Steed, Roger G.

Dear NWMO staff,

Further to my comments submitted on Sunday June 26, 2005 on reading "Choosing a Way Forward", the Draft Study Report, Having just completed reading the report, I would like to share the following comments with you:-

* On page 192, under the heading "Operations: Initial Fuel Receipt Phase", is the sentence "….the used fuel will require conversion in a processing building into a format appropriate for the long-term storage approach selected." I am not aware that that any irradiated fuel will require any conversion whatsoever. Please explain precisely what is meant by this sentence. Both 28-element and 37-element irradiated fuel bundles are perfectly happy to be stored in dry-storage canisters, so why would any conversion of the fuel itself be required?

* On page 199, in the first paragraph of Phase 3: Long-term containment, Isolation and Monitoring – Placement, the last sentence says, "Used fuel containers are assumed to be placed in the deeprepository over a 30-year operating period." I would suggest that the report needs to say that nuclear power is likely to continue in Canada, and therefore there will be irradiated fuel to look after far beyond the possible decommissioning of any fuel management options.

* Re page 227's Table 4-13, Does OPG include irradiated fuel produced by Bruce Power? One does get this impression from Table A7-1, but it would be useful to say so in the report's main body, rather than waiting to find it in an Appendix.

* Re Appendix 2, on page 240, at the end of the last paragraph of 1. Canadian Used Nuclear Fuel – Characteristics, the last sentence says, "At this stage, after about 18 months, the fuel is removed…." This is WRONG! Depending upon which part of a reactor's core the fuel is resident in, most fuel will be discharged from the reactor after between 6-9 months, or up to as much as 15 months, and very little will saty in the reactor as long as 18 months.

* Further in Appendix 2, the first paragraph on page 241's last sentence says, "After about one million years, the radioactivity in used fuel approaches that of natural uranium." This is WRONG! The gamma radiation from a fuel bundle which was discharged between only 200 and 500 years ago, will be of the same intensity as that emitted from freshly mined uranium ore. And John Sutherland, one of your highly qualified consultants, agrees with this!

* Finally, there are several errors in the listing at the bottom of page 276:- Point Lepreau GS is NOT in Musquash, but is at the tip of Point Lepreau. Gentilly 1 is not in Montreal, but rather is quite close to Trois Rivières.

I trust the foregoing comments will be helpful.

Roger G. Steed

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