Section Synopsis
Pages: 69-72The provided text outlines the decommissioning and closure phase for a Deep Geological Repository (DGR) for Canada’s used nuclear fuel. The process involves an extended monitoring period of approximately 100 years to verify safety, followed by a 30-year decommissioning phase. Key activities include the co-emplacement of low-level waste (LLW), the potential removal of intermediate-level waste (ILW) to other licensed facilities, the sealing of access tunnels and shafts with bentonite and concrete, and the reclamation of surface sites. The plan emphasizes an adaptive approach, citing that the final decision to close the repository will depend on regulatory oversight, international experience, and the 'desire of society' at that time.
Community Assessment Narrative
The decommissioning plan presents a highly technical and sequential approach to closure, yet it is characterized by significant temporal and procedural ambiguities. By projecting the final closure 100 years into the future, the proponent shifts the burden of finality and safety verification to future generations. While the 'adaptive' approach is framed as a benefit, it lacks a defined framework for how 'society’s desire' will be measured or what specific criteria would trigger a refusal to close the site. This creates a transparency gap regarding the long-term socio-political stability required for such a project.
Furthermore, the text exhibits a lack of specificity regarding the disposal of Intermediate-Level Waste (ILW). Stating that ILW will be moved to a 'Licensed facility' without identifying such a facility or the criteria for its selection introduces a significant regulatory and environmental unknown. The tone is generally professional, but the reliance on future 'subsequent regulatory submissions' to fill in critical gaps—such as the design of permanent markers for future generations—suggests a 'wait-and-see' strategy that may undermine current community confidence in the project's long-term feasibility and ethical responsibility.
Corrective Measures & Recommendations
The proponent should develop and disclose a formal framework for 'intergenerational consent' and social monitoring. This framework must define how 'society’s desire' will be assessed over the 100-year monitoring period, ensuring that local and Indigenous communities have a continuous, legally recognized role in the decision-making process leading up to final closure. This would mitigate the risk of social license erosion over the century-long timeline and provide clarity on the governance of the site post-emplacement.
Additionally, the proponent must provide a more detailed contingency plan for Intermediate-Level Waste (ILW) management. Relying on an unspecified 'Licensed facility' is insufficient for a comprehensive impact assessment. The proponent should identify potential pathways for ILW disposal, including the technical and safety criteria required for co-emplacement versus off-site transport. This would address the current ambiguity regarding waste streams and ensure that the environmental impacts of transporting or storing ILW are fully accounted for in the present assessment.
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 a cross-reference of Melgund Township’s assessment of the decommissioning phase against the IAAC’s February 16, 2026, Summary of Issues (SOI), there is strong alignment across social, technical, and waste management categories. The community's findings largely validate the high-level issues flagged by the Agency, while providing specific technical context that reinforces the need for the requested information.
Alignment on Social License and Governance
Melgund Township’s recommendation regarding the ambiguity of "society’s desire" and the need for a framework for "intergenerational consent" directly aligns with the IAAC’s section on Monitoring and institutional control. Specifically, the IAAC flagged concerns regarding "adequate consideration of intergenerational rolling stewardship," which mirrors the community's request for a defined protocol to measure public consent over the 100-year monitoring phase. Furthermore, the community's concern about how decision-making criteria will evolve supports the IAAC’s entry under Cumulative Effects: Acceptable Risk, which notes concerns regarding "intergenerational changes to acceptable risk related to the project."
Validation of Waste Stream Ambiguities
The community’s concern regarding the "unsubstantiated ILW disposal path" and the lack of specific criteria for co-emplacement versus off-site transport is explicitly supported by the IAAC’s section on Alternative means. The Agency has formally requested information regarding "alternatives related to... storage of intermediate and low-level waste." Melgund’s analysis validates this as a critical gap, emphasizing that without identifying the "licensed facilities" mentioned by the proponent, the cumulative environmental impacts cannot be fully assessed.
Technical Specificity on Reclamation
While the IAAC SOI includes a broad category for Reclamation—expressing "concern regarding how the area will be reclaimed after the DGR is sealed and decommissioned"—Melgund Township provides necessary technical specificity that supports this concern. The community’s identification of "shaft reaming" and the management of removed concrete liners highlights a specific waste generation and stability issue that falls under the IAAC’s broader request. Additionally, the community's demand for a geomechanical assessment of shaft stability during this phase reinforces the IAAC’s issue under Geology, geochemistry, and geological hazards, specifically regarding the "destabilization of geology from project activities."
Agreement on Long-Term Communication
Finally, the community’s identification of the "semiotic and cultural challenge" regarding permanent markers aligns perfectly with the IAAC’s issue under Cumulative Effects: Long-term sustainability. The Agency noted concerns regarding "the ability to communicate hazards to future generations." Melgund’s findings suggest that the current proposal lacks the detailed strategies required to address this specific Agency concern, confirming that this remains a significant gap in the proponent's submission.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Ambiguity in social decision-making criteria. | The term 'society’s desire' is undefined, making it impossible to evaluate how community input will influence the 100-year closure decision. | A defined protocol for measuring and incorporating public and Indigenous consent over the 100-year monitoring phase. |
| Environmental and safety impacts of shaft reaming. | The removal of concrete liners from shafts during decommissioning will generate significant waste and may alter the surrounding rock stability. | Detailed waste management plans for the removed concrete liners and a geomechanical assessment of shaft stability during reaming. |
| Unsubstantiated ILW disposal path. | The destination for ILW is unknown, which prevents a full assessment of the cumulative environmental impacts of waste transport. | Identification of potential licensed facilities or specific criteria for the co-emplacement of ILW. |
| Lack of detail on long-term communication strategies. | The effectiveness of 'permanent markers' for future generations is a complex semiotic and cultural challenge not addressed in detail. | Preliminary research or strategies on how markers will remain intelligible across linguistic and cultural shifts over millennia. |
Working Group Recommendations
Require a formal definition and methodology for assessing 'society’s desire' regarding the timeline for repository closure, ensuring Melgund Township's specific consent is weighted distinctly from broader regional or national sentiment.
Challenge the Proponent to demonstrate 100% self-sufficiency for emergency response services (fire, ambulance, spill response) required for the 'construction of facilities' (e.g., concrete batch plant) and 'decommissioning of surface structures' described in the text.
Assess the long-term socio-economic impacts of installing 'permanent markers' on local property values, land use, and community branding in Melgund Township.
Request a technical assessment of the environmental implications of 'co-emplacement' of Low-Level Waste (LLW) underground versus off-site disposal, specifically focusing on potential chemical interactions with the host rock and groundwater.
Request a specific baseline protocol for the 'surveys of soils and sediments' and 'ground water quality' monitoring mentioned, explicitly defining the Contaminants of Potential Concern (COPCs) related to decommissioning activities (e.g., concrete additives, demolition dust).
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.