Forum : Installations de stockage des déchets

It is a stretch to characterize waste storage at the federal government's Chalk River Labs (CRL) as safe and environmentally sound. The 2019 Annual Compliance Monitoring Report for CRL describes in considerable detail the radioactive groundwater contaminant plumes at CRL and their monitoring and treatment systems. To summarize briefly, in the Perch Lake basin, strontium-90 plumes from the Liquid Dispersal Area and Waste Management Areas A and B require continuing operation of three groundwater treatment systems. In the Maskinonge Lake basin, a “Wall and Curtain” passive groundwater treatment facility intercepts and treats the strontium-90 plume arising from the Nitrate Plant. Contaminant plumes from the NRX and NRU reactor facilities (he fuel bays) were for years leaking tritium and strontium-90. The resulting contaminant plumes now discharge directly into the Ottawa River untreated.

The federal government should move the sources of these radioactive contaminant plumes into secure long-term storage facilities, away from the river.

Furthermore, the federal government should establish a set of principles for waste storage. A starting point could be the following nine fundamental principles of radioactive waste management of the International Atomic Energy Agency
(https://www-pub.iaea.org/MTCD/publications/PDF/rwmp-3/INTRODUCTION.pdf)

Principle 1: Protection of human health: Radioactive waste shall be managed in such a way as to secure an acceptable level of protection for human health.
Principle 2: Protection of the environment: Radioactive waste shall be managed in such a way as to provide an acceptable level of protection of the environment.
Principle 3: Protection beyond national borders: Radioactive waste shall be managed in such a way as to assure that possible effects on human health and the environment beyond national borders will be taken into account.
Principle 4: Protection of future generations: Radioactive waste shall be managed in such a way that predicted impacts on the health of future generations will not be greater than relevant levels of impact that are acceptable today.
Principle 5: Burdens on future generations: Radioactive waste shall be managed in such a way that will not impose undue burdens on future generations.
Principle 6: National legal framework: Radioactive waste shall be managed within an appropriate national legal framework including clear allocation of responsibilities and provision for independent regulatory functions.
Principle 7: Control of radioactive waste generation: Generation of radioactive waste shall be kept to the minimum practicable.
Principle 8: Radioactive waste generation and management interdependencies: Interdependencies among all steps in radioactive waste generation and management shall be appropriately taken into account.
Principle 9: Safety of facilities: The safety of facilities for radioactive waste management shall be appropriately assured during their lifetime.

Votre document d’information explique comment le Canada entrepose ses "déchets de faible activité à longue durée de vie".
Ces propos sont absurdes car un déchet de faible activité est PAR DÉFINITION un déchet radioactif qui contient très peu de radionucléides à longue durée de vie.

En vertu de la nouvelle définition canadienne adoptée le 18 juin dernier par la Commission canadienne de sûreté nucléaire (CSST), un déchet radioactif peut être dit de faible activité à DEUX CONDITIONS:
a) il doit contenir très peu de radionucléides à longue durée de vie
b) il doit être permis de l'éliminer dans un site près de la surface.

Oui, vous avez bien lu : Il n’est plus nécessaire que sa radioactivité soit faible et qu’on puisse, par exemple, le manipuler à main nue.

Cette nouvelle définition figure à l’article 7.1 du REGDOC 2.11.1 que les commissaires ont adopté à leur réunion du 18 juin et le secrétariat de la CSST m’a fait parvenir leur procès-verbal le 21 septembre. Le secrétariat ma aussi assuré que la version officielle de ce règlement serait publiée « dans les plus brefs délais ». Nous arrivons à Noël et cela n’a toujours pas été fait.

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.

I largely agree with the policy as written - I believe it makes sense to keep the spent fuel (HLW) at the generation sites since these sites already have a security presence onsite and the building footprint for HLW is a small portion of the overall site. Furthermore, it makes sense to keep the HLW onsite rather than spending the resources to transport to a different interim storage facility - keeping it close to the site of production also makes transportation easier, more cost effective, and safer. My only question is in regards to SMRs/MMRs - in this case should there be a provision added in the policy in which these would be stored in a centralized location? For these reactor designs since they are smaller in size the supporting infrastructure and personnel are much smaller so it may make sense to store the "spent fuel" in a centralized location.

I'd encourage those not familiar with spent nuclear fuel to do some research and you would be amazed to learn that spent nuclear fuel is composed of solid ceramic (UO2) fuel pellets which look almost identical to the fresh UO2 fuel and workers standing next to the concrete/MACSTOR/dry storage contains receive dose rates well below regulatory limits.

I'd recommend that NRCan to continue with the Adaptive Phase management which utilizes storage rather than direct disposal as the Gen 4/breeder reactors and future designs will be able to utilize the "spent fuel" as feedstock and directly burying "spent fuel" (which still contains a large amount of usable energy) would just lead to extra resourced needed in the future to retrieve the direct disposal fuel.

