Debunking myths about the Chalk River Mound (aka “NSDF”)

The Chalk River Mound or “near surface disposal facility” is a proposed giant above ground landfill for one million tons of radioactive waste on the property of Canadian Nuclear Labs, less than one kilometre from the Ottawa River upstream of Ottawa-Gatineau and Montreal. We debunk below two of the most misleading myths about the proposed facility. Please contact us if you need more references for the material presented below, or browse our list of all posts for more information.

Myth # 1: It’s only “low level waste”


“Low level” in the context of radioactive waste does not mean “low hazard”

This is a really big mistake that almost everyone makes. “Low level” simply means the wastes can be handled by nuclear industry workers without the use of lead shielding because the wastes give off relatively low levels of gamma radiation. But they can and do contain high levels of other types of radiation such as “alpha” and “beta.”  “Low level” radioactive waste can remain hazardous for hundreds of thousands of years and includes some of the most toxic radioactive poisons known such as plutonium.

No “Intermediate waste” in the NSDF is a red herring.
Neither “Low level” OR “Intermediate level” radioactive wastes are supposed to be disposed of in above-ground engineered mounds (landfills) according to the International Atomic Energy Agency. That is because both categories are dangerous and pose risks to all life on earth for the duration of their radiological hazard, which is hundreds of thousands of years for BOTH CATEGORIES of waste.  The main thing that distinguishes “Low level” from “intermediate level” radioactive waste is that “low level” can be handled without shielding or robots because its risks come from inhalation or ingestion. “Intermediate level” waste on the other hand gives off strong gamma radiation and therefore requires lead shielding and/or remote handling.

Much of the legacy waste at the Chalk River site is a poorly characterized or uncharacterized MIXTURE of “low” and “intermediate” level wastes.
The dividing lines between the categories are blurry. There are many different definitions around the world. Canada’s definitions are inferior to those in other countries. The wastes are not all sitting around in nice neat packages labelled “low level” and “intermediate level”. It would be the work of decades to properly categorize, package and label all the legacy wastes, and arguably, this should be done before choosing technologies for managing the wastes. We are in touch with a former engineer at AECL who was in charge of waste characterization for decades and worked as a consultant for the IAEA. He says the knowledge level of legacy wastes at Chalk River was and likely still is “abysmal”.

The proponent is playing games with Waste Acceptance Criteria to enable maximum disposal of legacy wastes in the NSDF
Definitions are being finagled to enable claims that “only” low-level wastes would go in the facility.  Canada’s nuclear regulator, the Canadian Nuclear Safety Commission, allows proponents to make up their own definitions of waste classes.  The NSDF proponent defines wastes with long-lived beta/gamma activity as high as ten thousand radioactive disintegrations per second per gram of waste (Bq/g) as “low level”.  Finland puts any waste with activity greater than one hundred Bq/g in an underground facility, 65-90 meters deep in crystalline rock.5.

The proponent’s contract with Atomic Energy of Canada states that it will dispose of ALL wastes quickly and cheaply.
The main objective of the GoCo contract was to reduce Canada’s legacy radioactive waste liabilities. The ONLY strategies being advanced by the consortium are the above ground engineered mound (landfill) and in-situ burial of reactors on the Ottawa and Winnipeg rivers.  Thus, the contract provides a strong incentive for the consortium to dispose of uncharacterized legacy wastes in the NSDF since it’s the only project on the table.

Myth #2: It’s a “sound project from an engineering point of view.”

The engineered containment mound is expected to disintegrate within a few hundred years and the contents flow out of the mound into the surrounding wetlands that drain into the Ottawa River. The NSDF draft environmental impact statement includes 25 occurrences of the phrase “liner and cover failure as a result of normal evolution” and three occurrences of the phrase “inevitable failure of the cover.”  The “bathtub scenario” is mentioned 30 times in the draft EIS. It is projected to occur in the year 2400 when the cover fails, water enters the mound and overflows, and takes contaminants into Perch Creek and the Ottawa River. The Performance Assessment for the NSDF includes a graphic illustration of the bathtub scenario, a table listing quantities of radionuclides flowing out of the mound into the Ottawa River, and a pie chart showing estimated doses of various radionuclides to an infant downstream in Pembroke. Given the expected eventual disintegration of the mound and migration of its contents into the Ottawa River, it would seem to be inappropriate to refer to the project as “a sound proposal from an engineering point of view.” 

