May 8, 2017
Johanna Echlin
Ms. Nicole Frigault, Environmental Assessment Specialist Canadian Nuclear Safety Commission P.O. Box 1046 Station B 280 Slater Street Ottawa, Ontario K1P 5S9
Via e-mail: cnsc.ea-ee.ccsn@canada.ca
Dear Ms. Frigault,
Re: Comments on CNL’s Proposal for a Near Surface Disposal Facility (NSDF) at Chalk River Laboratories (EIS March 2017)
On behalf of Old Fort William Cottagers’ Association (OFWCA), I am sending the CNSC our comments regarding CNL’s proposal and draft environmental impact statement (EIS). We appreciate having this opportunity to voice our concerns and objections which are in Appendix A. Opposition resolutions passed by OFWCA and a number of Municipalities along the Ottawa River are in Appendix B. Our unanswered questions can be found in Appendix C. Appendix D and E contain correspondence with CNL and the CNSC respectively.
We trust that CNSC will consider our views seriously. Our community is just downriver from Chalk River.
For two major reasons, CNL’s proposal should not be allowed to proceed as it now stands. Both the location and the type of facility are seriously in question.
1. A disposal facility for radioactive waste should never be placed a kilometre away from the Ottawa River. Alternative locations at least 25 km from the river must be researched.
!1 2. Radioactive waste with long-lived radionuclides should never be disposed of in a landfill or in a near surface facility and this is CNL’s intention. This is entirely unacceptable and does not follow international guidelines. Alternatives for disposal or for storage need to be investigated. Only radioactive waste with very short half-lives, in another location, would be acceptable in the proposed engineered containment mound.
The classification system that CNL uses does not conform to international standards. Very hazardous radioactive materials with long half-lives are hidden in waste types (such as “demolition waste” and “soil”). Their system only confuses and makes evaluation nearly impossible. CNL must comply with International Atomic Energy Agency classifications.
CNL’s plan to bring all of Canada’s federally owned radioactive wastes from other areas of the country to Chalk River for disposal or storage is unacceptable. Our community and a number of municipalities are completely in opposition to any radioactive waste coming to Chalk River, either for storage or disposal, from any other location.
Good options for the legacy wastes now in interim storage at Chalk River must be determined. Placing them in the Engineered Containment Mound, which is the equivalent of a municipal landfill, is not a suitable plan and does not meet international standards.
CNL’s approach to “informing” local communities about their proposal has been insufficient. CNL dismisses concerns. They have not answered our questions sent to them in January. They have provided Quebec with an EIS in English. Their ads and interviews are deceptive. CNL’s strategy is to persuade their audience that all is proven and safe.
We rely on the CNSC to act as an independent watchdog. CNSC must protect our environment and all the people living along this river from a disastrous situation in the future. This could devastate a huge area of the country for generations.
A rigorous environmental assessment is required. We count on the CNSC to do the right thing.
Sincerely yours,
Johanna Echlin
!2 Table of Contents
Old Fort William Cottagers’ Association
Covering Letter to CNSC Pages: 1-2
Appendix A: Comments, Objections and Concerns Pages: 5-18
Appendix B: Resolutions List of Resolutions Pages: 20-21 Resolutions Pages: 22-31
Appendix C: Additional Questions with Respect to the Proposed Activities at the Chalk River Laboratories Site - January 24, 2017 (never answered by CNL) Pages: 32-41
Appendix D - 1: Correspondence Between OFWCA & CNL List of Correspondence 2016 Page: 42 Correspondence Pages: 43-64
Appendix D - 2 Correspondence Between OFWCA & CNL List of Correspondence 2017 Pages: 65 Correspondence Pages: 66-97
Appendix E: Correspondence Between CNSC & OFWCA List of Correspondence 2017 Page: 98 Correspondence Pages:99-105
!3 Appendix A
Old Fort William Cottagers’ Association
Comments, Observations, and Concerns
A.1 Resolutions Pages: 5-7 Opposition OFWCA’s resolution Municipal resolutions Petawawa Point Cottagers’ Association opposition
A.2 Public engagement Pages: 7-9 Unanswered questions - OFWCA requests answers to all questions submitted CNL information sessions insufficient CNL information deceptive CNL announced decisions without any public engagement
A.3 Engineered containment mound (ECM) Pages: 9-12 ECM comparable to a landfill Identification of radioactive wastes needed ECM unacceptable for hazardous materials with long-lived radionuclides CNL must adhere to international radioactive waste classifications CNL must provide comprehensive inventory Basic questions need answers A.4 Alternative disposal and storage options must be investigated Page: 12
A.5 Chosen location cannot be justified Page: 12
A.6 Radioactive and other contaminants will end up in the Ottawa River Pages: 13-15 Leaks inevitable CNL must answer many questions A.7 Alternative locations must be investigated Page: 15
A.8 Impact on Employment and economic prosperity Page: 15-16
A.9 Study required re: cancer and birth defects Pages: 16-17
A.10 Concerns about GoCo model Page: 17
A.11 Conclusion: Page: 18 A message from OFWCA to CNL, CNSC and the nuclear industry
!4 Appendix A
Old Fort William Cottagers’ Association
Comments, Observations, and Concerns
Old Fort William Cottagers’ Association (OFWCA) at Fort William, in the Municipality of Sheenboro, Pontiac, Quebec is about 15 kilometres downriver from Chalk River. OFWCA includes both seasonal and year round residents.
At the July 2016 annual general meeting of OFWCA, our members first learned of CNL’s (Canadian Nuclear Laboratories) March 2016 proposal for a Near Surface Disposal Facility (NSDF) for radioactive waste. The proposed facility, to be located on the Chalk River Laboratories (CRL) site, is to permanently dispose of one million cubic metres of radioactive wastes. CNL’s plans include bringing radioactive waste from other places in Canada for disposal in this facility in addition to the waste already in interim storage on the site.
OFWCA formed a sub-committee with the mandate to investigate CNL’s proposals. As Fort William and Sheenboro are the first communities, downriver from CRL on the Quebec side, we are particularly concerned about any and all proposals, plans and activities that are taking place and are being considered for the future. Our community is legitimately worried about any potential impacts to our health, safety and wellbeing. Past, present, and future activities affect our community as the Chalk River site is next to the Ottawa River upon which our community depends.
Resolutions
Opposition to Chalk River becoming a radioactive waste dumping ground for nuclear waste from other sites We know from CNL that at least 5% of the radioactive waste destined for this disposal facility will come from Whiteshell, Manitoba and from NPD in Rolphton, Ontario. Another 5% will come from other locations outside of Chalk River. Radioactive waste will come from Port Hope and Douglas Point, Ontario and Gentilly 1, Quebec and from CNL’s future decommissioning activities. Radioactive waste will also be accepted for disposal in the Engineered Containment Mound (ECM) on a commercial basis, including from universities and hospitals (CNL Responses Dec.16/2016 p.58 & EIS 3.2.1.1 & 2.3).
