National Observer: Waste headed for Ontario site is a radioactive ‘mishmash’: nuclear industry veterans

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By Natasha Bulowski | NewsPoliticsOttawa Insider | February 13th 2024

Former employee at Atomic Energy of Canada Limited Kerry Burns (centre right, with a beard and spectacles) at AECL’s Whiteshell Laboratories in Manitoba in 1979. Photo submitted by Kerry Burns

Approval of a nuclear waste disposal site near the Ottawa River hinged on a promise that only low-level radioactive waste would be accepted. But former nuclear industry employees and experts warn some waste slated for disposal contains unacceptably high levels of long-lived radioactive material.

The “near-surface disposal facility” at Chalk River Laboratories (CRL) will store up to one million cubic metres of current and future low-level radioactive waste inside a shallow mound about one kilometre from the river, which provides drinking water to millions of people in the region. But former employees who spent decades working at the labs in waste management and analysis say previous waste-handling practices were inadequate, imprecise and not up to modern standards. Different levels of radioactive material were mixed together, making it unacceptable to bury in the mound.

“Anything pre-2000 is anybody’s guess what the hell they have on their hands,” said Gregory Csullog, a retired waste inventory specialist and former longtime employee of Atomic Energy of Canada Limited (AECL), the Crown corporation that ran the federal government’s nuclear facilities before the Harper government privatized it in 2015.

Gregory Csullog standing at Mount Yucca
Gregory Csullog pictured at the Yucca Mountain nuclear waste repository in 2001 while employed with the International Atomic Energy Agency. Photo submitted by Gregory Csullog

Csullog described the waste during this earlier time as an unidentifiable “mishmash” of intermediate- and low-level radioactivity because there were inadequate systems to properly label, characterize, store and track what was produced at Chalk River or shipped there from other labs. “Literally, there were no rules,” said Csullog, who was hired in 1982 to develop waste identification and tracking systems.

International safety standards state low-level radioactive waste is suitable for disposal in various facilities, ranging from near the surface to 30 metres underground, depending primarily on how long it remains radioactive. High-level waste, like used fuel rods, must be buried hundreds to thousands of metres underground in stable rock formations and remain there, effectively forever. Intermediate-level waste is somewhere in the middle and should be buried tens to hundreds of metres underground, not in near-surface disposal facilities, according to the International Atomic Energy Agency (IAEA).

Radioactive waste is recognized by many health authorities as cancer-causing and its longevity makes disposal a thorny issue. Even short-lived radioactive waste typically takes hundreds of years to decay to extremely low levels and some radioactive isotopes like tritium found in the waste — a byproduct of nuclear reactors — are especially hard to remove from water.

What people are reading

Canadian Nuclear Laboratories (CNL) originally wanted its near-surface disposal facility to take intermediate- and low-level waste when it first proposed the project in 2016. Backlash was swift and concerned groups, including Deep River town council and multiple experts, argued it would transgress international standards to put intermediate-level waste in that type of facility. In 2017, CNL changed its proposal and promised to only accept low-level waste. The announcement quelled the Deep River town council’s concern, but some citizen groups, scientists, former employees and many Algonquin Nations aren’t buying it.

CNL says its waste acceptance criteria will ensure all the waste will be low-level and comply with international and Canadian standards. Eighty seven per cent of the waste will be loose soil and debris from environmental remediation and decommissioned buildings. The other 13 per cent “will have sufficiently high radionuclide content to require use of packaging” in containers, drums or steel boxes in the disposal facility, according to CNL.

Approval of a nuclear waste disposal site near the Ottawa River hinged on a promise that only low-level radioactive waste would be accepted. #ChalkRiverLabs

However, project opponents note that between 2016 and 2019, about 90 per cent of the intermediate-level waste inventory at federal sites was reclassified as low-level, according to data from AECL and a statement from CNL. The timing of the reclassification raised the alarm for critics, who took it to mean intermediate-level waste was inappropriately categorized as low-level so it could be stored in the Chalk River disposal facility. CNL said the 2016 estimate was based on overly “conservative assumptions” and the waste was reclassified after some legacy waste was retrieved, examined and found to be low-level.

The disposal facility will also accept waste generated over the next two decades and some shipments from hospitals and universities.

The history of Chalk River Laboratories

To fully understand the nuclear waste problem, you first have to know the history of Chalk River Lab’s operations and accidents, according to Mahdi Khelfaoui, professor of the history of energy, science and technology at the University of Quebec at Trois-Rivières and author of multiple articles on the nuclear industry and its history in Canada.

Chalk River Laboratories photographed in 1945. Photo from the National Research Council Canada archives

Chalk River is Canada’s biggest research facility. Built in 1944, it became home to the world’s first recorded nuclear reactor core meltdown in December 1952, followed by another incident in 1958. The 1952 accident was ranked a five on the International Atomic Energy Agency’s scale of one to seven; Chernobyl was a seven.

The partial reactor meltdown spewed radioactive material into the air and environment. During the year-long cleanup, highly radioactive debris and fuel rods were buried in a sandy area near the Ottawa River and millions of litres of contaminated water were dumped into ditches less than two kilometres from the river.

In this day and age, burying wooden boxes of fuel rods in shallow holes would be unthinkable, said Khelfaoui.

“At the time, the radioactive waste issue was almost synonymous with protecting the [commercial] interests of the nuclear industry,” said Khelfaoui. Public involvement in waste management policy was “nonexistent” before the end of the 1990s, he said.

Keeping accurate information on waste over time is a challenge and there have been inventory discrepancies at Chalk River, he added.

For example, the fuel rods buried in a “rudimentary” fashion after the 1952 meltdown were dug up and moved to safer storage in 2007, said Khelfaoui. AECL expected to find 19 fuel rods and cans in the boxes, but there were actually 32.

Over 75 years, Chalk River Laboratories developed CANDU reactors, did nuclear weapons research, supplied the United States’ nuclear weapons program with plutonium and uranium, and at one time was the world’s largest supplier of medical isotopes used to diagnose and treat cancers.

