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.
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.
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.
As noted in the recent Hill Times op-ed by Eva Schacherl, Political Opposition Growing to New Reactors, both small modular nuclear reactors AND the high-level fuel waste they produce are EXEMPT from environmental assessment in Canada
From the op-ed:
“The Impact Assessment Act was intended to create “greater public trust in impact assessment and decision-making.” But there will be no federal assessment of nuclear reactors up to 200 thermal MW in size, nor of new reactors built at existing nuclear plants (up to 900 MWth). Yet new tidal power projects, as well as offshore wind farms with 10 or more turbines, need an assessment under the regulations, as do many new fossil fuel projects.”
“Also exempted from federal assessment is the “on-site storage of irradiated nuclear fuel or nuclear waste” associated with small modular reactors. This will make it easier for SMRs’ radioactive waste to be potentially left in the northern, remote, and First Nations communities, where they are proposed to be built.”
This SMR fuel waste exemption was a last-minute insertion in the Impact Assessment Act regulations. It is found in section 28 of the Physical Activities Regulations (the so-called ‘project list’ for the new Impact Assessment Act and reads as follows:
28 The construction and operation of either of the following:(a) a new facility for the storage of irradiated nuclear fuel or nuclear waste, outside the licensed boundaries of an existing nuclear facility, as defined in section 2 of the Nuclear Safety and Control Act, other than a facility for the on-site storage of irradiated nuclear fuel or nuclear waste associated with one or more new fission or fusion reactors that have a combined thermal capacity of less than 200 MWth;
As far the fuel waste from the proposed SMR (the “MMR Project“) at Chalk River is concerned, there is another exemption in section 28 – the phrase “outside the licensed boundaries of an existing nuclear facility” allows it to be kept on site at Chalk River, a licensed nuclear facility.
OTTAWA—A contract quietly signed during the 2015 federal election campaign between Atomic Energy of Canada Limited (AECL) and a multinational consortium is costing Canadians billions of dollars and increasing risks to health from deadly radioactive pollutants.
The multi-billion dollar contract was an attempt by the former federal Conservative government to reduce Canada’s $7.9-billion nuclear waste liability quickly and cheaply by creating a public-private partnership or GoCo (government-owned, contractor-operated) contract.
The GoCo contractor is called the “Canadian National Energy Alliance” (CNEA) even though the majority of its members are foreign corporations. It currently consists of Fluor and Jacobs, two Texas-based multinationals involved in nuclear weapons production, and SNC-Lavalin. Under the contract, the consortium assumed control over all Canada’s federal nuclear facilities and radioactive wastes.
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 rather appear to have increased by about $200-million.
The Crown corporation, Atomic Energy of Canada Limited, was supposed to oversee the contract on behalf of the Government of Canada but may not have been in a position to do so. Serious problems at AECL were identified by the Auditor General in a 2017 report. Problems included lack of a board chair, lack of a CEO, no board directors at all for 2016 and most of 2017, failure to hold public meetings and lack of experience with the GoCo model.
Since 2015, it appears that the GoCo contractor has spent hundreds of millions of our tax dollars promoting three radioactive waste facilities that we believe to be quick, cheap, and substandard. They are: a giant, above-ground mound beside the Ottawa River at Chalk River, Ontario, for one million tonnes of mixed radioactive and non-radioactive wastes including plutonium, and entombment in concrete of two old nuclear reactors beside the Ottawa and Winnipeg rivers which provide drinking water to millions of Canadians.
More than two dozen submissions to the Impact Assessment Agency from ex-AECL nuclear waste experts including senior scientists and senior managers highlight serious concerns about the three projects and point out that they fail to meet international safety standards.
The consortium’s own studies show that all three facilities would leak radioactive contaminants into the environment and drinking water sources for millennia.
According to the consortium’s draft environmental impact statement, it appears that the giant Chalk River mound is expected to eventually disintegrate, in a process referred to as “normal evolution”. At that time, its radioactive and hazardous contents would flow out of the mound into surrounding wetlands that drain into the Ottawa River less than a kilometre away.
Hundreds of concerns about the three projects have been voiced by federal and provincial government departments, First Nations, civil society groups, 140 Quebec municipalities, nuclear waste experts, and concerned citizens. And yet the projects continue to lumber forward and the consortium continues to receive almost a billion dollars a year from Canadian taxpayers.
