Forum: Waste minimization

This will be my first comment, of many, as I make my way through your discussion paper. Question #1 "my views on waste minimization". Your own paper defines waste minimization as, "The waste hierarchy states that prevention, reduction (minimization), re-using, and re-cycling, should be favoured before disposal. Disposal is the only appropriate strategy if all other options have been exhausted." This argument is being used to support development of SMR's because the radioactive spent fuel from current CANDU reactors will be 're-cycled' into high-grade radioactive fuel. What a load of garbage! This isn't "re-cycling" - it is a dangerous game producing weapons-grade plutonium with plans to ship it to both highly-populated and remote regions! This is the sort of chess-like misuse and misdirection used by our 'government' to pre-shape the end-game. The nuclear industry has its hand in the waste and production game equally, and so far they rob Peter (proper storage is abysmal in 2020) to pay Paul (they're hoped-for SMR daydream, currenly awash in fresh tax-payer grants). A simple lay-person like myself can see the misuse of conceptual frameworks from the outset. For shame! The only 'minimization' factor worth any credit is to turn these reactors off immediately, and focus all our attention on hydrogen, solar, wind, batteries, geothermal, smart-grid and building renovation technologies. Furthermore, your language around minimization includes, "...incineration and compaction. These technologies are commonly practiced internationally". I live directly downwind from the incinerator at Blind River and I have never, once, been publicly informed of the risks I endure as a gardener and citizen. To placate citizens with 'commonly practiced internationally' is a rhetorical salve used to misdirect and obfuscate. Tell us in your discussion papers exactly what is going on, and where, if you want us to participate in well-informed citiizen engagement. Otherwise, you are only engendering more mistrust.

Thanks Sarah for your well informed and lived experience of dealing with the nuclear industry and its attempts to silence citizens with their well funded marketing narratives. I want to add to your list of concerns with "waste minimization". The 2015 "procurement process" of AECL assets to the private-sector contractor, Canadian Nuclear Energy Alliance (CNEA) resulted in "the transferred ownership of its subsidiary, Canadian Nuclear Laboratories (CNL), to the CNEA. Under a Government-owned, Contractor-operated (GoCo) model, the Corporation delivers its mandate through long-term contracts with both the CNEA and CNL, together called “the contractor”. The Corporation retains ownership of all lands, facilities, intellectual property, other assets, and liabilities." (https://www.oag-bvg.gc.ca/internet/English/parl_oag_201711_07_e_42672.html). This 2017 Auditor General report indicates that "$530 million for decommissioning and waste management" is being turned over this private sector consortium with the majority of partners being American corporations and SNC Lavalin (http://www.cnea.co/consortium-members/). With the new agreement between Canada and the United States to collaborate, waste management is part of this work (https://www.cnsc-ccsn.gc.ca/eng/resources/international-cooperation/inde...). The US recently announced its efforts to include low-level radioactive waste from nuclear reactors plants to be placed in municipal dumps. The reprocessing procedures for SMNRs required sealed containment of the existing high-level waste be opened so access the spent fuel so it can rendered into the SMNR fuel. All the existing containment concrete and devices are then waste that requires disposal. I have yet to see or read anything about the amount of radioactive waste that will be generated with this proposed "waste minimization" process or how this waste will be classified and how it will be safely disposed. My fear is that municipal dump sites will become the location for these types of wastes as the US is now proposing. In New Brunswick, Point Lepreau is located on the shore of the World Heritage Bay of Fundy. The last thing we need another Sellafield that has made the Irish Sea the most radioactive body of water in the world. The Bay of Fundy is too important to everyone in New Brunswick and Nova Scotia and the world. Remote First Nations and indigenous communities are already over-subscribed with legacy impositions of far-away engineered "solutions" leaving them impoverished, without drinkable water sources, contaminated sites. The last thing they need is another engineered nuclear reactor in their community producing radioactive materials that will then require decommissioning and disposal after its short operational life (if they ever become a reality). These discussion papers seem to ignore these concerns and how they might be properly addressed by citizens. What is missing from these papers seems to me to be more important than what I am reading

