The CNSC asked Swim Drink Fish Canada/Lake Ontario to look into its 2016 Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada. CNSC provided funding for the review.

1. 1
Submissions of Swim Drink Fish Canada/Lake
Ontario Waterkeeper
Re: CNSC Review of the Regulatory Oversight Report for
Uranium and Nuclear Substance Processing Facilities in Canada:
2016
Notice of Public Hearing, Ref. 2017-M-03
November 13, 2017
Submitted to:
Participant Funding Program Administrators cnsc.pfp.ccsn@canada.ca
and the CNSC Secretariat cnsc.interventions.ccsn@canada.ca
Cc: Adam Levine adam.levine@canada.ca and Doug Wylie doug.wylie@canada.ca

2. 2
TABLE OF CONTENTS
Executive Summary …………………………………………………………………………………… 3
Background ………………………………………………………………………………………..…… 6
• About Waterkeeper ……………………………………………………………………………. 6
• Waterkeeper’s past reviews of the PHCF .………………..………………………………… 6
Updates and persisting issues at the PHCF ………………..…………………………………….. 9
• Progress concerning comprehensive oversight of Contaminants of Concern (COCs)….. 9
• Concerns over lack of oversight of stormwater discharges…………………...……….......11
• Cameco’s once-through cooling system and its Fisheries Act self-assessment ……..…12
• Persisting deficits in environmental monitoring plans and data disclosure……………....14
• Persisting deficits in planned and unplanned release event disclosure…………………...16
• The need for more centralized and accessible water quality reporting……………….......18
Consistency and completeness of the 2016 Oversight Report …………………………….… 19
Concerns with uranium release limits for the PHCF and other processing facilities …..... 20
Conclusion …………………………………………………………………………………………..... 21
Appendix I: Independent Review of CNSC’s 2016 Regulatory Oversight Report for Uranium
and Nuclear Substance Processing Facilities, Including Cameco’s Port Hope Conversion
Facility, Wilf Ruland, P. Geo, November 13, 2017
Appendix II: Wilf Ruland, P. Geo CV
Appendix III: Pippa Feinstein, JD CV
Appendix IV: Waterkeeper’s submissions to the Commission during Cameco’s relicensing
hearing for the PHCF
Appendix V: Independent Review of Hydrological Issues Pertaining to a Review of Cameco
Vision in Motion Initiative and Cameco’s Application for 2017 Renewal of Site License, Wilf
Ruland, P. Geo, October 3, 2016

3. 3
EXECUTIVE SUMMARY
Last year, Swim Drink Fish Canada/Lake Ontario Waterkeeper (Waterkeeper) intervened in the
Canadian Nuclear Safety Commission’s (CNSC) hearing to consider Cameco Corporation’s
(Cameco) application to renew its Fuel Facility Operating Licence FFOL-3631.0/2017 (the
licence) for its Port Hope Conversion Facility (PHCF).
At that hearing, Waterkeeper raised a number of concerns with the facility’s environmental
monitoring programs as well as insufficient discharge limits and Action Levels concerning several
contaminants. Additionally, Waterkeeper drew the CNSC’s attention to the lack of publicly
available information from Cameco about its environmental performance.
As a result, the Commissioners invited Waterkeeper to follow up on various aspects of its
intervention during the current review process for CNSC staff’s 2016 Regulatory Oversight
Report for Uranium and Nuclear Substance Processing Facilities (the 2016 Oversight Report).
Funding was awarded by the CNSC for two main review tasks:
1) An overall review of the 2016 Oversight Report, including the public information sharing
component of the report; and
2) A more detailed look at the PHCF’s environmental protection performance including
stormwater runoff management, environmental monitoring and reporting, and its
compliance with the Fisheries Act and other relevant legislation.
Waterkeeper was provided with participant funding in order to be able to intervene in this matter
before the CNSC and has retained two experts to examine the PHCF’s operations and programs
in order to make recommendations for their improvement:
• Wilf Ruland, P. Geo, an experienced hydrogeologist who examined the potential impacts
of the PHCF and VIM on local surface water and groundwater quality; and
• Pippa Feinstein, JD, counsel and case manager for Waterkeeper who examined and
made recommendations concerning the PHCF’s Public Information Program (PIP) and
Fisheries Act compliance.
Waterkeeper is very familiar with the PHCF. The organization has been involved in several past
decision-making processes before the CNSC concerning this facility, including its environmental
assessment (EA) under the Canadian Environmental Assessment Act, 1992, as well as its
application for a Certificate of Approval from the then Ontario Ministry of Environment for its
industrial sewage permit, and its last licence renewal proceeding. During these processes,
Waterkeeper expressed concerns regarding the facility’s significant stormwater issues, the need
for better cooling water technology, and the need for better environmental monitoring and public
communication.
Overall, Cameco’s operations and communication with the public seem to be progressing with
each intervention. Improved environmental monitoring is being undertaken now compared with
what was the case in 2011, the Vision in Motion (VIM) project should address several legacy
issues hindering the facility’s environmental performance, and communications and information
sharing between the facility and local residents is steadily improving. That being said, more work
is needed.

4. 4
Since the early 1930s, refining activity around the PHCF site has proved detrimental to the
swimmability, drinkability, and fishability of the Port Hope Harbour and surrounding lakeshore,
Alexander Creek, and the Ganaraska River. While much of the initial environmental degradation
was due to a lack of understanding of the harmful substances being refined there, more recently
effluent discharge limits and environmental monitoring requirements have remained lax,
contributing further to historical pollution.
The PHCF’s location in the heart of the community’s harbour, embedded in a densely populated
town, is important to acknowledge. Many homes, business, and important aquatic communities
and habitats lie within its 1km exclusion zone. As a result, Waterkeeper stresses it is especially
important for Cameco’s VIM project and its continuing conversion operations to be thoroughly
scrutinized to ensure both are undertaken in a precautionary, responsible, and effective way.
Further, fully transparent, accountable, and ongoing communication with the public about the
progress of its VIM and continuing conversion operations will be crucial. These are the
ingredients necessary for the facility’s social licence to continue operate in the community.
A portion of the comments in this submission also relate to Waterkeeper’s overall review of the
2016 Oversight Report, including the public information sharing component of the report. Mr.
Ruland has found several issues in the report which require the CNSC’s attention, and his
concerns and recommendations are outlined in considerable detail in his report (attached as
Appendix I to these submissions) and are summarized in the last two sections of this submission.
After reviewing all available information, Waterkeeper makes the following recommendations:
Recommendation 1: Cameco or CNSC staff should make the PHCF’s list of COCs, and their
respective Effluent Release Limits and Action Levels available for public comment.
Recommendation 2: Stormwater management at the PHCF needs to be improved in the following
ways:
a) Cameco’s current informal program of stormwater quality monitoring should be
formalized going forward, with the CNSC to advise on an appropriate reporting
mechanism which will be available for review by both the regulator and the public. The
available storm sewer monitoring results for the 2017 monitoring period should be
properly reported;
b) Monitoring should be done at every active storm sewer outlet, and should be done on a
quarterly basis. If an outlet is dry on a scheduled monitoring date, then follow ups should
be done on days with sufficient precipitation that flow is occurring; and
c) Storm sewer monitoring should be done for the full list of COCs for the PHCF.
Recommendation 3: Cameco or CNSC staff should release the Fisheries Act self-assessment for
public review and include some type of monitoring regime to ensure the good operation of its
mitigation measures (if such a program does not already exist).
Recommendation 4: Quarterly, or annual reports should contain disaggregated data of sampling
results for all contaminant pathways (storm sewers, sanitary sewers, and the groundwater pump
and treat system).
Recommendation 5: Annual mass loadings from groundwater of uranium should be reported in
annual reports.

