Questions about Canada’s seventh report to the Joint Convention ~ letter to IAEA from CCRCA

From: Concerned Citizens of Renfrew County and Area

To: Rafael Mariano Grossi

Director General

International Atomic Energy Agency

Date: May 31, 2021

We thank the IAEA for organizing the September 2019 Integrated Regulatory Review Service (IRRS) Mission to Canada.Recommendation R1 in the report of this Mission is that ““The Government should enhance the existing policy and establish the associated strategy to give effect to the principles stated in the Canadian Radioactive Waste Management Policy Framework.”  

This is a still work in progress, as illustrated by Canada’s Seventh National Report to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management.  As appropriate, we would be grateful if you could forward this note to participants in the 7th review meeting of the Joint Convention.

Article 32 of the Joint Convention says:

2. This report shall also include…  (iv) an inventory of radioactive waste that is subject to this Convention that: (a) is being held in storage at radioactive waste management and nuclear fuel cycle facilities; (b) has been disposed of; or (c) has resulted from past practices. This inventory shall contain a description of the material and other appropriate information available, such as volume or mass, activity and specific radionuclides;

Canada’s 7th report says that data are “not available” (N/A) for activity and specific radionuclides in the Government of Canada’s waste at the Chalk River Laboratories (CRL).  This is where most federal radioactive waste is stored and is Canada’s only facility for commercial radioactive waste storage. CRL is managed by “Canadian Nuclear Laboratories”, a private company owned by a consortium of multinational engineering firms under a 2015 contract with Atomic Energy of Canada Limited (AECL).

Canada’s 7th report omits considerable data shown in Table B-2 (appended below) of AECL’s 2014 Comprehensive Preliminary Decommissioning Plan, as well as additional data listed as “available” but not shown in Table B-2.  

Table B-2 provides activity values of 1040 TBq beta/gamma, 2.1 TBq alpha, 1070 TBq tritium, and ~ 75 TBq unspecified for a portion of the Chalk River wastes.  Data gaps in Table B-2 include CRL’s  oldest Waste Management Area, WMA A, and one of its newest, WMA H, where the Shielded Modular Above-Ground Storage (SMAGS) facilities are found.  Despite the data gaps in Table B-2, the activity and radionuclide data found therein should be included in Table D.8 of Canada’s 7th report.  

Table B-2 also lists additional activity data as being “AVAILABLE” for certain CRL waste areas, including the WMA B circular concrete bunkers, rectangular concrete bunkers, and tile holes; the WMA C extension unlined trenches; the potentially contaminated equipment, materials and drummed liquids in WMA D; and the reprocessing wastes in the Thorium Pit from operation of the 233U extraction facility.  

These data should also be reported pursuant to Article 32 of the Joint Convention.

There are major differences between the waste volume data for CRL in Canada’s 7th report and in Table B-2.  Table B-2 shows a total volume of all waste types of 235,165 m3, with an additional 380,000 m3 of contaminated soils and slags.  These are far higher values than those in Table D.8 of Canada’s 7th report.  It gives a total of only 154,858 m3 of all waste types, and only 156,276 m3 of contaminated soils, at CRL. 

Canada’s 7th report also shows major unexplained changes in the inventory of federal radioactive waste relative to Canada’s 6th national report, The absence of adequate explanations for these changes calls into question the 7th report’s credibility.

Comparing data from Table D.8 (p. 48) in Canada’s 7th report to data in the 6th report (Table D.3, p. 27) for CRL, the reported volume of intermediate-level waste (ILW) decreased by 95% – from 19,648 to 1,050 m3.  

A footnote to Table D.8 says:

“Prior estimates were based on a conservative assumption that all waste stored within a structure that could contain ILW would be categorized as ILW until better characterization data became available. Between 2016 and 2019, retrieval and processing operations were conducted on selected legacy wastes in storage, and records were verified to extrapolate the current volumes.” 

Canadian Nuclear Laboratories (CNL), the operator of CRL, is not listed as a contributor to Canada’s 7th report.  Canada’s 7th report should identify the body that did the “better characterization” of ILW, provide details on how it was done, and specify quantities of ILW that were reclassified as low-level waste (LLW).   More generally, clarification is needed as to how the Government of Canada’s ILW and LLW are differentiated. 

The disappearance of 18,598 m3 of ILW at CRL can only be partly accounted for by a 12,873 m3 increase in LLW (comparing Table D.8 in Canada’s 7th report to Table D.3 in the 6th report).  

This apparent reclassification of federal ILW as LLW has implications for a proposed landfill at CRL, listed in section 3.0 of the 7th report as a “current priority”:

a near surface disposal facility (NSDF) for the disposal of up to 1,000,000 m3 of low-level radioactive waste (LLW) at CRL. Pending regulatory approval, the proposed disposal facility will be constructed, and the forecasted date of operations is 2024. 

Although this proposed “NSDF” facility is termed a “near surface disposal facility” in the 7th report, the final Environmental Impact Statement (EIS) for this facility says (p. 1-5) that it “would resemble a conventional landfill for municipal or industrial refuse, with measures to cover the waste.”

According to SSR-5, Disposal of Radioactive Waste, such a landfill facility would be suitable only for disposal of very low level radioactive waste (VLLW) – waste with low concentrations or quantities of radioactive content.  Plans to put LLW – and possibly ILW reclassified as LLW – in such an above-ground, landfill-type mound are a matter of concern.  Again, clarity is needed on how Canada’s wastes are classified.

Note that Canada’s 7th report does not provide data for wastes considered to be VLLW.

The final EIS indicates that CNL intends to put 134,000 m3 of packaged wastes in this proposed disposal facility (Table 3.3.1-1, p. 3-24). The final EIS (p. 3-23) and the NSDF Project Waste Acceptance Criteria (pages 12 and 24) identify as packages intermodal containers (e.g., 20-foot ISO containers), steel waste boxes (e.g., B-25 boxes), drums (e.g., 205-L drums), shielded waste packages, and disused sources.

These packages could contain a variety of long-lived and high-activity radionuclides, possibly not well characterized, and very likely unsuitable for landfill disposal.  

An NSDF Project Reference Inventory Report notes that there are data gaps “compared to what would be required for disposal assessment” of packaged wastes to be put in the facility.  This report describes assumptions, methods, use of scaling factors, qualitative assessments, etc. used to estimate activities of specific radionuclides in the packaged wastes at CRL.  These estimates do not appear in Canada’s 7th report.

Another major change in Canada’s 7th report relative to the 6th report is the 59% decrease in the reported volume of LLW in the form of “Contaminated soils” at Chalk River – from 382,842 m3 in 2017 (Table D.3) to 156,276 m3 in 2020 (Table D.8).  

No explanation is given for this decrease of 226,566 m3 in the reported volume of contaminated soils. The description in Canada’s 7th report of the sources of these contaminated soils — “Luggers, 205 L-steel drums, B-25 containers in SMAGS, sand trenches and above-ground stockpiles” — is identical to that found in the 6th report.

Canada’s reduced inventory of contaminated soils also has implications for wastes to be put in the proposed landfill.  The April 2017 draft EIS for this facility gave a volume figure of 370,000 m3 for “Soil and Soil‐like Waste” (p. 3-8) – similar to the figures of 380,000 m3 of contaminated soils and slags in WMA F found in Table B-2, and 382,842 m3 in the 6th report.  The final EIS has no figure for contaminated soils to be put into the facility – only a combined figure of 866,000 m3 for all types of non-packaged wastes.  

An explanation for the change in contaminated soil volume at CRL between Canada’s 6th and 7th reports is needed. 

Table D.12 and section 8.1 of Canada’s 7th report indicate that CNL was actively decommissioning various facilities (e.g., the waste water evaporator building, NRX delay tanks, NRX fuel bay,  NRX ancillary buildings, plutonium recovery laboratory, plutonium tower) at Chalk River during the April 1, 2017, to March 31, 2020 reporting period.  However, whereas the 6th report had separate tables for wastes from “normal operations” (Table D.3) and wastes from “decommissioning activities” (Table D.5), the latter table was omitted from Canada’s 7th report. 

An explanation is needed as to why a table describing wastes arising from decommissioning activities has been removed from Canada’s 7th report.

Table D.8 (p.49) in Canada’s 7th report has a row labeled “Decommissioning waste” for CRL.  The dates given for this row are January 1, 2005 to December 31, 2016.  This would seem to indicate that data for decommissioning waste for Chalk River in the 7th report were not updated from the 6th report, which shows the same time period.  

