Transportation of Nuclear fuel Waste as Integral Part of Project

Transportation as Integral Part of Project

Regarding the proposed Impact Assessment (IA) for the NWMO DGR proposal (“the project”), I would like to request that a full impact assessment  be conducted AND that transportation routes, containment methods and associated risks be included as part of the IA for the project.

The sheer quantity and toxicity of high level nuclear fuel waste (HLNFW) that will require transport from any and all points of generation within Canada to the proposed site in Northwestern Ontario exceeds by far any legislation or regulation currently in place to deal with shipments of radioactive material. The project would require the transport of at least 5.9 million used nuclear fuel bundles over thousands of kilometres along some of the most accident-prone routes in Canada; Ontario Highways 11 or 17 and others. This implies multiple daily truck loads, 24/7 indefinitely (at least 50 years for the waste already stockpiled) while new waste will be produced as long as nuclear generation continues.

It is imperative that this IA include an examination of the routes to be used the methods of transport of the waste and the potential risks to human health, safety and the environment inherent in this mammoth undertaking.

My home community of Thunder Bay is inescapably in the path of this transportation issue ON WHICH THE PROJECT DEPENDS. Without the transport of these wastes there would be no project. I raised objection to the siting of the project in Northwestern Ontario, mainly on account of the requirement to move this amount of highly toxic material  such great distances and the inherent potential risks over time. Unfortunately, the Site Selection Process created by NWMO excluded everyone except the residents of Ignace and members of the Wabigoon Lake Ojibway Nation (WLON) who were “deemed” to be potential “willing hosts” through a process rife with lack of transparency, unaccountability and questionable ethics. When I voiced my concerns, I was told I would have a chance to make my concerns known during the impact assessment process. I had no opportunity to raise my concerns before the site was declared. By the same token, no one living along the potential transportation corridors have had the opportunity to have concerns addressed in an accountable and orderly manner. Should this aspect of “the project” not be included within the present IA, the concerns of millions of people along the transportation routes will be silenced.

The Initial Project Description (IPD) lacks detailed information describing the Used Fuel Transportation Package (UFTP) and providing information on the testing processes involved in the approval of these containers for the extreme use contemplated in order to enable the project to exist. Again, transport of the HLNFW as proposed is a completely different order of magnitude compared to shipments already being transported along our highways. There are many questions regarding emissions en route, delays or obstructions of shipments due to weather or unforeseen events (highway blockages due to vehicle collisions) or collisions involving vehicles carrying a UFTP. How will first responders, many of whom are local volunteers, be expected to deal with incidents involving highly radioactive substances? These and other questions must be examined and satisfied before the project can be allowed to proceed. This federal IA is the only opportunity to address the above concerns. It must not be ignored.

Lack of a Transportation Plan showing alternative routes

Information on alternative routes and methods is another aspect of the transport issue that must not escape the public scrutiny that would be afforded only if transportation of HLNFW is included as part of the Project Description (PD). It is inconceivable that with over 1200 pages, the IPD does not include a treatment of alternative routes, methods of transporting waste and potential risks associated with each alternative. Equally incongruous is the fact that I could not find any suggestion within these pages that there there would be potential risks of any kind.    

During transportation, this waste could impact countless communities on multiple highway routes, railways, spur lines or holding/marshalling areas, yet routes have not been communicated and failure to include these questions within the PD ignores one of the most often heard concerns for this project, especially from communities along the potential transportation corridors. To ignore these concerns by excluding them from the IA would mislead the public regarding potential risks and impacts and result in diminished outcomes. Furthermore, lack of public acceptance of decisions arrived at through a constrained IA scope would taint the whole process.

Respectfully, 

Charles Faust

"This is a project that inherently spans many provinces, First Nations and communities and their respective rights. A federal IA is uniquely placed to assess the project’s strengths and weaknesses. It involves the transport and management of the most toxic, long-lived form of pollution known to the planet. That is exactly why it must undergo a full IA and attract the highest level of public scrutiny." (Legal Advocates for Nature’s Defence).