Canadian Coalition for Nuclear Responsibility (CCNR)Re: Comments on the Integrated Tailored Impact StatementGuidelines for the Deep Geological Repository (DGR)For Canada’s Used Nuclear Fuel Project

There is going to be a public impact assessment process. Now is the time to debate the alternatives for the first time in public.

TO – Impact Assessment Agency of Canada (IAAC), May 10 2026, https://www.ccnr.org/IAAC_NWMO_Guidelines_CCNR_2026.pdf

The Canadian Coalition for Nuclear Responsibility (CCNR) has reviewed the Draft
Integrated Tailored Impact Statement Guidelines for the Deep Geological Repository
(DGR) For Canada’s Used Nuclear Fuel, a Project of the Nuclear Waste Management
Organization (NWMO), and offers the following comments on those Draft Guidelines.

Stated Purpose of the Project
The stated purpose of the project is highly suspect because it is couched in selfcontradictory language. In its Initial Description of the project (p.v) the proponent states:

“Canada’s nuclear power plants have provided, and are expected to continue
providing, clean, reliable, and low-carbon energy for decades. However,
used nuclear fuel remains radioactive for a very long time and therefore
requires careful, permanent management to avoid placing a burden on future
generations.” Nuclear Waste Management Organization (NWMO)
Initial Project Description
Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project
December 2025

It is ironic that nuclear power is described, in two consecutive sentences, as a “clean”
energy source, but one whose waste byproducts nevertheless remain dangerously
radioactive for such “a very long time”, that extraordinary measures are required to
“avoid placing a burden on future generations.”

It is a stunning example of cognitive dissonance; that is, “the mental discomfort or
psychological stress experienced when a person holds two or more contradictory
beliefs, values, or attitudes, or acts in a way that goes against them.” On the one hand, the proponent asserts that nuclear power is essentially a problem-free technology, and
on the other hand is ready to expend upwards of $26 billion dollars and 160 years of
effort to “solve” what is a glaringly obvious problem – long-lived highly toxic garbage.

The contradiction in terminology is not just psychologically uncomfortable, but also selfdefeating – for NWMO goes on to enunciate (p.v-vi) its goal, accompanied by a
declaration of the industry’s intentions that belie that goal altogether.

“If implemented, the project would:

provide a permanent and safe disposal solution for used nuclear fuel;
support Canada’s commitments to climate action and achieving net-zero by
2050 by ensuring nuclear energy remains a sustainable and socially
responsible energy source;
eliminate the need for future generations to actively manage used nuclear
fuel, thereby reducing long-term environmental risks and advancing
equity in managing Canada’s nuclear legacy.”

A careful reading shows that the “safe disposal solution” for used nuclear fuel is not
really intended to unburden future generations altogether by “eliminating the need to
actively manage used nuclear fuel”, but rather to perpetuate the hazards of keeping
used nuclear fuel at the surface by “ensuring nuclear energy remains … sustainable” as
an energy source. Thus the DGR is not designed to “get rid” of used fuel once and for
all, but rather to clear the decks of older waste and make room for newer waste. The
industry has no intentions of ever stopping the production of that toxic waste material.

This is no small matter. Already the Agency is dealing with three major proposals for
new nuclear plants: the 4800 megawatt Peace River Nuclear Project, the 4800
megawatt Bruce C project, and the 10,000 megawatt Wesleyville project, with more
projects to come…. Already there are over 20,000 megawatts of new nuclear electricity
production planned (including the Darlington New Build). If these new plants are all built,
the annual production of used nuclear fuel in Canada will triple. And that is not the end
of the story. Further nuclear expansion in other provinces and territories is also planned.
To maintain credibility, the Agency cannot turn a blind eye to these contradictions. The
NWMO project currently under review by the Agency is only designated to deal with the waste produced by Canada’s existing operational fleet of 17 CANDU reactors (plus the
waste produced by seven shut-down power reactors and a handful of research reactors
owned by Atomic Energy of Canada Limited). That is less than one-third of the volume
of high-level radioactive waste now foreseen. It is patently false that the currently
proposed DGR project will “eliminate the need for future generations to actively manage
used nuclear fuel.” The stated goal of the project is, in that sense, fraudulent

In fact, no one intends to move used nuclear fuel into a DGR until it has been out of the
reactor for at least 30 years. Consequently, there will always be thirty years worth of
unburied waste at the surface (either in wet storage or dry storage) for each and every
operating nuclear reactor, no matter how fast the older used fuel may be buried. Based
on existing plans in Canada, the quantity of unburied used nuclear fuel under thirty
years of age will be tripled – or more than tripled – and will keep growing thereafter.
This is hardly “eliminating” the need for future generations to manage used nuclear fuel.

