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Responses to Questions Raised from the Peer Review of Canada's Seventh National Report for the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management

This document supplements the seventh Canadian National Report for the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. In support of the Seventh Review Meeting, Canada received 83 questions from 17 Contracting Parties. The answers provided in this document demonstrate how Canada has implemented its obligations under the Joint Convention.

Question Id Country Posted
By
Seque-nce Article Reference Question Answer

16603

Canada

Slovakia

1

Article 32

B, p. 17

As mentioned in text of National Report, since 1990, dry storage technology has been chosen at all the reactor sites for on-site interim storage of spent CANDU fuel. Were there any notable issues identified during the operation of dry spent fuel storage, which have led to changes in operation procedures or licence requirements?

No significant changes have been made to the technology or licensing of dry fuel storage methods or containers since the introduction of these facilities in the 1990s.

Canadian Nuclear Laboratories has experience in operating dry storage systems for spent fuel at 4 sites across Canada (Chalk River, Douglas Point, Gentilly-1, and Whiteshell). To date, there have not been any significant issues that led to changes in operations procedures or licence requirements. The expansion of facilities at one site did result in the need to modify supporting infrastructure to meet modern regulatory requirements (e.g., security). One upcoming challenge involves the aging management of storage structures, with many structures nearing the end of their engineered lifespan (50 years), with a need to extend or replace based on planned retrieval and disposal timelines.

No notable issues identified during the operation of dry spent fuel storage has led to changes in operation procedures or licence requirements for Hydro-Québec or New Brunswick Power's facilities.

For Ontario Power Generation facilities, no significant changes have been made to the technology or licensing of dry fuel storage methods or containers since the introduction of these facilities in the 1990s. Minor improvements have been made to the design of the containers for ease of decontamination, draining, and processing for storage.

16604

Canada

Slovakia

2

Article 25

F, p. 125

In regard to the Canada – United States Joint Radiological Emergency Response Plan, which was signed in 1996, are there any provisions to ensure that harmonized approach and appropriate coordination across national borders will be in place during emergencies?

Please note that the referenced Joint Radiological Emergency Response Plan (1996) is no longer applicable. Should a severe accident of national consequence take place, arrangements are now described under the Canada-United States Action Plan for Critical Infrastructure. This non-binding action plan:

  • promotes an integrated approach to critical infrastructure protection and resilience by enhancing coordination of activities and facilitating continuous dialogue among cross-border stakeholders
  • sets the framework for: federal-level Canada–U.S. collaboration on emergency management issues and the provision of assistance (supplies/equipment, emergency responders, expert support); and the integration of federal response and relief efforts for cross-border incidents
  • allows for more effective sharing of information
  • enables joint efforts to better prevent, prepare for, and respond to new and emerging threats

17090

Canada

United States of America

3

Article 6

K.2.6.1, p. 189

The report notes that the low-level waste near surface disposal facility is expected to be operational by 2024. If this project, which is pending regulatory approval, is delayed, please elaborate on the impact of this delay on the management of low-level waste. For example, do the current storage facilities have sufficient capacity to receive low-level waste, or will new storage facilities be needed in the short term?

Canadian Nuclear Laboratories (CNL) has developed plans that would allow it to continue to operate to approximately 2030 without building new storage facilities. Multiple contingency plans have been identified, evaluated and developed, with select mitigation plans currently in the execution phase. These include the repurposing of existing facilities and/or the delaying or halting of decommissioning and remediation activities.

Ongoing waste storage (“do nothing”) as an alternative option has been included in the Near Surface Disposal Facility (NSDF) environmental impact statement (EIS) in section 2.5.2.1. The “do nothing” option could involve the existing configuration of the Chalk River Laboratories (CRL) waste management areas (WMAs). This configuration includes the use of bunkers and storage buildings, as well as rolling stewardship or monitored retrievable storage for continued storage, and would need an indefinite interim storage space for existing legacy waste and waste that will be generated in the future (e.g., during decommissioning). However, the historic WMAs have minimal to no engineered barriers to contain their inventory. As such, these legacy wastes are exposed to weathering and erosion (rain, snow, corrosion, etc.), resulting in the release of contaminants into the environment. Although the releases and groundwater impact from these WMAs is currently being managed, the risk of future releases and environmental impacts the inventory poses could be substantially reduced through improved containment and isolation of the source term. Leaving the historic WMAs in their current configuration as an alternative to low-level radioactive waste (LLW) disposal is not technically feasible as it is unlikely to satisfy regulatory and licensing requirements for long-term waste management. Therefore, the practice of continuing to build additional temporary storage systems at the CRL site for LLW is not sustainable. It will not reduce the risks associated with waste release or the cost of laboratory operations. Furthermore, “doing nothing” will not help to create the conditions for the revitalization of the CRL property. 

Further, as noted in section 2.3 of the final EIS, continuing to build additional temporary storage systems at the CRL site for LLW is not consistent with modern waste management principles. In accordance with Canada’s Radioactive Waste Policy Framework, the waste producers and owners of radioactive waste are responsible for the funding, organization, management and operation of disposal facilities required for their wastes. As such, CNL does not consider ongoing waste storage as technically feasible, as it is not aligned with national policies.

In this light, CNL continues to exercise waste minimization and processing technologies to extend the current available storage capacity. CNL continues to monitor its inventory closely, while developing contingency planning in the event of further delays.

17091

Canada

United States of America

4

Article 12

K.3.4.2, p. 192-193

The report indicates that after the Port Hope and Port Granby projects are completed, long-term monitoring and maintenance will continue for hundreds of years. Please elaborate on the long-term monitoring activities planned for the sites.

Systems installed within and around the engineered aboveground mound at the Port Hope and Port Granby long-term waste management facilities will monitor the mounds. Visual inspections and monitoring of the collection systems for leachate will confirm the effectiveness of the mound cover systems. Sensors in both the covers and the base liners will monitor performance, while groundwater quality will be monitored through ongoing testing of specially designed wells surrounding the facilities.

17092

Canada

United States of America

5

Article 26

K.2.1, p. 166-167

The report notes that the draft regulatory documents (REGDOC-1.2.1, REGDOC-2.11.1, REGDOC-2.11.2, and REGDOC-3.3.1) are intended to form part of the licensing basis for waste management and decommissioning activities for applicable licenses. Please provide the anticipated timeline and process for adoption of the new requirements by licensees after approval by the Commission.

Implementation is considered during regulatory document development. The Canadian Nuclear Safety Commission (CNSC) has an implementation working group that facilitates discussions among its internal branches, and evaluates the need to implement regulatory documents in whole or in part, based on criteria such as safety significance and risk. Following publication of a CNSC regulatory document, CNSC staff contact licensees to formally request gap analysis and implementation plans. Licensees are typically given 6 months to provide these plans, but this time may change depending on the regulatory document and the anticipated time required to complete the plan. Specific implementation plans and associated timelines are established through follow-up discussions between CNSC staff and individual licensees. Licence conditions handbooks are updated to reflect implementation by including regulatory documents as guidance or compliance verification criteria with the relevant dates from the licensees’ implementation plan. Regulatory document implementation status is reported on an ongoing basis to the Commission through the appropriate regulatory oversight report.

18632

Canada

United Kingdom

6

Article 11

K2.5 (also Article 13)

Section K2.5 states that Ontario Power Group’s (OPG) application to construct a Deep Geological Repository for L/ILW has been withdrawn following a decision by the community not to support the project.

  1. Given the long timescales in building these types of facility, has Canada analysed the impact of this withdrawal in relation to (a) OPG’s capacity to store future waste; and, (b) Canada’s general obligations under the Joint Convention?
  2. If so, what is the output of this analysis?

Assessment of the project cancellation impact was conducted as part of contingency planning, and has been used to determine the future storage requirements for low- and intermediate-level radioactive wastes (L&ILW) based on a number of scenarios. Variables include in-service dates for a repository, as well as volume reduction of existing inventory, and production rate of operating wastes.

For many years, Ontario Power Generation (OPG) has used various means and technologies to minimize the generation of nuclear waste and to divert clean materials away from the waste stream (e.g., use of washable personnel protective equipment). As OPG explores alternative solutions for permanent disposal, OPG will continue to prioritize efforts in waste minimization. This includes minimizing waste production at the source, innovations in waste processing to reduce volume, and recycling of clean materials.

Additional projects have been undertaken to sort, segregate, and volume reduce the low-level radioactive waste at the Western Waste Management Facility, particularly waste that has been in interim storage for decades. Various technologies have been employed to decontaminate materials where possible, and options are being explored for the recycling of large metal components.

For the planned operating life of existing facilities, OPG has the capacity to store future wastes within the boundaries of its licensed properties. 

Canada continues to meet its obligations under the Joint Convention. Currently, all radioactive waste, including the L&ILW that was proposed for disposal in the OPG Deep Geologic Repository, is safely stored at facilities, locations and sites licensed by the CNSC. This will continue to be identified as a challenge and a measure to improve safety in Canada’s next National Report to the Joint Convention.

18633

Canada

United Kingdom

7

Article 11

K2.6 (also Article 13)

Section K2.6 states that the Radioactive Waste Leadership Forum launched a project to produce an Integrated Waste Strategy for Canada, the output expected in 2020.

  1. What is the output from this project?

The project was in response to an action from the Joint Convention that did not include Ontario Power Group.

  1. Given the statement in Section K2.5, how has this impacted Canada’s response to this action?

In the fall of 2020, the Minister of Natural Resources Canada tasked the Nuclear Waste Management Organization (NWMO) with leading an engagement process with Canadians and Indigenous peoples to inform the development of an integrated long-term management strategy for all of Canada’s radioactive wastes.

This work will address existing gaps, specifically in plans for the long-term management for low- and intermediate-level radioactive wastes. The proposed strategy will need to align with the federal government’s modernized Radioactive Waste Management Policy.

In collaboration with waste producers and owners, government, Indigenous peoples, civil society organizations, and interested Canadians, the focus will be on:

  • taking stock and describing the current waste management situation in Canada in terms of current and future volumes, characteristics, locations, and ownership of the waste
  • updating current plans and progress in advancing long-term management and disposal solutions for Canada’s wastes and identifying the gaps that must be addressed
  • providing conceptual approaches for dealing with those wastes for which no long-term plan exists, including technical options for long-term management or disposal, and options for the number of long-term waste management facilities in Canada
  • making recommendations about the staging, integration, establishment, and operation of long-term waste management facilities

The strategy recommendations will be based on public input, Indigenous knowledge, international scientific consensus, and best practices from around the world. The draft recommendations will be published in 2022.

There will be an opportunity for Canadians, Indigenous peoples and interested parties to provide feedback and comments on those recommendations before they are finalized for submission to the Minister of Natural Resources Canada.

The NWMO’s engagement process supersedes work that had been started by the Radioactive Waste Leadership Forum member organizations, who participated in NWMO engagement activities and provided input.

This is separate from Canada’s plan for used nuclear fuel, the Adaptive Phased Management siting process, and leverages the NWMO’s 20 years of recognized expertise in engaging Canadians and Indigenous peoples on plans for the safe, long-term management of used nuclear fuel.

18634

Canada

United Kingdom

8

Article 4

B.1.3.1.5

Section B.1.3.5 states that CANDU fuel bundles can be stored in Dry Storage Containers for up to 100 years or more without losing integrity. Additional research is ongoing.

  1. What is the evidence for the claim that CANDU fuel bundles can be stored in Dry Storage Containers for up to 100 years or more without losing integrity?
  2. Please can you clarify the purpose of the ‘additional research’. Is it referring to research to support the up to 100 year or more claim or to research in other areas?

In preparation for establishing dry fuel storage facilities at Ontario Power Generation sites, significant studies and analyses were performed to optimize the lifetime and reliability of the dry fuel storage containers.

Since the establishment of the Pickering Waste Management Facility in 1994, empirical studies have been performed on the containers (both in-service and controlled spares) to validate assumptions made during the preliminary design, and continuously update the projected lifecycle of these components. Initially, the expected in-service life of a dry fuel storage container was 50 years.

The "additional research" referenced supports the 100-year projected lifetime.

18635

Canada

United Kingdom

9

Article 19

E.2.3.7, E.2.3.7.1 (also Article 20)

Section E.2.3.7 refers to the Canadian Nuclear Safety Commission (CNSC) delegating responsibility for the issuing of certain types of licences to persons identified as designated officers under the legislation.

  1. Please will you give examples of which organisations these designated officers reside in, and if outside of the CNSC, how their independence is assured?

Section E.2.3.7.1 refers to ‘major’ licensing decisions.

  1. How is ‘major’ defined?
  2. Please can you provide some examples of ‘major’ licensing decisions.

Under the Nuclear Safety and Control Act (NSCA), the Commission may authorize designated officers (DOs) to carry out specific authorities. These authorities include – but are not limited to – lower-risk licensing decisions and certification decisions.

Licensing decisions for the following types of nuclear facilities are made by the CNSC Commission:

  • Class IA nuclear facilities, such as nuclear power plants
  • Class IB nuclear facilities, such as waste management facilities
  • uranium mines and mills

For other licence applications, the NSCA allows the Commission to designate certain CNSC staff to carry out specific licensing and regulatory actions. Staff who are granted this decision-making authority are referred to as DOs. When the Commission designates a person as a DO, it provides the person with a certificate of designated officer in accordance with sections 34 and 35 of the General Nuclear Safety and Control Regulations. The CNSC has 35 DO-designated positions; these positions are mainly operational managers in the Regulatory Operations Branch and Technical Support Branch at the CNSC. As noted above, licensing decisions made by DOs are for lower-risk facilities and activities. For example, licences for nuclear medicine, industrial radiography, and medical accelerator facilities are typically issued by a DO, in the order of thousands annually. Rigour is applied to all requests for DO decisions, and the Canadian Nuclear Safety Commission Rules of Procedure apply to such decisions.

For more information on the CNSC’s designated officer program, please refer to:

nuclearsafety.gc.ca/eng/the-commission/designated-officers.

Section E.2.3.7.1 of Canada’s National Report refers to major Commission decisions following a 2-part public hearing process.

Public hearings are governed by the Canadian Nuclear Safety Commission Rules of Procedure (the Rules). The Rules state that a public hearing can be held on one or more days, this refers to both 1- and 2-part public hearings (1-part hearings can take place on more than 1 day). This document refers to hearings as 1-part public hearings (rather than 1-day) and 2-part public hearings (rather than 2-day).

Public hearings deal with more significant licensing activities (such as licence renewals, changes in technology, or removal of a key licence condition for Class IA, Class IB, and uranium mine and mill facilities) or when the level of public interest is high. Typically, applications for renewal of nuclear power plants, or applications for major proposed waste projects are considered by the Commission in a 2-part hearing because of the high level of public interest. Both types of hearings provide for interventions from members of the public, other stakeholders, and Indigenous communities and nations.

For more information on the public Commission hearings and previous 2-part public hearings, please refer to: nuclearsafety.gc.ca/eng/the-commission/hearings/index.

18636

Canada

United Kingdom

10

Article 19

E.2.3.8.2

Section E.2.3.8.2 states that licences are typically granted for periods of 5-10 years and that in 2002 flexible licences were introduced.

  1. How does Canada manage the facility if the current licence holder is unwilling to apply for a further licence and no other potential licensees express an interest in managing the facility?

Section 26 of the Nuclear Safety and Control Act (NSCA) prohibits any person from conducting certain activities except in accordance with a licence.

Additionally, in accordance with the NSCA and the regulations made under the NSCA, applicants and licensees are required to make adequate provision for the safe decommissioning of existing or proposed new nuclear facilities by ensuring that sufficient financial resources or financial guarantees are available to fund all approved decommissioning activities should the licensee not be able to fulfill its obligations. Financial guarantees are a tangible commitment by a licence applicant or a licensee that there will be sufficient resources to safely terminate licensed activities. Operationally, the Commission may also require that financial resources be available for termination of licensed activities other than for decommissioning of nuclear facilities. For more information, please refer to Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-3.3.1, Financial Guarantees for Decommissioning of Nuclear Facilities and Termination of Licensed Activities.

