SAVE OUR SAUGEEN SHORES, INC. (SOS)

CLOSING REMARKS SAVE OUR SAUGEEN SHORES, INC. (SOS) Prepared by Jill Taylor, President of Save Our Saugeen Shores, INC. And Rod McLeod, Director, Save Our Saugeen Shores, INC. In the Matter of Ontario Power Generation Inc. OPG s Deep Geological Repository (DGR) Kincardine, Ontario Project for Low and Intermediate Level Radioactive Waste To the Joint Review Panel October 9 2014

1.0 INTRODUCTION Save Our Saugeen Shores, INC. (SOS), appeared before the Joint Review Panel in October 2013 and September 2014. Our written and oral and written submissions may be found on the CNSC website, Oral Presentation September 18, 2014 (Written Submission 21 July, 2014 document 99619.pdf), and Oral Presentation Oct 1, 2023 (94530E.pdf). We summarize here our REASONS for unconditional objection to the licensing of a DGR for radioactive nuclear waste at the Bruce Nuclear Site. THE UNSUITABILITY OF THE BRUCE SITE: 1. Only one site considered: OPG defied reasonable principles of infrastructure planning and the EA Process when they decided that only the Bruce site would be considered for the construction of a DGR project. This was a significant project error. They initiated the project without knowing if the site was suitable for an underground repository from environmental, containment or geophysical standpoints. They were, however, well aware before project inception that the site had been identified as highly sensitive due to challenges faced in their ongoing work at the Bruce Nuclear facility. These known societal and environmental sensitivities included: that the site is situated within a highly populated area of municipal and rural inhabitants, increased seasonally by the addition of seasonal residents and tourists; that there is a highly significant First Nations presence; that economic stability is rooted in the safe, picturesque and pristine nature of the environs; that the construction of a DGR could significantly affect residential land value and traditional economy; that tourism and agricultural were the major economic drivers; that the site was environmentally hyper sensitive due to its location on the Lake Huron shore; that Lake Huron was an international boundary and waterway; and, that the site was severely constrained by its boundaries, size and encroaching power uses. They were also aware that Lake Huron is one of the largest fresh water lakes in the world, currently providing drinking water to 40 million people. 2. Once OPG made the decision to propose a DGR on the Bruce site, scientific, political and public willingness was contrived within narrow parameters to rationalize its selection and to create a reverse order environmental impact assessment methodology. 3. OPG has stated that the Bruce site is well suited to the DGR, and has found no likely significant adverse effect during its construction, operation, decommissioning or post closure periods. This conclusion was reached despite: the complexity of the project; the long schedule of pre closure (approximately 120 years); the proposed period of monitoring the site post closure or the million years afterward, during which time the radioactive waste, and other aspects of potential harm associated with the mine, are in a process of disintegration. 4. From the early 2000s to this year, numerous expert and non expert stakeholders have opposed the location of a DGR at the Bruce site. The record includes statements that have been well researched, and that provide ample evidence of likely adverse environmental, health and socio economic effects extending beyond the site, to the locality, to the region and to the United States. Evidence indicates that adverse effects could contribute significantly to the likely degradation of land, air and water contexts at all these levels. 5. In 2014, the JRP sought clarity in a comparison of the Bruce geology to granite geology. A comparative site analysis was provided by the IEG. This analysis served to further prove that Bruce site was unsuitable, by pointing the reader unintentionally to ways in which the Bruce site was flawed. By loosely comparing the site to a hypothetical granite site, the scientific, geotechnical and safety case assertions of the EIS for a limestone 2

repository next to the Lake provided more evidence that the Bruce site was unsuitable to the DGR. 6. Unsuitable Proximity to Water: The DGR design relies on dispersal into the Lake of significant quantities of construction water, drilling process water, above and below ground sediments from construction and run off from construction and storage areas. The likely significant adverse effects of contaminants, including radionuclides, on land, air, ground water and Lake were not sufficiently recognized by OPG; they refrained from adequately qualifying or quantifying the contaminants, or the duration and extent of contamination. Yet in the next breath, they asserted that contamination would be limited in extent to a local discharge location at the shore of the lake, but not to the lake itself. Their conclusion of no likely significant adverse effect is not wellreasoned, transparent nor rational. Multiple interveners described the manner in which contaminates could reach large areas of land, ground water and lake water at, and far beyond, the Bruce nuclear site. Insufficient analysis and lack of precautionary logic has been demonstrated at many times by OPG, but was done so dramatically during the 2014 Hearing on the issue of contaminants entering the Lake at maximum precipitation events: OPG testified that overflow and unplanned releases from the SWMP and ditches could not be addressed in times of maximum precipitation events, as the site was too small to allow the enlargement of the SWMP and ditch network. This is the prevailing attitude toward safety of the Lake and the significance of the DGR to its integrity. 