HomeMy WebLinkAboutPSD-107-05
REPORT
PLANNING SERVICES
Meeting: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE
Date:
Tuesday, September 6, 2005
Report #:File #: By-law #:
PSD-107-05 PLN 33.13
Subject: NUCLEAR WASTE MANAGEMENT ORGANIZATION – COMMENTS
ON DRAFT STUDY REPORT
RECOMMENDATIONS:
It is respectfully recommended that the General Purpose and Administration Committee
recommend to Council the following:
1. THAT Report PSD-107-05 be received;
2. THAT Staff Report PSD-107-05 be adopted as the Municipality of Clarington’s
comments on the Nuclear Waste Management Organization’s Draft Study Report,
"Choosing A Way Forward";
3. THAT the Independent Peer Review prepared by Acres – Sargent and Lundy
regarding the Draft Study Report prepared by the Nuclear Waste Management
Organization be endorsed;
4 THAT the NWMO be requested to specifically recognize in the Final Study
Report that the interim storage of used nuclear fuel waste at the existing reactor
sites is an integral component of Adaptive Phased Management and that the
existing host communities be considered as the first host communities in the
implementation of Adaptive Phased Management for the purposes of
compensation; and
5. THAT a copy of this Report and Council’s resolution be forwarded to the
Nuclear Waste Management Organization, the Board of Directors and Advisory
Council for the NWMO, the member municipalities of the Canadian Association
of Nuclear Host Communities, the Honourable John Efford the federal Minister
of Natural Resources, Bev Oda, M.P., and John O'Toole, M.P.P. FORTHWITH.
REPORT NO.: PSD-107-DS
PAGE 2
Submitted by:
Reviewed b~~~ '-
Franklin Wu
Chief Administrative Officer
v . Crame, M.C.I.P.,R.P.P.
Director, Planning Services
JAS/FLlDJC/df
18 August 2005
CORPORATION OF THE MUNICIPALITY OF ClARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1C 3A6 T (905)623-3379 F (905)623-0830
REPORT NO.: PSD-107-05 PAGE 3
1.0 BACKGROUND
1.1 The Nuclear Waste Management Organization (NWMO) was created by the
Government of Canada in 2002 through the Nuclear Fuel Waste Act to
investigate approaches for the long term management of Canada’s used
nuclear fuel. The NWMO is required to submit a recommended approach and
implementation plan to the Minister of Natural Resources Canada by November
15, 2005. The Minister may seek public comment on the study, or request the
NWMO to undertake further work, before providing a recommendation to the
Government.
1.2 The Act requires the NWMO to consider, at a minimum, the following three
approaches - extended storage at reactor sites; storage at a central location;
and deep geological disposal in the Canadian Shield (Atomic Energy of Canada
Limited (AECL) concept). The NWMO will be the implementing agency once a
management approach is approved by the Government and is only responsible
for the used fuel waste expected to be generated by the existing nuclear
reactors for their current design lives (approximately 3.7 million fuel bundles).
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.
1.3 The NWMO is attempting to develop 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, and has previously released two major reports for public discussion -
Asking the Right Questions (November 2003), and Understanding the Choices
(September 2004). Council submitted comments on the second report through
its consideration of Staff Report PSD-007-05 on January 10, 2005.
1.4 In late May 2005, the NWMO released its Draft Study Report, Choosing A Way
Forward. In this report, the NWMO has proposed that a fourth option, which
they have called "Adaptive Phase Management" (APM), be considered for the
long term management of Canada's nuclear fuel waste. APM is essentially the
deep geological repository option with an extended schedule that incorporates
steps and decision points that provide flexibility and adaptability during
implementation, including provision for shallow underground storage of the
waste at the central site prior to final placement in a deep repository. In addition
to the crystalline rock of the Canadian Shield previously identified, Ordovician
sedimentary rock such as that found in Southern Ontario, the St. Lawrence
valley, and the Hudson's Bay basin has also been identified as potentially
providing a suitable rock formation for the repository.
A more complete description of APM is provided in Section 2 of this report.
REPORT NO.: PSD-107-05 PAGE 4
1.5 The NWMO has indicated that, subject to further refinement based on
comments received through consultation, it will be recommending to the
Government of Canada that APM be selected as the approach for the long term
management of Canada's nuclear fuel waste. However, the NWMO will not be
recommending a specific site for the central site at that time. Rather, it will be
identifying a number of broad economic regions in Ontario, Quebec,
Saskatchewan and New Brunswick within which it intends to seek a willing host
community.
