April 14, 2022 (Updated May 13, 2022)

IAEA Safety Guide SSG-29, Appendix 1, Siting of Near Surface Disposal Facilities, says siting is a “fundamentally important activity in the disposal of radioactive waste.” (Ref: https://www-pub.iaea.org/MTCD/publications/PDF/Pub1637_web.pdf, p. 83)

SSG-29 says the first two stages in the siting process are a “conceptual and planning stage,” during which “projected waste volumes and activities should be quantified,” and an “area survey stage,” involving “regional mapping or investigation.”   

The NSDF facility type and site were selected without quantifying volumes and activities of federal wastes awaiting disposal, and without a regional investigation, thus skipping the first two stages identified in the IAEA Safety Guide.

Proximity to contaminated structures being demolished at the Chalk River Laboratories — not safety or environmental protection — appears to have been the priority is choosing the site of the NSDF. No serious consideration was given to sites other than those on AECL’s 3700-ha Chalk River property,

Alternative sites should be sought to avoid rapid discharge of radioactive and hazardous substances to a major water body and to avoid placing wastes in an area with a high water table (Ref: CMD 22-H7, Section 3.2, Design Options Evaluation). 

Flat, sandy portions of the 30,770-ha Department of National Defence Garrison Petawawa property, adjacent to the Chalk River Laboratories, would accommodate a larger, less expensive, and safer in-ground concrete vault facility.  Vegetation was removed from extensive portions of this property to create a parachute training zone for the Canadian Airborne Regiment, which was disbanded in 1995.

A regional investigation of crown land for geological formations suitable for a shallow rock cavern facility should also be conducted.

IAEA Safety Requirement SSR-5, Disposal of Radioactive Waste, indicates that an in-ground concrete vault or a shallow rock cavern could contain a wider range of waste types than an above ground, landfill-type facility such as the NSDF. (Ref: https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1449_web.pdf)

The southern portion of the site chosen for the NSDF is underlain by a feature categorized in 1994 as a ““high-probability” fracture zone,” ten meters wide and over a kilometer long – a potential groundwater flow pathway with “permeability values several orders of magnitude greater than bulk rock mass.” (Ref: https://www.iaac-aeic.gc.ca/050/evaluations/document/139596, p.5-109).This feature should have eliminated the proposed site from further consideration.

Original site selection criteria announced by the proponent would have excluded any site with more than a 10% slope. This criterion was changed to 25% to allow CNL’s desired site (Ref: Near Surface Disposal Facility Site Selection Report 232-10300-TN-001 Revision 2. Oct. 2016).  .

Site selection criteria were also supposed to exclude known or proposed critical habitats for species listed under the Federal Species at Risk Act (SARA) or by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).”  However, construction of the NSDF would destroy 30 hectares of mature and semi-mature forest that provides high-quality maternity roosting habitat for three endangered bat species (Little Brown Myotis, Northern Myotis and Tri-colored Bat) and nesting habitat for six at-risk bird species (Canada Warbler, Golden-winged Warbler, Wood Thrush, Eastern Wood Pewee, Whip-poor-will, Wood Thrush).  It would also have adverse impacts on at-risk aquatic species such as the Blanding’s Turtle.

The proposed NSDF site is on a hillside, over fractured rock, with a high water table, surrounded on three sides by wetlands that drain into Perch Lake 50 metres from the base of the hill. Perch Creek flows from Perch Lake into the Ottawa River, one kilometre away.  The entire Chalk River Laboratories property — with its proximity to the Ottawa River, high groundwater table, uneven terrain, and fractured bedrock — is a very poor location for permanent radioactive waste disposal.  The NSDF would destroy habitat for many at-risk species.  Volumes and activities of federal wastes were not quantified prior to selection of a landfill-type disposal facility, so there is no certainty that the NSDF could safely  accommodate a significant portion of these wastes.

This is why concerned citizens say this is the “Wrong Plan” in the “Wrong Place”.