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Geologic Repository for Ā Low and Intermediate Level Radioactive Wastes,
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July 10, 2006

Comments on the Draft Comprehensive Study Scoping Document
for an Environmental Assessment of the Proposal by Ontario Power Generation
to Construct and Operate a Deep Geologic Repository for Disposal
of Low- and Intermediate-Level Radioactive Waste", (Bruce area of Ontario)
Canadian Environmental Assessment Registry number 06-03-17520

This draft Scoping Document lacks an underlying foundation of science and
engineering and should not, in and of itself, serve as the basis to proceed
with the contemplated project. Much preliminary work needs to be done.

To cite a case in point, during the late 1970's and 1980's, the Canadian
nuclear establishment, led by Atomic Energy of Canada, Ltd., (AECL) embarked
on an intensive high-level nuclear waste geological underground repository
project. Initially the project was referred to as a "concept verification,"
changed later to "concept assessment."

AECL spent nearly a decade undertaking scientific and technical studies, a
large part of which concentrated on the nature and integrity of the natural
granite rock formations into which such a repository would be constructed.
The concept assessment resulted in volumes upon volumes of analysis and
evaluation of granite plutonic rock formations. In effect, that target rock
was "studied to death."

The extensive Underground Research Laboratory (URL) in the Rural
Municipality of Lac du Bonnet, Manitoba remains today as an artifact of that
effort.

AECL considered the plutonic granite rock formations to be a superior
geological medium for a repository. Initially, it expected that the rock
would be very dense and have few fractures or cracks that would compromise
its integrity.

Publicly, the Crown Corporation exuded confidence in its underground
repository "concept."
And, in spite of the discovery of major water bearing fracture zones within
the URL, AECL went on to propose a full-scale Federal environmental
assessment (EA) process. AECL requested that its concept, based on its many
years of study, be adopted as the preferred approach for the long-term
management of Canada's nuclear fuel waste.

The EA Panel report produced a mixed assessment of the concept that finally
resulted in Federal legislation establishing the Nuclear Waste Management
Organization (NWMO) to carry on the work.

After three years of massaging the issue, in its final report, "Choosing the
Way Forward, " the NWMO concluded that the growing stockpiles of irradiated
nuclear fuel from Canada's reactors should ultimately wind up in a deep rock
underground tomb.

(This was no surprise as the NWMO is essentially a nuclear industry based
organizational mechanism that has always stated a preference for permanent
underground burial.)

But there was a significant change in the NWMO conclusions as compared with
those in the earlier effort spearheaded by AECL. NWMO called for an
expansion in the type of geological rock formations deemed suitable for the
dump, whereas AECL had largely restricted its dumpsite search and research
to the preferred special "plutonic" granite formations.

The NWMO has "declared" the suitability of the so-called "Ordovician
Sedimentary" rock which can be found in many parts of Canada, including
Ottawa, Kingston, and the Bruce Peninsula in Ontario. This means that such
locations can be considered as possible candidates for high-level (and
presumably low and intermediate level) nuclear waste dumps.

But, to the best of my knowledge, the NWMO reports and discussion papers did
not "assess" this new concept. Where is the science behind this decision?
Where are the extensive geological and engineering studies that would
support placing any kind of radioactive waste in such rock formations? Where
are the volumes and volumes of information concerning the nature and
integrity of "Ordovician Sedimentary" rock? In short, where is the proof
that the rock formations in the target Bruce area are scientifically
suitable for such a crucial facility? The scoping document does not address
this fundamental issue!

Is it simply coincidence that the Bruce region rock formations are now
"suitable" for underground nuclear waste dump purposes including low, medium
and high-level radioactive materials? Or, is this purely a political
decision to use the Bruce effort as a Trojan Horse for a future high-level
radioactive waste repository as well?

Dealing with the acceptability of this geological medium in such a
perfunctory manner in this scoping document is quite unacceptable.

It stands to reason that any environmental assessment of this project must
be preceded by a complete scientific investigation of the appropriateness of
the geological medium.

A full-scale panel review including maximum public involvement and
interaction is clearly warranted for any such facility.

Further, given the uncertainties surrounding the long-term integrity of any
underground facility, alternatives, such as continued on-site storage,
should be a major part of the discussions of this issue.

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Walter L Robbins

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March 8, 2006

Hon. Rona Ambrose
Minister of the Environment
House of Commons
Ottawa, Ontario K1A 0A6

Dear Ms. Ambrose,

Re: Environmental Assessment on Deep Geologic Repository for Low and
Intermediate Level Radioactive Wastes, Tiverton (ON); CEAR reference number
06-03-17520

A full-scale panel hearing process is absolutely essential for the
environmental assessment of the proposal for a deep geologic repository for
low and intermediate level radioactive wastes at or near the Bruce nuclear
site in Ontario. Anything less would be unacceptable given the unprecedented
nature of the proposal and its far- reaching consequences. This is a formal
request that you invoke the highest possible level and profile to this
environmental assessment.

As you may be aware, the current definition of low and intermediate
radioactive waste includes some isotopes that are extremely long-lived
(hundreds of thousands of years) and can be considered very serious
environmental and public health threats for those aeons of time.