If a licensee is unable or unwilling to apply for a further licence, the Commission has the authority to invoke a financial guarantee in such a manner it considers appropriate, including to terminate licensed activities and decommission the facility.

18637

Canada

United Kingdom

11

Article 20

Figure E.12

Figure E.12 shows the Government departments and agencies responsible for the management of radioactive waste in Canada. The figure appears to show the same ministerial reporting chain for the regulator and those responsible for developing and implementing policy for the final disposition of waste.

  1. How does Canada demonstrate effective independence of the regulatory functions from other functions where organisations are involved in both spent fuel and radioactive waste management?

Section E.3.2 of Canada’s 7th National Report discusses the independence of the Canadian Nuclear Safety Commission (CNSC).

The CNSC is independent of government and reports to the Parliament of Canada through a Minister, designated by the Governor in Council. Currently, this designate is the Minister of Natural Resources. Its enabling legislation is clear, we report to Parliament through a Minister, not to a Minister. The CNSC makes independent, fair, and unbiased decisions to regulate the nuclear industry.

The Commission itself is a quasi-judicial body. Commission decisions are reviewable only by the Federal Court. This is the way that the rationale for any Commission decision may be scrutinized for its reasonableness and for the fairness of the Commission’s process. Decisions are science-based and risk-informed, and consider all the evidence presented during open and inclusive public hearings. No licence will ever be issued unless the Commission is fully satisfied a project or activity will be carried out safely.

The Commission is accountable in the following ways:

  • accountability to Parliament: the Commission submits to Parliament its annual report as well as its Report on Plans and Priorities and a Departmental Performance Report. The President of the CNSC, as the head of the Commission, appears before parliamentary committees to elaborate on matters related to the administration of the regulatory regime
  • legal accountability: regulatory decisions by the Commission can be reviewed only be the Federal Court. As a federal agency, the CNSC is subject to various laws (e.g., the Canadian Charter of Rights and Freedoms, the Official Languages Act, the Privacy Act, the Access to Information Act and the Financial Administration Act)

The CNSC is an independent agency of the federal government. The Governor in Council (Cabinet) does have the authority, pursuant to section 19 of the Nuclear Safety and Control Act, to issue directives of general application on broad policy matters related to the CNSC’s mandate. Therefore, meeting the requirements of the CNSC’s mandate is the exclusive responsibility of the CNSC and not subject to direction from the Minister of Natural Resources.

18638

Canada

United Kingdom

12

Article 20

E.3.1.5

E3.1.5 states that the CNSC has established a plan to protect critical capabilities in which it identified critical roles and resource vulnerabilities, produced a catalogue of nuclear safety-related capabilities, and developed resourcing plans to address risks, including identifying successors.

  1. What is the status of this plan and has it been implemented?
  2. Does it include positions/roles to support Canada’s obligations under the Joint Convention (in terms of Article 20 Clause 1)?
  3. How many positions/roles are required to support these obligations and how many are currently filled?

The Canadian Nuclear Safety Commission (CNSC) has an evergreen human resources strategy grounded in workforce analytics. Directorates are responsible for their individual workforce plans to protect critical capability. Human resources staff provide workforce data on a quarterly basis to senior management to help inform financial and human resourcing plans. In addition, recognizing that there are major changes to the nuclear industry on the horizon that will likely have an impact on how the CNSC operates, an external consulting firm has been contracted to produce a strategic workforce plan for the organization. 

The CNSC has a delegation of authority for executives to enable them to fulfill their assigned financial and human resources responsibilities. The HR strategy includes workforce and succession planning for the roles stated in Article 20, Clause 1 of the Joint Convention.

18639

Canada

United Kingdom

13

Article 24

F.4.2

The Canadian national report Section F.4.2 states that Section 14 of the Radiation Protection Regulations requires that dose limits are not exceeded and quotes 150 mSv in a one-year dosimetry period for the lens of the eye.

GSR Part 3, Schedule III, specifies dose limits to the extremities, or skin, and to the lens of the eyes. GSR Part 3, has revised the dose limit from 150 mSv for the lens of the eye to 20 mSv per year (averaged to 100 mSv per 5 years). This change is based on the publication of ICRP 118.

  1. Is Canada going to adopt this latest standard?
  2. If so, please can you explain the timescales?
  3. If not, please can you explain the rationale for this decision?

On April 21, 2011, the International Commission on Radiological Protection (ICRP) issued a formal statement indicating that reactions for the lens of the eye have dose thresholds that are, or might be, lower than previously considered. This statement indicated the threshold for absorbed dose was now considered to be 0.5 gray (which is equivalent to 0.5 Sv for beta and photon radiation). For occupational exposure in planned situations, the ICRP therefore recommended an equivalent dose limit for the lens of the eye of 20 mSv in a year, averaged over defined 5-year periods (i.e., 100 mSv/5 years), with no single year exceeding 50 mSv. The International Atomic Energy Agency (IAEA) also incorporated these ICRP recommendations into Schedule III of the revised GSR Part 3, Schedule 3.

Following extensive stakeholder consultation and benchmarking, the Canadian Nuclear Safety Commission’s (CNSC) Radiation Protection Regulations were amended in November 2020 (with transitional provisions coming into effect on January 1, 2021). The revised regulations reflect updates based on operational experience and were informed by international guidance including ICRP 103, ICRP 118 and the IAEA’s GSR Part 3. 

During the prepublication and consultation phase of the regulation amendment process, the CNSC proposed 2 changes to the equivalent dose limit for the lens of an eye. The first change was to lower the current equivalent dose limit for the lens of an eye for a nuclear energy worker (NEW) from 150 mSv in a year to 50 mSv in a 1-year dosimetry period. The second was to introduce a new equivalent dose limit for a NEW for the lens of an eye of 100 mSv in a 5-year dosimetry period. Stakeholders provided extensive feedback on these proposed amendments, including their general agreement with the proposed dose limit for a 1-year dosimetry period. However, stakeholders had concerns about the science that underpins the ICRP recommendation for a 5-year dose limit and cited implementation challenges, including concerns about the current lack of a licensed dosimeter for measuring this dose in Canada. They also expressed significant concerns about the costs of implementing and managing exposures to the lens of an eye below the average dose of 20 mSv per year, especially in high-hazard work in nuclear power plant refurbishments. Some stakeholders indicated that in certain situations, a 5-year limit could restrict worker employment. Based on an analysis of all available information, the CNSC decided not to move forward with the proposed 5-year dose limit for the lens of an eye. The equivalent dose limit for the lens of an eye for a NEW was lowered from 150 mSv per 1-year dosimetry period to 50 mSv in a 1-year dosimetry period.

The CNSC has developed additional guidance in regulatory documents REGDOC-2.7.1, Radiation Protection, and REGDOC-2.7.2, Dosimetry, Volume I: Ascertaining Occupational Dose, to clarify its expectations. The revised lens of eye dose limit enhances worker protection and addresses stakeholder concerns regarding impacts on worker employment, and it will give industry and academia time to further research the science that supports the ICRP’s recommendations. In addition, it will allow time for licensed dosimetry to be developed in Canada and for practical implementation challenges to be addressed. Licensees are still expected to have measures in place in their radiation protection programs to manage cumulative doses to the lens of an eye. Additional guidance clarifying the CNSC’s expectations on this topic has been added to REGDOC-2.7.1. Future amendments to the dose limit for the lens of an eye, including the adoption of a 5-year dose limit, will be considered during the next review of the Radiation Protection Regulations.

18640

Canada

United Kingdom

14

Article 2

K.3.2.2

Section K.3.2.2. refers to the Gentilly-2 Nuclear Generating Station and the Storage-with-Surveillance (SWS) activities. This section provides the organisational numbers for the SWS phase of the life cycle.

  1. Has this facility been designated as a radioactive waste management facility in accordance with Article 2?
  2. Please can you explain how the organisational requirements have been determined and what the roles are?

The Gentilly-2 Nuclear Generating Station is not designated as a radioactive waste management facility and has a power reactor decommissioning licence.

In accordance with its decommissioning plan, Hydro-Québec adapted its organization according to its need (regulatory requirements, progress of work, etc.). The current organization includes staff from operation, maintenance, radiation protection, environment, laboratory technicians and project engineers. The organization is adapted according to the activities and the regulatory requirements to be met. Hydro-Québec has also utilized contractors for specific activities.

18852

Canada

Korea, Republic of

15

Article 25

F.5, 121~125

The report does not describe the emergency planning zones. Is the concept of emergency planning zones, such as precautionary action zone (PAZ) and urgent protective action planning zone (UPZ), applied to radioactive waste management facilities?

Emergency planning zones are mainly applied to nuclear power plants. For waste management facilities, a safety report is completed to determine credible accidents and the resulting dose consequences to the public. Based on these safety reports, there are no emergency situations that would result in a release to the public that would require the need for emergency planning zones for Canada’s waste management facilities.

18853

Canada

Korea, Republic of

16

Article 26.1

F.6.1, 126

In accordance with CNSC regulatory guide G-219 the decommissioning plans are required to be kept up to date throughout the lifecycle of a licensed activity.

  • Preliminary decommissioning plan (PDP) is updated every 5 years. Is there a regulation on the revision of detailed decommisioning plan (DDP)? Is DDP periodically renewed?
  • Do you have special considerations given to the heavy water reactors for decommissioning planning and implementation?

Canadian Nuclear Safety Commission (CNSC) guidance document G-219, Decommissioning Planning for Licensed Activities, was superseded by CNSC regulatory document REGDOC-2.11.2, Decommissioning, in January 2021. REGDOC-2.11.2 provides requirements and guidance regarding the planning and preparation for, as well as the execution and completion of, decommissioning. This regulatory document is complemented by the requirements and guidance in CSA standard N294, Decommissioning of facilities containing nuclear substances. Together, this regulatory document and CSA N294 provide requirements and guidance for decommissioning.

Section 7.1 of REGDOC-2.11.2 states: where decommissioning takes longer than 5 years, the detailed decommissioning plan shall be reviewed and, as necessary, updated every 5 years or as requested by the CNSC. The DDP should be reviewed and updated in light of incidents or events with relevant consequences for decommissioning, revised regulatory requirements, operational experience, lessons learned, and advances in decommissioning technology.

18854

Canada

Korea, Republic of

17

Article 9.3

G.6.1, 138

It is stated that the dry storage system for spent nuclear fuels is periodically inspected to prevent degradation. Is there a procedure to retrieve spent fuels in storage if unexpected aging and degradation is found in inspection and testing?

All Canadian Nuclear Safety Commission-licensed facilities that have dry storage technologies for spent fuel have specific licence conditions that require the implementation and maintenance of aging management programs.

Dry fuel storage containers at Ontario Power Generation facilities are loaded underwater in an irradiated fuel bay, vacuum dried, and then welded closed. The reverse sequence of steps would be followed to unload the flasks if required. Annual monitoring is conducted, and at this time, the integrity of the flasks continues to be excellent. If or when a need for detailed procedures was identified, they would be developed in accordance with the current governance.

Canadian Nuclear Laboratories has maintained existing capabilities and developed new capabilities to perform retrievals of spent nuclear fuels in storage. At this time, there has not been a realized need to deploy these capabilities at any sites across Canada.

At Gentilly-2, the first option is to remove the baskets containing the spent nuclear fuel bundles from each of the failed cylinders and return the baskets to the storage pool. When the storage pool will be drained and no longer accessible, the second option is to transfer the baskets to 1 of the 3 contingency cylinders that are empty. A final option would be to build smaller silos for spent nuclear fuel for quick use. The safety report already includes the possibilities of failure of the dry storage enclosures as well as the actions that would be taken in such a case. The aging management program includes quarterly inspections of all waste management facilities. Hydro-Québec periodically (biannually for the first 2 years of dry storage and annually thereafter) assess the interstitial air in each of the cylinders that contains the spent fuel baskets. In the event of a simultaneous failure of the first 2 barriers, Hydro-Québec would detect radioactivity in the air sampled. All results shows that the integrity is maintained.

18855

Canada

Korea, Republic of

18

General

K.3.1, 190

It is stated that the government should enhance the existing policy and establish the associated strategy based on IAEA IRRS review.

  • Please describe the main points of policies and strategies to be strengthened in detail, and the review plan and implementation measures of the Canadian regulatory body.

Modernizing Canada’s Radioactive Waste Policy

Natural Resources Canada (NRCan) is the federal department responsible for Canada’s radioactive waste policy. The Government of Canada is committed to continuous improvement with respect to ensuring that safe solutions are in place for managing radioactive waste for generations to come.

On November 16, 2020, the Minister of NRCan launched a process to review and modernize Canada’s policy for radioactive waste and decommissioning to ensure it has a strong radioactive waste policy in place that continues to meet international standards based on the best available science, and that reflects the values and principles of Canadians. This commitment addresses expectations from Canadians and international recommendations from the Integrated Regulatory Review Service review, further ensuring that Canadians can have confidence in the long-term management for all of Canada’s radioactive wastes. NRCan is leading the process in close collaboration from other federal departments and agencies with responsibilities for radioactive waste, including Environment and Climate Change Canada, Health Canada, and Global Affairs Canada.

From November 2020 to May 2021, NRCan engaged with Indigenous peoples, the public, stakeholders, experts, and any other interested parties to see how they would like to participate and what they would like to see in a modernized radioactive waste policy. 150 meetings and engagement sessions were held, and more than 600 written submissions were received. The views, perspectives and written feedback are publicly available in a What We Heard Report and 2 engagement summaries, at rncanengagenrcan.ca/en/content/what-we-heard.

On February 1, 2022, Canada released a draft Policy for Radioactive Waste Management and Decommissioning for a 60-day public comment period until April 2, 2022. The release of a final modernized policy is anticipated in 2022. The modernized policy will define the framework and overall direction for how radioactive waste management and decommissioning will be carried out in Canada.

Once NRCan has published the Policy on Radioactive Waste Management and Decommissioning, the Canadian Nuclear Safety Commission (CNSC) will conduct a full review of the regulatory framework for waste management and decommissioning to ensure that it is aligned with the policy. If any inconsistencies between the regulatory framework and the policy are found, then the CNSC will act to align the framework with the policy.

Development of an Integrated Strategy for Radioactive Waste

In Canada, waste producers and owners are responsible to develop plans for the safe management of their wastes, including over the long-term. While an integrated strategy must be defined by waste producers and owners who have the best knowledge of their waste and priorities, it should also be informed by dialogue with interested Canadians. The Minister of Natural Resources Canada asked the Nuclear Waste Management Organization (NWMO) to lead a dialogue with Canadians and Indigenous peoples to develop Canada’s integrated strategy for all of Canada’s radioactive wastes. The integrated strategy should include:

  • a description of the current waste management situation in Canada in terms of current and future volumes, taking into account potential small modular reactor waste, characteristics, locations, and ownership of the waste
  • an update on current plans and progress in advancing long-term management and disposal solutions for Canada’s wastes as well as the gaps that must be addressed
  • conceptual approaches for dealing with current and future radioactive waste inventory, including technical options for long-term management or disposal of the various waste types and options for the number of long-term waste management facilities in Canada
  • considerations regarding the staging, integration, establishment and operation of long-term waste management facilities

The NWMO commenced this work on March 30, 2021. The integrated strategy is still under development, and will be submitted to the Minister of Natural Resources Canada for consideration after the policy modernization is complete.

18856

Canada

Korea, Republic of

19

Article 26

Annex 8.1, 290

Chalk River Laboratories has planned to decommission the NRX reactor to an end-state agreed with the CNSC.