7. Unsuitable Proximity to Water: potential contaminant migration through rock mass and breached shaft, air and aqueous transport to the Lake is described in the EIS and IEG Reports. Chapter 4 of IEG cautions that permeability through a continuously fractured stratum at the 180 m level can occur from the DGR and shaft. If contaminants escape this transmission could likely transfer under the Lake, and then through vertical passage, reach the Lake bottom and water, causing dispersal of material into the Lake from the DGR. 8. Unsuitable Proximity to Water: the DGR site will require new above ground storage (short and long term) for radioactive packages from the Bruce and other sites, waiting for emplacement. The addition of these waste packages, as per the revised DGR plan for acceptance of Decommissioning Waste from other sites, increases significantly the potential for contamination of Lake and ground water during handling, and breach through accidental of malevolent means. The period of additional risk spans approximately 100 years. This has not been accounted for. 9. Unsuitable Size of the Site: the site is unsuitable due to its size, which is dramatically constrained above and below ground by existing legal boundaries, roads, natural features, by power and nuclear waste holding facilities. The WWMF, the nuclear reactors, public and worker road access, security buffers, lake buffers, the transmission grid and other factors constrain the current design and its expansion above and below grade. Graphic depictions of the DGR boundary are not accurate to survey plans; the expansion of the DGR and the decision to have only two entry/exit points to the DGR are the result of site constraints. This is evidence that the DGR is constrained by a site that is unsuitable. 10. Unproven and Potentially Unsuitable Geology of the Site: only 2 boreholes have been undertaken to the repository level on the site, and 6 boreholes have been drilled off site. A clay containing, argillaceous limestone strata will be laterally blasted to create the circulation system and 32 or 64 emplacement rooms at the 680 metre level below grade; under that layer, the composition of the rock is unsuitable for construction of the DGR, but must accommodate shafts, ramps and circulation paths. According to the 2 boreholes, the host Cobourg layer is only about 25 metres deep. The continuity of the geosphere barrier above has not been proven. There is a considerable amount of the barrier that contains shale with up to 17% petroleum; there are horizontal 3

fractures or deteriorated layers from grade to the 180 metre below grade level. Many interveners, including professionals and experts in the field, have questioned the suitability of the geology in the short or long term to accommodate the DGR at this location. The Town of Saugeen Shores has been disqualified as a DGR site due in part to insufficiency of barrier depth. International expertise and ongoing DGR construction in northern Europe points to granite hosts as the most suitable for DGR construction and the reality is that this design in limestone is entirely experimental. The geo scientific verification plan of 2014 is based on: 2 relevant boreholes; desk top surveys; modelling; on promises to develop more accurate information during construction, and to, in future, establish trigger and mitigation values for all stages of below grade construction and operation. In summary, the geo scientific plan lacks detail and has not been well scoped for this site, despite the fact that OPG has had 10 years to provide verification of the geology for the DGR. 11. Proximity to Resident and Seasonal Population: the DGR would be approximately 12 km from the Town of Kincardine and 12 km from the Town of Saugeen Shores; it would be closer to the Towns and Settlements of North Bruce, Brucedale, Underwood, Tiverton, Inverhuron and others, including the rural community; it is not distant from other Towns or Townships inland and on the coast. The populations of the locality and region swell dramatically from set values, with seasonal visitors who stay for long periods as property owners, tenants, migrant farm workers, and tourist visitors. The population of the vicinity should be described as significant. 12. Proximity to Adverse Effects of Climate (normal and adverse): the site is surrounded by the Lake on three sides, and is exposed to extreme weather events and harsh seasonal weather. No understanding of the true effect of current, short or long term future climate on the proposed DGR was demonstrated by OPG in the reporting, or during the Hearings. 