Review of "Environment Impact Statement on the Concept for Disposal of Canada's Nuclear Fuel Waste" (AECL-10711)
Draft - February 18, 1995
General comments
A topic as important as high-level nuclear waste disposal warrants a comprehensive environmental assessment. "End-of-pipe" solutions are generally more costly than alternative means of providing goods or services that are creating pollution and waste. Nuclear power has been discredited in the public view because its proponents failed to address "downstream" nuclear waste issues. The present study perpetuates this fragmented assessment approach by failing to consider "upstream" issues of waste generation and alternatives to generating these wastes.
The Environmental Impact Statement (EIS) is largely focused on risks to human health and the environment that would occur after the closure of a disposal facility. Our group, potential host communities, and the general public will all be more concerned about risks from waste transport and operation of the facility. The EIS does not provide an adequate assessment of these pre-closure risks. It is virtually silent on issues of cask handling. It does not describe whether wastes are placed in disposal containers at generating facilities or at the disposal facility. It does not discuss radiation exposure at points when fuel wastes are temporarily unshielded during transfers from existing dry storage containers to transportation casks, and from transportation casks to disposal containers.
The EIS (page 242-243) cites relatively high annual probabilities of accidents occurring at the disposal facility, both at the surface (0.2%) and underground (0.4%). The methodology for calculating these probabilities and resultant radiation exposures is not described. The EIS provides a table for estimated doses to the public from accidents at the facility (page 243), but does not provide an equivalent table for workers. In particular, the dose to an underground worker from dropping a container cask down the shaft combined with a ventilation failure is not estimated, and it is implied that the radiation dose from such an accident would be less than that from a shaft failure during which the ventilation system was functioning.
The EIS does not address the issue of increasing radiation levels within the facility during its operating life, and impacts of this increased radiation on worker health. It does not consider the possibility that exposure levels could rise to levels that would force premature closure of the facility owing to unacceptable radiation levels, or the associated costs of remedial action in this event.
Most significantly, the EIS does not provide a credible analysis of the potential for extended storage of fuel wastes at existing sites to reduce radiation exposure to workers and the general public. On page 262 it is stated that increasing the out-of-reactor time for the used fuel from 10 to 40 years would reduce the estimated external dose from cask handling by a factor of two.
The assumptions and calculations used to arrive at this conclusion are not detailed, and it appears inconsistent with a negative exponential trend in waste activity (e.g., page 2 of the Summary). A credible and thorough assessment of prolonged out-of-reactor storage is essential for making an informed decision on the proposed disposal concept. This assessment should examine exposures during normal operating conditions and from accidents.
The Panel's terms of reference require that it recommend "the steps that must be taken to ensure the safe long-term management of nuclear fuel wastes" (Summary, page 8). This should be considered in view of the following statements made by the proponent in the Summary of the EIS:
- "we expect a disposal system would function to protect human health" (page 9);
- "the purpose of geological disposal is to protect human health" (page 18); and
The EIS examines health only in the context of comparing theoretical radiation exposures associated with the disposal concept to regulatory dose limits for radiation exposure. "Safe" is defined in the Glossary of the EIS as "meeting criteria, guidelines, and standards". This very narrow legal definition of "safe" is not consistent with normal usage or with any dictionary definition of which we are aware. It appears to exclude a consideration of cumulative and population radiation doses. The EIS contains no discussion of scientific findings concerning health impacts caused by radiation exposure, and by extension does not attempt to link such findings to estimated radiation doses from operation of the proposed facility. Instead of a credible scientific assessment of health costs and benefits of the disposal concept, the EIS contains a series of unsupported assertions that health will be protected.
Risks can be minimized, but "safety" and "human health" are not realistic or achievable standards for nuclear waste management. Vague and unsubstantiated references to "health" and "safety" as a basis for EIS conclusions and possible future Panel recommendations may in fact tend to increase risks. The Panel has been given an unachievable absolute standard. Its terms of reference do not encourage the use of a credible scientific framework for assessing relative risks of various options within the "disposal concept". This is a serious shortcoming.