Some 8 years ago as a councilor for the municipality of South Bruce we began participating along with 8-10 other communities in what the Nuclear Waste Management Organization (NWMO) referred to as a learning exercise in the process of disposing of all of Canada's spent nuclear fuel rods. (CANDU reactors) At that time we were told it was limited to the current stock pile of spent fuel and would be disposed of in a deep geological repository. Spent fuel from SMRs was not discussed because such reactors were unheard of at the time.
However, wording of NWMO's current fact sheets and confirmed by the Canada Nuclear Safety Commission at a community meeting, if we become "a willing host" the dgr site will have to adapt to any future incoming waste from the new reactors. ( I suppose that's why the NWMO calls this concept Adaptive Phased Management )
Within 2 years our community of some 5800 will be asked to decide as to whether we are an "informed and willing community" able to show as the NWMO has stated "a profound level of support" for this proposal. It seems to me difficult to come to such a conclusion in that time frame when the rules of engagement as to what we are getting dumped on us keep shifting to the unknown impacts that SMR's will bring.

It seems there is a missing component to considering the desired level of waste minimization, which also applies into the hierarchy selection process. The general principle of reducing waste and disposal is fine but should be informed by the energy requirement of reducing or moving between steps in the hierarchy of waste treatment. If it takes say 50 kWh energy to avoid a waste (per instance) that would use 10 kWh and 0.1m^2 in disposal, that might not be a step worth taking. The energy difference might be bring greater benefit applied elsewhere - maybe even just as additional energy supply to society at large.

I am also suspicious about the "endless" nature of "minimization", in the wrong PR hands.Obviously stretch goals help innovation - until they don't, because they're not feasible. But we should understand what is acceptable, not merely say "it must be as small as possible". So meet some objective criteria per unit energy, and get applauded or otherwise rewarded for continuing to do better. There isn't a zero waste system, and we shouldn't punish energy producers for waste that is at realistically acceptable levels.

There should be no case where nuclear plant refurbishment or new SME plants should be considered without a full cost accounting of the related DWR (Deep Waste Repositories) required for the indefinite storage of both current and existing spent fuels and contaminated materials. One need only look to the deep waste repositories in Germany for an example of what is required (in 1.4km deep, geologically stable basaltic). Placing surface storage in an active seismic zone on the headwaters of the principal drinking water reserves of major cities and even smaller municipalities is incredibly short-sighted. As an architect deeply involved in the technical adjudication of large commercial buildings, we can deliver projects with upwards of 75% reductions in total energy use. We do not need to continually refer to the necessity of powering a low-carbon future with nuclear - as conservation and DSM csot as little as 1/10th the cost of new generation capacity - even without factoring in waste storage facilities. WWS (Wind Water and Solar) combined with massive reductions on demand-side should have an absolute priority over costly nuclear solutions - the problem is the entrenched nuclear lobby and knowingly corrupt players (SNC to name but one). Get out of the game of hot garbage grift Canada - take a lead on the issue and find a way out of this mess. From a citizen with a property and business on the Ottawa River.

Canada and it's nuclear industry needs to continue it's efforts on waste minimization and indeed increase it. The waste hierarchy is a crucial element when dealing with ANY waste but certainly with regard to radioactive waste. It is wholly inappropriate to continually use new "virgin" material when it is possible to either reuse or recycle material that is presently considered to be waste. One of the aspects that needs to be taken into account is that much of the material which is considered to be radioactive waste is not fuel nor exceptionally contaminated. Large quantities of, for example, metal is relatively easy to either decontaminate or reduce the volume of and it is tragic that this material is not reused either within the industry or if proven to be clean, for general use.
The other factor that needs to be considered in the justification of waste minimization is the cost and availability of disposal sites. At present, there are no available disposal sites in Canada for waste which needs to be disposed nor is there likely to in the near future. The arguments for why this is the case are not really appropriate for discussion here but until such facilities are available, then interim storage is the only option and such storage facilities are quite expensive to construct to a standard that meets the safety and security standards for such materials. In addition the cost of building geological disposal facilities are exceptionally high and therefore it is imperative for both the environment and the Canadian Taxpayer that these facilities are as small as possible and reserved for material where there really is no alternative waste routes.