However, the two reports have greatly different volumes – 332 m3 ILW and 16,894 m3 LLW in the 7th report; compared to 125 m3 ILW and 2,876 m3 LLW in the 6th report. 

This inconsistency should be addressed.

Of particular concern is the absence of data on activity and specific radionuclides for the Government of Canada’s decommissioning wastes.  GSR Part 6, Decommissioning of Facilities, states that 

During the preparation and updating of the final decommissioning plan, the extent and type of radioactive material at the facility (e.g. activated and contaminated structures and components) shall be determined by means of a detailed characterization survey and on the basis of records collected during the operational period. (p. 16)

Absence of data on activity and specific radionuclides for federal decommissioning wastes in Canada’s 7th report indicates that final decommissioning plans and detailed characterization surveys may not have been done prior to conduct of decommissioning activities.  This would be problematic given that 

With the implementation of the government-owned contractor-operated (GoCo) model at AECL sites, CNL continues to significantly accelerate decommissioning and remediation activities. (Canada’s 7th report, p. 2)

The data shown in Table D.8 in Canada’s 7th report for the Government of Canada’s Whiteshell Laboratories, currently undergoing accelerated decommissioning, differ substantially from those found in the 6th report.

The category of “Research reactor waste and decommissioned reactor waste” for the Whiteshell Laboratories, included in the 6th report, is missing from the 7th report.  Both LLW and ILW at Whiteshell are now labelled as “Decommissioning waste (January 1, 2005, to December 31, 2016).”  

As with the CRL decommissioning waste, this December 31, 2016 date may be an error.  A correction or further explanation is needed.  

Table D.5 in Canada’s 6th report gave volume and activity data for decommissioning wastes at Whiteshell (22 m3 and 148 TBq ILW, 1598 m3 and 6 TBq LLW); Table D.3 in the 6th report gave volume and activity data (863 m3 and 2,794 TBq ILW, 19,700 m3 and 325 TBq LLW) for Whiteshell operations wastes. 

Canada’s 7th report (Table D.8, p. 51) does not provide separate values for Whiteshell decommissioning and operations wastes – both are combined as “Decommissioning waste”.   Activity data for these wastes are now listed as “Not Available”.  

An explanation as to why data on the activity of the Whiteshell wastes were removed from Canada’s 7th report is needed.  As with the CRL decommissioning wastes, lack of activity data for the Whiteshell decommissioning wastes raises concerns that final decommissioning plans and characterization surveys may not have been done before decommissioning activities were carried out.

With regard to the volume of Whiteshell wastes, Table D.8 (p. 51) in Canada’s 7th report provides a figure of 240 m3 of ILW.  This represents only 27% of the 885 m3 of Whiteshell ILW in the 6th report (adding together the separately reported volumes of decommissioning and operations waste).  The 6th report had a footnote stating that “Volumes for ILW/LLW are based on method of storage and do not necessarily represent the actual breakdown of waste into ILW and LLW”.

Canada’s 6th report listed a total of 21,298 m3 of LLW at Whiteshell, including 19,700 m3 of “operations” LLW (in “above-ground concrete bunkers and trenches”) and 1,598 m3 of “decommissioning” LLW (in “above-ground concrete bunkers”).  In Canada’s 7th report, this total volume decreased by 21% to a value of 16,861 m3 of LLW in “above-ground concrete bunkers”.  

Canada’s 7th report gives no explanation for these considerable decreases in the ILW and LLW inventories at Whiteshell.  One possibility is that decommissioning wastes have already been shipped to Chalk River, even though Canada’s 7th report implies that this would not be done until approval was granted for the proposed CRL landfill:

“For the wastes that are currently on-site, CNL is planning to transport certain LLW and other suitable wastes from Whiteshell to CRL for disposal in the proposed NSDF” (p. 297).

The 7th report should explain the 73% decrease in ILW volume and the 21% decrease in LLW volume at the Whiteshell Laboratories. 

Accurate accounting of volumes and activities for the Whiteshell decommissioning wastes is of particular importance, given that the contract between AECL and the consortium of multinational engineering firms includes a special “target cost” agreement that provides bonuses for decommissioning Whiteshell as quickly as possible.  

With regard to Canada’s method of waste classification, the 6th report says:

A definitive numerical boundary between the various categories of radioactive waste – primarily between LLW and ILW – cannot be provided because activity limitations differ between individual radionuclides and radionuclide groups, and will be dependent on short- and long-term safety-management considerations. For example, a contact dose rate of two millisieverts per hour (mSv/h) has been used in some cases to distinguish between LLW and ILW.

A much different waste classification is found in the 7th report:

LLW contains material with radionuclide content above established clearance levels and exemption quantities, but generally has limited amounts of long-lived activity. For orientation purposes only, a limit of 400 Bq/g on average (and up to 4,000 Bq/g for individual waste packages) for long-lived alpha emitting radionuclides can be considered in the classification process. For long-lived beta and/or gamma emitting radionuclides, such as carbon-14, chlorine-36, nickel-63, zirconium-93, niobium-94, technetium-99 and iodine-129, the allowable average activity concentrations can be considerably higher (up to tens of kBq/g) and can be specific to the site and disposal facility. LLW requires isolation and containment for up to a few hundred years.

A similar classification of LLW is found in the NSDF Project Waste Acceptance Criteria (p. 36).  Both resemble the description of LLW in IAEA General Safety Guide GSG-1, Classification of Radioactive Waste. However, neither the new LLW classification in Canada’s 7th report, nor CNL’s LLW classification for its “NSDF”, would appear to identify wastes suitable for disposal in a landfill-type facility.  

As noted earlier, landfill-type facilities are suitable for disposal only Very Low Level Waste (VLLW) – typically, soil and rubble with low levels of radioactivity and very limited concentrations of longer lived radionuclides.  Past activities at CRL related to extraction of isotopes from irradiated fuels and targets (e.g., the plutonium recovery facility, the plutonium tower, the waste water evaporator, the nitrate plant, the thorium pit, the molybdenum-99 processing facility), have left a legacy of long-lived wastes that almost certainly will require management as ILW.

After AECL contracted a consortium of multinational engineering firms to operate the Government of Canada’s nuclear sites in 2015, Canada’s Parliament greatly increased annual appropriations to AECL for decommissioning and waste management. With this increased funding for accelerated decommissioning, and plans for three new disposal facilities for the Government of Canada’s wastes (the CRL landfill, and entombment of the NPD and WR-1 reactors), clear, transparent,  accurate and up-to-date data on federal radioactive wastes should be a high priority for Canada.

Although Canada’s 7th report claims (p. 189) that “Since the Sixth Review Meeting, significant progress has been made in developing and implementing long-term solutions for L&ILW at AECL sites which will address more than half of Canada’s inventory of these waste types,” this claim is not supported by evidence.  Although the Annex of the report describes CRL waste management areas A, B, C, D, E, F, G, H, and J; the Liquid dispersal area; Acid, chemical and solvent pits; Waste tank farm; Ammonium nitrate decomposition plant; and Thorium nitrate pit; it does not indicate that “long-term solutions” have been developed for radioactive wastes in any of these areas.

In summary, Canada’s 7th report could be revised to 

  • include all available data on activity and specific radionuclides for the Government of Canada’s radioactive wastes stored at CRL and Whiteshell;
  • explain the changes  in data for ILW, LLW, and contaminated soils at CRL  and Whiteshell in the 7th report relative to the 6th report, including information on the “better characterization” of ILW;
  • explain why data for wastes arising from decommissioning activities at Chalk River and Whiteshell are shown as not having been updated since 2017;
  • clarify whether final decommissioning plans and detailed characterization surveys were completed prior to conduct of accelerated decommissioning activities at CRL and Whiteshell;
  • explain why the separate table of wastes arising from decommissioning activities found in the 6th report was removed from the 7th report; 
  • clarify that the proposed “NSDF” at CRL would resemble a municipal landfill; and
  • provide evidence that long-term solutions have been developed for remediation of the CRL waste management  areas.

Addressing these issues would add rigour and credibility to Canada’s 7th report. 

We hope this note can stimulate discussions during the Seventh Review Meeting

Thank you for your attention to this matter.

