Evaluation of the Nuclear Legacy Liabilities Program (NLLP) of the Energy Sector, Natural Resources Canada

Reports 2011


Evaluation of the Nuclear Legacy Liabilities Program (NLLP) of the Energy Sector, Natural Resources Canada

Table of Contents


EXECUTIVE SUMMARY AND RECOMMENDATIONS

Introduction

This report presents the main findings of an evaluation of the delivery of the Nuclear Legacy Liabilities Program (NLLP). The objectives of the evaluation were to assess the relevance, performance, economy and efficiency of the NLLP sub-sub-activity.

The Nuclear Legacy Liabilities Program is contained in the Natural Resources Canada (NRCan) Program Activity Architecture (PAA), sub-activity 2.2.4, Radioactive Waste Management. The expected result for this sub-activity is "improved waste management practices meet modern day standards for safety and environmental protection."Footnote 1 The PAA performance indicator for this expected result is "progress on contaminated site cleanups and progress on the development of long-term waste management approaches."Footnote 2

The objective of the NLLP is to safely and cost-effectively reduce the nuclear legacy liabilities and associated risks based on sound waste management and environmental principles in the best interests of Canadians. The NLLP is part of a long-term 70-year strategy to deal with nuclear legacy liabilities which fall under the responsibility of the Government of Canada (GoC). The NLLP was initiated in 2006-07 with a five-year, $520 million plan, and is being implemented through a Memorandum of Understanding (MOU) between NRCan and Atomic Energy of Canada Limited (AECL). Under the MOU, NRCan is responsible for policy direction and oversight, including control of funding, and AECL is responsible for implementing the workFootnote 3 and, as the site licensee, is responsible for ensuring that all regulatory requirements are fully met.Footnote 4

Program Background

The Nuclear Industry in Canada

Nuclear energy currently provides around 15% of Canada's total electricity needs (over 50% in Ontario). The industry contributes to the Government's climate change and other atmospheric emissions reduction objectives since it is virtually an emissions-free electricity source. In Canada, it has been estimated that between 40 and 90 million tons of greenhouse gas (GHG) emissions are avoided annually through the use of nuclear power (assuming that the electricity would otherwise be generated by natural gas or coal, respectively).Footnote 5

The Canadian nuclear industry is comprised of approximately 150 companies that supply products and/or services to AECL and the utilities, concentrated in Ontario, and to a lesser extent in Saskatchewan, Quebec and New Brunswick. Annual employment (direct and indirect) associated with the nuclear industry in Canada is approximately 30,000 (an estimated 40,000 are believed to be generated through spin-offs).Footnote 6

The industry generates revenues of around $6.8 billion per annum, including: nuclear electricity produced (which represents about $5 billion per annum), export sales (including CANDU equipment/service exports [$500 million]), uranium ($1 billion), and medical and industrial isotopes and related equipment ($300 million). These figures do not take into account health (e.g., medical) and environmental aspects of nuclear technology.Footnote 7

Canada is one of the world's largest producers of uranium. Mining and milling of uranium is a $1 billion-a-year industry that directly employs over 1,000 Canadians. Canadian uranium is used in commercial nuclear power plants world wide to produce electricity, including Canadian-built CANDU (CANadian Deuterium Uranium) reactors which currently supply about 15% of Canada's electricity.Footnote 8

Federal and provincial tax revenues derived from the nuclear industry amount to approximately $1.5 billion annually.Footnote 9

Radioactive Waste and Legacy Liabilities

Radioactive waste is generated in Canada by uranium mining, milling, refining and conversion as well as nuclear fuel fabrication, nuclear reactor operations, nuclear research, and radioisotope manufacture and use. The first radium mine in Canada began operating at Port Radium in the Northwest Territories in the 1930s. Radium was refined for medical use and uranium was later processed in Port Hope, Ontario. Research and development on the application of nuclear energy to produce electricity began in the 1940s at the Chalk River Laboratories (CRL) of AECL.Footnote 10

More than half of the nuclear legacy liabilities under the responsibility of the GoC and addressed by the NLLP are the result of Cold War activities during the 1940s, 50s and early 60s. The remaining liabilities stem from R&D for nuclear reactor technology, the production of medical isotopes, and national science programsFootnote 11 carried out on behalf of the GoC by the National Research Council (NRC) (1944 to 1952) and AECL (1952 to present). Estimated at about $7 billion (current day dollars), these liabilities consist of buildings, a wide variety of buried and stored waste and affected lands.

Shutdown buildings and affected lands need to be safely decommissioned or remediated as required to meet federal regulatory requirements, and long-term solutions need to be developed and implemented for the waste.

Radioactive waste is currently managed by storing the waste in compliance with the requirements of the Canadian Nuclear Safety Commission (CNSC).Footnote 12

Canada's Radioactive Waste Policy Framework is comprised of principles governing the institutional and financial arrangements for the long-term management of radioactive waste by waste producers and owners. Under this framework, the federal government is responsible for ensuring that radioactive waste management is conducted in a safe, environmentally-sound, comprehensive, cost-effective and integrated manner. The Framework obligates the federal government to develop policy, to regulate, and to oversee producers and owners to ensure that they comply with legal requirements and meet their funding and operational responsibilities in accordance with approved waste management plans.Footnote 13

In turn, the waste producers and owners are responsible, in accordance with the principle of "polluter pays", for the funding, organization, management and operation of the facilities required for their waste. The Framework recognizes that arrangements may vary across the categories of nuclear fuel waste, low-level and intermediate-level radioactive waste, and uranium mine and mill tailings.Footnote 14

In April 2006, the federal government approved a long-term 70-year strategy to deal with nuclear legacy liabilities and a five-year plan to initiate the strategy, as well as authorizing the Minister of Natural Resources to consult the public on the further development of the long-term strategy. After five years, authorization was to be sought for the revised/refined long-term strategy as well as implementation of its next phase. The revisions to the long-term strategy were to take into account feedback received during public consultations, which initial NLLP documentation estimated would start in late 2006 or early 2007.Footnote 15

The Nuclear Legacy Liabilities Program (NLLP)

On June 2, 2006 an announcement was made that the GoC had committed $520 million to fund the five-year start-up phase of the NLLP.Footnote 16 The objective of the Program is to safely and cost-effectively reduce the nuclear legacy liabilities and associated risks based on sound waste management and environmental principles in the best interests of Canadians.Footnote 17 As Crown agents generated these legacy liabilities over many years while delivering government-driven and/or sponsored experimentation in a context of evolving regulatory standards, the GoC has a clear responsibility for dealing with the nuclear legacy liabilities.

The five-year start-up phase, 2006-07 through 2010-11, is directed at addressing health, safety, and environmental priorities, accelerating the decontamination and demolition of shutdown buildings, laying the groundwork for subsequent phases of the strategy, and continuing necessary care and maintenance activities. During the start-up phase, the long-term strategy was to be further developed and refined. Public consultations were to be conducted to inform the work (i.e., further development of the long-term strategy) as well as the decisions on the next phase of the strategy.Footnote 18

The NLLP waste liabilities are distributed on various AECL sites approximately as follows:

  • 70% Chalk River Laboratories (CRL), Chalk River, Ontario;
  • 20% Whiteshell Laboratories (WL), Pinawa, Manitoba; and
  • 10% at the three prototype power sites, in Ontario and Quebec: Footnote 19
    • Douglas Point, near Kincardine, Ontario;
    • Nuclear Power Demonstration, Rolphton, Ontario; and
    • Gentilly-1 at the Gentilly Nuclear Generating Station (near Bécancour, Québec).Footnote 20

Other AECL buildings and properties that are part of the NLLP are the shutdown heavy water plant sites at LaPrade, Québec; and Glace Bay, Nova Scotia.

AECL is the implementing agency for the NLLP, and NRCan is responsible for setting policy direction and providing oversight of the NLLP, including control of funding.

Multiple project milestones (161) were established at the beginning of the project and were identified in the program resourcing proposal authorizing the program spending.Footnote 21

The Canadian Nuclear Safety Commission (CNSC), which reports to Parliament through the Minister of Natural Resources, is the regulatory authority for the peaceful use of nuclear energy. It operates under the authority of the Nuclear Safety and Control Act (NSCA). The NSCA provides the CNSC with a range of authorities/powers, including:

  • making regulations;
  • issuing licences;
  • including any condition in licences; and
  • revoking, suspending, amending, replacing, or renewing any licence (following proper procedure).Footnote 22

Licences, certifications and authorizations serve as forms of permission. Most of the permissions issued by the CNSC are in the form of licences. Obtaining a licence requires the CNSC to be satisfied that, among other things, the applicant will make adequate provision for protection of the environment, the health and safety of persons, and the maintenance of national security and measures to implement international obligations to which Canada has agreed.Footnote 23

AECL holds a number of licences issued by the CNSC.

Evaluation Methodology

The time frame encompassed by this evaluation is 2006-07 to 2008-09. The following techniques were utilized:

  • document and literature review (45 documents): some of the documents reviewed are more recent (e.g., 2009 and 2010) than the scope of the evaluation as the explanatory material was not readily available elsewhere;
  • key informant interviews with NRCan, AECL, Office of the Auditor General (OAG) and CNSC representatives, as well as subcontractors (n=60);
  • case studies (5) of selected NLLP projects/sub-programs, including the following:
    • CRL Liquid Waste Transfer and Storage (LWTS) (project);
    • CRL Environmental Remediation (sub-program);
    • CRL Fuel Packaging and Storage (FPS) (project);
    • CRL Shutdown of Facilities (sub-program); and
    • Decommissioning of the Whiteshell Site (sub-program).

An independent nuclear decommissioning expert advisor was involved in all phases of the evaluation. The evaluation was restricted to AECL's CRL and WL.

Evaluation Findings

Relevance

Evidence gathered for this evaluation indicates that there is an environmental and regulatory need for the NLLP. Various structures and areas at the CRL and WL sites presented environmental as well as health and safety issues. These include contaminated buildings and land, as well as waste storage structures that need replacement due to corrosion. Cleanup work is required as a licence condition by the regulator (CNSC).

The Program is consistent with and supports federal government priorities, roles and responsibilities as well as NRCan strategic objectives. The waste and contamination situation is a recognized liability that appears in the Public Accounts of CanadaFootnote 24 and AECL's balance sheet. The literature review indicated that the trend around the world was to accelerate decommissioning work, in recognition of the fact that delaying work was not cost-effective and placed a burden on future generations.Footnote 25

The evaluation found that there was a recognized need for NRCan to enhance its oversight role for the NLLP, which included the oversight of funds spent.

Performance

There is general agreement (from all lines of evidence) that the NLLP work is behind schedule and over budget. Work involving roughly two-thirds of the NLLP milestones is expected to be completed by the end of the five-year funding period. However, assessing the progress of NLLP tasks using the NLLP milestones should be carried out with caution due to the significant variation in the milestones' importance, scope and size. Further, significant components of the program, in particular care and maintenance activities, are not covered by milestones.

Performance in this report is summarized according to the NLLP resourcing proposal for the first five years of the NLLP which included:

  1. a five-year technical program of work to:
    1. address health, safety and environmental priorities;
    2. accelerate the decommissioning of shutdown buildings and the remediation of affected lands;
    3. lay the groundwork for future phases of the long-term strategy; and
    4. continuing necessary care and maintenance activities to maintain the liabilities in a safe state until they can be fully addressed in subsequent phases of the Program;
  2. further development of the long-term 70-year strategy to deal with the nuclear legacy liabilities, including public consultation; and
  3. a management and accountability framework and a project management framework.Footnote 26

A. Five-Year Program of Work

1. Address health, safety and environmental priorities

In terms of addressing health, safety and environmental priorities, the following projects are examples of work underway at CRL:

  • Liquid Waste Transfer and Storage (LWTS) Project;
  • Environmental Remediation; and
  • Fuel Packaging and Storage (FPS) Project.

In spite of the delays in implementation, many of the higher-risk health, safety and environmental issues at CRL are being addressed.

2. Accelerate the decommissioning of shutdown buildings and the remediation of affected lands

In terms of accelerating the decommissioning of shutdown buildings, various sizeable CRL and WL buildings have been decontaminated and demolished. The buildings removed over the first three years had a total footprint (surface of main floor) of more than 6,500 square meters.

Examples of decommissioning include the removal of Building 107, the former CRL Radiochemistry Laboratory, and the creation of a firebreak at CRL for the NRX Reactor, for which Buildings 133, 144 and part of Building 204 (a 1950s fuel reprocessing building) were demolished. Further, the former CRL Plant Hospital (Building 464) was decommissioned and the site was released for redevelopment ahead of schedule.

WL adopted an accelerated decommissioning schedule in 2007; much progress has been made since that time. An example of an important project is the ongoing reconfiguration of the site's utility system. This is considered to be important because it is projected to reduce annual heating costs (through conversion to electric heating) by about $600,000 by 2012.Footnote 27 Furthermore, since 2006, the following achievements have been realized:

  • decommissioning of many of the non-nuclear redundant buildings on the main campus;
  • decommissioning of much of the redundant equipment and former experimental areas in the Shielded Facilities; and
  • decontaminating about one hundred laboratory rooms in the main nuclear research laboratory complex (Building 300), including the removal of furnishings and services.

Under the current decommissioning schedule for WL, it is estimated that it will take at least 20 years to complete the work.

Without the funding provided by the NLLP, the decommissioning activities would have been much more limited in terms of size and scope at both CRL and WL.

3. Lay the groundwork for future phases of the long-term strategy

The NLLP has undertaken much of the preparatory work for activities in upcoming phases:

  • interviewees advised that AECL was developing its next five-year plan as well as revising the Comprehensive Preliminary Decommissioning Plan (CPDP) for CRL;
  • new waste clearance facilities have been commissioned at CRL and WL;
  • a Waste Handling Facility has been established in the WL Shielded Facilities to process radioactive waste from decommissioning activities;
  • new waste management facilities to store high-level radioactive liquid wastes and used research reactor fuels were designed;
  • higher-level radioactive wastes buried in CRL Waste Management Areas (WMAs) were retrieved and remediated;
  • at WL, obtaining a CNSC license for a SMAGS (Shielded Modular Above Ground Storage) unit; and
  • many of the buildings and areas to be decommissioned at both WL and CRL are in a state of storage with surveillance as well as the three prototype reactor demonstration facilities (Rolphton, Douglas Point and Gentilly-1).

4. Continuing necessary care and maintenance activities

The NLLP resourcing proposal recognized that required care and maintenance activities, such as monitoring on-going discharges from buried wastes and maintaining shutdown buildings until they were decontaminated and demolished, would have to continue.

Examples of care and maintenance activitiesFootnote 28 include:

  • Storage with Surveillance (SWS), which at WL includes common services (heat, light, power, infrastructure operation and maintenance), nuclear operations services (design, engineering and construction support), radiation protection and compliance services, protective services (security, fire protection), grants in lieu of taxes to the local municipality, and environmental assessment follow-up activities. At CRL this includes storage with surveillance activities associated with shutdown buildings and facilities, legacy stored liquid wastes, legacy lands and dormant WMAs; and
  • Groundwater monitoring program for the CRL WMAs, legacy pits and pipeline routes, contaminant plumesFootnote 29 emanating from the WMAs, and legacy contaminant plumes in the inner laboratory area, including required updates to plume maps; and storage with surveillance activities related to the three shutdown prototype reactor demonstration facilities (i.e., the nuclear Power Demonstration (NPD) in Rolphton, Ontario; the Douglas Point reactor near Kincardine, Ontario; and the Gentilly-1 reactor in Bécancour, Québec.

5. Carry out public consultations to inform this work and decisions on the next phase

In-person public consultations were to be held to relay information and facilitate dialogue on issues. Public consultations to be conducted by NRCan were delayed until spring 2010. Most stakeholders, including government and the communities, agreed that consultations, had they been held earlier, would not have been timely considering the level of development of the long-term strategy, and overarching issues at CRL, including the issues regarding the National Research Universal (NRU) reactor and isotope production.

AECL senior management has noted that as the licensee, AECL is required to regularly inform and consult with the public on its activities and projects. AECL has included updates on NLLP projects and activities in its regularly scheduled meetings with local community officials and stakeholders, and has held public consultations for major projects as required through the CEAA process.Footnote 30

Costs

Actual costs of the NLLP decommissioning work are generally higher than estimated. Factors explaining the increased costs include: inadequate waste characterizationFootnote 31 information, lack of reliable site/building information, inadequate cost-estimates (for example, the original contingency estimates were too low), contracting practices, weak cost-estimating and risk assessment capacity, and a general initial reticence to obtain expertise from sources external to AECL for activities related to the NLLP.

Since the NLLP began, major efforts have been undertaken by AECL to improve this situation, such as: conducting characterization work and feasibility studies before proceeding with individual NLLP projects, increased reliance on information and expertise available from sources external to AECL, improved planning and reporting processes integrating risk considerations, and the engagement of new staff with international experience.

The evaluation findings indicate that several factors negatively impacted the delivery of NLLP tasks:

  • The technical difficulties and the time required to increase human resource (HR) capacity to meet program milestones were underestimated.
  • AECL experienced difficulties caused by a lack of HR capacity to undertake the work. This was exacerbated by staff turnover and the fact that some types of expertise, such as health physicists, were in short supply.
  • At the CRL site, ongoing operations carried out concurrently with the decommissioning work posed significant challenges to coordination, often delaying the release of buildings for decommissioning, and diverting staff to operational priorities.
  • There were additional and changing regulatory requirements and uncertainty in their implementation as well as turnover in CNSC staff.
  • There was a general initial (first four years of the program) reticence to obtain expertise external to AECL (e.g., regarding planning practices, best available technologies, etc.). However, improvements have been made in the last two years,
  • There was a lack of experience on the part of AECL and CNSC staff with respect to processes and decisions involved in the complex NLLP.
Project Management Approach

AECL's project management approach, including decommissioning work, is based on contracts that AECL's Liability Management Unit (LMU) establishes with internal AECL suppliers (lead suppliers). The internal suppliers must provide monthly progress reports to the LMU, which is the AECL organizational unit created to manage the NLLP program. The LMU oversees the AECL decommissioning projects and, in turn, reports to NRCan on overall performance. While all major design-build projects over $1 million are managed by the Research and Technology Operations Projects Group (RTOP) using the Primavera software, projects with smaller budgets are managed by individual suppliers, and project management procedures vary according to the type and size of projects (rather than, for example, technological risk).

While individual projects are tracked closely, AECL does not have an integrated system for managing overall cost and time resource expenditures of all NLLP projects against a master schedule and budget. As a result, for example, it is difficult to discern what percentage of the planned projects has been completed compared to the budget.

Although AECL and NRCan agreed that the work should be conducted using a blend of internal and external resources, and despite the fact that the use of subcontractors had increased since 2006, a number of interviewees from both AECL and NRCan agreed that there was still not enough use of subcontractors. The evaluation found that there were still some problem areas with subcontractor management at AECL, including oversight of procurement and project management, especially at the CRL site.

Current prioritization processes are risk-based to some extent, and AECL has developed a form of risk assessments for all of its projects. However, there is no system for quantitatively assessing the risk of time and cost overruns, as part of the planning process for either individual projects, or for the NLLP as a whole. It should be noted that the term 'risk' has multiple dimensions. In the case of this finding, the 'risk' referred to is a planning term applied to nuclear decommissioning, as is carried out by other countries and businesses dealing with nuclear waste, and encompasses project management risk (e.g., funding, contingency), technological risk, environmental risk, and health and safety risks.Footnote 32

The CNSC indicated concerns that the three other demonstration reactors (Gentilly-1, NPD and Douglas Point) currently awaiting decommissioning under the NLLP were physically deteriorating because of the concentration of resources on CRL and WL.Footnote 33

Storage with surveillance plans approved by the CNSC are in effect at these facilities. Any non-conformances, identified by either AECL or the CNSC, are addressed.

AECL and NRCan consider their current working relationship to be cordial and effective. NRCan NLLP staff have been monitoring the implementation of the NLLP closely and have a good understanding of the technologies, processes and decisions involved (this is facilitated by the fact that some of the NRCan NLLP staff are former AECL and CNSC employees).

Governance and Planning

Quarterly and annual reports, as well as annual plans, are provided to the Joint Oversight CommitteeFootnote 34 (JOC) by AECL. Some AECL managers expressed the view that NRCan asked too many detailed questions about these reports, and that responding to these queries was time-consuming on the part of the managers. However, other AECL managers and staff expressed the need for direct contact with NRCan staff rather than using the current hierarchical approach (proceeding through the LMU) to address NRCan questions.

There is general agreement that the Comprehensive Preliminary Decommissioning Plan (CPDP) that was developed for the CRL site CNSC licenceFootnote 35 and which was used as a basis for the NLLP, was overly optimistic. During the start-up stage, NRCan and AECL did not take advantage of external expertise and international experience to provide guidance to such a demanding and groundbreaking program. Sufficient conservatism re: milestones was not included in the CPDP to address the risks encountered during implementation. The level of characterization of the wastes and facilities was not sufficient to support detailed implementation plans. It should also be noted that the majority of CRL interviewees reported that the CPDP was developed quickly. This view was not universally held – a smaller number of program interviewees reported that the CPDP was developed over a one-year period.Footnote 36

The program resourcing proposal for the NLLP contained 161 milestones of varying magnitude and significance, most of which were not related to costs. As implementation progressed and further knowledge was gained, some of the milestones proved to be unrealistic, and others became redundant as the approaches for dealing with aspects of the liabilities evolved. Some of the milestones were changed after 2006 under the authority of the JOC, including those linked to the accelerated approach to the decommissioning work at WL. This flexible approach is consistent with best practices for decommissioning planning, where decision-making should provide the flexibility to adapt to new information (Appendix B).

Planning has improved significantly in that AECL now carries out feasibility studies as part of its pre-planning. As well, AECL is conducting more in-depth characterization and costing analyses as part of its planning for the next five years. Furthermore, projects are now gated more effectively — i.e., featuring go/no go decision points as better information becomes available with the progress of work. However, the lack of long-term radioactive waste management facilities in Canada hinders planning because its absence causes issues such as how to dispose of or store the waste. This is done on a case-by-case basis.

The NLLP Performance Measurement Strategy

AECL and NRCan have an NLLP Performance Measurement Strategy that is based on AECL reporting to NRCan, and in turn to Treasury Board Secretariat, on the achievements of the NLLP, relative to the NLLP five-year plan.

Performance reporting is complicated by the fact that a number of milestones have been added or deleted over time. Although the need to adjust milestones can be expected in long-term programs, there is a need to consider these adjustments when planning performance reporting (which does not appear to have been done).

As well, although budgets are established and reported on internally by the LMU for individual internal contracts related to the NLLP, there are no specific budgets attributed to the NLLP milestones. This complicates reporting on work completed compared to costs – the reporting approach committed to in the resourcing proposal for the NLLP.

Conclusions

The evaluation concludes that there is an environmental and regulatory need for the NLLP. The Program is consistent with, and supports federal government priorities, roles and responsibilities as well as NRCan strategic objectives. There is a recognized need for NRCan to play an enhanced oversight role for the NLLP.

Findings indicate that the NLLP work is behind schedule and over budget. Actual costs of the NLLP decommissioning work are generally higher than estimated. Technical difficulties, lack of HR, ongoing operations, regulatory requirements, and limited use of external contractors with relevant expertise to complement or augment AECL resources explain most of the delays and cost overruns. However, improvements were implemented during the last two years of the evaluation period.

There was general agreement among interviewees that the CPDP for the CRL site was overly optimistic. Sufficient conservatism in milestone development was not included in the CPDP to address the risks encountered during implementation. AECL senior management noted that in developing the CPDP, the best available characterization data of the facilities and wastes at that time were used; however, it did not adequately account for, in the early years of implementation, the required ramp-up of procedures, processes and regulatory requirements, contingency planning and timeframes. The evaluation found that the best available characterization data at that time was insufficient for the purposes for which it was used. Assessing the progress made with respect to completing NLLP tasks using program milestones should be carried out with caution due to the significant variation in the milestones' importance, scope and size.

AECL and NRCan consider their current working relationship to be effective. NRCan NLLP staff have been monitoring the implementation of the NLLP closely and have a good understanding of the tasks involved. However, while individual projects are tracked closely, AECL does not have an integrated system for managing overall cost and time resource expenditures of all NLLP projects against a master schedule and budget. Although budgets are established and reported on internally by the LMU for individual internal contracts related to the NLLP, there are no specific budgets attributed to many of the program milestones.

In terms of performance, many of the higher risk health, safety and environmental issues at CRL are being addressed, in spite of the delays in implementation. Various sizeable CRL and WL buildings have been decontaminated and demolished. WL adopted an accelerated schedule in 2007; much progress has been made since that time.

The NLLP has undertaken much of the preparatory work for activities in the upcoming phases. Public consultations to be conducted by NRCan were delayed until spring 2010. Most stakeholders, including government and the communities, agreed that earlier consultations would not have been timely. AECL senior management reported that it had kept the local public informed of program activities through its licensee commitments.

Program Preface to Recommendations and Management Response and Action Plan Table

The findings and recommendations of the evaluation of the delivery of the Nuclear Legacy Liabilities Program provide valuable feedback and will assist management in improving the future delivery of the Program. When it became clear in mid-2008 that NLLP implementation costs were higher than forecasted and that the Program would fall short of its milestone objectives, NRCan required AECL to conduct a mid-program review to evaluate the factors that had impacted program implementation costs and timelines, as well as identify measures to improve performance and maximize program delivery. In December 2008, AECL submitted its mid-program review and advised that the following factors had impacted costs and schedules:

  • the original set of milestones was too optimistic;
  • AECL did not have a good understanding of the technical challenges involved;
  • AECL needed time to "ramp-up" to implement this large program; and
  • the Program was competing with AECL Operations for personnel, and repairing the NRU reactor for radioisotope production was the top priority.

This experience is not unlike that of other countries such as the United States and the United Kingdom that have faced similar challenges at the outset of programs to actively deal with nuclear liabilities. As part of the mid-program review, AECL identified a number of measures to optimize program delivery, including the need for:

  • more detailed, up-front planning;
  • making greater use of option and feasibility studies;
  • increased use of external expertise and enhanced learning from foreign decommissioning experience; and
  • improved work prioritization and program monitoring.

