HomeMy WebLinkAboutCAO 11-05PICKERING
REPORT TO
COUNCIL
Report Number: CAO 11-05
Date: July 18, 2005
039
From:
Thomas J. Quinn
Chief Administrative Officer
Subject:
NWMO Draft Study Report "Choosing A Way Forward"
City of Pickering's Comments to NWMO
File: S-5610-011
Recommendations:
That Report CAO 11-05, concerning the Nuclear Waste Management
Organization's (NWMO) Draft Study Report "Choosing a \Nay Forward: Future
Management of Used Nuclear Fuel in Canada" be received.
That the peer review comments prepared by Acres-S&L. with respect to the
NWMO's Draft Study Report be endorsed and forwarded to the NWMO for
consideration in preparing its Final Study Report.
That the NWMO be requested to develop and describe in the Final Study Report,
a comprehensive approach to addressing the issue of host community
compensation for the interim storage of nuclear fuel at the existing nuclear
facilities, from the time the used fuel was initially located at these facilities, to the
time the used fuel is permanently removed from these facilities.
That a copy of this Report be forwarded to the NWMO, the Federal Minister of
Natural Resources, the Ontario Power Generation, member municipalities of
CANHC, M.P. Dan McTeague, M.P. Mark Holland, and M.P.P. Wayne Arthurs.
Executive Summary:
In May 2005, the Nuclear Waste Management Organization (NWMO) released a Draft
Study Report entitled "Choosing a Way Forward." This report ,.synthesizes NWMO's
work to date and presents a draft recommendation on a management approach for
Canada's used nuclear fuel. NWMO had asked for comments on the draft study report
by the end of August 2005.
To assist in commenting on the Draft Study Report, the NWMO agreed to provide peer
review funding through the Canadian Association of Nuclear Host Communities
(CANHC). As a result, the consulting company Acres-S&L (ASL) was hired to
undertake an independent review of NWMO's work. ASL has now completed its peer
review report.
0,;~deport CAO 11-05
Subject: NWMO Draft Study Report
Date:
July 18, 2005
Page 2
ASL found that the preferred management option recommended by NWMO (called
"Adaptive Phased Management") effectively addresses many of the concerns and
weaknesses associated with the other options that were examined, while building on
their strengths. Based on their review, ASL agreed that Adaptive Phased Management
is a technically reasonable approach.
In addition, ASL has identified several issues with NWMO's Draft Study Report, and
has provided specific recommendations with respect to each of these issues (see ASL's
Executive Summary, attached as Attachment 1). One of these issues is of particular
interest to the City; that being the issue of host community compensation for the interim
storage of used nuclear fuel at the existing nuclear facilities. ASL found some
confusion and/or inconsistency concerning the role NWMO verbally advised it would
play with respect to interim storage at existing reactor sites in comparison to the
position put forward by NWMO in the Draft Report. ASL therefore recommended that
NWMO clarify its position on this matter, and clearly state whether existing host
communities will be given the same consideration for mitigation and compensation as
new host communities.
It is appropriate for the NWMO to clarify this matter. As well, the. opportunity exists at
this time for the City to take a more proactive position and ask that the matter be dealt
with (not just clarified). Accordingly, in addition to seeking clarification on the NWMO's
role, an additional recommendation is included asking the NWMO to develop and
describe in the Final Study Report a comprehensive approach to dealing with the issue
of host community compensation for the interim storage of nuclear fuel at existing
nuclear facilities.
Financial Implications:
None, with respect to the preparation of this Report, as the full cost of ASL's peer
review was covered by the NWMO.
Background:
The Nuclear Waste Management Organization (NWMO) was mandated by the Nuclear
Fuel Waste Act to identify and recommend a suitable option for long-term nuclear waste
storage in Canada. The Act requires a final report to be submitted to the Minister of
Natural Resources Canada by November 15, 2005. The legislation also authorizes the
Government of Canada to decide on the approach. The Government's choice will then
be implemented by the NWMO, subject to all of the necessary regulatory approvals.
