We have received the following comments:
Please note, comments are posted in the language in which they are received.
Charles Rhodes, P.Eng., Ph.D.
Xylene Power Ltd.
I am totally opposed to licensing of a DGR as envisaged by the NWMO.
Climate change is primarily due to the rising atmospheric CO2 concentration. Today, in 2023, stopping further rise in the atmospheric CO2 concentration would require about 21,000 GWt of new dependable and sustainable clean (non-fossil) thermal power to meet the total thermal load presently met by combustion of fossil fuels. Due to increasing electrification in developing countries, by 2070 this total thermal load will likely rise to about 40,000 GWt.
Intermittent renewable electricity generation cannot supply dependable power and, due to electricity dispatch constraints, can only economically provide about 25% of the required clean energy. Meeting the anticipated 2070 total thermal load with dependable power and clean energy will require both maximum economic renewable energy generation and a fleet of about:
Based on a projected Canadian population of 60,000,000 in 2070, Canada's share of these reactors will be about 450 X 300 MWe SMRs.
In spite of ample evidence of relatively rapid climate change, elected governments with short time horizons continue to delay deployment of nuclear power plants with sustainable fuel cycles. The consequences of this deployment procrastination will be dire.
There is simply not enough minable natural uranium to provide sustainable displacement of fossil fuels using water moderated reactors. Sustainable displacement of fossil fuels requires fuel breeding fast neutron reactors (FNRs). The start fuel for a sustainable nuclear fuel cycle is best obtained by separating the TRans Uranium actinides (TRU) from used water moderated reactor fuel. However, such separation is physically impossible if the used water moderated reactor fuel is placed in a DGR.
The DGR should be totally replaced by used CANDU fuel reprocessing as described at
Interim storage of fission products and other radioactive material pending future use and reprocessing is best done using a facility such as Jersey Emerald, as described at:
A major feature of Jersey Emerald is permanent accessibility above the water table for future inspection/container repair.
|Ontario Power Generation (OPG)||Please see attached table||OPG comments on REGDOC-1.2.3|
|Bruce Power||Please see attached table||Bruce Power comments on REGDOC-1.2.3|
|NB Power||Please see attached table||NB Power comments on REGDOC-1.2.3|
|Nuclear Waste Management Organization (NWMO)||Please see attached table||NWMO comments on REGDOC-1.2.3|
|Canadian Nuclear Laboratories (CNL)||Please see attached table||CNL comments on REGDOC-1.2.3|
|Mississaugas of Scugog Island First Nation (MSIFN) ||Please see attached table||MSIFN comments on REGDOC-1.2.3|
Athabasca Chipewyan First Nation
|Please see attached table||Athabasca Chipewyan First Nation comments on REGDOC-1.2.3|
Protect our Waterways No Nuclear Waste (POW)
My comments and those of the organization, a group of concerned residents of South Bruce, called Protect our Waterways No Nuclear Waste (POW) are listed below regarding the regulatory document on the information needed to apply for a licence to prepare site for a DGR facility.
In your introduction of the document, you specify that a DGR is a facility where radioactive waste is placed in a deep, stable, geological formation.
This is a misleading statement as there is no actual tests that have been completed at either of the proposed sites that can support the conclusion that the rock will remain stable once the rock has been disturbed by the construction activities of blasting in the creation of the DGR.
Also in your introduction a claim has been made that the facility is engineered to isolate and contain radioactive waste to provide the long term isolation of nuclear substances from the biosphere.
How can such a claim be made for these specific sites under consideration when no actual testing has been completed at the site to determine if this is a fact? To date this has only been a claim made by the
proponents of the DGR solution with no actual real live experience to substantiate this claim.
In fact, the proponent of the DGR in these sites has stated that until the DGR is constructed there is no real specific data to provide at this time and that that this information regarding safety of the facility will only be available once the Federal regulatory bodies (CNSC and the Impact Assessment agency) have completed their reviews.
In addition, the proponent of the DGR has stated that there will be releases of radioactive substances into the biosphere through the ventilation staffs, elevator staff, the above ground repacking facility and excavation of rock will cause releases of radioactive radon gasses. The proponent also claims that all of the radioactive releases will be within the limits specified by the regulatory bodies.
The proposed document also states that a safety case for the site preparation of the project will be available. How is this possible when there is no specific site testing been completed to determine the parameters that defines the system or sets the conditions of operating a DGR?
