Absolute Need for a Full Impact Assessment and Public Hearing for the DGR Proposal

I have many serious concerns with the Initial Project Description (IPD) for a Deep Geological Repository (DGR) as proposed by NWMO which I hope to describe in ancillary comments to the Registry. But above all, I must assert the Absolute Need for a Full Impact Assessment and Public Hearing for the DGR Proposal.

This IPD represents arguably the most ambitious proposal ever to be considered by the Impact Assessment Agency, and its predecessors, in Canadian history. It involves the most toxic and long lived substances created by and known to us. In my view, the science governing the safety and predictability of managing this waste does not exist presently. At best it is an educated guess; at worst environmental nightmare and human disaster. Computer modelling will be used to demonstrate whether or not this proposal is safe. But how dependable is computer modelling and who will control it? The NWMO (the proponent) has seemingly infinite money and resources devoted to ensuring this project goes ahead. I have been following their activities over the last twenty years through the site selection process and found them to lack transparency and accountability. I suggest that there is a serious lack of trust in the NWMO among those closest to this proposal and a lack of familiarity within Canadian society as a whole. For this reason, a full IA and public hearing is critically important.

“Why the Project is Needed” (page V, IPD)

This section reads more like a political statement than a statement of fact or argument. That the project would provide a permanent disposal solution for used nuclear fuel might be true, however whether or not it would be  a safe disposal solution has yet to be demonstrated and a full IA with public hearing is the only way to that end. “Supporting Canada’s commitment to climate change…” and “ Eliminate the need for future generations…” read more like mission statements than arguments. They make unfounded assumptions resulting in misleading statements designed to garner blind trust.

The IPD Lacks Details and has Many Gaps

The IPD, in spite of its 1200 pages, lacks details of many critical parts of the project (gaps) which I hope to address individually in more deal in a separate comment to the registry. This lack of detail indicates to me that the proponent does not know how they intend to proceed or is not willing to tell us. This further diminishes public trust and reveals an entitled publicly funded organization that plans to get to the approvals stage without having to address any risks or uncertainties along the way.

The omission of transportation of the used nuclear fuel waste (UNFW) from generation sites across Canada to the proposed DGR is one blatant example of their unwillingness to confront aspects of the project where risks and uncertainty are identified. For this reason, a full IA and public hearing is critically important. The transportation of used nuclear fuel waste must be included in this IA.

The Used Fuel Packaging Plant (UFPP) lacks a complete or even summary description. Does the proponent not know how this will operate or do they not want to say? Either way, this is one of the areas of highest risk for radioactive releases affecting human health, environmental degradation, worker and occupational health and threats to neighbouring and downstream communities. For this reason, a full IA and public hearing is critically important.

Another serious omission from this IPD is any discussion of alternatives. NWMO decided decades ago that the only way to manage UNFW was to bury it deep in the Canadian shield and abandon it. There is an alternative: continued on-site storage in well designed, and robust at or near-surface storage as close as possible to the reactor sites where it can be monitored, measured for stability and mitigated if required.

Alternative means of constructing a DGR are inadequate or omitted. Examples are:

• ramp construction versus shaft
• packaging used fuel bundles at reactor site before transportation versus building and operating a UFPP at the DGR site where radioactive releases would be unavoidable
• modified mining methods to reduce excavation damage zones versus standard mining techniques
• repository layout
• waste placement in drift chambers or in floor
• used fuel container design

These are all areas where discussion of alternatives could lead to a better understanding of construction principles and evaluation of risks and uncertainties. The NWMO often cites “international best practices” as a justification for whatever it is they are promoting. Where then is our opportunity to consider what is being done elsewhere in the world in terms of the above? These alternatives must be included in the IA where a full impact assessment with a public hearing would ensure the best chance for identifying risks and choosing the best method of avoiding them.

In summary:

1. This project must be designated for a full impact assessment and public hearing
2. Transportation of UFNW must be included in the impact assessment
3. A thorough examination of alternatives to the project and alternative means of carrying out the project must be included in the impact assessment
4. A detailed project description is required to address gaps and shortcomings in the initial project description