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«General Comments on the Proposed New Decommissioning Strategy for the WR-1 Reactor 1. What is the problem? CNL appears to have decided on a ...»

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Comments on the “Project Description – In Situ Decommissioning of the WR-1 Reactor At the

Whiteshell Laboratories Site” (Registry Number 80124)

Page 1 of 12

By W. Turner (Concerned Citizen, former Pinawa Resident)

General Comments on the Proposed New Decommissioning Strategy for the WR-1 Reactor

1. What is the problem?

CNL appears to have decided on a technology without a thorough examination of the appropriateness

of that technology. Except for possibly immediate monetary considerations, CNL has not provided an unambiguous description of the problem it wishes to solve. From the project description provided, all we know is that WR-1 reactor needs to be decommissioned, and that CNL has a licence from the CNSC to do that over an extended period. CNL has provided no justification (only assertions) as why the permanent shutdown of the reactor has to be accelerated. I am not aware of any unacceptable risks to the workers, the public or the environment from the current status of the facility. So, what is the problem?

Except for assertions, the proponent provides no evidence that the “in situ decommissioned” facility will result in lower the risks to the environment, the workers and the public compared to current strategy of deferred dismantling. Further, CNL has provided no details that compares the end-state of the proposed undertaking to the resultant end-state of the current strategy. The rush to decommission in situ means the reactor will remain in place forever. This is not the case for the existing approach.

Which is better in the long run, a concrete structure that will remain in perpetuity, or a greenfield (or maybe brownfield) site?

Without a proper problem definition, any solution is OK, including “in-situ decommissioning” (whatever that means, see below). To paraphrase the Cheshire Cat in Alice in Wonderland, “If you do not know where you going, it does not matter what road you take”. This is not an approach that I would expect of a technologically sophisticated company.

One further concern is that the current decommissioning licence covers the whole Whiteshell site, not just the reactor. CNL has provided no information as to the impact to the whole site from the entombment of a small portion of that site. How do the effects from this proposed undertaking impact the effects from decommissioning the rest of the site? In other words, what are the cumulative effects? I suggest that the scope of the problem is much larger than the WR-1 reactor alone.

2. What is meant by “in situ decommissioning”?

The proponent states that the reactor on the Whiteshell site is currently in storage with surveillance with the ultimate objective of removing the reactor. For reasons that are mostly financial, CNL asserts that this situation is not acceptable. Therefore, the proponent is proposing to leave the reactor in place and to encapsulate the hazards by “in situ decommissioning”.

However, “in situ decommissioning” is not really defined anywhere in the project description. But one can infer what the proponent means from the document. For example, in Section 2.1.1, 4th paragraph

of the proponent states:

A new approach, In Situ Decommissioning (ISD), has been proposed for the decommissioning of the WR-1 Reactor. The below grade reactor systems, components and structure and associated radiological and non-radiological hazards will be permanently encased with grout.… An engineered cover will then be constructed over the below grade structure. ISD is a permanent, passive decommissioning end state.

Comments on the “Project Description – In Situ Decommissioning of the WR-1 Reactor At the Whiteshell Laboratories Site” (Registry Number 80124) Page 2 of 12

See also 3rd paragraph of Section 7 which states:

In Situ Decommissioning results in a concrete monolith which provides a robust and durable containment to allow for continued radioactive decay To me this appears to be another way of describing entombment. This is confirmed since the last

paragraph of Section 3.1.1, on page 3-2, states:

Following In-Situ Decommissioning, institutional controls and surveillance activities will be required to monitor environmental performance of the entombed material at the WL site.

Note the similarities with the IAEA definition of entombment, which is:

Entombment is the strategy in which the radioactive contaminants are encased in a structurally long lasting material until the radioactivity decays to a level that permits release of the facility from regulatory control (Decommissioning Strategies For Facilities Using Radioactive Material, Safety Report Series #50, IAEA, Vienna, 2007) In other words, for the WR-1 reactor, “in situ decommissioning” means entombment.

3. Is “entombment” disposal?

Although never stated explicitly, the proponent does not intend to retrieve any of the radioactive components from the entombed facility, since, once encapsulated, recovery would be virtually impossible. As such this undertaking is actually a proposal for a radioactive waste disposal site. By implication, once the radioactivity has decayed to some acceptable level, the site would eventually be abandoned.

That said, I am not aware of any Canadian standards, guidelines or legislation with respect to entombment. Therefore one needs to refer to international guidance, such as the IAEA. I quote several sections from the IAEA document Decommissioning Strategies For Facilities Using





Radioactive Material, Safety Report Series #50, IAEA, Vienna, 2007 pertaining to entombment:

2.4. ENTOMBMENT Entombment is the strategy in which the radioactive contaminants are encased in a structurally long lasting material until the radioactivity decays to a level that permits release of the facility from regulatory control. The fact that radioactive material will remain on the site means that the facility will eventually become designated as a near surface waste disposal site and criteria for such a facility will need to be met. [emphasis added].

3.3.3. Entombment Since the end state of an entombed site is equivalent to a waste disposal site, the end state cannot satisfy unrestricted release conditions. An entombed site will need some measure of monitoring and control well into the future, which will be undertaken by either the operating organization or the regulatory body. Since the area required for an entombed facility is normally less than that of the original facility, the remaining area of the site could be used for other purposes, including industrial applications. This option may also be considered if a waste disposal site does not exist within a Member State; the waste disposal facility could be created at the facility site. Such a new waste disposal facility would be of the ‘near surface disposal’ type that could receive radioactive waste from other sites, but only waste containing short lived radionuclides. [emphasis added].

