HomeMy WebLinkAboutPSD-007-05
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REPORT
PLANNING SERVICES
Meeting:
GENERAL PURPOSE AND ADMINISTRATION COMMITTEE
Date:
Monday, January 10, 2005
Report #:
PSD-007-05
File #: PLN
33,13
bl'd- DIO'('S-
By-law #:
Subject:
NUCLEAR WASTE MANAGEMENT ORGANIZATION - COMMENTS ON
SECOND DISCUSSION DOCUMENT
RECOMMENDATIONS:
It is respectfully recommended that the General Purpose and Administration Committee
recommend to Council the following:
1. THAT Report PSD-007 -05 be received;
2. THAT Staff Report PSD-007-05 be adopted as the Municipality of Clarington's
comments on the Nuclear Waste Management Organization's Second Discussion
Document, Understanding the Choices; and
3, THAT a copy of this Report and Council's resolution be forwarded to the Nuclear
Waste Management Organization, the Region of Durham, and the member
municipalities of the Canadian Association of Nuclear Host Communities,
FORTHWITH.
Reviewed bY:cJ~ ~ ~-,
Franklin Wu
Chief Administrative Officer
JAS/FL/DJC/lb
17 December 2004
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1C 3A6 T (905)623-3379 F (905)623-0830
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FEEPORT NO.: PSD-007-05
1.0 BACKGROUND
PAGE 2
1.1 Over the past 30 years, 1,7 million used fuel bundles have been created at Canada's
licensed commercial nuclear reactors, with an additional 85,000 bundles being
created each year. It is currently anticipated that the 22 existing nuclear reactors (20
of which are located in Ontario) will generate a total of 3.6 million used fuel bundles
over their expected operating lives. The Darlington Nuclear Generating Station, with
four reactors, currently has approximately 240,000 used fuel bundles stored on site.
1,2 In the 1970s, an expert panel engaged by the federal government concluded that
deep burial in the stable rocks of the Canadian Shield was the best method for
managing used nuclear fuel. Atomic Energy of Canada Limited (AECL) was given
responsibility for researching and developing a method based on this concept, which
came to be known as the "AECL concept". The Atomic Energy Control Board
(Canada's nuclear regulator at the time) subsequently confirmed deep geologic
disposal as the preferred approach for managing Canada's used nuclear fuel waste,
1.3 I n the late 1980s, an Environmental Assessment Panel, chaired by Blair Seaborn,
extensively reviewed the AECL concept. The Seaborn Panel Report, produced in
1998, drew four key conclusions from its review:
. Broad public support is necessary to ensure the acceptance of a concept for
managing nuclear fuel waste;
. Safety is a key part, but only one part of acceptability. Safety must be viewed
from both technical and social perspectives;
. From a technical perspective, the safety of the AECL concept has been
adequately demonstrated for a conceptual stage of development, but not from a
social perspective;
. The AECL concept has not been shown to have broad public support.
1 .4 The Government of Canada responded to the Seaborn Panel Report in 2002 with the
enactment of the Nuclear Fue/ Waste Act. This Act led to the creation of the Nuclear
Waste Management Organization (NWMO) which was directed to investigate
approaches for the long term management of Canada's used nuclear fuel and to
submit a recommended approach and implementation plan to the Government by
November 15, 2005. The Act requires the NWMO to consider, at a minimum, the
following three approaches:
. Extended storage at reactor sites
. Centralized storage
. Deep geological disposal in the Canadian Shield, based on the AECL concept.
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PAGE 3
The Act also introduced requirements for the producers of the used nuclear fuel to set
aside sufficient funds to ensure the availability of adequate resources for managing
the waste over the long term.
1.5 The NWMO's Mission Statement is "....to develop collaboratively with Canadians a
management approach for the long-term care of Canada's used nuclear fuel that is
socially acceptable, technically sound, environmentally responsible and economically
feasible. " In order to fulfill its mission, the NWMO has embarked on an extensive
consultation and study process that includes the release of the following documents:
. Discussion Document 1 Asking the Right Questions (November 2003)
. Discussion Document 2 Understanding the Choices (September 2004)
. Draft Study Report: To be released in early 2005
· Final Study Report: To be submitted to the Government of Canada by
November 15, 2005.
The NWMO has also released numerous background papers on various issues
related to the long term management of used nuclear fuel, such as ethical
considerations and management approaches being considered in other countries.
1.6 The purpose of this staff report is give an overview of the first two Discussion
Documents, and to provide the Municipality's comments on the second Discussion
Document. The NWMO has requested that comments be submitted by the end of
December 2004. As such, this report has already been forwarded to the NWMO as
the Municipality's preliminary comments, to be confirmed by Council.
1.7 As well, the Canadian Association of Nuclear Host Communities (CANHC), of which
Clarington is a member, has received funding from the NWMO to permit CANHC to
retain a peer review consultant to assist its member municipalities in their review of
the second Discussion Document. The main body of the report prepared by the
consulting firm Acres/Sargent & Lundy, the peer review consultant retained by
CANHC, forms Attachment 1 to this report, A full copy of the report is available for
review in the Planning Services Department.
2.0 OVERVIEW OF FIRST DISCUSSION DOCUMENT - ASKING THE RIGHT
QUESTIONS
2.1 This document was released in November 2003 and provided a broad discussion on
various issues related to the long term management of used nuclear fuel. It also
presented ten questions that outline the NWMO's initial thoughts about an analytical
framework for assessing the different management approaches. These questions, as
summarized below and presented in full on Attachment 2, were divided into five
categories:
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· Over-arching Aspects - Institutions and Governance, Engagement and
Participation in Decision-Making; Aboriginal Values; Ethical Considerations;
Synthesis and Continuous Learning)
. Social Aspects - Human Health, Safety and Well-Being; Security
. Environmental Aspects - Environmental Integrity
. Economic Aspects - Economic viability
. Technical Aspects. Technical Adequacy.
The NWMO, as reflected in the title of this document, requested Canadian's comments
on whether these were the right questions to guide the study of the management
approaches.
2.2 The document also provided preliminary background information on a number of
possible management approaches, including the three defined by the Nuclear Fuel
Waste Act, which are described in more detail in Section 3,3. of this report. Other
methods receiving international attention include reprocessing (applying chemical
processes to recover and recycle fissionable isotopes), partitioning (isolating different
products after the used nuclear fuel is reprocessed), and transmutation (transforming
some radioactive components into non-radioactive components using nuclear
reactions), However, there are technical difficulties associated with each method and
none of them has reached a stage where they could be considered as a practical
alternative for the long term management of used nuclear fuel waste,
3.0 OVERVIEW OF SECOND DISCUSSION DOCUMENT - UNDERSTANDING THE
CHOICES
3,1 Results of Discussions with Canadians
3,1.1 In the second document, the NWMO advises that Canadians have indicated that the
ten questions presented in the first document capture the key issues and
considerations that should be addressed in the study. They also indicated that the
NWMO's study should focus on the three management approaches defined in the
Nuclear Fuel Waste Act - extended reactor site storage, centralized storage, and
deep geological disposal in the Canadian Shield.
3.1,2 However, the NWMO was also asked to study a number of issues in more detail prior
to completing any assessment of management approaches, including:
. The hazard posed by used nuclear fuel to human health and the environment
. The risk posed by transportation of used nuclear fuel
. What "social acceptability" or "public confidence" will entail
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· How the assessment is affected by the volume of used nuclear fuel that ultimately
needs to be managed
· Opportunities to reuse or recycle used nuclear fuel
· Opportunities to site a deep disposal repository in geologic media other than as
required by the Nuclear Fuel Waste Act.
3.2 Development of an Assessment Framework
3,2,1 The NWMO assembled a multi-disciplinary Assessment Team and requested them to
translate the ten questions presented in the first discussion document into a
framework for assessing the management approaches. As a result of this exercise,
the following eight specific objectives were developed:
· Fairness - Distribution of costs, benefits and responsibilities within this generation
and across generations; public involvement in key decisions
· Public Health and Safety - No exposure to hazardous materials during
transportation or site operations
. Worker Health and Safety - No undue risks to workers employed to implement
management approach
. Community Well Being - Affect on the host community, those in the surrounding
region, and along transportation routes
. Security - Maintaining security of facilities, materials and infrastructure over a very
long period of time
. Environmental Integrity - Protection from localized or widespread environmental
damage from chronic or unexpected releases of radioactivity; impacts associated
with related infrastructure
. Economic Viability - Availability of funding now and in the future; cost must be
reasonable
. Adaptability - Able to accommodate changing knowledge and unforeseen
circumstances; provide flexibility to future generations
3.2.2 The following Value and Ethical considerations are embedded in these eight
objectives:
. Safety from Harm - Human health and the natural environment must be
protected, now and in the future
. Responsibility - Deal with the problems that we have created
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· Adaptability - Build in capacity to respond to new knowledge
· Stewardship - Use resources with care; leave sound legacy for future generations
· Accountability & Transparency- To rebuild trust in government and industry
· Knowledge - To inform people and develop necessary technical expertise
· Inclusion - Broad public engagement
· Respect - For all forms of life, for future generations, and for people and cultures
. Justice - Across groups, regions, and generations
· Fairness - To everyone affected, especially minorities and marginalized groups
. Sensitivity- To different values and interpretations.
3,3 Preliminary Assessment of Management Approaches
3.3.1 The NWMO's Assessment Team used the assessment framework to undertake a
preliminary analysis of the three management approaches defined in the Nuc/ear Fuel
Waste Act. A summary of the major advantages and disadvantages of each
approach is also provided by Attachment 3.
Extended Storaqe at Reactor Sites
3,3,2 This approach would involve the expansion of existing dry storage facilities or the
establishment of new long term storage facilities at each of the seven existing reactor
sites in Canada, Both surface and below-surface design options are possible, and
would allow for the safe retrieval of the waste. The storage facilities would eventually
need to be replaced (300 years was assumed), Preliminary cost estimate suggest
that this approach would cost $17,6 - $25,7 billion for the first 300 year cycle, with the
present value impact of the first repeat cycle being $2.3 - $4.4 billion, On-site
storage would require on-going maintenance and monitoring for very long periods of
time,
3.3,3 The most significant advantage of this approach is that no transportation of the used
nuclear fuel would be required, The appropriate technical expertise would be
available in the existing communities and the facilities could be easily monitored.
3.3.4 The key disadvantage of extended storage at reactor sites is the need for continuing
administrative controls and operations, including funding, for the thousands of years
that the fuel would remain hazardous. A number of the storage facilities would be
located in proximity to important bodies of water and would continue well past the
shutdown of the nuclear reactors,
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Centralized Storaoe
3.3,5 This option would involve creating new long term dry storage facilities at one site in
Canada. For assessment purposes. it was assumed that the centralized storage
facility would be a stand-alone facility located on an undeveloped site. Technologies
available include storage of the waste containers in surface buildings or vaults, in
shallow trenches or in rock caverns, and would allow for the waste to be retrieved.
