INPUT TO PUBLIC CONSULTATION BY THE
NUCLEAR WASTE MANAGEMENT ORGANIZATION (NWMO) ARISING
FROM THE DIALOGUE HELD IN TROIS-RIVIERES JULY 8-9 TH 2005
David Davies
Preface
This document is the outcome of my participation in the NWMO Dialogue held at the Hotel Gouvernor Trois-Rivieres in Trois-Rivieres on July 8-9 th,2005. I received much written information beforehand by mail and e-mail, including a hard copy of the draft study report to be finalized by Nov. 15 th. I managed to read through the whole of this draft before the opening session came to order at 6:00 p.m. on July 8 th.
My background is briefly as follows. My academic qualifications are:
(1) B.Sc., Honours in Mathematical Physics , University of Birmingham, 1954.
(2) M.A., Physics (Meteorology), University of Toronto, 1956.
(3) Ph.D., Dynamic Meteorology, McGill University, 1970.
I retired from a career as a Meteorologist and Research Scientist with the Meteorological Service of Canada (for a long period known as the Atmospheric Environment Service of Canada) in 1991, having spent many years working on Numerical Weather Prediction, and 10 years as the Technical Co-ordinator of an International Acid Rain Modelling Project funded by the Province of Ontario, the Canadian Meteorological Service, West Germany, the U.S. Electric Power Research Institute, and some U.S. States. The main model development was contracted out to a U.S. company and the development of the North American data bases was contracted out to a Canadian company. Throughout we collaborated and compared progress with a very similar U.S. Government Project funded under the NAPAP umbrella and contracted out to U.S. Universities and Companies. The outcome was the signing of the Acid Rain Agreement by the U.S. and Canada in March 1991. From 1992 until 1999, after I retired, I undertook contracts to quality assure emissions data, to act as rapporteur at technical meetings, etc.
List of Contents page
1. Introduction 2
2. My Understanding Of The Consensus Reached 2
3. Comments On The Conduct of the DialogueSessions 3
4. What was Missing from the Dialogue 4
(a) Consideration of the Political Dimension 4
(b) Emphasis on the Reality That Nuclear Fission Power Reactors Are Here To Stay 5
(c) The Need For A Closer Look At The Licensing Procedure 5
(d) Inclusion Of A Proposal For An NWMO Staffing Expansion 5
(e) The Need For A Back-Up Plan For Site Selection 6
(f) Lack Of Ranges On Estimates 6
(g) Opportunity To Initiate Closer International Collaboration on Nuclear Waste 7
(h) Incentives to Stimulate Public Participation 7
5. Some Specific Comments And Suggestions 7
1. Introduction
As Elizabeth Dowdeswell made clear in her opening statement, the purpose of the series of NWMO Dialogues being held across the country in the summer months is to review the Draft Study Report and the plan it contains in Chapter 1 in order to consider possible amendments that might be made before the final version is submitted to Cabinet on Nov. 15 th. These must not entail major rewrites of the whole Report.
2. My Understanding Of The Consensus Reached
Participants included people with diverse opinions on the future of nuclear fission generating stations in Canada.
Nevertheless, and please correct me if I am wrong, it is my understanding that a consensus emerged on the following points:
(1) The open process adopted by the NWMO is the correct one to follow, especially with regard to consulting the public and those most likely to be affected. The NWMO is to be congratulated for the hard and conscientious work that obviously went into the production of the Draft Study Report.
(2) The plan for nuclear waste management cannot be considered as something completely separate to a plan for future energy policy. The two must go hand-in-hand, if only because NWMO must have some idea how much nuclear waste it will be called upon to deal with in future years.
(3) The time-scale for implementation of the plan should be speeded up as much as humanly possible, so as to provide some concrete evidence that action is being undertaken in the reasonably near future and not simply being left to the next generation.
(4) Use of the word “disposal” should be avoided in the terminology wherever this can reasonably be done, since even the first option is strictly speaking “deep geological permanent safestorage in the Canadian Shield”.
(5) The Draft Study Report should be expanded to be more specific on the Findings and Recommendations of the Seaborn Panel and what responses have been made to them. It is not sufficient to post the Seaborn Report and a series of articles responding to concerns raised in it on the NWMO web-site.
(6) What is of concern to average citizens is the cost of the implementation of nuclear waste control measures per kilowatt hour as it will appear on their electricity bills. This does not explicitly appear in the Draft Study Report, although NWMO staff are verbally quoting 0.1 cents/kwh -- the same figure that was being bandied about 10 years ago without any allowance for a decade of inflation or the more elaborate measures now being contemplated. This discrepancy is something that should be investigated immediately so that an up-to-date value can be prominently and explicitly inserted in the final report.
(7) The Draft Study Report’s anticipation that communities will rush to volunteer to host a central storage site, deep or not, is a hypothesis that may well turn out to be wrong if latent NIMBY reactions by the Canadian public have been seriously underestimated by NWMO. An additional complication is that at some stage consideration will have to be given to the mechanism whereby a community opts to volunteer -- 50% + 1 in a referendum is probably not going to be enough.
(8) The so-called adaptive phased management plan being recommended is actually just common sense dangerously phrased so as to encourage procrastination by politicians, because it does not stress the urgency of initiating action in the near future.
(9) The Board of Directors of the NWMO should evolve so as to become much more independent of the organizations generating nuclear power than it now is. NWMO staff members gave attendees assurances that this is what is intended and that slow steps are being made in this direction. The emergence of the foregoing consensus alone makes the holding of the Trois-Rivieres Dialogue well worthwhile.