A black and white photo showing the labs where medical isotopes were produced at Chalk River from the pre-2000s
Chalk River Labs’ isotope separation laboratory in 1948. For 60 years, Chalk River Labs produced medical isotopes used to treat and diagnose diseases like cancer. Photo from the National Research Council Canada archives

Inherent inventory issues

Until the mid-1990s, waste wasn’t even categorized as intermediate, low or high-level, said Csullog, who worked at AECL back when the Crown corporation still ran day-to-day operations at Chalk River Laboratories. Much of it was stored together in what he described as a “mishmash of unsegregated, unmarked, uncharacterized mixture of low- and intermediate-level waste.”

“This mixing and lack of identification would make all these wastes unsuitable for the near-surface disposal facility,” said Csullog.

His main concern is the packaged legacy waste, which includes contaminated protective gear, old mops, rags, tools and lab equipment from former operations. For example, some of this equipment was used to clean up highly radioactive water that leaked out of the site’s two nuclear reactors, said Csullog.

nuclear reactor shown in black and white photo
A historic photo of the National Research Experimental Reactor (NRX). NRX began operation in 1947 as Canada’s first large-scale research reactor and played a major role in developing the CANDU reactor. It was used to test fuels and materials and for nuclear physics research in support of the Canadian nuclear power program, according to the Canadian Nuclear Safety Commission. NRX was shut down on Jan. 29, 1992. Photo courtesy of Canadian Nuclear Laboratories

During his 21 years at AECL’s Chalk River Laboratories, Csullog developed programs to label and track all the radioactive waste created or shipped to the site. He later wrote the International Atomic Energy Agency’s guidelines on waste inventory record-keeping systems.

Developing these programs for AECL posed a challenge because many of the logbooks he was given to transcribe at the outset of his work in 1982 had precious little information on where the waste came from, how it was created or its radionuclide content. Csullog described the information in these historical records as “meaningless.” Until the mid-’90s, there weren’t even waste package labels to link waste to the correct paperwork, which also hindered his work, said Csullog.

“We didn’t track it. You can’t throw it all together and say, ‘We’ll use historical information.’ It’s irrelevant,” said Csullog.

In an email statement to Canada’s National Observer, CNL said the radioactivity of the legacy waste packages is based on records from its waste database. “CNL recognizes there are gaps” in this data and said no waste will be placed in the facility based only on historic information. Data on older legacy waste data will be reassessed and “modern analysis techniques” used to ensure there is “enough information on the waste” to make certain it meets the acceptance criteria.

The majority of packaged waste now in storage was generated pre-1995 and there is enough information to classify it as low-level waste “within a reasonable certainty,” a CNL representative told the Canadian Nuclear Safety Commission (CNSC) during the licensing process. All waste generators have to submit documents detailing the properties of the waste and then it’s up to CNL to verify the waste matches the documentation before it goes into the disposal facility.

Even after Csullog’s waste identification and tracking program was implemented in the mid-’90s, some waste with higher radioactivity was still compacted with really low-level material when it should have been kept separate, said Csullog. This was done so the radiation emitted by each bale was limited enough for people to handle and move them but in hindsight, was a mistake, he said. At this period in time, the industry was on a learning curve when it came to waste management, said Csullog.

It takes a “very, very small amount of a contaminant that’s long-lived” to make low-level waste transition to intermediate, Csullog emphasized.

By the time Csullog left the Crown corporation in 1999, his final iteration of a waste inventory database was being used for package labelling, validation, inspection and compliance monitoring. While it was a vast improvement on past practices, the program still relied on estimates of waste characteristics and only helped keep tabs on newly created wastes — not the pre-2000’s waste Csullog says is unacceptable for the facility. Estimates are not a substitute for the more involved process of characterization, a process to verify the specific type and concentrations of radionuclides, said Csullog, but it helps identify which waste should be a priority and make a plan to verify its characteristics. Radionuclides are radioactive atoms.

To safely manage, dispose and store waste, it must first be characterized so you know how long the radionuclides take to decay and can then accurately classify waste as low or intermediate level based on their disposal requirements, said Kerry Burns, an expert on radioactive waste characterization methods who worked at AECL for 25 years and the IAEA for eight years.

In either case, Csullog said when he returned to AECL in 2006 after a stint working for the IAEA, his program that estimated waste characteristics and tracked them had been “abandoned.” The outstanding question in Csullog’s mind is what has been done to take its place.

In a detailed submission to the CNSC, Csullog outlined the many problems with waste identification and inventory systems during his time at AECL and the persistent lack of data to verify the radionuclide content of this older waste.

Csullog emphasized he is not against the disposal facility as a whole. He is against CNL putting this particular legacy waste into it. Instead, CNL should put this legacy waste into a deeper facility designed for intermediate-level waste since it will have to dispose of other intermediate-level waste anyway, he said.

A majority of the waste planned for disposal in the near-surface facility is soil and debris from decommissioned buildings. Most of the buildings decommissioned so far were administrative and likely had little contamination and CNL could feasibly have enough information on the radioactive properties, said Csullog. But the site’s wide range of research and development activities exposed lab equipment and some buildings to many different radioactive materials. For example, some labs separated plutonium for the U.S. weapons program, said Burns.

Kerry Burns, longtime AECL employee and radioactive waste characterization expert, outside his home in 2024. Photo submitted by Kerry Burns

Because of the site’s wide-ranging activities, it is unknown exactly what concentrations of radionuclides are in the legacy waste, said Burns.

The radionuclides typically encountered at Chalk River Labs have half-lives ranging from seconds to tens of thousands of years and can give off three different types of radiation. Low-level waste should decay to extremely low levels within roughly 300 years. As radionuclides decay, some of them turn into other radionuclides with different properties, which is vital to know when you’re planning how to store waste, said Burns.

