Regulatory Challenges in the Age of Nuclear Waste and Decommissioning

by Gordon Edwards, Ph.D.,October 7, 2019.

Executive Summary
This report was prepared for the Concerned Citizens of Renfrew County and Area (CCRCA) through a grant from the Canadian Nuclear Safety Commission’s Participant Funding Program.

The present report is intended to link two documents, the Integrated Waste Strategy issuing from Canadian Nuclear Laboratories (CNL) in April 2017 and the Regulatory Oversight Report for Canadian Nuclear Laboratories’ Sites: 2018, issuing from the Canadian Nuclear Safety Commission (CNSC) in September 2019.

Under the terms of the funding agreement, the participant is instructed to “review the Regulatory Oversight Report for Canadian Nuclear Laboratories Sites: 2018 and prepare a report on CNL’s Integrated Waste Strategy that examines issues such as the consolidation of high, intermediate, and low-level radioactive waste at Chalk River Laboratories, as well as waste characterization and analysis, packaging, labeling, and transport considerations,” and to “Summarize the findings and recommendations in a written report to be submitted to the Commission.”

CNL’s Integrated Waste Strategy was first expounded in an April 2017 document entitled Canadian Nuclear Laboratories Integrated Waste Strategy, Summary Document, Company Wide, CW-508600-PLA-006, Revision 0, henceforth referred to as the Integrated Waste Strategy. This CNL document, published 19 months after the consortium of private companies that now owns and operates CNL was awarded the contract to manage federal nuclear properties, represents a radical departure from radioactive waste practices and strategies previously espoused by Atomic Energy of Canada (AECL). 

Nevertheless, the CNL strategy document has received little discussion, debate or circulation. Most members of the public, including elected representatives, seem to be ignorant of its existence.

Surprisingly, the recently released CNSC Regulatory Oversight Report does not mention “CNL’s Integrated Waste Strategy” at all. Nor does the Oversight Report discuss the “consolidation of high, intermediate, and low-level waste at Chalk River Laboratories” referred to in the funding agreement, nor does it discuss the extensive transport of radioactive materials of all kinds that has been, is, and will be taking place over public roads and bridges in order to achieve the “consolidation” of radioactive waste at Chalk River Laboratories. 

One is tempted to conclude that any attempt to review the Regulatory Oversight Report in the light of the Integrated Waste Strategy would be futile, since the Oversight Report does not cite the Strategy document; however, CNSC has funded the present report explicitly on those terms. Of necessity, then, this report deals with much content that is completely missing from the Regulatory Oversight Report. 

List of Recommendations
1.  that CNSC not accept or circulate for public comment any draft proposal for a nuclear waste facility or a decommissioning project that is clearly at odds with international guidance;

2.  that in the case of the proposed WR-1 and NPD in-situ decommissioning projects, CNSC require the proponent to demonstrate that the original and already approved decommissioning strategy cannot be carried out, and in the absence of such a demonstration, the original decommissioning strategy be retained;
[Note: WR-1 and NPF are two federally-owned nuclear reactors, the first located beside the Winnipeg River at Pinawa, Manitoba, the second [NPD] located beside the Ottawa River at Rolphton, Ontario, 30 kilometres upriver from Chalk River.]

3.  that CNSC require that a complete list of radionuclides involved in any waste management, transportation or decommissioning scenario, complete with half-lives, activities (total becquerels as well as becquerels per kilogram or per litre), mode of disintegration, radioactive progeny and target organs, be provided by the proponent;

4.  that all information about the radioactive inventory involved in any such scenario be communicated to indigenous peoples and to other members of the Canadian public in plain language stripped of scientific symbols and abbreviations;

5.  that CNSC not accept the emplacement of any intermediate-level waste in any surface  or near-surface radioactive waste facility;

6.  that CNSC not accept the emplacement of any measurable amounts of transuranic waste in any surface or near-surface facility;

7.  that CNSC ensure that the necessary laboratory tests are carried out on each batch of decommissioning waste to detect the presence of transuranic contamination;