Does anyone in government have their eyes on this ball? Did they notice when AECL renewed the GoCo contract early in the pandemic lockdown, 18 months before expiry, despite the recent conviction of consortium partner SNC-Lavalin on a charge of fraud? Are they concerned by the rapidly rising costs and substandard proposals?
Are they aware that the consortium is bringing thousands of truckloads of radioactive waste to Chalk River from other federal facilities in Manitoba, Ontario, and Quebec? The Chalk River Laboratories site is not a good place to consolidate federal nuclear waste either for temporary or for long-term storage. It is seismically active and adjacent to the Ottawa River, source of drinking water for Ottawa-Gatineau, Montreal, and many other communities.
With all of the problems currently facing the world, one might ask, “Why should Canadians care about this nuclear waste problem?”
Radioactive waste is the deadliest waste on the planet. Nuclear reactors create hundreds of dangerous radioactive substances that remain toxic to all life for hundreds of thousands of years. Exposure can cause serious chronic diseases, birth defects, and genetic damage that is passed on to future generations. According to the U.S. National Research Council, there is no safe level of exposure to ionizing radiationreleased from nuclear reactors and nuclear waste facilities. And yet Canada is pouring billions of dollars into projects that will not keep these poisons out of our environment and drinking water.
Surely we can and must do better. The Ottawa River is a Canadian Heritage River that flows past Parliament Hill—surely we don’t want to be the generation responsible for permanently contaminating it with radioactive waste.
If we are going to spend a billion dollars a year managing our nuclear waste, let’s do it right. Let’s meet or exceed international standards and build secure storage facilities, well away from drinking water sources. Let’s make sure the wastes are carefully packaged and labelled and stored in monitored and retrievable conditions. This approach will create thousands of good, long-lasting careers in the nuclear waste and decommissioning field and show the world what top tier radioactive waste storage facilities look like.
A consortium of private multinational corporations is proposing to create a giant mound of radioactive wastes at Chalk River, Ontario, less than a kilometer from the Ottawa River. According to the draft Environmental Impact Statement (EIS) the proposed mega-dump will house a rather large quantity of plutonium.
plutonium and why should we worry about it?
Plutonium is a human-made radioactive element that is created as
a byproduct in nuclear reactors. The first reactors were built to produce plutonium
for use as a nuclear explosive in atomic weapons. Plutonium can also be
fabricated into fuel elements for nuclear reactors.
Plutonium remains radioactive for tens of thousands of years
after it is created. It comes in several different varieties or
“isotopes”. The most abundant varieties are plutonium-239, with a
half-life of 24,000 years; and plutonium-240, with a half-life of 6,600
years. The half-life is the time required for half of the atoms to
undergo radioactive disintegration. When a plutonium atom disintegrates it is
transformed into another radioactive material, sometimes one with a much longer
All isotopes of plutonium are highly toxic. Even very
small doses can lead to radiation-induced illnesses such as cancer, often resulting
Why is there plutonium at Chalk River?
The decision to build the Chalk River Laboratories (CRL) was
taken in Washington, D.C. in 1944. Canada, Great Britain and the United
States agreed to build the facility as part of an effort to produce plutonium
for bombs. In fact, plutonium produced at CRL played a role in both the
US and UK nuclear weapons programs.
During the late 1940s, British scientists carried out all
necessary pilot plant work at Chalk River to design their own large plutonium
production plant at Windscale, England. Plutonium produced at CRL arrived
in England just months before the first British nuclear explosion took place in
Australia in 1952.
For three decades, plutonium produced in Canadian research reactors was sold to the U.S. military to help finance the Chalk River Laboratories. A reprocessing plant at Chalk River was built to extract plutonium from irradiated nuclear fuel dissolved in nitric acid. It was shut down in 1954, but irradiated fuel containing Canadian plutonium was shipped to the U.S. until the mid-1970s. In all, at least 250 kg of plutonium was sold to the U.S. for nuclear weapons and warheads.
buildings central to plutonium production are slated for demolition
Various facilities at CRL were used in the 1940s and 1950s to
extract plutonium from fuels irradiated in the NRX reactor. In 2004,
environmental assessments were initiated governing the radioactive demolition
of three such structures:
Plutonium Tower, used
in the late 1940s to extract plutonium from fuel rods irradiated in the NRX reactor.