The image below is a simulation of the “bathtub effect” from the Radio Canada Decouverte documentary “Chalk River Heritage.”

City of Ottawa urges CNL and its regulator, the CNSC, to take action on the City’s concerns about the Chalk River mound, Rolphton Reactor tomb and related activities

May 3, 2021

In this letter Mayor Jim Watson urges CNL and the CNSC to take action on Ottawa’s concerns about the giant radioactive waste mound (NSDF) proposed for Chalk River and the entombment of a nuclear reactor beside the Ottawa River at Rolphton.

Specifically the letter and the resolution on which it is based calls on CNL/CNSC to:

  • stop current and future import or transfer of radioactive waste to Chalk River from other provinces
  • increase safeguards to protect the Ottawa River
  • prevent precipitation from entering the Chalk River Mound (NSDF)
  • provide timely environmental monitoring data
  • commit to prompt notification of spills/releases

City of Ottawa requests a regional assessment of radioactive waste disposal projects in the Ottawa Valley

The City of Ottawa is requesting a regional assessment of radioactive waste disposal projects in the Ottawa Valley under Canada’s new Impact Assessment Act. This review, if undertaken as requested, would address cumulative impacts of radioactive waste projects planned for the Ottawa Valley. It would be conducted by a committee appointed for the task by the Minister of Environment and Climate Change or by the Impact Assessment Agency.

City of Ottawa passes resolution of concern about CNL’s radioactive waste activities

OTTAWA CITY COUNCIL ACTS ON COMMITTEE RECOMMENDATIONS

That Council: 

1. Approve that the City of Ottawa urge the Canadian Nuclear Laboratories and its regulator, the Canadian Nuclear Safety OTTAWA CITY COUNCIL 8 AGENDA 51 WEDNESDAY, APRIL 14 2021 Commission, to take action on the City of Ottawa’s concerns related to the proposed Near Surface Disposal Facility (NSDF), Nuclear Power Demonstration (NPD) and related activities, including: 

a. stopping current and future import or transfer of external Atomic Energy of Canada Limited (AECL) waste from other provinces (e.g. Manitoba); 

b. increasing safeguards to protect the river during site demolition and waste transfer activities; 

c. preventing precipitation from entering the NSDF; 

d. providing the City of Ottawa with timely access to ongoing environmental monitoring data on the Ottawa River; and 

e. committing to prompt notification of spill/release events to City of Ottawa, and; 

2. Direct the Public Works and Environmental Services Department to provide an update to the Standing Committee on Environmental Protection, Water and Waste Management on City concerns being submitted through the NSDF Environmental Assessment process, and provide an annual update on radioactivity as part of the Drinking Water Summary Report that is issued to Council in fulfillment of the Safe Drinking Water Act 2002, and;

3. Request that the Minister of Environment and Climate Change initiate a regional assessment of radioactive disposal projects in the Ottawa Valley under the Impact Assessment Act, as amended in 2019, and; 

4. Direct the Mayor to write to the Ministers of Natural Resources, Environment and Climate Change, Infrastructure and Crown-Indigenous Relations, as well as the Canadian Nuclear Safety Commission and the Canadian Nuclear Laboratories to express the City of Ottawa’s concerns and call for action; and, 

5. Direct the City Clerk to share Council’s position and call to action with the Iroquois Anishinabek Nuclear Alliance as well as the Federation of Canadian Municipalities and the Association of Municipalities of Ontario.

Passed at

OTTAWA CITY COUNCIL 9 AGENDA 51 WEDNESDAY, APRIL 14 2021

Six reasons to STOP the Ottawa River radioactive waste dump

March 22, 2021

The Ottawa River is a Canadian Heritage River that flows past Parliament Hill. It has untold value as a beautiful natural and historical treasure. The river is sacred for the Algonquin People whose traditional territory it defines.

The Ottawa River is threatened by a giant landfill for one million tonnes of radioactive and other hazardous waste. A multinational consortium (SNC-Lavalin, Fluor and Jacobs) plans to build the seven-story mound on the grounds of the Chalk River Laboratories, northwest of Ottawa, directly across the Ottawa River from the province of Quebec.

