Why Bury it (nuclear waste)?

With Regard to the Impact Assessment of the Nuclear Waste Management Organisation
(NWMO) Proposed Deep Geological Repository (DGR) Near Revel Lake In Northwestern
Ontario

Why Bury it?

It is an extremely primitive Human reaction to hide things we no longer want to see, things we do
not want to deal with, and things that we are quite frankly afraid of. We have thrown things into
convenient holes, lakes, rivers and seas over our entire history. We bury things that are easy to
bury. We hide things out of view if we can quickly leave the scene ourselves and not be held
responsible. It almost seems like the “genetic response” but is it still valid? And does this
response truly apply to everything we wish to bury?

Since we mastered the use of fire, we have added burning to the arsenal of ways to make things
disappear. Of course, some things we cannot burn, such as the waste that the NWMO wishes to
make disappear.

Nuclear waste is unlike all other waste Humans have created.

The first scientists to create nuclear waste had little to no idea of how to deal with the outcome of
their experiments. They saw the confirmation of theory. They saw affirmation of their new
knowledge. They witnessed the practical manifestation of their accumulated ideas, but they did
not gain wisdom in how to control this new power or to manage the repercussions. What began
as trying to understand the world on an atomic scale, morphed into a politically-driven race to
build the most terrible way to be able to kill a lot of people quickly and to kill magnitudes more
slowly. Of course, with the fast chain reaction of a nuclear bomb, there is no consideration of the
waste. It is like any other form of destruction, that it can flatten Human dwellings and invoke
unimaginable fear in any survivors or witness who were at “safe” distances. Atomic bombs have
a major difference from conventional bombs, apart from their utter efficiency of materials, they
leave a radioactive footprint that remains hazardous to all living things for millennia.

Humans are good at breaking things. If someone has something we do not have, we break that
thing so no one has it. Having discovered the secret of atomic power we can break entire cities
and countries. We can break our continued history. This highly efficient and complex force of
destruction reflects our primitiveness, our ignorance and our arrogance. We decide that we have
enough knowledge to play with the most hazardous naturally-occurring element on the planet,
and all we can do with it is break it. When Enrico Fermi risked blowing up Chicago to test his
atomic pile, upon having a successful test he declared Man’s mastery of the atom. The scientists and US military risked burning up the Earth’s atmosphere with the first test of a nuclear bomb - apparently this was worth risking in an effort to gain revenge against the Japanese for the attack on Pearl Harbour. Fortunately, generations to come are still breathing that same atmosphere.

Breaking atoms apart in a sustained reaction is called “fission” and unfortunately this was easy to
do in retrospect. Everything about this process is bad. Everything about uranium is bad.

It comes out of the ground so it should go back into the ground.

Seems like a reasonable conclusion, but this is not just any element, such as carbon, which can be
mined in the form of coal and petroleum and can be safely sequestered back in the ground.
Burning all of these products puts carbon into the air, which promotes global warming. All of the
air-breathing life forms exhale carbon-dioxide which plants breathe in and release oxygen, for us
to breathe again. Forests sequester a vast amount of air-borne carbon in the ground around their
roots and this is re-released when loggers clear cut large areas. Unfortunately research in this
latter area has not quite reached the forefront of environmental awakening.

No. Uranium is the largest naturally-occurring element we know of. It is unstable and it is
continuously trying to achieve a stable condition through radioactive decay. This is what heats
the planet. We can thank Albert Einstein for giving us E=mc , which tells us that a lot of energy2
can be released for a very long time without depleting much matter. Like all other atoms,
uranium’s number of protons in the nucleus equals the number of electrons circling around the
nucleus. However, the number of neutrons in the nucleus do not always match the number of
protons. When these numbers match, things are stable, but with a proton / neutron mismatch, the
form of the atom is called an “isotope”. Some isotopes are good for nuclear reactors and bombs,
and others are not. They are all radioactive. The natural reduction of neutrons and eventually
protons and electrons is called “radioactive decay”, and this process takes thousands of years up
to millions of years to achieve a final stable state.

Everything about uranium is hazardous to life.

