Goodwin, Bruce

I offer the following comments on the NWMO draft report, 'Choosing a way forward', recognizing that they are very late, and perhaps too late to consider in your final deliberations. I had better intentions but poorer resolve.

1. The various options would benefit from more rounded and complete analyses to avoid negative comments that are based on 'apples and oranges' arguments. One important example that bears on risk is the identification and analysis of scenarios. The different options have different scenarios in terms of their qualitative description, probability of occurrence and/or consequences. Consider, for instance, a scenario we might call 'incomplete closure'. Its qualitative description and consequences might be similar for an option involving interim storageversus immediate disposal, but their probabilities are considerably different. Because the identification of scenarios is incomplete, your estimates of risk are seriously flawed.

2.The recommended option, which combines shallow underground storage and deep geological disposal, might impede efforts to find a suitable site that provides adequate protection for both facilities. It might lead to sub-optimal design or to a defected site and should be another factor that is considered in your deliberations.

3. The illustrative timeline (in the executive summary) is far too long, especially when compared with the progress now occurring in other countries (e.g. US and Finland). It is not clear how the recommended approach will (for example) promote "continuous learning", and why we need to allow for centuries ofretrievability. It appears that the major benefit of a long time line is to defer any actions or decisions that might raise public concerns.

4. Finally, the studies done in the last millennium were, admittedly, focused on the science and technology. The Panel awarded a passing grade to the science but gave a failure to the public acceptance. In this report, the pendulum has swung to deal almost exclusively with societal issues. In my view, the science is weak to sloppy and public acceptance could be acceptable but only because it defers indefinitely any significant decision making. I had hoped for a more constructive road forward.

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