May 5, 2024

Background

The multi-billion dollar radioactive waste cleanup liability at Chalk River Laboratories was described in an Ottawa Citizen article in 2011, Chalk River’s toxic legacy. The waste at Chalk River was produced during eight decades of operation of one of the world’s first nuclear laboratories that was originally set up to produce plutonium for US nuclear weapons. The cleanup cost is estimated at between $8 billion and $16 billion and is expected to take many decades to be completed.

In September 2015, the outgoing Conservative government contracted a multinational private sector consortium comprised of SNC-Lavalin and two US-based multinationals to reduce the radioactive waste cleanup liability quickly and cheaply. The consortium’s proposal, that won it the contract, was to create a giant above-ground landfill for one million tons of radioactive and other hazardous wastes.This giant mound is known as the “Near Surface” Disposal Facility (NSDF) even though it is expected to rise seven stories above the ground. The consortium’s plan includes bringing federal radioactive wastes to Chalk River from Manitoba, Quebec and other sites in Ontario for disposal in the mound. The NSDF received a licesne from Canada’s “nuclear industry captured regulator,” the Canadian Nuclear Safety Commission in January 2024.

The proposed facility is not appropriate for the types of waste that would go into it. The waste is heavily contaminated with post fission nuclear reactor waste and includes many radioactive materials such as plutonium that will remain hazardous and radioactive for thousands of years. Nuclear industry veterans who were in charge of managing the waste before privatization say the facility does not meet international safety standards and that the waste should be stored underground. An International Atomic Energy Agency (IAEA) safety standard says “waste produced by research facilities generally belongs to the ILW [intermediate-level waste] class and even, in some circumstances, to the HLW [high-level waste] class.” (Details)

For the purposes of this article, we are comparing the impacts of the NSDF on the status quo of leaving the wastes where they are at the present time, until state-of-the-art facilities that meet international safety standards can be designed and sited appropriately, well away from the Ottawa River. While awaiting design and siting of proper disposal facilities, existing groundwater treatment facilities at Chalk River Laboratories could be upgraded to fully capture the existing plumes from the leaking waste areas.

Here are ten ways the NSDF will make the radioactive waste cleanup problem at Chalk River worse rather than better:

1. Increasing contamination of the Ottawa River with radioactive and other hazardous substances

Most of the radioactive liquid effluent discharges from Chalk River Laboratories go directly into the Ottawa River.  Discharge points include the Process Outfall, the Sanitary Outfall, storm water outfalls, and the groundwater contaminant plumes from the NRX and NRU reactor facilities.  Radioactivity is also released to the Ottawa River from Perch Creek, which receives tritium, carbon-14, strontium-90, chlorinated solvents, mercury, and other toxic substances from the Liquid Dispersal Area and Waste Management Areas A and B.  

However, construction and operation of the NSDF would increase the quantity of regular ongoing radioactive and other hazardous discharges into the river and increase risks of large discharges during extreme weather events or earthquakes. (See for example: Chalk River Mound (NSDF) would release plutonium to the Ottawa River in “treated effluent”)

The NSDF location could not have been more poorly chosen.

Much of the public concern about the project site revolves around its proximity to the Kichi Sibi, the Ottawa River.  Algonquin peoples have lived on the Kichi Sibi and used it as a source of food and water and a means of transport since time immemorial.  Building a permanent radioactive waste disposal site a kilometer from a drinking water source for millions of Canadians makes no sense whatever.  Spills or accidents during operation of the NSDF would risk its permanent contamination.

The Ottawa River occupies an active fault line.  The NSDF site is underlain by fractured rock, allowing rapid groundwater movement.  After closure of the NSDF, its artificial engineered barriers such as the plastic cover and the plastic bottom liner would disintegrate.  The mound would erode and release its contents to the environment.   Migration of contaminants into the Ottawa River would be inevitable. 

The IAEA safety standard for disposal says that “A host geological formation and/or environment and site has to be identified that provide favourable conditions for the isolation of the waste from the accessible biosphere and the preservation of the engineered barriers (e.g. low groundwater flow rates and a favourable geochemical environment over the long term).” 

If one disregards international safety standards and environmental considerations (as CNL and CNSC appear to have done), one might argue that the NSDF “makes things better” for the current management at the Chalk River Laboratories.  The NSDF would “beautify the campus” — a place to dump the radioactive debris from demolition of over a hundred unused structures at Chalk River, and additional debris shipped from Whiteshell.  Canadian nuclear companies could continue to get rid of their waste cheaply.

But – even if the NSDF were to perform perfectly during its 50-year operational phase – building it so close to the Ottawa River would impose undue burdens on future generations. 

This represents a morally unacceptable approach, and one that is inconsistent with Canada’s international obligations.

2. Burdening future generations with a major remediation challenge

CNL claims that “only low-level waste” would go in the NSDF.  This claim is not backed by evidence.

