15.4 Traditional Foods and Medicines - Melgund NWMO Nuclear DGR Impact Assessment

Section Synopsis

Pages: 153-154

The provided text outlines the baseline data and planned assessment for traditional foods and medicines in the regional area of northwestern Ontario for a proposed nuclear waste project. It identifies key harvested species including fish, berries, wild rice, and game, while referencing existing studies on contaminant levels such as mercury and lead. The proponent acknowledges existing fish consumption advisories due to mercury and PCBs, asserting these are not project-related. Future work includes a participatory tissue sampling program and a targeted campaign to collect site-specific data for the Impact Statement.

Community Assessment Narrative

The text provides a broad overview of traditional land use but relies heavily on regional data that may be outdated or lack site-specific precision. By citing studies from 2014 and 2016, the proponent assumes that ecological and contaminant conditions have remained static over the last decade. While the inclusion of Indigenous-led studies is positive, the acknowledgement of 'low sample sizes' in these references suggests a potential weakness in the current baseline. There is a notable reliance on 'participatory' sampling for future data collection; while this encourages community engagement, it may introduce selection bias or result in inconsistent data if not supplemented by a rigorous, systematic scientific sampling design. Furthermore, the text quickly dismisses the project's impact on existing contaminants like mercury and PCBs. While the project may not release these specific substances, the analysis fails to address how project activities—such as land disturbance or hydrological changes—might interact with or mobilize existing environmental stressors. The tone is professional, yet the lack of specific details on the cultural protocols for gathering medicinal plants suggests a need for deeper integration of Indigenous Knowledge beyond simple species lists.

Corrective Measures & Recommendations

The proponent should conduct a contemporary, site-specific baseline study to supplement the decade-old regional data currently cited. This study must include systematic sampling of soil, water, and biota within the immediate project footprint and downstream areas to ensure a statistically robust baseline that accounts for current environmental conditions. Relying on voluntary participatory sampling alone is insufficient for a high-stakes impact assessment; a standardized monitoring framework is required to ensure data quality and representativeness across all seasons and species. Additionally, the proponent must provide a detailed cumulative effects framework that explicitly analyzes how project-related activities might interact with existing environmental burdens, such as mercury. Even if the project does not release mercury, the potential for physical disturbances to mobilize existing contaminants in sediments or soil must be rigorously evaluated. This should be coupled with a transparent consultation process regarding the specific locations and cultural significance of medicinal plants to ensure that mitigation measures are culturally appropriate and protective of Indigenous rights.

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)

The community findings from Melgund Township demonstrate a high degree of alignment with the issues identified in the IAAC Summary of Issues (SOI) published on February 16, 2026. Most notably, the community’s concern regarding the proponent’s dismissal of project interactions with existing mercury levels aligns directly with the IAAC’s section on Human Health and Well-Being, which explicitly flags "cumulative health effects in the region... including the intergenerational health implications of historic mercury releases from Dryden Mill." Melgund’s technical observation that project activities could mobilize existing mercury in sediments provides a specific mechanism of action that supports the Agency’s broader concern regarding legacy industrial contamination.

Furthermore, Melgund Township’s critique of the proponent’s reliance on decade-old studies (Chan et al. 2014 and CanNorth 2016) validates the IAAC’s findings under the Indigenous Peoples theme, specifically the sub-section on Uncertainty related to project effects. The IAAC notes concerns regarding "limited, inaccurate, or missing baseline data," which is directly supported by the community’s assessment that 10-year-old data fails to account for recent environmental changes or climate impacts. The community’s identification of a gap in "cultural significance and gathering protocols" for medicinal plants also aligns with the IAAC’s requirement to consider Indigenous Knowledge and the "Impacts to harvesting and travel."

A significant alignment is also found in the methodology of data collection. While the IAAC SOI mentions the "need for community-led baseline data collection" under Socio-Economic Conditions, Melgund Township’s analysis identifies a potential risk in the proponent’s current approach. The community assessment flags that relying solely on "participatory" or voluntary sampling may lead to gaps in health risk assessments. This suggests that while the IAAC and the community both value local involvement, the community assessment goes further by identifying that voluntary programs must be supplemented by systematic, professional scientific collection to ensure the "statistically robust baseline" the IAAC process requires.

Recommendations

The working group recommends that the proponent move beyond regional, historical data and implement a contemporary, site-specific baseline study. This study must prioritize systematic sampling of soil, water, and biota within the immediate project footprint and downstream areas. By establishing a standardized monitoring framework that operates across all seasons, the proponent can address the "high uncertainty" and "missing baseline data" flagged in the IAAC Summary of Issues. This approach ensures that the health risk assessments for traditional foods and medicines are based on current environmental realities rather than outdated regional averages.