Independent scientists and the public have not had a formal opportunity to comment on this project since August 2017 when hundreds of critical comments were submitted to the Canadian Nuclear Safety Commission. CNSC is the “responsible authority” under the old Canadian Environmental Assessment Act and would hold a licensing hearing at an undetermined date in the future. An Expert Panel  recommended in 2017 that the CNSC not be in charge of environmental assessment for nuclear projects. The panel also noted that the CNSC is widely perceived to be a captured regulator.

The Assembly of First Nations and more than 140 Quebec and Ontario municipalities have passed resolutions opposing the Ottawa River nuclear waste dump.

Here are six reasons to STOP this project:

1. The proposed site is unsuitable for a dump of any kind. The site is less than one kilometre from the Ottawa River which forms the border between Ontario and Quebec. The river is a drinking water source for millions of Canadians. After passing the Chalk River Laboratories, it flows downstream through Ottawa-Gatineau, past Parliament Hill, and on to Montreal. The site is tornado and earthquake prone; the Ottawa River itself is a major fault line. The site is partly surrounded by wetlands and the underlying bedrock is porous and fractured.

2. The mound would contain hundreds of radioactive materials, dozens of hazardous chemicals and tonnes of heavy metals. Radioactive materials destined for the dump include tritium, carbon-14, strontium-90, four types of plutonium (one of the most dangerous radioactive materials if inhaled or ingested), and up to 80 tonnes of uranium. Twenty-five out of the 30 radionuclides listed in the reference inventory for the mound are long-lived. This suggests the dump would remain dangerously radioactive for 100,000 years. 

A very large quantity of cobalt-60 in the dump would give off so much intense gamma radiation that workers must use lead shielding to avoid dangerous radiation exposures. The International Atomic Energy Agency says high-activity cobalt-60 is “intermediate-level waste” and must be stored underground.

Dioxin, PCBs, asbestos, mercury, up to 13 tonnes of arsenic and hundreds of tonnes of lead would go into the dump. It would also contain thousands of tonnes of copper and iron and 33 tonnes of aluminum, tempting scavengers to dig into the mound after closure.

3. The mound would leak radioactive and hazardous contaminants into the Ottawa River during operation and after closure. Many ways the mound would leak are described in the environmental impact statement. The mound is expected to eventually disintegrate in a process referred to as “normal evolution.”

4. There is no safe level of exposure to the radiation that would leak into the Ottawa River from the Chalk River mound. All of the escaping radioactive materials would increase risks of birth defects, genetic damage, cancer and other chronic diseases. The International Atomic Energy Agency says radioactive wastes must be carefully stored out of the biosphere, not in an above-ground mound.

5. International safety standards do not allow landfills to be used for nuclear waste disposal. The International Atomic Energy Agency says that only Very Low Level Radioactive Waste (VLLW) can be put in an above-ground landfill-type facility. Canada would be shirking its international obligations as a member state of the IAEA and a signatory to an international nuclear waste treaty if it allowed this dump to be licensed.

6. The giant Chalk River mound would not reduce Canada’s $8 billion federal radioactive waste liabilities and could in fact increase themThe giant pile of leaking radioactive waste would be difficult to remediate. Remediation costs could exceed those of managing the wastes had they not been put in the mound.

To Prime Minister Trudeau and members of the federal cabinet ~ Stop the Ottawa River radioactive waste dump


January 25, 2021


Dear Mr. Trudeau and members of the federal cabinet:

The Ottawa River is a Canadian Heritage River that flows past Parliament Hill. It has untold value as a beautiful natural and historical treasure. The river is sacred for the Algonquin People whose traditional territory it defines.

The Ottawa River is threatened by a giant landfill for one million tonnes of radioactive and other hazardous waste. A multinational consortium (SNC-Lavalin, Fluor and Jacobs) plans to build the seven-story mound on the grounds of the Chalk River Laboratories, northwest of Ottawa, directly across the Ottawa River from the province of Quebec.

Independent scientists and the public have not had a formal opportunity to comment on this project since August 2017 when hundreds of critical comments were submitted to the Canadian Nuclear Safety Commission. CNSC is the “responsible authority” under the old Canadian Environmental Assessment Act and plans to hold a licensing hearing this year. An Expert Panel  recommended in 2017 that the CNSC not be in charge of environmental assessment for nuclear projects. The panel also noted that the CNSC is widely perceived to be a captured regulator.