Nuclear industry veterans – those who were in charge of waste management before the 2015 privatization of CNL — say the proposed NSDF does not meet international safety standards and that long-lived waste (25 of the 30 radionuclides in the NSDF inventory)  must be stored underground.  They say, “The waste acceptance criteria are insufficiently protective for the material… to qualify as low level waste — the radionuclides do not decay to an acceptable level during the time that institutional controls can be relied upon.”

Putting long-lived radioactive waste in a giant mound would make it much more difficult to remediate in the future.  This is not responsible “environmental remediation.” 

Responsible management would involve carefully characterizing, packaging and labelling the waste and storing it in a place where it can be monitored and containers can be repaired as necessary.

3. Discharging waste directly into Perch Lake which drains into the Ottawa River

The IAEA safety standard for disposal emphasizes that the “fundamental safety objective in respect of the disposal of radioactive waste is to contain the waste and to isolate it from the accessible biosphere.”  It’s hard to imagine any design for a disposal facility that would conform less to this objective than the NSDF.

Parts of the NSDF mound would remain uncovered for 50 years, exposing the waste to precipitation and melting snow and ice.  The resulting leachate would need to be pumped uphill to a water treatment plant to remove a portion of its radioactive and hazardous contaminants.

The initial plan was to send leachate from the treatment plant back downhill through an “exfiltration gallery” into one of the adjacent wetlands.  CNL argued that this would “promote the exfiltration of treated water into the local groundwater regime” and compensate for water lost from nearby wetlands when drains were installed under the NSDF itself. 

CNL estimated it would take roughly ten years for contaminants to move through the wetlands into Perch Lake and Perch Creek, and that this would provide some time for shorter-lived radioactive substances such as cobalt-60 and tritium to undergo radioactive decay before emerging in these surface water bodies. 

Later, however, CNL decided that if only an exfiltration gallery were used, at certain times of the year there would be “insufficient infiltration capacity at the exfiltration gallery which could result in overland flow of treated effluent.”  This would cause erosion and rapid contaminant movement.  Therefore, a late addition to the NSDF project was a pipeline that could discharge contaminants directly into Perch Lake (a pipeline to the Ottawa River was also considered).

Water treatment cannot remove tritium, the substance that would contain the second highest amount of radioactivity in the NSDF at closure. CNL assigned a limit of 360,000 Becquerels per liter (Bq/L) for the allowable tritium concentration at the point of discharge of the pipeline,18,000 times the 20 Bq/L standard recommended by the Ontario Drinking Water Advisory Council (but never acted upon because of nuclear industry pressure).   

CNL maintains that these high levels of tritium are not a problem, because Perch Lake is a big lake (45 hectares).  If the tritium were diluted evenly throughout the lake, it would approach the current 7,000 Bq/L Ontario drinking water standard, roughly tripling the concentration in Perch Lake, Perch Creek, and the Ottawa River at the point of discharge of Perch Creek. For the animals that live in and around Perch Lake, the NSDF would make things worse. For people living downstream who swim and fish in the Ottawa River and drink its water, the NSDF would be a source of ongoing anxiety.

4. Blasting away a forested hillside to create the NSDF site will change hydrology and is likely to mobilize contaminants in adjacent wetlands

Construction at the NSDF site would require “slope depressurization”.  The water table is only five centimeters below the surface at the lowest point on the NSDF site.  Horizontal drains would be drilled in the rock mass to lower the water table prior to rock blasting.  

This would greatly alter local hydrology.

The NSDF site is adjacent to wetlands contaminated by past dumping practices.  The possibility that lowering the water table would increase movement of the plumes of radioactive and hazardous substances discharging from the Liquid Dispersal Area and Waste Management Areas A and B was ignored in the CNSC’s Record of Decision. 

Drying out of these wetlands would damage their vegetation cover and speed oxidation of their organic soils, which contain radioactive tritium, carbon-14, and strontium-90.

Subsequent blasting away of the forested hillside to create a more level surface for the NSDF would further alter local hydrology and promote erosion. Higher runoff from the deforested area – including from the access roads to the NSDF — would disturb downslope wetlands and cause an additional increase in the flow of contaminated groundwater into Perch Lake, Perch Creek, and the Ottawa River.

5. Airborne spreading of radioactive dust

Negative impacts of the NSDF would not be limited to nearby portions of the Perch Creek basin. As much as 370,000 cubic meters of contaminated soil found in other parts of the 3,700-hectare Chalk River Laboratories property could be put in the NSDF.  At present, vegetation growth covers the plumes from other leaking waste management areas.  This vegetation cover limits wind and water erosion, dust production, and surface runoff. 

Digging up and exposing this material would subject it to precipitation, winds, and the drying forces of elevated temperatures.  This would create additional contaminant migration.  Higher wind speeds, such as those associated with tornadoes, are increasingly common in the Ottawa Valley.

