Potential Regional Assessment of Radioactive Waste Disposal in the Ottawa Valley (Canadian Impact Assessment Registry reference number 81624)

Dear Minister Wilkinson,

Old Fort William Cottagers’ Association (OFWCA) strongly supports the City of Ottawa’s call for a Regional Assessment of the Ottawa Valley radioactive waste disposal projects under the Impact Assessment Act of 2019.   

Members of OFWCA are residents and cottagers in the community of Sheenboro/Fort William, Quebec. We are the first community downriver from Chalk River, Ontario. Some members live as close as three kilometres from Chalk River Laboratories.  We have been paying close attention for the past five years to Canadian Nuclear Laboratories’ (CNL) two proposals for radioactive waste disposal on the Ottawa River, at Chalk River and Rolphton, Ontario.  We have also been concerned for years about the legacy radioactive wastes that have been accumulating at Chalk River Laboratories.

Our position is that radioactive waste should not be disposed of without the possibility of retrieval and that both disposal sites are far too close to the Ottawa River, risking contamination of the drinking water for millions of Canadians.

It is also of great concern to our community that CNL has been implementing its own Integrated Waste Strategy that calls for federally owned and commercial wastes to be consolidated at Chalk River Laboratories. Shipments of intermediate- and high-level radioactive waste, including used reactor fuel – from Quebec, southern Ontario and Manitoba are underway. Not only is there a risk of an accident during transport but all communities en route are unnecessarily put at risk of radiation exposure. 

To our knowledge, consolidation of federal radioactive waste at the Chalk River Laboratories has not been subject to any kind of impact assessment. There are several serious concerns about the suitability of that site for radioactive waste disposal; such concerns could be properly aired and evaluated as part of a regional assessment.

OFWCA entirely agrees with the Joint Declaration of the Anishinabek Nation Iroquois Caucus on transport and abandonment of radioactive waste (https://nukewatch.org/newsite/wp-content/uploads/2020/03/Joint_Declaration_2020.pdf?x68309).

Legacy Radioactive Wastes at Chalk River Laboratories (CRL)

We believe that a regional assessment including the entire area of CRL and its $8 billion legacy radioactive wastes would be very beneficial to the Ottawa Valley. 

For seven decades radioactive waste has been accumulating at Chalk River Laboratories (CRL), due to nuclear research and development activities, and the area is highly contaminated. Three old reactor cores are buried in the sand. Fuel bays have had major leaks releasing tritium, strontium-90, and carbon-14. Radioactive plumes have been slowly but steadily entering the air and the wetlands, lakes and creeks which flow into the Ottawa River. Please refer to Chalk River's Toxic Legacy (http://ottawacitizen.com/news/chalk-rivers-toxic-legacy/wcm/12a1f5e3-9b71-4448-9414-1e4416fbacfc) by Ian McLeod, Ottawa Citizen 2011.

A great majority of the legacy radioactive waste at CRL would not be addressed by CNL’s disposal projects.

Remediation of this entire area should be a priority and a regional assessment would provide that guidance. 

CNL’s two radioactive waste disposal projects

The environmental assessments for CNL’s two proposals on the Ottawa River have been going on for five years. Both projects were initiated without prior Indigenous or public engagement. 

The Assembly of First Nations, fourteen former AECL officials and scientists, hundreds of citizens and organizations, and over 140 municipalities in Ontario and Quebec, including Gatineau, Montreal, Laval and now the City of Ottawa have opposed or raised serious concerns about CNL's proposals on the Ottawa River.  Old Fort William Cottagers’ Association passed resolutions in strong opposition to both of these proposals in 2017 and 2018.  

The above-ground disposal mound (“NSDF”) at Chalk River Laboratories 

The chosen location for the proposed above-ground massive mound at Chalk River is only one kilometre from the Ottawa River. The mound would be partly surrounded by wetlands, a lake and a creek all draining into the Ottawa River. The area, on a major fault line, is seismically active. The underlying bedrock is fractured and porous.   

The mound is designed to last 550 years barring any exceptional circumstances or unknown event. However, the hazardous wastes will be radioactive for thousands and some for millions of years. Some require lead shielding. The EIS (Environmental Impact Statement) describes many ways that this facility will leak and the mound will disintegrate in a process described as “normal evolution”. At that point radioactive contaminants would leak into the Ottawa River and the surrounding environment for millennia.

The environmental assessment commenced in 2016.  The process has not been transparent and there has been no opportunity for public comment since August 2017.  

We agree that something needs to be done about the wastes at Chalk River but we believe there are much better and safer alternatives to the current proposal. 

Entombment of NPD Reactor in Rolphton, Ontario

CNL’s proposal for the in-situ decommissioning (or the entombing in concrete) of the NPD reactor in Rolphton, Ontario raises many concerns. The site is only about 100 metres from the Ottawa River. The radioactive wastes at this site are dangerous and must be kept out of the biosphere for as long as they pose a radioactive hazard (many thousands to millions of years). 

Encasing radioactive waste and components of a reactor in concrete and grout makes it virtually impossible to retrieve the waste.

There is no doubt that grout and concrete would break down at the NPD reactor especially with earthquakes and freezing and thawing due to weather.  Radionuclides will migrate to the biosphere - the Ottawa River is just metres away. We believe that this is not a plan that Canada should support.  

The International Atomic Energy Agency does not recognize in-situ decommissioning (on-site entombment) as an option for planned permanent shutdown of a reactor.  Planned decommissioning of a so-called “legacy reactor” is not an emergency situation and does not justify this option. Not adhering to IAEA standards is ignoring public health and safety and the protection of the environment.

We urge you, Mr. Wilkinson, to initiate a regional assessment of the Ottawa Valley radioactive waste disposal projects under the Impact Assessment Act of 2019.  The cumulative impacts of all wastes and all current and future projects need to be considered.  

This regional assessment would greatly benefit the region, we believe.  It would ensure the future quality of drinking water, secure future employment opportunities and promote tourism, contributing to the prosperity of the Ottawa Valley. 

Thank you.

Sincerely yours,

Johanna Echlin

Old Fort William Cottagers’ Association

Sheenboro/Fort William, Quebec

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