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Northwatch Comments on the NWMO’s Initial Project Description of a Proposed Deep Geological Repository for High-Level Nuclear Waste

7 Feb 26, https://iaac-aeic.gc.ca/050/evaluations/proj/88774/contributions/id/64898

The following points summarize Northwatch’s comments on the NWMO’s Initial Project Description of a Proposed Deep Geological Repository for High-Level Nuclear Waste to be located at the Revell site in Treaty 3 territory in northwestern Ontario:

• NWMO’s Deep Geological Repository Project should be designated for a full impact assessment and public hearing
• The long-distance transportation of nuclear fuel waste from the reactor stations to the proposed repository site must be included in the impact assessment
• NWMO’s Initial Project Description is inadequate and does not provide the information required, including and particularly it does not sufficiently describe or otherwise demonstrate that it has adequately examined alternatives to the project or alternative means of carrying out the project, and the IPD largely goes off course in its description of the need and purpose of the project.
• As directed by the Nuclear Fuel Waste Act the need or purpose of the project is to effectively isolate the nuclear fuel wastes from people and the environment.
• The NWMO has not provided a clear statement of the need and purpose for the project, and when it discussed the need and purpose of the project in its IPD it muddied the waters by including unsupported promotional statements and out-of-scope policy statements about the future role of nuclear power.
• Instead of setting out careful consideration of alternative means of meeting the project need (to safely contain and isolate the nuclear fuel waste from people and the environment) the NWMO simply summarized some aspects of their 2003 studies. The IPD should include a contemporary assessment of alternative means of meeting the project need.
• The NWMO’s consideration of alternative means of carrying out the project is too limited; the alternative means examination should also include alternative sites, alternatives in repository access (ramp vs shaft), transportation in used fuel containers instead of in transportation packages, the alternative means of in-water transfer of used fuel at repository site (vs “in air” ie. in hot cells), alternative mining methods, alternatives in waste emplacement (in-room vs in-floor) and alternatives in used fuel container design
• The NWMO’s description of the project and project activities is too limited, and at times is promotional rather than factual in its approach.
• The NWMO has misrepresented the fuel waste inventory, upon which repository size, years of operation, and resulting degrees of risk and contamination all hinge.
• The NWMO excluded the first step in their project, which is the transfer of the used fuel waste from dry storage containers into transportation containers at the reactor site; this is consistent with past practice.
• Without foundation the NWMO is attempting to exclude long-distance transportation from the Impact Assessment process; this is inconsistent with the impact assessment law in Canada and with the manner in which the NWMO has been describing their project over the last twenty years.
• The Initial Project Description inadequately describes major project components and activities, including the Used Fuel Packaging Plant, waste placement and repository design and construction and closure, decommissioning and monitoring.
• The description of the Project Site, Location and Study Area(s) is flawed and in some respects inaccurate.
• The potential effects of the project are poorly described and in some instances the NWMO text is promotional rather than factual.
• The description of the site selection process is very selective in the information it presents and creates a false impression of community experience through the siting process in the 22 communities that the NWMO investigated.
• There are significant gaps and deficiencies in the Initial project description; several subject areas fundamental to the assessment of the deep geological repository are extremely limited or fully absent including the subjects of long-term safety, emergency response and evacuation plans, accidents and malevolent acts and security.
• The Initial Project Description was poorly organized and was not copy edited; it lacked an index and there was no glossary included.

February 13, 2026 - Posted by Christina Macpherson | Canada, wastes