Best regards,

Ole Hendrickson, Ph.D. (

Researcher, Concerned Citizens of Renfrew County and Area


Table B-2 Summary of Waste Management Areas at CRL and Estimates of Waste Volumes and Radioactivity Content 

Source: Chalk River Laboratories Comprehensive Preliminary Decommissioning Plan, CPDP-508300-PDP-001, Revision 2, March 2014 

AreaPeriod of OperationDescriptionWaste Volume (m3)
Major Activity (1)Notes

Waste Management Area A
Liquid Wastes
Various drummed and bottled liquids emptied into below-grade concrete structures.n.a.33N/AN/ALimited records for drummed and bottled liquids buried prior to 1956
Solid Wastes1946-1955Liquid wastes discharged into trenches in 1953 (4,500 m3), 1954 September (7.2 m3) and 1955 February (50 m3) resulting in contaminated soil. Solid wastes emplaced in unlined trenches and a variety of “special burials”, such as the NRX calandria.21,200Misc. liquids
Mixed FPN/ALimited records for solid wastes buried prior to 1955. Source of a groundwater plume.
Liquid Dispersal Area
Reactor Pit #11953-1998Liquid waste discharged to natural depression between 1953 and 1956 resulting in contaminated soil. Lightly contaminated equipment and suspect soils later used to fill depression.7,100n.a.β/γ α
100 0.1
Estimated disposal of 74 TBq 90Sr plus 100 g (Pu equivalent) of alpha-emitters. Source of a groundwater plume.
Laundry Pit1956-1957Aqueous waste from Decontamination Centre and Laundry discharged to engineered pit resulting in contaminated soil. 4,000n.a.β/γ α0.06 0.0003Small inventory compared with other LDA pits. 
Chemical Pit1956-1995Liquid aqueous waste from site labs and chemical operations discharged to a gravel-filled pit resulting in contaminated soil.17,700n.a.β/γ α  Tritium230 0.4 70Source of a groundwater 90Sr plume. Groundwater from Chemical Pit plume is subject of pump and treat program.
Reactor Pit #21956-2000Lightly contaminated water from Rod Storage Bays, and NRX & NRU operations resulting in contaminated soil.28,200n.a.β/γ α Tritium500 0.5 1,000Source of a groundwater plume.
Waste Management Area B
Sand Trenches1953-1963Solid wastes in unlined trenches covered with sand: Intermediate Level Radioactive Waste (ILW) emplaced prior to 1956 August, only Low Level Waste (LLW) emplaced after 1956 September.~9,000Misc. bottled liquidsMixed LLW and ILW
~75Use discontinued in favour of engineered structures. Limited inventory data. Source of two separate groundwater plumes.
Asphalt-lined trenches
1955-1959Intermediate-level solid wastes, i.e., wastes having external fields >100 mR/h at 30 cm, that were emplaced in asphalt-lined and –capped trenches1,600Misc. bottled liquidsILWN/AEstimated to contain 0.6 TBq of 239Pu.
Rectangular Concrete bunkers1959-1979Low level solid wastes in rectangular concrete bunkers. (Below grade but above the water table)8,500ResidualLLWA
Special burials1955-1973Various materials including the NRU and the second NRX calandrias.914*220*

Estimates are available for individual burials.
Circular concrete bunkers1979 – presentLow level solid wastes. (Below grade but above the water table)

Tile Holes – Nuclear Reactor Fuels1956 – presentReactor fuel high-level wastes in vertical, below-grade facilities.
120n.a.Used FuelAEstimates available for fissile material quantities. Fuel-bearing structures are the subject of a remediation program. Certain HEU fuels are candidates for return to U.S.
Tile Holes – 99Mo wastes1970 -presentHigh-level wastes from 99Mo production200n.a.ILWN/AEstimates available for fissile material quantities.
Tile Holes – other wastes1956 -presentA variety of high level wastes including reactor components.950n.a.ILWN/ACell wastes, reactor components, Rod Bay wastes.
Waste Management Area C
C Extension1993-2006Low level solid waste (external fields <100 mR/h at 30 cm) in unlined trenches. Higher proportion of drummed waste than Area C.9,000ResidualLLWACharacterization data available for some radionuclide inventories. Source of groundwater plume.
Sand Trenches1963-2006Low-level solid waste (external fields <100 mR/h at 30 cm) in unlined trenches. Total area is approx. 4.5 ha; impermeable cover installed on entire area in 2013. Waste is half from CRL and half from across Canada including NPD.100,000Drummed & bottled liquids
LLWN/ALimited characterization data for inventories. Source of a groundwater plume.
AreaPeriod of OperationDescriptionWaste Volume (m3)
Major Activity (1)Notes

Waste Management Area D1976 – presentFenced gravel compound used for aboveground storage of potentially contaminated equipment, materials and drummed liquids. Not a burial site. A Mixed Waste Facility used for temporary storage, sampling and bulking is also in WMA D.760 (LLW)
LLWASmall numbers of transient drums may be stored at any particular time. The drummed liquids (lightly contaminated aqueous wastes and waste oils) are stored in marine containers.
Acid, Chemical and Solvent Pits1982-1987Small fenced compound containing three small pits, which as the names imply were used for different non-active liquid wastes and very small quantities of solid wastes.Acid: minorAcid: 11.2 Chem.: 2.7 Sol.:  5.3

Acid: Hydrochloric, Sulphuric, Nitric, Chromic acids, potassium carbonate powder, citric powder and acid batteries. Chemical: Scintillation fluids, Alconox and other cleaning agents, ammonia, alkylating agents, others. Solvent: Mixed solvents, oils, scintillation solutions, ammonia, varsol, acetone, others.
Waste Management Area E1977-1984Used for disposition of lightly contaminated & suspect bulk materials (building debris and soils) from the CRL Controlled Area.N/An.a.Suspect slightly contaminatedN/AThe volume of suspect contaminated materials is believed to be a small fraction of the total volume of materials stored here.
Tank Farm1961-1968Tank Farm with intermediate to high-level wastes in tanks in concrete vaults with leak-detection systems  Intermediate – T-40F (secondary concrete containment), T-40E (empty), T-40D (concrete pad) High level – T-283A, B, C, D (all with secondary concrete containment)n.a.68β/γ α
150Monitoring & surveillance confirms containment of these wastes and the facility includes emergency transfer lines.
Waste Management Area F1976-1979Contaminated soils and slags from Port Hope, Albion Hills, Mono Mills and Ottawa stored above the water table in sand valley. Unsuccessful clay cover.~380,000zeroRadium0.5Approx. 515 GBq Total 226Ra,  4 – 13 Mg Arsenic,  80 Mg U.
Waste Management Area G1989-presentNPD spent fuel dry storage facility – aboveground concrete canisters.
4,921 (bundles)
zeroIrrad. UAComplete inventory data available. Monitoring & surveillance confirms containment within structures.
Waste Management Area H (MAGS and SMAGS)2001-presentPrefabricated metal and concrete storage buildings with capability of storing 865 m3and approximately 4,000 m3 each, respectively, of compacted LLW in B-1000 compactor boxes, 45-gallon drums (204 liters), wooden crates, boxes and B-25 containers. Bulk materials and NRX stack pieces are also stored in WMA H.9,000n.aMixed FPN/AAll waste will be removed by Operations prior to turnover to Decommissioning. Some residual contamination may be present as a result of operational activities.
WMA J Bulk Material Landfill (BML)2010–presentEngineered landfill used for the storage of sewage sludge for the CRL sewage treatment plant1,600n.a.Mixed FP
Leachate is transferred to the sewage treatment plant.
Nitrate Plant1953-1954Discharges of mixed fission products in salt solutions to limed pit following a process accident. Decontaminating solutions also released. Contaminated rubble from Building 233 demolition.
3,400n.a.β/γ60Estimated 60 TBq of β/γ activity (35% 90Sr) in liquid releases – small α inventories. Plant demolished and buried on-site, no data for solid waste inventories.
.Thorium Pit1955-1960Reprocessing wastes from operation of the 233U extraction facility.
150n.a.Nat. Th, 233U and mixed FPAApproximate total of 45 m3 reprocessing solution discharged in separate dispersals to crib containing ammonium carbonate (~4,000 kg of nat. Th, 27 g 233U).
Above Ground Buildings and Structures in Waste Management Areas
Buildings and Structures in WMAs1953 – presentVarious buildings/gatehousesN/An.a.N/AN/A

(1) Activity at time of emplacement – not corrected for decay N/A = no quantitative data available n.a. = not applicable A = quantitative data available 

CCRCA Comments on Canada’s radioactive waste policy review

Concerned Citizens call for an independent waste authority; no import, reprocessing, or abandonment; transparency and traceability.