5. 5
Recommendation 6: Once wastewater treatment plans are developed for the VIM excavation
activities, they should be made publicly available for review.
Recommendation 7: Cameco should improve its event reporting in the following ways:
a) The webpage reporting incidents should be included as a shortcut tab to the homepage
for the facility, as its current location is difficult to find;
b) The incident reports should include actual data of measured releases;
c) Appropriate Effluent Release Limits and Action Limits should be included in these reports
to provide the public with a better understanding of the severity of the incidents; and
d) The date on the first line of each report should be specified as its posting date.
Recommendation 8: Cameco should begin producing an annual overview report on water quality
and the various streams of liquid emissions from the PHCF. The report should include
information, references and links regarding the following:
• the full list of COCs for the PHCF;
• the area of contaminated groundwater and the extent to which it is being contained by
the Pump and Treat system;
• discharges to the sanitary sewer system;
• coolant water discharges;
• storm water discharges;
• calculations of mass loading of uranium and other key COCs to the Harbour from each
liquid emission stream;
• water quality in Port Hope Harbour; and
• water quality in Lake Ontario in proximity to the PHCF.
Recommendation 9: The CNSC should require more standardized and consistent Oversight
Reports
a) In future Overview Reports for processing facilities, the discussion for each featured
facility should include a description and analysis of each of the possible discharges of
liquids which could carry contaminants and potentially cause unacceptable off-site
environmental impacts:
a. process water;
b. cooling water;
c. off-site groundwater flow which may carry contaminants leaching from on-site soil
contamination;
d. sanitary sewer discharges;
e. storm sewer discharges.
b) Full references and/or links should be provided to the more detailed documentation/reporting
which has been summarized in the report section for each facility.
Recommendation 10: The CNSC should develop and implement a requirement for at least a
minimal groundwater and surface water quality monitoring program for any industrial facility
which is processing uranium and/or other nuclear substances.
Recommendation 11: The CNSC should initiate a process to review the licence limits for liquid
discharges of radiological contaminants from the facilities featured in the 2016 Oversight Report.
The licence limits for liquid discharges of any given radionuclide should consider both its

6. 6
radiological properties as well as its chemical properties, and should be protective of both human
health and the health of aquatic organisms.
Background
About Lake Ontario Waterkeeper
Waterkeeper is a grassroots environmental organization that uses research, education, and legal
tools to protect and restore the public’s right to swim, drink, and fish in Lake Ontario. Founded
in 2001, Waterkeeper is a non- political registered charity focusing on research and justice issues
in the public interest. It is dedicated to protecting and celebrating the Lake Ontario watershed,
including the wetlands, streams, rivers, and creeks that flow into the lake.
Waterkeeper also works with communities to facilitate the use of environmental laws to protect
their rights to swim, drink, and fish. The organization participates in legal processes to help
ensure that environmental decisions are made on the basis of sound and tested scientific
evidence by independent decision-makers and in the public interest. Waterkeeper is
participating in the current review of the 2016 Oversight Report (with a focus on the PHCF) to
ensure the Commission considers the public’s need for a swimmable, drinkable, fishable Lake
Ontario when considering the PHCF’s operations, the extent of its public information disclosure,
and whether it may want to add or amend any processing facilities’ licence terms (including the
PHCF).
Waterkeeper’s past concerns with the PHCF
Cameco first applied to make certain improvements to its Port Hope facility in 2008 – a project
that was called Vision 2010. Waterkeeper participated in the CNSC’s public hearing for this
application and argued the following:
• That Cameco’s project could be an important opportunity to remediate contaminated
lands and restore Port Hope’s waterfront from industrial to public use; and
• That Cameco’s project would be difficult for an EA to assess because it involved
simultaneously decommissioning, remediating, and refurbishing different parts of its
facility, as well as constructing completely new buildings.
Waterkeeper also requested that the EA, once undertaken, be based on real data rather than risk
assessment.
In 2009, Cameco requested a Certificate of Approval (CoA) for sewage works which would permit
it to release cooling water effluent into Lake Ontario.1
Waterkeeper prepared submissions to the
CNSC, Environmental Commissioner of Ontario, and the then Ontario Minister of Environment
(MOE) arguing:
• That the MOE was obligated to consider the CoA application in light of the extensive
historic contamination in Port Hope;
• That cooling water can degrade the environment (due to both chemical and thermal
pollution) and that Cameco must mitigate this impact by implementing ‘gold-standard’
cooling water technology; and
1
Although, it appears it had been releasing effluent into the lake for decades prior to this point, without
any permit to do so.

