NWMO Nuclear Waste Transportation and Burial

Our organization is writing to express concern about the Nuclear Waste Management Organization’s proposed deep geological repository for nuclear fuel waste which the NWMO is proposing to construct and operate between Ignace and Dryden in northwestern Ontario.

The Lake Superior Watershed Conservancy has many concerns about the project and the site selection process, but our comments are mainly focused on the Impact Assessment review process which began on January 5^th of this year.  We are mainly addressing the NWMO’s initial project description.

Given the enormity of this project’s impact not only on today’s environment, today’s human and other-than-human population, today’s biodiversity, today’s health impacts, today’s communities, but also the potential impacts on the far distant future of generations of all life, the 30-day comment period is much too short.  The potential impacts are far-reaching in time and space given the proximity to the flow of these Great Lakes waters.

Many people who are concerned about this project, including the transportation of the radioactive waste to the site, have not even heard about the comment period and, for those who were alerted to the comment period, it is a very short period of time to comment substantially on the initial project description. The review process must be thorough and allow public participation, and a 30-day comment period is not long enough.

The project description fails to provide important information about the project.  For instance, why the NWMO is attempting to persuade the Impact Assessment Agency that transportation of the nuclear waste across a route that practically spans the breadth of Ontario can be left out of the review. That is absurd. Describing transportation as part of their project has been going on for more than two decades.  The project’s transportation route is an integral part of the project as described and therefore cannot be left out of the review.

The NWMO provides far too little information about project activities, including those project activities that pose radiological risk for the workers, and for area residents including those downstream from the project site.  There is not enough information about the Used Fuel Packaging Plant, how the wastes will be transferred into the underground and placed in the emplacement rooms, how the containers will be monitored after they are underground, and how they will be retrieved or repaired in the event of a container failing.   These are enormous shortcomings in this project description.  The NWMO must be required to provide a detained project description.

Our organization is a Great Lakes water care organization concerned with the health of the Lake Superior watershed the feeds all the lower Great Lakes.  The planned transportation route connects the North Shore of Lake Superior and the North Channel of Lake Huron where there is plenty of opportunity for system failure due to highway's proximity to these freshwater seas. Highway accidents are caused by all manner of challenges from the narrow, two-way highway, the weather conditions being exacerbated by climate change year round with more snow and more sustained rainfalls that cause washouts and road closures.  Our conservation organization is requesting that this project be the subject of a full impact assessment including a public hearing, and that the Impact Assessment Agency ensure that the public can participate in a meaningful way through each step of the process.

This is a FOREVER responsibility on many fronts for generations to come. It is a responsibility that will be passed down long into the future. 

There is exponential growth in finding solutions to the seemingly impossible challenges we face today like our energy demands.  If we look to the billions of years of wisdom embedded in Nature’s systems, the wisdom embedded in the traditional knowledge of Indigenous people since time immemorial, and the smart use AI systems used with intention to do no harm to the air, water, and biodiversity that sustains our lives, alternatives to this project can be, and will be, found without taking the enormous risk by what is being proposed by NWMO.  

Given the sheer lack of essential information that has not been provided to the public in the project description, one can only surmise a great many “what ifs” have never even been discussed, let alone had plans created for them.

Thank you for considering our comments and concerns.