At least 10% of one million cubic metres of radioactive waste and other mixed wastes will come from outside Chalk River for disposal. 10% is 100,000 cubic metres. This is no small quantity - even though CNL repeatedly tries to present it to everyone as just a small amount. (100,000 cubic metres is like a 15 storey building or 40 Olympic swimming pools.) In fact, it has been
!5 confirmed to OFWCA by experts reading CNL’s draft environmental impact statement (EIS) that CNL intends to bring all of Canada’s federally owned radioactive wastes (excluding radioactive wastes that have been disposed of in-situ at Whiteshell and Rolphton) to Chalk River for disposal in the ECM. CNL also plans to transport high-level fuel waste from Whiteshell to Chalk River for storage (not disposal). (EIS 3.2.1.1 & 2.3.)
OFWCA and a number of Municipalities are completely against this plan to import waste for permanent disposal or for storage from other areas outside Chalk River. These communities want to prevent this from happening. We all say “no more waste coming to our river!” Not from Whiteshell, not from Rolphton, not from any other location. Radioactive waste should be dealt with locally and not transported. If it must be transported it should not be sent to a location on a major body of water.
OFWCA members fully understand that Canada must adopt a long-term plan for the radioactive waste that has accumulated on the Chalk River site for more than half a century. We in no way suggest sending it somewhere else. But we find it unacceptable either to store or to permanently dispose of radioactive material from other parts of the country next to the Ottawa River.
OFWCA voted upon and adopted the following resolution in July 2016:
OFWCA strongly objects to Chalk River (CNL) receiving and accepting radioactive waste and any other waste from another site outside the Chalk River facility. Disposal of radioactive waste and any other waste must be limited to Chalk River’s current levels of generated radioactive waste.
Between December 2016 and the present, the following Municipalities and Townships have passed resolutions supporting OFWCA and opposing any radioactive waste or any other waste coming to the Chalk River site from any location outside this site:
Municipality of Sheenboro (Pontiac) December 16, 2016 Municipality of Clarendon (Pontiac) January 12, 2017 Municipality of Bristol (Pontiac) March 6, 2017 Canton de Lochaber (Papineau) March 13, 2017 Township of Alfred and Plantagenet (Ontario) April 2, 2017 Municipality of Campbell’s Bay (Pontiac) April 7, 2017
The Municipality of Canton de Lochaber’s (Papineau) resolution is in opposition to the entire NSDF as proposed by CNL.
(See Appendix B pages: 20-31 to find a listing of the resolutions and copies of each resolution.)
Petawawa Point Cottagers’ Association (PPCA) has just recently been formed with the primary purpose of opposing CNL’s entire proposal for an NSDF. PPCA is also opposed to any additional
!6 radioactive waste coming to the Chalk River site. They will vote on a resolution this summer when their members are all on the river.
In July 2016 when OFWCA passed the above-mentioned resolution, members did not know what the CNL proposal for an NSDF entailed. But they objected to CNL’s plan to bring more radioactive waste and other waste from different areas of the country. Now, nearly a year later, and after much study and research about the proposal for an engineered containment mound (ECM), our members will consider adopting a different and stronger resolution at our next annual general meeting in July 2017. OFWCA has invited CNL to come to Fort William to answer questions before any vote is taken. CNL has agreed to come in July.
Public Engagement
65 Unanswered Questions. In the EIS, it is stated that “detailed written responses to stakeholder questions” is one of the communication tools that CNL developed to “effectively and meaningfully communicate with stakeholders for the NSDF Project” (EIS p.186, 4.3.1). And “Old Fort William Cottagers’ Association: In response to a letter provided as feedback at public information session held in Sheenboro, CNL prepared detailed answers to a number of questions raised by a community group of seasonal residents, the Old Fort William Cottagers’ Association” (EIS p.193, 4-9, 4.3.1.1.10). In the Appendix (4.0-21 p.Z-1) the EIS displays these questions and answers. OFWCA submitted written questions to CNL in person in Sheenboro on October 20th (pp.43-46). And yes, OFWCA did receive detailed answers from CNL two months later on December 16th (pp.47-63).
These answers triggered further questions. OFWCA sent these additional questions and others that had arisen (approximately 65 in all) to CNL on January 24, 2017 (Appendix C pp:32-41 for unanswered OFWCA Questions in an easily readable format or Appendix D-2 pages: 66-86). Receipt was acknowledged. However, in spite of repeated reminders, as of May 8th, no answers have been received. There is no mention anywhere in the EIS about these unanswered additional questions. Is CNL simply unwilling to answer our questions? Are they unable to answer them? Would the answers reveal more than CNL wants to reveal? We are missing valuable information. We are left with huge concerns.
OFWCA is requesting answers to all questions submitted to CNL on January 24th.
Information Sessions are not sufficient. The EIS declares that CNL has been engaging the public. On the surface it might appear this way. However, OFWCA’s perception is different.
There were three scheduled information sessions in two communities in Quebec: Rapides-des- Joachims and Sheenboro. Two locations and six information sessions in one year in the entire province of Quebec is not sufficient. Why were there no sessions further downriver (Shawville, Fort Coulonge, Campbell’s Bay)? There were five locations in Ontario, each with three sessions.
!7 Was Quebec short-changed? Quebec lies on one entire side of the Ottawa River and could be impacted by whatever happens at Chalk River. Nearly all CNL information is in English (at least until May 8th). How are francophones to become informed and engaged in this environmental assessment process and provide any sort of critique or comment during this “public comment” period?
Unfortunately all three sessions in Sheenboro were during off-season when only our resident members could attend. OFWCA has requested that CNL come to the Fort to meet with OFWCA. CNL has agreed to come on July 15th.
Did people leave information sessions with a comprehensive view of the proposal? The information sessions were poster board sessions with no formal presentation by CNL. People could come and go. People in one grouping do not hear what is being said somewhere else. This does not provide an opportunity for people to learn from others’ questions. Is this the CNL strategy – to keep people from asking or learning too much? Many who attended the sessions last June and October, did not sign in or register their concerns, not realizing that then they would be left out of CNL’s “statistics”. So, how meaningful are CNL’s statistics in this EIS (EIS p.188 Table 4.3.1-1 and Appendix 4.0-22 Public Feedback)?
It is our impression that people were provided with little information of consequence unless they asked very specific questions. But doesn’t one need to understand the subject before one can ask good probing questions? CNL did not go out of their way to describe the very real potential dangers of this radioactive waste disposal. People often left these sessions not knowing much more than when they arrived. These information sessions were geared to convey that all CNL’s plans are proven, perfect, safe and according to regulations.
How much impact has CNL’s information made on the public? CNL could say that people are fine with their plans but it is more likely that people just do not know and have not understood what their plans are. A surprising observation is that there are still people in the area who do not have any idea that CNL has a proposal let alone for what. We have heard repeatedly from people that they had never heard a word about it until recently when articles regarding opposition appeared in local journals. And now they are faced with a deadline. And many are only just beginning to listen.
A decision was announced without public engagement. It was July 2016 before many had heard a thing about CNL’s proposal. There was no public debate about the best solutions for the legacy of radioactive waste that currently exists at Chalk River. A decision was already taken without the input from anyone in the Valley let alone the communities right next door to this site at Chalk River. Having just months to figure out this complex plan and to react in some thoughtful way is what is upon us. It is a challenge. A challenge that is so important to the future of our beloved river and to all those living and depending upon it. Why wasn’t the whole Valley engaged in the process of decision making?
