Comments on Initial Project Description of Deep Geological Repository Proposal

Comments on Initial Project Description of Deep Geological Repository Proposal

Initial Product Description documents:

Nuclear Waste Management Organization (NWMO). Initial Project Description: Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project. December 2025, APM-REP-05000-0210-R000.

and

NWMO. Initial Project Description Plain Language Summary – English: Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project. December 2025. APM-REP-05000-0211-R000

Misleading assurances of safety in Initial Product Description (IPD)

The IPD and its summary document seem to be presenting the hopeful view of the nuclear industry in Canada regarding storage of used nuclear fuel. These documents describe the project as safe. However, the used nuclear fuel contains many toxic substances, including radioactive substances. Ionizing radiation can produce genetic mutations, cancer, and developmental problems. Evidence of harm from exposure of children to lead are found at very low levels of exposure. According to a presentation of IAAC and CNSC the DGR project would involve 5.9 million bundles of used nuclear fuel, which would remain radioactive for millions of years (Reference 1). There are many risks of exposures to toxic substances associated with the proposed DGR project. To describe this project as safe is not appropriate.

Need comparison of the risks of DGR proposal with the alternative option of continuing to keep waste at nuclear reactor sites

The risks associated with the DGR proposal should be compared to the risks from continuing to manage the waste at nuclear reactor sites. In addition other options could be considered.

Transportation should be included in risk evaluation

The risk assessment should include the risks associated with moving the nuclear waste to the proposed DGR. The amount of used nuclear fuel waste and the conditions on the transport routes make an accident during transport extremely probable. Consideration should be given to the risk of harm to the environment and people associated with transport, including emergency responders and health care workers. All of the communities along the transportation routes should be included in those informed and consulted about the proposed DGR. Because used nuclear fuel is much more dangerous than yellowcake, existing transportation rules might be inadequate for transport of used nuclear fuel.

Need full assessment of risk of contamination of environment

Impact assessment should include full evaluation of risk of contamination of groundwater, surface water, soil, and air. A full assessment of the risk to human health and the evironment is needed. The impact assessment should include effects classified as low or negligible risk in the IPD. The IPD does not present an adequate basis for excluding these things from the risk assessment.

The risk of contamination of groundwater and surface water should be fully evaluated.

Current geological faults in the region of the propose geological site are mentioned in the IPD. The process of excavation of the underground storage area apparently would involve use of explosives. What is the risk that additional faults would be created by construction techniques? Over long periods of time (hundreds of thousands of years) would the groundwater and surface water be contaminated with toxic substances from used nuclear fuel waste?

More information is needed on the proposed Used Fuel Packaging Plant. In addition, the impact assessment should include consideration of the risk of spills of toxic materials at the surface, and the mitigation needed.

Valued components should include groundwater near the earth’s surface and surface water.

Areas beyond the Township of Ignace and the Wabigoon Lake Ojibway Nation should be included in evaluations of risks to the environment and human health. The residents of these areas should have more opportunities to be informed and consulted about the DGR proposal. Of particular concern are locations downstream and downwind from the proposed DGR site.

Would the used nuclear fuel storage containers in the proposed DGR breakdown, and would this lead to toxic substances spreading into groundwater and surface water?

The environmental impact for thousands of years into the future should be evaluated. This includes considering the effects of climate change. What is the risk that precipitation and snow melt would cause flooding of the DGR? The proposal lacks adequate long-term monitoring.

If there is no way to retrieve the used nuclear waste from the DGR, then it seems likely that the risk of environmental contamination from the project would be greater.

Criteria for acceptable contamination following completion of proposed project

The level of risk to health and the environment that is considered acceptable following the proposed project should be described clearly in the impact assessment. The criteria for “safety” are not clear. Use of ALARA (As Low As Reasonably Achievable) could cause a substantial increased risk to human health and the environment from the project. Also, the health risks from the combined exposure to various toxic substances should be evaluated.

Concerns about building more nuclear reactors and the resulting nuclear waste

Before more reactors are licensed in Canada, the risks associated with them should be evaluated and compared with energy conservation, other methods of energy production, and energy storage options.

Another statement that appears to be misleading:

The summary of the IPD states on page i: “…the Wabigoon Lake Ojibway Nation (WLON), who have indicated that they are willing and informed hosts for the Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project…”

This statement does not match my understanding of the position of the Wabigoon Lake Ojibway Nation, which is that they are willing to give further consideration to the project.

Thank you for the opportunity to share my concerns,

Mary Carroll Chubb

(These comments were submitted on 2026-02-04.)

Reference

1. IAAC and CNSC. Integrated Impact Assessment of the Deep Geological Repository (DGR) for

Canada’s Used Nuclear Fuel Project (slides). Accessed at: iaac-aeic.gc.ca/050/documents/p88774/164674