13. Unsuitable Number of Unknowns on the Site: stated unknowns include, but were not limited to: geo science for construction purposes (for the purpose of drilling for the shafts, for the emplacement rooms, in relation to water inflow; in relation to gas and microbial activity; in relation to expansion post completion of Phase 1, etc.); geospheric barrier integrity ; the final design area of the project above and below ground; the amount of waste that had to be accommodated on the site in the long term; and the effects of future climate change in normal and adverse conditions. UNSUITABLE DEFINITION AND ANALYSIS OF SIGNIFICANCE OF ADVERSE EFFECT 1. OPG has been scant in their descriptions of the defined VECs, has used only the barest assumptions in planning for construction and operation, and has limited the extent of predicted measurable change in a way that does not meet the criteria of a comprehensive EA. In some responses, particularly those that extend beyond the surface level of their site, they ignore obvious effects, or undervalue effects. They use FEARO 1994 as a blunt instrument to examine potential change on land, air, water, and life forms. The FEARO definitions are old, are limiting and should not have been used alone in a project of such scale, complexity and duration especially given today s more acute state of impact assessment, and in the emerging values of our future. In 2014, Panel requested that in addition to the self prescribed definitions, that OPG be reasoned, transparent, demonstrate the precautionary principle, and that they take the 2013 critique of their EIS by Dr. Duinker into consideration. OPG, having now finished their work with no measurable change in attitude or substance, describes its narratives as reasoned and compliant in order to slide to the predetermined outcome. Their work is flawed, as is their process; thus, and despite their own assertions of no likely significant effect, they have reached the wrong conclusion. 4

2. Cumulative effect is described in the requirements of the Assessment to be incorporated into analysis of adverse effect. The results of robust cumulative effects analysis in determination of significance of effect is absent from the OPG work. 3. Consultation on significance is a key component of significance analysis in the EA Process (Duinker, 1983). As demonstrated by the submissions by interveners, and countless other reports, the OPG work did not demonstrate focus on the VECs that were important to the immediate community or larger region, nor did they take advice, or properly ask for it, in determining significance of effect to the stakeholders who would be influenced most profoundly by the DGR. This lack of consultation is inexcusable; and, so was the contrived and illegal context in which the OPG with NWMO and CNSC, met with the County of Bruce elected officials over a 7 year period, to manufacture consent through payment in lieu of proper adherence to the EA consultation process. FLAWED PROCESS (2004 2014): 1. General: It was unsuitable from a methodological and planning standpoint to consider only one location for the site of the DGR from project inception. To further impact a flawed process, or as a result of it, the process of scientifically investigating the suitability of the site was based on limited parameters. Then, that information was used to bolster the choice of the pre determined location. The method of establishing significance of adverse effect was biased and unreliable. After 10 years of study, the 2013 Hearings did not produce adequate evidence for the Panel to decide if the DGR was viable, or if effects were not significantly adverse such that the project should be licensed. In early 2014, a combination of revelations of insubstantial radionuclide inventory reporting, the requirement to open up the body of reporting to include the doubling in size of the DGR for decommissioning waste, plus the emergencies at the WIPP site, contributed to the requirement by the Panel to re open the Hearings and to hear new evidence. This continued questioning points to the overpowering flaws in process that have worsened in degree since the project was initiated by OPG. The 2014 Hearings and substantial reporting produced by OPG and CNSC have still not adequately explained the plan that had been developed for the DGR, its back up or the reasoning of decisions. Although the Hearings of 2014 period were to present a more resolved risk assessment, and to explain fundamental questions relating to the EIS, the questions asked by the Panel and public were not all answered, answered indefinitely, or unacceptably, leaving an unacceptable number of key aspects of projects as unknown, or for future development. 2. Public willingness was a process requirement of the DGR acceptance. Public willingness was reported by OPG to have been achieved, based on scant polling within an insufficient geographic extent. However, as described later in our closing remarks, public willingness was never achieved. Telephone polling was deliberately based on a majority of individuals who had connections to the nuclear or power industries, on household rather than individual support; and, in addition, questions asked on the telephone and in writing were leading. 3. Distribution of information, holding media briefings and consultation were to be part of the process. There was unreasonable bias using incorrect or inconclusive evidence presented to the public before and after the completion of the EIS. There was manipulation of the print media through contracts to advertise, there was false advertising and reporting. There were OPG meetings with public employees, elected officials, the general public and NGOs where information was communicated that was not accurate or truthful. Information packages were provided to the public in print and on line, as well as to and through the public health departments and municipal and county governments, that were based on false and misleading information about: the quality and quantity of radioactive material, the techniques of construction and duration of the construction, the adverse 5

