Letter from Dr. Ole Hendrickson, Concerned Citizens of Renfrew County and Area, to the editor of the Aylmer Bulletin, June 27, 2018

While it is true that near surface disposal facilities are recognized by the International Atomic Energy Agency (IAEA) as a preferred way of managing low-level radioactive waste, CNL’s proposal is for an above-ground mound, not a near surface disposal facility. This was conceded by CNL official Jim Buckley at a July 2017 meeting in Fort William (Pontiac). Mr Quinn’s use of the misleading term “NSDF” to suggest that CNL’s mound proposal is proven technology is troubling.

Pat Quinn (June 20 letter) also misleadingly calls the proposed NSDF facility “watertight”.  Wastes would be exposed to rain and snow, leaching radioactive contaminants from the mound and necessitating long-term operation of a complex and expensive water treatment facility that at best would only remove a portion of the contaminants.  Radioactive tritium would routinely be discharged to adjacent wetlands. The proposed location of the mound, a kilometre from the Ottawa River, makes this extremely problematic.

Not all the wastes that CNL wants to put in the mound would be “low-level”, as Mr Quinn claims. The IAEA classifies waste with significant quantities of long-lived radioisotopes as “intermediate-level”.  These are found in large amounts at Chalk River — and CNL is bringing in more from the WR-1 reactor at Manitoba’s Whiteshell Laboratories.  CNL’s intent, stated in the environmental impact statement, is to put all these wastes in the mound.

The formal environmental assessment process is well behind schedule. CNL requested more time to respond to hundreds of critical technical comments. While Mr Quinn says members of the public may participate in this process, there may be no further opportunities to do so for more than a year.

The NSDF project is wasting taxpayer dollars and delaying action to deal with the federal government’s 70-year legacy of nuclear waste. The project should be abandoned in favour of a geological repository that can isolate the waste from the biosphere and drinking water sources – the IAEA’s preferred option for managing long-lived radioactive waste.

Ole Hendrickson
Concerned Citizens of Renfrew County and Area

Dr. Hendrickson’s letter was written in response to the following letter from Pat Quinn of CNL published in the Aylmer Bulletin on June 20, 2018.

Canadian Nuclear Laboratories responds(This letter is in response to Colin Chisdale’s letter on CNL’s proposed Near Surface Disposal Facility (NSDF) at Chalk River in the Bulletin d’Aylmer (June 6), I invite Colin to contact me by email at communications@cnl.ca .)

There are misconceptions about the proposed NSDF, so I want to be clear that this facility is designed to protect the environment, not harm it. CNL employees care about the area and the Ottawa River, we are local residents and have a shared interest in responsibly addressing waste at the Chalk River Laboratories site. The NSDF will allow us to clean up and isolate historic, low-level contamination that is currently at the site, and dispose of the waste in a watertight enclosure that has been designed to withstand sabotage, earthquakes and flooding. These facilities are recognized internationally as a safe and appropriate way to dispose of low-level waste, and are being used successfully in Canada and the United States.

For two years CNL has engaged with the public about the NSDF project.  We have hosted many public meetings throughout Ontario and Quebec, including  a recent town hall meeting in Gatineau, hosted by MP for Hull-Aylmer, Greg Fergus. This is in addition to public information sessions, meetings, discussions, project orientations and site visits with elected officials, media, members of the public, members of the industry and non-governmental organizations. At each of these engagements we have openly discussed the project and have responded to requests for information. These events will continue, and I’d encourage Mr. Chisdale to stay tuned for future sessions and on the project’s progress.

This project is subject to a federal government-led, and very public, environmental assessment process. In order to proceed CNL requires an environmental assessment decision and authorization from the Canadian Nuclear Safety Commission. Members of the public are welcome to participate in this assessment, and are encouraged to raise any concerns they have through this formal review process.

Pat Quinn, Corporate Communications
Canadian Nuclear Laboratories
Ottawa

Ottawa, April 23, 2018—Five First Nations and 39 Canadian environmental and citizen groups today are calling on the International Atomic Energy Agency (IAEA) to investigate radioactive waste abandonment plans in Canada. They charge that Canada is “grossly deficient” in failing to formulate stringent policies for managing radioactive waste other than irradiated nuclear fuel.