3. Comments On The Conduct of the DialogueSessions
At the start of the main plenary sessions, Elizabeth Dowdeswell made excellent and entirely appropriate introductory statements that summarized what is in the Draft Study Report. However, she failed to solicit comments on what was missing from it. She got them just the same from Gordon Edwards (of the Canadian Coalition for Nuclear Responsibility) who hogged much of the discussion time in the plenary sessions and the morning breakout session on July 9 th. What he said very much needed to be said, although I think it could have been done without putting the hostile slant of a nuclear power abolitionist that he did on many of his remarks. In retrospect, I think it would have been preferable to have signed up admitted critics of any use of nuclear power beforehand and given them their own time in the program to make critical speeches upon condition they agree to refrain from dominating the discussion periods by making more long statements of their own in them.
In events of this nature, it is my understanding that the breakout sessions are most advantageously devoted to different topics, so that the details of each of these can be discussed by subgroups of the participants. Ideally, the participants themselves help to select the topics of the breakout sessions and then choose which to attend. The breakout sessions should begin and end with round-robin statements of limited time from each participant, so each gets a chance to say at least a few words. Summaries of what transpired are then presented afterwards to a plenary session. What actually happened was that the two breakout sessions discussed the same topics selected solely by NWMO focusing sharply on the main features of the Chapter 1 plan, presumably with the intention of seriously considering only any suggested minor adjustments to them. The NWMO moderators ruled out-of-order anybody who sought permission to speak off-topic, but had less success stemming longish statements and discussions from those who did not seek such permission, in many cases because it was unclear whether or not they were off-topic without hearing them through. For the Dialoguein Trois-Rivieres, I personally would have preferred the inclusion of an extra afternoon session from 2:00 to 5:00 p.m. on July 8 th so that the entire program could be expanded to include formal presentations from pre-registered critics and segments devoted to what is missing from the Draft Study Report. If participants had been invited to submit abstracts of 10-minute talks on what was missing, this might have encouraged them to read the Draft Study Report more thoroughly beforehand; it would have also added some variety to the whole Dialogue, and incidentally helped to level the debate playing field between academics and non-academics. Additionally, particularly for newcomers to the nuclear waste debate, it would have been very useful to include a 15-minute presentation reviewing Appendix 11 on the Regulatory Framework in the extra afternoon session.
The simultaneous translation services were very good because the translators appeared to have some familiarity with the subject matter. There was a consensus that the primary language used in the breakout sessions should be French so that only unilingual anglophones spoke in English. The way things worked out, all the unilingual anglophones were placed in the same breakout group, allowing the simultaneous translation service to be used for this group. The food and refreshments provided on July 9 th were for the most part excellent, although I myself would have preferred to have seen some plain bread or rolls available for breakfast. The sandwiches provided prior to the evening session on July 8 th were less acceptable because the contents of their minced fillings were not readily identifiable. Just plain cheese, chopped egg, or sliced ham would have been preferable. I am myself highly allergic to crab and lobster, and I have learnt to view with suspicion anything minced up that tastes fishy.
4. What was Missing from the Dialogue
(a) Consideration of the Political Dimension
No mention was made of the political situation in Canada and how it may impact the implementation of the plan recommended in Chapter 1. I seem to remember somebody from NWMO telling me last year in Montreal that the Nuclear Fuel Waste Act had the support of all parties when it was passed by Parliament in 2002. If so, this should still hold true of the current Parliament if the Liberal Minority Government decides amendments to the Act are needed before the plan is implemented. However, it seems to me that it would be prudent for NWMO to officially deliver copies of the Final Study Report to the leaders of all four Parliamentary Parties on Nov. 15 th, and not just to the Government, to make sure that no Party becomes miffed because of not being officially informed of its availability in a timely way. I personally would add the Leader of the Green Party to the official distribution list because I think we are close to electing our first Green MP somewhere in Canada. In the future, it is not hard to imagine the Bloc raising objections if one central site is chosen in Quebec and none in Ontario. In any case, I think Paul Martin will find himself committed to calling for an Election to be held in April 2006, so there may not be time for the Liberal Minority Government to peruse the Final Study Report and decide what to do about it before the House is dissolved next March. This raises the following question. Is there anything NWMO can do now to identify what amendments – if any – will have to be made to the Act? If so, recommendations concerning what they should be could be included in the Final Study Report in an attempt to get things moving before the Election. Similarly, if NWMO thinks that the plan can be implemented without amending the Act, this should be stated as a recommendation in the Final Study Report. Politics is too important to be left to the politicians.
(b) Emphasis on the Reality That Nuclear Fission Power Reactors Are Here To Stay
Some people are opposed to having any nuclear fission power reactors at all in Canada, strongly object to the construction of new ones, and see NWMO as the organization mandated to supervise the decommissioning of the old ones. Whatever one’s opinions on the desirability or otherwise of having nuclear fission power reactors, the reality is that they are here to stay in the world as a whole for the foreseeable future, with Canada unlikely to be an exception. For political reasons, to ensure the support of the public at large and all MPs, I think this reality should be demonstrated by including in the blank space of page 9 a chart showing how the total number of nuclear fission power reactors in the world has grown in time since the first ones were commissioned in about 1950 a few years after WW2, along with a similar (and perhaps superimposed) chart of the total number of countries using them. This would provide the strongest possible justification for having an NWMO plan at all inside the plan itself and thereby discourage anyone who might be tempted to disparage its importance. Appendix 10 reports that 32 countries now operate 400 nuclear fission power reactors, and that Canada has 22 (at 7 sites). Appendix 12 projects that Canada will continue to generate 15 per cent of its total energy supply from them and this will eventually entail an expansion from 7 to 10 sites. Both these appendices should be referred to on page 9. Any other unused blank space on page 9 could be filled with other relevant information, such as that China is now moving into nuclear power generation in a big way, and that Ontario’s commitment to close down its coal-powered generating stations almost surely means that Province will have to generate more nuclear power. The U.S. has just approved a new energy plan still relying mainly on oil, but anticipating the commissioning of more nuclear power reactors.