The Panel has been asked to assess a single, hypothetical case for nuclear waste disposal without a detailed sensitivity analysis of key variables such as final waste volumes, dimensions of the facility (including spacing of the wastes within it), and duration of interim storage prior to disposal. The questionable use of an absolute "safety" criterion in the Panel's terms of reference, the narrow interpretation of this criterion by the proponent, and the lack of a credible scientific approach to assessment of health risks for workers and the general public, have combined to produce an unacceptably flawed EIS.
Specific comments on the Summary of the EIS
The following specific comments are based upon page numbers in the Summary. When references are made to the full EIS, this is so noted.
Page 2 lists three characteristics of used fuel that are particularly important when considering its management. The third of these is that "volume per unit of electricity generated is small". This is clearly not a characteristic of used fuel, but is an important consideration in comparing sources of nuclear fuel wastes. The proponents should provide a detailed analysis of high level wastes generated per unit electricity for various reactor types used in Canada, and a general comparison with reactor types used in other countries.
Page 2 mentions that used fuel contains "chemically toxic elements in sufficient quantities that they need to be considered when evaluating the effects of disposal". These are described only in extremely general terms on page 244 of the EIS. This description does not include an analysis of the quantities of these elements in the used fuel.
The description of the characteristics of used fuel on page 2 of the Summary fails to mention any specific elements or isotopes that make it hazardous. Appendix F of the full EIS, which lists individual radionuclides in fuel wastes, states that many were not considered for the pre-closure studies. No rationale is provided for including or excluding radionuclides from pre-closure studies. There is only a general treatment of exposure pathways associated with radionuclides (EIS, page 240), with no attention given to individual elements. The potential for radionuclides to accumulated in the vicinity of the disposal facility is not examined, even though radioactive gases will be routinely vented during operation of the facility. Assumptions used in calculating worker exposures during operation of the facility are not provided. No attempt has been made to assess the accumulation of radiation in the underground portion of the facility and its implications for worker health and safety.
The figure on page 2, entitled "Decrease in activity of a used-fuel bundle", could be viewed as an attempt to create a false impression of lack of danger to human health. Equating nuclear wastes with such familiar items as buildings, people, books, money, and credit cards is not a scientifically credible approach. The "Activity Scale" on the y-axis of this figure has no units, such as sieverts, that would help assess the danger of nuclear fuel waste. Most significantly, the activity of a fuel bundle before it is placed in a reactor is not represented. An unused fuel bundle provides an essential baseline for comparison with used fuel bundles of different ages. The description beneath the figure states that radioactivity of a fuel bundle is "less than 0.001% of its initial value" after 1000 years. The initial value used for this comparison should be an unused fuel bundle, and not a fuel bundle just removed from a reactor.
Page 4 states that "utilities who own used fuel include the cost of its disposal in the rates charged for electricity". This point is critical for understanding the economic aspects of the proposed disposal concept. A detailed description of current funding arrangements to finance the proposed disposal facility must be an integral part of the EIS. This is currently lacking.
A figure on page 5 provides four scenarios for used-fuel projections, none of which is realistic. Although scenario 3 is "no new construction after 1993", it assumes that all current reactors will be operated for 40 more years. However, some reactors included in scenario 3 are no longer in operation. A scenario between 3 and 4 should be presented that reflects best judgement of probable lifetimes of currently operating reactors.
Page 5 speculates as to whether future generations might be "technologically incompetent". This is an interesting notion that should be further developed. What are the characteristics of a "technologically competent" society?
The statement on page 6 that "Canada cannot expect to dispose of its nuclear fuel waste in another country" suggests that the converse should also be stated explicitly: "Other countries cannot expect to dispose of their nuclear fuel waste in Canada". If this statement is not included in the EIS, the assessment must be revised to address international dimensions of nuclear waste transportation, including the potential for terrorist attacks and nuclear weapons proliferation.
The figure on page 7 labelled "Geological Media in Canada" suggests that disposal under Hudson Bay and certain other arctic waters are potential options. Although Canada has a valid claim to sovereignty over arctic waters under the "straight baselines" principle of international law, asserting Canada's right to marine disposal of nuclear wastes has additional legal implications. If the intent of the proponent is to retain a marine disposal option, a discussion of legal implications must be included in the EIS. Specifically, does Canada interpret its obligations under the London Dumping Convention (EIS, page 326) as precluding seabed disposal in its territorial waters?
