CNSC’s EA report for the Chalk River Mound – failure to consider “end state objectives”

By comparing the unconditional clearance levels in Schedule 2 of the Nuclear Substances and Radiation Devices Regulations to the Radionuclide Concentration Limits in Table 4 of the NSDF Waste Acceptance Criteria (WAC), one can conclude that long-lived radionuclides proposed for disposal – if present in packaged wastes at maximum permitted limits – would not decay to clearance levels for thousands to millions of years.

Summing the radioactivity quantities in Table 11 of the WAC, at 1600 years post-closure, the entire contents of the mound would exceed unconditional clearance levels by more than 5-fold, even if all radionuclides were evenly distributed throughout.  Hence removal from regulatory control would not be possible for millennia.

CNSC’s environmental assessment report makes confusing/contradictory statements about removal from regulatory control:

The Post-Institutional Control Period will occur after the IC period and continues indefinitely, subject to either federal or provincial regulatory control.

 At a given time in the future and/or after year 2400, and taking into consideration the regulatory requirements in effect at that time, CNL will seek Commission approval for the removal of the NSDF from CNSC regulatory control.

CNL’s licence specifically allows “Release from Regulatory Control — The licensee shall only release the decommissioned property, or any part thereof, for reuse upon the acceptance of the final end-state report by the CNSC.”

CNSC’s environmental assessment report is supposed to cover all licensing stages, including decommissioning and abandonment (removal from regulatory control).  But it contains absolutely no mention of an end-state report, and only the following passing reference to end state:

CNL indicated that although it is outside the scope of the NSDF project, CNL is establishing the Land Use Program to determine next land uses and end state objectives for all CNL managed sites in Canada.

End state objectives for the NSDF are definitely NOT outside the scope of the project.  End state is absolutely central to the whole concept of a disposal facility.  This is a fatal omission in the environmental assessment.

***The real end state would be a degrading mound that would expose the public to nuclear substances in excess of clearance levels for millennia.***

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