Some controlled activities — like operating a nuclear power plant — produce waste with fairly predictable types and amounts of radionuclides. As long as these predictable waste streams are kept separate, you can often measure, sample and analyze it, said Burns, who spent years at AECL developing radiochemical analysis methods to determine exact properties of waste, and authored multiple articles on these methods.

But these methods only work if the waste is consistent, monitored carefully over time and kept separate from other waste streams, said Burns.

“I am afraid that the legacy and decommissioning wastes at CNL fall into the category of a dog’s breakfast,” said Burns. To know exactly how dangerous and long-lived the materials going into the facility truly are, a detailed analysis of each package and container would be required, said Burns.

According to CNL’s waste acceptance criteria, radiochemical analysis is not part of its minimum verification requirements, though it may be done as an additional verification measure.

Canada’s National Observer asked CNL which waste streams, if any, have had their radionuclide content confirmed using radiochemical analysis.

CNL said radiochemical analysis and background information are used to create “fingerprints” for waste streams based on what background information and past data exist on the waste.

“Some fingerprints have been established, while others are still in development,” said CNL. The company gave no specifics on which waste streams were examined using radiochemical analysis.

All waste will have “sufficient characterization data” to confirm it can be placed in the near-surface disposal facility, according to CNL.

Radiochemical analysis is “prohibitively expensive” and “extremely time-consuming” but is the only way to determine the inventory of long-lived, hard-to-detect radionuclides in this waste, said Burns. This chemical analysis becomes even more challenging when waste from different operations is mixed together, as Csullog and Burns said was the case for a great deal of waste pre-2000. If a sample isn’t representative of the whole waste stream, the results won’t reflect everything in it, said Burns.

Canada’s National Observer asked CNL if it has a budget or cost estimate for radiochemical analysis and which wastes will require this analysis. CNL declined to answer.

CNL is responsible for ensuring waste meets its acceptance criteria. CNL is owned by a consortium of private companies (including AtkinsRealis, formerly SNC-Lavalin). AECL receives federal funding and contracts CNL to manage and run the federal sites, including Chalk River.

Minimum requirements for verification include inspecting waste package labels and providing documents on the waste profile and management plan. CNL’s waste acceptance criteria doesn’t specify how often verification takes place. CNL declined to explain how frequently it would verify waste.

Chalk River Labs photographed from the Ottawa River in the late 1940s. Includes a sign on the shore saying

Chalk River Laboratories photographed from the Ottawa River in 1945. It was constructed in 1944. Photo from the National Research Council Canada archives

Csullog and Burns can only speak to the waste management practices from their time at Chalk River. Burns’ team at AECL used radiochemical analysis paired with another group’s measurements to characterize the mixed waste that was compacted into bales. These bales are on the lower end of radioactivity compared to other operations waste and the characterization data showed even those are unsuitable for the disposal facility, said Csullog.

CNL could have adequate systems and practices in place to characterize and track waste being generated today, they say, though neither is convinced based on the company’s submissions to the CNSC. But proper waste management today doesn’t change the fact that the Chalk River site is dealing with waste from an era when far less was known about the importance of handling radioactive waste, said Csullog.

“It was a good place to work … but when it came to waste management, it was always sort of the lowest priority,” said Burns, referring to AECL back in his day. “You’re dealing with a research site where people get rewarded for publishing papers, for doing innovative research, not for handling wastes and putting it in storage.”

Natasha Bulowski / Local Journalism Initiative / Canada’s National Observer

‘We have a broken nuclear governance system’ ~ Regulator comes under fire for approving waste facility at Chalk River (iPolitics)

January 11, 2024

Excerpts:

“A decision to approve the construction of a nuclear waste storage facility two hours west of Ottawa has led Indigenous leaders, activists and experts to voice concerns about what they describe as fundamental aws within Canada’s nuclear regulator.”

“Critics of the decision believe the recent approval is the latest example of the CNSC prioritizing the nuclear industry over Canadians, which they say stems from a lack of regulatory independence.”

“Bloc Québécois MP Monique Pauzé lamented the approval what she described in French as an “insane and inconceivable project.”

“Ottawa confirms to us the bogus status of the hearings conducted by the CNSC where the Commission heard the opposition of multiple stakeholders only to nally brush them aside in the decision rendered yesterday,” Pauzé said in a statement.”

Letter to CCRCA members and friends

Ottawa River radioactive waste dump ~ license approved by the CNSC

January 13, 2024

Dear Friends

Yesterday afternoon Canada’s captured nuclear regulator, the CNSC, announced its approval of the license to build the giant above-ground radioactive waste mound beside the Ottawa River, aka the NSDF. See below a few links to good coverage of reactions to the announcement. 

There was never any doubt that the CNSC would approve the license. The surprise is how long it took them to do so — seven and a half years! That is a testament to the incredible opposition that mobilized to fight the ill-conceived plan. In a David and Goliath battle, opponents effectively derailed the original plan of the CNSC and the consortium to have shovels in the ground six years ago, in January 2018. That is an accomplishment worth celebrating!

The battle is not over. It will move to the courts now. And along with our allies, we will continue to push for an international ARTEMIS review of the proposal. On that note, thank you to everyone who signed and shared House of Commons e-Petition 4676; the petition just closed for signatures today having been signed by well over 3000 Canadians in just 30 days. A meeting with MP Sophie Chatel about how to move the request for an ARTEMIS review forward will take place soon. Other next steps are in the works and we will keep you posted about them as the plans crystalize. 

We are very grateful to our Algonquin brothers and sisters for their strong stand against irresponsible nuclear waste projects in their unceded territory. We look forward to continuing to work with them toward an ultimate victory at some point down the road. 🙂

This seems a good time to share the inspiring words of Algonquin Elder Claudette Commanda, delivered during a press conference at 50 Sussex Drive on August 10, 2023. The press conference can be viewed at this link and Claudette’s statement begins at 13 minutes. Here is some of what she said that day, to rousing applause:

“This nuclear waste facility will damage the water and we all know that. 

