Resend of comment re: APM-REP-05000-0211-R000

To Whom It May Concern

This long and complex document starts with two unsupported assumptions: 1) That nuclear waste can be safely stored for a "long time" and 2) That nuclear power is a reasonable tool for mitigating climate change.

 

The first assumption will remain unproven for a "long time" (millions of years). The document limits all discussion of the potential impact of then project to a 160 year timeline, despite the fact that radionuclides in the waste remain lethal for millions of years. Nowhere is there any explanation of how the waste will be monitored after it has been sealed in the repository. 

The second assumption is already far from true. Nuclear power cannot mitigate climate change for many reasons, but two should be sufficient to exclude it from consideration: Nuclear reactors take too long to build and cost too much (invariably, far more than what promoters promise at the outset).

 

The first step in any nuclear waste management plan should be to stop making more waste. Otherwise, no matter how successful any particular nuclear waste project appears to be, it won't go very far towards solving Canada's actual, ongoing nuclear waste problem. In fact, will enable making that problem worse.

The planned repository is explicitly limited to 5.9 million used fuel bundles, the expected total radioactive waste from all of Canada's previously closed and existing nuclear reactors. At the same time, the project explicitly encourages the development of new nuclear reactors and therefore the production of more waste. Nuclear power is described as "... a reliable, low-carbon source of power and contributes directly to Canada’s climate change commitments and goal of achieving net-zero emissions."

 

The document assesses many potential risks based on a matrix of potential damage versus likelihood that a particular event will occur. This process doesn't work well for radioactive contamination for many reasons. For example: There is no good way to assess the likelihood of radioactive containment remaining intact for thousands of years, let alone the millions of years the waste will remain dangerous. Nor can one properly estimate the risk of above-ground accidents or sabotage during reactor operation, on-site spent fuel storage, transport to the waste repository, additional storage time above ground at the repository facility (very likely decades or more), and during final placement in the repository.

 

A lot of room for a lot of errors — and once radioactivity is in the environment, there are limited ways to assess the potential damage across multiple generations of animals (including people) and plants.

Ironically, the document points out that existing radioactive contamination in the area is probably the result of nuclear bomb testing. The document also explicitly acknowledges the burden of leaving nuclear waste for future generations, but fails to draw the related conclusion that making more nuclear waste perpetuates inter-generational burdens — or even the conclusion that nuclear waste is a potential target (intended or unintended) of future nuclear wars.

The document acknowledges other significant knowledge gaps, but it isn't clear if answers to outstanding questions will have the ability to reverse any decision to proceed with this project if initial approval is granted by Canada's regulatory agencies. Some important outstanding issues include potential groundwater impacts, as well as the concerns of indigenous groups that have not yet been consulted.

The document also explicitly excludes any evaluation of transport issues beyond the immediate access routes to the site. However, transporting nuclear wastes from the existing and closed nuclear plants will require waste to be moved from reactor sites to the new proposed storage site over public roads, bridges, tunnels, and railways. Completely ignored is the potential for accidents at any point in the process, resulting in large populations receiving significant exposures from radioactive releases.

As U.S. citizens who (like every creature in the world) could potentially be impacted by radioactivity released from the proposed site, and in support of the many Canadians who also oppose the proposed plan, we request that all applicable agencies consider a more detailed risk assessment followed by well-publicized public hearings before allowing the project to move forward.