effects of the pre closure and post closure periods. Other examples of false information included implied endorsement from agencies that had not been consulted, such as the United Nations (DGR website, until September 2014). 4. The Observational Method of approach to planning and construction is the cornerstone of the OPG design and implementation process, but is not well suited to a project where: trust has been eroded, where there are an unfathomable number of unknown factors and hundreds of years of work that lie ahead. This is not, contrary to what OPG has assured us, a project that is similar to others: it is entirely experimental. In addition to being experimental the following unknown factors remain in addition to those mentioned above: the rock mass quality; the ground water inflow; the excavation deformation; the rock loading; the geo mechanical qualities ; the in situ stress and rock pillar integrity and response; the waste inventory, the integrity of the Cobourg formation for lateral blasting. Managing risks as they occur should not be the only basis of this project because the consequence of being wrong is so high. Despite requests from the Panel, triggers for change were not well described, and the ultimate requirement for a project exit plan is non existent. It is obvious that couching process description in the observational method is a way of saying that they cannot proceed with confidence because there are so many unknowns. The project should be rejected based on insufficient description of project plan and method, and the low probability of success. 5. Changing Parameters of Subject and Design: the ability to be open or predictive is part of a good process, but has not been demonstrated by the proponent. In fact, the project has changed so many times from 2004 14 that it has been difficult for OPG to match the most recent project subject and design to the requirements of assessment, or to link consultant reports to current presented material. Initial predictions of waste quantity, quality and project extent have been multiplied more times than is easy to calculate. Consultant reports on community acceptance, calculations of inventory, understanding of boundaries and changes to context are no longer accurate to 2014 descriptions. This is a fatal character flaw in projects that rely on extreme accuracy. There is a sense that everyone has lost track of what is happening; this lack of diligence and precision at this final licensing stage is anathema to the creation of an efficient and compliant design for the DGR. The unknowns and complex web of indefinite answers will lead to continual change during the design stage, and then fundamental changes to site plan that has been presented to the Panel. The extent of change cannot be anticipated, but will be required to meet the yet uncharted mandate of waste accommodation. At some point, the design will be impacted so significantly that it will be unrecognizable to the 2014 Panel. OPG s flagrant manipulation of site survey plans and boundaries to suit their plans, rather than recognizing boundaries and site parameters for what they are, is more than a signal that the project is in trouble. The lack of foresight and reluctance of the proponent to recognize changing project parameters as a roadblock to viability is a signal of another reason why a license should not be granted. 6. Project Precedents are not Reliable and the Culture is not Open: Key among the assurances made during the process of contact with the public was that the plans for the DGR were based on models in Europe and the United States that were proven to be successful. In fact, these assurances were false, as has been described in numerous intervener presentations, and underground repositories noted have been found to be defective, not in the same type of geologic formation, of shallow construction, or smaller size or for other types of waste. In addition, and in a substantive development the WIPP facility has been the subject of two very serious accidents that have caused its closure from February 2014 for an indefinite period of time. In a further defensive, but not suitable behavior, in discussions on the failures at WIPP, the CNSC and the OPG described poor safety culture as the cause of failure, and limited their discussion in a way that tangibly presented the reluctance of the authorities to recognize flaws in their own reasoning and culture. 6

7. Adversity of Effect is consistently Under Valued: Health and environmental effects that are adverse or significantly adverse have been underplayed since 2004. Under valuing short and long term health effects is one example of many where OPG has failed to account for cumulative effect, true degree of adverse significance, and has demonstrated a shallow response. There was no accurate reporting from OPG or the County of Bruce Health Department of the rates of cancers associated with nuclear hazard to use as a baseline for future prediction. There has been no attempt to account for or measure the degree to which the ILW radioactive hazard (some of which has the same degree of hazard as HLW), will impact workers or the public within a reasonably defined regional study area, during normal and abnormal conditions, or over a period of time greater than one hour. Neither have current negative effects of nuclear plant emissions and process been reported on to establish a baseline for effect of future effects. Environmental emissions from the predicted decades of construction do not adequately factor in aqueous and airborne transfer of vast amounts of crushed limestone, limestone pieces, bacteria, nitrates, radon and other gasses during construction, placement, trucking. There is not sufficient predictive modelling to convince of effect, nor is the quantity or quality of emissions known. These are examples of fundamental flaws in process the result in undervaluing health and environmental safety. Such analysis should be reliable and should be predicted accurately BEFORE, not during (over possibly 30 years) or after the project has been completed, in order to judge from the public standpoint, the health and environmental effects of the project. 