Conscientious people are rising. We must rise together, we are all in that medicine wheel. No matter our colour, our creed or our title, we are all related in the human family and we must stand together

We have a responsibility to our brothers the animals, to our sisters the animals. To the water life and to the land.

We cannot stop the thunder.

We cannot stop the rain from falling.

We cannot stop the lightning from shining

We cannot stop the rivers from flowing

But together as human beings, as brothers and sisters, we can certainly stop the nuclear waste facility from coming here on the Ottawa River.Meegwetch”

Thank you everyone for your ongoing interest and support. Please feel free to forward this message to anyone you think might be interested. Good overviews for people new to the issue are here and here. 

Best wishes,

Lynn

concernedcitizens.net

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

https://twitter.com/RadWasteAlert

Photo above of Kitchi Sibi on November 15, 2023, by Bev Moses

Radioactive waste site in Chalk River a go (National Observer, Natasha Bulowski)

Déchets nucléaires à Chalk River : « aucune surprise » pour Dylan Whiteduck, (Radio Canada)

Une installation de déchets nucléaires autorisée à Chalk River | Radio-Canada (Julien David-Pelletier, Radio Canada)

Kebaowek First Nation condemns CNSC decision to license the Chalk River nuclear waste dump and calls on the federal government to intervene

Kebaowek First Nation condemns CNSC decision to license the Chalk River nuclear waste dump and calls on the federal government to intervene

PRESS RELEASE

FOR IMMEDIATE RELEASE

NUCLEAR WASTE AT CHALK RIVER: KEBAOWEK FIRST NATION CONDEMNS CNSC DECISION AND CALLS ON THE CANADIAN GOVERNMENT

KEBAOWEK, January 9, 2024 – Despite concerns expressed by First Nations and increased support from over 140 municipalities across Canada, the Canadian Nuclear Safety Commission (CNSC) has granted the license for the Near Surface Disposal Facility (NSDF) project at Chalk River. In response, the Kebaowek First Nation strongly condemns this decision and calls on the federal government to intervene to stop this environmentally high-risk project.

“The Commission’s decision is unacceptable, notably because it goes against the rights of Indigenous peoples and environmental protection. The Canadian government must act promptly and immediately assert the suspension of the project. The Commission’s final decision is totally wrong when it states that the NSDF project will not cause significant environmental effects. While the decision states that CNL will take appropriate measures to safeguard the environment, the health, safety of individuals, and national security and to comply with national obligations, it is undeniable that the safety and health of people and the environment will be profoundly impacted for generations to come through this project, ” reacted Chief Lance Haymond of Kebaowek.

It is worth noting that the NSDF would release radioactive and hazardous materials into a nearby wetland and the Ottawa River during its operation and after its closure. The mound is expected to degrade through a process of “normal evolution”. The NSDF could also contaminate the river following earthquakes, wildfires, floods, and other extreme weather events. Not only is the Kichi Sibi sacred to the Algonquin Peoples, but the Chalk River site is also close to the sacred Algonquin sites of Oiseau Rock and Baptism Point.

In 2017, the Assembly of First Nations adopted a resolution stating that the CNSC and the Canadian government had not fulfilled their constitutional obligation to consult and accommodate First Nations regarding the NSDF. The Anishinabek Nation and the Iroquois caucus issued a joint statement on radioactive waste, asserting that “we must protect the land, water, and all living beings for future generations” and calling for no abandonment of radioactive waste, moving it away from major waterways, and eliminating the practice of importing or exporting radioactive waste.

In addition to the opposition of Algonquin First Nations to the project, over 140 municipalities in Quebec and Ontario, including Gatineau and Montreal, as well as several civil society organizations, have expressed their opposition to the NSDF plan. In 2021, the City of Ottawa adopted a resolution expressing its concern.

The Kebaowek First Nation, committed to defending the rights of Indigenous peoples and environmental preservation, expresses its eagerness to collaborate with the government and other stakeholders to ensure a careful consideration of Indigenous concerns and compliance with the obligations of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) in the context of this project. The First Nation maintains its categorical opposition to the establishment of a permanent NSDF on unceded Anishinabe territory, emphasizing the crucial importance of protecting Indigenous rights, the environment, and cultural heritage. Faced with a lack of trust in the CNSC and its persistent failure to uphold UNDRIP, the First Nation calls on the federal government, including the Minister of Environment and Natural Resources, to intervene and end the project.

“I want to be very clear: the Algonquin Peoples did not consent to the construction of this radioactive waste dump on our unceded territory. We believe the consultation was inadequate, to say the least, and that our Indigenous rights are threatened by this proposal. We demand the cancellation of the NSDF project. The focus should instead be on a real and successful cleanup of the site to permanently eliminate old radioactive waste,” explains Chief Haymond.

Kebaowek First Nation Chief Lance Haymond speaking at a press conference in Ottawa in June 2023

For more information: https://www.stopnuclearwaste.com/ 

To obtain the Board’s decision: https://www.cnsc-ccsn.gc.ca/eng/resources/news-room/nsdf-media-kit.cfm  

-30-

Source: 

Kebaowek First Nation

For information and interview requests: 

Mathilde Robitaille-Lefebvre 

Media Relations 

m.robitaille-lefebvre@seize03.ca 

819-852-4762

Justin Roy

Advisor 

Kebaowek First Nation 

Jroy@kebaowek.ca 

819-627-3309

Hill Times ~ Le déluge souligne l’importance de l’audience finale pour le dépôt de déchets nucléaires – Audience finale des délégations de trois premières nations

THE HILL TIMES | LUNDI 21 AOÛT 2023

Il est grand temps que le gouvernement s’occupe de cette catastrophe environnementale en devenir, un problème grave qui s’aggravera si on l’ignore.