The used nuclear fuel would need to be transported from the existing storage sites to
the new centralized facility. The first fuel shipments would occur approximately 30
years after a decision to implement this option and would continue over another 25 to
40 years, It is estimated that this approach for one 300 year cycle, including
transportation costs, would be $15.7 - $20 billion, with the present value impact of the
first repeat cycle being $3.1 - $3.8 billion, A centralized storage facility would
require on-going maintenance and monitoring for very long periods of time.
3.3.6 Centralized storage has a number of advantages over on-site storage. The site
would be selected solely on its attributes for the long term storage of used nuclear
fuel, and security and monitoring would be centralized rather than spread over
several sites,
3.3.7 Centralized storage is similar to on-site storage in that long term administrative,
operational and funding arrangements would be required. Transportation of the used
nuclear fuel to the site would also be required with its attendant risks and costs.
Deep Geolooical Disposal
3.3,8 This concept, as developed by AECL, would involve the encapsulation of used
nuclear fuel in long lived engineered containers placed and sealed within excavated
rooms in a naturally occurring geological formation 500 - 1000 metres below ground.
For assessment purposes, it was assumed that the repository would be located on a
remote undeveloped site on the Canadian Shield. The first fuel bundles would be
transported approximately 30 years after a government decision to implement this
approach, and would continue for a further 25 - 40 years. The repository would
eventually be backfilled and sealed and decommissioned after a period of extended
monitoring (70 years was assumed), Preliminary cost estimates suggest this
approach would cost $16.2 billion, including transportation, with the present value
cost being approximately $6,2 billion.
3.3.9 The key advantage of deep geological disposal is that the necessity for long term
institutional and operations controls and funding surety could be significantly reduced
or eliminated, The site could be selected for its specific geologic and hydrologic
attributes that, in combination with engineered features such as long lived waste
packages and material buffers, could effectively isolate the used nuclear fuel from
people and the environment for the very long time periods required,
3,3.10 Unlike on-site storage and centralized storage, there is no national or international
experience with the deep geological disposal of used nuclear fuel waste. The
emplacement of the waste deep in the ground and the eventual backfilling and
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closure of the facility would make monitoring and retrieval of the waste more difficult.
As with centralized storage, transportation of the used nuclear fuel waste would be
required.
3.4 Questions Posed by the NWMO
3.4,1 The NWMO has requested comments on the second Discussion Document and has
posed three sets of questions, as follows:
· Is the assessment framework comprehensive and balanced? Are there gaps
and, if so, what does the NWMO need to add?
· What are your thoughts on the strengths and weaknesses of each management
approach: deep geological disposal; centralized storage; and reactor site
storage?
· Are the specific elements that you feel must be built into an implementation plan?
What are your thoughts on what a phased approach must include?
The Municipality's comments on these specific questions are provided in Section 4
below.
4.0 COMMENTS ON QUESTIONS ASKED BY THE NWMO
4,1 Is the assessment framework comprehensive and balanced?
4.1.1 The CANHC peer review team has reviewed the process used by the NWMO to
derive the proposed assessment framework and has generally found it to be
comprehensive, reasonable and appropriate. Staff concurs with this opinion and
notes in particular that Safety from Harm for humans and the natural environment,
now and in the future, should remain as an over-arching requirement in the
assessment framework.
4.2 Are there gaps in the assessment framework and, if so, what does the NWMO
need to add?
Social Acceptabilitv
4.2,1 The NWMO's has indicated its intention to develop a management approach that is
"socially acceptable". However, social acceptability is not specifically identified as an
objective or a value or ethical consideration within the assessment framework. The
NWMO should either add social acceptability to the assessment framework as a
value or ethical consideration or explain how it is to be addressed in the assessment
framework.
4.2.2 Given the highly contentious nature of nuclear energy and the management of
nuclear fuel waste, it is unlikely that a high degree of concurrence regarding a
management approach will be achieved among Canadians. This will be particularly
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true in communities that will be impacted by the implementation of the management
approach, including those that currently host nuclear facilities, those along
transportation routes, and the community where any new management facility will be
located. The different socio-economic and demographic characteristics of these
communities could make it difficult to develop a universal definition of social
acceptability. The NWMO will therefore need to determine what is considered to be
"socially acceptable" in both the broader Canadian context and in a community-
specific context.
Selection of a Host Community
4,2,3 The NWMO has indicated its preference is to find a willing host community for the
nuclear waste management facility. The fallback position if no willing host
community comes forward (although not specifically acknowledged by the NWMO) is
to impose a solution and unilaterally identify a host community. However, for a
number of reasons including political climate and community resistance, neither of
these solutions may be feasible. In such a situation, the used fuel would remain
stored at the reactor sites, including the Darlington NGS, and the existing nuclear
host communities would become by default the host communities for the used fuel
waste facilities. It is therefore imperative that the NWMO's assessment framework
must recognize political and social realities and address the ability of each of the
management approaches to be implemented.
Continqency Planninq
4.2.4 The NWMO Assessment Team noted that it will be necessary to ensure that
contingency plans are known and available should they be required, at least for the
period in which active management of the waste is needed to ensure safety.
However, it is not clear from the review of Discussion Document 2 and the NWMO's
background papers whether the feasibility and availability of contingency plans for
each of the management approaches have been incorporated into the assessment
framework,
Relative Importance of Obiectives
4.2.5 The original ten questions and the current eight objectives are characterized by
Discussion Document 2 as all having equal importance, However, the NWMO's
Assessment Team, in undertaking the preliminary assessment of the management
approaches, used different weights to explore trade-offs between the different
objectives, such as:
. Security vs. Accessibility
. Remote location vs. Minimal handling and transportation of waste
. Assume responsibility today vs. Provide flexibility for future generations
. Making a decision vs. Managing uncertainty.
The Assessment Team noted that changing the weighting used in the assessment
provided a sensitivity analysis that indicated whether different weightings affected the
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ranking of the various management approaches. The CANHC peer review team
indicated in their comments that this type of sensitivity analysis is important and
necessary to fully evaluate the different approaches and to confirm that the
assessment framework is balanced.
Fatal Flaws
4.2.6 The NWMO's Assessment Team's report presents the results of their analysis in the
form of composite scores, but does not seem to consider fatal flaws (I.e. an issue or
problem that would exclude a particular option from further consideration). For
example, the composite scores of the on-site storage options beyond 175 years for
the objectives of Public Health and Safety and Security both include a score of zero in
their ranges. This indicates that at least some on the Assessment Team may have
considered these options to not be viable in the longer term. However, without a
consideration of fatal flaws, this would only have the effect of broadening the range of
scores as opposed to initiating a more significant assessment of these options.
Visibilitv of Waste
4,2.7 There is a conflict between the desire of some stakeholders to "keep an eye on the
waste" vs. the scientific community's general preference for deep geological disposal.
Reactor site storage (or, to a more limited extent, centralized storage) keeps the issue
and societal costs of nuclear waste more visible. This perspective would not
necessarily be addressed by a technically focused comparative analysis and could
significantly affect the current host communities due to its bias towards reactor site
storage,
4.2.8 The NWMO study should ensure (1) that the conflicting desires of some stakeholders
to keep the issue of used fuel visible versus the scientific community's general
preference for deep geological disposal are given proper weight, (2) that the technical
details of the selected management approach address this issue, and (3) that broader
social values and motives (such as keeping used fuel disposal highly visible in order
to highlight the issue) are considered,
Retrievabilitv
4.2.9 The NWMO's assessment of the three management approaches assumes that, with
reactor site storage and centralized storage, the waste will be repackaged and
therefore be retrievable. However, the assessment of the deep geological repository
concept does not explicitly identify the assumption that the waste will either be
repackaged or retrieved. The base assumption for deep geological disposal, instead,
is that the facility will be decommissioned after a certain period of operations and
monitoring. This approach requires that the used fuel containers be retrievable during
the pre-closure phase, but it does not address retrievability after the facility has been
decommissioned. The design concept includes backfilling around the spent fuel
disposal containers, which would hinder the ability to retrieve the spent fuel if
required. The issue of retrievability should be more fully addressed by the NWMO as
it develops a more detailed comparative analyses.
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4.2.9 In summary, staff agree with the opinion of the CANHC peer review team that it is
difficult to determine how balanced the NWMO assessment framework is without a
more thorough consideration of such issues as political climate, contingency planning,
relative weightings, fatal flaws and retrievability within the framework. This detail is
important so that it will be possible in future work undertaken by the NWMO to
confirm and evaluate the overall balance of the assessment framework.
4.3 What are your thoughts on the strengths and weaknesses of each management
approach: deep geological disposal; centralized storage; and reactor site
storage?
General Comments
4.3.1 Any changes to the weightings of the different objectives and corresponding factors
used in the on-going comparative assessment process will affect the relative strengths
and weaknesses of each management approach. As the comparative analysis process
continues, it will be necessary to assess the effect of changes to individual weightings
on the ranking of each management approach,
4,3,2 There appears to be a discrepancy in the advantages and limitations relative to the
objective for Adaptability. The ability to monitor performance and flexibility to adapt to
changing conditions was noted as being a relative advantage for at-reactor storage, but
was not mentioned for centralized storage, These same factors should be listed as an
advantage for centralized storage, In addition, Adaptability was noted as being a
limitation for deep geological disposal, which is consistent with its technical details.
However, the deep geological disposal approach had the same or higher performance
value score compared to the other approaches in the analysis of Adaptability. This
discrepancy should be clarified or otherwise resolved as the comparative analysis
process continues.
4.3.3 The relative strengths and weaknesses of the different management approaches as
discussed in Discussion Document 2 do not provide an indication of how they might be
affected by potential technical changes. There is no sensitivity analysis of what would
happen if there were significant changes in cost or design parameters as basic design
assumptions are validated during the detailed design stage for the selected approach
(eg. change in the volume of spent nuclear fuel requiring disposal). It may be an
advantage if one of the approaches was shown to be less sensitive to potential design
changes, Therefore, the sensitivity analyses conducted as part of the NWMO's
ongoing comparative analysis process should consider changes in key technical
assumptions,
4,3.4 The NWMO's discussion of the strengths and weaknesses of the three management
approaches does not appear to include a comparative assessment of the risks
associated with each approach. Comparative risks include both technical risks (such
as the impact of postulated accidents) and financial risks (such as changes in the
assumed discount rates used in the financial models). An approach may have a
relative strength (or weakness) if it can accommodate these types of risks better (or
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worse) than the other approaches. This issue should be considered during the ongoing
detailed comparative assessments that the NWMO is currently performing.