Two discussion documents were released by the NWMO ahead of the release of the
Draft Study Report. The City provided comments on both of these earlier documents.
Report CAO 11-05
Subject: NWMO Draft Study Report
'Date: July 18, 2005
Page 3
04i
Peer review funding was provided by the NWMO to the Canadian Association of
Nuclear Host Communities (CANHC) to assist in the review of the Draft Study Report.
The firm Acres-S&L (ASL) was again selected to provide CANHC with peer review
consulting services (ASL had provided peer review services to CANHC in the past).
The NWMO released its Draft Study Report in May 2005 and has asked that comments
be provided by the end of August so that it can review these comments and prepare a
Final Study Report for submission to the Federal Minister of Natural Resources by mid-
November 2005.
ASL conducted an independent review of the NWMO's Draft Study Report and its
reference materials. Through its review, ASL identified a number of key issues of
importance to the member municipalities of CANHC and provided recommendations on
these issues. ASL provided recommendations under three headings: the Draft Study
Report, Adaptive Phased Management (which is the recommended nuclear waste
solution), and Implementation Planning.
An Executive Summary of ASL's peer review report is attached as Attachment 1. The
full ASL report is available for viewing through the CAO's Office.
The key finding of the peer review is that ASL agrees with the recommended nuclear
waste management solution proposed by the NWMO, called Adaptive Phased
Management. ASL finds this option to be an appropriate technical solution that
effectively addresses many of the concerns or weaknesses associated with the other
options, while building on their strengths. ASL notes that while there are significant
risks and costs, along with benefits, associated with this option, Adaptive Phased
Management is more advantageous than the three primary alternatives.
At the outset of its work, NWMO was mandated to examine at least three options for
long-term nuclear waste storage: deep geological, centralized storage, and storage at
existing nuclear facilities. Other options could also be considered.
Following an assessment of the three primary approaches, the NWMO decided that
there was "considerable merit" in developing and assessing a fourth option that
leverages the strengths of the primary options while minimizing their risks and
unfavorable aspects. This fourth option is called "Adaptive Phased Management" and it
is the recommended solution being proposed by the NWMO for the long-term
management of used nuclear fuel.
Adaptive Phased Management is essentially the deep geological disposal option, but
with an extended schedule that specifically incorporates steps and decision points that
provide flexibility and adaptability during implementation. A brief summary of the three
phases of this approach is provided below.
;Report~ CAO 11-05
0
Subject: NWMO Draft Study Report
Date:
July 18,2005
Page 4
Phase 1: Preparing for Central Used Fuel Management. This phase would
extend over approximately the first 30 years from when a decision is made by
the Government of Canada on the issue. During this phase, used nuclear fuel
would remain at the current nuclear reactor sites under current storage and
monitoring conditions. Research would continue into technology improvements
for used fuel management. The key activity during this phase is the selection of
a preferred site and the decision of whether or not to construct a shallow central
underground storage facility. If the decision is made to not construct the shallow
storage facility, then the used fuel would continue to be stored at the reactor
sites until it is moved to the deep repository during Phase 3.
Phase 2: Central Storage and Technology Demonstration. This phase would
extend over approximately the next 30 years. Phase 2 would begin with the
operation of the underground research laboratory. This laboratory would
demonstrate the technology to be used and confirm that the selected site is
suitable for a deep repository. If the shallow storage facility is constructed, then
used fuel would be transported there from the reactor sites during this phase. If
it is not constructed, the used fuel would remain at the reactor sites until
transported for placement in the deep repository.
Phase 3: Long-Term Containment, Isolation and Monitoring. This phase
would extend beyond 60 years from when a decision is made. Phase 3 begins
with the receipt of the operating license for the deep repository. Assuming the
shallow central storage facility was constructed in Phase 2, fuel transport and
repackaging would continue in Phase 3 with the fuel now being placed in the
deep repository, and extended in-situ monitoring would begin. Access to the
repository would be maintained to assess the performance of the repository
system and to allow retrieval of the used fuel, if desired. Finally, a decision on
when to close and decommission the deep geological repository facility would be
made.
