Mémoire présenté lors de l’audience de la commission d’examen conjoint sur le dépôt en formations géologiques profondes proposé par OPG

Mémoire présenté par Heather Kleb, présidente et chef de la direction par intérim, Association nucléaire canadienne
lors de l’audience de la commission d’examen conjoint sur le dépôt en formations géologiques profondes proposé par OPG
le 20 septembre 2013

Good afternoon. My name is Heather Kleb. I am the president and CEO of the Canadian Nuclear Association, and I am here today to support OPG’s application. Also here with me today is our Manager of Regulatory Affairs, Peter Poruks. We believe this project is a safe and environmentally sound solution to managing low- and intermediate-level waste in the long-term.

In the next few minutes, I will describe the Canadian Nuclear Association, and elaborate on our reasons for supporting OPG’s application. These include the nature of the waste to be stored at this underground facility.

As well, I will discuss the comparison that was made to some of the alternative storage methods. I will speak to the protection that this project will provide for human health and safety, and the environment. And I will conclude with observations on the nuclear industry’s experience with similar repositories that are in operation elsewhere.

First, a few words about the Canadian Nuclear Association. We represent about 100 organizations, including OPG and Bruce Power. We mine uranium, process it as a fuel source, and use it for a wide range of purposes. We generate electricity. We also enable advanced manufacturers to inspect and improve their finished goods. And we enable better health care through CAT scans and disease treatments.

In all, our industry directly employs about 30,000 Canadians. Our suppliers employ another 30,000 Canadians. We also represent nearly $7 billion of economic activity, generate $1.2 billion in exports, and pay $1.5 billion in taxes.

We are here today because our industry has a strong interest in the proposal before you. This project is the first of its kind in Canada. It deals with our least radioactive waste. Not used nuclear fuel, but rather the protective clothing, tools and rags used in the daily life of a nuclear generating station.

True to the hallmarks of our industry, the Deep Geologic Repository is all about safety and responsibility. OPG has methodically researched, tested and validated its project. It has clearly demonstrated how the project will protect health, safety and the environment. In its approach, OPG has earned the trust and support of the host community, and all the other communities in Bruce County. In some ways, this support is the most important aspect of this project. Canadians who take the time to learn about our technologies often become our greatest supporters. The CNA’s members deeply appreciate this continuing public support.

The proposal before you today finds its roots in the federal government’s policy framework on radioactive waste management set out some 17 years ago. The Framework defines an approach that is safe, environmentally sound, and also comprehensive & integrated. The framework assigns clear roles and responsibilities to government and industry.

Essentially, the framework assigns the government the responsibility to develop policy, to regulate, and to ensure industry compliance. The framework assigns industry the responsibility to fund, manage and operate our waste facilities.

The core idea is that the polluter pays. Canadians understand this intuitively and our industry fully accepts this principle. We take complete responsibility for the full nuclear fuel cycle. We also accept the responsibility for helping the public to understand the risks and benefits of nuclear technology – to understand how we do what we do.

Madam chair, in reviewing certain submissions to your joint panel, as well as the commentary of various interest groups, it is clear that some members of the public have not understood the proposed project. In the interest of helping more Canadians to understand this project, I will describe the waste produced by our industry and the ways in which it is handled.

We take full responsibility for our waste. By this I mean we take every step needed to protect humans and the environment from our waste, and we fully cost this into our products.

How we manage radioactive waste depends on how long it will remain hazardous. The key measure is the half-life of the radioactive atoms, which we call isotopes. Every isotope has a half-life, which is the time it takes for its radioactivity to fall by half. For some isotopes, this half-life is measured in seconds, minutes and hours. The isotopes used in certain types of cancer therapies can have a half-life as little as three days. On the other hand, some isotopes will decay over thousands, millions and even billions of years. Sooner or later, however, all radioactive waste will become harmless. It is simply a matter of time, and entirely predictable.

In Canada we use three categories to describe radioactive waste: low, intermediate and high. Low-level waste is generated from hospitals, laboratories, industry and the nuclear fuel cycle. It includes things like tools, filters, rags and protective clothing. Typically its radioactivity is short-lived. Worldwide, low-level waste represents 90% of our waste volume, but only one percent of all radioactivity in waste. It has a higher volume, but lower threat. It does not require special shielding, but it does need to be handled with more care than ordinary garbage.

OPG manages this waste from all three of Ontario’s nuclear generating stations. It gathers this waste at the Western Waste Management Facility, located at the Bruce Nuclear Generating Station. To reduce the volume of waste, OPG burns it, or compresses it, and stores it securely in concrete warehouses. You can see one of these buildings at the bottom of this slide.

