Nuclear Wastes: What, Me Worry? (1978 Original)

Canadian Coalition
for Nuclear

Regroupement pour
la surveillance
du nucléaire

Nuclear Wastes:
What, Me Worry?

Part Three

[ click here for the 1987 Addendum ]



3.5. Fifth Shortcoming: Assessment of Risks

3.5.7. Retrievability of Buried Nuclear Wastes

Some people consider practical the ultimate disposal of irradiated fuel, whether processed or not, by placing it in suitable containers and leaving them on the surface where they can be suitably monitored for all time and remedial action taken if there are signs of failure. We consider that surface disposal is unsuitable because it leaves to future generations of man the duty to keep watch on the dangerous substances that we have left behind.             (pp.37-38)

The idea of permanent irretrievable storage of nuclear wastes is a relatively new one within the Canadian nuclear establishment. Back in 1972, Atomic Energy of Canada Limited was ardently advocating the opposite policy:

"Within the Canadian program, the policy that has been adopted is to provide monitored and supervised storage of the wastes for as long as they constitute any potential hazard, under conditions that permit retrieval at any time."

Report to the Science Council of Canada
AECL document #4767
December 1972

"All radioactive wastes ... must be stored in a way which would allow retrieval. With the current state of knowledge, the committee considers that there is no proven safe permanent disposal method."

AECL Waste Management Committee
1972 Report

As late as l974, the principle of retrievability was proudly proclaimed as the cornerstone of AECL's waste management philosophy. Retrievability of nuclear wastes was regarded as indispensable for safety reasons, just in case the plans for disposal were to backfire. Future generation- may be able to dispose of the wastes in a much more satisfactory way than we can today, but they wont be able to do so if the wastes are not retrievable stored:

"This million year period is a great deal longer than civilization has been in existence, so future conditions cannot be predicted that far ahead. Thus, retrievability must be built into schemes to guarantee that future generations will have at least one option for dealing with the radioactive wastes that are being produced now."

The Management of Radioactive Byproducts
from a Nuclear Reactor, by W.N. Campbell
presented at a Nuclear Symposium
in Montreal, 1974 (AECL-PP23)

Geological storage is mentioned in a few AECL documents prior to 1975, but it is always retrievable geological storage that is being discussed:

"Extensive work has been done in the USA and in Germany on the storage of radioactive waste in salt mines. Other proposals have been made for the use of rock caverns or shale deposits. Most methods have not allowed for retrievability but are essentially disposal methods. The fifth AECL design study is on salt mine storage with retrievability as an essential feature."

AECL Experience in Managing
Radioactive Wastes from Canadian Nuclear Reactors
by J.A. Morrison (printed March '74)

The first four Long Term Storage Options listed in the document were all retrievable surface storage methods. The report does go on to say that one of the advantages of using geological storage as a retrievable option is that it has the potential for ultimate irretrievable storage at some future date.

Somehow, in the last three years, Canadian nuclear authorities have completely changed their minds on what they plan to do with nuclear wastes for the next million years. Somehow, it has been decided that irretrievable geological disposal is "the best compromise between the safety and responsibility objectives", to quote the words of Dr. Peter Dyne in 1975. In other words, permanent disposal may be less safe if something goes badly wrong, but surface disposal or retrievable storage places a responsibility on future generations. The only way to avoid this dilemma -- which will be echoed around the world as nuclear power spreads -- is to stop producing nuclear wastes before the quantity of waste becomes unmanageably large.

Burning our Bridges

    I would like to record that there are many experts who have severe reservations about the safety of [geological waste] disposal operations.

    If disposal without retrieval is to be employed, extremely high standards of guarantees must be provided.

    Many feel that it will be extremely difficult, and some would go so far as to say that it is impossible, to obtain the guarantees which would be necessary to justify highly active waste being allowed to pass beyond control.

D.W. Clelland
British Nuclear Fuels Ltd
Management of Radioactive Wastes from Fuel Reprocessing,
OECD, 1973 (pp.1173-4)

    Short-term demonstrations of permanent waste repositories can show that radioactive wastes can be safely emplaced in geologic formations, but little more.

M. Willrich et al
Radioactive Waste Management & Regulation
Cited in the California Interim Report (California Report, p.106)

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[ RETRIEVAL --1987 Addendum ]

3.5.8. Transportation and Immobilization

In 25 years ... about 2500 shipments of irradiated fuel will be made each year or about eight per day.             (EMR Report, p.20)

The problems involved in stealing a significant quantity of irradiated fuel and doing anything with it that would threaten a population are so great that we conclude that such an occurrence is extremely unlikely. There is also the possibility that someone might blow up a storage bay with explosives in order to create havoc by spreading radioactivity. Again, such an occurrence ... would be very unlikely to result in a significant hazard to the population. Security , as applied to separated plutonium, is another matter. Even if fuel processing is undertaken, a significant quantity of separated plutonium or other fissile material in pure form should not be allowed to exist in Canada.             (pp.20-21)

We have not seen estimates of either health or environmental impacts likely to be associated with immobilization technology, but believe these to be small.             (EMR Report, p.31)

We believe that the EMR report seriously underestimates the risks of handling and transporting spent fuel. However unlikely they may be, accidents involving spent fuel can have devastating consequences. Security problems may become unmanageable as the demand for black market plutonium grows. In addition, experience has shown that the environmental and health effects of immobilization technology can be severe. Information bearing on these three points is briefly summarized below.

