Presentation on the High Level Waste Disposal Concept
May 2, 1996 Chalk River, Ontario
Ole Hendrickson
Concerned Citizens of Renfrew County
P.O. Box 981, Pembroke, ON K8A 7M5
Mr. Chairman and members of the Panel:
If other waste siting experiences are relevant to this assessment of the high level waste (HLW) disposal concept, perhaps none is so instructive as the current federal siting process for low-level radioactive waste (LLW). The process is intended to find a "volunteer community" for a facility to house uranium and radium refinery wastes from the former crown corporation, Eldorado Resources Ltd., in Port Hope, Ontario.
Atomic Energy of Canada, Ltd. (AECL), the proponent for the HLW process, is also deeply involved in the LLW process. The Chalk River Laboratories of AECL, which lie within the municipal boundaries of the Town of Deep River, have been proposed as the site for a deep rock cavern for permanent disposal of the Port Hope wastes.
This siting process is in its final stages. An environmental screening document (the "IA Report") has been finalized. It concludes that the proposed cavern facility would cause no significant negative environmental effects. The townspeople of Deep River have expressed strong support for the facility, voting 73% in favour of a Community Agreement in Principle that would give them $8.5 M in compensation and maintain employment at AECL at current levels for the next 15 years.
A federal Siting Task Force recently issued its final report to the Minister of Natural Resources. It concludes that the facility would protect health and pose no threat to the environment, and should be exempted from all further environmental assessment requirements. The Task Force's final report describes this process in glowing terms, suggesting that it be used as a model for future waste siting efforts.
Those faced with the difficult issue of HLW management will undoubtedly wish to know how this apparent remarkable success has been achieved. My group, Concerned Citizens of Renfrew County, is involved in both the HLW and LLW environmental assessments. We have a number of concerns about the Siting Task Force process, and we would like to offer some recommendations for the Panel to consider for siting a HLW facility. These recommendations are based largely on our experiences with the LLW siting process.
1. Don't accept a redefinition of "safety" as "meeting current standards"
- In the HLW Environmental Impact Statement (EIS), AECL defines "safe" as "Meeting criteria, guidelines and standards for protecting the health of humans and nonhuman biota". Webster's Third New International Dictionary defines safe as "secure from threat of danger, harm, or loss".
- The proposed Deep River LLW facility would be a mined cavern located less than 500 m from the Ottawa River. The area is seismically active, with numerous faults. A single 200-m deep borehole drilled at the proposed site had nearly 4000 fractures, a significant number of which are known to be open to water movement. This highly fractured, porous bedrock supports high rates of groundwater flow directly to the Ottawa River. Models show that an ever-widening portion of the river bed would be contaminated by uranium, radium, and arsenic. Yet the environmental assessment claims that the facility would be "safe", because the river would dilute concentrations of these toxic elements below drinking water standards.
- The IA Report contains only a superficial analysis of the health and environmental effects of contaminating the Ottawa River with radioactive and toxic wastes. It ignores the accumulation of radium, uranium and arsenic in sediments and aquatic food chains especially in fish, which are eaten by local residents and also support a major tourism industry.
- Some analysts suggest that drinking water standards for radionuclides are far less healthprotective than standards for nonradioactive carcinogens. Current standards may allow as many as 3502000 fatal cancers per million people exposed, compared to 12 for most chemical carcinogens.
- The International Joint Commission has recommended that governments incorporate those radionuclides which meet the definition of persistent toxic substance in their strategy for virtual elimination.
- Protection of health and the environment are best done by prevention. In the matter of nuclear waste, the risks have already been created. The goal is to minimize these risks. Claims that mined caverns will "protect human health" are false. The only way to protect health is the virtual elimination of these persistent, bioaccumulative, toxic substances.
2. Insist upon a principle of minimum human exposure (including workers and the general public) to set radioactive waste management priorities and choose among alternatives
- The only reference to worker radiation exposure in the LLW environmental assessment is as follows: "If LLW concentrations detrimental to the welfare of the workers are detected, mitigative measures will be employed, including suspension of work, if required".
