Deep Geologic Repository Joint Review Panel Commission d’examen conjoint du projet de stockage dans des couches géologiques profondes PMD 13-P1.130 File / dossier : 8.01.07 Date: 2013-08-13 Edocs: 4185365 Oral intervention from Intervention orale par Save Our Saugeen Shores Inc. Save Our Saugeen Shores Inc. In the Matter of À l’égard de Ontario Power Generation Inc. Ontario Power Generation Inc. Proposed Environmental Impact Statement Étude proposée pour l’énoncé des incidences for OPG’s Deep Geological Repository environnementales pour l’Installation de (DGR) Project for Low and Intermediate stockage de déchets radioactifs à faible et Level Waste moyenne activité dans des couches géologiques profondes Joint Review Panel Commission d’examen conjoint September 16 to October 12, 2013 16 septembre au 12 octobre 2013 WRITTEN SUBMISSION SAVE OUR SAUGEEN SHORES, INC. (SOS) In the Matter of Ontario Power Generation Inc. Proposed Environmental Impact Statement For OPG’s Deep Geological Repository (DGR) Project for Low and Intermediate Level Waste (L&ILW) Kincardine, Ontario To the Joint Review Panel September / October, 2013 Presented by Jill Taylor, President, Save Our Saugeen Shores, Inc. 1 Table of Contents 1. Why Are We Speaking Out? 2. Who Is Save Our Saugeen Shores, Inc. (SOS?) 3. OPG Environmental Impact Statement: A Plan with an Unacceptable Level of Risk 3.1 The Environmental Impact Statement Says: likely no significant risks 3.2 Conflicting Information 3.3 Understatement of Risk 4. Scientific, Social and Economic Concerns 4.1Why a DGR? 4.2 Cumulative Effects of One Aspect of Risk on Another in Time and Space 4.3 Cumulative Effects Assessment Table 10.4-1 and Analysis 4.4 Non-radiological Malfunctions and Accidents 4.5 A Science the Explains the Past But Cannot Predict the Future: Concerns about Geology and Safety 4.6 About $1-Billion 4.7 Residual and Adverse Effects of the DGR 4.8 What Beneficial Effects? 5. A Flawed Process of Consultation and Communication 5.1 Ethical Questions 5.2 Conflicts of Interest 5.3 One Community Choosing for All 5.4 Accepting Hosting Agreement Payouts: Infinite Obligation 5.5 Employment and Long-term Benefits Offered 5.6 The Fox in Charge of the Hen House 6. Misrepresentation of Information 6.1 What’s in a Name? 6.2 How is Radioactive Waste Classified? 6.3 How Less Than Candid Disclosure in Education Materials 6.4 Use of On-Side ‘Experts’ 7. Community Input 7.1 EIS and OPG Requirements 7.2 The Timeline 7.3 Public Attitude Analysis 2003, Intelliplus Ltd.: 7.4 Open Houses June 2003 7.5 Open Houses June 2007-10 7.6 Public Attitude Research (PAR) 2009 and the Socio-economic TSD Save Our Saugeen Shores, Inc. (SOS) 8. Lack of Informed Consent and Failure of Democracy 8.1 Poll to Test Willingness Left to Kincardine 8.2 The Telephone Poll of February 2005: not a Referendum or Vote 8.3 The Question that was Asked 8.4 Poll Results 8.5 Peer Review of Poll Results 9. Purchase of Support in Saugeen Shores and Adjacent Municipalities 9.1 Striking Deals 9.2 Was There an Official Agreement? 9.3 Presentations by OPG to Saugeen Shores Council, 2004 9.4 Was There an Official Agreement? 9.5 The Offer 10. How Well Informed Were People? 11. Continued Support by the Mayor of Saugeen Shores in 2012 11.1 Letter of Support June 26, 2012 11.2 SOS Deputation to Council June 25, 2012 11.3 Other Letters of Support as Unrepresentative CONCLUSION ENDNOTES APPENDICES 3 1.0 WHY ARE WE SPEAKING OUT? My name is Jill Taylor, and I represent Save Our Saugeen Shores, Inc. (SOS). We, the members of SOS, are here to object strenuously to the construction of a deep geological repository (DGR) at the Western Waste Management Facility (WWMF) for the disposal of radioactive nuclear waste. Through our own research and through reading of material prepared by or on behalf of Ontario Power Generation (OPG), we have apprised ourselves of the proposal before the Joint Review Panel for the Deep Geological Repository (in this report, DGR 1) for low and intermediate level waste (L&ILW). Save Our Saugeen Shores, Inc., is a grass-roots organization established in February, 2012, after residents of Saugeen Shores learned of their municipality’s plan to enter into the Nuclear Waste Management Organization’s (NWMO) process to find a site for all of Canada’s current and future used nuclear fuel. Since that time, the Town of Saugeen Shores has advanced to Stage 3 of the site-selection process for a DGR for the high level waste (HLW) — which we will refer to in this report as DGR 2 — along with 21 other towns, 6 of which are located in Bruce County. Shortly after we organized, in spite of alleged widely publicized communication and polling, many residents of