Section Synopsis
Pages: 216-218The provided text outlines the anticipated air quality impacts of the Deep Geological Repository (DGR) project, identifying various criteria air contaminants (CACs) generated during construction and operation. It details proposed mitigation strategies, such as dust suppression and emission controls, and concludes that residual risks are low. However, the document acknowledges that site-specific air quality dispersion modelling and Human Health and Ecological Risk Assessments (HHERA) have not yet been completed, relying instead on industry experience and general regulatory frameworks to justify its preliminary risk ratings.
Community Assessment Narrative
The proponent's assessment presents a notable tension between its stated 'high level of confidence' and the admitted absence of site-specific data. By assigning a 'low risk' rating to air quality impacts before completing dispersion modelling or the HHERA, the text risks appearing dismissive of potential local impacts. The reliance on 'well-established' industry experience serves as a placeholder for evidence, which may not account for the unique micro-climates or topographical features of the Ignace region. Furthermore, the document's suggestion that further assessment under the Impact Assessment Act (IAA) should be limited to components with 'moderate to extreme risks' is a pre-emptive scoping attempt that could undermine the thoroughness of the regulatory review. This approach prioritizes administrative efficiency over a data-driven understanding of environmental consequences, potentially eroding community trust regarding the transparency of the assessment process. The tone, while professional, leans toward optimism rather than objective caution, particularly in its assumptions about the limited range of dust and emission dispersion.
Corrective Measures & Recommendations
The proponent should immediately prioritize the completion and public release of site-specific air dispersion modelling and the HHERA. These studies must be finalized before the risk levels are formally categorized in the Impact Statement to ensure that the 'low risk' designation is based on empirical evidence rather than industry generalizations. This data should include specific scenarios for various weather conditions to validate the claim that emissions will settle within a 1 km radius. Additionally, the proponent should establish a community-led air quality monitoring committee involving the Wabigoon Lake Ojibway Nation and the Township of Ignace. This committee should be involved in defining the 'receptors' for the HHERA, ensuring that culturally significant sites and local health concerns are integrated into the monitoring plan. This collaborative approach would mitigate the risk of overlooking localized impacts that general regulatory standards might miss and would enhance the social license of the project through increased transparency.
On 16 February, 2026 the Impact Assessment Agency of Canada (IAAC), with input from the Canadian Nuclear Safety Commission (CNSC), published a Summary of Issues (SOI) for the proposed Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project, put forward by the Nuclear Waste Management Organization (NWMO). The SOI identifies the key issues that IAAC considers relevant to the federal integrated impact assessment process for the project. NWMO’s response to the SOI will assist IAAC in determining whether an impact assessment is required under section 16 of the Impact Assessment Act. If an impact assessment is required, the issues outlined in the SOI—together with NWMO’s response—will help shape the scope of the assessment and inform the continued development and finalization of the Integrated Tailored Impact Statement Guidelines and associated plans.
Alignments to IAAC Summary (SOI)
Based on the review of Melgund Township’s community findings regarding air quality and the IAAC Summary of Issues (SOI), the following alignments and observations are noted:
Melgund Township’s concerns regarding the generation of Criteria Air Contaminants (CACs) and the lack of site-specific data align with the IAAC SOI, specifically within Annex A: Additional Comments, Guidance and Recommendations. In this section, the Agency explicitly documents a request for the "monitoring of effects during construction and operations on air, water, soil and from blasting." This validates the community's observation that construction-phase emissions are a significant area of concern that requires active oversight. Furthermore, the community's identification of a gap regarding the Human Health and Ecological Risk Assessment (HHERA) is supported by the IAAC’s entry under Health, Social, and Economic Conditions, which notes specific concerns regarding "uncertainty due to limited or inadequate baseline health data."
However, a distinction exists in the specificity of the concerns. The IAAC SOI focuses heavily on Radiological Conditions, citing "Radiological effects to the... atmospheric environment." Melgund Township’s analysis provides a critical non-radiological technical nuance, flagging that fine particulates (PM2.5) from standard construction activities may travel beyond the Proponent’s generalized "500m-1km settling distance." The community’s finding that the "low risk" designation is currently unsubstantiated by site-specific dispersion modelling reinforces the IAAC’s broader observation under Indigenous Peoples — Current use of lands and resources, which flags "limited, inaccurate, or missing baseline data available to accurately predict effects." The community analysis effectively fills a gap in the SOI by challenging the technical assumptions used to justify preliminary risk ratings, rather than just the risks themselves.
Recommendations
The working group recommends that the Proponent be required to finalize and publicly release site-specific air dispersion modelling and the HHERA prior to the formal categorization of risk levels in the Impact Statement. This recommendation directly addresses the "uncertainty" and "baseline data" gaps identified throughout the IAAC Summary of Issues. By requiring empirical evidence rather than industry generalizations to validate the "low risk" status of air quality, the Proponent can satisfy the Agency's documented concerns regarding the adequacy of the Project Description and the transparency of risk characterization.
Furthermore, the establishment of a community-led air quality monitoring committee, inclusive of the Wabigoon Lake Ojibway Nation and the Township of Ignace, is recommended to address the IAAC’s identified issue regarding Monitoring and institutional control. This committee would ensure that "receptors" for the HHERA are defined based on local usage and cultural significance, directly responding to the IAAC’s call for the "Consideration of Indigenous Knowledge" in project planning. This collaborative governance model would mitigate the specific concern listed in the SOI regarding "transparency in reporting monitoring results" and ensure that non-radiological air quality impacts are not overlooked during the long-term assessment.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Lack of site-specific air quality dispersion modelling. | The 'low risk' designation is unsubstantiated by site-specific data. | Completion of air quality dispersion modelling and HHERA. |
| Pre-emptive scoping of the Impact Assessment. | Suggesting IAA assessment only applies to moderate/high risks may bypass community-valued components. | Clarification on how 'low risk' components will still be monitored and reviewed. |
| Reliance on generalized 500m-1km settling distances. | Fine particulates (PM2.5) can travel much further than 1km depending on wind. | Site-specific meteorological data and dispersion maps. |
Working Group Recommendations
Formally oppose the Proponent's proposal to limit the Impact Assessment Act (IAA) review only to components with 'moderate to extreme risks,' thereby attempting to exclude Air Quality based on a preliminary 'Low Risk' screening.
Require the inclusion of Melgund residents and seasonal land users as distinct 'sensitive receptors' in the upcoming Human Health and Ecological Risk Assessment (HHERA), ensuring they are not aggregated with the Township of Ignace.
Challenge the Proponent's reliance on generic industry data (MECP 2017) which assumes emissions settle within 500m to 1km, and demand the immediate completion and peer review of site-specific air quality dispersion modelling.
Understanding the Impacts of Nuclear Waste on our Community
This digital archive houses the public comments submitted to the Impact Assessment Agency of Canada regarding Project 88774: The Nuclear Waste Management Organization Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project. The impact assessment is led jointly by the Impact Assessment Agency of Canada and the Canadian Nuclear Safety Commission. This archive preserves community perspectives, concerns, and observations shared during the assessment process, particularly in relation to Melgund Township, Northwestern Ontario and the communities of Dyment and Borups Corners who are the closest and most impacted of all in the process.