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Nuclear Waste Disposal
Action Alert and Backgrounder

The Nuclear Waste Management Organization, a nuclear industry supported body, has released a set of draft recommendations on the disposition of high-level radioactive waste.

Sierra Club of Canada and others have identified critical weaknesses in the draft report. The public has until August 31, 2005 to respond. Read our action alert and backgrounder to find out what you can do.



The Issue
What You Can Do

Backgrounder

What the NWMO is doing
Summary of NWMO Recommendations
The NWMO Report
Areas of Concern


July 2005

The Issue - High Level Radioactive Waste

There is no foolproof or simple solution to the dilemma of high-level radioactive waste. Future generations will be burdened for thousands of years with nuclear fuel waste from Canadian nuclear reactors produced over the last fifty years.

A federal environmental assessment panel (the Seaborn Panel) called for the creation of a nuclear fuel waste management agency “at arm's length” from the nuclear industry, with a board of directors representative of independent “key stakeholders”. The federal government chose to ignore this recommendation when, in 2002, it created the Nuclear Waste Management Organization (NWMO).

NWMO is a private organization of the owners and producers of nuclear fuel wastes (Ontario Power Generation, Hydro Québec and New Brunswick Hydro), incorporated under the federal Nuclear Waste Act. The NWMO board is comprised solely of nuclear industry representatives. The nuclear industry strongly supports “deep geological disposal” of radioactive waste, an option that was rejected by the Seaborn Panel.

The mandate of NWMO is to study and recommend a method for the long-term management of high-level nuclear fuel waste in Canada by November 15, 2005.

In May 2005, the NWMO released a set of draft recommendations, Choosing a Way Forward: the Future Management of Canada's Used Nuclear Fuel, Draft Study Report (available online at www.nwmo.ca). The deadline for the public to submit comments on these recommendations is August 31, 2005.

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What You Can Do

Please let the NWMO and your federal MP know how you feel about the Draft Report.

Here are some general points to consider (specific comments on the draft report can be found in the “Areas of Concern” section below):

  • As a fundamental starting point, the management of high-level radioactive waste in Canada should be premised on the phase-out of nuclear power at the earliest possible time. There are better, more environmentally and fiscally responsible alternatives. If even a fraction of the billions of dollars in public money that has been given to the nuclear industry had been put in to fast-tracking renewable energy alternatives, Canada would now be a world leader in wind power and other renewable technologies.

  • The federal government should guarantee a joint federal/provincial environmental assessment panel on the full range of radioactive waste management options, which includes an explicit framework for the phaseout of nuclear power, following the NWMO recommendation in November 2005. The process should be adequately funded by the proponents in order to allow public interest intervenors to retain independent technical expertise. The federal government should also guarantee a full parliamentary debate and free vote on the recommendations of the NWMO and the environmental assessment panel.

  • Any waste management option should, for the foreseeable future, be based on surface and/or near-surface monitored and retrievable storage -- at least until a nuclear power phaseout has been achieved, the technical case for an alternative option (or options) been thoroughly reviewed, and a social consensus has been achieved.

  • If the federal government decides on a centralized waste management option (whether above or below ground), there will be risk to communities along the transportation route, as well as to the potential recipient community. In such a case, the potential recipient and transport route communities should all have veto power, and should receive funding from proponents for independent research and community education.

  • The federal government should guarantee that high level radioactive waste will not be imported into Canada.


Your comments should be submitted to the NWMO by August 31, 2005 at: www.nwmo.ca
or:

Toll Free 1-866-249-6966
Tel 416-934-9814
Fax 416-934-9526

By mail:

Nuclear Waste Management Organization
49 Jackes Avenue, First Floor
Toronto, Ontario
M4T 1E2


You can read the NWMO Draft Recommendation: Choosing a Way Forward: the Future Management of Canada's Used Nuclear Fuel, Draft Study Report online at: www.nwmo.ca. Paper copies can be requested directly from the NWMO at 416-934-9814 or 1-866-249-6966.