(c) The Need For A Closer Look At The Licensing Procedure
The critical action that the Canadian Nuclear Safely Commission will some day be called upon to take is to grant a licence to the NWMO for the construction and operation of a proposed central storage site. Perhaps completely satisfactory detailed rules for precisely how this should be done already exist, particularly with regard as to how the key people who will have to make a granting decision are selected or appointed to ensure their independence and avoid cronyism. If they do, it would be a good idea to summarize them in the Final Report; if they do not, the need to write some new rules should be identified.
(d) Inclusion Of A Proposal For An NWMO Staffing Expansion
In one of the breakout sessions on implementation, the current fairly modest staffing level of NWMO was described to us. Clearly, implementation of the proposed plan would require staff increases. However, I got the impression that although some preliminary thought is being given as to how the increased workload could be divided up between permanent staff and contractors, there is no intention of mentioning this in the Final Study Report because it is seen as something to be done later, after a plan has been approved by the Government. The problem here is that to propose a staffing expansion plan later would delay the start of getting things done. Why not include a staffing expansion plan in the Draft Study Report and get it approved along with everything else? Governments like the idea of contracting work out because it ostensibly reduces the permanent staff payroll in years to come. However, there are pitfalls in going overboard in contracting work out. One problem is that actually the contracting out of work by a project officer on permanent staff requires somebody to write a Request For Proposals (RFP) that includes descriptions of the tasks to be undertaken and what the deliverables should be in enough detail to make sure that the work done matches what is wanted. This can itself take a significant amount of someone’s time. Another problem is that any deliverables have to be approved by the project officer, and he/she will have many other duties in addition to approving deliverables. In my experience, it helps considerably to have RFPs drafted and deliverables quality-assured by an independent contractor reporting to the project officer. In any case NWMO, by virtue of its responsibilities, obviously requires a guaranteed continuity of permanent staff more than almost any other organization. Between now and Nov. 15 th, I think it would be prudent to include a proposal for something like a doubling of the NWMO permanent staff in the first year of operation, and the scheduling of training-cum-orientation courses for newly recruited staff members beginning after Labour Day 2006. Preparation of the training courses could begin after the Final Study Report has been filed. Even if proposals for staff augmentation are considered strictly speaking to belong in the documentation being prepared for NWMO’s budget for FY2006/7, having them explicitly mentioned in a Government-approved plan would help enormously in getting this budget approved.
(e) The Need For A Back-Up Plan For Site Selection
In the draft version of the plan, serious problems will arise if no acceptable communities volunteer to host a central site. It would be prudent to include a back-up plan for what should be done if this happens. In the cities, it is legally well-established that private property can be expropriated by the community for the common good -- such as to widen a road or build an airport -- provided reasonable compensation is paid to the owner. The same principle surely applies to the selection of a central site for thestorage of nuclear waste. No country has more relatively uninhabited geographical areas suitable for housing such central storage sites than Canada has. If no community volunteers to host an acceptable central storage site, one must be chosen and expropriated over the objections of the community concerned. My first thoughts on this matter are that the expropriated location should preferably be:
(i) in the middle of a virtually uninhabited area at least 10 km in radius containing a flat portion big and suitable enough to build an aircraft landing strip on at low cost, or within 30 km of an existing paved road;
(ii) not within 20 km of a natural waterway or lake. Unfortunately, this probably means choosing proposed locations where most of the few inhabitants are aboriginal peoples who may have rights under existing Treaties with the Federal Government.
(f) Lack Of Ranges On Estimates
The financial estimates in the Chapter 18 are for 3.6 million fuel bundles but no figures are provided for the total number of fuel bundles to be processed and their variation with time. I think it would be useful to include in the Final Report estimates of the maximum and minimum numbers of nuclear reactors Canada will have in 50 years time, given that the most likely number will be about 50% more than we have now. Inclusion of such estimates would underline the fact that the total amount of nuclear waste to be dealt with is unavoidably linked to the national energy policy. Similarly, I am concerned that there must be considerable uncertainty over how much each individual task included in the plan will actually cost in terms of billions of Can$2004, so it would be preferable to cite some ranges on the financial estimates of Table 4-12. It is not enough to build in an overall cushion of 30% as was done.
(g) Opportunity To Initiate Closer International Collaboration on Nuclear Waste
It is implicit in Appendices 10 and 11 that Canada should co-operate with other countries over the problem of what to do about nuclear waste. In my opinion, there is an opportunity for Canada to explicitly take a more prominent role in organizing this co-operation by making provision for doing this in the Final Report.