These measures have now been introduced in the program's delivery. The NLLP Evaluation Report has made a number of additional recommendations to improve both AECL's implementation of the NLLP and NRCan's program oversight. These recommendations expand on the mid-program review findings and provide additional feedback beyond the 2008 Review recommendations.

For fiscal year 2010-11, NRCan directed AECL to formalize the list of milestones that would be completed during the year. As at March 31, 2011, 37 of the 40 milestones that were identified had been completed for a milestone completion rate of 93 percent. Of the remaining three milestones, two will be completed by the end of May 2011, and the other milestone is scheduled for completion by the end of December 2011.

Recommendations and Management Response and Action Plan Table
Recommendations Management Responses and
Action Plans
Responsible (Target Date)

1. NRCan should proceed with its plan to present the next phase in two parts to Treasury Board Secretariat:

  1. a three-year detailed plan that would include specific program deliverables; and
  2. a higher-level plan that identifies objectives for the remaining two years.

Agreed. The second phase of the Program has been limited to three years. NRCan and AECL have set specific milestones for that period, and identified objectives for the following two years. Program findings over the next three years will inform priorities and milestones for future years.

ADM Energy Sector
Complete, December 2010

2. NRCan should enhance its oversight of the NLLP.

Agreed. An ADM-level steering committee (comprised of NRCan, AECL and potentially CNSC members) will be implemented by July 2011 to strategically oversee the work of the Joint Oversight Committee.

ADM Energy Sector
July 2011

3. NRCan should request from AECL a strategy with the following elements:

  • A long-term integrated waste management strategy;
  • An updated outsourcing strategy including a gap analysis of current AECL tendering mechanisms and a strategy to address the gaps. The strategy to address the gaps should include: procurement mechanisms; a training strategy; a project management framework with roles and responsibilities, tasks and timelines; and list of projects AECL intends to outsource.
  • Analysis of cost effectiveness of options reviewed for major new NLLP projects, where appropriate.

Agreed.

At NRCan's direction, AECL is preparing an integrated waste plan that will provide an assessment of viable options for the treatment and long-term management of the legacy waste inventory. An interim plan was completed in February 2011. The Steering Committee will ensure that a plan suitable for third-party review will be completed by March 2013.

Procurement is a centralized AECL Nuclear Laboratories function, and thus the recommendation extends beyond the NLLP. NRCan has instructed AECL to develop an action plan by June 2011 to improve procurement processes to support NLLP outsourcing requirements. Improvements to date have included putting in place standing contracts for services, such as engineering and cost-estimating support for building decommissioning.

AECL put in place a pre-project initiation process in 2009 for evaluating options for addressing liabilities based on a number of criteria, including cost. NRCan has directed AECL to develop an action plan by June 2011 to build on this process to include cost effectiveness analysis.

 

ADM Energy Sector (via the Steering Committee)
March 2013

 

 

ADM Energy Sector
June 2011

 

 

 

 

ADM Energy Sector
June 2011

4. NRCan should encourage AECL to explore the possibilities of using incentives successfully implemented by other countries in the delivery of nuclear decommissioning programs to support achievement of NLLP objectives.

Agreed. The use of incentives would be a significant change in AECL's approach to implementing the NLLP. The Steering Committee will ensure that AECL provides, by September 2011, a report on the use of incentives to enhance delivery of the NLLP. The Steering Committee will also examine approaches for incorporating the use of incentives in the delivery of the NLLP. The use of incentives will need to respect regulatory requirements, applicable Government of Canada policies for Crown Corporations, and negotiated labour contracts.

ADM Energy Sector (via the Steering Committee)
September 2011

5. NRCan should increase/raise its presence at the Chalk River Laboratories and Whiteshell Laboratories sites in order to improve communications.

Agreed. NRCan staff has increased its presence at AECL sites through site visits and participation in project-level workshops and meetings to enhance communication and provide for more timely and in-depth awareness of program issues and challenges. The frequency of trips to the sites will be at least once every two months starting in April 2011.

ADM Energy Sector
April 2011

6. NRCan, together with AECL, should review NLLP reporting requirements to identify opportunities to streamline reporting to increase value and reduce reporting burden, and define the depth of information/data detail required.

Agreed. A new monthly reporting requirement is in place that summarizes key program metrics, such as performance, finance, issues, and actions, and it is being enhanced for fiscal year 2011-12 to include additional metrics such as cost and schedule variances. Further, the format and content requirements for quarterly progress reports is being revised. The Steering Committee will consider implementing a joint project reporting portal to reduce the burden and ensure regular update on progress.

ADM Energy Sector (via the Steering Committee)
September 2011

7. NRCan should encourage AECL to continue to seek out the best technological, risk, and cost-benefit advice possible, nationally and internationally.

Agreed. Since the completion of the evaluation, AECL has contracted with international firms to review the program of work for the second NLLP phase and assist with the development of a new approach for managing legacy liquid waste. Further, AECL has signed cooperation agreements with the French National Agency for Radioactive Waste Management (ANDRA) and the U.K. Nuclear Decommissioning Authority and is working to put in place a similar agreement with the U.S. Department of Energy. The Steering Committee will critically review and provide input to annual plans for contracting NLLP work out to the private sector.

ADM Energy Sector
(via the Steering Committee)
Ongoing

8. NRCan should encourage AECL's use of lifecycle costing when considering waste management options for decommissioning and site restoration projects.

Agreed. AECL currently completes lifecycle cost analyses in some situations, for example before deciding to ship waste to U.S. commercial facilities for treatment. The Steering Committee will ensure that an action plan is prepared by September 2011 to fully address this recommendation.

ADM Energy Sector (via the Steering Committee)
September 2011

9. NRCan should encourage AECL and the CNSC to continue to discuss planned projects so that AECL and the CNSC arrive at a clear understanding of regulatory expectations for licensing submissions.

Agreed. NRCan staff has increased its interaction with the CNSC on the NLLP, and NRCan and CNSC staff have committed to ongoing strategic discussions on the NLLP. Senior management level meetings have also taken place between AECL and the CNSC to discuss NLLP regulatory matters. To the extent consistent with the CNSC's regulatory obligations, the Steering Committee will include CNSC's senior representation to ensure that regulatory requirements are fully integrated in the selection of the NLLP projects.

ADM Energy Sector (via the Steering Committee)
Ongoing

10. NRCan should enhance, and also encourage AECL to enhance, risk management practices by:

  • Updating the overall risk analysis and risk management framework, including the identification and rating (impact and likelihood) of environmental timing, cost and other risks, both at the project and program level. The framework should also include mitigation measures and make recommendations concerning the frequency for required updates.
  • Encouraging AECL to implement a quantitative risk management system using the industry standard for detailed planning and control.

Agreed.

The risk and control assessment for the Program was updated based on an August 2010 workshop facilitated by NRCan's Risk Management Centre of Expertise. Starting in 2011, NRCan will update the program risk and control assessment annually for approval by the Steering Committee. Regarding project-level risks, see response to next bullet.

The ADM Steering Committee will ensure that an action plan is prepared by November 2011 and is subsequently implemented to address this recommendation.

 

 

ADM Energy Sector
Complete,
October 2010

 

ADM Energy Sector (via the Steering Committee)
November 2011

1.0 Introduction and Background

1.1 Overview

This report presents the findings of an evaluation of the Nuclear Legacy Liabilities Program (NLLP) which was carried out from July 2009 through March 2010. The objectives of the evaluation were to:

  • assess the relevance of the NLLP sub-sub-activity 2.2.4.3 in terms of addressing an actual need, in relation to federal government priorities, and in relation to the role of the federal government;
  • assess the performance of the NLLP sub-sub-activity, that is, the degree to which it has achieved its expected results, and whether there have been any unintended results; and
  • assess the relevance, performance, economy and efficiency of the NLLP.

The timeframe encompassed by the evaluation was 2006-07 to 2008-09.

1.2 Program Objectives and Priorities

The objective of the NLLP is to safely and cost-effectively reduce the nuclear legacy liabilities and associated risks based on sound waste management and environmental principles in the best interests of Canadians.

It was recognized that this objective would only be fully realized through the implementation of a long-term 70-year strategy; however, the five-year start-up phase (the subject of this evaluation) was expected to result in important outcomes that would build toward achievement of the long-term objective.Footnote 37

The NLLP's five-year start-up phase encompassed the following priorities as described in the program resourcing proposal:

  • delivery of a five-year technical program of work to:
    • address health, safety, and environmental priorities;
    • accelerate the decommissioning of shutdown buildings;
    • lay the groundwork for future phases of the strategy; and
    • continue necessary care and maintenance activities to maintain the liabilities in a safe state until they can be fully addressed in subsequent phases;
  • further development of the long-term, 70-year strategy to deal with the nuclear legacy liabilities, including public consultation; and
  • a management and accountability framework and a project management framework.Footnote 38

1.3 Context

The Nuclear Industry in Canada

Nuclear energy currently provides around 15% of Canada's total electricity needs (over 50% in Ontario). Since it is virtually an emissions-free electricity source, it also contributes to climate change emissions reduction and other atmospheric emissions objectives. In Canada, it has been estimated that between 40 million and 90 million tons of greenhouse gas (GHG) emissions are avoided annually through the use of nuclear power (assuming that the electricity would be generated by natural gas or coal, respectively).Footnote 39

The Canadian nuclear industry is comprised of approximately 150 companies that supply products and/or services to AECL as well as the power generation utilities, concentrated in Ontario, and to a lesser extent in Saskatchewan, Quebec and New Brunswick. Annual employment (direct and indirect) associated with the nuclear industry in Canada is approximately 30,000 jobs, with an estimated further 40,000 jobs believed to be generated through spin-offs.Footnote 40

The industry generates revenues of around $6.8 billion per annum, including nuclear electricity produced (which represents about $5 billion per annum), export sales (including CANDU equipment/service exports [$500 million]), uranium [$1 billion], and medical and industrial isotopes and related equipment [$300 million]). These figures do not take into account health (e.g., medical) and environmental aspects of nuclear technology.

Until the National Research Universal was shut down for repairs,Footnote 41 Canada was the world's second largest supplier of medical isotopes (contributing to over half of the global supply of medical isotopes for nuclear medicine and 75% of the world's supply of Cobalt-60 used to sterilize medical equipments).Footnote 42

Canada is among the world's larger producers of uranium. Mining and milling of uranium is a $1-billion-a-year industry that directly employs over 1,000 Canadians, many of whom are residents of northern Saskatchewan. Canadian uranium is used in commercial nuclear power plants world-wide to produce electricity, including Canadian-built CANDU (CANadian Deuterium Uranium) reactors, which currently supply about 15% of Canada's electricity.Footnote 43

Federal and provincial revenues supplied through the nuclear industry through taxes are about $1.5 billion annually.

Radioactive Waste and Legacy Liabilities

In Canada, radioactive waste is generated by uranium mining, milling, refining and conversion, nuclear fuel fabrication, nuclear reactor operations, nuclear research, and radioisotope manufacture and use.Footnote 44 NRCan's Energy Sector notes that radioactive wastes have been produced in Canada since the early 1930s when the first radium mine in Canada began operating at Port Radium in the Northwest Territories. Radium was refined for medical use, and uranium was later processed at Port Hope, Ontario. Research and development on the application of nuclear energy to produce electricity began in the 1940s at the Chalk River Laboratories (CRL) of Atomic Energy of Canada Limited (AECL).Footnote 45

More than one half of Canada's nuclear legacy liabilities are as a result of Cold War activities undertaken between the 1940s and the early 1960s. The remaining liabilities stem from R&D for nuclear reactor technology, the production of medical isotopes, and national science programs conducted by the National Research Council (1944 to 1952), the Department of National Defence and by AECL (1952 to present).

The liabilities addressed by the NLLP consist of redundant research and associated buildings that have been shut down, a wide variety of buried and stored wastes, and affected lands. The shut down buildings and affected lands need to be safely decommissioned or remediated to meet current federal regulatory requirements, and solutions need to be developed and implemented to manage the resulting wastes.Footnote 46 NLLP legacy wastes were identified as the responsibility of the GoC, distinct from those produced by the nuclear industry and provincial utilities.Footnote 47

The NLLP waste liabilities are distributed approximately as follows:

  • 70% Chalk River Laboratories (CRL), Chalk River, Ontario;
  • 20% Whiteshell Laboratories, Pinawa, Manitoba; and
  • 10% at three AECL prototype power reactors, in Ontario and Quebec (which are not part of the NLLP evaluation):
    • Nuclear Power Demonstration, Rolphton, Ontario;
    • Douglas Point, near Kincardine, Ontario; and
    • Gentilly-1 at the Gentilly Nuclear Generating Station near Bécancour, Québec.

Other AECL buildings and properties that are part of the NLLP (but not part of this evaluation) are the former (shutdown) heavy water plants at LaPrade, Québec and Glace Bay, Nova Scotia.Footnote 48

Canada has a Radioactive Waste Policy Framework comprised of principles governing the institutional and financial arrangements for long-term management of radioactive waste by waste producers and owners. Under this framework, the federal government is responsible for ensuring that radioactive waste long-term management is carried out in a safe, environmentally-sound, comprehensive, cost-effective and integrated manner.Footnote 49

In addition, the Framework obligates the federal government to develop policy, to regulate, and to oversee producers and owners to ensure that they comply with legal requirements and meet their funding and operational responsibilities in accordance with approved waste long-term management plans.Footnote 50

In turn, the waste producers and owners are responsible, in accordance with the principle of "polluter pays," for the funding, organization, management and operation of long-term management and other facilities required for their wastes. The Framework recognizes that arrangements may be different for nuclear fuel waste, low-level radioactive waste and uranium mine and mill tailings.Footnote 51

In 2003, NRCan undertook an initiative to develop a framework for dealing with the legacy liabilities. The initiative encompassed the waste inventory as well as an overall strategy to deal with the wastes including costs, governance, and next steps. NRCan and AECL compiled the inventory and developed a strategy for reducing risks and liabilities over a 70-year period based on what were considered to be sound waste management principles. The estimated cost to implement the strategy over 70 years was $6.8 billion (2005 dollars).Footnote 52

In April 2006, the federal government adopted the 70-year strategy to deal with nuclear legacy liabilities, and a detailed five-year $520 million plan to initiate the strategy. This five-year Nuclear Legacy Liabilities Program (NLLP) was announced by the Government of Canada (GoC) in June 2006. The five-year NLLP start-up phase, 2006-07 through 2010-11, was directed at addressing health, safety, and environmental priorities, accelerating the decontamination and demolition of shutdown buildings, laying the groundwork for subsequent phases of the strategy, and continuing necessary care and maintenance activities. During the start-up phase, the long-term strategy was to be further developed and refined. Public consultations were to be carried outto inform this work and decisions on the next phase of the strategy.Footnote 53

Roles and Responsibilities of Major NLLP Players

AECL is the implementing agency for the NLLP. NRCan is responsible for policy direction and oversight, including control of funding. The Canadian Nuclear Safety Commission (CNSC) has the regulatory role for the NLLP.

Natural Resources Canada

With respect to the NLLP, NRCan represents the interests of the Government of Canada and provides policy direction and oversight (including control of funding); oversees implementation; and ensures value for money, transparency and accountability and leading public consultations related to the further development of the long-term strategy.Footnote 54 NRCan and AECL are implementing the NLLP in partnership.

In Canada, constitutionally, nuclear energy falls within the jurisdiction of the federal government. Its role encompasses research and development, as well as the regulation of all nuclear materials and activities in Canada.

The federal legislative framework consists of:

  • Nuclear Safety and Control Act (regulation);
  • Nuclear Energy Act (nuclear research and development);
  • Nuclear Fuel Waste Act (waste); and
  • Nuclear Liability Act (liability).Footnote 55

The Department of Natural Resources Act provides the Minister of Natural Resources with a range of powers, duties and functions with respect to natural resources, including their sustainable development, integrated management, responsible development and use, policy and scientific/technological development (among others).Footnote 56

NRCan's mandate encompasses promoting the sustainable development and responsible use of Canada's natural resources as well as ensuring the energy future for Canada through developing policies and programs which enhance the economic and environmental well-being of Canadians.Footnote 57 As NRCan's Report on Plans and Priorities for 2009-10 noted, ". . . the Department is the federal lead on nuclear energy policy. It works to maximize the economic and environmental benefits from this non-greenhouse gas-emitting source of electrical power."Footnote 58

NRCan's Energy Sector is responsible for developing Canadian policy on all energy sources. Within the Energy Sector, the Nuclear Energy Division (NED) develops and implements Canadian government policy on nuclear energy, provides advice on energy policy, as well as institutional, legislative and financial frameworks for the nuclear industry in Canada. NED works closely with the Uranium and Radioactive Waste Division (URWD) in this regard.Footnote 59

Two other organizations involved with delivering the NLLP report to Parliament through the Minister of Natural Resources: AECL and the CNSC.

Five other federal organizations have an interest in nuclear energy/waste management:
Health Canada, the Department of Foreign Affairs and Trade (DFAIT), Transport Canada, Industry Canada and the National Research Council (NRC).

Atomic Energy of Canada Limited (AECL)

AECL implements the NLLP program of work and is responsible for holding and administering all licences, facilities and lands.Footnote 60

AECL is a Crown Corporation established in 1952 to develop peaceful applications of nuclear energy. AECL's mandate encompasses a public policy support role and a commercial role.Footnote 61

The public policy support role includes: conducting nuclear R&D, producing medical isotopes, and the management of legacy and historic nuclear wastes. Most of AECL's R&D activities are conducted at the CRL, which house the National Research Universal Reactor. With respect to its commercial role, AECL designs, develops, deploys and refurbishes nuclear reactor systems based on Pressurized Heavy Water Reactor technology (CANDUFootnote 62).Footnote 63 AECL also operates a site in Pinawa, Manitoba (Whiteshell Laboratories) as well as some smaller sites in Ontario and Quebec.

AECL's Chalk River Laboratories (CRL)

The Chalk River Laboratories site is one of the more complex nuclear sites in the country. Activities and facilities at CRL encompass research reactors, isotope production, fuel fabrication and research, tritium processing, waste management and waste treatment, decommissioning projects, Class II Nuclear FacilitiesFootnote 64 and numerous radioactive laboratories. This occurs in an environment of continuous change to upgrade laboratory facilities, or to construct new facilities (the latter are Class I Nuclear Facilities).Footnote 65

Numerous organizations benefit from these facilities including universities, private corporations, and government agencies.Footnote 66 Research (non-power) reactors and nuclear research facilities are licenced by the CNSC as part of the Commission's mandate to regulate nuclear materials and activities for the protection of the health and safety of Canadians and the environment.Footnote 67

The National Research Universal (NRU) reactor at Chalk River has been a major part of Canadian nuclear research. Prior to its shutdown for repairs in 2009, the NRU produced the majority of the world's medical isotopes used in the diagnosis and treatment of life-threatening diseases. It is also Canada's only major materials and fuel testing reactor used to support and advance the CANDU reactor design. The NRU produces neutrons used by the NRC's Neutron Beam Centre to investigate and study all types of industrial and biological materials.Footnote 68

AECL's Whiteshell Laboratories (WL)

The NLLP also encompasses the Whiteshell Laboratories site of AECL in Pinawa, Manitoba. WL is the first licenced nuclear research site to be decommissioned in Canada. For more than 35 years, WL operated as a nuclear research and information laboratory. Among other technologies and advances, dry storage containment facilities for used nuclear fuel were developed there. As of 2010, there were approximately 300 employees at the WL site working on a decommissioning plan to remove buildings and reduce the risks and liabilities of the AECL property. The objective is to decommission the site to the point where only the Waste Management Area (WMA) remains until the majority of its contents are transferred to a permanent site.Footnote 69

AECL's Underground Research Laboratory (URL), located a short distance from Whiteshell, is in an advanced stage of decommissioning. Established in 1982, its purpose was to study the feasibility of safe disposal of nuclear fuel waste in a stable, low-permeability rock mass.Footnote 70

Canadian Nuclear Safety Commission (CNSC)

The Canadian Nuclear Safety Commission, which reports to Parliament through the Minister of Natural Resources, is the sole regulatory authority for the peaceful use of nuclear energy in Canada. It operates under the authority of the Nuclear Safety and Control Act (NSCA).Footnote 71 The NSCA provides the CNSC with a range of authorities/powers, including: making regulations; including any condition in licences; and revoking, suspending, amending, replacing, or renewing any licence (following proper procedure).Footnote 72

Under the Nuclear Safety and Control Act, the CNSC:

  • regulates the development, production and use of nuclear energy in Canada to protect health, safety and the environment;
  • regulates the production, possession, use and transport of nuclear substances, prescribed equipment and prescribed information;
  • implements measures respecting international control of the development, production, transport and use of nuclear energy and substances, including measures respecting the non-proliferation of nuclear weapons and nuclear explosive devices; and
  • disseminates information concerning the activities of the CNSC and the effects on the environment and the health and safety of persons, and on the development, production, possession, transport and use of nuclear substances.Footnote 73

The CNSC maintains regulatory oversight of operating nuclear facilities through licensing and compliance programs. Licences, certifications and authorizations serve as forms of permission. Most of the permissions issued by the CNSC are in the form of licences. Footnote 74 Obtaining a licence requires the CNSC to be satisfied that, among other things, the applicant will make adequate provision for protection of the environment as well as the health and safety of persons, and the maintenance of national security and measures to implement international obligations to which Canada has agreed.Footnote 75

AECL holds a number of licences issued by the CNSC.

1.4 NLLP Governance Structure

1.4.1 Memorandum of Understanding (MOU)

The roles and responsibilities of NRCan and AECL are outlined in a Memorandum of Understanding developed between AECL and NRCan, as described in section 1.3.

1.4.2 Joint Oversight Committee (JOC)

NRCan oversight of the NLLP is exercised primarily through the NRCan-chaired Joint Oversight Committee (JOC), comprised of NRCan and AECL members. Footnote 76 The JOC embodies the function of a Senior Project Advisory Committee as required by the Policy on the Management of Major Crown Projects.Footnote 77 This includes making decisions on the planning, delivery, reporting and administration of the Program by approving plans and reports, addressing issues and carrying out long-term planning.Footnote 78

The Director of NRCan's Uranium and Radioactive Waste Division chairs the JOC. The JOC takes a consensus approach to decision-making, recognizing the federal government's interests as ultimate owner of the liabilities and funder of the work, as well as AECL's need to protect health, safety and the environment, and meet regulatory requirements.Footnote 79

1.4.3 Performance Measurement Strategy

The NLLP Performance Measurement Strategy (PMS) is being implemented to provide input to assessment of the program's performance against the federal government's objectives and goals for the five-year plan. The PMS included detailed milestones as well as planned outcomes, which provided for higher-level measures of the success of the Program and its overall value to Canadians.Footnote 80

Outcomes contained in the PMS are for the NLLP to:

  • reduce risks and liabilities;
  • improve onsite environmental and safety conditions;
  • reduce uncertainties;
  • address regulatory requirements and Office of the Auditor General (OAG) concerns; and
  • enhance public confidence and support.Footnote 81

Contained in the original program resourcing proposal and, by implication, the PMS were 161 milestones of varying significance (e.g., some represent intermediate steps). Examples of the milestones include:

  • characterize and recover specified buried wastes;
  • decontaminate and demolish shutdown buildings; and,
  • design and construct new waste storage and analysis facilities.Footnote 82

The milestones were not linked to risk, funding or costs.

1.4.4 Liability Management Unit (LMU)

In 2006, AECL created a Liability Management Unit (LMU) as a business unit to manage AECL's implementation of the NLLP (as shown in Figure 1). Located at CRL, the mandate of the LMU encompasses all NLLP sites.

The LMU has its own segregated financial accounts in which it manages the federal funds received through NRCan for the NLLP, and the funds it receives from the rest of AECL to manage wastes generated by AECL operations after April 1, 2006.Footnote 83 Each fiscal year, the MOU requires AECL to propose, for approval by the JOC, a plan for contracting out work to the private sector.

The LMU contracts internally with AECL "lead (internal) supplier" groups to execute the NLLP projects. Where it is cost effective and deemed by AECL to be in the best interest of Canadians to do so, AECL subcontracts some work activities to private sector companies. Throughout this process, AECL continues to recognize the need to protect health, safety and the environment and comply with regulatory requirements.Footnote 84

The LMU maintains a master schedule of approved projects based on annual operating plans. According to the NLLP JOC 2009-10 Annual Plan (2009), when contracting internally within AECL, the LMU utilizes a supplier contract, i.e., an internal agreement between the LMU and an AECL lead supplier who is responsible for carrying out a portion or all of a project's tasks within a fiscal year to address an identified liability in whole, or in part. The lead suppliers can either conduct the work internally or through subcontracts with external suppliers.

The Liability Program Execution Branch, within the LMU, is the group responsible for providing oversight between the LMU and the AECL lead supplier groups for cost effective delivery of the projects and activities.Footnote 85 Project Client Representatives (PCRs) manage the LMU-led supplier relationship from the LMU perspective.

If the project is behind schedule or over budget, project reviews are conducted; however, there are no consequences for late delivery or cost overruns. According to interviewees, the review is less formal for operating projects than capital projects. Any change in requirements is reviewed in the context of the overall annual budget.

Procedures for contracting outFootnote 86 are as follows:

  • As due diligence, the LMU ensures that 'value for money' proposals are received from the lead suppliers and approved from a technical, cost-effective and strategic perspective.
  • For major projects, the LMU approves 'Client Requirements Documents' that define projects to be undertaken by AECL's Research and Technology Operations.
  • Where required, the LMU is also involved in reviewing the internal AECL Risk Review Panel Reports, which are prepared for internal funding approval, as well as the Project Execution Plans prepared by the project teams. Both of these documents provide details on contracting strategies.
  • The LMU also participates in Project Review Board meetings and other meetings where progress and related issues are reviewed and adjustments to third-party contracting can be noted through this oversight.

