Canada’s first formal license application for an SMR is the “Micro Modular Reactor” in Chalk River.
CCRCA, and many others provided written interventions to the CNSC on “the scope of an environmental assessment for the proposed Micro Modular Reactor Project at the Chalk River Laboratories” prior to the one-person “Panel of Commission: R. Velshi, President” that rendered its decision on July 26th.
The CCRCA submission noted, in particular, that under the Impact Assessment Act, the proponent would be required to include as a “factor” in the EA ““the extent to which the effects of the designated project hinder or contribute to the Government of Canada’s ability to meet its environmental obligations and its commitments in respect of climate change.”
We added, “the CNSC has proposed that proponents assess the total GHG production as part of CNSC-led environmental assessments” in its fact sheet entitled “Greenhouse gas emission assessments for the Canadian nuclear fuel cycle,”
Somehow, the Record of Decision on the project scope omits any mention of climate change.
The CNSC’s decision on the scope of the MMR project indicates that climate change is not a relevant factor in the consideration of environmental impact of SMRs.
Here’s our take-away:
- Reducing GHG emissions is a government priority. This is reflected in the Impact Assessment Act. The Minister of Natural Resources says nuclear power is essential to reduce GHGs (no path to net zero without nuclear)
- The CNSC did not include GHG emissions as a factor in assessing its first SMR license application – even when requested to do so – and even when its own “interim strategy for environmental assessments” calls for this.
- The CNSC should not lead environmental assessments of nuclear reactors, including SMRs.
- The Physical Activities Regulations under the Impact Assessment Act should be changed to remove exemptions for new nuclear reactors.
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:
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:
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.
The 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).
November 5, 2020
CNL’s Integrated Waste Strategy (version 0) (obtained through ATIP in December 2017, contains many redactions)
CNL’s Integrated Waste Strategy (Version 1) (“sanitized”, publicly available on CNL’s website)
The CNL Integrated Waste Strategy describes many types of radioactive wastes owned by the federal government in nuclear facilities in Manitoba, Ontario and Quebec. The document lays out a plan to consolidate as much of these wastes as possible at the Chalk River Laboratories site beside the Ottawa River upstream of Ottawa, Gatineau and Montreal for permanent disposal in a highly-controversial, yet-to-be-licensed giant radioactive waste mound.
Ottawa Valley residents are alarmed by this strategy to bring all of Canada’s federal nuclear waste to Chalk River. The site already has much radioactive waste in less than optimum storage conditions; wastes are leaking and contaminating the Ottawa River. See Chalk River’s Toxic Legacy by Ian McLeod in the Ottawa Citizen, December 16, 2011.
Radioactive waste shipments are already underway from other federal nuclear facilities in Canada. There are risks involved in transportation as described in our recent fact sheet “Transport of Radioactive Waste on Canadian Roads- a growing public risk”. Premature transportation of wastes before long-term management facilities are planned, evaluated, and licensed will result in double-transport and double-handling, creating additional unnecessary risks to workers and the public.
There are no approved disposal facilities at the CRL site; shipping containers full of wastes are presently being piled up at a Waste Management Area H as shown in the photograph below. The metal shipping containers are susceptible to corrosion and are exposed to precipitation in the current location.
The Chalk River Laboratories is not a good site for long-term storage of radioactive waste mainly because it is seismically active and adjacent to the Ottawa River which serves as a source of drinking water for millions of Canadians including citizens of Ottawa-Gatineau and many other communities.