Panel hearings must examine in detail all of the interdisciplinary questions
surrounding this proposal. For example, to mention a few:

. A complete analysis and airing of all relevant health physics and
epidemiological data to determine the possible health consequences of human
exposure to these substances in the near, intermediate and far term.

. The scientific and especially the geologic issues surrounding the choice
and the integrity of the specific types of rock formations in the Bruce
area, into which such a repository might be placed.

. Analysis of the management, techniques, and processes required for
successful retrievability of these substances in the event of breach of
repository conditions; understanding of the many kinds of conditions that
could lead to such a breach and an examination of mitigation strategies in
such an event.

. Questions surrounding the security and safety of the physical movement and
handling of these materials and the potential accessibility of them to both
inadvertent and deliberate human intrusion, prior and subsequent to final
repository closure. The disposition of such materials would be of more that
passing interest to terrorists.

. Proposed methodologies for continuous and long-term monitoring of the
status of the radioactive substances that would actually be placed in such a
deep repository, including an analysis of governance and institutional
capability and stability issues over long time frames.

. The environmental assessment should be bi-national in nature, inasmuch as
the contemplated site is close to Lake Huron, a body of water shared by both
the United States and Canada. It is my understanding that individuals and
groups within the United States have already expressed concern over this
proposal.

I also have a concern that this proposal could become a precursor of an
expansion to include high-level, irradiated fuel wastes from nuclear
reactors as a means of circumventing the spirit, if not the letter, of the
Federal Nuclear Waste Act.

Your urgent attention to this matter would be greatly appreciated.

Walter L Robbins
c.c. Linda Keen, President and CEO, Canadian Nuclear Safety Commission

Ā

No More Nukes

To: Ontario Power Authority: "Supply Mix Advice Report" formal comments
February 10, 2006

Ā

On a road trip across the United States last Spring, it became increasingly
evident to me that an energy revolution is in progress there. It was not
just the visibility of the many wind farms that are springing up, or more
hybrid cars and various energy saving initiatives. It was the fact that
state and local governments along with NGO's are seriously and actively
working to reduce energy consumption and develop renewable alternatives.
They are not just talking about it; they are doing it!

Back in the Summer of 2001, widespread blackouts were predicted for energy
greedy California. They did not occur and in that period alone, spearheaded
by a range of incentives from their state government, Californians reduced
their consumption of electrical energy by as much as 5500 megawatts.

I'm sure that Ontario Power Authority (OPA) and the Ontario Government are
well aware of the many such developments in North America and around the
world. In spite of the fact that some countries, such as China, still opt
for the construction of large scale, centralized electrical energy plants of
one kind or another, the real trends are in the opposite direction. And even
China is starting to look at the new realities of the 21st century.

A decentralized electrical energy system in Ontario would not only reduce
the impact of power disruptions, it would increase and spread-out the
economic benefits across the province. In addition, failure to adopt
clean-coal technology for existing plants to help manage the transition, can
only be viewed as myopic.

All of the great advantages of a cutting edge decentralized system of
renewable energy and conservation are well documented in the Ontario Clean
Air Alliance (OCAA) study which is very critical of the OPA plan, especially
as it relates to the possible construction of more nuclear plants.

Nuclear energy is a very expensive way to boil water, as the resulting
never-ending debt load carried by Ontarians demonstrates. I hate to think of
what another round of that kind of fiscal irresponsibility would bring to
all of us.

Ontario is moving away from its historical role as a high-electrical
consumption, industrial manufacturing bastion to a very different kind of
economy; essentially a knowledge-based, low energy consumption one. As OCAA
points out, Ontario's electricity demand growth has been "moderating" for
the last half century.

As for impacts on air quality, nuclear reactors themselves may not produce
the various noxious substances in our air, but they do produce high-level
radioactive waste which will be deadly to living things for hundreds of
thousands of years. In my view, the industry-based Nuclear Waste Management
Organization's proposals are badly flawed. Ultimately, if implemented, they
will return us to the late 1970's and early 80's when many Ontario
communities were terribly disrupted in a fruitless search for a nuclear
dumping ground.

Furthermore, uranium mining, milling and refining processes, with their
mountains of hazardous tailings, do contribute to poor air quality. And, it
has been estimated that as a non-renewable resource, uranium will not only
cost more, but, in time, the amount of energy needed to get it to reactor
fuel rod status will likely exceed the energy actually produced by the
reactors. Not much of a bargain for society there!

Designing and keeping those reactors running properly and safely requires
near "heroic" efforts. Only one bad slip, and the game is over. No other
energy technology can make that claim.

Given all the concerns over factors such as costs, safety, security,
radiation health, waste management, it is difficult to understand why the
Ontario Government and the OPA are so entranced with nuclear energy, an old
technology which would be long gone, if not propped up
by enormous public subsidies.

And, given the great importance and high priority of this issue, the current
level of consultation undertaken by the Government of Ontario is woefully
inadequate. Nothing short of formal public hearings within the scope of
provincial environmental laws and regulations are an absolute requirement.

Walter Robbins

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