nuclear gulags in Northern Ontario

Need for a full project description including transportation alternatives, social factors and scientific evidence

A full description of the NWMO project and related potential impacts must be presented in detail, including all project components (transportation, processing, DGR design and construction, placement of waste underground, monitoring, releases to air and water from all operations, retrievability of the wastes, performance thresholds).

Alternatives to the project (e.g. continued but improved and more secure long-term storage at the reactor stations) must be included and alternative means of carrying out project component activities must be comprehensive and detailed.

Long-distance transportation must be fully examined, including related exposures to radioactivity, the design and safety testing of the transportation containers, emergency response, support for First Responders, route selection, and notifications to local authorities.

The long-term safety and performance of the DGR / multiple-barrier “concept” must be part of impact assessment, not put off to far future license applications; the “safety case” must be part of this Impact Assessment Review.

The examination of social factors must include psychological and emotional impacts of the project, including those related to social division and to the methods of seeking consent for the project, including the consent of communities along the transportation route and in proximity to and downstream from the Revell site and the Free, Prior and Informed Consent of Indigenous people.

The guidelines must direct the production of an impact statement based on scientific evidence and sustainability principles and the impact assessment process must be structured to provide a rigorous assessment process rather than an approval process with the objective of preventing and avoiding impacts rather than attempting to mitigate them.

Disturbingly, these and other dangerous projects that affect us in Northern Ontario lead to constant battles where we try and preserve some semblance of an environment that will safely support future generations. Unfortunately, as an economic colony we don't possess any decision making body such as a territorial council or our own province and legislature where we can negotiate with the industrial onslaught. The worst example being the nuclear industry and their ongoing NWMO, DGR project. However, we will prevail....

Restating the position of most of the comments that the assessment include the impact of transportation and all the steps in handling the waste from the packaging at the nuclear plants, transporting across land and possibly water or air, to unloading, surface or near surface (shallow) storage, waste rock, handling (robotic and human), used fuels packaging plant (hot cells), any reprocessing or hardening plants (liquid radioactive waste) to be reprocessed or sent underground, waste rock sites, holding ponds, shafts, caverns and tunnels, ventilation and water holding (sumps) from underground to surface ponds and all relevant components of this DGR.

Need for a business plan including sequencing and costing all activities including transportation

What are the timings and order when these activities will happen as well as costs and the type of personnel that will be required. Will the mining of underground caverns occur at the same time as waste will be deposited? What are the human and robotic activities? This is also a safety question? Disconcertingly, this DGR project is part of a whole nuclear chain and a narrow scoping to only the underground storage (and largely ignoring transportation with the excuse it is covered by existing regulation) will limit the impact assessment and result in a decision questionable by a concerned public.

Seaborn Panel Report, 1998

This impact assessment should revisit the 95 technical issues, or more accurately, 95 deficiencies/shortcomings in the technical proposal for a Canadian nuclear waste repository, as were identified by the Scientific Review Group and other groups during the 1996-97 hearings held by the Environmental Assessment Panel (commonly known as the Seaborn Panel). (AI overview)

The Panel concluded that while the Atomic Energy of Canada Limited (AECL) concept for deep geological disposal was, on balance, technically safe, it had not been proven to have broad public support, partly due to these listed deficiencies.

Key areas of technical concern included:

• Computer Modeling Concerns: Deficiencies in modeling "real time" scenarios and predicting long-term geological stability.

• Safety and Environmental Risks: Specific concerns regarding earthquake impact and interruptions to water supply.

• Repository Design: Shortcomings in the proposed container design (intended to last 500 years to 1 million years).

• Buffer and Backfill Performance: Concerns regarding the clay-based buffer that minimizes groundwater movement and container corrosion.

• Site-Specific Factors: Although it was a "concept" review, the panel scrutinized the feasibility of repository sites in plutonic rock of the Canadian Shield.

The Seaborn Panel Report, released in February 1998, focused heavily on the societal and ethical aspects, concluding that technical safety alone could not guarantee the acceptability of the project.

