Resolution Regarding the Deep Geologic Repository

The Deep Geologic Repository (DGR) project being proposed by Ontario Power Generation (OPG) is currently being reviewed by a joint review panel. WHEN’s Volunteer Education Coordinator, Dorothy Goldin Rosenberg, delivered the following submission to the panel on WHEN’s behalf. Oral and telephone presentations will follow in mid-September 2013. Write your MPP and demand more consultations downstream from the project site.

Write the federal government and demand the Canadian Nuclear Safety Commission heed the concerns raised below.

Deputation on OPG’s Deep Geologic Repository Project for Low and Immediate level Nuclear Waste by the Women’s Healthy Environments Network (WHEN)

On the proposal by Ontario Power Generation to prepare a site, and to construct and operate a facility for the long-term management of low and intermediate level radioactive waste at the Bruce Nuclear site, near the shores of Lake Huron within the Municipality of Kincardine, Ontario.

Over the past years, we have participated in various Nuclear Waste Management Organization (NWMO) consultations and proposals related to high level wastes (which will cost billions of dollars). Our concerns with the storage of those wastes apply with this current proposal for low and intermediate waste levels as well.

Where is the proof of safety to reassure public concerns? The Precautionary Principle states the requirement of “Reverse Onus” meaning “Proof of Safety Beforehand”. Can anyone provide that proof? There is no guaranteed known way to do so given the complications of technology and the longevity of the waste.

Ontario Power Generation (OPG) is proposing to build a Deep Underground Geological Repository for low and intermediate level radioactive waste at its Bruce nuclear site in the municipality of Kincardine one kilometer from the shore of Lake Huron. This proposal is unprecedented in Canada, and should be treated with special concern for many reasons - notably that it will pave the way for more such sites in Ontario.

The Canadian Nuclear Safety Commission (CNSC) and the federal government need to acknowledge that the current environmental assessment process is taking place in a policy vacuum. The federal government has not established a framework for managing long-lived, non-fuel radioactive wastes in Canada, despite a legal obligation to do so under the 1996 Radioactive Waste Policy Framework.

Until now, radioactive waste has only been kept in temporary storage facilities. This current proposal would set an historic precedent for permanent deep underground disposal of radioactive waste in Canada. Because the radioactive wastes will remain toxic for hundreds of thousands of years, this proposed project is a threat not only to the locality and the region, but also to downstream communities on the Great Lakes in Canada and the United States of America. Therefore serious consultations should include communities on the Lake Huron shoreline to the south of the Bruce facility, as well as on the Michigan shoreline of Lake Huron, as well as communities on both the American and Canadian sides of the St. Clair River, and Lake St.Clair

I am not paid to write or present this deputation, but do so once again, as a volunteer because of my deep concerns for the present and future of all life on earth, today in particular relating to the planned OPG’s Deep Geologic Repository Project for Low and Immediate level Nuclear Waste in the Bruce Peninsula in Ontario.

My name is Dorothy Goldin Rosenberg MES, PhD and I teach about environmental and ecosystem health to graduate students at the Ontario Institute for Studies in Education of the University of Toronto. I am also the Volunteer Education Coordinator of the Women’s Healthy Environments Network (WHEN). WHEN promotes a clean safe environment and the use of the precautionary principle with regard to contaminants causing harm to our health and the ecosystem on which we depend. It is the reason that we do this work. WHEN believes that individuals can make a difference when they `Take Action for Prevention' in their homes and communities, but that there is also an important role for governments and communities in protecting human health and the environment.

As an environmental health researcher, educator and film producer, (“Toxic Trespass” NFB co production on children’s health and the environment and” Exposure: Environmental Links to Breast Cancer”) I am aware that we have more than enough evidence of growing numbers of diseases and conditions related to preventable exposures of toxic materials including radiation from the whole nuclear fuel process.

Concerns about the health impacts of the nuclear fuel chain:

Since the catastrophic nuclear reactor accident in Fukushima, Japan, despite attempts to cover up the known continuing tragedy of the situation there and despite the change in policy in many other countries, Ontario plans to continue its problematic expensive nuclear program. Since and following the crisis in Fukushima, radiation is being detected in the air, water and food not only in Japan but also in many other parts of the world. Recent media reports attest to more and ongoing contamination of soil and sea water from it. The long term health impacts will likely be widespread and this nuclear tragedy is described as among the worst in the world. Initially, some reports revealed the negation, denial, and cover ups by the nuclear industry, the International Atomic Energy Agency and supporting governments. This denial and cover up was similar to that following other major nuclear accidents (example Chernobyl), with their language of “safe” and “allowable” levels of exposure to radiation. With Fukushima, it has now been proven otherwise according to regular reports from Japan.

It must be understood and reiterated that there is no safe dose of ionizing radiation and even the smallest dose can cause cancer and other health effects (Biological Effects of Ionizing Radiation Vll (BEIR Vll) National Academy of Sciences, 2005 (despite reassurances from CNSC staff). Indeed, radiation is a known human carcinogen according to the International Agency for Research on Cancer (IARC) of the World Health organization and all nuclear facilities release radiation. IARC lists a number of radionuclides as proven causes of cancer including those produced from the mining, milling, manufacturing and use of uranium fission in nuclear power plants.