1.6 The purpose of this staff report is to give an overview of the NWMO Draft Study
Report and to provide the Municipality's comments on the report. The NWMO
has requested that comments be submitted by August 31, 2005. As such, this
report has already been forwarded to the NWMO as the Municipality’s
preliminary comments, to be confirmed by Council. Comments provided by
Acres-Sargent & Lundy (ASL) the peer review consultant retained by the
Canadian Association of Nuclear Host Communities (CANHC), have also been
incorporated into this report, where appropriate. The executive summary from
the ASL report forms Attachment 3 to this report.
2.0 OVERVIEW OF ADAPTIVE PHASED MANAGEMENT
2.1 The NWMO developed APM in response to comments made by Canadians that
this current generation should initiate the process and provide the necessary
financial resources to ensure the safe long term management of the used
nuclear fuel, that further research is required on the management and possible
re-use of the used fuel, and that future generations should make the final
determination on the final disposal of the waste. In this regard, APM is intended
to capture the strengths of the other three options while minimizing their
limitations.
2.2 APM is to be implemented in three phases, with Year 1 being that in which the
Government of Canada decides to proceed with APM. The NWMO has
cautioned however, that this projected schedule is conceptual only and may
change as the implementation process proceeds. A chart setting out the
projected timeframe and the key steps in the implementation process forms
Attachment 2 to this report.
2.3 During Phase 1 (approximately the first 30 years), the used nuclear fuel would
continue to be stored at the existing reactor sites and the NWMO would initiate
the search for a willing host community. The schedule assumes that a preferred
site would be selected in Year 10. An underground research facility would be
constructed at the central site and in Year 20, the decision would be made
whether or not to construct the shallow storage facility at the central site.
REPORT NO.: PSD-107-05 PAGE 5
2.4 Phase 2 would begin at approximately Year 30 with the start of operations at
the underground research facility where research would be conducted to
confirm the suitability of the site for the deep geologic repository for placement
in the repository. If the shallow storage facility has been constructed, the used
nuclear fuel would be transported to the central site and moved into the storage
facility. If the storage facility is not constructed, the used fuel would continue to
be stored at the existing reactor sites. Around Year 50, construction of the deep
geologic repository would begin.
2.5 Receipt of the operating license for the deep geologic repository would mark the
start of Phase 3 at approximately Year 60 and placement of the used nuclear
fuel in the repository would take place over a 30 year period. If the used
nuclear fuel remains stored at the existing reactor sites, it would be transported
to the central site. In-situ monitoring would be conducted over an extended
period (estimated to be 240 years) to confirm the long term safety and
performance of the repository, after which the repository would be backfilled
and access sealed. Post-closure monitoring would take place from the surface.
2.6 During each phase, the used nuclear fuel will be safely stored in appropriate
containers. Storage containers at the reactor sites will consist of the casks,
vaults and silos currently used in the dry storage facilities. These containers
have a design life of 50 years but are expected to last as long as 100 years.
Prior to the waste being transported to the central site, it would have to be
placed in certified transport containers. The storage containers to be used for
the shallow storage facility (if constructed) would be similar to the dry storage
containers currently being used, except with a 100 year design life. The
containers to be used for the long term isolation of the waste in the repository
would have a 100,000 year design life and would be designed to withstand long
term environmental effects such as climate change and glaciation.
2.7 The NWMO has conservatively estimated the cost of APM to be $24 billion,
including interim used fuel storage and retrieval from reactor sites,
transportation costs to the central facility, extended storage in underground
caverns, technology research and development and demonstration at the
underground research facility, and placement of the used fuel in a deep
geologic repository. These costs include the development and demonstration of
the technology to retrieve the fuel from the shallow storage facility, but not the
costs to perform retrieval operations from the deep repository. The present
value cost based on current long term economic factors is approximately $6.1
billion.
REPORT NO.: PSD-107-05 PAGE 6
3.0 DISCUSSION AND COMMENTS
Recommended Management Approach
3.1
Discussion
3.1.1 Each of the three original management options considered by the NWMO
exhibits strengths and weaknesses. For example, extended storage at reactor
sites would not require the transportation of the used nuclear fuel, but would
impose on-going responsibilities for the management of the waste for many
thousands of years at sites not specifically chosen for this purpose.
Centralized storage would provide more effective security for the waste, but
would also impose long term obligations on future generations. Deep geological
disposal would provide effective passive containment and isolation of the waste,
but would not allow future generations to retrieve the fuel if scientific advances
allow it to be safely re-used. In this regard, several factors have to be
balanced when determining the most appropriate management approach for
Canada's used nuclear fuel.
