Curmudgeon's Corner, 2006 Archives
. Comments to CNSC on Ontario Power Generation proposal for an Environmental Assessment of construction and operation of a deep geologic repository for low and intermediate level radioactive waste in the Bruce area, July 10, 2006 . To Federal Energy Minister re: Environmental Assessment on Deep Geologic Repository for Low and Intermediate Level Radioactive Wastes, Tiverton (ON), March 8, 2006 . Faxes and Email (No More Nukes) to Ontario Government officials re: Ontario Power Authority electrical energy supply mix advice energy plan, February 10, 2006 2007 Current 2005 Archives 2004 Archives 2003 Archives 2002 Archives 2001 Archives
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.
Walter L Robbins
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
To: Ontario Power Authority: "Supply Mix Advice Report"
formal comments
February 10, 2006
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