Re: Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project

Dear IAAC, 

I have followed the NWMO's Deep Geological Repository project for many years. 

The project has significant long-term environmental implications, and should be subject to a full and comprehensive review under the Impact Assessment Act. 

A comprehensive review must include all aspects of the project, including:

• Existing management and storage arrangements.
• The need, rationale and scope of the project, including whether it should be limited to existing waste nuclear fuels from CANDU reactors in Canada generated through their normal operating lives, or waste fuel from other, as yet unknown reactor types, as NWMO has indicated it may accept.  
• The transportation and handling of the waste nuclear fuel, including any repackaging or modification of materials, including the cumulative effects of these activities.  
• The impacts and risks associated with any long-term management facilities, including the possibility of leaks and other malfunctions
• The definition of 'consent' and the means and standards by which it would be considered to be obtained from the affected Indigenous and settler communities. 
• The contribution of the project to sustainability. 

Given its scope and significance the project must be subject to a public review, including public hearings and a panel reivew, independent of the CNSC's technical licencing process. 

Yours sincerely, 

Mark Winfield

Professor

Co-Chair, Sustainable Energy Initiative

York University

Toronto