Comments
3.1.2 The Municipality agrees with the assessment undertaken by the NWMO that
none of the three original management options completely achieves the
objectives set out by the NWMO or as expressed by Canadians. The
Municipality also agrees that APM, if implemented properly and in a timely
manner, will provide a technically effective, flexible and balanced approach for
the long term management of Canada's used nuclear fuel.
3.1.3 However, the Municipality is concerned that APM can be used as an excuse to
delay the implementation of a management approach and that the waste will
remain at existing sites indefinitely and long after the existing reactors have
stopped producing electricity. This concern is supported by the NWMO's failure
to firmly commit to the construction of a shallow storage facility at the central
site in Phase 1. If this facility is not constructed, the used nuclear fuel will
remain at the existing reactor sites for up to 90 years (assuming that the
projected timeline is adhered to). Although it could be argued that, because of
the adaptability inherent in APM, it would not be appropriate to impose a
management decision on future generations, it could also be argued that a
decision not to construct the storage facility is unfair to the existing host
communities. The Final Study Report and the implementation plan need to
clearly commit to the construction of the shallow storage facility at the central
site.
REPORT NO.: PSD-107-05 PAGE 7
Difficulties With Implementation
3.2
Discussion
3.2.1 The implementation process is key to the effectiveness of any management
approach. However, there are a large number of factors that, individually and
collectively, could create significant delays in the implementation of APM.
These factors could include:
?
Failure by the Government of Canada to accept the NWMO's
recommendation within a reasonable time period (eg. within two years of
its submission). The NWMO has estimated that the internal review by
federal departments should require approximately eight months. The siting
process cannot start until this step is completed.
?
The inability of the NWMO to identify a willing host community by Year 10.
The NWMO has indicated that it is not their intention to impose a site on a
community and that they will continue with their engagement process until
a willing host community for the repository has been identified. The
NWMO hopes to learn from the experiences of Sweden and Finland who
have undertaken successful site searches for willing hosts.
?
A decision by an apparent willing host community to withdraw its consent.
Given the lengthy time frame required for the implementation of APM, it is
possible that the identified willing host community could withdraw its
consent part way through the implementation process.
?
The time required to develop the necessary knowledge regarding the
suitability of Ordovician sedimentary rock for a deep geologic repository.
Limited rationale is provided in the Draft Study Report for identifying this
rock formation as a suitable medium for a repository. Since most of the
research undertaken to date on the deep geologic repository option has
been based on the AECL concept (building the repository in the granitic
rock of the Canadian Shield), a substantial amount of time may be
required to build a similar level of knowledge for sedimentary rock, which
could create delays in the siting process.
?
Difficulty in transporting the used nuclear fuel to the central site as a result
of social protests and potential legal action. The actual transportation of
the used nuclear fuel to a central site is expected to require approximately
30 years. Whether the transportation occurs in Phase 2 or Phase 3, this
issue could prove to be one of the most problematic factors in the
implementation of APM.
REPORT NO.: PSD-107-05 PAGE 8
Comments
3.2.2 The Municipality is concerned that the very long time frame required for the
implementation of APM will make it difficult to maintain the necessary political
will to ensure that the implementation process is completed in a timely fashion.
In order to ensure that the used nuclear fuel does not remain at the existing
reactor sites for an indefinite period of time or that on-site storage becomes the
management approach by default, a detailed implementation schedule should
be developed with key milestones/decision points clearly identified, and the
Government of Canada, the waste owners and the NWMO should formally
commit to adhering to this schedule.
3.2.3 In the short term, it is imperative that the Government commit to making a
timely decision on a management approach. Failure to make such a decision
will delay the initiation of the implementation plan and the search for a host
community, and could disrupt the momentum and technical expertise that has
been built up by the NWMO over the past three years.
3.2.4 The NWMO's Draft Study Report does not specifically acknowledge the
potential for the implementation of APM to be delayed. The Final Study Report
should identify and assess the factors that may delay or defer key milestones
and decision points, and appropriate contingency plans and mitigation
measures should be articulated in the Implementation Plan. The NWMO could
also supplement its public engagement strategy in order to assess the
concerns and possible impact of potential opposition groups and develop
appropriate response strategies.
Existing Host Communities
3.3
Discussion
3.3.1 The Nuclear Fuel Waste Act requires the NWMO to address significant socio-
economic effects as part of their implementation planning. The NWMO has
confirmed that the socio-economic dimension is the key to the success of their
strategy for managing used nuclear fuel, and has committed to a process of
on-going engagement with affected communities. Sufficient resources and
information will be provided to ensure that these communities have the capacity
to participate in discussions and decision-making. The Draft Study Report
identifies five potential means to manage socio-economic effects - mitigation,
enhancement, compensation, monitoring and contingency measures, and
community liaison measures.
