The following is a letter from Dr. Frank Greening. Dr. Greening has given us permission to post it here.
The DGR is Dead. Long Live the DGR!
1.0 Introduction
According to Wikipedia, "The king is dead, long live the king!", is a traditional proclamation made following the accession of a new monarch in European countries. The seemingly contradictory phrase is used to simultaneously announce the death of the previous monarch and assure the public of continuity by saluting the new monarch.
In looking at what happened last week with the announcement that the SON (Saugeen Ojibway Nation) voted to reject OPG’s plan to build a Deep Geologic(al) Repository (DGR) on the Bruce Nuclear site near Kincardine, one might have reasonably construed: “The DGR is dead”. However, immediately following this announcement by the SON, Ontario Power Generation (OPG), the proponent of the DGR, noted that while it accepted SON’s rejection of the Bruce Power site, it planned to start looking for an alternative location to build a DGR thereby effectively proclaiming: “Long live the DGR!” This reaction by OPG clearly demonstrates OPG’s belief in the inviolability of the DGR concept. The question is therefore not if a DGR will be built to house OPG’s Low and Intermediate Level (L&IL) nuclear waste, but rather where will it be built.
But OPG is not the only party interested in building a DGR in Southern Ontario to store nuclear waste. Thus, on January 24th, 2020, The Nuclear Waste Management Organization (NWMO) signed agreements with landowners in South Bruce, that will allow access to land for studies of a potential spent fuel DGR location. Dr. Mahrez Ben Belfadhel, Vice-President of Site Selection at the NWMO, noted with regard to this announcement: “With agreements in place and access to land in South Bruce, we expect to begin borehole drilling and baseline environmental monitoring in the coming months to assess the suitability of the area.”
A local farmer and landowner, Darren Ireland, who entered into an agreement with the NWMO noted “I was born and raised in this community, and my family and I are proud to call South Bruce home. We understand that this project has the potential to bring long-term benefits to the area, and we want to be part of building a sustainable, prosperous community for everyone now and in the future.”
The land access process was initiated in May 2019. Since then, the NWMO has worked with local landowners, including Mr. Ireland, to aggregate nearly 1,300 acres (526 hectares) of land northwest of Teeswater, Ontario. The agreements include a combination of option and purchase arrangements that allow the NWMO to conduct studies and landowners to continue using the land, in some cases through leaseback arrangements.
“The identification of a potential repository site in South Bruce is an important milestone for Canada’s (spent fuel disposal) plan, providing confidence that the organization can proceed with technical site evaluations and social studies in this area. This is the result of months of hard work and effort on behalf of the municipalities, local landowners and the NWMO,” said Dr. Ben Belfadhel. “Canada’s plan has been made stronger through the thoughtful and constructive contributions of the people and leaders in the area.”
The NWMO added it will continue discussions with landowners in the vicinity of the potential site over the coming months and years to further aggregate additional land in this area to form a site of approximately 1,500 acres (607 hectares). Canada’s plan calls for the NWMO to identify a single, preferred site to host the project, in an area with informed and willing hosts, by 2023.
Now here we see an obvious difference between NWMO’s approach, compared to OPG’s approach, to finding a suitable location for a DGR. Both organizations claim they want to select the ideal location based on technical considerations such as a stable, strong, dry, impermeable bed rock, and both organizations also want the site to be owned and occupied by a “willing host”. However, NWMO apparently believe that site selection should also depend on “the thoughtful and constructive contributions of the people and leaders in the area,” - who NWMO identify as the current landowners - while OPG sees that such “people and leaders in the area” are the traditional landowners - the SON.
2.0 So, who owns this land?
According to the Chiefs and Councils of the Saugeen Ojibway Nations:
The Saugeen Ojibway Nation (SON) is made up of the Chippewas of Nawash Unceded First Nation and the Chippewas of Saugeen First Nation. SON’s Traditional Territory is bounded on the south by the Maitland River system from Goderich to past Arthur, on the west by the Canada/USA border in the middle of Lake Huron, on the north by a line along the midpoint of the channel between the Saugeen (Bruce) Peninsula and Manitoulin Island, and on the east by a line down the middle of Georgian Bay. (See Figures 1 & 2)
Figure 1: Modern Map of the Bruce Peninsula
Figure 2: Traditional Territories of the SON
The maps depicted in Figures 1 & 2 do indeed show that the SON’s traditional territories extend from Tobermory in the north, to a line extending approximately from Goderich to Collingwood in the south. Thus, the prospective DGR sites at Kincardine and Teeswater clearly lie within these boundaries. However, there are some counter claims to portions of the SON’s traditional territories, for example claims by the Métis, and the Aamjiwnaang and Beausoleil First Nations.