Loading the contaminated soil in trucks, transporting it to the mound, dumping it, rolling over it with heavy equipment, and leaving it uncovered on the surface of the mound – all these activities would generate dust and allow the spread of radioactive and hazardous substances. 

There is also potential for contaminant spread during the decommissioning, demolition, and transport of parts of unused structures on the Chalk River “campus”, such as the Plutonium Tower and the Plutonium Recovery Laboratory.

Wind speeds at a mound cleared of all vegetation would likely be elevated compared to surrounding areas. 

Well-planned remediation activities are needed at Chalk River.  However, a geological waste management facility in which waste would be put underground would represent a safer alternative to a mound for containment and isolation of remediation waste. This alternative would largely eliminate the problem of dust generation at the disposal facility itself.

6. Exposing workers to Inhalation of radioactive particulates

Worker inhalation of radioactive particulates – especially those containing alpha-emitting radionuclides – would be a major new radiation exposure pathway associated with the NSDF.  The proposed mitigation measures in a “dust management plan” would only partially alleviate this problem, such as “Postponing work activities likely to cause dust if sustained wind speeds are predicted to exceed 40 km/hr, unless it can be shown that the work site is sufficiently protected that wind will not generate unacceptable amounts of dust.” Adding water to reduce dust generation at the NSDF site could turn contaminated soil into a muddy mess and create a major equipment cleaning problem.

Questions include: “What are acceptable amounts of dust?”  “How effective would the dust management measures be?”  “Why do CNL’s models assume near-zero radiation doses to workers from inhalation of radioactive particulate matter and dust?”  The CNSC’s Record of Decision does not address these questions. 

7. Concealing the intermediate-level radioactive waste problem

CNL claims that there is an urgent need to build the NSDF, and it is the “right solution”.  But the Government of Canada — when asked at an IAEA meeting about the impact of delay in building the NSDF, and whether current storage facilities have sufficient capacity for low-level waste — replied that CNL has “plans that would allow it to continue to operate to approximately 2030 without building new storage facilities.”

Focusing on the NSDF as an urgently needed “solution” for so-called “low-level” waste – and falsely characterizing this waste as mops, gloves, shoe covers and overalls — are distractions from the large quantities of intermediate- and high-level waste in shallow burial at Chalk River.  The older Chalk River waste areas contain highly varied, dangerous, long-lived, wastes that are “source terms” for plumes of radioactive and hazardous substances that are discharging into wetlands and streams draining into the Ottawa River.  CNL claims that it will eventually remediate the waste areas and hints that it will transfer their contents to the NSDF, but it seems to be in no hurry to get started – or even to make a proper assessment of their contents to determine if they would conform to the NSDF “waste acceptance criteria”.

Waste Management Area B, one of the oldest areas at Chalk River, remains an active site for waste “storage”, even though the concrete bunkers in the southern portion used for storage of intermediate level solid wastes are sources of contaminant plumes discharging into Perch Creek and the Ottawa River.  The GoCo contract under which the consortium of private companies operate Chalk River requires them to develop a plan for dealing with intermediate-level waste, but there is no publicly available evidence that they have made such a plan.  The IAEA says that intermediate-level waste must be put at least a few tens of meters underground.

This delay in developing an approach for the more dangerous waste at Chalk River allows the continuing spread of the plumes of hazardous and long-lived radioactive waste emanating from Waste Management Area B and other waste sites.

CNL’s only strategy for dealing with intermediate-level waste (ILW) appears to be to reclassify it as low-level waste (LLW) so it can go in the NSDF.  Fully 95% of the volume of the federal government’s ILW in past Canadian government reports to the IAEA is now shown as LLW.  CNL initially stated that “all of the waste” from decommissioning and remediation “is intended to be disposed” in the NSDF. 

CNL no longer claims that the NSDF is a solution for “all of the waste”, but it declines to estimate how much of the federal nuclear liability could be safely disposed of, either in terms of volume or radioactivity, in the NSDF.  This raises suspicions that CNL has no intent of properly characterizing the waste it intends to put in the NSDF. 

The focus on the NSDF as a “solution” for Canada’s nuclear legacy waste diverts attention from the need for a robust plan that encompasses all the federal radioactive waste – a plan that would deal in a more responsible manner with long-lived radionuclides than dumping them in an above-ground mound.

8. Accelerating the import of radioactive waste from other locations

The Chalk River Laboratories on the shore of the Ottawa River north-west of Ottawa is a poor location for storage of radioactive waste because the area is seismically active. The risk of a major earthquake in the Ottawa Valley is high relative to many other places in Canada. (details here)

Many of the initial municipal resolutions opposing the NSDF focused on waste imports.  CNL estimates that 5% of waste to put in the NSDF would come from federal nuclear sites other than Chalk River, and 5% from industry, universities, and hospitals. 

