In support of NWMO and a DGR in Northwestern Ontario

I am encouraged and pleased to see the DGR project advancing through the Impact Assessment process. I am supportive of this project and appreciate the demonstrated commitment to environmental stewardship, meaningful community engagement, and long-term economic benefits offered by NWMO and the DGR initiative. I look forward to the project continuing to progress in a responsible and transparent manner.

I have been involved with this project and engaged with NWMO regarding the DGR for over ten years. As an Indigenous person, a resident of Dryden, and someone who has lived in Northwestern Ontario for more than forty years, I was originally deeply concerned about this project. I love the outdoors, our communities, and our way of life in Northwestern Ontario. I am deeply connected to the land and have great respect for the plants and animals that call this place home.

Having grown up near the junction of Highway 17 and another major highway, I recognize the daily risks on our transportation corridors. I believe there are more dangerous goods transported through our region every day—often without public awareness—yet moved safely due to strong regulations and oversight. At the same time, our highways are frequently closed due to collisions and poor road conditions.

After years of learning from NWMO, I now have few concerns regarding the project’s ability to protect people and the environment, including transportation of used nuclear fuel, long-term containment, protection of the watershed, natural hazard resilience, and eventual decommissioning and abandonment. I recognize that each licensing phase will involve oversight by the Canadian Nuclear Safety Commission (CNSC), and I trust that their decisions are grounded in science and guided by public safety.

That said, I do have some specific concerns and worries, that I hope NWMO will still address and continue to examine as they advance this project.   In no particular order, here are a few of my concerns at this time;

1. Copper coating of the Used Fuel Container

Is the copper coating on the Used Fuel Container strictly necessary? If the repository is located at depth and isolated from the watershed, I question whether copper is essential given that other engineered and geological barriers already provide long-term safety. While I appreciate the anti-corrosion properties of copper, its bonding method, and its interaction with bentonite clay, I remain concerned about the quantity of copper required and its sourcing.

Copper mining is often associated with environmental harm, human rights concerns, and insufficient Indigenous consultation. If copper is necessary, I strongly encourage NWMO to ensure it is ethically sourced in a manner consistent with UNDRIP and Free, Prior, and Informed Consent (FPIC). If it is not essential, I would prefer to see it omitted to avoid unnecessary mining impacts.

Is the copper on the Used Fuel Container actually necessary?   If the DGR is really at a depth below and disconnected from the watershed, then why do we really need it?   I am glad that is bonded to the UFC in a way that it won’t crack or be removed.   I am glad of the anti-corrosion properties that copper, think they have chosen more than a sufficient thickness and am glad it is not part of the structural integrity of the UFC.   I like that its properties in an anerobic environment as learned through natural analogues and am reassured by its interaction with the bentonite clay and the role that the clay will play.   However, I am concerned about how much copper will be needed, and the source of that copper.   I believe it is generally accepted that most copper extraction and mining is done with a disregard for the environment caring concerns of; Environmental Hazards, Human Rights and Labor Issues, Public Health Impacts, and forms of Corruption and Economic Risks.   However, if the copper is truly not needed as the other barriers should provide safety for the lifetime of the hazards from Used Nuclear Fuel then I would prefer to see it left off of the UFC due to the concerns of copper mining.   When asking NWMO about sourcing of copper in the past, I have received answers along the line of ‘it’s a marketable product, that would likely be secured through an RFP’.   If copper is needed for this project I hope that as part of the Impact Assessment,  NWMO will be bound to ensure that the copper is ethically sourced and from a place, and in a manner that respects UNDRIP and FPIC.

2. Bentonite clay sourcing

I have similar concerns regarding the sourcing of bentonite clay. I would like clarity on the total quantity required over the life of the project and where it will be sourced. Large deposits exist in Wyoming and Montana, but I do not know whether extraction there meets UNDRIP and FPIC standards. I am also concerned with the current political tensions between Canada and the USA, and wonder whether Canadian bentonite deposits, such as those in Manitoba, could supply the project in a manner consistent with Indigenous rights and environmental responsibility.

Additionally, I understand current bentonite is processed in Germany to meet NWMO’s specifications. I would appreciate confirmation that the planned Sealing Material Compaction Plant will allow raw bentonite to be processed in Canada, on site, reducing international shipping and supporting domestic capacity.

