Comments on the Draft Guidelines for the Preparation of
Environmental Impact Statement for the Deep Geologic Repository of Low-
by Walter L. Robbins
June 12, 2008
Submitted to: Deep Geologic Repository Project, Canadian Environmental Assessment
Agency, 160 Elgin Street, Place Bell Canada, Ottawa, Ontario K1A-
Although this EIS Guideline is quite comprehensive, there are some critical issues that need more emphasis, greater clarity, and more specificity in order to attempt to elicit unambiguous responses from the proponent.
They are as follows:
(1) The need for a detailed rationale as to why the deep underground repository option was chosen.
The only explanation in the proponent’s original proposal was that "The deep geologic repository is being pursued as the preferred technology because of its greater margin of safety."
. The proponent must explain exactly why an underground facility of this kind would provide a greater margin of safety than the alternatives identified in its proposal. Some other countries such as the Czech Republic and Australia favour near surface engineered facilities for containment and monitoring of low and intermediate level radioactive wastes.
.The proponent must be able to explain why the more remote and difficult to monitor waste in a deep repository is in a more safe situation than the near or on surface facilities, including any studies or empirical evidence to support its contention. This is of heightened importance due to the very likely presence of underground water sources in deep repositories.
(2) Why this particular site was chosen; a site so near to one of the Great Lakes (Lake Huron).
.The proponent should be required to demonstrate why such a facility is to be sited on the shores of one of the major fresh water bodies in North America, which not only could impact Canadians but United States residents as well.
.The proponent must give a detailed explanation as to why it did not seek an alternative inland underground site which would be clearly outside of the geological zone that could affect the Great Lakes, in order to completely avoid the possibility of radioactive contamination of the lakes.
.The proponent must demonstrate why there should not be zero tolerance for the permanent geological emplacement of any radioactive wastes in the Great Lakes basin.
In its original proposal to nearby community residents, the proponent stated up front that: "It is important to note that no high level waste or used fuel would be allowed in the proposed facility. In fact, the facility is not designed to accommodate high level waste." The EIS Guideline must deal more directly with the question of the possible future expansion of the proposed facility to accommodate spent fuel.
The proponent must be required to deal specifically with the relationship of this proposed deep underground facility (DGR) and a number of significant issues surrounding the underground burial concept as follows:
. Explanation by the proponent of the recently announced management role of the Nuclear Waste Management Organization (NWMO) in this project, given that the specific statutory authority accorded to that organization is clearly restricted to nuclear fuel waste.
The types of waste involved in the Bruce project supposedly do not include nuclear fuel wastes. The presence of the NWMO, which is confined by law to nuclear fuel wastes, contradicts that assertion and raises suspicions of a hidden agenda.
. Explanation by the proponent of the relationship of the conclusions by the NWMO in its final report concerning an expansion of the geological formations deemed suitable for the burial of nuclear fuel wastes and the possible long term expansion of the Bruce project to accommodate such fuel waste.
The NWMO geological formation expansion included the kind of geology found at the
Bruce facility. In this regard, the proponent should provide detailed information
as to why this NWMO expansion conclusion in its final report coincides so closely
in time with the proposal to move ahead with the Bruce facility. The proponent should
describe the nature of the on-
. Explanation by the proponent as to the relative dearth of scientific and technical information and published studies concerning the nature and characteristics of the rock formations at the proposed DGR site.
In media reports, the proponent has stated that "There is a consensus in our research that shows the natural barriers will help protect the repository," and that "The limestone bedrock formations that are there have an extremely low rate of permeability. Also, there is a cap of shale 200 meters (about 656 feet) above the repository area that would act as a protective layer."
It should be noted that, in the 1980's, Atomic Energy of Canada (AECL) studied granite plutonic rock in the Canadian Shield for an extended period of time prior to its decision to develop its underground research laboratory (URL) in Manitoba, and later produced extensive volumes of technical data as part of its "concept assessment" concerning the likely density and suitability of such formations to contain spent nuclear fuel waste.
It should also be noted that AECL publicly characterized the supposed integrity of the rock formations in much the same manner as the proponent of the DGR project. However, the plutons did not live up to the "solid rock" expectations and pronouncements, especially with the later discovery of major water bearing fracture zones, requiring continuous pumping of water from the URL excavation. The proponent must explain how it would deal with any intrusions of water from limestone rock.
As for the integrity of limestone rock, for those of us living in the "limestone city" of Kingston, Ontario, it is common knowledge that this rock is "wet rock."