Although ASL agrees that Adaptive Phase Management is a reasonable solution, it
must be recognized that this approach has some very significant potential impacts on
nuclear host communities in that the nuclear waste would continue to be stored at the
existinq reactor sites for at least 30 years and possibly between 60 to 90 years or
longer.
The length of time the used fuel remains at the existing nuclear 'facilities is dependent
on the length of time it takes the Government of Canada to make a decision on the
issue, and on whether a decision is made to construct, or not construct, a shallow
storage facility (if it is not constructed, the fuel would continue to remain at the existing
sites until the deep repository is available). Moreover, there is the potential that some
of the decisions that are a critical part of the Adaptive Phased Management approach
could be delayed or deferred for longer than expected (for instance, there could be
strong opposition to the transport of high-level nuclear waste through communities).
Report CAO 11-05
Subject: NWMO Draft Study Report
Date:
July 18,2005
Page 5
043
As noted by ASL, any type of delays in decision-making with respect to the Adaptive
Phased Management approach would require a continuation of interim storage at the
existing nuclear sites even longer than projected. The risk is that because of
unexpected or unforeseen delays in implementing the recommended option, the
storage of used high-level nuclear fuel at the existing nuclear facilities would become
the de facto long-term solution.
In any case, whether it is for 30 years, 60 years, 90 years or more, the ongoing storage
and accumulation of used nuclear fuel in Pickering has the potential for significant
impacts on the community. These impacts need to be identified and assessed and
appropriate compensation and mitigation provided.
Unfortunately, to date the NWMO has not satisfactorily dealt with this issue. In fact, in
discussions with our peer review consultants, the NWMO admitted that certain socio-
economic impact mitigation measures, such as compensation for the unavoidable or
residual adverse impacts of the management approaches, are not being considered for
the current host communities. The NWMO has taken the position that the used fuel
owners are responsible for the interim management and storage of the used fuel, that
the NWMO will not become involved in discussion or actions related to current interim
storage arrangements, and that the NWMO's obligations will not begin until the used
fuel leaves its current locations.
This is unacceptable given the fact that the NWMO's own recommended solution
(Adaptive Phased Management) requires the storage of used nuclear fuel at the
existing reactors sites for an extended period of time (up to 90 years or more). It is also
inappropriate and unfair since the NWMO is prepared to consider mitigation and
compensation for new host communities, but not for existing host communities.
ASL recommends that the NWMO clarify is position with respect to this issue so that
the current host communities understand the roles and responsibilities of the different
organizations involved in developing interim storage policies.
Requesting clarification is appropriate. However, it would also be very important for
Council to take this opportunity in commenting on the Draft Study Report to request that
the NWMO examine and address the issue of existing host community compensation in
its Final Report. Not to do so would risk having the matter not dealt with at all.
Accordingly, in addition to seeking clarification of NWMO's role, it is recommended that
the NWMO be asked to develop and describe in its Final Study Report, a
comprehensive approach to addressing the issue of host community compensation for
the interim storage of nuclear fuel at the existing nuclear facilities, from the time the
used fuel was initially located at these facilities, to the time the used fuel is permanently
removed from these facilities.
Subject: NWMO Draft Study Report
Date: July 18, 2005
Page 6
Attachment:
1. Executive Summary, Independent Peer Review of NWMO's Draft Study Report,
prepared by ASL, July 2005
Prepared By:
Approved / Endorsed By:
A.L. (Joe) Hunwicks
Community Emergency Management
Coordinator
Thorn/a~ J. Quinn ~J ~-~ ~
Chief Administrative Officer ~
Thomas E. ~k
Division Head, )rporate Policy
TJQ:alh:tem
Attachment
Recommended for the consideration of
Pickering~,Co~ ~' "
045
1-1
1. EXECUTIVE SUMMARY
1.1 OVERVIEW
Acres-Sargent & Lundy (ASL) was engaged by the Canadian Association of Nuclear Host Communities
(CANHC) to assist in its evaluation of' Canada's Nuclear Waste Management Organization (NWMO) process
for the future management of Canada's used nuclear fuel. Specifically, CANHC requested ASL to review
NWMO's Draft Study Report "Choosing a Way Forward: The Future Management of Canada's Used Nuclear
Fuel." Accordingly, ASL performed a broad review of the Draft Study Report with the overall objective of
identifying issues or questions that CANHC should focus on as the NWMO continues its process.
