Home      About Us      Press Releases      Reports      Events      Committees      Join FARE      Contact «Reports Low-level plan found wanting Liner system for waste called problematic This abstract of a scientific peer review study of the Port Hope Initiative's preliminary plan for storing low-level waste has been posted on the CNSC's website. It shows serious deficiencies that need to be addressed as the low-level clean-up heads for licensing -- including the long-term viability of the repository for storing the waste in Welcome. Here is the CNSC's report: RSP-0219 Review of Liner and Cover Design and Construction Plans; The Port Hope Long-term Low-level Radioactive Waste Management Project Preliminary Engineering Design Report Volume 1. Design and Operations Plan LLRWMO-1340-PDD-12001, Revision 0, R. Kerry Rowe Inc. The conceptual design for the cover and liner proposed for the Port Hope Project Long Term Waste Management Facility, as detailed in the Preliminary Engineering Design Report [Volume 1, LLRWMO-1340-PDD-12001, Revision 0, July 2006] (the Report) is considered to be generally sound. Provided the issues raised in this review are addressed and provided that the detailed design, specifications and construction drawings are subjected to a thorough peer review to confirm that the issues raised herein have been addressed, it is considered likely that the “less than 1mm/a seepage rate” out of the landfill assumed in the Environmental Assessment Study Report will be achieved over the 500 year period being considered. The comments made in this review should be read in context. The Report that was reviewed is a Preliminary Engineering Design Report and as such contains a level of detail adequate for conceptual review but not for fully assessing the eventual performance. Greater details would be expected to be provided in the Detailed Design Report, including detailed specifications and construction quality control and assurance procedures. While this review identifies issues not addressed in the Report that need to be addressed, this is not meant as criticism since these details would not generally be provided in a Preliminary Engineering Design Report. Rather they are provided as a “check list” to assist in the preparation of that report and in the review of that report. It is my opinion that provided these issues are addressed (and I consider it feasible to address all of these issues), this landfill can provide safe long-term containment of the proposed wastes. There is no reason that a primary leachate collection system with a design life of many hundreds of years could not be designed for this site. However the current design does not, in this reviewer’s opinion, provided for adequate assurance of long term-performance for the primary leachate collection system. Specific factors to be considered in the revision of the design of the primary leachate collection system and preparation of the detailed design report, construction drawings and specifications have been itemized. Given the nature of the waste and provided that the design of the primary leachate collection system is revised to respond to the issues raised in this review, the design of the secondary leachate drainage layer with a hydraulic conductivity to exceed 1x10-4 m/s is considered reasonable. However it is recommended that redundancy is added with respect to the sump in the secondary layer (as well as in the primary layer). The Report provides some indication of factors to be considered with respect to the compacted clay liner. This is reasonable as far as it goes. However in order to prepare the final detailed design and specifications, additional work is needed as indicated in this review (including consideration of clay-leachate compatibility). The Report does not address the potential for cation exchange between the geosynthetic clay liner (GCL) and adjacent soil or the potential effect on GCL hydraulic conductivity. Nor does it adequately address the potential for freeze-thaw of the GCL in the landfill cover. To provide confidence that the assumed low hydraulic conductively of the GCL proposed for the cover will be achieved, it needs to be demonstrated that either: (a) frost will not reach the GCL; or (b) the geochemistry of any pore fluids in soil adjacent to the GCL is such that significant cation exchange is not likely. The Proponent has indicted that “it is anticipated that … the potential heat generation from decomposition of the organic component of the co-mingled waste will be significantly less compared to typical MSW landfill sites” and that “there is no measurable heat generated due to radioactive decay of the waste. Based on the above, it is expected that the temperature of the liner system will be very similar to the natural ambient temperature of the surrounding ground.” Presuming that this information is accurate, the liner temperature can be expected to be less than 20oC which will give an acceptable (greater than 500 years) service life for the geomembranes and minimizes any risks of desiccation of clay liners due heat generated