Planned DGR project riddled with issues. Full impact assessment needed.

I have several comments regarding the proposed deep geological repository (DGR) Project proposed for Revell River Ontario.

To start, the 30 day time period for response to the Initial Project Description for this massive project that potentially has far-reaching impacts is wholly inadequate. I reserve the right to make supplemental comments.

The Nuclear Waste Management Organization’s (NWMO) proposal is to transport 150,000 tons of high level radioactive reactor waste to the DGR site from reactors that are on average 1700 km away. Over a 50 year period, the waste will be transported, then repackaged, buried at the Revell Site in the Canadian Shield, backfilled and (after 160 years) abandoned. The waste is highly radioactive and will remain a health and environmental hazard for hundreds of thousands of years.

Transportation should not have been excluded from the Initial Project Description (IPD). All risks, impacts, routing and alternative options associated with the actual transportation of the toxic spent nuclear fuel absolutely need to be included in the assessment process as they are integral to and entirely functionally related to the project. Without waste there will be no DGR. The many risks and legitimate concerns associated with the transportation “plan” are obvious to anyone who has been on the highways or railways in Ontario. Off-site transportation of used fuel waste from nuclear reactors at this scale is unprecedented.

In addition, the IPD inadequately explores several other significant risks and issues associated with the proposal.

Repackaging fuel and then burying it underground is a highly technical and risky operation. Despite this, the IPD glosses over significant technical challenges and details regarding repackaging, burial layout and design, and long term “storage”. And what about the impact of accidents and the inevitable eventual leakage of radiation to the watershed, air and soil?

We are talking about spreading risk along a lengthy transportation corridor and then repackaging and dumping the waste in pristine watershed and atmosphere where no current risk of radioactive contamination currently exists. Keep the risk where it is now – near the reactor. Planning to bury and abandon this horrid legacy is immoral. I am not a geologist, or a hydrologist, but I do have a background in science. It is pure hubris to suggest that we can accurately predict what will happen to waste buried in a DGR area over hundreds of thousands of years.

Highly dangerous nuclear waste on trucks or train cars will have significant exposure to malevolent acts over 50 years of long distance (1700 +km) transport. Enough said.

Significant opposition and concern exists amongst many First Nations and other communities along the transportation corridor, in the DGR area, and downstream in the watershed. This despite the distribution of obscenely large sums of money in aid of “encouraging” a couple of select host communities. Consent has not been obtained from many of the Indigenous peoples living either in the DGR area and along the transportation corridor. This is not acceptable. In fact most communities both along the transportation route and downstream in the watershed that ultimately will be impacted have not been adequately included or consulted.

This project will be very expensive and is being done TO the people, environment and future generations. However the benefits seem to be FOR the corporations and companies that will line up for the significant dollars expected to flow in the completion of this massive project. And as mentioned, a few extremely lucrative financial agreements and prospects of significant short term economic benefits have helped NWMO obtain some support from very select “host” communities.

The need for this project is questionable – generally accepted best practices continue to include on-site monitoring and management of nuclear waste near the reactors where the waste is produced. The Full Impact Assessment needs to much more thoroughly examine the need for and the purpose of the project. It also needs to outline more completely alternatives to or alternative means of achieving the aims of safe management of the waste. Descriptions of these items in the IPD are cursory.

In fact, the justification for the DGR project seems political and appears to be obliquely mentioned in the IPD. By setting up a DGR and getting the waste out of sight and out of mind of the majority of the population, the way will be smoothed for more expansion of the nuclear industry. Expansion of that industry, as currently planned, could lead to production of double or triple the current volume of waste. Nuclear energy may be greenwashed and touted as low carbon (by some measures), but it is capital intensive, unwieldy, plagued with technical issues, cost overruns, delays and of course produces extremely toxic waste. Imagine what could be accomplished if we invested similar resources into developing more sustainable power production technologies.

Given the questionable need, significant risks, technical complexities, huge expenses, long term negative environmental legacy and many community concerns and issues associated with this project, the NWMO Revell River DGR needs to be subject to much more serious scrutiny under a Full Impact Assessment and should be referred to the Integrated Review Panel for public hearings.

This project needs to be stopped. Dead. We owe this to our grandchildren.