  1. The Institute of Reactor Safety in Germany prepared a report in 1976 dealing with the theoretical consequences of a major accident in a spent fuel reprocessing plant. It was calculated e cooling water were lost, the spent fuel could melt because of its heat generation disseminating large quantities of radioactive materials into the atmosphere. Fatal whole-body radiation doses could be delivered to populations situated hundreds of kilometres away from the storage bay, according to the study.

    This possibility is confirmed by Dr. Norman Rasmussen, author of the famous Rasmussen Report on Reactor Safety -- WASH-1400 -- who writes:

    The spent fuel storage pool is identified as having a significant radioactive inventory, second in amount to the reactor's core. Further, the decay heat levels in freshly unloaded fuel assemblies that may be stored in the pool may be sufficiently high to cause fuel melting if the water is completely drained. (Rasmussen, p.29)

    Such melting of fuel invariably results in the release of large amounts of radioactivity.

  2. The loss of cooling water from a spent fuel storage bay, referred to above, could happen accidentally or as a result of sabotage. The California Interim Report provides an example of such an accident, by referring to the possibility of dropping a 50-ton spent fuel shipping cask into the storage pool, thereby rupturing the floor of the pool. As for sabotage, it should be remembered that many of these storage pools are outside the containment of the reactor building and therefore much more accessible to the environment than the reactor itself.

    AECL disputes the findings of the German study mentioned above, but they have not done comparable calculations to determine the exact consequences of this type of accident.

  3. The EMR report states that the geological waste repository should be regarded "as a central, national facility, and should be located in Ontario". (EMR Report, p.6) Later, the report states that the 50-ton shipping flasks "have been designed to withstand all conceivable accidents." (EMR Report, p.20) We are skeptical whether such a flask could withstand a train crash in the Fraser Canyon, if spent fuel were to be shipped from B.C. to Ontario at some future date. We find it inadmissible to dismiss such hazards on the basis of their 'improbability' without actually assessing the consequences of such an accident.

  4. In view of the fact that many national and sub-national groups may wish to acquire plutonium for the purpose of constructing nuclear weapons, the possible theft of spent fuel must not be disregarded. If an entire shipload of natural uranium can be hijacked to Israel (as happened several years ago) there is no reason why a few of the 2500 annual shipments of spent fuel might not be diverted beyond the borders of Canada. The transportation industry may well be targeted for infiltration by underworld influences, given that plutonium is worth more than either heroin or gold, even on the open market.

  5. The study group seems to believe that plutonium can be diluted in some way so as to eliminate the security risk, by making the plutonium unsuitable for weapons use. (Otherwise, why do they say that separated plutonium in pure form should not be allowed to exist?) In actual fact, plutonium-spiked fuel bundles will be a very attractive target for potential plutonium thieves, since it is a simple, low technology chemical operation to separate the plutonium from a freshly fabricated fuel bundle. In many respects, plutonium fuel is easier to steal and easier to handle than separated plutonium. As Sir John Hill of the U.K. Atomic Energy Authority stated in Nucleonics Week of June 27, 1977, plutonium fuel must be sent "under heavy guard" in Britain. "We've got to do better than shipping around large quantities of plutonium with 10,000 armed guards trooping around with every shipment," Hill said.

  6. Occupational exposures at reprocessing plants have been horrendously high in the United States, as have radioactive effluents into the environment. In view of this experience, one cannot understand why the study group concludes that the risks associated with the immobilization technology will be small.

    At the West Valley reprocessing plant near Buffalo, for example, liquid effluents into local creeks were thousands of times higher than anticipated, leading to radioactive contamination far in excess of the regulatory limits. Meanwhile, radiation exposures to full time workers were so high that by 1971 there were 991 transient workers and only 162 full time workers, of which 123 full time workers received more than the regulatory limit of 5 rems. (When radiation exposures get too high, transient workers are hired to make the records look better. As previously pointed out, the health effects are by no means diminished by this practice.)

    At the Hanford reprocessing plant hundreds of thousands of gallons of high level liquid wastes have leaked into the soil, and occupational exposure has taken its toll. (See Radiation Exposures of Hanford Workers Dying of Cancer and Other Causes, Health Physics, vol. 33, November 1977].