Next we have intermediate-level waste. Typically this includes components found in reactors, such as the ion-exchange resins that we show in the picture at the bottom left of this slide. These are small beads used to minimize corrosion and remove radioactive contamination. We replace these periodically, along with filters and other components. These materials are more radioactive than our low-level waste. They must be shielded when they are removed.

Shielding simply means having something that will absorb radiation between you and the source of the radiation. The amount of shielding required to protect against different kinds of radiation depends on how much energy they have. Lead and water are common materials used for shielding. However depending on the type of radiation concerned, paper, or even dead skin cells, act as an effective shield.

Worldwide, intermediate level waste makes up seven percent of our radioactive waste by volume, and four percent by radioactivity.

Lastly we have high-level waste, which really means used nuclear fuel. It is highly radioactive, and thermally hot, so it needs cooling and shielding. Even though it comes out of the reactor in this condition, it is worth noting that radioactive decay steadily reduces the threat to humans and the environment. In fact, within 10 years, spent fuel loses 99.9% of its radioactivity. It is true that the remaining 0.1% of radioactivity will take a long time to disappear. But the point to remember is that most of the radioactive threat has disappeared, and the spent fuel is very much easier to handle.

Around the world, high-level waste represents just three percent of our waste volume but 95% of our waste radioactivity. It is obviously very different from the low- and intermediate-level waste that I described earlier.

Madam chair, this is a very important point that needs to be clearly understood in evaluating this proposal. OPG has not proposed to store any high-level waste in this repository. I am aware that this has been suggested by the project’s critics. But the fact is that OPG simply could not place used nuclear fuel into this repository. It would need a specific assessment and licence to do that. The licence that OPG seeks from this process will specifically exclude high-level waste.

A separate process is underway for used nuclear fuel management. Eventually there will be a proposal, and another assessment process much like this one. The public will see this process, and have its say. The location for this future proposal will be selected from over 20 different sites across Canada.

Madam chair, public acceptance lies at the heart of this review process. Looking back, it has been 12 years since the municipality of Kincardine approached OPG to propose a joint waste-management study for the Bruce site.

With the signing of a Memorandum of Understanding in 2002, the process got underway. This included a review of the technical feasibility, a socio-economic impact assessment, and a review of long-term waste management models used in the United States and Europe.

There were three options. The first was termed “enhanced processing, treatment and long-term storage.” This option resembled the facilities used in Belgium and the Netherlands. The second was a covered concrete vault at ground level. The third, a vault buried deep in rock, like the facilities in Sweden and Finland. A study conducted by independent engineering experts found all three were technically feasible. All three could be built. All three would meet Canadian safety standards easily. All three would deliver significant economic benefits, including jobs.

Given these three choices, the Kincardine municipal council voted in 2004 for the deep rock option. Their resolution considered this option the safest of the three safe options. Neighbouring communities also supported the project, including Saugeen Shores, Brockton, Huron-Kinloss, Aaron-Elderslie, South Bruce and Bruce County Council. Then Kincardine and OPG negotiated a Hosting Agreement.

Of the Hosting Agreement’s many elements, three stand out in particular. First, the repository would not store spent fuel. Second, OPG would guarantee the value of all properties so that no Kincardine property owner would ever suffer an economic loss resulting from radioactive contamination of property. Third, Kincardine council agreed to seek endorsement of this project from its residents.

The question was put to those residents by an independent opinion research firm. The question, as shown on this slide, was clear. The opinion firm sought out every adult resident, in the case of permanent residents, by phone, and in the case of seasonal residents, by letter. It heard from 71% of residents and found them favouring the project by a margin of nearly three to one.

With the people of Kincardine now on board, the project moved ahead into the regulatory approvals process. This included a comprehensive assessment of the repository’s effects on health, safety and the environment.

Over the course of four years, OPG carried out geophysical surveys, a drilling program, field tests and laboratory analysis. The results appear in the Environmental Impact Statement and the Preliminary Safety Report submitted to you in 2011.

The results were clear. Any radiation emitted by the project will be negligible. The repository will not harm water quality, and it will withstand a range of abnormal events. I will discuss each of these in turn.

First, radiation. It is normal for people to be alarmed by the risk of radiation, given that health effects can rise directly with the intensity and duration of exposure. Our industry works with radiation, and understands it very well. We operate within limits established by the regulator and work to do better than these limits. These limits are set very low, so that we ensure the safety of our workforce and the nearby population.

Radiation at the repository will be well below these thresholds. Only 5% of the contents will be intermediate-level waste, requiring shielding when handled. The remaining 95 % will be low-level waste, which can be handled with minimum protection. Radiation doses to workers and the public will be well below the regulated limits.