by the waste. However, it is recommended that the liner temperature be monitored in each cell to confirm the validity of the assertion that the liner temperature will be very similar to the natural ambient temperature of the surrounding ground. Both GCLs and compacted clay liners (CCLs) are susceptible to shrinkage and desiccation cracking, particularly when below a GM in a composite liner. The Report does not adequately address measures to minimize the risk of desiccation of the CCL or shrinkage and panel opening of the GCL during construction. Thus the detailed design report should address: (a) the construction procedures that will be adopted to ensure that there will be no desiccation of the CCL before or after covering with the geomembrane and prior to placement of waste; and (b) specification of a GCL that has a low probability of shrinkage. Leakage through the proposed composite liners at the LTWMF will be highly dependant on the presence and size of holes and the coincidence of the holes with wrinkles. Thus there is a need to (a) detect and repair holes formed during construction, and (b) minimize the potential development of holes during and after waste placement. The comments in the Report regarding geomembrane installation and testing of seams are reasonable in the context of a preliminary report but will need elaboration in the detailed design report. The Detailed Design Report should adequately address: the performance a leak detection survey shortly after construction of the liner system and the repair of holes; limits on gravel in the foundation soil to be placed below the geomembrane/composite liner; protection from damage or strains that could ultimately cause stress cracking due to indentation caused by gravel in the granular drainage layer; wrinkles in the geomembrane; construction methods and inspection procedures that minimize the risk of holes being formed in the geomembrane during placement of the drainage layers or the select waste; and procedures that minimize the risk of damage to the geomembrane during the operating life of the landfill (e.g. if there is a need to move waste or drums for any reason). The current design has granular layers above the geomembrane (in one case separated from the geomembrane by a geocomposite and in once case by a geotextile cushion). Provided that these layers are specified to be sand that does not contain angular particles (or isolated gravel) that could perforate the geomembrane, they should provide adequate protection of the geomembrane assuming that appropriate construction specifications are adopted. The geocomposite above the primary geomembrane has the potential of inducing tensile strains in the underlying geomembrane. If this is retained in the design, testing would be required to confirm that the proposed geocomposite will not induce significant tensile strain in the geomembrane under simulated field conditions. If the design is modified to address the concerns raised in this review regarding the design of the primary leachate collection system to include a coarse gravel drainage layer (as per O. Reg 232/98, Schedule 1), there will be a need to provide adequate protection of the geomembrane. A sand layer that does not contain angular particles (or isolated gravel) has the potential to provided this protection. Wrinkles in a geomembrane increase the potential for contaminant migration through a hole in the geomembrane at or near the wrinkle and the potential for development of future holes. The Report does not address the issues related to wrinkles. While it is difficult, and not essential, to construct without wrinkles, the construction specifications and the detailed design report should address the issue of minimizing wrinkles that will remain once the geomembrane is covered. The calculations of leakage through composite liners used in the Environmental Effects Assessment Report (Appendix C) appear to be based on techniques that underestimate the observed leakage through composite liners and do not take account of the effects of wrinkles. In this reviewer’s opinion, the leakages ultimately observed at the LTWMF are likely to exceed that indicated by the calculations in Appendix C even assuming good design, construction and construction quality control/assurance. The consideration of both advective and diffusive contaminant transport and the use of the Program POLLUTE in the Environmental Effects Assessment Report is considered appropriate. However the selection of parameters and the modelling itself (as reported in Section D8) was not reviewed since it is beyond the scope of the present assignment. The long-term performance of a geomembrane will depend on the geomembrane properties, the tensile strains in the geomembrane, the exposure to chemicals in the leachate, and temperature. The detailed design report will need to provide detailed specification of geomembrane properties that will maximize the likely service life of the geomembrane. The geomembrane should meet the specifications of both GRI GM-13 and O. Reg 232/98 (Schedule 3). The tensile strains