!8 In an article in the Pontiac Journal (March 29), Fred Ryan expresses the sentiment in our area very well – what is this thing they are doing? what’s it all about? there’s a deadline? who are we supposed to comment to? Hasn’t it already been decided and it’s on a fast track to begin construction? Aside from saying that the mound will be18 feet high (vs. 20-25 metres), Fred Ryan has it exactly right. http://pontiacjournal.com/column/chalk-river-what-could-go-wrong
Heads are spinning. It feels like a steam roller is coming upon us and there is no way to stop it. Living through this process to this point, we might also state that the environmental process badly needs reform.
CNL’s ads and interviews are deceptive. Their full-page ad (in nearly every paper and journal in April) conveys that all is proven and safe. It provides half-truths. CNL presents the disposal facility through rose coloured glasses. The illustration of the mound itself makes it look like a golf-course – or a nice flat grassy place to have a picnic maybe. It is going to be about 25 metres high – how can it appear flat? To simplify this radioactive waste disposal facility in such a fashion is deceptive. And it is not only their ads, they repeat the same refrain in their interviews – all is proven, safe, only a tiny amount of intermediate-level waste will go in, only a very small amount of radioactive waste will come from other areas etc. As CNL’s waste classification system does not match those of the International Atomic Energy Agency, it is difficult to determine much about the radioactive wastes that they intend to include. Hiding behind percentages and classifications that are not consistent with international standards is not being transparent. To repeat “safe” one hundred times in the EIS does not make it safe. This repetitive tactic of CNL’s has left many of us feeling distrustful of it all.
Engineered Containment Mound (ECM)
CNL calls the proposal a Near Surface Disposal Facility which includes the Engineered Containment Mound (ECM), the leachate collection system, the Waste Water Treatment Plant (WWTP), several leachate collection ponds, and other service buildings. The ECM itself will be enormous covering almost sixteen hectares and will be 20-25 metres in height (CNL Responses Dec.16/2016 p.58). The ECM is projected to contain one million cubic metres of radioactive waste by the year 2070. This ECM will be the first disposal facility for radioactive waste in Canada. Canada has never licensed such a facility before. The CNSC has never established regulations for a permanent disposal facility.
As the ECM will be 20-25 metres high, the name “near surface disposal facility” is inappropriate. CNL claims over and over again in the EIS, in ads and in interviews that this ECM is “proven technology”. However, after examining the particular sites provided by CNL as evidence, a number of experts have concluded that these facilities are in no way comparable to CNL’s ECM. First, none of these other facilities are mounds. Radioactive waste, in these other sites, are often in containers which provide cover from precipitation and shielding for the
!9 protection of workers and public. None of these facilities are on bodies of water. One is in the desert. Also what might be “proven” or “effective” in one area may have an entirely different impact if placed next to a major river.
CNL’s ECM is more closely comparable to a municipal landfill - a near surface landfill type facility as described by the International Atomic Energy Agency (IAEA) - than to any of the facilities for the disposal of radioactive waste cited by CNL.
CNL must provide comparable examples of mounds - or near surface landfill type of facilities - that are used as repositories for low and intermediate-level radioactive waste. Fifteen to twenty years of successful operation is not a sufficient period to justify CNL’s claim of “proven”.
Information about the quantity and the identity of all radioactive wastes must be made available by CNL. Initially, the project description indicated that only low-level waste (LLW) would be placed in the ECM. In October, CNL changed the project description to include intermediate-level waste (ILW). CNL often claims in ads and repeatedly in the EIS that there will only be a very “tiny” amount of intermediate-level waste – 1% CNL states. Mixed radioactive wastes (which could include mercury, PCBs and arsenic) will also be 1%. Hiding facts behind percentages is deceptive. 1% of the total is 10,000 cubic metres of intermediate level waste and 10,000 cubic metres of mixed wastes — these are not small amounts.
According to the International Atomic Energy Agency a landfill - which is what is being proposed by CNL for the ECM - is only suitable for very low-level radioactive wastes with short half-lives of no more than a few centuries. Even a near surface disposal facility - which is not what is being proposed - is not recommended for disposal of intermediate-level wastes that can be hazardous for hundreds of thousands of years. Intermediate-level wastes require a stable geological environment (IAEA 2011 Safety Standards Series SSR-5, http:// www-pub.iaea.org/MTCD/publications/PDF/Pub1449_web.pdf).
The fact that CNL does not adhere to IAEA waste classifications presents additional problems. CNL should be required to adhere strictly to international radioactive waste classifications, otherwise there is no way to understand what they are planning to include in this ECM. Some very hazardous materials with long-half lives can be included under low-level radioactive wastes. CNL must provide a comprehensive inventory of all wastes to be included in the ECM (low-level and intermediate-level waste) using the IAEA classification.
Hazardous radioactive wastes should not be exposed to the elements as will happen in the ECM (until the final cover is in place). A one-page document prepared by Dr. Ole Hendrickson, of Concerned Citizens of Renfrew County and Area (CCRCA) describes how CNL has flaunted IAEA guidelines (http://tinyurl.com/kks8lnn).
CNL has provided few details about the intermediate-level waste that they intend to dispose of in this facility. They claim that the ILW to be included will have short half-lives and will conform to the Waste Acceptance Criteria (WAC). However, the WAC is not available. CNL is still
!10 developing this criteria. How does CNL design this facility without knowing precisely what will be placed in it? More information about low-level radioactive wastes is also needed as some of these wastes may have very long half-lives and could be extremely harmful. CNL must conform with IAEA classifications in order for the EIS to be reviewed.
According to the EIS, all the radioactive wastes that are in storage now at Chalk River and all of Canada’s other federally owned radioactive wastes are destined for disposal in the ECM (with the exception of radioactive wastes that have been disposed of in-situ at Whiteshell and Rolphton and high-level fuel wastes and reactor vessels). Experts are well aware that these wastes include some highly toxic and long-lived radionuclides that will be hazardous for centuries. Instead of using the IAEA waste classifications (low-level, intermediate-level, high-level) in Table 3.2.1-1 of the EIS (p.112), CNL describes waste types and the volumes of each type of waste that will end up in the ECM ––– for example: soil and soil-like waste - 370,000 cubic metres, decommissioning and demolition waste - 390,000 cubic metres, co-mingled debris - 80,000 cubic metres, packaged waste - 150,000 cubic metres, miscellaneous waste - 10,000 cubic metres, etc.. Somewhere in these wastes is the 1% intermediate-level radioactive waste and also some low-level wastes with very long-lived radionuclides. But where? These hazardous wastes are hidden. This system is deceptive and CNL needs to recategorize this radioactive waste. So many questions arise due to this and many of these questions were addressed to CNL in OFWCA’s January 24th additional questions which remain unanswered. (See Appendix C pages: 32-41 for unanswered OFWCA Questions in an easily readable format. See Appendix D-2 pages: 66-86 January 24, 2017 Correspondence Between OFWCA & CNL.)
Each of these volumes should be broken down and re-characterized in order to conform to international standards. Each waste should indicate whether they have short-lived or long-lived radionuclides. Each type of waste in Table 3.2.1.1 of EIS may contain hazardous wastes. Demolition waste is not just one classification. Buildings on the CNL site contained some very radioactive materials. How will CNL separate and dispose of demolition debris and provide shielding and protection of workers? The same applies for soils on the Chalk River site, much of which are heavily contaminated. Will CNL simply pack less harmful wastes around wastes that are hazardous to provide shielding to workers and the environment? How will workers be protected from radiation? These wastes will be unprotected from precipitation until the final cover is in place. This is certainly not up to international standards.