Nevertheless, what is perhaps more relevant to the present discussion is the fact that in April 2019 the SON launched a court case against the federal, provincial, and several municipal governments in Ontario claiming that these various levels of government have breached treaties signed between the Crown and the SON’s leaders more than 100 years ago.
Under Treaty 45-1/2, signed in 1836, the SON gave up more than 600,000 hectares of land south of Owen Sound, Ontario. In exchange, the claim asserts, the Crown promised to protect forever what we now call the Bruce Peninsula from settler incursion. However, just 18 years later in 1854 under Treaty 72, the Crown demanded and achieved the surrender of the peninsula on the basis the government could no longer protect the lands from settlers.
SON now asserts that the Crown misled the First Nations and could have protected the peninsula as initially promised. Their claim calls for the return of lands on the peninsula still owned by Ontario or Canada, or that have not been bought and paid for by third parties. For their parts, the governments maintain they have dealt with the First Nations properly, have lived up to their treaty obligations and deny aboriginal title to the lands exist; thus, they want the claims thrown out.
This position appears to be at odds with a recent initiative by the Trudeau government when it decided to support a private member’s bill, C-262, that would require the adoption of measures to make Canadian law “consistent” with the 2007 United Nations Declaration on the Rights of Indigenous Peoples, the so-called UNDRIP declaration.
Two items of particular interest in UNDRIP are articles 26 and 19. Article 26 protects Aboriginal rights to all “lands, territories and resources” they have traditionally occupied. There are neither definitions nor exceptions — for example, to land ceded by treaty. And Article 19 requires Parliament and the provincial legislatures to obtain the “free, prior and informed consent” of Indigenous communities prior to adoption of legislation or administrative measures “that may affect them.”
However, to add further confusion to an already muddy legal quagmire, consider the 2017 Ktunaxa Nation vs. British Columbia case in which the Canadian Supreme Court ruled: If the duty to consult has been fulfilled (and the project has met its other regulatory tests), a project can proceed even over the objections of one or more First Nations. “Section 35 of the Constitution guarantees a process, not a result,” the ruling notably stated.
3.0 How did the Bruce Nuclear site come into being?
In the early 1950s a so-called Nuclear Power Group was set up under Harold Smith of Ontario Hydro to explore the possibilities of developing nuclear power in Canada. Out of the deliberations came the idea for NPD, a tri-partite undertaking among Canadian General Electric, Ontario Hydro and AECL. A design team began work at CGE in 1955. However, long before NPD was finished, W.B. Lewis, Harold Smith and the Nuclear Power Group were looking to bigger things. They were pushing for a full-scale power reactor and in 1958 another team called the Nuclear Power Plant Division was set up in Toronto.
Choice of the site for this projected full-scale reactor involved a long process of elimination. CANDU reactors require copious quantities of water to cool the reactor, so lakeshore locations were strongly favored. Originally in the running were points along the shoreline north of Manitoulin Island, and from Tobermory on the Bruce Peninsula all the way to Goderich. Gradually the choice was narrowed down to the stretch between Goderich and Southampton. Finally, Douglas Point - about half way between Kincardine and Port Elgin - was chosen primarily because, at this location, the limestone bedrock is close to the surface.
Construction of the 206 MW Douglas Point reactor began in 1960. Much of the land in the area was Crown owned and up for sale at a reasonable price. The Bruce Nuclear Power Development (BNPD) project site now occupies 2300 acres which was purchased by the Ontario Hydro Electric Power Commission for $50 to $70 an acre, the going price of farm land at that time. By comparison, in 2019, the average price per acre of land in the region was $9,049 among transactions that ranged in price between $5,100 and $16,700 per acre.
4.0 Why was the Bruce Nuclear site chosen for OPG’s DGR?
The fact that the site chosen for OPG’s DGR is located more or less at the center of the Bruce Nuclear Development site is no coincidence. The construction of Douglas Point, (started in February 1960), was soon followed by the construction of eight much larger CANDU reactors: Four 540 MW Units at the Pickering site near Toronto, with construction started in 1966, and four 750 MW Units at the Bruce site, with construction started in 1970. Figure 3 is an aerial photograph of the Bruce site as it appears today.