7. 7
• That the terms of both federal and provincial permits related to Cameco’s facility should
be better coordinated.
In 2011, the Environmental Impact Statement (EIS) for Cameco’s refurbishing and
decommissioning project was released. Waterkeeper intervened in the CNSC’s public hearing
to consider the EIS and determine whether to grant Cameco a licence that would cover its
planned renovations. For its intervention, Waterkeeper retained the services of David Dillenbeck
and Wilf Ruland who provided expert reports concerning stormwater and wastewater issues at
the site. The following is a brief summary of Waterkeeper’s submissions concerning the EIS:
• That the Cameco site is contaminated with a variety of pollutants (including over 87,500
cubic metres of contaminated soil) that fall under both federal and provincial jurisdiction
(containing Uranium, Petroleum Hydrocarbons, Vinyl Chloride, Trichloroethylene,
Ammonia, Radium-226, and Arsenic);
• That the site is located in a designated Area of Concern (A of C) and that there are many
pathways for the contaminated site to pollute surrounding surface and groundwater;
• That there was no stormwater quantity or quality management system at the facility and
that stormwater from the facility ran directly into Port Hope’s harbour via outfalls and
terrestrial runoff;
• That the EIS lacked sufficient information (especially with regards to baseline
characterization) and that it lacked a commitment to conduct surface water monitoring
during the project’s operations;
• That the project provided an opportunity to institute a stormwater management system.
Here, Waterkeeper made several recommendations concerning preferable options for
such a system;
• That a better plan to address flooding and spills was required;
• That wastewater estimates according to Cameco (48,000 m3
) may be low and that there
was contradictory information about these estimates in Cameco’s application.
Clarification of its plans, and the data used to inform them, were requested;
• That a plan be instituted for the contaminated water produced from the dewatering
process for contaminated soil, as no such plan was specified;
• That the harbour wall be made impermeable to prevent further groundwater movement
from the site, as no such plan was specified; and
• That the methods for sampling, processing, and disposal of contaminated soil be further
clarified. Waterkeeper recommended that Cameco use best industry practices when
addressing these issues at their facility.
The EA for the project proceeded as a comprehensive report which was released in May 2012.
Despite Waterkeeper’s concerns, the CNSC adopted few of Waterkeeper’s recommendations
and concluded that Cameco’s proposed changes to its facility would not cause significant
environmental effects, taking specific mitigation measures into account.
During last year’s licence renewal hearing for the PHCF, Waterkeeper continued to follow up on
its past concerns with the site – namely stormwater management, public access to information
(especially environmental monitoring and release event data), and plans for Cameco’s Vision in
Motion (VIM) project. In its submissions at the public hearing in Port Hope in November 2016,
the organization recommended the following:
Recommendations concerning the PHCF’s effluent discharges and effluent monitoring programs:

8. 8
1) A final VIM-specific wastewater treatment plan should be provided for public review upon
its completion;
2) A final plan for handling contaminated water from Port Hope Harbour during and after the
completion of VIM and PHAI remediation efforts. This plan should also be provided for
public review;
3) The proposed1825 kg/year release limit for uranium from the sanitary sewer system into
the harbour must be lowered. Reasonable Action Levels for uranium and all other COPCs
from all three pathways to the environment are required. These limits should be provided
for public review once completed;
4) Future quarterly and annual compliance monitoring reports should provide the full list of
COPCs which are being monitored for in the sanitary sewer discharges. Additionally, the
combined annual mass loading of uranium from the sanitary sewer discharges should also
be reported;
5) In the post-VIM period, uncontrolled contaminated stormwater discharges via the storm
sewer system should be monitored at least quarterly;
o This should be done at all active storm sewer lines,
o Monitoring should be conducted for all identified COPCs,
o Monitoring results should be included in all quarterly and annual compliance
reports,
o A calculation of the combined annual mass loading of uranium to the harbour from
all active sewers should be reported in annual compliance reports;
6) Monitoring of the Pump and Treat system should continue as planned;
o Groundwater monitoring results showing the areas of contaminated groundwater
discharges not being contained by the system should also be reported in quarterly
and annual compliance reports,
o Future quarterly and annual compliance reports should contain the full list of
COPCs, those that are being monitored, and any reasons for the exclusion of
others from being monitored,
o A calculation of the combined annual mass loading of uranium to the harbour from
all areas of uncontained contaminated groundwater should be reported in annual
compliance reports.
Recommendations concerning the PHCF’s Fisheries Act compliance:
7) Cameco’s Fisheries Act self-assessment report should be made publicly accessible as
well as CNSC staff’s review of it once it has been completed.
Recommendations concerning the PHCF’s Public information and disclosure programs:
8) The webpage reporting incidents should be included as a shortcut tab to the homepage
for the facility, as its current location is difficult to find;
9) The incident reports should include actual data of measured releases;
10) Appropriate Effluent Release Limits and Action Limits should be included in these reports
to provide the public with a better understanding of the severity of the incident;
11) The date on the first line of each report should be specified as its posting date.
Recommendation concerning the requested licence period’s length:
12) Based on the lack of information currently available to the Commission, Cameco's
relicensing application should be denied until all relevant information is available for the
Commission to make a more informed decision. In the alternative, a three to five-year
licence should be granted rather than a ten-year licence.
At the relicensing hearing last November, the Commissioners and CNSC staff recognized the
need for more information-sharing with the public about operations and the environmental

9. 9
performance of the PHCF. Cameco and CNSC staff made several undertakings on the public
record during the hearing to develop and publicly share more information about the facility and
the VIM project. CNSC President Binder encouraged Waterkeeper to intervene in the current
2016 Overview Report review process, and follow up on these undertakings.
In his overall review of the 2016 Oversight Report, Mr. Ruland has found several issues in the
report which require the CNSC’s attention and his concerns and recommendations are outlined
in considerable detail in his report (attached) and are summarized in the last two sections of this
submission. The remainder of these submissions are devoted to assessing the extent to which
CNSC staff and Cameco’s undertakings have been undertaken and adequately communicated
to the public.
Generally, over the course of Waterkeeper’s interventions before the CNSC concerning the
PHCF, it’s clear to see improvements are being made. Waterkeeper recognizes that the legacy
wastes at the Cameco site pose a significant challenge for the company, and its attempts, via
its VIM project and complementary work being undertaken by the Port Hope Area Initiative
(PHAI), to remove and safely store these wastes is an important step in the amelioration of the
Port Hope Harbour Area of Concern. Further, environmental monitoring and sampling plans for
the site have improved since 2011, stormwater infrastructure has been and will continue to be
upgraded to better address that contaminant pathway, and public information-sharing with the
public is steadily increasing.
At the same time, many concerns persist: additional environmental monitoring is still required to
better understand the PHCF’s effects on the local environment; more comprehensive and
demanding effluent release limits must be developed for the facility and made legally
enforceable; and information-sharing with the public must be more robust, especially regarding
the urgent need for better data sharing and incident reporting. As these submissions will show,
more work is still required in order to complete and deliver on Cameco and CNSC staff
undertakings from last year’s hearing.
Updates and persisting issues at the PHCF
Progress concerning comprehensive oversight of Contaminants of Concern (COCs)
Comprehensive and justified limits for COCS
Due to decades of refining operations around the Port Hope Harbour, and due to the lack of
knowledge in the early days of this activity about the adverse impacts of these substances could
have on the health of locals and the environment, refining operations were not adequately
contained and local water quality was severely degraded. Mr. Ruland explains that local
groundwater and soils on the PHCF site and its surroundings have long been contaminated with
the following Contaminants of Concern (COC): uranium, arsenic, ammonia, nitrate, fluoride,
Radium-226, trecholoroethylene, dichloroethylene, and vinyl chloride.2
2
Wilf Ruland, “Independent Review of CNSC’s 2016 Regulatory Oversight Report for Uranium and Nuclear
Substance Processing Facilities, Including Cameco’s Port Hope Conversion Facility”, November 13, 2017,
at 12 (Ruland Report, 2017).