3.3.2 There appears to be some inconsistency regarding the role of the NWMO in
working with the current host communities as it develops its recommended
management approach and implementation plans. The Draft Study Report
clearly states that the NWMO will work collaboratively with affected
REPORT NO.: PSD-107-05 PAGE 9
communities to develop and implement the recommended management
approach, and it clearly identifies current reactor site communities as implicated
communities of interest for each of the management approach options under
consideration.
For example, in Table 4-11 of the Report, “Describing Implicated Communities
for the Four Management Approaches,” the reactor site communities are
specifically identified as communities of interest until all used nuclear fuel is
relocated. Furthermore, the cost estimates developed by the NWMO for each
of the management approaches includes the costs for socio-economic
mitigation measures such as compensation. It would appear therefore, that the
NWMO had been planning to include the current host communities in
considerations for managing and mitigating the socio-economic effects related
to the adoption of Canada’s new long-term used fuel management policy.
3.3.3 However, the NWMO has recently advised that the used fuel owners are
responsible for the interim management and storage of the used fuel, including
socio-economic effects management and mitigation. The NWMO would not
become involved in discussions or actions related to current interim storage
arrangements, and their obligations would not begin until the used fuel leaves
its current locations. Accordingly, the current host communities would need to
pursue the issue of socio-economic impact mitigation with the current fuel
owners as opposed to the NWMO.
Comments
3.3.4 The position taken by the NWMO that they have no responsibility for the used
nuclear fuel while it remains at the existing reactor sites does not recognize that
reactor site storage is integral to the success of APM. The continued safe
storage of the waste at the reactor sites for as short a period as 30 years or as
long as 90 years or beyond provides the NWMO with the assurances and
flexibility that it needs to ensure that APM is properly implemented. Indeed, the
NWMO has promoted Adaptive Phased Management as a blend of the other
three management approaches, including Reactor Site Storage. In this regard,
interim storage at the current reactor sites is the first step of Adaptive Phased
Management and the existing host communities should be considered as the
first host communities in the implementation of Adaptive Phased Management.
3.3.5 It also needs to be emphasized that the existing reactor sites were selected on
the basis of their suitability for the development of nuclear generating stations
and not for the long term storage of the used nuclear fuel. Similarly, the existing
host communities, in concurring with the interim storage of the waste on-site in
dry storage containers, did not concur with, nor did they receive compensation
for, an extended and potentially indefinite period of on-site storage. It should
be noted that AECL has been studying the issue of long term management of
used nuclear fuel since the 1970s and, since that time, deep geological
REPORT NO.: PSD-107-05 PAGE 10
disposal has been considered the most technically suitable approach.
Clarington has always anticipated that a long-term management solution for the
used nuclear fuel produced at the Darlington Generating Station would have
been built or at least approved within a reasonable time period.
3.3.6 It is imperative that existing host communities be treated fairly and equitably in
the implementation of APM. The NWMO should explicitly recognize their
importance to the successful implementation of APM, and clearly state its
intention to afford the current host communities the same considerations as a
new host community once APM is approved by the Government of Canada.
In this regard, the NWMO should specifically address the issue of
compensation and on-going peer review funding for existing nuclear host
communities.
Identifying a Willing Host Community
3.4
Discussion
3.4.1 Finding a willing host community for the long term waste management facility
within a reasonable time period is critical to the success of APM. In this regard,
the challenge facing the NWMO is unprecedented in Canada. The engagement
process with the various stakeholders and affected communities will need to be
innovative in order to keep them effectively engaged over a number of
generations. Education regarding radiation in general and nuclear waste
management specifically will be necessary in order to allow these groups to
make informed decisions and to counter the inevitable opposition that will arise.
3.4.2 A difficulty with the projected timeframe for identifying a host community
proposed by the NWMO (ie. 10 years) is that a number of important issues may
not be decided prior to the siting decision. Key among these is the volume of
waste that will be accepted at the new management site. The NWMO has
indicated that it will only deal with the used nuclear fuel from existing reactors.
3.4.3 The Municipality agrees that a decision on the long term management of this
waste cannot wait until the broader issues related to energy policy and the
future of nuclear power are decided. However, it should also be recognized
that a siting decision made in the absence of this important information may not
be fair to not only the potential host community, but other affected communities
as well. Given the cost, time and complexity involved with the current NWMO
process, it is reasonable to expect that used fuel waste from any new nuclear
generating stations will eventually be moved to an existing long term
management facility.