The NWMO was established in 2002 under the Nuclear Fuel Waste Act (NFWA) to investigate approaches for
managing Canada's used nuclear fuel. The Nuclear Fuel Waste Act requires the NWMO to recommend a
preferred management approach to the Government of Canada by November 15, 2005. The NWMO will then
implement the approach chosen by file Government. As noted in the NWMO's Fact Sheet 9, "The NWMO
Study Process," the NWMO has committed to "develop collaboratively with Canadians a management approach
that is socially acceptable, technically sound, environmentally responsible, and economically feasible."
Tile purpose of tile Draft Study Report is to present the NWMO's recommended approach for the long-term
management of used nuclear fuel in Canada. The NFWA requires that the following three primary management
approaches, as a minilnum, be studied: deep geological disposal, storage at nuclear reactor sites, and centralized
storage. However, the NFWA also noted that other methods may be considered. Based on its assessment of the
three primary approaches, the NWMO decided that there is "considerable merit" in developing and assessing
another approach that leverages the strengths of the primary options while minimizing their risks and
unfavorable aspects. Accordingly, the NWMO developed a new option called Adaptive Phased Management
(APM) that is intended to capture the strengths and mitigate the limitations of the other options. The NWMO
has designated APM as the preferred management approach.
APM is essentially the deep geological disposal option, but with an extended schedule that specifically
incorporates steps and decision points that provide flexibility and adaptability during implementation. During
Phase 1 of the APM scheme, used nuclear fuel would remain at the current nuclear reactor sites under current
storage and monitoring conditions. Research ~vould continue into technology improvements for used fuel
management. The key activity during this phase is the selection of a preferred site and the decision of whether or
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not to construct a shallow central underground storage facility. If the decision is lnade to not construct the
shallow storage facility, then the used fuel would continue to be stored at the reactor sites until it is moved to the
deep repository during Phase 3. Phase 2 would begin with the operation of the underground research laboratory.
This laboratory would demonstrate the technology to be used and confirm that the selected site is suitable for a
deep repository, lfthe shallow storage [hcility is constructed, then used fuel xvould bt; transported there from the
reactor sites during this phase. If it is not constructed, the used fuel would remain at the reactor sites until
transported fbr placement in the deep repository. Phase 3 begins with the receipt of the operating license for the
deep repository. Assuming the shallow central storage facility was constructed in Phase 2, fuel transport and
repackaging would continue in Phase 3 with the fuel now being placed in the deep repository, and extended in-
place monitoring would begin. Access to the repository would be maintained to assess the performance of tile
repository system and to allow retrieval of the used fuel, if desired. Finally, a decision on when to close and
decommission the deep geological repository facility would be made. Although the APM process is flexible, the
final disposition is finn, in that the used fuel will be disposed in a deep geological repository.
The [bllowing figure illustrates the impact on tile duration of interim onsite storage associated with the different
management options.
Figure 1-1 -- Comparison of Potential Interim Storage Durations
Now
Years after Approach Selected
0 10 20 30
40 50 60 70 80 90 100
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There are two key points illustrated in this figure. The first key issue is that the durations are all impacted by
how long it will take before a decision is made to select an approach. The second key issue is that used nuclear
fuel could remain in interim storage at the current reactor sites for over 90 years froln now. This duration may
exceed the storage capacity and licensing parameters for these facilities, and could create technical and security
concerns that ~vere not envisioned when these facilities were designed and approved for short-term interim
storage.
Overall, ASL believes that the Adaptive Phased Management approach effectively addresses many of the
concerns or weaknesses associated with the other options, while building on their strengths. The Adaptive
Phased Management approach is technically reasonable and achieves its goal of providing balance relative to the
assessment attributes. It should be noted that while there are significant risks and costs, along with benefits,
associated with the APM, this approach is considered to be advantageous compared to the three primary
alternatives.
