Pushing ahead with a disposal facility, before properly characterizing the wastes is an act of very poor judgement according to an expert in waste inventory control and radioactive waste characterization.

The following submission to the CNSC for the NSDF licensing hearing was prepared by Greg Csullog, an expert on radioactive waste characterization who worked for 21 years at Atomic Energy of Canada Limited and seven years at the the International Atomic Energy Agency. He has given us permission to share his intervention here. His qualifications and experience are summarized at the start of his intervention which can be viewed below.

This information is critical to the issue of whether or not CNSC should grant approval to CNL to construct the NSDF. The bottom line is that the legacy radioactive wastes accumulated at Chalk River Labs over a period of nearly eight decades are a poorly characterized mishmash of “low” and “intermediate” level waste, and they are not suitable for disposal in the proposed NSDF.

The legacy radioactive wastes accumulated at Chalk River Laboratories over a period of nearly eight decades are a poorly characterized mishmash of “low” and “intermediate” level waste, and they are not suitable for disposal in the proposed NSDF.

Here are some key “takeaways”:

• in Mr. Csullog’s opinion, the NSDF proponent has displayed a deep lack of knowledge of “low level waste” and “intermediate level waste” and how they must be handled
• For the vast majority of time that radioactive wastes were generated, collected and stored at CRL, LLW and ILW were not characterized, labeled, and tracked and most were not managed separately. Simply put – a lot of LLW and ILW were stored together in unmarked packages.
• mixing a small amount of ILW with LLW would mean the mix of LLW and ILW wastes would have to be re-classified as all ILW, just as contaminating 1000 ml of water with 1 ml of toxic water would turn drinkable water into non-drinkable water.
• Prior to the 1990’s  wastes were not classified as would be commonly accepted today. They were placed into  storage based on where they were generated, the radiation field they emanated, and the size,  shape and weight of packages. They were NOT classified as LLW and ILW
• CNSC would seem to have underestimated the huge effort if would take to adequately characterize stored waste, much of it a mish-mash of unsegregated, unmarked, uncharacterized, mixture of LLW and ILW.
• CNSC should advise the NSDF project that it  would be better off considering a non-surface option for this mish-mash. 
• bad past practices would make it extremely difficult for anyone to determine how  much LLW and ILW was stored (at CRL) and that puts any estimate like done for the JC [Joint  Convention] in the suspect category.

Here is Greg Csullog’s full intervention. Click on the link below the window if you prefer to read in your browser without downloading.

Greg Csullog also submitted details comments on the Draft Environmental Impact Statement for the NSDF. They are posted on the Impact Assessment registry at these links.

Greg Csullog (May 1, 2017)

Greg Csullog (May 29, 2017)