After reading the previous responses I see a familiar trend of NIMBY-isim and anti-nuclear blanket statements. We have declared a CLIMATE EMERGENCY and recent analysis (IEA, IPCC, and most recently the EU "Road to EU Climate Neutrality by 2050") declares that nuclear needs to be increased rapidly if we are to meet our climate targets. Fossil fuels continue to be increased and people are dying from the emissions and the environment is under attack (acidification of the oceans, mercury increases in water, SOx and NOx emissions, etc.).

I agree with the current policy about waste hierarchy and I have seen this actively utilized in the nuclear industry (different containers for different types of waste, utilizing a reusable plastic suit, etc.). This also makes sense economically since it is expensive to deal with nuclear waste so whenever possible this process should be followed.

I am worried about statements such as "minimizing the generation of radioactive waste means decreasing the volume of produced waste quantities" for a couple of reasons:

1. There is no mention of optimization or the benefit from a never-ending minimization process. Ultimately the best way to minimize the generation of radioactive waste would be to never continue with nuclear power generation, or research facilities, or medical treatments/research. However, this literal interpretation of the statement would not take into account the net positives that nuclear contributes (i.e. nuclear power is a clean generation source that NASA cites has already saved millions of lives (https://www.nature.com/articles/497539e) and medical isotopes are used for cancer treatment and are utilized in sterilization techniques for food and medical equipment).
2. I also consider the phrase "decreasing the volume" to be misleading - I can utilize various techniques (compaction, incineration, filtration, evaporation) which would decrease the volume but would increase the concentrate the activity into a smaller volume which may alter the strategy for disposal/transportation. Instead the statement should include some mention of activity and volume since the two are interrelated.

Another aspect to consider is new research contradicting linear non-threshold models. The TENORM, LLW, and non-radioactive waste activity limits should be revisited if research shows the low levels of radiation have hormesis/non-harmful effects in which case certain amounts of waste would be dealt with outside of the Radioactive Waste Policy and therefore free up resources for other programs.

The four pillars of the waste hierarchy are really not a hierarchy but, properly used, act as a support for minimization of waste and minimization of radiotoxicity as a whole.

Prevention: It could be misinterpreted as not pursuing nuclear and forgoing its huge benefits. That is a self-defeating approach in light of the need for huge quantities of non-carbon energy and, for instance, the many medical applications of radioactivity.

However, prevention should be practiced as part of all designs of structures that are near neutron-emitting cores of reactors. On decommissioning it was realized that the deliberate omission of elements such as niobium as in the stainless steel of a reactor tank would have been a good preventative measure. Niobium becomes activated to Nb-94 with a half-life of 20,000 years, rendering the steel useless for re-use, turning it into long-term radioactive “waste”.

Reduction: Volume is only one aspect. But reduction in radioactivity can be a major factor if the other two pillars, re-use and recycling come into play. Take used CANDU fuel. At the moment its long-lived million-year radioactivity is a major concern. Being a solid, its volume cannot be reduced much.

But examined in detail, used CANDU fuel is not waste at all. Less than 1% of the material has yielded energy from the splitting of its heavy atoms, leaving a fission product residue of medium-sized atoms. Of these about 70% are non-radioactive valuable atoms immediately, while the remainder decay to stable atoms relatively quickly, requiring only safe storage during that time rather than permanent disposition. Only about half a dozen fission products have very long half-lives, with the result that their radioactivity is less than the natural uranium atoms from which they originated.

All the other atoms in used CANDU fuel are heavy, either uranium (mostly) or transuranic elements created in the reactor by neutron irradiation of uranium. Each of them, like uranium itself, can yield about 200 MeV of nuclear energy when split. This energy can all be extracted in a type of SMR, or larger reactor, called a fast-spectrum reactor. Such reactors have existed in research and commercial versions in sizes from 20 kWe to 800 MWe starting in 1951.

This has two major consequences. It extracts over 100 times more non-carbon energy from the used fuel. Second, in splitting the heavy atoms with their million-year radiotoxicity it produces stable fission products (70%) or atoms with much shorter radioactive half-lives.

The choice of such reactors fulfills the first pillar of waste minimization in that massive stockpiles of used fuel waste are avoided.

Second, the amount of material remaining, the fission products, is reduced to less than 1% of the mass of the current used fuel for every MW-h of energy produced.