OTTAWA – Le 10 août, la Commission canadienne de sûreté nucléaire a tenu une audience finale sur l’autorisation d’un gigantesque dépôt de déchets radioactifs en surface près de la rivière des Outaouais, en amont d’Ottawa-Gatineau et de Montréal, à Chalk River (Ontario), qui a créé un précédent.

Des délégations de trois Premières Nations algonquines – Kebaowek, Kitigan Zibi et Barriere Lake – se sont réunies au 50 Sussex Dr. à Ottawa pour faire leurs présentations finales en personne aux membres de la communauté, aux alliés non autochtones et à une poignée de représentants élus, au mépris d’un décret de la Commission canadienne de sûreté nucléaire (CCSN) stipulant que l’audience ne serait que virtuelle. La CCSN a présidé l’audience via Zoom.

Pendant l’audience, une tempête sans précédent s’est abattue sur le site, avec d’énormes quantités de pluie, de tonnerre, de grêle et de vent qui ont soufflé sur les chaises de la terrasse extérieure couverte où la foule en surnombre regardait les débats. Malgré la férocité de l’orage, les aînés algonquins ont entretenu un feu sacré cérémoniel tout au long de la cérémonie.

Si le projet est approuvé, la décharge géante, appelée “installation de stockage en surface” (IGDPS) par le promoteur, contiendrait un million de tonnes de déchets radioactifs et dangereux dans un monticule en surface sur la propriété des laboratoires de Chalk River, une installation nucléaire fédérale fortement contaminée établie sur des terres algonquines volées en 1944 afin de produire du plutonium pour les armes nucléaires américaines. Les laboratoires de Chalk River représentent un énorme passif environnemental pour le gouvernement du Canada, avec un coût de dépollution estimé à plusieurs milliards de dollars.

Le promoteur de la décharge est un consortium multinational composé de SNC-Lavalin et de deux multinationales basées au Texas : Fluor et Jacobs. Le consortium a été engagé par le gouvernement conservateur en 2015 pour réduire rapidement et à moindre coût l’énorme responsabilité fédérale en matière de déchets nucléaires hérités. Paradoxalement, les coûts pour les contribuables de la gestion des déchets radioactifs hérités du gouvernement fédéral canadien ont grimpé à plus d’un milliard de dollars par an après la privatisation.

L’audition du 10 août a créé un précédent à deux égards. Si elle est approuvée, l’IGDPS sera la toute première installation de stockage permanent des déchets de réacteurs nucléaires au Canada. Deuxièmement, la décision d’autoriser ou non l’installation est un test important de l’engagement du Canada envers la Déclaration des Nations unies sur les droits des peuples autochtones, qui interdit le stockage de déchets radioactifs sur les terres des peuples autochtones sans leur consentement libre, préalable et éclairé. Dix des onze Premières nations algonquines, dont les membres vivent dans la vallée de l’Outaouais depuis des temps immémoriaux, ont déclaré qu’elles ne consentaient pas à ce que l’ IGDPS soit implanté sur leur territoire non cédé.

Bon nombre des déchets qu’il est proposé d’éliminer dans le NSDF resteront dangereux et radioactifs pendant des milliers, voire des millions d’années, selon le Dr. J.R. Walker, le plus grand expert canadien en matière de déchets radioactifs hérités du gouvernement fédéral et de la meilleure façon de les gérer. M. Walker a clairement indiqué que les déchets proposés pour l’IGDPS ne sont pas des déchets de faible activité, mais des déchets radioactifs de “niveau intermédiaire” qui devraient être éliminés à des dizaines, voire des centaines de mètres sous la surface du sol. Il a également affirmé que la proposition n’était pas conforme aux normes de sécurité internationales.

Le site proposé pour l’IGDPS se trouve sur le flanc d’une colline entourée de zones humides qui se jettent dans la rivière des Outaouais, à moins d’un kilomètre de là.

La déclaration d’impact sur l’environnement du promoteur documente les nombreuses façons dont la décharge pourrait fuir pendant son exploitation et après sa fermeture. Trois isotopes du plutonium figurent sur la longue liste des radionucléides qui seraient rejetés dans la rivière des Outaouais dans les “effluents traités” de la décharge. Le monticule devrait se dégrader, s’éroder et finalement se désintégrer en raison de “l’évolution naturelle”.

La plupart des gens pensent qu’il est répréhensible de déverser délibérément des matières radioactives dans une importante source d’eau potable telle que la rivière des Outaouais, car il n’existe pas de niveau d’exposition sûr à ces poisons fabriqués par l’homme. Chaque rejet accidentel ou délibéré augmente les risques de cancer, de malformations congénitales et de dommages génétiques chez les populations exposées.

L’Assemblée des Premières Nations et plus de 140 municipalités situées en aval, dont Ottawa, Gatineau et Montréal, ont adopté des résolutions exprimant leur inquiétude à l’égard de la proposition du IGDPS.

Malgré les nombreuses lacunes et la forte opposition, le personnel de la Commission canadienne de sûreté nucléaire n’a jamais hésité à soutenir le projet de décharge. Il semble qu’il n’ait jamais reçu le mémo en 2000 lorsque le mandat de l’organisation a été modifié par une nouvelle législation, passant d’un rôle de promotion de l’industrie nucléaire à un mandat strictement axé sur la protection des Canadiens et de l’environnement.

L’audience du 10 août a été présidée par un seul commissaire, ainsi que par la présidente de la CCSN. Leurs curriculum vitae respectifs font état de longs états de service et d’allégeance à l’industrie nucléaire. Les deux fonctionnaires n’ont pas posé une seule question aux équipes d’intervenants des Premières nations, qui étaient manifestement choquées par le manque d’intérêt pour les informations qu’elles s’étaient donné tant de mal à rassembler et à partager. Un membre de l’équipe a demandé : “Pouvons-nous vous poser des questions ?”, ce à quoi le président a sèchement répondu : “Ce n’est pas notre façon de procéder.”