8.  that CNSC not accept the emplacement of any measurable quantities of radioactive carbon-14  in any surface or near-surface facility, given its 5700 year half-life and its exceptional environmental mobility as radioactive carbon dioxide or carbonic acid;

9.  that CNSC ensure that no ion-exchange resins be emplaced in any surface or near-surface radioactive waste facility (among other reasons, the fact that carbon-14 contamination is almost always found in such resins);

10.   that CNSC reconsider its opposition to the mandatory environmental assessment of new nuclear reactors and recommend that such assessments be required;

11.  that CNSC require any proponent of a facility for permanent storage of radioactivewaste to propose and prepare a comprehensive strategy for the transmission of RK&M (Records, Knowledge and Memory on Radioactive Waste) to future generations, including a detailed inventory of specific radionuclides included in the proposed facility along with relevant physical, chemical and biological properties ;

12.  that CNSC require any proponent of a facility for permanent storage of radioactive wastes to provide detailed instructions as to how the wastes can be retrieved and repackaged if need be at some future date, and failing the provision of those instructions, approval for the project be withheld;

13.  that CNSC require any proponent of a facility for permanent storage of radioactivewaste to examine the option of Rolling Stewardship as an alternative to abandonment ;

14.  that CNSC request the government of Canada to formulate a socially acceptable  policy on the long-term management of radioactive wastes other than used nuclear fuel, based on extensive public consultations with First Nations and other Canadians.

15.  that CNSC establish a new set of regulations governing the transport of radioactive waste, including requirements for justification and discussion of alternatives ;

16.  that CNSC withhold approval for the transportation of radioactive wastes over public roads unless the proponent of such transport can show a demonstrable improvement in security and environmental protection as a result of such transport;

17.  that CNSC send a correction to the Ontario Office of the Fire Marshal and Emergency Management giving the true radioactive inventory of the Chalk River liquid being transported over Ontario roads and clarifying the danger following a potential spill;

18.  that CNSC staff recalculate and publish the amount of drinking water that could be ruined if accidentally contaminated with various quantities of high-level radioactive liquid waste currently being trucked from Chalk River to South Carolina; 

19.  that CNSC not permit the transport of irradiated fuel from other CNL sites to the Chalk River site unless CNL presents an irrefutable safety case for doing so;

20.  that CNSC initiate a consultation process to develop a new classification scheme for radioactive waste materials based on health and environmental considerations rather than ease of handling;

21.  that CNSC require a thorough manifest of radionuclides, complete with half-lives, activity levels in becquerels, and type of radioactive emission, to accompany every shipment of radioactive waste material, easily accessible for use by first responders;

22.  that CNSC develop an entire suite of regulations focused exclusively on radioactive wastes, concentrating on questions of waste characterization, hazard analysis, packaging, labeling, and transport requirements.

A List of Organizations and Acronyms

CNL = Canadian Nuclear Laboratories, owned and operated by a consortium of multinational corporations (SNC-Lavalin, Fluor and Jacobs), contracted by the Harper government in September 2015 to reduce the federal government’s $7.9 billion radioactive waste liability;

CNL Sites: Since 2015, CNL manages the following federally-owned nuclear sites – CRL (Chalk River Laboratories), WL (Whiteshell Laboratories), DP (Douglas Point Nuclear Reactor), G-1 (Gentilly-1 Nuclear Reactor), NPD (Nuclear Power Demonstration Reactor), PH (Port Hope Legacy Radioactive Wastes), PG (Port Granby Legacy Radioactive Wastes).

AECL = Atomic Energy of Canada Limited, a federal crown corporation to whom CNL reports and from whom CNL is allocated annual federal funding; AECL was previously responsible for all of the sites and radioactive wastes now under the management of CNL;

CNSC = Canadian Nuclear Safety Commission, Canada’s nuclear regulatory agency;

CRL = Chalk River Laboratories, Canada’s main federal nuclear research centre since its construction was first authorized in Washington DC in December 1944.

WL = Whiteshell Research Laboratories, Canada’s second federal nuclear research centre, sited at Pinawa, Manitoba, in operation from 1960 to 1998, now being decommissioned;
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