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. Commentary on selected background papers commissioned by the Nuclear Waste
Management Organization (NWMO): July, 2004

Several of these papers taken together provide a strong rationale for
continued storage of nuclear waste at the reactor sites along with
heightened security and research into transmutation technologies.

Background Paper: 6-1 Technical Methods: Status of Reactor Site Storage
Systems for Used Nuclear Fuel, by SENES Consultants Limited

24 pages plus appendices

This is a descriptive paper which summarizes the methods used for the
storage of irradiated fuel at commercial Canadian nuclear power sites in
Canada. It includes an appendix which provides a handy list of 39 world-wide
web site locations which contain information about the on-site storage of
nuclear waste around the globe.

One of its main conclusions is that the dry storage facilities of irradiated
fuel at Canada's nuclear power sites currently have a design life of 50
years and that "...the actual life of dry storage containers is thought to
be 100 years or more." It goes on to state that "...in the event that
centralized facilities for the management of used fuel are not available on
a timely basis, extended use of dry storage would provide a reliable method
of managing used fuel in the longer term. In such an event, regulatory and
environmental issues would need to be revisited."

In my view, although predictions about the length of time into the future
that dry storage facilities would remain "reliable," are somewhat
speculative, given proper monitoring and security measures, perhaps a fairly
long-term containment is possible. Unfortunately, the paper did not discuss
the adaptation of a surface dry storage facility to a near-surface one,
hardened to the point where it could withstand most terrorist attack
scenarios.

Like other papers on this subject, I am not comforted by the bland
regulatory descriptions of wet or dry storage security arrangements, systems
and procedures. "Local police," and "security staff," etc. would be of
little value in the event of a major security breech of these containment
structures. Let there be no doubt that these installations could well become
very high-priority terrorism targets, throughout North America and
especially anywhere near the Great Lakes.

However, this paper does reinforce my own view of the need for a Government
of Canada policy decision to continue to improve the on-reactor-site storage
system.

The paper also reinforces my view of the need for a full-scale environmental
assessment of the various options provided for in the legislation, or any
other option being seriously considered.

This paper, when considered along with the following one (which analyses the
potential options for management of nuclear fuel waste), gives added
strength to adoption of extended on-reactor-site-storage.

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Background Paper: 6.5 Technical Methods: Range of Potential Options for the
Long-Term Management of Used Nuclear Fuel, by Phil Richardson & Marion Hill,
Enviros Consulting

38 pages

This paper examines no less than 16 options for the long-term management of
nuclear waste. It includes brief descriptions of each option along with a
short summary of "assessments" of each option.

Also included are the criteria used for these assessments, i.e.,
environmental, technical, economic and specific social and ethical
considerations. Other criteria identified as "not used" deal with
sustainability, intergenerational equity, general ethical considerations and
public acceptability. The authors provide their reasons for these criteria
omissions.

Based on the results of published assessments of these options, the authors
placed them into three categories: Those of considerable interest, those of
some interest and those of very little interest.

Three options appear in the "considerable interest" category and they are:
above ground storage, underground storage and underground "disposal." As
opposed to "storage," disposal is generally defined here as "permanent," wit
"... no intention to retrieve the waste..."

In it's descriptions of the options, using it's restricted set of criteria,
this paper leans heavily in the direction of so-called underground "disposal
It tends to measure a number of the other options against the "disposal"
option in it's assessment statements and always winds up with "disposal" as
the winner. The technical argument for this option is given more weight
because it is favoured by many other countries and international agencies.
That particular viewpoint has become something of a "mantra" which we have
been hearing since the late 1970's.

No reference is made in this assessment to the fact that various technical
problems associated with Atomic Energy of Canada's underground burial concep
were identified by the Federal Environmental Review Panel during it's length
assessment process.

The authors state that the partitioning and transmutation (P&T) option was
placed in the "some interest," rather than in the "considerable interest"
category because "it is not a complete management option for used fuel and
could not be implemented soon." I personally surveyed the considerable
progress in accelerator transmutation of nuclear waste and found that some o
the key scientists involved considered that the technology could provide a
complete management option for used fuel.

However, this paper does state that "It is recognized internationally that t
possibility that P&T could become a readily available and very attractive
treatment option in several decades time (emphasis supplied), could be a
reason for choosing storage rather than disposal."

But why not go further. If on-site dry storage is suitable for 50 to 100 yea
as stated in the previous discussion paper, there should be plenty of time t
research and develop an appropriate transmutation option designed specifical
for the destruction of nuclear waste. What is needed is political will along
with the phase out of the formidable vested interests in the underground
burial option.

Walter Robbins
July, 2004

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