Don’t let the facts interfere with the truth
In spite of the very high probability of being ignored, I decided to bite the bullet and submit a comment to the Environmental Assessment of the Bruce DGR. If I didn’t submit I’m sure my conscience would bother me when this outrageous boondoggle goes forward. My submission is reproduced below.
The proposed Bruce DGR is technically unnecessary and potentially harmful to Canada’s nuclear industry.
Canada’s strategy for the disposition of nuclear waste can be summarized in terms of four basic points:
- High Level Waste (HLW) – Highly radioactive long-lived used nuclear fuel would be stored in a Deep Geologic(al) Repository (DGR) at depths of 500 m or more, designed to last for at least 100,000 years,
- Low Level Wastes (LLW) – Low radioactivity short-lived wastes from reactor operations (tools, overalls, paper towels, and the like) is stored in near surface facilities to decay for a few 100 years and then go into engineered landfills.
- Intermediate Level Wastes (ILW) – Mainly from reactor refurbishment and decommissioning (mostly low volatility metal structures) and small volumes of special wastes from operations (ion exchange resins) are stored in engineered surface facilities (concrete trenches, wells and similar facilities) with the possibility that small volumes needing special handling could be stored in the futures DGR for HLW.
- Historical (Legacy) – Large volumes of wastes from uranium/radium mining and refining have relatively low radiation levels but are long lived, frequently occurring at defunct operations in remote areas and are dealt with generally using varied shallow land burial schemes involving excavation and covering with non-contaminated earth.
The Bruce DGR plan represents an abrupt departure from the above strategy in proposing that Low Level reactor operational wastes be treated in the same manner as High Level used nuclear fuel i.e. burial in a DGR. This is not only an unnecessary and uneconomic plan but it also sets a new and unrealistic standard for Low Level Waste disposal ultimately harmful to Canada’s nuclear industry.
There is no operational need for the Bruce DGR.
- The existing facilities for Low and Intermediate Level Waste surface storage at the Bruce site have proven satisfactory with an excellent safety record in terms of environmental, public and occupational health. These facilities serve all the Ontario reactors. There has been no technical or other development requiring a change to these arrangements.
- The current Low Level waste stored in these facilities (volumes exceeding 200,000 m3) will decay naturally to radiation levels allowing their burial in engineered landfills after a few 100 years. Therefore, it is not necessary to isolate Low Level wastes from the public and the environment in a DGR for thousands of years as is the case for HLW.
- The protections against such hazards as glaciation, human intrusion and loss of institutional controls provided by deep burial (~ 680m for the proposed Bruce DGR) while needed for used nuclear fuel repositories are not required for Low Level waste storage.
The Bruce DGR is not consistent with best international practice.
- No other country is proposing to treat Low Level nuclear waste in the same way as used nuclear fuel. Such a strategy is considered by other nations as not only unnecessary but prohibitively expensive.
- Sweden (Forsmark), Finland (Olklluoto) and Russia (Novouralsk) have opted for what one might call Shallow Geologic Repository (SGR) approach to store Low Level Wastes at depths of 60m, 70-100m and 7m respectively. These are essentially sub-surface storage facilities where surface storage buildings have been replaced by drive-in caverns. They are qualitatively very different than mine-like DGRs.
- The US WIPP (Waste Isolation Pilot Plan) facility, often cited in discussions about the Bruce DGR, is designed to hold wastes from nuclear weapons development containing significant amounts of plutonium and other transuranics. It is at a depth of 600m in a salt formation. The wastes stored at WIPP are neither Low Level nor short-lived wastes. Therefore, WIPP is not comparable to the proposed Bruce DGR. There is no US plan to store Low Level waste in DGR type facilities.
The Bruce DGR would probably not result in increased public safety and environmental benefits.
- Proponents of the Bruce DGR claim it will be have a greater margin of safety than the existing surface arrangements but no evidence to support this claim has been offered.
- The hard rock mining involved in constructing a DGR is likely to be a much more hazardous activity in terms of worker injuries and fatalities than constructing extra building to house waste on the surface.
- The thirty years or more of emplacement activities involved in filling up the facility with the large volumes of Low Level wastes would require workers be exposed to hazards typical of deep underground operations such as gas/dust explosions, cave-ins and tunnel collapses.
- As the WIPP fire of 2014 showed fighting a fire underground in a DGR was difficult to locate and extinguish. The resulting contamination took about three years to clean up. It may well be that immediate access to a fire in a surface facility might limit damage and contamination.
Approval of the Bruce DGR would be harmful to the development of nuclear energy in Canada.
- Requiring such extreme cautionary treatment of Low Level wastes as exemplified by placement in a DGR would raise unfounded and exaggerated fears of small levels of radiation in the public mind and hence, add credibility to anti-nuclear critics who make the false and alarmist claim that any amount of radiation however small is dangerous. By approving the Bruce DGR the CNSC would in effect appear to be endorsing this nonsensical point of view.
- Implementing the Bruce DGR would set the precedent that Low Level wastes would henceforth have to be stored in unnecessary and expensive DGRs resulting in increased overhead costs for all reactor systems now and in the future. This could further discourage future investment in nuclear power.
- Communities with Historical/Legacy Wastes could reasonably deduce from the Bruce DGR model the unrealistic expectation that their nuclear wastes should also be stored in DGRs. This might well provoke a strong reaction for fair and equal treatment from First Nations in whose lands much of the historical wastes are located.
- The much more stringent treatment of Low Level waste from uranium mining and refining implied by the Bruce DGR would put another damper on the struggling Canadian uranium industry.
- Fears have been expressed that the Bruce DGR with minor modifications could also be made to hold used nuclear fuel. Assurances have been given that this will not be allowed and this would require a true loss of institutional control.
The main reason given for OPG’s bizarre about face on the technology of Low Level Waste storage is simply that a DGR is the stated preference of the local municipalities. Thus, its rationale is based on a “social license” justification and not a technical one. Given this, it is not surprising the project has been debated on social, political, economic grounds rather technical ones. However, as argued above the unrealistic attitudes it fosters on Low Level waste are likely to have a negative impact on the future of the nuclear industry in Canada.
Therefore, it is concluded that the proposed Bruce DGR is technically unnecessary and potentially harmful to Canada’s nuclear industry.