Comments on Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project Initial Project Description APM-REP-05000-0211

MANITOBA ENERGY JUSTICE COALITION - NO NUKES MANITOBA Campaign

Comments on Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project

 Initial Project Description APM-REP-05000-0211

Requirement for Comprehensive Impact Assessment

As one of the largest industrial developments in Canada, and one that contemplates the movement, repackaging and burying of some of the most toxic and dangerous human-made products on earth, this project must be subject to a complete and Comprehensive Impact Assessment with a Panel Review, meaningful public participation and public hearings.The Initial Project description is inadequate for a number of reasons as outlined below.

Inadequate Timelines

The 30 day comment period on the Initial Project Description is inadequate, especially considering that this project has been contemplated for decades, and will have repercussions well beyond the 160 years that is allocated to operations and post-closure monitoring. 

The  timeline for application for Participant Funding is also inadequate. There are so many issues to be dealt with on the technical, public health, engineering and risk assessment methodologies amongst other aspects of the work to be undertaken that it is challenging for public interest groups (many of them volunteer based) to determine where to focus attention and consider bringing independent professional expertise to the table.  

Climate Change

One of our primary concerns is climate change. The IPD seeks to make the case that this project is essential if Canada is to achieve net zero emissions and to meet our climate change commitments. In support of this case, it is stated that the deep geological storage of nuclear waste will allow the continuation of the nuclear power industry. We object strenuously to the self-serving positioning in this document of nuclear power as a solution to climate change by the NWMO – which comprises the major nuclear industry participants in Canada. 

There is strong evidence to support the position that building more nuclear plants and refurbishing old ones will in fact cause increased greenhouse gas emissions due to continued use and potentially new build out of fossil fuel generated electricity pending nuclear reactor construction and start of operation. As the global temperatures continue to rise above 1.5 degrees Celsius since pre-industrial times, and as climate tipping points are rapidly approaching, the assertion that this project will assist in meeting climate change commitments is false and misleading and must be removed from the project description and justification.

Transportation Excluded

It is essential that transport of the waste from nuclear reactors be included in the scope of this impact assessment. The project would not exist without the transportation of the waste. Regardless whether or not CNSC licenses nuclear transportation in Canada, the public deserves the opportunity to provide feedback about the unprecedented volumes of high level waste that will pass on a daily basis along the extensive transportation route to the proposed site. In addition, CNSC regulates many other aspects of this proposed project that have NOT been excluded from the scope that NWMO is suggesting. If transport is by road, it must traverse some of the most hazardous routes in the country (eg. Highways 11 and 17 in Ontario), well known for an increasing number of fatal accidents involving large transport trucks.  These northern routes are often closed due to weather conditions. NWMO attempts to take road closures into consideration by reducing the number of days that waste will be transported, however, it is often impossible to predict when and where closures will occur, and when they do, trucks carrying radioactive materials will be forced to stop, either at rest stops or along the highway itself, raising questions about the dose impacts to drivers of the vehicles who will not be able to switch out when their exposure limit is reached. 

These routes pass through the territories of Indigenous Nations who have the constitutional and legal right to consent or object to the daily transport of radioactive and hazardous materials. They also pass through many small communities, often metres from dwellings and buildings such as schools. Non-indigenous communities along the transportation routes must be afforded the opportunity to participate in the assessment and comment on this project. Without that, this project cannot be said to have gained the social license that is required for it to proceed, as noted for example in NWMO’s Preliminary Transportation Plan, 2021 which states: 

For a site to be selected, the NWMO will need to demonstrate the following:

1) A deep geological repository can be safely implemented with a strong technical safety case;

2) The project can be implemented in partnership with informed and willing hosts; and

3) Confidence that a safe, secure and socially acceptable transportation plan can be developed.

NWMO has included the transportation of nuclear fuel waste in its description of this project for the past 20 or so years. It is integral to the project and must be included in the scope.

Greenhouse Gas Emissions

This project also has an obligation to consider and report on the greenhouse gas emissions that it will entail. At page 84, The IPD summary states: “The Project will emit GHGs throughout all phases, including direct and indirect emissions from various sources like mobile fleets, heating plants, backup generators, blasting, land clearing, electricity consumption, and used nuclear fuel transport”. Evidently, NWMO would like to avoid counting the GHG emissions from 50 years of daily transfers to NW Ontario. These emissions do not appear in Table 24.1 Potential Wastes and Emissions, presumably because they would like to exclude long-distance transportation from the scope of the IA. That sleight of hand, however, will not make the emissions go away.  

Project Impacts outside of Ontario

We question NWMO’s statement that there will be no impacts outside of Ontario. The proposed site is on watersheds that drain into Hudson Bay, via Lake of the Woods, the Winnipeg River and Lake Winnipeg. Any release of radioactive contamination into water, such as from the interface between ground and surface waters, or from the above ground operations of the Used Fuel Processing Plant, or from movement of nuclear materials around the site, or an accident that may occur on the site, could result in radioactive releases into the watersheds. The same is true of any airborne radioactive contamination which can travel with the wind into Manitoba or the United States. Many Manitobans spend time and travel back and forth to NW Ontario for business and leisure. Many also are property owners in the area of the proposed site. Manitobans therefore have a direct and local interest in this project.

Inconsistent Argument used to justify the proposal

The IPD says this project enables reassurance that future generations will not have to actively manage nuclear waste as it will be safely stored underground. This statement defies logic, since there is also the above-mentioned continuation of the nuclear industry, and ignores the fact that several large nuclear projects have been announced by IACC and are now in the IAAC planning stages. If approved, these will create additional huge quantities of irradiated fuel waste, which will need to be managed well into the future at the surface due their thermal heat and extreme radioactivity. The project justification of eliminating burdens for future generations is false and misleading and must be removed. Only if there is a commitment to the phasing out of nuclear power in Canada could this argument conceivably be valid.

Indigenous Rights

NWMO has many fine words about its “journey of reconciliation”, “acknowledgement of truths” and so on, but their actions are not always consistent with their words. They have not addressed the stated opposition to this project of at least 13 Treaty 3 First Nations in the vicinity of the proposed site. The following comment on p.82 of the IPD  “The NWMO will also respect the physical and cultural heritage of other potentially affected Indigenous groups if they have historically exercised Rights within WLON’s territory, although to a lesser extent” is in fact, disrespectful. In particular, we support Eagle Lake First Nation’s position that they have not been properly consulted.