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D. Bilinsky's picture

IAEA General Safety Requirements (GSR), Specific Safety Requirements (SSR) and Safety Guides (SSG) reflect international consensus of established requirements and recommendations take precedence over supporting informational series publications such as the IAEA Safety Report referenced within NRCan's Decommissioning Discussion Paper. Contrary to NRCan’s presumption, the only special circumstance acceptable to the IAEA where in situ confinement for reactors may be considered is for nuclear facilities that have been damaged in a severe accident. The 2019 IAEA Integrated Regulatory Review of Canada’s nuclear regulatory framework previously stated the strategy of in situ confinement (disposal) for reactors is not in full compliance with IAEA safety standards GSR Part 6 and SSG-47. Nevertheless, NRCan advocates in situ decommissioning and Section 5.1 of CNSC regulatory document REGDOC-2.11.2 may consider in situ decommissioning for legacy sites, even in situations where removal is possible and practicable.

Canadian Nuclear Laboratories (CNL) has proposed in situ decommissioning of the Whiteshell WR-1 reactor in Pinawa, Manitoba via creation of an Intermediate Level Waste (ILW) disposal site. The removal of the WR-1 reactor followed by ILW consolidation at a larger ILW site is preferable to creating another long-term legacy liability ILW disposal site. Consolidation of smaller nuclear waste inventory sites reduces the burdens on future generations of securely maintaining and monitoring multiple long-term legacy sites while still providing protection of people, the environment and national security. Consolidation of nuclear waste sites also has the benefit of increasing the number of locations released for reuse by future generations.

Canada should improve alignment of nuclear policies and regulations to internationally agreed standards, specifically key fundamental recommendations found in IAEA GSR 6 and SSR 5 by; dismantling and removing nuclear facilities where possible and practicable, and due to the presence of long-lived radionuclides, ILW requires a greater degree of containment and isolation than that provided by near-surface disposal. ILW disposal at significant depth provides greater protection against the migration of long-lived radionuclides and a potential future glacial degradation event.

Verifiable policy and regulatory alignment with IAEA safety standards will build trust with Canadians and provide assurance that the Government of Canada is serious about its commitment to meet international standards and best practices in achieving its top priority of protecting the health and safety of Canadians and the environment, now and in the future.

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