DGR project must have full impact assessment and public hearing and transportation must be included.

I am writing to express my concern about the Nuclear Waste Management Organization’s proposed deep geological repository for nuclear fuel waste which the NWMO is proposing to construct and operate between Ignace and Dryden in northwestern Ontario.

There was not enough time given in this process for me to properly review and thoroughly comment on this broad and very important issue for all Canadians, therefore I reserve the right to make more comments further on but here are some comments:

 NWMO’S “Deep Geological Repository project” must be designated for a full impact assessment and public hearing.

Transportation must be included in the impact assessment since public roads from all over will be used for at least twenty years to get to the designated site and have an impact on many communities that didn’t get to have their say in the matter but will be greatly impacted, especially, when something will go wrong. The reasoning for excluding it from the impact assessment does not stand as they often deal with other matters that concern other agencies.

A thorough examination of alternatives to the project and alternative means of carrying out the project must be included in the impact assessment

The initial project description fails to provide the necessary information about the NWMO’s project, but a detailed project description is necessary in regards to these essential components:

The long-term safety, the transportation, the emergency response and evacuation plans, what happens in case of accidents (I am concerned about the impact on the cost to tax-payers, property owners and the environment), acts of terrorism, security measures, health of the population and of the workers, project steps (transportation, there is no description concerning the used fuel packaging plants, the concurrent placement of wastes in underground chambers while construction is ongoing (I am concerned about water contamination since France now builds with measures to avoid having rainwater in the constructions that will house radioactive elements after having seepage issues), as well as monitoring through operational, closure and post-closure stages.

There needs to be climate considerations and estimates of climate impacts, the potential effects section is inadequate, the radioactivity and estimates of radioactive releases from various project activities over various time frames and assessing those effects, and the impact on community profiles (differential treatment, transportation and downstream communities are largely excluded). What is the sequencing of the approvals/licenses? The water “management” doesn’t include key issues such as: pumping of groundwater from the underground (volumes, contamination, storage, treatment, release), water from the used fuel packaging plant (volumes, contamination, storage, treatment, release), alternatives to the project (for example continued on-site storage) are not described, alternative means of carrying out the project description is inadequate or missing. It would need to specify whether ramps versus shafts are used; transportation in used fuel containers instead of in transportation containers; what mining methods are prioritized and why; what is the repository layout (items should be inventoried and recoverable); waste emplacement (in room vs in floor) used fuel container design, the project description states that access to the site will be limited; no details are provided as to roadways, forests and waterways used by the public.

A review panel for the “Decommissioning of the Gentilly-1 Waste Facility project,” must also be carried out (Reference Number 90092). Please immediately release the Environmental Effects Report (“Environmental Effects Review for Gentilly-1 Waste Facility – Phase 3 Decommissioning”.

Impacts of transport and disposal of the waste are to be included in the assessments, including by consulting communities along the route of radioactive waste from the plant, and by consulting First Nations on whose traditional territory this hazardous waste would be stored.

The decisions that are made are too important for our generation and future ones. Many other repositories will use this process and I fear the way it is done isn’t right but it will become the model to base the process on and Canadians such as myself are not satisfied with the process, planning and presentation of what is to be carried out and we cannot give full and prior consent to a project such as this one.

Please stop producing nuclear waste. Nuclear energy is not clean. It is costly since we have to contain it in the safest manner forever and to this day, nobody has managed to do so properly. Therefore, the planning process must be detailed and thought out expertly and carefully.

Thank you,

Alexandra Franche, Concerned Canadian living on the un-ceded Anishinabe Algonquin territory in Ontario