The discussion paper states:
"In-situ decommissioning cannot be considered a reasonable decommissioning option for planned decommissioning of... future nuclear facilities... where removal is possible and practicable.”
This raises questions: "Is removal of proposed small modular reactor (SMR) designs – such as the MMR proposal at Chalk River or the ARC-100 and Moltex proposals in New Brunswick "possible and practicable" after shut-down? Does Canada’s nuclear regulator intend to include removal costs in the “financial guarantee” for decommissioning? Or is the plan to dispose of them “in-situ” (on-site) - rather than at an NWMO repository)?
The paper goes on to state:
“In-situ decommissioning may be considered a solution… for legacy sites."
The IAEA’s General Safety Requirements document, Decommissioning of Facilities, says that in-situ decommissioning (also known as entombment) “is not considered a decommissioning strategy and is not an option in the case of planned permanent shutdown. It may be considered a solution only under exceptional circumstances (e.g. following a severe accident).” The 2019 IAEA review of Canada’s nuclear safety framework calls for “revising… current and planned requirements in the area of decommissioning to align with the IAEA guidance that entombment is not considered an acceptable strategy for planned decommissioning of existing NPPs and future nuclear facilities.”
As in-situ decommissioning is not an option according to the IAEA’s safety requirements, it should be removed from the list of options in the discussion paper. The discussion paper should state that in-situ decommissioning is not an option for “legacy sites” or “future nuclear facilities.”
"Prompt” and “deferred” decommissioning - dismantling and removal of nuclear facilities- are the only options deemed acceptable by the IAEA. These are the only options that should be included in Canadian policy. Nuclear reactors are water-cooled and built near major water bodies. Their wastes must be isolated and contained in a facility located AWAY from major water bodies.
Policy should identify “prompt” decommissioning as the preferred option, and should discuss why prompt decommissioning is preferred, and under what circumstances decommissioning might need to be deferred. It should note that one such circumstance is that a suitable waste management facility is lacking. Canadian decommissioning policy should include development of a long-term decommissioning waste management facility so that decommissioning can be carried out promptly and is not deferred indefinitely.
Canada's decommissioning policy should require accurate estimates of funding required for decommissioning of nuclear facilities and for long-term management of decommissioning wastes. It should address financial guarantees and acknowledge the need to ensure that adequate funding is available so the burden does not fall upon future generations of taxpayers.