10. 10
Contaminated soils and groundwater are present across the main PHCF site, as well as the
Center Pier, and Port Hope Harbour. Mr. Ruland has found that uranium levels below certain
portions of the PHCF measure in the 1000s of μg/L, with peak levels in 2016 of approximately
19,000 μg/L. By comparison, the Ontario Drinking Water Quality Standard for uranium is 20 μg/L,
and the Ontario Provincial Water Quality Objectives for uranium is 5 μg/L.3
Uranium is an
indicator substance, meaning that high concentrations of uranium in surrounding the PHCF likely
indicate elevated levels of other COCs. However, to date, the CNSC’s commitment to oversight
and regulation of the other COCs (beside uranium) remains unclear. In the PHCF’s licence and
Licence Condition Handbook (LCH), the only Effluent release limits or Action Levels for the PHCF
to surrounding water concerns uranium.4
At last year’s relicensing hearing for the PHCF, CNSC staff undertook to look into identified
COCs for the PHCF, and set Effluent Release Limits and Action Levels for those COCs that were
monitored and discharged. CNSC staff undertook to report on this in a year’s time – which would
roughly correspond to the current intervention opportunity:
“we will present in the regulatory oversight report next year any changes, any updates
that are required on action levels, and things that we will be setting as a result of this
[hearing], of our completed work on effluent limits”.5
Referring to the COCs for the PHCF, the Commission asked which of them had been monitored
and considered in the risk assessment for the facility. CNSC staff explained that the method for
including potential contaminants in the list is considered a risk assessment process. Cameco
representatives confirmed that all potential contaminants from the submitted list were monitored,
and noted that their reports were focused on specific substances that are primary contaminants
of concern. CNSC staff submitted that the LCH did not include the list of other COCs because
either they did not pose a significant risk, or else the monitoring of other constituents was an
appropriate surrogate. The Commission affirmed CNSC staff’s suggestion that a way to move
towards increasing transparency for the PHCF was the application of appropriate CSA standards
for environmental monitoring and for effluent monitoring, which include steps to document how
that selection process of COCs has been conducted. CNSC staff added that the PHCF would
be compliant with such standards by the end of year 2017, and that that process would generate
more publicly available results.6
In the Record of Decision from last year’s relicensing hearing, the Commission also noted its
concern over the disparity between contaminant release limits and actual measured discharged
amounts. It also confirmed the need for more comprehensive COC Effluent Release limits and
Action Levels for contaminants at the PHCF. The Commission directed CNSC staff to provide:
“in all CNSC staff documentation, a clear, understandable to lay persons, explanation of
release limits and action levels, basis for the accepted values and rationales and
justifications for changes to those, if proposed for approval and as appropriate”.
The Commission directed that CNSC staff include Action Levels in their reports, despite the fact
that these are not regulatory requirements. It recognized this information would serve as a
3
Ruland Report, 2017 at 13.
4
Transmittal of Revision 1 of Cameco Corporation’s Port Hope Conversion Facility’s Licence Condition
Handbook, e-Doc 5206729, at 50-51 (PHCF LCH, 2017).
5
Canadian Nuclear Safety Commission, Public hearing transcripts, November 9, 2016 at 42 (2016
Hearing Transcripts).
6
Ibid at para 95.

11. 11
demonstration of the defence in depth for COC inclusion, further underscoring the need for
transparency.7
As part of the current intervention process, Cameco notified Waterkeeper that it has undertaken
a review of COCs at the PHCF according to applicable CSA standards and that it plans to submit
a proposed list of COCs, and their respective Effluent Release Limits and Action Levels, with
justifications, by next month (December 2017). Once submitted, CNSC staff will be responsible
for reviewing and approving the COC list, including applicable Effluent Release Limits, and Action
Levels.
Nothing is yet available for Waterkeeper to review, despite CNSC staff’s undertaking to provide
this documentation by the current intervention opportunity. However, Waterkeeper is relieved to
hear the work is progressing. Waterkeeper submits that once the CNSC reviews and approves
Cameco’s list of COCs and their respective Effluent Release Limits and Action Levels, these
should be shared with the public for comment. Detailed rationales should be provided for how
COCs were selected, and how their respective release limits and Action Levels were determined.
Recommendation 1: Cameco or CNSC staff should make the PHCF’s list of COCs, and their
respective Effluent Release Limits and Action Levels available for public comment.
Concerns over lack of oversight of stormwater discharges
In addition to groundwater and sanitary sewer discharges, contaminants are discharged into the
harbour via the stormwater system for the PHCF. Mr. Ruland believes that there are leaks and
breaks in the PHCF’s aging stormwater network, and that some amount of contaminated
groundwater enters the pipes and is released directly into the harbour. While Mr. Ruland stresses
this issue is not as serious as it was when he first identified it back in 2011, it is still a significant
cause for concern.
Last year, Mr. Ruland found that the PHCF lacked any Effluent Release Limits or Action Levels
for these stormwater discharges, meaning that these pollution pathways were essentially not
being regulated at all. Despite Waterkeeper’s concern at last year’s relicensing hearing for the
PHCF, no Effluent Release Limits for stormwater have been included in the facility’s new licence
or LCH. As such, the CNSC’s complete lack of regulatory oversight of stormwater at the PHCF
continues.
Monitoring results from the uncontrolled stormwater releases via the storm sewer system are
also not publicly available in the facility’s Quarterly Compliance Monitoring and Operational
Performance Reports, or its Annual Compliance Monitoring and Operational Performance
Reports, nor is any data indicating its performance included in the Annual Groundwater and
Surface Water Review Report or the 2016 Oversight Report.
There are also several shortcomings concerning current monitoring plans for stormwater at the
PHCF. Monitoring is only being conducted at seven of ten active outfalls, and only semi-
7
Canadian Nuclear Safety Commission, Record of Decision in the Matter of Cameco Corporation,
Application to Renew the Nuclear Fuel Facility Operating Licence for the Port Hope Conversion Facility
at paras 93-94 (2016 Record of Decision).

