Evidence is accumulating that wastes proposed for disposal in the NSDF are “Intermediate Level”

January 22. 2024

See also~ National Observer: Waste headed for Ontario site is a radioactive ‘mishmash’: nuclear industry veterans

An NSDF media kit on the website of the Canadian Nuclear Safety Commission states that

“Canadian Nuclear Laboratories (CNL) has been authorized to construct an engineered facility, called a near surface disposal facility (NSDF), to dispose of low-level radioactive waste at the Chalk River Laboratories (CRL) site in Deep River, Ontario. Low-level radioactive waste includes contaminated building materials, soils, and operational equipment (for example, protective shoe covers, clothing, rags, mops, equipment and tools).” (emphasis added)

On page 88 of the transcript of the final licensing hearing for the NSDF on August 10, 2023, Meggan Vickerd, CNL deputy vice-president of Integrated Waste Services is quoted as saying this:

“It is important to restate that only low-level radioactive waste from Canadian sources will be accepted. This waste consists of building demolition debris from current decommissioning activities at the Chalk River Laboratories site, legacy wastes and associated impacted soils, as well as general waste items such as mops and rags generated from our ongoing operations.” (emphasis added)

In Paragraph 39 of its Record of Decision for the NSDF license approval, the Canadian Nuclear Safety Commission states: “The NSDF will contain only LLW.”

The statements above that the NSDF would only contain low-level waste do not stand up to scrutiny. The use of examples like “mops and rags and shoe covers” is misleading.

Consider that:

Much of the legacy waste at the Chalk River Labs site was created during plutonium production for the US nuclear weapons program and other activities involving “post-fission” radioactive waste ie. waste produced in a nuclear reactor. This post-fission waste includes very long-lived radioactive materials that are difficult to manage. Some of this waste can actually become more radioactive over time due to the complex decay chains of long-lived alpha emitters.

According to the  International Atomic Energy Agency, waste from research facilities such as Chalk River Laboratories generally belongs to the “Intermediate-level” waste class and must be kept underground, tens of metres or more below the surface.

Twenty-five out of the 31 radionuclides listed in the reference inventory for the mound are long-lived with half-lives from thousands to millions of years.

A former senior manager at AECL told the CNSC that the waste would not decay to unconditional clearance levels for thousands of years. The design life of the facility is only 550 years. He also said that “the emplaced material is intermediate level radioactive waste that should not be emplaced in a near surface facility because it requires a greater degree of containment and isolation than that provided by near surface disposal.” (emphasis added) (more info)

It is becoming increasingly clear that long-lived radioactive materials that predominate in the NSDF licensed inventory, would outlive the facility by thousands of years.

Background

During the public comment period on the Environmental Impact Statement for the NSDF in 2017, many groups and individuals expressed concern about intermediate level waste being placed in an above ground mound.

The Town of Deep River and its then mayor Joan Lougheed were among those concerned about intermediate level waste being put into the NSDF. Mayor Lougheed was quoted in a 2017 Globe and Mail article, “Ontario town slams proposal for nuclear-waste facility,” as saying the town had concerns about the intermediate-level radioactive material that requires isolation and containment for more than several hundred years.

Shortly after the Globe and Mail article was published, CNL publicly announced that it would not put intermediate level waste in the mound. However CNL’s final Environmental Impact Statement says, “It is not practical, technical, or economical, to separate the long-lived radionuclides from the waste streams…”  

According to the Canadian Environmental Law Association, most of the radionuclides in the proposed inventory for the NSDF have half-lives longer than 10,000 years, and their proposed quantities are very large.

According to the former director of Safety Engineering and Licensing at AECL and former Champion of the Nuclear Legacy Liabilities project, in his April 6, 2022 submission to the CNSC:

“The waste acceptance criteria are insufficiently protective for the material permitted to be emplaced in the proposed Engineered Containment Mound to qualify as low level waste — the radionuclides do not decay to an acceptable level during the time that institutional controls can be relied upon. Consequently, the emplaced material is intermediate level radioactive waste that should not be emplaced in a near surface facility because it requires a greater degree of containment and isolation than that provided by near surface disposal.” (emphasis added)

and

CNL’s proposal is not a disposal facility for low level radioactive waste:
Proposal is an Engineered Containment Mound comprising a large and unverified quantity of intermediate-level waste;  (Slide 12)

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

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 Inventorydated 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.