8. Insufficient Accounting of Degradation: We can use another example of insufficiency of valuation of effect where it relates to air quality degradation. This example of flawed logic, has been brought to attention numerous times by interveners, but has been sidelined as of insignificant effect by OPG, who argue that the DGR project is no different than other construction projects, or at least, no different from the construction of a dam or mine in a populated area. Contrary to the OPG assertion that this is a normal construction project, we point out that there is usually a critical peak in air quality degradation in construction projects that tapers off after completion of demolition and/or earth removal and foundation placement. The construction of the DGR is not a typical construction project. It involves potentially 3 periods of 6 10 years of excavation and rock and soils removal and trucking, prior to placement at the waste rock management area. The work goes on 24 hours a day, 7 days a week. There is no clarity of the impact cumulatively of the activities on site that will degrade air quality, create noise, traffic or safety, during that potentially thirty year period. There is little emphasis placed on the work that would degrade air at the work site, or the surrounds during storage and emplacement of waste, or the tracking of the demolition and decommissioning of the Bruce buildings and reactors themselves in the later lifetime of the DGR. The effect of particulate and toxins in air is not qualified or quantified; the effect of adverse weather on the movement of particulate is not quantified; the location of the particulate drift over air and water to remote areas is not quantified. Therefore, duration, extent, quantity and quality of air degradation has not been adequately assessed. Without this assessment, which under any circumstances could be presumed to be frequent, long lived and consequential, the assessment of no residual significant effect on air quality is incorrect. 9. Lack of Depth in Analysis and Narrow Focus of EIS Sections: There is lack of depth in analysis of impact during the construction, emplacement or post closure phase of the DGR that is blatant in some key examples, and less noticeable in others. The section from 2014 on Malevolent Acts (4.3) highlights the inconsistency of analysis of unplanned events, their impact through the risk analysis process. For example, the consequences of aircraft crash, military attack and explosion are described as malevolent acts. The OPG analysis indicates that the consequence of such acts would be limited to the waste packages that it directly affects. The section concludes that the subject waste is not combustible, and that public exposure (to the aircraft crash or explosion) would be limited. That exposure (radioactivity only) was quantified as follows: to a person at the nearest site boundary from detonation of explosives, around the annual natural background dose of 2 msv. This OPG narrative cannot stand as a professional impact analysis of an aircraft crash or malevolent explosion at the Bruce nuclear site. Why is the focus so narrow of the writer so narrow, and does it indicate a fundamental misjudgement of other risks associated with impact? The answer is yes, and the evidence is breathtaking. 7

10. If acceptance of the DGR proposal is supposed to be based on trust, trust has been eroded at the level of attitude, competence, diligence, transparency and process. Assessment of the trust that would be necessary to proceed is at the root of a project that relies on an Observational Method. Trust has been lost based on: the lack of diligence in understanding the local and regional context; the manipulation of our politicians; the lack of transparency about how residual adverse effect was calculated and interpreted. 11. Under valuing of Cultural and Socio Economic impacts including marginalization of people, real property and association with the land, cultural landscape, traditional beliefs, well being and the healthy primary economic base of agriculture and tourism. 12. Transparency and ability to repeat decision process and arrive at the same conclusion: multiple third party reviewers were unable to understand how the conclusion of no significant adverse effect was reached. The narrative was not transparent, the decision trees were not followed consistently, or to the end of logical thought process, therefore the work was not credible, defensible, clear, or reliable. The third party reader will never know how many logically imagined similar scenarios would be rated (not a transparent method/not clear in terms of decision trees), or how the decision, not significant was established. OPG has written their scenarios to meet the requirement of what they judge to be the least significant outcome of an adverse residual effect. That is how they reach the above conclusion of no significant effect, on any of the VECs. 13. Ignoring Follow on Implications on the Placement of HLW in Bruce County is Perilous: the process of cumulative effects analysis, precaution and truthfulness should have involved the discussion of the reasonable potential for a second DGR to be built in Bruce County in the foreseeable future, and, or to ask the question again, will the DGR 1 eventually host the HLW? Also, if the DGR Phase 1 for L &ILW is built, and if decommissioned waste is brought to the WWMF in 2040, and if that waste begins to be put into the Phase 