Requirements for High Level Nuclear Waste Management Planning

Thank you for this opportunity to comment on the Initial Project Description. I have opposed the development of nuclear power, which generates nuclear waste, for many years. I always maintained that without any plan for managing high level waste including waste fuel rods, Canada should not generate more waste. Finally, after both federal and provincial governments have announced their intentions to greatly expand nuclear power in Canada, the issue of high level nuclear waste management is being addressed. In other words, governments are committing Canadians to the generation of 150,000 tonnes of waste with no plan for disposal. The minimal 30-day window for comments is disappointing, however: surely such an important project deserves more cconsideration. It implies the government does not want public input. I believe my concerns, although stated briefly here, are critical and I hope you will act on them.

- First, transportation must be included in any assessment of a management plan. Transportation is integral to the issue of a DGR in Northern Ontario. With nuclear power sites primarily in Southern Ontario, transportation is a sine qua non for the project. I understand the NWMO wants to exclude transportation from the assessment and that should not be allowed. We're not discussing low level waste, this is transportation and disposal of 150,000 tonnes of highly radioactive and highly dangerous used fuel.

- There should be an integrated assessment under both the Nuclear Safety and Control Act and the Impact Assessment Act that encompasses all aspects of the proposed DGR in Northern Ontario. There should be an integrated review panel conducting a full impact assessment with robust public input.

- Packaging for transportation, routes, safety and security , especially in the event of malevolent actors -- all these need to be fully examined.

- Water management is critical. Governments have not done a good job of safe water management, especially in Northern Ontario. Fifty years after mercury pollution was identified in the English-Wabigoon River system, the people of Grassy Narrows are still suffering from Minimata disease, and the mercury still hasn't been cleaned up. Some people believe it can't be cleaned up, that the mercury will be there for hundreds of years. Eight years of study by the Ontario government hasn't resulted in a single plan to reduce the mercury pollution. What safeguards will be put in place to prevent radioactive contamination of the water, around the DGR, the transportation routes and the packaging facilities? Keeping radioactivity out of the environment for 100,000 years is an enormous challenge, on a timescale that is far beyond human control.

For all these reasons, I believe we should not proceed to generate any more spent fuel rods. It is impossible to guarantee that high level radioactivity will not contaminate people and the environment, and the contamination will last for 100,000 years.

However, we do need an integrated, full assessment to figure out what to do with the spent fuel rods that are currently sitting in temporary storage at the power plant sites. That has been important since Gentilly, Lepreau and Pickering were built decades ago.

I hope you will take my comments and those of others opposed to the DGR project seriously.

Janice McQuay