(h) Incentives to Stimulate Public Participation
It seems to me that simply advertising opportunities for input to NWMO decision-making in the newspapers is not enough. People are busy with their own lives and are reluctant to spend their free time discussing what should be done about nuclear waste. Possibly, NWMO could ask organizations such as the Riding Associations of the Political Parties, Scientific Societies, Environmental Groups, etc., to nominate people to attend NWMO events such as the current round of Dialogues and pay them stipends for their time.
5. Some Specific Comments And Suggestions
(a) Concerns About Ordovician Sedimentary Rock
I was surprised to see ordovician sedimentary rock mentioned as being possibly acceptable as a central storage site as the old igneous rock of the Canadian Shield without mention of its thickness. Presumably that near Hudson’s Bay was formed on top of the Canadian Shield rock, so by drilling deep enough one would go right through it and penetrate the Canadian Shield rock anyway. My suspicion is that sedimentary rock is more prone to water seepage and less hard than igneous rock, and therefore that it is significantly less suitable for storing nuclear waste. On the other hand, it would be easier to drill through sedimentary rock, so to maximize the depth of a deep depository below mean sea level obtainable from a given amount of drilling effort, one would like to drill right through the sedimentary rock and store the nuclear waste below it in old igneous rock that is geologically inert.
(b) The Possibility Of Choosing More Than One Central Site
I strongly suspect that the most suitable potential central storage sites will turn out to be in Quebec. If just one central storage site were chosen and it turned out to be in Quebec there could be a stronger NIMBY reaction (with political overtones) than there would be if just one were chosen in Ontario. My intuitive feeling is that three central storage sites should be chosen initially, one each in Ontario, Quebec, and Northern Saskatchewan; but that drilling operations start first in Ontario and later be continued in Quebec with Saskatchewan being last. The potential for running into political problems might be reduced if a central storagesite could be found that straddled the Ontario-Quebec border. Is there any chance of storing nuclear waste in abandoned Uranium mines? If there is, this would reduce drilling costs.
(c) Ambiguity About The Extent Of Shallow Underground Storage At A Central Site
While I concede that there could be shallow underground staging area at a central site, I see no reason to delay for very long before putting nuclear waste in its final placement deep underground. I suppose, therefore, that I am thinking in terms of accumulating incoming waste for say 6 months to a year in a shallow underground staging area that is not overlarge, and then moving it all as quickly as possible deep underground so as to empty the staging area.
(d) Unwarranted Public Fear of a Chernobyl-type Accident At A Central Storage Site
In one of our breakout sessions, some participants insisted on spending a lot of the time discussing the possibility of a Chernobyl-type out-of-control nuclear reaction at a centralstorage site. NWMO’s Sean Russell correctly stated that radio-active material has to attain a critical mass for a nuclear explosion to occur, and that there is absolutely no possibility of this happening at a nuclear waste storage site because of the way the bundles are constructed. This was not enough to satisfy those who raised the issue, but this was not the place for him to explain the nuclear physics involved in more detail and the moderator eventually moved us on to another subject. Nevertheless, the debate on the matter reflects the fact that the public-at-large does not distinguish the dangers associated with nuclear reactors from those associated with the storage sites for nuclear waste. As the safety record in France shows, nuclear reactors are safe provided they are properly maintained and properly operated. However, they do produce nuclear waste. On the other hand, there is no possibility of a nuclear explosion at a nuclear waste storagesite even if it is not properly maintained and not properly operated. The danger is only that the radioactive waste material might escape from the capsules encasing it and somehow be transported to the surrounding areas. Proper maintenance and operation of the storage site will ensure that this does not happen under normal circumstances. However, terrorists could steal the nuclear waste and find ways to harm people with it, so it has to be guarded. Perhaps some Section of the Draft Study Report could be rewritten to place greater emphasis on thesafety of nuclear waste storage, but it is difficult to decide exactly how this should be done. It might be preferable to ask the Canadian Association of Physicists to officially certify that there is absolutely no risk of a runaway nuclear reaction at a nuclear waste storage site, and prominently include this certification in the Final Report. But there is not much time left to get this done before Nov. 15 th. With some luck on the timing, Sean Russell could draft a proposed certification, and the Executive of CAP could approve it if they happen to have a meeting scheduled in September or October, as is possible.
(e) Lack Of Aboriginal Participation At Trois-Rivieres
It is obviously very important to involve aboriginals in the NWMO Public Consultations so it was disappointing that no Quebec aboriginals attended the Trois- RivieresDialogue, especially when there has been significant aboriginal attendance at theDialogues held in Ontario and New Brunswick. Perhaps an attempt should be made to find out why they did not attend and investigate if there is any other way they can make their views known.
(f) Possible Technological Breakthroughs
The two possible technological breakthroughs that would completely change the picture with regard to nuclear waste are:
(a) the development of a power station based on nuclear fusion;
(b) the development of an efficient and reliable re-usable space shuttle.
With (a), nuclear fusion power stations with no (or much less) nuclear waste would quickly replace nuclear fission power stations when they become significantly cheaper. With (b), nuclear waste could be dumped in the sun instead of being buried, though then of course it could never be recovered if a use is found. Note that the U.S. is contributing a huge amount of financial support to a new international effort to develop fusion energy in France, I think in addition to funding existing U.S. fusion projects.
(g) Involving The Universities
The NWMO has not so far held any public consultations and discussions in the Universities, and perhaps it should do so.
(h) Minor Suggestions
(i) In Table A10-1 on page 285, substitute South Korea for Korea to clearly distinguish it from North Korea.