    Even without reprocessing, immobilization can only be done at high temperatures which is likely to drive off into the atmosphere radioactive gases and volatile substances (such as iodine-129, with its 17 million year half-life). It seems imprudent to assume, without any supporting evidence, that the health and environmental effects will necessarily be small.

This concludes our discussion of shortcoming #5 of the EMR report in assessing the risk associated with radioactive waste disposal. The study group's assessment is --

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[ TRANSPORTATION --1987 Addendum ]

3.6. Sixth shortcoming: Siting a Waste Repository

Few people want to see the repository close to their own homes. Hence, the inhabitants of densely populated southern Ontario are likely to opt overwhelmingly for disposal in remote, central or northern areas... "Why should we accept noxious wastes that arise from the demands of city folk down south?" This familiar cry will be raised wherever in northern areas the repository is finally placed ... statements of this sort are largely self-defeating... The paramount consideration must be to pick a site that will not fail.             (EMR Report, p.29)

In view of the paramount importance that the study group attaches to the question of siting, it is remarkable that they make no recommendations on this subject other than suggesting an Ontario location. Experience to date suggests that siting a waste repository will be a major headache on both political and technical grounds, and may delay the waste disposal program by several decades. To allow the expansion of Canada's nuclear power program to proceed in hopes that a waste repository will be successfully sited and fully demonstrated by 1995 seems excessively optimistic -- it means siting it right the very first time, before 1983.

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3.6.1. Political Problems

In 1971, Dr. Alvin Weinberg (who was then Director of the Oak Ridge National Laboratory) announced U.S. plans to dispose of high level radioactive wastes in an abandoned Salt Mine in Lyons, Kansas. At a press conference held at the time, he referred to it as "one of the most far-reaching decisions any technologists have ever made, since these wastes can be dangerous for up to a million years." The U.S. Congressional Committee which authorizes funds for such projects was told that the Lyons site was the very best site available, as it had been carefully selected following an extensive research program lasting 15 years and costing 100 million dollars.

The plan came under immediate attack by the Kansas Geological Survey and other state officials, who argued that the mine did not offer sufficient protection to the stored radioactive wastes. Nuclear authorities claimed that the salt formation guaranteed that no water would come in contact with the stored wastes; however, experimental drilling showed that there was water in the mine and there were many unsuspected pathways for further seepage to take place. Within two months of the original announcement, the site was abandoned as being clearly unacceptable.

On September 9, 1977, in a report to the U.S. Congress by the Comptroller General of the United States, entitled, "Nuclear Energy's Dilemma: Disposing of Hazardous Radioactive Waste Safely", (henceforth known as G.A.O. Report No. 2) it is written:

We believe public and political acceptance is the biggest obstacle that ERDA must overcome in resolving the waste disposal problem. ERDA has twice been unsuccessful in developing potential waste disposal sites because of insufficient attention to the public acceptance factor.

In Kansas, public and political opposition developed over the proposed Lyons site ... In Michigan, ERDA did not adequately inform all the affected public and government officials about the pilot repository program ... Public opposition in Michigan has delayed the program about a year ... An ERDA official told us that the agency is beginning to face public opposition in Louisiana, the other prime waste repository candidate. (GAO Report#2, p.15-16)

At Madoc, Ontario, the same kind of political bungling was apparent. The much more recent public reaction in the Thunder Bay area confirms our suspicion that no site for a waste repository will be found without a major political battle. Since AECL is still hoping to site a demonstration reprocessing plant at the same location as the geological waste repository, the kind of political difficulties already experienced will be even more intense in the future because of the extraordinary hazards associated with reprocessing (not to mention the security implications that inevitably accompany any plutonium separation facility.) The public won't put up with it easily.

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3.6.2. Technical Problems

Although political opposition has been a major factor, safety considerations have also played an important role in invalidating numerous waste disposal sites. Neither the U.S. nor Germany has been able to successfully locate a waste repository, despite the fact that they are 10 or 15 years ahead of Canada. According to the California Interim Report:

  • Project Salt Vault [the Lyons site] was rejected partially because of hydrological problems and because of drill holes in the surrounding area.

  • The Asse Salt Mine [in Germany] might well be rejected if it were evaluated in the U.S. because of incompletely understood but potentially serious hydrological problems. Previously, there had been flooding in nearby abandoned salt mines, and standing brine exists at the ASSE site.

  • At ERDA's Carlsbad facility [in New Mexico] in 1975 a core drill struck an unpredicted distortion of the geological bed which contained pressurized gases and brine just below the sat formation. The site for drilling was moved several miles to another section of the same study area. (California Report, p.108)

Since the primary safety requirement for geological disposal of radioactive waste is isolation from water, these past mistakes do not augur well for the future.

