TAKE ACTION: ON-SITE Disposal of Nuke Reactors

TAKE ACTION: ON-SITE Disposal of Nuke Reactors

Postby Oscar » Thu Dec 19, 2019 11:31 am

On-site Disposal Of Nuclear Reactors Is Not Acceptable.

[ https://www.sierraclub.ca/en/on-site-di ... acceptable ]

-- deadline for letter submissions is Friday, December 20, 2019 --

Natural Resources Canada (NRCan) needs to hear from you today about a proposal to allow nuclear reactors to be transformed into permanent radioactive waste disposal facilities.

The federal government has the responsibility to develop radioactive waste policy. Under the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, ratified in 2001, Canada must pay “due regard to internationally endorsed criteria and standards” such as those related to decommissioning of nuclear facilities.

The safety standard on Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities, prepared by the International Atomic Energy Agency in 2018, says, "On-site disposal of decommissioning waste is not a recommended practice in the case of decommissioning after normal operation."

However, our “independent” nuclear regulator, the Canadian Nuclear Safety Commission (CNSC), wants to allow on-site disposal of nuclear reactors - facilities that will remain radioactive for thousands of years after shut-down.

The CNSC is proposing that nuclear facility operators consider the strategy of “in situ decommissioning” - to place the facility, or portions of the facility, in a safe and secure condition, in which some or all of the radioactive contaminants are disposed of in place, which may result in the creation of a waste disposal site (draft REGDOC-2.11.2, Decommissioning)

The nuclear industry wants to go further. In its comments on the draft REGDOC, it wants the CNSC to call in-situ decommissioning an “accepted and acceptable practice,” and to delete language that would require operators of nuclear facilities “to conduct a comparison of alternative decommissioning strategies.”

The federal government has no policy on decommissioning of nuclear facilities, and only a 143-word, 3-bullet “Radioactive Waste Policy Framework” that makes no reference to Canada’s obligation to follow international standards.

In 2015 the federal government contracted a multinational consortium to operate their own nuclear facilities - including six shut-down reactors. The consortium has proposed “in-situ decommissioning” of federal reactors located in Pinawa, Manitoba and Renfrew County, Ontario. Environmental assessments of these two proposals are being conducted under the 2012 version of the Canadian Environmental Assessment Act, which gives the CNSC exclusive authority to decide if these proposals are acceptable.

Please join with us in asking Minister of Natural Resources to uphold Canada’s international obligations and fill the radioactive waste policy void. Tell him that on-site disposal of nuclear reactors and other nuclear facilities is unacceptable.

Thank you for taking action and for sending your letter below!

Dr. Ole Hendrickson - Sierra Club Canada Foundation Board of Directors

= = = =

To: The Honourable Seamus O'Regan - Minister of Natural Reslources * Seamus.ORegan@parl.gc.ca

c.c: Andrew Hayes, Interim - Interim Commissioner of the Environment and Sustainable Development, Rumina Velshi, President - Canadian Nuclear Safety Commission, Honourable Jonathan Wilkinson - Environment and Climate Change Minister *
Andrew.Hayes@oag.bvg.gc.ca,cnsc.consultation.ccsn@canada.ca,ministre-minister.ec@canada.ca

c.c: Health and Agriculture Critics
Marilyn.Gladu@parl.gc.ca,Luc.Berthold@parl.gc.ca,don.davies@parl.gc.ca,Alistair.MacGregor@parl.gc.ca,Elizabeth.May@parl.gc.ca

Message Subject * On-site Disposal Of Nuclear Reactors Is Not Acceptable.

Your message *

Dear Minister O'Regan,

I am writing to ask you to halt the ongoing process to approve nuclear reactors as nuclear waste sites.
Nuclear energy can never be safe, but at the very least we need to be doing everything we can to deal with the toxic legacy of this industry. Shut-down nuclear power plants and their wastes are dangerous for thousands of years, placing nearby citizens and wildlife at risk for millennia.

In spite of the magnitude of this risk, the nuclear industry, aided by the Canadian Nuclear Safety Commission, has successfully accelerated the process to ram through the approval of nuclear plants as waste sites. Throughout the existing process, our government has failed to acknowledge its responsibility to develop adequate policies on decommissioning of nuclear facilities and management of radioactive waste.

I am also deeply concerned that by allowing this process to continue, Canada is abandoning its responsibilities as a signatory to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. Under this convention, Canada must pay “due regard to internationally endorsed criteria and standards." Not doing so puts communities at unacceptable risk. The CNSC's draft “regulatory document” on decommissioning, which proposes to allow on-site disposal of decommissioning wastes at nuclear reactor sites, does not conform to the International Atomic Energy Agency's safety standard on decommissioning.

As Minister of Natural Resources, it is your responsibility to develop nuclear waste policy in the best interests of Canadians. This role should not be delegated to the nuclear industry regulator. Nuclear facilities should be decommissioned either through immediate dismantling or deferred dismantling. Each of these two options should be considered carefully by operators of nuclear facilities, and the choice of the preferred option should be justified.

Please reject the proposal before you to allow nuclear reactors to become nuclear waste dumps and launch a legitimate process to deal with our toxic nuclear waste legacy that respects the rights of Indigenous peoples, incorporates the best-available scientific information, and upholds Canada’s international obligations.

Sincerely,
Oscar
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