NUCLEAR WASTE WATCH
A Network of Organizations Concerned about High Level Radioactive Waste and Nuclear Power in Canada
POSITION STATEMENT AND BACKGROUND
- The first priority of responsible waste management is reduction at source. High level radioactive waste in Canada can only be reduced at source through a binding commitment to the early phaseout of nuclear power. Early nuclear phaseout means that there would be no new reactors and no major refurbishment of reactors to prolong their current lifespans.
- Neither the safety nor the acceptability of deep geological disposal of radioactive waste in perpetuity was established to the satisfaction of the federal environmental assessment panel (the Seaborn Panel) that reviewed the evidence. Any waste management option should, for the foreseeable future, be based on surface and/or near-surface monitored and retrievable storage -- at least until a nuclear power phaseout has been achieved, the technical case for an alternative option (or options) has been thoroughly reviewed, and a social consensus has been achieved.
- The Seaborn Panel called for the creation of a nuclear fuel waste management agency at arms length from the nuclear industry, with its board of directors representative of independent key stakeholders. In direct opposition to this, the government created the Nuclear Waste Management Organization (NWMO) with its board comprised solely of nuclear industry representatives. The nuclear industry strongly supports deep geological disposal of radioactive waste, so the ability of the NWMO to make an objective recommendation is questionable.
- Given the importance of this issue to present and future generations of Canadians, the government should guarantee a joint federal/provincial environmental assessment panel on the full range of radioactive waste management options following the NWMO recommendation in November 2005. The process should be adequately funded by the proponents in order to allow public interest intervenors to retain independent technical expertise. The federal government should also guarantee a full parliamentary debate and free vote on the recommendations of the NWMO and the environmental assessment panel.
- If the Government of Canada decides on any kind of centralized waste management option (whether above or below ground), there will be risk to communities along the transportation route, as well as to the potential recipient community. In such a case, the potential recipient and transport route communities should all have veto power, and should receive funding from proponents for independent research and community education.
- The Nuclear Fuel Waste Act should be amended to guarantee that Canada will not consider the importation of high level radioactive waste, at least until there is a global phaseout of both nuclear power and nuclear weapons. A similar restriction should apply to the importation of any fresh reactor fuel if the irradiated fuel is to remain in Canada.
Nuclear power in Canada had its origins in the allied nuclear weapons program, the Manhattan Project, that resulted it the nuclear bombing of Hiroshima and Nagasaki. Until 1965, Atomic Energy of Canada Limited (AECL) produced plutonium for American nuclear weapons. This activity left its own deadly legacy of radioactive waste at the Chalk River Nuclear Laboratories in the Ottawa Valley.
In the 1960s, AECL, Ontario Hydro and their private sector partners built several unsuccessful prototype power reactors including the NPD, Gentilly-1 and WR-1 reactors. These were followed by the Douglas Point reactor at Bruce. These were followed quickly in the 1970s by Ontario Hydros larger-scale Pickering A and Bruce A stations (4 reactors each). The 1980s saw the operation of Ontario Hydros Pickering B and Bruce B stations (4 reactors each) and single CANDU 6 reactors for both Hydro Québec (Gentilly 2) and New Brunswick Power (Point Lepreau). The last nuclear plant to be built in Canada was Ontario Hydros Darlington station (4 reactors) ordered in 1973, with its last reactor operational in 1993.
The environmental impacts of the nuclear fuel chain, of which nuclear power is a part, include: uranium mining and refining emissions, thermal effluent from cooling water outflow, airborne radioactive emissions, waterborne radioactive emissions, low and intermediate level radioactive waste, and high level radioactive waste. High level radioactive waste is the irradiated uranium fuel bundles, comprised of the uranium oxide CANDU fuel contained in the metal bundles, sometimes referred to by the nuclear industry as spent fuel.
Most of the high level radioactive waste (about 30,000 tonnes) is currently being temporarily stored in water-filled pools, or dry storage containers at each nuclear facility where they were produced. These highly toxic radioactive wastes are extremely long-lived...