The contracting process was described in interviews and the file review as being a challenge because of the specialized nature of the CRL, an operational nuclear site, and the WL site. AECL requires the contractors it engages to obtain security clearance, be knowledgeable about the site characteristics, and be familiar with its methods for designing and constructing new facilities and decommissioning older ones on a licensed nuclear site.

This has resulted in a learning curve for some of the contractors (despite the fact that some have worked on U.S. nuclear decommissioning projects under Environmental Protection Agency requirements). From the AECL perspective, AECL has to be able to provide timely and adequate support to the contractors and to specify detailed specifications for work and deliverables. According to some of the subcontractors, this has been problematic.

Over the 2006-09 period, contracting out increased from $13.2 million (21% of NLLP expenditures of $62.9 million in 2006-07) to $26.1 million (25% of $105.1 million in NLLP expenditures in 2008-09).Footnote 87

Large multi-year projects are now completed in phases with various approval points. Funding for the next phase is based on the previous completed phases – and not de facto approval based on the conceptual design. A gated process takes into account the high degree of uncertainty of many of the large projects, as well as regulatory changes and updated costing information. Each phase is approved and can be cancelled if the preliminary assumptions have changed. Some interviewees indicated that there were too many gates for lower risk projects.

For contracts with the private sector, procurement is normally conducted on a competitive bidding basis using TBS guidelines. Some sole source contracts have been awarded. Some for emergency situations or for security reasons; others for unclear reasons. Contracts to the private sector have been issued for:

  • selected shutdown of a facility and placing it in a sustainable safe state;
  • maintenance and surveillance;
  • assessments of radiological hazards, costs and waste management requirements;
  • pre-project evaluations of technical options; and
  • projects to decommission a facility, or to construct a facility.
Figure 1: NLLP Roles and Relationships
Figure 1: NLLP Roles and Relationships
Text Version

Figure 1 illustrates the NLLP roles and relationships. The bottom row illustrates that the lead suppliers and contractors & consultants report to the Liability Management Unit (LMU) in the middle row. Then the LMU reports to the NRCan/AECL Joint Oversight Committee (JOC) on the top row.

Bottom row:

Lead suppliers: manage facilities, manage and execute projects; manage subcontracted work; provide technical expertise.

Contractors and consultants: execute subcontracted work; manage and execute projects; provide specialized advice; provide third party reviews.

Arrows going back and forth between the lead suppliers and contractors & consultants identify the joint working relationship on: work packages; technical specifications; invitations to bid; subcontracts; payments; bids for subcontracts; invoices.

Middle row:

LMU: sets strategy and priorities; issues contracts; oversees and tracks progress;

Arrows going back and forth to the LMU from the bottom row regarding lead suppliers: client requirements documents; technical specifications; contracts; funding; progress reports; progress reports.

Arrows going back and forth to the LMU from the bottom row re: contractors and consultants: bids; invoices; progress reports; client requirements documents; invitations to bid; technical specifications; contracts; payments.

Top row:

Arrows going back and forth to the top row from LMU to NRCan/AECL JOC: annual plan; quarterly progress reports; year-end reports

NRCan is responsible for policy direction and oversight; funding.

AECL is responsible for the execution of work; licenses; site management

 

Source: Implementation of a Comprehensive Program to Deal with Canada's Nuclear Legacy Liabilities (2009).

1.5 Overview of Areas of Work and Key Projects

1.5.1 Key Areas of Work

As the evaluation team noted previously, the NLLP included:

  1. a five-year technical program of work to:
    1. address health, safety and environmental priorities;
    2. accelerate the decommissioning of shutdown buildings and the remediation of affected lands;
    3. lay the groundwork for future phases of the long-term strategy; and,
    4. continue necessary care and maintenance activities to maintain the liabilities in a safe state until they can be fully addressed in subsequent phases of the program.
  2. further development of the long-term 70-year strategy to deal with the nuclear legacy liabilities, including public consultation; and
  3. a management and accountability framework and a project management framework.Footnote 88
1.5.2 Addressing Health, Safety and Environmental Concerns

Addressing health and safety concerns encompasses a number of projects that are meant to reduce health, safety and environmental risks at the AECL sites within the five-year period of the program, or shortly thereafter.

At CRL, the two largest health, safety and environment projects are the Liquid Waste and Transfer Storage (LWTS) project, and the Fuel Packaging and Storage (FPS) project.

The purpose of the Liquid Waste Transfer and Storage (LWTS) Project at the Chalk River Laboratories was to provide a new storage facility for legacy radioactive waste contained in 21 aging tanks and for which there is no offsite disposal route. Twenty (20) of the tanks date from the 1950s and 1960s. In addition, the project included building or locating the equipment needed to retrieve and transfer the wastes to the new facility. LWTS became a formal project in 2004, previous to the NLLP, with funding supplied from the federal government's Program Integrity initiative. This project was put 'on hold' during the evaluation period, and later cancelled by the JOC. However, an alternative solution for dealing with the legacy radioactive wastes, the Mobile Cementation Skid, was proposed in June 2009.

The specific objectives of the LWTS Project were to design, licence, construct, and cold commission the equipment, materials and facilities necessary to:

  • retrieve, transfer and store all of the stored liquid wastes, including sludges and rinses, in new storage tanks for at least 25 years; and
  • down-blend the contents of the Fissile Solution Storage Tank (FISST) to a Uranium-235 enrichment level – low enough to minimize criticality and safeguard constraints during storage and future processing.Footnote 89

The Fuel Packaging and Storage (FPS) project involves the design, licensing, construction and commissioning of a facility for the storage of used research reactor fuel as well as the equipment necessary to first dry the fuel, and then repackage it. The facility was being designed to store the older, experimental fuels from approximately 100 tile holesFootnote 90 (existing structures used to store all used research reactor fuel at CRL) with problematic and degraded fuel and storage conditions.Footnote 91

The early generation tile holes, which contain the oldest experimental fuels, require recovery of the fuel contents, drying of the fuel and new storage facilities. This required the construction and "cold" commissioning (excluding radioactive materials) of a new storage block and the associated drying and repackaging facility by the end of 2010-11. Recovery of the fuel rods was to commence in 2011-12.Footnote 92

Environmental Remediation at CRL is not a program but a combination of four NLLP projects which have the objective of reducing risks that relate to health, safety and environmental priorities at the CRL site. These projects have been grouped (for this analysis) into the following categories:

  • Ground Water Treatment Systems – groundwater contamination being managed by three treatment facilities (i.e., Chemical Pit, Spring B, and Nitrate Plant) adjacent to CRL's waste management areasFootnote 93 (WMAs) that are already in operation;
  • South Swamp Treatment System – installation and implementation of this treatment facility to intercept and remove radioactive contaminants that originate from WMA "A" and currently discharge into the South Swamp wetland;
  • River Sediment Remediation – characterization of the sediment associated with past operations of CRL and located in the Ottawa River near the process sewer outfall, and possible remedial action; and
  • Legacy Lands Projects – characterization of areas within CRL's supervised property that have been impacted by former operations, experimental work and waste storage, and possible remediation or control to allow natural deterioration and decay to occur.Footnote 94

Planned activities include the recovery of solvent bunkers contained in steel drums and buried in WMA "B" for over 40 years. They also include the recovery of several specific waste burials including an active liquid waste tank and some waste fuel debris, and the recovery of glass blocks of vitrified liquid waste. The latter were buried at two sites in 1958 and 1960 near WMA "A" and have the potential to cause further environmental contamination in the area. The CNSC is requiring AECL to accelerate the recovery of these glass blocks (i.e., deliver the work earlier than originally planned by AECL) through a site licence condition.Footnote 95

1.5.3 Accelerate the Decommissioning of Shutdown Buildings and Affected Lands

The four stages of decommissioning are: safe shutdown, storage with surveillance, dismantling and demolition, and completion. The decommissioning process itself requires successively: decontamination, dismantling, removal of contaminated equipment and building components, and demolition.Footnote 96

Many buildings and structures at CRL were built after the 1940s. CRL facilities include nuclear reactors, fuel handling and processing facilities, and storage and support buildings, which have housed a variety of activities involving radioactive and industrial hazards. Many structures are at the end of their operating life cycle, are complex in nature, and are potentially contaminated (confirmation of contamination is part of the planning process). One of the objectives of the five-year plan is to accelerate building decommissioning to reduce the current backlog of shutdown buildings. These buildings present fire and physical risks.Footnote 97

The costs involved in monitoring, maintaining and repairing shutdown buildings to ensure that they remain in a safe and compliant state until they are demolished can be substantial. Safe shutdowns involve the removal of stored wastes, hazardous chemicals and other hazardous sources, as well as loose surface contamination. Building assessment information is used to characterize any hazards and determine the decommissioning and remedial work necessary to manage the building(s) in a cost/risk-optimal manner.Footnote 98

Completed NLLP activities related to this program area include:

  • completion of the removal of Building 107;
  • establishment of the firebreak between National Research Experimental (NRX) reactor building and Building 204, through removal of Buildings 133 and 144 and a portion of Building 204; and
  • completion of several environmental assessments so that removals can take place in future years.Footnote 99

At the beginning of the NLLP, it was expected that by the end of the five-year start-up phase, decommissioning activities would have been conducted on 47 buildings and affected lands. Footnote 100 Delivery of these activities was described by AECL as having been affected by the availability of funding (through other programs) to construct replacement buildings and facilities, and by the success of these non-NLLP projects in adhering to their schedules.

In both cases, this resulted in delays in decommissioning certain buildings.

WL Decommissioning

The Whiteshell Laboratories (WL) is located approximately 100 km northeast of Winnipeg on a 4000-hectare site adjacent to the Winnipeg River near Pinawa, Manitoba. The WL site was established in the early 1960s to carry out AECL research and development activities for higher temperature versions of the CANDU reactor.

The initial focus of the research program was the Whiteshell Reactor 1 (WR-1) Organic Cooled Reactor (OCR), which began operation in 1965. The OCR program was discontinued in the early 1970s in favour of the successful heavy-water-cooled CANDU system. WR-1 continued to operate until 1985 in support of AECL nuclear research programs.Footnote 101

Decommissioning activities have been divided into two activity areas: affected and unaffected lands. The Decommissioning Plan, established in 2001, includes all site facilities, buildings and land within the affected areas, and the Underground Research Laboratory (URL) site. The original WL Decommissioning Project was scheduled to take place within a 60-year, phased approach.Footnote 102

During the 2006-11 period, Building 300 Nuclear Research Complex was to be prepared for demolition, and storage with surveillance activities were to be continued with the already shutdown WR-1 Reactor (Building 100). Other non-nuclear buildings were also scheduled to be decommissioned, including storage sheds, containers, etc. In addition, the low-level liquid waste underground collection system and treatment facility were to be reconfigured due to reduced liquid waste handling requirements. The URL was to be put in a safe, sustainable shutdown state, and site restoration was to be conducted.Footnote 103

1.5.4 Laying the Groundwork for Subsequent Phases of the Strategy

Part of the NLLP includes preparatory work for activities to be undertaken in upcoming phases. Work to be undertaken to deliver the "Laying the Groundwork for Subsequent Phases of the Strategy" aspect of the NLLP for the 2006-07 through 2010-11 timeframe encompasses:

  • To lay the groundwork for the subsequent phases of the strategy – Waste clearance facilities were to be constructed and commissioned at both CRL and WL to permit effective segregation of dismantled components and rubble into radioactive and non-radioactive waste streams.
  • To construct waste characterization facilities at both sites to analyse radioactive wastes so that treatment and long-term management needs can be determined.
  • To construct additional waste storage to manage wastes generated by decommissioning activities, including: five low-level radioactive waste bunkers and an engineered soil storage facility at WL; and the construction of interim waste storage facilities at CRL.
  • To construct a "warm cell" to examine and analyze cemented molybdenum-99 (Moly-99) wastes and to upgrade "hot cells" to examine and analyse waste reactor fuel and components. (Hot cells are facilities that shield operators from direct radiation through the use of thick concrete and steel walls, remote handling equipment and filtered ventilation and safety systems. Warm cells are used for lower radiation field wastes and are designed to permit more rigorous, destructive testing than in a hot cell.) Over 6,000 containers of cemented Moly-99 have been stored for the last 35 years. Investigations are needed to assess container degradation.
  • To complete a geological assessment of the CRL site in 2010-11, as well as the conceptual design work for a potential long-term management facility to host low- and intermediate-level waste.
  • To complete, depending on the results of public consultations, a conceptual design of an incinerator by the end of 2010-11 at CRL.
  • To initiate design work for a Standpipe Retrieval Facility at WL to retrieve fuel from WMA standpipes, and process and package fuel and to initiate design work for a Solid and Liquid Waste Processing Facility.Footnote 104
1.5.5 Care and Maintenance Activities

The NLLP also supports care and maintenance activities, such as monitoring ongoing discharges from buried wastes and maintaining shutdown buildings until they are decontaminated and demolished. These activities need to continue until the liabilities are addressed in a later stage of the 70-year strategy. It was also recognized that the associated costs could be significant, representing approximately one-third of the funding requirement.Footnote 105

The following are some examples of care and maintenance activities:

  • Whiteshell is shut down and under a decommissioning licence. The NLLP pays for the ongoing operational costs associated with WL, consistent with ensuring licence requirements are met and including common services (heat, light, power, infrastructure operation and maintenance), nuclear operations services (design, engineering and construction support), radiation protection and compliance services, protective services (security, fire protection), grants in lieu of taxes to the local municipality, and environmental assessment follow-up activities.Footnote 106
  • Storage with surveillance (SWS) activities associated with shutdown buildings and facilities also include legacy stored liquid wastes, legacy lands and the groundwater monitoring program for the CRL WMAs, legacy pits and pipeline routes, contaminant plumes emanating from the WMAs, and legacy contaminant plumes in the inner laboratory area, including required updates to plume maps. SWS is also applied to the three shutdown prototype reactor sites, namely the Nuclear Power Demonstration (NPD) reactor in Rolphton, Ontario; the Douglas Point reactor near Kincardine, Ontario; and the Gentilly-1 reactor in Bécancour, Québec Footnote 107
1.5.6 Public Consultations

In-person public consultations were to be held to relay information and facilitate dialogue on issues. These consultations were planned to be held in three community areas linked to CRL as part of the NLLP. At WL, in-person consultations were to be held in Pinawa and Winnipeg, Manitoba. Other potential locations for consultations were Kincardine and Bécancour. NRCan was to play a leading role in public consultations, in partnership with AECL.Footnote 108

1.6 Logic Model

The logic model for the NLLPFootnote 109 is shown in Figure 2.

Figure 2 Logic Model of the Nuclear Legacy Liabilities Program (NLLP)

Figure 2 Logic Midel of Nuclear Legacy liabilites Program

 

Larger image

Text Version

This figure depicts the interrelationships among the resources (financial and human), activities, outputs (tangible immediate results), and outcomes (short-, medium- and long- term results) for the Nuclear Legacy Liabilities Program (NLLP). It should be noted that there is seldom a one-to-one linear relationship among activities, outputs and outcomes. Usually several activities contribute to the production of a given output, and several outputs contribute to the achievement of one outcome.

The logic model is sub-divided into three activity streams.

Stream One’s activity is to implement the decommissioning and legacy waste management components of the five-year plan. This activity is carried out by Atomic Energy of Canada Limited (AECL).

Stream Two’s activity is to further develop the long-term strategy, including public consultations. This activity is carried out by Natural Resources Canada (NRCan) working with AECL.

Stream Three’s activity is to monitor implementation.

All three activity streams are linked, that is, the knowledge and experience gained by implementing the decommissioning and legacy waste management components of the five-year plan provide input to the development of the long-term strategy. Both of these activities produce experience which is applied to the third activity stream, monitoring implementation.

The remainder of the NLLP’s logic model describes the outputs (tangible immediate products resulting from the activities) and outcomes (short, medium and long-term) of the NLLP.

The contents of these parts of the logic model are as follows:

Outputs Row

The outputs (physically tangible results) of the activities are:

  • Buildings (that are) advanced through the decommissioning process;
  • Buried wastes (that are) recovered and stored;
  • Contaminated lands (that are) restored or improved;
  • Waste analysis and storage facilities (that are) constructed;
  • Other required facilities (that are) constructed,
  • Studies and documentation (that are) required for future phases of the strategy completed; and
  • Buildings and sites (are) maintained in (a) safe state.

Outcomes result from production of outputs, over time, with the involvement of other parties. One outcome is seldom the result of one output, but rather, as the result of time, the actions and outputs of other parties, as well as the interplay of other outcomes. 

The NLLP logic model contains four short-term outcomes, three-medium-term outcomes, and two long-term outcomes. All of these outcomes contribute to achievement of the NLLP’s objective, which is to safely and cost-effectively reduce the nuclear legacy liabilities and associated risks based on sound waste management and environmental principles in the best interests of Canadians.

Short-term outcomes row

Short-term outcomes develop over time (usually three to five years) as a consequence of the outputs. For example, the first output “buildings advanced through the decommissioning process” contributed to achieving the short-term outcome of “regulatory requirements satisfied and the Auditor General’s concerns addressed.

The short-term outcomes for the NLLP are:

  • Regulatory requirements satisfied and Auditor General concerns addressed;
  • Increased understanding of the liabilities;
  • Stakeholders are aware of and understand the strategy, (and) provide input; and
  • The funds are managed effectively and work is focussed on risks and liabilities.

Medium-term outcomes row

Medium-term outcomes develop over the mid-term (usually five to ten years) as a consequence of the short-term outcomes in combination with the short-term outcomes and activities of a number of players. Usually one short-term outcome supports the achievement of more than one medium-term outcome.

For example, the short-term outcome of increased understanding of the liabilities, in combination with other factors, can lead to the medium-term outcome of risks and liabilities are reduced, as well as another medium-term outcome of improved on-site environmental and safety conditions. 

The medium-term outcomes for the ESSB are:

  • Improved on-site environmental and safety conditions;
  • Risks and liabilities are reduced; and
  • Enhanced public confidence and support for long-term strategy.

Long-term outcomes row

Long-term outcomes develop over the long-term (usually more than ten years) as a consequence of the medium-term outcomes in combination with the medium term outcomes and activities of a number of players. The NLLP has two long-term outcomes.

Each medium-term outcome usually contributes to all long-term outcomes. For example, the medium-term outcome of risks and liabilities are reduced can lead to achievement of both of the NLLP’s long term outcomes.

These long-term outcomes are:

  • The five-year health, safety and environmental priority issues are all addressed; and
  • Facilities, studies and plans are in place to enable the next phase of the strategy.

Both of the NLLP’s long-term outcomes support fulfilment of the NLLP’s objective, which is to safely and cost-effectively reduce the nuclear legacy liabilities and associated risks based on sound waste management and environmental principles in the best interests of Canadians.

 

1.7 NLLP Budget versus Reported Expenditures

Table 1 below displays the budget approved in 2006.

Table 1: NLLP Budget, 2006-07 to 2010-11 ($ millions)

 

2006-07 2007-08 2008-09 2009-10 2010-11 Total
Address health, safety and environmental priorities 16.5 38.9 37.6 12.3 9.3 114.6
Accelerate decommissioning of shutdown buildings 12.4 18.3 21.0 21.2 25.3 98.2
Lay groundwork for subsequent phases of the strategy 12.9 27.0 40.0 38.4 52.7 171.0
Continue required care and maintenance activities 23.2 25.5 25.0 24.5 31.0 129.2
Total implementation 65.0 109.7 123.6 96.4 118.3 513.0
Oversight 1.0 1.5 1.5 1.5 1.5 7.0
Total 66.0 111.2 125.1 97.9 119.8 520.0

Source: initial NLLP documentation.

Table 2 provides an overview of the reported NLLP expenditures for the first three years by type of expenditure. AECL labour accounted for about 35-40% of expenditures, while external contracts and purchased equipment accounted for an additional 35-40%. The other category includes ongoing maintenance costs of facilities, etc. Note that AECL has been unable to spend the allocated annual budgets and has carried forward unspent amounts.

Table 2: NLLP Expenditures, 2006-07 to 2008-09 ($ millions)
Expenditure 2006-07 2007-08 2008-09 Total
Salaries 29.3 35.5 44.2 109
3rd Party Contracts 11.1 30.1 26.1 67.3
Equipment & Materials 3.1 7.6 8.9 19.6
Other 21.5 23.2 25.9 70.6
Total 65.0 96.3 105.1 266.4

Source: JOC Annual Reports.

Table 3: NLLP Expenditures by Priority Area, 2006-11 ($ millions)
Areas of Work 2006-07 2007-08 2008-09 Total Spent to date Approved Budget (2006-11) Remaining To be Spent
Address Health Safety Environmental Priorities 16.6 32.7 30.0 79.3 114.6 35.3
Accelerate Decommissioning Buildings 12.4 15.1 15.7 43.2 98.2 55.0
Lay the Groundwork for Future Phases 12.9 17.1 19.3 49.3 171.0 121.7
Care and Maintenance 23.2 31.4 39.2 93.8 129.2 35.5
Funding carried forward* 10.2 3.7 4.5 18.4 - -
Oversight         7  
Total 65.0 96.3 105.1 266.4 520.0 247.5

Source: NRCan Annual Reports to the Treasury Board Secretariat.
*Not included in total.

NRCan submits annual progress reports to Treasury Board Secretariat on the NLLP. In the most recent report (for fiscal year 2008-09), it was reported that AECL had spent $266.5 million or 51% of the approved budget over the first three years of the NLLP, with 49% to be spent over the last two years.

2.0 Evaluation Scope and Methodology

2.1 Objectives, Scope and Evaluation Issues

The time frame encompassed by this evaluation was 2006-07 through 2008-09. The activities included in the evaluation included all of the NLLP areas of work. The objectives of the evaluation were to assess the relevance of the NLLP sub-sub-activity in terms of addressing an actual need, in relation to federal government priorities, and in relation to the role of the federal government; assess the performance of the NLLP sub-sub-activity (i.e., the degree to which it achieved its expected results), whether there had been any unintended results; and assess the economy and efficiency of the NLLP sub-sub-activity.

2.1.1 Evaluation Issues

The evaluation addressed the following issues and questions:

Relevance

  1. What is the environmental need that the Program is trying to address, and its magnitude, related risks and targeted group?
  2. Is the Program consistent with government priorities and NRCan strategic objectives?
  3. Is there a legitimate, appropriate and necessary role for NRCan in the Program? Is NRCan's role appropriate in the context of the role of others?

Performance (effectiveness, efficiency and economy)

  1. To what extent have intended outcomes and results been achieved as a result of the Program? Are there any contamination situations that the Program has not addressed?
  2. Have there been unintended (positive or negative) outcomes? Were any actions taken as a result of these?
  3. How economic is the Program? How does its economy compare to that of similar programs or alternative program design and delivery models (in other jurisdictions, international or private sectors)?
  4. How efficient is the Program? Do the overall processes and internal practices used by AECL represent good project management practices? Were appropriate consultations conducted?
  5. What are the internal and external factors influencing the effectiveness, efficiency and economy of AECL's delivery of the Program? Is AECL's internal management /governance of the NLLP appropriate or are there improvements that could be made?
  6. Did the NLLP start-up phase (2006-07 through 2010-11) have a clearly defined strategic and operational plan? Was the planning process appropriate and effective? Were the right priorities identified? Were the original milestones an appropriate benchmark for measuring success?
  7. What is the nature of the working relationship between NRCan and AECL on the NLLP? Is there a more appropriate governance model, or are there improvements that can be made? Was the governance structure and working relationship between NRCan and AECL appropriate?
  8. What factors drove the cost and schedule variations for the work accomplished to date?
  9. Are there any best practices and lessons learned?

2.2 Methodologies and Limitations

The evaluation employed a multiple lines of evidence approach, based on three techniques. The evaluation was also supported by a subject matter expert advisor who participated in all aspects of the evaluation.

2.2.1 Literature and Document Review

A document review and literature review were conducted as part of this study. A review of program files and documentation was conducted to provide an in-depth understanding of the NLLP and to gather evidence for the purposes of the evaluation. Prior to developing the instruments and conducting the field work, a review of domestic and international documentation and literature on nuclear waste management practices was conducted. This was done in order to better assess the results of the Program, including project management and approaches chosen for waste management. A two-day workshop was also conducted by the subject matter expert for the evaluation team to provide background and insight into nuclear waste decommissioning. Since there exists a plethora of information on the topic of nuclear waste, the subject matter expert provided advice on documents to review to ensure completeness of the review.

2.2.2 Key informant interviews

Interviews were conducted in person in the National Capital Region, at the CRL site and at the Whiteshell site. Some interviewees, who were not located at one of the main AECL sites, were interviewed by phone. Interviews varied between 30 and 120 minutes in duration. A total of 60 individuals were interviewed as part of the process. Interviewees included:

  • NRCan staff and managers (n=5);
  • AECL WL or CRL management and staff (n=48);
  • CNSC staff ( n=1);
  • OAG representatives (n=2); and
  • industry subcontractors (4).

Subcontractors included representatives from private firms that conducted work either for the CRL or WL sites. Approximately 30 of these interviews were also used for the purposes of the case studies.

The large number of interviews was intended to mitigate the risk of bias that is normally inherent in interviews. The range of interviewees (from senior management to staff), as well as using multiple lines of evidence, also were used as mitigation measures.

2.2.3 Case Studies

Case studies were used to gather information on specific projects (or groups of projects) to gain a deeper understanding of key projects, as well as issues affecting many NLLP projects in general. Five case studies were conducted, two of which were NLLP projects. The remaining three other case studies were actually NLLP sub-programs which were comprised of several projects. The five case studies were:

  • CRL Liquid Waste Transfer and Storage (LWTS) Project;
  • CRL Environmental Remediation;
  • CRL Fuel Packaging and Storage (FPS) Project;
  • Decommissioning of CRL Shutdown Facilities; and
  • Whiteshell Laboratories Site.

Selection criteria for the case studies included their relative importance to the NLLP, in particular, their correspondence to the NLLP priorities for the first five years, as well as potential for lessons learned for the evaluation in general. They encompassed the key NLLP projects, including some of the most challenging ones. Techniques used for the case studies were key informant interviews (approximately 30) and document review. Key informant interviewees included AECL personnel, contractors, the CNSC and NRCan personnel.