Updated July 14, 2021

Concerned Citizens of Renfrew County and Area 

The Honourable Seamus O’Regan 

Minister of Natural Resources 

House of Commons Ottawa, Ontario K1A 0A6 

Via e-mail:

May 31, 2021

Re: Canada’s Radioactive Waste Policy Review

Dear Minister O’Regan:

Concerned Citizens of Renfrew County and Area (CCRCA) is an incorporated, non-profit organization that has been working for the clean-up and prevention of radioactive pollution from the nuclear industry in the Ottawa Valley for 40+ years. Our current focus is nuclear waste, in particular the proposed giant mound for one million cubic meters of radioactive waste at the federally owned Chalk River Laboratories, and the proposed “entombment” of the federal Nuclear Power Demonstration reactor at Rolphton, Ontario.

A modernized radioactive waste policy should state Canada’s intent to fully meet its obligations pursuant to international legal instruments developed by the International Atomic Energy Agency (IAEA), specifically the Convention on Nuclear Safety and the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management.  

The modernized policy should explicitly state Canada’s intent to meet its obligations under Article 4 (Implementing Measures) and Article 5 (Reporting) of the Convention on Nuclear Safety, and under Article 12 (Existing Facilities and Past Practices) and Article 32 (Reporting) of the Joint Convention

With regard to Article 32, Canada should require that all owners and generators of radioactive waste maintain full inventories of waste volume or mass, activity and specific radionuclides.  Where only estimates of volume or mass, activity and specific radionuclides are available, the methods and assumptions used in preparing these radioactive waste inventory estimates should be described in sufficient detail that an independent body can verify the estimates.  

Radioactive waste inventories should be updated regularly and be made publicly available on an ongoing (e.g., annual) basis. 

A national body – a national radioactive waste authority – should be established with a legislated mandate to maintain records, knowledge and memory of radioactive waste.  The authority should be charged with maintaining a national radioactive waste inventory..  It should have a capacity and legal mandate to inspect nuclear facilities and independently verify inventory information provided by waste generators and owners.  The national authority should be independent of other bodies — whether government or private sector — that regulate, utilize or promote nuclear energy.

The radioactive waste authority should ensure traceability of radioactive waste, including any transfers of waste for processing, storage, or disposal.  Responsibility for traceability and maintenance of records, knowledge and memory related to radioactive waste should not rest with Canada’s nuclear regulator.  

When any proposal is submitted to Canada’s nuclear regulator for a new nuclear facility or activity (such as decommissioning) that would generate, store, dispose of, or transfer wastes, the proponent should also be required to submit estimates of the volume or mass, activity and specific radionuclides in the radioactive wastes associated with that facility or activity to Canada’s national radioactive waste authority.  

In the case of any proposed new nuclear reactors – such as “small modular reactors” – this should include a full accounting of activation products created by neutron bombardment of reactor components, fission products and transuranics in the fuel, and wastes associated with fuel fabrication, processing, and reprocessing.  

The proponent of a new nuclear facility or activity (such as decommissioning) should also be required to submit a detailed management plan for wastes arising to the national authority.   Acceptance of the waste estimates and the management plan by Canada’s national radioactive waste authority should be required prior to approval of any new facility or activity by Canada’s nuclear regulator.

Canada’s modernized radioactive waste policy should state explicitly that the protection of human health by avoiding radiological exposure shall be given the highest priority in radioactive waste management, and cannot be compromised by economic considerations of “cost-effectiveness”.  It should state explicitly that radioactive waste generation shall be minimized.  It should state explicitly that every effort shall be made to minimize the waste burden imposed on future generations.   

Canada’s modernized policy should state explicitly that radioactive waste shall be contained and isolated from the biosphere.

Canada’s modernized policy should state explicitly that the public shall have full access to information about radioactive waste.  

Canada’s modernized policy should state explicitly the principle of justification as described in the IAEA Fundamental Safety Principles:  that “facilities and activities that give rise to radiation risks must yield an overall benefit,” and that the benefit must “outweigh the radiation risks to which they give rise.”

The national radioactive waste authority should be given the mandate to ensure that generators and owners of radioactive waste adhere to these principles.

At present, Canada’s 143-word “Radioactive Waste Policy Framework” (RWPF) – in calling only for “waste disposal plans” – ignores the internationally agreed pre-disposal requirements for radioactive waste found in the IAEA General Safety Requirements (GSR) Part 5, Predisposal Management of Radioactive Waste.  Requirements of GSR Part 5 that are not addressed in the RWPF include 2 on “National policy and strategy on radioactive waste management,” 8 on “Radioactive waste generation and control,” 9 on “Characterization and classification of radioactive waste,” 11 on “Storage of radioactive waste”, and 20 on “Shutdown and decommissioning of facilities.” 

Canada is currently on a slippery slope to radioactive waste abandonment, with risks of undocumented waste transfers and illegal dumping, exposing future generations to unknown radiological hazards.  The emphasis on disposal in the RWPF creates an “out of sight, out of mind” mentality.  

Much of Canada’s current radioactive waste legacy has been created by the Government of Canada itself.  The federal government has failed to acknowledge its own responsibilities as waste generator and owner.  It remains an active promoter of nuclear energy under a Nuclear Energy Act that gives the Minister of Natural Resources powers to “utilize, cause to be utilized and prepare for the utilization of nuclear energy.”   

The RWPF, in stating the “polluter pays” principle, is fundamentally at odds with Government of Canada assertions that nuclear energy is “clean”.  

A national radioactive waste authority that is accountable to elected public officials but independent of government or industry bodies that promote or utilize nuclear energy is an essential complement to a modernized radioactive waste policy.

As owner of Canada’s only licensed commercial radioactive waste storage facility at the Chalk River Laboratories (CRL), the federal government has assumed ownership of significant inventories of industrial, hospital, and university wastes. 

Some industrial wastes stored at CRL are imports from foreign countries.  Canadian companies are major manufacturers of cobalt-60 “sealed sources”.  Canada’s Seventh National Report to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management says “Canada remains a global leader in the production and export of Category 1 cobalt-60 radioactive sealed sources, supplying approximately 95 percent of the global demand.”

Article 28 of the Joint Convention says 

A Contracting Party shall allow for re-entry into its territory of disused sealed sources if, in the framework of its national law, it has accepted that they be returned to a manufacturer qualified to receive and possess the disused sealed sources.

Canada has not to our knowledge accepted the return of sealed sources in the framework of its national law; nonetheless, Canadian companies such as Nordion, Best Theratronics, and SRB Technologies are doing a brisk trade in waste imports in the form of disused sealed sources and expired self-luminous tritium devices..  

These companies do not necessarily limit their imports to devices of their own manufacture.  Imported radioactive wastes are being sent to CRL, where they become the property of the Government of Canada.

Canada’s modernized radioactive waste policy should ban radioactive waste imports.

A national radioactive waste authority should have the mandate to track the inventory of private sector waste transferred to Government of Canada ownership.  The authority should collect payments that are adequate for the long-term management of transferred wastes.  It should assume the management of the fund currently overseen by the federal crown corporation Atomic Energy of Canada Limited. It should be responsible for developing appropriate management strategies for federal nuclear wastes.  

Responsibility for management of wastes owned by the Government of Canada should not be in the hands of a body with a mandate to promote and utilize nuclear energy 

With regard to Canada’s obligations under Article 12 (Existing Facilities and Past Practices) of the Joint Convention, the national radioactive waste authority should be responsible for remediation of areas contaminated by past practices.  Canada’s obligations in this regard are described in requirement 49 (“Responsibilities for remediation of areas with residual radioactive material”) of the IAEA GSR Part 3, Radiation Protection and Safety of Radiation Sources.  

Areas with “residual radioactive material” include those contaminated by uranium mines and processing facilities formerly owned by the Government of Canada (including those in the Port Hope area) as well as federally-owned nuclear facilities (such as the Chalk River Laboratories).   

GSR Part 3 requirements for areas contaminated by past practices include a remedial action plan, appropriate record keeping, a strategy for managing wastes arising, and public involvement in planning, implementation and verification of remedial actions.  

These requirements should be met by a national radioactive waste authority – a body that does not have a mandate to promote and utilize nuclear energy.  

The federal crown corporation Atomic Energy of Canada Limited is not the appropriate body to meet these requirements.

Of particular concern to our group is that Atomic Energy of Canada Limited is allowing private companies under contract to transfer radioactive and other hazardous wastes from federal nuclear facilities in Manitoba, southern Ontario, and Quebec to the Chalk River Laboratories.  This is being done under an unapproved “Integrated Waste Strategy”.  There is no long-term management plan for the transferred wastes, nor is there a remedial action plan for the Chalk River Laboratories.