4.3.5 The assessment framework considers the impact of the management approaches
on new host communities; however, the NWMO does not appear to have
analyzed the impact of the separate management approaches on the current host
communities. It would seem appropriate to ensure that the current host
communities are afforded the same considerations and potential benefits as new
host communities within the ongoing assessment process. This would be
especially appropriate if a decision relative to which management approach to
use is not made, or if the decision cannot be implemented, so that the current
host communities become the storage communities by default.
Comments on Deep Geoloqical Disposal
4,3.6 The site selection process for deep geological disposal does not note limitations
associated with establishing the geological suitability of potential sites. A good
example of this is the experience with Yucca Mountain in Nevada, which has been
selected by the American government for the geological disposal of its high level
nuclear waste, Despite many years of research, scientists have not yet been able to
fully characterize the geological conditions at the site and the probability and effects of
major seismic events on the operation and integrity of the repository. This lack of
certainty has resulted in significant delays and cost overruns in the implementation of
the Yucca Mountain project.
Comments on Reactor Site Storaqe
4,3.7 It will take approximately one million years for the level of radioactivity of the used
nuclear fuel to decay to that of natural Uranium. Given this time frame and the
inevitable expansion of urban development in the vicinity of the existing reactor sites in
Ontario, plus their location adjacent to important bodies of water, reactor site storage is
clearly not a viable alternative for the long term management of the waste.
4.4. Are there specific elements that you feel must be built into an Implementation
Plan?
4.4.1 Many of the problems and delays in the implementation of major projects with
significant environmental implications stem from the failure to correctly identify all the
required permits and permit application requirements associated with a given project.
Siting and approvals is a significant phase of each of the management approaches and
the overall management of spent fuel in Canada is politically complicated. The NWMO
should ensure that the implementation plans developed for the separate management
approaches include comprehensive and specific permitting schedules that define which
permits are required, when they are required, how long it takes to apply for and obtain
them, and who has to make the application. Possible conflicts or uncertainties
regarding the legal jurisdiction of different government agencies should be identified.
4.4.2 Problems and delays can also stem from determined opposition from one or more
stakeholders (such as environmental groups or elected officials) when the EA and
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applications are reviewed. Technical issues (engineering, conceptual designs, etc.) or
costs are frequently not the critical parameters that determine a project's success or
failure, Involving key stakeholders early in the project sometimes can eliminate
determined opposition by allowing concerns to be addressed in the basic project
design. Focused discussions with these stakeholders may provide valuable
information for the NWMO's implementation plans in terms of identifying potential
opposition, assessing the primary concerns of potential opponents, and developing
mitigation measures to address these concerns.
4.4.3 The Implementation Plans for either Centralized Storage or Deep Geological Disposal
must be sufficiently flexible to allow them to adapt to changing circumstances. Both of
these approaches will require the identification of a host community and the
Implementation Plans must address the possibility that a willing host cannot be found
or that an apparent willing host withdraws its concurrence partially through the project
implementation. The Implementation Plans must also anticipate the possibility that
future governments may be unwilling to implement the management approach
recommended by the NWMO.
4.4.4 The NWMO's recommendation to the Government of Canada in November 2005 will
not specify a community or an economic region in which the long term management
approach should be implemented. Rather, the NWMO will focus on developing
characteristics that would be appropriate in choosing the specific economic regions for
deep geological disposal and centralized storage approaches. The NWMO should
however also ensure that the implementation plans for these two management
approaches anticipate the specific issues and considerations that may be associated
with the economic region and community that are eventually identified to host the
waste management facility,
4.4,5 As the implementation plans are developed, the resulting details could affect the
comparative assessments of the different management approaches performed up to
that point. Accordingly, the NWMO should ensure that the comparative assessments
are updated and re-evaluated as required to be consistent with the planned
implementation details.
4,5 What are your thoughts on what a phased approach to implementation must
include?
4,5,1 There are many apparent advantages to a staged approach to implementation.
Adaptability would be enhanced by enabling new technical developments (such as
improvements in design and operational requirements) to be incorporated into the
management approach, A phased implementation would also enable emerging options
that have been screened out to date (such as partitioning and transmutation) to be
monitored.
4,5,2 However, staff concur with the opinion of the CANHC peer review team that a phased
approach also has the potential to negatively affect the overall effective implementation
of the project. For example, a phased approach could produce cost overruns and
schedule delays resulting from changes in the design of key components in an attempt
to incorporate ongoing technical developments. There is also potential for the project
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scope to increase, which could increase the project's overall schedule and cost, based
on additional analyses to evaluate new alternatives. To avoid these difficulties, the
NWMO should ensure that the overall project implementation plans include key project
milestones where "go - no go" decisions are made, as well as points where designs
are finalized, or "frozen," to enable the project to proceed with minimal potential for
design changes.
4,5,3 To be able to capitalize on new technical or other advances, the design parameters
associated with the selected management approach should be developed and selected
to maximize overall system flexibility. For example, instead of designing a centralized
storage facility for the entire planned inventory of used nuclear fuel during the initial
phase of the project, it may be beneficial to perform the design in phases. The design
for the later phases would then be able to incorporate the latest information and
technology available at that time with minimal impact on the implementation timeline for
the first phase.
4.5.4 The selection of either the Centralized Storage approach or the Deep Geological
Disposal approach will require the used nuclear fuel waste to remain stored at the
existing reactor sites for an extended period - a minimum of 30 to 55 years for
Centralized Storage, and a minimum of 40 to 70 years for Deep Geological Disposal.
These time periods could be increased if implementation is delayed, It is therefore
imperative that the implementation plans for both of these approaches recognize the
extended periods that the used fuel waste will remain at the existing reactor sites and
the possibility that the waste will remain longer than anticipated.
5.0 COMMENTS ON THE NWMO PROCESS
5,1 The NWMO's engagement activities were designed to establish an informed dialogue
with many diverse communities of interest, including the Canadian public at large,
business interests and non-governmental organizations, However, these engagement
activities have not been designed to, nor have they achieved, consultation with nuclear
awareness groups or environmental groups. Although these groups may have a
focus or an agenda that runs counter to the NWMO's stated purpose, the NWMO
should specifically solicit their input. In addition, or alternatively, the NWMO should
develop an assessment of the positions of these groups, the influence they may exert
on the process, the impact this influence could have on the recommended
management approach, and what can be done to gain their input or otherwise address
their positions,
5,2 The NWMO has undertaken specific consultation with the existing nuclear host
communities and has provided funding to enable CANHC to retain the professional
advice of a peer review consultant. Nevertheless, in both Clarington and Pickering,
there has been very little interest or participation from among the broader community in
the NWMO's process. Recent public information and discussion events held by the
NWMO in both communities were very poorly attended, It is unclear whether this poor
attendance is a product of lack of interest within the community or poor advertising by
the NWMO, or a combination of both, Nevertheless, the NWMO needs to make a
more concerted effort to engage the citizens of the existing nuclear host communities.
o t." ,.J
REPORT NO.: PSO.o07.o5
PAGE 15
This could include interviews with the local media to ensure coverage in local
newspapers and television.
5.3 The extent of the NWMO's consultation program is constrained by the necessity of
making a recommendation to the Government of Canada on a preferred management
approach by November 15, 2005 as imposed by the Nuclear Fuel Waste Act. In order
to fulfill its mandate to develop an approach for the long term management of Canada's
used nuclear fuel that is "socially acceptable, technically sound, environmentally
responsible and economically feasible", the NWMO must address an enormous
number of complex technical, social, environmental and economic issues. The volume
and complexity of this information is simply beyond the ability of the average citizen to
absorb, making meaningful dialogue with the NWMO somewhat difficult. It is not clear
whether the NWMO will be able to achieve the desired level of public consensus and
social acceptability that will enable an approach for the long term management of
Canada's used nuclear fuel to be successfully identified and implemented.
6.0 CONCLUSIONS
6.1 The current NWMO process is intended to identify and recommend a waste
management approach for Canada's high level nuclear waste. The process to identify a
host community will be initiated once the Government of Canada accepts the NWMO's
recommendation on a management approach. Based on past experience with the
Siting Task Force, which was unable to find a willing host for the Port Hope area
wastes, the Municipality of Clarington has significant concerns that the used nuclear
fuel will remain for an indefinite period at the existing reactor sites. The NWMO needs
to give more credence to this scenario in its assessment process and make a more
concerted effort to engage a variety of stakeholders in the existing nuclear host
communities.
Attachments:
Attachment 1 - Extract from Peer Review Report - Acres/Sargent & Lundy
Attachment 2 - Ten Questions from First Discussion Document
Attachment 3 - Summary of Key Advantages and Disadvantages of Management Approaches
Interested parties to be advised of Council and Committee's decision:
Elizabeth Dowdeswell
Nuclear Waste Management
The Regional Municipality of Durham
Mayor David Ryan
City of Pickering
Mayor Glenn Sutton
Municipality of Kincardine
Mayor Ann Aikens
Town of Deep River
Mayor Len Simpson
Town of Pinawa
Mayor Maurice Richard
Laville de Becancour
'.....: \~', <:..)
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ATTACHMENT 1
Report PSn-007-oS
Nuclear Waste Management Organization
Independent Peer Review of
NWMO Discussion Document 2,
"Understanding the Choices"
Prepared for
Canadian Association of Nuclear Host Communities
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ACRONYMS AND ABBREVIATIONS
Term
Definition or Clarification
AECL
Atomic Energy of Canada Limited
ASL
Acres-Sargent & Lundy
CANDU
Canada Deuterium Uranium
CANHC
Canadian Association of Nuclear Host Communi1ies
CEAA
Canadian Environmental Assessmen1 Act
CNSC
Canadian Nuclear Safety Commission
CRL
Chalk River Laboratories
DGR
Deep geological repository (facility)
EA
Environmental Assessment
NFWA
Nuclear Fuel Waste Act
NPV
Net present value
NWMO
Nuclear Waste Management Organization
RFP
Request for proposal
SAR
Safety analysis report
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1. INTRODUCTION
Acres-Sargent & Lundy (ASL) was engaged by the Canadian Associa1ion of Nuclear Host Communities
(CANHC) to assist in its evaluation of Canada's Nuclear Waste Management Organization (NWMO) process
for the future management of Canada's used nuclear fuel. Specifically, CANHC requested ASL's assistance by
reviewing NWMO's Discussion Document 2: "Understanding the Choices: The Future Management of
Canada's Used Nuclear Fuel." This report summarizes our review of Discussion Document 2 for CANHC.