The evaluation was restricted to Chalk River Laboratories and Whiteshell and so did not include: Rolphton, Ontario, Douglas Point, near Kincardine, Ontario; Gentilly-1 at the Gentilly Nuclear Generating Station (in Bécancour, Québec); LaPrade Heavy Water Plant, LaPrade, Québec; or Glace Bay Heavy Water Plant, Glace Bay, Nova Scotia.

2.2.4 Expert Advisor

A subject matter expert advisor to NRCan played a key role in the evaluation. The expert facilitated a workshop on nuclear decommissioning for the evaluation team and provided input to all phases of the evaluation, including development of the methodology. The expert also participated in the key informant interviews and provided comments on each of the technical reports and the final report.

3.0 Evaluation Findings

3.1 Relevance

3.1.1 What is the environmental need that the Program is trying to address, its magnitude, related risks and targeted group?

Summary: Evidence indicates that there is an environmental and regulatory need for the Program. Various structures and areas at CRL and WL present environmental issues, including contaminated buildings and land, as well as outdated waste storage structures that need to be replaced. There are no documented risks to local communities, but the groundwater at CRL is being monitored. Cleanup work is required by the regulator (CNSC) as a condition of licensing.

Analysis

The NLLP is intended to address environmental issues identified that resulted from 60 years of nuclear-related activities. According to the program resourcing proposal and the Annual Progress Report to Treasury Board Secretariat for 2006-07Footnote 110 and 2007-08,Footnote 111 the NLLP represents an estimated liability of approximately $7 billion (current dollars).

The federal obligations for decommissioning and waste management are recorded as a long-term liability on AECL's balance sheet.Footnote 112 The amount of this liability is based on the discounted value of the estimated future costs of decommissioning, including all ongoing costs of disposal of the wastes, ongoing costs of operations under decommissioning, storage with surveillance, etc. (liability estimates are inflated for future years and discounted back to the present value using the Treasury Board Secretariat approved discount rate).Footnote 113

The liability estimates include the shutdown of redundant research facilities and associated buildings as well as the costs of treatment of a wide variety of wastes stored on AECL grounds that now pose an environmental hazard to the surrounding lands and water systems. Shutdown buildings and affected lands need to be decommissioned to meet federal regulatory requirements, and long-term solutions need to be developed and implemented for the wastes.

CRL interviewees identified various infrastructure items that presented environmental risks. These included various waste management areas and buildings, as well as radioactive waste storage facilities. At the time, there was no evidence that there were risks to the communities in the area, although there was ongoing sampling and testing of groundwater for radioactive contamination. Examples of risks to be addressed, as determined through the interviews, document review and case studies were:

  • WMA "A" contains expended reactor components as well as buried liquid wastes that need to be cleaned up. The area is the source of underground plumes that contain Sr-90.Footnote 114
  • Aging tanks that contain higher-level radioactive liquid waste are rusting. The tanks have to be replaced, and the contaminant waste relocated to a new storage facility elsewhere. The tanks are not leaking at this point, but there is evidence of corrosion. This is being addressed by the LWTS project, which will provide a new storage facility for legacy radioactive waste in 21 aging tanks, which are beyond their design life and are starting to corrode.
  • Containers used to store spent fuel also need replacement. Stored fuel wastes – about 22 tons of material – are primarily metallic uranium and uranium dioxide, and as such, are more prone to corrosion than the modern alloy-clad uranium oxide fuels in use today. The condition of some of the tile holes has deteriorated over time. Some of the cap gaskets on the older holes have allowed water to leak in, subjecting the stored fuel to corrosion. Of the 7,000 holes, about 100 are considered to be in a deteriorated condition and need to be replaced.
  • Ground Water and South Swamp Contamination – Historic waste storage operations at CRL have led to several instances of groundwater contamination due to leaching of the waste from CRL's WMAs. The focus of these treatment systems is to arrest the spread of the environmental impact; the liability associated with groundwater contamination will be addressed through ongoing treatment of plumes. There is also surface contamination in South Swamp, resulting from discharges from WMA "A" Footnote 115.
  • River Sediment Remediation – There is a contaminated area in the Ottawa River (CRL side) measuring roughly 200 by 400 meters. It is comprised of radiation and heavy metals (primarily mercury). The site is under 30 meters of water and is not subject to wind or wave action. AECL has not yet identified any reasonable direct means of human contact and exposure. CRL is further investigating risk to human health and the veracity of these assumptions. There is a need to make sure that decisions are carefully made, and that the public is consulted.
  • Legacy Lands Projects – Some of CRL's supervised property is contaminated as a result of former operations, experimental work and waste storage.
  • Some of the older (1940s-1950s) CRL buildings were built of wood, many of which are destined for decommissioning. The materials used to construct the buildings play a role in how they are decommissioned, and the extent to which flammability needs to be considered because of the contaminants that could be released under such conditions. It has been determined that the structures generally present various levels of contamination; and that the structures and materials are highly flammable. These factors are considered in allocating priorities for action by AECL.

Other specific areas that also need to be addressed, include a number of the CRL Waste Management Areas (WMAs 116), as well as buildings and other infrastructure on site. 117 According to the majority of interviewees, these and other areas and infrastructure are deteriorating and are presenting on-site health and safety risks, including fire hazards. In 2005, the CNSC required a financial guarantee that decommissioning would be appropriately funded.

To date,Footnote 118 three areas have been remediated of contamination, with the waste disposed of. The three sites are: 1) Blimkie's Meadow, 2) Lysimeter Patch, and 3) Perch Lake Meteorological Study Area/Canopy. These areas have been formally turned back over to the landlord (Operations at AECL). Table 4, following,Footnote 119 is a list of the 30 known contaminated sites that are under maintenance and surveillance funded by the NLLP.

Table 4: CRL Supervised Areas/WMAs - NLLP Responsibility March 2009
Area
WMA A East and South Swamps
WMA B West Swamp
Grey Crescent
Perch Lake Swamp
Areas of Contamination Associated with LDA Pipeline Leaks
Ottawa River Sediment
Dawson City
Shooting Range
1953 Pipeline
O-Nest Transfer
Twin Lake Experimental Site
Glass Blocks
Deep Boreholes
Shallow Boreholes
Under NRU Stack Duct
LDA Pipeline Plume #2
WMA A Plume
Glass Block Plume
LDA Chem Pit Plume
LDA Reactor Pit #1 Plume
LDA Reactor Pit #2 Plume
WMA B Plume #1 (Sr90)
WMA B Plume #2 (Sr90)
WMA C Plume
Nitrate Plant Plume
Thorium Pit Plume
Main Stream at Perch Lake Inlet #2
Perch Lake Sediment
Perch Creek
Bulk Storage Compound

The Whiteshell site differs from the Chalk River site in that the WL facilities are newer than CRL's (i.e., WL dates from the 1960s while some CRL buildings date from the
1940s). Thus, WL waste information was recorded in a way that met more modern standards and waste management itself was conducted to meet more modern standards. In addition, as noted earlier, the research reactor at Whiteshell (WR-1) was partially decommissioned in the 1990s.

WL does not have legacy lands and infrastructure dating from the 1940s and 1950s, during which waste management and record-keeping practices were significantly less demanding than today's standards. The contamination is also less complex due to the soil structure at the WL site, which is less permeable than that at CRL.

WL has better information about its facilities. Planning of decommissioning at WL has focused on operating cost reduction as a priority.

In 2005, a number of buildings in WL were in a state of Storage with Surveillance with some contaminated areas requiring attention. From an environmental perspective, there are no immediate risks, in part due to the geological characteristics of the site. The ground has a strong clay component, which to some degree creates a natural barrier against seepage from buried radioactive wastes in the waste management area, and there is no evidence of contamination in the soil, except for some surface contamination at the WMA.

3.1.2 Is the Program consistent with government priorities and NRCan strategic objectives?

Summary: The objective of the NLLP is consistent with federal roles, responsibilities and priorities. The NLLP also supports all three of NRCan's strategic objectives.

NRCan's overall objective is to ensure the responsible and sustainable development of Canada's natural resources, including nuclear energy. The waste and contamination situation is a recognized liability that appears in the Public Accounts of Canada, and on AECL's balance sheet.

Prior to the development of the NLLP, AECL could only afford to address the most pressing issues, and in some cases, with short-term solutions. According to the literature review and expert advice, world nuclear waste management trends currently (2009-10) favour accelerated efforts to decommissioning due to a number of considerations, including the increased costs of delaying such work. Delaying work is also seen as imposing a burden on future generations.

Analysis

Federal Responsibility

According to NRCan interviewees, supported by the documents listed below, nuclear regulation and waste management policy fall within the jurisdiction of the federal government, with high priority afforded to health, safety, security and environmental implications in relation to nuclear activities in Canada. The legislative framework is comprised of four key Acts:

  • Nuclear Safety and Control Act (regulation);
  • Nuclear Energy Act (nuclear research and development);
  • Nuclear Fuel Waste Act (waste); and
  • Nuclear Liability Act (liability).Footnote 120

As noted previously, both AECL and the CNSC report to Parliament through the Minister of Natural Resources.

In addition to the policy and other responsibilities of NRCan, there are five other federal entities which have some responsibility for nuclear security, health, safety and trade. These are: DFAIT; Health Canada; Transport Canada; Industry Canada; and the National Research Council (NRC).Footnote 121

NRCan Mandate and Priorities

NRCan's Energy Sector has the lead Government of Canada (GoC) role for energy policy. Its goal is that the secure and sustainable production and use of Canada's energy resources provide benefits for Canadians economically, environmentally and socially.Footnote 122

The NLLP's objectiveFootnote 123 is entirely consistent with the mandate of the Energy Sector.

NRCan's first strategic objective, as expressed in its 2009-10 Departmental Performance Report, is "Natural resource sectors are internationally competitive, economically productive, and contribute to the social well-being of Canadians."Footnote 124 The social well-being of Canadians, particularly related to the NLLP's health, safety and environment priority, clearly supports this strategic objective.

The second NRCan strategic objective that "Canada is a world leader on environmental responsibility in the development and use of natural resources" is directly supported by the NLLP. Environmental responsibility is among the NLLP's fundamental elements.Footnote 125

NRCan's third strategic objective is "Natural resource knowledge, landmass knowledge and management systems strengthen the safety and security of Canadians and the stewardship of Canada's natural resources and lands." The NLLP is clearly oriented towards strengthening the stewardship of Canada's natural resources and lands, while supporting the safety and security of Canadians.Footnote 126

NRCan supports the federal government in its regulatory responsibilities of nuclear materials and activities in Canada. NRCan's objective is to ensure the responsible and sustainable development of Canada's natural resources, including nuclear energy. NRCan is supported by AECL and the CNSC within the Canadian nuclear energy program, in fulfilling this objective.

The document review indicated that NRCan's strategic objectives and priorities were well aligned with and supported by the NLLP; this finding was consistent with the interview data. Interviewees agreed that the NLLP was consistent with overall government priorities. Prior to the NLLP, TBS-funded programs supported decommissioning activities on AECL sites; however, the funding was insufficient in terms of magnitude and continuity relative to the requirement.

The legacy radioactive waste, site contamination, and decommissioning situation are a recognized liability that appears in the national accounts of Canada. Thus the role of the federal government in the NLLP is appropriate.

The NLLP was and continued to be relevant to the needs of the stakeholders, in this case, AECL. CRL interviewees explained that the funding levels required to address clean-up and decommissioning issues were much greater than AECL's resourcing capacity and that AECL's commercial activities were presently unable to cover decommissioning costs.

A senior interviewee said that until 2006, waste management was under funded from 1983 forward, and that previous to the NLLP, AECL could only address the most pressing issues, and in some cases, with short-term solutions.

Other government interviewees also reinforced the fact that AECL did not have the funding base to address liabilities with respect to contamination and site clean-up requirements. They further noted that world trends were towards accelerating decommissioning work to shorter time cycles, and that delaying decommissioning was seen as placing a burden onto future generations.

3.1.3 Is there a legitimate, appropriate and necessary role for NRCan in the Program? Is NRCan's role appropriate in the context of the role of others?

Summary: NRCan's role in the NLLP is appropriate, given the Minister's responsibility to Parliament for AECL and CNSC. This role responds to a need for better oversight of funds than was the case under the previous funding program. The general view (of interviewees, including stakeholders) is that there is an oversight role for NRCan in NLLP.

Analysis

NRCan supports the federal government in its responsibilities regarding nuclear materials and activities in Canada. The Department of Natural Resources Act (DNRA) deals with this in a general way, for example, Section 6 notes that the Minister of Natural Resources " In exercising the powers and performing the duties and functions assigned to the Minister by section 5, the Minister shall (a) have regard to the sustainable development of Canada's natural resources and the integrated management thereof. . .(e) seek to enhance the responsible development and use of Canada's natural resources and the competitiveness of Canada's natural resources products; …"Footnote 127

There are two complementary legislative Acts that deal with the long-term management of nuclear fuel waste. One is the Nuclear Safety and Control Act (NSCA), which is administered by the CNSC. The second is the Nuclear Fuel Waste Act (NFWA) administered by NRCan. The latter requires owners of nuclear fuel waste to establish a trust fund to pay for the long-term management of the wastes. The former gives the CNSC the authority to require licencees to provide financial assurance that the full costs of nuclear decommissioning will be covered (financial assurance can include commitment on the part of provincial or federal government).Footnote 128

NRCan's activities, roles and responsibilities under the NLLP are therefore consistent and compliant with the DNRA, NFW, and NSCA.

The need for government involvement, in particular NRCan's oversight role, was supported by the majority of NRCan and AECL interviewees.

In addition to these considerations, there are two organizations which report through the Minister of Natural Resources to the Parliament of Canada that play key roles in the Canadian nuclear energy program, i.e., the CNSC and AECL. Thus, the Minister of NRCan is responsible and accountable for the NLLP, AECL and the CNSC; i.e., the oversight function, regulation and delivery of the NLLP. The NLLP is therefore directly relevant to, and consistent with the mandate of the Minister of Natural Resources and his/her department.

This evaluation concluded that the NRCan oversight role vis-à-vis the NLLP is needed and consistent with the mandate of the Department and the Energy Sector.

3.2 Performance

3.2.1 To what extent have intended outcomes/results been achieved as a result of the Program?

Summary: The evaluation found that the NLLP project work was generally behind schedule, with some projects over budget. About two-thirds of the NLLP milestones were expected to be completed by the end of the five-year funding period. However, results based on milestones should be analyzed with caution as the milestones vary considerably in size and scope. As well, there were changes in milestones, with some of the original milestones cancelled because of changes in strategy, or operational buildings not being turned over to decommissioning, and new ones added. Many of the delays were attributed to start-up challenges, insufficient experience and capacity to manage the NLLP at the outset, and insufficient data on the nature of the contamination for legacy sites (especially at CRL).

In spite of the delays in implementation, many of the higher risk health, safety and environmental issues in CRL were being addressed. Some buildings were successfully decommissioned, including buildings 107, 133, 144, 464 and part of Building 204. A waste analysis facility was also completed at CRL. A large amount of characterization and environmental risk assessment work had been conducted for the WMAs. Key projects such as the FPS and LWTS were under way, although the latter was on hold due to a significant increase in estimated costs and an extended schedule. Environmental monitoring and remediation work had also been initiated. Documentation also indicated annual maintenance cost savings of $180,000 as a result of decommissioned buildings in CRL.

Whiteshell adopted an accelerated schedule starting in 2007. Various buildings were decommissioned, and waste management facilities were established. The site's utility system was being reconfigured. A decentralized electric heating system was being installed so that the central power oil-fired boilers could be shut down and dismantled, which was expected to lead to significant cost savings ($600,000 in annual cost savings by 2012).

The evaluation confirmed that without the NLLP, the decommissioning activities would have been much more limited in terms of size and scope.

Analysis

The implementation of the program has been slower than expected (see Table 3, which compares the original approved expenditure forecast to actual expenditures). This has also had an impact on the achievement of the program milestones, which is another indicator of results achieved (albeit imperfect, as discussed earlier).

Table 5 AECL NLLP Expenditures: 2006-09 ($ millions)
Areas of Work Program resourcing proposal Actuals Differential
Address health, safety, environmental priorities 93.0 80.1 -12.9
Accelerate decommissioning buildings 51.7 43.1 -8.6
Lay the groundwork for future phases 79.9 46.5 -33.4
Care and maintenance 73.7 94.5 20.8
Funding carried forward* (2009-2010)   4.5 4.5
Total 298.3 268.7 -29.6

Source: Annual Progress Report for Nuclear Legacy Liabilities Program, NRCan (2010).
*Included in total.

A total of 161 milestones were identified and approved in the 2006 program resourcing proposal for the NLLP.

A mid-program review conducted by AECLFootnote 129 confirmed that about two-thirds of the NLLP milestones, under NLLP, would be achieved in the five years of the start-up phase, including many of the high priority health, safety and environment milestones and the decommissioning of some of the key buildings and facilities. However, as indicated in the Comprehensive Preliminary Decommissioning Plan (2006), an analysis of NLLP results, based on milestones, should be made with caution as milestones vary considerably in size, scope and cost implications.

As indicated in the minutes of the Joint Oversight Committee (JOC)Footnote 130 as well as interview data, the evolution of the five-year start-up phase resulted in the need to make changes to the program milestones. For WL, 10 milestones were deleted and 37 milestones added due to the accelerated decommissioning strategy selected in 2007. Changes in the decommissioning approach at CRL made three milestones redundant. Also, as indicated in JOC meeting minutes, AECL Operations "continues to use a number of CRL buildings that were to have been turned over to the NLLP during the five-year start-up phase for decommissioning. As a result, the NLLP cannot complete the decommissioning milestones that were associated with those buildings."Footnote 131 Appendix C contains a complete inventory of the milestones and their status as at March 2009.

According to interviewees and the document review and analysis, the causes of delays in achieving milestones were as follows:

  • There was insufficient understanding of the underlying character of the contamination at many sites and facilities to be decommissioned. The technical issues were often more complex than first understood.
  • There were delays by CRL Operations in turning buildings/sites over to the decommissioning group. The need to coordinate timing and release of buildings by Operations at CRL remained a continuing challenge. This was not an issue at Whiteshell.
  • CNSC licensing processes were more complex and lengthy than originally thought (by AECL).
  • The time and complexity of environmental assessment requirements were also described by the majority of interviewees as having caused delays.
  • CRL interviewees noted that a lack of appropriately skilled personnel, sometimes delayed planning of decommissioning. An example of this was the long period of time required to hire health and safety (radiation protection and health physicist) personnel.
  • The lack of a comprehensive waste management strategy also caused a slow down in the project. Interviewees noted, for example, that the United Kingdom, which was more advanced in decommissioning at sites such as Dounreay (located on the northern coast of Scotland),Footnote 132 had an integrated waste strategy that identified the different kinds of waste and their disposition.
  • The lack of a detailed and accurate inventory and records of the legacy wastes stored in the different waste management areas at CRL caused delays and complicated the waste characterization activities.

The majority of interviewees felt that the original projections were too optimistic and that there was insufficient understanding of the complexity of the decommissioning projects, the need to hire, train and integrate new staff, and the need to gain expertise both internally and in the contractor community. Some projects involved the need to obtain foreign experts and other government departments, which led to further delays (see example in the following box).

Decommissioning: CRL Solvent Bunker No 1.

CRL Solvent Bunker No. 1 contained a number of legacy solvents and some chemical weapons agents such as mustard gas and other blistering agents dating back to the post World War II era. Decommissioning involved Department of National Defence and staff from Defence Research and Development Canada (DRDC) in Suffield. Project delays were caused by the need to accommodate the schedules of the experts. Coordination was needed between radiation protection and removal staff. All those involved with the bunker needed to wear protective clothing and use respirators and other special safety equipment. The decommissioning project team chipped away at the concrete to expose six drums, some of which contained traces of mustard gas. Glass bottles were discovered in the drums that contained a radioactive solution of Plutonium.

This was further complicated by the challenges faced in coordinating with CRL Operations regarding the release of facilities. In spite of delays and the time taken to mobilize and implement the NLLP, interviewees reported that the high risk areas (from a health and safety perspective) had been, or were being addressed.

It should be noted that in addition to the actual tear down of buildings (or recovery of buried waste), decommissioning involves establishment of 'enabling facilities' to permit treatment or storage of the waste generated. These facilities need to be constructed before conducting decommissioning work.

The following describes the major achievements of the NLLP as taken from the AECL report:Footnote 133

  • The decommissioning of buildings at Chalk River Laboratories (CRL) and Whiteshell Laboratories (WL), such as the CRL Radiochemistry Laboratory, the CRL Plant Hospital, the WL Engineering and Administration Building, the WL Cafeteria, as well as the Underground Research Laboratory (URL) near WL.Footnote 134
  • The design, construction and commissioning of waste clearance facilities at CRL and WL (an enabling facility).Footnote 135 The purpose of these facilities is to monitor likely clean waste in order to confirm that it can be recycled or disposed of as non-radioactive waste. These facilities will enhance AECL's ability to demonstrate that significant volumes of legacy waste can be managed as conventional waste, which will result in considerable cost savings to the Program.
  • Establishment of a Waste Handling Facility in the WL Shielded Facilities to process radioactive waste produced by decommissioning activities (an enabling facility). The facility has two compactors and an automated gamma waste assay system.Footnote 136
  • The design of new waste management facilities to deal with stored liquid wastes and used research reactor fuels.
  • Waste retrievals and remediation of higher-level radioactive wastes buried in CRL ; WMAs.

The following describes some of the specific accomplishments at CRL and at WL.

Chalk River Laboratories:

In spite of NLLP delays, there have been a number of accomplishments in decommissioning at CRL. The discussion that follows highlights the most significant areas of NLLP programming at CRL.

Results and Progress on the Liquid Waste Transfer and Storage (LWTS) Project

The purpose of the LWTS Project at the CRL was to provide a new storage facility for legacy radioactive waste now contained in 21 aging tanks. The original plan in 2000 for dealing with the liquid waste (currently stored in tanks) was to use vitrification (i.e., encasing the waste in glass). This option was later deemed to be prohibitively expensive, as it would cost several hundreds of millions of dollars.

The LWTS Project was initiated in 2004 at an estimated cost of $40 million. Prior to the initiation of the NLLP in 2006, the cost estimate had been increased to $64 million, and it was further increased to $100 million in the fall of 2007. By December 2008, the cost estimate had increased to $170 million plus contingency, and the date for completion of construction was 2013, plus an estimated five years to complete the transfer.

Because of the significant increase in the cost estimate, AECL established an AECL Review Team in January 2009 to assess next steps. In particular, the team was asked to evaluate technologies for dealing directly with the liquid waste (e.g., solidification) to determine whether the intermediate step of constructing new storage tanks could be avoided. Following the review, AECL recommended a new approach that would avoid the need to construct new storage tanks and could be accomplished at a significantly lower lifetime cost. AECL advised that a small percentage of the liquid waste inventory (11,500 litres) could be treated in the CRL Waste Treatment Centre, and recommended that mobile cementation equipment be constructed in order to cement the remainder of the waste by 2019 into a form suitable for long-term management. In June 2009, AECL obtained a third-party review from external experts of their decision-making process to arrive at the new approach.

During the review of the LWTS Project in the first half of 2009, the project was put 'on hold', however it was decided to complete the remaining 10% of the detailed design of the new liquid waste storage system (one of the NLLP milestones) including design and safety analyses to support an application to the CNSC for construction approval. This work was to be completed in the first half of 2009.

The LWTS was later cancelled by the JOC, and AECL's proposed new approach for managing the waste was adopted, including the design and construction of a Mobile Cementation Skid to solidify the bulk of the legacy liquid waste.

Results and Progress on the Fuel Packaging and Storage (FPS) Project

The purpose of the FPS project is to remove old containers of fuel waste that are considered to be in poor condition from about 100 tile holes and to safely transfer the fuel to a new stand alone facility. This involves the removal, drying and re-storing of the fuel in a new facility as well as construction of a weight-bearing system to handle the removal equipment.

The project was at least three months behind the schedule (developed four years ago). It was expected that the facility construction would be completed by March 2011. The FPS project was approved in 2004 based on a conceptual design, with an original budget of $56.6 million. Given the recently completed detailed design, a new cost estimate for the project of $82 million has been provided. The $25.4 million cost increase was primarily related to escalation in the costs of materials and required engineering.

Results achieved for CRL Environmental Remediation

Progress and results to date are summarized as follows:

  • Ground Water Treatment Systems - Historic waste storage operations at CRL have led to several instances of groundwater contamination due to leaching of the waste.Footnote 137 Further, in the past liquid waste was disposed in pits at the site. The focus of this project is to arrest the spread of the environmental impact. The liability associated with groundwater contamination is being addressed through the ongoing treatment of plumes at three locations, and the construction of a fourth groundwater treatment system (the South Swamp Treatment System described under the next bullet). However, there have been challenges with contamination control at the existing Chemical Pit and Spring B groundwater treatment plants. These challenges have been or are being addressed through a number of initiatives.
  • South Swamp Treatment System – This project is at the Technical Scope of Work (SoW) stage. The conceptual design was revised as issues were raised about the quality of the information that was used to develop the previous design. Thus, the anticipated environmental benefit of reducing the amounts of Sr-90 contained in the surface of the South Swamp will not be achieved until a new treatment strategy is developed and implemented. Footnote 138
  • River Sediment Remediation – This project is focused on assessing the nature of AECL legacy contamination (radioactive and non-radioactive) found in the Ottawa River sediments (both spatial and temporal aspects), determining the requirements for remedial measures, and implementing remedial measures as necessary.Footnote 139

    Interviewees noted that based on preliminary investigations completed to date there appeared to be very little risk to human health although CRL was investigating further. Physically interacting with the contamination (e.g., through removal) was thought not likely to be the best solution because disturbing the sediment might have higher risks (e.g., for workers, and due to the potential further dispersal of some of the contamination) than leaving it in-situ. In the longer term, as gaps are addressed, a finalized conceptual site model will evolve and a comprehensive Ecological Risk Assessment and Human Health Risk Assessment will be conducted considering each remediation option.
  • Legacy Lands ProjectsFootnote 140 — Certain areas within CRL have been impacted by former operations, experimental work and waste storage. Some of these areas are to be remediated while others will be controlled to allow for natural attenuation and decay to occur. The essence of this project is to plan and execute work on a priority basis on those impacted areas to protect health, safety and the environment, and reduce the liability.