(ii) In Table 4-12 on page 226, convert the 2002Can$ to 2004Can$. * END *
NUCLEAR WASTE MANAGEMENT ORGANIZATION (NWMO) ARISING
FROM THE DIALOGUE HELD IN TROIS-RIVIERES JULY 8-9 TH 2005
David Davies
Preface
This document is the outcome of my participation in the NWMO Dialogue held at the Hotel Gouvernor Trois-Rivieres in Trois-Rivieres on July 8-9 th,2005. I received much written information beforehand by mail and e-mail, including a hard copy of the draft study report to be finalized by Nov. 15 th. I managed to read through the whole of this draft before the opening session came to order at 6:00 p.m. on July 8 th.
My background is briefly as follows. My academic qualifications are:
(1) B.Sc., Honours in Mathematical Physics , University of Birmingham, 1954.
(2) M.A., Physics (Meteorology), University of Toronto, 1956.
(3) Ph.D., Dynamic Meteorology, McGill University, 1970.
I retired from a career as a Meteorologist and Research Scientist with the Meteorological Service of Canada (for a long period known as the Atmospheric Environment Service of Canada) in 1991, having spent many years working on Numerical Weather Prediction, and 10 years as the Technical Co-ordinator of an International Acid Rain Modelling Project funded by the Province of Ontario, the Canadian Meteorological Service, West Germany, the U.S. Electric Power Research Institute, and some U.S. States. The main model development was contracted out to a U.S. company and the development of the North American data bases was contracted out to a Canadian company. Throughout we collaborated and compared progress with a very similar U.S. Government Project funded under the NAPAP umbrella and contracted out to U.S. Universities and Companies. The outcome was the signing of the Acid Rain Agreement by the U.S. and Canada in March 1991. From 1992 until 1999, after I retired, I undertook contracts to quality assure emissions data, to act as rapporteur at technical meetings, etc.
List of Contents page
1. Introduction 2
2. My Understanding Of The Consensus Reached 2
3. Comments On The Conduct of the DialogueSessions 3
4. What was Missing from the Dialogue 4
(a) Consideration of the Political Dimension 4
(b) Emphasis on the Reality That Nuclear Fission Power Reactors Are Here To Stay 5
(c) The Need For A Closer Look At The Licensing Procedure 5
(d) Inclusion Of A Proposal For An NWMO Staffing Expansion 5
(e) The Need For A Back-Up Plan For Site Selection 6
(f) Lack Of Ranges On Estimates 6
(g) Opportunity To Initiate Closer International Collaboration on Nuclear Waste 7
(h) Incentives to Stimulate Public Participation 7
5. Some Specific Comments And Suggestions 7
1. Introduction
As Elizabeth Dowdeswell made clear in her opening statement, the purpose of the series of NWMO Dialogues being held across the country in the summer months is to review the Draft Study Report and the plan it contains in Chapter 1 in order to consider possible amendments that might be made before the final version is submitted to Cabinet on Nov. 15 th. These must not entail major rewrites of the whole Report.
2. My Understanding Of The Consensus Reached
Participants included people with diverse opinions on the future of nuclear fission generating stations in Canada.
Nevertheless, and please correct me if I am wrong, it is my understanding that a consensus emerged on the following points:
(1) The open process adopted by the NWMO is the correct one to follow, especially with regard to consulting the public and those most likely to be affected. The NWMO is to be congratulated for the hard and conscientious work that obviously went into the production of the Draft Study Report.
(2) The plan for nuclear waste management cannot be considered as something completely separate to a plan for future energy policy. The two must go hand-in-hand, if only because NWMO must have some idea how much nuclear waste it will be called upon to deal with in future years.
(3) The time-scale for implementation of the plan should be speeded up as much as humanly possible, so as to provide some concrete evidence that action is being undertaken in the reasonably near future and not simply being left to the next generation.
(4) Use of the word “disposal” should be avoided in the terminology wherever this can reasonably be done, since even the first option is strictly speaking “deep geological permanent safestorage in the Canadian Shield”.
(5) The Draft Study Report should be expanded to be more specific on the Findings and Recommendations of the Seaborn Panel and what responses have been made to them. It is not sufficient to post the Seaborn Report and a series of articles responding to concerns raised in it on the NWMO web-site.
(6) What is of concern to average citizens is the cost of the implementation of nuclear waste control measures per kilowatt hour as it will appear on their electricity bills. This does not explicitly appear in the Draft Study Report, although NWMO staff are verbally quoting 0.1 cents/kwh -- the same figure that was being bandied about 10 years ago without any allowance for a decade of inflation or the more elaborate measures now being contemplated. This discrepancy is something that should be investigated immediately so that an up-to-date value can be prominently and explicitly inserted in the final report.
(7) The Draft Study Report’s anticipation that communities will rush to volunteer to host a central storage site, deep or not, is a hypothesis that may well turn out to be wrong if latent NIMBY reactions by the Canadian public have been seriously underestimated by NWMO. An additional complication is that at some stage consideration will have to be given to the mechanism whereby a community opts to volunteer -- 50% + 1 in a referendum is probably not going to be enough.
(8) The so-called adaptive phased management plan being recommended is actually just common sense dangerously phrased so as to encourage procrastination by politicians, because it does not stress the urgency of initiating action in the near future.
(9) The Board of Directors of the NWMO should evolve so as to become much more independent of the organizations generating nuclear power than it now is. NWMO staff members gave attendees assurances that this is what is intended and that slow steps are being made in this direction. The emergence of the foregoing consensus alone makes the holding of the Trois-Rivieres Dialogue well worthwhile.