Le régime de gouvernance nucléaire gravement déficient du Canada a été décrit précédemment dans le Hill Times. La gouvernance nucléaire au Canada s’appuie fortement sur la CCSN pour presque tous les aspects de la surveillance de l’industrie nucléaire. La CCSN est largement perçue comme un “régulateur capturé” qui promeut les projets qu’elle est censée réglementer.

Il est clair que notre régime de gouvernance nucléaire gravement déficient a permis à l’IGDPS – un simulacre grotesque d’installation de gestion responsable des déchets radioactifs – d’être proposée et prise au sérieux au Canada. La décision de la CCSN d’approuver le permis pour l’IGDPS est attendue prochainement.

La puissante tempête qui s’est abattue sur le 50 Sussex Dr. pendant que l’on entendait des témoignages en langue algonquine sur la cupidité et la destruction inconsidérée de l’environnement a souligné la gravité de la décision envisagée. Il ne fait aucun doute qu’une tempête record comme celle qui a frappé l’IGDPS au cours de sa phase de remplissage de 50 ans – alors que les déchets sont exposés aux éléments – pourrait facilement provoquer d’importants déversements de poisons radioactifs et d’autres matières dangereuses dans la rivière des Outaouais.

Il est grand temps que le gouvernement se réveille et s’attaque à cette catastrophe environnementale en cours, un problème grave qui ne fera que s’aggraver au fur et à mesure qu’il sera ignoré.

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Lynn Jones est une gestionnaire de programme de santé publique à la retraite qui travaille maintenant pour Concerned Citizens of Renfrew County and Area, une organisation non gouvernementale qui œuvre depuis plus de 40 ans à l’assainissement et à la prévention de la pollution radioactive provenant de l’industrie nucléaire dans la vallée de l’Outaouais. Elle est basée à Ottawa.

L’image ci-dessous est une simulation de l’effet baignoire tirée du documentaire de Découverte “Chalk River Heritage”.

Flaws and deficiencies in the CNSC-led Environmental Assessment for the NSDF

June 29, 2023

The seven year long, CNSC-led, Environmental Assessment of the proposed giant radioactive waste mound or “NSDF” has been fraught with serious problems and deficiencies.  These deficiencies, in our view, have led to a poor-quality assessment, leaving the Commission with poor recommendations on which to base its EA decision.

Inadequate consultation with Indigenous Peoples on whose unceded territory the proposed radioactive dump would be built

CNSC and the proponent announced the design, site and commencement of an EA for the dump in 2016. No consultation with Algonquin First Nations occurred prior to the announcement of the design, site and EA. Some consultations occurred during the protracted EA, but not all Algonquin First Nations were consulted. As a seeming afterthought, after the final NSDF licensing hearing concluded in June 2022, the CNSC decided to leave the record open for further consultations with two of the eleven Algonquin First Nations whose peoples have lived in the Ottawa River watershed since time immemorial, and whose people never ceded their territory to the Crown via a treaty.

Problems in the early stages with the project description and scoping for the EA

1 The CNSC dismissed critical comments on the project description, submitted by radioactive waste management experts, that should have resulted in a fundamental rethinking of the project design, or at least major changes to the scope of the Environmental Assessment.

2  The CNSC’s scoping of the Near Surface Disposal Project (NSDF) was seriously flawed. A combined scoping decision for three separate projects (the NSDF, and the entombment of the NPD and WR-1 reactors) was made nine days before the draft environmental impact statement (EIS) for the NSDF project was released. The CNSC allowed the proponent to conduct environmental impact studies before the project scope was determined. The scoping decision ignored many serious criticisms of the NSDF project description. It was released by a 1-person “Panel” comprised solely of the CNSC President. The public was not apprised of the “Panel” hearing, which may never have actually taken place.

Obstacles to “meaningful public participation”

3  The CNSC did not require the NSDF proponent to translate documents into French, despite a clear potential for adverse environmental impacts in the Province of Quebec. The closest residents to the NSDF project site are in Quebec. Lack of access to French language documents led to a complaint from a Quebec citizen and a decision by the Commissioner of Official Languages to require translation of the draft EIS.

4  The CNSC delayed or refused to provide access to documents referenced in the draft EIS for the Near Surface Disposal Project. A footnote on page 3-14 of the draft EIS (12) states that “The Safety Analysis Report demonstrates that even after failure of some of the design features, the wastes do not present a risk to the public and environment.” However, the Safety Analysis Report was not released until after the public comment period on the draft EIS ended. Key portions of this document (such as section 4.2.1.3 on “Nuclear Criticality Safety”) were redacted.

5  The CNSC did not provide the “meaningful opportunities for public participation” required by section 4(1)(e) of CEAA 2012.  CNSC closed  the record for public comments pursuant to the Environmental Assessment in August 2017 following CNL’s release of a draft Environmental Impact Statement.  This created nearly a 5-year gap before the May/June 2022 hearing.  CNSC provided no opportunity for the public to provide formally recorded comments on the final EIS, despite the numerous changes made to the project that are reflected in it.

6 The CNSC arbitrarily decided that written intervenors at the May/June 2022 hearing would not have the right to make final submissions.

7  The CNSC’s January 31, 2023 Notice of Public Hearing and Procedural Guidance for Final Submissions said that “new information may not be presented.”  This was changed very close to the submission deadline (on May 17, 2023) to “Final submissions may reference any material on the record.”

8  The CNSC public hearings provided no opportunity for witnesses to be cross-examined.

9 During public hearings, the proponent (CNL), its contractor (AECL) and the regulator (CNSC) were given unlimited time to make their arguments, but intervenors (other than First Nations) were restricted to 10 minute presentations. In some cases this required thousands of hours of research to be summarized in 10 minutes.

10 The document registry for the NSDF EA was very cumbersome and awkward and did not facilitate access to submissions by all interested parties.