  • Please describe the end-state of the NRX reactor agreed with the CNSC?

The decommissioning strategy for NRX separates activities into 2 distinct stages of work:

  • Stage 1: Scoping and characterization, interior demolition of reactor supporting systems and equipment
  • Stage 2: Final decommissioning of the reactor block, storage blocks and building structures

Stage 1 activities have been approved by the Canadian Nuclear Safety Commission through a detailed decommissioning plan (DDP) and work is progressing according to plan. A second DDP for Stage 2 will propose the final end state for the NRX, based on information collected during Stage 1 with consideration of health, safety, security and environmental factors, strategic planning and experience from other Canadian and international research reactor decommissioning projects.

In the preliminary decommissioning plan, the final end state of the NRX reactor was stated as the complete removal of the NRX reactor structure, all process equipment and associated vessels, tanks, piping, services, control systems, Building 100 and concrete footings. The reference final end-state was that the site of the former NRX reactor and Building 100 would be consistent with its location in controlled area 2 at Chalk River Laboratories.

18857

Canada

Korea, Republic of

20

Article 26

Annex 8.2, 292

Regarding Douglas Point Waste Management Facility, CNL plans to hold a hearing scheduled in 2020 to commence Phase 3 of decommissioning.

  • Are there rules governing the progress of the hearing?
  • What is the process of the hearing?
  • Who will participate in the hearing?

The rules governing the progress of a hearing are documented in the Canadian Nuclear Safety Commission Rules of Procedure (laws.justice.gc.ca/PDF/SOR-2000-211.pdf).

The 2020 hearing related to the Douglas Point Waste Facility was conducted as a 1-part public hearing. For a 1-part hearing, all of the evidence pertaining to the making of licensing decisions is heard from the applicant, Canadian Nuclear Safety Commission (CNSC) staff and intervenors by the Commission in a single hearing session.

To allow potential intervenors to review the proposal and prepare for the hearing, written submissions from the applicant and CNSC staff must be filed at least 60 days prior to the hearing day. Intervenors are then invited to register their submissions at least 30 days prior to the hearing. Participants may file supplementary information up to 7 days prior to the hearing day.

During a public hearing, simultaneous interpretation in one or the other of Canada’s official languages is provided when necessary. Verbatim transcripts are produced and published on the CNSC’s website following each hearing day. The Commission’s decision and its reasons for decision are published after the conclusion of the hearing. As a result of the 2020 hearing for the Douglas Point Waste Facility, the Commission approved the request. The associated record of decision can be found at the following link: nuclearsafety.gc.ca/eng/the-commission/pdf/Decision-CNL-DPWM-20-H4-e.pdf.

At the Commission hearing, the participants include CNSC staff, the proponent, and intervenors. The list of intervenors for the Douglas Point Waste Facility hearing in 2020 included Indigenous communities, individual citizens, citizen and advocacy groups, unions and associations, municipalities and townships, and other CNSC licensees.

18858

Canada

Korea, Republic of

21

Article 22

F.2.2.1

It is stated that the Port Hope Area Initiative (PHAI) was initiated in 2001 to treat historical waste.

  • What kinds of waste is historical waste and how is it treated and managed?

The historic low-level radioactive waste is primarily soil contaminated with residue from the radium and uranium refining activities of Eldorado Nuclear, a former Crown corporation that operated between the 1930s and 1980s. The historic waste also contains a small volume of contaminated building material from Eldorado facilities. The Port Hope Area Initiative (PHAI) is being carried out as 2 projects: the Port Granby project and the Port Hope project.

In Port Granby, historic low-level radioactive waste has been excavated from a former waste management site on the shore of Lake Ontario and transported to a new long-term waste management facility 700 m away from the lake, where it is being safely managed in an engineered aboveground storage mound that was capped and closed in 2021.

The Port Hope project involves wastes from various sites in Port Hope being excavated and transported to a new long-term waste management facility in that community for placement in an engineered above-ground mound.  

18859

Canada

Korea, Republic of

22

Article 23

F.3.2

Related to the Quality Management System (QMS),

  • What does the personnel of CNSC do to improve the QMS except for comparing requirements?
  • Do you have a checklist to review and assess the QMS?

Canadian Nuclear Safety Commission (CNSC) staff assess licensee documentation against the regulatory requirements set out in CSA standard N286-12, Management system requirements for nuclear facilities, and/or other applicable regulatory documents or standards. The checklist is a table with the applicable regulatory requirements, completed with the information provided by the licensee to address those requirements. In general, the tier 1 (management system manual) and tier 2 (programs) documents are reviewed. Based on the risk approach process and complexity of the licensee’s documentation, CNSC staff may review tier 3 documents to assess how those tier 3 documents demonstrate the requirements specified in the programs.

CNSC staff also have promotional meetings with licensees, especially when a new standard or major change is in effect. If a new regulatory document or standard is published, the first step taken by the CNSC is to request licensees to submit a gap analysis and an implementation plan to staff for review and acceptance. 

During compliance activities such as inspections, CNSC staff identify corrective actions and also raise recommendations to improve licensee management systems. The recommendations are based on industry good practice or CNSC staff operating experience. Corrective actions are steps that the licensee must take to address instances of non-compliance with the management system program requirements. These corrective actions are tracked to completion by the CNSC.

18860

Canada

Korea, Republic of

23

Article 4.1

G.1.1

G.1.1 describes criticality safety, but it does not specify residual heat removal and relevant regulations. Where is the information on residual heat removal specified, and what are the details?

All Canadian Nuclear Safety Commission (CNSC)-licensed facilities that have wet or dry storage technologies for spent fuel have specific licence conditions that require the implementation and maintenance of safety analysis programs.

The CNSC regulatory framework is looked at holistically, as such, some requirements may be found in other safety and control area regulatory documents. The licence conditions handbook is the tool that states the regulatory requirements (CNSC regulatory documents or standards) that a licensee must comply with.

As far as residual heat removal is concerned, CSA standards CSA N292.0, General principles for the management of radioactive waste and irradiated fuel, and N292.2, Interim dry storage of irradiated fuel, are listed as relevant sources of regulatory information.

18861

Canada

Korea, Republic of

24

Article 9

G.6.1

It is stated that the nuclear operators perform periodic tests, inspection and surveys to prevent aging of the structures, components and systems for dry storage of spent nuclear fuels.

  • Does this include spent nuclear fuel itself?

Regulatory requirements for inspection, monitoring, testing, and maintenance are set out in Canadian Nuclear Safety Commission regulatory document REGDOC-2.11.1, Waste Management, Volume I: Management of Radioactive Waste, and the following CSA standards: N292.0, General principles for the management of radioactive waste and irradiated fuel; N292.1, Wet storage of irradiated fuel and other radioactive materials; and N292.2, Interim dry storage of irradiated fuel.

Ontario Power Generation dry fuel storage casks are filled with helium as the final stage of processing. Additionally, periodic monitoring of the dry fuel storage flasks is performed to monitor aging and to confirm the integrity of the storage containers. These actions maintain optimal conditions for long-term storage of spent nuclear fuel, minimizing the potential of accelerated aging.

Canadian Nuclear Laboratories (CNL), on behalf of Atomic Energy of Canada Limited, implements a comprehensive monitoring and inspection program for dry storage systems used for spent nuclear fuels. The inspections have been centered on monitoring the storage structures (physical), monitoring the storage-waste package annulus (physical and chemical), and in situ visual inspections using a CNL-developed inspection tool/system. To date, there has not been evidence of package degradation that warranted further inspection of the spent nuclear fuel itself. It is noted, however, that CNL plans to perform physical inspections of the spent nuclear fuel to assess the impact of 50 years of dry storage in support of a commercial agreement between agencies in Canada and Korea.

Hydro-Québec periodically (biannually for the first 2 years of dry storage and annually thereafter) assesses the interstitial air in each of the cylinders that contains the spent fuel baskets. The dry storage method favored by Hydro-Québec (CANSTOR structures) offers 3 different safety barriers: the first is the sheath of the fuel bundles; the second is the welded basket, which contains 60 bundles each; and the third is the cylinder, which contains 10 baskets each. In the event of a simultaneous failure of the first 2 barriers, Hydro-Québec would detect radioactivity in the air sampled. The absence of radioactivity in the interstitial air of the cylinders is an indicator of the integrity of the bundles in dry storage.

For New Brunswick Power, the periodic tests, inspections and surveys do not include the actual spent fuel itself, only the structures that store the spent fuel.

18862

Canada

Korea, Republic of

25

Article 11

H.1

Regarding radioactive waste management,

  • Are incineration or pyrolysis used to minimize the volume of radioactive waste generated? If so, what law and technical standards are applied?
  • How do you dispose of radioactive waste containing cellulose (cottons, papers, woods, etc.)?

Ontario Power Generation uses incineration to reduce the volume of low-level radioactive wastes at the Western Waste Management Facility. This includes materials containing cellulose. This process was subject to a screening level environmental assessment under the Canadian Environmental Assessment Act (CEAA) and was subsequently licensed to operate by the Canadian Nuclear Safety Commission (CNSC). The incinerator operates in compliance with required provincial environmental laws, such as the Ontario Environmental Protection Act. Technical Safety and Standards Authority approval is required to operate the pressurized propane system and to confirm yearly validation of safety shutdowns. Technical standards are applied as per the CNSC licence requirements.

Canadian Nuclear Laboratories (CNL) does not currently utilize incineration or pyrolysis approaches at the CNL-operated sites. CNL has made use of third-party, offsite commercial facilities for thermal treatments of wastes. Thermal treatment will continue to be used while aligned to CNL’s integrated waste strategy. It is envisioned that at the proposed Near Surface Disposal Facility, materials from the cellulose waste stream could be emplaced directly into the mound, assuming that the facility Waste Acceptance Criteria have been met.

There is no incineration or pyrolysis at the Gentilly-2 site.

New Brunswick Power uses incineration as a volume reduction process for radioactive wastes through third-party, offsite commercial facilities. All requirements including Waste Acceptance Criteria, transportation of dangerous goods and licensing requirements are defined and controlled by the vendor/shipper. Radioactive wastes containing cottons, papers, and woods are processed and stored in New Brunswick Power’s onsite Solid Radioactive Waste Management Facility.            

Incineration is used to reduce the volume of radioactive waste generated from Cameco’s fuel cycle facilities. Contaminated combustible material (including cellulose materials such as cottons, paper and wood) is consolidated and incinerated at a central location. This process was subject to a screening-level environmental assessment under CEAA and was subsequently licensed to operate by the CNSC. Ongoing operations are also subject to an Environmental Compliance Approval from the Province of Ontario under the Ontario Environmental Protection Act. Emission limits are placed upon particulate matter, cadmium, lead, mercury, dioxins and furans, hydrochloric acid, sulphur dioxide, nitrogen oxides and uranium. The ash from the incinerator will ultimately be sent to a uranium mill for uranium recovery within the nuclear fuel cycle.

There are currently no facilities, locations or sites in Canada that are licensed for the disposal of radioactive wastes.

18863

Canada

Korea, Republic of

26

Article 17

B.1.4.3.2.4, 41

It is stated that effluent discharge from uranium mines and mills located near lakes is controlled by regulatory-approved codes of practice and by effluent quality regulation.

  • Is radiation/activity being monitored (activity concentration measurement, etc.) on the environment (lakes, etc.) located near the facilities performed?

As per Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures, licensees that have direct discharges to the environment are required by the CNSC to perform environmental monitoring. The environmental monitoring program must be designed in accordance with CSA standard N288.4, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills

Activity of radionuclides (generally Ra-226, Th-230, Po-210, and Pb-210) are routinely measured in: treated water discharged to the environment; surface water, sediment, and biota (fish) in the receiving environment; groundwater; and in soil and vegetation located on and surrounding the facility boundary. Radionuclide concentration in the air (collected as total suspended particulate) and radon are also measured.

18864

Canada

Korea, Republic of

27

General

K.2.4.4

How much public acceptance has been raised through Nuclear Waste Management Organization (NWMO)’s social involvement with local communities? Has it achieved tangible results?

Collaboration with both experts and the public is key to the design of Canada’s plan for the long-term management of used nuclear fuel, and is at the heart of the Nuclear Waste Management Organization’s (NWMO) implementation plan. The NWMO has involved and will continue to involve people throughout the process in the implementation of the plan by:

  • soliciting input from the public and specialists during the design of the site selection process
  • carrying out a community-driven site selection process that involves interested host communities in decision-making at every step, including the planning and implementation of technical and social assessments and work
  • collaboratively engaging in dialogue with the interested community, First Nation and Métis communities, and surrounding municipalities about potential sites and the implementation of the project
  • responding to the views, questions and concerns of others who are most likely to be affected by the implementation of the project, including those potentially affected by the transportation of used nuclear fuel

At the local level, the site selection process is community-driven and collaborative. It is designed to ensure, above all, that the selected site is safe, secure, and has informed and willing hosts. The safety and appropriateness of potential sites will be evaluated through a series of progressively more detailed scientific, technical and social assessments.

The NWMO has always said the decision about willingness to host the project is in the hands of communities themselves. It’s up to the community to decide the best way to define their willingness, whether or not they are willing, and how they will express that willingness. 

After gradually narrowing focus from 22 communities to 2, the NWMO is on track to select a single, preferred site for a deep geological repository in 2023. The project will only proceed with interested communities, First Nation and Métis communities, and surrounding municipalities, working together to implement it.

Public input and review doesn’t end with site selection – before the project can proceed, it will be subject to be a full, open and transparent Impact Assessment process, and anyone who is interested or potentially affected will be able to participate. Ultimately, the project will only proceed after the regulator confirms it will be safe.

19397

Canada

Slovenia

28

Article 23

F

Does the CNSC approve the licensee management system manual and programs? What does this approval include?

For a new licence application, Canadian Nuclear Safety Commission (CNSC) staff review proponent’s programs and licensing basis documentation, such as the management system program, and verify that they meet CSA standard N286-12, Management system requirements for nuclear facilities, and/or other applicable standards or regulatory documents that contain elements of management system. CNSC staff communicate their comments to the licensee, and formally inform the licensee if the documentation is acceptable and compliant with the regulatory requirements. Changes to the management system programs listed in a licence or licence conditions handbook are also reviewed by CNSC staff.

The implementation and maintenance of a licensee’s management system program is assessed during CNSC compliance activities (e.g., inspections, desktop reviews).

19781

Canada

Sweden

29

Article 19.1

K.2.1, p.166

It is reported in K.2.1 that CNSC staff are currently in process to completing updated regulatory documents, e.g. REGDOC-2.11.1 Volume I and Volume III. It is understood that this update was triggered by the discussion paper from 2016, DIS-16-03. To what extent - if any - has this update of the regulator documents taken outcomes from the IRRS mission in 2019?

The suite of waste management regulatory documents is discussed in section K.2.1 of Canada’s 7th National Report.

As part of its ongoing modernization of the regulatory framework, the Canadian Nuclear Safety Commission (CNSC) started engagement with stakeholders on developing waste management and decommissioning regulatory documents in 2016. An initial discussion paper was published in 2016 (DIS-16-03, Radioactive Waste Management and Decommissioning), followed by a What We Heard Report in 2017. Public consultation followed from 2018–20, which included workshops with industry, interested members of the public, Indigenous nations and communities, and civil society organizations.

Prior to the start of the Integrated Regulatory Review Service (IRRS) Mission to Canada in the fall of 2019, all drafted regulatory documents were out for public consultation (some had even returned from public consultation). The IRRS team observed that the CNSC is updating the waste and decommissioning regulatory documents, and noted that the finalized versions of the regulatory documents should be in line with International Atomic Energy Agency safety standards once finalized. The IRRS team suggested that the CNSC consider clarifying in REGDOC-2.11.2, Decommissioning, that in situ decommissioning is not considered an acceptable strategy for the planned decommissioning of existing nuclear power plants and future nuclear facilities.