Probably nothing worries me more than the impact of climate chaos storms, floods, fires, tsunamis, etc. on "temporarily stored" or abandoned nuke/rad waste. Think Fukushima.

Waste Storage is broader than the restrictive term “Waste Storage Facilities” entitling the Discussion Paper.

“Figure 1: Location of Radioactive Waste Management Sites in Canada” is solely associated with this Waste Storage Discussion Paper and is too general to be meaningful. The locations of all the sites should be labelled according to waste function: Production, Storage and/or Disposal of UF/HLW, ILW and LLW as defined by the Canadian Nuclear Safety Commission (CNSC). Also, the American term Spent Fuel in Figure 1 should be replaced by the traditional Canadian term Used Fuel. World Nuclear News has also drifted away from the term “spent fuel” to “used fuel.” This Figure should be corrected and should be attached to each amended Discussion Paper to ensure clarity.

NRCan needs to require the Regulator and Utilities (Contractors) to behave as responsibly as would a Scout Leader when setting up camp in the wilderness. You never put the latreen upstream of your water source. This is simple stuff, not complicated by acronyms and Agency names. No experts required. Do not put any nuclear waste anywhere near the Ottawa River upstream of at least five major Canadian cities. Regardless of the perceived merits of the technology the concept is so fundamental that continued discussion beggars the imagination!

Good evening my name is bill noll and I am a member of Protect our Waterways No Nuclear Waste group of residents in South Bruce in opposition to becoming a compelling willing host community for a DGR.. Our group conducted a telephone poll by an independent research organization of the South Bruce residents in Oct 2020 and found 64 % of the residents are not in favor of a DGR and prior to covid 19 restrictions we created a petition against the DGR signed by 1500 residents.. Despite this high level of support within the community against the DGR ,we are being ignored by the NWMO and our Council.

The NWMO nine step process is not a community driven event rather it is organized to gain support within the community for the NWMO agenda. That is to find a desperate community willing to accept nuclear waste in return for short term economic gains .

In this regard ,we are proposing that you consider adopting the following policy additions to the Canada Nuclear waste policy

1 A social and economic feasibility study must be conducted prior to formal start of a proposed project within the municipality. Must be completed independent of the proponent and not near the end of the siting process as outlined in the 9 step NWMO process.

2. Proponent should not be permitted to fund dedicated staff within the municipality to aid the proponent in the promotion of their project. It is the responsibility of the proponent to educate and informed the community of the merits of their project it is not a municipality responsibility

3. Funding should not be provided to the municipality by the proponent for activities unrelated to the project with the hope of winning support within the community for their project. Called well being or goodwill activities

4. Opposition group(s ) should be provided funding to conduct peer level reviews of studies performed by the NWMO and the municipality.

5. Municipality must demonstrate independence from the proponent.

6. DGR must be designed with retrievability and must demonstrate isolation in perpetuity

7. POW NNW recommendation is to keep the spent fuel at the reactor site until better technology is developed to either hardened the current storage containers or reduce the impact of the highly radioactive elements of the spent fuel..

The regulator should require that licence applicants provide information about wastes that would result from the activity that they are asking to have licensed. This is a requirement of the General Application Requirements of the General Nuclear Safety and Control Regulations, section 3 (1) (j):

An application for a licence shall contain the following information: the name, quantity, form, origin and volume of any radioactive waste or hazardous waste that may result from the activity to be licensed, including waste that may be stored, managed, processed or disposed of at the site of the activity to be licensed, and the proposed method for managing and disposing of that waste;

The CNSC does not enforce this regulation. It does not require that waste information is contained in a license application. The failure of the CNSC to require this information creates huge uncertainty with regard to costs and environmental acceptability of new nuclear facilities.

