From Canadian Coalition for Nuclear Responsibility to The Canadian Nuclear Safety Commission re: Comments on the Project Description for the Micro Modular Reactor Project at Chalk River

Comments on Global First Power's Inadequate Project Description for the Micro Modular Nuclear Reactor Project at Chalk River 

To whom it may concern,

The Canadian Coalition for Nuclear Responsibility (CCNR) considers the MMR 'project description’ to be totally inadequate, as it does not address in any meaningful way the decommissioning of the facility at the end of its useful lifetime, nor the ultimate disposition of the various waste streams. It also fails to discuss the behaviour of the core under any specific accident scenarios.

The proposed reactor will generate post-fission radioactive wastes of all kinds, from high-level waste (irradiated nuclear fuel) to a wide variety of low and intermediate level wastes. All of these waste streams will involve many varieties of human-made radioactive poisons including fission products (like radioactive cesium, radioactive iodine, and radioactive strontium) and/or transuranic actinides (like plutonium, americium, neptunium and curium) and/or activation products (like tritium, carbon-14, radioactive varieties of iron and nickel isotopes, and many more).  

Since the proposed reactor is intended to serve as a prototype for eventual deployment in many isolated locations in Canada, the details of dismantling the radioactive structure, protecting the workers, preventing the spread of long-lived radioactive dust (i.e. particulates of carbon-14 and/or alpha-emitting plutonium and other actinides) in the community, as well as packaging the wastes and shipping them off-site, must all be spelled out.  In particular what roadway or railbed requirements will be required to accommodate the transport of massive spent fuel flasks over great distances to some final repository?

The anticipated time delay between permanent shut-down and final decommissioning must be spelled out, along with anticipated measures to monitor and protect the radioactive structure in the interim.  Alternatively, the proponent must indicate any intention it may have of following the highly contentious option of “in-situ” decommissioning -- an approach that is currently envisioned for the NPD and WR-1 reactors, despite very explicit warnings from the IAEA not to utilize such a procedure except in extreme circumstances.

The CCNR concludes that the bottom line is this: a full environmental assessment of this project is required, and it must be based on a much more detailed project description. Science is not a matter of wishful thinking, and environmental assessments cannot be replaced with untested assumptions, no matter how ardently they may be espoused by the proponents or by the regulatory staff.

It must be borne in mind that there have been a number of serious nuclear accidents involving small reactors (such as the NRX accident in 1952 and the Lucens reactor accident in Switzerland in 1969) where significant long-term contamination of the surroundings has occurred. It is entirely inappropriate for CNSC or the proponent’s sponsors to prejudge the environmental case without a full public examionation of the potential that exists for long-term contamination of the local environment, whether that local environment is at Chalk River or at some as yet unidentified remote northern community.

Due to some rather serious computer problems that I have been experiencing in recent weeks,I have been unable to save and send the CCNR submission before the midnight September 14 deadline.  Accordingly I will send it in the next couple of hours after the deadline in hopes that CNSC will still accept those comments as part of the public record.

The CCNR submission provides more deatils on the points mentioned above and other aspects of the project.

Yours very truly,

Gordon Edwards, PhD, President,

Canadian Coalition for Nuclear Responsibility.