The CNSC subsequently revised the regulatory document to stipulate that in situ decommissioning is not considered a reasonable option for the planned decommissioning of existing nuclear power plants, or for future nuclear facilities and situations where removal is possible and practicable, and published the regulatory document.

19782

Canada

Sweden

30

Article 6.1.4

Executive Summary, p.3 and K.2.5, p.188

It is reported that in January 2020, the Saugeen Ojibway Nation voted to not support the deep geologic repository proposed by Ontario Power Generation (OPG) for its low- and intermediate-level wastes and that OPG has withdrawn its application. What was the main reason for the Saugeen Ojibway Nation not to support the project? Could Canada pleas share lessons learned from his experience?

Indigenous engagement:

In the Canadian context, it is important to engage as early and as extensively as possible with Indigenous communities – at the community level – in the siting of a nuclear-waste disposal project, before the project is formally submitted to regulators for approval. In 2021, Canada enacted legislation called the United Nations Declaration on the Rights of Indigenous Peoples Act, providing a roadmap for the federal government and Indigenous peoples to work together to implement that declaration, known as UNDRIP. A key principle of UNDRIP is free, prior and informed consent on projects that affect them or their lands.

In the case of the Ontario Power Generation (OPG) Deep Geologic Repository (DGR), engagement with Saugeen Ojibway Nation (SON) did begin in 2004, before OPG submitted the project to the Canadian Nuclear Safety Commission (CNSC) in 2005. However, the only written agreement to host the project, prior to formal project launch, was with the municipality, Kincardine. OPG’s engagement with SON continued for 15 years after project launch, through to their community vote on the project in January 2020, with important milestones along the way: a protocol agreement between OPG and SON in 2004 on communications, a 2009 OPG–SON agreement on capacity funding, a 2013 OPG letter of commitment to SON not to proceed to construction without SON support, and a 2019 OPG–SON interim agreement to identify and resolve legacy issues related to the historic development of the Bruce nuclear site. SON also participated in the 2013–14 public hearings on the project’s environmental assessment, and SON developed its own direct relationship with the CNSC on the project.

OPG’s engagement with SON for the first 14 years was largely at the leadership level, between OPG’s DGR project team and SON’s Advisory Committee, consisting of SON’s appointment of several elected band councillors and led by SON’s external counsel. OPG information sessions in SON communities for direct engagement with SON members did not begin until 2019, but did include 22 sessions over a year that reached hundreds of individuals. In hindsight, however, it would have been preferable to engage more directly with individual community members earlier in the process. Nevertheless, the engagement that did occur was authentic, involved extensive listening to concerns and questions, and helped OPG to develop its offer to govern the project jointly with SON, while providing direct economic benefits to the community.

It is important to note that, following SON’s vote not to support the project, OPG respected the 2013 commitment it made to SON, and cancelled the project in 2020, helping to maintain a relationship of mutual respect and trust that continues today. Furthermore, in 2021, OPG launched its first-ever Reconciliation Action Plan, to continue on the path of reconciliation with Indigenous peoples in all the communities where OPG operates.

Support before site selection:

Any process launched by OPG in the future to site a waste disposal facility would first engage with members of the public, interested municipalities and Indigenous communities. The goal would be to obtain local support before selecting a project site. This is in contrast to a “decide-and-defend” process of first selecting a site on technical feasibility criteria, and then seeking to build the necessary local support. The process to first seek local support is modelled on best practices seen elsewhere, such as in the Nuclear Waste Management Organization (NWMO) to site a deep geological repository (DGR) for used fuel for all of Canada. In its process called Adaptive Phased Management, the NWMO began in 2010 with a call to interested communities to learn more about the proposed DGR, and 22 responded. NWMO has since narrowed the list to 2 communities, where it has engaged extensively for more than a decade, aiming for final site selection by the end of 2023, after which it would formally launch a project with a willing host community and local Indigenous support, with the goal of a facility in service by 2043–45.

19783

Canada

Sweden

31

Article 3.1

C.1.2, p.38

It is reported that AECL conducted early reprocessing experiments at CRL from the 1940s to the 1960s, that CNL stores liquid waste from the reprocessing experiments in three tanks, and that the last transfer of radioactive liquid solutions occurred in 1968. It is also reported that experiments were carried out between 1958 and 1960 to convert high-level radioactive liquid solutions into a solid (glass). Did those experiments include all of the radioactive liquid waste in the storage tanks, or are there still radioactive liquid waste to be managede? If so, what are the future plans to manage this liquid waste?

Only a small volume of the waste (approximately 1,300 curies in <0.1 m3) was converted to glass for experimental purposes. Canadian Nuclear Laboratories continues to manage a number of tanks that contain legacy liquid wastes. Plans are currently in place to recover/retrieve, process, stabilize, and/or immobilize these legacy wastes so that they may be suitable for a future disposal facility. These materials are part of the overall Chalk River Laboratories integrated waste strategy and reduction of liabilities to maintain or improve upon the safety of the public, workers, and the environment.

19784

Canada

Sweden

32

Article 19.2.2

E.2.3.5.2, p.76

Table E.1 provides an account for timelines for regulatory review of license applications for Class IB nuclear facilities. It is reported that a regulatory review is initiated once the Commission has determined that the applicant has submitted sufficient information to begin the review. What guidance or criteria are there for CNSC to judge when “sufficient information” has been submitted?

The Canadian Nuclear Safety Commission (CNSC) initiates the licensing process once it receives a licence application from an applicant. CNSC staff conduct a sufficiency check to determine whether the application contains the information that is required to be submitted to conduct a full technical assessment under the CNSC’s Safety and Control Area Framework (outlined in annex 3 of Canada’s National Report). The information required to be submitted in a licence application is dependent on the type of licence being applied for and can be found in regulations and licence application guides published by the CNSC. The sufficiency check confirms that the appropriate information was submitted for review in accordance with regulatory requirements, including supporting evidence, reference standards, and links, to be able to conduct a technical assessment against relevant regulatory and technical criteria under the licensing basis. As an example, a sufficiency check would confirm that a waste management program was submitted as part of a licence application, whereas a technical assessment would determine if the waste management program was in compliance with regulatory requirements.

A licensing application is subject to many layers of scrutiny before CNSC staff draft recommendations for the Commission’s (or a designated officer’s) consideration. An application will go before the Commission (or designated officer) for a decision only if it is complete and comprehensive, meets regulatory requirements, and CNSC staff have assessed the application and are prepared to provide a recommendation to the Commission (or designated officer).

19886

Canada

Russian Federation

33

Article 32

General

RW management methods applied in Canada are similar to those implemented in other countries. Since no RW disposal facilities are currently available in Canada, the main focus is placed on the minimization and reduction of RW volumes, conditioning, interim or long-term RW storage. Are there any plans to establish some national RW disposal facility? If so, when and where?

Canada has a plan for the safe, long-term management of used nuclear fuel. The Nuclear Waste Management Organization (NWMO) is a federally mandated organization tasked with designing and implementing this plan in a manner that protects people and the environment for generations to come. Canada’s plan calls for used nuclear fuel to be safely contained and isolated inside a deep geological repository – a system of natural and engineered barriers. The plan is based on years of public input, Indigenous knowledge, international scientific consensus, and best practices from around the world.

Canada’s plan will only proceed in an area with informed and willing hosts, where the municipality, First Nation and Métis communities, and others in the area are working together to implement it. The NWMO plans to select a site in 2023, and 2 areas remain in its site selection process: the Ignace area and South Bruce, both in Ontario. Information on the current status of the NWMO program is available in the organization’s annual report, available on its website.

Additionally, in the fall of 2020, the Minister of Natural Resources Canada tasked the NWMO with leading an engagement process with Canadians and Indigenous peoples to inform the development of an integrated long-term management strategy for all of Canada’s radioactive wastes. The intent of this work is to identify next steps to address gaps in Canada’s current radioactive waste management strategy, in particular for low- and intermediate-level radioactive wastes, and to look further into the future. The strategy and recommendations are expected to be submitted to the Minister of Natural Resources Canada by the end of 2022.

Canadian Nuclear Laboratories has proposed to construct and operate the Near Surface Disposal Facility at the Chalk River Laboratories site, a disposal facility for low-level radioactive waste (LLW). This facility is intended to provide disposal solutions for Atomic Energy of Canada Limited-owned LLW liabilities, recognizing an allowance of a small percentage of the total inventory for other generators such as universities and hospitals. 

19887

Canada

Russian Federation

34

Article 32

General

As for 2019, AECL and OPG acting as the waste owners (operating 20 out of 22 Candu reactors in Canada) are correspondingly responsible for some 90 – 95% of the annually accumulated low- and intermediate-level waste inventory. What approximate amount of waste has been accumulated to date and what is the forecasted amount of waste generation?

As stated in table D.6 of Canada’s 7th National Report, the volume of low-level radioactive wastes in Canada as of December 31, 2019, was 2,524,670 m3, and the volume of intermediate-level radioactive wastes in Canada as of December 31, 2019 was 15,681 m3. Canada’s National Reports to the Joint Convention do not contain waste projections. However, radioactive waste projections in Canada can be found in Natural Resource Canada’s Inventory of Radioactive Waste in Canada Reports, the most recent report is current to December 31, 2019 and can be accessed through the following link: nrcan.gc.ca/sites/nrcan/files/energy/pdf/uranium-nuclear/17-0467%2520Canada%2520Radioactive%2520Waste%2520Report_access_e.pdf

19888

Canada

Russian Federation

35

Article 32

General

INFCIRC/603/Rev7 presents the definition of a Good Practice stating the criteria of a significant contribution to the safety as its key provision. Please, indicate what criteria of significant contribution to the safety govern the decision-making on denoting some specific program, policy or practice as a Good Practice?

Canada recommends that this question be directed to the current President of the Joint Convention or the International Atomic Energy Agency.

19889

Canada

Russian Federation

36

Article 32

General

Promotion of progress in nuclear safety is seen as an objective of the Joint Convention. Based on which estimated safety indicators you conclude on the progress associated with the safety of storage facilities?

The objectives of the Joint Convention are as follows:

  1. to achieve and maintain a high level of safety worldwide in spent fuel and radioactive waste management, through the enhancement of national measures and international co-operation, including where appropriate, safety-related technical co-operation
  2. to ensure that during all stages of spent fuel and radioactive waste management there are effective defenses against potential hazards so that individuals, society and the environment are protected from harmful effects of ionizing radiation, now and in the future, in such a way that the needs and aspirations of the present generation are met without compromising the ability of future generations to meet their needs and aspirations
  3. to prevent accidents with radiological consequences and to mitigate their consequences should they occur during any stage of spent fuel or radioactive waste management

When making regulatory decisions about the management of radioactive waste, the CNSC considers the extent to which the owners of the waste have addressed the following 6 principles:

  • generation of radioactive waste is minimized to the extent practicable by the implementation of design measures, operating procedures and decommissioning practices
  • management of radioactive waste is commensurate with the waste’s radiological, chemical and biological hazard to the health and safety of persons, to the environment and to national security
  • assessment of future impacts of radioactive waste on the health and safety of persons and the environment encompasses the period of time during which the maximum impact is predicted to occur
  • predicted impacts on the health and safety of persons and the environment from the management of radioactive waste are no greater than the impacts that are permissible in Canada at the time of the regulatory decision
  • measures needed to prevent unreasonable risk to present and future generations from the hazards of radioactive waste are developed, funded and implemented as soon as reasonably practicable
  • trans-border effects on the health and safety of persons and the environment that could result from the management of radioactive waste in Canada are not greater than the effects experienced in Canada

The CNSC is committed to optimizing regulatory efforts, and to consulting and cooperating with provincial, national and international agencies to:

  • promote harmonized regulation and consistent national and international standards for the management of radioactive waste
  • achieve conformity with the measures of control and international obligations to which Canada has agreed concerning radioactive waste

19890

Canada

Russian Federation

37

Article 32

E.2.7.3, p. 92

The Report states that according to the contract signed with AECL, CNL is acting as a nuclear legacy management operator. Please indicate whether some long-term program has been developed to manage the legacy facilities? If so, does it specify relevant schedules? What are its goals and what indicators are planned to be achieved in a long-term perspective?

Canadian Nuclear Laboratories (CNL) sites are currently operated under the government-owned, contractor-operated model, with Atomic Energy of Canada Limited (AECL) serving as the government’s client representative. While the restructuring of AECL has seen the creation of CNL (enduring entity), which is now operated by a contractor, AECL retains ownership of the lands, assets and liabilities associated with CNL’s licences. A long-term program of scope, schedule, and funding has been established to manage all AECL-owned nuclear liabilities, including current and legacy facilities. As an example, AECL and the Government of Canada maintain a “liability cost estimate” to provide funding assurance for the lifecycle management of nuclear liabilities. Plans are developed on various time scales, including annual, 5-year, 10-year and lifecycle. The lifecycle planning runs to the year 2100. The long-term goals for CNL-operated sites are site-dependent, with recognition that land-use end-state targets are informed through engagements with government agencies, public stakeholders, and Indigenous communities.

19891

Canada

Russian Federation

38

Article 11

Section K

Section K.2.4.6 (p. 179-181) of the Report indicates that two types of bedrock are considered in Canada as potentially suitable for deep RW disposal facility siting – crystalline and sedimentary. Is it true that the considered disposal concept (the one shown in Figure K.6) is identical in both cases?

The Nuclear Waste Management Organization is exploring the potential to host a deep geological repository in the 2 areas remaining in the site selection process: the Ignace area, which is a crystalline rock formation, and South Bruce, which is a sedimentary rock formation.

The repository design uses a series of engineered and natural barriers that work together to contain and isolate used nuclear fuel from people and the environment. The actual underground footprint at any particular site would depend on a number of factors, including the characteristics of the rock, the location of underground features in the rock, the final design of the repository and the total inventory of used fuel to be managed. The engineered barrier concept is the same for both rock types, although some dimensions and specifications will be different. 

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Article 11

Section K

Could you please clarify what software is used to make simulations in safety assessments for deep geological repositories for SNF?

Several different software packages are used by the Nuclear Waste Management Organization (NWMO) for long-term safety assessment, with some software included as an alternative modelling approach to improve confidence in the results. The primary post-closure safety assessment system model by the NWMO is a custom linked software based on COMSOL, Hydrogeosphere and AMBER. The primary supporting software includes FRACMAN, TOUGH3, ORIGEN and MCNP.

The Canadian Nuclear Safety Commission (CNSC) conducts its own post-closure safety assessment modelling to independently verify that human health and the environment will be protected throughout the post-closure phase of the project. CNSC staff have developed several modelling tools to do so. This includes an internally developed system-level modeling software, DOC-WMF, which consists of a repository model, a geosphere model (based on Goldsim®) and a biosphere model for assessing dose to public. In addition, CNSC staff have been developing a more sophisticated safety assessment model (process-level modelling) using COMSOL Multiphysics® Finite Element Method software, for assessing the migration of contaminants from used nuclear fuel, through engineered barriers and the geosphere and into the surface environment.

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Article 32

Section K

It is stated in the NR that as part of its ongoing modernization of the regulatory framework, the CNSC is currently completing the development of Guidance on Deep Geological Repository Site Characterization (REGDOC‑1.2.1). Could you please outline the basic guidance of this document on characterization of site geology?

Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-1.2.1, Guidance on Deep Geological Repository Site Characterization, was published in January 2021 and is available on the CNSC’s public website.

This guidance document describes the elements of a site characterization program for a deep geological repository (DGR). It refers to the information that is used to: evaluate the suitability of a potential DGR site; inform the design of a DGR facility; and support the DGR safety case. This is necessary information for detecting potential environmental impacts at various stages – including the collection of baseline information before a DGR is constructed, as well as verification and monitoring data collected throughout a DGR facility’s lifecycle.