The Nuclear Waste Act can be viewed online at: http://laws.justice.gc.ca or at www.nfwbureau.gc.ca

E-mail addresses and other information for federal MPs can be found at: http://www.parl.gc.ca/





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Background

What the NWMO is doing

The NWMO has drafted a recommendation to the federal government to permanently dispose of High Level radioactive nuclear waste in an underground geologic repository.

The repository is to be sited in Ontario, Saskatchewan, New Brunswick or Quebec, in either Ordovician sedimentary rock formations, or in the crystaline rock of the Canadian Shield. The NWMO's recommendation will be finalized and submitted to the federal government on November 15, 2005.

The Nuclear Waste Act requires the NWMO to study at minimum:

  • deep Geologic disposal in the Canadian Shield (a concept developed by Atomic Energy of Canada Limited and Ontario Hydro in the 1980's, but not recommended by the Seaborn Panel Environmental Assessment);

  • long term storage at nuclear reactor sites; and long term centralized storage, above or below ground.

  • They may propose other management options.

In their three year study of these options, the NWMO are required to assess each option and to consult with the public and Aboriginal peoples on each option. Their mandate includes only the management of high level nuclear fuel wastes (used nuclear fuel bundles), and has been interpreted narrowly by the NWMO to include only the isolation, storage, or conversion of the wastes.

The NWMO interpret their mandate to exclude managing the production of the waste, and disconnect it from all discussion of energy policy.



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Summary of NWMO Recommendations

The NWMO is Recommending: “Phased Adaptative Management”

Following two and a half years of study the NWMO are recommending a modified version of deep geologic disposal in the Canadian Shield, for the management of high-level radioactive nuclear waste. Called “Phased Adaptive Management”, it involves moving all of Canada's 3.7 million used nuclear fuel bundles (high level radioactive nuclear waste) over the course of 300 years from storage at existing nuclear reactor sites to a sealed deep geologic disposal facility. The plan also includes the construction of a deep geological disposal demonstration facility at the disposal site (for rock characterization and testing prior to final disposal), and allows for the possibility of constructing an interim shallow underground centralized storage facility at the site prior to geologic burial.

This approach has 3 major phases:

1. Continued storage of fuel at existing nuclear reactor sites (1-30 years) while:

  • A site suitable for a deep geologic repository, and interim shallow centralized storage is found.
  • A deep geologic demonstration facility is licensed and built at the site
  • A decision is made whether or not to build an interim centralized (shallow underground) storage facility for the waste prior to disposal, and If Yes: an operating licence is obtained
  • a construction licence for deep geological repository is obtained

2. Centralized storage OR continued reactor site storage (30-60 years) while:

  • research is conducted at demonstration facility to ensure suitability of site for deep geologic disposal.
  • If an interim centralized storage facility is to be built at the disposal site, the facility is built, an operating licence is obtained, and the waste is moved from reactor sites to centralized storage. Otherwise, waste remains in storage at reactor sites.
  • an operating licence for the deep geological disposal facility is obtained
  • A decision is taken for when to move to deep geological disposal.

3. Deep geologic disposal (approximately 60- 300 years)

  • The fuel is repackaged and moved from centralized storage or from reactor storage into the deep geologic disposal facility. (including repackaging at the site)
  • The facility is monitored for up to 300 years
  • a decision is taken to seal the facility (at approximately 300 years).
  • Fuel remains sealed under ground for infinity

A more detailed description of this option is can be found in Appendix 3 of the report : pages 247-261. A map of possible site locations can be found on page 252 of the report.



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The NWMO Report

The NWMO report: Choosing a Way Forward: the Future Management of Canada's Used Nuclear Fuel, Draft Study Report is a summary of the NWMO's study of nuclear waste management options.

