Undocumented Wastes

One of the biggest problems with the DGR proposal as it stands is that it just doesn’t make a lot of sense. The Bruce facility has quite a bit of low-level waste – common office furniture and appliances that have some slight acquaintance with the nuclear environment. But these wastes are currently handled quite well in their temporary arrangement, as they are quite legitimately temporary waste. These wastes are incinerated and stored aboveground, where their short storage requirement means that they are not straining the Bruce Nuclear Generating Station’s (BNGS) capacity for handling them. There is no need to store these wastes underground. If that truly is the purpose of the DGR, then it is simply a tremendous boondoggle and it should be rejected out of hand as a colossal waste of money.

This leaves the intermediate-level wastes (ILW), of which the BNGS has only a scant amount. If storing these wastes alone is truly the purpose of the DGR, then it has a tremendous overcapacity and is again a colossal waste of money. We would not want to rule out the possibility that the DGR is simply intended as a make-work project that will keep the able-bodied people of the area busy for many years digging this tremendous hold in the ground; but we would like to think that their lives and energies could be put to more productive purposes.

But few observers think that the DGR is simply a boondoggle. Hence, the concerns that OPG intends to use this facility (a) either to house nuclear waste from other facilities, which will be transported to the DGR from all over Canada, or (b) that it plans to house high-level waste (HLW) here also. Or (c) both of the above. Concerns are exacerbated by the fact that, while building the facility in the first place must go through extensive public review, a change in the site license to allow it to accept high-level waste or waste from elsewhere is an administrative task that can be accomplished at the will of the regulatory agency. Adding nuclear fuel to the fire is the fact that there is some material known everywhere else in the world as high-level waste that the Canadian Nuclear Safety Commission (CNSC) has already (re)classified as intermediate-level waste, thus making it officially suitable for the DGR.[link to a discussion of waste (re)classification]

Thus, the concerns of the United Church of Canada:

The OPG proposal, if approved, would set a precedent for subsequent low and intermediate level waste disposal within Canada and potentially pave the way for a high-level waste site being pursued by the NWMO in Lake Huron communities. With due respect to OPG’s assurances that high-level waste is not being included in its proposal, precedents exist such as in Sellafield, where some parties fully expected that a low- and intermediate- level waste site would eventually be expanded to include high-level wastes. Interpretations of intent and of what was promised go back and forth with each change in government. It is sensible to be aware that NWMO [Nuclear Waste Management Organization] reflects the overall interests of the nuclear industry, which holds the strongest influence on decisions about the approaches the NWMO will take…

Likewise, the Saugeen Ojibway Nation (SON) has provided documentation of the DGR regulators and proponents ignoring and whitewashing this issue:

OPG [Ontario Power Generation] has taken the position that under the terms of the EIS [Environmental Impact Statement] Guidelines, matters relating to the transportation of nuclear wastes need not be considered as part of this review. SON strongly disagrees.

SON has consistently taken the position that the continued and increased transportation of nuclear wastes through its Territory is a critical factor in assessing the safety and acceptability of the DGR Project, and specifically, in assessing potential impacts of the Project on SON Rights and interests. Any assessment of the Project that fails to consider these matters is fundamentally incomplete.

SON has raised concerns about transportation issues for many years in its engagement with OPG and through submissions to CNSC regulatory proceedings. OPG has documented SON concerns about the transportation of wastes into its Territory in the EIS. OPG ought to have included consideration of these matters as a requirement of CEAA and the guidelines, as well as based on proper expectations of an enhanced and precautionary development approach as explained in section 4 below.

Under the Guidelines, OPG was required to address any concerns raised by Aboriginal people about the project or other past or present means of storing or disposing of nuclear waste, and regarding the cumulative effects of the project in combination with any other over these areas.

It was incumbent on OPG to not only identify SON concerns with regard to transportation issues, but to address those concern. OPG has failed to do so. It was not acceptable for OPG to have ignored SON concerns and all questions relating to transportation on the basis of its existing transportation licenses. Such an approach shields from public and regulatory scrutiny OPG’s statement that “volumes, means and routes” for transportation will not change. It does not address potential changes resulting from the DGR Project respecting: the guaranteed continuation of waste transportation to the site and through SON territory, increased possibility of terrorist attack due to the heightened profile and public awareness of the Project, effects of increased uses of existing transportation due to population growth over the very long term, and importantly, the cumulative effects of transportation of wastes to the DGR Project with other future nuclear waste management projects in the area.

Additionally, SON has submitted, and continues to take the position that a project for the long-term management of spent nuclear fuel (the “HLW DGR Project”) ought properly to have been included in the cumulative effects analysis of the DGR Project. A proper cumulative effects assessment in this case would need to seriously and transparently consider the cumulative effects of the continued and increased transportation of low and intermediate level nuclear wastes in combination with the transportation of spent nuclear fuel [which is considered high-level waste] over the same roads and through the same areas. These are novel and critical concerns, and are materially different from the transportation issues relating to the WWMF [Western Waste Management Facility, the temporary facility currently housing the waste] facility alone.

Without full information and analysis relating to the increased and continuing transportation issues from the DGR Project alone, and those resulting from the DGR Project in combination with a future HLW DGR Project, the totality of potential adverse impacts of from the Project cannot be known.

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