In a letter to the IAEA Director General, the groups say that Canada is failing to meet its commitments under the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. Five First Nations chiefs are delivering this same message at UN Headquarters in New York.

“Canada has a policy vacuum when it comes to managing its most voluminous radioactive waste, which is not irradiated nuclear fuel,” said Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility. “This waste contains long-lived radionuclides like plutonium, and Canada is irresponsibly planning to abandon them at insecure sites beside major water bodies – sites chosen for convenience rather than for long-term safety.”

The letter to the IAEA points out that Canada’s classification of nuclear waste allows highly dangerous radionuclides like plutonium to be classified as “low level” and not isolated from the biosphere for 240,000 years as is needful.

The letter also notes that three current proposals for abandoning the federal government’s radioactive wastes are “completely out of alignment with IAEA guidance.” The Canadian Nuclear Safety Commission (CNSC) is currently assessing proposals for:

• An above-ground landfill at Chalk River, Ontario, beside the Ottawa River, for the permanent storage of 1 million cubic metres of radioactive waste  including significant amounts of long-lived alpha and beta/gamma emitters;
• Entombment of the radioactive remains of the NPD nuclear power reactor 100 metres from the Ottawa River at Rolphton, Ontario; and
• Entombment of the radioactive remains of the Whiteshell-1 nuclear reactor beside the Winnipeg River in Manitoba.

The letter informs the IAEA that the CNSC has dismissed warnings from scientific experts, including ex-AECL staff, about the three proposals, and charges that the CNSC has given “incomplete and misleading information” to the Joint Convention.

The letter is signed, among others, by the Anishinabek Nation and four other First Nations, as well as the Ontario Clean Air Alliance, Friends of the Earth Canada, Nature Québec, Sierra Club of Canada, Eau Secours!, Greenpeace Canada, the Canadian Environmental Law Association, le Ralliement contre la pollution radioactive, the Canadian Association of Physicians for the Environment, and the Canadian Coalition for Nuclear Responsibility.

Today’s announcement in Ottawa, followed by a rally on Parliament Hill, coincides with a special event taking place at the 17th Session of the United Nations Permanent Forum on Indigenous Issues in New York City. This afternoon, Grand Chief Patrick Madahbee of the Anishinabek Nation and four Chiefs of the Mohawk Nation attending the UN event will cite the letter to the IAEA and will ask the UN to determine whether Canada’s radioactive waste plans are in violation of the UN Declaration on the Rights of Indigenous Peoples, which calls for “free, prior and informed consent” when toxic materials are stored on indigenous lands.

WEBCAST: “Radioactive Waste and Canada’s First Nations” will take place April 23 at 1:15 PM at the UN Permanent Forum on Indigenous Issues in New York and will be webcast live on the United Nations web site:   http://webtv.un.org/

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MEDIA CONTACTS:

Resources:

Chalk River Nuclear Waste Dump:  https://concernedcitizens.net/chalk-river-mound/

NPD reactor entombment and other news:  https://concernedcitizens.net/news/

Fact sheet on disregard of IAEA standards

Ten Things Canadians need to know about the Chalk River Radioactive Mega-dump

Ten MORE things Canadians should know about the Chalk River radioactive mega-dump

Nine quick facts about the NPD reactor “entombment”

For immediate release 

Chalk River consortium gets 10-year licence

Nuclear regulator confirms its reputation as a rubber stamp organization

Decision paves the way for a giant radioactive dump at Chalk River, a new generation of subsidized reactors and growing stocks of toxic long-lived radioactive waste that Canadian taxpayers will be on the hook for 

(Ottawa/Montreal, 4 April 2018)   In a clear attempt to avoid public scrutiny, just before the Easter weekend the CNSC gave a consortium of multinational corporations based in the U.S., U.K. and Canada, an unprecedented 10-year license to run the Chalk River Laboratories. The licence gives the consortium free rein to advance its nuclear business at the federally-owned facility, located on the Ottawa River 200 km upstream from the nation’s capital, using billions of dollars of taxpayers’ money.