We submit that Atomic Energy of Canada Limited is acting in a non-transparent and unaccountable manner and showing disrespect for the Government of Canada’s obligations to Indigenous rights holders and to the public at large.

With regard to lack of transparency of activities related to radioactive waste transport, processing and storage, Atomic Energy of Canada Limited is allowing Canadian Nuclear Laboratories, a private company owned by a consortium of multinational engineering firms, to make its own determinations regarding a range of activities at the Chalk River Laboratories that may have significant adverse environmental impacts but are not being adequately disclosed or reviewed under the Impact Assessment Act.  

During the period November 2020 to March 2021, numerous “section 82” waste-related
projects were posted on the Impact Assessment Registry with essentially no information other than the following headings:

81139 Canadian Nuclear Laboratories Cask Facility Project
81177 Canadian Nuclear Laboratories Intermediate Level Waste Storage Area
81178 Canadian Nuclear Laboratories Bulk Storage Laydown Area
81209 Canadian Nuclear Laboratories Material Pit Expansion Project
81375 Canadian Nuclear Laboratories Building Demolition Project
81389 Canadian Nuclear Laboratories Waste Management Area Modification Project
81403 Canadian Nuclear Laboratories Heel Storage Removal Project
81424 Canadian Nuclear Laboratories Effluent Monitoring Stations Upgrade Project
81443 Canadian Nuclear Laboratories Multi-Purpose Waste Handling Facility

For each of these projects, a “Notice of Determination” has now been issued.  All have been similar to the one for project 81443:

Canadian Nuclear Laboratories, on behalf of Atomic Energy of Canada (AECL) has determined that the proposedMulti-Purpose Waste Handling Facility Project at AECL’s Chalk River site is not likely to cause significant adverse environmental effects… Therefore, Canadian Nuclear Laboratories, on behalf of Atomic Energy of Canada may carry out the project, exercise any power, perform any duty or function, or provide financial assistance to enable the project to be carried out in whole or in part.

Beginning on April 1, 2021, our group sent repeated e-mails asking for information on these projects to the contact person listed in the Impact Assessment Registry: Patrick Quinn, Director, Corporate Communications, Canadian Nuclear Laboratories.  Mr. Quinn has sent e-mails in reply promising to provide information, but no information has been forthcoming to date.  In the meantime, the 30-day deadlines for public comments on all these projects have passed.  

We question the acceptability of a process by which Canadian Nuclear Laboratories, a privately-owned company, makes its own determinations that its projects, carried out on federal land, are not likely to cause significant adverse environmental effects.  

We brought this to the attention of Nana Kwamena, Ph.D., Director, Environmental Assessment Division, Canadian Nuclear Safety Commission, on April 8th.  She replied:

The projects listed below are activities that CNL is authorized to conduct under its current licence.  No additional authorization or assessment is required by CNSC.  Therefore, I recommend reaching out directly to CNL to receive additional information about these projects.

We also brought this to the attention of Mr. David McGovern, President of the Impact Assessment Agency of Canada (IAAC), We asked “Is Canadian Nuclear Laboratories a federal authority for the purposes of section 81 of the [Impact Assessment] Act?  If so, how should we proceed in obtaining information that will allow us to submit comments on this company’s projects?” 

On April 16th the IAAC replied that AECL “is the federal authority responsible for making the environmental effects determination required by section 82 of the Impact Assessment Act (IAA) as it is a Crown corporation,” and AECL “indicated that they work with the Canadian Nuclear Laboratories (CNL) in implementing their obligations.”  IAAC added that “we have been assured that AECL or CNL will be in touch with you shortly to provide answers to any questions you may have on these projects” However, neither AECL nor CNL provided details on the projects prior to the date of this submission. 

Lack of transparency and lack of opportunities for public input related to radioactive waste-related activities on federal lands is unacceptable.  Full transparency must be a foundational principle of Canada’s radioactive waste policy.  It is particularly troubling that the Government of Canada itself is violating this principle.

We note that the Government of Canada has provided $50.5 million to Moltex Energy Canada Inc., to develop a process to “recycle” – extract plutonium from — used nuclear fuel.  Moltex has announced that it is partnering with Canadian Nuclear Laboratories to “design, build and optimize the test apparatus used to process the used fuel.”  

Waste and nuclear weapons proliferation issues related to reprocessing used fuel to extract plutonium for use in small modular reactors have received considerable media attention in recent days.  Our group is very concerned that research on this process will be carried out at Chalk River Laboratories, very likely without transparency. 

Canada’s radioactive waste policy should prohibit reprocessing of nuclear fuel waste.

Problems identified in this submission — non-transparency, lack of full waste accounting, undocumented waste transport, lack of waste traceability, waste imports from foreign countries, the slippery slope toward waste abandonment, nuclear weapons proliferation risks of plutonium reprocessing, lack of remedial action plans for areas contaminated through past practices, avoidance of environmental assessment – should be addressed in a modernized policy, and through creation of a national radioactive waste authority, independent and arms-length from any government department, crown corporation or agency whose mandate includes the utilization or promotion of nuclear energy.

Five good reasons to support the City of Ottawa’s call for an assessment of Ottawa Valley radioactive disposal projects

On April 14, 2021 the City of Ottawa council passed a resolution of concern about the Chalk River and Rolphton radioactive waste disposal projects, joining more than 140 municipalities, the Anishinabek Nation and Iroquois Caucus, and the Assembly of First Nations.

Prior to being passed by the full Ottawa City Council, the resolution was studied and passed unanimously by the City’s environment committee after an eight hour meeting on March 30, 2021 which can be viewed here. Among other things, the resolution calls on the Minister of Environment and Climate Change to initiate a regional assessment of Ottawa Valley radioactive disposal projects under the Impact Assessment Act of 2019.  (See Mayor Jim Watson’s letter to Minister Wilkinson here.)

Here are five reasons to support the City of Ottawa’s call to Minister Jonathan Wilkinson:

1. Radioactive waste in the Ottawa Valley is a very large and complex problem. It makes up the lion’s share of federally-owned “legacy” radioactive wastes, an $8 billion liability for the citizens of Canada.

The radioactive wastes currently on site at the Chalk River Laboratories, upstream of Ottawa-Gatineau, make up most of the Government of Canada’s eight billion dollar nuclear liability. This federal radioactive cleanup liability exceeds the sum total of 2000 other federal environmental liabilities . As Canada’s largest and most complex federal environmental liability, this challenge is worthy of the best and most thorough assessment available under the new Impact Assessment Act.

2. Proposed Ottawa Valley radioactive disposal projects are substandard, highly controversial, and would NOT address many parts of the needed cleanup.

The proposed Chalk River Mound (“Near Surface Disposal Facility”) and Rolphton Reactor Tomb (“NPD Closure Project”) are low budget, inadequate proposals meant to quickly and cheaply reduce Canada’s federal nuclear liabilities. The two projects were proposed five years ago by a consortium of private companies contracted by the Harper government in 2015. The proposals ignore safety standards of the International Atomic Energy Agency and have been found wanting in thousands of critical comments submitted by Indigenous communities, municipalities, former AECL scientists and managers, NGOs, citizens’ groups and individuals.

The projects are expected to leak radioactive contaminants into the Ottawa River for millennia, according to Environmental Impact Statements produced by the proponent. The giant Chalk River Mound is expected to disintegrate as part of a process of “normal evolution” according to the proponent’s “performance assessment” study.

The vast majority of radioactive wastes in the Ottawa Valley would NOT be addressed by these two projects.

3. Environmental assessments of the giant mound and reactor tomb are being badly fumbled.

The environmental assessments of the NSDF and NPD closure projects were initiated in 2016 by the Canadian Nuclear Safety Commission. Numerous problems with the CNSC’s handling of the EAs were identified in Environmental Petition 413 to the Auditor General of Canada in January 2018. Problems have continued to arise including lack of opportunity for public input, lack of transparency, and lack of firm deadlines for completion of the assessments. The EAs have been ongoing for far longer than is normal or reasonable for such assessments.

The Canadian Nuclear Safety Commission has been identified as a captured regulator that promotes the projects it is supposed to regulate. The CNSC is therefore not an ideal agency to be overseeing assessments of radioactive disposal projects in the Ottawa Valley.

4. The complex challenge of nuclear waste in the Ottawa Valley is NOT addressed by the assessments that are currently ongoing.