The purpose of Discussion Document 2 is to share the NWMO's recent work and thoughts about the long-term
management of used nuclear fuel in Canada. The document provides information "important for a public
dialogue about the relative merits of the different waste management approaches." Our review will address the
following questions asked by the NWMO in the discussion document as a means to seek continued public
involvement:
. Is the assessment framework comprehensive and balanced? Are there gaps, and if so, what
should be added to the assessment framework?
. What are our thoughts on the strengths and weaknesses of each management approach: deep
geological disposal, centralized storage, and reactor site storage?
. Are there specific elements that we believe must be built into an implementation plan? What
are our thoughts on what a phased approach must include?
These questions were supplemented by questions asked by CANHC during the performance of our review,
This Independent Peer Review is organized into several sec1ions. Section 2 of this report provides a summary of
the results of our review and includes a table of the key issues we identified and the corresponding
recommendations we developed, Section 3 discusses the methodology and approach we used to perform our
review. Section 4 provides a detailed discussion of the key issues and questions related to Discussion Document
2. Section 5 includes background information related to CANHC, the NWMO, and the overall study that the
NWMO is to develop its recommended management approach.
In addition, several appendixes are included to provide references and general information rela1ed to our
independent peer review. Appendix A contains correspondence and administrative information related to our
engagement to perform the independent peer review, including CANHC's Request for Proposal, ASL's
proposal. minutes from the interview/kick-off teleconference, CANHC's authorizing ASL to perform the
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review, and contact information for ASL's key personnel. Appendix B includes several NWMO fact sheets that
provide more background information about Canadian used nuclear fuel issues. To facilitate accessing NWMO
information on the Internet related to Discussion Document 2 and our review, Appendix C includes a copy of
the site map for NWMO's web site and Appendix D includes a table of web links. Appendix E provides a
listing of the background papers developed by NWMO related to their study. In order to provide a
comprehensive overview of Discussion Document 2, Appendix F includes Discussion Document 2's Executive
Summary, Appendix G includes summaries developed by the Joint Waste Owner's to provide an overview of
the three main management approaches,
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2. EXECUTIVE SUMMARY
2.1 OVERVIEW
The NWMO was established under the Nuclear Fuel Waste Act (NFW A) to investigate approaches for
managing Canada's used nuclear fuel. The Nuclear Fuel Waste Act requires the NWMO to recommend a
preferred management approach to the Government of Canada by November 15, 2005. The NWMO will then
implement the approach chosen by the Government. In order to provide an overview of used nuclear fuel and
related issues in Canada, Appendix B contains nine fact sheets developed by the NWMO that address topics
such as the NWMO organization, what is "used nuclear fuel," the Canadian nuclear regulatory framework, and
the NWMO study process, among others. As noted in the NWMO's Fact Sheet 9, "The NWMO Sludy Process,"
the NWMO has committed to "develop collaboratively with Canadians a management approach that is socially
acceptable, technically sound, environmentally responsible, and economically feasible,"
The NFW A requires that the following three main management approaches must be studied: deep geological
disposal, storage at nuclear reactor sites, and centralized storage. Other methods may also be considered. To
undertake the study, the NWMO has "adopted an iterative study process, undertaken in phases to allow
information, analyses, and thinking to be considered in a staged manner." Discussion Document 2 was
developed and issued as part of this iterative and open process to summarize the progress so far and the next
steps the NWMO is taking to arrive at its recommended management approach.
ASL performed a broad review of Discussion Document 2 with the overall objective of identifYing questions
that are not currently being asked by either the NWMO or others reviewing the NWMO's process. The intent of
the review was to identifY key issues and areas that we recommend CANHC focus on as NWMO continues in
their process.
2.2 RESULTS
Discussion Document 2 is a high level document that contains a broad summary of the NWMO's activities
since Discussion Document I was issued. As a summary document, it contains a significant number of
references to other NWMO documents that address the topics and issues related to developing the
recommendation for which management approach the Canadian government should use, These references are
generally located on the NWMO web site. Appendix C provides the current site map ofNWMO's web site for
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reference, Appendix D contains a reference table developed by ASL in its review of Discussion Document 2
that lists the web sites referenced in the document along with the related files posted on the web,
The current assessment framework is derived from the original1en questions discussed in NWMO's Discussion
Document I, "Asking the Right Questions," and consists of eight objective and associated guiding principles
and influences, The framework was developed by a multi-disciplinary Assessment Team assembled by the
NWMO to develop a comparative analysis of alternate approaches. The NWMO's Assessmen1 Team based
their work on the ten questions posed in Discussion Document I and on the NWMO's engagement with
Canadians and ongoing research and analysis activities.
The eight objectives of the NWMO's current assessment framework are as follows:
. Fairness
. Public Health and Safety
. Worker Health and Safety
. Community Well-Being
. Security
. Environmental Integrity
. Economic Viability
. Adaptability
Based on the updated framework, the NWMO Assessment Team performed a comparative analysis of the three
main management approaches by systematically comparing the approaches against the objectives using a multi-
attribute utility analysis. The NWMO Assessment Team's report was issued in June 2004 and forms a
significant basis for the information presented in Discussion Document 2,
The NWMO has performed significant engagement activities and actively solicited a wide range of input on its
work. The NWMO's engagement activities were designed to establish an informed dialogue with a wide range
of stakeholders, ranging from the Canadian public at large to governments, business interests, and interested
individuals.
The NWMO has developed conceptual designs, cost estimates, transportation requirements, and preliminary
project timelines for each of the main management approaches; these can be accessed on NWMO's web site as
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noted in Appendix D. The conceptual designs and cost estimates are intended to provide sufficient detail to
confirm the engineering feasibility of the management approaches to support the current phase of the NWMO's
study, which is appropriate, The NWMO has arranged for independent reviews of these technical evaluations.
The NWMO noted in Discussion Document 2 that these third-party reviews concluded that the designs are
reasonable and feasible, that the cost estimates have been prepared in accordance with appropriate estimating
methodology, and that the technical information as a whole is suitable for the options review and directional
decision-making requirements of the NWMO,
Based on the conceptual designs and cost estimates, the Assessment Team analyzed each of the three main
management approaches within the current assessment framework. The resulting relative strengths and
weaknesses of each approach is summarized in Figure E-l (starting on page 7) in Discussion Document 2's
Executive Summary (provided in Appendix F of this report to facilitate reference). The relative strengths and
weaknesses are discussed in more detail in Section 4.3.2 below.
The Assessment Team's report notes that the overall management of spent fuel in Canada is politically
complicated, Under the Canadian constitution, energy policies and land management that involve the
production of spent fuel are responsibilities of the provincial governments, while managemen1 of radioactive
materials is the responsibility of the federal government. Discussion Document 2 notes that the NWMO will be
focusing on implementation plans as their study moves forward and that implementation is a critical part of
making a recommendation. The NWMO notes that the development of implementation plans will include, at a
minimum, consideration of the following elements:
. Oversight and monitoring systems
. Ongoing societal involvement
. Institu1ional design, including human resource capacity
. Ownership and liability
. Dispute management
. Principles to guide site selection; and
. Education and information programs,
The NFW A states that the selected management approach will be implemented by the NWMO "subject to all of
the necessary regulatory approvals," Discussion Document 2 contains implementation timelines for each of the
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three main management approaches. Siting and approval for each of the approaches is a critical element of each
of the timelines, The NWMO has started to assess the regulatory framework within which the selected approach
will be implemented,
2.3 KEY ISSUES AND RECOMMENDATIONS
ASL identified several issues and corresponding recommendations during its independent peer review as
summarized in the table below. The detailed results and discussion of these issues is presented in Section 4,
Table 2-1 - Issue and Recommendation Summary
Issue / .Recomm..l"I~lItiQn > ,... .'
Assessment Frllmework
Although the Assessment Team's report provides alternate
weightings of the different overall objectives, it does not
provide the weightings for the specific influence variables
associated with each objective, As a result, ASL cannot
determine how balanced the assessment framework is.
The Assessment Team report notes that a practical strategy
for implementing an overall management approach must The NWMO should provide explanations of
take the political climate into accounl, and Ihat this factor is how political climate, contingency planning,
outside the scope of the Team's assessment. fatal flaws, and relative importance of the
objectives and specific influence variables
The Assessment Team notes that "The assessment were considered, so that it is possible in
suggests it will be necessary to ensure, , , that contingency future work to confirm and evaluate the
plans are known and available should they be required, at overall balance of the assessment
least for the period in which active management of the framework,
waste is needed to ensure safety,"
The Assessment Team's report presents the results of their
analysis in the form of composite scores, and does not
seem to consider fatal flaws (that is, an issue or problem
that would exclude a particular option from further
consideration).
The NWMO should specifically solicit input
The NWMO has not systematically engaged with groups from groups that focus and represent public
opinion. In addition, or alternatively, the
that focus and represent public opinion, such as nuclear NWMO should develop an assessment of
awareness groups or environmental groups. These groups the positions of these groups, the influence
may have specific agendas that may be counter to the they may exert on the process, the impact
NWMO's ultimate objective to implement a management this influence could have on the
approach once the Canadian government makes a decision recommended management approach, and
based on the NWMO's recommendation, what can be done to gain their input or
otherwise address their positions,
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Issue < .'...... Jilei!Qi!1l'1'1enctat!I)O <. "..... ....
.,.... ....... ....< ...."
The NWMO study should ensure (1) that
the conflicting desires of some stakeholders
There is a conflict between Ihe desire of some stakeholders to keep the issue of used fuel visible versus
to "keep an eye on the waste" versus the scientific the scientific community's general
community's general preference for deep geological preference for deep geological disposal are
disposal. For example, a reactor site storage (or, to a more given proper weight, (2) that the technical
limited extent, centralized storage) keeps the issue and details of the selected management
societal cosls of nuclear waste more visible, and so approach address this issue, and (3) that
provides an impetus for reducing the generation of this type broader social values and motives (such as
of waste, A comparison was made to trash along the side of keeping used fuel disposal highly visible in
a road: if disposed in a landfill and out of sight, there is less order to highlight the issue) are considered.
of a constant reminder of the overall costs associated with
creating the trash. This perspective would not necessarily As part of the engagement process, the
be addressed by a technically focused comparative analysis NWMO should consider establishing focus
and could significantly affect the current host communities groups to identify specific concerns Ihat
due to its bias towards reactor site storage, people may have with "keeping an eye on
the waste" (Le" technical or social) to
support fully addressing this issue.
The used nuclear fuel is retrievable in the two storage
approaches, but by design is not retrievable in the deep The NWMO should more fully address the
geological disposal approach after the site is issue of retrievability as it develops more
decommissioned, Discussion Document 2 does not fully
address this issue, nor is it fully addressed in the detailed comparative analyses.