A statement on a University of Florida website regarding aquifers and ground water describes consolidated formations as "...those composed of solid rock with ground water found in the cracks. The amount of ground water in a consolidated formation depends on how many cracks there are and the size of the cracks. For example, consolidated limestone formations often contain caverns with much water in them." It is fair to say that water and radioactive waste do not mix.
. Explanation by the proponent of exactly what would be required to modify the DGR repository configuration to accommodate nuclear fuel wastes, and what measures can be taken to preclude such an outcome.
Diagrams of the proposed configuration exhibit a decided resemblance to the diagrams provided by AECL for its original multi staged demonstration vault and ultimate repository for nuclear fuel wastes.
. Explanation by the proponent as to how it would provide mechanisms to undergird its public assurances that nuclear fuel waste would not be allowed in the proposed facility or an expansion and modification thereof.
Simple verbal assurances from contemporary individuals and organizations are meaningless in view of the lengthy isolation time frames required for some of the intermediate radioactive materials.
It should be noted that during the 1980's, while the same kinds of assurances were
provided by AECL to the public in Manitoba concerning the non-
(4) Security and Safety
The Guideline is weak on the issue of security. Although the proponent states that low and intermediate level waste has been transported without incident in the past, this is no guarantee against possible future problems of theft, accidents, and terrorism.
.The proponent must be required to provide as much detail as possible, consistent with national security requirements, concerning measures, past and future, designed to minimize and effectively deal with risks and negative consequences which could result from transportation and handling accidents.
.Similarly, the proponent must provide information concerning its capability to prevent theft and terrorist attacks on shipments and handling of radioactive materials prior to and subsequent to emplacement into a proposed deep underground repository.
There are many unpleasant scenarios as to how low and intermediate level wastes can be used by terrorists to create panic situations, health impacts and negative economic effects, etc. upon populations. Such threat possibilities should not be taken lightly. This EIS guideline must deal with these security and safety issues.
(5) Comment on Draft Joint Panel Review Agreement
It is a serious, if not fatal, mistake to involve the Canadian Nuclear Safety Commission in the selection and the conduct of the Panel for this environmental assessment. So serious, that it places public credibility of the assessment in peril.
The Canadian Environmental Assessment Agency (CEAA) should be the sole agency involved in all matters relating to the Panel for this assessment.
Otherwise, a strong perception of bias is inevitable! The statement in the draft document that "The members of the Joint Review Panel are to be unbiased and free of any conflict of interest in relation to the Project ..." will be rendered totally meaningless.
Truly unbiased Panel members must be highly credible individuals drawn from the ranks of the public who have absolutely no prior association or special interest in this project or any other project dealing with nuclear issues such as radioactive wastes. It is neither necessary nor desirable that the Panel members "...have knowledge or experience relevant to the anticipated environmental effects of the Project." The only way such relevant knowledge could be obtained would be from either proponents or critics of these types of projects. Persons chosen from either category cannot be expected to be unbiased.
There are many outstanding persons in Canadian society who have the credentials for the role of Panel member; persons who have other similar kinds of experience, knowledge and ability as well as good judgement and can study the issues involved, listen to the interveners, weigh the pros and cons and reach judicious and wise decisions. Those are the kinds of people to find for this Panel.
Thank you for the opportunity to comment on this draft guideline and Panel review agreement.
(3) High Level Waste Issue
Similar comprehensive information on the part of the proponent of the Bruce project is not evident.
Walter Robbins
Walter Robbins hosts his website http://www.nukeshaft.ca
He was a former employee of the U.S. Atomic Energy Commission during the later 1950's in the Organization and Management Division, headquarters, Germantown, Maryland.
During the 1980's, he was a volunteer spokesperson for the citizen group, Concerned Citizens of Manitoba.
He is the author of Getting The Shaft, The Radioactive Waste Controversy In Manitoba, Queenston House Publishing Company, Ltd., Winnipeg, Manitoba, 1984.
Volume One -
1980-
Originally published in paperback as "Getting
The Shaft, The Radioactive Waste Controversy in Manitoba."
Volume Two -
update: 1984-
The growing prospect of nuclear waste dumps on both sides of the U.S.-
Volume Three -
update:1988-
Federal Environmental Panel concludes that Atomic Energy of Canada Ltd.'s permanent underground nuclear waste burial concept lacks public acceptability.
Volume Four -
update:1998-
Mixed Oxide plutonium transport and the Nuclear Waste Management Organization and
nuclear waste issue grinds on
Nuclear Waste Saga
A free web site dedicated to the well being of future generations
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