In total, spent fuel contains roughly 350 nuclides, about 200 of which are radioactive. Its level of activity per unit mass declines to that of natural uranium and its associated radioactive decay products after about one million years.
It is generally accepted that high level radioactive waste must be kept isolated from the environment for a very long periods of time... in the order of hundreds of thousands of years. However, current storage methods require strict institutional controls, which cannot be assumed to be reliable beyond several hundred years. For that reason, the Canadian nuclear industry (and other national nuclear programs) has proposed so-called permanent disposal options which theoretically would protect the natural environment even in the absence of institutional controls. The lack of an agreed radioactive waste management solution is widely perceived as the most serious reason for public opposition to nuclear power. The nuclear industry proposals for deep geological disposal have been challenged as being intentionally out-of-sight/out-of-mind, in order to solve the public relations problem rather than deal with the technical problems.
In 1977, the federal government appointed a committee of three men to make recommendations on the management of radioactive waste. After only four months of review and with no formal public consultation, the committee published its findings (known as the Hare Report after its Chairman, Kenneth Hare). They supported deep geological disposal,and recommended that an operating waste site should be in place between 1995 and 2000. The report was widely viewed as pro-nuclear propaganda designed to allay public fears about radioactive waste management at a time of aggressive nuclear power expansion in Canada.
Several other inquires were under way at this time, which dealt in part with radioactive waste management. The Ontario Royal Commission on Electric Power Planning (known as the Porter Commission after its Chairman) issued a report on nuclear power in September 1978. Amongst other things, the report recommended that if there was not satisfactory progress on radioactive waste management by 1985, a moratorium on additional nuclear power stations would be justified.At the same time, the National Committee on National Resources and Public Works (a federal parliamentary standing committee) was conducting a review of the Hare Report. Yet the federal and Ontario governments did not wait for their recommendations of these bodies.
The Canadian and Ontario governments, led by Atomic Energy of Canada Limited (AECL) initiated the Canadian Nuclear Fuel Waste Management Program in 1978, which focused on deep geological disposal in the granite landforms of the northern Canadian Shield. About $700 million was spent on research activities on nuclear fuel waste disposal, notably the Underground Research Laboratory that was established in the rural municipality of Lac du Bonnet, Manitoba for test purposes.
AECL and Ontario Hydro continued with this program over the next decade, but it was not until October 1989 that an environmental assessment panel was appointed to consider the question of safety and acceptability of nuclear fuel waste burial in a generic context. This is discussed in more detail below.
Background for NWW Position Point #1
1. The first priority of responsible waste management is reduction at source. High level radioactive waste in Canada can only be reduced at source through a binding commitment to the early phaseout of nuclear power. Early nuclear phaseout means that there would be no new reactors and no major refurbishment of reactors to prolong their current lifespans.
By the end of 2002, Canadian reactors had produced about 40,000 metric tonnes of high level radioactive waste -- about 1.7 million irradiated fuel bundles. Without an early nuclear phaseout, an additional 2 million fuel bundles (about 45,000 metric tonnes) will be produced. Thus total production could mount to 3.7 million fuel bundles weighing about 85,000 tonnes.The estimated total production of radioactive waste assumes that CANDU reactors in Ontario will have a 40-year lifetime. In reality they do not last that long without large-scale refurbishment. Independent analysts and the nuclear industry alike agree that a reasonable estimate for the CANDU lifetime without extensive refurbishment is 25 to 27 years.
The first priority of responsible waste management is reduction at source. The priority hierarchy of waste management is (1) reduction, (2) reuse, and (3) recycling. In the case of radioactive waste, reuse in CANDU reactors is not possible. Recycling, i.e. reprocessing, of radioactive waste is possible, but not desirable for several reasons. First, there is no compelling economic reason to reprocess irradiated fuel, since virgin uranium fuel used in a once-through fuel cycle remains a cheaper alternative. Second, there is no environmental advantage to reprocessing. Indeed, reprocessing results in a larger quantity of acidic liquid radioactive waste that is more difficult to manage than the original irradiated fuel. Finally, the reprocessing of the irradiated fuel to extract plutonium has proliferation and security concerns since plutonium can be used in nuclear weapons.
