Water Management Discussion in the IPD is Insufficient ( and Air)

Water Management Discussion in the IPD is Insufficient ( and Air)

Water “management” omits key issues which must be addressed. The IPD virtually ignores the possibility of radioactive releases to surface and groundwater from surface activities (Used Fuel Packaging Plant (UFPP)) and the danger to human health and the environment that could result. It also ignores the possibility of radioactive releases contaminating groundwater within the underground repository and the possible migration of this contaminated water to the surface.

Releases of radionuclides to the air from activities at the UFPP are also ignored or minimized and require further discussion of potential accumulated effects. The potential effects section is totally inadequate and must include an analysis of potential accumulated impacts to downstream and downwind communities and values. But first, it must acknowledge the potential for these types of releases to occur, which it fails to do.

Used Fuel Packaging Plant - The Big One

The IPD omits discussion of contaminated waters from the used fuel packaging plant (volumes, contamination, storage, treatment, release) and the potential for impacts to human health and the environment. No detailed descriptions or map of the surface activities is provided and there is no discussion of surface water movement (where it will go and what communities might be affected. Hydrology can predict where surface water will go, but the proponent has not admitted that significant radioactive releases to surface water will occur and therefore have not acknowledged communities and values which might be impacted.

In an earlier comment (Initial Project Description ( IPD) Lacks Detail) I stated that:

“the UFPP is among my greatest concerns for harmful radioactive releases that would negatively impact human health and the natural environment. And yet, at this late stage there is a complete lack of detail on how this would work, what risks and uncertainties could reasonably be anticipated and how the proponent plans to counter them.

What we know is that the used fuel bundles will arrive in transport containers from the reactor sites. They will need to be inspected and repackaged from transport containers into containers for burial. This is not an activity to be taken lightly, yet we are left to assume that they have it figured out and there is little or nothing to worry about. I am worried about radioactive releases to air and water, worker health and safety, legacy waste and the possibility of permanent surface storage of materials at the site if DGR plans do not progress as intended. And that is based on what we know about the UFPP which is very little.

The NWMO has stated that there will be releases due to this activity into the air and surface water but they have provided no detail on how much, what level or what steps will be taken to counter this hazard.”

The Impact Statement must acknowledge this oversight and provide a real “project description”; not an outline of what they hope to do if approvals are granted. Only then will the public be afforded an opportunity to understand what is at risk and enter into a discussion of potential impacts.

Unlike the next section on contaminated groundwater migrating to the surface, the potential impacts from radioactive releases into surface water from surface activities at the UFPP will be immediate and significant, in my view. They must be considered in great detail in the Impact Statement if this process is to have any credibility.

Underground Repository

The IPD also omits discussion of contaminated waters being pumped from the underground repository to the surface (volumes, contamination, storage, treatment, release). Mining operations typically pump water that occurs in underground workings, to the surface to enable work to continue. Yet the IPD does not acknowledge that radionuclides from this man-made ultra-toxic environment underground could be pumped to the surface with the groundwater. The Impact Statement must include a discussion of the mining processes to be used and the potential for fracturing, followed by the possibility for contaminated water being pumped to the surface and what, if any potential impacts could result.

While on a much longer timeline than releases directly to surface water, the natural migration of contaminated groundwater from the underground repository over time is a real possibility. Yet there is no discussion or recognition of this potential source of contamination entering the surface runoff at some point. Predicting the movement of groundwater, while not as precise as that of surface water, is still a potential concern here given the toxicity and instability of the used nuclear fuel waste and the time frame during which it will remain toxic to human health and the environment.

Rather than ignore the possibility that this potential impact exists, the Impact Statement must include it and deal with it if this process is to have any credibility.

Radioactive Releases - Where Will It Go?

The potential effects section in the IPD is inadequate. Radioactivity and estimates of radioactive releases from various project activities over various time frames and assessing those effects are largely ignored. I firmly believe, as above, that there will be radioactive releases to the surface water and airshed. Downstream communities have been largely excluded from consideration in the site selection process, and now in the IPD in terms of potential impacts due to the location and operation of the proposed DGR.

This proposed project would place a great quantity of the most toxic substance in existence in the upstream watershed of the Wabigoon River/ Turtle River Tertiary Watersheds, both of which feed into the Winnipeg River and subsequently, the Nelson River Primary watershed.

The legacy of mercury poisoning in the Wabigoon River downstream from the Reed Paper Mill in Dryden in the 1960s is well known. The destruction of a way of life and the physical health of Grassy Narrows and Wabaseemoong community members is perhaps less less understood. But the lack of mitigation, rehabilitation and reconciliation of this industrial cataclysm is a lesson we must not forget. Once a toxic substance is introduced into an environment, mitigation of the impacts of that pollution is not possible. After more than 50 years, those communities are still trying to get recognition for the damage to which hey have been submitted. How is it possible that the federal and provincial governments and the nuclear industry can suggest that burying the worst possible form of waste in the headwaters of the same Wabigoon River is a good idea?

The Impact Statement must include a section on community profiles and the different impacts that could result from contaminated water or air from the DGR operation over the projected 160 years of operation and beyond. Downstream communities should have had a say in whether this site is acceptable. They didn’t. But at the very least, the Impact Statement must recognize the potential impacts to neighbouring and downstream communities that could follow if the project is approved.