Over 99% of the initial radiation in the NSDF would be in cobalt-60, found in “sealed sources”: devices such as gamma irradiators.  After cobalt-60 decays to the point where these devices no longer kill bacteria or cancer cells, companies such as Nordion and Best Theratronics import the “disused sources” from around the world and ship them to Chalk River for storage. Waste cobalt-60 devices still emit highly dangerous levels of radiation and must be shielded. 

Not all these waste devices were made in Canada.  Companies are not required to track their origins before importing them. 

Another Canadian company, SRB Technologies, imports waste devices such as exit signs that contain tritium.  Most exit signs are imported from the U.S., which prohibits their disposal in municipal landfills (Canada allows this).  Tritium would represent the second highest initial amount of radiation in the NSDF inventory. 

Chalk River is Canada’s only licensed commercial waste storage facility.  The NSDF would represent a convenient way for industry to get rid of its waste, at taxpayers’ expense.

Imports from other federal sites are also a concern.  CNL’s 2019 submission to the CNSC for renewal of the operating licence for the Whiteshell Laboratories in Manitoba anticipates that “a total of approximately 1500 shipments of Low-Level Waste, 500 shipments of Intermediate-Level Wastes and 46 shipments of High-Level Waste (the baskets of irradiated reactor fuel from the Concrete Canister Storage Facility) will be transferred to Chalk River during the completion of the Whiteshell Labs Closure Project.”

Bringing waste to Chalk River from other locations means higher worker and public radiation exposures during waste transport, increased risks of accidents and spills, increased emissions to air and water, and more pollution for future generations to deal with.  Many Ottawa Valley residents are willing to look after the waste already at Chalk River, having benefited from the good jobs there, but don’t want to be the dumping ground for all of Canada’s (or the world’s) radioactive waste.

The City of Ottawa specifically asked for cessation of radioactive waste imports to the Ottawa Valley in April 2021.

9. Destruction of irreplaceable wildlife habitat

After the May/June 2022 CNSC hearing on the NSDF Project , Kebaowek First Nation insisted on being allowed to conduct its own field work at the site chosen by CNL.. 

Even though much of their work had to be done in the fall and winter, what they found was stunning.

Using motion-sensitive cameras, they recorded the presence of three active Black Bear dens, with video footage of bears entering them to hibernate.  Ontario provincial regulations prohibit the destruction of bear dens.

Why would the NSDF site provide such good Black Bear habitat? A 2018 study found that slope is the main predictor of where bears make their dens.  In that study, the likelihood of a site being used increased 6.15% for each 1° increase in slope.  Advantages of denning on steeper slopes relate to safety from disturbance and avoidance of heat loss, with dens on steep slopes having drier and better drained soils that lessen heat loss compared with wetter dens.  Many studies report that bears den primarily in forested habitat types.  A 2005 study of den selection by Grizzly Bears in British Columbia showed that their dens were primarily in mature forest stands.

The NSDF site, with its steep slope; its sandy, well-drained soil that lessens heat loss and is easy for bears to excavate; its healthy, mature forest cover; its lack of human disturbance; and its distance from road traffic – represents irreplaceable Black Bear denning habitat.  Destruction of this habitat would likely have significant negative impacts on the regional Black Bear population in the upper Ottawa Valley.

Kebaowek First Nation documented how rich in biodiversity the NSDF site is overall.  A pack of Eastern (or “Algonquin”) Wolves – a distinct species found only in Canada that is threatened with extinction — was denning nearby and preying on the deer and moose that winter at the NSDF site.  Three endangered bat species preferentially use the NSDF site, with its abundance of old trees that are suitable for maternity roosts and are close to ideal foraging habitat (Perch Lake and surrounding wetlands).  Endangered Blanding’s Turtles, which make long overland migrations before laying their eggs in spring, also use the NSDF site, as do many species of at-risk migratory birds, including Whip-poor-wills, Golden-winged Warblers, and Canada Warblers.

We should all be grateful to the Kebaowek First Nation for doing independent field work.  In its 2016 NSDF Site Selection report, CNL did not record the presence of Black Bears, nor their dens.  Nor was there any mention of the use of the site by Eastern Wolves.  CNL’s final environmental impact statement makes no mention of bear dens, and scant mention of the presence of wolves.

10. Squandering billions of dollars that would be better spent on a state-of-the-art facility that meets international safety standards.

Hundreds of millions of dollars have already been spent on the ill-conceived NSDF and millions more would be spent to build and operate it. This money would be much better spent on designing and siting a state-of-the-art facility, well away from the Ottawa River, that is compliant with IAEA safety standards.

In the short term, waste in leaking sites at Chalk River could be dug up and stored above ground in concrete structures while awaiting a plan for a carefully sited facility well away from the Ottawa River.