REGDOC-1.2.1 specifically describes the role of site characterization in the CNSC’s regulatory process, and provides specific guidance on the characterization of both the geological and surface environments. The geological environment includes the geological and hydrogeological setting, geochemistry, geological stability, and geomechanics. The surface environment includes climate, the aquatic and terrestrial environments, surface water hydrology, geomorphology, and geotechnical characteristics of surficial deposits. The document also includes guidance on the characterization of land use such as natural resource potential.

Guidance is also provided on data acquisition and verification, and the facilities for collecting this type of information – with an emphasis on ensuring the quality and consistency of site information.

The appendix to REGDOC-1.2.1 describes the role of site characterization in the siting process.

Further detail on DGR site evaluation and site characterization will be available in a new standard: CSA standard N292.7, Deep geological disposal of radioactive waste and irradiated fuel, which is expected to be published in the spring of 2022. This document will include both requirements and guidance.

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41

Article 32

Section

Could you please clarify what kinds of monitoring activities are provided for Douglas Point WMF and Gentilly-1, 2 which are currently under Phase 2 of Deferred Decommissioning – ‘Storage with Surveillance’ (SWS)?

Regulatory requirements for storage with surveillance are set out in Canadian Nuclear Safety Commission regulatory document REGDOC-2.11.2, Decommissioning, specifically in section 8.1, Storage with surveillance.

The Douglas Point and Gentilly-1 storage with surveillance (SWS) includes safety-related systems (SRS), which are subject to monitoring, surveillance, testing, evaluation, and maintenance activities. The frequency of these various activities are documented within their respective SWS plans. Monitoring activities include fire control system alarm checks, water sampling, radiation monitoring, and air monitoring. Surveillance activities include visual checks regarding general physical conditions and operating status of equipment. Testing includes inspection, maintenance, and certification, as necessary for identified SRS.

Monitoring at Gentilly-2 includes environmental monitoring (radiological and conventional) and an aging managing program of structures (building onsite, waste management facility). There is maintenance on the systems that are still active (the fire protection system, for example, requires maintenance and inspections, radioactive effluents, electrical power supply). There is still physical security onsite.

21222

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China

42

Article 28

J.1.3.1  P160 para 5

Licensees are required to report their inventory of sealed sources and radiation devices to the CNSC annually for Category 3, 4 and 5 sources, and more frequently for Category 1 and 2 sources. Please supplement the frequency of reporting for Category 1 and 2 sources.

Licensees are required to submit an annual compliance report which includes a full inventory of their sources (Categories 1–5). Licensees who possess Category 1 and 2 sealed sources are also subject to sealed source tracking requirements which means their inventories are always up to date, as they must report any acquisitions and transfers within timelines specified in the licence (typically 24 hours prior to domestic transfer, 7 days before any export and within 48 hours following receipt of a domestic transfer or import).

21223

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China

43

Article 28

J.1.1 P159 para 3

If a radioactive sealed source has decayed below its exemption quantity or its clearance level as defined in the NSRDR, it may be released from CNSC regulatory control, pursuant to subsection 5.1 of the NSRDR. As described above, Is the classification of radioactive sources in Canada dynamically managed? How to implement?

Licensees must maintain their own inventories and keep track of activities as the sources decay. However, when a source is removed from inventory, the licensee must maintain records of what was done with the source. If it has been released from regulatory control, the licensee must be able to demonstrate to the Canadian Nuclear Safety Commission that the source had in fact decayed below its exemption quantity or its unconditional clearance level as defined in the Nuclear Substances and Radiation Devices Regulations. Confirmation that radiation markings had been removed would also be sought. This information can be obtained during an inspection or as part of the review of the annual compliance report inventory submission.

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China

44

Article 12

H.2.1 P148 para 2

In 1982, the Canadian government established the Low Level Radioactive Waste Management Agency, which was responsible for the clearance and management of LLW in the history. How was it implemented?

The office is a separately funded program formerly under Atomic Energy of Canada Limited (AECL), originally reporting out of an AECL office located in Ottawa, Ontario. The work continues under the current Canadian Nuclear Laboratories Historic Programs Office, located in Port Hope, Ontario.

This program manages “historic” low-level radioactive wastes in Canada for which the producer no longer exists and the current owner can no longer be held responsible, and the Government of Canada has accepted responsibility.

The first priority of the office was to find ways of resolving the identified historic waste problems. This was funded largely by additional federal funds for individual projects. The office also ensures that a collection, treatment and safe management service is available, including on a commercial basis when the owner can be held responsible. There is also a public information function, and a historic artifacts program that can receive items such as historic radium painted dials for safe management.

The office assumed responsibilities of projects previously carried out through the Atomic Energy Control Board (AECB) on behalf of the Federal/Provincial Task Force on Radioactivity. The AECB took initiatives in 1975 to deal with historic situations requiring remedial work for which no other agency of government had direct responsibility.

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45

Article 32

B.1.1.1 P13  para 3

Please introduce the criteria of very low level radioactive waste in Canada.

Canadian Nuclear Safety Commission regulatory document REGDOC-2.11.1, Waste Management, Volume I: Management of Radioactive Waste, sets out the general classes of radioactive waste used as the basis for a classification system in Canada. Section 7.1 of this regulatory document states that very low-level radioactive waste (VLLW) has a low hazard potential and is above the criteria for unconditional clearance levels and exemption quantities. Long-term waste management facilities for VLLW do not need a high degree of containment or isolation. Concentrations of longer-lived radionuclides in VLLW are generally very limited.

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46

Article 32

B.1.4 P24 last para

How to treat and condition tritiated waste from PHWR in CANDA, and how to reduce the tritium discharge during tritiated waste treatment, conditioning, and storage.

Given the fact that tritium is a perfectly water-miscible radionuclide (radionuclide bound in the water molecule), it is very difficult or even impossible to capture, purify or filter it.

Tritium capture at the Ontario Power Generation nuclear power plants is maximized to the greatest extent possible in order to reduce the potential for airborne emissions through low-level waste streams. This includes the dewatering of filters and resins, in addition to ensuring that low-level radioactive waste is dry prior to shipment. Finally, operation of the tritium removal facility at Darlington reduces tritium content in primary heat transport and moderator water at the stations – reducing the source term for waste products. 

When radioactive wastes from the Gentilly-2 facility contain appreciable concentrations of tritium, Hydro-Québec may opt for hermetic containers or mechanisms that limit air exchange between the waste package or its storage enclosure and the environment. In some cases, leaching or drying the waste in a radiological worksite can reduce the tritium concentrations in radioactive waste. The tritium levels in the air or the residual water are then managed by the authorized systems for managing radiological effluents from the Gentilly-2 facility.

All tritiated waste at New Brunswick Power’s facilities is handled in accordance with their waste management procedures, which are based on eliminating and reducing the amount of tritium present in waste before it is placed in storage. 

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47

Article 32

B.1.4 P24 last para

The C-14 in the waste resin of the Qinshan CANDU reactor moderator system has reached the level of 1E+10Bq/L, and the C-14 in the waste resin of other systems is about 3E+8q/L, and they are currently stored in the waste resin storage tank. Please introduce the research progress of the treatment and conditioning spent resin containing C-14 in Canada.

Ontario Power Generation is currently working with several vendors, with a target to execute "proof of concept" testing in 2022. The aim is to remove and capture C-14 from the resin before further processing the resin for volume reduction. Further information will be available after the preliminary testing is complete.

At Gentilly-2, the highest concentration of C-14 assessed in the moderator system’s heavy water was 2.4 E+12Bq/L, in 2012. And it is estimated that 90% of the C-14 produced during the normal operation of the reactor was attached to spent resins from the moderator, which were formerly also stored in 2 dedicated underground tanks (approximately 150 m3 of moderator resins). There are some initiatives, under early development, that could be useful in capturing all the C-14 from the resins on molecular sieve columns. Also, control of the pH and chemical conditions of the water present is important during any mechanical pumping work on the spent resins to limit the release of C-14.

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48

Article 12

Annex 4 fig 4.13

In the waste management facility at Pickering Power Station, a replacement waste storage facility is mentioned. Is there a separate storage facility for HLW and ILW/LLW?

The Pickering Waste Management Facility has 2 distinct functions - the irradiated fuel storage buildings (storage buildings 1 to 4) are used for the storage of high-level radioactive waste. The second functional area is the storage of intermediate-level radioactive waste (ILW) in the retube waste storage containers, which are described and pictured in section 5.2.4 of Canada’s National Report. These containers house ILW from retube activities performed at the Pickering station in the 1990s; they are in a separate fenced area outdoors, and are considered interim storage for legacy materials. This area does not actively receive ILW for storage.

ILW and low-level radioactive wastes from Pickering operations are transported to the Western Waste Management Facility for interim storage and processing where applicable.

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Article 32

B.1.1.1 P13  para 3

Please introduce the replacement frequency and replacement index of molecular sieve in Canadian nuclear power plants (CANDU)? And the operation and management experience in reducing the crushing or powdering of molecular sieves. How can the tritium be removed from the waste molecular sieve and how to deal with and dispose of this type of waste?

For Ontario Power Generation, filters used in the moderator and primary heat transport systems are replaced at varying frequencies based on the design of individual systems/power stations. When removed from the system, the filters are allowed to dry in an area with active ventilation, to maximize tritium capture at the source. These filters are stored as intermediate-level radioactive waste in specifically designed flask liners; they are not crushed. Interim storage is at the Western Waste Management Facility in in-ground containers.

Hydro-Québec has used molecular sieves for multiple purposes at the Gentilly-2 facilities, and under different ambient conditions (atmospheric tritium concentration). All the molecular sieves produced were then stored in barrels and stored in Hydro-Québec’s onsite storage facilities.

For New Brunswick Power, molecular sieves are only used in chemistry analysis equipment, and are very small components. These components are typically regenerated and are used for approximately 6 years. Once they are spent, the components are dried and placed into the active waste stream.

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Article 32

B.1.3.4 P 20 para 4

Canada has stored enough dry storage irradiated fuel, is there any disposal plan about them?

Canada has a plan for the safe, long-term management of used nuclear fuel. The Nuclear Waste Management Organization (NWMO) is a federally mandated organization tasked with designing and implementing this plan in a manner that protects people and the environment for generations to come.

Canada’s plan calls for used nuclear fuel to be safely contained and isolated inside a deep geological repository – a system of natural and engineered barriers. The plan is based on years of public input, Indigenous knowledge, international scientific consensus, and best practices from around the world. This approach was endorsed by the Government of Canada.

Canada’s plan will only proceed in an area with informed and willing hosts, where the municipality, First Nation and Métis communities, and others in the area are working together. The NWMO plans to select a site in 2023, and 2 areas remain in the site selection process: the Ignace area and South Bruce, both in Ontario. Information on the current status of the NWMO program is available in its annual report, found on the organization’s website.

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Article 7

B.1.3.4

The Qinshan third nuclear power plant 6#,7#dry storage module will use denseness storage technology, is there any good experience for us to know?

Canada has extensive experience in developing and implementing dry storage solutions for spent nuclear fuel. Information about Canada’s dry storage technologies can be found in Canada’s National Report.

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Article 4

A.6 P9 para 6-7;G.3.1 P134 last para

Does Canada have any good attempts in the management of spent fuel, storage of spent fuel and communication with the public?

Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-3.2.1, Public Information and Disclosure, sets out the regulatory requirements for public information and disclosure, and provides guidance on the development and implementation of CNSC requirements for public information programs and disclosure protocols. In addition, CNSC regulatory document REGDOC-3.2.2, Indigenous Engagement, identifies requirements for CNSC licensees, with respect to Indigenous engagement and provides guidance and information on conducting Indigenous engagement activities.

Ontario Power Generation (OPG) has an excellent safety record in the management of spent fuel, both while in the irradiated fuel bays and in dry fuel storage casks. OPG’s Nuclear Sustainability Solutions division is based on the 3 pillars of stewardship, lasting solutions, and peace of mind. It produces a quarterly newsletter to the communities in which it operates, presentations are made to interested public groups, and public tours are conducted of its waste management facilities (pre-pandemic). All of this combines to establish good communications with the public.

Canadian Nuclear Laboratories (CNL) has extensive experience in the management of used nuclear fuel, ranging from packaging, to transportation, to extended storage. This has included developing and implementing concrete canister storage solutions and the MACSTOR (modular air-cooled canister storage) solution, recognizing the MACSTOR option is now offered via SNC-Lavalin. Due to the security sensitivities associated with spent nuclear fuel, communication on transportation initiatives has been more limited than for other classes of radioactive waste. CNL has communicated information on storage and transportation via mechanisms such as a local Environmental Stewardship Committee.

All spent fuel resulting from the operation of the Gentilly-2 nuclear facility is now in dry storage. Over the past few years, Hydro-Québec has maintained an open channel with the various surrounding stakeholders on the decommissioning project. The dry storage operations and the progress of the Gentilly-2 decommissioning project were also the subject of some reports in the local media. Since the nuclear power plant has been shut down, the interest of the local communities has been less than when in operation.

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53

Article 3.2

C.1.3,P38 para 6

As for NORM, only radium-bearing wastes resulting from the former radium industry and tailings and waste rock from uranium mines and mills were discussed in the report. Is there any non-exempt waste generated by non-nuclear industry in Canada? If so, how do provinces handle and dispose of them?

Radioactive wastes can be generated from the use of nuclear substances and prescribed equipment in the medical, industrial, academic and research, and commercial sectors. Nuclear substances in these industries are regulated by the Canadian Nuclear Safety Commission (CNSC).

Wastes generated by these industries are generally considered low-level radioactive wastes. CNSC regulatory document REGDOC-2.11.1, Waste Management, Volume I: Management of Radioactive Waste, provides that very-short-lived low-level wastes that contain short half-life radionuclides can be stored for a decay period and subsequently cleared for release. For wastes containing long-lived radionuclides, licensees may transfer waste to a CNSC-licensed radioactive waste management facility, location or site for long-term management.

Additionally, disused sealed sources (as described in section J in Canada’s National Report) can be returned to the manufacturer in Canada or its country of origin, or transferred to a CNSC-licensed waste management facility, location or site to be dispositioned.

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Article 3.2

Page 49 table D.8; Page 53 table D.9

Currently, most contaminated soils are stored in situ. Is there a treatment plan for them? If they are planned to be disposed at near surface disposal site in the future, what technology for conditioning is planned to use?

The treatment plan for the contaminated soils on the Canadian Nuclear Laboratories (CNL) sites is highly dependent on the characteristics of specific areas/sources. Areas of the site go through CNL’s environmental remediation process in order to establish the optimal remedial action to clean up the site. For contaminated soils where the remedial action is to excavate the material and dispose of it in the proposed Near Surface Disposal Facility (NSDF), the material will be managed through CNL’s waste management process, which includes processing if required. Many contaminated soils currently meet the Waste Acceptance Criteria (WAC) for the proposed NSDF at the Chalk River Laboratories (CRL) site. Should the waste material require processing, it will be managed at the CRL site in waste processing and storage facilities in order to meet the proposed NSDF WAC.

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Article 13

K.2.3.1, Page 169 para 4

In last report, it is mentioned that the near surface disposal facility (NSDF) would be built by 2020, but the date has been changed into 2024 in this report. What is the main reason for the delay?