3. Comments On The Conduct of the DialogueSessions
At the start of the main plenary sessions, Elizabeth Dowdeswell made excellent and entirely appropriate introductory statements that summarized what is in the Draft Study Report. However, she failed to solicit comments on what was missing from it. She got them just the same from Gordon Edwards (of the Canadian Coalition for Nuclear Responsibility) who hogged much of the discussion time in the plenary sessions and the morning breakout session on July 9 th. What he said very much needed to be said, although I think it could have been done without putting the hostile slant of a nuclear power abolitionist that he did on many of his remarks. In retrospect, I think it would have been preferable to have signed up admitted critics of any use of nuclear power beforehand and given them their own time in the program to make critical speeches upon condition they agree to refrain from dominating the discussion periods by making more long statements of their own in them.
In events of this nature, it is my understanding that the breakout sessions are most advantageously devoted to different topics, so that the details of each of these can be discussed by subgroups of the participants. Ideally, the participants themselves help to select the topics of the breakout sessions and then choose which to attend. The breakout sessions should begin and end with round-robin statements of limited time from each participant, so each gets a chance to say at least a few words. Summaries of what transpired are then presented afterwards to a plenary session. What actually happened was that the two breakout sessions discussed the same topics selected solely by NWMO focusing sharply on the main features of the Chapter 1 plan, presumably with the intention of seriously considering only any suggested minor adjustments to them. The NWMO moderators ruled out-of-order anybody who sought permission to speak off-topic, but had less success stemming longish statements and discussions from those who did not seek such permission, in many cases because it was unclear whether or not they were off-topic without hearing them through. For the Dialoguein Trois-Rivieres, I personally would have preferred the inclusion of an extra afternoon session from 2:00 to 5:00 p.m. on July 8 th so that the entire program could be expanded to include formal presentations from pre-registered critics and segments devoted to what is missing from the Draft Study Report. If participants had been invited to submit abstracts of 10-minute talks on what was missing, this might have encouraged them to read the Draft Study Report more thoroughly beforehand; it would have also added some variety to the whole Dialogue, and incidentally helped to level the debate playing field between academics and non-academics. Additionally, particularly for newcomers to the nuclear waste debate, it would have been very useful to include a 15-minute presentation reviewing Appendix 11 on the Regulatory Framework in the extra afternoon session.
The simultaneous translation services were very good because the translators appeared to have some familiarity with the subject matter. There was a consensus that the primary language used in the breakout sessions should be French so that only unilingual anglophones spoke in English. The way things worked out, all the unilingual anglophones were placed in the same breakout group, allowing the simultaneous translation service to be used for this group. The food and refreshments provided on July 9 th were for the most part excellent, although I myself would have preferred to have seen some plain bread or rolls available for breakfast. The sandwiches provided prior to the evening session on July 8 th were less acceptable because the contents of their minced fillings were not readily identifiable. Just plain cheese, chopped egg, or sliced ham would have been preferable. I am myself highly allergic to crab and lobster, and I have learnt to view with suspicion anything minced up that tastes fishy.
4. What was Missing from the Dialogue
(a) Consideration of the Political Dimension
No mention was made of the political situation in Canada and how it may impact the implementation of the plan recommended in Chapter 1. I seem to remember somebody from NWMO telling me last year in Montreal that the Nuclear Fuel Waste Act had the support of all parties when it was passed by Parliament in 2002. If so, this should still hold true of the current Parliament if the Liberal Minority Government decides amendments to the Act are needed before the plan is implemented. However, it seems to me that it would be prudent for NWMO to officially deliver copies of the Final Study Report to the leaders of all four Parliamentary Parties on Nov. 15 th, and not just to the Government, to make sure that no Party becomes miffed because of not being officially informed of its availability in a timely way. I personally would add the Leader of the Green Party to the official distribution list because I think we are close to electing our first Green MP somewhere in Canada. In the future, it is not hard to imagine the Bloc raising objections if one central site is chosen in Quebec and none in Ontario. In any case, I think Paul Martin will find himself committed to calling for an Election to be held in April 2006, so there may not be time for the Liberal Minority Government to peruse the Final Study Report and decide what to do about it before the House is dissolved next March. This raises the following question. Is there anything NWMO can do now to identify what amendments – if any – will have to be made to the Act? If so, recommendations concerning what they should be could be included in the Final Study Report in an attempt to get things moving before the Election. Similarly, if NWMO thinks that the plan can be implemented without amending the Act, this should be stated as a recommendation in the Final Study Report. Politics is too important to be left to the politicians.
(b) Emphasis on the Reality That Nuclear Fission Power Reactors Are Here To Stay
Some people are opposed to having any nuclear fission power reactors at all in Canada, strongly object to the construction of new ones, and see NWMO as the organization mandated to supervise the decommissioning of the old ones. Whatever one’s opinions on the desirability or otherwise of having nuclear fission power reactors, the reality is that they are here to stay in the world as a whole for the foreseeable future, with Canada unlikely to be an exception. For political reasons, to ensure the support of the public at large and all MPs, I think this reality should be demonstrated by including in the blank space of page 9 a chart showing how the total number of nuclear fission power reactors in the world has grown in time since the first ones were commissioned in about 1950 a few years after WW2, along with a similar (and perhaps superimposed) chart of the total number of countries using them. This would provide the strongest possible justification for having an NWMO plan at all inside the plan itself and thereby discourage anyone who might be tempted to disparage its importance. Appendix 10 reports that 32 countries now operate 400 nuclear fission power reactors, and that Canada has 22 (at 7 sites). Appendix 12 projects that Canada will continue to generate 15 per cent of its total energy supply from them and this will eventually entail an expansion from 7 to 10 sites. Both these appendices should be referred to on page 9. Any other unused blank space on page 9 could be filled with other relevant information, such as that China is now moving into nuclear power generation in a big way, and that Ontario’s commitment to close down its coal-powered generating stations almost surely means that Province will have to generate more nuclear power. The U.S. has just approved a new energy plan still relying mainly on oil, but anticipating the commissioning of more nuclear power reactors.