3. Excavated Rock Management Area (ERMA)

I believe the ERMA will represent one of the most significant long-term surface impacts of the project. While I understand the rock has been tested for acid-generating potential and arsenopyrite, I ask that this testing continue throughout construction, operation, and decommissioning.   I also believe we need to see clear contingency plans for managing any rock found to be acid-generating or containing harmful minerals.

Although the detailed plans for the restoration and rehabilitation of the ERMA, should be inplace and shared now, I would also like assurance that full environmental assessment and secured funding for ERMA rehabilitation will be required prior to the license for decommissioning or abandonment take place.

If safe rock is available for community use in road building or landscaping, I hope NWMO will make it accessible although I know they do not want to be in the bussiness of 'selling rock', it is a local resources that could be used to benefit people and communities. 

4. Indigenous and Métis engagement

I have been impressed by NWMO’s engagement to date, particularly in the Wabigoon Lake Ojibway Nation–Ignace area. I encourage continued and enhanced engagement and consultation, especially with First Nations and Métis communities.

I am deeply concerned by the absence of mention of Métis in Section 3.3; Plan for Future Indigenous Engagement and Participation of the Initial Project Description.   As well, Métis are not included in Table 22.1: Indigenous Groups, Preliminary Valued Components, Measurement Indicators, Assessment Endpoints, and Components That Could Influence or Inform Their Assessment found in the Initial Project Description Plain Language Summary – English.   I absolutely respect Wabigoon Lake Ojibway Nations sovereignty, and oversight offered into the project and am looking forward to their Regulatory Assessment and Approval Process (RAAP), and I hope that the absence of Métis in both of these tables specifically refer to the RAAP.   But I also deeply believe that Métis need to be included in every part of the decision making process of this project.   Métis are a distinct rights-bearing people under Section 35 of the Constitution Act, 1982.   The history and presence of the Northwestern Ontario Métis Community in the area should not be undermined by the current tensions between Grand Council Treaty #3 and the Métis Nation of Ontario.   I hope to see both of these tables updated to include the Northwestern Ontario Métis Community ensuring they have input, engagement and consultation during every step of the project, as inherent by their rights.

5. Local environmental protection

The Initial Project Description does a great job of outlining some of the work that has been done to understand impacts to the environment including Species at Risk.   I appreciate the baseline data that has been collected and am glad to see the eDNA studies.   I appreciate the details in sections 15.7 – 15.11 of the Initial Project Description Plain Language Summary – English. However, NWMO does need to increase its understanding of the local and surrounding environment and better detail the risks and mitigation put in place to minimize risk and impacts of this project.   I have specific concerns to moose, bats, amphibians, do not believe no reptiles have been found.   I have concern surrounding the protection of Black Ash found 10km from the project site, and more importantly the protection of swamp, marsh and fen at the project site, as these are important natural filters and a hotbed for biodiversity.   Any disturbance caused by the project should have detailed inventories of the plant species found and consultation with local Indigenous communities and other interested area residents.   It is important to note that much of the site has seen recent logging activity, but that does not mean that there is not species of interest that are important to people on site that we need to know, understand, and protect.   

I encourage detailed plant inventories, continued consultation with Indigenous knowledge holders, and clear mitigation measures.

I also support the idea of relocating important plant species to an educational natural garden at the Centre of Excellence if disturbance of species of interest must occur.

6. Communicating NWMO’s body of knowledge

NWMO has produced over two decades of scientific work and reporting. I believe this extensive body of evidence is essential for public understanding and confidence. However, communicating complex technical information to concerned or skeptical audiences remains challenging. I encourage NWMO to continue improving accessible, transparent communication of its research, regulatory oversight, and international best practices.

The NWMO was formed in 2002, some 24 years ago.  The study and licensing of a DGR for Used Nuclear Fuel in Canada predates that.   With such a long history and body of knowledge, I am deeply concerned with how NWMO will share and communicate its story.   With more than 24 years of work and 1020 documents and reports on their website that speak to a deep geological repository how do they communicate this body of work to those who are concerned about the project and not willing to listen to the facts or the story.   I believe this body of work is essential in understanding the project, it’s safety, and it’s deep concern for protecting people and the environment from the dangers of Used Nuclear Fuel.   The NWMO has made annual reports to Parliament and have received continuous government oversight and approval of their process in efforts to keep people informed of their work as mandated through the Nuclear Fuel Waste Act.   The Nuclear Industry in Canada has a strong track record in regarding safety and supporting communities, with Nuclear Energy contributing to the power grid since the 1970’s.   Even if it was decided to disconnect Nuclear Energy from our future, there is still the problem of the current Waste from this almost 50+ years of Nuclear Energy production in Canada that must be delt with.   There is international consensus that a DGR is the safest way to protect people and the environment as a long-term solution.   The additional oversight from the Canadian Nuclear Safety Commission and International Atomic Energy Agency and should provide reassurance that peoples best interests are kept in mind.   NWMO has a challenging job of sharing this knowledge and the body of work that is based on science and supports why they have issued their Initial Project Description for a Deep Geological Repository in the Revell batholith.