Rock Solid: second edition, Dr Helen Wallace, 2025

More current is the 2025 publication of Rock Solid, the second edition, by Dr Helen Wallace for Greenpeace Switzerland. Her publication should be compared to the weaknesses of the project description submitted by NWMO for their DGR.

The following quote from the executive summary outlines the unresolved issues in the geological disposal of nuclear fuel waste.:

• "Copper or steel canisters and overpacks containing spent nuclear fuel or high- level radioactive wastes could corrode more quickly than expected.

• The effects of intense heat generated by radioactive decay, and of chemical and physical disturbance due to corrosion, gas generation, cement water, and resulting changes in mineral content, could impair the ability of backfill materials to protect the canisters from stresses in the rock and to trap some radionuclides.

• Build-up of gas pressure in the repository, as a result of the corrosion of metals and/or the degradation of organic material, could damage the barriers and force fast routes for radionuclide escape through crystalline rock fractures or clay rock pores.

• Poorly understood chemical effects, such as the formation of colloids, could speed up the transport of some of the more radiotoxic elements such as plutonium.

• Unidentified fractures and faults, or poor understanding of how water and gas will open up and flow through excavated tunnels, fractures and faults, could lead to the release of radionuclides in groundwater much faster than expected.

• Excavation of the repository will damage adjacent zones of rock and could thereby create fast routes for radionuclide escape.

• Future generations, seeking underground resources or storage facilities, might accidentally dig a shaft into the rock around the repository or a well into contaminated groundwater above it; or deliberately seek to extract canister metals or nuclear materials for military use.

• Future glaciation could cause faulting of the rock, rupture of containers and penetration of surface waters or permafrost to the repository depth, leading to failure of the barriers and faster dissolution of the waste.

• Faults could be re-activated, creating fast routes for radionuclides to escape or leading to earthquakes which could damage containers, backfill and the rock."

Need for a business plan

This project also deserves a business plan that would help present a full description, especially costs, for the public and decision makers to be presented before parliament. A business plan would include comparisons and strategies, organization, staffing, control and finance of the entire project (including transportation, packaging and handling at both ends and enroute) and plant, and equipment required. Importantly, the public and decision makers need accurate estimate of what the entire DGR project (including packaging and transportation) will cost us when it is expected to get going in the early 2040's and the ongoing operating costs until and including abandonment. The costs of retrieval and remediation would also be estimated.

The Russian experience and creation of nuclear gulags

In considering this deep geological repository and others, troublesomely, are we creating not only wastelands but industrial gulags in Northern Ontario. The building of a "technological archipelago" of "atomic towns" and facilities is compellingly told in “The Gulag Archipelago” by the Russian historian and prisoner, Aleksandr Solzhenitsyn. He ironically registered his own occupation as a "nuclear physicist" upon entry to a Stalinist camp.

In a webinar on March 12, 2022 regarding the impacts of the war in Ukraine, Andrey Ozharovsky (physicist and nuclear expert based in Moscow) addressed the dangers associated with military actions around the Chernobyl Nuclear Power Plant and other Ukrainian nuclear facilities. The list of Russian waterways contaminated by radiation is long and alarming. Canadians might take heed of the warnings of brave Russians who like Alexei Navalny, are dead or rotting in an Arctic penal colony. Last we heard of Ozharovsky he was detained by the Mongolians while measuring radiation levels near uranium mining sites.

In his book Command and Control, Eric Schlosser (2013) frequently draws parallels between the management of nuclear weapons and the correctional system, often comparing nuclear silos or facilities to prisons in terms of their isolation, secrecy, and internal logic. While a nuclear work camp may not be a prison, there is a comparison between the two. Securely managing a nuclear site involves a complex array of safety, environmental and counter terrorism challenges. Essentially, it's a secretive, paramilitary organization run in a walled or electrically fenced barb wired area to keep out intruders. The real enemy however is mostly within.