12. 12
annually.8
Further, storm sewer discharges are not metered, meaning there is no way to
determine the flow-weighted average uranium concentration for discharges,9
apparently this is
due to the design of the stormwater infrastructure, which does not allow for reliable flow
monitoring.
The lack of stormwater regulation, monitoring, and public reporting is of deep concern to
Waterkeeper. Mr. Ruland believes that the majority of water contamination in the harbour was a
result of the PHCF’s contaminated stormwater discharges. Average uranium concentrations in
the storm sewer discharges to the harbour have been measured in 2011 at 218 μg/L,10
though
more recent discharges to the harbour have shown some improvements with an average of 116
μg/L in 2015, and 134 μg/L in 2016.11
These values are still high. Further, as uranium is a “key
indicator” of low-level radioactive waste and a surrogate for the presence of many other
potentially harmful contaminants, thus these findings for uranium would likely indicate that other
COCs are also being released into the harbour via the PHCF stormwater system.
Waterkeeper is pleased to note the VIM project will involve the following improvements to the
storm sewer network over the next five years:
• the number of active storm sewer outlets is to be reduced from 10 to 4.
• New piping will be installed in many areas, reducing or eliminating the potential for
leakage of contaminated groundwater into the system.
• Flows from the 4 outlets will be metered, allowing mass loading calculations to be carried
out and flow-weighted average discharge concentrations to be calculated.
• The storm sewer system will be equipped with oil and grit separators, which will help
improve discharge water quality.
However, more work is necessary regarding the need for stormwater discharge limits, more
frequent monitoring of stormwater discharges, and accessible public reporting of stormwater
monitoring results.
Recommendation 2: stormwater management needs to be improved in the following ways:
d) Cameco’s current informal program of stormwater quality monitoring should be
formalized going forward, with the CNSC to advise on an appropriate reporting
mechanism which will be available for review by both the regulator and the public. The
available storm sewer monitoring results for the 2017 monitoring period should be
properly reported.
e) Monitoring should be done at every active storm sewer outlet, and should be done on a
quarterly basis. If an outlet is dry on a scheduled monitoring date, then follow ups should
be done on days with sufficient precipitation that flow is occurring.
f) Storm sewer monitoring should be done for the full list of COCs for the PHCF.
Cameco’s once-through cooling system and its Fisheries Act self-assessment
8
Ruland Report, 2017 at 14.
9
Ibid.
10
Independent Review of Hydrological Issues Pertaining to a Review of Cameco Vision in Motion Initiative
and Cameco’s Application for 2017 Renewal of Site License, Wilf Ruland, P. Geo, October 3, 2016 at 7
(Ruland Report, 2016).
11
Ruland Report, 2017 at 15.

13. 13
Port Hope supports significant fish populations. The Environmental Risk Assessment (ERA) for
the facility includes a description of the local aquatic environment. It explains that alewife,
rainbow smelt, threespine stickleback, and lake whitefish spawn along the shoreline of Lake
Ontario in Port Hope. It notes the Ganaraska River has resident populations of brown trout, brook
trout, rainbow trout, and walleye. Northern pike and lake whitefish also spawn in the river which
provides nursery habitat for these species. The ERA explains that the Ganaraska River is a (“key
producer”) spawning site for wild chinook salmon and coho salmon. It also explains the harbour
provides sheltered warmer water for a modest aquatic community including smallmouth bass,
yellow perch, and spottail shiner.12
The PHCF relies on a once-through cooling system for its conversion operations. The system
draws in water from an intake pipe in the harbour, close to the open lake. The water then gets
passed through pipes around the UO2 and UF6 facilities’ machinery, absorbing the heat
generated in processing the substances, and thus cooling them down. Once the water passes
through the facilities, it is discharged back into the harbour at a higher temperature, with some
degree of contamination possible while passing through the pipes. The system is subject to
conditions in an Environmental Compliance Approval (ECA) as well as a permit to take water
(PTW), both issued by the Ontario Ministry of Environment and Climate Change (MOECC).
Over its past licence term, Cameco initiated a self-assessment to determine whether it would
require a permit from the Department of Fisheries and Oceans Canada (DFO) to operate its once-
through cooling system.
Baseline impingement13
sampling was conducted from October to December 2012, and then
again from April to July 2013. Apparently only round goby, alewife and crayfish were found to
have been impinged and not in significant numbers. Baseline entrainment14
sampling occurred
from June to July 13 and March to July 2014. During 2013 testing, rainbow trout, brown trout,
blue gill, smallmouth bass, and crayfish juveniles were identified as well as round goby eggs,
and white sucker eggs and larva. The ERA for Cameco’s application confirms no species at risk
were identified during these studies except for an incident between April and May 2014 when
the north side of the intake structure breached and allowed fish to pass through the cooling
system, bypassing the intake screen. During that incident, round goby, rainbow trout, brook
sickleback, white sucker, yellow perch and a juvenile snapping turtle were sucked into the
system. The snapping turtle is a federal and provincial species of concern, subject to a federal
management plan. The intake structure was subsequently repaired and no more snapping turtles
have been found to be impacted by the cooling water system.15
No action was mentioned with regards to preventing similar incidents from happening again. Nor
does it appear as though there is regular monitoring of the cooling water system’s intake outside
of these self-assessment periods.
12
Appendix E, the Environmental Assessment Report for Cameco’s Port Hope Conversion Facility
Relicensing Application, CNSC Staff CMD for the 2016 relicensing process, 16-H8 at 21.
13
The term impingement refers to a process whereby larger aquatic species are killed by being drawn up
and crushed against the intake grate of the cooling water system.
14
The term entrainment refers to a process whereby juvenile fish, eggs, and larvae are drawn through
the intake grates and into the cooling water system, often resulting in death or serious injury.
15
PHCF Environmental Assessment Report at 31.

14. 14
The ERA also discusses three thermal studies which were conducted on behalf of the PHCF
between 2011 and 2014. In assessing thermal discharges from the cooling system, CNSC staff
observed thermal exceedances in the summer months of 2011 but noted they were probably
due to natural processes in the harbour. Staff also noticed that exceedances were observed or
predicted between September and December (of an unspecified year). They were associated
with one of the two cooling water outfalls, and risks to different species were identified on the
assumption that fish spent the entire period in the turning basin during the exceedances.
However, further study indicated that fish did not necessarily spend a significant amount of time
in the turning basin during October and November. No tagging study was done to determine fish
movement during December, which was the month that exhibited the highest number of thermal
exceedances.
During last year’s relicensing hearing for the PHCF, CNSC staff made an undertaking on the
record to share Cameco’s Fisheries Act self-assessment and CNSC staff’s review of it once it
was completed.16
The estimated completion date was December 16, 2016. These documents
had not yet been shared with Waterkeeper prior to the organization receiving intervenor status
in the current proceeding. They were requested from CNSC staff and Cameco in preparing these
submissions.
Cameco has since released a two-page summary of its self-assessment and the letter on behalf
of CNSC staff accepting the self-assessment’s conclusions that no significant harm to fish or
fish habitat will result from the facility’s cooling water system. On the basis of Cameco’s self-
assessment and CNSC staff’s approval of it, a Fisheries Act authorization was found to be
unnecessary.
The two-page summary includes high-level descriptions of mitigation measures in place to
address fish impingement and entrainment at the cooling water intake point. These include the
low volume water withdrawal (<1 m3
/s), low approach velocity (below USEPA 316b guidelines),
and the installation of mesh screening in the harbour intake as well as the pump house.
Impingement and entrainment was assessed on the basis of 24 sampling days in 2012 and 2013
for impingement, and 54 samples collected biweekly over 13 weeks in 2014 for entrainment.
These sampling periods were expected to have the highest volumes of impinged and entrained
fish. No Species at Risk were identified among the fish, fish larvae, and fish eggs collected during
sampling. A table with total entrainment and impingement mass is included for alewife, emerald
shiner, rainbow smelt, and round goby, as well as equivalent predator yield.17
However, no disaggregated data is provided in the summary to illustrate the range in monitoring
results, nor is there any information explaining the adequacy of sampling methodology or
explaining how the historical or potential presence of species at risk the harbour in past years or
at other times of the year was taken into account in the self-assessment. Further, no information
is provided in the summary document concerning any follow-up measures to address potential
impacts of thermal pollution from the cooling water system. Finally, the summary does not
include any discussion of whether further periodic monitoring of the cooling intake will be
undertaken by Cameco, at least to prevent or identify any potential intake screen failures.
16
2016 Hearing Transcripts at 32 and 39.
17
Cameco, “Self-Assessment of Impingement and Entrainment Losses”, Cameco Fuel Services Division
Technical Reports, Public Summary, Fall 2017.