1.2 KEY ISSUES AND RECOMMENDATIONS
ASL identified several issues and corresponding recommendations during its independent peer review of the
Draft Study Report as summarized in Table I-1. The issues related to the Draft Study Report are discussed in
Section 3; the issues related to Adaptive Phased Management are discussed in Section 4; and the issues related
to implementation planning are discussed in Section 5.
Table 1-1 -- Issue and Recommendation Summary
Issue Recommendation
Draft Study Report
There is a risk associated with an approach that combines
quantitative and qualitative assessment factors, in that more
weight can be given to quantifiable versus qualitative factors.
For example, while the GoldedGartner Lee analysis
acknowledges the potential for significant cost impacts related
to social protests, it later notes that "the risks and costs are not
significant" for transporting used fuel in a centralized approach.
The NWMO should develop an
assessment of the qualitative risks and
costs included in its analysis, as well as an
assessment of the direct and implicit
assumptions, to ensure that appropriate
contingency measures have been
considered if extreme or unlikely events
occur. These assessments should be
included in the Final Study Report.
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Issue
The GoldedGartner Lee assessment refers to the impact that
could result from opposition groups, such as the potential for
social protests that could affect the transportation of used fuel.
However, there is no formal discussion or assessment of
opposition groups, or a discussion of possible mitigating
measures needed to address this issue. This would be
relevant or could be a significant concern if these groups are
able to stop or change transportation options, which could
mean that onsite storage is extended or becomes the long-
term approach.
In discussions with ASL, the NWMO clarified that certain socio-
economic impact mitigation measures, such as compensation
for the unavoidable or residual adverse impacts of the
management approaches, are not being considered for the
current host communities. The NWMO noted that the used fuel
owners are responsible for the interim management and
storage of the used fuel, including socio-economic effects
management and mitigation. Accordingly, the NWMO would
not become involved in discussions or actions related to
current interim storage arrangements, and the NWMO's
obligations would not begin until the used fuel leaves its
current locations.
Recommendation
The NWMO should supplement its public
engagement strategy as required to
assess the concerns, positions, and
possible impact of potential opposition
groups. This assessment should be
performed during implementation planning,
and mentioned in the Final Study Report.
The NWMO should clarify its position
towards the current host communities
relative to changes in the planned duration
of interim storage in the Final Study
Report. For example, the NWMO should
clearly state whether or not it plans to
afford the current host communities the
same considerations as new host
communities for changes in interim storage
plans once a new national policy is
decided upon.
Adaptive Phased Management
The Draft Study Report, in Section 3.3, specifically discusses
the advantages and limitations of the three primary
management approaches (Deep Geological Disposal in the
Canadian Shield, Storage at Nuclear Reactor Sites, and
Centralized Storage). However, the report does not include a
comparable discussion of the advantages and limitations for
Adaptive Phased Management.
There is a potential that some of the decisions that are a
critical part of Adaptive Phased Management could be delayed
or deferred for longer than expected. Any type of delays would
require a continuation of interim storage, with the risk that on-
site interim storage would become the de facto long-term
management approach. As noted throughout the Draft Study
Report, that option has several disadvantages, not the least of
which is the lack of fairness to the current host communities.
The NWMO should develop a specific
discussion of Adaptive Phased
Management advantages and limitations,
comparable to the write-ups for the other
options found in Section 3.3. This
discussion should be included in the Final
Study Report.
The NWMO should ensure that the
implementation plans for Adaptive Phased
Management consider the potential impact
of delaying or deferring decisions, and
should develop corresponding
contingencies and mitigation measures as
appropriate. For example, implementing
legislation could include requirements that
the used fuel will be moved off-site within a
defined time-frame, or else certain
mitigation measures would go into effect.
This issue will have to be addressed
during implementation planning, but it
should be mentioned in the Final Study
Report.