The new license sets the stage for SNC Lavalin and its consortium partners to build and test a new generation of small nuclear reactors at Chalk River, and to create a giant radioactive dump on the surface that would leach radioactive waste into the Ottawa River, a primary source of drinking water for the residents of Ottawa, Gatineau, Laval, Montreal and other populations downstream.

Canada’s Auditor General has noted that SNC Lavalin and other members of the consortium operating Chalk River received at least $866 million in federal money for contractual expenses in the 2016–2017 fiscal year alone. The federal allocation for fiscal year 2017-2018 was also close to a billion dollars.

In 2013 SNC Lavalin was banned from bidding on any international engineering projects funded by the World Bank for 10 years, because of fraudulent practices. That same year, CH2M, another consortium member, was convicted of criminal fraud-related charges in the USA. SNC Lavalin also faces criminal charges for multimillion dollar bribes in connection with the building of the Montreal Superhospital.

The questionable past activities of some of these corporations, the unprecedented licence duration, the elimination of vitally important licence conditions, the billions of dollars in federal subsidies, and the inevitable exposure of millions of Canadians to radioactive pollutants were among the concerns raised by First Nations, citizens’ groups and independent experts at a three-day January 2018 public hearing.

Citizens’ groups charge that the CNSC completely disregarded thorough and well-documented concerns and recommendations on the licence proposal presented by dozens of intervenors, including former Chalk River scientists, at the January hearings. This confirms critics’ views that Canada is in urgent need of a credible, responsible nuclear authority that puts protection of health and the environment ahead of the convenience of the nuclear industry. CNSC shows all the signs and symptoms of a “captured regulator”.

The Chalk River licence, signed by CNSC President Michael Binder on the 39^th anniversary of the Three Mile Island nuclear disaster, eliminates numerous safety compliance criteria that were previously included in the licence to govern operations at the Chalk River facility. The previous 17-month Chalk River licence had 2020 words and was accompanied by a 257-page “Handbook”, with licence compliance criteria “written in mandatory language”.  The new licence has 590 words and its Handbook is only 61 pages long.  Prepared by CNSC staff, the new Handbook replaces most of the previous explicit compliance criteria with references to standards that have been prepared by the nuclear industry.

“There is an urgent need for responsible, credible, public interest-driven management of Canada’s nuclear industry and its ever-growing waste problem,” says Dr. Ole Hendrickson of the Concerned Citizens of Renfrew County and Area. “In particular, there is a policy vacuum at the federal level when it comes to the long-term management of highly toxic post-fission radioactive wastes, other than nuclear fuel wastes.”

The Government of Canada carries an eight billion dollar liability on its balance sheet for the waste generated by past operations at Chalk River and other federal nuclear sites. The Trudeau government, far from showing leadership in addressing this waste problem, recently launched a campaign to champion a new generation of nuclear reactors. It plans to promote nuclear power as “clean” and “NICE” (Nuclear Innovation – Clean Energy) at a May 22-23 Clean Energy Ministerial meeting in Scandinavia, without public consultation or parliamentary debate.

Incredibly, the licence indicates that no financial guarantee is required from the multinational consortium for possible damages arising from its operations. It states that the federal government, as ultimate owner of the Chalk River Laboratories and its assets, is responsible for any resulting liabilities.

“The cozy relationship between the nuclear industry, the CNSC, and the political class has been hidden from the public for too long,” says Dr. Gordon Edwards, President of the Canadian Coalition for Nuclear Responsibility (CCNR).  The CCNR and other citizens’ groups are calling for reform of nuclear governance, including (1) widespread public hearings to establish guiding principles for long-term nuclear waste management; (2) suspension of existing plans to abandon nuclear wastes beside major water bodies; (3) removal of the CNSC from playing a decisional role in environmental assessments, and (4) a thorough review of Canada’s Nuclear Safety and Control Act.

In the 17-year history of the CNSC, the Commissioners have never once refused to grant a licence requested by the nuclear industry.