7. Public discourse and unwelcomed actions

I respect the right of individuals to express concern, but I am troubled by actions that may create environmental risk or public misunderstanding. I encourage consideration of safeguards and response plans to address disruptive actions that could impact communities or the environment.

I believe people have the right to be concerned with the project, and to voice their concerns, but I hope they also take the time to learn the facts, the science, and listen to industry professionals.   I am deeply concerned about what those who are critical to the project or who simply say not in my backyard might do.   We have already seen some rather interesting acts done such as the release of  “Two-hundred-and-eighty yellow 1.5 to 3-inch cedar “nuke pucks,” hand-painted with black and red nuclear symbols have been released at the headwaters of the Turtle River and English-Wabigoon River systems east of Dryden, between Wabigoon and Ignace. They will float downstream to demonstrate the threat of radiation to communities along these waterways.” by  We The Nuclear Free North (https://www.netnewsledger.com/2022/06/22/nuke-puck-flotilla-released-for-radioactivity-awareness/).   There are also numerous plastic lawn signs going up around the area, that are an eyesore, polluting the natural environment, even on islands in the middle of a lake that the highway passes.   Although these may seem innocent I am wondering about what further actions and the consequences on people and environment might be taken by those who are strongly opposed to the project, and what safeguards need to be in place to mitigate and respond to these actions.

8. Traffic and transportation

While I have confidence in the safety of used fuel transportation, I remain concerned about overall project-related traffic: worker commuting, supply shipments, bentonite transport, rock hauling, and equipment delivery. Given the existing safety challenges on Highway 17, I request further study of cumulative traffic impacts and contingency planning for highway closures affecting site access and operations.

Although I believe that the transportation of Used Nuclear Fuel is not of concern due to the oversight and regulations currently in place, and the long international safety track record.  I do have some more general concerns regarding transportation.   I have heard that there could be up to two trucks a day delivering Used Nuclear Fuel.   That sounds like a very small impact on our highways based on current traffic.   However, what additional traffic will also come with this project.   With an estimated 700 employees during construction (living in work camps)  but again during operation what will commuter traffic be like in the different phases of the project?   What other supplies will need to be transported to the DGR, how many daily shipments of bentonite and how is it being transported, how many shipments of the used fuel containers and what distance will it be travelling, along with the many other supplies needed.   Will the trucks moving rock to the ERMA be on site all the time, or will they be travelling back and forth, will those trucks need shipments of fuel or like the underground machinery is the plan that they will be electric vehicles that move the excavated rock?    How will all this traffic related to the project impact our current traffic, and increased traffic due to new efforts to increase interprovincial trade and supply chains?   What studies have been done to see how this additional traffic will be handled on our roads.   We need to understand this greater traffic picture.   Our roads in Northwestern Ontario are not safe, and we would greatly benefit from a double lane highway from Thunder Bay to the Manitoba Border, if not across the province, but I do not feel this falls on the responsibility of the proponent.  Highway 17 is an essential corridor for the people that live here, as well as the greater Trans-Canada community.   With multiple daily accidents which regularly close our highways for hours on end, I am more concerned with this commuter traffic, and the safe operation of the DGR if employees do not have access to the roads when closed for multiple hours.   

9. Shipment frequency and temporary storage

I note that the UFPP is designed to receive up to five transportation packages per day, which exceeds earlier estimates of two shipments daily. If seasonal shipping windows are being considered, I request clarity on shipment schedules, transportation container supply, and plans for temporary dry storage, including safety specifications.