When we go to our municipal dump in Sheenboro we must separate all our garbage. Items that are hazardous to the environment such as paint, chemicals, batteries must be separated from all the other categories of waste (e.g. metal, cans, glass). We do not just dump everything together as “household waste”. It does not appear that CNL is even doing this basic categorization for radioactive wastes to be disposed of in this ECM.
How can CNL justify placing any of these radioactive materials in the ECM? The EIS Table 5.7.6-1 (p.720) “Bounding NSDF Project Waste Radionuclide Inventory to be Placed in ECM” lists radioactive materials which have very long-lived radionuclides that will be placed in the ECM. Fissile materials such as plutonium-239 and uranium-235 are included. Dr. Ole
!11 Hendrickson (CCRCA) and Dr. Gordon Edwards, of Canadian Coalition for Nuclear Responsibility, have prepared a table with these same radioactive materials indicating their half- lives. Most of these radioactive materials have half-lives of hundreds of thousands of years and even millions of years. For example, uranium-235 has a half-life of 704 million years (http:// tinyurl.com/n6lr89h). Placing radioactive wastes such as these in the ECM cannot be justified. This ECM is not adequate for radioactive wastes with half-lives of thousands, hundreds of thousands and millions of years.
CNL must answer these basic questions: -How will CNL keep track of the inventory of different wastes? -How will CNL specifically limit ILW and mixed wastes to 1% each? -How will the radioactive wastes be categorized and separated? -How will CNL ensure that wastes meet the WAC? -What is CNL’s justification for placing wastes with half-lives of thousands, hundreds of thousands and millions of years in the ECM? -How could CNL then say the environment and people will be safe?
Alternative disposal and storage options must be investigated
An alternative option for disposal is a shallow cavern. The IAEA recommends that intermediate-level waste be emplaced in a “facility constructed in caverns, vaults or silos at least a few tens of metres below ground level and up to a few hundred metres below ground level” (IAEA 2011 Safety Standards Series SSR-5, http://www-pub.iaea.org/MTCD/publications/ PDF/Pub1449_web.pdf). An option such as this should be investigated in a location at least 25 km away from the Ottawa River and away from wetlands, lakes and creeks.
Monitored Retrievable Storage or “Rolling Stewardship” is an another option. Rolling Stewardship is an alternative that CNL has not investigated and it should be considered. This provides long-term monitoring. The waste is retrievable. Any leaks can be detected and repaired. Decisions can be reversed. The waste is contained. Information and responsibility are transferred from one generation to the next (Dr. Gordon Edwards “Rolling Stewardship” http:// www.ccnr.org/Rolling_Stewardship.pdf). This system may be more expensive in the short-term but may save the environment and the health, safety and wellbeing of all on the river. The chosen site should not be next to a body of water – the Ottawa River or any other body of water. Storage should be done locally vs. transporting radioactive waste long-distances.
CNL’s chosen location for the ECM cannot be justified
The chosen location for the ECM is basically in the middle of wetlands - East Swamp, South Swamp and Perch Lake Swamp. Perch Lake is at the foot of this proposed site and Perch Creek,
!12 only 100 metres from the ECM, discharges directly into the Ottawa River. It is unbelievable that CNL could state (in EIS) as their overall motive for this proposal “to reduce the risks associated with CNL legacy wastes” and that then CNL would choose this site. The site was chosen primarily for convenience and reduced cost. This is short-sighted. This site is not suitable for any type of facility for radioactive waste.
-The Perch Creek Basin is already contaminated by existing radioactive waste areas. This ECM would further burden this environment. -34 acres of mature forest will be destroyed.
Radioactive and other contaminants will end up in the Ottawa River
This ECM should not be placed next to the Ottawa River or any large body of water. The CNL chosen site is unsuitable because of its proximity to wetlands, Perch Lake and Creek and the Ottawa River. In the EIS the description of this ECM indicates a number of ways that contaminants will leak into the surrounding area and ultimately into the river.
During the initial phase the cells are exposed to the elements. In spite of leachate collection and treatment, there are just too many vulnerabilities and ways that contaminants will end up in the surrounding environment and ultimately in the Ottawa River. During the post-closure phase with “natural evolution”, the covers and liners will ultimately fail and contaminants will leak.
Even when all the systems devised by CNL are working normally and leachate is being collected and treated in the Waste Water Treatment Plant (WWTP), we learn in the EIS that some but not all radioactive contaminants will be removed from the leachate. This leachate is then discharged into the wetlands that drain into the Ottawa River (EIS Table 3.5.3-1 on page 3-23). The same is true for other toxic substances like PCBs, lead and dioxin (Table 3.5.3-1 on page 3-23). And tritium cannot be removed from water in the WWTP. The EIS states that very high levels of tritium will have to be reduced, but the EIS has left devising the way to do this till some future date.
The EIS addresses leakage in section after section“leakage of leachate from the ECM during the post-closure phase (i.e. after Year 2400) from liner and cover failure as a result of normal evolution” (one example of many 5.4.2-18).
A number of scenarios are described in the EIS where contaminants will freely leak into the surroundings and work their way to the river. One is the Bathtub Effect Overflow Scenario: if the base liner is still intact but the top liner has been compromised, water will enter the ECM and percolate through the waste. With no way for the leachate to escape, the ECM will fill up like a bathtub and leachate will discharge into the surrounding wetlands.
!13 Do not count on this ECM working to contain radioactive contaminants long after Post-Closure in year 2400 due to the normal forces of nature and “evolution”. If the ECM, by some miracle, remains intact for 400 years ultimately, through the gradual disintegration of covers and liners and erosion, the system will fail. Liners top and bottom will not last indefinitely even without an extraordinary event, natural or human-made.
400 hundred years - that is far away, you might say. But not so. It is only a speck of time in relation to the long-lived radioactive materials that will lie within this ECM, such as plutonium and uranium. Contaminants will leak into the air and flow into the Ottawa River for thousands of years and the river will then be permanently contaminated by radioactive wastes. Millions of people will be exposed. (Reference: Dr. Ole Hendrickson, CCRA, https://tinyurl.com/lklofxa)
It is, however, more than likely that the system will fail long before then. This ECM will leak. At what point in time or under what circumstances no one can know. But leak it will and with our river just a kilometre away radioactive and other contaminants will work their way into Perch Creek and thus into the Ottawa.
-Will it be a broken pump, a blocked pipe, a power failure preventing leachate collection or water treatment or some heavy sharp object (there are many demolished building parts destined for this ECM) that will puncture a liner? (CNL just reported a leak on April 21st at the Port Granby Long-Term Waste Management Facility which they are managing. The leak resulted in untreated water being released on the site.) -Or will it be some extraordinary event? -Could it be rain that just overwhelms and overruns all the best laid plans of drainage and ponds, and cripples the system? We know rain on the river - how it can fill and sink a boat in an evening or flood whole areas and neighbourhoods (as we are seeing right now in early May). -Or might it be a tornado or some microburst that rips and tears asunder and hurls the contents far and wide – into the wetlands, Perch Lake, the river even? These occur more and more frequently. Or a lightning strike? A strike set an island on fire this past summer just a short distance downriver from Chalk River. -Or an earthquake? Chalk River is in a seismic zone with earthquakes on average every 5 days. An earthquake larger than a 6 could come one day. -Or just the heat from some fissile materials contained within melting the liner or creating a fire? -Or intruders, either in innocence or with malicious intent, begin to dig? -Or a tree taking root or animals burrowing?