Saugeen Shores learned for the first time of OPG’s plan to site DGR 1 (L&ILW) next to the Western Waste Management Facility (WWMF). The WWMF, located on the Bruce Nuclear Generating Station near Tiverton, Ont., is less than one kilometre from the shore of Lake Huron on which we reside, and only 12 kilometres from the boundary of our town. Our town is so close to the proposed DGR 1, that the Guidelines for the Preparation of OPG’s Environmental Impact Statement (EIS), under 5.1 Setting, even require the EIS to concisely describe the proximity of the DGR not only to Kincardine, but to the Town of Saugeen Shores. SOS believes siting a DGR for L&ILW in Kincardine is a dangerous and deeply flawed project. The burial plan for the waste raises on-going safety, health, environmental and socio-economic concerns. In addition, in our opinion, the educational and political process has also been fraught with conflicts of interest, misrepresentation and non- disclosure, as well as lack of democratic due process in the DGR planning. The disposal of ILW, some of which has the potential radioactive hazards of nuclear fuel waste and for comparable periods of time1, requires the same standards of technical safety, ethical awareness and social responsiveness as in planning for high-level radioactive waste disposal. Our research indicates that some of the L&ILW to be stored in the DGR is as highly radioactive and long-lasting as the isotopes from the irradiated Save Our Saugeen Shores, Inc. (SOS) nuclear fuel that has been discussed as being disposed of in the DGR 2. We are here to address the JRP from a neighbouring town because the municipal boundary of the Town of Kincardine does not constitute a physical barrier that could protect our town and Lake Huron itself from the risk of a negative impact. Because we are on the shore of the same body of water, because we share groundwater and air, because we share roads, local food and drinking water, we are integrally connected. Because the DGR construction may cause a threat to our safety and security, and negatively affect the value of our properties, and for a multitude of other reasons, we are here today. Up until now, we have been excluded from the process of community consultation. Despite public statements made by our mayors since 2004, and by OPG, there is no demonstrated willingness or support of the DGR 1 by Saugeen Shores residents. We were not, as promised to OPG by then-mayor Mark Kraemer, contacted by our municipality at any time to inform us about the DGR 1. Nor were we contacted by the municipality to inform us of Council’s support for the DGR 1 in Kincardine. None of our core membership has ever been polled, contacted or formally consulted during the process conducted by consultants assigned to reach out to municipalities adjacent to the Town of Kincardine. There is NO indication that 40% of the residents of Saugeen Shores endorsed the long term management plans proposed by OPG in the form of a DGR as is asserted by the EIS Volume 1. It is a major oversight that the municipality of Saugeen Shores did not seek to clearly and comprehensively inform all citizens of this very important plan for storage of radioactive waste. Further, to maintain that we were in support of the plan is simply untrue. If community consent is considered a pillar of the acceptability of the project for its proposed setting, consent has not been achieved. Everything that we cherish and wish to extend as a legacy to our children has to do with the protection of our Great Lakes heritage and environment. We have been taught since childhood, and continue to believe and to work toward a goal that all Ontarians are expected to embrace, to be good stewards of Lake Huron, the land and its setting. We expect no less of industry, our leaders and our neighbours. 2.0 WHO IS SAVE OUR SAUGEEN SHORES, INC. (SOS)? The mission of SOS is to provide public education and raise awareness about the health, environmental, and socio-economic risks of radioactive waste and prevent its deep burial in Saugeen Shores, its neighbouring regions and the Great Lakes Basin. We took on this task after observing that our municipal council, rather than providing a range of educational materials about this issue, chose to display almost uniformly pro- DGR 2 information on its website and in NWMO-sponsored kiosks at the municipal 5 offices. SOS maintains there should not be DGRs for any nuclear waste anywhere in the Great Lakes Basin, due to the potential for radioactive contamination of this precious resource — the drinking water of 40 million people — and the potential for other adverse environmental, social, health and economic impacts from a DGR.