As a former health professional, I can attest to the pain and suffering of patients with cancer and other environmentally linked diseases. No doubt, everyone reading this or present here knows of someone who has had cancer and/or who has died from it. In Canada, half of the male population and slightly less than half of the female population will be diagnosed with cancer at some time in their lives. Childhood cancer rates are expanding one per cent per year and if that child or grandchild is yours or someone close to you, you know what anguish that is, for not only the child but also the whole family. Of course, such anguish applies to those with breast and other reproductive cancers especially if it’s a diagnosis of your mother, sister, wife, partner, daughter or friend. Therefore we must ask how much of this cancer is preventable? We know that for most cancers, only 5-10% are due to inherited genetic mutations so we must ask what is causing the other 90-95% to develop the disease and how much might be prevented.

We must also ask how much cancer can be attributed to radiation? And how much can be prevented? There are many safer more sustainable ways to provide electricity services than nuclear power that have been well articulated and presented to you at various consultations on Darlington and Pickering in recent years, but thus far they have been largely ignored in the decisions by the CNSC and the Ontario government – this even while the government has been supporting the Green Energy Act, which is just a beginning but a necessary one, to the required overall transition to a healthy future for all life in the province and ecosystem. Instead of continuing to produce more waste, there must be serious decisions taken to move toward sustainability which includes phasing out and decommissioning the reactors as soon as possible, not constructing new ones and put the billions of dollars saved to the safer, healthier solutions – energy efficiency, conservation and renewables – see

We are all well aware there is major public concern about radioactive waste disposal because it is long-lived and can adversely affect human health and the environment.

In terms of alternatives to the current proposal part “alternative means of carrying out the project” include:surface and near-surface storage; alternatives to ‘natural’ containment (i.e.,engineered barrier); the status quo Western Waste Management Facility (WWMF); alternative storage systems; and reduction at source – this latter should include plans for a phase out of nuclear energy development and a clearly planned decommissioning timeline.

The International Joint Commission on the Great Lakes Water Quality Agreement makes it clear that Canadian nuclear facilities on the Great Lakes have had measurable transboundary effects. Why do the CNSC and other decision makers not heed this evidence?

The Environmental Assessment should consider a range of possible environmental impacts for a minimum period of one million years, reflecting the extremely long half-lives of various radioisotopes that will be placed in the proposed location. Would this not provide clear guidance to OPG and remove the possibility of any selective interpretation of text in the scope as currently proposed by CNSC staff?

Transportation is an obvious major environmental issue for the proposed project. Since the WWMF and the new proposed site are both near each other on OPG’s Bruce nuclear site, transportation between them is relatively short, however, transportation from Darlington and Pickering to the Bruce site is more problematic.

As such, WHEN is concerned that municipalities along the way must be consulted on the initiation of further decades of radioactive waste transportation through their communities. This is particularly relevant given that the CNSC is apparently refusing to consider site storage (i.e. at the Darlington and Pickering sites) as an alternative to the undertaking.

The "safety case" for the approval of the Deep Geologic Repository relies on technical arguments to demonstrate that the proposed repository will isolate the wastes for a required time period, which is effectively unpredictable., However, there are many admitted areas of uncertainty around the effectiveness of the (lack of) containers, the estimates of corrosion and gas buildup, the reliability of the computer models, the characterization of the geology and so on. This varies with the material but is certainly for the duration of several thousands of years. As such, key questions include, how such material would be able to re-enter the human environment? What conduits are available, in terms of permeable rock formations, fault zones, fracture zones (which may have no fault movement along them), and deep groundwater circulation? There is further uncertainty as to how the nuclear waste will interact with the barriers (ie corrosion of the barriers, the releasing of gases), seismic or glacial activity, and how radioactive material will react in a closed environment. Again, we must ask - where is proof of safety?

Therefore these issues are not just technical but must be regarded as ethical/moral ones and they cannot only be dealt with by geologists, engineers and other scientific professionals. We must not and cannot continue the mistakes of the past. The impacts will be local, regional and international including trans-boundary with the US and beyond, including economic and cultural ones. Activities and industries such as fishing and tourism could potentially be destroyed.

Since a significant proportion of the intermediate level waste consists of refurbishment waste, generated in the process of extending the expected lifetime of existing reactors, a commitment to phasing out the existing reactors entirely would go a long way toward reducing the need for further storage.

Therefore, our recommendations are to maintain the status quo regarding the existing nuclear waste including on-site storage at Darlington and Pickering, following with proposals to reduce waste (including to reuse and recycle it on site); expand the concept of “reduction at source” of nuclear waste to include reduction in demand for electricity through education, advertising and efficiencies; expand the concept of “reduction at source” of nuclear waste to include phase out of all existing nuclear plants and seriously invest in energy efficiencies, conservation and renewable electricity production.