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CCRCA comments on EIS - May 15, 2017

posted May 15, 2017, 10:15 AM by Lynn Jones   [ updated May 15, 2017, 10:17 AM ]
CCRCA has submitted comments to the Canadian Nuclear Safety Commission on the Environmental Impact Statement for the NSDF.
The eight-page document is posted on the resources page on this website.
Here is the executive summary:

Executive Summary 

Serious deficiencies of the Environmental Impact Statement (EIS) for the proposal by the Canadian Nuclear Laboratories to build a Near Surface Disposal Facility (NSDF) at the Chalk River Laboratories are highlighted in this submission.  These deficiencies include the following:


1.  The EIS does not describe the wastes that it intends to dispose of in adequate detail. If, under the Near Surface Disposal Facility (NSDF) project, Canadian Nuclear Laboratories intends to dispose of all the building decommissioning waste at the Chalk River Laboratories property, to dispose of waste from the Whiteshell Laboratory and Nuclear Power Demonstrator reactors, to dispose of waste from remediation of existing Waste Management Waste Areas, and to dispose of commercial waste, the EIS must describe this radioactive waste in adequate detail. 


2.  The EIS does not clearly and precisely specify the problems or opportunities that the NSDF project is intended to satisfy. Rather than providing generalities about overall decommissioning and remediation objectives at the Chalk River Laboratories and elsewhere, the EIS should clearly and precisely specify the problems or opportunities that the NSDF project itself is intended to satisfy.  If the proponent is aware of decommissioning and remediation waste that may not be suitable for landfilling in a mound, then the purpose of the project should be revised and clarified accordingly. 


3. The EIS for the proposed NSDF completely ignores the Comprehensive Preliminary Decommissioning Plan (CPDP) (CPDP-508300-PDP-001 Revision 2, March 2014) for the Chalk River Laboratories (CRL). The NSDF project departs in very significant ways from the preferred decommissioning strategy described in the CPDP.  By ignoring the CPDP in its EIS for the Near Surface Disposal Facility, CNL disregards many years of accumulated knowledge about CRL facilities and hazards.  As a result, the NSDF project may not represent a “technically feasible, safe and environmentally acceptable approach,” and may well present a number of design, operational problems and adverse environmental effects that are not addressed in the EIS.


4. The NSDF EIS ignores the detailed guidance in CNSC Regulatory Guide G-320: Assessing the Long-term Safety of Radioactive Waste ManagementThe EIS fails in many ways to address important safety considerations for radioactive waste management discussed in Guide G-320, such as demonstration of long-term safety of the public and the environment. 


5. The EIS does not consider the cumulative environmental impacts of carrying out the proposed NSDF project in conjunction with other activities at the Chalk River Laboratories (CRL), such as:


      Clean-up of Two Legacy Landfill Areas at the CRL site - 22196

      Decommissioning and Dismantlement of Buildings in built-up area - 40302

      Proposal from Atomic Energy of Canada Limited to decommission a plutonium recovery laboratory - 6503

      Proposal from Atomic Energy of Canada Limited to decommission a plutonium tower building at Chalk River Laboratories - 6513

      Proposal from Atomic Energy of Canada Limited to decommission a waste water evaporator located at the Chalk River Laboratories - 6517

      Proposal from Atomic Energy of Canada Limited to Decommission the NRX Ancillary Buildings - 27095


6. The EIS ignores the IAEA Safety Standard for Disposal of Radioactive Waste (SSR-5) and fails to adequately consider the alternative of constructing a Geological Waste Management Facility (GWMF). This is the preferred means for long-term management of low-level radioactive wastes according to IAEA Safety Standard SSR-5


7. The EIS uses the term “near surface disposal facility” in a manner that does not conform to the IAEA’s use of this term.  The EIS should acknowledge that the proposal is not a “near surface disposal facility,” but a landfill type facility with a mound whose summit would project some 25 meters above its base.  The IAEA deems landfilling of radioactive wastes acceptable only for very low-level radioactive wastes or wastes with very short half-lives that will decay to stable forms during the period in which the landfill is capable of isolating wastes from the environment.  The proposed landfilling of intermediate-level radioactive wastes, or large amounts of low-level radioactive wastes with long half-lives, does not conform to IAEA Safety Standard SSR-5. Environmental impacts of the project should be assessed accordingly.


8. The EIS fails to acknowledge that that abandonment is a necessary phase and component of the project.  Making a decision to allow abandonment of nuclear wastes without adequate information to inform this decision would set a very bad precedent for other disposal projects.  The EIS must provide sufficient information to inform a federal decision on this matter.

9. The EIS fails to provide sufficient detail on the post-closure phase of the project.


10. The EIS does not provide a detailed analysis of environmental effects associated with the “post-institutional control” phase. 


11. The EIS completely ignores waste redistribution.  The EIS fails to consider means by which future generations would be warned to stay away from the facility, and the very serious consequences if warnings were not heeded and waste redistribution were to occur.  This deficiency makes it highly likely that the NSDF project would cause significant adverse environmental effects that cannot be justified in the circumstances.