Imagine for a moment that a family somehow managed to set up house right on top of the repository. The potential radiation dose would be incredibly weak. In fact, background radiation, which includes sunshine, would be about 20-thousand times more powerful. The bottom line: the radiation risk is negligible.

The studies also included an assessment of the risks posed by malfunctions, accidents, and malevolent events. The assessment covered everything that could be imagined — fires, explosions, airplane crashes, accidents deep underground. Add to that earthquakes, new ice ages like the nine glaciations the site has already experienced, and the effect of a meteor directly hitting the repository’s entrance.

Even in these most extreme scenarios, radiation would remain well below background levels. This would remain true looking forward one million years. The bottom line: the repository is safe.

Environmental protection will also be assured. Much of the commentary about this project has focused on water, both at the tap and in the Great Lakes. Many people have asked what would happen if radiation from deep below ground were somehow to reach the water at or near the Earth’s surface. The simple reality is that the site’s geological features will virtually eliminate this risk. Consider the fact that drinking water in this area comes from wells drilled to a depth of about 100 m. Radioactive waste will be stored at around 680 m below the surface, in a geological formation completely separate from the surface.

To pose a threat, the radiation would need to climb nearly 600 m. The bedrock that would house the repository is inherently stable. For example, the water found in the Coburg Formation limestone is hundreds of millions of years old. It has never mixed with the waters at the surface.

What about the risk that contamination would reach Lake Huron? Not only is the repository 680 m below the surface, but it is also about 1 km inland from the lake. It is completely isolated from the lake by the surrounding limestone, and by the layers of shale found between the repository and the surface.

The limestone is rich in clay, through which radionuclides cannot travel. Directly above this protective limestone, we find a layer of shale 200 m thick, formed about 450 million years ago. Above that, another layer of shale 270 metres thick, formed about 425 million years ago. At the surface, we find yet another dense layer of glacial till. These geologic formations have been in existence for millions of years and will be there for many millions more.

Even if radioactive chemical elements could penetrate these multiple protective layers, the nature of the rock means the journey would take hundreds of thousands of years. And, returning to a point I made earlier, radiation decays over time. By the time that these chemical elements would hypothetically reach the surface, their radioactivity would be well within the safety limits. The bottom line: the quality of water in the Great Lakes, and in the drinking wells of Bruce County, will not be affected.

It could be argued, I suppose, that these assessments have all been carried out on a repository that does not exist. Recognizing that argument, OPG carried out significant research on the repositories that do exist in the United States and Europe.

In the United States, the Waste Isolation Pilot Plant in New Mexico houses intermediate-level waste. Like OPG’s proposed repository, the New Mexico site is located in sedimentary geology at a similar depth. Since beginning operations in 1999, the Waste Isolation Pilot Plant has operated safely and twice been recertified by the U.S. Environmental Protection Agency.

Similarly, the Forsmark facility in Sweden has been managing low- and intermediate-level waste safely since 1988. And the Olkiluoto facility in Finland has also managed low- and intermediate-level waste safely since 1992.

This front-line research, plus numerous other studies, are summarized in OPG’s Safety Assessment. This document has been reviewed by international experts from Belgium, France, Switzerland and the United Kingdom. All of these experts had considerable experience with low- and intermediate-level waste. All concurred with OPG’s proposed approach. Their conclusions, coupled with the experience of operating the three repositories that I have described, all confirm the bottom line: The proposed repository is technically proven, and safe.

The repository will not only protect the environment, and humans, but it will also contribute further to the quality of life here in Kincardine. I read with amusement an article in a Michigan newspaper last month that described this community as, I quote, “dirt poor.” Looking around, the reality is quite different. Kincardine and its neighbours have prospered from the operation of the Bruce Nuclear Generating Station and the Western Waste Management Facility.

The proposed repository will bring further benefits, including a guaranteed, inflation-protected $35 million dollars committed in 2004. In addition, OPG will spend some $800 million to build and operate the repository. A significant proportion of that amount will be spent in Bruce County. This means more jobs, both in building the repository and operating it for many years.

The bottom line: Kincardine and its neighbours already form a centre of nuclear excellence. The repository will only improve this high standing.

Madam chair, you and your colleagues have heard a great deal of evidence this week, and you will hear much more in the weeks that follow. As you continue your work, I would urge you to keep these three points in mind.

OPG’s proposed project is a safe solution to managing low- and intermediate- level waste. It is also a project that respects the environment. And, thirdly, it is a project that carries the support of local elected representatives, and the local population.

OPG has risen to the challenge to define a long-term storage solution, and proposed an innovative project that is supported by Canada’s nuclear industry.

That concludes my formal presentation. I’d be pleased to take your questions.