Transportation Concerns

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.

I have many concerns about the project, the NWMO’s method of selecting the site, and the unprecedented nature of the NWMO’s proposed Deep Geological Repository. My comments are about the Impact Assessment review process which began on January 5^th and the draft guidelines for the preparation of an impact statement which were posted for a thirty-day comment period on April 10^th.   

During the comment period on the Initial Project Description more than 600 sets of comments were submitted, identifying many issues and concerns and many shortcomings with the Initial Project Description.

For me, living in North Bay, this waste is proposed to travel through my city. There are many people who live along the highways (both 11 north and 17 west).  I would like to see specific details related to the prevention of accidents. Will these transports be accompanied by police escort to ensure safety? Will they have lead vehicles warning other drivers of the sensitive material being transported (similar to over size vehicles)? If not, how will the safety of the transportation be ASSURED. There are many accidents on these highways, many involving tractor trailers. Also, if there is construction on the highways how will the transport remain in motion or again, have safe passage assured? How will the cylinders for storage be tested in ALL conditions - cold winter snow, under water, air born, etc. How will spills be cleaned? How will first responders be trained in responding to accidents? How will good samaratins be trained of how to administer first aid to the driver of the nuclear waste vehicle? How will the safety of the driver be assured? What kind of training will be given to the transport drivers and who will over see the training and compliance? That is a huge issue already so new standards will have to be put in place. 

How will the public know when the transports are on the highway, so we can make informed decisions about our own travel to ensure our safety by not being in proximity to the transports carrying the waste? How will water ways and drinking waters, and ground waters be protected? How will we assure healthy food and water to areas impacted by spills? How will transports be maintained to assure tire blow outs or other mechanical issues are not to fail? How will tow truck drivers be trained on how to safely respond to maintenance issues of the transports? How and where will transports be parked when the driver needs a rest - some of the waste is coming from as far as New Brunswick. 

How will you get consent of the communities who will be expected to allow this risk to their local roadways? What thresholds will be considered adequate for that consent? How will wildlife be considered and protected? 

If something goes wrong in the underground depository, how will you get underground to deal with it? How will it be monitored (abandnment can not be an option)? 

The draft guidelines leave out many important issues and do not require enough information about the NWMO’s project, the many different components and activities that are part of the project, or the potential for negative effects.

 LONG-DISTANCE TRANSPORTATION MUST BE INCLUDED IN THE PROJECT REVIEW. 

The draft guidelines require information about local transportation but would allow the NWMO to update a 2021 “Preliminary Transportation Plan” instead of providing a detailed description of their transportation program as part of the impact statement. Transportation of the wastes is part of the project and the impact statement must include a detailed description.

THE NWMO MUST BE REQUIRED TO PROVIDE A DETAILED PROJECT DESCRIPTION.

The draft guidelines do not require enough information about the project activities. For example, the guidelines must require a detailed description of 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. Releases to air and water at all stages of the project must be described, as well as their potential for harming humans and the environment.

I am requesting that the impact statement guidelines be strengthened to require a detailed description of the NWMO’s project and its activities and components.

Thank you for considering my comments and concerns.