    Implementation of specific legacy lands remediation measures will be phased in based on assessments of health, safety and environmental risks, business risk and regulatory requirements. Characterization is progressing (a number of areas have been investigated to date).
CRL Shutdown of Facilities

This project involves responding to the need to accelerate facility decommissioning at CRL. Many of the older buildings and structures at CRL are at the end of their operating life, complex in nature, and potentially contaminated, as they housed a variety of activities involving radioactive and industrial hazards.

Main achievements to date include:

  • To protect the shutdown NRX reactor, a firebreak was created in fiscal year 2008-09 between it and the connected used fuel storage and handling bays by removing a portion of the Bay building (B204) and connected buildings B133 and B144. The longer-term strategy is to fully decommission the B204 bays once suitable waste management facilities are in place to process and accept the significant volume of wood and concrete waste that will be created by the demolition.
  • Building 107 was demolished by the end of 2007-08, with the exception of the concrete slab, piers and underground services located at the north end of the site.
  • Buildings 133 and 144 were removed.
  • The Health Physics Building (Building 464) has been decommissioned and the site released for redevelopment ahead of schedule.

Avoided maintenance and heating costs of CRL buildings (buildings 107 and 464) that were completely decommissioned, will amount to approximately $180,000 in savings per year as a result of decommissioning work to date at CRL.

Delays in CRL building shutdown have occurred for a number of reasons, primarily because of delayed turnover of buildings by AECL Operations to the Decommissioning and Waste Management group. With the decommissioning of buildings that are no longer required, the three major types of risks (fire risk, physical risks, and cost management risks) are being addressed. The removal of shutdown buildings reduces operations and maintenance costs, and storage with surveillance costs described above.

Whiteshell Laboratories:

The WL decommissioning program was accelerated after 2007. Previous to 2005, the overall plan was to complete the decommissioning work within a 60-year timeframe.

Since 2006, the following have been achieved:

  • Decommissioning of many of the redundant buildings on the main campus.
  • Decommissioning of much of the redundant equipment and former experimental areas in the Shielded Facility.
  • Decontaminating about one hundred laboratory rooms in the main nuclear research laboratory complex (Building 300), including the removal of furnishings and services; obtaining a CNSC license for a shielded modular above-ground storage (SMAGS) unit, and initiating construction.
  • Addressing immediate risks by cementing the site inventory of liquid wastes:
    • significant progress has been made in removing the ventilation system components from Building 300;
    • facilities were built to handle radioactive waste; WL now has new waste clearance and waste handling facilities; and
    • WL non-nuclear buildings have been or are being evaluated for reuse, recycling or demolition:
      • a Detailed Decommissioning Plan (DDP) was completed for the South-Side Buildings and another DDP for the North-Side Buildings was under project review; and
      • buildings 500, 501, 518, 529, 530, 400, 406, 410, 921, the Fire Training Trailer and the Environmental Storage Trailer were decommissioned and the associated building sites remediated. The site's utility system is currently being reconfigured (two buildings have been converted to date). Footnote 141 This is being done to install a decentralized electric heating system in all non-redundant buildings so that the central power oil fired boilers can be taken out of service and dismantled, leading to significant cost savings.

Other work is ongoing, including decommissioning of the Underground Research Laboratory.

Under the current decommissioning schedule for WL, it is estimated that it will now take at least 20 years to complete the work.

Decommissioning work is above budgeted costs. WL interviewees explained that the 2005 liability estimates were not adequate (for example, a contingency estimate of 25% was provided, while world practice was a minimum 50%), and as a result, the indirect costs of decommissioning were underestimated. The care and maintenance costs associated with the site have increased (e.g., increased fire protection requirements).

The 60-year schedule was based on gradual decommissioning, with buildings left in a state of storage with surveillance (SWS). However, this would have involved extensive maintenance costs, while an accelerated schedule will partly avoid these costs (SWS still involves heating and maintenance costs). It was reported (in interviews as well as by experts) that U.S. sites were adopting this approach. The schedule had been revised twice since the beginning of the present NLLP funding cycle to reflect the accelerated approach.

The work on the reconfiguration of the heating system was based on a study of forecasted energy costs, with the help of a contractor and in cooperation with the provincial hydro provider. WL adopted an accelerated schedule in 2007; much progress had been made since that time. An example of an important achievement was the reconfiguration of the site's utility system. This was considered to be important because it was projected to reduce annual heating costs (through conversion to electric heating) by about $600,000 by 2012.Footnote 142 Considering the changeover costs, the investment was expected to be recovered within a five-year timeframe.

According to senior management at WL, the entire accelerated approach was based on the prioritization of the work based on the projected maintenance costs. Priority was given to specific buildings to reduce the footprint of those buildings by 90%.Footnote 143 At this point, waste was being stored on site, and a shielded modular above-ground storage unit was being constructed to provide additional storage capacity. Waste would eventually be sent offsite, possibly to CRL, according to interviewees.

3.2.2 Have there been unintended (positive or negative) outcomes? Were any actions taken as a result of these?

Summary: Although not necessarily all classifiable as 'outcomes', the evaluation found that there had been several major unintended or unanticipated discoveries involved in the delivery of the NLLP.

The first was the discovery of how poorly documented and misunderstood the nature of the legacy wastes were. This resulted from a lack of characterization and location information that delayed the delivery of NLLP projects.

Another unanticipated discovery was the degree to which AECL was properly equipped to deliver a major decommissioning operation in terms of access to the technology, knowledge, and practices involved. This contributed to an underestimation of schedule and resources (financial, technological and human) requirements.

A third unanticipated discovery was the complexity of operating a major decommissioning project in parallel with ongoing operations at the CRL site. This resulted in competition between operational and decommissioning groups at AECL for human resources and equipment, which delayed the decommissioning work substantially.

The fourth unanticipated outcome, which was positive, was the increased knowledge base and capacity within AECL to undertake complex nuclear site decommissioning projects as a consequence of the experience gained thus far under the NLLP (e.g., at the WL site). AECL WL interviewees reported the hope that this capacity could eventually serve as useful experience for undertaking contract work in the future.

Analysis

The evaluation found that the technical complexity and the time required to increase human resource capacity to meet the NLLP milestones were underestimated. The nature and even the location of wastes were often unknown.

As a result of this and AECL's reticence to obtain advice from external sources (see section 1.4.4), some projects were significantly delayed or experienced cost overruns.

Examples follow:

  • The Fuel Packaging and Storage (FPS) Project: Although this project was reported as being delayed by only a few months, the cost estimates of the project had increased considerably. Delays occurred in defining and awarding major external contracts, as well as in resolving technical problems in the design. As well, contractors had to comply with the new management systems requirements outlined in CSA N286-05 resulting in delays in obtaining approvals. Finally, delays were encountered in the health and safety review processes. AECL reported that,Footnote 144 as a result, the original budget increased from $56 million to $82 million.
  • The Liquid Waste Transfer and Storage Project (LWTS): This project was initiated in 2004 at an estimated cost of $40 million. Although $30 million was spent on the project, AECL decided to place the project on hold pending a technical review of the technology options developed, partly because the cost estimate had increased to over $100 million by 2007. By December 2008, the cost had increased to $170 million plus contingency, and the date for completion of construction was 2013, plus an estimated five years to complete the transfer. A number of factors explained this increase:
     
    • The 2004 cost estimate was based on an estimate provided by a private sector firm in the 1990s. In retrospect, this cost was inaccurate and the analysis outdated.
    • The technical complexities and scope of the LWTS project were greater than originally anticipated when the project was first conceived.
    • Over the past ten years, regulatory requirements have changed resulting in an increased level of effort required for the project.
    • Considering the excessively high new cost estimates, contracts were cancelled in order to delay work while the approach for managing the waste was reassessed. Part of the increased costs included compensation for contractors resulting from the cancelled contracts.

The above projects demonstrate the challenges inherent in many of the decommissioning projects. The challenges often arise from a number of sources. Undocumented contamination means that investigatory work has to be conducted as part of the detailed planning before the decommissioning effort can proceed. Also, in many cases the technical approaches for projects have needed to be revisited because the technical approach originally envisioned was found to be either unfeasible or not cost-effective.

3.2.3 How economic is the Program?
3.2.4 What factors drove the cost and schedule variations for the work accomplished to date?

Summary: Given the nature of decommissioning activities, it is difficult to identify the extent to which a given program is a "least cost" alternative or is relatively cost effective (economic). As a result, this section focuses on the factors that drove the cost and schedule variations.

The evaluation found that the actual costs and scheduling of the decommissioning work generally exceeded original forecasts.

The evaluation did not point to specific approaches that were "uneconomic." Rather, it found a lack of adequate understanding of the complexity of the problem at the outset, which resulted in underestimation of the costs and the time required to complete the decommissioning work, as well as insufficient project/program management capacity to manage a program of this size and complexity. Factors contributing to this situation included inadequate cost estimating expertise (which led to erroneous cost estimating and overly optimistic cost estimates initially), inadequate characterization information, poor planning, insufficient conservatism in milestone development and insufficient systems and training for managing the NLLP as a portfolio of projects.

The situation has been improving, particularly in the last two years. Characterization work is now being carried out, as are feasibility studies and better pre-planning of individual projects. In addition, new staff members with appropriate (e.g., international) experience are being engaged, and lessons learned from other jurisdictions are being actively pursued.

One area that can potentially cause the Program to be uneconomic is the lack of long-term solutions for radioactive waste. Because there is no formal long-term plan, low and medium-level radioactive wastes are being stored in temporary facilities – sometimes at high cost – pending a final decision regarding how to handle the waste permanently.

While a considerable volume of the radioactive waste generated from the decommissioned facilities and buildings has been shipped to the U.S. for treatment or destruction, there has been a need to put some waste in temporary storage, which will have to be removed and relocated when a final waste storage solution is developed. While this practice will need to continue for some time (because it can take more than a decade to site, characterize and construct long-term radioactive waste management facilities) there is a need to move toward identifying and implementing long-term solutions.

A more definitive conclusion regarding cost-effectiveness would require identification of whether or not similar results had been obtained at lower costs elsewhere, which would involve benchmarking with other decommissioning programs (i.e., conducted by other countries). This was external to the Terms of Reference for this study; however, given the cost overruns and delays as well as expert advice, it is likely that the work carried out to date could have been accomplished more quickly and at lower costs.
Analysis

In the context of program evaluation, economy refers to the use of resources (public funds) to produce program impacts. Therefore, when asking how economic a program is, evaluators assess the extent to which programs make good use of resources to achieve expected outcomes.

The analysis that follows is based on interviews, document reviews, expert advice and case studies.

This evaluation found that the following factors explained the cost and schedule variations for the work accomplished throughout the first three years of the NLLP:

  • lack of adequate pre-planning including characterization, costing, contingency estimates and prioritization;
  • operational issues – difficulty in timing of the transfer of facilities from Operations to the Decommissioning and Waste Management Division;
  • project management weaknesses (e.g., contracting, risk assessment) to deliver a program of this magnitude;
  • a widely-reportedFootnote 145 history of inaccurate and incomplete records of stored wastes, which increased the time required to conduct characterization activities and sometimes resulted in undocumented wastes found in sites being decommissioned;
  • failure to adequately characterize the nature of the contamination contained in many of the facilities in advance of preparation of the overall plans and budgets;
  • insufficient conservatism in milestone development; and
  • Uncertainties as to the best technical approach to take in some projects (e.g., LWTS).
Project Management

AECL has implemented a variety of systems and practices to manage projects that have evolved over time.

The Research and Technology Operations Projects Group (RTOP) manages CRL projects costing more than $1.0 million. RTOP uses a mature project management system based on PrimaveraFootnote 146 as its main scheduling and resourcing tool. Meanwhile, Excel-based tools are then used to provide summarized reports of the Primavera outputs. RTOP also use project management tools, such as Project Management Body of Knowledge (PMBOK)Footnote 147 and the International Organization for Standardization. Financial reporting is conducted monthly through Oracle, with variance reports being provided to clients.Footnote 148 RTOP also provides NLLP with monthly reports, and attends project review boards and stakeholder reviews.

As AECL's overall manager of the NLLP, the Liability Management Unit is responsible for ensuring that client needs are met for NLLP decommissioning projects. A recent AECL "Lessons Learned" study (2009)Footnote 149 concluded that project management for the NLLP suffered from a number of issues. The study indicated that, from the outset, the LMU did not fully recognize the full scope or complexity of what was being proposed in the NLLP.Footnote 150 Thus, a clearly defined and delineated management structure was not yet in place to provide a "portfolio" management approach.Footnote 151

Other issues identified in the report and confirmed in the interviews that impeded progress, caused delays and cost overruns in delivering the NLLP were:

  • conflicts in obtaining human resources from within AECL due to a lack of coordination among the AECL lead suppliers;
  • insufficient understanding of the LMU and its functioning within AECL;
  • insufficient staffing of the LMUFootnote 152 to manage a $500 million program; and
  • inexperience of AECL staff in planning and managing NLLP-related large projects and in techniques such as cost-benefit analysis, risk assessment and contract management.
Inaccurate and incomplete historical records

Many CRL facilities were shut down in the 1950s and records were incomplete or missing. The lack of historical records at CRL was a major factor inhibiting proper characterization. For example, wastes were found in unanticipated locations, and the nature of the wastes was seldom known previous to discovery.

Failure to adequately characterize the nature of contamination at specific sites

One of the key steps in the planning process of decommissioning is characterization. Characterization refers to the use of physical surveys and analytical techniques to identify what kind of radiological and hazardous materials are present in facilities and sites, and to probe into the internal structure and properties of these materials. Characterization of site infrastructure and materials provides essential information for planning. Characterization results in better decisions based on the collection and analysis of information describing the hazards at the facility, the condition of the facility structures, and the nature and levels of contamination.

While the major effort of decommissioning is the removal of radioactive material, other potentially hazardous contaminants must also be characterized and removed, such as asbestos, mercury, polychlorinated biphenyls (PCBs), and lead. The characterization process should encompass all structures, land and water within an adequate perimeter, including soil and water (surface and subsurface), adjacent waterways, gaseous effluents and surface solids. Characterization is typically conducted throughout the lifespan of projects. It is especially important in the initial phases of projects and is the first step in cost-benefit analyses as well as risk assessments.

A majority of interviewees were of the opinion that the characterization information was inadequate. A number of them explained that characterization was now (2009-10) an ongoing process and that new items or contaminants had been found since 2006. Project manager interviewees observed that projects were implemented with limited information and/or cost-estimates that were ultimately found to be significantly below the actual costs.

Interviewees provided examples of projects with inaccurate characterization or costing information. Contractors involved in these projects were forced to make assumptions based on limited information. Those interviewed commented that better characterization should have been conducted. FPS, for example, was described as having involved a number of uncertainties and risks. The exact condition of many of the tile holes to be addressed by the FPS project was unknown initially and required further investigation.

Cost estimates were not adequate

Accurate cost estimation of decommissioning requires good information regarding the underlying structures or areas (characterization information), as well as good costing models. The evaluation noted that both factors were weaknesses in AECL's costing efforts. Characterization was weak, and as noted by interviewees, AECL lacked good costing models and experience in costing at the outset of the NLLP. This situation was improving as the organization gained both better information and increased experience in costing.

Some interviewees mentioned that human resource capacity to conduct cost estimates was also limited and that internal staff had been challenged by the volume of estimates involved. A senior member of the three-person team responsible for costing was about to retire, and there was no replacement available immediately.

It should be noted that a minority of interviewees disagreed regarding the availability of information initially. For example, one senior interviewee reported that there was "a lot" of information available previous to 2005. Hazard assessments were reported as having been conducted. A number of projects were "mature" in 2005 (e.g., LWTS, FPS, hot cell upgrade, waste treatment centre upgrade). These interviewees indicated that cost estimates varying from Class C (indicative) to Class A (suitable for contracting) reliabilityFootnote 153 were available, depending on the project. AECL also was described as having used estimates provided by contractors. These interviewees also reported, however, that characterization of the WMAs was limited at the time.

Examples of the cost impacts of these issues follow:

Liquid Waste Transfer and Storage Project – The LWTS project was expected to be significantly over budget. (As previously noted, the project was put 'on hold' during the evaluation period, and later cancelled by the JOC. However, an alternative solution for dealing with the legacy radioactive wastes, the Mobile Cementation Skid, was proposed in June 2009.)

  • By the time that the project was cancelled by the JOC, approximately $30 million had been spent on the LWTS project. The most recent estimates to complete the project were significantly above the original 2004 estimate ($40 million) and the estimate used for the program resourcing proposal in fall 2006 ($64 million). By fall 2007, the cost estimates had increased to approximately $100 million with a forecast completion date of 2011. By December 2008, the cost had increased to $170 million plus contingency, and the date for completion of construction was 2013, not including the estimated five years to carry out the transfer.

    According to AECL, the original cost estimate (from 2004) was based on an estimate provided by a private sector firm in the 1990s. In retrospect, this cost was inaccurate and the analysis outdated. The technical complexities and scope of the LWTS project were greater than originally anticipated when the project was first conceived. Part of the LWTS costs included compensation for contractors resulting from cancellation of contracts.
  • Fuel Packaging and Storage (FPS) Project – While this project was at least three months behind the schedule that had been developed four years ago, the project had encountered a number of challenges that had delayed progress. Some delays were encountered during the negotiation and awarding of major contracts.

    FPS project cost increases were primarily related to escalation in the costs of materials and required engineering. The FPS project was approved in 2004 based on a conceptual design, with an original budget of $56.6 million. Given the recently completed detailed design, a new cost estimate for the project of $82 million was provided. The $25.4 million cost increase was primarily related to escalation of materials costs and required engineering. A change request was provided to NRCan in February 2009 to reallocate funds to allow completion of the project.
  • CRL Shutdown of Facilities – The revised cost and schedule of the high-priority LWTS project also led to deferrals in planned studies regarding legacy waste treatment and long-term management, as well as some characterization and initial decommissioning work (note: timing of building shutdown is determined by AECL's laboratory operational needs, not the NLLP). Many of the buildings slated for decommissioning lack adequate records and characterization of their wastes.
  • Whiteshell (WL) Site – In 2005, the liability estimates were not robust, and as a result, the costs of decommissioning were underestimated. WL staff had since recognized that more experience with decommissioning and better understanding of the site contamination was needed before accurate projections could be made.
Uncertainties as to the best technical approach to take in project planning

One of the challenges faced by AECL staff concerns the best technological option to follow. This is made more difficult given that technologies are evolving and attitudes of the public and government toward the long term disposition or storage and/or transportation of radioactive waste can be the overriding factor in decision-making.

For example, some of the capital investments at CRL and WL are being made to store radioactive waste because there are no long-term radioactive waste management facilities in Canada. As a result, facilities are being built for temporary storage, pending a time when permanent solutions are developed and implemented. Evolving technologies and philosophies concerning the treatment of contaminated wastes can also cause uncertainty. For example, an alternative to storage of some wastes is incineration in the U.S. AECL has recently explored this option, but there is a risk that a change in the U.S. government policy could in theory remove this option at some point in the future.

In order to improve its ability to use the best technological options, AECL has recently (within the last 12 to 18 months) increased its interaction with other international agencies engaged in decommissioning, has hired staff from other organizations abroad, and has increased its use of consultants and experts to assess options.

While work at WL is less complex (less diverse wastes, less waste and more modern record-keeping), there is a disparity between the quality of the cost-estimates and the characterization information. For example, one senior interviewee believed that good cost estimates existed for about 60% of the work with 20% of projects considered as medium-risk and 20% considered as a higher-risk from a costing perspective. Many projects had unknowns and the total liability estimate was therefore not robust. The five-year planning budget was considered to be "coarse level" budgeting according to many interviewees. The implication for future WL work is to improve the basis of the cost-estimates by basing them on reliable characterization information as a first step. Reliable characterization information would identify the amount and nature of the waste to be dealt with, which in turn allows identification of processes, expertise and technologies required to be forecasted more reliably.

3.2.5 How efficient is the Program? Do the overall processes and internal practices used by AECL represent good project management practices?
3.2.6 Is AECL's internal management /governance of the NLLP appropriate or are there improvements that could be made?

Summary: AECL has implemented an internal management/governance for the NLLP which now appears to be functioning well. The governance structure is based on a Joint NRCan-AECL Oversight Committee and a Liability Management Unit managing all contracts within AECL and clearly defined supplier groups and clients. The evaluation found that generally, the governance structure was now working relatively well.

However, there are two exceptions to this. First, there does not appear to be a shared set of priorities across AECL (between Operations and the decommissioning group). Second, AECL reported a general perception that NRCan required excessively detailed reporting which some felt could be alleviated if NRCan had an increased site presence at CRL and WL.

As noted previously, AECL also utilizes a major capital project management group to manage projects over $1 million of value. Project management procedures for large projects are based on Primavera software.

Although project management, including contracting practices, was less effective for the first three years of the NLLP, improvements had been made since that time in terms of working with external contractors, employing external experts familiar with decommissioning, and networking with facilities and agencies that were advanced in decommissioning standards and practices. However, the evaluation found that there could be greater use of subcontractors and that issues with subcontractor management still had to be addressed. This was also supported by the internal mid-program review.Footnote 154 A number of interviewees noted that AECL had traditionally favored internal work – and to some extent still did.

At CRL, effective project implementation still suffers from a lack of integrated site planning between decommissioning activities and operational activities, and the lack of standard procedures for smaller projects not managed by the Research and Technology Operations Projects Group.

AECL has also faced challenges in increasing its utilization of contractors (issues of training, security clearance, and meeting health and safety, as well as knowledge of decommissioning practice and the AECL site). Contracting practices, while improving, have slowed work progress and increased costs in the past. Lack of adequate characterization information and a lack of early contractor involvement in projects have challenged AECL-contractor relationships and increased costs.

Analysis

Roles

The NLLP organizational structures, roles and relationships include:

  1. The NRCan/AECL Joint Oversight Committee is responsible for making decisions on the planning, delivery, reporting and administration of the NLLP.
     
  2. The AECL Liability Management Unit is the organization through which AECL-NRCan interaction takes place in addition to the JOC. The LMU oversees client requirement documents, specifications and funding of contracts, arranges invitations to bid, technical specifications and contractor payments. It also sets overall strategies and priorities and oversees and tracks progress and develops plans for AECL's implementation of the NLLP.
     
  3. AECL lead suppliers manage and execute projects, or subcontract work and provide technical expertise.
     
  4. External contractors and consultants provide expertise, manage and implement subcontracted projects.

The interviews conducted for the evaluation indicated that the governance structure was in general working well, and there was good collaboration between NRCan and AECL. Some AECL staff members believed that NRCan requested more detailed information than was necessary, and that this could be ameliorated if NRCan established a more frequent CRL site presence in order to better track the details of the NLLP implementation.

Under the MOU, AECL is required to propose for approval by the JOC a plan for contracting out work to the private sector each fiscal year. The contracts to be let are identified in the JOC Annual Plan. Contracting out of work has varied between 21% and 31% of overall expenditures since 2006. AECL has developed an internal strategy for contracting out and appears to be applying it where feasible.

Quality Assurance

A site-wide Decommissioning Quality Assurance Manual (00-01913-QAM-016) was issued in 2002 by AECL. However, according to interviewees the manual for decommissioning was not as yet in use throughout all parts of AECL. This was especially true for smaller projects not managed by RTOP, where different quality assurance procedures might be utilized by different groups.

Contractors and consultants are engaged to execute subcontracted work and to provide advice and third party reviews. Project progress is reported monthly through one-page monthly progress reports that describe highlights of the work that has been completed, expenditures made, issues encountered and actions to respond to issues.

Project Management and Access to Expertise

In the planning phase of the NLLP, NRCan relied on AECL's expertise. Neither NRCan nor AECL appeared to have used the decommissioning experience (lessons learned) of other countries during that planning phase. Thus information regarding a range of items such as the need for appropriate planning time (one year), lessons learned regarding decommissioning practices and technology, and human resource management were not incorporated into the NLLP. This was recognized and reported as part of the mid-program review, where AECL identified a number of measures to optimize program delivery; including the need for increased use of external expertise and enhanced learning from foreign decommissioning experience (interview data also supported this finding).

According to the mid-term review of NLLP and interview data, there is a need for AECL to better link into international experience and learning in decommissioning. AECL is now (2009-10) doing this through accessing expertise abroad, networking, attending training and conferences abroad, and through sub-contracting to firms with expertise in the appropriate areas. One of the areas that international experience has shown to sharpen focus and drive innovation is private sector involvement.Footnote 155 As noted previously, AECL has contracted out between 21% and 31% of its Annual Plan budget to third-party contractors over the first three years of the start-up phase.Footnote 156

According to interviewees, project management procedures differ depending on the size of the internal contract (project) – there is no standard NLLP process for project management. Large capital projects or high-risk projects (more than $1 million) are generally managed by the Research and Technology Operations Projects Group using project management software called Primavera. For smaller and more operational projects the management procedures can vary considerably, depending on the management procedures of the supplier group implementing the project.

Generally, according to interviewees (AECL and contractors), projects proceed in phases, sometimes called gating. This means that a project will not proceed until one phase is completed and approved. For example, a project may require a feasibility study, a conceptual design, and a detailed engineering design. Each stage will require review, challenge, and approval to proceed. Internal interviewees as well as external contractors indicated that various gates could be lengthy due to insufficient staff (in terms of turnover, sheer numbers, and expertise) available from the AECL side, and staff turnover, and differences of opinion regarding what was considered to be an acceptable deliverable at each review point.