15. 15
Cameco refused to provide a copy of their original report, instead offering to answer questions
concerning its summary. Further, the CNSC’s approval of Cameco’s assessment, which was
also shared with Waterkeeper, is a one-page letter. Waterkeeper submits that this type of limited
information disclosure is inadequate. It is unclear why Cameco is so hesitant to provide original
copies of certain technical reports to assist Waterkeeper’s reviews.
Recommendation 3: Cameco or CNSC staff should release the Fisheries Act self-assessment for
public review and include some type of monitoring regime to ensure the good operation of its
mitigation measures (if such a program does not already exist).
Persisting deficits in environmental monitoring plans and data disclosure
According to Cameco’s LCH for the PHCF, “The primary goal of a public information and
disclosure program is to ensure that information related to the health, safety and security of
persons and the environment, and other issues associated with the lifecycle of the nuclear
facilities are effectively communicated to the public”.18
A robust and transparent Public
Information Program (PIP) also lies at the heart of any facility’s social licence to operate within a
community. Section 2.6 of the PHCF’s current licence requires a PIP.19
When Waterkeeper was denied access to Cameco’s PIP last year, CNSC staff encouraged
Cameco to consider Waterkeeper’s request for public disclosure, despite the fact that it was not
legally required by RD/DC 99.3.20
Cameco provided a copy of their PIP to Waterkeeper upon request as part of this current review.
The PIP does not require the release of monitoring data for routine PHCF operations or release
events. Waterkeeper recommend this be changed, and will discuss more below.
Generally, Cameco continues to improve its public disclosure over time. However, more work is
still urgently required to improve the facility’s transparency. Cameco’s hesitancy to release raw
data and large technical reports is discouraging. Apparently, Cameco’s past disclosures have at
times been taken and used out of context by members of the public, causing difficulties for the
company. Waterkeeper is sensitive to this issue, and at the same time believes that this past
experience should not permit the company’s operations to remain opaque or exempt from public
scrutiny. Cameco may still provide the context it deems appropriate to accompany any release
of raw monitoring data or plans, helping to ensure that it is properly understood by the public.
Disclosure of monitoring plans and sampling data
There is a lack of publicly available information concerning the specifics of much of the
wastewater monitoring at the PHCF. Between the quarterly and annual compliance reports for
the PHCF, virtually no disaggregated monitoring data for any contaminant pathway to the Lake
is provided. Information on the groundwater contamination beneath the facility, and the pump
and treat system being used to contain it, is included in the 2016 Annual Groundwater and
Surface Water Review Report (March 2017) for the PHCF, but this report is not on the PHCF
18
PHCF LCH, 2017.
19
Current Nuclear Fuel Facility Operating Licence, Cameco Corporation Port Hope Conversion Facility,
FFOL-3631.00/2027, section 2.6.
20
2016 Hearing Transcripts at 43.

16. 16
website and thus not publicly accessible.
In the 2016 Overview Report there are also several significant information and data gaps. The
pump and treat system for groundwater is explained, but no data demonstrating its performance
is shared. No groundwater contamination concentrations are provided. The percentage capture
rate of COCs in ground water is not provided, only the mass of captured contaminated water is
shared. There is no mention of stormwater discharges in the report, let alone any data concerning
the volume and concentration of these discharges. These last reporting failures are particularly
significant as Mr. Ruland believes that contaminated groundwater seeps into these storm sewers
and constitutes the highest input of uranium into the harbour.
At last year’s relicensing hearing for the PHCF, Cameco representatives conceded that they
would revise their policies concerning proactive environmental monitoring data disclosure,
“With respect to real-time data, I think we see that as being another aspect that we can
look at. We're quite comfortable with the aggregated data that's providing that
overarching reassurance, as Mr. Feinstein [sic] referenced. But we do share that detailed
information with CNSC staff, and they review it and comment and provide any follow-up
through their inspections or inquiries in relation to that data”.21
This seemed to indicate that more comprehensive monitoring data and information was already
being shared with CNSC staff. As such, it should not prove unduly arduous to share the same
information with the public as well.
However, there does not appear to have been any change concerning the degree of
environmental monitoring data disclosure on the facility’s website since last year’s hearings and
Cameco’s undertaking.
Recommendation 4: quarterly, or annual reports should contain disaggregated data of sampling
results for all contaminant pathways (storm sewers, sanitary sewers, and the groundwater pump
and treat system).
Recommendation 5: annual mass loadings from groundwater of uranium should still be reported
in annual reports.
Wastewater treatment plans for VIM and PHAI activities
At last year’s relicensing hearing for the PHCF, Waterkeeper requested that Cameco publicly
disclose more information about its wastewater treatment plans, including wastewater treatment
plans for the excavation work that will be conducted in the Port Hope Harbour as part of the
Vision in Motion project and Port Hope Area Initiative. At that time, there was no information
about these plans shared during the relicensing application last year.
As part of Waterkeeper’s information requests during the current intervention opportunity,
Cameco explained that as these activities are only expected to occur sometime in 2020 or 2021,
detailed plans have not yet been prepared.
Recommendation 6: Once wastewater treatment plans are developed for the VIM excavation
activities, they should be made publicly available for review.
21
2016 Hearing Transcripts at 46.

