One of the biggest concerns about the DGR is: what kind of nuclear waste, exactly, does OPG intend to store there? Different government representatives including the OPG said the DGR at the Bruce site would be only for "low-" and "medium-level" nuclear waste, but their definition of “medium-level” placed no limits on the amount of radiation emitted. Furthermore, their analysis of certain wastes neglected to account for most of their radioactivity. It became hard to trust OPG’s analysis of the situation when their work contained such shortcomings. Now the situation has become much more complex as we don't know whether the high-level waste will be buried with low-level and medium-level waste? Why is there a laundromat washing low-level uniforms in Teeswater, suddenly opened, and where is the water with the waste going? We want to know, exactly, how many tonnes of high-level waste will be stored there? What is the capacity of the site? Why is NWMO buying more land in the Teeswater area? How much nuclear waste will be transported to the Teeswater site? And if that site is rejected, where will all the waste go if it is moved to Ignace, in Northern Ontario? These are the sorts of Waste Concerns we already have.
Having reliable knowledge of the radioactivity of the wastes that the DGR will hold is of course crucial for evaluating its safety. OPG and the CNSC gave us ballpark figures for the level this radioactivity with the designations Low Level Waste (LLW), Intermediate Level Waste (ILW), and High Level Waste (HLW). Only LLW and ILW were officially being allowed in the proposed DGR at the Bruce reactor site. They were insistent that the high-level (HLW) would be buried separately. Now we are getting the strong impression from our questioning of OPG and CNSC and NWMO officials that somewhere, someone or some entity has taken the position that single storage facility and procedure can be appropriate, so long as no HLW is included. But that in the long run, the HLW storage site might be outfitted to take the ILW and LLW.
The problem is that for ILW especially, there is a tremendous variety in the level and life-span of its radioactivity – and its consequent hazard to people and the environment. The current definition of ILW being used includes waste that just about everyone else in the world includes along with their High Level Waste. This not only makes any such projects less safe, it means that studies done elsewhere in the world cannot be used to validate the safety of the proposed OPG project, since this proposed DGR includes “ILW” of much higher radioactivity than those studies. This is especially important since OPG’s own estimates of the radioactivity of its wastes were significantly lower than actual measured values of those wastes.
Back when the DGR was first proposed, there were two definitions of these categories in use: one by the International Atomic Energy Agency (IAEA), and one by the province of Manitoba that was designed to keep the federal government from using its research site at Whiteshell to store nuclear waste from around the country.
In 2008, after the proposal process got underway, with the lesson of Manitoba in mind, the Canadian government had the Canadian Standards Association produce a new standard that made it easier for crown companies like OPG to categorize their dangerous waste as ILW instead of HLW. For the moment, we will just give OPG’s own definition, as this was the operational one for the first proposed DGR (which has since been voted against by the SON):
OPG considers that all its radioactive waste that is not used fuel is LLW or ILW. OPG considers waste as LLW if the corresponding waste package has a dose rate of less than 10 mSv/h at 30 cm, and as ILW if the dose rate is greater than or equal to 10 mSv/h at 30 cm, or known to have a significant amount of long-lived radionuclides.
Responses to Information Requests Package #11 p. 11
Note that the definition of ILW is open-ended: there is a minimum value, but no upper bound. Earlier definitions invoked judgment in classifying waste as HL if it had a high enough level of radioactivity. OPG’s definition restricts HLW to spent nuclear fuel.
No doubt this is a convenient definition for bureaucrats, who would no longer need to conduct measurements of radiation levels in order to classify nuclear waste. But it flies in the face of established practice. For example, William H. Lenneman, Head of the Waste Management Section, Division of Nuclear Safety and Environmental Protection, IAEA characterized it thus:
High-level waste is characterized, of course, by high radiation levels …. Examples are solidified high-level waste or… spent fuel and possibly cladding hulls. Other examples of what sometimes is considered a high-level waste are removed highly irradiated reactor components, such as control rods, piping or flow orifices….
IAEA Bulletin, Vol. 21, #4. p. 2
This is in distinction to OPG’s plans to include “pressure tubes, end fittings and calandria tubes” in its ILW inventory, which is especially significant since it significantly underestimates their radiation levels.
We do note that the IAEA discussion says that such “highly irradiated reactor components” are “sometimes” considered high-level waste; but we also note that even countries that do not consider such components to be HLW still treat them in the same manner as their HLW, in consideration of their highly dangerous nature. For example, the Swiss Nagra agency, in forming the plans for its own DGR, says that
Nagra’s mission is to develop safe geological repositories in Switzerland for all radioactive wastes arising in Switzerland. Two types of repositories are foreseen, one for low and intermediate level waste (L/ILW) and one for spent fuel, vitrified high level waste and long-lived ILW (SF/HLW/ILW).