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Issue Recommendation
The NWMO's Draft Study assesses the technical aspects of
transportation, such as the number of shipments, estimated
costs, and statistical accident rates. The Draft Study also notes
that there are significant economic benefits associated with
transportation, such as the number of jobs created. However,
the study does not fully address the negative socio-economic
impacts or the potential impact of opposition groups. If these
types of events effectively stop implementation of Adaptive
Phased Management or another recommended approach,
then the status quo option of onsite storage will become the
default approach.
The potential duration of interim storage is impacted by how
long it will take to select a management approach. With the
recommended approach, Adaptive Phased Management, used
nuclear fuel could potentially remain in interim storage at the
current reactor sites for over 90 years from now. This duration
may exceed the storage capacity and licensing parameters for
the interim storage facilities, and could create technical and
security concerns that were not envisioned when these
facilities were designed and approved for short-term interim
storage. For example, the security risks for locations near
heavily populated urban areas and adjacent to the Great Lakes
may be significantly increased if the duration of interim storage
significantly increases at these locations.
The NWMO should ensure that
transportation issues are studied and
addressed in greater detail as it continues
its planning and implementation work. For
example, the implementation plan for the
recommended approach should include
contingency evaluations for selected
extreme events or unanticipated delays.
This issue will have to be addressed
during implementation planning, but it
should be mentioned in the Final Study
Report.
Transportation issues should be
specifically addressed as the NWMO
develops (for the Final Study Report) a
recommended assessment of the
qualitative risks and costs included in its
analysis as discussed earlier in this report.
Given the potentially lengthy time frames
associated with Adaptive Phased
Management, the NWMO should confirm
and document that the existing reactor
sites have adequate storage capacity for
current and future used fuel inventories.
The storage capacity should consider both
potential facility and site space limitations
and constraints. This should be addressed
in the Final Study Report.
The NWMO should address the potential
increase in security risks associated with
an increase in the duration of interim
storage. This should be mentioned in the
Final Study Report and addressed in detail
during implementation planning. Also,
contingencies should be considered if
current sites are not able to obtain the
licenses required to support expansion
based on changes in the duration of
interim storage requirements.
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Issue Recommendation
Implementation Planning
The NWMO has had extensive engagement with Canadian
citizens regarding its work as discussed in Appendix 5 of the
Draft Study Report. This item was discussed with the NWMO
during the CANHC meeting in St. Johns on June 3, 2005,
when a question was posed to the NWMO attendees regarding
the make-up of the participants in the engagement process
(that is, how many private citizens, how many people were
representing organizations, etc.). Appendix 5 of the Draft Study
Report lists the number of participants and organizations, but
does not analyze these data against expectations for
participation and the overall quality of the engagement
process. This information could provide valuable insight into
the effectiveness of the NWMO's engagement process and
indicate areas for improvement and lessons learned from their
experiences.
There appears to be some confusion or inconsistency
regarding the role of the NWMO in working with the current
host communities as it develops its recommended
management approach and implementation plans. The Draft
Study Report notes that "[the NWMO] will be responsible for
managing and coordinating the full range of activities related to
the long-term management of used nuclear fuel." The NWMO's
recommendation and implementation plan will affect the
current host communities, and it would seem that the NWMO
would take an active role in working with the current host
communities to manage and mitigate socio-economic effects
before the used fuel leaves interim storage. However, the
NWMO stated that it would not be involved with detailed
discussions or actions taken relative to mitigating socio-
economic effects until the used fuel leaves interim storage.
It is recommended that the NWMO
develop and/or study data characterizing
the make-up of engagement participants to
verify the quality of the engagement
process and to identify areas for
improvement during implementation
planning. This issue will have to be
addressed during implementation
planning, but it should be mentioned in the
Final Study Report.
It is recommended that the NWMO clarify
its role regarding current interim storage at
reactor sites, so that the current host
communities understand the roles and
responsibilities of the different
organizations involved in developing
interim storage policies. This clarification
will support effective planning and
implementation of current and/or new
storage policies. This issue will have to be
addressed during implementation
planning, but it should be mentioned in the
Final Study Report.
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