Melgund Recreation, Arts and Culture
Public Comments Archive

B. PROJECT INFORMATION

Detailed Technical Assessment Report • Ref: REC-3F1I-BL8O

Section Synopsis

Pages: 41-42

The provided text outlines the purpose, need, and potential benefits of a proposed Deep Geological Repository (DGR) for Canada’s used nuclear fuel. It positions the project as the implementation of the Adaptive Phased Management (APM) plan, mandated by the Nuclear Fuel Waste Act (NFWA). The project aims to isolate approximately 5.9 million fuel bundles in a stable geological formation to ensure long-term safety and intergenerational equity. Key benefits cited include supporting Canada’s net-zero goals, providing long-term economic opportunities in northwestern Ontario, and transitioning from active interim storage to a passive, permanent disposal solution under the oversight of the Canadian Nuclear Safety Commission (CNSC).

Community Assessment Narrative

The text presents a highly structured and professional justification for the project, yet it exhibits a distinctly promotional tone that may obscure critical complexities. By framing the project as an essential component of Canada’s 'transition to net-zero emissions,' the proponent aligns nuclear waste management with popular climate goals, which could be perceived as a strategic bias to garner public support. While the document emphasizes 'transparency and accountability' through CNSC licensing, it lacks a balanced discussion of the inherent risks associated with deep geological disposal, such as potential containment failure or the complexities of transporting 5.9 million fuel bundles to northwestern Ontario.

Furthermore, the 'adaptive' nature of the management system is mentioned but not defined, leaving an ambiguity regarding how the project would respond to new scientific data or community opposition once construction begins. The claim of 'enduring benefits' for host communities is presented as a certainty, yet the text does not address the potential for 'boom-bust' economic cycles or the social strain on small regional infrastructures. The reliance on the 2024 Nuclear Fuel Waste Projections Report assumes a static nuclear landscape; however, it does not account for the potential influx of waste from Small Modular Reactors (SMRs) or other new technologies, which could significantly alter the project's scope and the validity of the current environmental impact assumptions.

Corrective Measures & Recommendations

The proponent should provide a detailed 'Adaptive Management Framework' that explicitly defines the criteria and thresholds for project modification, suspension, or reversal. This would address the ambiguity of the 'adaptive' label and provide the community with a clearer understanding of how unforeseen technical or social issues will be managed. This framework must include specific mechanisms for integrating Indigenous Traditional Knowledge alongside Western science to ensure that 'inclusive' engagement translates into meaningful influence over project outcomes.

Additionally, a comprehensive socio-economic impact study specific to northwestern Ontario is required to substantiate the claims of long-term local benefits. This study should analyze the existing labor market capacity, housing availability, and infrastructure readiness to prevent negative socio-economic externalities. The proponent should also clarify the project's scalability; specifically, how the DGR design would accommodate waste from future nuclear technologies not included in the current 5.9 million bundle projection, ensuring that the 'permanent solution' remains viable under changing national energy policies.

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 assessment findings demonstrate a high degree of alignment with the IAAC Summary of Issues (SOI) published on February 16, 2026, particularly regarding the technical and socio-economic uncertainties of the DGR project. A primary point of convergence is found in the "Project description, purpose, need and alternatives considered" section of the SOI. Melgund’s concern that the 5.9-million-bundle waste projection is too narrow is directly mirrored by the IAAC’s identified need for more information on "Future modifications for accepted waste," specifically regarding potential changes to the types or volumes of waste managed if national energy policies shift toward new reactor technologies.

There is also strong alignment regarding the "Adaptive Phased Management" (APM) framework. Melgund Township’s critique that the term "adaptive" lacks operational constraints or triggers for re-assessment is validated by the IAAC under the "Monitoring and institutional control" subsection. The Agency explicitly flags the need for "criteria for project modification, suspension and reversal," which supports Melgund’s recommendation for a formal "Adaptive Management Framework" to prevent the proponent from making significant project changes without further regulatory oversight.

In the realm of socio-economics, Melgund’s findings provide specific local context to the broader concerns listed in the IAAC’s "Socio-Economic Conditions" and "Infrastructure and Services" sections. While the IAAC identifies a general concern regarding the "Local economic boom and bust cycle" and "long-term labour force," Melgund’s analysis goes further by identifying a gap in the proponent’s submission: the lack of a localized labor market analysis for northwestern Ontario. Melgund’s recommendation for a study on housing availability and infrastructure readiness directly supports the IAAC’s concern regarding the "Effects of temporary workers on services and infrastructure."