CNSC staff recommendations to Commissioners fail to mention that the Commission is required to refer the decision to Cabinet if the project is likely to cause significant adverse environmental effects 

12 There is no mention of CEAA 2012 Section 52 in CMD 22-H7.  In this document CNSC staff recommend that the Commission decide that the NSDF is not likely to cause significant adverse environmental effects.  However, Section 52 says the Commission could decide that the NSDF is likely to cause significant adverse environmental effects; in which case the Commission must refer the matter to the Governor in Council (Cabinet).  Were CNSC staff so certain that the Commission would never dare to disagree with one of their recommendations that they felt it was not worth mentioning this option?  Regardless, this is a serious omission.  Information provided in CMD 22-H7 about “matters of regulatory interest” with respect to the proposed NSDF should be complete and objective.

CNSC staff allowed the proponent to write its own conditions (856 “mitigation measures”) and the manner in which they are written makes them impossible to enforce.

13. Section 53 of CEAA 2012 says that it is the decision maker — either the Commission or Cabinet  and not the proponent – that “must establish the conditions… that would permit a designated project to be carried out.”  However, CNSC staff allowed the proponent to write its own conditions (the 856 mitigation measures in CNL’s 105-page NSDF Consolidated Commitments List) in a manner that they would be impossible to enforce. There is no evidence that the Commission ever reviewed these conditions.  Furthermore, the CNSC staff draft licence handbook for the NSDF Project requires CNL to only implement mitigation measures during construction and pre-operation activities. Most of the significant adverse impacts of the NSDF Project would occur in the operation and post-closure phases. By only requiring mitigation of adverse effects occurring during construction and pre-operation activities, the CNSC’s approach would not mitigate the most significant adverse impacts of the NSDF Project.

“With regard to section 53, it is astounding that the CNSC has allowed the proponent, CNL, to write its own mitigation measures, and to write them in such a way that nearly all of them would be unverifiable.”

Ole Hendrickson, CCRCA researcher

Problems with the “Administrative Protocol” document

The “Administrative Protocol” is a document co-signed by the regulator and the proponent. It described the steps to be followed for the Environmental Assessment with milestones and target dates. 

Six different versions of Appendix A to the Protocol were published between 2016 and 2022.

The Administrative Protocol omitted any mention of the Duty to Consult with First Nations

At one point in the middle of the EA process all the dates for milestones were removed.  Interested parties were left with no idea when they might be required to allocate time to preparing final briefs and oral presentations.

An original provision for a dedicated Environmental Assessment hearing was removed. No Environmental Assessment hearing was ever held. The Environmental Assessment report was buried in a staff document and contained no references whatsoever.

And finally…

The CNSC, as responsible authority, was unable to complete the Environmental Assessment in a “timely manner” as required by section 4(1)(f) of CEAA 2012.

EAs normally are completed within one or two years. The EA of the NSDF is currently in its seventh year and counting.

Should the CNSC be responsible for environmental assessment?

The Expert Panel on Reform of Environmental Assessment recommended in its final report to the Minister of Environment and Climate Change in 2017 that the CNSC not be in charge of Environmental or Impact Assessments. The CNSC-led EA of the NSDF proposal was started before the Expert Panel review so it was conducted previous legislation, but the flaws and failings documented above seem to suggest that removing the CNSC from involvement in Impact Assessment would be prudent.

Photo below by Robert Del Tredici, August 2018, Ottawa

A call for World-class Cleanup at Chalk River Laboratories

April 2022

Canada’s $16 billion nuclear waste legacy is in danger of being abandoned in substandard facilities and allowed to leak into our rivers and drinking water. Instead, let’s use our expertise  to turn Canada into a world leader in the cleanup and safe storage of  radioactive waste.  

WORLD-CLASS NUCLEAR WASTE CLEANUP would protect  health, drinking water, property values and peace of mind.    

What do experts say is needed?  

The International Atomic Energy Agency says that radioactive waste  facilities must be carefully sited and waste placed below ground to keep  radioactive materials out of air and water and protect current and future  generations. The IAEA says that siting is a fundamentally important activity in the disposal of radioactive waste. Location of a disposal facility in a “stable geological formation” provides protection from processes such as erosion and glaciation.  It says that  nuclear reactor entombment should only be used in the case of a “severe accident”, such as a meltdown.

Retired AECL scientists say that IAEA guidance must be followed, that  Canada has an obligation to follow the guidelines as a signatory to the  Joint Convention on the Safety of Radioactive Waste Management.  

First Nations, in a Joint Declaration, endorsed by resolution at the  Assembly of First Nations, say that nuclear waste should be managed  according to five principles: 1) no abandonment, 2) monitored and  retrievable storage 3) better containment, more packaging, 2) away from  drinking water and major water bodies and 5) no unnecessary transport  (exports and imports) 

The Canadian Coalition for Nuclear Responsibility says radioactive  waste should be carefully managed in monitored and retrievable condition  so that repairs to packaging can be made as needed, to keep the contents  out of the biosphere, our air, soil and drinking water. The CCNR suggests  that a “rolling stewardship” strategy whereby each generation teaches  each subsequent generation how to look after the wastes and keep them  out of the biosphere.

Some countries such as Finland have made good progress building  facilities to keep radioactive waste out of the biosphere. Finland puts  low- and intermediate-level radioactive wastes produced by its four nuclear reactors in bedrock  geological facilities 100 meters deep. It has over 25 years of experience  with these facilities. They will also house the radioactive remains of the  reactors when they are shut down and dismantled. 

WORLD-CLASS NUCLEAR WASTE CLEANUP would bring  money into the Ottawa Valley economy and support good  careers for generations of valley residents.  

WORLD-CLASS NUCLEAR WASTE CLEANUP would involve: 

Thoroughly characterizing all wastes

Establishing an impeccable record-keeping system for use by current and future generations.

Careful packaging and labelling of the wastes. Repairing packages  when they fail and improving them if safer packaging materials become  available. 

Regional mapping to locate a site with stable bedrock 

Construction and operation of an in ground or underground storage facility. Materials that will be radioactive and  hazardous for thousands of years cannot be safely stored on the surface.

