Is the proposed nuclear Near‐Surface Disposal Facility a threat to the Ottawa River?

By Stefan Klietsch, PERC Intern

In recent years, there has been public controversy surrounding Canadian Nuclear Laboratories’ (CNL’s) proposed Near‐Surface Disposal Facility (NSDF) that would be located near the Town of Chalk River on the controlled CNL site and roughly one kilometre away from the Ottawa River. CNL is proposing the NSDF as a solution to isolating existing low‐level nuclear waste that is already being stored temporarily on site at Chalk River Laboratories. CNL’s proposed NSDF is a long‐term plan to protect the environment, and the proposed NSDF was the best solution among other competing alternatives. The NSDF remains under review by the Canadian Nuclear Safety Commission (CNSC).

Critics say differently however. The Assembly of First Nations and more than 140 Quebec and Ontario municipalities have passed resolutions opposing the NSDF. Ecologist Dr. Ole Hendrikson and organizations such as Ottawa Riverkeeper have alleged that future tornadoes or earthquakes could disrupt the NSDF and threaten nuclear spillover into nearby wetlands and the Ottawa River. They allege that the NSDF would be dangerously radioactive for 100,000 years, and that it would effectively be a landfill contrary to International Atomic Energy Agency standards that only Very Low Level Radioactive Waste (VLLW) can be put in above‐ground landfill‐type facilities. They further allege that CNSC is a captured regulator.

What is the truth here? We from the PEN reached out to CNL Manager of NSDF Regulatory Approvals, Sandra Faught and Dr. Ole Hendrickson to answer our top questions about the NSDF.

To CNL: Your organization has written, “14 locations were considered and judged according to size, access to utilities, flood risks, geotechnical considerations and species at risk.” Can you further elaborate on the broad disqualifying factors of the rejected locations? How likely is it that there are more appropriate locations to choose that CNL may have overlooked?

Through both rigorous scientific and technical consultation and validation, as well as third party verification Canadian Nuclear Laboratories’ (CNL) has chosen the best suited site at the Chalk River Laboratories (CRL). CNL completed its site selection following the requirements of the Canadian Environmental Assessment Act (CEAA) 2012, where each alternative was assessed, and the most preferable option is selected after a systematic consideration of technical and economic feasibility and environmental effects.

The selection process for the siting of the NSDF at the Chalk River Laboratories was comprehensive and began with the establishment of mandatory criteria that must be satisfied by candidate locations; mandatory criteria included minimum area of 14 hectares, minimum site width of 200 metre, access to water for sanitary and process requirements, access to electrical power, and access to gas or other heating fuel. Exclusion criteria was then applied to remove any locations that were constrained by project requirements or by pre‐defined factors; exclusion criteria are physical, cultural and biological features that will eliminate a location from the list of potential sites because development is either not permitted or poses a risk for the intended use. The exclusion criteria applied during the site selection for NSDF included, but was not limited to, locations within the flood plain, known seismic fault lines, known and likely habitats of species at risk, and known archaeological sites. Two candidate sites at CRL remained following this process.

The preferred site, the East Mattawa Road (EMR) site, provides greater protection to the Ottawa River from a hydrological perspective. The groundwater transit time from the EMR site to the nearest surface waterbody is estimated to be 5 to 15 years with an average transit time of approximately seven years. The ERM site is on a bedrock ridge that forces water away from the Ottawa River. The groundwater transit time from the alternate site is approximately two years, so although it appears farther on a map, from a water movement perspective, it is closer to the Ottawa River.

The proposed facility has been specifically designed for the selected site and the proposed waste inventory. The facility and the site together form the entire waste disposal system, which is designed to contain the contaminants for hundreds of years after closure of the facility and ensure that there are no significant adverse effects to humans, biota, or the environment.

To CNL: Your organizations has written, “The waste will be isolated by a three metre thick multi‐layer base liner and cover system that has been tested to last over 550 years, at which point the radioactivity will have decayed to levels you would find in the natural environment.” Can you explain what it means for the waste to have “decayed to levels you would find in the natural environment”? Does this mean that the waste will no longer be dangerous after 550 years?

The proposed NSDF will contain only low‐level radioactive waste. Part of the reason why the wastes are classified as “low‐level” is because the vast majority of the wastes have short half‐lives, meaning that the material decays away in short time periods. Radioactive material that decays quickly is not a long‐term hazard. Low level waste can contain longer‐lived radionuclides, but in small concentrations. Long‐lived radionuclides are a natural part of the environment, and exist in all rock and soil on the planet. When the proposed facility is closed the mix of radionuclides left managed in the engineered mound can be compared to what can be found in local, naturally occurring bedrock. The science shows that the waste in NSDF becomes less radiotoxic than naturally occurring areas after only about 10 years following closure.

Long‐term modelling of the facility is an important aspect for determining safety to humans and the environment. In one modelling scenario conducted by technical experts, a person is assumed to live on top of the facility 300 years into the future. This person raises livestock, grows crops, and consumes their own locally produced foods. The resulting radiological exposure to this person is about the same as eating 150 bananas per year, or 1 banana every 2 and a half days. This is a very small amount of radiological exposure, about 1% of the natural occurring background radiation that all Canadians are exposed to through our environment.

The total inventory placed in the NSDF will be controlled through the NSDF Waste Acceptance Criteria (WAC). CNL’s compliance with the WAC ensures our responsibility as the licensee; that all waste received for disposal is in compliance with the design and licensing basis for the facility. Waste shall comply with all of the criteria in the WAC to be considered acceptable for disposal in the NSDF. Waste that does not meet the WAC will not be placed in the NSDF and will be placed in safe storage.

