November 2020 (updated April 2022)

See also: Critical comments from former AECL officials and scientists on CNL Disposal projects

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://api.cnsc-ccsn.gc.ca/dms/digital-medias/CMD22-H7-63B.pdf/object?subscription-key=3ff0910c6c54489abc34bc5b7d773be0

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.”

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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 as
former Manager for Strategic Planning for the Canadian Nuclear Legacy Liabilities Program.

source: https://www.ceaa.gc.ca/050/documents/p80122/119775E.pdf page 2

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 members
of the public to be subject to unacceptable radiological risks into the far future.

source: https://www.ceaa.gc.ca/050/documents/p80122/119034E.pdf page 7

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 released
into the environment. As noted previously, the predicted doses exceed the public dose limit specified in Canadian Regulations [10] for more than 100,000 years.

source: https://www.ceaa.gc.ca/050/documents/p80122/119034E.pdf page 8

These are Dr. Walker’s concluding remarks about the NSDF environmental impact statement:

5.0 Concluding Remarks
The Draft EIS [1] 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 [1] is in noncompliance with international requirements and guidance, for
example:
• Entombment is not acceptable as a decommissioning strategy [2];
• Near surface disposal is not acceptable for intermediate level waste [8]; and
• Perpetual institutional control is not acceptable [6 – 10, 13].

Source: https://www.ceaa-acee.gc.ca/050/documents/p80124/121207E.pdf page 9

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
a situation.”

J.R. Walker (former Director, Safety Engineering & Licensing; Champion, NLLP Protocol, AECL)

“The proposal described in the Draft EIS [1] would cause Canada to be in violation of its obligations
under the Joint Convention [17], since:
• Internationally endorsed criteria and standards have been ignored, e.g., General Safety
Requirements Part 6: Decommissioning of Facilities [4] and Specific Safety Requirements:
Disposal of Radioactive Waste [7];
• Reasonably predictable impacts on future generations are greater than those permitted for the
current generation; and
• Undue burdens are imposed on future generations.”

“4.6 Summary
NPD will remain a radiological hazard for tens of thousands of years (see, for example, Figure G-75 of
[20]). 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 [1] 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 [17]; 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
Canada today.”

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

(This post was originally created in November 2020. Updated April 2022.)

Since the GoCo contract was signed, costs to Canadian taxpayers appear to have almost quadrupled. According to AECL financial reports, its parliamentary appropriations rose from $327-million in 2015 to $1.3-billion (approved) for the year ending March 31, 2021. AECL’s nuclear waste liabilities have not gone down, but appear to have increased by about $200-million.

Parliamentary Appropriations

Here are the figures and references for parliamentary appropriations to AECL:

$327 million in 2015

$491 million in 2016

$784 million in 2017

$826 million in 2018

Reference is the Five Year Consolidated Financial Summary in AECL’s annual report 2018, page 390

Parliamentary appropriations to AECL:

$829 million in 2019

$868 million in 2020

Reference is the Five-Year Financial Summary table on page 35 of AECL’s annual report 2019-20, page 35

Approved parliamentary appropriations for the year ending March 31, 2021 are $1.3 billion. The reference is Page 30 in this document: https://www.aecl.ca/wp-content/uploads/2020/08/AECL-2020-2021-Q1-Financial-Report.pdf The quote reads as follows:

The appropriations approved for operating and capital expenditures for the year ending March 31, 2021 total $1,254 million.

$1.254 billion rounded to two figures is $1.3 billion. So the parliamentary appropriations for AECL have risen from $327 million in 2015 to $1.3 billion in 2020-21, which is roughly quadrupled.

Update April 2022 ~ appropriations approved for year ending March 31, 2022 were $1.23 billion (see blue highlight below).

This table is from the Atomic Energy of Canada Limited 2021-22 Third Quarter Financial Report page 29

Nuclear Waste Liabilities

The figures for the nuclear waste liabilities are in the second last line in the table entitled Five-year financial summary, on page 36 of AECL’s annual report 2019-20 The report refers to the liabilities as “Decommissioning and waste management provision and contaminated sites liabilities”

In the farthest right column, the figure for 2106 is 7.87 billion which matches what the Auditor General reported in his special report in 2017 which said:

“One element of the Corporation’s mandate concerns decommissioning and waste management to deal with the results of decades of nuclear activities at the Corporation’s sites and with the cleanup of waste at orphan sites for which the federal government has assumed responsibility. The cost of this work is estimated at over $7.9 billion as of 31 March 2016.”

Report of the Auditor General of Canada to the Board of Directors of Atomic Energy of Canada Limited—Special Examination—2017 https://www.oag-bvg.gc.ca/internet/English/parl_oag_201711_07_e_42672.html

The figure on the farthest left is the amount of the liabilities for 2020. It is $8.06 billion or 8.1 billion, rounded to two figures.

