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How investment in SMRs supports “defense nuclear programs”

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1. Rolls-Royce, 2017, ‘UK SMR: A National Endeavour’, https://www.uknuclearsmr.org/wp-content/uploads/2017/09/V2088-Rolls-Royc…

“The indigenous UK supply chain that supports defence nuclear programmes requires significant ongoing support to retain talent and develop and maintain capability between major programmes. Opportunities for the supply chain to invest in new capability are restricted by the limited size and scope of the defence nuclear programme. A UK SMR programme would increase the security, size and scope of opportunities for the UK supply chain significantly, enabling long-term sustainable investment in people, technology and capability.

“Expanding the talent pool from which defence nuclear programmes can draw from would bring a double benefit. First, additional talent means more competition for senior technical and managerial positions, driving excellence and performance. Second, the expansion of a nuclear-capable skilled workforce through a civil nuclear UK SMR programme would relieve the Ministry of Defence of the burden of developing and retaining skills and capability. This would free up valuable resources for other investments.”

International Atomic Energy Agency still says “entombment” is not an acceptable decommissioning strategy

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November 2, 2020

The Canadian Nuclear Safety Commission, Canada’s “captured” nuclear regulator, had hoped that the latest updated guidance from IAEA would allow entombment of old reactors as a decommissioning strategy.

Here is CNSC in 2017, “dispositioning” critical comments on the proposed entombment of old (and still highly radioactive) nuclear reactors at Rolphton, Ontario and Pinawa, Manitoba:

“Yes, the document referenced, IAEA GSR 6, indicates that
entombment is not recognized internationally, in principle,
as a preferred decommissioning strategy (entombment may
be considered a solution only under exceptional
circumstances, such as following a severe accident). The
IAEA is currently working on a document to provide
guidance with respect to their position on entombment
in situ decommissioning the applicability of entombment in
the context of decommissioning and in particular, the
regulatory requirements and expectations for applying
entombment as a decommissioning option strategy. There is
no scheduled date for the publication of this document;
however, CNSC staff will keep apprised of its development
to inform this EA and licensing review process.
Irrespective of the IAEA guidance document, under the
CNSC’s regulatory framework, applicants are responsible
for selecting and justifying their proposed decommissioning
strategy.”

That quotation is from this document: https://www.ceaa-acee.gc.ca/050/documents/p80124/118863E.pdf
Page 9, top right.

The CNSC must have been disappointed when the new IAEA guidance document was published in 2018 and it STILL says that entombment is not acceptable as a decommissioning strategy.

The new IAEA document is

Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities ~ Specific Safety Guide No. SSG-47, Vienna, 2018

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. 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 explicitly recommended that Canada align its decommissioning strategy with this standard, during a peer review mission in September 2019. See a summary of IAEA recommendations to Canada here.

Undeterred, the CNSC is attempting to make entombment acceptable in its own “RegDocs”, pseudo regulations that rely heavily on nuclear industry created CSA standards, but that is another story, that is covered elsewhere. See Ole Hendrickson’s recent Op Ed in the Hill Times and the recent letter to Prime Minister Justin Trudeau that requests urgent action to address nuclear safety gaps in Canada.

RED ALERT ~ CNL tells CNSC it has current plans to put “intermediate level waste” in above ground mounds

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July 2019

In October 2017, Canadian Nuclear Laboratories (CNL) announced that it would not put Intermediate Level Waste (ILW) in a proposed above-ground mound.

CNL incorrectly calls this mound a “Near Surface Disposal Facility” (NSDF). International Atomic Energy Agency (IAEA) safety requirements state that a near surface facility should consist of in-ground vaults or trenches, and is suitable only for Low Level Waste.

In March 2019, the Canadian Nuclear Safety Commission (CNSC), Canada’s captured nuclear regulator, released a draft “Regulatory Document” on waste management for comment. The CNSC’s proposed language on ILW was that it “generally requires” greater isolation than would be provided by near surface disposal.

Putting ILW above-ground would go against common sense. Because of its long-lived radionuclides, the IAEA requires that ILW be disposed of “at least a few tens of metres below ground level.”

In June 2019 CNL submitted its comments on the draft RegDoc. CNL asked CNSC to further weaken its wording on ILW, saying “There are current plans to place ILW in aboveground mounds.”  CNL wanted the language on ILW changed from “generally requires” to “may require” greater isolation.

CNSC’s final version of the Regulatory Document, published February 2021, retains the original language of “generally requires”.

This could allow CNL to dispose of long-lived, intermediate-level radioactive waste in its proposed above-ground mound, the so-called NSDF.

Why did CNL say in October 2017 that it would not put ILW in the NSDF, but tell CNSC in June 2019 that there are “current plans to place ILW in aboveground mounds”?

From the IAEA Specific Safety Requirements No. SSR-5, Disposal of Radioactive Waste, page 4:

(b) Near surface disposal: Disposal in a facility consisting of engineered trenches or vaults constructed on the ground surface or up to a few tens of metres below ground level. Such a facility may be designated as a disposal facility for low level radioactive waste (LLW)

(c) Disposal of intermediate level waste: Depending on its characteristics, intermediate level radioactive waste (ILW) can be disposed of in different types of facility. Disposal could be by emplacement in a facility constructed in caverns, vaults or silos at least a few tens of metres below ground level and up to a few hundred metres below ground level. It could include purpose built facilities and facilities developed in or from existing mines. It could also include facilities developed by drift mining into mountainsides or hillsides, in which case the overlying cover could be more than 100 m deep. 