When does it happen? Before institutional control ends – or after, when no one is watching.
CNL must answer these concerns: -What can be done to mitigate effects from these scenarios? -What techniques are proposed to limit the amount of run-off so that the WWTP is not overwhelmed during an extreme storm event?
!14 -What techniques are proposed to divert run-off from storm events during the waste emplacement phase? -What happens to all the concentrated contaminants that are removed from the leachate during treatment - where will these concentrated contaminants be placed? -How is the ECM protected from extreme wind? A tornado?
Disposal is permanent and forever. How can this ECM just be abandoned when it is indicated in EIS that the system will ultimately fail sometime in Post-Closure due to “natural evolution”? What are the plans for Post-Closure Year 2400? How will this ECM be monitored? When the cover deteriorates what will be done? Doing this facility in the fastest, most financially economical way now will likely have huge long-term implications. Long-term strategies are essential.
The EIS does acknowledge some of these situations and their acknowledgement underscores the statement and the OFWCA position : DO NOT place this ECM or any other facility for radioactive waste beside the Ottawa River – or any large body of water.
Alternative locations at some distance from the Chalk River property need to be investigated Find an alternative location that is not in the middle of wetlands and 100 metres from a surface stream that discharges directly into the Ottawa River one km away. (This facility must be located away from the river. Only waste that is suitable for disposal and waste that is currently on the Chalk River site in interim storage can be considered for disposal. Waste must not be brought in from other locations.)
OFWCA recommends that the EIS include an examination of potential alternative sites on federal lands, such as those owned by the Department of National Defence, near the Chalk River property that would be at least 25 km from the Ottawa River.
The wellbeing of the environment will have an impact on employment and economic prosperity
Why are some communities supportive of CNL’s proposal? Some people and some communities are supportive of the proposal. CNL provides badly needed employment for people on both sides of the river. Employment is one big concern in the Valley. Could people lose their jobs if this proposal is not accepted? The EIS states that CNL employs 2500 people and that 50 additional people will be needed to work on the project site. Are these 50 people already employed? It is possible that some might lose their jobs when the NRU is decommissioned in March 2018. Would those people then be employed to work on this new project instead? Aren’t employees still needed whether or not there is a disposal facility as the radioactive waste remains in storage on site and needs to be secured. We do not have answers to these questions but we
!15 fully appreciate the concerns and worries of people who are depending on CNL for their livelihood.
On the one hand, the EIS considers that the disposal facility will contribute to local and regional economies and that the potential for workers moving to the area could increase the demand for housing and community services. However, the EIS also says that the project could negatively affect worker and local quality of life (EIS p. 216, 5-8).
Jobs could be lost. Devaluation of local properties could occur. A different risk should be considered related to jobs and the economic well-being of the area. The public’s perception of an idyllic area to live in could change. We have heard repeatedly the refrain “if they do this thing, I am out of here!” and some residents and cottagers consider selling their properties if construction is approved. A prominent business man and general manager of a company in the region has told OFWCA that he will uproot his family and leave the area if the proposal is accepted. He does not want his family or his descendants to be exposed to contamination. He wonders, depending on the final outcome, if construction of the NSDF could also have longer term impacts to the viability of his company.
Will people and new companies move to the Valley when they learn of the risk of radioactive contamination and the need for emergency preparedness training? Will tourists still come?
Our community of Sheenboro and the whole region needs to continue to be viable and the quality of life in the region greatly depends on a clean and healthy environment in order to attract new young families, businesses, and tourists.
A better project proposal – one that is planned from the outset in consultation with local communities – would provide better guarantees of long-term employment. This would enhance, not tarnish, CNL’s reputation for responsible long-term radioactive waste management.
Cancer & Birth Defects The government must undertake to study the levels of cancer, other illnesses and birth defects in Pontiac and Renfrew Counties. This is essential. People who live within 50 kilometres of Chalk River Laboratories are concerned. We have been concerned for years. People on both sides of the river depend on the river, swim in the river, eat fish from the river and the vegetables from neighbouring farms. We want to know if so many people are dying of cancer and so many babies are being born with defects because of radioactive contamination. There have been accidents and leaks for more than half a century. People wonder if the rates for illnesses and birth defects are higher in Pontiac and Renfrew than in the rest of the country. Is it only a perception or is there some basis of truth in what people are perceiving, feeling and seeing? It is unacceptable that people should just go on being worried. A study would either put their minds at ease or confirm their fears. The truth is needed and wanted. There should also be a study done now before any project goes forward in order to establish a
!16 baseline. If the CNSC will not undertake such a study, OFWCA will request that the Quebec government consider doing it.
Concerns about GoCo Model Though the Chalk River site remains federal property under the ownership of Atomic Energy Canada Limited (AECL), it is now managed and operated by private companies. It is “government-owned, contractor-operated”.
This is of great concern as private companies tend to be interested in their bottom line and making profits. And profits need to be made over the short-term. These companies will be managing operations at Chalk River on a 10-year contract. And their contract to manage CNL ends in 2025 – that is only five years after the opening of the proposed disposal facility. They will make profits for a number of years but they will not be invested in the Chalk River site for a hundred years.
The fastest and most cost effective approach to the management of Canada’s radioactive wastes, that could devastate whole areas, is extremely short-sighted. The long-term implications are enormous. What happens when the contract ends – how will CNL be managed then? Who will then be responsible for the disposal facility and pay what is necessary if there is a future leak or worse? What will be the government’s role? Ultimately, the tax payers of Canada will be liable.
Long-term strategies and controls are essential to ensure the health of our river and the safety and wellbeing of all people in the Valley.
!17 Conclusion
A Message from OFWCA to CNL, to CNSC and to the Nuclear Industry
• Do not dispose of and abandon radioactive waste next to a large body of water. • Do investigate alternative sites at least 25 km away from the Ottawa River, lakes and streams. • Do not transport radioactive waste across the country to dispose of it next to a major river or any large body of water. • Do not bring to Chalk River any additional radioactive waste from anywhere for storage or for disposal. • Do not put hazardous radioactive waste with half-lives of thousands of years in this ECM. • Do not hide hazardous radioactive waste behind percentages. • Do comply with IAEA radioactive waste classifications. • Do identify all hazardous radioactive waste with long-half lives to be placed in ECM (both LLW and ILW). • Do investigate alternative means for disposal or storage of radioactive waste already on the Chalk River site. • Do not try to lull people into believing that this proposal for an ECM is “proven and safe”. • Do not print glossy ads that are misleading and deceptive. • Do not give half-truths to people. Tell people the whole truth. • Do not ignore concerns. • Do not dismiss concerns by claiming they are unfounded. • Do consider the opinions of independent scientists and environmentalists. • Do not make huge decisions that will impact people and the environment and just announce them. • Do engage people and communities in the decision making process. • Do not ignore Quebec by writing everything in English. • Do not claim you are informing the public when information sessions in Quebec were held in only 2 locations (Rapides-des-Joachims and Sheenboro) on 3 occasions between Spring 2016 and Spring 2017. • Do make presentations (vs. poster board sessions) to communities not just to councils. • Do not take months to answer questions sent to you by a nearby community. • Do not then neglect to answer further questions but claim in the EIS that questions were answered. • Do answer all questions. Information is necessary. • Do not use compensation and other financial incentives to silence people. • Do not claim that nuclear energy is “clean”. And then think you can dispose of and abandon radioactive waste without anyone noticing. • Do be a positive example to the world.