It all gets done by invoking the third and fourth pillars, re-using the existing used CANDU fuel and recycling it through fast-spectrum reactors.

The following general comments apply to the four Discussion Papers, including the paper on "Waste Minimization"
• the linkages between the discussion papers are not acknowledged or identified
• the discussion papers are not placed in an overall context of radioactive waste management principles and policy objectives
• the discussion paper descriptions present a non-critical approach to current practices
• the discussion papers lack references or links to support the statements and content

While we appreciate that the intent of the discussion papers was to provide a brief overview, but the paper on waste "minimization" used a lot of its page space to describe current practices (strategies vs policy) but was selective in how it presented current practices.
In the context of a paper that described current practices, the NRCan Discussion Paper on Waste Minimization was selective in how it presented current practices, or even the range of current practices. It also excluded any analysis of the health, social or environmental consequences of these practices. For example, the following areas are directly relevant, but where either missing or inadequate in their presentation:
- Descriptions of current practices and operations in Canada that are only very generally referred to in the description of strategies but are not even explicitly identified, including incineration of low level radioactive waste, compaction, and export of radioactive wastes internationally for “processing” and the required repatriation of concentrations of those radioactive wastes
- Discussion of environmental and health effects and risks related to minimization practices, such as incineration
- Discussion of “Clearance” levels for radioactive wastes, and the relationship between clearance levels and the free release of radioactively contaminated materials into landfills and municipal water systems, including the policies and principles that seemingly allow these practices in Canada
- Policy implications of “recycling” or reprocessing of radioactive wastes, including as it relates to the potential contamination of metal streams, such as steel, and related concerns around security and proliferation in the case of recycling or reprocessing high level nuclear fuel waste
- Principles of protection of human health and the environment in relationship to preventing or mitigating the known or potential health and environmental impacts of radioactive waste reprocessing / recycling
- Linkages between this discussion paper and the decommissioning discussion paper, particularly related to clearance levels for the decommissioning of radioactive sites or clean up projects such as at Port Hope

Q1. What are your views on waste minimization? Should Canada continue to use the concept of the waste hierarchy?

A 1. The first principle in waste management is waste avoidance – no more production. The waste hierarchy developed for other waste materials does not transfer onto management of radioactive wastes, given the radiological risk and the radiological contamination that occurs if radioactively contaminated materials were mixed with non-contaminated materials (for example, if radioactive contaminated steel were allowed to enter the commercial steel recycling waste stream)

Q2. What should be the role of government, regulator and waste owners with respect to minimizing radioactive waste?

A2. To achieve the first policy goal of waste avoidance the Government should adopt an energy policy that drives the phaseout of nuclear power and radioactive waste production. Energy companies, such as provincial utilities that currently operate nuclear reactors (i.e. radioactive waste generators) should shift in their supply options to clean energy sources that produce no wastes while generating electricity, i.e. renewables. In the interim, regulators should ensure that waste generators are carefully isolating and containing any radioactive waste generated, avoiding cross contamination and release to the environment.

Q3. Are there other principles, beyond those identified by the International Atomic Energy Agency, that you feel are important to consider when designing and implementing a waste minimization program?

A3. Additional IAEA principles include protection of human health and the environment, protection of future generations, avoiding burdens on future generations, and safety and control. The IAEA has also identified relevant objectives, including transparency, security, non-proliferation, continual improvement, and long-term commitment. As with all nuclear operations, the U.N. Declaration on the Rights of Indigenous Peoples must be applied.

I attended this morning's RT and would like to raise two points of order:
1. No accommodation for French! With the federal government's vast resources, this is unacceptable. I hope it's unlawful to boot.
2. A starting time of 9:30 a.m. EST means someone from B.C. had to tune in at 6:30 a.m. their time. Unreasonable! I admire the person from Alberta who joined at 7:30!

1. I must ask, what kind of blurring language or concept is "minimization"? I propose a principle of honest language. This proposed word (a weasel word, really) becomes deceptive packaging, since the total net amount of radioactive waste (both at mining sites, and man-made radioactive waste) continually grows rapidly, with no proven solution to deal with it.

