Re: Initial consideration of operating license for MAPLE reactors
Concerned Citizens of Renfrew County and Area would like to draw your attention to the need for further environmental assessment of the Medical Isotope Project. We suggest that it would be premature to give initial consideration to licensing the operation of facilities connected with this project until all of the AECB's legal obligations under the Canadian Environmental Assessment Act (CEAA) have been met.
Section 10 of the Atomic Energy Control Regulations refers to the issuance of licenses for construction of nuclear facilities. Section 10(3)(b) indicates that the written application for a construction license should set out
"an assessment of the hazards that may result from the operation of the nuclear facility and a description of the measures taken to prevent or minimize such hazards."
The Law List Regulations of CEAA, Schedule I, Part II, Item 3(b) references section 10 of the Atomic Energy Control Regulations. We believe that all the provisions of section 10 should be taken into account when an environmental assessment is performed pursuant to the licensing of any nuclear facility. This includes hazards that may result from its operations. Environmental assessment is routinely taken into account when licenses are renewed for existing nuclear facilities. Logically, licensing of the operation of new nuclear facilities should receive a higher level of environmental assessment that the renewal of licenses for existing facilities.
An initial screening of the Medical Isotope Project was conducted in early 1997. On April 4, 1997,
Board members accepted the conclusions of the environmental screening report prepared by AECB staff in cooperation with staff of Natural Resources Canada, which determined that the proposed project to construct two 10 MW MAPLE reactors and a processing facility for the commercial production of medical isotopes at the Chalk River Laboratories in Chalk River, Ont., is not likely to cause significant adverse environmental effects (AECB 1997a) [emphasis added]
Section 4 of the CEAA screening report for the Medical Isotope Project (AECB/NRCan 1997) is entitled "Scope of the Project and of the Assessment". It states that "the undertaking comprises the construction of two MAPLE reactors, a processing facility, and the modification to existing facilities and services on site. [emphasis added]. This screening report, and the press release describing the April 4, 1997 decision by the AECB, both indicate that an assessment of the environmental effects of operating the new facilities associated with the Medical Isotope Project has not yet been done.
By not considering project operations - particularly operating hazards and measures taken to prevent or minimize such hazards - the CEAA screening report did not fully address section 10 of the Atomic Energy Control Regulations. Section 7.5 of the CEAA screening report (AECB/NRCan 1997) describes "Routine Operations" but does not the hazards associated with them. Of particular concern are hazards associated with management of the wastes generated by the project. Furthermore, Section 4 of the CEAA screening report states that "transportation of radioactive material to and from CRL were assessed" [emphasis added]. But Section 6.2.4 ("Transportation of Radioactive Material") did not discuss the transportation of radioactive material to CRL.
We find it particularly disturbing that issues relating to
have not been considered. We also find it disturbing that Canadian taxpayers may be expected to bear the waste management costs associated with this project, thereby further subsidizing the operations of MDS/Nordion, a private, for-profit health care services corporation. We submit that the provision of long-term funding for management of solid high-level wastes from the Medical Isotope Project is an issue of major concern from an environmental assessment perspective.
We believe that the Board has not been provided with adequate information on waste issues related to the production of medical isotopes at Chalk River Laboratories. The removal of weapons-grade materials from commerce and transportation, and the removal of associated threats of terrorism and nuclear proliferation, should be a global priority. Alternative methods exist for medical isotope production that would largely alleviate these security concerns and greatly reduce waste volumes.
In particular, 99-Mo could be recovered from solution reactors powered with 20% enriched uranyl nitrate fuel, eliminating wastes generated in target fabrication and target disassembly (Glenn et al. 1995). It should be noted the volume of waste U-235 generated per unit of medical isotope produced will double when production is shifted from the NRU reactor to the new MAPLE reactors, owing to their lower neutron flux density (AECL 1996). AECL (1996) briefly examined the solution-fueled reactor as an alternative to the MAPLE reactors and concluded that it "may have significant advantages over a conventional reactor, but the time required to develop and license such a reactor is uncertain". The CEAA screening report (AECB/NRCan 1997) failed to consider this alternative.
The management of high-level liquid wastes associated with this project is also a matter of serious concern. Current processing operations generate significant amounts of U-235 that are stored in solution in the "FISST" tank. We previously noted (CCRCA 1997) that this tank has received considerable attention from AECB in recent years, including the potential for a criticality event or an accidental release of its contents. But all project documents we have seen are silent on the long-term fate of the wastes in the FISST tank.
