NWMO Nuclear Waste Transportation and Burial scheme

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.

While I have many concerns about the project itself and the NWMO’s method of selecting the site and their site selection, my comments are on the Impact Assessment review process which began on January 5^th and the NWMO’s “initial project description”. 

The 30-day comment period is too short. Many people who are concerned about this project, including the transportation of the radioactive waste to the site, will not have even heard about the comment period and, for those of us who were alerted to the comment period, it is a very short period of time to comment on the initial project description. This is an important project that will have impacts for generations into the future.  The review process must be thorough and allow public participation, and a 30-day comment period works is not long enough.

The project description is not satisfactory by any stretch as it leaves out very important information about the project.  For instance, why is the NWMO trying to persuade the Impact Assessment Agency that transportation can be left out of the review? They have been describing transportation as part of their project for more than twenty years!  They cannot do this project as described without the transportation route.  It is not an option. It is a critical component and, as such, cannot be left of the review.

The NWMO provides far too little information about project activities, including those project activities that pose radiological risk for the workers, and for area residents including those downstream from the project site.  There is not enough information about the Used Fuel Packaging Plant, how the wastes will be transferred into the underground and placed in the emplacement rooms, how the containers will be monitored after they are underground, and how they will be retrieved or repaired in the event of a container failing.   These are enormous shortcomings in this project description. A long distance transportation plan must be inclued in the project review.

I am requesting that this project be the subject of a full impact assessment including a public hearing, and that the Impact Assessment Agency ensure that the public can participate in a meaningful way through each step of the process.

I want you to know that I live very close to Highway 17, the Trans-Canada highway, north of Sault Ste Marie.  I travel this highway on a regular basis year-round and am very familiar with the dangers this highway poses particularly with winter weather driving, highway closures, highway washouts and closures being exacerbated by climate change, the topography of steep hills, turns, rock cuts etc. all pose serious potential for accidents during the transportation of these radioactive materials.  What is the long-term safety plan? What are the emergency response and evacuation plans throughout the route? How is it possible that the brief barely addresses any of this, if at all.  Also given the extremely severe danger posed by the radioactive contents of these vehicles, how are they being secured against malevolent acts?  The transportation route also poses a grave danger to the health of the precious Great Lakes waters and ALL who depend upon them human and all others. This is a huge marine environment in the heart of North America feeding all the lower Great Lakes. The fish and all those who live along and in these waters will be affected at not just accident sites... but water flows and carries with it all hazardous material and the longterm impacts are unknown. The vehicles carrying the nuclear waste will traverse the North Channel of Lake Huron and the North Shore of Lake Superior; they will cross the bridges and skirt the shorelines of many rivers and lakes that flow into the Great Lakes.  The health and safety of Great Lakes waters are of paramount importance not just in the vicinity of the transportation route but the entire route of Great Lakes waters. 

Climate change is producing more snow, more ice, more sustained rainstorms, and more unpredictable conditions lasting for longer periods of time.  None of this is being addressed in the design.  Climate impacts are increasing affecting many aspects of the transportation route and the destination. Where is the detailed account of these risks, and safety plans?

Related to the transportation concerns are the fact that the fuel packaging plant itself lacks even a summary description, let alone the necessary complete description. There isn’t any description, let alone detailed description, of the monitoring program for the underground chambers to house the nuclear waste—not when they are in operation, not when the facility closes, nor what happens post closure half a century from now.  This is a FOREVER responsibility.   

How is it that worker and occupational health are not even addressed given the long term, forever impacts, for every community along the entire route.   The potential effects section is very poorly described and entirely inadequate.   The radioactivity and estimates of radioactive releases from various project activities over various time frames, and assessing those effects, has been almost completely ignored!

We must be provided with a thorough examination of the alternatives to the project.

Thank you for considering my comments and concerns.