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Media contacts:

Dr. Gordon Edwards, 514-489-5118

Canadian Coalition for Nuclear Responsibility

Dr. Ole Hendrickson, 613-234-0578,

Concerned Citizens of Renfrew County and Area

Background information:

Fact Sheet

Eleven key concerns ignored by CNSC in approval of 10-year license for Chalk River

Hearing transcripts and interventions: http://nuclearsafety.gc.ca/eng/the-commission/hearings/documents_browse/results.cfm?dt=2018-01-24

Record of Decision: 

https://tinyurl.com/CRL-record-of-decision-2018

(Ottawa, Ontario, March 22, 2018) An environmental scientist and a health expert say that dumping of tritium-contaminated water into the Ottawa River from a defunct nuclear reactor in Rolphton, Ontario is a risk to humans and other species, and that the practice is part of a systemic problem with the regulation of the nuclear industry in Canada.

The multinational consortium responsible for the dumping, Canadian Nuclear Laboratories, has defended its actions, saying that the concentration of tritium it has dumped into the Ottawa River is 10,000 times below the discharge limit in its federal license.

Tritium is a radioactive form of hydrogen that is released in very large quantities from Canadian nuclear reactors. A small amount is also produced naturally in the Earth’s upper atmosphere. Tritium combines with oxygen to form radioactive water molecules that travel rapidly through the human body right into cell nuclei, where tritium can be incorporated into genetic material. Once there, it acts as a ticking time bomb that will eventually decay, giving off a beta particle that can cause severe damage on the molecular level.

The risks of exposure to tritium have been greatly underestimated by the nuclear industry in Canada, according to Dr. Éric Notebaert, a physician and board member for Canadian Association of Physicians for the Environment. “Each and every release of tritium increases risks of cancer, birth defects in offspring and genetic mutations in humans who drink the contaminated water or breathe the contaminated air,” Notebaert said, adding: “There is no safe level of exposure to tritium or any other manmade radioactive element.”

According to Dr. Ole Hendrickson, environmental scientist and researcher for the Concerned Citizens of Renfrew County and Area, discharge limits for radioactive substances in Canada do not protect the public from exposure to man-made radioactive materials that are routinely released from nuclear facilities. These discharge limits, known in the industry as “Derived Release Limits” or DRLs, are calculated by the facilities themselves, using voluntary guidelines, and are based on many assumptions about how the emissions will be absorbed by humans. The release limits do not take into account humans being exposed to multiple radioactive pollutants and to cumulative emissions from more than one source of pollution.

“The nuclear industry has been hiding behind DRLs for years. The limits are set very high so that actual releases look low in comparison. It is time that the industry was called out on these absurd limits that allow very high levels of contamination to be characterized as low, confusing the public and decision-makers in the process,” Hendrickson stated.

Hendrickson calculates that the tritium release limit for the Rolphton reactor — upstream from Ottawa —  is so high that, if the facility released the permitted amount, the Ottawa River would be contaminated with tritium at a level 8,000 times higher than the natural background level. It would also be more than twice the Ontario drinking water standard of 7,000 Becquerels/litre — a standard that the Ontario Drinking Water Advisory Council recommended in 2009 should be reduced to 20 Becquerels per litre.

“A one-litre bottle of water from the Ottawa River would contain 17,000 Bq of tritium, meaning that it would be giving off 17,000 radioactive disintegrations from tritium every second, second after second,” said Hendrickson. “This gives a whole new meaning to the term ‘sparkling water.’”

Hendrickson cites other examples that he says illustrate the absurdity of DRLs and their lack of connection to health protection.  “Before it closed in 2013 Shield Source, a tritium light factory in Peterborough, Ontario had a DRL for tritium gas that was over 200 times higher than the total global natural tritium production rate.  Each year, in theory, Shield Source could have emitted more than ten times the world’s natural tritium inventory. Had they done so, tritium levels in rainfall, and in every water body in the world, would have risen several hundred-fold, exceeding those measured at the peak of nuclear weapons testing in 1963.

“Another tritium light factory, SRB Technologies in Pembroke, Ontario during the late 1990’s and early 2000’s released more radioactive tritium annually to the local environment than all of Canada’s nuclear power stations combined, while well within its DRL.”