3.4.4 A comparable situation is faced by existing host communities. At the time the
decision was made to build the nuclear stations, these communities were not
aware that the used nuclear fuel would be stored at the reactor sites for a
REPORT NO.: PSD-107-05 PAGE 11
potentially indefinite period. Continuing refurbishments could extend the
projected operating lives of the generating stations, thereby adding to the
stockpile of used fuel waste that must be safely stored on-site and eventually
moved to a long term management facility. Therefore, it is important that any
potential host community be fully aware of the implications of accepting a long
term management facility for used nuclear fuel.
Comments
3.4.5 The NWMO should commit to providing the necessary resources to enable
affected groups, including existing host communities, to be effectively involved
in the siting process and to make informed decisions. Such resources should
include education regarding radiation and nuclear waste management.
3.4.6 Given the number and diversity of communities involved in the siting process,
both now and in the future, the NWMO must recognize that a broad consensus
or a high degree of social acceptability will probably never be achieved. In
order to avoid paralyzing the siting process, the NWMO needs to develop
realistic criteria by which social acceptability within each community can be
determined.
3.4.7 The NWMO study must acknowledge that the siting process cannot move
forward in isolation from a broader discussion on energy policy and the future of
nuclear energy. This is critical to ensure that potential future host communities
are aware of the long term implications of accepting a management facility for
used nuclear fuel. Similarly, the host communities for any new nuclear
generating facilities must also have assurances that the used fuel waste will not
remain on-site indefinitely.
4.0 CONCLUSIONS
4.1 Adaptive Phased Management possesses the potential to provide a balanced
and effective strategy for the long term management of Canada's nuclear fuel
waste. However, the identification of APM and its approval by the Government
of Canada is only the first step in an implementation process that will span
many years and engage many future generations.
4.2 Given the enormity of the task facing the NWMO, the Municipality of Clarington
and the other existing host communities must continue to ensure that their
comments and concerns are heard and addressed by the NWMO. This is
important to ensure that the existing reactor sites do not become the long term
management solution by default and that appropriate compensation is provided
to these communities.
REPORT NO.: PSD-107-05 PAGE 12
Attachments:
Attachment 1 Glossary of Terms
Attachment 2 Key Steps in Implementation of Adaptive Phased Management
Attachment 3 Executive Summary – ASL Peer Review Report
Interested parties to be advised of Council and Committee’s decision:
Ms. Elizabeth Dowdeswell
Nuclear Waste Management Organization
Board of Directors
Nuclear Waste Management Organization
Advisory Council
Nuclear Waste Management Organization
Mr. Roger Anderson, Chair
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
Mayor Norm McFarlane
City of Saint John
Mayor Rick Austin
Municipality of Port Hope
Mr. John Efford
Minister of Natural Resources Canada
Ms. Beverly Oda, M.P.
REPORT NO.: PSD-107-05 PAGE 13
Mr. John O'Toole, M.P.P.
REPORT NO.: PSD-107-05 INTERESTED PARTIES LIST
Ms. Elizabeth Dowdeswell, President Mayor Ann Aikens
Nuclear Waste Management Town of Deep River
Organization P.O. Box 400
49 Jackes Avenue 100 Deep River Road
Toronto, ON M4T 1E2 Deep River, ON K0J 1P0
Board of Directors Mayor Len Simpson
Nuclear Waste Management Town of Pinawa
Organization P.O. Box 100
c/o Ms. Kathryn Shaver, Executive Burrows Road
Director Pinawa, MB R0E 1L0
Nuclear Waste Management
Organization Mayor Maurice Richard
49 Jackes Avenue La Ville de Becancour
Toronto, ON M4T 1E2 1295, Avenue Nicolas-Perrot
Becancour, PQ G9H 3B8
Advisory Council
Nuclear Waste Management Mayor Norm McFarlane
Organization City of Saint John
c/o Ms. Kathryn Shaver, Executive 15 Market Square
Director P.O. Box 1971
Nuclear Waste Management Saint John, NB E2L 4L1
Organization
49 Jackes Avenue Mayor Rick Austin
Toronto, ON M4T 1E2 Municipality of Port Hope
56 Queen Street
Roger Anderson, Chair P.O. Box 117
The Regional Municipality of Durham Port Hope,ON L1A 3V9
605 Rossland Rd. E.
Whitby ,ON L1N 6A3 The Honourable Mr. John Efford
Federal Minister of Natural Resources
Mayor David Ryan House of Commons
City of Pickering Ottawa, ON K1A 0A6
One The Esplanade
Pickering, ON L1V 6K7 Ms. Bev Oda, M.P.
