November 2020 (updated April 2022)
The most recent critical comments from ex-AECL experts are interventions submitted for the final licensing hearing that starts on May 30.
Dr. JR Walker’s intervention is here: https://www.nuclearsafety.gc.ca/eng/the-commission/hearings/cmd/pdf/CMD22/CMD22-H7-63.pdf
He says: “On the face of the documents provided, there is no justification for approval of the proposed Engineered Containment Mound until the deficiencies are corrected.”
Several ex-AECL scientists have pointed out, in comments on the environmental assessments, that all three of CNL’s proposed nuclear waste projects fail to meet international safety standards for radioactive waste facilities. The comments are publicly available on the website of the Impact Assessment Agency. Links to the submissions are compiled in this post. Below we highlight some that are especially pertinent to lack of compliance with international safety guidelines. See also the Globe and Mail article from June 2017 “Scientists decry plan for Ontario nuclear-waste site”
Concerns about the Near Surface Disposal Facility (Chalk River Mound)
Dr. Michael Michael Stephens, former Manager for Strategic Planning for the Canadian Nuclear Legacy Liabilities Program at AECL
I am commenting as a resident of Deep River, as a Canadian taxpayer, and from my 25 years’ working experience in radioactive waste management and decommissioning of nuclear facilities, including assource: https://www.ceaa.gc.ca/050/documents/p80122/119775E.pdf page 2
former Manager for Strategic Planning for the Canadian Nuclear Legacy Liabilities Program.
The concept of the NSDF project deviates significantly from internationally-accepted waste management principles and practices. Before consideration is given to allowing it to be implemented, it should be,subjected to a comprehensive technical review by an international group of experts arranged through the International Atomic Energy Agency, and the results should be made public.source: https://www.ceaa.gc.ca/050/documents/p80122/119775E.pdf page 5
DR. J.R. Walker, former Director of Safety Engineering and Licensing at AECL
A must-read submission on the NSDF (Chalk River Mound)
This quote is about non-compliance with international guidlines:
The proposed project does not meet Canadian and international guidance and would require memberssource: https://www.ceaa.gc.ca/050/documents/p80122/119034E.pdf page 7
of the public to be subject to unacceptable radiological risks into the far future.
This quote is about eventual failure of the mound:
The institutional control period ends 300 years post-closure, and the design life of the facility is 500 years post-closure. Subsequently, the facility will fail and the radionuclide inventory will be releasedsource: https://www.ceaa.gc.ca/050/documents/p80122/119034E.pdf page 8
into the environment. As noted previously, the predicted doses exceed the public dose limit specified in Canadian Regulations  for more than 100,000 years.
These are Dr. Walker’s concluding remarks about the NSDF environmental impact statement:
5.0 Concluding Remarks
The Draft EIS  and the associated project proposal contain numerous deficiencies. For example,
• The proposal employs inadequate technology and is problematically located;
• The proposal does not meet regulatory requirements with respect to the health and safety of
persons and the protection of the environment; and
• The authors have failed to meet the requirements of the Canadian Environmental AssessmentAct 2012.
The extent and gravity of these deficiencies preclude a conclusion that the project is unlikely to cause significant adverse environmental effects, taking into consideration the implementation of mitigation measures.Source: https://www.ceaa.gc.ca/050/documents/p80122/119034E.pdf page 10
Concerns about the proposed Whiteshell reactor entombment
Dr. J.R. Walker, former Director of Safety Engineering and Licensing at AECL, explains that the Whiteshell Reactor Entombment would not meet IAEA guidelines.
The proposed facility  is in noncompliance with international requirements and guidance, forSource: https://www.ceaa-acee.gc.ca/050/documents/p80124/121207E.pdf page 9
• Entombment is not acceptable as a decommissioning strategy ;
• Near surface disposal is not acceptable for intermediate level waste ; and
• Perpetual institutional control is not acceptable [6 – 10, 13].
Peter Baumgartner and six colleagues, former AECL scientists and engineers, outline many serious concerns and note that IAEA doesn’t consider entombment to be a decommissioning strategy except in emergencies. Read their submission on the IAA website: https://www.ceaa-acee.gc.ca/050/documents/p80124/114856E.pdf page 9
Dr. Michael Stephens, former Manager, Business Operations, Liability Management Unit; and former Manager, Strategic Planning, Nuclear Legacy Liabilities Program at AECL states:
It is surprising that the proponent is proposing to entomb the WR-1 reactor, which was successfully operated throughout its operating lifetime and underwent a planned permanent shutdown in 1985. Entombment is not an accepted practice in the world’s nuclear community in such a situation.Source: https://www.ceaa-acee.gc.ca/050/documents/p80124/114855E.pdf page 1
Concerns about the Rolphton Entombment
Dr. Michael Stevens and Dr. J.R. Walker both also commented on the proposed entombment of the NPD reactor at Rolphton, noting the lack of compliance with IAEA guidance.
Here are the links to two of their submissions on the Rolphton project:
Here are the links to two of their submissions on the Rolphton project:
Dr. Michael Stephens (former Manager, Business Operations, Liability Management Unit; Manager, Strategic Planning, Nuclear Legacy Liabilities Program, AECL)
“It is surprising that the proponent is proposing to entomb the NPD reactor, which was successfully
operated for 25 years and underwent a planned permanent shutdown in 1987. The proponent must
surely be aware that entombment is not an accepted practice in the world’s nuclear community in such
J.R. Walker (former Director, Safety Engineering & Licensing; Champion, NLLP Protocol, AECL)
“The proposal described in the Draft EIS  would cause Canada to be in violation of its obligations
under the Joint Convention , since:
• Internationally endorsed criteria and standards have been ignored, e.g., General Safety
Requirements Part 6: Decommissioning of Facilities  and Specific Safety Requirements:
Disposal of Radioactive Waste ;
• Reasonably predictable impacts on future generations are greater than those permitted for the
current generation; and
• Undue burdens are imposed on future generations.”
NPD will remain a radiological hazard for tens of thousands of years (see, for example, Figure G-75 of
). It is absurd to conclude that cement grout, a reinforced concrete cap above the reactor vessel, and
an engineered barrier (fill, geomembrane, soil, and vegetation) over the building footprint will protect
the public for that period of time”
“The Draft EIS  and the associated project proposal contain numerous deficiencies.
These deficiencies include:
a) The proposal does not discharge Canada’s liabilities concerning the NPD Reactor, since it
neither safely disposes of the radiological hazard nor does it get the liability off the books;
b) The proposal fails to address Canada’s international obligations, since it fails to meet the
requirements of the Joint Convention on the Safety of Spent Fuel Management and on the
Safety of Radioactive Waste Management ; and
c) The proposal and its assessment lack credibility, since it employs inadequate technology that
would result in radiological doses to future residents that exceed those that are permissible in
Bill Turner also commented on the Rophton project. Mr. Turner is a retired AECL Quality Assurance Specialist and Environmental Assessment Coordinator/Strategic Planner. He points out that according to the IAEA, entombment is not considered a decommissioning strategy and is not an option in the case of planned permanent shutdown. He quotes from IAEA guidance document Decommissioning of Facilities, General Safety Requirements Part 6, IAEA, Vienna, 2014 on page 1 of his 10 page submission. Here is a link to his full submission: https://www.ceaa-acee.gc.ca/050/documents/p80121/114830E.pdf