- The LLW assessment did not even attempt to calculate worker exposures, and was therefore unable to minimize them.
- Insufficient data are provided in the HLW EIS and supporting documents to verify estimates of worker exposures, particularly for accident scenarios.
- Neither the HLW nor the LLW studies compares waste management alternatives from the perspective of minimizing total population dose.
3. Don't allow certain parties' desire for a "disposal solution" divert attention from the larger issue of responsible management of radioactive wastes
- The original STF warned that "Disregard for community concerns has not been the only obstacle to effective action on lowlevel wastes. A second major factor has been the declared preference of the Atomic Energy Control Board (AECB) for the concept of permanent disposal as the ultimate acceptable means of handling lowlevel radioactive wastes... One unfortunate aspect of the Board's adherence to this idea is the inhibiting effect it has on the search for simpler solutions, such as longterm storage, that concentrate on improved management of the wastes."
- The original STF recommended "that, rather than permanent disposal, the concepts of improved management and longterm storage, with the ability to monitor and retrieve wastes, become the immediate objectives for the handling of lowlevel radioactive waste."
- This recommendation was ignored in the case of the Deep River Project. AECL chose the "disposal" option and the site, ruling out alternatives for storage and management. Aboveground monitored storage for LLW would almost certainly be preferable to controlled leakage into the Ottawa River with respect to minimizing radiation exposure to the general public.
- A similar disregard for storage and management characterizes the HLW EIS. It fails to examine the potential of long-term storage to minimize radiation doses received by workers and the general public during waste handling and transport.
4. Do a problem analysis quantify current waste levels at all sites, rates of production, and storage conditions
- For the LLW proposal, an "Inventory of Waste Quantities" was conducted by the original STF. It showed that AECLChalk River already had over 35 times more radioactivity at the time of initial storage than all the Port Hope waste sites combined.
- The STF recommended that "Cabinet authorize the initiation of plans of action to determine the waste management requirement of all communities currently housing lowlevel radioactive waste repositories," and that such action plans "be carried out jointly by an independent group... and representatives of the communities in question." This recommendation has never been acted upon in the matter of current waste inventories at AECL-Chalk River.
- The HLW EIS lacks a detailed analysis of the current status of HLW inventories in Canada, and none of scenarios for the size of disposal facilities reflects a realistic projection of future HLW inventories.
5. Don't regard highlevel fuel wastes in isolation. Examine all radioactive wastes and prioritize action based on threats to human health and the environment
- There is no suitable longterm storage method for liquid high-level wastes in the "FISST" (fissile solution storage tank) at the Mo99 Production Facility at AECL-Chalk River.
- No suitable longterm storage method exists for wastes in the seven highlevel tanks in Area E.
- There are several sites at AECL-Chalk River where low and mediumlevel wastes were dumped in the ground (either deliberately or as a result of accidents) and are now migrating in an uncontrolled fashion towards the Ottawa River.
- Various contaminated buildings have been sealed off and are awaiting decontamination and decommissioning.
- Despite repeated admonitions from Canada's Auditor General, AECL has refused to properly account for liabilities associated with cleaning up these existing waste problems at the Chalk River Laboratories.
- This lack of a clear AECL commitment to proper management of all types of radioactive wastes raises serious questions about AECL's credibility in the matter of the current assessment of the HLW disposal concept.
6. Amend laws that circumvent environmental assessment for siting of wastes at facilities with existing AECB licenses
- Atomic Energy Control Regulations state that the AECB can issue one license for two or more facilities in the same vicinity "if it considers that only one license is necessary".
- Proposals for storage of less than 100 trillion Bq of LLW or less than 500 tonnes of fuel waste do not trigger the Comprehensive Study List Regulations under the Canadian Environmental Assessment Act (see section 19(g)), but permanent disposal of ANY amount or type of radioactive waste would receive comprehensive study.
- However, existing licensed facilities such as AECLChalk River are exempt from this provision.
- This exemption may create an incentive to locate radioactive waste disposal sites at existing licensed facilities to avoid costly environmental assessments.
