the subject was held on Monday, October 3, in the Ontario Parliament Building at Queen’s Park, Toronto. A 25-minute video of the media conference can be seen at https://youtu.be/75Q-kydrB8s with Janet McNeill of Durham Nuclear Awareness, Christine Elwell of the Sierra Club Canada Foundation, and myself, as presenters. On Tuesday, October 4, we learned that the shipments of liquid nuclear waste have been postponed at least until February 17, 2017, as a result of a lawsuit filed in US federal court asking for an in junction against the planned transports. On October 5 Christine Elwell raised the liquid nuclear waste transport issue at the public meeting of the International Joint Commission held in Toronto that week.
Since the original letter was sent out, more groups have come forward wanting to endorse the letter. On Friday October 14 we will send another letter to the heads of state and the GLEC advising them of the additional endorsing groups. If you want your group to be listed as an endorser, please send me by return e-mail the exact name, location, contact person and e-mail.
NOTE: The entire press package can be viewed at http://ccnr.org/GLWQA_pack.pdf . This includes the media reease, the letter to Trudeau and Obama with all the endorsing groups so far, the letter to the GLEC co-chairs, some additional background material including relevant excerpts from the 2012 Great Lakes Water Quality Agreement.
September 30, 2016
The Right Honourable Justin Trudeau
Prime Minister of Canada
House of Commons
Ottawa, ON K1A 0A6
President Barack Obama
United States of America
White House, 1600 Pennsylvania Ave. N.W.
Washington, DC 20500
Dear Prime Minister Trudeau and President Obama:
Re: Transport of Highly Radioactive Liquid Waste over Public Roads
We are writing to you in connection with Canada’s commitment to eliminate highly enriched uranium (HEU) from civilian nuclear facilities such as Chalk River as part of President Obama’s 2009 initiative – a goal that we fully support and applaud as part of a
global non-proliferation objective. However we do not support current plans to transport HEU in liquid form from Chalk River to the U.S. Department of Energy’s Savannah River Site in South Carolina in 100-150 truckloads along public roads and bridges. Each such shipment will carry an inherently dangerous highly radioactive liquid solution containing dozens of nuclear fission waste byproduct materials in addition to the HEU.
Duty to Act
Under the 2012 Great Lakes Water Quality Agreement (GLWQA) which your two governments are the Parties to you committed to “eliminate or reduce, to the maximum extent practicable, environmental threats to the Waters of the Great Lakes” [Art. 2 1 (c)] and “to anticipate and prevent environmental problems, by implementing measures that are sufficiently protective to achieve the purpose of this Agreement” [Article 2 3].
The proposed series of transports of highly radioactive liquid waste over a period of years could have a potentially devastating impact on the Great Lakes / St. Lawrence River ecosystem. Depending on the routes chosen, there could be a spill or spills into a waterway flowing into the Great Lakes or the St. Lawrence River, or a spill into one of the rivers connecting the Lakes (St. Mary’s River, St. Clair River, Detroit River or the Niagara River), or a spill directly into the St. Lawrence River itself.
The GLWQA stipulates that notification through the Great Lakes Executive Committee (GLEC) is required where planned activities concerning “storage and transfer of nuclear waste” could lead to a pollution incident or could have significant cumulative impact on the Great Lakes.  Has such notification occurred through the Great Lakes Executive
Committee? More importantly, has the Great Lakes Executive Committee been accurately apprised of the contents and potential hazards of these planned shipments?
In the absence of detailed and accurate notification, the GLEC cannot respond by providing meaningful advice to your governments and providing your governments with “perspectives and insights from federal agencies, state and provincial governments, tribal governments, First Nations, Métis, municipal governments, watershed management agencies, and local public agencies on issues relating to the implementation of the GLWQA,” in accordance with the terms of its mandate, which also allows for public input.