• The Plutonium Recovery
between 1949 and 1957 to extract plutonium isotopes from enriched fuels
irradiated in the NRX reactor.
• The Waste Water Evaporator, used between 1952 and 1958 to process
radioactive liquid wastes left behind from the plutonium extraction work.
Decommissioning of this facility would include: removal, treatment and storage
of plutonium-bearing liquid wastes and sludge in tanks, plutonium-contaminated
process lines and equipment; decontamination and removal of process equipment
and processing cells for handling plutonium; removal of building
structures containing plutonium residues; segregation of solid wastes and
transfer of these plutonium-contaminated materials to waste management
facilities at CRL.
In December 2011 the Canadian Nuclear Safety Commission gave the go-ahead for dismantling the first of these structures, the Plutonium Tower. In 2012, changes to the Canadian Environmental Assessment Act introduced by Stephen Harper’s government made it permissible to demolish radioactively contaminated buildings without any environmental assessment (EA).
To date, only the auxiliary buildings associated with the Plutonium Tower have been decommissioned, but the Tower itself is still standing. And as far as the Plutonium Recovery Lab and Waste Water Evaporator go, neither has been decommissioned. All these decommissioning projects will be difficult, and will generate lots of long-lived, intermediate-level waste.
buildings are just three examples of demolition projects that would produce
plutonium-contaminated rubble likely destined for the proposed megadump. Chalk
River scientists were keenly interested in testing plutonium as a reactor
fuel. Some three tonnes of
plutonium-based fuel elements were fabricated at Chalk River using remote
handling devices called gloveboxes. Such facilities would also result in
plutonium-contaminated wastes when demolished.
The draft EIS estimates that total quantities of plutonium to be placed in the planned landfill-type facility would be measured in the trillions of Becquerels. A Becquerel is a unit of radioactivity, indicating that one radioactive disintegration is taking place every second. (Every radioactive atom eventually disintegrates, or explodes, giving off one or two subatomic projectiles called “atomic radiation”. All forms of atomic radiation — alpha particles, beta particles, gamma rays, and neutrons–are damaging to living cells.)
Plutonium will inevitably
leak into the Ottawa River (EIS)
The draft EIS indicates that after failure of the landfill cover, which is bound to occur at some point after abandonment, millions of Becquerels of each plutonium isotope would enter Perch Creek every year. Perch Creek flows into the Ottawa River about 1 km away.
September 15, 2020 The Hon. Jean-Yves Duclos, President
The Hon. Joyce Murray, Vice-Chair
The Hon. Bardish Chagger, Member
The Hon. Catherine McKenna, Member
The Hon. Chrystia Freeland, Member
The Hon. Jonathan Wilkinson, Member
Treasury Board of Canada
Dear Mr. Duclos and Members of the Treasury Board:
We would like to bring to your attention problems with the handling of Canada’s $8 billion federal nuclear waste and decommissioning liability by Atomic Energy of Canada Limited (AECL).
As detailed in the attached discussion paper, “The Government of Canada’s Radioactive Wastes: Costs and Liabilities Growing under Public-Private Partnership”, taxpayer funding to AECL roughly quadrupled to $1.3 billion between 2015/16 and 2020/21. During this period, AECL’s reported liabilities increased by $332 million.
The previous Conservative Government attempted to cut costs and accelerate reduction of federal nuclear waste liabilities by implementing a public-private partnership or GoCo (“Government owned, Contractor operated”) contract between AECL and a multinational consortium.
The GoCo contractor is advancing substandard radioactive waste projects that do not comply with international standards and obligations. Environmental assessments are mired in controversy and several years behind schedule.
In the process of implementing the GoCo contract, Government oversight was greatly reduced and control over Canada’s federally-owned nuclear facilities and radioactive wastes was largely transferred to American-owned interests. It appears that AECL’s president Richard Sexton, is an American national and former senior executive in two of the original corporations awarded the GoCo contract in 2015 as members of the Canadian National Energy Alliance (CNEA) consortium. Mr. Sexton is also the Fee Distribution Officer who determines the “award fees” received by the consortium. AECL’s Lead Contracts Officer is an American national. The board of CNEA is comprised of a majority of American nationals. The GoCo contract was recently renewed unexpectedly, 18 months prior to its official expiry date, with no information provided as to the reason for the early renewal.
