July 2019

In October 2017, Canadian Nuclear Laboratories (CNL) announced that it would not put Intermediate Level Waste (ILW) in a proposed above-ground mound.

CNL incorrectly calls this mound a “Near Surface Disposal Facility” (NSDF). International Atomic Energy Agency (IAEA) safety requirements state that a near surface facility should consist of in-ground vaults or trenches, and is suitable only for Low Level Waste.

In March 2019, the Canadian Nuclear Safety Commission (CNSC), Canada’s captured nuclear regulator, released a draft “Regulatory Document” on waste management for comment. The CNSC’s proposed language on ILW was that it “generally requires” greater isolation than would be provided by near surface disposal.

Putting ILW above-ground would go against common sense. Because of its long-lived radionuclides, the IAEA requires that ILW be disposed of “at least a few tens of metres below ground level.”

In June 2019 CNL submitted its comments on the draft RegDoc. CNL asked CNSC to further weaken its wording on ILW, saying “There are current plans to place ILW in aboveground mounds.”  CNL wanted the language on ILW changed from “generally requires” to “may require” greater isolation.

CNSC’s final version of the Regulatory Document, published February 2021, retains the original language of “generally requires”.

This could allow CNL to dispose of long-lived, intermediate-level radioactive waste in its proposed above-ground mound, the so-called NSDF.

Why did CNL say in October 2017 that it would not put ILW in the NSDF, but tell CNSC in June 2019 that there are “current plans to place ILW in aboveground mounds”?

From the IAEA Specific Safety Requirements No. SSR-5, Disposal of Radioactive Waste, page 4:

(b) Near surface disposal: Disposal in a facility consisting of engineered trenches or vaults constructed on the ground surface or up to a few tens of metres below ground level. Such a facility may be designated as a disposal facility for low level radioactive waste (LLW)

(c) Disposal of intermediate level waste: Depending on its characteristics, intermediate level radioactive waste (ILW) can be disposed of in different types of facility. Disposal could be by emplacement in a facility constructed in caverns, vaults or silos at least a few tens of metres below ground level and up to a few hundred metres below ground level. It could include purpose built facilities and facilities developed in or from existing mines. It could also include facilities developed by drift mining into mountainsides or hillsides, in which case the overlying cover could be more than 100 m deep. 

From the IAEA Specific Safety Requirements No. SSR-5, Disposal of Radioactive Waste, page 55:

Intermediate level waste (ILW): Waste that, because of its content, particularly of long lived radionuclides, requires a greater degree of containment and isolation than that provided by near surface disposal.  

From CNL updates NSDF Waste Inventory, dated October 26, 2017:

Canadian Nuclear Laboratories (CNL) announced today that it has re-evaluated its proposal for the Near Surface Disposal Facility (NSDF) at Chalk River Laboratories, and has made the decision to only include low-level radioactive waste in the NSDF…. Intermediate level waste will continue to be managed in interim storage at Chalk River Laboratories until a long-term disposal solution for this category of radioactive waste has been developed and approved. 

From CNSC REGDOC-2.11.1, Volume I, Management of Radioactive Waste, March 2019 draft, section 6.1, Waste Classification, bullet 4, page 4:

Due to its long-lived radionuclides, ILW generally requires a higher level of containment and isolation than can be provided in near surface repositories.

From Canadian Nuclear Laboratories Comments on Draft Regdoc-2.11.1, Volume 1: Management Of Radioactive Waste, page 11 of 25, comment #13 on section 6.1, dated June 27, 2019: 

The 4th bullet is a potentially misleading or biasing statement. There are current plans to place ILW in aboveground mounds. 

Amend 4th bullet to read, “Due to its long‐lived radionuclides, ILW generally may require a higher level of containment and isolation than can be provided in near surface repositories.