The discussion paper states that “The International Atomic Energy Agency (IAEA) document providing guidance on the topic of waste storage is IAEA Safety Standards Safety Guide No. WS-G-6.1, Storage of Radioactive Waste.” However, the IAEA document providing REQUIREMENTS for waste storage is GSR Part 5, Predisposal Management of Radioactive Waste. NRCan should ensure that Canada’s radioactive waste policy addresses the full set of GSR Part 5 requirements. The IAEA states these 22 requirements in the strongest possible legal terms, as “shall” statements. Requirement 1 states that “The government SHALL provide for an appropriate national legal and regulatory framework within which radioactive waste management activities can be planned and safely carried out. This shall include the clear and unequivocal allocation of responsibilities, the securing of financial and other resources, and the provision of independent regulatory functions.” Requirement 2 states that “the government SHALL ensure that a national policy and a strategy for radioactive waste management are established… The policy and strategy SHALL be compatible with the fundamental safety principles… and with international instruments, conventions and codes that have been ratified by the State.” Canada’s current policy falls far short of these two requirements. Our national legal framework is deficient. Our main piece of nuclear legislation – the Nuclear Safety and Control Act – contains not one single reference to waste. Current policy does not provide for clear and unequivocal allocation of responsibilities. It does not clearly distinguish between waste “generators” and waste “owners”. It does not even mention the responsibilities of “regulators” and “operators” of waste facilities, even though GSR Part 5 sets out many requirements for each. The federal government itself – despite being one of the largest generators and owners of radioactive waste – has abdicated its own responsibilities for managing its wastes and developing a national waste strategy by handing these responsibilities over to private sector operators, who operate in a policy void. Canada, despite having ratified the Convention on Nuclear Safety, does not provide for independent regulatory functions in respect of waste management. Our regulator, the CNSC, reports through the Minister of Natural Resources, who is expressed charged with promoting and utilizing nuclear energy under the Nuclear Energy Act. The Convention says “Each Contracting Party shall take the appropriate steps to ensure an effective separation between the functions of the regulatory body and those of any other body or organization concerned with the promotion or utilization of nuclear energy.” To conclude, Canada needs an independent authority for radioactive waste management. And Canada needs an independent regulator that is not captured by the industry and government bodies that promote and utilize nuclear energy.

Much of the issue boils down to NO PERMANENT SOLUTION TO RAD-WASTE. Yet the absolute amount of rad-waste meanwhile accumulates and is proposed to increase even more, --all requiring long-term costly taxpayer-supported high-tech protection. And with no end in sight, the need will continue for generations (until a war or natural disaster makes it impractical). Has the industry dealt with all the unsafe rad-waste (say, at mining sites) from the 1960s yet? If no, why trust new promises?

Keys points as general comments for (Nuclear Waste Storage) review:

Natural Resources Canada question no. 1: What are your views on how radioactive waste is currently being stored ?

I. Nuclear waste is not only a Canadian problem, but also a transboundary problem (locally, provincially, nationally, and internationally) during a leak, nuclear event or security breach:

a. Nuclear waste and storage is a global problem, not just in Canada and is a transboundary risk that needs to be managed locally, provincially, nationally and internationally, during a nuclear waste event, leak or security breach from Canada (i.e., USA, EU, and globally);
b. Nuclear waste streams need to be analyzed and modelled using large scale modelling techniques: examples: atmospheric transport, toxicology, EMOs, ERPs and interventions.

II. Provincial EMO (emergency measures organizations) & ERP plans:

a. Currently, provincially, ERP (Emergency Response Plans) are inadequate, local resources are not adequately prepared, or resourced, to respond to a nuclear waste leak, event, or security breach. Provinces have the provincial jurisdiction in terms of environmental impacts and public health protection and environmental measures and mitigation outside federal undertakings and nuclear waste storage risks go beyond federal lands and undertakings and activities.

Natural Resources Canada questions no. 2: What should be the roles and responsibilities of government, the regulator and waste owners with respect to radioactive waste storage?

III. Nuclear Waste Storage Governance: AAR process

Nuclear Waste storage sites need to be integral to the emergency response plans (locally, provincially, federally, and internationally) as per the following AAR process: authority, accountability, and responsibility process (not just the legal structures):

There is a need to identify and elucidate the following risk constructs:

a. Owners of the risk: obviously is the Government of Canada, structured around the regulator;
b. Managers of the risk: industry is currently the managers of nuclear waste storage sites but are not transparent about their plans on emergency procedures and nuclear storage plans to the general public;
c. Generators of the risk: Private sector industry during storage and transport and required monitoring of the risk path;
d. Proximate nuclear waste impacts and responsibilities: Who is proximate to nuclear waste storage sites (e.g. local governments, citizens, aboriginal peoples, environment); therefore, who will take charge during a nuclear waste storage site event, leak, security breach: 911, fire department, private sector waste management companies, etc.…

Safest regards,

Simon J. Daigle, B.Sc., M.Sc., M.Sc (A)
Climate Change air quality expert (Tropospheric Ozone).
Occupational and Industrial Hygienist (Applied).
Epidemiologist (communicable and non-communicable diseases).

NRCan’s “Waste Storage Facilities” discussion paper uses most of its print space to list four “reasons for storing radioactive waste”, making a claim that all wastes are being managed “in interim storage facilities that are safe, secure and environmentally sound”, and that progress is being made – it particularly notes – on a long term management approach (aka “disposal”) for high level nuclear fuel waste, and then assigns the most page space to its partial citing of the “Canadian Standards Association (CSA) documents and then summarizing IAEA Safety Standards Safety Guide No. WS-G-6.1, Storage of Radioactive Waste.

Notably absent is any discussion of current radioactive waste policy, and how it relates to the various categories of radioactive wastes.