Mining uranium out of the ground is hazardous to everyone on the mine site, and there are high
rates of cancer and other disease for these workers compared to other mining operations. All of
the equipment exposed to this natural radiation becomes radioactive itself to a low level.
Transportation of the raw uranium ore is hazardous. Because uranium ore contains various
isotopes of uranium, the ore has to be separated so that the desirable reactor-grade uranium
remains. This process is called “enrichment”. Nothing is added; rather, the unwanted portions are
removed. All the equipment in the processing plant becomes radioactive. The selected uranium is
formed into pellets and packed into rods that can be inserted by machine into the reactor.

Inside the nuclear reactor, the uranium is bombarded by free neutrons and when the uranium
atoms split they release more neutrons to keep the reaction going. Each split atom releases other
energy, such as gamma rays, which are extremely high-energy high-frequency electromagnetic
waves - like light or x-rays or radio waves, all of which can be hazardous to Humans at high
enough energy levels. Gamma radiation is not to be trifled with; it is extremely hazardous to all
life even at low levels. A high amount of heat is generated, as well, which is what the goal is
after all: make heat to boil water to make steam to run a turbine that turns a generator to produce
electricity.

Fission is the most dangerous way to boil water.

When a uranium atom is split by a neutron, the atom does not break into two equal halves; rather,
it breaks randomly into unequal ejections that are all radioactive. Within the reactor, the radiation
level is thousands of times higher than for the uranium ore. We have achieved getting heat to boil
water but we also raise the “radioactive heat”of the materials involved. The entire reactor core
becomes highly radioactive and the spent fuel can only be handled by machines. A Human
coming into proximity of freshly removed waste fuel would die immediately without having to
contact the material.

We have turned an already hazardous natural element into something that is so diabolically toxic
there are not words or numbers to describe it.

The nuclear waste is both physically hot and radioactively hot, and must be stored in cooling
pools for about ten years. From there it goes into other storage containers to cool further. These
containers break down and are continuously monitored and repaired or replaced. Again,
machines must perform the transfer of the waste from one containment to the next as it is too
hazardous for Humans to be exposed to. Because of the hazard to life these materials represent,
the facilities are protected by armed guards, and must be proximal to the reactor that produced
them. Since the reactors used for generation of electricity were built, the waste has always been
kept at the reactor site for both practical and safety reasons. In Canada some of these reactors
have been operating since the 1970s, and have accumulated fifty years worth of nuclear waste.
Generations of workers and specialists have taken care of this waste, and all of the emergency
response infrastructure is in place in case of an accident.

For fifty+ years Canada has used “Rolling Stewardship” to manage its nuclear waste.

For fifty+ years Canada has followed the “Proximity Principle” in managing its nuclear waste.

Why would we change this management system?

Why would the NWMO want to abandon a proven waste management system built upon
responsible scientific experience?

Why does the NWMO believe that spending billions or trillions of dollars to implement a
questionable plan is worthwhile?

It has been said that the life span of a nuclear reactor is possibly 3 Human generations BUT the
radioactive decay period for the nuclear waste is 300,000 Human generations.

The NWMO is the nuclear industry. It is not a governmental agency. It is not at arms-length from
any of the bodies it interacts with. The CNSC is funded in part by the NWMO and essentially
rubber stamps whatever the NWMO wants to do. They are a captive regulator with all the
negatives that implies. The actual government of Canada also abides whatever the NWMO wants
to do. Why?

Multiple reasons.

The word “nuclear” is like the word “cancer” inasmuch as when a person hears it they mentally
shut down. The average person being told they have cancer may be in too much shock to take in
anything the doctor tells them immediately afterward about treatment plans, the extent of the
cancer, or anything else. Similarly, as soon as a person hears the word “nuclear” they mentally
shut down because they do not understand it now and think they never will; that anything to do
with nuclear is too complex to understand. And the industry - especially the NWMO - is very
happy to reinforce that fallacy. Governments defer to the nuclear industry since the people in that
industry must know what they are doing and what they should do in the future. Right?

Wrong.

Instead of following what has worked so far - CANDU reactors, Rolling Stewardship, Proximity
Principle, expansion of wind farms, expansion of solar farms - the industry wants to build many,
many more reactors of a design already proven to be unworkable by the US Navy’s disastrous
experiments in California in the 1960s/70s, they want to move all the accumulated nuclear waste
1,000s of kilometres over public roads, process the waste and abandon it in newly constructed
mines. They want to have small nuclear reactors that can be abandoned in place when their fuel is
expended. They want to take in nuclear waste from other countries.