As long as new nuclear reactors are being built and old ones are continuing to operate,
there is no possibility of achieving the visionary dream of all used fuel safely locked
away in underground chambers. Such a dream is a complete fantasy. It would only be
possible if nuclear power were phased out completely.

Instead, a picture emerges of an increasing number of reactors in operation, each with
its core full of intensely radioactive used fuel, and each surrounded by at least thirty
years worth of additional unburied used fuel in wet and dry storage. Even if all the older
fuel (more than 30 years old) were instantly transported over thousands of kilometres to
the site of the DGR, the remaining catastrophe potential at each reactor site would be
only marginally diminished.

Meanwhile additional risks of fuel damage and radioactive releases would arise in
countless locations across the country due to the vicissitudes of travel along some of
the most hazardous routes in Canada. Thousands of citizens – perhaps millions –would
encounter truckloads of high-level radioactive waste passing through their communities, along their highways, over their bridges, for many decades to come. Severe transport
accidents, even if very infrequent, could result in radioactive contamination of people
and the environment in locations far removed from the generating stations. The
combined efforts of moving spent fuel to a repository location while expanding the
production of nuclear electricity at many new sites may very well make the country less
safe than it would have been if traffic of spent fuel were precluded.

In its report on nuclear energy in Ontario entitled “A Race Against Time”, the Ontario
Royal Commission on Electric Power Panning concluded as follows:

“The hazards associated with transportation, in particular the possibility of
accidents and the threat of hijacking, are real possibilities. Hence, the
minimization of handling and transporting spent fuel is a desirable
objective. (p. 91)
We prefer on-site (i.e. generating station site) spent fuel storage to a
centralized facility. We believe that a central facility would presuppose
the reprocessing of spent fuel; it would also involve more transportation
and social and environmental problems. (p. 95)
Royal Commission on Electric Power Planning
A Race Against Time, 1978

CCNR believes that the Guidelines should include an entire section on transportation –
including (a) routine gamma and neutron exposures (i.e. to those in vehicles following a
transport, to those passing the transport in the opposite direction, to those being
repeatedly exposed along the route, to those irradiated during stops), (b) container
designs and testing of same, (c) severe accident scenarios (fires of greater intensity and
duration than those tested for, drops of greater distances and impacts, sidewise
collisions that might bypass impact limiters, et cetera), and (d) emergency measures
planning and the role of first responders.

Alternatives to the Project

The Impact Assessment Act clearly states that the Agency “must” consider “alternatives to the project,” as well as alternative means of carrying out the project. However on page 9 of the Draft Guidelines, we read

“In the Initial Project Description, the proponent described the ‘alternatives to’
the project that are technically and economically feasible to meet the need for
the project and achieve its purpose. This analysis was carried out through
their Choosing a Way Forward study process pursuant to the Nuclear Fuel
Waste Act. IAAC and the CNSC determined that this information is sufficient
and no additional information is required in the Impact Statement related to
‘alternatives to’.”

CCNR strongly disagrees with this determination. A great many Canadians are unaware
of the fact that there is an alternative to the proposed DGR project that is economically
and technically feasible, and that does not involve moving used nuclear fuel off-site. It is
simply called: continued storage at reactor sites. The nuclear industry agrees that this
method is safe and can be continued for centuries without undue difficulty, provided that
the wastes are repackaged when necessary.

When NWMO published “Choosing A Way Forward”, four options were laid out. The
Government of Canada decided to choose the fourth option – the DGR option,
rebranded as “Adaptive Phased Management”. But there was no public process by
which the pros and cons of the “reactor-site storage” alternative could be discussed.
The Government of Canada did not take the opportunity to solicit other perspectives. At
that time CCNR published a critical commentary on “Choosing a Way Forward”, entitled
“Following the Path Backward” ( http://www.ccnr.org/follow_path_back.pdf ). However there
was no public forum or avenue by which any non-industry point of view could be heard.
There was simply no mechanism for dissenting voices to be weighed in the balance.