(c) The Need For A Closer Look At The Licensing Procedure
The critical action that the Canadian Nuclear Safely Commission will some day be called upon to take is to grant a licence to the NWMO for the construction and operation of a proposed central storage site. Perhaps completely satisfactory detailed rules for precisely how this should be done already exist, particularly with regard as to how the key people who will have to make a granting decision are selected or appointed to ensure their independence and avoid cronyism. If they do, it would be a good idea to summarize them in the Final Report; if they do not, the need to write some new rules should be identified.
(d) Inclusion Of A Proposal For An NWMO Staffing Expansion
In one of the breakout sessions on implementation, the current fairly modest staffing level of NWMO was described to us. Clearly, implementation of the proposed plan would require staff increases. However, I got the impression that although some preliminary thought is being given as to how the increased workload could be divided up between permanent staff and contractors, there is no intention of mentioning this in the Final Study Report because it is seen as something to be done later, after a plan has been approved by the Government. The problem here is that to propose a staffing expansion plan later would delay the start of getting things done. Why not include a staffing expansion plan in the Draft Study Report and get it approved along with everything else? Governments like the idea of contracting work out because it ostensibly reduces the permanent staff payroll in years to come. However, there are pitfalls in going overboard in contracting work out. One problem is that actually the contracting out of work by a project officer on permanent staff requires somebody to write a Request For Proposals (RFP) that includes descriptions of the tasks to be undertaken and what the deliverables should be in enough detail to make sure that the work done matches what is wanted. This can itself take a significant amount of someone’s time. Another problem is that any deliverables have to be approved by the project officer, and he/she will have many other duties in addition to approving deliverables. In my experience, it helps considerably to have RFPs drafted and deliverables quality-assured by an independent contractor reporting to the project officer. In any case NWMO, by virtue of its responsibilities, obviously requires a guaranteed continuity of permanent staff more than almost any other organization. Between now and Nov. 15 th, I think it would be prudent to include a proposal for something like a doubling of the NWMO permanent staff in the first year of operation, and the scheduling of training-cum-orientation courses for newly recruited staff members beginning after Labour Day 2006. Preparation of the training courses could begin after the Final Study Report has been filed. Even if proposals for staff augmentation are considered strictly speaking to belong in the documentation being prepared for NWMO’s budget for FY2006/7, having them explicitly mentioned in a Government-approved plan would help enormously in getting this budget approved.
(e) The Need For A Back-Up Plan For Site Selection
In the draft version of the plan, serious problems will arise if no acceptable communities volunteer to host a central site. It would be prudent to include a back-up plan for what should be done if this happens. In the cities, it is legally well-established that private property can be expropriated by the community for the common good -- such as to widen a road or build an airport -- provided reasonable compensation is paid to the owner. The same principle surely applies to the selection of a central site for thestorage of nuclear waste. No country has more relatively uninhabited geographical areas suitable for housing such central storage sites than Canada has. If no community volunteers to host an acceptable central storage site, one must be chosen and expropriated over the objections of the community concerned. My first thoughts on this matter are that the expropriated location should preferably be:
(i) in the middle of a virtually uninhabited area at least 10 km in radius containing a flat portion big and suitable enough to build an aircraft landing strip on at low cost, or within 30 km of an existing paved road;
(ii) not within 20 km of a natural waterway or lake. Unfortunately, this probably means choosing proposed locations where most of the few inhabitants are aboriginal peoples who may have rights under existing Treaties with the Federal Government.
(f) Lack Of Ranges On Estimates
The financial estimates in the Chapter 18 are for 3.6 million fuel bundles but no figures are provided for the total number of fuel bundles to be processed and their variation with time. I think it would be useful to include in the Final Report estimates of the maximum and minimum numbers of nuclear reactors Canada will have in 50 years time, given that the most likely number will be about 50% more than we have now. Inclusion of such estimates would underline the fact that the total amount of nuclear waste to be dealt with is unavoidably linked to the national energy policy. Similarly, I am concerned that there must be considerable uncertainty over how much each individual task included in the plan will actually cost in terms of billions of Can$2004, so it would be preferable to cite some ranges on the financial estimates of Table 4-12. It is not enough to build in an overall cushion of 30% as was done.
(g) Opportunity To Initiate Closer International Collaboration on Nuclear Waste
It is implicit in Appendices 10 and 11 that Canada should co-operate with other countries over the problem of what to do about nuclear waste. In my opinion, there is an opportunity for Canada to explicitly take a more prominent role in organizing this co-operation by making provision for doing this in the Final Report.