Assessment Team's report, "Assessing the Choices,"
Management Approaches
Any changes to the weighting of the different objectives and Potential changes in the relative strengths
corresponding factors used in the ongoing comparative and weaknesses should be reviewed as the
assessment process will affect the relative strengths and comparative analysis process continues.
weaknesses.
The site selection process for deep geological disposal Consideration should be given to the effect
does not include as a limitation the challenges associated
with establishing the geological suitability of potential sites. associated with confirming the technical
suitability of potential sites (such as
This issue is an ongoing concern in the United States with schedule delays and cost impacts).
the Yucca Mountain project.
There appears to be a discrepancy in the advantages and
limitations relative to the objective for Adaptability. For
example, Adaptability was noted as being a weakness of This discrepancy should be clarified or
deep geological disposal. However, the deep geological otherwise resolved as the comparative
disposai approach had the same or higher performance analysis process continues.
value score compared to the other approaches in the
analysis of Adaptability,
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Issue .,. ~llccirrtmlll'ldatlon ..., ...,' ..'.
,. .
The sensitivity analyses conducted as part
of the NWMO's ongoing comparative
The relative strengths and weaknesses of the different analysis process should consider changes
management approaches as discussed in Discussion in key technical assumptions. (It should be
Document 2 do not provide an indication of how they might noted that the Assessment Team's
be affected by potential technical changes. sensitivity analysis addresses broader
changes in future conditions; this
recommendation is intended to apply at
more of a technical design leveL)
Social effects on communities and siting issues are not
mentioned in the limitations for reactor site storage even
though the current host communities were not selected The ongoing comparative analysis should
based on their suitability for extended storage. The analysis specifically assess the overali impact of the
notes technical limitations for at-reactor storage (such as selected management approach on the
proximity to large bodies of water), but does not note any current host communities to ensure that
social disadvantages. they are afforded the same considerations
and potential benefits as new host
Discussion Document 2 does not discretely analyze the communities,
impacts of the separate management approaches on the
current host communities,
The strengths and weaknesses noted by the NWMO in
Discussion Document 2 do not mention or appear to Relative technical and financial risks should
account for a comparative assessment of the risks related be identified and considered during the
to the different approaches. The comparative risks include
both technical risks (such as the impact of postulated ongoing detailed comparative assessments
accidents) and financiai risks (such as changes in the that the NWMO is currently performing.
assumed discount rates used in the financiai models).
Implementation Plan
Background paper 7-8 notes that any proposal to postpone The NWMO should ensure that the
implementation plans developed for the
a decision on a preferred lang-term option would itself have separate management approaches include
significant implications and may be deemed worthy of a comprehensive and specific permitting
review panel. schedules that define which permits are
required, when they are required, how long
Many of the problems and delays in the implementation of it takes to apply far and obtain them, and
major projects with significant environmental implications who has to make the application, Possible
stem from the failure to correctly identify all the required conflicts or uncertainties regarding the legal
permits and permit application requirements associated with jurisdiction of different government
a given project. agencies should be identified.
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Issue ..... ... ..... > Recommendation .,.... ..... ....... ......
..
ASL's earlier recommendation about the
Problems and delays can also stem from determined need to engage groups that focus and
opposition from one or more stakeholders (such as represent public opinion should be pursued
environmental groups or elected officials) when the EA and in recognition that they may provide
valuable information for the NWMO's
applicalions are reviewed. It should be noted that technical implementation plans in terms of identifying
issues (engineering, conceptual designs, etc.) or costs are
frequently not the critical parameters that determine a potential opposition, assessing the primary
project's success or failure, concerns of potential opponents. and
developing mitigation measures to address
these concerns.
The assessment performed by the Assessment Team is not
specific with respect to the choice of economic region for a In addition to supporting site selection, the
centralized storage facility or geologic repository, The NWMO should ensure that site-specific
NWMO's ongoing efforts will focus on developing issues and considerations are identified and
characteristics that would be appropriate in choosing addressed within the associated
specific economic regions for deep geological disposal and implementation plans.
centralized storage approaches.
As the implementation plans are developed, the resulting The NWMO should ensure that the
details could affect the comparative assessments of the comparative assessments are updated and
different management approaches performed up to that re-evaluated as required to be consistent
point. with the planned implementation details,
The NWMO should ensure that the overall
project implementation plans include key
project milestones where "go - no go"
decisions are made, as well as points where
Although a phased approach is reasonable and has designs are finalized, or "frozen," to enable
significant advantages, in ASL's experience, it has the the project to proceed with minimal potential
potential of negatively affecting the overall effective for design changes. To be able to capitalize
implementation of a project. on new technical or other advances, the
design parameters associated with the
selected management approach should be
developed and selected to maximize overall
system flexibility.
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3. METHODOLOGY
ASL's independent review was performed by a core team of consultants that have significant spent fuel
disposal experience, as well as experience in assessing the impacts of new nuclear facilities and associated
development and permitting requirements, Immediately before project authorization, a combination interview/
kick-off meeting was held between ASL and the CANHC Steering Committee to review ASL's qualifications
and to confirm the planned approach for the independent evaluation,
ASL performed a broad review of Discussion Document 2 with the overall objective of identifying questions
that are not currently being asked by either the NWMO or others reviewing the NWMO's process, The intent of
the review was to identify key issues and areas that we recommend CANHC focus on as 1he NWMO continues
in their process.
During the project interview/kick-off teleconference, ASL and CANHC discussed several questions and
comments that provide further depth to the issues and supplement the questions included in Discussion
Document 2, ASL utilized these questions during its review of the document to provided focus on the key issues
relative to the current host communities, These questions and issues are summarized below:
. Assessment Framework
Is the assessment framework comprehensive and balanced?
Are there gaps, and if so, what should be added to 1he assessment framework?
How can the NWMO reconcile the apparent preference of Canadians to "keep an eye on
the waste" and the apparent preference of the scientific community for deep geological
disposal?
Do the various management approaches adequately address the possibility that the waste
could be retrieved?
. Management Approaches
What are our thoughts on the strengths and weaknesses of each management approach:
deep geological disposal, centralized storage, and reactor site storage?
Focus on the impact on the existing site communities.
. Implementation Plan
Are there specific elements that we believe must be built into an implementation plan?
What are our thoughts on what a phased approach must include?
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If the NWMO recommends an approach that involves relocating the waste, the ability of
that approach to be implemented must be addressed, given social and political realities.
Otherwise, onsite storage will become, by default, the selected management approach.
Whether or not a phased approach to implementation is adopted, the waste will remain at
the existing sites for a number of years. Therefore, the interest of the existing host
communities must be considered when developing an implementation plan,
In addition to considering these questions and comments, ASL reviewed the NWMO's process, including its
assessment framework, management approaches, and implementation plan, in consideration of the types of
environmental screening and permitting processes used for other major projects.
ASL did not review each of the documents referenced in Discussion Document 2 as part of our independent
peer review, as this depth of review is beyond the scope of our independent peer review. However, we reviewed
certain documents in some detail and did review the types and subjects of documents relative to the context of
Discussion Document 2 and the questions and comments used to guide our review. For example, our review of
the list of background papers developed by the NWMO regarding certain topics, such as Guiding Concepts,
provides an indication of how thoroughly the NWMO has addressed that particular topic. Selected reference
documents were reviewed in more detail as appropria1e to address the key questions and comments used to
guide the independent peer review.
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4. DETAILED EVALUATION RESULTS
4.1 OVERVIEW OF DISCUSSION DOCUMENT 2 / UNDERSTANDING THE CHOICES
Discussion Document 2 contains the following elements:
. Part I / Foundations of the Assessment
Chapter I / Introduction
Chapter 2 / Understanding Canadian Values
Chapter 3 / Reporting Back
. Part 2 / A Preliminary Comparative Assessment
Chapter 4 / Choosing and Describing An Assessment Approach
Chapter 5 / An Assessment
. Part 3 / Towards a Management Approach
Chapter 6 / A Responsive Framework
Chapter 7 / NWMO's Work Continues
Chapter 8 / Engaging Canadians
. Appendices
Appendix I / Profile of the NWMO
Appendix 2 / Engagement Activities
Appendix 3 / NWMO Background Research
Appendix 4 / Screening Rationale for Methods of Limited Interest
Appendix 5 / Glossary
Building on Discussion Document I, Part I of Discussion Document 2 reports on the NWMO's further
exploration of the values and priorities of Canadians and presents insights from the dialogues convened in
Discussion Document I, "Asking the Right Questions." Part 2 provides a fuller description of the approaches
that the NWMO will now focus on for the study. Part 3 "takes stock" of what the NWMO has learned to date
and identifies a path forward for the next phase of the NWMO's study. The Executive Summary of Discussion
Document 2 is included in Appendix F of this report to provide a more detailed summary of the document. In
addition, as noted earlier, ASL developed the Reference Table in Appendix D that lists the web sites referenced
in Discussion Document 2 along with the related files posted on the web. This table summarizes the
information that the NWMO has developed so far in its study and provides an indication of how they have
addressed the issues and questions raised so far in the process. The web links noted in Appendix D are listed in
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the order they are referenced in Discussion Document 2 (it should be noted that some web sites are referenced
multiple times, and so are repeated in the reference table to denoted the references made in each section of
"Understanding the Choices").
4.2 ASSESSMENT FRAMEWORK
4.2.1 General Discussion
The current assessment framework is derived from the original ten questions discussed in the NWMO's
Discussion Document 1, "Asking the Right Questions." To help with the comparative analysis of alternate
approaches, the NWMO put together a multi-disciplinary Assessment Team and asked them to develop an
assessment framework based on the ten questions posed in Discussion Document 1. The NWMO Assessment
Team issued its report in June 2004,
Based on the NWMO's engagement with Canadians and its research and analysis activities, the Assessment
Team converted the original ten questions into eight objectives and associated guiding principles and
influences, which comprise the assessment framework. The discussion in Part 2 of Discussion Document 2 is
hased on the Assessment Team's report. The original ten questions are summarized below:
1, Does the management approach have a foundation of rules, incentives, programs, and
capacities that ensure all operational consequences will be addressed for many years to come?
2, Does the management approach provide for deliberate and full public engagement through
different phases ofthe implementation?
3. Have aboriginal perspectives and insights informed the direction and influenced the
development of the management approach?
4, Is the process for selecting, assessing, and implementing 1he management approach one that is
fair and equitable to our generation and future generations?
5. When considered together, do the different components of the assessment suggest that the
management approach will contribute to an overall improvement in human and ecosystem well-
being over the long-term?
6. Does the management approach ensure that people's health, safety, and well-being are
maintained (or improved) now and over the long-term?