The last report presented timelines that did not reflect the full extent of stakeholder and Indigenous community engagement activities and processes, or the due diligence offered by Canadian Nuclear Safety Commission (CNSC) staff during their review. In response to comments received from the public and technical review from the regulator on the 2017 draft environmental impact statement (EIS), Canadian Nuclear Laboratories (CNL) has conducted several additional studies and analyses, including an operational safety analysis, comprehensive post-closure safety assessment, ecological risk assessment, and design changes, the results of which are included in the final EIS. In July 2021, the CNSC announced acceptance of the final EIS for the Near Surface Disposal Facility (NSDF) Project from CNL. The CNSC has scheduled a 2-part public hearing to consider CNL’s application to amend its operating licence to authorize the construction of the proposed NSDF. Part 1 took place on February 22, 2022, and Part 2 is scheduled for May 31, 2022.

The revised timelines for the project, pending regulatory approval, are as follows:

  • Construction phase, which includes site preparation: anticipated to start in early fall 2022 or as soon as the relevant regulatory permits and approvals are in place
  • Operations phase: anticipated to begin in 2025 and end in approximately 2070 (i.e., approximately 50 years)

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Article 15

Annex 1, Page 208

At present, Canada is developing the regulatory document "REGDOC-2.11.1, Waste Management, Volume III: Safety Case for Long-Term Radioactive Waste Management, Version 2". What is the main motivation for updating the version?

Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-2.11.1, Waste Management, Volume III: Safety Case for the Disposal of Radioactive Waste, was published as Version 2 in January 2021. This was a result of the CNSC’s initiative to modernize the regulatory framework in the areas of radioactive waste management and decommissioning. The regulatory document was updated and modernized to align with national and international standards and best practices. The CNSC framework, which is comprised of evergreen documents, adapts over time based on operational experience and an evolving nuclear industry.

REGDOC-2.11.1, Volume III provides requirements and guidance for the development of a safety case and supporting safety assessment for the post-closure phase of disposal facilities, locations or sites for all classes of radioactive wastes.

To develop this regulatory document, the following International Atomic Energy Agency standards were reviewed, among others: GSR-5, Predisposal Management of Radioactive Waste; SSR-5, Disposal of Radioactive Waste; and SSG-23, The Safety Case and Safety Assessment for the Disposal of Radioactive Waste.

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Article 11

K.2.5 P188  last para

As disposal facilities are not yet available in Canada, and the radwastes now are interim or long-term storage. And OPG’s deep geologic repository project for its low- and intermediate-level radioactive waste has been cancelled. Please supplement the latest information of the siting or other status of the disposal facility for the low- and intermediate-level radioactive waste.

Ontario Power Generation (OPG) remains focused on improving the sustainability of nuclear power production. For many years, OPG has used various means and technologies to minimize the generation of nuclear waste and to divert clean materials away from the waste stream. As OPG explores alternative solutions for permanent disposal, OPG will continue to prioritize efforts in waste minimization. This includes minimization of waste production at the source, innovations in waste processing to reduce the volume, and recycling of clean materials.

Additional projects are being undertaken to sort, segregate, and reduce the volume of legacy materials stored at OPG’s Western Waste Management Facility. After several decades of interim storage – and advancements in waste processing techniques – there are opportunities to improve the use of existing facilities.

OPG remains committed to lasting solutions for nuclear waste disposal. OPG supports the Nuclear Waste Management Organization (NWMO) process to develop a deep geological repository for the permanent disposal of used fuel, with the current project timeline of site selection by 2023 and facility in service by 2043–45.

At the federal level, Natural Resources Canada (NRCan) is currently updating Canada’s radioactive waste policy, which includes developing a strategy for low- and intermediate-level radioactive waste (L&ILW). NRCan has asked the NWMO to develop Canada’s integrated strategy for radioactive waste for L&ILW, which is due to be released in 2022.

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Article 32

B.1.1,  P13  para 1

For the wastes such as positioning rings and shielding plugs generated during the replacement of pressure pipes, the activity concentration of Ni-59 and Ni-63 is expected to be higher than the upper limit of low-level radioactive waste. How to handle and dispose of such wastes.

Activated metal waste from retubing operations at Ontario Power Generation facilities is stored in shielded flasks at the Darlington, Pickering and Western Waste Management Facilities where the activity limits for low-level radioactive waste are exceeded. These containers take different forms at the 3 facilities, as detailed in the report annex. Decontamination, decay, and volume reduction are all being evaluated for the long-term management of these components.

At Gentilly-2, this equipment is currently stored in an auxiliary bay and are considered intermediate-level radioactive waste. They will be transferred in modified spent fuel baskets and stored onsite (until a permanent solution is developed) in waste structures that were originally design for activated reactor pieces.

For New Brunswick Power, a separate waste management storage structure within its solid radioactive waste management Facility was built specifically for reactor component storage. This includes pressure tubes, calandria tubes, positioning springs, etc.

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Lithuania

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Article 23

Section F3.2, Page 111

The Report mentions, that “…CNSC staff review the licensee’s program documentation against the criteria established in the requirement documents and standards that are referenced in the licence and LCH to assess the effectiveness of the licensee’s management system.” Could you, please clarify, if the management system requirements are defined not only in the Standard N286-12, Management system requirements for nuclear facilities but also in other specific standards or requirements documents?

CSA standard N286-12, Management system requirements for nuclear facilities, applies to all nuclear facilities and is based on a set of 12 principles. The principles are supported by generic requirements (clause 4). The standard then presents the specific requirements (clauses 5 to 9) that are applicable to the lifecycle of nuclear facilities. For example, clause 9 applies to radioactive waste management facilities.

The Canadian Nuclear Safety Commission (CNSC) regulatory framework is looked at holistically; as such, some requirements may be found in other safety and control area regulatory documents. The licence conditions handbook (LCH) is the tool that states the regulatory requirements (CNSC regulatory documents or standards) that a licensee’s management system must comply with. These documents or standards contain requirements on elements such as organization (e.g., responsibilities), operating experience, change management, records management, contractor management, etc. For example, the following documents contain information about management system/quality assurance:

  • CNSC regulatory documents: REGDOC-2.2.2, Personnel Training; REGDOC-2.6.3, Aging Management
  • CSA standards: N285.0, General requirements for pressure retaining systems and components in CANDU nuclear power plants; N286.7-16, Quality assurance of analytical, scientific and design computer program; N294, Decommissioning of facilities containing nuclear substances

As such, CSA N286 is complemented by other CNSC regulatory documents and CSA standards.

CNSC staff prepare technical assessment reference matrices (TARMs) to assess licence applications. TARMs are used for planning, sufficiency checks, and conducting technical assessments. For management system, CNSC staff assess applications against all regulatory documents and CSA standards that contain requirements related to management system. All those are referenced in the TARM for different management system review topics.

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Article 24.2

P.118-119

The report states, "the CNSC’s licensed release limits are known as derived release limits (DRLs). A DRL is a sub-type of a licence limit that is derived…". Please elaborate the regulatory mechanism of DRLs, i.e. whether DRL is a regulatory requirement, a voluntary target value of a license that has been approved by the regulatory body, etc.

The Nuclear Safety and Control Act and the General Nuclear Safety and Control Regulations require that adequate provisions are made for the protection of the environment and the health and safety of the public.

Currently, for nuclear substances released from Class I nuclear facilities, the Canadian Nuclear Safety Commission (CNSC) establishes licensed limits known as derived release limits (DRLs). A DRL ensures that members of the public do not receive radiation doses that would be harmful. For most facilities, the DRL is based on a most-exposed person receiving a radiological dose of 1 mSv/yr from radiological releases of a facility during normal operations. This most-exposed person is a person who would have a higher dose than the average member of the public due to a combination of factors, such as location, lifestyle, and food consumption. This person is determined from site-specific surveys and can be based on an actual or hypothetical person. The dose of 1 mSv/yr is the annual dose limit established in the Radiation Protection Regulations.

For facilities that have environmental releases, DRLs are required under CNSC regulatory document REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures. Thus, an exceedance of a DRL will be subject to enforcement actions from the CNSC. DRLs must be reviewed and approved by CNSC staff before they are included in the licence as a regulatory requirement. DRLs are calculated according to the methodology in CSA standard N288.1, Guidelines for modelling radionuclide environmental transport, fate, and exposure associated with the normal operation of nuclear facilities.

When CNSC regulatory document REGDOC-2.9.2, Controlling Releases to the Environment, is published and implemented, licence limits will no longer be set using the DRL approach. Instead, licence limits will be set at the maximum predicted design release concentration.

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Article 24.2

P.118-119

For the discharge limits set for gas and liquid radioactive wastes into the environment, please provide information on the following:

  1. Are there total annual discharge limits, that are only distinguishable between liquid and gas in Bq, set for radioactive wastes generated from nuclear facilities, i.e. NPPs, reprocessing facilities, etc.? If there are, do the total annual discharge limits for liquid and gas, consist of nuclides specific or groups of nuclides specific limits? Also, what are, the set limits per nuclides/groups of nuclides especially for tritium, as well as the basis for those set limits? For examples, discharge limits are set based on, expected annual release calculated from actual discharge amounts of previous years, calculation assuming upper limit of 1mSv over a year for each nuclides, committed effective dose received by the public of 1mSv over 70 years, etc. If there are discharge target values, recommended by a regulatory body for nuclear facilities licensees to be achieved, which are lower than the set limits, please provide the basis for the target values.

Releases of nuclear and hazardous substances are controlled and monitored by the licensee’s effluent and emissions control and monitoring program, and the environmental monitoring program. Licensees must demonstrate compliance with their release limits and action levels.

During normal operations of a facility, where radiological releases (airborne emissions or waterborne discharges) are authorized there are established limits and controls referred to as derived released limits (DRLs) and action levels that are identified within the licence or licence conditions handbook (LCH).

Currently, for radionuclides, limits are derived using the DRL approach. DRLs are derived through site-specific application of public dose modelling using the CSA standard N288.1, Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities.

In addition to the DRL, some nuclear facilities in Canada have a discharge target value, which is called a dose constraint. A dose constraint is lower than the regulatory public dose limit and is established in the optimization process to ensure that the dose to the public is well below the public dose limit. More information on CNSC staff’s expectations for dose constraints will be documented in the upcoming CNSC regulatory document REGDOC-2.9.2, Controlling Releases to the Environment. This document is currently under development.

When REGDOC-2.9.2 is published and implemented, licence limits will no longer be set using the DRL approach. Instead, licence limits will be set at the maximum predicted design release concentration, at a level lower than that derived based on the DRL.

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Article 24.2

P.118-119

  1. Are there nuclides specific or groups of nuclides specific concentration limits set for each gas and liquid discharges into the environment? What are those discharge concentration limits and the basis for the set concentration limits, especially for tritium? For examples, discharge concentration limits are set based on, expected annual release calculated from actual discharge amounts of previous years, calculation assuming upper limit of 1mSv over a year for each nuclides, committed effective dose received by the public of 1mSv over 70 years, etc. If there are discharge target concentration values recommended by a regulatory body for nuclear facilities licensees to be achieved, which are lower than the set concentration limits, please provide the basis for the target concentration values.

In Canada, each radionuclide, including tritium, has its own discharge limit, which is currently derived using the derived release limit (DRL) approach.

DRLs are calculated according to the methodology in CSA standard N288.1, Guidelines for modelling radionuclide environmental transport, fate, and exposure associated with the normal operation of nuclear facilities.

Each nuclear facility that has releases of tritium to the environment has their own site-specific DRL for tritium. This is because the DRL depends on site-specific parameters, including location of the nearest potential receptors, potential exposure pathways for those receptors, and meteorological conditions at the site. For nuclear power plants in Canada, the tritium DRLs are found in appendix D of the Regulatory Oversight Report for Nuclear Power Generating Sites: 2019: https://nuclearsafety.gc.ca/eng/resources/publications/reports/regulatory-oversight-reports/npgs-report-2019.

According to CSA N288.1, additivity effects from different radionuclides must be considered in the DRL calculations. The purpose of this assessment is to ensure that the dose limit of 1 mSv/yr is not exceeded considering exposure from all radionuclides and release pathways from all sources onsite.

In addition to the DRL, some nuclear facilities in Canada have a discharge target value, which is called a dose constraint. A dose constraint is lower than the regulatory public dose limit and is established in the optimization process to ensure that the dose to the public is well below the public dose limit. More information on Canadian Nuclear Safety Commission (CNSC) staff expectations for dose constraints will be documented in the upcoming CNSC regulatory document REGDOC-2.9.2, Controlling Releases to the Environment.

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Article 24.2

P.118-119

  1. Also, please provide the actual amounts of each gaseous and liquid radioactive wastes released or discharged annually into the environment from nuclear facilities between 2016 and 2020, especially, for annual discharge amounts of tritium and other nuclides in forms of gas and liquid, per types of nuclear facilities (NPPs with reactor types, reprocessing facilities, others)
  2. For an evaluation of exposure dose from tritium, if other than the radiological concentration factor of 1 is used for the evaluation, please provide the used radiological concentration factor and the basis for its use.

Total releases of radionuclides to the environment from the major nuclear facilities regulated by the Canadian Nuclear Safety Commission from 2016 to 2020 can be found on the CNSC’s Open Government portal: open.canada.ca/data/en/dataset/6ed50cd9-0d8c-471b-a5f6-26088298870e.

A radiological concentration factor of 1 is used for the evaluation of exposure dose from tritium.

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Article 24.2

P.118-119

How is the clearance system applied for gaseous and liquid radioactive wastes generated from nuclear facilities?

The conditional clearance levels are applied for any gaseous and liquid radioactive effluent that the licensee wants to discharge directly to the environment or to the sewer.

The values recommended are taken from IAEA-TECDOC-1000 and have been derived on the basis that their release from a licensed facility will not result in an annual effective dose to a member of the public of greater than 10 μSv/yr.

In Canada, radioactive wastes generated from Canadian Nuclear Safety Commission-licensed facilities and activities are not released to the environment. Airborne discharges are called emissions and waterborne discharges are called effluent. These are generated during normal operations of the facility and can be safely released if the concentrations are below the licence limit.

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Article 9

p. 140, G.6.1

How is the security of the installations ensured during maintenance and inspection?

At all nuclear facilities in Canada, security protocols are in place to ensure appropriate monitoring continues during periods of security system maintenance. This may include use of patrols for continuous surveillance or periodic surveillance, or the use of alternate remote surveillance, depending on the location, security risk and planned duration of maintenance. During maintenance, all nuclear facilities are still required to be in compliance with the Nuclear Security Regulations and applicable Canadian Nuclear Safety Commission (CNSC) regulatory documents and licence conditions. Routine CNSC compliance activities, including inspections, are conducted to verify licensee compliance with regulatory requirements.

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Planned Activities

p. 174, K.2.4.2

For the choice of the long-term management of spent fuel location, it is described that field testing is done, as well as community consultation.

Could Canada, please, detail how the geological characteristics of the potential sites are assessed? In the site selection process, how is the balance made between technical and societal aspects (e.g. if other locations have better siting characteristics for a DGR, but less local support from the population)?

Since 2010, the Nuclear Waste Management Organization (NWMO) has been engaged in a multi-year, community-driven process to identify a site where Canada’s used nuclear fuel can be safely contained and isolated in a deep geological repository (DGR). The site selection process was based on evaluating safety and other factors. These are described in the NWMO 2010 document Moving Forward Together: Process for Selecting a Site for Canada’s Deep Geological Repository for Used Nuclear Fuel, available on the NWMO website.

This process started with 22 municipalities and Indigenous communities that expressed interest in learning more and exploring their potential to host the project. The NWMO has gradually narrowed its focus to fewer areas through technical site evaluations and social engagement to assess safety and the potential to build supportive and resilient partnerships, key criteria to assess the suitability of each area.

Today, the NWMO is engaging with 2 potential siting areas, including First Nation and Métis communities in the areas, interested in learning more about Canada’s plan. The Township of Ignace in northwestern Ontario, and the Municipality of South Bruce in southern Ontario are considered potential host areas for the project.