Nagra Technical Report NTB 09-06, p.I
The more long-lived ILW is to be treated in the same way as the HLW, and this turns out to be standard practice among other countries that are pursuing their own DGRs. In fact, such Long-Lived ILW often gets its own acronym: LLW, or LL-ILW. In any case, while a country might still choose to process its HLW and LLW streams separately, they are still treated as similarly dangerous, and the best practices in decisions about what to do with them is to treat these decisions as part of the same process. For example:
The December 30, 1991 French Waste Act entrusted Andra, the French national agency for radioactive waste management, with the task of assessing the feasibility of deep geological disposal of High Level and Long-lived waste (HLLLW).
S. Voinis, A. Roulet, D. Claudel, A. Lesavre, Agence Nationale pour la gestion des déchets radioactifs (Andra), “Operational Safety and Radioprotection Considerations When Designing the ILW-LL Disposal Zone”, p. 1
Similarly, see this article in the newsletter of the European Nuclear Society, a nuclear energy advocacy group that bills itself as the “largest nuclear group for science and industry.” Although the article’s title is “HLW disposal: Status and Trends”, it quickly goes on to expand its purview to LL-ILW:
LL-ILW and HLW originate almost exclusively from nuclear reactors and their fuel cycle facilities, as well as the defense facilities of those countries which developed nuclear weapons. Though quite limited in volume, they constitute the bulk of the waste radioactivity. For those countries with no weapons activities and which do not reprocess their spent fuel, all their HLW and LL-ILW is inside their spent fuel assemblies which constitute for them the ultimate waste. We shall now focus only on those two categories of waste.
Bertrand Barré for The International Nuclear Energy Academy, “HLW disposal: Status and Trends”
The UK, likewise, tasked its Committee on Radioactive Waste Management (CoRWM) to make “recommendations to Government on the management of the UK’s intermediate-level (ILW) and high-level (HLW) radioactive wastes.” Miller, Tooley and Thomson, “Storage and Disposal of ILW and HLW in the UK”, p. 1
Basically, there is no other country besides Canada that has decided it’s appropriate to take all of their ILW and store it permanently in the same manner and place as their LLW. What does this mean for the future? We need to be careful when we use the terms ILW and HLW as if they can be easily separated. And we need to be careful that in future years, once the HLW is buried, that future generations don't reason it would make sense to store the ILW in the same burial shaft. We need to ensure from the very beginning that the definitions of ILW and HLW are not changed or used to suit the needs of the moment.
There are numerous problems in using the same procedures and facilities to store a body of waste with widely varying levels of radioactivity. We have emphasized the safety problems that attend on underestimating the radioactivity of the waste to be stored. But there are also of course tremendous economic issues with using stringent containment strategies on waste that does not need them. Countries like the UK that have decided to process some of their ILW along with LLW have realized that neither class of waste is homogenous, and that the lower-radioactivity waste stream that requires special attention in this way is “intermediate-level waste (ILW) and for the small amount of low-level waste (LLW) that is unsuitable for near-surface disposal.” In fact, the UK has created a class of waste called Very Low Level Waste (VLLW) and has floated the idea that “in appropriately controlled quantities [this could] be safely disposed of with domestic refuse”. Miller, Tooley and Thomson, “Storage and Disposal of ILW and HLW in the UK”, p. 10
We’re not sure whether disposal “with domestic refuse” is indicated in any case; but there are certainly reliable and effective solutions (such as the status quo) that cost exponentially less than storing all the LLW in custom-designed metal canisters in a huge cavern dug hundreds of meters into the ground.
We need to be careful that future proponents of any type of DGR don't suggest an "all-in-one solution, because that would represent the worst of both worlds: it would store highly radioactive waste under conditions that have not been found safe for it, and it would store Low Level Waste under expensive conditions that are not required. It would substitute bureaucratic convenience for both safety and economy.
One of the most important requirements in planning for any situation is to have a complete set of information. It is therefore entirely appropriate that one of the requirements for the Environmental Impact Assessment is that it contain a complete list of all the chemical elements – radioactive or not – that the proposed waste contains. This not only allows proper evaluation of the plan, it also provides a rationale for excluding waste that the repository has not been planned for.
However, this is not the position that OPG is taking. For instance, the International Institute of Concern for Public Health documents the following exchange with OPG:
IR EIS-04-107: Request # 10 (IICPH): Section 8.1 General Information and Design Description
The Reference Inventory Report (page 23, Table 2.8) provides the inventory of non-radioactive components in the waste (in kg at the year 2052). OPG was asked to clarify whether some of the substances listed in the Table are stable end products of the decay of the radionuclides in the wastes.