Issues of ethics and accountability have arisen in connection with the GoCo contract. The Caretaker Convention appears to have been disregarded in September 2015 when the multi-billion dollar GoCo contract was signed during a federal election campaign. The Integrity Regime appears to have been disregarded when the GoCo contract was quietly renewed by AECL in April 2020, during the early days of the pandemic lockdown, despite the conviction in Canada in late 2019 of the Canadian consortium partner SNC-Lavalin on a charge of fraud.
We believe that intervention is required by Cabinet and/or Parliament to restore control of and oversight over Canadian nuclear facilities and radioactive wastes, and to ensure that public funds are spent wisely.
Yours truly, Gordon Edwards, Ph.D, Canadian Coalition for Nuclear Responsibility
Éric Notebaert, MD, M.Sc., Canadian Association of Physicians for the Environment
Ole Hendrickson, Ph.D, Concerned Citizens of Renfrew County and Area
CC: Karen Hogan, Auditor General of Canada
Greg Fergus, Parliamentary Secretary to the President of the Treasury Board
Nous désirons porter à votre attention des problèmes liés à la manière dont Énergie atomique du Canada Ltée (EACL) gère les $8 milliards de déchets nucléaires et de déclassements qui relèvent du gouvernement fédéral.
Comme on le constate dans le document ci-joint « Les déchets radioactifs du gouvernement du Canada : La croissance des coûts et obligations en partenariat public-privé », le financement public d’EACL a pratiquement quadruplé depuis 2015-16 pour atteindre $1,3 milliard en 2020-21. Pendant cette période, les obligations d’EACL se sont accrues de $332 millions.
Le précédent Gouvernement Conservateur avait tenté de réduire les coûts et d’accélérer la réduction des obligations nucléaires fédérales en créant un PPP, un partenariat public-privé (« propriété du Gouvernement, géré par un entrepreneur ») entre EACL et un consortium multinational.
Pour les déchets radioactifs, l’entrepreneur de ce PPP met de l’avant des projets inadéquats qui dérogent aux règles internationales et à nos obligations. Embourbées dans la controverse, les évaluations environnementales accumulent des années de retard.
Dans le cadre de ce PPP, le Gouvernement a considérablement réduit sa surveillance, tandis que la gestion des installations nucléaires et des déchets radioactifs de propriété fédérale se voyait en bonne partie transférée à des intérêts américains. Il semble que Richard Sexton, le président d’EACL, soit un citoyen américain et un ex-dirigeant senior de deux entreprises qui avaient originellement obtenu ce contrat de PPP en 2015, au sein de l’Alliance nationale de l’énergie canadienne (ANEC). M. Sexton est aussi responsable de la répartition des revenus au sein de ce consortium. Le principal responsable des contrats d’EACl est aussi un citoyen américain. Le contrat en PPP a récemment été renouvelé à l’improviste, 18 mois avant sa date d’expiration officielle, sans qu’on ne fournisse la moindre explication du renouvellement hâtif.
Plusieurs enjeux d’éthique et d’imputabilité ont surgi de ce contrat en PPP. On semble avoir ignoré la convention de transition quand on a conclu ce contrat en PPP de plusieurs milliards de dollars pendant la campagne électorale fédérale de 2015. On semble aussi avoir ignoré le régime d’intégrité quand EACL a discrètement renouvelé ce contrat en PPP en avril 2020, au début du confinement attribuable à la pandémie, même si le partenaire canadien du consortium, SNC-Lavalin, avait été condamné pour fraude à la fin de 2019.
Nous estimons que le Conseil des ministres et/ou le Parlement devraient rétablir leur contrôle et leur surveillance des installations nucléaires et des déchets radioactifs fédéraux, afin que les fonds publics soient dépensés avec prudence.
Sincèrement vôtres, Gordon Edwards, Ph.D,Regroupement pour la surveillance du nucléaire
Éric Notebaert, MD, M.Sc.Association canadienne des médecins pour l’environnement Ole Hendrickson, Ph.D, Concerned Citizens of Renfrew County and Area
Cc. Karen Hogan, Vérificatrice générale du Canada
Greg Fergus, Secrétaire parlementaire du président du Conseil du Trésor
Radioactive waste is dangerous, poses risks to all living things and must be kept out of the biosphere for as long as it poses a radioactive hazard (many tens of thousands of years). Article 11 of the Joint Convention states that parties shall “ensure that the generation of radioactive waste is kept to the minimum practicable”.