Alarming experiences and future warnings

Schlosser also details the 1980 Damascus, Arkansas, Titan II missile accident, where a dropped socket punctured a fuel tank, leading to an explosion. The incident nearly detonated a 9-megaton nuclear warhead, highlighting severe risks in America's nuclear arsenal safety, management, and secrecy during the Cold War. It illustrates the military historical maxim,”if it can go wrong, it will go wrong”.

George Orwell, in his book (1945) the Animal Farm describes a scenario where the livestock revolt against the Manor owner, Mr. Jones, aiming to create a self-sufficient, equitable society known as Animalism. Pigs, being the most intelligent, take leadership but slowly become corrupt. Orwell’s writings on prisons, particularly in his essay "A Hanging" and his novel Nineteen Eighty-Four, reflect a deep concern with the dehumanization of inmates, the moral degradation of those who run them, and the use of prisons as tools for state control.(knowunity.co.ca)

Company towns and the nuclear experiences

In Northern Ontario, we are very familiar with company towns. Historically, the elected municipal councils are a strong reflection of the often single industry that supports the local economy. For example, in Dryden it is a pulp and paper and in Ignace it was the Mattabi Mine. Here, there is confusion in the public mind as to actually who is running the Township of Ignace, the elected council or the NWMO? The NWMO provides funds to the Township of Ignace, which are then used to hire consultants to provide supposedly independent advice to the municipality. In the case of the hosting agreement between Ignace and the NWMO did the township council actually read the hosting agreement or simply sign it, committing their community to long term support of the DGR?

Along with the town of Dryden, successive mill owners and governments have protected the pulp and paper plant despite the effects of mercury contamination in the English-Wabigoon River system since the 1960's. The mill is the the main economic base for Dryden whereas the mercury contamination has caused Minamata disease and ongoing health, economic and cultural devastation in Grassy Narrows. Understandably, Grassy Narrows wants a full cleanup of the river and a halt to current mill operations. In he event of radioactive contamination downstream from the DGR or nuclear transport one can only wonder if the response by the nuclear industry and government will be the same as to that of mercury. Of course, just dealing with mercury alone is difficult enough but trying to deal with more than 200 radionuclides would be an impossible conundrum.

First Nations and environmental colonialism

Lamentably, poverty and powerlessness have been at the heart of the relationship between the nuclear industry and First Nations reserves. In Canada reserves are not legally classified as prisons, however academic, legal, and community perspectives often compare them to carceral spaces due to historical and ongoing systems of control, surveillance, and isolation that mirror incarceration. This comparison primarily stems from the restrictive nature of the Indian Act, which has historically restricted movement and controlled resources, and the persistent social and economic conditions that many First Nations face.

The Saugeen Ojibway Nation (SON), which comprises the Chippewas of Saugeen First Nation and the Chippewas of Nawash Unceded First Nation, were not consulted, nor did they provide consent, when the nuclear generating station was built on their traditional territory in the 1960's. The SON, despite the significant, long-term impacts on their lands, waters, and rights have lived in poverty beside the very well paid workers in the nuclear industry.

The list of First Nation communities near major nuclear power plants and former uranium mining areas in Ontario is long and a few in Northern Ontario include the Serpent River First Nation community that is closest to the Elliot Lake area formerly known as the "Uranium Capital of the World," with 12 decommissioned uranium mines and 10 tailings management areas in the region. Community members have faced long-term impacts from mining pollution and effluent management. Others include the Sagamok Anishnawbek First Nation: Located eastward along the north shore of Lake Huron, and Batchewana First Nation situated near Sault Ste. Marie.

Downstream from the Revell DGR site are Wabigoon Lake Ojibway Nation (WLON), Eagle Lake First Nation, Wabauskang First Nation and the Asubpeeschoseewagong Netum Anishinabek (Grassy Narrows First Nation), Wabaseemoong Independent Nations. If we include the entire headwater watershed areas of the English-Wabigoon and Turtle River Watersheds in Treaty Three and beyond to Manitoba, the list of reserves is long indeed.