7, Does the management approach contribute adequately to human security? Will it result in
reduced access to nuclear materials by terrorists or other unauthorized agents?
8. Does the management approach ensure the long-term in1egrity of the environment?
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9. Is the economic viability of the management approach assured and will 'the economy of the
community (and future communities) be maintained or improved as a result?
10. Is the technical adequacy of the management approach assured and are design, construction and
implementation of the method(s) used by it based on the bes1 available technical and scientific
insight?
The current objectives developed by the Assessment Team are summarized below:
. Fairness. Capacity to ensure fairness in the distribution of costs, benefits, and risks: process
and substance.
. Public Health and Safety. Capacity to ensure public health and safety.
. Worker Health and Safety. Capacity to ensure worker health and safety
. Community Well-being. Capacity to ensure community well-being
. Security. Capacity to ensure security of materials, facilities, and infrastructure
. Environmental Integrity. Capacity to ensure environmentai integrity
. Economic Viability. Capacity to ensure economic viability
. Adaptability. Capacity to adapt to changing conditions over time.
The relationship between the original ten questions and the eight objectives of the current assessment
framework is shown in Figure 4-5 of Discussion Document 2, "Elements of the Objectives Hierarchy Plotted
Against the Original Ten Questions."
4.2.2 Comprehensiveness and Balance
The process used to derive the current framework, as described in Discussion Document 2, is considered to be
reasonable and appropriate and is supported by the documents referenced in the discussion document.
Although ASL believes that the assessment framework is generally comprehensive, we identified potential gaps
in the assessment framework as it is described and used in Discussion Document 2. One potential gap relates to
the potential political climates that may exist during the decision and implementation phases of the management
approaches, The Assessment Team report notes that a practical strategy for implementing an overall
management approach must take the political climate into account, and that this factor is outside the scope of
the Team's assessment, Jfthe political climate does not support making a decision or implementing a decision,
then, by default, the used fuel will likely remain at the current sites, It was not clear from our review of
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Discussion Document 2 and the NWMO's background papers whether this factor and related strategies are
assessed by the NWMO,
Another potential gap in the assessment framework that was noted in the Assessment Team's report is related to
contingency planning. The Assessment Team notes that 'The assessment suggests it will be necessary to
ensure. . . that contingency plans are known and available should they be required, at least for the period in
which active management of the waste is needed to ensure safety," Again, it was not clear from our review of
Discussion Document 2 and the NWMO's background papers whether this factor and related strategies are
assessed by the NWMO.
In addition to these gaps, it is not clear how the relative importance or priorities of the eight objectives will be
addressed when assessing the different management approaches. In Figure 4-5 of Discussion Document 2, the
original ten questions and eight current objectives are characterized as all having equal importance (i.e" the
order in which they are listed does not imply a prioritization of concerns). In the Assessment Team's report,
however, the Assessment Team notes that it used different weights to explore trade-offs between 1he different
objectives based on competing values and preferences identified during the NWMO's engagement activities. As
noted in Section 5.2 of the Assessment Team's report, these competing values include the following:
. Security vs, Accessibility
. Remote location vs. Minimal handling and transportation of waste
. Assume responsibility today vs. Provide flexibility for future generations
. Making a decision vs. Managing uncertainty
The Assessment Team's report presents the results of1heir analysis in the form of composite scores and does
not seem to consider fatal flaws (that is, an issue or problem that would exclude a particular option from further
consideration). For example, the composite scores of the onsite storage options relative to the objectives of
Pubic Health and Safety and the objective for Security, beyond 175 years, both include a performance value
score of zero in their ranges, This indicates that at least some on the Assessment Team may have considered
these options to untenable; however, without a consideration of fatal flaws, this would only have the affect of
broadening the range of scores as opposed to initiating a more significant assessmen1 of these options.
The Assessment Team indicated that changing the weighting used in the assessment as part of their
methodology provides a sensitivity analysis that indicates whether different levels of importance for different
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issues impact the ranking of the management approaches, In ASL's opinion, this type ofsensi1ivity analysis is
important and necessary to fully evaluate the different approaches and confirm tha1 the assessment framework
is balanced, The Assessment Team report indicates the magnitude of the relative weights used in its assessment
ofthe overall objectives, but not for the specific influence variables associated with each objective,
In summary, ASL believes that the assessment framework is generally comprehensive but cannot determine
how balanced it is. The NWMO should provide explanations of how political climate, contingency planning,
fatal flaws, and relative importance of the objectives and specific influence variables were considered, so that it
is possible in future work to determine whether the assessment framework is balanced, The NWMO should also
explore the potential effect of fatal flaws,
4.2.3 Engagement
The NWMO has openly described its methods and framework and has actively solicited a wide range of input
on its work, The NWMO's engagement activities were designed to establish an informed dialogue with the
following communities of interest (reference the NWMO's Engagement Plan, dated June 10,2003):
. Canadian public at large
. Governments (federal, provincial, local/municipal, aboriginal)
. Residents and representatives from communities with current storage sites
. Communities that might be affected in future (through storage or transportation)
. Non-profit and non-governmental organizations from civil society (health, social sciences,
energy, environment, faith, professional societies, culture, education, development, civil rights,
labor, etc.)
. Business interests
. Nuclear energy corporations
. Individuals who have any interest in nuclear waste management and/or who have an area of
relevant expertise
. The NWMO
Based on the references cited in Discussion Document 2, the NWMO has achieved a wide range of engagement
in accordance with its plan. A recent e-dialogue coordinated by Royal Roads University (reference Group #1 on
November 29, 2004), however, identified a potential gap in the communities engaged by the NWMO, The
engagement activities have not been designed to, nor have they achieved, consulta1ion with groups that focus
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and represent public opinion, such as nuclear awareness groups or environmental groups. This perspective is
confirmed by our review of the engagement documents posted on the web by the NWMO, which do not appear
to include input from these types of groups,
These groups may have specific agendas that may be counter 10 the NWMO's ultimate objective to implement a
management approach once the Canadian government makes a decision based on the NWMO's
recommendation, Accordingly, ASL believes that the NWMO should specifically solicit the input from these
types of groups, In addition, or alternatively, the NWMO should develop an assessment ofthe positions of these
groups, the influence they may exert on the process, the impact this influence could have on the recommended
management approach, and what can be done to gain their input or otherwise address their positions.
4.2.4 Timing
Based on the progress made by the NWMO to date, as measured against the timeline established by the NWMO
to complete the study, the three-year duration allotted by the NFW A is technically sufficient to develop a
recommended management approach, Figure 8-1 in Discussion Document 2, "NWMO Study: A Process of
Interactive Engagement," summarizes the NWMO process and timeline, It should be no1ed that this process and
timeline are consistent with the NWMO's Engagement Plan, issued in June 2003, and the document "NWMO
Approach to Development of Analytical Framework," issued in July 2003.
Discussion Document 2 includes the estimated duration for implementing each of the three primary
management approaches, as noted below:
Table 4-1 - Key Activity Durations of the Main Management Approaches
Estlmat,lIllDuratlon for Estimated Duration for
Management Approach Sititill&:Approvals Dasilln and Construction
Reactor site extended storage 5 years 5 years
Centralized storage 10 years 10 years
Deep geological repos itory 10 to 15 years 10 to 15 years
The existing industry experience with the three main management approaches support the three-year time
allowed for the NWMO to develop a recommended approach and for the estimated duration of the design and
construction phases, The Joint Waste Owner Overview Documentation (see Appendix G) indicates that Atomic
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Energy of Canada Limited (AECL) and Ontario Power Generation began to investigate various options for dry
storage in the 1970s and that AECL has more than 25 years of experience with dry storage systems, This paper
also notes that centralized extended storage systems are already operational in 12 countries and used over a
wide range of circumstances from providing common temporary storage for used fuel from a few reactors to
providing a fully centralized management system for used fuel at the national level. While uncertainties exist
related to the long-term performance of deep geological repositories, many countries support the concept,
including Sweden, Italy, Spain, Japan, China, and the United States, among others. The design concept for deep
geological repository for used CANDU fuel was developed by AECL during the period 1978-1996 as part of
the Canadian Nuclear Fuel Waste Management Program.
It should be noted that the actual time required to gain social acceptance of the recommended approach and
corresponding implementation and overall schedule for the selected management approach will be determined
at least in part by the political climate, adding importance to the need for the NWMO to assess the impact of
potential political climates as discussed earlier.
4.2.5 "Keeping an Eye on the Waste"
CANHC requested ASL to assess how the NWMO can reconcile the apparent preference of Canadians to "keep
an eye of the waste" and the apparent preference of the scientific community for deep geological disposal. In
our opinion, this can be achieved within the assessment framework that the NWMO has established and by
utilizing the multi-attribute utility analysis that the Assessment Team adopted. As the name of this analytical
method implies, this type of analysis takes several factors into account related to each objective, For example,
the influence diagrams shown in Chapter 5 of Discussion Document 2 show the factors included in the
Assessment Team's analyses, Accordingly, factors related to "keeping an eye on the waste" can be incorporated
into ongoing assessments of the different options, For example, the objectives of Fairness, Community Well-
Being, Security, and Adaptability may all be influenced to a certain extent by this factor.
The NWMO is taking steps to evaluate the need to assess the issue of monitoring the waste. For example, the
NWMO has assessed monitoring waste in Background Paper 3-5, issued in November 2004. This paper noted
that the selected used nuclear fuel management system, whether a deep geological repository or an extended
storage system, will require monitoring. The purpose of the paper was to develop a risk-based monitoring
framework for used fuel management approaches. This was carried out in two steps:
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. First, the various management methods were reviewed to estimate potential risks at each stage
of their development.
. Second, the results of the review were used to develop, at a conceptual level, a monitoring
framework that focuses on the main areas of potential risk.
The paper identified several gaps in the risk estimates and its documentation, but indicated that none of them
affect the paper's overall conclusions. The paper recommends that the gaps need to be addressed as part of the
implementation of the approach selected by the Canadian govermnent.
Another aspect of "keeping an eye on the waste" was identified during the e-dialogues coordinated by Royal
Roads University (reference Group #3 on November 29,2004). In essence, a comment was made that a reactor
site storage (or, to a more limited extent, centralized storage) kept the issue and societal costs of nuclear waste
more visible, and so provides an impetus for reducing the generation of this type of waste. The comparison was
made to trash along the side of a road: if disposed in a landfill and out of sight, there is less of a constant
reminder of the overall costs associated with creating the trash. This perspective would not necessarily be
addressed by a technically focused comparative analysis of the potential management approaches, and so
highlights the value of the multi-attribute utility analysis used by the NWMO. This perspective could
significantly affect the current host communities due to its bias towards reactor site storage, and so should be
addressed as the NWMO moves closer towards making a recommendation.