Additionally, it is recommended that the proponent develop a rigorous cumulative effects framework that specifically addresses the mobilization of mercury. Given that the IAAC has explicitly identified the Dryden Mill mercury legacy as a key issue, the proponent must demonstrate how physical disturbances from construction and operation will be managed to prevent the re-introduction of these contaminants into the food chain. This technical work should be integrated with a transparent consultation process that maps the cultural landscapes of medicinal plants. These recommendations serve to bridge the gap between general environmental concerns and the specific, localized protections required to uphold the rights and health of the Melgund Township community and surrounding Indigenous Nations.

Key Claims

People in the regional area consume a variety of locally harvested foods including fish, plants, and game.

Metal concentrations in regional food samples are generally similar to or lower than health guidance, with the exception of mercury and lead.

Uranium levels exceeded guidelines in 22 households across two communities in the Boreal Shield ecozone.

Mercury and PCBs are present in the baseline environment but are not expected to be released by the project.

A participatory tissue sampling program will be used to support the Impact Statement.

Underlying Assumptions

Regional data from 2014 and 2016 accurately reflect current baseline conditions at the specific project site.

Participatory sampling will yield a 'well-distributed' and scientifically representative dataset.

Project activities will have no physical or chemical interaction with existing mercury and PCB contaminants in the watershed.

Indigenous communities will be willing and able to participate in the proposed tissue sampling program.

Critical Observations & Gaps

Analysis Table

Issue Identified	Implication	Information Required
Reliance on outdated studies (Chan et al. 2014 and CanNorth 2016).	Using 10-year-old data may result in an inaccurate baseline that fails to account for recent environmental changes or climate impacts.	Updated, site-specific field sampling data from the last 1-3 years.
Dismissal of project interaction with existing mercury and PCB advisories.	Project activities could mobilize existing mercury in sediments, even if the project itself does not 'release' mercury.	A cumulative effects analysis focusing on the mobilization of existing contaminants.
Reliance on 'participatory' sampling for critical baseline data.	Voluntary programs may not capture data from all affected groups, leading to gaps in the health risk assessment.	A systematic sampling plan that complements community-led efforts with professional scientific collection.
Lack of detail regarding the cultural significance of medicinal plants and specific gathering protocols.	Simple lists of species do not account for the spiritual or traditional importance of specific harvesting locations.	Integration of Indigenous Knowledge studies that map cultural landscapes, not just species presence.

Working Group Recommendations

Human Environment (People)

Formalize the proposed 'participatory tissue sampling program' into a scientifically rigorous, statistically valid monitoring campaign that does not rely solely on voluntary submissions.

The Proponent proposes a 'participatory tissue sampling program' to collect data on fish, game, and plants. While community engagement is positive, relying on voluntary submissions creates data gaps and selection bias. For Melgund residents who rely on these foods for subsistence and health, the assessment requires a defensible scientific methodology (systematic sampling) to ensure that 'safe consumption' conclusions are based on comprehensive data, not just what was voluntarily provided. This ensures the health risk assessment is robust enough to protect the community.

HEP-025

Environment

Require the Proponent to update the 'Traditional Foods' baseline data with contemporary field studies (2024-2025) rather than relying on literature from 2014 and 2016.

The Initial Project Description relies heavily on the 'First Nations Food, Nutrition and Environment Study' (2014) and the 'Nokiiwin Tribal Council Country Foods Study' (2016). These datasets are nearly a decade old. Environmental conditions, particularly regarding wildlife populations (moose, grouse) and vegetation patterns (berries, wild rice), change over time due to climate and other factors. To accurately assess the Project's impact on the availability of these resources for Melgund residents, the baseline must reflect current realities, not historical data.

ENV-022

Human Environment (People)

Request immediate, site-specific baseline testing of private residential wells in Dyment and Borups Corners for Uranium and heavy metals, independent of regional averages.

The Proponent's submission notes that 'Residential sources of drinking water are understood to be predominantly well water' and explicitly states that 'Uranium levels were above guideline values in 22 households' in the Boreal Shield ecozone studies cited. As Melgund is an unorganized territory with zero municipal water infrastructure, residents are 100% reliant on private wells. Relying on regional data from 2014 (Chan et al.) is insufficient for establishing a safety baseline. The Proponent must verify current local water quality to ensure that any future changes in groundwater chemistry can be accurately attributed to the Project rather than existing conditions.

HEP-026

Environment

Challenge the Proponent's assertion that 'neither mercury nor polychlorinated biphenyls are expected to be released' by requiring a specific assessment of contaminant mobilization via physical sediment disturbance and hydrological changes.

The Proponent's submission acknowledges that mercury and PCBs are present in the existing baseline and subject to current advisories in the Wabigoon and Dinorwic systems. While the facility itself may not introduce new mercury, construction activities, road building, and drainage changes can methylate and mobilize existing legacy mercury in wetlands and sediments. For Melgund Township, which sits within these watersheds, the distinction between 'releasing' new chemicals and 'mobilizing' existing ones is irrelevant if the outcome is increased toxicity in local fish. The Proponent must model the physical mobilization of these specific baseline contaminants rather than dismissing them solely because they are not part of the waste stream.

ENV-023

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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.