!18 Appendices B & C
Old Fort William Cottagers' Association
Appendix B Resolutions
List of Resolutions Pages: 20-21
Resolutions Pages: 22-31
Appendix C Additional Questions
Additional Questions with Respect to the Proposed Activities at Chalk River Laboratories January 24,2017 (not answered) Pages: 32-41
t1 Appendix B
Old Fort William Cottagers' Association
List of Resolutions
1. Old Fort William Cottagers'Association (OFWCA) - resolution passed July 23,20t6. Resolution states: page:22
"OFWCA strongly objects to Chalk River (CNL) receiving and accepting radioactive waste and any other waste from another site outside the Chalk River facility. Disposal of radioactive waste and any other waste must be limited to Chalk River's current levels of generated radioactive waste".
2. Municipality of Sheenboro (Pontiac) - resolution passed December 20r2416. Resolution states: page:Z3
"This Municipality is opposed to CNL bringing more nuclear waste from outside the Chalk River site".
3. Municipality of Clarendon (Pontiac) - resolution passed January 12r 2017. Resolution states: page:24
"And is unanimously resolved to support Old Fort William Cottagers'Association and the Municipality of Sheenboro in their petition to the Canadian Nuclear Laboratories (CNL) in their objection that CNL receive or accept radioactive waste or any other waste from another site outside the Chalk River facility. Disposal of radioactive waste and any other waste must be limited to Chalk River's current levels of generated radioactive waste".
4. Municipality of Bristol (Pontiac) - resolution passed March 6,2017 Resolutions states: page: 25
"We support the Old Fort William Cottagers'Association and the Municipality of Sheenboro in their petition to the Canadian Nuclear Laboratories (CNL) in their objection that CNL receive or accept radioactive waste or any other waste from another site outside
Ja Appendix B
List of Resolutions (continued)
the Chalk River facility. Disposal of radioactive waste and any other waste must be limited to Chalk River's current levels of generated radioactive waste".
5. Canton de Lochaber (Papineau) - resolution passed March 13,2017 Resolution states: pages: 26-28
"Que le Conseil de Canton de Lochaber s'oppose au projet d'IGDPS, tel que prdsent6 par les LNC; Que le Conseil de Canton de Lochaber informe les intervenants au projet des risques pour la sant6 publique de contamination radioactives sur les cultures agricoles en bordure de la rividre des Outaouais; Que la rdsolution sera envoy6e d l'association Old Fort William Cottagers, au ddputd Stdphane Lauzon et au D6putd Alexandre Iraca. Adopt6 d 1'unanimit6."
6. Township of Alfred and Plantagenet (Ontario) April 2,2017 Resolution states: pages: 29-30
"Be it resolved that Council of the Township ofAlfred and Plantagenet support Old Fort William Cottagers'Association's resolution objecting to the Chalk River Near Surface Disposal Facility receiving and accepting radioactive waste and any other waste from another site outside the Chalk River facility".
7. Municipality of Campbell's Bay (Pontiac) - resolution passed April 4,2017 Resolution states: page: 31
"IJnanimously resolved to support the Old Fort William Cottagers'Association and the Municipality of Sheenboro in their petition to the Canadian Nuclear Laboratories (CNL) in their objection that CNL receive or accept radioactive waste or any other waste from another site outside the Chalk River facility. Disposal of radioactive waste and any other waste must be limited to Chalk River's current levels of generated radioactive waste".
Jt OId Fort William Cottager$' Association (OFWCA) Sheenboro, Quehec
Minutes of OFWCA AGM, Hotel Pontiac, Saturday July 23'd 20L6r9:30 a.m.
The following resolution was adopted and passed on JuIy 23,2016: OFWCA strongly objects to Chalk River (CNL) receiving and accepting radioactive waste and ary other rraste from another site outside the Chalk Riyer facility. Disposal of radioactive waste and any other waste rnust be limited to Chalk River's current Ievels of generated radioactive waste.
Signed,
Heidi Kaulbach Secretaly of the OFWCA
JE Appendix C
OId Fort William Cottagers' Association
Additional Questions With Respect to the Proposed Activities at the Chalk River Laboratories Site - January 24,2017
The following questions were sent to CNL on January 24,2017 . OFWCA has not received any answers to these questions (as at May 8, 2017). The comments in italics are takenfrom CNL's December 16, 2016 responses to OFWCA\ previous questions of October 20, 2016 in order to provide context.
CNL tells us that their operotions will have low impact on the environment.
l.What specifically does low impact mean?
CNL tells us that N,SDF is proven technology and that N,SD^FS have been built ond safety operated around the world.
2.The sites referred to in CNL's project description do not appeff to be comparable. Has the same type of NSDF been built anywhere? Where? And are the conditions (climate etc.) the same? Is there any other NSDF site surrounded by river water (a major river where millions depend on it)?
3. Can CNL say this is "proven" technology when NSDFs have only been operating for 15 to 20 years? How can we know how an NSDF will function after 100, 200, 500 years?
CNL tells us that waterfrom precipitation will be collected and treated in the Waste Water Treatment Plant and any contamination will be removed before the water is released into the environment. And extensive monitoring of water will he conducted,
4. Can radioactive contamination actually be removed from water?
5. What about intermediate-level contamination - can this be removed from water through treatment?
6. Wouldn't it be more efficient to treat waste contaminated with hazardous substances prior to placement in NSDF?
7. Where would wastes from the Waste Water Treatment plant be discharged?
3d 8. How do existing earthen mound facilities treat precipitation that becomes radioactively contaminated during operations?
9. If the system fails and there is a leak what will CNL do? What happens after CNEA contract ends in 2025?
Regarding intermediate-level waste (ILW):
CNL tells us that Intermediate-level waste will be limited to 1% of the total (that is 10,000 cubic metres of ILW)
10) How will this be limited to loh? Does CNL simply stop placing ILW once a lohlimit has been reached? What system will be in place for recording how much ILW has been placed in NSDF? What is the inventory system?
CNL tells us an exqmple of intermediote level woste would be waste with q concentrotion of short-lived rodionuclides which ot present require shielding for safe handling and plocement.
11) This waste needs shielding for safe handling and placement - how will this be implemented and specifically how will LW be placed in the NSDF * will it be contained in something, will there be cells specifically for intermediate-level waste, will CNL ensure that certain wastes that might create heat are not placed together?
12) Isn't it true that NSDFs are not recommended for intermediate-level waste?
13) CNL provides an example for ILW as waste that in 100 years is decayed to low level - but some ILW have much longer half-lives - hundreds or thousands of years. How will CNL handle these wastes?
14) Who is responsible for setting limits on levels of radionuclides disposed of in this NSDF at Chalk River - is it CNL or CNSC?
CNL tells us thot mixed wastes will be limited to 1% of the total (that is 10,000 cubic metres of mixed wastes that are radioactive and could include arsenic, PCBs, mercury).