Madoc was not only a political fiasco but a technical farce as well. The detailed and well-researched brief prepared by Citizens Opposing Radioactive Pollution (CORP, Box 430, Madoc, Ontario) clearly demonstrates that the Mount Moriah site near Madoc meets almost none of the informal guidelines suggested by the AECL for a geological waste repository. One of the 24 technical objections raised by the CORP brief deals with groundwater:

... the Mount Moriah site represents the highest point in the [Moira River] watershed ... [and] the majority of the groundwater movement occurs through bedrock ... There are approximately 30 existing wells in a 10-kilometre radius and 600 wells in a 30-kilometre radius of the Mount Moriah site. Most of these wells extend 50 to 200 feet into the bedrock.

Earlier observations on the movement of groundwater at depths greater than 3000 feet from the surface indicate an erratic distribution within the Canadian Shield. The quantity of groundwater bears a complicated relationship with the fracture systems found in igneous and metamorphic rocks. In the Madoc area, groundwater contamination even at a depth of 3000 feet could conceivably result in surface water contamination as well, since the major part of the stream base flow in the area evidently originates from bedrock springs.

Such contamination, should it occur, would extend in diluted form to the lower reaches of the watershed, including the areas of Madoc, Tweed, and Belleville. (pp. 2-3)

Before any detailed siting procedures are undertaken, certain general policies must be established. Is the waste repository to be sited in an 'uninhabited' area, or is it not? Is the waste repository going to be co-located with a demonstration reprocessing plant at some future date, or is it not? Each of these questions is of major political importance, and should not be decided without broad consultation with the independent scientific community, political representatives, and the Canadian public. No one can say how long this will take.

In view of the deadline of l995 for successful demonstration of geological disposal of radioactive wastes (assuming little or no political opposition and well nigh infallible choice of geological formation) it is highly doubtful that a suitable site can be selected in time; if there is much slippage in the schedule, however, we may be forced into commercial reprocessing without having an acceptable solution to the waste disposal problem -- contradicting conclusion 10 of the EMR report, as already discussed in the section on reprocessing.

Common sense dictates a slowdown of the nuclear expansion program -- at least until siting arrangements for a waste repository have been finalized.

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[ SITING --1987 Addendum ]

3.7. Seventh shortcoming: Assignment of Costs

The government of Canada should finance all the cost of developing the technology for safe storage and disposal of radioactive wastes.             (EMR Report, p.7)

We are sure that all costs necessary to achieve this end will be readily borne.             (EMR Report, p.73)

The cost of building and operating central storage and disposal facilities should be recovered through charges against the organizations producing and supplying the radioactive waste.             (EMR Report, p.6)

The cost of disposing of radioactive wastes has got to be reflected in the price of nuclear-generated electricity

The total cost includes research and development into waste disposal methods, construction and operation of a waste repository, transportation and immobilization of the wastes, security measures required to safeguard the wastes, disposal of uranium tailings, and decommissioning costs. All of these deferred costs should be included in the initial capitalization of a nuclear power plant or in its operating costs.

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3.7.1. Research and Development

Canadian taxpayers have already invested about two billion dollars in research and development designed to make nuclear power commercially viable. So far, the only province which has reaped the benefits of this massive investment is Ontario.

On February 28, 1977, AECL briefed senior civil servants in Ottawa on their grandiose plans for another two billion dollar research effort -- this time for ^ demonstration Fuel Cycle Centre, incorporating (a) reprocessing of spent fuel to extract plutonium, (b) fabrication of plutonium-spiked fuel bundles, (c) solidification of high-level liquid wastes, and (d) geological disposal of the solidified wastes.

If nuclear power is as economical as it is claimed to be, why should Canadian taxpayers have to spend four billion dollars in fifty years without any hope of recovering the investment? (It is true that Ontario Hydro boasts that its nuclear stations are saving Ontario rate payers about $100 million per year, but those savings would not even cover the operating budgets of AECL and AECB, which are federally funded. Moreover, Ontario rate payers are not paying for waste disposal.)

Research expenditures on waste disposal should be recovered from the utilities who are licensing nuclear power plants, and who will be the beneficiaries of such research. This could be done by imposing a special "licensing tax" on all newly licensed power reactors. Such a tax could be designed so as to recover all research expenditures up to the year 2000 from those nuclear plants which are projected to be cleansed up to the year 2000. The tax should be proportional to the megawatt rating of the power plant, which in turn is roughly proportional to the amount of waste which will be produced by that power plant during its useful lifetime.

