Section Synopsis
Pages: 27-29The NWMO document outlines the historical selection of Adaptive Phased Management (APM) as the chosen method for long-term nuclear fuel management, asserting that the federal government's 2007 decision precludes the need to evaluate alternative projects during the current Impact Assessment. It further identifies ten 'Alternative Means' for project implementation—including road alignments, water sources, and worker accommodations—that remain under study for technical and economic feasibility.
Community Assessment Narrative
The NWMO's reliance on a 2007 federal decision to bypass the 'Alternatives to the Project' section of the Impact Assessment feels like a strategic avoidance of modern scrutiny. For those of us in Melgund Township, being told that the 'no-action' alternative was dismissed nearly twenty years ago—long before many current residents were even aware of the Revell site selection—is a bitter pill. The document uses glossy phrases like 'inclusive and collaborative approach' and 'broadly regarded as socially acceptable' to paint a picture of universal agreement that simply does not exist on the ground in Dyment or Borups Corners. This 'corporate speak' masks the reality that the decision was largely top-down, and the 'social acceptance' claimed likely refers to national polling rather than the specific concerns of the people living less than 10km from the proposed site.
Table 13.1, which lists 'Alternative Means,' is particularly concerning because it treats life-altering infrastructure as mere technical variables. For a small community, the 'options for primary and secondary access road alignments' or 'location of permanent and temporary accommodation camps' are not just engineering choices; they represent the potential for massive traffic increases, noise pollution, and a fundamental shift in our local social fabric. The mention of 'effluent water discharge' and 'Excavated Rock Management Areas' (ERMA) is presented without any acknowledgement of the visual blight or the potential for dust and contamination that could drift toward our homes.
Impacts on Local Recreation: The proposed infrastructure described in the 'Alternative Means' section poses a direct threat to the traditional lifestyle of Melgund residents. New access roads and transmission lines will inevitably bisect established hunting grounds and snowmobile/ATV trail networks that have been used for generations. The 'options for using surface water' and 'effluent water discharge' locations could jeopardize the health of local fisheries, turning our weekend fishing spots into industrial zones. Furthermore, the influx of a temporary workforce into 'accommodation camps' will likely overwhelm local resources, potentially displacing residents from the quiet enjoyment of the area and putting undue pressure on the Dyment Recreation Hall, which serves as our primary social hub. The acoustic environment, currently characterized by silence, will be shattered by the construction and operation of these 'alternative' road and energy configurations.
Corrective Measures & Recommendations
The NWMO must conduct a localized 'No-Project' impact study specifically for Melgund Township and the immediate vicinity of the Revell site. It is insufficient to rely on a 2007 national mandate; the proponent must demonstrate why the DGR is preferable to current on-site storage specifically in the context of the 2025 environmental and social landscape of Northern Ontario. This study should include a 'Stigma Assessment' to determine how the project will affect local property values and the long-term viability of our community as a residential area.
Regarding the 'Alternative Means,' the NWMO must establish a formal Melgund Community Liaison Committee with the power to veto specific road alignments or camp locations that are deemed too disruptive to local residents. We demand a 'Recreation Mitigation Fund' specifically for the Dyment Recreation Hall and local trail associations to ensure that if our traditional lands are restricted, there is direct, tangible investment in our community infrastructure to compensate for the loss of quiet enjoyment and land access.
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)
Melgund Township’s community findings show a high degree of alignment with the IAAC Summary of Issues (SOI), particularly regarding the socio-economic and environmental risks posed by the Revell site. The community’s concern over "accommodation camps" and their impact on local character and emergency services is directly mirrored in the IAAC section "Effects of temporary workers on services and infrastructure," which flags potential increases in cost of living and strain on local services. Furthermore, the Township’s observation regarding the lack of social integration for these camps supports the IAAC’s identified issue of "Social cohesion and community wellbeing," validating the community’s fear that a temporary workforce influx could lead to social friction and a "boom and bust" economic cycle.
On environmental matters, the Township’s focus on the lack of specific thresholds for water discharge and rock management (ERMA) aligns closely with the IAAC’s concerns under "Geochemical behaviour of rock material" and "Potential and cumulative effects on water." The IAAC specifically notes the potential for acid rock drainage and metal leaching from excavated material, which validates Melgund’s demand for baseline water quality data and a robust dust management plan. Additionally, the community’s call for a "Stigma Assessment" regarding property values is well-supported by the IAAC’s inclusion of "Economic impact on property value" and "Economic impacts from public perception" as key issues for the assessment.
A significant alignment is also found in the critique of the project’s justification. Melgund Township’s assertion that the 2007 federal decision is outdated and requires a modern comparative analysis (DGR vs. on-site storage) is reflected in the IAAC’s Annex A under "Project need." The Agency acknowledges public concerns regarding whether "interim storage is a better option until risk and uncertainties are reduced," effectively validating the Township’s position that the proponent’s reliance on a nearly 20-year-old mandate is insufficient for the 2025 environmental and social landscape.
However, there are notable gaps where the community’s demands go beyond the current IAAC scope. While the IAAC mentions "Socio-economic impacts to land use" generally, it does not specifically address Melgund’s requirement for a "Recreation Mitigation Fund" targeted at local assets like the Dyment Recreation Hall. More importantly, the IAAC SOI focuses on engagement and communication but does not yet reflect the Township’s demand for a "Community Liaison Committee" with the specific power to veto road alignments or camp locations. This represents a critical gap between the Agency’s broad interest in "meaningful engagement" and the Township’s requirement for local agency and direct infrastructure compensation.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| The document lists 'accommodation camps' as a technical option without discussing social integration or impacts on Melgund. | Accommodation camps can lead to social friction, increased demand on emergency services, and changes in community character. | A detailed Social Impact Management Plan for the proposed workforce housing. |
| The 'Alternative Means' for water discharge and rock management lack specific environmental thresholds. | Water discharge and rock management (ERMA) can lead to long-term contamination of local watersheds. | Baseline water quality data for all potential discharge points and a dust management plan for the ERMA. |
| The refusal to re-evaluate 'Alternatives to the Project' based on a 2007 decision. | Dismissing alternatives limits the scope of the IA and ignores 20 years of technological and social change. | A modern comparative analysis of the DGR versus continued on-site storage at reactors. |
Working Group Recommendations
Challenge the Proponent to demonstrate 100% self-sufficiency for emergency response (Fire, Medical, and Security) for the proposed 'accommodation camps' and 'access road' options listed in Table 13.1.
Request a detailed hydrogeological impact assessment for each 'Alternative Mean' regarding water supply (surface vs. groundwater) and discharge locations identified in Table 13.1.
Demand a comparative traffic safety and noise study for the 'primary and secondary access road alignments' specifically focusing on the proximity to residential clusters in Dyment and Borups Corners.
Request specific mitigation and monitoring plans for dust and runoff for the various 'ERMA' (Excavated Rock Management Area) configurations mentioned in the filing.
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.