Geological studies are designed in an iterative manner to assess and confirm if the geology of the areas is suitable for constructing a repository. Building on earlier desktop work, intensive geological studies are underway in both potential siting areas to further assess suitability and the potential to meet the technical site evaluation factors. This includes activities such as airborne geophysical surveying, seismic surveys, geological mapping, and borehole drilling, coring and testing. Initial borehole drilling and testing recently concluded in the Ignace area and is anticipated to be completed in South Bruce later in 2022. Ongoing monitoring, modelling, lab analysis, data interpretation and integration will continue.

The NWMO must demonstrate long-term safety of any potential repository site, and the project will only proceed with interested communities, First Nation and Métis communities, and surrounding municipalities, working together to implement it.

Any potential site for a DGR will be evaluated under Canada’s regulatory framework, which clearly identifies the requirements for site characterization data as part of the waste system description, and as required information for safety assessment models and the overall DGR safety case.

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General

p.9, A.4

Related to CNSC continuous improvement, could Canada, please, detail how the assessments are done?

In Canada, all Canadian Nuclear Safety Commission (CNSC) licensees are required to strive to further reduce the risks associated with their licensed activities on an ongoing basis, and they are expected to consider additional safety and mitigation options as techniques and technologies evolve. In addition, the CNSC is committed to continuously improving its regulation of the Canadian nuclear industry.

The CNSC’s management system integrates the key elements of CNSC work into a holistic framework of programs and activities through which the organization achieves its goals as Canada’s nuclear regulator. The CNSC’s Internal Quality Management Division (IQMD) oversee the management system and facilitates identifying, developing, and implementing corporate improvement initiatives through a functional group called Continuous Improvement and Change Management Initiatives. The CNSC employs multiple sources of information, the analysis of which is used to inform improvements to the CNSC management system.

Examples of sources used to identify opportunities for improvement include:

  • internal audit office, which conducts audits and evaluations and the Departmental Audit Committee, which ensures the independence of internal audit
  • self-assessments of internal processes, programs, and policies
  • formal and informal third-party reviews such as audits, evaluations, assessments, and peer reviews
  • operational experiences and lessons learned from within the CNSC, and from other domestic and international regulators
  • lessons learned from other government departments and agencies
  • Commission review and direction when programs, policies, or processes are presented
  • ongoing feedback from staff and industry, and other key stakeholders’ strategies to identify and transfer critical knowledge

This approach results in regular review and assessment strategies, allows participation from all staff and management, and results in ongoing continuous improvement in achieving the CNSC’s goals as Canada’s nuclear regulator.

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Article 32.1.2

p. 17, B.1.3.1.1
p. 19, B.1.3.2.2

Once the NPP unit will be in decommissioning, is wet storage of spent nuclear fuel a possibility in Canada, or is it meant to be stored only in dry interim storage?

If wet storage is possible, could Canada detail the measures taken, or imposed, for criticality safety and for SSC ageing management (in particular for the pool liner and structure)?

In Canada, in order to transition from operations to decommissioning, licensees are required to submit stabilization activity plans to the Canadian Nuclear Safety Commission (CNSC) for acceptance. A stabilization activity plan comprises steps for the facility’s transition from a permanent shutdown state to a stable state for decommissioning. Stabilization activities include defuelling the reactor, maintaining cooling for the irradiated fuel bays and transferring the spent fuel to dry storage.

A nuclear power plant cannot complete its decommissioning until all of the spent fuel has been transitioned to dry storage. CNSC regulatory document REGDOC-2.11.2, Decommissioning, defines in situ decommissioning as follows: “to place the facility, location or site, or portions thereof in a safe and secure condition in which some or all of the radioactive H27contaminants are disposed of in place, which may result in the creation of a waste disposal site.” Further, section 5.1 of REGDOC-2.11.2 states, “In situ decommissioning shall not be considered a reasonable decommissioning option for planned decommissioning of existing or future nuclear facilities and situations where removal is possible and practicable; nevertheless, in situ decommissioning may be considered a solution only under exceptional circumstances (e.g., following a severe accident) or for legacy sites. In situ decommissioning for legacy sites is only considered viable where the use of in situ will be protective of workers, the public and the environment; decommissioning was not planned as part of the design; the fuel has been removed; and the site will remain under institutional control for the period defined in the safety case.”

In Canada, spent fuel is typically in wet storage for 7 to 10 years, after which it is transferred to dry storage. Wet storage is not intended to be used for long periods. 

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Article 32.1.4

p. 27, B.1.4.2.1

Could Canada, please, detail the alternative solutions envisaged for the permanent disposal of L&ILW?

In the fall of 2020, the Minister of Natural Resources Canada tasked the Nuclear Waste Management Organization with leading an engagement process with Canadians and Indigenous peoples to inform the development of an integrated long-term management strategy for all of Canada’s radioactive waste.

This work will address existing gaps, specifically in plans for long-term management of low- and intermediate-level radioactive wastes. The strategy proposed will need to align with the federal government’s modernized Radioactive Waste Management Policy.

In collaboration with waste producers and owners, government, Indigenous peoples, civil society organizations, and interested Canadians, the Nuclear Waste Management Organization will focus on:

  • taking stock and describing the current waste management situation in Canada in terms of current and future volumes, characteristics, locations, and ownership of the waste
  • updating current plans and progress in advancing long-term management and disposal solutions for Canada’s wastes and identifying the gaps that must be addressed
  • providing conceptual approaches for dealing with those wastes for which no long-term plan exists, including technical options for long-term management or disposal, and options for the number of long-term waste management facilities in Canada
  • making recommendations about the staging, integration, establishment, and operation of long-term waste management facilities

The strategy recommendations will be based on public input, Indigenous knowledge, international scientific consensus, and best practices from around the world. The draft recommendations will be published in 2022.

There will be an opportunity for Canadians, Indigenous peoples and interested parties to provide feedback and comments on those recommendations before they are finalized for submission to the Minister of Natural Resources Canada.

Canadian Nuclear Laboratories (CNL) reviewed several alternatives for the disposal of low-level radioactive waste as part of the development of the environmental impact statement for the proposed Near Surface Disposal Facility. In addition to the selected preferred options, this included evaluation of ongoing waste storage, disposal in a geologic waste management facility, and segregation of very low-level waste for disposal in a separate facility. In addition, CNL currently utilizes long-term waste management facilities at the Port Hope and Port Granby projects that are part of the Port Hope Area Initiative. As well, the Nuclear Power Demonstration and Whiteshell Reactor-1 prototype reactors are currently being proposed as in situ decommissioning projects.

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Article 24

p. 113, F.4.3

Although it is mentioned that action levels are facility-/activity- specific, could Canada, please, provide some examples of such action levels? How is their effectiveness and appropriateness evaluated?

Is the licensee expected to provide the ERA during the licence application? Are transboundary effects considered and analysed in the ERA?

The Canadian Nuclear Safety Commission (CNSC) has adopted the use of radiation protection action levels in its regulatory framework. Specifically, subsection 3(1) of the General Nuclear Safety and Control Regulations requires an application for a licence to contain any proposed action level for the purpose of section 6 of the Radiation Protection Regulations. An action level is defined as a specific dose of radiation or other parameter that, if reached, may indicate a loss of control of part of a licensee’s radiation protection program and triggers a requirement for specific action to be taken. When a proposal for an action level is accepted by the CNSC, it is incorporated into a CNSC licence.

To assist licensees, the CNSC has published regulatory document REGDOC-2.7.1, Radiation Protection. The action levels selected by the licensees are parameters of their radiation protection program that represent timely indicators of potential losses of control. When an action level is reached it will alert licensees to a potential loss of control of part of their program in advance of any dose limits being exceeded. When an action level is reached, the licensee is required to comply with subsection 6(2) of the Radiation Protection Regulations, which specify requirements for investigating the exceedance, for identifying and taking action to restore the effectiveness of the radiation protection program, and for regulatory notifications in the time period specified in their licence.

Action levels for radiation protection programs can include a number of parameters specific to the licensed activity. Examples include:

  • the quantity of radiation exposure or dose that an individual receives (“individual dose”)
  • a radiation level within a work area (“ambient dose rate”)
  • radioactivity per unit surface area (“surface contamination level”)
  • a concentration or a quantity of a nuclear substance in a workplace

As noted in REGDOC-2.7.1, the radiation protection program should include requirements for regular review of, and when appropriate, revision of action levels. Over the lifetime of a facility or activity, an action level may be dynamic or static. That is, it may be revised upwards or downwards to accommodate the prevailing circumstances. For example, an action level for a new facility or activity may warrant refinement once sufficient operating experience is gained. Similarly, if conditions at a facility change, a related action level may also need to be reviewed and revised accordingly.

The CNSC has also adopted environmental protection action levels in its regulatory framework. Similar to radiation protection action levels, the purpose of these action levels is to present timely indicators of potential loss of control. When an action level is reached it will alert licensees to a potential loss of control of part of their program before any licensed release limits are exceeded. When an action level is reached, the licensee is required to investigate the exceedance, take any corrective actions or preventative measures required to restore the effectiveness of the environmental protection program, and notify the Commission in the time period specified in their licence.

Detailed requirements and guidance outlining CNSCs expectations for environmental protection action levels are provided in REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures and CSA standard N288.8, Establishing and implementing action levels for releases to the environment from nuclear facilities.

In order to be effective in identifying a potential loss of control, environmental protection action levels are established by the licensee, and are operationally derived using the licensee’s effluent monitoring data, an assessment of an upper value of normal operation (e.g., 95th percentile), and known loss of control events. In accordance with CSA N288.8, action levels are required to be reviewed at a minimum of every 5 years and may increase or decrease over time to reflect changes in the licensee’s operation (as long as the licensee continues to operate within their approved licensing basis). This periodic review ensures that action remain appropriate over time.

Radiation and environmental protection action levels are performance-based objectives that are independent of the licensee environmental risk assessment (ERA). Licence applications to construct, operate or decommission a nuclear facility shall contain a predictive ERA that describes the potential effects, including transboundary, on the environment and the health and safety of persons from the proposed activities, along with the measures that will be taken to prevent or mitigate those effects. The ERA also informs the design of the licensee effluent and environmental monitoring programs.

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Article 24

p. 114, F.4.6.2

Is the licensee expected to provide the ERA during the licence application? Are transboundary effects considered and analysed in the ERA?

In accordance with the Class I Nuclear Facilities Regulations, an application for a licence to construct must contain information on the effects on the environment and the health and safety of persons that may result from the construction, operation and decommissioning of the nuclear facility, and the measures that will be taken to prevent or mitigate those effects.

Detailed requirements and guidance outlining Canadian Nuclear Safety Commission (CNSC) expectations for an environmental risk assessment (ERA) are provided in REGDOC 2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures, and CSA standard CSA N288.6, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills.

The ERA forms a core component of the licensee’s environmental protection program and is required to be updated at least every 5 years. During this update, new information, including monitoring data, is used to assess whether the predictions made in the previous ERA remain valid. Monitoring data does take into account any potential exposures from other sources, including potential transboundary effects.

In addition, the assessment of cumulative effects is required as part of an impact assessment, for which an ERA is used to support.

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72

General

p. 2, § 3.0

Could Canada, please, detail on which basis the period of validity of a decommissioning licence is chosen, and the consequences if an operator passes the delays (penalties...?)?

Section E.2.3.8.2 of Canada’s 7th National Report contains information regarding licence periods, which are valid for a licence to decommission. A nuclear facility is licensed throughout its entire lifecycle, with authorization required for site preparation, construction, operation, decommissioning and abandonment. The typical licence period for any licence issued by the Canadian Nuclear Safety Commission (CNSC) is 5 to 10 years. 

The licence period does not typically cover an entire lifecycle stage, such as decommissioning, and is not designed to do so. The licence period granted is independent of the time proposed to be spent in a particular lifecycle stage, be it operations or decommissioning. Decommissioning of a reactor facility could take decades, particularly if deferred decommissioning is selected.

The Commission also has discretion in specifying the licence period for any licence that it issues. In considering each application, the CNSC takes careful account of all relevant factors and information pertaining to the preceding licensing stage. Factors include facility-related hazards, the development and implementation of safety programs, the implementation of an effective monitoring and maintenance program, licensee experience, and performance.

If a licence to decommission (or any licence issued by the CNSC) expires and is not renewed, the licensee can no longer conduct the activities that were approved in the licence. The CNSC requires applicants and licensees to make adequate provision for the safe decommissioning and associated waste management of existing or proposed nuclear facilities by ensuring that sufficient financial resources are available to fund all approved decommissioning and waste management activities should the licensee not be able to fulfill its obligations.

If a licensee takes longer to decommission a reactor facility than originally planned, and the licence continues to be renewed, there are no penalties issued by the CNSC for this.

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France

73

Article 32.1.4

Section D – page 57

The Report from Canada indicates that the dedicated isotopes facilities (Multipurpose Applied Physics Lattice Experiment (MAPLE) and new processing facility) at Chalk River (Ontario) remain in an extended shutdown state.

Could Canada specify what the purpose of this extended shutdown is: decay for some difficulties to obtain a sufficient radiological safety during the decommissioning procedures, absence of relevant solution for long term management of radioactive waste, or anything else?

The MAPLE reactors and processing facility are in an extended shutdown state. Canadian Nuclear Laboratories and Atomic Energy of Canada Limited have recently made the determination that there are no viable re-use options for the facilities, and as such they are in the process of being transferred into a storage-with-surveillance state, a planned stage of a decommissioning program during which the facility will be maintained in a safe condition until decontamination and dismantling actions are performed.

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Article 32.1.4

Section B - page 29

Canada’s report indicates that McArthur River and Cigar Lake uranium mines are two of the highest-grade uranium ore bodies in the world. The report specifies that some of the ore bodies in the Athabasca Basin contain other elements, such as nickel and arsenic, and that such feature brings additional considerations to the management of tailings and waste rock that result from mining and milling these ores.

Managing the chemical toxics closely tied to the radioactive waste, in particular from ore exploitation, is a tricky topic that concerns many countries. Could Canada give details on this specific management?

Mineralized waste rock and broken ore are stored in engineered containment facilities, constructed of low-permeability materials (e.g., concrete, HDPE, bentonite) with a leachate collection system. Water from these facilities is collected and conveyed for treatment. Site water treatment facilities are designed to effectively remove uranium, radium-226, and other substances (e.g., nickel and arsenic) that are associated with the ore body. Treated water is regularly monitored to ensure compliance with applicable release limits and continued protection of the environment.

Precipitates from these treatment facilities can be filtered and returned to the underground mine for disposal, processed through the milling circuit, or disposed of in engineered tailings facilities. Treatment processes are such that these substances are precipitated out of solution as chemical compounds that will remain stable over the long term. 

During operation, engineered tailings facilities are actively dewatered to promote tailings consolidation and maintain hydraulic containment of the facility. At decommissioning, the final configuration of these facilities will be such that the interaction of surficial or ground water with the consolidated tailings mass is reduced.

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Article 3.2

Section C.1.3 - page 38

Canada’s report indicates that Naturally Occurring Radioactive Materials (NORM) is regulated by the provincial and territorial governments, each having its own specific regulations on the handling and disposal of the material. The report specifies that Canadian Guidelines for the Management of NORM were developed by the Federal Provincial Territorial Radiation Protection Committee to harmonize standards throughout the country and ensure appropriate control of NORM. Furthermore, it is indicated that provincial regulations should also be consulted.

Could Canada provide the key aspects of NORM management described in the guidelines? Are there specific rules for these provincial regulations? If so, what exactly are they?

The Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM) set out principles and procedures for the detection, classification, handling and material management of NORM in Canada, and also includes guidance for compliance with federal transportation regulations. These guidelines provide the framework for the development of more detailed NORM management practices and guidelines by regulatory authorities, affected industries and specific workplaces.