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3.7.2. Construction and Operation

The study group recommends that at least two hard-rock sites be chosen by 1981 for development into geological repositories, with shafts sunk by l985. No cost estimates are given, but G.A.O. Report No. 2 cites a figure of $200 million per repository for similar geological repositories which ERDA hopes to have operational by l985 in the United States (and expresses considerable skepticism that the 1985 target date can be met). If these figures are indicative, it could cost close to half a billion dollars to prepare two such repositories in Ontario. This cost should be recovered from the utilities who will be using the repositories, perhaps by using the same kind of "licensing tax" arrangement described above.

In assigning costs to the utilities in order to cover the operating expenses of a waste repository, great care must be exercised. It is far better to overestimate than to underestimate, since excess funds can always be returned but unexpected losses cannot always be recouped. These kinds of funding problems are discussed in a January 1978 Report to the U.S. Congress by the Comptroller General of the United States entitled "Improvements Needed in the Land Disposal of Radioactive Wastes -- A Problem of Centuries" (henceforth called G.A.O. Report No. 3):

South Carolina currently receives 8 cents for each cubic foot of waste buried. As of January 1975, the State had a balance of $118,283 in an interest-earning account. In addition, the licensee maintains a $20,000 performance bond.

[A special study commissioned by the South Carolina Department of Health and Environmental Control] concluded that

  1. the required size of the perpetual care fund as of January 1975 should have been $1,643,550 to generate sufficient income to pay for the annual routine surveillance and maintenance costs;

  2. $130,000 should be added to the fund each year for contingencies, and

  3. $2,583,400 would be required by 1995 to adequately maintain the site.

In 1995 -- the estimated date the site would reach capacity -- the fund will have $1,211,971 at the current charge of 8 cents a cubic foot. This would leave a shortage of $1,371,429. (GAO Report#3, p.35)

These figures refer to a low-level waste burial facility; costs will no doubt be much higher for a geological repository.

After a short period of retrievability, it is assumed that the waste repository will be sealed shut. However, operating costs may extend beyond that period of time. Monitoring of the waste repository may have to extend into the indefinite future so that any radioactive leaks can be detected in timely fashion. Emergency action may be required in case such leaks do occur. The period of retrievability may have to be extended for a much longer period of time than is now anticipated, due to uncertainties in the experimental data. All of these factors may add considerably to the operating cost of the repository; careful cost estimates will have to be worked out which incorporate all of these eventualities from the outset. Future generations should not have to pay for our mistakes. As the study group notes

While it is accepted that if something should go wrong with a deep geological disposal site it would indeed be difficult to rectify, nevertheless, if done correctly, such disposals could be ignored or forgotten by future societies. (EMR Report, p.52)

The question arises, "What kind of insurance policy are we going to provide just in case our best-laid plans go astray?"

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[ R&D AND OPERATING COSTS --1987 Addendum ]

3.7.3. Transportation Costs

Since irradiated fuel has to be shipped in 50-ton shipping flasks, it is recognized that transportation costs will constitute a sizable portion of waste disposal costs. If remote siting is considered advisable, transportation costs may become extremely expensive. Conversely, if no clear policy regarding remote siting is enunciated, there will be a powerful economic motivation to site the repository as close as possible to the reactors. The California Interim Report makes the following observations:

The railroads estimate the cost of a typical shipment by special train at $24,000 compared to a cost of $9,000 by regular train or truck service. The "special train" would transport only spent fuel travel at speeds less than 35 mph, and carry special guards ... Only four train casks and nine truck casks are currently in service. This small number of casks limits the amount of fuel that can be transported at one time. For example, an estimated 16 months would be required to ship 251 spent fuel elements from Humboldt Bay (California) to the G.E. Morris [Illinois] spent fuel storage facility. (California Report, p.51)

The study group makes it very plain that safety must take priority over economics: "The objective of the waste management program must be the protection of the health and safety of the Canadian public. Economic expediency must not stand in the way of this objective." (EMR Report, p.6)

High transportation costs and a shortage of shipping flasks will make it economically expedient to site the waste repository in Southern Ontario; therefore it is urgent that the policy question on remote siting be resolved as soon as possible, solely on the basis of the health and safety of the Canadian public. For the same reason, there should be no approval for a centralized interim spent fuel storage facility until the geological waste repository has been successfully sited -- otherwise, there will be tremendous economic pressure to locate the geological repository close to the interim storage facility rather than vice versa. The study group has come to the same conclusion: "It seems to us, then, that the utilities should plan on storing irradiated fuel at the nuclear power plants where it is produced until at least 1990, if not longer, to avoid shipping it more than once."

