March 6, 2017. Deep Geologic Repository Project Project Manager Canadian Environmental Assessment Agency 160 Elgin Street 22nd Floor, Ottawa [email protected] Re: Submission of SOS Great Lakes to the Minister of Environment and Climate Change and the Canadian Environmental Assessment Agency on the Subject of Additional Information Submitted by the Proponent, Ontario Power Generation, for the Proposed Deep Geological Repository Project for Low and Intermediate Level Waste in Kincardine Ontario (ref 17520) To whom this may concern: SOS Great Lakes is pleased to be able provide a submission during the public comment period on the matter of the Additional Information Package submitted to the CEAA by OPG for the Deep Geologic Repository in Kincardine. The commentary has been provided in the form of a Report, with chapters written by our volunteer members and Board. We have benefited from the work of Mr. John Jackson, our expert, retained through participant funding from the CEAA. Mr. Jackson has written the Chapter on Cumulative Effects. Thank you for providing us this opportunity to participate in this important process of consultation with the public. Sincerely, Jill Taylor, President on behalf to SOS Great Lakes, and the Board of Directors. <contact information removed> <contact information removed> <contact information removed> Comments to the Minister of Environment and Climate Change on Ontario Power Generation’s Response to the Minister’s Request for Additional Information on the Proposed Deep Geologic Repository for Low and Intermediate Level Waste March 6, 2017 Prepared by Members of SOS Great Lakes <contact information removed> <contact information removed> <contact information removed> 1 2 INTRODUCTION SOS Great Lakes SOS Great Lakes is a not- for-profit corporation comprised of volunteer Canadians and Americans dedicated to the prevention of the burial and abandonment of radioactive nuclear waste anywhere in the Great Lakes Basin. Our effort started in 2012 with the announcement by the Nuclear Waste Management Organization (NWMO) of a potential plan to locate a High Level Waste DGR (DGR2) in Saugeen Shores a few kilometres north of the Bruce Nuclear site. We started as S.O.S. (Save our Saugeen Shores) and were successful when NWMO backed down and withdrew. To save face they claimed it was because of a problem with the soil, soil they had rigorously tested years before. The reality was a Town unwilling. Freed from work on DGR 2, we turned our attention the OPG plan to locate DGR1 for L&ILW at the Bruce Nuclear site. We learned quickly that concerned Canadians and Americans well outside the prescribed study area for DGR1 were being ignored by both the proponent and the joint regulators, CEAA and CNSC. We re-branded as SOS GREAT LAKES, with members from all walks of life, and a cross- section of occupations and expertise. Some have a family history near the Great Lakes for generations. Others have no close geographic connection but are intelligent observers, whether in Canada or the United States, of public policy issues and errors such as this one. All are appalled at the unnecessary and dangerous proposal of DGR1. We are not the “uninformed” or “anti-nuke fringe” players CNSC management regularly tries to marginalize. Locally, we have consistently supported Bruce Power for its economic and social contributions to the local communities in the region. Our concern is directed at the irresponsibly dangerous and unnecessary DGR1 plan and the deception that CEAA and CNSC have allowed OPG to perpetrate on the public throughout the approval process. Many of our members and supporters in allied groups were registered participants in the Joint Review Panel Hearings of 2013 and 2014. Our written and oral presentations can be found on the CEAA website. Those submissions and our several detailed letters to you after your election show how siting a DGR for L&ILW on the shore of Lake Huron on the Bruce Nuclear site 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, it is our opinion that the political process surrounding the Hosting Agreement with Kincardine, and the ongoing support by neighbouring municipalities due to intervention by OPG has been fraught with conflicts of interest, the precise antithesis of democratic due process in the DGR planning. The disposal of ILW in the DGR 1, some of which has the potential radioactive hazards of nuclear fuel waste and for comparable periods of time, requires the same standards of technical, safety, ethical awareness and social responsiveness as in planning for high-level radioactive waste. We continue to participate in the public process of review of this project because the DGR construction will cause a threat to the safety and security of the environment, the Great Lakes in perpetuity. We are all stewards of the Great Lakes, their shores and their role in the lives of not just the 40 million Canadians and Americans whose drinking water comes from the Lakes, but a world that cherishes fresh water anywhere. We expect no less of industry and our leaders. 3 Our Submission Our Submission to the Minister is comprised of commentary in chapter format relating each of the three primary questions sent to OPG by the Minister in February 2016. Each of our chapters has been written by one of our members. We have been assisted in our submission by Mr. John Jackson, hired through the CEAA Participant Funding Program, to prepare commentary on OPGs Cumulative Effects Analysis. The topics discussed include: commentary on OPG’s Study of Alternate Locations, the Cumulative Effects Analysis of the DGR for L&ILW in Kincardine, in combination with 3 potential APM used fuel DGRs in the one of the communities of Huron- Kinloss, South Bruce, and Central Huron, and the OPG Mitigation Measures Report. OPG Has Submitted a Flawed Environmental Assessment. In December 2016, OPG has presented a deeply flawed addition to its deeply flawed Environmental Impact Statement. We urge the Minister to reject the EA for OPGs Deep Geologic Repository and to reject the licensing of the DGR at Kincardine. Thank you. 4 TABLE OF CONTENTS INTRODUCTION ........................................................................................................................................ 3 ALTERNATE LOCATIONS .......................................................................................................................... 9 Summary ............................................................................................................................................... 10 1 The Letters from the Minister and Agency to OPG, and Letters from OPG to the Agency .............. 12 1.1 February 2016, the Minister to OPG .......................................................................................... 12 1.2 April 2016, OPG to the Agency .................................................................................................. 12 1.3 September 2016, the Agency to OPG ......................................................................................... 12 1.4 The OPG December 2016 Submission ....................................................................................... 13 2 Chronological Background to the Minister’s Request for Information on Specific Comparative Alternate Locations ........................................................................................................................... 15 2.1 The OPG’s EIS 2011 for the Joint Review Panel (JRP) ................................................................ 15 2.2 OPG Response to EIS‐02‐40 ........................................................................................................ 15 2.3 CELA’s Identification of the Error (2013) ................................................................................... 15 2.4 OPG Responses on Alternative Locations from November 2013 to May 2015 ......................... 16 3 The JRP Report .................................................................................................................................. 19 3.1 The JRP Report (May 2015) had its Concerns with the IEG Report on Alternatives .................. 19 4 Why a Failure to Study Actual Alternate Locations is Particularly Unacceptable ............................ 20 4.1 Avoiding Proximity to the Great Lakes ...................................................................................... 20 4.2 Recognition of Experimental Nature and Risk of DGRs ............................................................. 20 4.3 Why are Accidents and Failures of Great Importance to Analysis of Options and a Range of Actual Locations? ............................................................................................................................. 21 5 OPG’s Submission to the Minister .................................................................................................... 23 5.1 Technical and Economic Feasibility at Alternate Locations ....................................................... 23 5.2 The Alternate Location, Project Description per OPG ................................................................ 25 5.3 Regional Characterization .......................................................................................................... 25 5.4 Crystalline Location Characterization .......................................................................................