Thus, reduction at source is the only alternative for responsible waste management. High level radioactive waste in Canada can only be reduced at source through a binding commitment to the early phaseout of nuclear power. Early nuclear phaseout means that no major refurbishment will be conducted on reactors at the end of their current lifespans.
Nuclear phaseout would also enhance the possibility of social consensus on radioactive waste disposal. From a process point of view, production of an indeterminate, unlimited amount of radioactive waste makes it even more unlikely that any community would be willing to accept a waste facility.
Nuclear phaseout has another important advantage. It would give both private and public sector power companies the confidence to commit their resources to a planned, long-term implementation of green energy alternatives that are cheaper, cleaner and safer than nuclear power. Phaseout agreements have already been put in place in countries such as Sweden, Germany, and Belgium, which have had significant nuclear generating capacity.
Background for NWW Position Point #2
2. Neither the safety nor the acceptability of deep geological disposal of radioactive waste in perpetuity was established to the satisfaction of the federal environmental assessment panel (the Seaborn Panel) that reviewed the evidence. Any waste management option should, for the foreseeable future, be based on surface and/or near-surface monitored and retrievable storage -- at least until a nuclear power phaseout has been achieved, the technical case for an alternative option (or options) has been thoroughly reviewed, and a social consensus has been achieved.
No country in the world has yet devised an acceptable solution to the problem of long-term management of high level radioactive waste, although several (notably the United States at Yucca Mountain) are advancing towards the industry-favoured solution of deep geological disposal despite strong public opposition. While the nuclear industry would like to pretend that this is only a social problem, it is also a complex, intractable technical problem, given the incredibly long hazardous life-times of radioactive wastes.
In October 1989 the federal government appointed an environmental assessment panel (known as the Seaborn Panel after its Chairperson, Blair Seaborn) to consider the safety and acceptability of nuclear fuel waste burial in a generic context (i.e. without a specific site proposal). After eight years of deliberation, the panel released a report in March 1998. The panel itself noted that the panel now believes that the concept of deep geological disposal could be accepted only if it is placed in the context of other alternatives.
Not only did the panel review just one option (deep geological disposal), but the panel clearly stated that the safety of that option was not adequately demonstrated. The final report stated that the safety of AECLs concept of deep geological disposal must be analyzed from both technical and social perspectives. The panel concluded that
...from a technical perspective, safety has on balance been adequately demonstrated for a conceptual stage of development, but from a social perspective it has not. Safety is a key part of acceptability. Thus the concept cannot be regarded as acceptable if it fails to demonstrate safety from both perspectives.
A lack of consensus in the Seaborn Panel was revealed by the limited support it gave to the technical case for deep geological disposal. Thus the Panel stated that the technical had been demonstrated only on balance and only for a conceptual stage of development. The panel noted that serious technical problems remained. For example, the Scientific Review Group stated that AECLs methodology for performance of the generic waste site was unreliable and it cannot be used to determine whether [it] is safe or is not safe.AECLs analysis of risk, the selection of scenarios and the scenario analysis were all seen as inadequate, in part because of a failure to consider worst-case scenarios.AECLs modelling approach was described as having ...a number of weaknesses, and insufficient scenarios to estimate the range of potential hazards... models were described as insufficient to demonstrate that the deep geological disposal concept could be used for a specific site.It was also suggested that an early detection and monitoring system for the vault should be further explored. In another blow to its credibility, the feasibility of the concept was brought into question by the probable lack of human and financial resources for its implementation.