It has come to our attention that the radioactive liquid in question has been misleadingly described by the Canadian Nuclear Safety Commission (CNSC) as “Highly Enriched Uranyl Nitrate Liquid” (HEUNL). Such a description seriously misrepresents the
extremely toxic and radiologically complex nature of this liquid waste. Highly enriched uranyl nitrate is a specific chemical compound  that is only one of dozens of compounds contained in the acidic liquid solution, which includes (among others) radioactive varieties of cesium, strontium, iodine, yttrium, rhodium, ruthenium, lanthanum, europium, niobium, praseodymium, zirconium, cerium, barium, xenon, and neodymium – each one having a much greater radioactivity than the highly enriched uranium itself. Indeed, the highly enriched uranyl nitrate portion represents less than one ten-thousandth of the total radioactive inventory contained in the liquid contents of the proposed shipments. 
Never before in North America has liquid waste of this nature, containing virtually the entire spectrum of fission products found in irradiated uranium, been transported over public roads. Moreover, liquid waste of a very similar nature left over from isotope
production operations, also containing highly enriched uranyl nitrate liquid, has been routinely solidified on-site at Chalk River since 2003, ever since the Fissile Solution Storage Tank (FISST) was completely filled and could accommodate no more liquid.
We therefore fail to understand or accept any justification for transporting this highly dangerous material in liquid form.
Failure to prepare an Environmental Impact Statement (EIS)
We also fail to understand why this unprecedented transport of highly radioactive liquid waste has not been subjected to any public environmental assessment process in Canada or in the USA, involving the preparation of an Environmental Impact Statement (EIS) so that other government departments and the public can provide input on the potential environmental impacts, as well as on alternative waste management approaches that could make the transports unnecessary. Indeed, it appears to us that proper notification through the Great Lakes Executive Committee would only be meaningful if such an EIS were carried out in both countries so that the results of those assessments could be made available to the GLEC.
Alternatives are available
As noted in a 2011 report prepared for the Canadian Minister of Natural Resources, the liquid waste in the FISST tank that is now planned to be shipped to South Carolina was originally intended to be down-blended in order to eliminate Highly Enriched Uranium (HEU) by converting it to Low Enriched Uranium (LEU). LEU is not nuclear-weapons-usable material and can therefore be solidified and stored on-site indefinitely, along with the solidified contents of some 20 other tanks of liquid nuclear waste at Chalk River. 
In February 2016, Indonesia was authorized by the US DOE to carry out such a downblending of radioactive liquid containing weapons-grade highly enriched uranyl nitrate, thereby foregoing the need to transport the material to the USA. The Indonesian downblending operation has already been completed, just a few months after permission was granted. The Indonesian weapons-grade HEU liquid was associated with the production of medical isotopes, as is the case with the Chalk River material.  Solidification of the liquid waste in the FISST tank at Chalk River is likewise a viable option, as previously mentioned, and can be used in conjunction with down-blending.
We ask you, Mr. Prime Minister and Mr. President, to cancel or delay these planned shipments of liquid radioactive waste from Chalk River to the Savannah River Site until
(1) a public environmental impact statement has been prepared in Canada and in the United States that includes a full examination of potential environmental impacts as well as viable alternatives to the planned transport, with the opportunity for public input; and
(2) proper notification of the radioactive contents and potential impacts of the proposed shipments of highly radioactive liquid waste has been provided through the Great Lakes Executive Committee and communicated to all stakeholders, including the appropriate EIS documents.
We look forward to receiving your response within 30 days as to the status of either cancelling these unprecedented shipments of highly radioactive liquid wastes, or preparing environmental impact statements in both Canada and the USA that are independent, comprehensive and public, to address the unique hazards associated with these proposed transports.
If your office has any questions or comments with respect to any of the above, please feel free to contact the undersigned regarding radiological characteristics and hazards of the proposed shipments, or contact Christine Elwell, Sierra Club Ontario at
email@example.com for considerations related to the Great Lakes Water Quality Agreement.
Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility,
53 Dufferin, Hampstead QC, H3X 2X8
firstname.lastname@example.org (514) 489 5118