So, "minimizing" the increase? But still continue the increase? Changes is cubic volume is minor. It's like the difference between accelerating to 200 km/hr slowly versus quickly. Meaningless. Is this not clever but deceptive playing with words? How can there be truthful minimization except by desisting from growing the amount of further radioactive materials?

2. The problem of radioactive waste cannot escape being part of the problem of the eventual cost of the whole nuclear industry. An unbiased examination of cost versus benefit is apparently lacking, both by the industry and by the government ministry.

Who can guarantee absence of destabilizing, destructive wars during centuries or millennia to come? Nation-states come and go in history, but harmful radioactivity ... persists! The need of contamination-free water and environment persists! Animal and human life have needs that persist.

The nuclear industry has always counted on government subsidizing and backstopping it, so it does not face the full force of real economic and health/safety liability issues. Nor does it take the perspective of centuries or millennia. So it tends to remain in an artificial echo chamber of self-serving opinions about its viability. This is not right. This is not in the public interest.

Even with mere consideration of it in terms of dollars, what is the cost in today's dollars of doing anything at all with nuclear waste or nuclear sites, for thousands of years? Huge by any standard, surely.
Years ago, with other art students visiting Elliot Lake, we hiked past uranium tailings, ponds with weird colored water. (Glad no one slipped into them.) Soon, I learned the pottery instructor had been diagnosed with radiation sickness, resulting from clay he had "harvested" somewhere abouts. (Is this the sort of area that will be designated "likely safe"?) Apologies if this was cross-posted.

NB's Point Lepreau Nuclear Generating Station, commissioned in 1983, has underperformed. It has cost billions of dollars to repair and maintain and has just completed its first year, since the early 1990s, without a shutdown. Its projected life is ending before fulfilling expectation. Potassium iodide pills were distributed when the plant was first built, to people living within 20km of the plant. The 20km radius includes marshland, a provincial beach & park & spreads into the Bay of Fundy, an area of diverse plant, bird, & animal populations; the plant itself was built on a live fault line, despite pleas from geologists to reconsider. Is there any wonder why there is a lack of trust in this technology or in the people who make the critical decisions related to it? I am concerned about the minimization hierarchy. I recognize there is as much, if not more danger posed by "cleared" levels of radioactive waste that are now considered acceptable & safe. The fact that there is no tracking system for this is a worry, particularly due to their far reaching & long term effects. Where do they go & how far? One example of waste being treated casually, is on page 23 of the Provincial Health Nuclear Emergency Plan itself that states:"...The SJRH decontamination system has the capacity to decontaminate 9 to 18 people before the cistern capturing waste water would need to be emptied." There is no specific information or further references regarding how this waste water is to be handled or disposed. In addition, some small surrounding hospitals that are under threat of reduction of hours or closure, are also factored into the emergency plan. The authors of this plan clearly did not understand that the 'solution is not dilution' of radioactive waste. What is now being done with spent fuel is basically unknown. Yet, we're expected to place trust in undeveloped SMR technology. The idea of recycling spent fuel has many security concerns ranging from transportation safety to threats of terrorism. Our government(s) need(s) to follow the calendar for decommissioning nuclear reactors and invest in green forms of energy. Further, owners or producers of pollution in any of its forms, need to take responsibility for it. Polluters do not pay and taxpayers are deeply discouraged by this. To be considered in the minimization plan is a need for improved trust, transparency, security, protection of health & environment, and a responsibility to leave a healthy environment for future generations to enjoy. As solutions go, the best way to minimize radioactive waste is to simply stop producing it.