in the geomembrane can be minimized (and hence its service life maximized) by: (a) minimizing the potential for angular particles (e.g. gravel) in the soil below the geomembrane/GLC composites and in the CCL in the geomembrane/CCL composite; (b) having adequate protection above the geomembrane; and (c) minimizing wrinkles in the geomembrane. The Report indicates that “there are no maximum concentrations that would exclude material from being required to be managed at the LTMWF” (§8.1, p. 8-1). Thus it will be important that waste containing contaminants that would reduce the service life of the geomembrane, and especially waste with high concentrations of these contaminants (e.g. hydrocarbons, surfactants, trace metals etc.) be located in the waste pile well away from the liner system. This should be addressed in the detailed operations plan. It is also recommended that the leachate characteristics be monitored with time. Assuming that: (a) the HDPE geomembranes specifications meet both GRI GM-13 and O. Reg 232/98 (Schedule 3), (b) the issues identified in this review are adequately addressed, (c) the temperature of the geomembranes does not exceed 20oC, and (d) the leachate characteristics with respect to contaminants that can impact on the geomembrane service life are not higher than found in MSW leachate, the service life of the geomembranes in the primary and secondary liners are estimated to be of the order of 600 years and hence in excess of the 500 year design period for the facility. The 2:1 berms inside the landfill are considered steep and may induce undesirable stresses in the liner system (especially the geomembranes). It is recommended that these slopes be reduced to 3:1. The Detailed Design Report should include details regarding the testing, inspection and monitoring programs to be conducted prior to, during and following construction of the liner, during operations and following closure of the facility. The Report addresses a limited number of these issues. This review has highlighted a number of factors that should be considered in the Detailed Design Report. There should also be an independent (3rd party) firm, experienced in CQA for lined landfill facilities with both geosynthetic and compacted clay liners, retained for Construction Quality Assurance. This review has identified a number of issues that need to be addressed in order to minimize leakage to the underlying groundwater. Provided that these issues are adequately addressed and appropriate Third Party Construction Quality Assurance is provided during construction, it is considered likely that the long-term post closure annual average leakage out of the landfill to be less than 1mm/a assumed in the Environmental Assessment Study Report over the specified 500 year facility design life. Lakeshore Road residents should be applauded Why is broken pipe contaminating lake? Low-level plan found wanting Liner system for waste called problematic CNSC advised it's too cozy with industry Conflict of interest: We told them that What to do if Cameco burns Emergency plan says buy a lot of duct tape Briarpatch magazine interviews FARE How citizens thwarted the nuclear industry Our new council: Where they stand on Cameco emissions The stigma of risk: Assessing the cost of living in the plume International studies show the social price we pay Cost of Cameco on our waterfront: $6 million a year FARE consultant lists jobs, taxes we'd gain if it moved elsewhere Peer review says SEU screening fatally flawed Town council's intervention called for health testing Town tells CNSC: Answer us or else Peer review team acknowledges "the high level of sustained public concern." An intervention by Farley Mowat "One more ounce of contamination would be an ounce too much" Why CNSC screening was inadequate Sierra Legal Defence Fund files brief on behalf of FARE Why we shouldn't trust the CNSC David Craig's commentary aired on CHUC CNSC screening report on Cameco EA This was released on May 11, but was not put on the regulator's website At last: CNSC report on Cameco's mid-term review It notes the many interventions by FARE members FARE affidavit for panel review Waterkeeper submission to CNSC on May 19, 2005 Dr. Eric Mintz February 2004 health study report A critique of the Mortality Study for Port Hope 2002 Letter from FARE to Federal Minister of the Environment Unresolved concerns of the people of Port Hope (5 April 2005) Prepared by Families Against Radiation Exposure and Port Hope Community Health Concerns Committee at the request of Paul Macklin, MP 22 July 2004: The 623 questions raised by the Research Sub Committee CNSC: A lax regulator FARE documents how little it did to force compliance between 2002 and 2004. admin@ph-fare.com P.O. Box 202 Port Hope, Ontario L1A 3W3 Questions or problems regarding this web site should be directed to admin@ph-fare.com. Copyright © 2005 Families Against Radiation Exposure, Inc. All rights reserved. Last modified: 15 April 2005 Archived Information » top of this page « administration

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