CANDU is the safest reactor type in the world for generating electricity. Its reliability is the envy
of every country using nuclear to support their electric grids. The proposed small-modular-
reactors all use salt-based moderators. Salt and metal do not go together well, and the US navy
tested this as thoroughly as an unlimited budget allows and were not successful. They went back
to conventional designs. OPG is planning to use an unproven design in the refurbishment of part
of the Darlington nuclear plant. Why? Because ‘new = better’. Or not.

Rolling Stewardship is a recognition of the 24/7 oversight that nuclear waste requires and the
execution of that responsibility. Safety infrastructures are already in place.

The Proximity Principle is not merely keeping the waste where it was generated, but assuring that
the established safety methods and networks continue to keep everyone safe.

As long as the Earth is rotating there is wind. In Alberta, several wind farm projects were delayed
and denied to protect the oil industry. These projects could have supplied ALL of Alberta’s
energy needs at low cost and low environmental impact. Wind turbines that can connect
synchronously with the grid the same way large nuclear, coal, and hydro generators connect , are
being developed. Alberta should be building refineries to make value-added products such as
lubricants and plastics, instead of remaining as a Second-World raw materials supplier.

Why does Canada NOT build wind turbines here? Why are we buying them from Europe
instead? More Second-World thinking.

The NWMO calls the reactor-site containers “interim”, where the containers for abandonment in
the mines are “permanent”. Of course, the shipping containers are also interim, i.e. temporary.
These have only been tested in a computer simulation and as small-scale models. Even though
the NWMO chief Transportation Engineer says “Full scale testing is the Gold Standard”, he also
says “The NWMO will NOT be doing full-scale testing of these containers”. He didn’t just say it,
he screamed it.

Once the shipping casks arrive at the abandonment site, there is further processing. The shipping
container has to be opened and the nuclear waste is removed and put into the burial casks. This
means that a processing centre must be built at the abandonment site and all of this handling
greatly increases the risk of contaminating the environment and causing illness for the site
workers and downstream communities. Where the fuel rods went into the reactor all shiny and
solid, what comes out is brittle and breaks into shards and fine dust particles very easily. And
remember that even this nuclear waste that has been cooled for fifty years is still highly
radioactive, far more radioactive than the uranium ore and far more radioactive than when the
uranium pellets packed in rods first went into the nuclear reactor.

The reactor itself becomes nuclear waste. You cannot just turn a nuclear reactor ‘on’ and ‘off’;
rather, power has to be ramped up and similarly ramped down. Power must be supplied to the
facility so that circulating pumps can cool everything down, and this takes months of reliable
electricity flowing from other sources. The reactor components must be handled as carefully as
the nuclear waste and be disposed of in a thoughtful manner.

The fact is EVERYTHING Man-made is temporary and will break. And does break.

Justin Trudeau made a comment about “repatriating nuclear waste” meaning that since Canada
supplied the uranium to other countries that Canada should take responsibility for the disposal of
that waste. No. This naive statement assumes that moving nuclear waste and abandoning it is the
correct solution. The hazards increase exponentially with international shipping and the
nightmares of oceanic contamination are unimaginable. Unfortunately, there is precedent for
deliberate disposal of nuclear waste at sea by the USA and several European nations. Does this
make accidental disposal at sea acceptable?

And what about transportation of all of that nuclear waste?

Why is transportation not considered in the NWMO’s initial Project Description?

The Ontario Ministry of Transportation has statistics regarding traffic accidents all over the
province. A major nuclear facility is right in the Greater Toronto Area, in Pickering. Nuclear
waste from this location will have to move through very densely populated areas and with the
GTA expanding daily there is no real escape of this fact if one is intent on making the
ill-advised move.

In the GTA the percentage of all traffic accidents involving transport trucks is almost 25%

The Bruce generating station is along the shore of Lake Huron near Goderich. Nuclear waste
would have to move by truck either to a rail head south of Goderich, or across the rolling
farmland eastward to Barrie and the 400 highway. An accident here with release of
contamination would devastate certain farming and food supply chains.