G.A.O. Report No 2 gives cost estimates for transporting spent fuel which are in broad agreement with those of the California Interim Report:

[Spent fuel shipping costs are] presently estimated to range form $8,000 to $18,000 for truck transport and $14,000 to $22,000 for rail transport per metric ton of spent fuel shipped from the reactor. (GAO Report#2, p.53)

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[ TRANSPORTATION COSTS --1987 Addendum ]

3.7.4. Immobilization Costs

Although glassification of wastes has been demonstrated on a laboratory scale, it is generally considered to be far removed from the realm of immediate commercial application. All experience so far has dealt with the glassification of high-level liquid wastes created as a byproduct of reprocessing operations, and that experience is not uniformly good. In particular, there is no acceptable technology for solidifying the neutralized high level liquid wastes which are stored in large tanks at reprocessing plants in the U S., nor is there any method for removing all of the intensely radioactive sludge from these tanks. The cost of disposing of this radioactive waste is astronomical

On March 8 1977, the Comptroller General of the United States issued a report entitled "Issues Related to the Closing of the Nuclear Fuel Services, Incorporated, Reprocessing Plant at West Valley, New York,' henceforth known as G.A.O. Report No 4. Here are a few excerpts:

Before decisions can be made on what to do with the high-level liquid wastes, ERDA has to do years of additional research.... An ERDA contractor has estimated that the cost of waste disposal at NFS [Nuclear Fuel Services] would range from $58 million to $567 million. The contractor study did not cover the cost of decommissioning the plant.         (GAO Report #4, p.5)

The wastes referred to here are 600,000 gallons of high-level liquid wastes containing 30,000 gallons of radioactive sludge:

Removing the sludge from the storage tanks is currently the most difficult technological problem in ERDA's waste management program.         (GAO Report#4, p.3)

When the NFS Reprocessing Plant was licensed, New York State set up a special fund to pay for waste disposal and decommissioning of the facility at the time NFS abandoned its investment in 1976, the fund had accumulated only $3 000 000 : pitifully inadequate to cover the actual costs of cleaning up the mess ! (G.A.O. Report No. 1, page 15)

Each solidification alternative requires additional research and development work and will not be available for application to NFS waste for as many as 14 years. In laboratory tests ERDA has converted neutralized wastes to a dry solid form but this technology needs to be demonstrated on a larger scale.         (GAO Report#4, p.13)

If Canada does decide to reprocess its spent fuel, the liquid wastes resulting will not be as intractable as those now existing in the United States -- we have learned by their mistakes! Nevertheless, there seems to be no sound basis on which to assess the actual cost of waste immobilization. Very little work has been done anywhere in the world on the problem of immobilizing spent fuel without reprocessing it, so the cost of doing so cannot be properly estimated. On the other hand, the cost of immobilizing liquid waste from reprocessing is highly uncertain. As the California Interim Report states:

[Dexter Peach of the General Accounting Office] indicated a full reprocessing facility with solidification and immobilization units had never been built and that 10 years was not an unreasonable period to expect for remaining design and licensing work.

Any near-future design and construction of facilities might carry with it large economic risks due to possible retrofitting because of technical criteria and regulatory uncertainties.

Little information has been provided the Commission on the economic viability of solidification and immobilization.

Costs will be affected by stringency of regulatory standards which are yet to be set.         (California Report, p.84)

The regulatory uncertainties mentioned above could play a key role in determining the economies of waste immobilization. For example. the current maximum permissible dose limits for members of the general public in Canada are 20 times higher than those in the United States. If a facility is designed to meet current standards and then those standards are mode significantly more stringent, the cost of making the necessary changes may be very large. The same applies to regulatory limits on emissions of radioactive gases during immobilization; tighter limits could require expensive modifications

In the light of past experience, it would be prudent to assume that the cost of waste immobilization could be quite significant. It will be a long time before we know what the actual cost might be. Until we find out, we should anticipate future problems by overestimating rather than underestimating the cost of immobilization.

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3.7.5. Security Costs

The U.K. Atomic Energy Authority has its own private police force which is not answerable to Parliament or to the British Government. Unique among British police forces, its members have the right to carry arms, to engage in hot pursuit, and to arrest on suspicion. Plutonium fuel shipments are regarded as top secret security matters, and all those who have any knowledge of such shipments operate under the British Secrets Act and therefore require security clearance. No information about plutonium shipments is available even to Members of Parliament.

The cost of maintaining a security force should be considered as part of the cost of nuclear electricity, and it should be budgeted accordingly. The size and capability of such a security force will depend in part on how rapidly the nuclear industry is allowed to grow in Canada, and in part on whether or not the reprocessing of irradiated fuel is allowed -- for with reprocessing comes separated plutonium and fresh plutonium-spiked fuel, both of which are much greater security risks than the irradiated fuel itself.