During a recent review of the Environmental Impact Statement for the proposal to entomb the Rolphton Nuclear Power Demonstration (NPD) reactor in cement and grout, it was revealed that the reactor basement continuously fills with water that seeps in through cracks in the foundation, becoming highly contaminated with radioactive tritium and other toxic substances like PCBs, mercury and lead. The facility manager, Canadian Nuclear Laboratories, routinely dumps batches of the contaminated water directly into the Ottawa River, even though it exceeds Ontario and Canadian surface water quality standards by hundreds and thousands of times.

Canada’s nuclear regulator, the Canadian Nuclear Safety Commission, widely perceived to be a “captured agency”, published a discussion paper in 2012 on establishing release limits at nuclear facilities. The discussion paper acknowledged that Canadian DRLs are not meeting international standards and need to be lowered. CNSC has not yet taken any regulatory action on these recommendations.

ABOUT CCRCA

The Concerned Citizens of RenfrewCounty and Area was formed in 1978 to research and advocate about nuclear waste and other pollution issues in Eastern Ontario and the Ottawa River watershed. The group works closely with other citizen and environmental groups to promote responsible management of radioactive wastes and protection of the environment.

The multinational consortium that brought us the plan for the giant radioactive “Chalk River Mound” now wants to entomb a defunct nuclear reactor right beside the Ottawa River at Rolphton, Ontario, 200 km upstream of Ottawa-Gatineau. Essentially “entombment” means to cover over with cement and grout and hope for the best.

This plan is just as crazy as the mound, if not more so, since it would be situated a mere 400 meters from the Ottawa River. The International Atomic Energy Agency (IAEA) says “entombment” is not a decommissioning strategy and should only be used in the case of a severe accident.

Cement and grout, in the Upper Ottawa Valley climate with freeze-thaw cycles and abundant precipitation can only last a small fraction of the time during which the witches’ brew of toxic man-made radioactive substances, contained in the defunct reactor, will be hazardous to all life. IAEA says such materials need to be kept out of the biosphere for as long as the hazard persists which is more than 100,000 years.

Do you have a half hour to help prevent this crazy plan from going forward? If so, your assistance would be greatly appreciated!

Comments are needed on the Environmental Impact Statement for the project. The deadline is February 13, 2018 at midnight. So far there are only 13 comments posted on the public registry. We need more comments from concerned citizens and groups to show that we will not stand by silently and allow such irresponsible abandonment of nuclear waste beside the Ottawa River.

If you can help, step one would be to read some background materials (see below) and step two would be to write a short letter outlining your concerns and send it to: Lucia Abellan, Environmental Assessment Officer, Canadian Nuclear Safety Commission Email: cnsc.ea-ee.ccsn@canada.ca. The subject line of your email should read ” Comments on the EIS for the Nuclear Power Demonstration Closure Project”

Key points to mention are 1) retired nuclear scientists such as Dr. J. R. Walker  have raised very serious concerns about the proposal (you could include one or more quotes from the  Walker submission) and 2) that you would like remind/urge the regulator to insist that long-lived radioactive wastes be stored in state-of-the art facilities, well away from drinking water sources, to ensure that they are kept out of our air and drinking water for as long as they remain hazardous.

Here are some useful background documents:

1) Nine quick facts on the crazy plan to “entomb” a nuclear reactor beside the Ottawa River

2) NPDRolphton ~ overview of important information and links produced by the Old Fort William Cottagers’ Association

3) Submission by Dr. Gordon Edwards on the Whiteshell 1 reactor (a similar “entombment” on the Winnipeg River)

Thanks everyone for your ongoing support. Please get in touch if you have any questions or comments!

www.concernedcitizens.net

https://www.facebook.com/RadWasteAlert/

Norm Odjick, Director General, The Algonquin Anishinabeg Nation Tribal Council

Grand Council Chief Patrick Wedaseh Madahbee Anishinabek Nation

Patrick Nadeau, Executive Director, Ottawa Riverkeeper

Lynn Jones, Concerned Citizens of Renfrew County and Area

Réal Lalande, Stop Oléoduc Outaouais / Ralliement contre la pollution radioactive (RCPR)