Some workers and families at the DGR site and the Centre of Excellence will live in Dryden or Ignace. Through construction, operation and until abandonment of the DGR site, bunkhouses similar to those mining, oil or forestry communities will house workers, flying in and out according to work schedules. As in remote industries, turnover will be high. Perhaps better paid and fed their work existence will be that of a wage slave. Theirs will be a radioactive environment of isolation, secrecy, and internal logic. (nothing can go wrong: the corollary being, if it can go wrong, it will go wrong). Mental health, addiction and other human problems will be similar to those found in the oil industry. The social impact of these camps on host communities needs consideration.

The agreement between the Nuclear Waste Management Organization (NWMO) and Wabigoon Lake Ojibway Nation (WLON) is confidential. Disturbingly, the agreement likely includes includes clauses, similar to the agreement with Ignace that appear to restrict criticism and limits access to technical and scientific information keeping it confidential and away from public scrutiny. Also, the agreement thought to be for about the same amount as Ignace which is 170 million dollars (2025$) while some Ignace are complaining WLON got considerably more. The Nuclear Waste Management Organization (NWMO) offered the Municipality of South Bruce a hosting agreement worth over $418 million in financial benefits. Understandably, in Ignace there was rancour over this difference in $$$.

The Eagle Lake First Nation (Migisi Sahgaigan) claim they were unfairly excluded from being a host community, that the selection process was flawed, and that the project, placed within their traditional territory, risks their rights. Eagle Lake First Nation (Migisi Sahgaigan) and the Wabigoon Lake Ojibway Nation were historically part of the same reserve. This case is now in Federal Court. Anyway, this IA process should examine the divide and conquer strategies of the NWMO, the consultation and payment with one group while omitting the other. Indeed, the exclusion of transportation is an expansion of this strategy all across Northern Ontario.

The big difference between the agreements with NWMO and Ignace and that of WLON is the latter agreed agreed to an Indigenous-led Regulatory Assessment and Approval Process (RAAP). This allows Wabigoon Lake Ojibway Nation (WLON) to develop and implement its own sovereign assessment process, ensuring that the project's impacts are measured against Anishinaabe Values, and that mitigation conditions are designed by the First Nation.

With the WLON agreement we understand payment amounts go to individuals rather than to the collective (WLON) band. These payments however appear to conflict with the values of the United Nations Declaration on the Rights of Indigenous Peoples Ac (UNDRIP) received Royal Assent and came into force on On June 21, 2021, well before the hosting agreements between the NWMO, Ignace and the WLON.

Key principles of UNDRIP are the rights to free, prior and informed consent before a project such as this DGR is started? These principles underlie the importance of recognizing and upholding the rights of Indigenous peoples and ensuring that there is effective and meaningful participation of Indigenous peoples in decisions that affect them, their communities and territories.

Previously, the province had proceeded with large withdrawals of land in 2015 for the NWMO, long prior to any consultation with any First Nation communities. Now questionably, the WLON band members are receiving large payments ahead of the impact assessment or RAAP processes. This usurps the notion of either being free, or informed. Worse, it buys uninformed support by coercion.

Other undesirable characteristics of single industry communities is the control of business and individuals through the awarding of contracts. For example, a supplier when bidding on a contract knows they first have to make a contribution to a political party that supports the industry which in turn is given favourable treatment. I.e low taxes, relaxed environmental standards, training support, subsidies, etc.) Individuals that step out of line are dismissed or excluded from contracts.

Apparently, the Nuclear Waste Management Organization (NWMO) has established guidelines for its philanthropy, which it describes as "sponsorships and donations" to support community well-being in its potential host areas. We read the community engagement fund ($50 million dollars yearly) is not traditional philanthropy, but rather as investments in community well-being, sustainability, and capacity building.

This author believes the Office of the Auditor General of Canada should audit the philanthropic and other “investments” by the NWMO and indeed the “giving, philanthropic or investing” activities of the whole nuclear industry and bring this report to parliament to see if the spending is responsible and in the public interest. Subsidies of the industry and by ratepayers need accountability. Again, there is considerable concern this industry through organizations such as the NWMO, is buying support.