Figure 3: The Bruce Nuclear site looking north
The photograph shows Bruce B at the lower center of the image, the white domed Douglas Point reactor just above center left, and Bruce A, adjacent to the Baie du Doré to the right near the top of the image.
Very early in the operating history of the CANDU Units at Pickering and Bruce the steadily increasing amounts of nuclear waste became an issue. A first step towards solving this problem was taken in 1966 when the Radioactive Waste Operations Site 1 (RWOS-1) was put into operation at the Bruce site. RWOS-1 was established to provide storage for solid low and medium level radioactive waste primarily from Douglas Point, and to a lesser extent from Pickering and the Nuclear Power Demonstration (NPD) reactor at Rolphton, Ontario.
Somewhat later, in 1974, the Radioactive Waste Operations Site 2 (RWOS-2) commenced operations. This facility was designed for the receipt, processing and storage of low and medium level radioactive waste generated by all Ontario Hydro nuclear power stations. RWOS-2 comprised a Waste Volume Reduction Facility (incinerator with in-service date of 1977) and above and below ground storage structures.
Waste designated as “Low level” included items such as mop heads, floor sweepings, clothing and tools. On the other hand, “Medium level waste” consisted of items such as spent ion exchange filters and used reactor parts. Once fully operational, about 3,000 m3 of low-level radioactive waste was incinerated at RWOS-2 each year, resulting in about 50 m3 of waste ash. At the same time, about 500 m3 of radioactive waste was compacted each year. Also, each year, over 1,000 m3 of waste that could not be incinerated or compacted was stored “as is”.
In 1976, after 10 years of receiving radioactive waste, RWOS-1 operations were discontinued. However, in 1996, groundwater monitoring wells at RWOS 1 showed leakage of radioactive contaminates (e.g. tritium), often in excess of the Ontario Drinking Water Objective and even beyond the regulatory Maximum Permissible Concentration (of tritium) for water (MPCw). The monitoring data suggested that a plume of contaminated groundwater had reached the neighboring Inverhuron Provincial Park. It was therefore decided that all of the waste at RWOS-1 should be retrieved, segregated and packaged for transfer to RWOS-2.
In 2001 RWOS-2 was renamed the Western Waste Management Facility (WWMF) as the agreement between OPG and Bruce Power gave the latter exclusive use of the word “Bruce” as it pertains to the site. Since 2001, the WWMF has been operated by OPG.
Also, in 2001, the federal government introduced an Act respecting the long-term management of nuclear fuel waste. Known as the Nuclear Fuel Waste Act, this legislation came into effect on November 15, 2002. However, this legislation dealt only with the long-term management of used nuclear fuel (high-level waste), not L&ILW. Nevertheless, the introduction of the Nuclear Fuel Waste Act prompted the Municipality of Kincardine to initiate discussions with OPG regarding the long-term management of the L&ILW stored at the WWMF.
From its inception, the WWMF was only considered an interim solution to the disposal of radioactive waste. Furthermore, under the Government of Canada’s Radioactive Waste Policy Framework (1996), OPG was responsible for implementing a long-term solution for managing its L&ILW, which included the funding, organization, management, operation and disposal of such wastes.
In 2002, the Municipality of Kincardine and OPG signed a Memorandum of Understanding (MOU), under which OPG, in consultation with the Municipality of Kincardine, (but not the SON, by virtue of its omission from the MOU,), would develop a plan for the long-term management of L&ILW at the WWMF.
As part of the MOU-related activities, Golder Associates, on behalf of OPG and the Municipality of Kincardine, conducted an Independent Assessment Study of three long-term waste management options: enhanced processing and surface storage, surface concrete vaults, and deep rock vaults. The study, published in 2004, included technical feasibility and socio-economic impacts, as well as a review of international practices for waste management.