Again, the eight billion dollar federal radioactive cleanup liability is the biggest and most expensive federal environmental challenge by far. The vast majority of the wastes comprising this liability are already in the Ottawa Valley at the Chalk River Laboratories. For an indication of the complexity of this challenge at Chalk River see the Ottawa Citizen article by Ian McLeod, Chalk River’s Toxic Legacy. Radioactive wastes not addressed by the mound and the tomb proposals include the three reactor cores dumped in the sand at Chalk River (including one from the 1952 NRX partial meltdown), the highly radioactive solidified medical isotope production wastes (including weapons-grade uranium-235), the tanks of intermediate- and high-activity liquid wastes at the ‘Waste Tank Farm”, the spent fuel from the NRX, NRU and NPD reactors, and the NRX and NRU reactors themselves.

The private sector consortium running Canadian Nuclear Laboratories plans to consolidate the federal governments’s radioactive waste from across Canada in the Ottawa Valley and is already shipping radioactive wastes from Manitoba, Quebec and elsewhere in Ontario to Chalk River. There are serious concerns about consolidating federal nuclear wastes at the Chalk River site, in a seismically-active area, beside a major river (The Kitchissippi/ Ottawa) that provides drinking water for millions of Canadians. Serious concerns about long term storage of radioactive waste in close proximity to water bodies are noted in the Joint Declaration of the Anishinabek Nation Iroquois Caucus on transport and abandonment of radioactive waste. Consolidation of federal government nuclear wastes in the Ottawa Valley and First Nations’ guidance to store waste away from major water bodies are not addressed by the current NSDF and NPD environmental assessments.

CCRCA recently learned that the consortium is going ahead with radioactive waste projects such as a new cask facility to receive shipments of highly-radioactive spent fuel from the Whiteshell (MB) and Gentilly-1 (QC) reactors, and a new intermediate-level waste storage facility that would likely contain dangerous commercial wastes. The consortium is making determinations about the significance of the impacts of these projects on behalf of Atomic Energy of Canada (AECL) with no transparency or public input. Assessment of the risks and implications of these projects should be done through a transparent public process. AECL, which has been reduced from thousands of employees to around 40, appears to be shirking its role of overseeing its contract with the consortium. 

The cumulative impacts of all wastes and all current and future projects need to be considered together. A regional assessment could do this.

5. A regional assessment of radioactive waste disposal in the Ottawa Valley could address all problems noted above.

A regional assessment could:

  • make existing baseline data publicly accessible and produce a broad-based analysis of the problem
  • look at cumulative impacts of all the current and proposed management strategies for Ottawa Valley radioactive wastes, and transport of wastes from Manitoba, southern Ontario and Quebec to Chalk River.
  • address leaking waste management areas at the Chalk River Labs, radioactive waste imports to the Ottawa Valley and the potential creation of new wastes associated with the proposed new “small modular” reactor research and development
  • incorporate Indigenous knowledge and priorities
  • look at the big picture including the need to protect drinking water, property values and tourism and provide secure long-term employment opportunities for Ottawa Valley communities.
  • provide assurance to the federal government and other levels of government that the largest federal environmental cleanup liability is being properly addressed.

To support the City of Ottawa’s call, please consider writing to the Minister of Environment and Climate Change Canada  For your reference, Mayor Jim Watson’s letter to Minister Wilkinson is available for download here.

Letters should be sent to The Honourable Jonathan Wilkinson <>

with cc to: OttawaValley-ValleeOutaouais (IAAC/AEIC) <> Please be sure to state that you letter is Re: Canadian Impact Assessment Registry reference number 81624, “Potential regional assessment of radioactive waste disposal in the Ottawa Valley”

and: your member of parliament. Please forward a copy of your letter to us at <>

The Minister is required to respond to Ottawa’s request by July 31, 2021, so send your letters as soon as possible. But don’t hesitate to send them after July 31st too, as this issue is not going away any time soon.

Debunking myths about the Chalk River Mound (aka “NSDF”)

The Chalk River Mound or “near surface disposal facility” is a proposed giant above ground landfill for one million tons of radioactive waste on the property of Canadian Nuclear Labs, less than one kilometre from the Ottawa River upstream of Ottawa-Gatineau and Montreal. We debunk below two of the most misleading myths about the proposed facility. Please contact us if you need more references for the material presented below, or browse our list of all posts for more information.

Myth # 1: It’s only “low level waste”

“Low level” in the context of radioactive waste does not mean “low hazard”

This is a really big mistake that almost everyone makes. “Low level” simply means the wastes can be handled by nuclear industry workers without the use of lead shielding because the wastes give off relatively low levels of gamma radiation. But they can and do contain high levels of other types of radiation such as “alpha” and “beta.”  “Low level” radioactive waste can remain hazardous for hundreds of thousands of years and includes some of the most toxic radioactive poisons known such as plutonium.

No “Intermediate waste” in the NSDF is a red herring.
Neither “Low level” OR “Intermediate level” radioactive wastes are supposed to be disposed of in above-ground engineered mounds (landfills) according to the International Atomic Energy Agency. That is because both categories are dangerous and pose risks to all life on earth for the duration of their radiological hazard, which is hundreds of thousands of years for BOTH CATEGORIES of waste.  The main thing that distinguishes “Low level” from “intermediate level” radioactive waste is that “low level” can be handled without shielding or robots because its risks come from inhalation or ingestion. “Intermediate level” waste on the other hand gives off strong gamma radiation and therefore requires lead shielding and/or remote handling.

Much of the legacy waste at the Chalk River site is a poorly characterized or uncharacterized MIXTURE of “low” and “intermediate” level wastes.
The dividing lines between the categories are blurry. There are many different definitions around the world. Canada’s definitions are inferior to those in other countries. The wastes are not all sitting around in nice neat packages labelled “low level” and “intermediate level”. It would be the work of decades to properly categorize, package and label all the legacy wastes, and arguably, this should be done before choosing technologies for managing the wastes. We are in touch with a former engineer at AECL who was in charge of waste characterization for decades and worked as a consultant for the IAEA. He says the knowledge level of legacy wastes at Chalk River was and likely still is “abysmal”.

The proponent is playing games with Waste Acceptance Criteria to enable maximum disposal of legacy wastes in the NSDF
Definitions are being finagled to enable claims that “only” low-level wastes would go in the facility.  Canada’s nuclear regulator, the Canadian Nuclear Safety Commission, allows proponents to make up their own definitions of waste classes.  The NSDF proponent defines wastes with long-lived beta/gamma activity as high as ten thousand radioactive disintegrations per second per gram of waste (Bq/g) as “low level”.  Finland puts any waste with activity greater than one hundred Bq/g in an underground facility, 65-90 meters deep in crystalline rock.5.

The proponent’s contract with Atomic Energy of Canada states that it will dispose of ALL wastes quickly and cheaply.
The main objective of the GoCo contract was to reduce Canada’s legacy radioactive waste liabilities. The ONLY strategies being advanced by the consortium are the above ground engineered mound (landfill) and in-situ burial of reactors on the Ottawa and Winnipeg rivers.  Thus, the contract provides a strong incentive for the consortium to dispose of uncharacterized legacy wastes in the NSDF since it’s the only project on the table.

Myth #2: It’s a “sound project from an engineering point of view.”

The engineered containment mound is expected to disintegrate within a few hundred years and the contents flow out of the mound into the surrounding wetlands that drain into the Ottawa River. The NSDF draft environmental impact statement includes 25 occurrences of the phrase “liner and cover failure as a result of normal evolution” and three occurrences of the phrase “inevitable failure of the cover.”  The “bathtub scenario” is mentioned 30 times in the draft EIS. It is projected to occur in the year 2400 when the cover fails, water enters the mound and overflows, and takes contaminants into Perch Creek and the Ottawa River. The Performance Assessment for the NSDF includes a graphic illustration of the bathtub scenario, a table listing quantities of radionuclides flowing out of the mound into the Ottawa River, and a pie chart showing estimated doses of various radionuclides to an infant downstream in Pembroke. Given the expected eventual disintegration of the mound and migration of its contents into the Ottawa River, it would seem to be inappropriate to refer to the project as “a sound proposal from an engineering point of view.” 

The image below is a simulation of the “bathtub effect” from the Radio Canada Decouverte documentary “Chalk River Heritage.”

Updated list of First Nations and Municipal Resolutions against the CNL’s current plans for nuclear waste dumps

May 27, 2021

Assembly of First Nations resolution is here:

Example resolution in English:

Montreal Municipal Council’s unanimous resolution (press release and full resolution):

How would the “Near Surface” Disposal Facility leak? Let us count some of the ways

 REVISED and UPDATED, February 23, 2021

by Dr. Ole Hendrickson, PhD

Canadian Nuclear Laboratories (CNL) – run by a consortium of profit-making multinational  companies – is proposing to build a“Near Surface Disposal Facility” for a  million cubic meters of radioactive waste at its Chalk River facility along the Ottawa  River. CNL’s final environmental impact statement (EIS) describes several ways that contents  of the proposed “engineered containment mound” of radioactive waste could leak into the Ottawa River. 