Small modular nuclear reactors, currently under consideration for taxpayer-funded development in Canada, would produce long-lived hazardous nuclear waste as part of normal operations. These reactors are proposed for Northern, remote and First Nations communities in some of Canada’s most fragile and globally important ecosystems. UNDRIP principles of free prior, and informed consent with indigenous communities have not been respected.
Production of plutonium and other fuels for small modular nuclear reactors would create long-lived hazardous nuclear waste. Small modular nuclear reactors would themselves become hazardous, long-lived nuclear waste; too hot to handle after their short lifespan of a few decades, and too costly to transport, they would likely be abandoned in place leaving permanently contaminated, radioactive exclusion zones, a few hectares in size, everywhere they were deployed.
Low-carbon alternatives to nuclear technology for electricity generation are readily available, faster to deploy, much less expensive and do not generate radioactive waste. They also create more jobs. Small nuclear reactors are therefore not a useful or necessary climate change mitigation strategy.Canada can much more easily, cheaply and quickly get to net zero carbon with a combination of energy conservation and renewables. For details please see Environmental Petition 419 to the Auditor General of Canada.
Small nuclear reactor proponents tout the notion that small reactors will use existing nuclear waste for fuel. This is a dangerous fantasy. In reality, “recycling” radioactive waste creates more radioactive waste, passing the buck to future generations. Worse, reactor technologies that use recycled fuel require extraction of plutonium, creating serious national security risks associated with nuclear weapons proliferation.
We submit that federal support and funding for development of small modular nuclear reactors would constitute an abnegation of Canada’s international commitment to minimize generation of radioactive waste.
We urge you to bring this matter to the attention of your Cabinet colleagues, and cease all government support and taxpayer funding for small modular nuclear reactors.
Anne Lindsey, MA, O.M., Winnipeg, Manitoba
Brennain Lloyd, North Bay, Ontario
Candyce Paul, English River First Nation, Saskatchewan
Dr. Cathy Vakil, MD, Kingston, Ontario
Dr. Dale Dewar, MD, Wynyard, Saskatchewan
Dr. Dorothy Goldin-Rosenberg, PhD, Toronto, Ontario
Eva Schacherl, MA, Ottawa, Ontario
Ginette Charbonneau, Physicist, Oka, Quebec
Gretchen Fitzgerald, BSc, Halifax, Nova Scotia
Johanna Echlin, M.Ed., Montreal, Quebec
Dr. Judith Miller, PhD, Ottawa, Ontario
Dr. Kathryn Lindsay, PhD, Renfrew, Ontario
Kerrie Blaise, MSc, JD, North Bay, Ontario
Lynn Jones, MHSc, Ottawa, Ontario
Dr. Martha Ruben, MD, PhD., Ottawa, Ontario
Pippa Feinstein, JD, LLM, Toronto, Ontario
Dr. Susan O’Donnell, PhD, Fredericton, New Brunswick
Office of/Bureau du Richard Cannings MP South Okanagan – West Kootenay
June 17, 2020
Don’t approve Nuclear Waste regulations which put Canadians at risk, says NDP Natural Resources Critic Richard Cannings
The Canadian Nuclear Safety Commission (CNSC) should not approve a suite of regulatory documents on radioactive waste at its meeting June 18, 2020 and instead live up to the Liberal government’s commitment to openness and transparency for regulatory development. Some of these regulations developed by commission staff are at best vague guidelines that leave nuclear waste policy decisions in the hands of private industry, instead of actually prescribing actions that are in the public interest.
These regulatory changes would pave the way for several controversial nuclear waste disposal projects, including a giant mound at Chalk River, Ontario, two entombments of shut- down reactors, and a proposed deep geological repository for the burial of high-level nuclear fuel waste.
This proposal does not meet Canada’s commitment to meeting or surpassing international standards for the handling of nuclear waste. For example, the entombment of nuclear reactors is designated as “in-situ decommissioning”, a practice that the International Atomic Energy Agency says should only be used as a last option for facilities damaged in accidents.