The assessment found that all three long-term management options were technically feasible and could be safely constructed and operated at the WWMF. Ultimately, the Municipality of Kincardine identified a deep geologic repository or DGR as its preferred option for the long-term management of L&ILW, and endorsed the project on April 21, 2004. The DGR was proposed to be constructed 1.2 kilometers from Lake Huron below the shelf of the lake which is connected to the Great Lakes basin. The DGR waste storage areas would be located 680 meters below ground, constructed in low-permeability limestone capped by 200 meters of low-permeability shale. Figure 4, below, shows the proposed location of the DGR in relation to the present WWMF site and the Lake Huron shoreline.
Figure 4: Proposed Location of OPG’s DGR at the Bruce Nuclear Site
5.0 Opposition to a DGR at the Bruce Nuclear Site
The general public’s response to OPG’s 2004 plan to build a DGR for the permanent disposal of its L&IL nuclear waste was slow to take shape, but by 2010 a consensus began to emerge that the construction of a DGR on the Bruce Nuclear site should be opposed because of issues such as:
the danger of burying nuclear waste next to the great lakes and the possible negative impact on the drinking water of 40 million people
the environmental harm caused by the dirt, dust, noise and traffic that the equivalent of an industrial mining site would bring
concerns over having more nuclear waste transported on local roads
concern over property values
an undoubtedly negative impact on tourism
a belief that the perceived economic benefits would be insufficient to counter the negative impact on the South Bruce community
In addition, between 2013 and 2018, opposition to OPG’s DGR extended well beyond South Bruce and became highly politicized. For example:
• September 18th, 2014: Senators Stabenow, Kirk, Levin and Baldwin introduce resolution 565 in US Senate that the Canadian government should not allow a permanent nuclear waste repository to be built within the Great Lakes Basin.
• November 30th, 2017 – A letter signed by 104 Great Lakes Mayors opposing OPG’s proposed nuclear waste repository was sent to Catherine McKenna, Minister of Environment and Climate Change.
A timeline of key events concerning OPG’s DGR proposal since 2015 provides a convenient summary of how we arrived at the SON’s game-changing vote on January 31st, 2020:
May 6th, 2015: The Joint Review Panel (JRP) for the DGR Project submits its Environmental Assessment Report to the federal Minister of the Environment recommending that the Project be allowed to proceed
February 18th, 2016: The federal Minister of the Environment requests OPG provide additional information on three aspects of the environmental assessment: Alternate locations for the project, cumulative environmental effects of the project, and an updated list of mitigation commitments for each identified adverse effect under the Canadian Environmental Assessment Act
January 3rd, 2017: OPG submits the additional information requested by the Minister of the Environment
April 5th, 2017: The Canadian Environmental Assessment Agency (CEAA) requests that OPG provide additional information on the DGR and in particular: A description of the land and resource uses for the alternative locations that highlight the unique characteristics of these locations from the perspective of Indigenous peoples (e.g. land availability for traditional uses, access, etc.)
May 29th, 2017: OPG submits the additional information requested by CEAA
August 21st, 2017: The Minister of Environment and Climate Change requests OPG update its analysis of the potential cumulative effects of the project on the physical and cultural heritage of the SON
March 12th, 2019: OPG sign an interim agreement with Saugeen Ojibway Nation (SON) regarding historic issues.
With regard to this last (March 2019) entry, OPG stated:
The agreement signed in March lays the groundwork for further progress in 2019 and beyond to identify and attempt to resolve legacy issues related to the past 60 years of nuclear development in SON traditional territory, including construction of the Douglas Point reactor and the OPG-owned Bruce A and B reactors.
On the DGR, OPG is required to update its cumulative effects analysis for the federal Minister of Environment and Climate Change, stating the impact on the physical and cultural heritage of SON; and that analysis must be informed by the result of SON’s own community process on the DGR. OPG is engaging with SON members to help inform a community vote, which SON says it may hold near the end of 2019.
6.0 Discussion
The idea of establishing a deep geologic repository for Canada’s nuclear waste is not new as an extract from a 1994 report on radioactive waste disposal jointly written by AECL and Ontario Hydro shows:
Reviews initiated by governments in Canada going back to the 1970s have concluded that disposal, rather than storage of nuclear waste is necessary.
For example, the 1977 study group chaired by F.K. Hare recommended that waste should not be allowed to accumulate indefinitely in interim storage. Ontario's 1980 Royal Commission on Electric Power Planning concluded that "There is clearly an urgent need to develop ultimate disposal facilities to ensure that these wastes are isolated from the world's ecosystems." The 1988 House of Commons Standing Committee on Environment and Forestry also recognized the need for disposal, stating that, whatever the future of nuclear energy, "the waste which it produces must be disposed of."
