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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 SL-008521 -Fmal.doc/071505 Project 11769-0I 1 0 4 t-3 SL-008521 ri.al 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 S I,-008521 -Final.doc/()71505 Prqject 11769-011 OF,,) I A'rrACHUENT t, TO R eRT p, l 047 1-3 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. S1,-008521 -I:inal dac/071505 Prqject 11769-0 048 Acres-S&L 1-4 SL-008521 Final 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. gl -008521-Final doc/071505 Prgject 11769-011 A ACHMENl # I 04 i ..... .................. Acms-S&L 1-5 SL-008521 Final 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. SL-008521-Final doc/071505 Pro. ject 11769-01 I AI'rACHMENT# I TO REPORT 1-6 SL-008521 Final 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. Last page o1' Section 1 s1,-0o852 I-Final doc/071505 Project 11769-011