The Assembly of First Nations and more than 140 Quebec and Ontario municipalities have passed resolutions opposing the Ottawa River nuclear waste dump.

Here are six reasons to STOP this project:

1. The proposed site is unsuitable for a dump of any kind. The site is less than one kilometre from the Ottawa River which forms the border between Ontario and Quebec. The river is a drinking water source for millions of Canadians. After passing the Chalk River Laboratories, it flows downstream through Ottawa-Gatineau, past Parliament Hill, and on to Montreal. The site is tornado and earthquake prone; the Ottawa River itself is a major fault line. The site is partly surrounded by wetlands and the underlying bedrock is porous and fractured.

2. The mound would contain hundreds of radioactive materials, dozens of hazardous chemicals and tonnes of heavy metals. Radioactive materials destined for the dump include tritium, carbon-14, strontium-90, four types of plutonium (one of the most dangerous radioactive materials if inhaled or ingested), and up to 80 tonnes of uranium. Twenty-five out of the 30 radionuclides listed in the reference inventory for the mound are long-lived. This suggests the dump would remain dangerously radioactive for 100,000 years. 

A very large quantity of cobalt-60 in the dump would give off so much intense gamma radiation that workers must use lead shielding to avoid dangerous radiation exposures. The International Atomic Energy Agency says high-activity cobalt-60 is “intermediate-level waste” and must be stored underground.

Dioxin, PCBs, asbestos, mercury, up to 13 tonnes of arsenic and hundreds of tonnes of lead would go into the dump. It would also contain thousands of tonnes of copper and iron and 33 tonnes of aluminum, tempting scavengers to dig into the mound after closure.

3. The mound would leak radioactive and hazardous contaminants into the Ottawa River during operation and after closure. Many ways the mound would leak are described in the environmental impact statement. The mound is expected to eventually disintegrate in a process referred to as “normal evolution.”

4. There is no safe level of exposure to the radiation that would leak into the Ottawa River from the Chalk River mound. All of the escaping radioactive materials would increase risks of birth defects, genetic damage, cancer and other chronic diseases. The International Atomic Energy Agency says radioactive wastes must be carefully stored out of the biosphere, not in an above-ground mound.

5. International safety standards do not allow landfills to be used for nuclear waste disposal. The International Atomic Energy Agency says that only Very Low Level Radioactive Waste (VLLW) can be put in an above-ground landfill-type facility. Canada would be shirking its international obligations as a member state of the IAEA and a signatory to an international nuclear waste treaty if it allowed this dump to be licensed.

6. The giant Chalk River mound would not reduce Canada’s $8 billion federal radioactive waste liabilities and could in fact increase themThe giant pile of leaking radioactive waste would be difficult to remediate. Remediation costs could exceed those of managing the wastes had they not been put in the mound.

Prime Minister Trudeau and Members of Cabinet, we urge you to take the decision-making authority out of the hands of CNSC for this project and stop the Chalk River nuclear waste dump. Protect the Ottawa River for current and future generations of Canadians. 

Yours sincerely,

Gordon Edwards, Canadian Coalition for Nuclear Responsibility, Montreal, QC

Éric Notebaert, Canadian Association of Physicians for the Environment, Montreal, QC

Réal Lalande, Action Climat Outaouais, Gatineau, QC

Paul Johannis, Greenspace Alliance of Canada’s Capital, Ottawa, ON

Lynn Jones, Concerned Citizens of Renfrew County and Area, Ottawa, ON

Johanna Echlin, Old Fort William (Quebec) Cottagers’ Association, Sheenboro, QC

Robb Barnes, Ecology Ottawa, Ottawa, ON

Beatrice Olivastri, Friends of the Earth Canada, Ottawa, ON

Ole Hendrickson, Ottawa River Institute, Ottawa, ON

Eva Schacherl, Coalition Against Nuclear Dumps on the Ottawa River, Ottawa, ON

CC

Hon. Erin O’Toole, Leader of the Official Opposition

Yves-François Blanchet, Leader of the Bloc Québécois

Jagmeet Singh, Leader of the New Democratic Party of Canada

Annamie Paul, Leader of the Green Party of Canada

Ottawa River looking north; photo taken opposite Chalk River Nuclear Laboratories

Presentation – Update on Chalk River radioactive waste disposal -BCI Jan. 2021

This presentation was given at the AGM of Biodiversity Conservancy International, January 14, 2021



This slide from the presentation shows Chalk River Labs in 1948.  The original 10 megawatt version of the NRX reactor had been completed a year earlier, in July 1947.   Plutonium was extracted from uranium irradiated in the NRX and shipped to the U.S. to make nuclear weapons.  Later, irradiated targets containing plutonium were shipped to the U.S, for processing there.  This continued until the mid-1960s.  