Comments on the “Project Description – In Situ Decommissioning of the WR-1 Reactor At the Whiteshell Laboratories Site” (Registry Number 80124) Page 3 of 12 3.4.3. Entombment The entombment strategy has many similarities to the immediate dismantling strategy insofar as it affects the regulatory body. The regulatory staff will initially make the transition from operations to decommissioning. However, with this strategy, the regulatory staff will also have to be knowledgeable with regard to the requirements for near surface disposal facilities …, since this is the end point of the decommissioning project. Once the decommissioning is completed, the staff will have a disposal site to regulate. There are limited international practice precedents for entombing facilities. The main difference in the regulatory requirements for entombment will be that in addition to the decommissioning regulations being necessary there will also need to be regulations for the near surface disposal of radioactive waste. Since it is unlikely that the site of the operating facility was evaluated to serve as a location for a near surface disposal site, such an evaluation may be conducted as part of the approval process for the entombment strategy. [emphasis added].

In other words, entombment is disposal.

4. Is entombment an acceptable decommissioning strategy for nuclear reactors?

Let’s look at another section of the IAEA document Decommissioning Strategies For Facilities Using Radioactive Material, Safety Report Series #50, IAEA, Vienna, 2007 pertaining to the acceptability of

entombment as a decommissioning strategy. Section 3.2.3. Entombment, states:

Entombment is not relevant for a facility that contains long lived isotopes because these materials are not suitable for long term surface disposal. Consequently, reprocessing facilities, fuel fabrication facilities, enrichment facilities or facilities that use or process thorium or uranium would not be appropriate for entombment. However, entombment could be a viable option for other nuclear facilities containing only short lived or limited concentrations of long-lived radionuclides, i.e. in order to comply with the site release criteria.

[emphasis added].

Although the proponent does not provide inventories of any of the possible long-lived radionuclides remaining in the reactor and its associated structures, there is no doubt that they are there.

The guidance quoted above does not explicitly include nuclear reactors. A more recent IAEA document that does address reactors (Decommissioning of Facilities, General Safety Requirements Part 6, IAEA, Vienna, 2014), states that with respect to permanently shutdown reactors entombment is

not recommended. To quote the sections 1.9 and 1.10 from this publication:

1.9. Strategies for decommissioning that have been adopted or are being considered by States include immediate dismantling and deferred dismantling. In principle, these two possible decommissioning strategies are applicable for all facilities.

— Immediate dismantling: In this case, decommissioning actions begin shortly after the permanent shutdown. Equipment and structures, systems and components of a facility containing radioactive material are removed and/or decontaminated to a level that permits the facility to be released from regulatory control for unrestricted use, or released with restrictions on its future use.

Comments on the “Project Description – In Situ Decommissioning of the WR-1 Reactor At the Whiteshell Laboratories Site” (Registry Number 80124) Page 4 of 12 — Deferred dismantling: In this case, after removal of the nuclear fuel from the facility (for nuclear installations), all or part of a facility containing radioactive material is either processed or placed in such a condition that it can be put in safe storage and the facility maintained until it is subsequently decontaminated and/or dismantled. Deferred dismantling may involve early dismantling of some parts of the facility and early processing of some radioactive material and its removal from the facility, as preparatory steps for the safe storage of the remaining parts of the facility.

1.10. A combination of these two strategies may be considered practicable on the basis of safety requirements or environmental requirements, technical considerations and local conditions, such as the intended future use of the site, or financial considerations. Entombment, in which all or part of the facility is encased in a structurally long lived material, is not considered a decommissioning strategy and is not an option in the case of planned permanent shutdown. It may be considered a solution only under exceptional circumstances (e.g. following a severe accident). [emphasis added].

In other words, entombment is not an acceptable strategy for the permanent shutdown of the WR-1 reactor.

5. Can “disposal” be licenced?

It is my understanding that under the Nuclear Safety and Control Act, there is no provision for a “disposal” licence.

Under Prohibitions, Section 26 of the Act states:

“Subject to the regulations, no person shall, except in accordance with a licence, (a) possess, transfer, import, export, use or abandon a nuclear substance, prescribed equipment or prescribed information; … (e) prepare a site for, construct, operate, modify, decommission or abandon a nuclear facility;

…” Under current legislation, the only licence that would be available at the end of the institutional control period (which is not really addressed in this project description document) is a licence to abandon. To comply with the regulatory guide G-320, “the predicted impact on the health and safety of persons and the environment from the management of radioactive waste are no greater than the impacts that are permissible in Canada at the time of the regulatory decision” (Section 7.4, Assessment Time Frames, CNSC Regulatory Guide, G-320, page 24). This means that at the time of the application for a licence to abandon, the residual activity in the grouted reactor site will have to meet radioactive clearance criteria.

In other words, “disposal” cannot be licenced (at present). The only option for the proponent is to apply for a licence to abandon at the end of the institutional control period.

6. Should CNL be the Proponent?

If the timeline, for the radioactivity to decay to acceptable levels, is thousands of years into the future (which is likely given that radioactive nuclides present have half-lives that are in this range or greater)

institutional controls will be required to cover this time period. The 2nd paragraph on page 7-2 states:

The WR-1 Reactor site will be returned to AECL for Institutional Control.

Comments on the “Project Description – In Situ Decommissioning of the WR-1 Reactor At the Whiteshell Laboratories Site” (Registry Number 80124) Page 5 of 12 This is of concern. CNL appears to be making commitments on the part of AECL, (by extension, the Government of Canada) that could last forever. The proponent must be accountable for the entire life of the project, i.e. from design, through construction, commissioning, operations up to and including final closure. Since CNL’s contract with AECL is for a maximum of 10 years, CNL should not be the proponent.

7. Who should be involved in the decision?



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