An unbelievable proposal by the Ontario Power Authority (OPA) for a deep underground radioactive waste repository a half mile from the shore of Lake Huron is in the works. If the plan succeeds, all of Ontario's “low and intermediate” level radioactive garbage, will eventually be transported to and permanently buried at the site, which is part of the extensive Bruce nuclear complex.

What is low and intermediate?  Anything radioactive, from mops and clothing, to reactor tubes and components, is included in the categorization. The "intermediate" level waste requires special handling and can pose risks for significant periods of time.

But “low and intermediate” are arbitrary and fuzzy categories based primarily on the types of material and the overall gamma radiation dose rates.  Many observers believe that this is a totally inadequate method for determining the ultimate risks these materials could pose to the environment and especially to human health..  What is needed is a complete inventory of the specific radionuclides and their inherent radio-toxic characteristics and capabilities to do biological harm over specified periods of time.  To the best of my knowledge, no such complete analysis of the elements in so-called low and intermediate waste has been undertaken.  

We are told that nuclear reactor fuel waste will not be placed in this facility.  But this proposed repository could easily be a “Trojan Horse” for a full scale geological dump for “high-level” irradiated reactor fuel bundles, i.e., the really hot, lethal and incredibly nasty, radioactive stuff!  More about that in a moment.

While thinking about this issue, it is important to bear in mind that any amount of ionizing radiation increases cancer risks, as concluded by the U.S. National Academy of Science (NAS)  report on radiation risk, (Biological Effects of Ionizing Radiation).

When the Canadian Environmental Assessment Agency (CEAA)  issued its draft Environmental Impact Statement guidelines for this project for public comment, I raised several salient points in my response:

Why, I asked, was the deep underground repository option chosen?
    
 The explanation in the proponent’s (Ontario Power Authority’s) original proposal was that "The deep geologic repository is being pursued as the preferred technology because of its greater margin of safety."

 It seemed to me that the proponent must explain exactly why an underground facility of this kind would provide a greater margin of  safety than the alternatives identified in its proposal. I understand that some other countries  such as the Czech Republic and Australia favor near surface engineered facilities for containment and monitoring of low and intermediate level radioactive wastes.

 
Why would anyone want to construct such a site so near to one of the Great Lakes (Lake Huron)? 

Lake Huron is one of the major bodies of  fresh water in North America–part of the Great Lakes System.  I believe that the proponent should be required to demonstrate why such a facility is to be sited on the shores of this lake. It is possible that any leaking radioactive material from the repository could impact both Canadians and U.S. residents.

I requested that the proponent be required to give a detailed explanation as to why it did not seek an alternative inland underground site which would be clearly outside of the geological zone that could affect the Great Lakes, in order to completely avoid the possibility of radioactive contamination of the lakes.  There should be zero tolerance for the permanent geological  emplacement of any radioactive wastes in the Great Lakes basin.  It is simply common sense!
 
But the big question for me is: Could this project be eventually extended to accommodate nuclear fuel waste? 

The guideline must deal more directly with the question of the possible future expansion of the proposed facility to accommodate nuclear fuel waste. Simple verbal assurances from contemporary individuals and organizations are meaningless in view of the lengthy isolation time frames required for much radioactive waste and irradiated nuclear fuel waste..

The main questions I raised in my comments are:

Why did Canada’s (industry dominated) Nuclear Waste Management Organization (NWMO), in its final report in 2004, identify the types of rock formations which happen to be present at the proposed Bruce nuclear complex as being suitable for permanent underground storage of irradiated nuclear fuel waste?  Previously, granite rock of the Canadian Shield was considered the preferred host medium. 

Why is the limestone rock at the site considered suitable for any kind or level of radioactive waste, given the well-known connection between limestone and underground water sources?

Why, indeed, is this proposal for a radioactive waste repository on the shores of Lake Huron being contemplated at all?

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