Why Transportation Should be Within the Scope of the Impact Assessment

First, I would like to address the issue of transport of the high level waste as used nuclear fuel bundles by RAIL.

NWMO has proposed road and rail transport of the Nuc.fuel bundles as an alternative to transport by road , by transport trucks only.

RAIL TRANSPORT CONCERNS:

NWMO has NOT made an agreement with CPKC ,the Canadian Pacific Kansas City Railines ,to transport the used nuclear fuel bundles using the 100 Dry Storage  containers.

CN and GO trains share these rail lines with CPKC especially along the Southern Ontario Rail Corridors and NO agreements have been set in place to justify NWMOs announcement in their 2021 Transpotation Report that this is their alternative choice.
If this goes through the following must be considered as part of the Impact Assessment:

Assessments on the shared lines must be done with CN,CPKC,and GO with regards to the longduration impacts over fifty years, on rail  infrastructures,the impacts of climate changes on derailments ie derailments due to sun kinking,the impacts of derailments on the small and large, high density populations living alongside the rail corridors.
The CNSC and Transport Canada should be required to do a Crash test of the Dry Storage Containers and should update their certification regulations with regard to the transport of these dry storage containers over such long distances assuming that they may come from as far as New Brunswick and Quebec ,as well as Ontario.

ROAD and RAIL CONCERNS:

There should be comprehensive security and emergency response plans for each rail and road shipment that takes into consideration derailments and transport accidents in the more difficult to access remote areas of northern and northwestern Ontario.Conversely, to gain social acceptance people need to know that there are comprehensive security and emergency response plans in the high density and smaller  population areas living alongside the rail corridors in northern,and southern Ontario,the GTA,Montreal and Quebec and the affected Maritimes.

Does the Transport Security Plan study any threat assessments ie. terrorist threat situations?
 

There will be " Critical Groups" of people at risk for doses of radiation in marshalling yards or transport truck stops or at accident scenes.Have they been identified?.....There is a dire need to look at different "Severity Categories"refer to Kempe 1993.

Impacted in an accident scenario will be human and non human biota.Will that study be done?
In the event of a nuclear waste accident/ contamination special attention must be given to the releases of  nuclides such as a. Gases like tritium ,b.semi volatiles like iodine and cesium which by the way is water soluble.c.particulate fission products including strontium which is also water soluble and d. actinides such as plutonium.

Note that when shareholders,that is us ,check their household house and property insurance policies,that there is NO insurance coverage for nuclear accidents or contamination.Most people are unaware of this and need to know.

ROAD TRANSPORT

For the past fifteen years MTO statistics show that the percentages of truck transport accidents between Nipigon and the Revell Site area are exceptionally high.From Sistonens Corners just outside of Thunder Bay to Ignace the transport truck collision rate is often over 60 percent of all collisions on that stretch. The latest MTO stats show that the transport truck collision rate is third highest in Northwestern Ontario from Nipigon to the Revell dgr site ,next is the 400 and the 401.

What needs to be studied in this Impact Assessment are the following: 

Road geometry,traffic data, crash rates related to posted speed limits,the  province's terrain,numbers of lanes feeding into the trans Canada,divided roadways, population proximities,collector and connecting roadways, highway infra structures ie the bridge in Kakabeka that now takes all east and west transport truck traffic,the lack of shoulders on northwestern highways especially between Thunder Bay and Ignace,driver behaviours and their lack of official training, the increasing demands of across Canada transport truck transportation and so on.
Have any of these issues been addressed as they apply to the most radioactive wastes ever transported?Will Transport Canada address all of these issues.Not likely.Will the IPA consider these as significant and demand the necessary studies?

And lastly,will the IPA get CNSC to update their UFTP tests that are woefully inadequate and outdated?Their tests come from the 1980s,have NEVER  used full scale models just 1/7 or 1/2 scale models and do not apply  to the geograghy of northwestern Ontario..Their Crash Test scenario from the UK in 1984 is no longer meaningful in 2026  in Canada with references to Canada's UFTPs. The IP A must demand these upgrades.

Conclusion.

The IPA  needs to examine this alternative.They should reconsider the Proximty Principle and simply maintain and monitorthe used nuclear fuel bundles at the nuclear reactor sites as they have been doing for the past sixty years but harden off those sites, build stronger  storage areas on site,continue monitoring the dry storage containers until a method of reprocessing or using the waste can be found.

The IPA must recognize that all of these issues related to the transportation of the used Nuc fuel bundles and  that have been mentioned are issues raised by thousands of petition signers and voices across Ontario.
Transportation must be kept within the scope of this I P A.