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3.7.6. Tailings Management Costs

G.A.O. Report No. 1 points out that "the Federal Government will be paying about $85,000,000 to clean up radioactive tailings piles at all inoperative uranium mills that were privately owned." (GAO Report#1, p.15) The report also states that the U.S. Nuclear Regulatory Commission "will no longer issue a mill licence, or renew an existing licence, unless the mill owner submits a reclamation plan for tailings and a bonding arrangement to finance the plan when mill operations cease." (GAO Report#1, p.12)

It must be observed that the $85 million expenditure referred to above does not provide for permanent disposal of the tailings, but only for temporary emergency action. At the present time, there is no known acceptable method for disposing of these tailings on the surface of the earth. As already argued, there is only one method of disposing of uranium tailings in an acceptable manner which is presently known, and that is geological disposal deep underground in a hard rock formation. This will no doubt be an expensive proposition; however, the cost of not providing such a permanent solution could be very much greater. We do hope it works!

We recommend that uranium mills in Canada be required to lay aside sufficient money to pay for the cost of geological storage of the tailings if no satisfactory surface disposal method has been found by the time the uranium mill is to be decommissioned. We further recommend that the Canadian government use its International Marketing Arrangements to achieve a similar policy on a worldwide basis, the cost of which would be reflected in the world price of uranium. If we ourselves cannot manage to solve this very serious waste disposal problem, what confidence can we have in our ability to solve the far more serious problem of safely disposing of irradiated fuel? And if we cannot get international agreement on the question of tailings disposal, what hope do we have of obtaining international cooperation in disposing of irradiated fuel?

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[ TAILINGS COSTS --1987 Addendum ]

3.7.7. Decommissioning Costs

The cost of decommissioning a CANDU reactor lies somewhere in the range between $30 million and $100 million. Ontario Hydro has more than 20 nuclear power reactors in operation or on order (8 at Pickering + 8 at Bruce + 4 at Darlington = 20), yet the cost of decommissioning these reactors is in no way reflected in the cost of Ontario Hydro's nuclear-generated electricity. But somewhere down the line, someone is going to have to pay between $600 million and $3 billion just to dismantle these power plants.

As indicated earlier, if we were to maintain 75,000 megawatts of nuclear electricity in this country we would have to decommission an average of four 600 megawatt CANDUs per year, at an average annual cost of between $120 million and $400 million

There is no excuse for not including the cost of decommissioning in the initial capitalization of a nuclear power plant, along with the cost of research and development into waste disposal methods & the construction of a geological waste repository or two.

There is no reason not to include the cost of geological disposal of uranium tailings in the price of uranium

There is no advantage to the Canadian people in not including the cost of the transportation and immobilization of spent fuel, the operating expenses of a waste repository and the security measures needed to safeguard the nuclear wastes, within the operating budget of nuclear power reactors

But none of these things is being done. "Consequently, the true cost of nuclear power is not being reflected in the cost to the consumer of nuclear power." (G.A.O. Report No. 1, page ii)

There should be no further expansion of the nuclear power industry in Canada until all of these costs have been satisfactorily internalized in the capitalization and operation of all new nuclear power plants since some of these costs will not be known with any accuracy for many years, current expansion plans should be radically revised downwards

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3.8. Eighth shortcoming: Public Participation

AECL should actively seek more comment and discussion of their programs than they have in recent years. Their program documents and progress reports on waste management should not only be public documents but they should be sent to interested groups and individuals in an active search for comments.

We also suggest that they organize and sponsor at least once a year symposia on the waste management program inviting representatives from utilities, the nuclear industries, universities, citizen groups and interested individuals, as a means of informing the public and also for receiving comments and criticism. (EMR Report, p.51)

We are happy that the study group recognizes the vital importance of public participation and freedom of information The suggestion concerning yearly symposia on radioactive waste management echoes a recommendation that we have been making for the last two years; namely, that there be such seminars on all topics of public concern in the field of nuclear power -- seminars on reactor safety, seminars on reprocessing technology, seminars on the biological effects of radiation, and so on.

In addition to the representatives listed in the above passage, however, we would insist on inviting selected well-qualified people from outside the country who are knowledgeable about the subject matter but independent of the nuclear industry. Such people often know what questions to ask, what parallels to draw, and what statements to challenge, thereby making the seminar both lively and profitable.

Freedom of information is a topic all on its own. It has been found to be exceedingly difficult to see documents which have a direct bearing on public health and safety, even though they have been prepared by crown corporations using public funds. True public participation can never be effective unless the principle of freedom of information is accepted as axiomatic. The burden of proof should be on the corporation to prove that a certain document should be kept confidential for reasons of national security or proprietary interest; it should not be up to the citizen, whose resources are limited, to laboriously seek out the desired information. The Canadian nuclear establishment has been more open than their American and European counterparts, but still has a long way to go before information is available as it should be for scrutiny by conscientious citizens.

We would be happier if the study group had made more of an effort to involve the public in the preparation of their report It is recognized that they were under severe time constraints, which partly explains their aloofness from the Canadian nuclear critics Nonetheless, we question why no effort was made to send out copies of the draft report to 'interested groups and individuals in an active search for comments'. And how are we to interpret the paternalistic tone apparent in the following simplistic diagnosis?