15) Regarding Mixed Waste - How does CNL limit the amount to r.Yo?
CNL tells us that all waste will meet the Waste Acceptance Criteria for the NSDF and be demonstrated to be safe. Waste Acceptance Criteria ore carrently being developed,
16) How does CNL design this facility before knowing what the Waste Acceptance Criteria (WAC) is?
33 CNL tells us that "there have been no exceedances of elfluent from Chalk River Laboratories' operations. The Loboratories' ffiuents do not pose a threot and have negligible impact to the public or to the environment.
17) How do we, the public, understand this statement that there have been 'no exceedances'when we have read that there have been exceedances over the years with significant threats to our health?
CNL tells us about their extensive monitoring program and that they are committed to reducing the impact of their operations on the environment. Water is monitored at the nearest water treatment system, in Petawuwa, and most contaminonts are below detection at that location. The presence of tritiam over the lost few years has been well below acceptable limits. Drinking wster limit is 7000 Bq/l.
18) Residents of the Municipality of Sheenboro with properties on the Ottawa River are much closer to CNL than residents of Petawawa, and may take drinking water directly from the river. Does CNL monitor and report levels of tritium and other radionuclides in Sheenboro, a.9., in Baie Downey?
l9) Why is 100 BqlL often cited as the highest level that tritium should be in drinking water - but Canada maintains that 7000 BqL is safe?
20) The 2015 Annual Safety Report says that "The risks associated with the presence of 90Sr in the Perch Lake basin are considered to be moderate; that is, contaminant concentrations exceed the benchmark value in localized regions of the drainage basin;" and Figure 4 shows that strontium-90 levels in Perch Lake and Perch Creek are increasing through time. Are strontium-90 releases to the Ottawa River increasing? How serious are the risks associated with strontium-90 in the longer term? Would the NSDF address these risks? If so, how? What impacts might construction and operation of the NSDF have on strontium-90 releases to the Ottawa River from Perch Creek (or from other discharge points at CNL)?
CNL tells us (in Dec.2016) that CNL is preparing an Environmental Impact Statement. Should adverse effects be identijied, CNL must demonstrate how these can be mitigated sutisfactorily. The EIS analyzes severe abnormal situations (e.g. glaciution, a seismic event much larger than the very conservative design basis earthquake) that could give rise to the failure of NSDE, and demonstrates that under these circumstances, people and the environment will be protected.
3+ 2l) OFWCA and our much larger community are anxious to see CNL's EIS and will hope that what is contained therein will address some of our concerns. Again, we wonder how do you design a facility without first having established WAC, EIS?
22) Wouldn't this NSDF be destroyed by glaciation (especially with this NSDF's height being 25 metres) causing widespread contamination if the NSDF contains radionuclides with half-lives of thousands of years?
CNL tells us thut NSDF will occept wastes from a) Building decommissioning b) Remediotion of impacted soils, c) Operationol and legacy waste in interim storage d) Commercial sources and e) waste from laboratory operations
23) How is all the material from the buildings that CNL is now demolishing being stored in interim? In containers? How is the material being categorized and separated - by what criteria? Some of these buildings may contain ILW - is this being separated from LLW? How is CNL categorizingthis waste ?
CNL tells us that within the 1,000,000-cubic metre total volume of the Engineered Containment Mound, opproximately 1% of the waste is expected to be mixed wastel that is, hozardous waste that is contaminated with radiouctivity and could also be contaminated with arsenic, mercury and PCBs, The Wuste Acceptance Criteria will determine the quantities of the materials that are placed in the N,SDE Again, water will be treuted in Waste Water Treatment Plant.
24)What is CNL's waste categorization system with respect to all radioactive waste and mixed waste that will be placed in NSDF? How will these wastes be verified with WAC? How will quantities of ILW and mixed wastes be inventoried and verified and limits controlled?
25) Without the WAC, we do not know the quantities and types of any of the wastes including PCBs, Mercury, Arsenic. We want to know this information. Re: remediation of impacted soils - isn't some of this highly radioactive? How will this be handled and where will it be placed in NSDF? Treatment may work for some hazardous material but what will this mean for the levels of tritium that cannot be removed from this water even with treatment?
CNL tells zs N,SDFsite is suitoble to retain materials long term, the design ltfe of the NSDF is 550 years.
26) How do we know these materials can endure 550 years? As lay people - this is quite difficult to comprehend. And especially in our climate?
5b4- 27) And doesn't disposal mean forever?
28) If this disposal site includes radionuclides with long- half lives, it will remain hazardous for many thousands of years - how is this NSDF adequate?
The Safety Analysis and the Performance Assessment (included in the EIS) will be important to see and to be evaluated.
CNL tells us the waste to be put into the NSDF will contain no free liquids.
29) Does this mean that liquids will be included but will be contained in something? What will they be contained in?
CNL tells us the N,SDI' design will be developed based on the codes and standards set by the International Atomic Energy Agency, federal regulators and provincial outhorities. It will build on the large bose of experience for similar facilities that exists in the US, Europe qnd Canada.
30) Does the knowledge and experience that scientists have accumulated in order to develop these "codes and standards" span more than 50 years? How can these codes and standards determine how something will function for 550 years (the "design life" of the NSDFX Or for thousands of years?
CNL tells us the Engineered Containment Mound willfeature a double, composite base liner system ond a cover system, both of which are comprised multiple engineered barriers that work together as a system to encapsulate the wuste ond isolute it from the environment. CNL tells us they have engaged a highly-experienced engineering consultingJirm to prepare the design.
31) Re: puncture resistance and weight bearing: does not the sheer weight of what will be placed in NSDF and the compression of such materials (such as brick, metal, wood from decommissioned buildings) increase the likelihood of puncture? How will this material be placed to avoid this? (U.K. NSDF did suffer puncture with resulting leaks.)
32) Again, how can NSDF be designed and declared adequate before the WAC has been defined? This undertaking will affect our communities into the long-term future.
CNL tells us the N,SDF is being designed to resist un earthquake with a magnitude of 6.0 on the Richter scale. This will ensure the facility remains intoct and that hazards to workers, the public and the environment ore contained.
3t* 33) CNL indicates that the risk of an earthquake is low - but if there is an earthquake of 6 or higher with the epicentre near or at Chalk River - what is the probability of a leak(s) in NSDF?
CNL tells us that they must ensure that required security measures ore in place to prevent acts such as sabotoge.
34) Once active institutional control ends in 2100, how will the site -NSDF - be protected from sabotage?
CNL tells us monitoring in 2015 conJirmed stubility in tritium concentrations in the Ottuwu River near Chalk River Laboratories with levels neor or below the detection limif of Bq/L in Petawawa and Pembroke. Tritium concentrations found in river water at sll monitoring locotions were well below the Canadian drinking water gaideline of 7,000 Bq/L.
35) Acceptable tritium levels in water in Canada are 7000 Bq/Litre - that is far higher than in other countries - e.g. 100 in Europe and 14.7 in California. Why this huge difference? What are the tritium concentrations found at Chalk River, at Petawawa and at Pembroke?
36) Would waste water treatment plant discharges increase tritium releases to the Ottawa River?
37) We understand that tritium cannot be removed from water so even if CNL collects water through the leachate system and then treats the water - tritium will not be removed. Every time there is precipitation, water will be collected, treated and then released into the river with tritium still present. The river water will be contaminated especially now that all this radioactive material in the NSDF is exposed to the elements - can you not use temporary covers on the cells to prevent this from happening?