From the IAEA Specific Safety Requirements No. SSR-5, Disposal of Radioactive Waste, page 55:

Intermediate level waste (ILW): Waste that, because of its content, particularly of long lived radionuclides, requires a greater degree of containment and isolation than that provided by near surface disposal.  

From CNL updates NSDF Waste Inventory, dated October 26, 2017:

Canadian Nuclear Laboratories (CNL) announced today that it has re-evaluated its proposal for the Near Surface Disposal Facility (NSDF) at Chalk River Laboratories, and has made the decision to only include low-level radioactive waste in the NSDF…. Intermediate level waste will continue to be managed in interim storage at Chalk River Laboratories until a long-term disposal solution for this category of radioactive waste has been developed and approved. 

From CNSC REGDOC-2.11.1, Volume I, Management of Radioactive Waste, March 2019 draft, section 6.1, Waste Classification, bullet 4, page 4:

Due to its long-lived radionuclides, ILW generally requires a higher level of containment and isolation than can be provided in near surface repositories.

From Canadian Nuclear Laboratories Comments on Draft Regdoc-2.11.1, Volume 1: Management Of Radioactive Waste, page 11 of 25, comment #13 on section 6.1, dated June 27, 2019: 

The 4th bullet is a potentially misleading or biasing statement. There are current plans to place ILW in aboveground mounds. 

Amend 4th bullet to read, “Due to its long‐lived radionuclides, ILW generally may require a higher level of containment and isolation than can be provided in near surface repositories.

2000 nuclear waste shipments planned, from Pinawa Manitoba to Chalk River, Ontario

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This is page 41 of the application for renewal of the Whiteshell Labs license. The CNSC hearing for this license renewal is scheduled for October 2-3, 2019. This page outlines CNL’s plans for transport of low, intermediate and high level radioactive waste from Pinawa, Manitoba to Chalk River, Ontario. The full license application can be viewed at http://www.cnl.ca/en/home/about/WLSiteRelicensing2018.aspx

A total of 2,000 shipments are described in this excerpt, including shipments of liquid waste and irradiated nuclear fuel rods. Shipments are already underway as of March, 2019.

Multinational consortium yields to public pressure on nuclear dump plan

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(Ottawa, October 30, 2017) The multinational consortium running Canadian Nuclear Laboratories (CNL) and managing Canada’s federally-owned radioactive waste announced on Thursday (October 26th) that it will remove intermediate-level waste, which requires remote handling, from its plans for a giant radioactive mound beside the Ottawa River at Chalk River, Ontario.

Citizens’ groups who have been working for months to sound the alarm about the CNL proposal hailed the announcement as a partial victory. Over 200 submissions, most highly critical, were sent to the Canadian Nuclear Safety Commission during the public comment period for the project’s environmental impact study that ended in August.

CNL said in a press release October 26th that it was responding to comments from the public and the Canadian Nuclear Safety Commission, and that wastes intended for disposal in the proposed facility will meet guidelines for low level radioactive waste set out by the International Atomic Energy Agency (IAEA).

“We are pleased that our concerns are being heard,” said Johanna Echlin of the Old Fort William Cottagers’ Association, based in Sheenboro Quebec. “We said from the start that the facility should not contain “intermediate level” waste which is supposed to be disposed of in underground caverns according to the IAEA.”

There is still a long way to go before the proposal could be considered acceptable, according to Echlin. She notes that even “low level” radioactive waste is not supposed to be disposed of on top of the ground in a mound according to the IAEA. “It’s only common sense”, says Echlin. “You don’t have to be a rocket scientist or nuclear engineer to understand that radioactive waste should not be placed on plastic liners that will deteriorate long before the waste becomes harmless.”

“Low-level” waste is a misnomer that causes a lot of confusion, according to Dr. Ole Hendrickson of Concerned Citizens of Renfrew County and Area. “Low-level” waste is so named because it can be handled without using robots or special shielding, unlike used nuclear fuel rods which can provide a fatal dose of radiation within seconds to a person standing a few feet away.

“Low-level” radioactive waste can contain very hazardous materials, says Hendrickson. “Man-made isotopes such as plutonium, neptunium, and americium have extremely long half lives. They are highly toxic and will be around for thousands of years. Yet significant quantities are destined for this facility if it gets approved.”

Citizens groups say the proposed technology, an “engineered mound” similar to a municipal landfill, is not acceptable. They would like to see a “state-of-the-art” facility that would keep the radioactive materials out of the air and water for as long as they remain harmful, which could be longer than 100,000 years.  Facilities currently under construction in Finland and France which utilize engineered caverns in stable rock, tens of metres below the surface, would be much safer and could serve as an example for a new Canadian facility.

Dump opponents are also concerned about the site for the facility. “You couldn’t choose a worse site for this dump if you tried,” according to Echlin, “on the side of a hill, that would have to be deforested, and smack in the middle of a wetland that drains into the Ottawa River only a kilometre away”.

Proximity to the river is causing worry about possible contamination of drinking water since the Ottawa River is a drinking water source for millions of Canadians downstream of Chalk River in cities such as Ottawa-Gatineau and Montreal.

Ole Hendrickson of the CCRCA notes that siting was not done according to IAEA guidance that calls for a site that can ensure the environment will be adequately protected during the entire lifetime of the facility. “CNL should explore the 70,000 acres of federal land adjacent to the Chalk River Labs property to find a more suitable location,” Hendrickson said. “With a better location, away from the river and in stable rock, we could all get behind this project and build a facility that Canada can be proud of,” he added.

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