According to the Nuclear Waste Management Organization (NWMO), its proposed project, a deep geological repository (DGR), will “provide a permanent and safe disposal solution for used nuclear fuel.”[i] (#_edn1)

However, according to the NWMO, its project does not include the transportation of radioactive nuclear fuel waste from reactors sites to the proposed deep geological repository (DGR).[ii] (#_edn2)  Our first request is that the IAAC order a full impact assessment and public hearing of this project, and thoroughly consider the impacts and risks of transportation in the review.

Our second request is that the IAAC consider alternatives to the proposed DGR. According to the NWMO’s 2005 report, Choosing a Way Forward: The Future Management of Canada’s Used Nuclear Fuel, radioactive nuclear wastes must be fully isolated from people and the environment for one million years or more.[iii] (#_edn3)  Furthermore, according to the 2005 report, if a radioactive release occurs in a DGR “it may be difficult for a future generation to detect the breach in a timely way and take corrective action.”[iv] (#_edn4)

It is our submission that the NWMO’s 2025 Initial Project Description has failed to prove that its proposed DGR will provide a “safe disposal solution” for Canada’s used nuclear fuel for one million years or more.  

In Germany, six nuclear stations have on-site, above-ground, attack-resistant reinforced concrete vaults for the storage of their nuclear wastes.  The concrete walls and roofs of these vaults are approximately 1.2 and 1.3 metres thick respectively.[v] (#_edn5)

The International Joint Commission’s Great Lakes Water Quality Board is calling for Ontario Power Generation’s (OPG’s) on-site storage facilities to be “hardened” to protect them from terrorist attacks, and located away from shorelines to prevent them from being compromised by flooding and erosion.[vi] (#_edn6)

According to a report prepared for OPG, the total capital cost of building above-ground, attack-resistant, reinforced concrete vaults at the Bruce, Darlington and Pickering Nuclear Stations would be $236 million (2002$) per station.[vii] (#_edn7)

Storing used nuclear fuel in above-ground, attack-resistant, reinforced concrete vaults at the nuclear generating station sites would enable current and future generations to detect and correct radioactive releases in a timely way; and it would avoid the risks associated with the transportation of used nuclear fuel to northern Ontario.

In conclusion, it is our submission that the Impact Assessment Agency of Canada should evaluate whether building above-ground, attack-resistant, reinforced concrete vaults, at our nuclear generating sites, is a better storage solution for used nuclear fuel than building a DGR and transporting used nuclear fuel from multiple nuclear stations to a  DGR in northern Ontario.