AECL and NRCan interviewees generally agreed that there was still not enough use of subcontractors and that there were issues with subcontractor management. This was also found to be the case in AECL's internal mid-program review.Footnote 157 A number of interviewees stated that AECL had traditionally favored internal work – and to some extent still did. According to interviewees, external subcontractors had been used for NLLP project work ranging from design to laboratory and demolition work. Most agreed, however, that more work could be sub-contracted.

Expert advice indicated that greater use of external suppliers could accelerate completion of work, and provide expertise that was presently in short supply at AECL. Internal AECL interviewees in general agreed that the work should be conducted using a blend of internal and external resources. Contractor interviewees reported having had varying experiences with AECL, some finding AECL to be understaffed and not sufficiently clear on what it wanted in projects.

According to interviewees, a number of obstacles prevented AECL from subcontracting more work. AECL reported that its security requirements rendered the subcontracting process generally challenging. Obtaining security clearances and providing onsite access for decommissioning work was one example of such challenges. Contractors also needed special training to work on the AECL site due to the rigorous health and safety standards required on a site with nuclear radiation risks. This was the reason that some AECL managers preferred to subcontract work that involved fewer health and safety risks. To some extent, the relative remoteness of the CRL location was also a barrier. Not all companies could or were willing to pay for temporary housing of their employees; not all of their employees were willing to relocate to the Chalk River area.

Some interviewees also observed that the procurement function did not facilitate the contracting process. It was suggested that better supply arrangements would help increase the use of subcontractors. Procurement was not timely according to some interviewees. For example, one interviewee stated that months and sometimes the better part of a year were spent negotiating terms and conditions with one government department

Contractors interviewed as part of this evaluation provided comments on AECL's management of contracts. One contractor with an ongoing contract was satisfied with AECL's management practices towards subcontractors. There were numerous reporting requirements, but AECL also held regular meetings to discuss progress, including budget, schedule and action items, which was appreciated by the contractors.

The other firms experienced several challenges. These included a number of unexpected problems that they attributed to the uncertainty involved in the work; for example, lack of proper characterization before the projects were contracted. This created problems for fixed price contracts, as the lack of information led to multiple change orders. The multiple change orders, in turn, increased the costs for contractors, who were unable to recover the costs of the changes due to the fixed price ceiling of the contracts. In one case, this was reported as having amounted to two million dollars.

Earlier involvement in the project, breaking the contract into phases, or pay-as-you-go contracts would alleviate this problem, according to contractor interviewees. Some contractors felt that the AECL project managers did not have adequate skills and knowledge to manage contracts and reported that that there was considerable disagreement between the firms and AECL on the scope of the project. Turnaround time that AECL project managers built into the contracts to grant approval or comment on deliverables, and high AECL staff turnover were described as having caused significant project delays and cost overruns.

An AECL interviewee with international experience said that international companies used incentives with success. This was confirmed by expert advice as well. Financial incentives were built into the contracts and encouraged suppliers to conduct the work within expected timeframes. It was reported that real change occurred when incentives were built into the contracts.

According to AECL WL interviewees, the project management approaches and tools were also inconsistent on that site. Excel-based tools were used for short-term planning; some AECL staff/managers worked with the Primavera system, while others used other Microsoft software for planning purposes. There was no integrated system at this point in time. According to most of the WL interviewees, a more integrated system would help overall monitoring and long-term planning.

Other suggestions were made to improve the project management processes at the WL site. Two interviewees mentioned that the approach to project management should be based on project size and risk, i.e., AECL should not apply the same level of rigor to all projects. Another interviewee suggested that risk assessments should determine the level of gating (number of approvals within a given project).

Two interviewees observed that there were silos within the organization and that AECL could do a better job at coordinating the work among the various engineering, science and operational divisions. They suggested that regular meetings and better planning would help alleviate this situation. Information sharing with CRL was another area where improvements were described as being possible. The fact that a Project Client Representative was on-site in WL was reported as being useful. AECL did not take advantage of the lessons learned by others quickly enough, according to most interviewees.

Most WL interviewees agreed that AECL made good use of subcontractors at the WL site. Subcontractors were used for various tasks, including planning, drilling, etc. One interviewee mentioned that there was still internal resistance to using external resources. A few interviewees described the AECL procurement process as having been a barrier to increasing the use of subcontractors (e.g., AECL had not pursued tools available to it that would speed up the process of hiring subcontractors).

CRL and WL: Prioritization of work

An effective prioritization process ensured that priorities were addressed from a risk perspective and that the work is scheduled efficiently. Interviewees indicated that the prioritization of projects was principally based on risk assessments, and was carried out separately for each site. The same criteria were used for prioritization at both sites. One CRL interviewee explained that the process was based more on risk than on a cost-benefit analysis. The literature and file review supported this assertion.

WL interviewees said that the prioritization process was more informal at that site, based more on the expected maintenance cost savings than on actual risks (that were lower than CRL's). Interviewees commented that the prioritization of projects was adequate for both sites. It should be noted that varying perceptions of 'risk analysis' were found to exist among the interviewees. In general, the identification of risks used did not include weighing technology options, cost benefit considerations, and contingency planning.

Two interviewees outside of the LMU expressed concerns regarding the current priority given to CRL and WL. They reported that there also existed concern regarding the three other site reactors (Gentilly-1, NPD and Douglas Point). According to these observers, these facilities were not adequately maintained, and there was inadequate site surveillance. Lack of appropriate documentation on risks was reported. These interviewees also commented that there existed concerns that the site situations were deteriorating. Lack of characterization information at those sites was also reported to be an issue.Footnote 158

3.2.7 What are the internal and external factors influencing the effectiveness, efficiency and economy of AECL's delivery of the Program?

Summary: Several factors have influenced effectiveness, efficiency and economy. The major factor is a lack of human resource capacity on the part of AECL and the CNSC. This includes levels of staffing, staff turnover and staff training (experience levels).

Lack of experienced staff was described as a key issue for both AECL and CNSC at the beginning of the NLLP (e.g., experienced in terms of contract management, risk and cost benefit analysis, and decommissioning). AECL initially experienced difficulties due to a lack of human resource capacity to undertake the work, as well as turnover among staff. Major efforts were made to attract, hire and train staff after the first two years of operation under the NLLP.

While AECL had sent staff on courses such as those offered at the Argonne National Laboratory, AECL did not take advantage of international experience that could have been gained on decommissioning by employing experts in decommissioning as advisors or by engaging staff with experience in decommissioning in other parts of the world. This situation had improved within the last year (2009-10), as AECL was becoming more proactive in networking, sending staff for training and hiring experts from other countries with decommissioning experience.

Other factors included lack of adequate coordination of decommissioning with the Operations Division at CRL and lack of coordination on the "draw on" CRL resources which also delayed the release of buildings for decommissioning. In turn, these created delays for some of the projects.

Misunderstood, changing or unclear regulatory requirements were also a factor that had affected the delivery of the Program. Additionally, time required for environmental assessments were underestimated, as well as the work required to meet CNSC requirements.

Inexperience in planning and cost estimating in the first few years led to the creation of deadlines/milestones that were overly optimistic, and poorly conceived cost estimates, which led to project overruns.

Analysis

According to documentationFootnote 159 and interview data, availability of human resource expertise had proved to be a limiting factor in the ability for AECL to conduct planned work. Specifically, health physicists, radiation protection surveyors, designers/engineers, occupational health and safety specialists, project management personnel, and safety and licensing specialists were reported as having been the most difficult to staff.Footnote 160 Regulatory processes (environmental assessments and regulatory approvals) had also limited the ability of NLLP activities to stay on track; however, the responsibility for this experience was shared by both the regulator and regulatee.

Interviewees at both CRL and WL corroborated the observations contained in the JOC Annual Report (2009). A number of CRL interviewees reported that the first years of NLLP were quite difficult because AECL had a limited number of staff to undertake the planned work. AECL, which was originally staffed to conduct research, lacked adequate decommissioning expertise, such as a sufficient number of radiation protection surveyors and health physicists.

Subsequently, the LMU was challenged by high turnover of staff including project management staff on major projects. Turnover among the project client representatives was high, and many positions remained unfulfilled when the interviews were conducted (2009-10). This was frustrating for LMU management and also contributed to delayed project work.

An example of the impact of staffing shortages was the CRL facilities shutdown. The limited availability of internal specialized resources (i.e., radiation surveyors, cost estimators, technical writers) slowed progress. This had currently been addressed through better-defined work processes, augmentation of internal staff, and by contracting external experts to provide assistance in a timely fashion.

At WL, staffing issues were also a major challenge initially. In 2002, WL staff had been reduced to the small number of 304. To meet the new demand for decommissioning work, WL authorities hired a large number of staff (both technical and professional) in all areas of decommissioning. The lack of internally employed health physicists created a bottleneck, causing delays in the ability to complete work under the Decommissioning Project. One interviewee explained that it was difficult to attract staff to WL, and that it took two years to staff WL to an appropriate level for the workload. Most of the staff hired had limited experience, which meant that WL had to train the new staff as well.

While AECL had sent staff on courses such as those offered at the Argonne National Laboratory, AECL did not take advantage of international experience that could have been gained on decommissioning by employing experts in decommissioning as advisors, or by engaging staff with experience in decommissioning in other parts of the world.

Interviewees noted that AECL had gradually been able to hire staff with expertise in decommissioning who had worked on decommissioning programs outside Canada. This fact, in addition to increased networking, training and access to U.S. and U.K. agencies engaged in decommissioning, raised the level of knowledge at AECL. According to interviewees, although succession plans were in place, few staff members were hired before the people that they were replacing had left. This prevented the transfer of knowledge between those leaving and those arriving. Several interviewees also noted that other major AECL Operations' projects resulted in taking staff away from decommissioning work. This was due to the limited number of technical resources that were in demand from a number of operational units.

Another factor that influenced the effectiveness of NLLP delivery was the linkage between AECL Operations and the decommissioning teams. For buildings that were still in use, the normal procedure was to wait for AECL Operations to turn over the building for decommissioning work. According to a number of interviewees, Operations at CRL had delayed release in many instances due to operational needs, which in turn had delayed some NLLP projects. This was one of the challenges of conducting work on an operating site. AECL was working on ways to simplify demolition decision-making processes for buildings and to better coordinate decommissioning with site-wide operational requirements at CRL. (This was not an issue at WL as it was no longer an operational site.)

The third factor that was affecting the decommissioning process was regulatory requirements. Some interviewees reported that the extensive number of environmental impact assessments required had been underestimated and consumed a significant amount of time. There were two aspects of the regulatory process which caused additional problems. First, at the outset, CNSC itself went through a learning curve, as it had not dealt with this type of decommissioning activity previously. CNSC was also short of staff and expertise, which had to be strengthened to help deal with the AECL decommissioning program. Second, the CNSC had much less prescriptive regulations than the Environmental Protection Agency in the U.S. Therefore the requirements of the CNSC were not clear, and it took some time for AECL to understand and adjust to the CNSC requirements. According to interviewees, the CNSC did not have the practice of making requirements well known in detail, in advance.Footnote 161

One stakeholder indicated that AECL was not providing the necessary documentation to obtain licences for decommissioning work, and this had also caused some delays. It should be noted that clarification of the requirements was a mutual responsibility (regulator and regulatee). All parties agreed, however, that the process now was running more smoothly and effectively.

One example of unexpected delays due to regulatory requirements was the Liquid Waste Transfer and Storage Project. According to project interviewees, prolonged discussions were required with the CNSC to resolve issues related to the code classification of the facility tanks and piping; the issue was resolved in June 2008. AECL staff interviewed were of the opinion that regulatory requirements had changed over the past ten years, thereby increasing the level of effort (and hence costs) required to meet the CNSC requirements.

3.2.8 What is the nature of the working relationship between NRCan and AECL on the NLLP? Is there a more appropriate governance model or are there improvements that can be made?

Summary: AECL and NRCan consider their current working relationship to be cordial and effective.

NRCan's oversight role is well recognized and AECL senior managers feel that this has led to improved quality of planning and reporting. Compared to prior funding programs at AECL, NRCan is more engaged, and its staff has a good understanding of nuclear waste management.

Quarterly and annual reports, as well as annual plans, are provided to the JOC by AECL. Some AECL managers thought that NRCan engaged at an excessively detailed level and that responding to these queries was time-consuming on the part of the AECL managers.

Public consultations to be conducted by NRCan were delayed until spring 2010. Most stakeholders, including government and the communities, agreed that earlier consultations would not have been advisable, given the lack of information regarding decommissioning needs at CRL in the earlier years of the NLLP.

Analysis

The five-year plan is being implemented through a MOU between NRCan and AECL whereby NRCan is responsible for policy direction and oversight, including control of funding, and AECL is responsible for implementing the work. As defined by the MOU, the Joint NRCan-AECL Oversight Committee (described previously) makes decisions on the planning, delivery, reporting and administration of the Program.

According to the MOU, AECL is expected to prepare and submit to the Joint Oversight Committee, in a format and schedule acceptable to the Committee:

  • quarterly progress reports, including any proposed change requests;
  • semi-annual updated financial estimates; and
  • annual year-end reports, including an audited financial summary.

The MOU specifies a reporting framework that describes the roles and responsibilities of AECL and NRCan with regards to reporting. The NLLP program resourcing proposal also provides a performance measurement and reporting strategy with outcomes statements, indicators, data and timing of reporting. The JOC is expected to meet regularly to review and approve annual plans and associated budgets, and quarterly and annual progress reports against approved annual plans and associated budgets. The JOC also oversees the administrative framework.

AECL senior managers were in agreement that the current NRCan-AECL working relationship and NRCan's oversight role were working effectively. The roles and responsibilities of each partner were clearly described in the MOU document. The JOC was described as a good mechanism through which NRCan could exercise its oversight role. NRCan's oversight role was well-recognized and the working relationship was positive. AECL senior managers reported that this had led to improved quality of planning and reporting.

NRCan was seen to have been engaged and its staff had a good understanding of waste management. However, AECL staff observed that NRCan might not have a sufficient appreciation of non-technical issues such as procurement and licensing.

AECL interviewees also mentioned that both parties were working on improving their communications (e.g., notification of changes, how a problem might be addressed, etc.).

Quarterly and annual reports as well as annual plans were provided to the JOC by AECL. AECL interviewees who discussed this issue believed that these reports were useful and met accountability requirements. These AECL interviewees reported that quarterly and annual reports were detailed, but that this was justified. AECL used internal reports provided by the lead suppliers to input to the JOC reports.

Some AECL managers, however, thought that NRCan asked too many detailed questions about these reports, and that responding to these queries was time-consuming on the part of the managers. It should be noted that this communication was not direct. The NRCan inquiries were forwarded to the LMU, and subsequently were forwarded to technical experts elsewhere in AECL. The experts provided their input to the LMU, which in turn processed the responses to NRCan.

AECL managers suggested that some of the reporting issues would be alleviated if NRCan had more local presence at CRL. An NRCan office, for example, would allow the Department to have more contact with the project teams and would allow for more direct communication. However, while some AECL interviewees thought it would be effective for NRCan to interface with AECL at the project management level, others thought that in-person meetings could facilitate communications.

The amount of funding ($100 million per year) was seen as justifying the level of reporting. NRCan required fact-based reports for presentation to TBS. NRCan interviewees agreed with AECL interviewees' comments that more frequent site visits would improve the quality of oversight, and that oversight could be accomplished without a permanent office at CRL. For the next phase, a more gated approach to project approvals was planned (i.e., approvals would be sought at specific project checkpoints), and funding for projects would only be approved with proper characterization. It was further observed that a graded approach should also be used, such that the number of gates used would be commensurate with the level of project cost and complexity.

NRCan officials were also of the opinion that the JOC was operating effectively and that there was a good oversight function and a good working relationship. NRCan interviewees believed that the management of NLLP had improved through the JOC reporting structures. NRCan staff was of the opinion that the MOU was appropriate, despite the fact that there were many unknowns when it was first drafted.

Public Consultations: CRL and WL

According to the NLLP program resourcing proposal, NRCan was responsible for conducting public consultations as part of the NLLP. These were delayed until spring 2010. Some NRCan officials felt that in the first years of NLLP, the long-term strategy was not sufficiently developed to conduct the consultations. Also, AECL officials requested a delay as there were overarching issues at CRL that would have had a negative impact on the consultations, including the issues regarding the National Research Universal reactorFootnote 162 and isotopes production.

A local government official also was of the opinion that consultations on the decommissioning activities should occur after the NRU was again operational as this was a major concern for the community. As well, the Radioactive Waste Strategy Group, comprised of radioactive waste custodians, also expressed concerns about these consultations and thought that there could be confusion with other processes already underway, including Ontario Power Generation'sFootnote 163 environmental assessment of the Deep Geologic Repository at Kincardine.Footnote 164

However, interviewees explained that AECL met with community representatives on a quarterly basis through the Environmental Stewardship Council to discuss broad issues at CRL and that decommissioning activities were included in these discussions. AECL was also described as having met with local elected officials through regular breakfast meetings. The Council included environmental groups and local officials that met on a quarterly basis in order to hear presentations and discuss environmental matters related to CRL. The CNSC participated as an observer in that group. NRCan representatives had made a presentation at the Council and had also met with First Nations and MétisFootnote 165 groups. A contract was in place with a consultant to assist with the preparation for the upcoming consultations.

In the case of Whiteshell, AECL had led consultations with the local communities. Interviewees explained that there were quarterly and biannual meetings with provincial government representatives. There was a Public Liaison Committee that met every six months with community representatives. Discussions with the community were broad for the environmental assessment leading up to the approval to begin decommissioning the site; and AECL generally had a good working relationship with the community according to interviewees.

3.2.9 Did the NLLP start-up phase (2006-07 to 2010-11) have a clearly-defined strategic and operational plan? Were the original milestones an appropriate benchmark for measuring success?

Summary: The plan developed for the start-up phase was too optimistic, and was not based on adequate information about the location and nature of the radioactive contaminants on the AECL site or within the AECL facilities. Further, the plan assumed that AECL Operations would turn over a number of buildings at CRL for decommissioning, which did not occur because of requirements for the continued use of those buildings. As a result, many of the original milestones set in 2006 were not realistic, and could not be met in the start-up phase. Thus, the original set of milestones cannot be used as a benchmark for measuring success.

The evaluation found that there were too many milestones, at varying levels of importance. The study further noted that the milestones were not always realistic and were not linked to costs. Post 2006, milestones were adjusted, especially at WL, to reflect the new approach for accelerating the work at that location. This was done under the authority of the JOC.

Initial planning suffered from a lack of lead supplier input, which was being addressed for the next planning phase.

During the last few years, improved characterization and costing information had been developed for the next planning exercise. However, there remained concerns that available information was still insufficient for a five-year plan.

The lack of a long-term waste management strategy (which would include identified facilities, timelines and waste acceptance criteria) also makes effective planning challenging. NRCan is considering seeking approval for the next five-year phase into two parts: an initial submission covering the first three years, and second submission in the third year covering the final two years.

Analysis

AECL submitted to the CNSC, in February 2006, a detailed five-year operational plan for implementing its Comprehensive Preliminary Decommissioning Plan (CPDP) (2005) for the CRL site. The Gantt charts contained in this detailed five-year plan were used by NRCan to set the milestones for the CRL component of the start-up phase for the NLLP.Footnote 166 The JOC approved changes to the original milestones twice for three principal reasons: implement a new decommissioning approach at WL to reduce ongoing costs and accelerate the schedule, to account for changes in strategy for components of the legacy liabilities at CRL, and due to delays in the turnover of buildings to the NLLP for decommissioning because of AECL Operation's continued requirements for the buildings.

These findings were corroborated by AECL interviewees who agreed that the initial version of this CPDP and its associated operational plan were inadequate for a number of reasons. Interviewees who were involved in the planning exercise recalled that planning was based on the existing (inadequate) information base and what could be achieved if more resources were available. A few interviewees reported that the question had been asked as to what would be done with more resources and whether more resources would accelerate the process.One of the issues, according to one interviewee, was that the focus was on a 70-year plan, prepared a few years previously by a now retired AECL employee. It was also the opinion that the planners were not fully aware of the limitations of the available information. The gaps in the CPDP planning process were what led to the subsequent scope changes, delays and increased costs.

Interviewees observed that the planners were probably too optimistic about how quickly progress could be made. They believed this was related to the fact that AECL's available funds for decommissioning shifted from a very low level of funding to significant annual financial resources provided by the NLLP. Another weakness identified by AECL interviewees was that the plans completed by the LMU were developed internally by the LMU itself. The work was then contracted to the lead suppliers who were not involved in the planning. The situation subsequently improved and currently featured more integration of the lead suppliers into the planning process. However, it was noted that this was still a work in progress.

The majority of interviewees, including NRCan, also agreed that the original NLLP milestones were, in hindsight, inappropriate and too numerous. Initially, interviewees reported that AECL considered the milestones to be achievable and that the organization had adequate capacity. However, it became apparent that AECL did not have adequate capacity to implement a program of the scale of the NLLP, initially. Thus, AECL experienced problems spending the funds. AECL also recognized later that greater emphasis should have been placed on characterization.

One senior interviewee explained that there was not a perfect correlation in terms of the milestones, project deliverables and dollars. For example, the FPS project had milestones for degraded fuel retrieval that did not match the level of funding required to achieve the task. Also, the level of knowledge and planning was described as being insufficient for this type of approach: an interviewee stated that milestones had been identified without sufficient planning and assessment when determining an appropriate solution.

In general, AECL CRL interviewees reported that the planning (and hence identification of milestones) was completed within three months, which international experience indicated was a relatively short time-frame for such an undertaking. It should be noted that this view was not universally shared among interviewees — other program managers noted that a February 2006 AECL document that was submitted to the CNSC, used as the basis for the milestones, was in their view a polished document. Furthermore, these interviewees noted that AECL had sufficient time between February 2006 and August 2006 to further refine the milestones where required.

Generally speaking, it was reported that managing with strict [inflexible] milestones was difficult considering the level of uncertainty. An interviewee stated that it was impossible to quantify deliverables in certain stages, despite the fact that deliverables and milestones were normally used as nuclear decommissioning components in other countries. Senior AECL management interviewees reported that AECL would not take this approach in the future due to the uncertainty inherent in this type of work.

Liquid Waste Transfer and Storage Project – CRL interviewees expressed concern that not enough planning was conducted at the inception of the LWTS project.

CRL Environmental Remediation – In a number of cases, AECL found that the program milestones were not appropriate or realistic once they initiated field work under the NLLP. Some of the problems encountered included: the wastes were more voluminous than expected, some contents did not match expectations, and more rigor was required to resolve the problem.

CRL Shutdown of Facilities – The experience of CRL indicates how important it is to develop a systematic approach for the entire cycle of building decommissioning. Otherwise, wastes created in decommissioning buildings may have to be moved and stored, requiring construction of new facilities. One of the big challenges reported with respect to CRL decommissioning was dealing with the waste produced.

However, one interviewee explained that some flexibility had been built into the system: the MOU allowed AECL to carry over up to 1/12 of the annual funding in any given year. Some of the milestones had also been changed since 2006, including some to reflect the new approach at WL to accelerate the work at WL.

The exhibit box displays some of the evaluation findings with respect to planning for the case studies. It should be noted that in the case of CRL shutdown buildings, a large percentage of the radioactive waste generated was sent to the U.S. for treatment or destruction. This limited the amount of radioactive waste that needed to be put into storage .

Preparation for future phases

For the next phase, AECL interviewees reported that the intention was for AECL to proceed with more caution with respect to planning. There was recognition that there had been flaws in the plan for this phase, and that there were opportunities for improvement. Planning for the next phase started in mid-2009 and, according to interviewees, AECL had developed cost estimates for most activities. In spite of the planning that had occurred, two senior interviewees felt that AECL was behind in terms of planning for the next phase. Although the process was described as being in better condition than it had been in 2005, some projects were still in either the investigation or the pre-project assessment phase at the time that the evaluation's interviews were conducted (fall-winter 2009).

Additional exploratory work was described by interviewees as being needed for some remediation projects. Still, there was much better characterization information available on specific sites than was available for the 2005 CPDP and the associated 2006 detailed five-year operational plan. AECL also had better knowledge of the CNSC regulatory requirements. In contrast to the previous exercise, AECL was also involving project managers (lead suppliers) in the planning process for the next cycle.

For facilities decommissioning, AECL has costing information for most buildings and can estimate schedule and cost (with accuracy within -30% to +50%). It should be noted that these are, "order of magnitude" estimates, not "budgetary estimates (which typically range from -15% to +30%)," nor are they "definitive estimates (which typically range from -5% to +15%)." This level of accuracy was seen by experts as indicating a need for (external) expertise to assist with cost estimating.Footnote 167

One of the outstanding issues affecting long-term planning and program costing continues to be the long-term radioactive waste management strategy. Canada does not have a long-term management facility for low-level or intermediate-level radioactive waste, which means that any radioactive waste generated under the NLLP must be shipped to the U.S. for treatment or destruction, or stored on an interim basis. A feasibility study is being conducted to assess the suitability of the CRL site to host a geological (rock) repository for the long-term management of low-level and intermediate-level radioactive waste, and AECL is planning to submit a report on its findings to NRCan by the end of 2010.

For future planning, some of the interviewees believed that more flexibility was needed, and that a five-year timeframe provided that possibility. Several senior AECL interviewees suggested that a five to ten-year rolling plan should be developed, with a two-year detailed plan component (comprised of actions where the lowest amount of uncertainty would exist). The later years of the plan would be described at a lower level of detail (comprised of actions where the amount of uncertainty would be higher than for the first two years of the plan). NRCan interviewees suggested the same model.

This approach was described as allowing for both the technical unknowns and possible changes in regulation. A gated process could also be used to help reduce the risk of projects with high levels of risk according to the interviewees. It would require external contractors to carry out a phase of work and then, based on the results of that phase, return to decision-makers (AECL, NRCan) with work plans and estimates for the subsequent phases of work in order to receive additional funding.

