Comments received on REGDOC 2.3.4

We have received the following comments: 

Please note, comments are posted in the language in which they are received.

Bruce PowerPlease see attached documentBruce Power comments on REGDOC-2.3.4
OPGPlease see attached documentOPG comments on REGDOC-2.3.4
Global First Power (GFP)Please see attached documentGlobal First Power comments on REGDOC-2.3.4
Canadian Nuclear Association (CNA)Please see attached documentCNA comments on REGDOC-2.3.4
Canadian Nuclear Laboratories (CNL)Please see attached documentCNL comments on REGDOC-2.3.4
Nicole CorradoSection 3.9.8

I grew up near a nuclear dump and nuclear power plant, near Pickering.  I never felt safe there, especially with that loud false alarm in January 2020.  I was so glad to move.  There is no safe disposal of nuclear waste or safe use of nuclear.  

I am quite concerned with 3.9.8, which mandates testing “fish tissue and other receptor species tests for exposure uptake”.  As Canada is moving away from animal testing, this seems counterintuitive to include animal testing in a document to modernize practices, especially when there is no mention of phasing out and replacing the practice.  Mining is harmful to all life, and to the planet.  Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated.  Canada is phasing out toxicity testing on animals.  Please switch to animal free methods of testing effluent and other substances.  For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans.  
Mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc.  Please do not use animal testing for pollution monitoring. 
There are cruelty free modern alternatives to animal testing, including acute lethality testing.  Cell cultures can determine effect of pollution for instance.  Please reach out to antivivisection organizations regarding these tests, and lobby to change these outdated laws.

Please stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species.  These tests involve pumping effluents into fish tanks about once a month, and if more than half the fish die, the experiments are repeated.  There are animal free ways to test for pollution.  Any guardians of companion fish will test their tank using paper strips and test tubes. They do not deliberately expose the fish to effluents to see what happens.  Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows and rainbow trout, and stop cutting up fish to test their livers for mercury.  Please lobby the government to put an end to mandatory toxicity testing under the Fisheries Act and go cruelty free.  Please only use non lethal sampling of wild fish, or take tissue samples from fish who were already caught for human consumption.  Please do not kill or harm any animals for research.  

Many mining companies also kill animals as “pests”.  Please only use non lethal methods of wildlife coexistence.  

Please only use humane non lethal methods to manage beavers and other wildlife.  Killing beavers only leaves room for more animals to move in.  And the traps kill many other animals.  London Ontario and many other places manage beavers without killing.  

NB PowerPlease see attached documentNB Power comments on REGDOC-2.3.4

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