Comments on the Draft Integrated Tailored Impact Statement Guidelines For the Deep Geological Repository (DGR)for Canada’s Used Nuclear Fuel Project

It is important the Impact Statement for the DGR be detailed with clear explanation of the connection of conclusions to scientific evidence.

The scope should include the people and environments along the transportation routes from the nuclear reactors to the proposed DGR site. Also, locations downstream and downwind from the proposed DGR site should be included.

The time frame for which effects of the project and monitoring should be considered is hundreds of thousands of years.

When the Impact Assessment Statement classifies effects as low or negligible risk, a clear explanation of the basis for this decision should be included. 

Detailed description of the processing of the nuclear materials and of the containers is needed. This includes information on the proposed Used Fuel Packaging Plant.

The inclusion of alternative options in the guidelines is very valuable. The options should include keeping the waste at nuclear reactor sites.

The impact assessment guidelines for evaluating transport of waste should include consideration of the effects of the much greater radioactivity and chemical toxicity of the nuclear waste compared to yellow cake.

As part of the evaluation of the risk of contamination of groundwater and surface water, current geological faults in the region of the proposed DGR and how the process of excavation of the underground storage area could increase the number and extent of faults needs to be considered.

Over long periods of time (hundreds of thousands of years), would the groundwater and surface water be contaminated with toxic substances from used nuclear fuel waste?

Would the used nuclear fuel storage containers in the proposed DGR breakdown, and would this lead to toxic substances spreading into groundwater and surface water?

The impact assessment should include consideration of the risk of spills of toxic materials at the surface, and the mitigation needed.

The guidelines should include consideration of whether it will be feasible to retrieve the used nuclear waste from the DGR.

The criteria for acceptable contamination following completion of the proposed project need to be made clear. Use of ALARA (As Low As Reasonably Achievable) could cause a substantial increased risk to human health and the environment from the project. Also, the details of how the health risks from the combined exposure to various toxic substances are estimated need to be included.

Thank you for the opportunity to share my concerns.