CNL tells us: In Phase 1 - initial woste capacity of 525,000 cubic metres. In Phase 2 the capacity of the Engineered Containment Mound will be expanded to 1,000,000 cubic metres. In the 30 yearsfollowing the end of operations of the NSDF (i.e. 2071-2100) thefacility will be under active institutional control. This work includes monitoring and inspection. Leachute collection system will continue to collect and route leachate to the Wqste Water Treatment Plant. Following this, the Waste Water Treatment Plant will be decommissioned. Inactive or passive institutional control will continue following the end of active institutional control, from the period 2100-2400.
31 Many questions about the Timeline:
38) CNEA's contract ends in 2025 - only 5 yrs. after the opening of NSDF. What happens then? Who then will be responsible?
39) By 2070 the final cover should be in place - and water treatment will discontinue just 50 yrs. from the opening. HoweveE materials will continue to be placed in NSDF up until that time. IfActive Control only continues for 30 more years (2100) isn't this a very short period when ILW & Mixed wastes have been placed in NSDF right up till2070? a0) Why is this whole process for NSDF being done so quickly? Before WAC? Before many questions are answered? Before the public has been truly informed and engaged? (Two poster information sessions in Sheenboro when seasonal residents are not in the area is not enough.) Why isn't the public being fully engaged and informed? How can the public truly give informed input in this process?
41) Before the final cover system is in place, could the mound of radioactive waste sustain a tornado? A microburst? (We have been having these quite frequently on the river.)
42) Can the final cover system sustain a tornado? A microburst?
43) Inactive control from2100 to 2400: What precisely is inactive control?
44) How will any unsuspecting intruders in future generations be warned?
45) How will tree growth with invasive roots be controlled?
46) What will stop animals from digging tunnels etc. in NSDF?
47) Any holes or entry points anywhere in this NSDF will allow water to infiltrate. Water that infiltrates will find a way to exit. Erosion occurs and contaminates will leak out with the water. How will CNL ensure this does not happen?
48)How would saboteurs be stopped from infiltrating?
CNL tells us the NSDF building site measures slightly more than 33 hectures. Based on the currentfootprint, the engineered containment mound (ECM) will measure approximately 16 ho, including the woste disposal areo und the surrounding berm that provides structural stability. The part of the ECM that holds and encapsulates the woste will measure* 10.7 hectares. The total air spoce within the ECM will be approximately 1,400,000 cubic metres. The mound will vary in heightfrom 20 to 25 metres,
3s a9) This plan covers a huge area and will have an impact on the environment. What are all the impacts?
50) Why is the NSDF engineered containment mound being designed to accommodate one million cubic metres of waste? What is the rationale for a facility of this size? How does the size of this proposed facility compare to other North American facilities?
51) Would alllsome wastes be compacted or processed to reduce their total volume?
52) Re:Air space within the ECM: 1,400,000 cubic metres?: Surely if there is air space within the NSDF, wouldn't the whole structure collapse?
CNL tells us NSDF may accept waste that is generatedfrom other CNL decommissioning projects: the Nucleur Power Demonstrotion und Whiteshell Laboratories Closure Projects which could generate 50,000 cubic metres of waste for the NSDE CNL has and will continue to occept waste on a commercial basis. NSDF could potentially occept woste from future decommissioning activities undertaken by CNL, for example Port Hope after its long-term woste monogement facilities are closed, Gentilly 1, or Douglas Point. CNL tells us there is no Jinal decision on this issue.
53) Downriver communities are objecting to any radioactive waste and mixed waste being brought from elsewhere to Chalk River for disposal. 50,000 cubic metres from NPD and Whiteshell are unacceptable. The quantities for all these other outside sites have not been specified. We want to know specifically
54) Would this NSDF also accept wastes from currently operating power reactors?
55) Would CNL accept wastes (for disposal in this NSDF) imported to Canada from other countries by third parties?
56) Have alternatives to disposal been considered? What are the alternatives? Have other sites been considered? Which ones? Why has this plan for NSDF been adopted? And why was Chalk River (surrounded by river water and a major river) chosen? Why is there a need now for disposal? In such urgency?
57) Shouldn't all the decisions regarding quantities, and types of wastes - V/AC - all be made before selection of a site and design of a facility? If CNL did bring waste from other areas how would the waste be categorized?
CNL tells us material from Whiteshell will be transported to Chalk River by rood, railway, or o combinotion of both. Shipments are expected to begin in late 2019 and continuefor up to 6 years.
"f1 58) Why doesn't Whiteshell have its own disposal facility? Wouldn't this make more sense than transporting across the country? And transporting for a period of 6 years?
CNL tells us that under the Global Threat Reduction Initiotive, the United States agreed to accept our materials in liquidform to ollow that country to reprocess them und rease the resalting materiols to fuel power reaclors in the Uniled States. Conoda does not huve the technology nor the facilities to undertake this reprocessing. Another option, solidfficution/down blending, would result in the requirementfor long-term management of the produced radioactive material in Canada, whereas repatriation of the highly-enriched uranium moterials contributes to the global efforts to consolidate highly enriched uranium inventories in fewer locations around the world. Transpofiation of nuclear material will be carried out under stringent oversight.
59) Isn't solidification of HEU wastes what has been done in the past at Chalk River?
60) Aren't there already solidified HEU wastes that will require long-term management in Canada?
61) Could solidified HEU wastes be managed in the same way as waste reactor fuel rods?
CNL tells us The Government of Canads hos committed to invest $500 million for neu) infrostructure facilities at the Chalk River Laborqtories over the nextJive years. This funding will enable o complete transformation of the Chalk River site through renewed infrostructure and the construction of new science focilities and supporting infrastructure.
62) Re: Revitalizing Chalk River - the creation of more radioactive waste is concerning. What will happen to this newly created radioactive waste once the NSDF is finally sealed and covered in2070? Does this mean this newly revitalized site will have to transport the radioactive waste to some other location for disposal after 2070?
CNL tells us not all facilities to be built at the Chalk River site will produce waste that is nuclear in nuture.
63) Very good news and we support facilities that do not produce waste that is nuclear in nature.
CNL tells us there is no plan for a Geologic Waste Management Facility or DGR at Chalk River Laboratories at this time. Members of the OFWCA may recoll on update provided to Craig Robinson in 2014 on the subject of o Geologic Waste Monagement Focility. At that time, CNL (then AECL) wos completing a technical study to ossess the feasibility of using the Cholk River site for a geologicol repository to safely monoge
tto Intermediote Level Waste. The feasibility studies toere concluded ond no further activities in this regard are being pursued.
64) OFWCA is pleased to learn that a DGR is not being considered at Chalk River. We would object strongly.
CNL tells us being prepared in the event of an emergency is an essential port of being a responsible nuclear license holden CNL hos o comprehensive emergency preparedness program in place, and works with the nuclear regulator, the Conadian Nuclear Safety Commission, municipal, provincial andfederal governmenl ogencies,Jirst responders and international organizations to always be ready.
65) We understand that CNL is working with Sheenboro on emergency preparedness. Could CNL make a presentation to OFWCA next July regarding this subject? (No use in coming prior to July!)
+t