To CNL: Is the claim true that the NSDF would not be in compliance with International Atomic Energy Agency standards advising against above‐ground nuclear storage?

In the development of the NSDF, CNL has met both Canadian and International requirements and guidance. This includes regulatory documents issued by the Canadian Nuclear Safety Commission (CNSC), as well as safety guidance issued by the International Atomic Energy Agency.

The key features the NSDF Project have addressed in the IAEA design principles for radioactive waste disposal are multiple safety functions, containment of radioactive waste, isolation of radioactive waste, and surveillance and control of passive safety features. For example, IAEA SSR‐5, paragraph 1.14 (b) states: “Near surface disposal: Disposal in a facility consisting of engineered trenches or vaults constructed on the ground surface or up to a few tens of metres below ground level. Such a facility may be designated as a disposal facility for low level radioactive waste (LLW)”. CNL’s NSDF is an engineered facility with multiple barrier systems, located on the surface, which will only contain LLW. Therefore, the facility meets IAEA guidance.

Furthermore, the appropriateness of a facility design and radiological inventory is determined by the Safety Case. The NSDF Safety Case clearly demonstrates that the facility meets the guidance put forth by the IAEA and CNSC. The Safety Case can be found on the CNL website, in both English and French.

To Dr. Hendrickson: For all the flaws of the proposed NSDF, Canadian environment and geography is complex all throughout the country. Just how plausible is it that a waste-disposal location could be found that is safer yet reasonably economical?

The Ottawa River occupies a major, ancient fault that today experiences frequent earthquakes. Owing to this seismic activity, rocks close to the river are fractured with high rates of groundwater movement. This applies to the entire Chalk River property. Canadian Nuclear Laboratories failed to consider the unsuitability of its chosen location: next to the river, with fractured and porous bedrock, and the water table right at the surface.

Away from the river to the south in Ontario, seismic activity, faults and fractures decline rapidly. Reasonably economical and far better locations for a waste facility could be found either on the much larger federal Garrison Petawawa property that adjoins Chalk River, or on provincial crown lands further from the Ottawa River.

The International Atomic Energy Agency says “siting is a fundamentally important activity in the disposal of radioactive waste.” The IAEA’s recommended siting process is to first develop a generic design for the waste facility, then to survey a region of interest to find areas with appropriate features and characteristics to accommodate this design.

CNL skipped both steps. It ignored the full range of options for a radioactive waste facility, opting for a landfill-type mound that is suitable only for very low-level waste with short half-lives. And CNL picked a site as close as possible to the Chalk River “Active Area” where there are hundreds of old radioactively-contaminated structures awaiting demolition.

CNL chose its landfill design without assessing the amounts and characteristics of the radioactive wastes in these structures, or in the leaking waste areas at Chalk River where dumping has occurred over the past 70 years. While some of these structures and waste areas are in urgent need of clean-up, only a tiny fraction of the wastes in them could be safely contained and isolated in CNL’s chosen landfill design. Furthermore, the waste fraction that could be landfilled is mixed inseparably with other, unsuitable wastes.

Most of the Chalk River wastes contain radioactive substances such as uranium, radium, thorium and plutonium with very long half-lives. An appropriate waste facility design must isolate these substances from the biosphere for hundreds of thousands of years. CNL’s above-ground mound-type design for the NSDF would deteriorate in a few centuries.

Since hastily making its ill-advised decision in fall 2015, CNL has spent hundreds of millions of taxpayer dollars in an effort to justify that decision. Haste makes waste. If the NSDF is approved, the federal government would waste even more money on a facility that would do essentially nothing to address its eight billion dollar nuclear liability and that would permanently contaminate the Ottawa River.

To Dr. Hendrickson: Does the height of the NSDF base relative to the Ottawa River and the claimed sturdiness of the container not reasonably eliminate the possibility for the waste to reach the Ottawa River within hundreds of years?

There is absolutely no doubt that the NSDF would discharge wastes to the Ottawa River. Although the river would not likely rise up to flood the facility, wastes exposed to water and wind in a 50-year operational phase would move downslope into the river. Storm water ponds would overflow into adjacent wetlands. Extreme weather events would spread contaminants from the waste mound throughout the immediate area, creating unacceptable risks for workers and local residents, and adding to the existing load in the Perch Creek basin. The NSDF design includes a pipeline to discharge partially treated waste during operations directly into Perch Lake, which drains into the Ottawa River.

Following closure the mound would deteriorate. Long-lived radioactive substances such as uranium, radium and plutonium — and non-radioactive substances such as lead, arsenic and mercury — would enter the river for hundreds of thousands of years.

To Dr. Hendrickson: You allege that the Canadian Nuclear Safety Commission is a captured regulator that cannot reasonably be trusted to mediate the environmental stakes in the proposed NSDF. Does CNSC lack history of rejecting proposals because of bias in favour of them, or is the consultative process of CNSC merely effective at mediating design issues or discouraging the worst proposals from ever being applied for in the first place?

The CNSC is not the appropriate body to approve the NSDF. Elected government officials and local Indigenous communities should independently make decisions about the acceptability of this project. The NSDF project is being funded by taxpayer dollars. It would take place on ‘federal’ land (in actuality, unceded Algonquin territory) and would involve the disposal of the federal government’s own waste.

Federal radioactive waste policy says that waste producers and owners are responsible for the facilities required for their wastes. Letting the CNSC make a final decision on the NSDF would represent a complete abdication of responsibility by the Government of Canada. This is not a regulatory matter. This is a decision with significant impacts on future generations and their environment, essentially in perpetuity.

We from the PEN thank both Mrs. Faught and Dr. Hendrickson for their time.