Finally, Melgund’s observations regarding Indigenous engagement align with the IAAC’s "Indigenous Peoples" section, specifically the "Consideration of Indigenous Knowledge." Both the community and the Agency highlight the lack of clarity on how Traditional Ecological Knowledge (TEK) will influence decision-making. Melgund’s specific call for a "formal protocol for Indigenous consent" aligns with the IAAC’s Annex A, which emphasizes the pursuit of "free, prior and informed consent" under the United Nations Declaration on the Rights of Indigenous Peoples. Overall, Melgund’s findings serve to validate and provide regional specificity to the Agency’s high-level summary of issues.

Key Claims

The Project is essential for Canada's transition to net-zero emissions.
The DGR will safely isolate approximately 5.9 million used fuel bundles.
The Project fulfills the legislated requirements of the Nuclear Fuel Waste Act (NFWA).
The transition to passive disposal eliminates the burden of active management for future generations.
The Project will provide long-term employment and business opportunities in northwestern Ontario.

Underlying Assumptions

Deep geological disposal is the most effective and safe long-term solution for nuclear waste.
The projected inventory of 5.9 million bundles is an accurate reflection of future waste volumes.
The CNSC regulatory process is sufficient to ensure long-term transparency and safety.
The northwestern Ontario region possesses the capacity to absorb and benefit from the project's economic inputs.
Passive disposal is inherently lower risk than maintained interim storage over millennial timescales.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
The waste projection is limited to the current reactor fleet and specific refurbishment plans. If waste volumes exceed 5.9 million bundles due to new reactor builds, the current project scope may be insufficient. Clarification on the facility's maximum capacity and its ability to scale for future nuclear technologies.
Claims of long-term employment for northwestern Ontario are not supported by a local labor market analysis. Local communities may experience infrastructure strain or economic displacement if the project relies on external labor. A detailed regional socio-economic impact assessment and a local procurement/hiring strategy.
The text mentions engagement with Indigenous Peoples but does not specify how their rights or traditional knowledge will impact decision-making. Engagement without a clear definition of 'inclusive' or 'Indigenous-led' processes may lead to a lack of social license. A formal protocol for Indigenous consent and the integration of Traditional Ecological Knowledge (TEK) in monitoring.
The 'Adaptive Phased Management' system is not defined in terms of its operational constraints or triggers. The term 'adaptive' could be used to justify significant changes to the project after approval without further oversight. A clear definition of the 'adaptive' parameters and the regulatory triggers for re-assessment.

Working Group Recommendations

Human Environment (People)

Request a localized socio-economic baseline that distinguishes Melgund Township's specific labor and business capacity from the broader 'Northwestern Ontario' region cited in the text.

The text promises 'long-term employment... in northwestern Ontario,' but this broad regional definition risks bypassing the immediate host community. Dyment and Borups Corners may face the infrastructure strain of the project without accessing the benefits if the Proponent relies on labor from larger regional centers. Establishing a specific local baseline is crucial to ensure economic promises translate into tangible opportunities for Melgund residents rather than just regional statistics.
HEP-130
Human Environment (People)

Require the inclusion of 'Intergenerational Community Burden' as a Valued Component to counter-balance the Proponent's claim of 'advancement of intergenerational equity.'

The text argues the project advances equity by removing the need for future generations to manage waste. However, for Melgund, this 'solution' creates a permanent, localized burden (stigma, land use restrictions) for future generations of residents. This discrepancy must be captured as a Valued Component to accurately assess the long-term social cost to the specific community hosting the waste, ensuring the 'equity' argument is not used to mask local disadvantages.
HEP-131
Environment

Request the specific geological baseline data and hydrogeological modeling used to substantiate the claim that the selected site is a 'stable geological formation' capable of isolating 5.9 million bundles.

The Proponent's core safety premise relies on the assertion of a 'stable geological formation.' As the host community, Melgund requires independent verification of the rock mechanics and hydrogeology specific to the Revell site to ensure that 'permanent containment' is scientifically valid and not merely a theoretical assumption derived from general regional geology.
ENV-106
Human Environment (People)

Challenge the Proponent's claim of 'protection of people' by demanding a detailed emergency response strategy that addresses the specific lack of local infrastructure in Melgund.

The Initial Project Description claims the project ensures the 'protection of people,' yet Melgund Township (Dyment/Borups Corners) is an unorganized territory with **ZERO** local emergency services (No Fire, No Ambulance, No Police). The processing and storage of 5.9 million used fuel bundles introduces high-consequence risks. Reliance on distant regional services (Ignace/Dryden) creates unacceptable response times and risk exposure. The Proponent must demonstrate 100% self-sufficiency in emergency response capacity to validate their safety claims, as the community has no capacity to assist.
HEP-132

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.