Comments from We the Nuclear Free North on the NWMO's Initial Project Description - calling for a full impact assessment and public hearing

We the Nuclear Free North is an alliance of Indigenous and non-Indigenous people and groups opposed to transporting, processing, burying and abandoning highly radioactive nuclear waste in Northwestern Ontario. The Alliance has been working together for the past six years to share information about the risks and realities of the Nuclear Waste Management Organization’s proposed deep geological repository for all of Canada’s high-level nuclear fuel waste.

In 2020 the NWMO focussed their investigation on two remaining candidate sites: the Teeswater site in South Bruce in southwestern Ontario and the Revell site between Ignace and Dryden in northwestern Ontario. In November 2024 the NWMO announced that it  had selected the Revell site between Ignace and Dryden and began referring to the site as the “Wabigoon Lake Ojibway Nation – Ignace” site.

Just weeks before the NWMO announcement that it had selected the Revell site in the heart of Treaty 3 territory Treaty 3 Chiefs in Assembly passed a resolution expressing their continued opposition to the NWMO’s project and investigations in Treaty 3 territory. Strong resolutions in opposition have also been passed by Nishnawbe Aski Nation, Anishnabek Nation and the Chiefs of Ontario.

We have many concerns about the project and the NWMO’s method of selecting the site and their site selection, but our comments will focus on the Impact Assessment review process which began on January 5^th and the NWMO’s “initial project description”. The Canadian Environmental Law Association has also filed a submission on behalf of We the Nuclear Free North which we adopt as an addendum to these comments.

Our comments are: 

• The project must be the subject of a full impact assessment including a public hearing, and the Impact Assessment Agency must ensure that the public is able to participate in a meaningful way through each step of the process. 
• The 30-day comment period is too short. Many people who are concerned about this project, including the transportation of the radioactive waste to the site, will not have even heard about the comment period and for those of us who were alerted to the comment period it is a very short period of time to comment on the initial project description. This is an important project that will have impacts far, far into the future.  The review process must be thorough and allow public participation, and a 30-day comment period works against that.
• The project description is poorly done and leaves out important information about the project.  For one, the NWMO is trying to persuade the Impact Assessment Agency that transportation can be left out of the review after describing transportation as part of their project for more than twenty years.

LONG-DISTANCE TRANSPORTATION MUST BE INCLUDED IN THE PROJECT REVIEW. 

• The NWMO also provides too little information about project activities, including those project activities that pose radiological risk for the workers and for residents in the area and downstream from the project site.  For example, 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. 

THE NWMO MUST BE REQUIRED TO PROVIDE A DETAILED PROJECT DESCRIPTION. 

The following issues must be addressed in detail by the NWMO in future impact assessment documents:

• Long-Term safety.
• Transportation
• Emergency response and evacuation plans
• Accidents
• Malevolent acts / Security
• Health, including Worker and Occupational Health Transportation

• Use fuel packaging plant)
• Concurrent placement of wastes in underground chambers while construction is ongoing
• Monitoring through operational, closure and post closure stages
• Climate considerations and estimates of climate impacts
• Radioactivity and estimates of radioactive releases from various project activities over various time frames and assessing those effects (largely just ignored)

• Water “management” including: pumping of groundwater from the underground (volumes, contamination, storage, treatment, release) and water from the used fuel packaging plant (volumes, contamination, storage, treatment, release)
• Alternatives to the project (e.g. continued on-site storage)
• Alternative means (of carrying out the project

• The project description states that access (to the site) will be limited: will Tower Road and Dyment Road (currently used extensively by the public) be gated or decommissioned? will the canoe route through the area be blocked or restricted? will hunting and fishing and foraging in the area be disallowed? If so, for what area?

Our submission with enclosures is attached.