Transportation Omission from the IPD

1.Transportation Omission from the IPD 

      A fundamental issue requiring review is the explicit exclusion of transportation impacts from the current IPD. The document does not adequately address the implications of moving radioactive waste from existing reactor sites to the proposed Deep Geological Repository (DGR), despite transport average distances of  1,800 km across multiple regions.

This omission is procedurally and substantively significant. Transportation of high-level nuclear waste introduces a distinct and non-trivial set of impacts, including:

• public and occupational health risks,
• accident and emergency-response scenarios,
• security and safeguarding concerns,
• cumulative impacts on communities and ecosystems along transport corridors,

By excluding transportation, the IPD artificially narrows the project boundary, presenting the DGR as a site-specific intervention rather than a national-scale infrastructure system. Transportation is an integral and inseparable component of DGR operations: without the transport of spent nuclear fuel to the repository, there is no functional DGR project. According to statements by the NWMO, DGR operations would involve approximately 2 to 3 transport loads per day or similar timeline for rail/truck shipments for a period of 50 to 60 years, representing a sustained, long-duration transportation program rather than an exceptional or temporary activity. Conversely, there is no justification for transportation in the absence of an operational DGR. Treating these elements as separate or sequential misrepresents the project’s true scope and operational reality. This fragmented framing materially understates total project impact and prevents meaningful assessment of risk distribution across space and population.

The necessity of transporting waste over such distances also raises questions of consent and equity for communities far removed from both the waste generation and its final disposal yet nonetheless exposed to associated risks.

A full Impact Assessment is therefore required to:

• formally include transportation as an integral component of the project,
• evaluate alternative routing, modes, and timing scenarios,
• assess cumulative and cross-jurisdictional impacts,
• and enable public deliberation with all potentially affected communities.

Final Recommendation

Based on the IPD’s own description of scope, impact, and public relevance, it is requested  that the IM agency:

1. Designate a full Impact Assessment including transportation, addressing environmental, social, institutional, and cumulative effects through defined indicators and comparative scenarios.
2. Convene a public debate, structured as a deliberative process rather than informational consultation.
3. Include a panel of independent experts and stakeholders to ensure plural evaluation, transparency, and procedural legitimacy.

2. The Project Functions as a System Implementation

Systems engineering defines a system as a combination of interacting elements organized to achieve one or more stated purposes. In  practice, safety must be demonstrated at the level of the system that delivers the intended function, not merely at the level of individual components. The stated purpose of the proposed project is the emplacement of used nuclear fuel bundles into repository cavities for long-term isolation.

Transportation and the deep geological repository are therefore functionally interdependent elements organized to achieve a single purpose. The repository cannot emplace fuel without transportation, and transportation has no independent safety purpose absent the repository. Together, they constitute an integrated system whose safety and reliability must be assessed on a system-wide basis.

In accordance with paragraph 22(1)(a) of the Impact Assessment Act, which directs that an impact assessment take into account a project’s effects “including any cumulative effects that are likely to result from the project in combination with other physical activities”, the integrated nature of transportation and repository activities supports assessing the undertaking as a whole rather than as isolated components. 

After more than 45 years in the telecommunications industry, encompassing the introduction of products to the consumer market and large infrastructure systems, and informed by leadership of large, multidisciplinary engineering organizations, I learned that approval of safety-critical systems requires evaluation of the complete system rather than isolated components.  Individual components may satisfy standalone requirements; however, such compliance does not ensure that the integrated system will perform safely or reliably under operational and abnormal conditions.

Even if the proponent characterizes transportation and the repository as separate subsystems, the DGR components and the transportation of spent fuel operate together as an integrated system that provides a capability neither can accomplish independently. Consequently, safety and reliability assessments must account for adverse scenarios that arise from cross-subsystem interactions rather than isolated component failures. Transportation introduces precisely such interactions, including route-dependent conditions, mode transfers, cumulative operations over extended timeframes, variability in emergency response capabilities, and corridor-wide public exposure. These factors directly influence overall system risk and therefore cannot be excluded from a comprehensive safety case.

Given that transportation and the deep geological repository function together as an integrated system, it is respectfully requested that the Impact Assessment Agency of Canada consider a full impact assessment which includes transportation in order to evaluate safety, environmental, and societal effects at the system level rather than in isolation. Assessments limited to individual components or activities may not fully capture effects that arise from interactions between subsystems, cumulative operations over extended timeframes, or variability in operating and emergency-response conditions.