During operation… 

1. Wastes being added to the mound would be exposed to the elements. 

Rain and melting snow would leach radioactive contents down through the mound. Different  radioactive elements would leach at different rates depending on how strongly they were  bound to the wastes. Radioactively contaminated leachate would be collected in a system of  pipes and pumped uphill to a water treatment plant. Some but not all radioactive contaminants  would be removed prior to releasing the treated leachate into adjacent wetlands (for part of the year) or directly into Perch Lake, which drains into the Ottawa River via Perch Creek. Table 3.4.2-2 on page 3-58 of the final EIS shows levels of different radionuclides in leachate that would be discharged from the water treatment plant. 

2. Tritium as radioactive water would leach in very large amounts from the  mound.

Tritium – a radioactive form of hydrogen with a half-life of 12.3 years – is readily taken up by living organisms and incorporated in body tissues. When tritium decays it emits  “beta radiation” damaging to DNA and other cell constituents. Tritium is part of the water  molecule and cannot be removed by water treatment. The EIS estimates that the tritium in a liter of leachate would emit 140 thousand beta particles per second.  After passing through Perch Lake and Perch Creek, water containing roughly 7 thousand beta particles per liter per second (the current Ontario drinking water standard) would be released into the Ottawa  River, be incorporated in fish and other aquatic life, and enter downstream drinking water supplies. Large amounts of tritium would also be released from the mound and Perch Lake as water vapour. 

3. Other toxic substances such as PCBs leaching from the mound would be only partially removed by water treatment.

Table 3.4.2-3  on pages 3-59 and 3-6 of the EIS indicate that leachate from the mound would include a very wide range of  non-radioactive toxic compounds such as arsenic, mercury, lead, chloroform, ethylene dibromide, PCBs  and dioxin. Measurable amounts would be released to the environment. 

4. Heavy storm events could erode the mound’s surface and wash toxic  substances into low areas.

The EIS proposes an elaborate system of contact water ponds, non-contact water ponds, surface water management ponds, drainage ditches, and culverts.  Highly contaminated water washing off active dumping areas would flow into a contact pond and be pumped to the water treatment plant. Water washing off “inactive” areas (but contaminated by dust from active dumping areas) would flow into non-contact water ponds, be pumped to a perimeter ditch and three storm-water management ponds.  These ponds would discharge to adjacent wetlands that are already contaminated by existing nearby leaking radioactive waste areas.

5. The capacity of storm-water ponds would be exceeded during extreme  rainfall events or snowmelts.

The EIS (page 3-76) says that “when the probable maximum precipitation flow will exceed the surface water management ponds attenuation capacity,” adjacent emergency outlet structures “will be able to convey this flow.”

6. Clearing 34 hectares of mature forest and discharging waste water would  impact wetlands.

The existing forest recharges adjacent wetlands. Loss of the forest’s infiltration  and recharge capacity would tend to dry out these wetlands and expose their radioactive contents  (such as tritium, strontium-90 and carbon-14) to erosion. The EIS notes (page 5-278) that waste water discharge to adjacent wetlands and Perch Lake “may cause changes to water levels, flows, and channel and bank stability, and scouring of the wetland, affecting water quality at downstream locations.”

7. Other possible ways the facility might leak during operations

(not described  in detail in the EIS) include pump failures during extreme storm events with loss of electrical power,  improper installation of the base liners, puncture of the base liners by heavy or sharp materials, melting  of liners by radioactively hot materials, and blockage of the leachate collection system. 

After closure… 

1. Wastes in the mound would be re-exposed to the elements when the top  cover fails.

After waste dumping ended the leachate collection system and water treatment plant  would be shut down, and a top cover placed over the wastes. The EIS acknowledges that the top cover would inevitably fail with “normal evolution” through forces such as erosion, extreme storms,  burrowing animals, root penetration, etc.  It proposes the “conversion of a largely undisturbed, mature forested area to a permanently fenced, turf-grass habitat that is highly modified (i.e., mown, fertilized and maintained as tree-free to avoid the disruption of roots to the cover structure)” (p, 5-509).

2. Failure of the top cover while the more protected base liners remain intact  would initiate a “bathtub scenario”.

Rain and melting snow would again leach the  radioactive wastes, but the leachate collection and pumping system would no longer be operational.  Contaminated leachate would be trapped by the bottom liner and accumulate in the space between the  mound and the surrounding berm. Leachate levels would rise and spill over along the low point of the  berm.  A different scenario involves failure of the bottom liner, releasing leachate into groundwater.

3. Radioactive wastes would flow directly into Perch Creek and the Ottawa  River less than 1 kilometer away, essentially forever.

Long-lived radioactive elements  such as plutonium and uranium, exposed to wind and water erosion, would flow into the river for  thousands to millions of years. Table 5.2.3-8 on page 5-155 of the draft EIS estimated that, under the bathtub scenario, plutonium (Pu)  isotopes (Pu-239 and Pu-240) would exit the dump at 21.4 million and 32.4 million Becquerels per year.  Eventual failure of the bottom liners would also allow radionuclides to move through groundwater,. These details were removed from the final EIS, but it is clear that the Ottawa River would be permanently contaminated by radioactive waste, and countless  generations of people drinking its water would be exposed to increased cancer risks.

How Do I Know if I Have a Leaky Gut? | The Wholesome Heart

What would go into the Chalk River Mound? (Ottawa River radioactive waste dump)

December 2020

Canadian taxpayers are paying a consortium (Canadian National Energy Alliance) contracted by the federal government in 2015, billions of dollars to reduce Canada’s $16 billion nuclear liabilities quickly and cheaply. The consortium is proposing to construct a giant mound for one million tons of radioactive waste beside the Ottawa River upstream of Ottawa-Gatineau. The proposed dumpsite is partially surrounded by wetlands that drain into the Ottawa River less than one kilometre away. 

There is considerable secrecy about what would go into the mound; the information that follows has been  derived from the proponent’s final environmental impact statement (EIS) (December 2020) which lists a partial inventory of radionuclides that would go into the gigantic five-to-seven story radioactive mound (aka the “NSDF”). The EIS and supporting documents also contain inventories of non-radioactive hazardous materials that would go into the dump.

Here is what the consortium says it is planning to put into the Chalk River mound (according to the final EIS and supporting documents)

1)  Long-lived radioactive materials

Twenty-five out of the 30 radionuclides listed in Table 3.3.1-2: NSDF Reference Inventory and Licensed Inventory are long-lived, with half-lives ranging from four centuries to more than four billion years.

To take just one example, the man-made radionuclide, Neptunium-237, has a half-life of 2 million years such that, after 2 million years have elapsed, half of this radioactive substance will be present, together with its radioactive decay products such as Uranium-233. At the time of closure of the mound, the neptunium-237 will be giving off 17 million radioactive disintegrations each second, second after second.

The mound would contain up to 80 tonnes of Uranium and 6.6 tonnes of thorium-232.

2) Four isotopes of plutonium, one of the most deadly radioactive materials known, if inhaled or ingested.

John Gofman MD, PhD, a Manhattan Project scientist and former director of biomedical research at the DOE’s Lawrence Livermore Laboratory, stated that even one-millionth of a gram of plutonium inhaled into the lung, will cause lung cancer within 20 years. Sir Brian Flowers, author of the UK Royal Commission Report on Nuclear Energy and the Environment, wrote that a few thousands of a gram, inhaled into the lungs, will cause death within a few years because of massive fibrosis of the lungs, and that a few millionths of a gram will cause lung cancer with almost 100% certainty.

The four isotopes of plutonium listed in the NSDF reference inventory are Plutonium-239, Plutonium-240, Plutonium-241 and Plutonium-242. According to Table 3.3.1-2 NSDF Reference Inventory and Licensed Inventory from the EIS, The two isotopes 239 and 240 combined will have an activity of 51 billion Bq when they are emplaced in the dump. This means that they will be giving off 51 billion radioactive disintegrations each second, second after second. These plutonium isotopes could constitute a significant hazard to workers during emplacement of plutonium wastes and plutonium contaminated debris in the mound.

3) Fissionable materials 

Fissionable materials can be used to make nuclear weapons.

