April 2022

The radioactive wastes at Chalk River Laboratories (CRL), Canada’s main nuclear research facility, are well described in Annex III, Origin and Types of Radioactive Waste, in the International Atomic Energy Agency (IAEA) General Safety Guide GSG-1, Classification of Radioactive Waste:

Waste from research reactors III–16.
The waste generated by research reactors and from some disused radioactive sources is particularly significant because, owing to its level of activity concentration and to the half-lives of the radionuclides, it does not meet the waste acceptance criteria of near surface disposal facilities.

Waste from research facilities III–17.
Research facilities (e.g. hot cell chains, glovebox chains) or pilot plants for checking fuel fabrication processes (particularly the fabrication of mixed uranium plutonium oxides, known as MOX), for fuel reprocessing (particularly advanced schemes), and for post-irradiation examinations, as well as their
analytical laboratories, generate types of waste that, often, are different from the typical waste generated by industrial plants. Owing to the presence of non-negligible amounts of long lived alpha emitters, waste from research facilities generally belongs to the ILW class and even, in some circumstances, to the HLW class.

Annex III, Origin and Types of Radioactive Waste, IAEA General Safety Guide GSG-1, Classification of Radioactive Waste:

These two paragraphs indicate that the radioactive waste at CRL would not be appropriate for near surface disposal. Much is likely to belong to the ILW class, requiring disposal tens of meters or more below the ground surface.

The NSDF proponent is misusing the name “Near Surface Disposal Facility” for an above -ground
landfill. It beggars belief that CNSC staff would support the construction of an aboveground facility for wastes from a Government of Canada research facility, nearly all of which (by volume) will remain hazardous and radioactive for more than 100,000 years.

It beggars belief that CNSC staff would support the construction of an aboveground facility for wastes from a Government of Canada research facility, nearly all of which (by volume) will remain hazardous and radioactive for more than 100,000 years.