November 5, 2020
The multinational consortium, Canadian National Energy Alliance, has been managing Canada’s nuclear facilities and radioactive wastes under a GoCo (Government-owned, Contractor-operated) contract since September 2015.
The consortium is proposing to quickly and cheaply dispose of all Canada’s federal radioactive wastes in a giant landfill beside the Ottawa River and two concrete “entombments” of old, highly radioactive nuclear reactors beside the Winnipeg and Ottawa rivers.
The proposals are undergoing protracted Environmental Assessments. They are mired in controversy and years behind schedule. Here are the links to Environmental Impact Statements for the three projects:
Part of the reason for the controversy is that the consortium’s proposals flout safety standards of the International Atomic Energy Agency. As a member state, Canada is supposed to follow IAEA guidance.
Here are some examples of IAEA guidance that is being flouted:
The relevant text is section 5.17 on page 32 and it reads as follows:
Entombment, in which all or part of the facility is encased in a structurally long lived material, should not be considered an acceptable strategy for planned decommissioning (emphasis added). It might be considered as a last option for managing facilities that have been damaged in an accident, if other options are not possible owing to high exposures of workers or technical difficulties.
The IAEA Safety Standard for Disposal of Radioactive Waste says that the fundamental safety objective of radioactive waste management, including disposal, is “to protect people and the environment from harmful effects of ionizing radiation.” The strategy to achieve this objective with regard to disposal of radioactive waste is “to contain the waste and to isolate it from the accessible biosphere… [which] is taken generally to include those elements of the environment, including groundwater, surface water and marine resources, that are used by people or accessible to people.”
The NSDF proposal turns the IAEA standard on its head. Rather than isolating radioactive wastes from groundwater and surface water, and disposing of them in stable environments ensuring long-term safety, it would use a design similar to a municipal landfill, in which wastes would be deliberately and routinely allowed to come into contact with the environment, including rain and snow.
The NSDF proposal calls for a giant mound exposed to the elements. Surface run-off from the mound would carry radionuclides into three storm-water management ponds. These would discharge directly into the East Swamp wetland. Sub-surface waters leaching through the mound would carry radionuclides through a collection system to a newly constructed water treatment facility. This facility would remove some radionuclides (presumably for disposal using an unspecified method), while allowing others (e.g., tritium) to pass through untreated for release into the East Swamp stream, Perch Creek and the Ottawa River.
The NSDF proposal flouts IAEA guidance calling for “impermeable and water diverting features” for LLW disposal, and a “stable, geological environment” for ILW disposal. Canada, which participates actively in development of IAEA Safety Standards, should not be allowed to flagrantly disregard them at a government-owned facility.
CNL’s use of the term NSDF — “Near Surface” Disposal Facility — is misleading.
This IAEA safety guide
“Near Surface Disposal Facilities for Radioactive Waste” Specific Safety Guide SSG-29 says on page 37
4.15. The concept of near surface disposal covers a wide range of facilities
(e.g. disposal at the surface in engineered vaults or trenches, or disposal at
varying depths — from a few metres to a few tens of metres — in facilities with various types of engineered barriers).