Of further concern is the lack of clarity in the proposed regulations. In many cases the licensee is directed to develop safety requirements with no explicit directions as to what those safety requirements are. The giant mound at Chalk River is meant to contain up to 1 million cubic metres of low- to intermediate-activity nuclear waste but these activity levels are not defined and the private owner of the facility would get to decide what materials are stored in that mound of nuclear waste.
The Minister of Natural Resources has committed to consulting Canadians on a policy framework and strategy for radioactive waste. Instead we have this backdoor process with limited public input and no parliamentary oversight. The minister should be conducting a public process to develop a Canadian framework for radioactive waste management that meets or exceeds international best practices, a framework that does not allow the nuclear industry to police itself.
The Canadian Nuclear Safety Commission is on the cusp of approving new rules for the disposal of nuclear waste in Canada.
Minister of Natural Resources Seamus O’Regan, pictured delivering the opening keynote at the Canadian Nuclear Association’s annual conference in Ottawa on Feb. 27, 2020. The Canadian Nuclear Safety Commission reports to Parliament through Mr. O’Regan. The Hill Times photograph by Andrew Meade
On June 18th, Canada’s industry-friendly regulator, the Canadian Nuclear Safety Commission (CNSC), will formalize new guidance and requirements for disposal of radioactive waste. The CNSC’s new rules are tailored to allow the nuclear industry to “solve” its waste problem as easily and cheaply as possible.
While the CNSC claims to have consulted the public in preparing five new regulatory documents (“REGDOCs”) for radioactive waste storage and disposal, the documents largely reflect the agency’s separate interactions with industry giants such as Cameco, Ontario Power Generation, Bruce Power, and Canadian Nuclear Laboratories (a privately-owned corporation controlled by U.S. interests).
With Canadian nuclear reactors approaching the end of their useful life, or already shut down, the CNSC’s proposal to allow permanent, on-site disposal (and eventual abandonment) of radioactive waste at existing nuclear facilities is attracting criticism.
This strategy, known as “in-situ decommissioning”, is expressly supported in a new CNSC decommissioning REGDOC, even though its use is specifically proscribed by the International Atomic Energy Agency (IAEA).
Plans to use existing nuclear facilities for permanent waste disposal were initially set out in a 2014 Canadian Standards Association document prepared by industry and government nuclear officials. This document identifies “in situ confinement—to place the facility in a safe and secure condition with the intention to abandon in-place” as a decommissioning strategy option.
In 2015, the consortium of multinational companies that owns Canadian Nuclear Laboratories and operates the federal government’s nuclear sites (including six shut-down reactors) proposed to use this option for federal reactors in Ontario and Manitoba—to entomb them in concrete and grout. These proposals triggered federal environmental assessments that are being led by the CNSC.
In February 2020 the IAEA released a review of Canada’s nuclear safety framework, and observed that “The CNSC is currently considering two licence applications related to in situ confinement of legacy reactor facilities. This strategy of in-situ confinement is not consistent with SSG-47.”
SSG-47 is the 2018 IAEA Specific Safety Guide, Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities. The IAEA suggested that CNSC “consider revising its current and planned requirements in the area of decommissioning to align with the IAEA guidance.”
But tather than following IAEA guidance that “entombment is not considered an acceptable strategy for planned decommissioning,” the CNSC decommissioning REGDOC to be approved on June 18th says “In situ decommissioning may be considered a solution… for legacy sites.”
The REGDOC then goes further, opening the door for abandonment of future nuclear facilities such as small modular reactors if their removal is not “practicable”.
Approval of this REGDOC and four others dealing with radioactive waste is being rushed by the CNSC behind closed doors during the coronavirus pandemic. The CNSC dismissed a written request from civil society groups to speak at, or even make written submissions for, its so-called “public meeting” on June 18th.
Civil society groups have long noted that Canada lacks policies and strategies for managing radioactive waste. Federal policy is limited to a 143-word Radioactive Waste Policy Framework that does not mention the fundamental principle of dealing with radioactive waste in a manner that protects human health—now and in the future—without imposing undue burdens on future generations.
In February, the IAEA recommended that “The Government of Canada should enhance the existing policy and establish the associated strategy to give effect to the principles stated in its Radioactive Waste Policy Framework.” The government responded that “Natural Resources Canada will review its existing policy for radioactive waste, and consider how it may be enhanced.”