The need to involve the general public, and the potential for strong opposition from some sectors of the public, was also recognized at that time, as an extract from a paper presented at the 1982 International Conference on Radioactive Waste Management shows:
The "not in my backyard" syndrome is now generally accepted as a real and substantial impediment to waste disposal siting. Recently, a number of countries, including Canada, have found difficulty not only in finding sites for low-level nuclear waste disposal facilities, but even in finding publicly acceptable places to conduct geological research to assess the safety of the geologic disposal concept for nuclear waste disposal.
This phenomenon first manifested itself in Canada in 1977, a few years after Atomic Energy of Canada Limited (AECL) started its geological research program in Ontario. In March of that year, more than 1000 people at a public meeting in the town of Madoc in southeastern Ontario told AECL in no uncertain terms that they did not approve of such research in their backyard.
The geological research conducted in the Madoc area, which was preliminary to deep drilling, had been based on informal agreements among AECL, Ontario Hydro, the Canadian government and the government of Ontario. The public opposition to the research resulted in some political uncertainty, and AECL was instructed to discontinue its activities in Hastings County, which includes Madoc.
After the 1977 public relations debacle at Madoc, AECL shifted its DRG development activities to its Whiteshell Nuclear Research Establishment, located near Pinawa, Manitoba, 95 km northeast of Winnipeg. However, after revelations that radioactivity from the site was leaking into the Winnipeg River, the Manitoba legislature passed the THE HIGH-LEVEL RADIOACTIVE WASTE ACT on July 17th, 1987, which stipulated, inter alia, that:
No person shall provide facilities for the storage of high-level radioactive wastes that were not produced on-site as the result of research in Manitoba, transported to the site for use in on-site research in Manitoba, …, or provide facilities for the disposal of high-level radioactive wastes in Manitoba
This legislation sent a clear message to the world that Manitoba would not accept any out-of-province high-level radioactive waste for storage or disposal anywhere in the Province, thereby killing any prospect of a DGR for Ontario’s radioactive waste being established in Manitoba. As a result, after 1987, OPG was forced to limit its search for a site for the disposal of its nuclear waste to locations within the Province of Ontario. And, as a footnote to this narrative, in 1998 the Federal Government announced the closure of the Whiteshell Laboratories, and decommissioning of the facility has been underway since then.
At the same time, the need for aboriginal peoples to participate in discussions of the siting of any DGR proposal began to emerge, as illustrated by comments made by Lyle Morrisseau of the Sagkeeng First Nation at the Nuclear Fuel Waste Environmental Assessment Panel Public Hearings held March 1997:
“We would like to participate in these hearings and develop a parallel process before the final recommendations are out. We would also like to be given the time and resources to be able to develop with our leadership . . . a process that would look directly at the recommendations that have come from these hearings as well as to develop our own recommendations in a parallel sense”.
However, it appears that such concerns were essentially forgotten just a few years later when OPG first proposed a DGR for disposal of its nuclear waste. Thus, following OPG’s 2003 announcement of its plans to build a DGR on the Bruce Nuclear site, SON expressed deep concern about the DGR Project and pushed the Canadian Nuclear Safety Commission (CNSC) for the highest review standards and argued for SON to have a central role in the review of the Project. The CNSC responded to these concerns by noting in the Project’s Terms of Reference issued in 2006 that the Joint Review Panel must consider evidence and information specifically on potential impacts to SON rights and interests.
Eventually, in 2009, a Protocol Agreement was signed between SON, OPG and NWMO which provided a process to provide SON with the necessary tools and resources to participate in the regulatory approvals process for the DGR Project. A Joint Liaison Committee was also established between SON, OPG and NWMO to provide a mechanism for direct communication.
Nevertheless, by 2012, it was clear that the SON was still not satisfied with the DGR approval process when it wrote:
OPG does not, at this time, have the support of the SON communities for the construction of its DGR Project in SON Territory. For many years, SON has maintained its position that SON consent is required before the DGR Project can proceed. SON has repeatedly sought assurances from OPG and others in this respect. For many years, those requested assurances were not forthcoming.