Because high level radioactive waste will have environmental and health repercussions for hundreds of thousands of years, there is an extraordinary inter-generational social dimension to the decisions that must be made in the near future. During the Seaborn environmental assessment process, there was widespread rejection of the deep geological disposal concept by intervenors, who argued that AECL had failed to demonstrate safety and acceptability. The federal nuclear regulatory agency, the Atomic Energy Control Board (now the Canadian Nuclear Safety Commission) stated that demonstrating a methodology to assess safety falls short of demonstrating the overall safety of the disposal concept.The panel noted that the AECL concept was not developed in a comprehensive social and ethical framework, and that the concerns of Native peoples were not adequately addressed. The Atomic Energy Control Board was also criticized for its lack of objectivity.
Given the technical and social uncertainties about various aspects of deep geological disposal, it is advisable for the foreseeable future to place high level radioactive waste in some form of monitored and retrievable storage, at least until a social consensus has been achieved on all technical issues. Social consensus will inevitably be contingent upon the achievement of a nuclear phaseout.
In the light of growing terrorist threats around the world, nuclear facilities have been recognized as high priority targets. Irradiated fuel bays and dry storage containers outside of concrete containment structures pose a significant risk. Waste facilities should be hardened using the best available technology in order to reduce the risk of a major catastrophe in the event of an attack by air, land or water.
Background to NWW Position Point #3
3. The Seaborn Panel called for the creation of nuclear fuel waste management agency at arms length from the nuclear industry, with its board of directors representative independent key stakeholders. In direct opposition to this, the government created the Nuclear Waste Management Organization (NWMO) with its board comprised solely of nuclear industry representatives. The nuclear industry strongly supports deep geological disposal of radioactive waste, so the ability of the NWMO to make an objective recommendation is questionable.
Foremost among the 15 recommendations of Seaborn Panel report in 1998 was that the government create an independent nuclear fuel waste management agency (NFWMA) at arms length from the nuclear utilities and from AECL, with a board of directors appointed from among key stakeholders. In its December 1998 response to the Seaborn Panel Report, the Canadian government supported creation of a NFWMA, but decided to place the nuclear industry in sole charge of the agency. The governments decision was broadly condemned by environmental and community groups across the country.
A leaked secret Cabinet document that was made public in March 1999 revealed that the government was manipulated by its own federal department dealing with nuclear issues (Natural Resources Canada -- NRCan). The cabinet was apparently panic-stricken by vague warnings from NRCan that the government could be liable for the expenses of radioactive waste disposal if it took broader responsibility in the nuclear waste agency. This became the rationale for granting the nuclear utilities sole control over the agency that would become the Nuclear Waste Management Organization (NWMO).
Shortly after the Nuclear Fuel Waste Act came into effect in November 2002, the NWMO was created. Under the terms of the Act, the NWMO is under the control of Ontario Power Generation, Hydro Québec, New Brunswick Power, and Atomic Energy of Canada Limited (AECL).
The governments decision to ignore the recommendation of the Seaborn panel on this process question opens the NWMO to a perception of bias, setting the stage for a divisive social confrontation over the management of high level radioactive waste.
Background to NWW Position Point #4
4. Given the importance of this issue to present and future generations of Canadians, the government should guarantee a joint federal/provincial environmental assessment panel on the full range of radioactive waste management options following the NWMO recommendation in November 2005. The process should be adequately funded by the proponents in order to allow public interest intervenors to retain independent technical expertise. The federal government should also guarantee a full parliamentary debate and free vote on the recommendations of the NWMO and the environmental assessment panel.
The Nuclear Fuel Waste Act (the Act) came into force on November 15 2002. The Act created the Nuclear Waste Management Organization (NWMO) and specifies that within three years (i.e. by November 2005), the NWMO would recommend to the Minister of Natural Resources one of three possible approaches for the management of nuclear fuel waste. These approaches include: (a) deep geological disposal in the Canadian Shield based on Atomic Energy of Canada Limiteds plans; (b) storage at nuclear sites; and (c) centralized storage, either above or below ground (see section 12(2) of the Act).