1 project, will that waste take priority over LLW (mops and rags) produced at Bruce, from that time forward? If so, between 2040 and 2060, will the DGR1 be filled, and then another 2 panels required, just to accommodate the ongoing and stored waste from Bruce, and the decommissioning of Bruce A and B? Will there then be LLW left on the surface in perpetuity? Was this the plan all along? And, what has happened to the HLW at Bruce? If no solution to HLW is found, will we find Pickering and Darlington stuffed down our DGR, with the HLW still standing around with the LLW waiting for a home? These questions have not been answered, but the ones that have indicate lack of planning resulting in inevitable significant adverse effects and high risk in a project that has no exit plan. Therefore the plan to consider a full or half size DGR for L&ILW prior to a master plan for all of the waste in the country being established, including the serious and innovative consideration of alternative means of recycling or secure hardened storage of waste in a less adverse manner, should be implemented immediately. No license granted should be granted to any storage repository at this location, and no license should be considered again prior to rethinking the plan for storage from the current day forward. 14. OPG did not address internationally accepted interpretations of the precautionary principle, and most importantly since 2004 has never answered the question, what is the consequence of being wrong QUALITATIVE RISK COMPARISON AMONG FOUR ALTERNATE MEANS FOR MANAGING THE STORAGE AND DISPOSAL OF LOW AND INTERMEDIATE LEVEL RADIOACTIVE WASTE IN ONTARIO (IEG REPORT, MARCH 25, 2014) 1. In order to comparatively review multiple options for storage and deep burial of nuclear waste, the Panel asked OPG to commission an independent study to be conducted by experts in science and risk assessment, to look at 8

four options. The assumption was that these options would operate indefinitely, and hold 200,000m3 of packaged volume of L&ILW. The IEG were NOT asked to evaluate the risk of an over doubled size of an expanded DGR at the WWMF or in granite. Their base case was the 200,000 cubic metre volume facility. 2. The four options were: Status Quo Storage Above Ground at the Bruce; Enhanced Storage at the Bruce, a DGR at the WWMF, and a conceptual DGR in granite (near a lake). Only the DGR at the WWMF and the Status Quo, have known or studied characteristics, so the mere imagining of the enhanced storage option and the granite DGR option (despite the experience of DGRs in granite in Europe, and decades of mining experience in the Canadian Shield), contributed to the difficulty of IEG reaching a conclusion that would carry weight in comparative assessment. 3. What their examination did do was to pose a situation that has not been posed before: to look at flaws in the WWMF site, as well as advantages, in comparison to a granite host. The Summary of Differences provides ample proof that the limestone DGR at the WWMF is not suitable due to its properties. DEFICIENCIES IN THE OPG/IEG RELATIVE RISK ANALYSIS OF COMMUNITY ACCEPTANCE OPG s retained expert, IEG, and therefore OPG, did a very poor job in response to the Panel s request for a relative risk analysis of the community acceptance factor. The response to the Panel s request discloses multiple errors and omissions as summarized below: 1. They failed to do any analysis of the other three alternative sites/means. 2. They missed obvious defects in earlier reports/surveys despite ample evidence of those defects in earlier JRP submissions. See, for example, our SOS Oral Presentation (September 18, 2014) Slides 2 to 6, detailing the several errors in the OPG/IEG reliance on the 2003 Intellipulse Report, and Slides 9 and 10 exposing the defects in the Kincardine Survey. 3. OPG/IEG either failed or refused to consider the potentially game changing effect on community acceptance of the fact that the Mayors support was bought with OPG s 2004 Cash for Support Hosting Agreement. This was especially so when those Mayors (and every one else except OPG) had every right to believe that by accepting cash, they were at least saving themselves from any prospect of being asked to host high level waste because it was going to Northern Ontario. It was only much later when they had already spent the cash that they learned, not so. 4. Accordingly, IEG failed or refused to acknowledge the possible need to discount the Mayor s evidence of support because it was bought. 5. OPG/IEG failed to make the effort to review the 2013 submissions of the Bluewater Coalition. Those submissions would have alerted them not only to many of the report/survey defects referred to above, but to the fact the Mayors support and testimony was developed and refined in a series of what have now been found to be unlawful meetings. 9

6. Equally, they failed or refused to pay attention to the OPG notes of the unlawful Bruce County Council Meetings where the future testimony to the JRP was conceived, prepared and polished, by OPG. 7. The so called expert analysis by IEG was anything but an independent expert report. It was obviously slanted in favour of OPG s proponecy for DGR 1 at Kincardine and therefore not independent. The errors and omissions were of a number and magnitude as to suggest it was anything but expert. IN CLOSING Save Our Saugeen Shores believes, in the strongest terms, that the OPG justification for siting a DGR for radioactive nuclear waste at the Bruce site is unsupportable, is based on flawed process and logic, has relied on contrived and unlawful means of support, and should be rejected. end 10