The difference between the liabilities in 2016 at $7.9 billion and 2020 at $8.1 billion is a small increase of $200 million.

November 5, 2020

The multinational consortium “Canadian National Energy Alliance” is proposing three substandard nuclear waste disposal projects. They are a giant above-ground mound alongside the Ottawa River at Chalk River, Ontario, for one million tons of radioactive waste and two “entombments” of old nuclear reactors beside the Ottawa and Winnipeg rivers, at Rolphton, Ontario and Pinawa, Manitoba.

The consortium was required to prepare Environmental Impact Statements for all three of its proposed disposal projects, as part of the Environmental Assessment process. Here are links to the three studies:

https://iaac-aeic.gc.ca/050/evaluations/document/119303 (Chalk River Mound aka NSDF)

https://iaac-aeic.gc.ca/050/evaluations/document/121057 (Rolphton entombment)

https://iaac-aeic.gc.ca/050/evaluations/document/120775 (Whiteshell entombment)

The EIS for the Chalk River Mound describes many ways that the mound would leak radioactive contaminants into the environment and the Ottawa River. The ways the mound would leak are summarized in this post:

How would the Chalk River Mound leak? Let us count some of the ways

This post describes the expected eventual disintegration of the Chalk River mound, using excerpts from the Environmental Impact Statement for the Chalk River Mound (NSDF) and supporting documents:

Consortium’s study appears to show the Chalk River mound would disintegrate

The cracking and leaking of the entombed reactors planned for Rolphton, Ontario and Pinawa, Manitoba is described in the Environmental Impact Statements and summarized in this post:

Proposed reactor tombs would leak radioactive materials into the Winnipeg and Ottawa Rivers for millennia

November 5, 2020

The multinational consortium, Canadian National Energy Alliance, has been managing Canada’s nuclear facilities and radioactive wastes under a GoCo (Government-owned, Contractor-operated) contract since September 2015.

The consortium is proposing to quickly and cheaply dispose of all Canada’s federal radioactive wastes in a giant landfill beside the Ottawa River and two concrete “entombments” of old, highly radioactive nuclear reactors beside the Winnipeg and Ottawa rivers.

The proposals are undergoing protracted Environmental Assessments. They are mired in controversy and years behind schedule. Here are the links to Environmental Impact Statements for the three projects:

https://iaac-aeic.gc.ca/050/evaluations/document/119303 (NSDF)

https://iaac-aeic.gc.ca/050/evaluations/document/121057 (NPD)

https://iaac-aeic.gc.ca/050/evaluations/document/120775 (Whiteshell)

Part of the reason for the controversy is that the consortium’s proposals flout safety standards of the International Atomic Energy Agency. As a member state, Canada is supposed to follow IAEA guidance.

Here are some examples of IAEA guidance that is being flouted:

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 (emphasis added). 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 Safety Standard for Disposal of Radioactive Waste says that the fundamental safety objective of radioactive waste management, including disposal, is “to protect people and the environment from harmful effects of ionizing radiation.” The strategy to achieve this objective with regard to disposal of radioactive waste is “to contain the waste and to isolate it from the accessible biosphere… [which] is taken generally to include those elements of the environment, including groundwater, surface water and marine resources, that are used by people or accessible to people.”

The NSDF proposal turns the IAEA standard on its head.  Rather than isolating radioactive wastes from groundwater and surface water, and disposing of them in stable environments ensuring long-term safety, it would use a design similar to a municipal landfill, in which wastes would be deliberately and routinely allowed to come into contact with the environment, including rain and snow. 

The NSDF proposal calls for a giant mound exposed to the elements.  Surface run-off from the mound would carry radionuclides into three storm-water management ponds.  These would discharge directly into the East Swamp wetland.  Sub-surface waters leaching through the mound would carry radionuclides through a collection system to a newly constructed water treatment facility.  This facility would remove some radionuclides (presumably for disposal using an unspecified method), while allowing others (e.g., tritium) to pass through untreated for release into the East Swamp stream, Perch Creek and the Ottawa River.

The NSDF proposal flouts IAEA guidance calling for “impermeable and water diverting features” for LLW disposal, and a “stable, geological environment” for ILW disposal.  Canada, which participates actively in development of IAEA Safety Standards, should not be allowed to flagrantly disregard them at a government-owned facility.

CNL’s use of the term NSDF — “Near Surface” Disposal Facility — is misleading.

This IAEA safety guide
“Near Surface Disposal Facilities for Radioactive Waste” Specific Safety Guide SSG-29 says on page 37

4.15. The concept of near surface disposal covers a wide range of facilities
(e.g. disposal at the surface in engineered vaults or trenches, or disposal at
varying depths — from a few metres to a few tens of metres — in facilities with various types of engineered barriers).