True minimization of used nuclear fuel “waste” can only be achieved by recycling the used fuel through fast-spectrum reactors (FSRs). Otherwise the so-called transuranics (TRUs), Pu, Am, etc., in the used fuel will remain radioactive for close to 400,000 years before the radioactivity level returns to the background level equal to the original uranium.
Consuming the TRUs in FSR types of small modular reactors (SMRs) eliminates the long-term radiotoxicity by eliminating the heavy atoms themselves, splitting them and extracting copious non-carbon energy. Only split atom fission products (FPs) are left, about 70% of which are stable non-radioactive atoms immediately, while the remainder decay in days, weeks or months, with only two isotopes of importance having 30-year half-lives, Sr-90 and Cs-137. Today those are the only radioactive fission products of note left in the oldest Pickering used fuel bundles.
Even those two radioactive isotopes can be extracted according to a CNL expert who noted: “Separation of Cs-137 and Sr-90 from other FPs in a reprocessing waste stream is technically feasible and not difficult at all to me”.
Recycling of used CANDU fuel is part of the modus operandi of at least two of the SMR types considered in Canada at present. Both are FSRs, the SSR-W of MOLTEX and the ARC-100 of Advanced Reactor Concepts. They use variations of electrorefining, or pyroprocessing, that was worked out by the Argonne National Laboratories in the USA and operating since the 1980s. Its only residues are FPs, with all else being recycled.
This reduces the used nuclear fuel immediately to 1%, the FPs. And even those turn relatively quickly into non-radioactive atoms and minerals, platinum-group metals at higher concentrations than the best ores in Africa, increasingly scarce rare earths needed for solar panels and wind turbine motors, and valuable noble gases.
Continuing along the path to a DGR deprives humanity of $ 60 trillion non-carbon electricity via the current 60,000 tons of used CANDU fuel. Recycling provides Canadian enriched starting fuel for the planned SMRs, avoiding importing enriched U235 at twice the cost. And it assures Canada of a home-grown non-carbon fuel supply for centuries.
The Adaptive Phased Management plan is easily changed to recycling by the NWMO, since it was created by the NWMO itself in 2005 and agreed to by Parliament in 2007. The Nuclear Fuel Waste Act of 2002 in its Article 20(2) even provides the legal underpinnings for such a change in direction that adopts new methods of nuclear waste management. Recycling is such a new method.
Recycling provides the only approach to reach the ultimate minimum for nuclear fuel waste. It also maximizes the yield of non-carbon energy from our uranium resources.
Since already two of the SMR vendors are proposing recycling as part of their operating procedure, the NWMO must reexamine its current focus on its non-productive DGR and adopt recycling as its new mandate.

In Canada we have highly flexible CANDU reactors capable of running on various fuel types, and we are progressing towards using SMR's with LEU or HALEU, and SMRs to run on spent fuel. If we take a national approach to develop a coherent closed fuel cycle amongst our different reactor types we would be able to massively reduce our amount of waste, and also almost curtail our need for fresh uranium, particularly if we convert our CANDU's to Thorium reactors. There are so many options to consider. Once-through fuel cycles to disposal creates unnecessarily huge amounts of waste, and at some point in the not too far future we will run out of inexpensive uranium, so now is the time to set our great-great-great-grandchildren up for success with ample green energy and closed fuel cycles. The money set aside for the Deep Geological Repository is more than enough to build fuel reprocessing and recycling facilities, and so funding which is usually the biggest challenge, is already available to actually follow the mantra of waste minimization.

I add an excerpt from an article published by Susan O'Donnell (me) and Gordon Edwards. (The Hill Times, March 19, 2021). We based our analysis on peer-reviewed literature, not nuclear industry spin.

The innocuous “recycling” label for the dirty and dangerous process of reprocessing aligns with the federal and provincial government branding of nuclear power as a “clean technology” - both labels mislead.

Plutonium is the primary nuclear explosive material in the world’s arsenals of nuclear weapons. However, plutonium can also fuel nuclear reactors, and the nuclear industry in Canada has never lost sight of its dream of using plutonium as fuel in this country. Now the industry is developing its fantasy in New Brunswick.

A derivative of uranium that does not exist in nature, plutonium is one of the many radioactive materials created inside every nuclear reactor fuelled with uranium. In New Brunswick, the used fuel from the existing Point Lepreau CANDU reactor is stored on-site in secure temporary and aging concrete silos.

Extracting the plutonium from Point Lepreau’s used fuel rods is a key component of the design for one of two experimental nuclear reactors for New Brunswick. In the design, the extracted plutonium would be transformed into fuel for the new reactor. New Brunswick’s plutonium plan is a marked departure from current practice in Canada.

Countries that extract or separate plutonium from used nuclear reactor fuel – either for military or commercial use – require special oversight from the International Atomic Energy Agency (IAEA).

Only a handful of countries do it commercially: the UK, France, India, Japan and Russia. China is expected to commercialize the process by 2025. Adding Canada to this list would be a milestone in international relations. And yet New Brunswick is planning to do it, without any Parliamentary debate.

