Deep River Disposal Project - Comments by CCRCA

Deep River Disposal Project: Comments on initial environmental screening

Prepared for Concerned Citizens of Renfrew County

O. Hendrickson, Ph.D. March 27, 1996

The 1986 Federal Policy on the Management of Low Level Radioactive Wastes states "It is the policy of the federal government to ensure that low level radioactive wastes will be dealt with in such a way that human health and the environment will be protected now and in the future. As a corollary, the Policy states that "the disposal facility must provide sufficient isolation of the wastes from the biosphere to ensure that current and future populations and their water supplies will be protected". The federal government appears to be violating this Policy by proposing to place low-level radioactive wastes from the vicinity of Port Hope, Ontario at a location on the property of Atomic Energy of Canada, Ltd. (AECL - Chalk River) where leakage into the Ottawa River is a certainty.

Siting criteria would normally exclude areas of significant seismic risk, but the federal screening dismisses earthquake damage concerns because "the bedrock at the proposed depth of the mined cavern facility is already assumed to have sufficient permeability to allow migration of dissolved contaminants from the facility to the Ottawa River." (PA-2, p. 30)

A basic tenet of radioactive waste disposal, isolation from the biosphere, is violated by the proposed facility. Without commenting on the appropriateness of "screening" a proposal to allow deliberate leaching of radioactive wastes into a major water body, there are serious problems with the assumptions and analyses used to examine waste movement. For example:

1. The environmental screening includes only a one-dimensional analysis of the interaction between groundwater (containing leachate from the dump) and the Ottawa River. Concentrations of arsenic and radionuclides are estimated by treating the Ottawa River as a "biosphere point" (PA-2, Table 6.4).

2. While it is claimed that the SWIFT-II model "does accurately calculate mass flux of contaminants and volumetric flow rate of groundwater into the river" (PA-2, p. 59), it is later stated (p. 60) that "We have also assumed that groundwater discharges are uniform across the portion of the river-bottom considered in the modelling". No attempt was made to model the increase through time of the area of river bottom that would discharge leachates.

3. The SWIFT II model "does not accurately model transport within a surface water body" (PA-2, p. 59). The need to conduct more mixing studies is repeatedly cited.

4. No consideration was given to accumulation of contaminants in river sediments. Biosphere modelling (PA-2, pp. 129-134) is extremely primitive and of questionable relevance. Contaminated water is assumed to be used either for watering livestock or irrigating vegetables. No consideration was given to biomagnification in aquatic food chains; most notably, accumulation of contaminants in fish.

Other deficiencies

Health risk assessment (PA-2, pp. 135-139) is based on annual dose received by a single individual. There is no recognition that millions of people are downstream of the proposed dump site, and that these people will live an average of over 70 years, rather than a single year.

There are already a number of leaking radioactive waste sites as well as ongoing routine radioactive waste discharges at AECL-Chalk River. Ottawa's drinking water has already been shown to be contaminated by AECL-Chalk River (Joshi and McCrea 1992). Contamination of the Ottawa River by the proposed new facility must be assessed in the context of current and predicted future discharges from the entire AECL property.

Regulatory problems

AECL-Chalk River has stated its intent to use the cavern for "co-disposal" of its own "low-level" wastes, which contain roughly 35 times the activity of the Port Hope wastes in only one eighth the volume (AECL 1987). Although the "average" AECL wastes would therefore be several hundred times more radioactive than the Port Hope wastes, they were ignored in the environmental screening of the proposed facility. Co-disposal would apparently not be designed to remediate existing waste problems, but would involve placement of newly generated, higher activity wastes.

The Atomic Energy Control Act would allow AECL to put its own wastes in the cavern without any special licensing procedure. An existing property that has a license (such as AECL-Chalk River) need not obtain a separate license for a new facility on the same property. In theory, even high-level nuclear fuel wastes could be placed in the cavern with little or no regulatory oversight.

References

AECL. 1987. Inventory of waste quantities. Low-Level Radioactive Waste Management Office. Atomic Energy of Canada Limited. Research Company Head Office. Cat. No. M39-51/1-2E.

Joshi, S.R. and McCrea, R.C. 1992. Sources and behavior of anthropogenic radionuclides in the Ottawa River waters. Water, Air and Soil Pollution 62: 167-184.

PA-2. 1995. Preliminary performance assessment of a proposed low-level radioactive waste disposal facility - Town of Deep River. Siting Task Force Tech. Bib. No. 420. Dept. of Natural Resources Canada, Ottawa.