The list is not intended to include all stable end products of all radionuclides – only elements that are important for overall chemical composition or are otherwise important for the non-radiological safety case.
IICPH submission 89441E, p. 6
There are multiple problems with OPG’s approach. Most fundamentally, the whole point of the review process is to let people and organizations outside of OPG see what elements will be going into the repository and offer their own feedback. This purpose is defeated if OPG decides beforehand which information to show. OPG doesn’t get to decide on its own which “elements… are important” and whether the proposed design addresses them adequately – that’s the purpose of the review process.
This is especially problematic because in many cases, OPG has used its own estimates for the concentration and even the presence of important radionuclides. Frank Greening, a career radiochemist for Ontario Hydro and OPG, responding to his examination of the data provided by OPG, notes that
What is notable about these tables is the fact that much of the data are not based on direct measurements at all but rather on “scaling factors, used fuel ratios and neutron activation calculations”. Indeed, none of the data for pressure tubes, end fittings and calandria tubes is based on direct measurements and only a handful of radionuclides are reported to have been directly measured for steam generator waste.
Frank Greening, submission 98019E, p. 2
To date the NWMO has relied solely on calculated values to estimate inventories of individual radionuclides in pressure tube waste even though measured values of many species are readily available.
As a result,
The specific activities published by OPG and the NWMO for radionuclide inventories associated with CANDU pressure tube refurbishment waste are seriously underestimated, sometimes by factors of more than 100.
This is especially of concern when OPG has not merely underestimated the radioactive activity, but omitted important radionuclides from consideration altogether. As the IICPH notes,
Many of the radionuclides in the waste are alpha emitters. Internal exposure to alpha particles is particularly dangerous. This factor alone deserves consideration, especially for workers who may be at greatest risk of internal exposure to alpha particles. […]
The potential impact of drinking water contamination, due to the potential migration of toxic waste to groundwater, poses a threat to human health and the environment for countless future generations. Even if the level of radioactivity diminishes over time, enough will remain to cause serious harm for a million years or more. Potential geological changes over time, that may increase the chance of releasing radioactivity into the environment, have also not been adequately addressed.
IICPH submission 89441E, p. 9
The importance of listing all alpha emitters can be seen from the following table, in which Mr. Greening compares reported data from actual measurements of nuclear reactor pressure tubes to the estimated values from OPG. In the last line, he also provides real measurements for curium-244, which OPG completely left out of their EIS analysis.
Looking at this data reveals three salient points:
• The measured activities of alpha-emitting transuranic radionuclides in irradiated pressure tubes are considerably higher than the OPG/NWMO “used fuel ratio” estimates
• Cm-244, which is not included in the OPG/NWMO’s estimates, is by far the highest alpha activity measured in irradiated pressure tube samples
• There is a high degree of variability (by up to a factor of 3), between measurements from different pressure tube samples.
A comparison of [OPG’s estimates with actual measurements] shows that the alpha-activities in Bruce samples are somewhat higher than the activities of the equivalent species in Pickering samples. Nevertheless, these measured values are consistently higher than the OPG/NWMO estimated values by a factor of at least 3. More importantly, however, the reported OPG/NWMO values imply that Cm-244 is entirely absent from irradiated pressure tubes when in fact this radionuclide accounts for more than 90% of the alpha activity in this type of waste. It is worth noting that Cm-244 is an [especially] important component of radioactive waste because it decays to another alpha-emitter, Pu-240, and is a significant neutron source through spontaneous fission and the associated (a,n) reactions with 0-17 and 0-18 in metal oxides in the waste matrix.
But it’s not just OPG’s omission of its most potent alpha-emitter in its inventory. Note also Mr. Greening’s concern with curium’s decay products and their radioactive and chemical profile. Not including curium in their estimates also means that they leave its decay product plutonium-240 out of their estimates, and do not allow for its effects on the chemical reactions that take place around it. Likewise, plutonium-240 itself decays into (among other things) mercury, a toxic chemical in its own right. As the IICPH notes:
It is important to include all stable end-products, particularly as the composition of decay products will change over time, many of these products are hazardous, and they affect the chemical activity within the repository.
Many of the resulting stable progeny from the decay of radionuclides are heavy metals, such as mercury, lead, and thallium, which are very toxic to human health and the environment. Has OPG examined the impact of this?
OPG can hardly make a proper plan for the DGR if it simply ignores important components of the toxic and radioactive materials that it plans to store there.
Estimates vs. Actual Measured Data
One of the biggest problems with the DGR proposal as it stands is that it just doesn’t make a lot of sense. The Bruce facility has quite a bit of low-level waste – common office furniture and appliances that have some slight acquaintance with the nuclear environment. But these wastes are currently handled quite well in their temporary arrangement, as they are quite legitimately temporary waste. These wastes are incinerated and stored aboveground, where their short storage requirement means that they are not straining the Bruce Nuclear Generating Station’s (BNGS) capacity for handling them. There is no need to store these wastes underground. If that truly is the purpose of the DGR, then it is simply a tremendous boondoggle and it should be rejected out of hand as a colossal waste of money.