3.2.10 Are there any best practices and lessons learned?

Summary:

As the NLLP represents a new and unprecedented challenge for AECL in dealing with Canadian nuclear legacy liabilities, many lessons were learned and opportunities for improvement have been identified. Key lessons learned were:

  • Effective planning of decommissioning activities requires adequate characterization of the underlying assets and lands to be decommissioned.
  • A complex decommissioning program such as the NLLP requires a build-up of internal capacity or extensive use of external resources (i.e., a "ramp-up" phase).
  • An effective decommissioning program should be properly phased to permit adequate up front planning and characterization work to be completed before full implementation is undertaken.
  • In an operating site such as CRL, integrated planning and coordination of capital projects with operating facilities requirements is critical to avoid delays in the program.
  • Decommissioning is an activity with high levels of risk and as a result adequate risk analysis, gating, and contingencies must be allowed for in terms of time and cost.
  • Decommissioning facilities on an operating site takes time as allowances have to be made for adequate planning, including: characterization, environmental assessments, regulatory approvals, building capacity and engagement of skills, and if necessary, procurement of equipment and/or contractors.
  • Incentives can help retain expertise and ensure that decommissioning projects are on track.

As the NLLP represents a new and unprecedented challenge for AECL in dealing with Canadian nuclear legacy liabilities, many lessons were learned and opportunities for improvement identified. Key lessons learned and identified solutions concerned the need for detailed planning (e.g., adequate characterization of the radioactive contamination on sites to be decommissioned); the need to plan for buildup of adequate capacity to undertake a project such as NLLP, in terms of staffing, contractor capacity, procurement procedures; and the requirement to develop appropriate costing and risk management procedures to deal with the high risk nature of decommissioning projects in an uncertain environment.

Key lessons learned have been derived from the discussions with both AECL and NRCan staff, a review of documents and literature, and from the case studies.

Effective planning of decommissioning activities requires adequate characterization of the underlying assets and lands to be decommissioned.

The case studies demonstrated the need to adequately characterize the underlying contamination before detailed planning. AECL has conducted much of the characterization work as it has been required for specific projects. The disadvantage of this approach is that it can cause delays in decommissioning schedules, and reduce the ability to pre-plan the entire program in terms of cost and timing. The lesson learned is that characterization work performed during the early planning phase facilitates costing and detailed planning of activities.

A complex decommissioning program such as the NLLP requires a buildup of internal capacity or an extensive use of external resources (i.e., a "ramp up" phase).

A lesson learned from the NLLP experience is that managing and implementing a program such as the NLLP requires a significant number of internal and external human resources and contractor capacity if the program is to proceed on a reasonable schedule and budget. This takes time to build, and as a result, must be planned when scheduling the overall program.

An effective decommissioning program should be properly phased to permit adequate up front planning and characterization work to be completed before full implementation is undertaken.

The requirement to "do something immediately" should be avoided, and the requirements should be defined and planned clearly before proceeding with the detailed individual contract/project design and implementation of projects. It was also recognized that there was a need for integrated planning due to the number of projects competing for resources and the complexity of work. There was therefore a need to identify the interfaces between groups.

In an operating site such as CRL, integrated planning and coordination of capital projects with operating facilities requirements is critical to avoid delays in the program.

The NLLP at CRL encountered conflicts between the decommissioning activities and ongoing operational requirements for facilities. While these types of conflicts cannot be completely avoided, they demonstrate the importance of undertaking overall site planning and scheduling of operational requirements compared to decommissioning requirements to avoid conflicts and delays.

Decommissioning is a highly risky activity, and as a result, adequate risk analysis, gating, and contingencies must be allowed for in terms of time and cost.

Experience with the NLLP has demonstrated that:

  • Unexpected events need to be accounted for in project costing and scheduling. This means allowing adequate cost and time contingencies in project planning depending on the assessed level of uncertainty at the planning stage of a project.
    • Unexpected technical challenges related to waste handling, dosimetry, equipment or other issues can arise during the course of work.
  • In high risk projects, incorporating "review" and "decision to proceed" decision points into project schedules permit management to base its project decisions on the knowledge gained in each successive phase. This lowers the inherent risk involved as each point is subject to a go ahead decision based on up-to-date information. This type of gating must be adjusted to the nature of the project, as too many gates will slow down a low risk project excessively, while too few gates for a high risk project could lead to a waste of resources before management realizes that a given technical approach is not appropriate.

Decommissioning facilities on an operating site takes time as allowances have to be made for adequate planning (including characterization), environmental assessments, regulatory approvals, building capacity and engagement of skills, and if necessary, procurements of equipment and/or contractors.

  • This also implies that adequate lead times for internal and external review and approval processes, including regulatory approval processes, need to be accurately accounted for in scheduling decommissioning activities.Footnote 168
  • To ensure minimum disruption in scheduling, good procurement processes are essential to ensure that services and materials are obtained in a cost-effective and timely manner.
  • Advance identification of expectations by the regulator, through a good flow of communications, is essential if regulatory delays are to be avoided.
  • Financial allocation for programs of this magnitude and technical complexity/risk need to have a 'ramp up' initial phase in order to plan and staff appropriately.
  • A set of shared priorities is required across the organization, i.e., between the Operations and Decommissioning staff.

The use of incentives to help retain expertise and ensure that projects are on track.

According to literature and expert advice, decommissioning project authorities should make sure that appropriate requisite internal and/or external expertise is in place to develop a comprehensive decommissioning plan. However, retaining on board resources may pose a challenge to the expeditious performance of the decommissioning activities, since the retained staff will ultimately recognize that it will be performing activities that will terminate specific responsibilities. To address this challenge, incentives keyed to delivery of specific milestones within a specific timeframe have been shown to be an effective motivational workforce mechanismFootnote 169.

4.0 Conclusions

The NLLP is contained in the NRCan Program Activity Architecture, sub-activity 2.2.4, Radioactive Waste Management. The expected result for this sub-activity is "improved waste management practices to meet modern day standards for safety and environmental protection." The PAA performance indicator for this expected result is "progress on contaminated sites cleanups and progress on the development of long-term waste management approaches."

AECL's lands and facilities are the site of radioactive legacy waste and decommissioning liabilities which date back to post World War II research activities of various federal departments and agencies, including the National Research Council and the Department of National Defence.

The need to resolve the AECL nuclear legacy liabilities is a recognized national priority that appears in the Accounts of Canada and AECL's balance sheet. World trends are tending towards accelerated decommissioning of nuclear sites contaminated with radioactive wastes, viewing delaying such work as not economical and imposing a burden on future generations.

The need for additional funding to address the liabilities is recognized by the federal government and was requested by the Office of the Auditor General. Previous to the NLLP, AECL could only afford to address the most pressing needs for managing the nuclear legacy liabilities.

The conclusion of the evaluation study is that there is an environmental and regulatory need for the NLLP. A number of structures and areas at the Chalk River Laboratories site and Whiteshell Laboratories site present health, environmental and safety issues. The issues encompass contaminated buildings and land, waste storage structures that need replacement due to corrosion, and potential fire hazards posed by old wooden buildings. Cleanup work is required by the regulator (the Canadian Nuclear Safety Commission.

The evaluation also concludes that the NLLP is consistent with government priorities and NRCan strategic objectives, and that the oversight role played is appropriate. The original program resourcing proposal for the NLLP contained 161 milestones; however, those milestones were inconsistent in terms of significance, risk, scope and magnitude, were not linked to costs, and were too numerous. Under the authority of the NLLP's Joint Oversight Committee, they had been revised at least twice in the past four years.

Performance

There is general agreement supported by all of the lines of evidence that the NLLP work is behind schedule and over budget. Using the milestones as a guide, approximately two-thirds of the work is expected to be completed by the end of the five-year funding period, although results based on milestones should be analyzed with caution. However, in recent years under the NLLP, AECL has undertaken major efforts to improve the situation.

The higher risk health, safety and environmental issues are at CRL and have been or are being addressed. A number of buildings were successfully decommissioned and waste management facilities have been built. WL adopted an accelerated schedule starting in 2007 (to present day). The site's utility and heating systems are being reconfigured to reduce costs and facilitate decommissioning. Without NLLP, the decommissioning activities would have been substantially more limited in terms of size and scope.

The actual costs of the decommissioning work are generally above those estimated. Factors explaining these gaps include issues with planning, and information on which plans were based, such as inadequate waste characterization information, lack of reliable site/building information, inadequate cost estimates and cost estimating capability, and a general reluctance to draw upon the experience of organizations external to AECL. This situation is improving in terms of conducting characterization work, feasibility studies, improved planning processes and the engagement of new staff with international experience.

Findings also indicate that the technical difficulties and the time required to increase human resource (HR) capacity to meet the NLLP milestones were underestimated. AECL initially experienced difficulties due to a lack of HR capacity to undertake the work, as well as high turnover among its staff and also at the CNSC. Delays in the release of buildings for decommissioning resulted in delays for many projects. Changing regulatory requirements also created delays in NLLP delivery.

Project Management Approach

AECL's project management is based on a system of contracts with internal AECL suppliers (lead suppliers). The internal suppliers are required to provide monthly progress reports to a centralized Liability Management Unit, and on a quarterly basis reports are provided to the Joint Oversight Committee. There is a Quality Assurance Manual used for decommissioning and waste management, however interviewees reported that it is not used in all areas of AECL.

There is no standard approach (or standard software used) for project management and management practices vary according to the type and size of projects. AECL does not have an integrated system for reporting on NLLP projects. Overall, evidence indicates that there is not enough use of subcontractors and that there are issues with subcontractor management at AECL, including oversight of procurement and project management, especially at CRL. It is agreed that the work should be conducted using a blend of internal and external resources.

Current prioritization processes are risk-based, however, the risks identified do not involve cost-benefit analysis and, in the past, the contingency estimates were smaller than is the general practice internationally. AECL does not use a quantitative risk analysis program, such as PERTMASTER. Concern was also expressed during interviews that the three prototype reactor sites (Gentilly-I, NPD and Douglas Point) containing legacy waste may not be adequately maintained and that there is inadequate site surveillance.Footnote 170

Contracting issues, which appear to result from inexperience and staff turnover, include over reliance on the fixed price approach, combined with excessive change orders (changes to the original statement of work), which resulted in significant financial penalties to subcontractors.

No system of incentives is in place for AECL staff or for contractors, which international experience shows can reduce costs and delivery time substantially.

Governance and Planning

AECL and NRCan consider their current working relationship to be cordial and effective. NRCan is engaged and its staff has a good understanding of nuclear waste management.

Quarterly and annual reports, as well as annual plans, are provided to the Joint Oversight Committee by AECL. Reporting to NRCan is seen by AECL to involve too much detail; however, the volume of questions from NRCan to AECL demonstrates that more information or better context information (or both) are needed.

A plan was developed for the NLLP, and there was general agreement that the plan was too optimistic with respect to achievement of specified milestones, risk, and budget targets, and was not based on adequate documentation of wastes or characterization. As the evaluation team noted previously, the plan contained an overabundance of milestones, some of which were later found to be inappropriate or unrealistic. Some of the milestones were changed after 2006, partially to reflect the accelerated schedule for work at WL.

There has been an improvement in the characterization and costing information for planning for the next NLLP phase, although many agree that this is still insufficient for a five-year plan. The lack of long-term radioactive waste management facilities in Canada also hinders planning.

Public consultations to be conducted by NRCan were delayed until spring 2010. Most stakeholders, including government and the communities, agreed that earlier consultations would not have been timely considering the overall situation at CRL.

Appendix A: Selected Definitions

Characterization: Refers to the use of analytical techniques and physical survey to determine the radiological and hazardous materials present in a facility and site, and to probe into the internal structure and properties of a material. Characterization of site infrastructure and materials provides essential information that provides basic input to planning.

Contingency: Contingency may be defined as a provision for unforeseeable elements of cost within the defined project scope, especially if experience shows that these costs are likely to occur. As mentioned earlier, a contingency factor should be systematically added to all project cost-estimates. According to Taboas et al. (2004), cost-estimates are typically established upon ideal conditions; however, various events or factors may increase costs, such as weather conditions, changes in site conditions, waste acceptance criteria, etc. Traditionally, contingency has been applied to an overall estimate (typically 25 percent). Later practices have been to apply a contingency by line item that can vary from 10 percent (conventional radwaste packaging) to 75 percent (reactor removal).

Decommissioning: Can be defined as a staged process through which a nuclear facility, at which normal operations have finally ceased, is taken out of service, including full or partial dismantling of buildings and their contents. It may include other operations such as the decontamination of buildings which are not to be dismantled and the remedial treatment or restoration of the land under and around the facility. The objective of decommissioning is to remove the hazard [that] the facility poses progressively, giving due regard to security considerations, the safety of workers and the general public and protecting the environment, while in the longer term reducing the number of sites and acreage of land which remain under regulatory control (U.K. Department for Business, Enterprise & Regulatory Reform: 2004Footnote 171).

Financial guarantees: Funds that the CNSC has access to in case a licencee is unable to fulfill its obligations for decommissioning.

Sr-90: Strontium-90 is a radioactive isotope of strontium derived from reactor-fuel fission products.

Uranium (in the context of the nuclear industry): The fuel source for nuclear power is uranium. Uranium has 16 isotopes, one of which is U-238. U-238 is slightly radioactive, with a half-life of 4.5 billion years. U-235, another uranium isotope, is less stable than U-238 and can be easily split, consequently, it is the primary fuel used to generate heat in a nuclear power plant (naturally occurring uranium is about 99.3% U-238; and 0.7% U-235).

Appendix B: Key Best Practices in Decommissioning

NOTE: the Canadian Standards Association has a standard on decommissioning facilities containing nuclear substances (N294-09), issued in 2009 (during the time when the data for this evaluation was collected) that covers many of the topics covered in this Annex.

Although there are no unique or preferred approaches to decommissioning and dismantling of nuclear facilities (OECD, 2003), the following generic guidelines and best practices were derived from international literature and documentation in this field.

Characterization
The previous subsection described the characterization process. According to Taboas et al. (2004), a decommissioning plan must be based on defensible comprehensive characterization of the facility. It is a pre-requisite for evaluating the health and safety, technology, waste management, and financial requirements in order to assess costs and disposal options accurately.

Information Quality and Accessibility
Information should be available to the project authorities in order to support the process of developing the decommissioning plan. The information should be high quality (reliable), accessible, and utilized. This includes historical data regarding the operations of the facility, and records of any incidents or accidents (CNSC, 2000a).

Relevant Expertise
Relevant expertise is key in the decommissioning process. The project authorities should make sure that appropriate requisite internal and/or external expertise is in place to develop a comprehensive decommissioning plan. Staff who operated and maintained the plant should be involved so that the planning can benefit from their detailed knowledge (McKeown, 2003; Taboas et al., 2004). However, retaining on board resources may pose a challenge to the expeditious performance of the decommissioning activities, since the retained staff will ultimately recognize that it will be performing activities that will terminate specific responsibilities. To address this challenge, incentives keyed to delivery of specific milestones have been shown to be an effective motivational workforce mechanism (Taboas et al., 2004). On another note, international experience in decommissioning shows that knowledge should be shared between senior and younger team members in order to develop capacity (McKeown, 2003).

Risk Analysis and Alternative Decommissioning Strategies
Risk management is one of the most important aspects of decommissioning. Managing risk requires authorities to undertake risk assessment of various decommissioning strategies, and to evaluate those strategies while adding the societal and political factors to the overall risk analysis process (Taboas et al., 2004).

In the decision making process of decommissioning nuclear facilities, authorities need to take into account the risk of potential adverse impacts (Taboas et al., 2004). Adverse impacts can be grouped in the following three categories: policy and socio-economic factors, technological and operational factors, and long-term uncertainties (OECD, 2006). In order to identify those potential adverse impacts, the project authorities should develop a risk assessment of alternative decommissioning strategies (Bond et al., 2003; Taboas et al., 2004).

Where a clear strategic preference is not immediately apparent, alternative strategies should be compared using a simple detriment-benefit method (CNSC, 2000a). Stakeholder consultations should also be involved in establishing selection criteria for alternatives (Bond et al., 2003). In all cases, the underlying objective of the chosen decommissioning strategy is to achieve an end point that properly protects workforce, the public, and the ecosystem (CNSC, 2000a; OECD, 2002; Taboas et al., 2004).

Detailed and Flexible Plan
Decommissioning plans can be expected to vary in approach, complexity and detail. As significant uncertainties may exist at the preliminary planning stage (e.g., highly complex operations, evolution of regulatory requirements, technologies and waste management services) the decommissioning plan should allow for flexibility. Preliminary plans should be based on the best available conservative information and predictions (CSNC, 2000a). Decision making should provide the flexibility to adapt to new information (OECD, 2004). Plans should be sufficiently detailed to demonstrate that the decommissioning activities will remediate all significant impacts and hazards to persons and the environment in a feasible manner, that the project complies with all applicable requirements and regulations, and that it enables credible estimates of the amount of financial guaranteesFootnote 172 (CNSC, 2000b).

Stakeholder Participation
Stakeholder participation helps build clearer public awareness, buy-in, and can potentially improve the decommissioning plan. Full dialogue should be maintained during the decommission planning and activities in order to ensure openness and transparency, since the public and other stakeholders are increasingly demanding to be involved in decommissioning activities (OECD, 2002; McKeown, 2003). The process of stakeholder participation is complex and is subject to many different interpretations. There are however a few areas of agreement on this process:

  • stakeholder participation should be project-specific;
  • people directly impacted by the project require special consideration;
  • the intent of participation from all parties involved throughout the process is highly desirable and crucial to the success of a project;
  • no specific exclusions of individuals or organization from a group can be made – there is no systematic or fool proof process to identify who might be an interested or affected party; and
  • those responsible for managing participation should be independent of those with a vested interest in its outcome, including stakeholders and the sponsoring agency (Taboas et al., 2004).

The following are key aspects of stakeholder participation as developed by the Peer Review Committee of the American Society of Mechanical Engineers (cited in Taboas et al., 2004).

Timing of involvement
All categories of stakeholders should be involved right at the initial formulation of the decision process. Inclusion eliminates any complaint that decisions were already made and that participation was merely done to justify "done deals".

Required information for meetings
Individuals or groups of stakeholders deserve a level of relevant information sufficient for them to offer meaningful and informed input. Technical assistance from project management, a regulatory agency, or preferably from an independent organization should be offered when stakeholders lack an understanding of basic principles relating to the project (e.g., radioactivity).

Participation in decision making
Any credible stakeholder participation process must create meaningful dialogue. Continual iterative involvement between decision-makers and stakeholders should be maintained during the process. Stakeholders should be encouraged to be specific with their questions and comments.

Reconciliation of competing and contradictory interests
Because of potential contradictory interests within and among the stakeholders, a properly managed stakeholder participation process must include relevant segments within each. The decision-maker must be able to get input from a diverse set of representatives and ensure that the decision process considers their views.

Including stakeholders in the final decision
A full description of the final decision should be made public as soon as possible. The following information should be included: how the final decision was determined. a general outline of how the process progressed as a direct consequence of stakeholder participation, elements based on the desires of stakeholders, and, elements not based on the desires of stakeholders, including why they were not accepted.

Engineering complexity
Safety of the workforce, the public, and the environment are absolute priorities. In addition, efforts should be made to reduce the engineering complexity of decommissioning strategies as far as practicable. According to McKeown (2003), where radiologically safe, manual processes should be preferred over machine-based processes for complex operations. Depending on the characteristics of the installations to be dismantled, authorities should evaluate the potential benefits of delay that may allow for the decay of relatively short-lived nuclidesFootnote 173, which may permit physical access by humans (McKeown, 2003). In some situations, a deferred removal strategy may not result in engineering complexity reduction as radiation levels would remain too high to allow manual dismantling (e.g., light water reactors) (OECD, 2006).

Cost estimates
Decommissioning activities represent significant costs, thus, reliable cost estimating is one of the most important elements of decommissioning planning (Taboas et al., 2004). The objective is to ensure that the decommissioning cost estimates are calculated correctly and in a conservative manner in order to ensure that sufficient funds will be available when required (OECD, 2002). Cost estimates should include all decommissioning activities, including: labor, materials, equipment, waste management, environmental assessment, monitoring, and administration (e.g., training, safety, licensing, management, government and public liaison) (CNSC, 2000a; 2000b; Taboas et al., 2004).

Contingency
Contingency may be defined as a provision for unforeseeable elements of cost within the defined project scope, especially if experience shows that these costs are likely to occur. As mentioned earlier, a contingency factor should be systematically added to all project cost estimates. According to Taboas et al. (2004), cost estimates are typically established upon ideal conditions; however, various events or factors may increase costs, such as weather conditions, changes in site conditions, waste acceptance criteria, etc. Traditionally, contingency has been applied to an overall estimate (typically 25 percent). Later practices have been to apply a contingency by line item that can vary from 10% (conventional radwaste packaging) to 75% (reactor removal).

Methods
Costs may be estimated in a number of ways. The techniques used for preparing cost estimates will vary with the project's degree of definition, the availability of databases and the level of engineering data available. Cost comparisons of using facility staff labor versus outsourcing to specialty firms with dedicated personnel and equipment should be evaluated (Taboas et al. 2004).

Information gathering is also an essential part of the cost estimate process. Careful attention must be directed at the outset to clearly identify what information is needed, how it is to be obtained, and how it is to be used. This information includes: site and facility characterization data, inventory of systems and structures, local area labor, materials and equipment costs, and insurance, taxes, engineering and regulatory fees (Taboas et al., 2004).

There are various types of costs. Activity-dependent costs are related to the performance of specific activities. Period-dependent costs, such as management and engineering costs, are related to project duration. Project schedules have a direct impact on period-dependent costs and both are highly correlated. The activity-dependent costs are directly related to technology and have a direct impact on the project schedule (Taboas et al., 2004).

Human factors
According to the CNSC, "Decommissioning planning throughout the life cycle of the licenced activities should consider human factors to ensure safe, efficient and effective decommissioning." (CNSC, 2000a: 17). "Human factors" are "factors that influence human performance as it relates to the safety of a nuclear facility or activity over all phases, including design, construction, commissioning, operation, maintenance, and decommissioning" (CNSC, 2003a: 1). Human factors include training, use of contractors, procedure development, and ergonomic issues (CNSC, 200a). When applying for a decommissioning licence, the CNSC evaluates (among other things) whether or not the applicant has made adequate provision for human factors as they relate to the safe conduct of the proposed decommission activities (CNSC, 2003b). Applicants therefore need to develop a Human Factors Engineering Program Plan based on established human factors principles and practices (CNSC, 2003b).

In a paper presented at the Canadian Nuclear Society Conference (Davey: 2005), it is indicated that the nuclear industry has adopted a human factors application model, which is based on the application of specific analytical, design, assessment, and in-service tracking activities that incorporate human factors application emphasis. However, the author notes that the model is heavily weighted to front-end analytic activities. This may be less appropriate for application areas like decommissioning where project requirements are more difficult to fully characterize during project planning. The current model is also less accommodating and responsive to design and operating environment changes. Finally, the model has evolved with a safety-related activities emphasis driven by regulatory expectations. Application experience to date for decommissioning and other industry projects suggests that this may have contributed to an under emphasis of human factors application to the production or business performance aspects of project design and operation. The author concludes by indicating that the current industry human factors application model should be adapted to address unique decommissioning project needs. This should result in more focused and effective application benefit.

The US Nuclear Regulatory Commission published a Standard Review Plan (2007) that includes a section on Human Factors Engineering.Footnote 174 It identifies twelve areas of review that are needed for, "successful integration of human characteristics and capabilities into nuclear power plant design".

A health and safety program should also be in place. This program should ensure adequate protection for workers during the conduct of decommissioning activities and should be developed using the information acquired during the risk analysis. The program should include: potential hazards, appropriate training and certification, hazard controls, including engineering and administrative controls, work procedures, and, an emergency response plan (Taboas et al., 2004).

Best use of materials
The following fundamental environmental principles should be followed in nuclear waste management in order to act in accordance with internationally agreed rules and procedures: reduce, recover, recycle, and re-use (the "four Rs"). Applying these principles means minimizing contamination and recovering, recycling and reusing materials, equipment, and even "waste" to the fullest practical extent (WNA, 2007). When it is not possible to recycle or re-use, wastes should be managed and packaged to modern standards which have been accepted by waste disposal facilities (McKeown, 2003). In all cases, disposal should be used as a last resort. Applying the "four Rs" follows the principle of sustainability not only on an environmental point of view but also creates opportunities for workforce re-deployment and local re-development (WNA, 2007). It is also important that the waste streams be properly defined to allow development of appropriate treatment and disposal routes. It is also important to segregate waste streams at their source (McKeown, 2003).

Quality assurance (QA) program
CNSC (2006a) and Taboas et al. (2004) recommend that a quality assurance program be established in decommissioning activities. According to the latter, QA requirements should be commensurate with the safety implications involved for each project. QA program plans should be developed for all decommissioning projects and are different than QA program plans for an operating facility. These plans should cover all major project activities and address:

  • qualified vendor selection and vendor surveillance;
  • organization and responsibilities;
  • material receipt inspection;
  • design reviews;
  • document control and record keeping;
  • record closeouts; and
  • audits.