The following are key discussion area which are also missing from the NRCan Discussion Paper on Radioactive Waste Storage Facilities:
- Discussion of waste categories, classification, inventories, or volumes
- Information about the current practice of consolidating radioactive waste at centralized sites (such as the Western Waste Management Facility at the Bruce Nuclear Generating Station (NGS) where low and intermediate level wastes from Ontario Power Generation’s Darlington and Pickering wastes are sent, as well as the wastes from Bruce NGS, and at the Chalk River Laboratory (CRL) where commercial waste and waste from other federal properties are centralized)
- Information about radioactive waste transportation, which is necessitated by current practices of waste consolidation, such as at the WWMF and CRL
- Acknowledgement of issues and failures with current radioactive waste storage systems, such as leaking irradiated fuel bays where high level nuclear fuel waste is stored, uncertain and missing inventories of low and intermediate level wastes at the WWMF, CRL and at Whiteshell Laboratory in Manitoba
- Discussion of environmental and health effects and risks related to current storage practices, such as release of tritium to groundwater from storage systems at the Western Waste Management Facility and as a result of multiple failures of irradiated fuel bays at Pickering and Bruce, and contamination
- Acknowledgement of issues arising from absent, inadequate or incomplete waste inventories, including at Chalk River, Whiteshell and the Western Waste Management Facility
- Risks related to delayed transfer of spent fuel waste from wet to dry storage and excess debris in fuel bays
- Consideration of security risks and increased vulnerability due to non-hardened storage systems
- Principles of protection of human health and the environment
- Linkages between this discussion paper and the decommissioning discussion paper, particularly related to decommissioning challenges which are increased as a result of poor storage practices

1. What are your views on how radioactive waste is currently stored in Canada?

A key issue with current storage practices is the lack of transparency and public access to information about design and performance of these systems. In general, storage systems have been constructed with the shortsighted assumption that they are temporary or interim, and their design have not been subject to public review and they have not maximized security features (for example, irradiated fuel waste is left in the reactor pool for much longer than the specified time period, where it is most vulnerable to infrastructure failure and to malevolent acts, and then is moved into “temporary” dry storage which is not hardened and in the majority of cases is exposed to extreme weather and malevolent acts by placing it in proximity to large water bodies).

2. What should be the roles and responsibilities of government, the regulator, and waste owners with respect to radioactive waste storage?

Government should establish an independent agency to oversee radioactive waste management, removing the policy function from the regulator. The regulator should demonstrate independence and apply regulatory standards developed through a public process and which are prescriptive and objective. The waste owners should fund the waste management systems, with public scrutiny, regulatory oversight, and detailed reporting.

Comments from Ginette Charbonneau
Ralliement contre la pollution radioactive

Subject: Radioactive waste storage facilities

NRCan consultation to modernize Canada's radioactive waste policy

The management of radioactive waste essentially consists of confining them in a secure manner for a sufficient period of time to allow their radioactivity to decrease to levels comparable to the ambient radioactivity.

Context
After an independent study recommended that high-level radioactive waste be disposed of in the deep geological formations of the Canadian Shield, the Seaborn Commission concluded that the concept did not necessarily have popular support. The concepts of acceptability and risk perception are linked. The public has the right to demand to feel safe. If the public does not feel safe with something that is proposed by the government, the proposal is unacceptable!
There are recurrent legitimate concerns:
• a certain uneasiness with an approach that does not provide perpetual supervision;
• a fear that leaving wastes in the deep geological formations of the Canadian Shield will not protect future generations;
• a feeling that electricity could be produced in a much better way (wind and solar energy) than with nuclear power and at a lower cost;
• a feeling of social injustice (keep your waste at home) in small remote communities called upon to house radioactive waste.
To isolate the radioactive waste from the biosphere, the government should select solutions that are socially acceptable, technically safe, environmentally responsible and economically viable.

The current classification and hierarchy of radioactive waste are too vague and their permanent storage is not planned
Waste categorizations are too vague and constantly changing. There are abusive interpretations especially because of very imprecise inventory and labeling. The waste of the past has been poorly catalogued. So there is more risk because the contents are uncertain.
We want a revision of the class of so-called low-level waste that contains a small amount of long-lived radionuclides (thousands of years). It is too vague.
When you put all this waste together, that makes a lot of long-lived waste. Because of this inadequate definition, radioactive wastes having a life of several thousands years would be placed in a mound near the surface that has a presumed life of only 500 years.
First, short-lived and long-lived wastes should be separated to be stored in a site whose longevity is long enough for their decay time. Then, they should be divided into categories of low, intermediate and high level activity which take into account not only the amount of radiation, but also factors of toxicity for the human organism.
Short-lived, low-level wastes could be stored in proper containers and sites and could be incinerated at the end of their useful life.
Intermediate level wastes have a long life and require shielding because of their intermediate radioactivity.