In response to our earlier intervention on this matter we received a letter from AECB staff maintaining that the "New Processing Facility includes facilities for solidifying wastes, thus eliminating the need for long term storage of liquid radioactive waste in the FISST tank" (Aly 1997). But this response does not indicate whether the new processing facility will be used to solidify existing wastes in the FISST tank. And new high-level liquid wastes will continue to be added to the FISST tank until it is replaced. As of October 1997, the new processing facility was still in the "conceptual design stage" (AECB 1997b). How long is the transition to the new facility expected to take? What will be done with the high-level liquid wastes that will continue to accumulate until it is operational? And what will we done with the accumulated backlog of high-level liquid wastes? These wastes pose a continuing environmental hazard that must be dealt with in the context of this project.
There are indications that AECL is now preparing an environmental screening document for construction of a new Waste Management Area for storage of the solidified U-235 wastes from the Medical Isotope Project. If this is true, we observe that this environmental screening should be incorporated within an overall assessment of the operations of the new facilities. A piecemeal analysis of environmental effects from this project is contrary to the intent of CEAA. It makes it essentially impossible for the public to participate meaningfully in the environmental assessment of the overall project. It also makes it very difficult for the Board to render a decision concerning the significance of its environmental effects. It remains our view that "it is essential that the Medical Isotope Project be subjected (at minimum) to comprehensive study" (CCRCA 1997).
The use of U-235 poses not only security risks, but also criticality hazards. The operation of the MAPLE reactors and the processing facility, and the handling of the U-235 targets and U-235 oxide powder, all pose risks of serious accidents involving uncontrolled fissioning of U-235. AECL (1996) does not assess criticality risks associated with fabrication and handling of the U-235 targets, and provides virtually no details on this aspect of operations. Although AECL (1996) does assess the hazards to the public of airborne emissions from accident scenarios involving facility operations, AECB/NRCan (1997) did not consider these operational aspects as part of the scope of its project screening, and hence did not perform a credible assessment of accident scenarios.
A serious accident at the Medical Isotope Project facilities would have adverse effects on the local community in addition to potential airborne exposures to a member of the public living off the CRL site. These include radiation doses to site workers who are resident in the community, the disposal of highly contaminated liquid wastes generated by such an accident (including the risk of contamination of public drinking water supplies), and the psychological stress to all community members in dealing with an emergency situation. These potential hazards must be assessed.
The conclusion in AECL (1996) that "environmental effects from the accident scenarios are insignificant" is irresponsible, in our view. This could result in carelessness on the part of AECL as operators of the new facilities, as manifested in inadequate worker training, poor quality assurance and control, and failure to implement emergency planning measures and to maintain readiness to respond to emergencies. Emergency planning and response measures are essential for mitigation of potential adverse environmental effects during the project's operational stages. These topics have received no consideration whatsoever in the environmental assessment of the project to date.
In conclusion, the Board's April 4, 1997 decision that construction of Medical Isotope Project facilities "is not likely to cause significant adverse environmental effects" can not be applied to the issuance of an operating license for these facilities. We request that the Board conduct a comprehensive study of the environmental effects associated with operation of these facilities, and issue a finding concerning the significance of these effects. This study should be conducted prior to initial consideration of an operating license. Its results should be used to inform the Board's decision on the project and be taken into account in the terms of any license that may be granted for operation of project facilities.
Yours sincerely,
References
AECB. 1997a. AECB announces recent decisions. Environmental assessment of the Medical Isotope Project. New Release 97-07. Atomic Energy Control Board, Ottawa.
AECB. 1997b. Initial consideration: Construction approval for the MDS Nordion Medical Isotope Reactor (MMIR) project - new processing facility. BMD 97-186.
AECB/NRCan. 1997. Canadian Environmental Assessment Act screening report for the Medical Isotope Project at the Chalk River Laboratories. Revision 2. 12 February 1997. Prepared by the Atomic Energy Control Board in collaboration with the Department of Natural Resources Canada. File 26-1-62-4-2.
AECL. 1996. Environmental screening report for the Medical Isotope Project. 28 October 1996. Atomic Energy of Canada Limited, Ottawa.
Aly, A.M.M. 1997. Reply to Ms. Lynn Jones, President, Concerned Citizens of Renfrew County and Area. 12 May 1997.
CCRCA. 1997. Comments on "Canadian Environmental Assessment Act screening report for the Medical Isotope Project at the Chalk River Laboratories". 5 March 1997.
Glenn, D., Heger, A.S. and Hladik, W.B. III. 1996. Comparison of characteristics of solution and conventional reactors for 99-Mo production. Nuclear Technology 118: 142-150.