There is going to be a public impact assessment process. Now is the time to debate the
alternatives for the first time in public. CCNR believes that the Agency has a duty not to
simply accept the proponent’s point of view on the alternatives, even though the
Government has indicated its preference for the DGR approach. According to the IAA
law, any alternative to the project that is technically and economically feasible “must” be
properly addressed during the Impact Assessment process. Politics does not enter into
it. Accordingly, CCNR believes there must be a section in the Guidelines specifically
addressing the “reactor-site storage” alternative to the proposed DGR,

Some may argue that reactor-site storage is not an acceptable practice for a century or
more, because of the possibility of violent external events (airplane crashes, military
attacks), extreme weather events (tsunamis, earthquakes), or societal disintegration
(anarchy, revolution). But if those are legitimate concerns, why are we planning to build
more nuclear reactors? With new reactors operating, there is bound to be on-site
storage of at least thirty years worth of used nuclear fuel, none of which can be put
underground quickly. Continued onsite storage is definitely an alternative.

Some may argue – and indeed NWMO does argue – that we have to think of future
generations, not just for a few centuries, but for many thousands of years into the future.
But in that case there is no urgent need for the DGR right now. As long as we are intent
on expanding the production of nuclear waste, would it not make more sense to wait
until we decide to wind down the nuclear enterprise altogether at some future date?
That way we can deal with all the waste at once instead of maintaining regiments of
high-level waste here, there, and everywhere, with more on the highways every day.

At any rate, if concern for far-future civilizations is NWMO’s concern, why is there no
discussion of far-future civilizations in NWMO’s Project Description? Indeed, how are
we to communicate with far-future civilizations, when we don’t even know what
languages they will be speaking? If we choose to tell them nothing, what will prevent
them from digging up the buried waste, perhaps without them realizing what it is? Will
they imagine it is buried treasure? It will surely be clear that somebody did a gigantic
excavation in the remote past. What could it be? On the other hand, if we leave a
marker saying “Danger, Do Not Dig Here”, I can imagine some future archaeologist
rubbing his hands with glee and saying, “Folks, this looks interesting; let’s dig here!”.

CCNR recommends that there should be a section in the Guidelines dealing with the
question of communicating with future generations, along with what information we
should be communicating. Do we not have an obligation to impart to future generations
the important facts about the radioactive legacy we are leaving them?

“…The Radioactive Waste Management Committee (RWMC) of the OECD
NEA (Nuclear Energy Agency) launched an initiative ion the “Preservation of
Records, Knowledge and Memory”, hereafter “RK&M Initiative” that ran from
March 2011 to April 2018. Twenty-one organisations from 14 countries,
representing implementing agencies, regulators, policy makers, R&D
institutions, and international ad archiving agencies, plus the IAEA
(International Atomic Energy Agency), contributed to the work.”
Stephan Hotzel, GRS and Chair of the RK&M Initiative
Nuclear Energy Agency (OECD)

Of course this is assuming that the DGR does not turn out to be a colossal mistake, like
the Asse-2 salt mine in Germany. It was used as a deep underground nuclear waste
repository for low and intermediate-level waste for decades until persistent leakage of
radioactive poisons into groundwater led the German government to order the spending
of over $5 billion (equivalent) to remove the radioactive waste from the repository – a
task that will take at least 30 years, a task that is ongoing today.

Alternative Means

The Impact Assessment Act requires the Agency to consider alternative means of
carrying out a proposed project. It seems clear that the greatest danger of experiencing
radioactive releases from used nuclear fuel comes about through the handling or
manipulation of individual fuel bundles that are damaged in some way – small cracks or
pin holes, for example. In general, the less handling of the fuel, the better.

According to NWMO’s current plans for the DGR, spent fuel will be transported to the
site of the DGR where they will then be repackaged prior to emplacement in the
repository. Repackaging entails removing the fuel bundles from the transport containers
and repackaging them in a copper-coated steel burial container.

CCNR recommends that if the DGR Project is given the go-ahead, this final
repackaging step be eliminated, thereby putting less strain on the host community. This
can be accomplished by repackaging the used fuel into burial containers before
shipping them to the DGR site. In this way the “willing host community” and the
neighbouring environment will be better protected from inadvertent radioactive releases
caused by handling damaged fuel bundles. The pre-packaged burial containers can be
lowered into the DGR without ever having to open them up, greatly reducing the
chances of fugitive emissions.