68 King Street East
Mayor Glenn Sutton Bowmanville, ON L1C 3X2
Municipality of Kincardine
1475 Concession 5 Mr. John O'Toole, M.P.P.
R.R. # 5 77 King Street E.
Kincardine, ON N2Z 2X6 Bowmanville, ON L1C 1N4
Attachment 1
Glossary of Terms
AECL
Atomic Energy of Canada Limited
APM
Adaptive Phased Management
ASL
Acres/Sargent & Lundy (CANHC peer review consultant)
CANHC
Canadian Association of Nuclear Host Communities
NWMO
Nuclear Waste Management Organization
Present Value
The amount of money that must be invested today to earn
compound interest in order to yield enough future value to cover
costs at a known period of time.
AECL
APM
ASL
CANHC
NWMO
Present Value
Attachment 1
to Report PSD-107-05
Glossary of Terms
Atomic Energy of Canada Limited
Adaptive Phased Management
Acres/Sargent & Lundy (CANHC peer review consultant)
Canadian Association of Nuclear Host Communities
Nuclear Waste Management Organization
The amount of money that must be invested today to earn
compound interest in order to yield enough future value to cover
costs at a known period of time.
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SL-OO&S21~Final.doc
ATTACHMENT 3
to Report PSD-107-0S
Nuclear Waste Management Organization
Independent Peer Review of
NWMO Draft Study Report
"Choosing a Way Forward"
Prepared for
Canadian Association of Nuclear Host Communities
SL-008521
July 2005
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55 East Monroe Street
Chicago, IL 60603-5780 USA
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1. EXECUTIVE SUMMARY
1.1 OVERVIEW
Acres-Sargent & Lundy (ASL) was engaged by the Canadian Association 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 to review
NWMO's Draft Study Report "Choosing a Way Forward: The Future Management of Canada's Used Nuclear
Fuel." Accordingly, ASL performed a broad review of the Draft Study Report with the overall objective of
identifying issues or questions that CANHC should focus on as the NWMO continues its process.
The NWMO was established in 2002 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 IS, 2005. The NWMO will then
'implement the approach chosen by the Government As noted in the NWMO's Fact Sheet 9, "The NWMO
Study 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 purpose of the Draft Study Report is to present the NWMO's recommended approach for the long-term
management of used nuclear fuel in Canada. The NFW A requires that the following three primary management
approaches, as a minimum, be studied: deep geological disposal" storage at nuclear reactor sites, and centralized
storage. However, the NFW A also noted that other methods may be considered. Based on its assessment of the
three primary approaches, the NWMO decided that there is "considerable merit" in developing and assessing
another approach that leverages the strengths of the primary options while minimizing their risks and
unfavorable aspects. Accordingly, the NWMO developed a new option called Adaptive Phased Management
(APM) that is intended to capture the strengths and mitigate the limitations of the other options. The NWMO
has designated APM as the preferred management approach.
APM is essentially the deep geological disposal option, but with an extended schedule that specifically
incorporates steps and decision points that provide flexibility and adaptability during implementation. During
Phase I of the APM scheme, used nuclear fuel would remain at the current nuclear reactor sites under current
storage and monitoring conditions. Research would continue into technology improvements for used fuel
management. The key activity during this phase is the selection of a preferred site and the decision of whether or
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not to construct a shallow central underground storage facility. If the decision is made to not construct the
shallow storage facility, then the used fuel would continue to be stored at the reactor sites until it is moved to the
deep repository during Phase 3. Phase 2 would begin with the operation of the underground research laboratory.
This laboratory would demonstrate the technology to be used and confirm that the selected site is suitable for a
deep repository. \fthe shallow storage facility is constructed, then used fuel would be transported there from the
reactor sites during this phase. If it is not constructed, the used fuel would remain at the reactor sites until
transported for placement in the deep repository. Phase 3 begins with the receipt of the operating license for the
deep repository. Assuming the shallow central storage facility was constructed in Phase 2, fuel transport and
repackaging would continue in Phase 3 with the fuel now being placed in the deep repository, and extended in-
place monitoring would begin. Access to the repository would be maintained to assess the performance of the
repository system and to allow retrieval of the used fuel, if desired. Finally, a decision on when to close and
decommission the deep geological repository facility would be made. Although the APM process is flexible, the
final disposition is firm, in that the used fuel will be disposed in a deep geological repository.