- This creates fears that, if a cavern for the Port Hope LLW is built at AECLChalk River, additional wastes, possibly including HLW, will be put there with minimal regulatory oversight and no public scrutiny.
- These fears have been aggravated by the Community Agreement in Principle for Deep River, which would allow AECL-Chalk River to "co-dispose" of 25,000 cubic metres of its own wastes in the cavern. The LLW environmental assessment totally ignored the nature of these wastes, their potential to migrate to the Ottawa River, and the risks they would pose to public health and the environment. They could be hundreds of times more radioactive and contain about 10 times the total radioactivity of the Port Hope wastes.
- The final report of the STF added to these fears by recommending that steps needed to complete licensing and construction of the proposed Deep River facility be "exempted from any further public hearing requirement under either the Environmental Assessment and Review Process or the Canadian Environmental Assessment Act."
- Given these regulatory exemptions, even HLW could be put in a mined cavern at AECL-Chalk River with a minimum level of environmental assessment, even though the site is not located on the Canadian Shield and its bedrock is unsuitable for waste containment.
- The HLW panel should be aware that, if it approves the disposal concept, further environmental assessment could be minimal if the concept were to be implemented at an existing licensed facility. This panel could be the last opportunity for a full public discussion of proper management of HLW.
7. Insist on full scientific and interagency review throughout the environmental assessment of radioactive waste management
- A study of bedrock geology at AECLChalk River concluded that bedrock "would be considered fair to good quality rock... for engineering purposes." This was rewritten in the Executive Summary to state that the bedrock "would be considered fair to good quality rock for siting a LLRW management facility". This tampering with scientific conclusions should have been detected and corrected by a proper peer review process.
- Another example of tampering with conclusions occurred in the Executive Summary of the IA Report itself. It states that "the maximum concentration of arsenic... that might enter possible drinking water sources was considerably less than the current acceptable federal or provincial drinking water standards." However, the text of the report shows that arsenic concentrations would exceed 1 mg/L at the point of contact with the river within 10,000 years, 40 times the Canadian Drinking Water Guideline of 0.025 mg/L, or 200 times the Ontario provincial water quality objective of 0.005 mg/L.
- The STF made a video entitled "Environmental Assessment and Cooperative Siting Process". It claimed that the environmental assessment report would be sent to other agencies for review, and results of those reviews collated and made available to the public before the referendum.
- The IA Report never received any independent review.
- The same STF video claimed that all technical documents would be made available to the public before the referendum vote.
- The key technical document, the Preliminary Performance Assessment (PA2) was not released until after the referendum.
- The STF abandoned all pretence of impartiality in the final few weeks prior to the referendum, when it placed paid advertisements in local media claiming that "the area's water resources would be protected", and that the facility "would be safe", "would protect human health", and "would protect the environment"
8. Consider a competitive grants program for independent scientists to work on radioactive waste issues
- The U.S. Department of Energy has recognized the need for independent research to discover new options for cleaning up military HLW, and has allocated $50 M per year for a competitive grants program to this end.
- Independent research could provide innovative ideas for addressing radioactive waste management issues in Canada.
9. Conduct full scientific and technical assessments, have these independently reviewed, and make results available to the public before discussing compensation
- The STF process has been characterized as an experiment in environmental assessment, giving socioeconomic factors priority over scientific and technical considerations.
- The STF process, which began as a positive experiment in communitybased decision making, ended, in the words of a former Community Liaison Group chair, in deceit and manipulation.
- It resulted in a governmentsponsored assessment process that may have concealed or minimized the negative environmental effects of the Deep River proposal.
- Negotiating a compensation package before determining technical acceptability sets a dangerous precedent for environmental assessment. It suggests that a short-term benefit to one community is an acceptable trade-off for serious long-term environmental and health costs.
- The STF process must be viewed as a failed experiment. However, the recommendations of the final report have not yet been accepted or rejected. If the STF recommendations are accepted, they will set very dangerous precedents for all future environmental assessments, including siting of a HLW disposal facility.
Thank you, Mr. Chairman, for this opportunity to make a presentation to the Panel.
I welcome your questions.