No matter how the radioactive waste is produced in Canada (mining, milling, refining, reactors, R&D, medical and non-medical isotopes, decommissioning, etc.), the Policy must elucidate a clear path forward towards disposal, else management cannot be achieved. This should include tentative start and end points for all waste streams, including their times and locations. These are called plans. Do not shy away from plans. The public and utilities work with them every day. Confidence cannot be gained in policies without illustrative plans with time lines and sources of funding. Since Canada invokes the “user pay” principal, this should not be a significant problem.
The longer waste disposal is delayed, the greater will be the costs for interim storage including the unnecessary proliferation of “in-situ’ disposal sites for legacy R&D reactors and their associated ILW and LLW. Ultimately, they may require re-excavation by future governments who may be required to live up to higher standards.
The greatest cost for delayed Waste Disposal is the potential extremes associated with Waste Minimization including its costs. Delay in disposal requires increased storage plus its continuing care and maintenance plus the continuing care and maintenance of non-decommissioned facilities. This also invokes the process of reducing and containing the volume of the contaminated wastes to levels beyond what should be considered practicable. The cost trade off should consider the ratio of the cost for the safe removal of the waste volume from the environment versus the cost for the excavated ground volume (soil or rock) and their associated operations for each volume.
One of the greatest problems associated with the legacy wastes at CRL and WL are the quantities and assays of the deposited ILW and LLW on the waste management sites. Preliminary estimates of the volumes and radionuclide content of LLW and ILW to 2008 (Baumgartner 2011) are ranked as preliminary in that the current inventory is incomplete, partly due to very limited waste-characterization practices in the past (i.e., limited to either needing or not needing radiation shielding), limited compilation of waste-receipt records in a comprehensive database and the loss of waste-receipt records in a fire at CRL predating 1956. An arbitrary quantity of Used Fuel was added to the CRL inventory in lieu of this knowledge. This lack of knowledge undermines any safety case for “in-situ” disposal of the legacy wastes at the CRL and WL sites.
Baumgartner, P. 2011. Preliminary estimates of AECL’s current and future low- and intermediate-level radioactive wastes. Atomic Energy of Canada Limited Report 361101-01613-REPT-001 Rev. 4