The following figure illustrates the impact on the duration of interim onsite storage associated with the different
management options.
Figure 1-1 _ Comparison of potential Interim Storage Durations
Now
Years after Approach Selected
o 10 20 30 40
50
60
70
80
90
100
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There are two key points illustrated in this figure. The first key issue is that the durations are all impacted by
how long it will take before a decision is made to select an approach. The second key issue is that used nuclear
fuel could remain in interim storage at the current reactor sites for over 90 years from now. This duration may
exceed the storage capacity and licensing parameters for these facilities, and could create technical and security
concerns that were not envisioned when these facilities were designed and approved for short-term interim
storage.
Overall, ASL believes that the Adaptive Phased Management. approach effectively addresses many of the
concerns or weaknesses associated with the other options, while building on their strengths. The Adaptive
Phased Management approach is technically reasonable and achieves its goal of providing balance relative to the
assessment attributes. 11 should be noted that while there are significant risks and costs, along with benefits,
associated with the APM, this approach is considered to be advantageous compared to the three primary
alternatives.
1.2 KEY ISSUES AND RECOMMENDATIONS
ASL identified several issues and corresponding recommendations during its independent peer review of the
Draft Study Report as summarized in Table I-I. The issues related to the Draft Study Report are discussed in
Section 3; the issues related to Adaptive Phased Management are discussed in Section 4; and the issues related
to implementation planning are discussed in Section 5.
Table 1-1 -Issue and Recommendation Summary
Issue
Draft Study Report
There is a risk associated with an approach that combines
quantitative and qualitative assessment factors, in that more
weight can be given to quantifiable versus qualitative factors.
For example, while the Golder/Gartner Lee analysis
acknowledges the potential for significant cost impacts related
to social protests, it later notes that "the risks and costs are not
significant" for transporting used fuel in a centralized approach.
The NWMO should develop an
assessment of the qualitative risks and
costs included in its analysis, as weli as an
assessment of the direct and implicit
assumptions, to ensure that appropriate
contingency measures have been
considered if extreme or unlikely events
occur. These assessments should be
included in the Final Study Report.
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The Golder/Gartner Lee assessment refers to the impact that
could result from opposition groups, such as the potential for The NWMO should supplement its public
social protests that could affect the transportation of used fuel. engagement strategy as required to
However, there is no formal discussion or assessment of assess the concems, positions, and
opposition groups, or a discussion of possible mitigating possible impact of potential opposition
measures needed to address this issue. This would be groups. This assessment should be .
relevant or could be a significant concern if these groups are performed during implementation planning,
able to stop or change transportation options, which could and mentioned in the Final Study Report.
mean that onsite storage is extended or becomes the long-
term approach.
In discussions with ASL the NWMO clarified that certain socia- The NWMO should clarify its position
economic impact mitigation measures, such as compensation towards the current host communities
for the unavoidable or residual adverse impacts of the relative to changes in the planned duration
management approaches, are not being considered for the of interim storage in the Final Study
current host communities. The NWMO noted that the used fuel Report. For example, the NWMO should
owners are responsible for the interim management and clearly state whether or not it plans to
storage of the used fuel, including socio-economlc effects afford the current host communities the
management and mitigation. Accordingly, the NWMO would same considerations as new host
not become involved in discussions or actions related to communities for changes in interim storage
current interim storage arrangements, and the NWMO's plans once a new national policy is
obligations would not begin until the used fuel leaves its decided upon.
current locations.
Adaptive Phased Management
The Draft Study Report, in Section 3.3, specificaily discusses The NWMO should develop a specific
the advantages and limitations of the three primary discussion of Adaptive Phased
management approaches (Deep Geological Disposal in the Management advantages and IimUations,
Canadian Shield Storage at Nuclear Reactor Sites, and comparable to the write-ups for lt1e other
Centralized Sto~ge). However, the report does. n~ include a options found in Secti?n 3.3. This .
comparable discussion of the advantages and limitations for discussion should be Included In the Final
Adaptive Phased Management. Study Report.
The NWMO shOuld ensure that lt1e
implementation plans for Adaptive Phased
Management consider the potential impact
There is a potential that some of the decisions that are a of delaying or deferring decisions, and
should develop corresponding
critical part of Adaptive Phased Management could be delayed contingencies and mitigation measures as
or deferred for longer than expected. Any type of delays would appropriate. For example, implementing
require a continuation of interim storage, with the risk that on- legislation could include requirements that
site interim storage would become the de facto long-term the used fuel will be moved off-sUe Within a
management approach. As noted throughout the Draft Study defined time-frame, or else ceriain
Report, that option has several disadvantages, nol the le~st of mitigation measures would go Into effect.
which is the lack of fairness to the current host commUnities. This issue will have to be addressed
during Implementation planning, but it
should be mentioned in the Final Study
Report.
