Posted: January 18, 2024
Construction of the NSDF at Chalk River is approved: what does this mean?
Government regulators have approved the construction of a Near Surface Disposal Facility at Chalk River. We explore the ongoing technical and procedural concerns with the project, what this decision means, and where this leaves us.
Chalk River Laboratories, located about 200 km upstream of the City of Ottawa on the banks of the river, has been host to extremely concerning and persistent issues with radioactive waste since the 1950s. There is no question that the legacy waste currently stored at Chalk River poses a danger to the river and must be dealt with in the most robust and rigorous way possible.
On January 8th, the Canadian Nuclear Safety Commission (CNSC), the federal government regulator on radioactive waste, announced that construction would proceed on the hotly-debated Near Surface Disposal Facility (NSDF) first proposed in 2016. We have many concerns with both the technical and procedural aspects of the project in its current state.
Concerns with the NSDF Proposal
Ottawa Riverkeeper has engaged on this issue since the NSDF was first proposed, having voiced our concerns with the project and the process on several occasions. One major procedural concern is the assertions from Anishinābeg Algonquin communities that there have not been adequate consultations on the project, which we have echoed here.
In addition, we have investigated the technical aspects of the NSDF to ensure that the final solution is technically robust to protect freshwater ecosystems and the people who rely on them. In May 2022, Ottawa Riverkeeper officially intervened on the project proposal as part of the CNSC’s public hearings. While improvements have been made to the design and the oversight process, Ottawa Riverkeeper calls for the project in the final decision to be strengthened further. We’ve outlined our other concerns below.
Location of the NSDF
The selected location of the NSDF has been questioned by numerous groups. While Canadian Nuclear Laboratories (CNL) selected a site that met their requirements from within the properties owned by Atomic Energy of Canada Ltd, alternative locations were not included in their selection process.
The proximity to the Ottawa River is one of the primary reasons the location has been scrutinized. The flow of groundwater in this area has been well studied due to the presence of legacy waste that is being monitored. We know that groundwater flows very slowly into Perch Lake and the adjoining Perch Creek, taking years, which is one of the reasons this location was selected, as CNL feels confident that this additional time would allow for them to be able to address any unexpected contamination should this occur. The location also slopes away from the Ottawa River and towards Perch Lake. The flow of surface water is much faster than groundwater and therefore it is worth noting that should there be unexpected or unforeseen contamination to either Perch Lake or Perch Creek, this only provides a small buffer of protection for the Ottawa River.
Wilf Ruland, an experienced hydrogeologist, described the geology of this location as unfavourable for this type of facility in a report provided to Ottawa Riverkeeper as part of our submission to the CNSC. Ruland found that these unfavourable conditions had been alleviated through engineered features, but the question remains why alternative sites were never even considered.
Waste-water Treatment Plant
The waste-water treatment plant (WWTP) for the NSDF is designed around a process which has shown promise in pilot studies. However, when examining the design and wastewater treatment proposed for the NSDF, Dr. Banu Örmeci, the Jarislowsky Chair in Water and Health and the Director of the Global Water Institute at Carleton University raised concerns about how the treatment plant would perform.
In her report to Ottawa Riverkeeper as part of our submission on the NSDF, Dr. Örmeci advocated for the more robust and proven treatment of reverse osmosis. This has not been included in the initial construction of the WWTP. This is taken into account in the decision on pages 18 and 19, which state that should the current design fail to treat leachate from the NSDF as expected, “the treatment process for the WWTP could be changed based on the characteristics of the leachate and that there will be space in the WWTP to install additional equipment if required.” Unfortunately, this may take time and additional funds to install. Once again, Ottawa Riverkeeper questions why these protections are not provided at the outset to ensure that the leachate is treated as thoroughly as possible.
Ongoing monitoring
Another area of concern that Ottawa Riverkeeper raised in our intervention was whether the ongoing monitoring outlined within the proposal was adequate. Not only will low-level radioactive waste be stored in the NSDF, but chemical contaminants such as aluminum, cobalt, iron, and phosphate will also be included, and all are estimated to be present in quantities above their respective effluent targets. As Ruland points out, “chemical potency will necessitate longer-term explicit planning and assessment than has been provided in the final EIS and its supporting documents.”
Included with the CNSC decision is the 2021 Draft Environmental Assessment Follow-Up Monitoring Program for the Near Surface Disposal Facility (EAFMP) which the CNSC has written, and which will need to be finalized now that construction of the NSDF has been authorized. The CNSC also noted in its decision that “the opportunity remains for direct involvement in the development and implementation of the EAFMP” and that “CNL will be required to finalize and implement the EAFMP for the NSDF Project in consultation with Indigenous Nations and communities, and relevant regulators.”
In our intervention, Ottawa Riverkeeper emphasized the importance of ensuring that there are opportunities to review and provide feedback on this draft monitoring program. A robust process is required to confirm that the monitoring activities are addressing the concerns raised by the many intervenors from throughout the watershed. This should be considered for the immediate future, but importantly also for the period after the NSDF has closed, including the ‘institutional control period’ of 300 years as well as throughout the ‘post-institutional control period’, which is scheduled to begin in 2400. Given the type of materials present and the length of time for which they can pose an environmental risk, long-term monitoring will provide critical data and allow for mitigation as needed.
Where does this leave us?
Legacy waste exists at the Chalk River site and must be dealt with to protect human and ecological health. The Ottawa River, a mere 1.1 km away, is rich in biodiversity and provides drinking water for more than 2 million people. Once it flows into the St Lawrence near Montréal, that number jumps by an additional 5 million people who rely on freshwater from this river.