The link between nuclear weapons and nuclear power is strong but rarely acknowledged. The first nuclear reactors were built not to produce electricity but rather to produce plutonium for bombs. From 1945 to 1965, Canada made plutonium at Chalk River and sold it to the U.S. military for use in bombs.

In 1974, India exploded its first atomic bomb using plutonium created in a Canadian nuclear reactor, a gift from Canada. Several years later, extracting plutonium from used nuclear fuel was banned by the Carter administration in the U.S. and the first Trudeau administration in Canada. South Korea and Taiwan were likewise forbidden (with pressure from the U.S.) to do it.

Why did both the U.S. and Canada ban this “recycling” scheme? It is highly dangerous and polluting to “open up” the used nuclear fuel in order to extract the desired plutonium; and extracting plutonium creates a civilian traffic in highly dangerous materials that can be used by governments or criminals or terrorists to make powerful nuclear weapons without the need for terribly sophisticated or readily detectable infrastructure.

• Afin d’être crédible aux yeux de la population canadienne, le Canada doit se référer à un organisme indépendant du gouvernement et de l'industrie pour superviser la gestion et le déclassement des déchets radioactifs.
• Le Canada doit respecter toutes les exigences de l’Agence internationale de l’énergie atomique (AIEA) pour le démantèlement des réacteurs nucléaires.
• Les déchets radioactifs ne doivent PAS être abandonnés; la politique doit orienter les soins et le suivi perpétuels. Et il est trop dangereux que des reposoirs de déchets radioactives de moyenne et haute activité soient situés à proximité de zones habitables et des sources d’eau potable des communautés. De plus, il vous faut prévoir l’imprévisible qu’entraîneront les changements climatiques.
• Les déchets radioactifs de niveau moyen et élevé ne doivent pas être placés dans une installation de gestion de déchets nucléaires près de la surface. Seuls les déchets de faible activité pourront être classés dans une IGDPS éloignée de zones habitables et des sources d’eau potable des communautés.
• Tous les sites sur le territoire canadiens que stockent ou produisent des matières radioactives, quelqu’ils soient et où qu’ils soient, devraient impérativement faire l’objet d’une surveillance armée et des services secrets afin de prévenir des actes de malveillance, de guerre, de terrorisme, de vols de combustible, de piratage informatique ou de données. Des précautions comparables devraient être mises en place pour tout transport de matières radioactives.
• Dans une perspective de sécurité nationale, les sites nucléaires ne devraient être accessibles qu’au personnel autorisé et aux inspecteurs de l’AIEA. Il ne devrait y avoir aucune visite en ces lieux, ni à proximité. Les vols d’avions et de drones au-dessus des sites devraient être interdits. La circulation en bateau à proximité des sites nucléaires devrait être contrôlée.
• Le gouvernement et l'industrie doivent être ouverts et transparents dans la gestion des déchets radioactifs et de leur transport. Les peuples autochtones et les autres Canadiens ont le droit d'accéder à l'information, de participer à la prise de décisions et de connaître les risques. C’est pourquoi le gouvernement du Canada doit rejoindre un plus grand nombre de citoyens et citoyennes afin de les consulter dans les deux langues officielles. Les documents fournis sur les sites devraient être accessibles dans les deux langues officielles et vulgarisés afin qu’ils soient faciles à comprendre par des personnes non initiées aux questions nucléaires.
• Pas d'importation de déchets radioactifs d'autres pays et que cela fasse partie des contrats avec les acheteurs.
• Pas d'extraction de plutonium des déchets de combustible radioactif. Le Canada est un pays pacifique. Les citoyens ne veulent pas que le Canada autorise l’usage de combustible usé sur le territoire canadien.
• Le Canada doit cesser de produire des déchets radioactifs préjudiciables à la vie.