The purpose of the report is:

  • To recommend (draft) to the minister a method for Nuclear waste management;
  • To summarize their analysis and study including:
  • Development and use of their Analytical framework
  • Assessment of each nuclear waste management option using the framework (including risk and safety assessments);
  • To summarize the comments of the “general public” and Aboriginal peoples on each of the management options studied;
  • To outline an implementation approach (including siting and public consultation) for each option studied;
  • And to serve as a public information and education document about nuclear waste management.




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Areas of Concern

The NWMO draft report is troubling for several reasons:

  • Education: the information presented in this report presents a view of the nuclear industry, radiation safety, the generation of nuclear energy, nuclear waste management, and the history of nuclear fuel waste management policy making which is favourable to the nuclear industry. This perspective excludes the challenges, politics, controversies and problems that surround the nuclear industry and the development of nuclear waste management policy. Especially troubling is the lack of debate uncertainty, and controversy that exists within the scientific community about the effects of radiation on risk levels and ionizing radiation (see http://www.nirs.org/press/06-30-2005/1 or the BEIR VII - Biological Effects of Ionizing Radiation report for recent findings). The NWMO draft document is presented to the public as an objective, depoliticised, unbiased, and factual source of information upon which to make a decision.

  • Radiation health and safety (reported on in Appendix 2, pages 240-246) is not treated reasonably. Information of questionable integrity is presented in a manner favourable to industry. Very little information about the actual health effects of radiation is provided or analyzed, especially with respect to ecosystems or people, and no information is provided about the behaviour of radioactivity over hundreds of thousands of years in particular geologic and biospheric environments. Very little information is provided in the assessment and analysis of the different options (chapter four of the report) to substantiate claims made that the ecosystem, and communities will not be adversely affected in the short or long term.

  • The assessments conducted by the NWMO and summarized in chapter four of the report are unsubstantiated. Rather they appear to be a collection of assertions favouring deep geologic disposal without much actual judgement or analytical basis. The environmental and human consequences of these assertions could be devastating. See above.

  • Uncertainty (the quality of knowledge and certainty of claims) is not taken seriously, and not treated with respect. Too much confidence is placed in predictions and modeling over hundreds of thousands of years based on analogue data.

  • Siting: no assurance is provided that this will be a voluntary siting process; that communities or aboriginal nations/communities near a facility or on a transportation route will have a veto power or planning authority; or that Aboriginal and Treaty rights will be respected to the satisfaction of Aboriginal peoples and the law. Many social justice issues remain about the fairness of an economically or culturally excluded community accepting to host a facility in return for compensation and a boom and bust economy. Many areas of social justice are glossed over. (see chapters 11-15 of the report)

  • General Public consultation by the NWMO, in fulfilment of its legislated requirements, has been poor, focusing mainly on opinion polling, surveys, and focus groups made up of individuals unfamiliar with nuclear waste issues. Very little attempt has been made to actually engage groups such as environmental, social justice or public interest groups on their own terms, and no effort has been made to engage with the claims, experiences, or information of groups who have had negative experiences with the nuclear industry.

  • Consultation with Aboriginal peoples has not occurred in any way that is considered by aboriginal groups, nations, or governments to be legitimate or legally appropriate. Aboriginal peoples have not been provided with the resources, freedom, or capacity to comment on each of the nuclear waste management options studied, and the experiences of aboriginal peoples with the nuclear industry (and their knowledge) have not been engaged by the NWMO. Despite constant denouncement from aboriginal organizations, the NWMO continues to use what it calls “Traditional Ecological Aboriginal Knowledge” in what many have called inappropriate, pejorative, and offensive ways. (Assembly of First Nation responses to the work of the NWMO can be found online at: www.afn.ca)

  • No commitment to a phase out or termination of the polluting source: While the omission of such a commitment may be unsurprising, given that NWMO is industry-controlled, it is socially and environmentally irresponsible. Any socially and environmentally acceptable plan for the management of nuclear fuel waste must include a commitment to the early phase-out of nuclear power generation.


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