17. 17
Persisting deficits in planned and unplanned release event disclosure
Cameco’s Public Disclosure Protocol for the PHCF confirms that the company undertakes to
provide “timely information postings” on its website about “unusual operational events” that may
have off-site consequences. The Protocol also confirms that environmental incidents reported
to the CNSC under section 29 of the General Nuclear Safety and Control Regulations and non-
routine environmental incidents reported to the MOECC Ontario Spills Action Center are also
posted online.
Over the course of Cameco’s last licence period, it experienced 15 reported events. Over the
last year, it has experienced a further 6 events. These included small fires in October and April
2017, a release of hydrogen fluoride in May 2017, a fluorine leak in February 2017, a uranium
hexafluoride leak in January 7. All these events are described as “small”, however no actual or
estimated volumes or event duration information is included in any of these event reports.
Cameco was also fined an Administrative Monetary Penalty for a failure to comply with certain
licence terms. According to a CNSC report in September 2017, CNSC staff conducted an
inspection at the PHCF and found that Cameco had failed to verify that work was being
performed correctly and according to approved procedures as required by Cameco’s PHCF
LCH. These actions constituted a failure to comply with a condition of a licence, in accordance
with paragraph 48(c) of the Nuclear Safety and Control Act. Apparently, there was a hydrogen
fluoride (HF) leak at the uranium hexafluoride (UF6) plant. The CNSC asserted there were no
environmental impacts associated with the leak, though they did not provide estimated volumes
of released HF. The incident appeared to be significant because it resulted in the termination of
two employees and suspension of a third.22
Ultimately, the best way to establish the
insignificance of events is to provide real data to support these assertions.
While Waterkeeper commends Cameco for posting event reports, postings should be more
prominent on the facility’s website, as their current location is easily missed. In fact, the CNSC
website contains more easily accessible event reports than Cameco’s. These event alerts are
presumably intended as public warnings, and thus should be easily and quickly accessible. It is
still difficult to find event reporting on the Cameco website (and an internal search of the Cameco
website for “releases”, “incidents”, “unplanned releases”, “event reports”, and “release reports”
did not produce any actual release event reports). Waterkeeper recommends that a link to the
webpage with reported incidents be included as a shortcut tab to the homepage for the PHCF,
or at least the facility’s “environment” webpage.
Waterkeeper also recommends that each incident report should include actual data of
measurable releases. If the data is not available at the time of posting, it should be added as an
update to the report once quantities have been assessed. Applicable Effluent Release Limits or
Action Levels should also be included in each report so that the public can gauge the severity of
the incident. Finally, Waterkeeper recommends that the date on the first line of each report be
specified as its posting date so that members of the public can more easily compare posting
dates with event dates.
22
Canadian Nuclear Safety Commission, “Regulatory Action – Cameco Corporation”, September 6,
2017online: <http://nuclearsafety.gc.ca/eng/acts-and-regulations/regulatory-action/cameco.cfm>.

18. 18
During last year’s relicensing hearing, Cameco explained it was in the process of launching a
new website for the PHCF, which would go live in 2017. Cameco representatives undertook to
improve event reporting with more definitive information including quantities and concentrations
of spills:
“In relation to the quantities and categorizing, if you look at our incidents that are
reported, there are times where we do give more definitive information around quantities,
and sometimes we're a little inconsistent in that regard. So an improvement in that
particular piece fits well with the point we've made previously about our desire to
continually improve our performance”.23
However, to date, any such improvements do not appear to have been carried out or be planned.
Recommendation 7: Cameco should improve its event reporting in the following ways
e) The webpage reporting incidents should be included as a shortcut tab to the homepage
for the facility, as its current location is difficult to find;
f) The incident reports should include actual data of measured releases;
g) Appropriate Effluent Release Limits and Action Limits should be included in these reports
to provide the public with a better understanding of the severity of the incident;
h) The date on the first line of each report should be specified as its posting date.
The need for more centralized and accessible water quality reporting
Ultimately, Mr. Ruland is able to assess the PHCF’s impacts to local surface and groundwater
due to his extensive professional experience paired with the familiarity with the PHCF that has
grown after his reviews of it over the last 6-7 years. He knows the contamination pathways and
can find, or else request, documentation of the measured impacts of each pathway. However,
for members of the public, this information is simply not accessible.
Mr. Ruland notes,
“It is currently quite a challenge for anyone seeking to understand the nature and potential
impacts of liquid emissions from the PHCF to find the information needed. Information
on different liquid flows is found in several different reports, and in the case of storm
water emissions monitoring information is not being formally reported at all. This needs
to change!”24
Mr. Ruland recommends a centralized source of information on all potential impacts of PHCF
operations to local surface and groundwater. He suggests the creation of an annual report which
includes information, references and links regarding: the full list of COCs for the PHCF; the areas
of contaminated groundwater and the extent to which they are being contained by the Pump
and Treat system; discharges to the sanitary sewer system; coolant water discharges; storm
water discharges; calculations of mass loading of uranium, and other key COCs, into the Harbour
from each liquid emission stream; water quality in Port Hope Harbour; and water quality in Lake
Ontario in proximity to the PHCF.
23
2016 Hearing Transcripts at 43.
24
Ruland Report, 2017 at 18.

19. 19
Recommendation 8: Cameco should begin producing an annual overview report on water quality
and the various streams of liquid emissions from the PHCF. The report should include
information, references and links regarding the following:
• the full list of COCs for the PHCF;
• the area of contaminated groundwater and the extent to which it is being contained by
the Pump and Treat system;
• discharges to the sanitary sewer system;
• coolant water discharges;
• storm water discharges;
• calculations of mass loading of uranium and other key COCs to the Harbour from each
liquid emission stream;
• water quality in Port Hope Harbour; and
• water quality in Lake Ontario in proximity to the PHCF.
Consistency and completeness of 2016 Oversight Report
Mr. Ruland, reviewed the 2016 Report and found its descriptions of all the facilities and their
regulatory compliance was inconsistent. For example, stormwater impacts were addressed
completely differently for each facility, with some facilities including detailed updates, and others
including no information at all. No rationale is provided for these inconsistencies: the fact that no
mention of PHCF stormwater discharge is included in the report should not be taken to mean
that stormwater issues at the facility are not significant or noteworthy.25
The inconsistency and lack of any standardization in reporting for each facility in the 2016
Oversight Report makes it difficult, if not impossible, to compare facilities against one another.
It also frustrates any attempt to get a broader or systemic understanding of processing facilities’
environmental performance across the country.
Recommendation 9: The CNSC should require more standardized and consistent Oversight
Reports
b) In future Overview Reports for processing facilities, the discussion for each featured
facility should include a description and analysis of each of the possible discharges of
liquids which could carry contaminants and potentially cause unacceptable off-site
environmental impacts:
a. process water;
b. cooling water;
c. off-site groundwater flow which may carry contaminants leaching from on-site soil
contamination;
d. sanitary sewer discharges;
e. storm sewer discharges.
b) Full references and/or links should be provided to the more detailed documentation/reporting
which has been summarized in the report section for each facility.
The 2016 Oversight Report is also incomplete, lacking key information concerning the
environmental impacts of Canadian processing facilities. For example, Mr. Ruland notes that the
25
Ruland Report, 2017 at 5-6.