The NSDF proposal is intended to store 1 million m3 of waste, 90% of which is “waste currently in storage at the [Chalk River Laboratories] site, waste generated during environmental remediation and decommissioning activities at the [Chalk River Laboratories] site, and expected future waste resulting from ongoing CNL operations” Throughout the licencing of this project there have been incremental improvements to the original proposal. Ottawa Riverkeeper believes improvements to this proposal are needed to ensure it is technically robust. These include the improvements we have outlined above, which should be added to the project to better safeguard the environment and freshwater.
Over the past 7.5 years, there have already been several changes to this project, thanks to the advice of intervenors in the public hearings. One such improvement to the original proposal was to limit the facility to only low-level waste and to exclude intermediate-level waste. Another improvement involved the installation of a physical cap to the facility while it is being filled (similar to what is done in the Centre de l’Aude in France) to protect it from the elements, rather than waiting until after it has been filled (an estimated 50 years) before capping it. The efforts of intervenors have therefore already drastically improved the project from its initial proposal.
In its decision, the CNSC has put in place novel steps for further review as the project advances. The current license is only for the construction of the NSDF Project and does not include authorization to operate the NSDF. To operate the NSDF, an additional license application will have to be authorized by the CNSC. While it seems highly improbable that the NSDF would be constructed and then never used, the approval process for the operation of the NSDF may provide new opportunities for public comment and oversight, which has the potential to create further improvements to the project at that time.
We are disappointed that the project has been given the go-ahead despite major concerns around inadequate consultation with Anishinaabeg Algonquin communities and without including the full extent of improvements we have advocated for. Ottawa Riverkeeper remains committed to monitoring developments at the Chalk River site and actively pursuing opportunities to establish the highest level of safeguards for freshwater.
There is a fundamental problem associated with all radioactive sites. That is the proclivity on the part of the nuclear industry to use the fact that some waste has already contaminated a specific location to excuse the continued use of that location for additional activities and waste disposal. This is, in fact, the rational for using the Chalk River location for a storage facility in the first place. The desire to mitigate the existing problem enables the thinking that the problem can legitimately be enlarged. Not so!
Boy Scouts are taught not to locate their latrines upstream from their source of drinking water. No amount of rational discussion by people with high foreheads can alter the fundamental stupidity and poor planning which has already taken place. This is not about ‘near surface disposal’ but more accurately about ‘disaster mitigation’ of fundamental mistakes perpetrated by the nuclear industry over many decades. Any ultimate agreement reached with the proponents of this facility must ensure that no further waste will be permitted to be imported into the watershed and that every conceivable measure to protect the river be included.
People with a vested interest in the nuclear industry should not be permitted to direct ultimate decision making. This problem extends beyond the next seven generations and our thinking must reflect not the wistful promise of nuclear power but the awesome danger which it represents!
I am very concerned that the Ottawa Riverkeeper is repeating CNL’s and CNSC’s endless LIE that only low-level waste will be included in the NSDF. CNL/CNSC have only conveniently changed the definitions of low and intermediate level waste – but it remains that very long lived radionuclides will be going into this above ground facility and will certainly leak into the Ottawa River. At best with great luck, the mound may contain the radioactive waste for a few hundred years but not for the thousands and thousands of years that some of this waste will remain radioactive and harmful to the Ottawa River. The truth about what will be placed in the dump must be told.
To everyone visiting the ORK web site and concerned about protecting the water quality and aquatic biodiversity of the Ottawa River:
In this decision making process it’s time that we listen to common sense and follow the precautionary approach taught in many conservation biology classes. As a community, we want to safeguard the water supply of over 5 millions residents (and growing). Isn’t that important ? It’s thus time that we think carefully about any proposal for waste sites and that we follow some basic wisdom before considering locating such a volume of nuclear waste a mere one kilometer from the Ottawa River. It is also time we listen to what First Nations wisdom offers us. It is not ecologically sound to place huge piles of waste, especially nuclear wastes, next to our water supply, whatever the technology proposed. For the sake of the 7 generations of citizens to come, and those after them, it is crucial that our governments and decision makers use wisdom and the precautionary approach and not build this waste site next the river. It is most important also to think of the incredible aquatic biodiversity of the area. Indeed, the area where the nuclear waste site is proposed at Chalk River is part of an Ottawa River segment that includes unique river habitats, including a rich fish and freshwater mussel community that is unequal in the watershed. That river segment goes from Rapides-des-Joachim (next to Rolphton dam) to the Rocher Fendu at Portage du Fort; that 142 km river segment with near natural flow (no hydro dam), including many rapids where Lake Sturgeon spawn, deserves SPECIAL PROTECTION if we want to conserve the extraordinary aquatic biodiversity found in that area. That regions includes Canada’s largest known underwater cave network inhabited by a stunning fish and freshwater mussel fauna. In that area populations of the Lake Sturgeon and of the rare Hickorynut mussel cohabit and are thriving. The proposed nuclear waste site at Chalk River will, for centuries to come, represent a serious risk to not only millions of humans who depend on the water quality of the Ottawa River water, but will also represent an unacceptable risk to the Ottawa River aquatic ecosystem and its biodiversity. It’s time to listen to common sense and take a precautionary approach to safeguard the community’s water well. In the spirit of reconciliation and of ecological wisdom this waste site must be placed far away from our water source, the Ottawa River.
Thanks for your support. André L Martel — aquatic biologist, research scientist and scuba diver with three decades of experience studying the Ottawa River aquatic biodiversity