The Act stated that the NWMO would have to include a program for public consultation as part of its implementation plan for each approach, but it did not specify any democratic or accountable decision-making process once a recommendation has been made by the NWMO. This leaves an accountability gap and a significant democratic deficit on radioactive waste management.
Moreover, of the possible waste management options, only deep geological disposal was reviewed by the Seaborn Panel. Not only did the panel review just one option (deep geological disposal), but as noted above, the panel clearly stated that the safety of that option was not adequately demonstrated.
Given the Seaborn panel rejection of the overall safety of deep geological disposal, and the failure to initiate any other more comprehensive and accountable review of alternate options, the call by Nuclear Waste Watch for environmental assessment review and parliamentary debate is the only sensible alternative.
An environmental assessment process, satisfying the requirements of the various statutes, should be convened jointly between the federal government and the provinces and territories (a) where high level radioactive waste is currently located, and (b) on the Canadian Shield where the waste could possibly be relocated (Northwest Territories, Nunavut, Saskatchewan, Manitoba, Ontario, Québec, Newfoundland & Labrador, and New Brunswick).
The process initiated through the Nuclear Waste Management Organization has three strikes against it. First, it is controlled by the nuclear industry and thus has little credibility. Second, it has been instructed to make a recommendation on one of three options, only one of which (deep geological disposal) has received detailed examination to date, and the jury is still out on that option. The three-year NWMO process will not have the accountability of an environmental assessment process. Third, the Nuclear Fuel Waste Act has failed to lay out any accountable, democratic process for deciding on the recommendation that is made by the NWMO.
It is important to note that there is no need to act hastily on these matters, since on-site storage for high level radioactive waste is adequate for many decades. Moreover, we are making a decision that will impact the environment and health of our descendants for hundreds of thousands of years.
Background for NWW Position Point #5
5. If the Government of Canada decides on any kind of centralized waste management option (whether above or below ground), there will be risk to communities along the transportation route, as well as to the potential recipient community. In such a case, the potential recipient and transport route communities should all have veto power, and should receive funding from proponents for independent research and community education.
In the fourth position point, Nuclear Waste Watch recommended that a environmental assessment panel review be guaranteed on a full range of waste management options, and that a full parliamentary debate and free vote should take place on the recommendations of the NWMO and the environmental assessment panel. The Seaborn panel noted that inadequate information had been provided in their process on how the proponents would proceed to a site a disposal facility.Inevitably, any site-specific proposal would require a joint federal/provincial environmental assessment. However, the principle of informed and voluntary consent in all affected communities should be guaranteed in advance by the federal government.
Background for NWW Position Point #6
6. The Nuclear Fuel Waste Act should be amended to guarantee that Canada will not consider the importation of high level radioactive waste, at least until there is a global phaseout of both nuclear power and nuclear weapons. A similar restriction should apply to the importation of any fresh reactor fuel if the irradiated fuel is to remain in Canada.
Despite recommendations from environmental groups, the Nuclear Fuel Waste Act does not prohibit the importation of high level radioactive waste (irradiated fuel) from foreign reactors. This opens up the possibility of Canada becoming a dumping ground for foreign waste, adding another level of uncertainty to any waste management proposal. While relocation of high level radioactive waste may be desirable in the future for reasons of security and environmental protection, it should not be considered until a secure global phaseout of both nuclear power and nuclear weapons has been achieved.
The Canadian government has approved in principle the possible use of mixed oxide (MOX) plutonium fuel in Canadian reactors. The fuel is being manufactured using plutonium from Russian and American nuclear warheads. A fuel test using American and Russian plutonium is currently being conducted at the Chalk River Laboratories of Atomic Energy of Canada Limited (AECL) near Pembroke, Ontario. The controversial test shipments of plutonium to Chalk River were opposed by environmental and community groups, First Nations and municipal governments. The federal government commitment-in-principle to allow the use of MOX fuel included an agreement to allow the irradiated fuel waste to remain in Canada in perpetuity.