20. 20
portion of the report concerning the PHCF fails to contain any information concerning the
groundwater pump and treat system, fails to provide contaminant concentrations in
groundwater, fails to provide the percentage capture rate of the groundwater pump and treat
system, and contains no mention of any stormwater discharges. These failures in reporting are
significant, as groundwater and stormwater are the most significant contaminant pathways at
the site. The 2016 report also fails to contain any information or data concerning cooling water
and sanitary sewer discharges to support Cameco’s assertions that these discharges are
meeting applicable regulatory requirements. Finally, there is also not mention of any release
events. Though, the report notes that fluoride concentration in the harbour rose to a high of
0.15mg/L, 0.3mg/L higher than the CCME guideline for fluoride, this guideline exceedance is not
accompanied by any explanation for this, or any recognition that this exceedance poses an issue
for local water quality.
Recommendation 10: The CNSC should develop and implement a requirement for at least a
minimal groundwater and surface water quality monitoring program for any industrial facility
which is processing uranium and/or other nuclear substances.
Concerns with uranium limits for the PHCF and other processing
facilities
Uranium limits for the PHCF
The previous release limit for uranium to Cameco’s sanitary sewers of 1,825kg was lowered in
the facility’s current licence to 275 μg/L with an Action level of 100μg/L.26
During last year’s
relicensing hearing, CNSC staff claimed this lower amount was set according the Canadian
Council of Ministers of the Environment (CCME) Water Quality Guidelines of 15 μg/L. However,
the Provincial Water Quality Objectives (PWQO) limit for uranium is 5 μg/L and was set
specifically to protect aquatic life in Lake Ontario. Mr. Ruland registered concerns with CNSC
staff using the CCME guidelines over the PWQOs during last year’s relicensing hearing, however
his recommendations on this issue to not appear to have been adopted.
CNSC staff claimed the PWQO of 5 μg/L was only ever suggested as an interim measure and
that it had since been replaced by the subsequent CCME limit.27
According the Cameco and
CNSC staff, regular monitoring of the sanitary sewers at the PHCF site generally revealed
uranium concentrations at 20 μg/L, so it is difficult to understand why Effluent Release limits and
Action Levels for this substance have still been set so high.28
In the relicensing process’ Record of Decision, CNSC staff recognized that the protective limits
based on the toxicity of uranium are more stringent than the limits based on radiological doses.
Staff subsequently lowered the originally proposed 1,825 kg/year limit, to a more conservative,
toxicity based interim value of 275 kg/L specifically for this reason. The lower Effluent Release
Limit apparently takes into account the dilution that would occur before the contaminated water
reaches the lake, and would meet the Canadian federal water quality limit for the protection of
aquatic life of 15 μg/L upon dilution. CNSC staff also agreed with Waterkeeper that the point of
26
LCH PHCF, at 50-51.
27
2016 Hearing Transcripts at 57.
28
Ibid at 28.

21. 21
control should be at the facility, at a much tighter limit, rather than relying on the wastewater
treatment plant as a point of control.29
At the same time, even if this estimate of dilution is correct, discharges close to the Action Level
for uranium may still not comply with the Fisheries Act which states that the concentration of any
substance released into waters frequented by fish must by measured, and its lethality assessed,
prior to dilution in receiving waters.30
As such, the exact concentration of contaminants being
discharged must be regularly monitored.
Further, as Mr. Ruland found when reviewing the 2016 Oversight Report, all other processing
facilities still have unreasonably high uranium licence limits. For example, the uranium limit for
the BWXT facility in Toronto is 9,000 kg/year. These amounts, if discharged into Waste Water
Treatment Plants (WWTP), would subsequently be partly released into receiving waterbodies (in
Port Hope and Toronto, this Is Lake Ontario) and partly concentrated in WWTP biosolids, which
in some cases are spread on farm fields.31
WWTPs are not equipped to adequately treat
radioactive substances, nor do municipal sewer bylaws include parameters or conditions on
nuclear substances, instead deferring to CNSC expertise and jurisdiction to manage the release
of these substances.32
Recommendation 11: The CNSC should initiate a process to review the licence limits for liquid
discharges of radiological contaminants from the facilities featured in the 2016 NPFD Report. The
licence limits for liquid discharges of any given radionuclide should consider both its radiological
properties as well as its chemical properties, and should be protective of both human health and
the health of aquatic organisms.
Conclusion
At last year’s relicensing hearing for the PHCF, Waterkeeper raised a number of concerns with
the facility’s environmental monitoring programs as well as insufficient discharge limits and
Action Levels concerning several contaminants. Additionally, Waterkeeper drew the CNSC’s
attention to the lack of publicly available information from Cameco about its environmental
performance.
As a result, the Commissioners invited Waterkeeper to follow up on various aspects of its
intervention during the current review process for CNSC staff’s 2016 Oversight Report for
Canadian nuclear substance processing facilities.
Generally, over the course of Waterkeeper’s interventions before the CNSC concerning the
PHCF, it’s clear to see improvements are being made. Waterkeeper recognizes that the legacy
wastes at the Cameco site pose a significant challenge for the company, and its attempts, via
its VIM project and complementary work being undertaken by the Port Hope Area Initiative
(PHAI), to remove and safely store these wastes is an important step in the amelioration of the
Port Hope Harbour Area of Concern. Further, environmental monitoring and sampling plans for
29
Affirmed in the 2016 Record of Decision at para 91.
30
Fisheries Act RSC 1985, c F-14 s 36(6).
31
Ruland Report 2017, at 9.
32
For example, the Toronto sewer bylaw explicitly refers to CNSC jurisdiction concerning regulated
releases of radioactive substances. City of Toronto, bylaw Chapter 681, Sewers, s 681-2(3)(o).

22. 22
the site have improved since 2011, stormwater infrastructure has been and will continue to be
upgraded to better address that contaminant pathway, and public information-sharing with the
public is steadily increasing.
At the same time, many concerns persist: additional environmental monitoring is still required to
better understand the PHCF’s effects on the local environment; more comprehensive and
demanding effluent release limits must be developed for the facility and made legally
enforceable; and information-sharing with the public must be more robust, especially regarding
the urgent need for better data sharing and incident reporting. As these submissions will show,
more work is still required in order to complete and deliver on Cameco and CNSC staff
undertakings from last year’s hearing.
A portion of the comments in this submission also relate to Waterkeeper’s overall review of the
2016 Oversight Report, including the public information sharing component of the report. Mr.
Ruland has found several issues in the report which require the CNSC’s attention, and his
concerns and recommendations are outlined in considerable detail in his report (attached as
Appendix I to these submissions).