For more information on the management of NORM in Canada please refer to:

canada.ca/en/health-canada/services/publications/health-risks-safety/canadian-guidelines-management-naturally-occurring-radioactive-materials.html.

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Article 28

Section J.1.3.2 – page 161

The section J.1.3.2 entitled “Disposal of radioactive sealed sources in Canada” of Canadian report mentions that some disused radioactive sources can be managed by radioactive decay, be recycled by some manufacturers, or be sent to a licensed radioactive WMF. However no disposal option is mentioned for the long term.

Could Canada specify the disposal options currently considered for the long-term management of the disused radioactive sources for which a radioactive decay cannot be expected on the human time scale, in particular of categories 1 and 2?

Currently, there are no facilities, locations or sites in Canada that are licensed to dispose of radioactive wastes, including disused sealed sources.

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Cyprus

77

Article 20

Section J.1.3.7

This is a very interesting way of resolving the issue of liability. What legal or regulatory requirements are in place to oblige licensees participate with a premium to this insurance scheme? Is it applicable to all source categories (5 to 1)? Would it be possible that, CNSC being the only insured party, this would be taken as exonerating the responsibility of the licensees, for example being less “careful” in meeting their obligations?

All licensees who are users of sealed sources and radiation devices (all categories) have a licence condition included in their licence for a financial guarantee. This condition would be removed from the licence only if deemed non-essential for that particular licensee (e.g., a licence that only authorizes the possession and use of sealed sources < 50 Mbq). The licence condition states the following: “The licensee shall maintain, at all times, a financial guarantee in respect of the activities authorized by this licence of a value set by the Commission and in a form acceptable to the Commission.”

Licensees who are users of sealed sources and radiation devices have the option of submitting their own financial guarantee plan or participating in the insurance program put in place by the Canadian Nuclear Safety Commission (CNSC), provided their liability for these sources does not exceed $1 million. The application of the financial guarantee program applies to all source categories within the limits specified (sealed sources greater than 50 MBq, all radiation devices). 

Experience has demonstrated over the last 6 years of program implementation that licensees continue to take responsibility for their sources. The CNSC has only used the insurance plan on 3 occasions. It has been made clear to licensees that a financial guarantee does not relieve a licensee from complying with all regulatory requirements for termination of licensed activities. Only the CNSC may invoke a financial guarantee program and will only do so after having exhausted all other regulatory options with the licensee, when the licensee-owner cannot be identified or when a non-nuclear entity is involved.

Additional information can be found on the CNSC website at nuclearsafety.gc.ca/eng/nuclear-substances/licensing-nuclear-substances-and-radiation-devices/licensing-process/financial-guarantees/index.

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Germany

78

Article 26

p. 126

In Canada, does the decommissioning of facilities require that the spent fuel is removed from those facilities being dismantled?

Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-2.11.2, Decommissioning, provides requirements and guidance for decommissioning with respect to planning, preparation, execution and completion.

In order to transition from operations to decommissioning, licensees are required to submit permanent shutdown plans, stabilization activity plans and detailed decommissioning plans to the CNSC for acceptance. A stabilization activity plan comprises steps for the facility’s transition from a permanent shutdown state to a stable state for decommissioning. Stabilization activities include defuelling the reactor, draining and storing cooling water from the reactor main systems, draining water from secondary and auxiliary cooling systems, cleaning and decontamination, maintaining cooling for the irradiated fuel bays, transferring the spent fuel to dry storage, modifying the operating conditions/programs to align with the state of the facility, performing extensive radiological surveys, and maintaining routine surveillance of the facility.

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Germany

79

Article 9

p. 141, 275

For the Cluff Lake a comprehensive environmental assessment and licensing process, including extensive public engagement, regulatory approval for decommissioning was granted in 2004 with agreed end-state decommissioning objectives.

In Canada, what is the relationship between end state of decommissioning and release from CNSC licensing? How is the end state of nuclear facility defined and how does regulator engage with defining/approving end state?

As outlined in Canadian Nuclear Safety Commission (CNSC) regulatory document REGDOC-3.5.1, Licensing Process for Class I Nuclear Facilities and Uranium Mines and Mills, the licensee’s responsibility can be terminated once long-term monitoring has confirmed the successful completion of decommissioning and confirmation that end-state decommissioning objectives have been met. The Commission may issue a licence to abandon or an exemption from licensing that will end the licensee’s responsibility for the site and if applicable, then transfer responsibility for regulatory oversight to a third party (e.g. province, territory, federal government) for institutional control.

CNSC regulatory document REGDOC-3.6, Glossary of CNSC Terminology, defines end state as: “With respect to decommissioning, the proposed physical, chemical and radiological condition of a facility at the end of the decommissioning program.”

End-state objectives for a nuclear facility are required to be identified during the planning for decommissioning and outlined in the preliminary decommissioning plan early in the lifecycle of the facility. These should be based on the proposed end state and the anticipated future use of the site. As planning for decommissioning advances, end states and remediation goals are further identified in the detailed decommissioning plan. It should include descriptions of anticipated occupancy and use of the site and activities that may occur in the surrounding areas.

The remediation goals and end-state objectives are selected by the licensees, with consideration of the proposed end use, and established with input from relevant stakeholders and in consultation with the regulators.

Following the completion of decommissioning, a final end-state report is required to be submitted to the CNSC for approval. The report outlines how end-state conditions have been met or provide an explanation for why objectives have not been met with detailed survey results of the site.

The CNSC requires, after successful completion of decommissioning, an application for a licence to abandon or exemption from licensing. This submission must be supported by reports on the results of the decommissioning and site restoration activities, as well as the results of the radiological and environmental monitoring, to demonstrate that the site no longer needs to be licensed under the Nuclear Safety and Control Act.

Decommissioning ends with the release of the facility from CNSC regulatory control. If unrestricted release cannot be achieved, institutional controls are required to be in place and the facility may need to remain under CNSC oversight.

If institutional controls are required, the CNSC expects the following actions to be taken by the responsible party, following completion of decommissioning:

  • implementation of a visual inspection plan for periodic examination of the facility, location or site to look for signs of deterioration of the facility, location or site (e.g., slumping of the ground), or erosion of the surface
  • operation and maintenance of a monitoring system to detect any radionuclide release within the site boundary
  • implementation of any active controls to prevent unrestricted access to the site

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Ukraine

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Article 32.2.1

Annex 4, page 217

Is there any plan for handling of the corroded fuel containers and fuel or fuel is just placed in a new stainless-steel container?

Although the fuel is safely stored, monitored and inspected, Canadian Nuclear Laboratories is currently evaluating various options for safe retrieval, stabilization and packaging of legacy fuel and fuel containing materials which have experienced package and fuel degradation during storage. All plans for fuel management are tied to ongoing definition of the Waste Acceptance Criteria of the national deep geological repository being developed by the Nuclear Waste Management Organization.

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Ukraine

81

Article 32.1.2

B.1.3.1.1, page 16

In case of reactor operational life extension, would there be enough place on site to store the spent fuel?

As stated in section B.1.3.1.1 of Canada’s 7th National Report, each nuclear power plant site in Canada has enough space to store all the spent fuel produced during the operating life of the station. Should a licensee wish to extend the life of a station, a request would need to be made to the Canadian Nuclear Safety Commission (CNSC) to do so, and approval from the Commission through a public hearing process would need to be gained. Such a request would be accompanied with documentation that supports the life extension, which is required to contain information on radioactive waste management. CNSC staff would perform a full technical assessment of the documentation, and would verify that there is an adequate plan in place to manage the additional radioactive wastes that would be generated due to the life extension, prior to the extension being granted.

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Canada

Montenegro

82

Article 24

F, F.4.5, F4.6, page 114

The Report stated that the nuclear sector reduces the risk of unplanned effluent releases of radioactive material into the environment by: installing multiple barriers; having reliable components, systems and competent staff; and detecting failures and correcting them.

  1. Could you explain about main challenges in preventing unplanned releases and protection of the environment?
  2. Who performs environmental monitoring of radionuclides around facilities for nuclear and radioactive waste management – these facilities or some independent legal entities?

As a licence condition, the Canadian Nuclear Safety Commission (CNSC) requires each licensee to implement and maintain an environmental protection program. It is the responsibility of the proponent or the licensee of the facility to perform environmental monitoring of both radionuclides and hazardous substances. The environmental monitoring program must meet the requirements in CNSC regulatory document REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures and CSA standard N288.4, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills.

CNSC staff provide oversight through reviews of licensees’ environmental monitoring programs, environment monitoring reports and annual compliance reports, reviews of events, and inspections focused on environmental protection. The CNSC requires licensees to report routine performance data and unusual occurrences. Where a licensee has an unplanned release, CNSC staff follow up to ensure that the licensee takes appropriate corrective actions.

In addition, the CNSC has implemented its own Independent Environmental Monitoring Program (IEMP). The objective of the IEMP is to build Indigenous and public trust in the CNSC’s regulation of the nuclear industry, via an independent, technical and accessible environmental sampling program around nuclear facilities. It is separate from, but complementary to, the CNSC’s ongoing compliance verification program and helps to confirm the CNSC’s regulatory position and decision making.

Ontario Power Generation (OPG) has a strong program for protection of the environment with few unplanned releases of radioactive effluents. At OPG facilities, the most common radiological releases are from off-gassing of tritium and C-14 from handling and storage of low- and intermediate-level radioactive wastes, and from the incineration of waste. Unplanned releases may include minor spills from equipment, leaks from sumps, or water ingress/egress from inground structures. Multiple barriers exist for containment of spills to prevent releases to the environment. OPG is compliant with the N288 series of CSA standards. Routine effluent, environmental, and groundwater monitoring samples are collected by site staff and analyzed by third party labs. An exception is environmental thermoluminescent dosimeters that are analyzed by OPG Health Physics Labs. An environmental risk assessment is completed every 5 years by a third-party consultant that monitors the surrounding water, sediment, vegetation and soil.

Bruce Power’s facilities are well designed with respect to operational performance to mitigate unplanned releases and protect the environment; typically, unplanned releases are a result of spills or accidents. The number of annual occurrences remain low and are of low risk and consequence. Identification of cause is typically equipment malfunction. To date, these incidents are responded to effectively to maintain protection of the environment and human health. The Chemistry and Operations departments perform the environmental monitoring at the stations.

The primary challenges at Canadian Nuclear Laboratories (CNL) facilities are related to equipment malfunction and/or human error as described below. There are a number of factors that could be involved in an unplanned release to the environment. It could have been from equipment malfunction, degradation of an emissions control system (i.e., clogged filter) or from human performance. In general, CNL’s releases are very well controlled. In 2007, the CNSC required development of action levels that were based on the operational history of the facilities in question. Exceeding these action levels requires reporting to the regulator (CNSC). Prior to this requirement, CNL’s action levels were a percentage of the allowable annual limit and were very high, and in some facilities it would have been impossible to exceed them. Basing the action levels on historical performance brought all limits down to a more reasonable level and prompted more scrutiny by management on emissions. This led to better overall performance because lower-level releases were recognized as being out of the ordinary and were investigated and corrected. Since the inception of these action levels in 2007, CNL had 2 major events with multiple action level exceedances (a reactor leak and unusual iodine releases from isotope production facility), but apart from these 2 events, CNL has had <15 exceedances in 15 years. This performance is great, considering >50 airborne effluent locations are monitored weekly and 12 liquid effluent locations monthly and each of these for a number of different parameters. Sample collection and preparation is performed by staff at CNL. These samples are then sent to various internal and external labs for analysis depending on the parameter in question. However, all the radiological monitoring is completed in-house. For some non-radiological analysis and anything sent out externally, CNL follows ISO 17025. For the radiological sampling and analysis, these are done following quality assurance plans that are in compliance with one of the following CSA standards: N288.4, Environmental monitoring at Class I nuclear facilities and uranium mines and mills; N288.5, Effluent monitoring at Class I nuclear facilities and uranium mines and mills; N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills.

With respect to radioactive waste and spent fuel storage facilities, Hydro-Québec assess all the possible events in its safety report: from the generation of the waste in the nuclear facility to its safe storage onsite, including transportation between facilities. Also, a qualified response team is on the site at all times for any waste handling. Some other prerequisites are good weather conditions, maximum limit of wind speed or maximum speed for vehicle (waste convoy). Finally, all waste facilities are subject to environmental monitoring, for the quality of surface water, groundwater, air, gamma atmosphere, etc. Any unforeseen release of radioactivity into the environment would be quickly detected and action would be taken immediately to correct the situation. Hydro-Québec performs its own environmental monitoring of radionuclides around facilities for nuclear and radioactive waste management.

For New Brunswick Power’s facility, the main potential challenges are from the physical handling and transportation of the waste from the site to the storage facilities. Preventing unplanned releases and protecting the environment are embedded into training, equipment design, and procedures for these activities. New Brunswick Power is responsible for conducting environmental monitoring and sampling around their waste management facility.

For Cameco’s processing facilities with legacy waste (may be generated by previous site operator, or generated 3 to 4 licence cycles previously), the primary challenge is waste package integrity with limited documented characterization information. To ensure protection of people and the environment during storage and/or characterization, measures such as appropriate packaging to the known waste characteristics, multiple containment (overpacking drums, indoor storage of packages, storage within containment features such as dykes or berms), surveillance (scheduled inspections for package integrity with repackaging as required), and characterization for processing to unrestricted release, permitted disposal or long-term storage are used to prevent unplanned releases. Environmental monitoring for Cameco facilities is performed by Cameco as per the environmental protection program for each facility. At least every 5 years, routine monitoring and non-routine monitoring (i.e., project, responsive, investigative) data is assessed under the facility environmental risk assessment (ERA). Ongoing review of monitoring data may trigger immediate action at site-specific criteria levels under the corrective action program. Review of data as part of the ERA may trigger action to implement a systemic change to the environmental program, including monitoring or preventative action.

At Cameco’s mines, engineered containment facilities are utilized for the storage of materials such as waste rock, ore, tailings, contaminated water, treated water, tanks and pipelines. These facilities in general are constructed of a low permeability material (e.g., HDPE liner, concrete, and bentonite) and have a drainage collection system to contain potential leakage. This low permeability containment allows for the safe storage of solid and liquid wastes and minimizes the release of contaminated water entering the environment. These facilities are regularly inspected and maintained to ensure they continue to function as designed. Unplanned releases are not a common occurrence and are of low environmental risk and consequence. Environmental monitoring related to the facility operating licence is generally performed by site employees or qualified contractors. Community based monitoring programs in northern Saskatchewan are managed by qualified contractors, with assistance from community members.

Orano’s facilities are well designed with respect to operational performance, in order to mitigate unplanned releases and protect the environment; typically, unplanned releases are a result of spills or accidents. The number of annual occurrences remains low, and these are of low risk and consequence. Identification of cause is typically equipment malfunction or training. To date, these incidents are responded to effectively to maintain protective of the environment and human health. Site facility employees conduct the monitoring. Facilities are also subject to monitoring conducted by uranium industry and environmental protection regulators; auditors and community programs.

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Article 32.2.4

D/ p. 51; Annex 5/p. 257, 262

How long do you plan to store spent resins? Do you intend to condition stored spent resins and if yes, to which final form?

At Ontario Power Generation facilities, spent resins will remain in interim storage at the Western Waste Management Facility until a final repository is established and in service (expected 2045). Options for conditioning of spent resins are currently being evaluated; however, a final technology determination has not been made. A decision is expected by the end of 2022.

Since the release of this report, the resins from the Canadian Nuclear Laboratories (CNL)-operated Douglas Point and Gentilly-1 sites were removed and processed. For these sites, CNL utilized third-party commercial processing facilities to reduce the volume of wastes, with the resultant residues being shipped to Chalk River Laboratories for interim storage.

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