I am a resident of Manitoba, and I am submitting these comments as an individual. 

First of all I would like to say the all of the documents provided in this application speak of the long term, very detrimental impacts should something go wrong. To my recollection over the past 45-50 years, the question of what to do with intermediate and high level radiative nuclear waste has been the elephant in the room with no consensus on what is safe and reasonable. One of the solutions proposed has always been to bury the waste, but it was always deemed to be too risky. So now it has been decided that because the waste has piled up to a huge problem, that this solution is suddenly a risk worth taking and they acknowledge there will be risks. Did it not occur to the nuclear industry that it should have been solved before the industry got started? Not having a solution for the end of the use cycle ahead of time is unbelievable with such a dangerous substance. How are we to take any suggestions at this point, from the nuclear industry that anything they present has any credibility?

On the issue of taking transportation out of this Impact Assessment Process, is absolutely beyond reason to me.

Firstly the applicant claims there will be 5.9 million nuclear waste bundles to be transported at Five (5) trucks per day for 50 years. That means each truck would be carrying 64.66 fuel bundles per truckload. I have been informed that Pinawa transports one spent fuel rod per truckload to Chalk River for storage at a time. That fuel rod has to be carefully loaded onto the truck by a crane because it is large and very heavy. So I’m wondering how 64.66 spent fuel bundles would fit safely on each truckload. The numbers don’t make sense so I’m not surprised that NWMO wants to exclude transportation from this impact assessment process.

Secondly Highways 11 and 17 in Ontario are the most accident prone highways in Ontario. Trucks regularly get in accidents. The highway accident reports in Ontario for trucks with radioactive nuclear waste loads show that these loads are not exempt from those statistics. They also show that those supposedly impervious containers they are transported in have leaked when in accidents. The highway accident reports are very vague on extent of leak and result including what clean up or mitigation resulted or if anyone was hurt or worse, so the risk is not made clear. That appears to be in keeping with how the oil and gas spills are reported as well and many of those take years to get cleaned up. That would be a disaster with nuclear waste. I was advised with a compromised container in a trucking accident, the driver/s of the transport truck would likely die on the site of the accident from radiation.

How are we to have any confidence in this process when that elephant in the room is requested to be excluded? It’s a major part of the project. I am definitely not in favor of excluding the transportation from this impact assessment application and everyone along the transport routes is potentially an impacted First Nation, person, town, city or territory and as such everyone has a right to be meaningfully consulted. If there isn’t significant approval from all parties along that route, this project should not go ahead.

In respect to the DGR project itself, I have a couple of comments

January 27^th, 2026 there was an earthquake registering 4.1 close to Barry, Ontario. Shock waves were felt in Toronto. It didn’t do major damage, but it was a very unusual event and yet it happened. A more serious earthquake could have had bad outcomes for the existing on site stored spent nuclear waste at the various nuclear power plants in the region. According to geological maps, there is a shallow fault line that runs from Wabigoon Lake to Lake Winnipeg. To my knowledge there hasn’t been seismic activity on that fault line but the same could be said for the one close to Barry, Ontario. A stronger earthquake could rupture the containment rooms and the containers. What’s the plan in case something like that happens? In addition, all of the on site and the proposed DGR would be at risk for air attacks should war break out. It seems no one really gave that any thought ahead of time.

Bruce “C” is proposed to add a fleet of new reactors to that site. It has been heavily opposed by the First Nations in the area. It will continually increase the waste that needs to be disposed of substantially when we still have no track record of how any plan of waste disposal is going to go. My opinion is that development of all future nuclear reactors should be halted until we know we have a safe method of disposal or science develops a way to neutralize radioactivity.

There is a probability of radioactive particulates and gasses due to fuel handling, radioactive wastewater from washing equipment, spills from equipment and machinery, spent filters and ion exchange media, spent equipment and tools from maintenance of hot cell equipment, used air filters, or active waste from nuclear structures, systems and components. There will be radiation seepage in the movement of waste from facility to truck to repackaging warehouse to loading and depositing the waste in the DGR. This will pose a health risk to people who work there and possibly the area surrounding the warehouse.

Finally my concern is that I don’t see any mention of who is responsible for evacuation, containment and clean-up of man-made or natural event resulting in a critical incident. What is the plan? I see no mention of that. Who is responsible to initiate and pay for evacuations? Who is responsible to initiate and pay for on site or in transit containment and clean up? Who is responsible for off-site or not in transit containment and clean up (in air, land or water)? Who is responsible for liability for all of those?