Although a 1981 Joint Statement of the governments of Canada and Ontario announced that "responsibility for disposal site selection and subsequent operation need not be allocated until after concept acceptance" (page 8), it is clear that this should not exempt the proponent from a generic treatment of socio-economic issues in the EIS. Such a treatment is in fact contained in Section 6.11. Our experience in Renfrew County suggests that the potential for a nuclear waste siting process to create significant tensions within a community and among neighbouring communities should not be underestimated. The decision not to identify an operator diminishes the power of the EIS. This greatly weakens the Panel's ability to judge the economic and social feasibility of the disposal concept. The EIS does not forthrightly address the issue of "Who should be the operator of the facility?". This question is also side-stepped in the recommendations (see below).
If interpreted literally, the 1981 Joint Statement would also suggest that an assessment of the "disposal concept" could be made without considering the operation of the disposal
facility. This is obviously impossible. The EIS does "indicate how AECL would propose that the disposal concept be implemented" (page 8), although, as noted throughout this brief, the treatment of operational aspects is inadequate.
On page 9, a list of waste barriers to "protect humans and the natural environment" includes "the geosphere", defined as "the rock, any sediments overlying the rock below the water table, and the groundwater". Rocks, sediments, and groundwater are normally considered part of "the natural environment". By redefining these elements of the environment as part of the barrier system for the proposed facility, the proponent appears to be seeking approval for a much wider degree of environmental contamination than would be accepted by most members of the public. Would widespread groundwater contamination be considered an acceptable part of the proposed nuclear waste facility?
There appears to be no particular standard for determining container lifetime, and, by extension, isolation of the nuclear wastes (page 10). If there is no standard, there should at least be some baseline for comparison. For example, the residual radiation within the facility at the projected time of container disintegration could be compared to radiation levels in naturally occurring ore bodies.
Page 10 also states that the disposal vault would be "excavated nominally" to a depth of 500 to 1000 metres. What is meant by "nominal excavation"? What is the basis for choosing this range of depths? Prevention of waste migration to the surface environment is obviously a major consideration in choosing a vault depth, and a thorough treatment of this topic is needed in the EIS.
The table on page 12, entitled "Canadian Research and Development on Disposal", outlines a series of static activities that are all irrelevant to "disposal" in the sense of "the act or process of disposing". What research has been done to generate accident probabilities during the actual handling of casks of a size and shape analogous to those that would be placed in the disposal facility? Has the research and development to date produced information relevant to actual operating conditions, or is it restricted to the "post-closure" mode?
Logically, one would expect to find a detailed treatment of short-term performance of a disposal system during its operational mode before the discussion of long-term performance (page 13). Neither the EIS nor the Summary is organized according to a logical time sequence of activities. Pre-closure assessment is presented almost as an afterthought rather than as an essential part of the EIS.
The diagram on page 19 of "The Hypothetical Disposal Vault" lacks a scale for distance, but suggests that containers will be placed in close proximity to one another. The brief discussion of criticality danger in the EIS should be strengthened with an analysis of spacing and fuel age considerations.
A section on "Estimated Socio-Economic Effects" (page 39) refers to the potential for "a new demand in the market place" created by a disposal facility. This statement must be amplified and clarified. Does the proponent intend to create an international, competitive market for high-level waste disposal based on a low-cost facility that meets minimum safety standards, or is the intent to protect human health and the environment and minimize the burden placed on future generations?
The table on page 40, entitled "Estimates of Schedule and Cost..." lists no sources for any of the cost estimates provided. Among the primary references (described on page vii), only that entitled "Engineering for a Disposal Facility" appears to contain cost estimates. A detailed economic analysis is essential for assessment of the disposal concept. The recommendations in the EIS can not even be seriously considered without such an analysis.
One of the key recommendations of the EIS is that "the federal
government and the owners of the used fuel" be given responsibility
for implementing the disposal concept (page 44). This vaguely worded recommendation
amounts to a request by the proponent for an unlimited public subsidy for
disposal of Canadian, and perhaps even foreign, high-level nuclear wastes.
This is totally at odds with the "polluter pays" principle. Utilities
generating nuclear wastes must be financially accountable for their disposal.