The potential site in South Bruce, has neighbouring farms and homes within 100 meters of the proposed creation of a DGR and the above ground repacking facility. Will the review consider the construction activities associated with creating a DGR including items such as heavy equipment operating hourly, blasting occurring frequently, noise being created by the constant backing up of vehicles, disruption to local traffic by heavy vehicles on the roads leading to the facility, dust created in the environment surrounding the site, and releases of radon gasses from the excavated rock that maybe on site.
Do not understand that without a full evaluation of the completed structure for a DGR and testing, you can determine the site is suitable for a facility's full life cycle.
Two other major component of the site selection plan have been ignored in your introduction namely the repacking facility that uses hot cells in its operation and the rock pile plans for the excavated rock pile which is assumed to be 15 meters high and cover an area of 65 acres.
The NWMO implementation of a DGR is still under design review and changing and most importantly significantly different design than any DGR in the world.
The major differences being the type of rock in South Bruce, the transport of the spent fuel from the reactor sites, the repacking facility is unlike any in the world requiring hotcells to protect the workers, the container design, the actual spent fuel itself, elevators versus ramp for transporting the spent fuel to the DGR, and the placement of the spent fuel bundles in the cavity.
The other factors of concern are environmental issues. The site in South Bruce has a major river running in the middle of the site, the site is rich with aquifers supplying the drinking water for the community of
of South Bruce, with all the noise during construction the wild life in the area will be impacted, and the quality of life for those that live in the adjacent property will be severely impacted.
No longer can we rely on history to determine how the change in our climate will effect our weather conditions. We can only expect the weather to be more intense than previous years and given the South Bruce site has a major river within the site and we have ponds being constructed there is a high probability flooding will occur and the chance for the river to become polluted from not only the ponds but the excavated rock as well
Given all the issues I see with the structure of the document, I find the intent of the site preparation document totally inadequate to determine if a site preparation should be licenced. There are way too many omissions in the introduction to make that determination.
Gracia Janes Environment Convenor
Provincial Council of Women of Ontario
PROVINCIAL COUNCIL OF WOMEN OF ONTARIO
Comments on the GCNSC draft guide for proponents in preparing the "license to prepare the site" for a proposed deep geological repository, i.e. REGDOC 1.2.3.
As it relates to the Nuclear Waste Management Organization’s selection of one of two proposed sites at South Bruce and somewhere in between Ignace and Dryden, for burial and abandonment of all of Canada's high level nuclear waste, the Provincial Council of Women of Ontario strongly supports the view of other organizations and individual experts, that there should be a very strong set of rules in place before licenses to prepare any chosen site for a proposed deep geological repository are applied for.
PCWO were intervenors at the Ontario Power authority Power Generation Project #17529 OPG/Bruce hearing from 2013 and 2014, regarding the deep burial of low and intermediate nuclear waste, where the Environmental Assessment and the site preparation were dealt with together on a rushed basis, and had many flaws.
Examples of the flaws cited by PCWO, were the:
Finally, the Provincial Council of Women (PCWO) believes that it is extremely important that the long term safety of this, the first deep geological repository in Canada, site which will have to hold an enormous amount of high level nuclear waste, be secured through a strong the environmental impact assessment process under the Impact Assessment Act, and only then should a site preparation permit be applied for.
|Northwatch||Please see attached table||Northwatch comments on REGDOC-1.2.3|
|Dr. Sandy Greer||Please see attached table||Dr. Sandy Greer comments on REGDOC-1.2.3|
|Alexandra Franche||Please see attached table||Alexandra Franche comments on REGDOC-1.2.3|
|Dr. F. R. Greening||Please see attached table||Dr. F. R. Greening comments on REGDOC-1.2.3|
|Northwatch||Please see attached table||Northwatch feedback on comments REGDOC-1.2.3|
|Concerned Citizens of Renfrew County and Area (CCRCA)||Please see attached table||CCRCA feedback on comments REGDOC-1.2.3|
|Sierra Club Canada Foundation (SCCF)||Please see attached table||SCCF feedback on comments REGDOC-1.2.3|
|We the Nuclear Free North (WTNFN)||Please see attached table||WTNFN feedback on comments REGDOC-1.2.3|
|Nuclear Waste Watch||Please see attached table||Nuclear Waste Watch feedback on comments REGDOC-1.2.3|
|Canadian Environmental Law Association (CELA)||Please see attached table||CELA feedback on comments REGDOC-1.2.3|
Sustainable Energy Group
Please allow me to voice my concerns about this process and my opposition to the creation of a Deep Geological Repository (DGR) in either designated location under consideration in Ontario. My concerns include the following:
1. As Mississaugas of Scugog Island First Nation pointed out, "The list of risks to health and safety of the public does not include potential risks to groundwater.” The protection of ground water is essential — especially so to Indigenous people — and must not be contaminated by blasting rock in creating a nuclear tomb 500 meters underground, burying highly radioactive nuclear waste for many thousands of years, and then permamently sealing it. The likelihood of groundwater becoming contaminated by a DGR over time is certain, and probably within only a few hundred years. Copper does corrode and bentonite is not a pemanent seal. Neither is rock that is susceptible to geological movement. DGRs are not a reliable or affordable solution.
