Presentation to the Honourable Anne McLellan, April 30, 1996
O. Hendrickson, Ph.D CCRC, Box 981, Pembroke, ON K8A 7M5
Madame Minister - The main issue here is responsible management of radioactive wastes. The Siting Task Force has asked you to issue a determination that building a leaking toxic and radioactive waste dump next to a major water body would have no significant negative effects. To put it another way, the STF has asked that a leaking radioactive dump be removed from Lake Ontario, and another one built on the Ottawa River, at a cost of hundreds of millions of dollars.
Significant negative environmental effects of this proposal include:
- transport of radioactive materials through populated areas... two train derailments have occurred in Petawawa in the last 11 years - most recent one on March 4 of this year
- surface discharge of contaminated water during waste emplacement - the cavern will have to be pumped out continuously during its operation
- most notably, contamination of groundwater with toxic wastes and migration of these wastes through bedrock to the Ottawa River, less than 500 metres from the cavern
Document PA-2, the Preliminary Performance Assessment, is the key technical document for this proposal. It was released AFTER the September 21, 1995 referendum that approved a Community Agreement in Principle to site the waste facility within the municipal boundary of Deep River. Some of its findings were included in the "IA Report" - the actual environmental assessment issued before the referendum. PA-2 clearly shows that the proposed facility would contaminate the Ottawa River with arsenic, radium, and uranium.
The entire AECL property is in a seismically active zone with numerous faults. The highly fractured, porous bedrock at the proposed N-1 site supports high rates of groundwater flow directly to the Ottawa River. This site is not suitable for containing radioactive wastes. Only one borehole has been drilled at the actual site, but more data would definitely not alter this conclusion.
Of the 130 technical documents issued by the STF, only PA-2 analyzed the capacity of the proposed site to contain radioactive wastes. However, the results of an earlier study of bedrock geology (STF Tech. Bib. No. 338, 1994) were altered to suggest that an analysis of waste containment was made:
p. 79 (SUMMARY) Based on these average fracture characteristics and other geomechanical and hydrogeological data, the mapped bedrock at CRL would be considered fair to good quality rock... for engineering purposes.
ii) (EXECUTIVE SUMMARY) Based on these average fracture characteristics... the mapped bedrock at CRL would be considered fair to good quality rock for siting a LLRW management facility.
The Executive Summary of the IA Report itself also contains a highly misleading statement. 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, Figure 11.3.7 shows arsenic concentrations over 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.
There are also a number of significant unknowns with this proposal:
- risks to workers building a cavern in unstable rock
- radiation exposure of workers in the underground cavern
- AECL has received the right to "co-dispose" 25,000 m3 of its own wastes in the cavern. These wastes would be, on average, about 250 times more radioactive than Port Hope wastes. Their characteristics, migration pathways, and health effects are completely ignored in the IA Report. They are likely to contain over ten times the total radiation of the Port Hope wastes
- 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... Joshi and McCrea 1992 shows Ottawa River fish are already contaminated by AECL discharges
- The IA Report lacks believable cost estimates for the proposal. A mined cavern for LLRW has been built in Sweden at a cost of $300 M. The IA Report suggests that a cavern could be built in Deep River for over eight times the volume of wastes at less than half this cost - $138 M
Three other concerns with this proposal
- The option of "permanent, non-retrievable disposal" and the proposed location of the facility were both chosen by AECL, not Deep River. Alternatives for improved storage and management arbitrarily ruled out. The original STF recommended "rather than permanent disposal, the concepts of improved management and long-term storage, with the ability to monitor" these wastes
- Putting compensation ahead of technical acceptability sets a dangerous precedent for environmental assessment. suggests a short-term benefit to one community is an acceptable trade-off for serious long-term environmental and health costs
- The impact assessment and supporting documents have not received any independent scientific and technical reviews. It would be highly irresponsible to make a determination until these have been done
I conclude that you must either abandon this project, or create a public
Panel with a mandate to examine all alternatives, including long-term monitored
storage of these wastes.