The natural route for all of the Southern Ontario nuclear waste is along the main highways, going
through the Sudbury area, through Sault Ste Marie, and over the north shore of Lake Superior
along Highway 17 through Nipigon and Thunder Bay, then on to the Ignace-Dryden area. On this
stretch of the Trans Canada Highway, Nipigon to Dryden, transport trucks are involved in over
60% of all accidents.

Repeat: 60% of accidents involve transport trucks west of Nipigon.

Nuclear waste from New Brunswick has to pass through Quebec and into Ontario. Can it bypass Montreal? Is there a safe route for NB's nuclear waste? It is safest where it is.

NWMO estimates that 30,000 to 50,000 trucks would be required to move the EXISTING
quantity of nuclear waste from all of the reactors across Canada, including those from New
Brunswick and Quebec.

Nuclear waste transport by rail is safer but the limited number of routes go through large and
small communities, and along the Lake Superior shore line where a derailment would be
disastrous.

So why has transportation been left out of the Impact Assessment of the project when
TRANSPORTATION IS KEY TO THE PROJECT? Is it too much wishful thinking that NWMO may not be intending to move the nuclear waste afterall? That NWMO is going to contiue following the Proximity Principle and Rolling Stewardship? Not likely.

The other detail that is key to the project is the abandonment in a deep hole... or even a shallow
hole.

Everyone assumes that rock is solid. That is not entirely true. All rock has microscopic fissures
throughout and these allow minute amounts of water to move through the rock. They even allow
bacteria to be found hundreds of metres below the surface. Every mine has to deal with
underground water, fissures large and small that can cause rock wall failures and subsidence, and
just the basic dangers of Humans and machines being places we were probably not meant to be.

The NWMO recognises the presence of groundwater at the proposed abandonment site, and even
relies on that water to leak into the site to activate the bentonite clay used as part of the
“isolation” of the nuclear waste burial casks. Yet, NWMO representatives perpetually contradict
the scientific papers of their own corporation, stating that no ground water will penetrate the
mine, similar to the Finnish DGR reps claiming “there is no communication between the water
in the mine with any ground water” - and the Finland DGR is not as deep as the NWMO
proposes. (Finland has not yet allowed burial of its nuclear waste in its DGR)

Another little detail that NWMO scientists recognise is the tectonic instability of the precise area
proposed for their hole: it is an earthquake cluster region. Great. Who knew there could be
earthquakes in the middle of the Precambrian Shield? Actually, Indigenous people knew, but
who would consult with them? In the 1970s seismic detectors were placed around the region and
more were added to capture more accurate readings. So, the rest of us - at least the Canadian
geologists - now knew about the earthquake cluster at Revell Lake and have seen the Shield
dance. The earth cannot quake unless there are major fissures or fault lines. These are distinct
points of entry and exit for ground water, and channels for underground water to flow through.
There is almost a guarantee that any contamination that escapes the burial casks will affect
watersheds for hundred of kilometres.

In the attempts to drill through the crust of the Earth, water was encountered much deeper than
anyone expected. The USSR had the deepest drill hole and found a river nearly 20km down. This
is not unusual considering that all the water on Earth came to us by way of celestial transport, i.e.
comets crashing into our home world. There are many forces within the crust and from the upper
mantle that force this water upward through sea vents, volcanoes and rock fissures. The NWMO
reps like to say that water cannot defy gravity. It does not have to. It has help from friendly
forces.

It is dumbfounding when a group of nominally intelligent people get together and make horrific
decisions. A large number of scientists from around the world agreed at a United Nations
conference that the use of DGRs was the best way to deal with nuclear waste: Dig a hole and
abandon it. Walk away. Run. Does this simply reflect what happens when a group of Humans
gets together? Mob mentality. The group sinks to the lowest common denominator of
intelligence and makes important decisions no child would make. This group is fully invested in
nuclear and cannot see that fission is a lose-lose approach. We have been lucky so far; just a few
melt-downs; just a few million cancer cases; background radiation is double what it was before
the Nuclear Age. Let’s call it quits on nuclear just for now. Fusion is coming and it is safe. If the
reaction goes awry it stops. Fusion is what supports the Star Trek fantasy future everyone who is
pro-nuke thinks we are in now, but they are wrong. Fusion is completely clean and safe - just
like solar, wind, hydro - but fission is dangerous at every step.