3. Misleading Framing of Intergenerational Responsibility

The NWMO states in the IPD  that the current generation has benefited from nuclear-generated electricity and therefore has a responsibility to solve the associated waste problem now, rather than leaving it to future generations. While this framing appears ethically compelling, it is materially misleading.

Future generations in Canada will still be required to address the unresolved consequences of today’s nuclear system. In addition to managing the proposed DGR over multiple generations, they will also face the far more significant and costly task of decommissioning the existing nuclear reactor fleet, with major decommissioning activities expected to occur around the 2060 timeframe.

As a result, the proposed project does not eliminate intergenerational burden. Instead, it adds a new, permanent responsibility—the long-term management of a DGR—on top of the already unavoidable obligation to decommission aging reactors. In addition, the  project deprives them of the ability to exercise responsible stewardship by emplacing the waste in a DGR that prevents meaningful monitoring and would require complex, risky, and prohibitively expensive retrieval if problems were to occur.This compounds, rather than resolves, the challenges transferred to future generations.

Framing the project as one that relieves future generations of responsibility obscures this reality. Future Canadians will be required to manage:

• the long-term operation and monitoring of the proposed DGR,

• any future DGRs necessitated by continued nuclear expansion,

• and the decommissioning, remediation, and long-term stewardship of the current reactor fleet. 

Therefore  claims of urgency,claims of solving the problem,and claims of intergenerational closure are not supported by the project scope .Consequently, there is no demonstrated need to rush implementation of the proposed DGR as framed in the IPD .  Therefore,,timing of the project should not be a given but one that considers all the inputs to make an informed decision. 

For the reasons listed above,I am requesting the Impact Assessment agency designate that this project must have a fullI Impact Assessment including the question on timing and a public hearing 

4 Incomplete Treatment of Nuclear Waste Volumes

A fundamental deficiency of the Integrated Project Description (IPD) is its incomplete and artificially constrained treatment of the spent nuclear fuel waste inventory. The IPD limits its assessment to approximately 5.9 million bundles of spent nuclear fuel, representing waste generated by the existing reactor fleet up to a defined cutoff point.

This framing excludes the additional spent fuel that will be generated by planned and underway nuclear new-build facilities that are already part of Canada’s energy strategy. By omitting these sources, the IPD presents the waste challenge as bounded and finite, when it is open-ended and expanding.

The IPD states that this volume limit reflects the quantities agreed to in existing hosting agreements with the Wabigoon Lake Ojibway Nation and the Township of Ignace. While these agreements are relevant to matters of consent and authorization, the requirements for the content and scope of the IPD are defined by the Impact Assessment Agency of Canada (IAAC), not by contractual arrangements or community agreements. IAAC guidance requires that the IPD describe the project in sufficient detail to enable assessment of all reasonably foreseeable project-related effects. Limiting the assessed waste inventory to volumes reflected in hosting agreements therefore represents a proponent-defined constraint that is inconsistent with IAAC’s requirements for a complete and forward-looking project description.

Additional spent fuel arising from reactor life extensions, approved or planned nuclear new-build projects, and related policy commitments is reasonably foreseeable. Excluding these waste streams from assessment results in a partial and misleading characterization of the problem the project is intended to address. By defining the assessed waste inventory solely by reference to current hosting agreement limits, the IPD conflates consent mechanisms with analytical requirements and excludes foreseeable future conditions from consideration.

The IPD relies on NWMO’s Choosing a Way Forward document, which states that four alternative approaches for managing Canada’s spent nuclear fuel were reviewed and that Adaptive Phased Management was recommended to the federal government as the preferred approach because it allows for phased implementation and adaptation to new information, experience, and changing societal values over time. However, where this rationale is invoked within the IPD, adaptability cannot be used to justify an incomplete definition of the waste inventory or the deferral of assessment of reasonably foreseeable long-term impacts. A disposal system cannot be meaningfully described as adaptive unless the full scope of the problem it is intended to address is clearly defined.

This constrained approach has significant implications. By assessing only a partial inventory of spent fuel, the IPD risks:

• underestimating repository capacity requirements and thermal loading;

• understating long-term monitoring, containment, and stewardship obligations;

• obscuring cumulative environmental, social, and intergenerational impacts; and

• precluding meaningful evaluation of how repository performance may be affected under expanded waste scenarios.