The nuclear industry is not alone in finding the public wary of its plans. All high technology industry faces the same problem. Many people now question the wisdom of highly technical solutions to social needs, even when these are urgent and inescapable. The disposal of nuclear wastes, which Canadian society cannot now avoid, is just such a case. It has become surrounded by myths and suspicions. Only wide public consultation can sweep these away. (EMR Report, p.51)

The study group seems to be suggesting that anyone who is alarmed about the possible mismanagement of tremendously toxic radioactive wastes is probably also opposed to such things as computers, transistors, photovoltaic cells, and technological progress in general. Such a representation may say more about the attitude of the study group than it does about Canadian nuclear critics. It would not be hard to illustrate at least as many "myths and suspicions" within the Canadian nuclear establishment, even on the subject of radioactive waste management, than can be found among the masses of Canadian citizens who simply want to bequeath to their children a world that is still intact and relatively non-threatening

Technical myths can be found in several places in the EMR Report -- for example, conclusions 17 and 18 on page 7, and the erroneous statement on page 22 that coal-fired plants give rise to more airborne radioactivity than nuclear plants of equivalent electrical power rating. Political and psychological myths are even more abundant.

Does the study group really believe that buried radioactive wastes can or even should be "ignored or forgotten by future societies"? This attitude is irresponsible, since leakage from the repository cannot be detected except by careful monitoring. As well, the coal-versus nuclear comparison is a good example of political mythology (to be found on page 53). Not only does the study group ignore the fact that clean-burning coal technologies exist (such as fluidized bed combustion, which drastically reduces sulfur oxides, nitrogen oxides, and fly ash), but it suggests that all electricity-producing technologies are as nasty as coal and nuclear. The fact of the matter is, of course, that both coal and nuclear produce large quantities of poisonous pollutants, while wind-generated electricity, solar-generated electricity, run-of-the-river generators, wave power, tidal power, and many other methods of electricity generation are about as clean as any technology could possibly be.

Public participation will never develop beyond tokenism unless there is official recognition of three significant deficiencies which prevent truly effective public participation: lack of communication, lack of information, and lack of resources.

Lack of communication is perhaps the most important of the three, because it makes it impossible for a consensus to emerge. Canadian citizens do not find it EASY to communicate with each other about important political matters. Groups such as the Canadian Coalition for Nuclear Responsibility find it difficult and costly to stay in touch with members, whether by telephone or by mail. If public participation is to be effective, means of communication must be made available at moderate cost. Special rates for newsletters and other mailings should be available. Inexpensive printing facilities would also be a great boon, so that when a brief like this is prepared it can be disseminated as an information document to "balance" the official EMR Report, EP 77-6.

Lack of information has already been touched upon in referring to the concept of "freedom of information" But access to documents is only part of the answer, since those documents are often difficult to interpret. What would be most useful would be a small government-funded research group consisting of technically competent people who could pursue research "in the public interest" in response to specific requests from citizen groups or from individuals who desire certain information in order to participate effectively in the political process. If such a group could enjoy immunity from governmental interference, it could play a very useful and constructive role in elevating the level of debate and increasing the value of public participation in many areas of Canadian political life. Lack of information must not be replaced by information overkill. What is needed is a selective and judicious ferreting out of what seems to be most pertinent or useful in a particular situation Most people have neither the time, the patience, nor the resources to do the necessary digging and sifting

Lack of resources: money for salaries, space for offices, machines for photocopying, presses for printing, computers for calculating, compositors for typesetting, addressographs for mailings, video-machines for taping, facilities for conventions, and so on. Instead of having to work with inadequate and unreliable equipment, non-profit groups performing a public service should be provided vita those obvious needed resources.

The Canadian Coalition for Nuclear Responsibility is an experiment in effective public participation. Working with very little money and with limited resources, we are trying to make a contribution toward responsible decision making. It is our fervent belief that nuclear power is far too important a matter to be decided by a handful of individuals, whether they be scientists or cabinet ministers. If we are going to proceed down the nuclear path much farther, it is essential that the Canadian public fully realizes what the implications are, both good and bad, of that choice. We believe that a national inquiry into nuclear power, coupled with a massive outreaching educational program, is the correct approach at this point in time. Whatever consensus might emerge from such an exercise in participatory democracy, it will be a consensus that we will all be able to live with, knowing that we all helped to forge it. But to proceed down the nuclear path without regard to legitimate and intelligent voices of protest is to invite confrontation, alienation, and a deeply divided society.

We strongly urge the Standing Committee on National Resources and Public Works to recommend to the Parliament of Canada and to the Government of Canada that there be a national inquiry into nuclear power accompanied by a massive public education program, possibly modeled on the Swedish experiment of l973-74.

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