Immediate decommissioning should be the preferred strategy, as it avoids shifting the burden of decommissioning to future generations.
The IAEA says decommissioning can be postponed if the necessary waste management infrastructure is not available, but then efforts should be made to develop the infrastructure. The federal government does not have any infrastructure for the permanent management of long-lived intermediate level waste that would be produced during the decommissioning of its reactors and does not even plan for it. This serious flaw prevents proper decommissioning. There is an urgent need to create this infrastructure.
Doing nothing… and burial… are not acceptable downgrading strategies. In situ decommissioning (in situ burial) should be banned in accordance with IAEA guidelines for old reactors, current reactors and new small modular reactors. The excuse that this is not feasible or that it was not planned is unacceptable. This demonstrates poor planning for the management of radioactive waste in Canada. If there were permanent management infrastructure for intermediate and high level waste, the temptation to entomb would be less strong.
The SMRs had to be small and transportable and their waste had to be repatriated. Now they are exempt from environmental assessment and it would be allowed to leave their waste in-situ! It is against IAEA guidelines to deal with radioactive pollutants in a safe and environmentally acceptable manner. Entombment is the opposite of site remediation.
Only a nuclear accident could justify the entombment. In Chernobyl, following the nuclear accident, there is an entombment that has cracked over time. They've built another sarcophagus and now they're going to build a radioactive waste disposal and processing site.
The IAEA demands that the decommissioning strategy be justified. The CNSC's draft REGDOC decommissioning stated: “The licensee shall justify the chosen strategy and shall perform a comparison of alternative decommissioning strategies. But the nuclear industry - LNC, SGDN, OPG and others - opposed it. The CNSC has removed this requirement. Basically the problem is the lack of infrastructure for the permanent management of long-lived intermediate level waste and long-lived high level waste.
We must characterize and sort the waste, make a detailed inventory, guarantee their traceability, put them in well-insulated and robust containers and monitor them as they disintegrate. Radioactive waste cannot be left in a concrete sarcophagus. Whether we have to transport the longer-lived radioactive waste to a more suitable disposal site and away from water bodies, everything has to be planned. For a new facility, decommissioning planning should begin early in the design phase of a new facility such as a PRM. The CNSC did not require a preliminary decommissioning plan when applying for a license to build an SMR at Chalk River.

Comments from Ginette Charbonneau
Ralliement contre la population radioactive

Subject: Principles of radioactive waste management and their reduction
NRCan consultation to modernize Canada's radioactive waste policy

Canada must include in its policy that nuclear energy will be the energy of last resort, and must end its efforts to revive nuclear energy.

The Reduce-Reuse-Recycle “hierarchy” is unacceptable. The hierarchy of wastes developed for other wastes does not transfer to radioactive waste management, because of the radiological risk and radiological contamination created if radioactive materials were mixed with uncontaminated material.
The policy should adhere to the following IAEA principles: “The objective of radioactive waste management is to treat radioactive waste in a manner that protects human health and the environment, now and in the future, and without placing undue burdens on future generations. "
1. Benefits: Minimization of the production of radioactive waste and optimization of their management.
The first principle of waste management is to stop producing radioactive waste. To achieve this goal, the government should adopt an energy policy that encourages the phase-out of the use of nuclear energy, as it produces radioactive waste. Energy companies, which currently operate nuclear reactors, should reorient their supply options towards clean energy sources, i.e. renewable energies. Regulators should ensure that waste generators isolate carefully and contain properly all radioactive waste generated, avoiding cross-contamination and release to the environment.
2. Transparency: Establishment of methods and approaches to build trust between those involved and those affected by the management of radioactive waste.
Precise definitions of radioactive waste, well-maintained inventories and provisory and long-term management plans for all kinds of radioactive waste are needed to ensure transparency.
3. Protection of people and the environment: Implementation of radioactive waste management methods ensuring the protection of people and the environment.
Canada must penalize radioactive waste polluters.
Radioactive waste must be kept separate from the food we eat, the water we drink, the air we breathe and the land we cultivate. Minimize the transport of radioactive waste and keep it away from bodies of water.
4. Security: Implementation of physical protection systems against radioactive waste.
Radioactive waste must never be abandoned and it must be recoverable in the event of a problem or if there is a new technology to treat it. The monitoring of radioactive waste must be continuous and their containers must be changed regularly to avoid leaks. There are needs for more robust and longer-lasting containers.
Regarding safety, the IAEA cites two types of very dangerous radioactive waste: high activity disused radioactive sources and spent nuclear fuel. Canada has large amounts of both types of waste. The import of r