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|Personne ou organisme qui a soumis le commentaire||Section du document ou référence||Commentaire|
Charles Rhodes, P.Eng., Ph.D.
Xylene Power Ltd.
I am totally opposed to licensing of a DGR as envisaged by the NWMO.
Climate change is primarily due to the rising atmospheric CO2 concentration. Today, in 2023, stopping further rise in the atmospheric CO2 concentration would require about 21,000 GWt of new dependable and sustainable clean (non-fossil) thermal power to meet the total thermal load presently met by combustion of fossil fuels. Due to increasing electrification in developing countries, by 2070 this total thermal load will likely rise to about 40,000 GWt.
Intermittent renewable electricity generation cannot supply dependable power and, due to electricity dispatch constraints, can only economically provide about 25% of the required clean energy. Meeting the anticipated 2070 total thermal load with dependable power and clean energy will require both maximum economic renewable energy generation and a fleet of about:
Based on a projected Canadian population of 60,000,000 in 2070, Canada's share of these reactors will be about 450 X 300 MWe SMRs.
In spite of ample evidence of relatively rapid climate change, elected governments with short time horizons continue to delay deployment of nuclear power plants with sustainable fuel cycles. The consequences of this deployment procrastination will be dire.
There is simply not enough minable natural uranium to provide sustainable displacement of fossil fuels using water moderated reactors. Sustainable displacement of fossil fuels requires fuel breeding fast neutron reactors (FNRs). The start fuel for a sustainable nuclear fuel cycle is best obtained by separating the TRans Uranium actinides (TRU) from used water moderated reactor fuel. However, such separation is physically impossible if the used water moderated reactor fuel is placed in a DGR.
The DGR should be totally replaced by used CANDU fuel reprocessing as described at
Interim storage of fission products and other radioactive material pending future use and reprocessing is best done using a facility such as Jersey Emerald, as described at:
A major feature of Jersey Emerald is permanent accessibility above the water table for future inspection/container repair.
|Ontario Power Generation (OPG)||Veuillez consulter le tableau ci-joint||Commentaires d'OPG|
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|Athabasca Chipewyan First Nation||Veuillez consulter le tableau ci-joint||Commentaires de Athabasca Chipewyan First Nation|
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|Dr. Sandy Greer||Veuillez consulter le tableau ci-joint||Commentaires de Dr. Sandy Greer|
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|Dr. F. R. Greening||Veuillez consulter le tableau ci-joint||Commentaires de Dr. F. R. Greening|
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Please allow me to voice my concerns about this process and my opposition to the creation of a Deep Geological Repository (DGR) in either designated location under consideration in Ontario. My concerns include the following:
1. As Mississaugas of Scugog Island First Nation pointed out, "The list of risks to health and safety of the public does not include potential risks to groundwater.” The protection of ground water is essential — especially so to Indigenous people — and must not be contaminated by blasting rock in creating a nuclear tomb 500 meters underground, burying highly radioactive nuclear waste for many thousands of years, and then permamently sealing it. The likelihood of groundwater becoming contaminated by a DGR over time is certain, and probably within only a few hundred years. Copper does corrode and bentonite is not a pemanent seal. Neither is rock that is susceptible to geological movement. DGRs are not a reliable or affordable solution.
2. Transporting nuclear waste from New Brunswick, Quebec and Ontario to the DGR site is another highly questionable risk. It is unthinkable to allow this to happen, as both the risk of accidents and the enormous cost involved makes this concept ludicrous.
3. Nuclear waste needs to stay where it is now, near the power plants that produced it. There it can be repackaged most safely and least expensively as required until a proper and affordable solution can be found. The same is true for the medium-level nuclear waste. Most of that waste can be stored with the nuclear reactors when they are decommissioned.
4. Small Modular Nuclear Reactors (SMNRs) are not a solution to the climate emergency that is already getting out of control. This latest nuclear technology is no more than a Hail Mary pass from a desparate dying industry trying to survive. SMNRs are uneconomical and are not needed to meet our energy requirements as they will be too late, too costly, and are likely to fail. Efficiency and renewable energy, especially wind and solar, is where funding needs to go. SMNRs are not now, and never will never will be, economically competitive with renewable energy, including hydro.
5. As well, nuclear proliferation is an additional risk created by the nuclear industry through the creation of plutonium in reactors. This is truly worrisome and must end before a military or terrorist disaster occurs. The threat of a nuclear war is now the highest it’s ever been, thanks to Russia, North Korea, Iran, and other countries, including the United States.
Finally and importantly, the climate emergency demands immediate and effective action with responsible stewardship. Nuclear has no place in mitigating the climate crisis. This needs to be accepted now, so we can tackle the climate emergency quickly and most effectively.
I have not been able to read all submissions, but I agree with comments submitted by:
by Bill Noll, Vice Chair of Protect our Waterways No Nuclear Waste (POW),
and by Dr. Sandy Greer.
I agree with the Athabasca Chipewyan First Nation submission and will make comments about a couple quotes:
“2. Recommendation: ACFN recommends that the standard to which radioactive waste will be contained and isolated from the environment takes into the account Indigenous peoples use of the environment to ensuring the safety of Indigenous people for future generations. ACFN is concerned that Indigenous uses of the land and resources (e.g., drinking water from the rivers, streams, lakes etc. and consumption of animals and plants) are not factored into the standards of how radioactive waste is contained and isolated from the environment.”
I will even go further and push for amendments to have lower tritium levels allowed in the current water regulations as well as other toxic radionuclide components. It’s astounding how the limit is permissive in Canada compared to other countries.
“9. Recommendation ACFN recommends that the benefits of engagement include the contribution Indigenous knowledge toward reducing potential risks and impacts on Indigenous communities throughout the lifecycle of DGR. Further, ACFN recommends that Indigenous engagement take place throughout the life of the project. Decommission plans should be developed with input from Indigenous communities and made available for them to review.”
Prior, full and informed consent must be given to the First Nations and surrounding canadian communities. Water has a way of moving around and spreading around the contaminants of high-level toxic waste that will be buried in the DGR. In Port Hope, a town of 16 000 that had a refinery of radium and uranium, has to be cleaned up of low level toxic nuclear waste in the surface soil and this is costing millions; that is strictly the cost for the environmental damage, as little long-term health studies have been conducted. Imagine how costly and risky that DGR project is. It isn’t a guarantee that can be made for First Nations that their land, water and air will be kept intact and their land is sacred to them; they can’t just uproot and go live somewhere else. Canada has the world’s largest freshwater reserve. Our First Nations are trying to protect it and they have a right to do so and to be given thorough details before the project is underway.
We must stop producing nuclear waste and contain the tons we have indefinitely, safely. DGRs as presented are not a viable solution.