-- deadline for letter submissions is Friday, December 20, 2019 --
Natural Resources Canada (NRCan) needs to hear from you today about a proposal to allow nuclear reactors to be transformed into permanent radioactive waste disposal facilities.
The federal government has the responsibility to develop radioactive waste policy. Under the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, ratified in 2001, Canada must pay “due regard to internationally endorsed criteria and standards” such as those related to decommissioning of nuclear facilities.
The safety standard on Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities, prepared by the International Atomic Energy Agency in 2018, says, "On-site disposal of decommissioning waste is not a recommended practice in the case of decommissioning after normal operation."
However, our “independent” nuclear regulator, the Canadian Nuclear Safety Commission (CNSC), wants to allow on-site disposal of nuclear reactors - facilities that will remain radioactive for thousands of years after shut-down.
The CNSC is proposing that nuclear facility operators consider the strategy of “in situ decommissioning” - to place the facility, or portions of the facility, in a safe and secure condition, in which some or all of the radioactive contaminants are disposed of in place, which may result in the creation of a waste disposal site (draft REGDOC-2.11.2, Decommissioning)
The nuclear industry wants to go further. In its comments on the draft REGDOC, it wants the CNSC to call in-situ decommissioning an “accepted and acceptable practice,” and to delete language that would require operators of nuclear facilities “to conduct a comparison of alternative decommissioning strategies.”
The federal government has no policy on decommissioning of nuclear facilities, and only a 143-word, 3-bullet “Radioactive Waste Policy Framework” that makes no reference to Canada’s obligation to follow international standards.
In 2015 the federal government contracted a multinational consortium to operate their own nuclear facilities - including six shut-down reactors. The consortium has proposed “in-situ decommissioning” of federal reactors located in Pinawa, Manitoba and Renfrew County, Ontario. Environmental assessments of these two proposals are being conducted under the 2012 version of the Canadian Environmental Assessment Act, which gives the CNSC exclusive authority to decide if these proposals are acceptable.
Please join with us in asking Minister of Natural Resources to uphold Canada’s international obligations and fill the radioactive waste policy void. Tell him that on-site disposal of nuclear reactors and other nuclear facilities is unacceptable.
Thank you for taking action and for sending your letter below!
Dr. Ole Hendrickson - Sierra Club Canada Foundation Board of Directors