In summary, the NWMO is evaluating monitoring requirements and is using appropriate analytical tools that
can reconcile requirements with competing objectives. Moving forward, it will be important for CANHC to
review the final phases of the NWMO study to ensure that these factors are given proper weight (as discussed
earlier in this review), that the technical details of the selected management approach address this issue, and
that broader social values and motives (such as keeping used fuel disposal highly visible) are considered. As
part of the engagement process, the NWMO should consider establishing focus groups to identify specific
concerns that people may have with "keeping an eye on the waste" (i.e., technical or social) and to support fully
addressing this issue.
4.2.6 Retrievability
The three primary management approaches required to be considered are summarized in Appendix G, which is
a copy of the Joint Waste Owners Conceptual Designs Overview paper as posted on the NWMO's web site. Of
the three approaches, Reactor Site Extended Storage and Centralized Extended Storage include assumptions
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that the waste wiJI be repackaged. Accordingly, for these two approaches, the NWMO has addressed the
possibility that the waste could be retrieved. The third approach, the deep geological repository concept, does
not explicitly identify the assumption that the waste will either be repackaged or retrieved. The base assumption
for deep geological disposal, instead, is that the facility wiJI be decommissioned after a certain period of
operations and monitoring. This approach requires that the used fuel containers be retrievable during the pre-
closure phase, but it does not address retrievability after the facility has been decommissioned. The design
concept includes backfilling around the spent fuel disposal containers, which would hinder the ability to
retrieve the spent fuel if required.
In summary, the used nuclear fuel is retrievable in the two storage approaches, but by design is not retrievable
in the disposal approach after the site is decommissioned (closed). Discussion Document 2 does not fully
address this issue, nor is it fully addressed in "Assessing the Choices." For example, retrievability is a factor in
the "Adaptability" influence diagram, but the performance value scores for the deep geological disposal
approach are approximately the same as for the other approaches. ASL believes that the NWMO should more
fully address this issue as it develops more detailed comparative analyses.
4.3 MANAGEMENT APPROACHES
4.3.1 General Discussion
The table below summarizes the management approaches that the NWMO has identified and considered to
date:
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Table 4.2 - Summary of Management Approaches Considered by the NWMO
Methods Requiring Review Methods Receiving
(Mandated by NFWA) International Attention Methods of Limited Interest
Deep Geological Disposal in the Reprocessing, Partitioning, and Direct Injection
Canadian Shield Transmutation
Rock Melting
Storage at Reactor Sites Storage or Disposal at an Sub-Seabed Disposal
International Repository
Centralized Storage Above or
Below Ground Emplacement in Deep Boreholes Disposal at Sea
Disposal in Ice Sheets
Disposal in Subduction Zones
Disposal in Space
Dilution and Dispersion
Source: Table 3-1, Potential Technical Methods, in Discussion Document 2
Appendix G of this review paper contains overview documents prepared by the Joint Waste Owners for the
NWMO that describe the management methods in more detail; they are included to facilitate the reader's
reference. The NWMO has developed conceptual designs, cost estimates, transportation requirements, and
preliminary project timelines for each of the main management approaches, which can be accessed on the
NWMO's web sitc. as noted in Appendix C. The conceptual designs and cost estimates are intended to provide
sufficient detail to confirm the engineering feasibility of the management approaches to support the current
phase of the NWMO's study, which is appropriate. The timelines shown for each of the approaches in
Discussion Document 2 allow for detailed design and construction ofthe selected facilities.
The NWMO has arranged for independent reviews of these technical evaluations. Overall, the NWMO noted in
Discussion Document 2 that these third-party reviews concluded that the designs are reasonable and feasible,
that the cost estimates have been prepared in accordance with appropriate estimating methodology, and that the
technical infonnation as a whole is suitable for the options review and directional decision-making
requirements ofthe NWMO.
The methods receiving international attention were presented for comment in the NWMO's Discussion
Document I. In "lJndcrstanding the Choices," the NWMO reports that "For the most part, Canadians indicated
that these methods should not receive detailed study at this point, although it would be appropriate to maintain a
"watching-brief" on these methods." The Assessment Team's report, "Assessing the Choices," provides the
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specific reasons that these methods were screened out (see Section 3.2.2). However, the Assessment team noted
that "Canada may wish to maintain some interest in each of these options by undertaking research and/or
tracking related international developments."
The methods of limited interested are described in Discussion Document 2's Appendix 4. The NWMO is not
actively pursuing these methods further based on the screening rationale presented in Appendix 4.
4.3.2 Strengths and Weaknesses
The Assessment Team analyzed each of the three main management approaches within the current assessment
framework. The resulting relative strengths and weaknesses of each approach is summarized in Figure E-lin
Discussion Document 2's Executive Summary (provided in Appendix F of this report to facilitate reference).
The following table summarizes the advantages and limitations that the NWMO has identified for each of the
main management approaches:
Table 4-3 - Key Strengths and Weaknesses of the Main Management Approaches
Management Approach Key Advantage$ .i ... ... KeyL.illlitatiol'ls
At-Reactor Storage No transportation of spent nuclear fuel There will be need for continuing
is required administrative controls and operations,
There is nuclear expertise at the including necessary funding, for
thousands of years
existing sites and communities
The ability to monitor performance The reactor sites were selected for their
suitability for reactor operation, not fuel
and flexibility to adapt to changing storage (for example, their proximity to
conditions should be facilitated large bodies of water is needed for
Required technologies are already reactor operations, but is not needed
deveioped and may be a liability for fuel storage)
Centralized Storage Site selection could be made solely on There will be need for continuing
the basis of used nuclear fuel administrative controls and operations,
management including necessary funding, for
If done well, siting can be achieved thousands of years
with community participation Site selection would result in potentially
Some security concerns could be contentious community involvement
abated Transportation of spent nuclear fuel is
Required technologies are already required
developed
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Management Approach Key Adv;mtages ..................... Kllyi.;hllltlltij)I'IS ..
.. ...........
Deep Geological The eventual permanent Advance "proof' that the system would
Repos itory emplacement of used nuclear fuel work is not scientifically possible
would reduce or eliminate the because performance is required over
necessity for long-term institutional thousands of years'
and operational continuity and Monitoring is more difficult as compared
financial surety.
to the other options as the site is
Site selection could be made solely on backfilled and closed.
the basis of used nuclear fuel
management Adaptability and flexibility are reduced
because retrieval of the used fuel
If done well, siting can be achieved becomes more difficult.
with community participation Site selection would result in potentially
Security concerns could be abated contentious community involvement
Transportation of spent nuclear fuel is
required
. Although the systems do not have proof, the Assessment team, in its report "Assessing the Options:' notes that the
conceptual design developed on behalf of the Joint Waste Owners for a deep geological repository facility (DGR)
provides sufficient detail to confirm the engineering feasibility of a DGR and to allow preparation of a conceptual cost
estimate for its implementation.
The weighting of the different objectives and corresponding factors used in the ongoing comparative
assessment process will affect the relative strengths and weaknesses. Accordingly, it wilI be important to review
potential changes in the relative strengths and weaknesses as the comparative analysis process continues.
The site selection process for deep geological disposal does not note limitations associated with establishing the
geological suitability of potential sites. Based on the experience in the United States with the Yucca Mountain
project, consideration should be given to the effect associated with confirming the technical suitability of
potential sites (such as schedule delays and cost impacts).
There appears to be a discrepancy in the advantages and limitations relative to the objective for Adaptability.
The ability to monitor performance and flexibility to adapl'to changing conditions was noted as being a relative
advantage for at-reactor storage, but was not mentioned for centralized storage. We believe these same factors
should be listed as an advantage for centralized storage. In addition, Adaptability was noted as being a
limitation for deep geological disposal, which is consistent with its technical details. However, the deep
geological disposal approach had the same or higher performance value score compared to the other approaches
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in the analysis of Adaptability. This discrepancy should be clarified or otherwise resolved as the comparative
analysis process continues.
The relative strengths and weaknesses of the different management approaches as discussed in Discussion
Document 2 do not provide an indication of how they might be affected by potential technical changes.
Although the Assessment Team's report lists basic assumptions used for conceptual designs, there is no
sensitivity analysis of what would happen if there were significant changes in cost or design parameters as these
assumptions are validated during the detailed design stage for the selected approach. For example, what would
be the effect of a change in the volume of spent nuclear fuel requiring disposal because reactor operating life is
extended or shortened? Does the design or costs significantly change? It may be an advantage if one of the
approaches was shown to be less sensitive to potential design changes.
One of the limitations (weaknesses) noted for centralized storage and deep geological storage is the effect on
communities and siting issues; however, these are not mentioned in the limitations for reactor site storage even
though the current host communities were not selected for extended storage. The analysis notes technical
limitations for at-reactor storage (such as proximity to large bodies of water), but does not note any social
disadvantages. This issue also does not seem to be addressed by any of the NWMO's background papers
(especially in reference to the papers regarding Social and Ethical Dimensions).
The strengths and weaknesses noted by the NWMO in Discussion Document 2 do not mention or appear to
account for a comparative assessment of the risks related to the different approaches. The comparative risks
include both technical risks (such as the impact of postulated accidents) and financial risks (such as changes in
the assumed discount rates used in the financial models). Similar to the potential advantage (or disadvantage)
for an approach to accommodate changes in the technical assumptions (discussed above), an approach may
have a relative strength (or weakness) ifit can accommodate these types ofrisks better (or worse) than the other
approaches. This issue should be considered during the ongoing detailed comparative assessments that the
NWMO is currently performing.
4.3.3 Impact on Current Host Communities
The assessment framework considers the impact of the management approaches on new host communities;
however, Discussion Document 2 does not discretely analyze the impact of the separate management
approaches on the current host communities. The NWMO's list of background papers as shown in Appendix E
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also does not include a paper on the impact on current host communities. Accordingly, the overall impact of the
selected management approach on the current host communities has to be assessed by evaluating how the
current host communities fit into the definitions of the new communities that will be affected by the selected
management approach. Specifically, in the report "Assessing the Options," the Assessment Team notes that:
It is vital to consider what would lead a community to agree to having a used nuclear fuel facility
with in its boundaries. . The siting policy may also include benefits to a host community to
compensate that community for taking on the burden associated with used nuclear fuel while a
much wider population shares the benefits.
Considering that the current host communities are listed as a strength associated with the reactor site extended
storage approach, the benefits to the wider population may even be magnified if the current host communities
evolve into becoming the ongoing used nuclear fuel storage communities. It would seem appropriate to ensure
that the current host communities are afforded the same considerations and potential benefits as new host
communities within the ongoing assessment process. This would be especially appropriate if a decision relative
to which management approach to use is not made, or if the decision cannot be implemented, so that the current
host communities become the storage communities by default.
