Opposition to DGR in NW Ont

I would like to express my strong opposition to the proposed DGR project in Northwestern Ontario. As a science teacher who spent my career prioritizing the importance of sound scientific methodology and critial thinking skills, I find it difficult to tolerate what NWMO is attempting to pass off as "settled science" relative to the trasportation and burial of  spent nuclear wase in Northwestern Ontario, utilizing a never before tested technology.  

My opposition will focus on two issues:  1) the lack of valid scientific data to support claims of "safety" put forward by NWMO, and 2) the absence of reliable risk assessment data, including the lack of transparency regarding transportation risk.

1. Lack of scientific data to support claims of safety of a DGR.

It is duplicitous for NWMO to claim "safety" on paper from a "technical perspective" when there is no real world data outside the theoretic conceptual plan to support such claims.  NWMO's support for the DGR uses jargon such as "settled science" and "best practice" which inherently insinuates that this method has been done before, tested, and proven to be effective.  Since there is no operational DGR for spent nuclear waste anywhere in the world, the requisite scientific data to support claims of "safety" simply does not exist.  Safety of a DGR cannot be determined solely by a "technical plan on paper" put forward by an invested industry intent on burying their 60-year-stockpile of forever toxic nuclear waste.  No other Canadian regulatory board would accept this kind of non-evidence-based, non-independent claim of safety of an unproven technology.

When Health Canada was asked about scientific data regarding DGR safety, they stated that this has all been left to the Canadian Nuclear Safety Commission (CNSC), an offshoot of the nuclear industry.  I cannot trust this relationship as a truly independent nor scientifically unbiased assessment of something as crucial as the possibility of thousands of years of potential leakage of radiation/toxic radionuclides into our environment.  There has not been the test burial of even ONE container of spent nuclear waste to observe and collect data from.  In spit of this, NWMO exudes confidence in its ability to "safely" bury 6 million of these radioactive toxic waste bundles.  However, their confidence may be cloaked in ambiguity, given that they are choosing to transport the waste 1600 km over one of Canada's most dangerous highways, into a different watershed, and far removed from the large populations that produce the waste and have profited from its production for over half a century.  

Given the absence of reliable scientific data to support DGR safety, it is not surprising that both Quebec and Manitoba have banned the burial of spenct nuclear waste anywhere in their provinces.  It is also apparent why the U.S. government introduced bipartisan resolutions in the House and Senate opposing the burial of spent nuclear waste in Southern Ontario because of its location in the Great Lakes basin.  Northwestern Ontario residents are not a small, expendable population, and should not be expected to assume the numerous and potentially catastrophic  risks associated with the experimental transport, burial and abandonment of nuclear waste, utilizing a scientifically unproven technology.

2.  Lack of reliable risk assessment data.  NWMO ignores or obfuscates the inherent risks of this proposed project during their pubilc engagement presentations.

a) NWMO defines risks to each individual concern as "small".  However, because the consequences of failure are significant, if not catastrophic, risk is actually greater than reported.

b) NWMO also refers to individual risk factros (eg. seismology) and not to "project risk factors" which must take into account ALL risks.  The risks are numerous and complex, including the risks involved in TRANSPORT of the material, which is an essential component for valid risk assessment of the DGR.  Spent nuclear waste contains a complex mixture of radioisotopes.  Its components are difficult to characterize and they pose a range of significant hazards in the event of accidental release.  The lack of regulations and stardards specific to transport of spent radioactive waste creates unacceptable risks to conveyers, first responders, and the general public.  Transport of radioactive waste should not take place without strong justification, full transparency, and putlic input.  While NWMO should welcome the opportunity to discuss their plans to mitigate the serious risks involved in trasnport of this unprecedented amount of spent nuclear waste they have, instead, attempted to omit treansportation form the federal impact assessment.  This begs the questions...where is the "transparency" and what is NWMO afraid of??

c). NWMO is also the group determining the risk level based on hypothetical datsa that they feed into a computer program.  This, once again, is not scientific real world data because there is no operational DGR for high level spent nuclear waste anywhere in the world to obtain relevant and reliable data from.  

In conclusion, NWMO has failed to provide adequate scientific data to validate "safety" related to the transport and burial of 6 million bundles of high level spent nuclear waste.  Public engagement sessions have repeatedly failed to communicate the inherent uncertainity, risks and lack of real world scientific data to support NWMO's adamant claims of "safety" of a DGR.