However, this situation radically changed on August 7th, 2013, when SON Chiefs Chegahno and Kahgee received a letter from Tom Mitchell, President of OPG that stated:
“OPG will not move forward with the construction of a deep geologic repository for low and intermediate level nuclear waste until the SON community is supportive of the project.”
Now, on January 31st 2020 - almost seven years on from this commitment by OPG - the SON overwhelmingly voted down the proposed deep geological repository (DGR) for storage of low- and intermediate-level radioactive nuclear waste next to Lake Huron. Out of 1,232 total votes, there were 4 spoiled ballots, 170 yes votes, and 1,058 no votes, indicating that 85% of those casting ballots had said no to a DGR at Bruce Power’s nuclear generating station in Kincardine, Ontario.
7.0 Conclusions
In view of the fact that the January 31st 2020 vote was by secret ballot, the reasons for the SON’s rejection of the DGR were not identified in the press release by the SON following the announcement of the voting results. Nevertheless, such reasons are no doubt essentially the same as the concerns raised by the SON in its DGR intervention presented to the JRP in October 2013:
Ontario Power Generation Inc. (“OPG”) has proposed to build a deep geologic repository for the permanent disposal of low and intermediate level nuclear wastes (“DGR Project” or “Project”) at the Bruce Nuclear site, in the heart of SON’s Traditional Territory. SON has consistently expressed a fundamental and abiding concern that the DGR Project poses a grave threat to its peoples’ rights, interests and way of life. Concerns arise from the untested nature of the technology being used and the permanent — and irreversible — changes the Project will bring to SON Traditional Territory.
SON has particular concerns that OPG has not yet studied or understood many significant potential risks created by the Project and their impact on SON rights and Traditional Territory, including the strong potential for stigma impacts to their fishery and tourism-based economies. Another principal concern remains that the DGR Project has not been understood in the context of existing nuclear issues at the Bruce Nuclear site, including its connection to the long-term management plan for spent nuclear fuel. These concerns have resulted in a significant lack of confidence in the development process for the Project and an overall anxiety about the threat it poses to the SON people.
Thus, we see that there is no single issue that caused the SON to reject the proposed DGR. For example, if lake water quality was a major concern of the SON, OPG could resolve this issue by simply moving the selected site to a location such as Teeswater which is over 30 km from Lake Huron and only 40 km from OPG’s original preferred location – the Bruce Nuclear site. However, since there are evidently many, more generic, issues for the SON, it appears very likely that the SON would reject the creation of a DGR anywhere on land within its traditional territories, (shown by the maps in Figure 2 of this report).
But OPG has made it clear that in spite of the negative vote by the SON, it is nonetheless not giving up on its plan to create a DGR somewhere in Ontario. Now this clearly implies looking for a potential site outside of the SON’s traditional territories. However, this would undoubtedly create a new set of problems for OPG because Section 35 of the Canadian Constitution Act (1982) states that:
The existing aboriginal and treaty rights of the aboriginal peoples of Canada are hereby recognized and affirmed.
And as the map in Figure 5 below shows, all of the Province of Ontario is made up of lands that are protected by aboriginal treaty rights.
Figure 5: Ontario’s Aboriginal Lands Under Treaty Rights
Thus, we conclude that if OPG wants to keep pushing for a DGR for its ever-growing mountain of radioactive waste, it is most certainly faced with a long, hard battle with the aboriginal peoples of Ontario, many of whom will no doubt claim the veto powers already accorded to the SON.
However, OPG should not consider that it’s alone in the global nuclear community in having trouble convincing potential hosts to give their approval to the creation of a DGR. After all, no lesser nuclear power-house than the USA has also struggled for many years to accomplish this goal as noted by J. Samuel Walker in his 2009 book: The Road to Yucca Mountain: The Development of Radioactive Waste Policy in the United States. The final chapter of this book ends with the following sobering comment:
The history of the search for an acceptable location for a (radioactive) waste repository has highlighted both technical and political complexities that responsible officials recognized, but too often dealt with indifferently or incompletely between the late 1940s and the early 1970s. Progress on technical issues in the late 1970s and 1980s occurred simultaneously with setbacks on the political issues that siting triggered. The quest for a long-term solution to nuclear waste disposal has remained a perplexing national problem that is too important to ignore, too controversial to compromise easily, and too complicated to settle conclusively.
Dr. F. R. Greening
Hamilton, ON
February, 2020