Moreover, the IPD does not adequately assess the mitigation measures that would be required to manage an expanded waste burden, nor does it evaluate their effectiveness, feasibility, or long-term performance across the full lifecycle of the project. As a result, the IPD fails to represent the complete consequences of Canada’s ongoing and reasonably foreseeable nuclear waste generation.

A full impact assessment is therefore required to determine whether the project scope must be redefined to include all reasonably foreseeable spent nuclear fuel waste streams, rather than being limited to a snapshot defined by current contractual arrangements that do not reflect planned future conditions or the long-term purpose of the proposed repository.

5 Section 22 of the Impact Assessment Act 

Under section 22 of the Impact Assessment Act, the purpose of an Initial Project Description is to support the identification and assessment of project-specific effects, mitigation measures, and sustainability considerations.  Multiple statements contained within the IPD, characterizing nuclear energy as clean, low-carbon, or essential to achieving net-zero emissions do not assist in assessing the environmental, health, social, or Indigenous impacts of the proposed waste management project. Nor are such statements necessary to evaluate the Project’s own greenhouse gas emissions or climate resilience. Accordingly, this information does not contribute to meeting the purpose of an Initial Project Description as set out in section 22, and reflects normative or policy-based opinion rather than the factual, project-specific information the public should reasonably expect to be presented at this stage of the assessment process. Its inclusion risks introducing policy advocacy into a process that is intended to be neutral, evidence-based, and effects-focused.

 Therefore ,the IPD functions not only as a waste management proposal but also as an Implicit endorsement of nuclear energy's role in Canada's  climate and energy policy . This creates a tension between the NWMO's stated mandate and the broader policy framing used to justify the project and goes beyond what is the impact to the environment people's health  and the steps to migrate the impact . 

Recommend that the IPD be rewritten to remove any wording that reflects any policy based opinion 

6.

The timing of the proposed Deep Geological Repository (DGR) project requires formal review. The Impact Project Document (IPD) advances implementation based on urgency yet does not demonstrate that delaying the project would increase risk to public health, safety, or the environment.

Existing on-site and interim storage facilities are widely recognized as capable of safely managing spent nuclear fuel for several decades, on the order of 50 years or more. This available capacity provides temporal flexibility and undermines claims that immediate implementation of a DGR is necessary to address an imminent risk.

At present, there is no operating Deep Geological Repository for spent nuclear fuel anywhere in the world. The proposed project therefore relies heavily on predictive modelling and theoretical performance assessments that cannot yet be validated through real-world operational experience. Proceeding in the absence of such evidence risks locking Canada into a long-term system based on untested assumptions with multi-generational consequences.

The proposed DGR, as defined in the IPD, is limited to the management of spent fuel from the existing nuclear reactor fleet. It does not resolve reactor decommissioning, does not account for spent fuel arising from already planned nuclear expansion, and does not eliminate the long-term stewardship obligations that will continue to fall on future generations. Implementing the proposed DGR therefore does not eliminate the nuclear waste problem for future generations; it addresses only one component of a much broader and ongoing challenge.

Economic, Scope, and Public-Interest Considerations

The timing of the project also warrants review on economic and affordability grounds. Ontario Power Generation has recently sought approval for significantly higher payments for nuclear-generated electricity, reflecting rising capital costs associated with reactor refurbishments and new nuclear construction. These developments indicate that the nuclear system is entering a prolonged period of intense capital expenditure with direct implications for electricity rates, industrial competitiveness, and public finances.

The NWMO has estimated the cost of the proposed spent-fuel DGR to exceed $25 billion, representing a major capital obligation layered onto an already capital-intensive nuclear program. This estimate also does not include the cost of a separate Deep Geological Repository for low- and intermediate-level radioactive waste, which has already been proposed and approved by the federal government. Nor does it reflect the cost implications of planned nuclear expansion, which is projected to add generating capacity equal to or greater than the existing reactor fleet and will generate additional spent fuel waste beyond the limits assessed in the IPD.

As a result, the financial scale of the nuclear waste management system is systematically understated. Proceeding rapidly with DGR implementation risks locking in under-scoped costs that may ultimately be borne by electricity ratepayers or transferred to taxpayers through subsidies or public debt.

Taken together, the absence of demonstrated urgency, the availability of safe interim storage, the lack of operating experience, the exclusion of foreseeable future waste streams, and the escalating cost pressures on the electricity system all reinforce the need to treat timing as a decision variable rather than an assumed necessity. A formal full impact assessment should explicitly consider alternatives such as deferral, phased implementation, or conditional progression tied to demonstrated need, operational evidence, affordability, and the public interest.