Initial Project Description ( IPD) Lacks Detail

For all the 1200 + pages in this IPD, there is almost no description of what NWMO intends to do through all phases of the development, should approval be confirmed. I have commented already on the complete exclusion of the transport of high level nuclear fuel waste (HLNFW) from the reactor sites across Canada to the proposed site of the DGR. Not only does this fail to provide necessary detail on how they intend to proceed with this integral activity to the Project, but it is also a blatant attempt to side-step due process and ignore one of several mine fields in their plan. I reaffirm here that transportation of HLNFW must be included in the impact statement in order that the public have an opportunity to understand how and where this will be conducted and comment on the potential risks and uncertainties involved.

But there are many other parts to the Project for which precious little detail is provided, leading me to wonder “Why?”. NWMO has had over 20 years to develop plans for their project.

• Why have they not provided a project description now, when it counts, instead of a cut-and-paste rehash of former AECL plans from another century?
• Do they not have a detailed plan? Or do they believe they can get through the IA without having to confront the concerns of an informed public?

In my estimation, the following areas are so lacking in detailed description that review and comment seems pointless:

• the Used Fuel Packaging Plant (UFPP)
• the concurrent placement of wastes in the DGR while mining operations are going on
• how monitoring will take place through the different stages (operations, closure, post-closure)
• mining methods (how will this be carried out in a way that minimizes Excavation Damage Zones?)

I consider these to be serious gaps in the project description that need to be understood if this IA is to be meaningful.

Used Fuel Packaging Plant

Along with transport of the HLNFW, the UFPP is among my greatest concerns for harmful radioactive releases that would negatively impact human health and the natural environment. And yet, at this late stage there is a complete lack of detail on how this would work, what risks and uncertainties could reasonably be anticipated and how the proponent plans to counter them.

What we know is that the used fuel bundles will arrive in transport containers from the reactor sites. They will need to be inspected and repackaged from transport containers into containers for burial. This is not an activity to be taken lightly, yet we are left to assume that they have it figured out and there is little or nothing to worry about. I am worried about radioactive releases to air and water, worker health and safety, legacy waste and the possibility of permanent surface storage of materials at the site if DGR plans do not progress as intended. And that is based on what we know about the UFPP which is very little.

The NWMO has stated that there will be releases due to this activity into the air and surface water but they have provided no detail on how much, what level or what steps will be taken to counter this hazard.

Concurrent Placement of Wastes

I have major concerns with the stability of the rock formation in which these waste will be buried. There is concern that the shield rock is already fragmented. Surely mining operations (drilling, blasting, mucking) will further fragment the surrounding rock in which waste will be deposited. It seems likely to me that ongoing mining operations while placing waste will complicate and perhaps compromise the activity and its ability to result in safe containment of the wastes over time. Yet there is no discussion of this risk in the IPD.

Monitoring Through All Phases

Monitoring for radioactive releases during the operations, closure and post-closure phases is inadequate. There is not enough detail provided of me to be able to understand what is intended and to comment on my assessment of the monitoring plan.

Mining Methods

Again, there is not enough detail in the IPD to be able to comment on the risk of fragmentation of surrounding rock due to mining operations during construction. The supposition is that this is a stale rock formation and will also be stable at the time of placement of wastes. How will mining construction be completed to ensure this desirable outcome?

Summary

In my view, this Initial Project Description is totally inadequate because it does not provide enough detail on how the Project will be constructed. The above examples are just the most obvious ones to me. There will be others. I am left believing that the NWMO has purposely avoided providing detailed descriptions out of fear that this would raise more difficult questions.

I strongly suggest that this IPD be retracted and that a new IPD be presented for review in its place, with adequate time for the public to review and comment (eg. three to six months).