Related to the transport of Used Nuclear Fuel, I was surprised to read in Section 11; ESTIMATED MAXIMUM PRODUCTION CAPACITY OF THE PROJECT of the Initial Project Description Plain Language Summary – English that the “The UFPP is designed to receive and process up to five certified transportation packages each day.”,  as previous estimates only ever mentioned two shipments a day.   However, I have started hearing dialogue from NWMO that due to concerns about winter road conditions shipments may occur over a shortened window like a ‘9 month period’.   If this is the case, I do not feel like I’ve seen sufficient plans about what this looks like, This would mean more than 2 shipments a day, and maybe is how they are looking at the UFPP being able to receive and process up to five shipments a day.   I wonder what the results of this are on the number of certified transportation containers required and what studies have been done on the manufacture, ready supply, longevity, and replacement of the certified transportation containers.    Section 11 also mentions “Modules and baskets filled with used fuel may be placed into temporary dry storage, as required”.   I feel like I have not seen sufficient plans detailing how much temporary dry storage is required nor the specifications of this temporary dry storage detailing how it will protect people and the environment from the dangers of Used Nuclear Fuel.

10. Water use

I am concerned about water demand during construction and operation, its sourcing, and potential environmental impacts. I request further study specific to the Revell Batholith site before licensing decisions are made.

I am also deeply concerned about the amount of water that will be needed to run the DGR and it’s source and lasting effect on the environment, and what studies have been done or need to be done to support this.  On page 47 of the Deep Geological Repository Conceptual Design Report Crystalline / Sedimentary Rock report, September 2021, (https://www.nwmo.ca/-/media/Reports---Reports/APMREP004400209.ashx?sc_lang=en) both Table 9: Surface Facilities Average Water Demand during Operations, and Table 10: Underground Activities Service Water Average Water Demand indicate the expected amount of water that is estimated.   I don’t know if the maximum amount of 190 m³ of water during construction and cumulatively the maximum amount of 185 m³ of water during operation can be supported and sustained by the local environment nor the impacts that it will have on the surrounding environment.   I don’t know if this is a lot of water, or a reasonable amount of water, but is something that NWMO should need to study, clarify and define through this section of the Impact Assessment.   I hope that it is requested and provided by NWMO that before a license to prepare site, and a license to construct is granted that a report similar to the Conceptual Design Report is developed specific to the Revell batholith and this project as proposed in the Initial Project Description.

11. Low- and intermediate-level waste

Finally, I request clearer information regarding the quantities, handling, transport, storage, and disposal plans for low- and intermediate-level waste generated by the project, including whether any will be co-emplaced in the DGR and how contaminated transport containers or modules will be managed.

The last concern I’d like to bring up at this time is related to low-level waste (LLW) and intermediate-level waste (ILW).   The EXECUTIVE SUMMARY at the beginning of the Initial Project Description Plain Language Summary – English, does a great job of disclosing that this project will produce LLW & ILW that will become the responsibility of NWMO to handle appropriately in accordance with Canada’s Policy for Radioactive Waste and Decommissioning.  I would like the Initial Project Description to provide more details to the amount and nature of LLW & ILW as well as the storage facilities and the eventual disposal of the LLW & ILW including all waste to be placed in the DGR in the Revell batholith.  Details seem to be lacking in this regard.   NWMO has said that the DGR will not hold any liquid waste, but could any of the LLW & ILW be liquid waste?   I am also concerned with details around the certified transportation containers, will these eventually become contaminated to a point that these are considered LLW or ILW and how will they be disposed of?   Will the used fuel module that will carry used fuel in the certified transportation containers remain the property of current waste owners and need to be transferred back to them, or will they become property of NWMO and need to be disposed of, possibly in the DGR in the Revell batholith as I am guessing they will be contaminated and considered LLW or ILW.   I am guessing the current Dry Storage Containers will remain property of the waste owners, and likely will not be shipped, however, details of rail shipment of Used Nuclear Fuel suggests they might be shipped, if so will they be contaminated to a point that they are considered LLW or ILW and need to be disposed of?   I am encouraged by reading a response from NWMO previous engagement included on page 660 of the Initial Project Description that says “The Project scope covers Canada’s used nuclear fuel. While it is technically feasible to store ILW within the proposed DGR, this is not the intent of the current Project for now. The Project will not be including international waste. Accepting international waste would require a change in mandate and approvals.”, and understand that any changes to a project scope would result in additional review by CNSC and IAAC.   Page 97 of the Initial Project Description does not fully confirm this, and leaves the possibility of ILW being placed underground stating “ILW is planned to be transported to a Licenced facility or co-emplaced underground with the LLW.”   NWMO should have to clarify and detail it’s plans for LLW & ILW.

In closing, I remain strongly supportive of this project and encouraged by its progress through Impact Assessment. I look forward to continued engagement with NWMO, CNSC, and IAAC, and to seeing how these concerns are addressed and included in the next step.