Some people still think nuclear power as we have it now is “green”. It’s not.

From mining the uranium ore, to the effluence from the reactor facilities, to the deadly
radioactivity of its waste to its radioactive contamination of everything around it - it is an
environmental nightmare. Take, for example, those 30,000 to 50,000 trucks moving just the
current waste. Let’s call it 40,000 to split the difference. Assuming these are standard
18-wheelers, that is 720,000 tyres. Modern rubber tyres are infused with zinc-oxide to help
preserve the rubber; however, normal road-wear causes rubber “dust” to break off the tyre
surface and this dust contains that zinc-oxide. Zinc-oxide is toxic to Humans, and probably to
every living thing that breathes air. California is moving to restrict the use of zinc-oxide in tyre
production to improve Human health. It is because of this airborne zinc that many people are
actually over-zinced instead of deficient in zinc.

The entire process of the DGR site location has been corrupt and insincere. Ontario Power
Generation would have been smarter to simply go about their business quietly, buy some land,
dig their hole and abandon their nuclear waste. But no. For whatever reason they created the
NWMO with its fancy “Nuclear” title (but unfortunate “Waste” inclusion), and then proceeded in
a cookie-cutter con-man motif. The surveys conducted regarding “Canada’s Plan” vetted the
participants to make sure no one surveyed knew anything about nuclear power. Ignorance is a
good foundation for a plan, right?

Once citizens heard about the siting plans, various groups formed to bring awareness to the
masses and to try to block the projet. Environment North from Thunder Bay got involved.
Northwatch in North Bay swung into action. Two groups in Dryden and another in Thunder Bay.
Then We The Nuclear Free North became an umbrella for all of these groups. It took a lot of
rallies, door-to-door education, writing to councillors in communities along the transport route
and contacting Indigenous groups who would be effected. All of this as a grass roots movement
against the war chest of the nuclear industry. The People attended any NWMO event they got
wind of - hard to do since the NWMO never gave warning of where their information bus might
show up. The NWMO refused to participate in any free debate, always restricting time for
dissenters and what they could talk about. This does not look like a confident group, the NWMO.

Then the NWMO picked a community that was poor, that had pretty much no reason to exist
anymore with its primary industry gone, (that had full vacancy of its council until criminals took
the chairs,) and who were willing to “put up their hand” to wave in all the promised loot. At
every step, NWMO manipulated which voices would be amplified, what questions could be
asked, and how the future would unfold. The result was that three Councillors voted and only
those three were allowed to vote. But why was Ignace even allowed to have a say? or to put up its
hand? It is two townships over from the DGR site. It is not in the watershed. It really had nothing
to offer other than being an easy push-over.

Contrasting Ignace is South Bruce, near the Bruce generating station. Here is a community that
was already pro-nuclear. The community organised a referendum and there were groups on both
sides of the decision arguing their case with intelligence and enthusiasm. The local Indigenous
groups were fully engaged, as well.

Indigenous groups near Ignace were selectively invited by NWMO to have presentations. and to
participate in the site selection process. Groups left out were rightly miffed, as they are in the
watershed of the nuclear waste abandonment site. The selected group voted to “continue with the
process”, which was not quite the same as saying “Yes” to the project. Really, they just wanted
more money before they said ‘no’. NWMO immediately spun this into indigenous approval of
the site selection.

Ultimately, the NWMO will do what they want. The omission of transport from the Impact
Assessment may be a ploy to let the objectors have a ‘win’ while something nastier slides
through? This is what people will surmise when an industry treats communities with disrespect
and lies at every turn. The sad part is that our elected officials seem complacent and complicate.
Despite Eagle Lake First Nation launching a judicial review of NWMO’s siting process, NWMO
proceeds anyway.

I think it would be wiser for the nuclear industry to save rate payers' millions of dollars by abandoning the nuclear waste abandonment plan. Apply those funds to building more wind and solar power. Ontario has a lot of open space for wind farms, whcih do not have to built within or even close to populated areas. Indeed, all of Canada has a lot of available space for Canadian-manufactured wind turbines. The cost of wind and solar power keeps plummeting while nuclear is stratospheric and unknown. It is time to make a paradigm shift and act as thoughtfully as we claim we are.

Thank you
K O’Connor