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Issue
The NWMO's Draft Study assesses the technical aspects of
transportation, such as the number of shipments, estimated
costs, and statistical accident rates. The Draft Study also notes
that there are significant economic benefits associated with
transportation, such as the number of jobs created. However,
the study does not fully address the negative socia-economic
impacts or the potential impact of opposition groups. If these
types of events effectively stop impiementation of Adaptive
Phased Management or another recommended approach,
then the status quo option of onsite storage will become the
default approach.
The potentiai duration of interim storage is impacted by how
long it will take to select a management approach. With the
recommended approach, Adaptive Phased Management, used
nuclear fuel couid potentially remain in interim storage at the
current reactor sites for over 90 years from now. This duration
may exceed the storage capacity and licensing parameters for
the interim storage facilities, and could create technical and
security concerns that were not envisioned when these
facilities were designed and approved for short-term interim
storage. For example, the security risks for locations near
heavily populated urban areas and adjacent to the Great Lakes
may be significantly increased if the duration of interim storage
significantly increases at these locations.
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RecommendatIon ..
The NWMO should ensure that
transportation issues are studied and
addressed in greater detail as it continues
its planning and implementation work. For
example, the implementation plan for the
recommended approach should include
contingency evaluations for seiected
extreme events or unanticipated delays.
This issue will have to be addressed
during implementation planning, but it
should be mentioned in the Final Study
Report.
Transportation issues should be
specifically addressed as the NWMO
develops (for the Final Study Report) a
recommended assessment of the
qualitative risks and costs included in its
analysis as discussed earlier in tl1is report.
Given the potentially lengthy time frames
associated with Adaptive Phased
Management, the NWMO should confirm
and document that the existing reactor
sites have adequate storage capacity for
current and future used fuel inventories.
The storage capacity shouid consider both
potential facility and site space limitations
and constraints. This should be addressed
in the Final Study Report.
The NWMO should address the potential
increase in security risks associated with
an increase in the duration of interim
storage. This shouid be mentioned in the
Final Study Report and addressed in detail
during implementation planning. Also,
contingencies should be considered if
current sites are not able to obtain the
licenses required to support expansion
based on changes in the duration of
interim storage requirements.
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Issue
Implementation Planning
The NWMO has had extensive engagement with Canadian
citizens regarding its work as discussed in Appendix 5 of the
Draft Study Report. This item was discussed with the NWMO
during the CANHC meeting in Sl. Johns on June 3, 2005,
when a question was posed to the NWMO attendees regarding
the make-up of the participants in the engagement process
(that is, how many private citizens, how many peopie were
representing organizations, etc.). Appendix 5 of the Draft Study
Report lists the number of participants and organizations, but
does not analyze these data against expectations for
participation and the overall quality of the engagement
process. This information could provide valuable insight into
the effectiveness of the NWMO's engagement process and
indicate areas for improvement and lessons leamed from their
experiences.
There appears to be some confusion or inconsistency
regarding the role of the NWMO in working with the current
host communities as it develops its recommended
management approach and implementation plans. The Draft
Study Report notes that "[the NWMO] will be responsible for
managing and coordinating the full range of activities related to
the long-term management of used nuclear fuel." The NWMO's
recommendation and implementation plan will affect the
current host communities, and it would seem that the NWMO
would take an active role in working with the current host
communities to manage and mitigate socia-economic effects
before the used fuel leaves interim storage. However, the
NWMO stated that it would not be involved with detailed
discussions or actions taken relative to mitigating socio-
economic effects until the used fuel leaves interim storage.
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Recommendation'
It is recommended that the NWMO
develop and/or study data characterizing
the make-up of engagement participants to
verify the quality of the engagement
process and to identify areas for
improvement during implementation
planning. This issue will have to be
addressed during implementation
pianning, but it should be mentioned in the
Final Study Report.
It is recommended that the NWMO clarify
its role regarding current interim storage at
reactor sites, so that the current host
communities understand the roles and
responsibilities of the different
organizations involved in developing
interim storage policies. This clanncation
will support effective planning and
implementation of current and/or new
storage policies. This issue will have to be
addressed during implementation
planning, but it should be mentioned in the
Final Study Report.
Last page of Section I.
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