While waiting for all of the above steps to be completed, wastes should  be stored in above ground monitored and reinforced (and shielded if  necessary) concrete warehouses; such facilities were pioneered by  Atomic Energy of Canada Limited in the 1990s.  

WORLD-CLASS NUCLEAR WASTE STORAGE FACILITIES  would protect the Ottawa River and future generations.  

Inadequate siting process for the NSDF

April 14, 2022 (Updated May 13, 2022, and November 1, 2023)

The site for the proposed Chalk River NSDF is on the side of a steep forested hill, the base of which is surrounded by wetlands that drain into the Ottawa River less than one kilometer away. This proposed location is of deep concern for many critics of the proposal, including Algonquin First Nations, 150+ Quebec and Ontario municipalities, and many citizens’ groups and NGOs.

The choice of such an unsuitable site for the NSDF can be traced back to an inadequate siting process that failed to meet international safety standards and recommendations produced by the International Atomic Energy Agency, of which Canada is a member state.

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

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

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

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

Proximity to contaminated structures being demolished at the Chalk River Laboratories — not safety or environmental protection — appears to have been the priority is choosing the site of the NSDF.

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

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

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

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

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

Original site selection criteria announced by the proponent would have excluded any site with more than a 10% slope. This criterion was changed to 25% to allow CNL’s desired site (Ref: Near Surface Disposal Facility Site Selection Report 232-10300-TN-001 Revision 2. Oct. 2016).  In face, the proposed NSDF site was rejected as a site for VERY LOW LEVEL RADIOACTIVE WASTE due to its slope and exposed bedrock, back in the days before privatization of the the Chalk River Laboratories.

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

The proposed NSDF site is on a hillside, over fractured rock, with a high water table, surrounded on three sides by wetlands that drain into Perch Lake 50 metres from the base of the hill. Perch Creek flows from Perch Lake into the Ottawa River, one kilometre away.  The entire Chalk River Laboratories property — with its proximity to the Ottawa River, high groundwater table, uneven terrain, and fractured bedrock — is a very poor location for permanent radioactive waste disposal. 

Chalk River Laboratories

MEDIA RELEASE: Nuclear regulator’s case to approve giant nuclear waste mound is fraught with serious errors and omissions, citizens’ groups say

OTTAWA, February 22, 2022 – Citizens’ groups from Ontario and Quebec provided Canadian Nuclear Safety Commission (CNSC) President Rumina Velshi with a searing critique of CNSC’s case to approve a giant radioactive waste mound alongside the Ottawa River in advance of a February 22nd hearing.

If approved, the giant landfill would stand 60 feet high and hold one million tonnes of mixed radioactive and hazardous wastes. Some of the contents would remain dangerously radioactive for thousands of years, but the mound itself is only expected to last a few hundred years according to studies produced by the proponent, Canadian Nuclear Laboratories, owned by a consortium of multinational corporations. International safety standards prohibit disposing of long-lived radioactive wastes in landfills.

The citizens’ critique of key licensing documents found eleven critical flaws ranging from a failure to provide detailed information about what would go into the dump, as required under the Nuclear Safety and Control Regulations, to a failure to note serious deficiencies in the siting process for the facility.

“You couldn’t find a worse site for this dump if you tried,” said Johanna Echlin of the Old Fort William (Quebec) Cottagers’ Association, one of the groups that co-authored the citizens’ critique. “The site is on the side of a hill, and is surrounded on three sides by wetlands that drain into the Ottawa River, a kilometre away. The water table is just inches under the surface at that location and the bedrock is highly fractured.” 

The site of the proposed facility is also of concern to downstream communities who take their drinking water from the Ottawa River, including Ottawa, Gatineau and Montreal. The three cities are among the more than 140 municipalities that have passed resolutions of concern about the proposed dump. The Assembly of First Nations has also passed a resolution opposing the facility.

Ole Hendrickson, a scientist and researcher for the group Concerned Citizens of Renfrew County and Area said there are a number of serious errors in the licensing documents including a 1000-fold overestimate of radioactivity in nearby uranium ore bodies. “That gross overestimate is used by the proponent and the regulator to make the case that the giant mound would be less radioactive than surrounding rocks after a few hundred years,” Hendrickson said.  “In fact, high-radioactivity waste containers in the dump would exceed levels in surrounding rocks for thousands of years.”

The Quebec-based Ralliement contre la pollution radioactive contributed a number of findings to the critique. The group is very concerned about the presence of cobalt-60, which alone will provide 98% of the initial radioactivity in the dump, even though its radioactivity will decline rapidly thereafter. Used cobalt-60 sources require lead shielding because they emit intense gamma radiation that endangers workers. 

Physicist Ginette Charbonneau, a spokeswoman for the Ralliement, says that only low-level cobalt-60 sources could be accepted in an above-ground mound and that the criteria for accepting such waste in the dump must be tightened.

“It is also out of the question that long-lived radioactive substances like plutonium be disposed of in a landfill,” Charbonneau said. “This is simply a senseless proposal, which is not in line with international standards at all,” she added.

The citizens’ groups say the case to approve the giant radioactive landfill, called the NSDF by the proponent, is so seriously flawed that CNSC Commissioners cannot make a sound licensing decision based on the contents of the documents. They have asked that the citizens’ critique be distributed to Commissioners at the hearing on Feb 22 and that all of the flaws, errors and omissions be fully addressed before the Commission is asked to make a decision on the license for the dump. 

The licensing hearings for the giant radioactive waste dump will take place in two parts. Part 1 will take place February 22.  Part 2 will start on May 31, but is expected to take several days as it will include presentations from Indigenous communities, municipal representatives, NGOs and members of the public. Requests to intervene in the hearings must be submitted in writing to the CNSC by April 11, 2022.  See Notice of Public Hearing for details.

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Graphic above from Radio Canada Découverte, March 2018, showing the mound overflowing as part of the degradation and erosion process, described by the proponent in its Performance Assessment report.