Natural Resources Canada estimates that over half the nuclear wastes at Chalk River – including contaminated buildings, buried wastes, and contaminated lands – came from Cold War weapons-related activities.

Hill Times Letter to the Editor ~ We need parliamentarians to stop project, prevent Ottawa River from being permanently contaminated by gigantic radioactive landfill

January 18, 2021

Re “CNL working to accomplish responsible action in managing Canada’s nuclear research and development legacy” (The Hill Times, Letters to the Editor, December 14, 2020).

https://www.hilltimes.com/2021/01/18/278089/278089

This letter from Joe McBrearty, President and CEO of Canadian Nuclear Laboratories (CNL) deepens my concern about the handling of Canada’s $8 billion nuclear waste liability. 

Mr. McBrearty claims that the Chalk River Mound beside the Ottawa River, 150 km north of Ottawa-Gatineau, “will contain only low-level radioactive waste which contains radionuclides that require isolation and containment for only a few hundred years.”

Unfortunately this claim does not stand up to scrutiny.

Last month CNL published its final environmental impact statement listing a partial inventory of radionuclides that would go into the gigantic five-to-seven story radioactive mound (aka the “NSDF”).

Twenty-five out of the 30 radionuclides listed in the inventory are long-lived, with half-lives ranging from four centuries to more than four billion years. To take just one example, the man-made radionuclide, Neptunium-237, has a half-life of 2 million years such that, after 2 million years have elapsed, half of the material will still be radioactive. 

The inventory includes four isotopes of plutonium, one of the most deadly radioactive materials known, if inhaled or ingested.

It is incorrect to say that these materials “require isolation and containment for only a few hundred years.” Many of them will be dangerously radioactive for more than one hundred thousand years. The International Atomic Energy Agency states that materials like this must be stored tens of meters or more underground, not in an above-ground mound.

The CNL inventory also includes a very large quantity of cobalt-60, a material that gives off so much strong gamma radiation that lead shielding must be used by workers who handle it in order to avoid dangerous radiation exposures. The International Atomic Energy Agency considers high-activity cobalt-60 sources to be “intermediate-level waste” and specifies that they must be stored underground. Addition of high-activity cobalt-60 sources means that hundreds of tons of lead shielding would be disposed of in the mound along with other hazardous materials such as arsenic, asbestos, PCBs, dioxins and mercury.


CNL’s environmental impact statement describes several ways that radioactive materials would leak into surrounding wetlands that drain into the Ottawa River during filling of the mound and after completion. It also describes CNL’s intent to pipe water polluted with tritium and other radioactive and hazardous substances from the waste treatment facility directly into Perch Lake which drains into the Ottawa River.

I stand by my original conclusion: We need parliamentarians to step up now to stop this deeply flawed project and prevent the Ottawa River from being permanently contaminated by a gigantic, leaking radioactive landfill that would do little to reduce Canada’s $8 billion nuclear waste liability.

Letter to the editor published in the Hill Times Monday January 18, 2021

Health and environmental groups appeal to International Atomic Energy Agency to nix Canadian appointment


For immediate release 
(Montreal, March 23, 2020) Three independent civil society organizations — the Canadian Association of Physicians for the Environment, the Canadian Coalition for Nuclear Responsibility and the Ottawa River Institute —  are asking the Director General of the UN’s International Atomic Energy Agency (IAEA) to reconsider the recent appointment of a Canadian as chair of its commission on safety standards.

In a recent letter to IAEA Director General Rafael M. Grossi, signed by Dr. Gordon Edwards, Dr. Éric Notebaert, MD, and Dr. Ole Hendrickson, the authors say they are concerned about the appointment of Rumina Velshi, president of the Canadian Nuclear Safety Commission (CNSC), to chair the IAEA’s commission on nuclear safety standards because the organization she heads has a documented record of disregarding IAEA safety standards and advocating for exemption of smaller nuclear reactors from environmental assessment in Canada. 

