Ottawa Riverkeeper submits written comments to the CNSC concerning the 2019 Regulatory Oversight Report for Canadian Nuclear Laboratories

In 2019, Ottawa Riverkeeper was provided with participant funding to submit a written intervention concerning the impacts of the Chalk River Laboratories to the Ottawa River. This is a summary of our submission.

Contributed by Pippa Feinstein

Canadian Nuclear Laboratories operates the Chalk River Laboratories (CRL) site in the municipality of Deep River. CRL is comprised of multiple nuclear facilities, some of which are operational while others are no longer functioning, as well as several waste areas. For many years, Ottawa Riverkeeper has been involved with decision-making processes concerning CRL via the Canadian Nuclear Safety Commission (CNSC) licence renewal processes. We are also a member of Canadian Nuclear Laboratories’ Environmental Stewardship Council. 

In Spring 2019, the CNSC announced it would hold a meeting to consider a Regulatory Oversight Report (ROR) concerning Canadian Nuclear Laboratories facilities, prepared by CNSC staff. Ottawa Riverkeeper was provided with participant funding to submit a written intervention concerning the impacts of the CRL to the Ottawa River. 

This submission aimed to provide an evaluation of deficits in public information disclosure by Canadian Nuclear Laboratories at Chalk River and an overview of some potential environmental impacts to local streams and lakes. Ottawa Riverkeeper also sought to document past activities as well as current operations in order to provide a better understanding of the CRL site. 

Within the ROR, we focused on three main issues: 

  1. concerns over legacy and contamination issues at the site and the degree to which they are being contained; 
  2. concerns over regulatory gaps in government oversight of CRL;
  3. concerns over the lack of transparency around CRL, including CNSC procedural and public information deficits. 

1. Concerns over the environmental impacts of CRL facilities and waste sites on the Ottawa River

CRL’s earliest facilities were built during the Second World War, and many of the site’s reactors and waste areas predate the country’s nuclear regulations, as well as many of our environmental laws. Much of the development, and the earliest accidents and malfunctions at CRL also occurred at a time when much less was known about nuclear energy and its relationship with the environment. All of this means that certain legacy environmental issues at the site are still present today.

Several Chalk River facilities directly border the shores of the Ottawa River and are in close proximity to several lakes, including Perch Lake and Sturgeon Lake. Contaminated water leaching from the waste management areas makes its way to these lakes via groundwater. Many of the CRL facilities are also surrounded by wetlands, creeks, and other watercourses intimately connected to the ecology of the Ottawa River watershed. 

In our submission, Ottawa Riverkeeper reviewed and provided descriptions of the largest nuclear facilities and waste sites at CRL, discussing the histories and main environmental concerns related to each of them. We also made a series of recommendations to improve current environmental monitoring activities of these facilities and waste sites. These included: clearer characterization of strontium and tritium plumes in the groundwater from CRL facilities and waste management areas; more information concerning the revised stormwater management system for the site; and more details concerning the efficacy of current wastewater treatment efforts at CRL.

2. Concerns over gaps in the regulatory oversight of CRL

It was especially important to get Ottawa Riverkeeper’s description of the larger facilities and waste sites on the public record in this intervention, because the current licence for CRL does not specify the individual pieces of infrastructure to which it applies, nor do Canadian Nuclear Laboratories or the CNSC provide a permanently available online map of the site and its buildings, waste areas, or environmental management infrastructure. This lack of transparency is further frustrated by the fact that the CRL’s Licence Conditions Handbook (LCH) is becoming increasingly vague (1), and relying on less transparent and rigorous verification criteria (2). LCHs contain important  details about licence conditions for specific sites or aspects of operations. Further, the licence only includes licence release limits for one third of the CRL site, not adequately addressing contamination around Maskinonge or Perch Lakes, despite the fact that both feed into the Ottawa River. Finally, release limits that are specified in the licence may not be comprehensive enough (3), or take into account ecological contaminant thresholds (4)

Ottawa Riverkeeper also requested more information from the federal Department of Fisheries and Oceans and Ontario’s Ministry of Environment, Conservation, and Parks concerning Fisheries Act permits and Environmental Compliance Approvals for CRL facilities. While nuclear regulation is primarily the responsibility of the CNSC, other agencies at all levels of government are also responsible for ensuring that nuclear facilities protect local waterbodies and ecosystems. Ottawa Riverkeeper sought to ensure relevant authorities were collaborating to comprehensively address the environmental impacts of CRL. 

As of the time of submission, we are still awaiting responses from both Governmental agencies.

3. Concerns over the lack of public access to information concerning CRL facilities and operations

Ottawa Riverkeeper recommended improvements to public information sharing to better facilitate the public’s right to know about the facilities and their operations. This included a request for real-time public environmental data disclosure, and better public reporting of unplanned events at both facilities. We also highlighted procedural deficiencies in the ROR meeting process that frustrated attempts to ensure fulsome public disclosure of environmental information.

Conclusion

Ottawa Riverkeeper’s participation in the ROR process allowed us to formally submit our comments regarding the oversight of this facility, document what information is publicly available, and to provide recommendations to improve transparency and reduce environmental impacts at the Chalk River Laboratories site. The information obtained through this process details the complexities and challenges present at this site. You can read the entirety of our ROR submission (Only available in English) on our website here. We remain concerned about the impact of the CRL site and are committed to intervene where possible in order to protect the Ottawa River.

1. 56 licence conditions from the previous LCH were not included in the current LCH, many of which had contained important particulars about licence conditions for specific sites or aspects of operations.
2. Marked by a move toward Canadian Standards Association (CSA) criteria which are less facility-specific and not user-friendly for members of the public.
3. Contaminants of concern identified in the CRL Environmental Risk Assessment are broader than those in its licence or LCH.
4. Only human radiation doses seem to have been taken into account when determining release limits, to the exclusion of ecological or toxic considerations.

One response to “Ottawa Riverkeeper submits written comments to the CNSC concerning the 2019 Regulatory Oversight Report for Canadian Nuclear Laboratories”

  1. Jennifer Cuff says:

    As a resident who lives on the shores of the Ottawa River, I am passionately concerned by the nuclear waste that is leaching into our River. I hope to stop this irreversible damage to our waterways.
    In unity,
    Jennifer Cuff

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