(h) Incentives to Stimulate Public Participation
It seems to me that simply advertising opportunities for input to NWMO decision-making in the newspapers is not enough. People are busy with their own lives and are reluctant to spend their free time discussing what should be done about nuclear waste. Possibly, NWMO could ask organizations such as the Riding Associations of the Political Parties, Scientific Societies, Environmental Groups, etc., to nominate people to attend NWMO events such as the current round of Dialogues and pay them stipends for their time.
5. Some Specific Comments And Suggestions
(a) Concerns About Ordovician Sedimentary Rock
I was surprised to see ordovician sedimentary rock mentioned as being possibly acceptable as a central storage site as the old igneous rock of the Canadian Shield without mention of its thickness. Presumably that near Hudson’s Bay was formed on top of the Canadian Shield rock, so by drilling deep enough one would go right through it and penetrate the Canadian Shield rock anyway. My suspicion is that sedimentary rock is more prone to water seepage and less hard than igneous rock, and therefore that it is significantly less suitable for storing nuclear waste. On the other hand, it would be easier to drill through sedimentary rock, so to maximize the depth of a deep depository below mean sea level obtainable from a given amount of drilling effort, one would like to drill right through the sedimentary rock and store the nuclear waste below it in old igneous rock that is geologically inert.
(b) The Possibility Of Choosing More Than One Central Site
I strongly suspect that the most suitable potential central storage sites will turn out to be in Quebec. If just one central storage site were chosen and it turned out to be in Quebec there could be a stronger NIMBY reaction (with political overtones) than there would be if just one were chosen in Ontario. My intuitive feeling is that three central storage sites should be chosen initially, one each in Ontario, Quebec, and Northern Saskatchewan; but that drilling operations start first in Ontario and later be continued in Quebec with Saskatchewan being last. The potential for running into political problems might be reduced if a central storagesite could be found that straddled the Ontario-Quebec border. Is there any chance of storing nuclear waste in abandoned Uranium mines? If there is, this would reduce drilling costs.
(c) Ambiguity About The Extent Of Shallow Underground Storage At A Central Site
While I concede that there could be shallow underground staging area at a central site, I see no reason to delay for very long before putting nuclear waste in its final placement deep underground. I suppose, therefore, that I am thinking in terms of accumulating incoming waste for say 6 months to a year in a shallow underground staging area that is not overlarge, and then moving it all as quickly as possible deep underground so as to empty the staging area.
(d) Unwarranted Public Fear of a Chernobyl-type Accident At A Central Storage Site
In one of our breakout sessions, some participants insisted on spending a lot of the time discussing the possibility of a Chernobyl-type out-of-control nuclear reaction at a centralstorage site. NWMO’s Sean Russell correctly stated that radio-active material has to attain a critical mass for a nuclear explosion to occur, and that there is absolutely no possibility of this happening at a nuclear waste storage site because of the way the bundles are constructed. This was not enough to satisfy those who raised the issue, but this was not the place for him to explain the nuclear physics involved in more detail and the moderator eventually moved us on to another subject. Nevertheless, the debate on the matter reflects the fact that the public-at-large does not distinguish the dangers associated with nuclear reactors from those associated with the storage sites for nuclear waste. As the safety record in France shows, nuclear reactors are safe provided they are properly maintained and properly operated. However, they do produce nuclear waste. On the other hand, there is no possibility of a nuclear explosion at a nuclear waste storagesite even if it is not properly maintained and not properly operated. The danger is only that the radioactive waste material might escape from the capsules encasing it and somehow be transported to the surrounding areas. Proper maintenance and operation of the storage site will ensure that this does not happen under normal circumstances. However, terrorists could steal the nuclear waste and find ways to harm people with it, so it has to be guarded. Perhaps some Section of the Draft Study Report could be rewritten to place greater emphasis on thesafety of nuclear waste storage, but it is difficult to decide exactly how this should be done. It might be preferable to ask the Canadian Association of Physicists to officially certify that there is absolutely no risk of a runaway nuclear reaction at a nuclear waste storage site, and prominently include this certification in the Final Report. But there is not much time left to get this done before Nov. 15 th. With some luck on the timing, Sean Russell could draft a proposed certification, and the Executive of CAP could approve it if they happen to have a meeting scheduled in September or October, as is possible.
(e) Lack Of Aboriginal Participation At Trois-Rivieres
It is obviously very important to involve aboriginals in the NWMO Public Consultations so it was disappointing that no Quebec aboriginals attended the Trois- RivieresDialogue, especially when there has been significant aboriginal attendance at theDialogues held in Ontario and New Brunswick. Perhaps an attempt should be made to find out why they did not attend and investigate if there is any other way they can make their views known.
(f) Possible Technological Breakthroughs
The two possible technological breakthroughs that would completely change the picture with regard to nuclear waste are:
(a) the development of a power station based on nuclear fusion;
(b) the development of an efficient and reliable re-usable space shuttle.
With (a), nuclear fusion power stations with no (or much less) nuclear waste would quickly replace nuclear fission power stations when they become significantly cheaper. With (b), nuclear waste could be dumped in the sun instead of being buried, though then of course it could never be recovered if a use is found. Note that the U.S. is contributing a huge amount of financial support to a new international effort to develop fusion energy in France, I think in addition to funding existing U.S. fusion projects.
(g) Involving The Universities
The NWMO has not so far held any public consultations and discussions in the Universities, and perhaps it should do so.
(h) Minor Suggestions
(i) In Table A10-1 on page 285, substitute South Korea for Korea to clearly distinguish it from North Korea.
(ii) In Table 4-12 on page 226, convert the 2002Can$ to 2004Can$. * END *
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