NRCan officials say this review will include consultation with Indigenous groups and the public, but its start has been delayed by the pandemic.
It appears that the CNSC has decided to move quickly to pre-empt this government review, so as to allow maximum flexibility for the nuclear industry to use quick and cheap options to deal with its vexing challenge of radioactive waste disposal. When it comes to protecting people from exposure to harmful radiation, the fox is guarding the chicken house.
Ole Hendrickson is a retired environmental scientist, and a member of the Concerned Citizens of Renfrew County and Area.
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.
A 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. -30-
To the Prime Minister, Parliament and the Federal Government The undersigned organizations have grave concerns about the handling of Canada’s federally-owned radioactive waste by a private-sector consortium that includes SNC-Lavalin and two Texas-based multinational corporations. *
● Canada has no adequate federal policies and strategies for the long-term management of radioactive wastes and the consortium has been given a free hand to advocate and implement proposals that, in our view, are unequal to the task of protecting people’s health and the environment. ● Under its federal contract with Atomic Energy of Canada Limited the consortium is receiving billions of our tax dollars to advance radioactive waste disposal and reactor “decommissioning” projects that fail to even meet existing international safety guidelines. ● The consortium’s current plans include entombingthe radioactive remains ofnuclear reactors in cement next to the Ottawa and Winnipeg Rivers, against the explicit advice of international bodies and independent nuclear scientists; these “entombed reactors” would leak radioactivity into the rivers for thousands of years and contaminate drinking water for millions of Canadians. ● The consortium also plans to erect a massive above-ground mound adjacent to a swampy area that drains into the nearby Ottawa River; the mound would hold more than one million tons of mixed radioactive waste including a multitude of long-lived, human-made radioactive materials such as plutonium-239 and hazardous non-radioactive materials such as PCBs, lead, arsenic and asbestos. ● The consortium is already transporting large quantities of radioactive waste along public roadsfrom Pinawa, Manitoba, from Douglas Point, Ontario, and from Gentilly, Quebec, all the way to Chalk River, site of the proposed mound, located upstream from our nation’s Capital.
We request that the Federal Government terminate its contract with the consortium at the end of the first six-year term in 2021 or as soon as possible.
We also request formulation of exemplary policies and projects for Canada’s radioactive waste that meet or exceed international obligations. Such policies and projects would: ● be developed with meaningful consultation with First Nations and the broader Canadian public ● create many long-term, well-paying Canadian jobs while protecting health and property ● safely store radioactive waste in state-of-the-art facilities away from sources of drinking water ● re-establish Canadian leadership in the nuclear field with world-class science-based solutions to address the growing global radioactive waste problems
* Membership in the consortium, known as Canadian National Energy Alliance, has changed more than once since the consortium assumed control of Canada’s federally-owned nuclear waste in 2015, when it received all shares of Canadian Nuclear Laboratories, a wholly owned subsidiary of Atomic Energy of Canada Limited. Current consortium members include SNC-Lavalin, which is debarred by the World Bank for 10 years and faced charges in Canada for fraud, bribery and corruption; Texas-based Fluor Corporation, which paid $4 million to resolve allegations of financial fraud related to nuclear waste cleanup work at a U.S. site; and Texas-based Jacobs Engineering, which recently acquired CH2M, an original consortium member that agreed to pay $18.5 million to settle federal criminal charges at a nuclear cleanup site in the U.S.
Alliance of the Anishinabek Nation and the Iroquois Caucus
Canadian Coalition for Nuclear Responsibility
Canadian Association of Physicians for the Environment
Sierra Club Canada Foundation
Friends of the Earth Canada
Ontario Clean Air Alliance
Ottawa River Institute
FTQ – Fédération des travailleurs et travailleuses du Québec
Greenspace Alliance of Canada’s Capital
National Council of Women of Canada
Provincial Council of Women of Quebec
Provincial Council of Women of Ontario
Concerned Citizens of Renfrew County and Area
Les Artistes pour la Paix
Concerned Citizens Committee of Manitoba
Prevent Cancer Now
Action Climat Outaouais
Ralliement contre la pollution radioactive
Bonnechere River Watershed Project
Old Fort William (Quebec) Cottagers’ Association
Pontiac Environmental Protection
Petawawa Point Cottagers Association
Coalition Against Nuclear Dumps on the Ottawa River