4.4 IMPLEMENTATION PLAN
4.4.1 General Discussion
The NFW A states that the selected management approach will be implemented by the NWMO "subject to all of
the necessary regulatory approvals." Discussion Document 2 notes that the NWMO will be focusing on
implementation plans as their study moves forward and that implementation is a critical part of making a
recommendation. As stated in Discussion Document 2:
The NWMO is persuaded of the critical importance of mapping out specific plans for implementing
any course of action. The manner in which any approach is implemented will affect the
effectiveness and the extent to which it is responsive to societal needs and concerns.
We believe that how any approach is implemented will be every bit as important as which
approach is selected.
The NWMO notes that the development of implementation plans will include, at a minimum, consideration of
the following elements:
. Oversight and monitoring systems
. Ongoing societal involvement
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. Institutional design, including human resource capacity
. Ownership and liability
. Dispute management
. Principles to guide site selection; and
. Education and information programs.
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In Discussion Document 2, a preliminary implementation plan is addressed for each primary management
approach as summarized below (the costs estimates are also noted for reference):
. Reactor Site Extended Storage
Siting and Approvals
Design and Construction
Operations
Monitoring
Building Refurbishments and Repackaging
Costs: Total to be Spent (2002 $)
Costs: NPV of total to be spent (2004 $)
. Centralized Storage
Siting and Approvals
Design and Construction
Transportation and Operations
Monitoring
Building Refurbishments and Repackaging
Costs: Total to be Spent (2002 $)
Costs: NPV oftotal to be spent (2004 $)
. Deep Geological Disposal
Siting and Approvals
Design and Construction
Transportation and Operations
Monitoring
Decommissioning
Costs: Total to be Spent (2002 $)
Costs: NPV oftotal to be spent (2004 $)
5 years
5 years
35 to 40 years
Ongoing
10 year duration, done every 300 years
$17.6 - $25.7 billion / 300-year cycle
$2.3 - $4.4 billion / 300-year cycle
10 years
10 years
25 to 40 years
Ongoing
Variable duration, done every 300 years
$15.7 - $20.0 billion/ 300-year cycle
$3.1 - $3.8 billion / 300-year cycle
10 to 15 years
10 to 15 years
25 to 40 years
70 years (maximum assumed for costs)
25 years
$16.2 billion
$6.2 billion
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These timelines were assessed in more detail in the Assessment Team's report based on the conceptual design
papers developed by the NWMO.
4.4.2 Specific Needs for Implementation Plans
Siting and approvals is a significant phase of each of the management approaches. As noted above, the NFW A
requires that the selected approach be implemented in accordance with all the necessary regulatory approvals.
The Assessment Team's report notes that the overall management of spent fuel in Canada is politically
complicated. Under the Canadian constitution, energy policies and land management that involve the
production of spent fuel are responsibilities of the provincial governments, while management of radioactive
materials is the responsibility of the federal government.
The NWMO has started to assess the regulatory framework within which the selected approach will be
implemented. The NWMO documents related to this issue include Fact Sheet 4, "The Canadian Regulatory
Framework," background paper 7-8, "Review of the Canadian Environmental Assessment Act (CEAA) Process
in Relation to Nuclear Waste Management," and background paper 7-9, "Review of the CNSC Licensing
Process in Relation to Spent Fuel Management."
Background paper 7-8 discusses the four basic types of environmental assessments in the CEAA and their
associated level of detail summarized as follows:
. Screening. Minimum level of EA required, although some screenings can be reasonably
detailed.
. Comprehensive Study. Next level, requires more detail.
. Review panel. More formal EA involving experts appointed by Minister of Environment.
. Mediatiou. Infrequently used voluntary process of EA negotiation in which an independent
mediator (usually appointed by Minister of Environment) helps interested parties resolve their
issues.
The following table summarizes which types of environmental assessments are anticipated to be applicable for
the separate management approaches as discussed in background paper 7-8 (reference pages 5 and 6).
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Table 4-4 - Anticipated Environmental Assessments for the Main Management Approaches
An.ticipatedLIi..quire~~of
EnvironmentalA$sessment
Implications for the NWMO
ManagementApproach
Deep Geological Disposal
Review panel
Would theoretically start as a comprehensive
study.
Would theoretically start as comprehensive
study, but extensive transportation requirements
would likely dictate the need for a review panel.
A screening would be required if the proposed
project were to fall within the boundaries of the
currently licensed facility.
If the project were to include areas outside the
existing boundaries of the nuclear facility, a
"comprehensive study" would be required.
"Any proposal, however, to postpone a decision
on a preferred long-term option would itself
have significant implications and may be
deemed worthy of a review panel."
Centralized Storage
Review panel
Reactor Site Extended
Storage
Screening or comprehensive
study
In ASL's opinion, many of the problems and delays in project implementation stem from the failure to correctly
identify all the required permits and permit application requirements associated with a given project.
Accordingly, the NWMO should ensure that the implementation plans developed for the separate management
approaches include comprehensive and specific permitting schedules that define which permits are required,
when they are required, how long it takes to apply for and obtain them, and who has to make the application.
Possible conflicts or uncertainties regarding the legal jurisdiction of different government agencies should be
identified.
Problems and delays can also stem from determined opposition from one or more stakeholders (such as
environmental groups or elected officials) when the EA and applications are reviewed. Getting stakeholders
involved early in the project sometimes can eliminate determined opposition by allowing key concerns to be
addressed in the basic project design.
ASL's earlier comments about the need to engage groups that focus and represent public opinion should be
pursued in recognition that they may provide valuable information for the NWMO's implementation plans in
terms of identifying potential opposition, assessing the primary concerns of potential opponents, and developing
mitigation measures to address these concerns. It should be noted that technical issues (engineering, conceptual
PSD-(}07-D5 - Attachment 1/121304
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designs, etc.) are frequently not the critical parameters that determine a project's success or failure. Cost is also
not necessarily the critical parameter; as noted in "Assessing the Options" (Section 3.6.9), "The least expensive
method is not necessarily the wisest choice if it does not meet other public policy objectives and cannot be
successfully sited."
"Assessing the Options" (Section 3.6.10) notes that the Assessment Team's analysis covers only general
considerations regarding how communities respond to the issue of site selection and recognizes that different
communities may have very different attitudes. The assessment performed by the Assessment Team is not
specific with respect to choice of economic region for a centralized storage facility or geologic repository.
Discussion Document 2 recognizes this and notes that the NWMO's ongoing efforts will focus on developing
characteristics that would be appropriate in choosing specific economic regions for deep geological disposal
and centralized storage approaches. In addition to supporting site selection, the NWMO should ensure that site-
specific issues and considerations are identified and addressed within the associated implementation plans.
As the implementation plans are developed, the resulting details could affect the comparative assessments of
the different management approaches performed up to that point. Accordingly, the NWMO should ensure that
the comparati ve assessments are updated and re-evaluated as required to be consistent with the planned
implementation details.
4.4.3 Phased Approach
Discussion Document 2 indicates that taking a staged approach is important based on the dialogues conducted
to date. A staged approach is seen as building adaptability into the selected management approach, regardless of
which one is chosen. Staging provides for reviews and adjustments, and supports continuous learning and the
ability to incorporate new technical developments (such as improvements in design and operational
requirements). A phased approach to implementing one of the main management approaches would also enable
monitoring of emerging options that have been screened out to date, such as partitioning and transmutation.
Although a phased approach is reasonable and has significant advantages, in ASL's experience, it also has the
potential of negatively affecting the overall effective implementation of a project. For example, a phased
approach includes the potential for cost overruns and schedule delays resulting from changes in the design of
key components in an attempt to incorporate ongoing technical developments. There is also potential for the
project scope to increase, which could increase the project's overall schedule and cost, based on additional
PSD-007-0S - Altachmcnll/l2\J04
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analyses to evaluate new alternatives (occasionally referred to as "analysis paralysis"). To avoid this during the
staged approach, the NWMO should ensure that the overall project implementation plans include key project
milestones where "go - 110 go" decisions are made, as well as points where designs are finalized, or "frozen," to
enable the project to proceed with minimal potential for design changes. To be able to capitalize on new
technical or other advances, the design parameters associated with the selected management approach should be
developed and selected to maximize overall system flexibility. For example, instead of designing a centralized
storage facility for the entire planned inventory of used nuclear fuel during the initial phase of the project (as
shown in the Discussion Document 2 timelines), it may be beneficial to perform the design in phases.
Hypothetically, the initial phase could account for 50% of the planned inventory, while the remaining 50% is
designed after the facility is operational (several years later). The design for the second 50% would then be able
to incorporate the latest information and technology available at that time with minimal impact on the
implementation timeline for the first 50%.
Last page of Section 4.
PSD-007-05 - Attachment 1/121304
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ATTACHMENT 2
,
Report PSD-007-o5
NUCLEAR WASTE MANAGEMENT ORGANIZATION
QUESTIONS ASKED IN FIRST DISCUSSION DOCUMENT
Question 1
Over-Arching Aspects
Institutions and Governance
Does the management approach have a foundation of rules, incentives, programs and capacities that ensure
all operational consequences will be addressed for many years to come?
Question 2 Engagement and Participation in Decision-Making
Does the management approach provide for deliberate and full public engagement through different phases
of implementation?
Question 3 Aboriginal Values
Have aboriginal perspectives and insights informed the direction, and influenced the development of the
management approach?
Question 4
Ethical Considerations
Is the process for selecting, assessing and implementing the management approach one that is fair and
equitable to our generation, and future generations?
Question 5 Synthesis and Continuous Learning
When considered together, do the different components of the assessment suggest that the management
approach will contribute to an overall improvement in human and ecosystem well-being over the long term?
Is there provision for continuous learning?
Social Aspects
Question 6. Human Health, Safety and Well-Being
Does the management approach ensure that people's health, safety and well-being are maintained (or
improved) now and over the long term?
Question 7 Security
Does the method of dealing with used nuclear fuel adequately contribute to human security? Will the
management approach result in reduced access to nuclear materials by terrorists or other unauthorized
agents?
Environmental Aspects
Question 8 Environmental Integrity
Does the management approach ensure the long term integrity of the environment?
Economic Aspects
Question 9 Economic Viability
Is the economic viability of the management approach assured and will the economy of the community (and
future communities) be maintained or improved as a result?
Technical Aspects
Question 10 Technical Adequacy
Is the technical adequacy of the management approach assured and are design, construction and
implementation of the method(s) used in the management approach based on the best available technical
and scientific insight?
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