2. Transporting nuclear waste from New Brunswick, Quebec and Ontario to the DGR site is another highly questionable risk. It is unthinkable to allow this to happen, as both the risk of accidents and the enormous cost involved makes this concept ludicrous.
3. Nuclear waste needs to stay where it is now, near the power plants that produced it. There it can be repackaged most safely and least expensively as required until a proper and affordable solution can be found. The same is true for the medium-level nuclear waste. Most of that waste can be stored with the nuclear reactors when they are decommissioned.
4. Small Modular Nuclear Reactors (SMNRs) are not a solution to the climate emergency that is already getting out of control. This latest nuclear technology is no more than a Hail Mary pass from a desparate dying industry trying to survive. SMNRs are uneconomical and are not needed to meet our energy requirements as they will be too late, too costly, and are likely to fail. Efficiency and renewable energy, especially wind and solar, is where funding needs to go. SMNRs are not now, and never will never will be, economically competitive with renewable energy, including hydro.
5. As well, nuclear proliferation is an additional risk created by the nuclear industry through the creation of plutonium in reactors. This is truly worrisome and must end before a military or terrorist disaster occurs. The threat of a nuclear war is now the highest it’s ever been, thanks to Russia, North Korea, Iran, and other countries, including the United States.
Finally and importantly, the climate emergency demands immediate and effective action with responsible stewardship. Nuclear has no place in mitigating the climate crisis. This needs to be accepted now, so we can tackle the climate emergency quickly and most effectively.
I have not been able to read all submissions, but I agree with comments submitted by:
by Bill Noll, Vice Chair of Protect our Waterways No Nuclear Waste (POW),
and by Dr. Sandy Greer.
I agree with the Athabasca Chipewyan First Nation submission and will make comments about a couple quotes:
“2. Recommendation: ACFN recommends that the standard to which radioactive waste will be contained and isolated from the environment takes into the account Indigenous peoples use of the environment to ensuring the safety of Indigenous people for future generations. ACFN is concerned that Indigenous uses of the land and resources (e.g., drinking water from the rivers, streams, lakes etc. and consumption of animals and plants) are not factored into the standards of how radioactive waste is contained and isolated from the environment.”
I will even go further and push for amendments to have lower tritium levels allowed in the current water regulations as well as other toxic radionuclide components. It’s astounding how the limit is permissive in Canada compared to other countries.
“9. Recommendation ACFN recommends that the benefits of engagement include the contribution Indigenous knowledge toward reducing potential risks and impacts on Indigenous communities throughout the lifecycle of DGR. Further, ACFN recommends that Indigenous engagement take place throughout the life of the project. Decommission plans should be developed with input from Indigenous communities and made available for them to review.”
Prior, full and informed consent must be given to the First Nations and surrounding canadian communities. Water has a way of moving around and spreading around the contaminants of high-level toxic waste that will be buried in the DGR. In Port Hope, a town of 16 000 that had a refinery of radium and uranium, has to be cleaned up of low level toxic nuclear waste in the surface soil and this is costing millions; that is strictly the cost for the environmental damage, as little long-term health studies have been conducted. Imagine how costly and risky that DGR project is. It isn’t a guarantee that can be made for First Nations that their land, water and air will be kept intact and their land is sacred to them; they can’t just uproot and go live somewhere else. Canada has the world’s largest freshwater reserve. Our First Nations are trying to protect it and they have a right to do so and to be given thorough details before the project is underway.
We must stop producing nuclear waste and contain the tons we have indefinitely, safely. DGRs as presented are not a viable solution.