The mound would contain “special fissionable materials” listed in this table extracted from an EIS supporting document, Waste Acceptance Criteria, Version 4, (November 2020)

4) Large quantities of Cobalt-60 

The CNL inventory includes a very large quantity of cobalt-60 (91 quadrillion Becquerels), contained in waste cobalt-60 irradiating devices. Cobalt-60 when concentrated in irradiators gives off so much strong gamma radiation that lead shielding must be used by workers who handle them in order to avoid dangerous radiation exposures. The International Atomic Energy Agency considers high-activity cobalt-60 irradiators to be “intermediate-level waste” and specifies that they must be stored underground. Addition of high-activity cobalt-60 irradiators means that hundreds of tons of lead shielding would be disposed of in the mound.

5) Very Large quantities of tritium

The mound would contain 890 trillion becquerels of tritium, a radioactive form of hydrogen. Tritium readily combines with oxygen to form radioactive water. It moves readily through the environment and easily enters all cells of the human body where it can cause damage to cell structures including genetic material such as DNA and RNA. For more on the hazards of tritium see the Tritium Primer on the TAP website:

Because it is part of the water molecule, removal of tritium from water is very difficult and expensive. There are no plans to remove tritium from the mound leachate. Instead the consortium plans to pipe the contaminated water directly into Perch Lake which drains into the Ottawa River.

6) Carbon-14

The mound would contain close to two trillion becquerels of Carbon-14, an internal emitter that is hazardous in similar ways to tritium. Carbon is a key element in all organic molecules. When it is inhaled or ingested it can become incorporated into organic molecules and cellular components including genetic material.

7) Many other man-made radionuclides 

Radionuclides such as caesium-137, strontium-90, radium, technetium, nickel-59, americium-243 are listed in the partial inventory of materials that would go into the dump. See the partial inventory here:

8) Non-radioactive hazardous materials

Hazardous materials destined for the dump include asbestos, PCBs, dioxins, mercury, up to 13 tonnes of arsenic and hundreds of tonnes of lead. (Reference)

9) Large quantities of valuable metals that could attract scavengers

According the the final EIS, the mound would contain 33 tonnes of aluminum, 3,520 tonnes of copper, and 10,000 tonnes of iron. It is well known that scavenging of materials  occurs after closure of facilities such as the Chalk River mound. Scavengers would be exposed to high radiation doses as they sought to extract these valuable materials from the dump.

10) Organic Materials

80,339 tonnes of wood and other organic material are destined for the mound. These materials would decompose and cause slumping in the mound, therefore potentially compromising the integrity of the cap.


Most of the radioactive and hazardous material would get into the air and water, some sooner, some later.

Some would get into ground and surface water during creation of the mound, such as tritium which is very mobile and cannot be removed by the proposed water treatment plant. Others would get into the air, during construction and could be breathed by workers. Some materials would leach slowly into groundwater. Still others would be released when the mounds deteriorates over time and eventually disintegrates several hundreds of years into the future. For details on the expected disintegration of the mound in a process described as “normal evolution” see this post:


The mound would actually get more radioactive over time

See the submission entitled “A Heap of Trouble” by Dr. Gordon Edwards, president of the Canadian Coalition for Nuclear Responsibility for a chilling description of this process. Here is a quote from the submission:

The Near Surface Disposal Facility (NSDF) project is presented not as a temporary, interim
storage facility but as a permanent repository that will ultimately be abandoned. We are
dealing with a potentially infinite time horizon. The proponent seeks approval not just for a
few decades, but forever. Such permission has never before been granted for post-fission
radioactive wastes in Canada, nor should it be granted. Long-lived radioactive waste
should not be abandoned, especially not on the surface beside a major body of water.

The facility will remain a significant hazard for in excess of 100,000 years.

This point was raised by Dr. J.R. Walker, a retired AECL radioactive waste expert in his submission on the draft environmental impact statement. You can read his full submission here:

“There is no safe level of exposure to any man-made radioactive material.

“There is no safe level of exposure to any man-made radioactive material. All discharges, no matter how small,  into our air and water can cause cancer and many other diseases as well as genetic damage and birth defects.”

~ Dr. Eric Notebaert, Canadian Association of Physicians for the Environment.

This dump would not not meet international safety standards for radioactive waste management. Details

Groups oppose plans to abandon defunct nuclear reactors and radioactive waste ~

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Ole HendricksonFebruary 3, 2021ENVIRONMENT

Signs indicating the presence of radioactive waste. Image credit: Dan Meyers/Unsplash

The Canadian Nuclear Safety Commission (CNSC) has just given a green light to the preferred industry solution for disposal of nuclear reactors — entomb and abandon them in place, also known as “in-situ decommissioning.” This paves the way for the introduction of a new generation of “small modular” nuclear reactors or SMRs.

SMRs bring many challenges, including safety of untested designs, nuclear weapons proliferation risks, high costs, disposal of radioactive waste, and public acceptance. Groups concerned about nuclear safety are objecting to plans in the works to abandon these nuclear reactors and the radioactive waste they produce once they are shut down.

Over 100 Indigenous and civil society groups have signed a public statement opposing SMR funding, noting that the federal government currently has no detailed policy or strategy for what to do with radioactive waste. Many of these groups are also participating in a federal radioactive waste policy review launched in November 2020.

The Assembly of First Nations passed resolution 62/2018 demanding that the nuclear industry abandon plans for SMRs and that the federal government cease funding them. It calls for free, prior and informed consent “to ensure that no storage or disposal of hazardous materials shall take place in First Nations lands and territories.”

SMR waste includes not only reactor fuel but also the reactors themselves.

An SMR emits no radiation before start-up (other than from uranium fuel) and could easily be transported at that stage. But during reactor operation, metal and concrete components absorb neutrons from the splitting of uranium atoms — and in the process, transform into radioactive waste. Removing an SMR after shut-down would be difficult and costly, and comes with the need to shield workers and the public from its radioactivity.

Abandoning nuclear reactors on site has been in the works for some time. CNSC helped draft a 2014 nuclear industry standard with in-situ decommissioning as an option and then included it in a July 2019 draft regulatory document.

However, when the International Atomic Energy Agency (IAEA) released a peer-reviewed report on Canada’s nuclear safety framework last February, it said in-situ decommissioning is “not consistent” with IAEA safety standards.

The IAEA suggested that CNSC “consider revising its current and planned requirements in the area of decommissioning to align with the IAEA guidance that entombment is not considered an acceptable strategy for planned decommissioning of existing [nuclear power plants] and future nuclear facilities.” It also noted that CNSC is reviewing license applications for in-situ decommissioning of shut-down federal reactors in Ontario and Manitoba, and encouraged Canada “to request an international peer review of the proposed strategy” for legacy reactors.

But CNSC continued to pursue this strategy. Clever language in a June 2020 document appeared to rule out on-site reactor disposal, but left the door open where removal is not “practicable”:

“In-situ decommissioning shall not be considered a reasonable decommissioning option for planned decommissioning of existing nuclear power plants or for future nuclear facilities in situations where removal is possible and practicable.”

At public meeting last June, CNSC Commissioner Sandor Demeter asked: “why are future facilities in this sentence when in fact we should be designing them so that in-situ decommissioning is not the option?” Former CNSC staff member Karine Glenn replied that “leaving some small parts of a structure behind…especially if you are in a very, very remote area, may be something that could be considered.” 

Glenn is now with the industry-run Nuclear Waste Management Organization, tasked with leading the development of a radioactive waste management strategy for Canada.

Commissioners decided to approve the regulatory document, but with added text to clarify where in-situ decommissioning would be acceptable. They asked for additional text on “legacy sites” and “research reactors,” stating that “[t]he Commission need not see this added text if it aligns with the oral submissions staff made in the public meeting.”

But no new clarifying text was added to the final version of the document published on January 29, 2021. It enables abandonment of SMRs — by retaining the reference to future nuclear facilities — and of “research and demonstration facilities, locations or sites dating back to the birth of nuclear technologies in Canada for which decommissioning was not planned as part of the design.”

The CNSC seems willing to ignore international safety standards — and a decision of its own commission — to accommodate nuclear industry proponents of SMRs and allow radioactive waste to be abandoned in place.

Meanwhile, the federal government has assigned the nuclear industry itself — via the Nuclear Waste Management Organization — the task of developing a radioactive waste strategy for Canada. Barring public outcry, that strategy will be abandonment.

Ole Hendrickson is a retired forest ecologist and a founding member of the Ottawa River Institute, a non-profit charitable organization based in the Ottawa Valley.