Summary comments on the Deep Geologic Repository (DGR) Project for Canada's Used Nuclear Fuel

Summary comments on the Deep Geologic Repository (DGR) Project for Canada's Used Nuclear Fuel Feb 4 2026

I have five major concerns with the proposed DGR assessment:

1. Given the chosen site of the DGR in the farthest reaches of northwestern Ontario, transportation becomes a key element in impact assessment of safety and risk. Despite NWMO’s desire to have transportation considered separately, it is integrally connected to any assessment of this DGR and must be included in the Impact Assessment. The logistics of moving 5.9 million radioactive spent fuel assemblies over a 50 year period from sites more than a thousand miles away is staggering:

“NWMO’s plan to bury and abandon all of Canada’s high-level nuclear fuel waste in northwestern Ontario will involve 2-3 shipments per day for more than 50 years, with each truck hauling 35 tonnes of radioactive waste per trip. Over 90% of the shipments will come from southern Ontario, averaging 1,700 km per trip, with most of those kilometres travelled on the poorly maintained and mostly 2-lane roads of northeastern and northwestern Ontario. The remaining shipments will be coming from the east – Chalk River in the Ottawa Valley, Quebec and New Brunswick.Again, mostly 2-lane roads, and – again – riding a road of radioactive risk that will cut across northern Ontario.” (NUCLEAR WASTE TRANSPORTATION  - BackGrounder - NorthWatch)

2. If those responsible for the prepared documents can call nuclear power “clean” and also talk about 5.9 million highly radioactive spent fuel assemblies, “Houston, we have a problem.”  Miguel Deschênes in his submission presents the problem with great clarity:

“1. Developers are not trustworthy

On page v of the document, it states that "Canada's nuclear power plants have been providing clean energy for decades,... ». Then, on page vii, it is explained that the project itself "would contain and isolate approximately 5.9 million spent fuel assemblies," representing approximately 112,750 tonnes of irradiated and highly radioactive heavy metals. This waste contains a wide variety of radioactive substances that are dangerous to living beings. One of the most famous isotopes found in these spent fuel bundles is plutonium-239. Need we remind you that Canadian plutonium was used in the bomb that destroyed the city of Nagasaki in 1945? To say on page v of the document that nuclear energy is clean and to specify on page vii that it will generate 112,750 tonnes of highly radioactive (and potentially destructive) heavy metals in Canada is staggering incoherent.

On page iv of the document, there is a list of twelve specialists and managers who prepared, reviewed, approved and accepted this document, which includes this glaring logical error. This leads to the conclusion that the developers seem willing to present all possible arguments, however incongruous, to defend this project, while concealing the negative aspects that could overshadow it. They therefore have neither the capacity for reflection nor the objectivity required to manage this project, when it would be essential to protect the safety of the public and the environment in complete transparency.”

3. There needs to be a budget in order for there to be a proper assessment of the DGR. A budget provides an important lens for how the project will be monitored and developed. It gives insights into the estimated expense and priority of different aspects of the project.  Not having a budget is serious shortcoming of the preliminary proposal that needs to be rectified.

4. There needs to be serious introspective consideration of the risks of  managing and maintaining the DGR over a multigenerational time-frame -160 years. How can we be assured and what mechanisms can be put in place to minimize the possibility of cost-cutting and safety shortcuts far into the future over multiple governments, private profit-driven corporations obtaining responsibly for management that may have very different priorities (note the serious change in direction and competence of the current US federal administration) and very different fiscal constraints.

5. This DGR is a first of its kind in the world, has the potential for serious risks particularly around transport of the waste and will need to maintain safety and proper monitoring for generations. It requires a full Environmental Impact Assessment.