“We fear that Ms. Velshi’s chairmanship could result in the lowering of international standards, with an emphasis on benefits to the nuclear industry and support of ‘innovation’ at the expense of public protection,” says the letter.

According to the letter, Ms. Velshi might not meet the IAEA’s standards for regulatory officials’ independence from the nuclear industry. Before her appointment as CNSC president, she worked for Ontario Power Generation for eight years in senior management positions and led the OPG commercial team involved in a multi-billion dollar proposal to procure new nuclear reactors. 

published statement from the Canadian Nuclear Safety Commission dated February 26, 2020 says its president, Rumina Velshi, “intends to use her chairmanship to champion the importance of greater harmonization of standards and ensure they support nuclear innovation.”  In a recent address to the Canadian Nuclear Association Ms. Velshi reiterated these sentiments.

The letter’s authors cite the final report of a recent IAEA review of Canada’s nuclear safety framework as evidence of the CNSC’s failure to meet IAEA safety standards. The review identified numerous deficiencies and found that “CNSC regulations do not comprehensively cover all IAEA Fundamental Safety Requirements.” The review also found Canada to be out of alignment with IAEA standards for nuclear reactor decommissioning.

“The CNSC is proposing to permit entombment and abandonment of very long-lived radioactive entrails of shutdown ‘legacy’ nuclear reactors as an acceptable strategy for decommissioning in Canada. This approach is expressly rejected by IAEA safety standards, except in emergency circumstances such as severe reactor accidents (i.e. meltdowns),” says Dr. Edwards, President of the Canadian Coalition for Nuclear Responsibility.  “We are alarmed by this attempt of the CNSC to permit practices in Canada that the IAEA warns against and we don’t want to see this approach exported to the rest of the world.”

The letter to the IAEA Director General cites the CNSC’s handling of three controversial proposals for nuclear waste disposal as further evidence of the regulatory agency’s disregard of IAEA safety standards. The proposed facilities include: a giant, above-ground mound, close to the Ottawa River, for one million tons of mixed radioactive and other toxic wastes including long-lived radionuclides such as plutonium-239, americium-243, zirconium-93, nickel-59, carbon-14 and many more; as well as the planned entombment in concrete of two shutdown federal reactors beside the Winnipeg and Ottawa rivers, which provide drinking water for millions of Canadians.

The groups call on the IAEA director to maintain the integrity of IAEA safety standards and to continue to emphasize the vital importance of ensuring independence and objectivity, stating:  “We value IAEA safety standards; at the moment they are all that is of an official nature standing between Canadians and three nuclear waste disposal projects that would adversely affect the environment and public health in Canada for generations.”

The letter notes that the CNSC is widely perceived to be a “captured regulator”, that prioritizes needs of the nuclear industry over protection of the public from radioactive pollutants released from nuclear facilities.
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Links:

  1. Letter to IAEA Director General March 12, 2020. https://concernedcitizens.net/2020/03/20/letter-to-iaea-director-general-march-12-2020/ 
  2. Federal nuclear regulator urges Liberals to exempt smaller reactors from full panel review. Globe and Mail, November 6, 2018.  https://www.theglobeandmail.com/business/article-federal-nuclear-regulator-urges-liberals-to-exempt-smaller-reactors/ 
  3. CNSC president wants to harmonize international nuclear safety standards, Email message from CNSC February 26, 2020. https://concernedcitizens.net/2020/03/20/cnsc-president-wants-to-harmonize-international-nuclear-safety-standards/
  4. Remarks by President Rumina Velshi at the Canadian Nuclear Association 2020 Conference. CNSC February 27, 2020. https://www.nuclearsafety.gc.ca/eng/resources/presentations/president-velshi-remarks-canadian-nuclear-association-2020-conference.cfm
  5. REPORT OF THE INTEGRATED REGULATORY REVIEW SERVICE MISSION TO CANADA, International Atomic Energy Agency. https://www.iaea.org/sites/default/files/documents/review-missions/irrs_canada_2019_final_report.pdf
  6. International peer review finds deficiencies in Canada’s nuclear safety framework. Blog post. March 7, 2020. https://concernedcitizens.net/2020/03/07/international-peer-review-finds-deficiencies-in-canadas-nuclear-safety-framework/