Appendix C: Progress achieved by milestone (as at March 2009)

Status Milestone ID Milestone Description Original Date (in MOU Annex A) Planned Completion Date (most recent forecast) Actual Completion Date Comments
Address Health, Safety & Environmental Priorities - CRL Site
Original T1-01 Complete characterization of buried waste glass blocks 2006 2006 2006  
Original T1-02 Confirm South Swamp ground water treatment design and cost estimates 2006 2006 2006  
Original T1-03 Recover and store buried waste glass blocks 2007 2006 2006  
Original T1-04 Investigate and analyze river sediment 2007 2009    
Original T1-05 Reduce fire risks and fence WMA "A" and "B" swamps 2007 2007 2007  
Original T1-06 Recover Building 204 buried rod section waste at WMA "A" 2007 2007 2007  
Original T1-07 Recover buried Solvent Bunker 1 at WMA "B" 2007 2009    
Original T1-08 Recover buried Bottle Crib at WMA "B" 2007 Beyond 2011 March    
Original T1-09 Complete characterization of buried NRU rod section bunkers at WMA "B" 2007 2010    
Original T1-10 Complete year 4 of Tile Hole Investigation and Stabilization (THIS) project (puncture closed cans, inspection) 2007 2011 March    
Original T1-11 Remediate Waste Lysimeters Patch 2007 2007 2007  
Original T1-12 Recover buried Caustic Cells Waste at WMA "B" 2008 Beyond 2011 March    
Original T1-13 Complete year 5 of THIS project (further inspection and test retrieval) 2008 2011 March    
Original T1-14 Complete final detailed design for Liquid Waste Storage System 2008 2009   Liquid waste management options being re-assessed (2009 March)
Original T1-15 Procure Liquid Waste Storage System waste retrieval and transfer system 2008 Beyond 2011 March   Liquid waste management options being re-assessed (2009 March)
Original T1-16 Procure and construct South Swamp ground water treatment facility 2008 Beyond 2011 March    
Original T1-17 Recover buried Active Liquid Tank 2 Waste at WMA "A" 2009 Beyond 2011 March    
Original T1-18 Complete selected retrievals from Compartments 2 and 3 of the NRU rod section bunkers at WMA "B" 2009 Beyond 2011 March    
Original T1-19 Complete characterization of buried Slightly Active Solvent (SAS) bunker at WMA "B" 2009 Beyond 2011 March    
Original T1-20 Complete waste recovery and decommission the Bulk Storage Area 2009 2011 March   Actinides encountered, which will extend schedule. Options to advance work being assessed
Original T1-21 Construct Liquid Waste Storage System 2009 Beyond 2011 March   Liquid waste management options being re-assessed (2009 March)
Original T1-22 Train operators and cold commission Liquid Waste Storage System 2009 Beyond 2011 March   Liquid waste management options being re-assessed (2009 March)
Original T1-23 Train operators and commission South Swamp ground water treatment facility 2009 Beyond 2011 March    
Insert New46 Dispose of WMA D mixed liquid waste off-site (approximately 50,000 litres)   2008 2008  
Insert New47 Dispose of WMA C C-14 liquid waste drums off-site (approximately 50,000 litres)   2007 2007  
Delete T1-24 Complete processing of WMA "D" waste drums through Waste Treatment Centre 2010 No longer needed   Delete - Waste was dispositioned by an alternative route (See New46)
Original T1-25 Recover buried Slightly Active Solvent (SAS) bunker at WMA "B" 2010 Beyond 2011 March    
Original T1-26 Train operators and cold commission Fuel Packaging and Storage Facility 2010 2011 March    
Original T1-27 Initiate transfer of legacy waste to the new Liquid Waste Storage System 2010 Beyond 2011 March   Liquid waste management options being re-assessed (2009 March)
Original T1-28 Remediate river sediment 2011 Beyond 2011 March    
Original T1-29 Complete characterization of the buried Cobalt Bunker at WMA "A" 2011 Beyond 2011 March    
Original T1-30 Recover selected buried liquids from trenches at WMA "B" 2011 Beyond 2011 March    
Original T1-31 Complete construction of the Phase 1 Fuel Packaging and Storage Facility 2011 2011 March    
Original T1-32 Operate Chemical Pit Groundwater Treatment System Ongoing Ongoing    
Original T1-33 Operate Spring B Groundwater Treatment System Ongoing Ongoing    
Original T1-34 Operate Nitrate Plant Groundwater Treatment System Ongoing Ongoing    
Original T1-35 Operate South Swamp Groundwater Treatment System Ongoing starting in 2009 Beyond 2011 March    
Accelerate Decommissioning of Shutdown Buildings & Affected Lands - CRL Site
Original T3-33 B100 NRX Reactor – Achieve Storage with Surveillance (SWS) State 2011 2011 March    
Original T3-34 B100X D2O Salvage Building/Trench - Demolition complete 2010 Beyond 2011 March    
Original T3-73 B100X D2O Salvage Building/Trench – site available 2011 Beyond 2011 March    
Original T3-74 B101 NRX Fan House – Final Decommissioning Documentation Completed 2007 Beyond 2011 March    
Original T3-75 B101X NRX Filter House - Ready for Demolition 2011 Beyond 2011 March    
Original T3-13 B103 Control Room for Delay Tank - Final Decommissioning Documentation Completed 2008 Beyond 2011 March    
Original T3-80 B103 Control Room for Delay Tank - Prepare for Demolition 2011 Beyond 2011 March    
Original T3-14 B104 Control Room for Delay Tank #2 - Final Decommissioning Documentation Completed 2008 Beyond 2011 March    
Original T3-15 B107 Physics & General Chemistry Lab – Demolition complete 2008 2008 2008 Final floor slab removal is targeted for 2009.
Original T3-81 B107 Physics & General Chemistry Lab - Site Available 2009 2011 March   Final floor slab removal is targeted for 2009.
Original T3-82 B126 NRX Monitor and Water Valve House - Demolition Complete 2007 Beyond 2011 March    
Original T3-07 B133 NRX Rod Bay Washroom - Demolition complete 2007 2008 2008  
Original T3-08 B144 NRX Gas Holder Building - Demolition complete 2007 2008 2008  
Original T3-16 B145 Research Building Pool Test Reactor (PTR) - Available for Reuse 2008 2011 March    
Insert New52 B175 NRU Carpenter Shop - Demolition complete   2009   May include B168 (shed), if turned over for decommissioning.
Original T3-09 B200 Reactor and Processing Facilities Commissioning - Begin Shutdown 2007 2009    
Original T3-36 B200 Reactor and Processing Facilities Commissioning - Begin Preparation for Demolition 2010 Beyond 2011 March    
Insert New49 Create firebreak for B204 by removing section of building   2008 2008  
Original T3-10 B204 NRX Rod Bays – Achieve SWS State 2007 2008 2008 B204A bays SWS achieved. B204B bays SWS will be achieved as per mid-program review (beyond 2011 March).
Original T3-37 B207 Liquid Waste Storage - Begin Shutdown 2010 Beyond 2011 March    
Original T3-57 B207 Liquid Waste Storage - Shutdown Complete 2011 Beyond 2011 March    
Original T3-01 B210 Heavy Water Upgrading Plant - Shutdown Complete 2006 2011 March    
Original T3-38 B210 Heavy Water Upgrading Plant - Available for reuse 2010 Beyond 2011 March    
Original T3-02 B212 D2O Storage – Shutdown Complete 2006 2011 March    
Original T3-25 B212 D2O Storage - Available for Reuse 2009 Beyond 2011 March    
Original T3-58 B220 Pu Recovery - Achieve SWS State 2011 Beyond 2011 March    
Original T3-59 B223 Plutonium Tower - SWS State Maintained 2011 Beyond 2011 March    
Original T3-39 B224 Cool Waste Storage Area - Begin Shutdown 2010 Beyond 2011 March    
Original T3-60 B224 Cool Waste Storage Area - Shutdown Complete 2011 Beyond 2011 March    
Original T3-40 B228 Waste Solution Evaporator - Begin Preparation for Demolition 2010 Beyond 2011 March    
Original T3-26 B240 Surge Tank and Pump House - Achieve SWS State 2009 Beyond 2011 March    
Original T3-41 B241 Disposal Area Valve House - Turnover to Decommissioning 2010 Beyond 2011 March    
Original T3-27 B241 Disposal Area Valve House - Achieve SWS State 2011 Beyond 2011 March    
Original T3-28 B242 Waste Delay Tanks – Begin Shutdown 2009 Beyond 2011 March    
Original T3-42 B242 Waste Delay Tanks - Shutdown Complete 2010 Beyond 2011 March    
Original T3-83 B242 Waste Delay Tanks – Begin Preparation for Demolition 2011 Beyond 2011 March    
Original T3-19 B401 Gate House - Begin Shutdown 2008 2009    
Original T3-46 B401 Gate House - SWS Preparation Complete 2010 2010    
Original T3-84 B401 Gate House – Begin Preparation for Demolition 2011 2011 March    
Original T3-20 B407 Fire Hall and Garage - Begin Shutdown 2008 2010    
Original T3-62 B407 Fire Hall and Garage - Demolition Preparation Complete 2011 2011 March    
Original T3-21 B449 Guard House in Fence - Begin Shutdown 2008 2011 March   Security may have continued use requirement for B449 beyond 2011 March.
Original T3-12 B464 Health Science & Dosimetry - Demolition Complete 2007 2007 2007  
Original T3-85 B464 Health Science & Dosimetry - Site Available 2008 2007 2007  
Original T3-32 B485 Salt Storage – Demolition Complete 2009 2010    
Original T3-87 B485 Salt Storage -Site Available 2010 2011 March    
Original T4-01 Decommission Building 157 Stack Duct 2009 Beyond 2011 March    
Insert New50 Remove sludge from B240 Tank 1   2010    
Original T4-02 Put Building 240 Tank 1 into a Safe SWS State 2010 Beyond 2011 March    
Original T4-03 Commence preparing Building 103 Delay Tank 1 for demolition 2010 Beyond 2011 March    
Original T5-01 Complete clean up of O-Nest and Twin Lake Experimental Sites 2009 Beyond 2011 March    
Original T5-02 Complete clean up of Ottawa Riverbank 2011 Beyond 2011 March    
Original T5-05 Complete clean up of Shooting Range 2011 2009    
Original T5-03 Complete coring, assessment and remediation planning work for the Upper Inactive Landfill, the Inactive Landfill Sandpit and Dump 3 2011 Beyond 2011 March    
Original T5-04 Complete waste recovery at original CRL site construction camp (Dawson City), including building and piping debris 2011 Beyond 2011 March    
Delete T3-11 B215 Tritium Extraction - Achieve SWS State 2007 Beyond 2011 March   Delete - The building is still under an operating licence and is under the responsibility of CANDU Technology Development (CTD). Future use of the CECEUD has not been decided and the scope of decommissioning has yet to be determined. Facilities Decommissioning carries out monitoring and surveillance under the extended shutdown criteria at the expense of CTD.
Delete T3-17 B225 Active Delay Columns - Begin Shutdown 2008 Beyond 2011 March   Delete - The shutdown date for B225 has been extended indefinitely due to the shutdown of the Dedicated Isotope Facilities and the possible extension of NRU production plans.
Delete T3-18 B229 Fissile Solution Storage Tank - Begin Shutdown 2008 Beyond 2011 March   Delete - The shutdown date for B229 has been extended indefinitely due to the shutdown of the Dedicated Isotope Facilities and the possible extension of NRU production plans.
Delete T3-29 B243 Delay Tanks for Building - Begin Shutdown 2009 Beyond 2011 March   Delete - The delay tanks will be required for longer term operation of the active drain system.
Delete T3-30 B429 Research Reactor Fuel Fabrication Facility - Begin Shutdown 2009 Beyond 2011 March   Delete - Operations in this building will continue due to the shutdown of DIF and life extension plans for NRU. This is a possible future site of new Canadian Neutron Center as outlined in Vision 2018.
Delete T3-47 B429 Research Reactor Fuel Fabrication - Shutdown Complete 2010 Beyond 2011 March   Delete - Operations in this building will continue due to the shutdown of DIF and life extension plans for NRU. This is a possible future site of new Canadian Neutron Center as outlined in Vision 2018.
Delete T3-48 B432 Main Library - Begin Shutdown 2010 Beyond 2011 March   Delete - Shutdown by Operations is dependent on the construction of a new Engineering & Administration building. Design of that building has not started; it will be sited at the existing B401 Facility.
Delete T3-63 B432 Main Library - Shutdown Complete 2011 Beyond 2011 March   Delete - Shutdown by Operations is dependent on the construction of a new Engineering & Administration building. Design of that building has not started; it will be sited at the existing B401 Facility.
Delete T3-49 B442 Filtered Water Storage - Begin Shutdown 2010 Beyond 2011 March   Delete - Operations has asked to keep the facility while determining if it can be used for a burst test experiment for the Advanced CANDU Reactor.
Delete T3-50 B456 Engineering Tech, Occupational Development & Training, Decommissioning - Begin Shutdown 2010 Beyond 2011 March   Delete - Vision 2018 states that B456 will be replaced by a new high bay area by 2014. Staff from B456 will be relocated into a new Engineering building that won't be available until 2013 at least. Project documentation will be started once a decision is made on the funding for the new Engineering building.
Delete T3-72 B456 Engineering Tech, Occupational Development & Training, Decommissioning - Shutdown Complete 2012 Beyond 2011 March   Delete - Vision 2018 states that B456 will be replaced by a new high bay area by 2014. Staff from B456 will be relocated into a new Engineering building that won't be available until 2013 at least. Project documentation will be started once a decision is made on the funding for the new Engineering building.
Delete T3-64 B442 Filtered Water Storage - Shutdown Complete 2011 Beyond 2011 March   Delete - Operations has asked to keep the facility while determining if it can be used for a burst test experiment for the Advanced CANDU Reactor.
Delete T3-65 B449 Guard House in Fence - Demolition Preparation Complete 2011 Beyond 2011 March   Delete - Security may have continued use requirement for B449 beyond 2011 March. Additional Decommissioning Planning resources are required to complete the Environmental Assessment (EA) and other planning documents. The EA has been combined with the EA for B401 & B407. Delays in the completion of the B700 project will delay the shutdown of B401 by approximately 6 months into the spring of 2010.
Delete T3-44 B250 Chemical Engineering - Tritium Lab - Begin Shutdown 2010 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-45 B250 Chemical Engineering - General Building - Begin Shutdown 2010 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-61 B250 Chemical Engineering - General Building - Shutdown Complete 2011 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-76 B102 Drum Cleaning Building - Begin Shutdown 2007 Beyond 2011 March   Delete - Turnover from Operations depends on the availability of a decontamination center for large items. Schedule for replacement is experiencing delays. Fire audit findings may advance turnover.
Delete T3-77 B102 Drum Cleaning Building - Begin Demolition 2010 Beyond 2011 March   Delete - Turnover from Operations depends on the availability of a decontamination center for large items. Schedule for replacement is experiencing delays. Fire audit findings may advance turnover.
Delete T3-78 B102X Drum Cleaning - Begin Shutdown 2007 Beyond 2011 March   Delete - Turnover from Operations depends on the availability of a decontamination center for large items. Schedule for replacement is experiencing delays. Fire audit findings may advance turnover.
Delete T3-79 B102X Drum Cleaning - Ready for Demolition 2011 Beyond 2011 March   Delete - Turnover from Operations depends on the availability of a decontamination center for large items. Schedule for replacement is experiencing delays. Fire audit findings may advance turnover.
Delete T3-51 B468 R&IS Vehicle Decontam - Shutdown Complete 2010 Beyond 2011 March   Delete - A new Decontamination Centre will not be available until 2012 at the earliest, as per Vision 2018. Turnover of B468 to Decommissioning will follow.
Delete T3-86 B468 R&IS Vehicle Decontam - Begin Preparation for SWS State 2011 Beyond 2011 March   Delete - A new Decontamination Centre will not be available until 2012 at the earliest, as per Vision 2018. Turnover of B468 to Decommissioning will follow.
Delete T3-22 B514 Emergency Storage Building - Begin Shutdown 2008 Beyond 2011 March   Delete - The Site Landlord decided in 2008 to refurbish the building. Refurbishment is complete, extending the life of the facility.
Delete T3-52 B514 Emergency Storage Building - Demolition Complete 2010 Beyond 2011 March   Delete - The Site Landlord decided in 2008 to refurbish the building. Refurbishment is complete, extending the life of the facility.
Delete T3-88 B514 Emergency Storage Building - Site Available 2011 Beyond 2011 March   Delete - The Site Landlord decided in 2008 to refurbish the building. Refurbishment is complete, extending the life of the facility.
Delete T3-66 B527 Ammonia/Hydrogen/Amine Tower - Begin Shutdown 2010 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-67 B527 Ammonia/Hydrogen/Amine Tower - Shutdown Complete 2011 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-23 B530 Change Room & Storage - Begin Shutdown 2008 Beyond 2011 March   Delete - The current tenants are performing an analysis to convert the building into storage and additional shower/change room space for the Waste Management Areas. Turnover to Decommissioning has been postponed while this option is being investigated.
Delete T3-68 B530 Change Room & Storage - SWS Preparation Complete 2011 Beyond 2011 March   Delete - The current tenants are performing an analysis to convert the building into storage and additional shower/change room space for the Waste Management Areas. Turnover to Decommissioning has been postponed while this option is being investigated.
Delete T3-24 B550 Change House - Begin Shutdown 2008 Beyond 2011 March   Delete - The current tenants are performing an analysis to convert the building into office space and conference room for the Waste Management Areas. Turnover to Decommissioning has been postponed while this option is being investigated.
Delete T3-69 B550 Change House - Demolition Preparation Complete 2011 Beyond 2011 March   Delete - The current tenants are performing an analysis to convert the building into office space and conference room for the Waste Management Areas. Turnover to Decommissioning has been postponed while this option is being investigated.
Delete T3-53 B558 Hydrogen/H2O Exchange Tower - Begin Shutdown 2010 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-70 B558 Hydrogen/H2O Exchange Tower - Shutdown Complete 2011 Beyond 2011 March   Delete - Vision 2018 states that a new lab facility will be available by 2014. Preliminary work on EA documentation will start by 2011.
Delete T3-54 JL Gray Building - Begin Shutdown 2010 Beyond 2011 March   Delete - Operations has decided to occupy the JL Gray Building for an extended period of time due to space shortages at the CRL site.
Delete T3-71 JL Gray Building - Shutdown Complete 2011 Beyond 2011 March   Delete - Operations has decided to occupy the JL Gray Building for an extended period of time due to space shortages at the CRL site.
Accelerate Decommissioning of Shutdown Buildings & Affected Lands - WL Site
Insert New53 Issue Detailed Decommissioning Plan for the Active Liquid Waste Treatment Centre (B200)   2010    
Insert New54 Issue Detailed Decommissioning Plan for the Laundry and Decontamination Centre (B411)   2010    
Insert New5 Demolition and Site Clean-Up of the Engineering and Administration Building (B400), Cafeteria (B406), Cafeteria Garbage Shed (B410), and Pedestrian Link (partial) (B921) Complete   2008 2008  
Insert New6 Demolition and Site Clean-Up of Audio/Visual Storage (B504), Civil Utility Building (B509) and the Borehole Instrumentation Test Facility (B526) Complete   2009    
Insert New7 B500/530 Removal & Site Remediation Complete   2006 2006  
Insert New8 Demolition of the non-nuclear structures, buildings B306, 307, 503, 515, 525, 531 and Site Remediation Complete   2011 March    
Insert New9 Complete decontamination and strippage of Hot Cells 6-12 & SEM in Shielded Facility and issue interim end state report   2009    
Insert New55 B300 Core Area (Stages 1 and 4) and High Bay (Stage 3) ventilation systems removed.   2011 March    
Insert New12 Complete cementation of all active liquid waste (Amine, TFRE, UTS)   2009    
Insert New13 Complete decommissioning of redundant deep and shallow boreholes.   2009    
Original T7-03 Achieve Safe Sustainable Closure State for URL 2010 2010    
Delete T7-01 Reconfigure Low-Level Liquid Waste Underground Distribution System 2008 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T7-02 Complete Preparation of Shielded Facility for SWS 2009 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T7-04 Complete Demolition of Redundant Non-Nuclear Buildings 2010 not applicable   Delete - The milestone is being replaced with several milestones covering groups of redundant non-nuclear buildings to be demolished. B524 was demolished before the start of the NLLP. B505, B531 and possibly B503 are no longer considered redundant.
Delete T7-05 Complete preparation of Building 300 for demolition 2010 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Accelerate Decommissioning of Shutdown Buildings & Affected Lands- Prototype Reactors
Original T10-01 NPD, Gentilly 1 & Douglas Point - Prepare Decommissioning Licensing Documents 2011 Beyond 2011 March   Licensing strategy (applying for CNSC operating versus decommissioning licences) being re-assessed in FY 2009-10
Lay The Groundwork For Subsequent Phases Of The Strategy - CRL Site
Original T8-01 Compile and analyze existing Geologic Repository data 2007 2007 2007  
Original T8-02 Complete construction of Waste Analysis (Clearance) Facility (WAF) 2008 2008 2007  
Original T8-03 Train operators and commission WAF 2008 2009 2008  
Original T8-04 Develop preliminary Moly-99 Waste Conditioning Technology 2008 2009    
Original T8-05 Complete site remedial work at WMA "C" including cover installation 2009 Beyond 2011 March    
Original T8-06 Prepare site abandonment safety case for WMA "C" 2009 Beyond 2011 March    
Original T8-07 Procure and install Inactive Size Reduction Equipment 2009 2009    
Original T8-08 Complete ventilation and electrical modifications for Hot Cell Upgrades 2009 Beyond 2011 March    
Original T8-11 Complete characterization of WMA "F" 2010 Beyond 2011 March    
Original T8-12 Procure and construct Waste Characterization Facility (WCF) 2010 2010   Characterization strategy to be more fully developed, documented, and approved in FY 2009/10
Original T8-13 Procure WCF Process Equipment 2010 2010   Characterization strategy to be more fully developed, documented, and approved in FY 2009/10
Original T8-14 Procure and install Active Size Reduction Equipment 2010 2010    
Original T8-15 Complete pre-siting work and conceptual design for the Geologic Repository 2010 2010    
Original T8-16 Implement AECL Communications Framework for long-term strategy 2010 2010    
Original T8-17 Revise IRUS Safety Assessment and complete EA Process (Dependent on results of public consultations) 2011 Beyond 2011 March    
Original T8-18 Complete Moly-99 Waste Conditioning Technology Specification 2011 Beyond 2011 March    
Original T8-19 Complete Non-Fuel Tile Hole Investigation at WMA "B" 2011 2011 March    
Original T8-20 Train operators and commission WCF 2011 2011 March    
Original T8-21 Procure and commission Metals Decontamination Equipment 2011 2011 March    
Original T8-22 Develop conceptual design and complete EA process for Incinerator (Dependent on results of public consultations) 2011 2011 March    
Original T8-23 Complete Moly-99 Waste glove box surrogate work 2011 Beyond 2011 March    
Original T8-24 Annual Contribution to Nuclear Fuel Waste Act Trust Fund Annual Ongoing    
Delete T8-09 Complete Environmental Assessment for Hot Cells Upgrades Project 2009 No longer needed   Delete - An Environmental Assessment will not be needed.
Delete T8-10 Complete conceptual design and siting work for new Inactive Landfill 2009 No longer needed   Delete - A detailed evaluation of future needs for landfill capacity determined that a new landfill will not be needed for longer than had been thought.
Lay The Groundwork For Subsequent Phases Of The Strategy - WL Site
Original T9-05 Complete construction of Low-Level Contaminated Soil Storage Facility 2010 2011 March    
Insert New14 Design, construct and operate Waste Clearance Facility   2008 2008  
Insert New15 Decommission and remove Warm Cells 14 to18 from the Shielded Facilities   2010    
Insert New56 Complete conceptual design for replacement of Low Level Liquid Waste (LLLW) collection and treatment systems in the Shielded Facilities and B300   2011 March    
Insert New57 Complete conceptual design for replacement of Medium Level Liquid Waste (MLLW) collection and treatment systems in the Shielded Facilities   2011 March    
Insert New58 Detailed design completed for the replacement of Laundry and Decontamination Centre systems in the Shielded Facilities and B300   2011 March    
Insert New19 Design, construct and operate Waste Handling Facility   2009    
Insert New20 Relocate Analytical Science Labs from B300N to the Shielded Facilities   2010    
Insert New24 Design, site preparation and procurement complete of temporary LLW storage structures   2010   2010 March
Insert New25 Complete design, technology transfer, and licence for a new Shielded Modular Above Ground Storage (SMAGS)   2010    
Insert New26 Complete construction of temporary LLW storage structures   on hold   On hold pending re-assessment of need before SMAGS is available
Insert New27 Complete construction of a SMAGS   2011 March    
Insert New28 Install new 4160 Vac overhead power distribution line   2007 2007  
Insert New29 Install B408 transformer   2007 2007  
Insert New30 Install B401/402, RD-14M & Shielded Facility transformers   2008 2008  
Insert New31 Install and operate B401, B402, B408 & RD-14M electric heating systems   2009    
Insert New32 Connect B902 to new overhead line   2009    
Insert New33 Install and operate B902 electric and propane heating systems   2009    
Insert New34 Install B100 & B405 transformers, and install and operate B100, B405 and Shielded Facilities electric heating systems   2010    
Insert New37 Complete the seal-coating application for LLW bunkers 1-6.   2007 2007  
Insert New38 Complete baseline characterization of Winnipeg River Sediments as per approved sampling plan and submit baseline report to CNSC for review.   2008 2008  
Insert New39 Complete the WMA Fitness-for-Service report and submit to CNSC for review.   2008 2008  
Insert New40 Complete the WL Lagoon Fitness-for-Service report and issue for use.   2008 2008  
Insert New41 Complete assessment designed to confirm hydrogeological conditions at WL WMA   2009 2009  
Insert New42 Complete engineering assessment of WL Sewage Lagoon Fitness-for Service   2007 2007  
Insert New43 Complete the remediation of the FIG & ZEUS Experimental Infrastructure   2009    
Insert New44 Characterize the Cs. Experimental Pond and issue a remediation options study report for use.   2009 2009  
Insert New59 Complete planned non-invasive standpipe characterization studies, a detailed design for invasive sampling, and a preliminary evaluation of potential remediation technologies.   2011 March    
Delete T9-01 Initiate work to design and obtain regulatory approvals for Standpipe Retrieval Facility (to be completed in 2012) 2006 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T9-02 Initiate work to design and obtain regulatory approvals for Solid and Liquid Processing Facility (to be completed in 2012) 2007 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T9-03 Complete construction of Waste Analysis Facility 2008 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T9-04 Expand WMA for new waste storage facilities 2010 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T9-06 Complete construction of 5 Low-Level Active Waste Storage Bunkers 2011 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.
Delete T9-07 Design and obtain regulatory approvals for Medium Level Waste Bunker Retrieval Facility 2011 not applicable   Delete - The milestone is being replaced with new milestones corresponding to the new WL decommissioning approach.