This leaves the intermediate-level wastes (ILW), of which the BNGS has only a scant amount. If storing these wastes alone is truly the purpose of the DGR, then it has a tremendous overcapacity and is again a colossal waste of money. But few observers think that the DGR is simply a boondoggle. Hence, the concerns that OPG intends to use this facility (a) either to house nuclear waste from other facilities, which will be transported to the DGR from all over Canada, or (b) that it plans to house high-level waste (HLW) here also. Or (c) both of the above. Concerns are exacerbated by the fact that, while building the facility in the first place must go through extensive public review, a change in the site license to allow it to accept high-level waste or waste from elsewhere is an administrative task that can be accomplished at the will of the regulatory agency. Adding nuclear fuel to the fire is the fact that there is some material known everywhere else in the world as high-level waste that the Canadian Nuclear Safety Commission (CNSC) has already (re)classified as intermediate-level waste, thus making it officially suitable for the DGR.[link to a discussion of waste (re)classification]
Thus, the concerns of the United Church of Canada:
The OPG proposal, if approved, would set a precedent for subsequent low and intermediate level waste disposal within Canada and potentially pave the way for a high-level waste site being pursued by the NWMO in Lake Huron communities. With due respect to OPG’s assurances that high-level waste is not being included in its proposal, precedents exist such as in Sellafield, where some parties fully expected that a low- and intermediate- level waste site would eventually be expanded to include high-level wastes. Interpretations of intent and of what was promised go back and forth with each change in government. It is sensible to be aware that NWMO [Nuclear Waste Management Organization] reflects the overall interests of the nuclear industry, which holds the strongest influence on decisions about the approaches the NWMO will take…
Likewise, the Saugeen Ojibway Nation (SON) has provided documentation of the DGR regulators and proponents ignoring and whitewashing this issue:
OPG [Ontario Power Generation] has taken the position that under the terms of the EIS [Environmental Impact Statement] Guidelines, matters relating to the transportation of nuclear wastes need not be considered as part of this review. SON strongly disagrees.
SON has consistently taken the position that the continued and increased transportation of nuclear wastes through its Territory is a critical factor in assessing the safety and acceptability of the DGR Project, and specifically, in assessing potential impacts of the Project on SON Rights and interests. Any assessment of the Project that fails to consider these matters is fundamentally incomplete.
SON has raised concerns about transportation issues for many years in its engagement with OPG and through submissions to CNSC regulatory proceedings. OPG has documented SON concerns about the transportation of wastes into its Territory in the EIS. OPG ought to have included consideration of these matters as a requirement of CEAA and the guidelines, as well as based on proper expectations of an enhanced and precautionary development approach as explained in section 4 below.
Under the Guidelines, OPG was required to address any concerns raised by Aboriginal people about the project or other past or present means of storing or disposing of nuclear waste, and regarding the cumulative effects of the project in combination with any other over these areas.
It was incumbent on OPG to not only identify SON concerns with regard to transportation issues, but to address those concern. OPG has failed to do so. It was not acceptable for OPG to have ignored SON concerns and all questions relating to transportation on the basis of its existing transportation licenses. Such an approach shields from public and regulatory scrutiny OPG’s statement that “volumes, means and routes” for transportation will not change. It does not address potential changes resulting from the DGR Project respecting: the guaranteed continuation of waste transportation to the site and through SON territory, increased possibility of terrorist attack due to the heightened profile and public awareness of the Project, effects of increased uses of existing transportation due to population growth over the very long term, and importantly, the cumulative effects of transportation of wastes to the DGR Project with other future nuclear waste management projects in the area.
Additionally, SON has submitted, and continues to take the position that a project for the long-term management of spent nuclear fuel (the “HLW DGR Project”) ought properly to have been included in the cumulative effects analysis of the DGR Project. A proper cumulative effects assessment in this case would need to seriously and transparently consider the cumulative effects of the continued and increased transportation of low and intermediate level nuclear wastes in combination with the transportation of spent nuclear fuel [which is considered high-level waste] over the same roads and through the same areas. These are novel and critical concerns, and are materially different from the transportation issues relating to the WWMF [Western Waste Management Facility, the temporary facility currently housing the waste] facility alone.
Without full information and analysis relating to the increased and continuing transportation issues from the DGR Project alone, and those resulting from the DGR Project in combination with a future HLW DGR Project, the totality of potential adverse impacts of from the Project cannot be known.