Section Synopsis
Pages: viii-ixThe provided text outlines the NWMO's commitment to safety and environmental protection for the Deep Geological Repository (DGR) project. It details the regulatory oversight provided by the Canadian Nuclear Safety Commission (CNSC) under the Nuclear Safety and Control Act (NSCA) and the Impact Assessment Act (IAA). Key concepts mentioned include the precautionary principle, the 'As Low As Reasonably Achievable' (ALARA) principle, and the development of a 'safety case' to demonstrate long-term protection of people and the environment through monitoring, effluent limits, and emergency response planning.
Community Assessment Narrative
The document is saturated with comforting corporate terminology like 'international best practices' and 'rigorous standards,' which serves to mask the inherent risks of burying nuclear waste less than 10km from our backdoors in Melgund. For those of us in Dyment and Borups Corners, the term 'reasonable level' of risk is deeply unsettling; what the NWMO deems 'reasonable' from an office in Toronto is likely very different from what we consider acceptable for our families. The reliance on the ALARA (As Low As Reasonably Achievable) principle is a classic example of 'marketing fluff' used to justify releases of radioactive or hazardous substances by balancing them against 'economic' and 'practical' considerations. This suggests that if protecting our water becomes too expensive, the 'reasonable' threshold might simply be moved. Furthermore, the 'graded approach' to oversight sounds like a bureaucratic excuse to apply less scrutiny to activities they unilaterally decide are lower risk, which provides little comfort to a community in the immediate shadow of the Revell site.
Impacts on Local Recreation: The NWMO's mention of evaluating changes to 'air, water, land, plants, and animals' and implementing 'environmental monitoring' has direct, potentially chilling effects on our local way of life. For generations, the Revell area has been a prime location for hunting and fishing; the introduction of an industrial 'exclusion zone' and the stigma of a nuclear site will likely drive game away and deter locals from harvesting off the land. Our snowmobile and ATV trails, which are the lifeblood of winter recreation in Melgund, face disruption from increased heavy traffic and potential land access restrictions. There is also a significant concern that the Dyment Recreation Hall, our primary community gathering space, will be overshadowed by the influx of a transient workforce and the industrialization of the landscape, turning a quiet rural haven into a high-traffic corridor. The document fails to address how 'environmental monitoring' equipment and personnel will intrude upon the solitude that residents and campers currently enjoy in the bush.
Corrective Measures & Recommendations
The NWMO must move beyond vague promises and provide Melgund Township with a legally binding 'Zero Discharge' commitment for hazardous and radioactive materials, rather than hiding behind the flexible ALARA principle. We require a dedicated, community-led environmental monitoring station located specifically in Dyment, with real-time data accessible to the public, to ensure that 'reasonable' risks are not being exceeded without our knowledge.
Additionally, the proponent must establish a Recreation and Land Use Mitigation Fund specifically for Melgund residents. This fund should guarantee the maintenance and relocation of any impacted snowmobile or ATV trails and provide long-term financial support for the Dyment Recreation Hall to ensure it remains a viable community hub amidst the industrialization of the Revell site. Transparency is needed on exactly which lands will be closed to hunting and fishing, with a requirement for 'land-for-land' replacement to ensure our recreational footprint is not permanently diminished.
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 show a high degree of alignment with the IAAC Summary of Issues (SOI), particularly regarding the transparency of environmental monitoring and the protection of local land use. The community’s concern regarding vague monitoring parameters (Observation 3) is directly mirrored in the IAAC’s section on "Monitoring and institutional control," which flags concerns over monitoring methods and the need for transparency in reporting results. Furthermore, the Township’s specific request for a monitoring station in Dyment with real-time data supports the IAAC’s Annex A recommendation for increased oversight of effects during construction and operations for communities in close proximity to the Revell site.
There is also strong alignment regarding the socio-economic impacts on land use. Melgund’s concerns about the industrialization of the Revell site and the displacement of hunting, fishing, and ATV/snowmobile trails are validated by the IAAC’s "Socio-economic impacts to land use" section. This section specifically identifies the need for information on how the project affects recreation, hunting, and existing road access. The Township’s recommendation for a "land-for-land" replacement strategy provides a concrete mitigation pathway for the general concerns summarized by the Agency.
A significant technical alignment exists between the Township’s critique of the ALARA (As Low As Reasonably Achievable) principle and the IAAC’s inclusion of "Radiation exposure limits" in Annex A. While the IAAC notes general concerns that current limits may be unsafe, Melgund’s analysis provides a more specific policy critique, arguing that the "economic" and "practical" flexibility within ALARA allows for environmental degradation. This supports the IAAC’s "Radiological effects on health" theme by highlighting a specific regulatory loophole that the community feels prioritizes proponent costs over local health.
However, a gap exists regarding the "graded approach" to regulation. Melgund Township specifically flagged that lower-risk activities—often those causing the most local nuisance, such as noise, dust, and traffic—might receive less oversight (Observation 4). While the IAAC SOI mentions "nuisances" generally under construction effects, it does not explicitly address the community’s concern that the CNSC’s regulatory framework might intentionally de-prioritize these "lower-risk" local impacts. Additionally, the Township’s demand for a legally binding "Zero Discharge" commitment and a dedicated "Recreation and Land Use Mitigation Fund" for the Dyment Recreation Hall represents a specific local requirement for financial and legal certainty that goes beyond the broader "distribution of economic benefits" currently outlined in the IAAC’s summary.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| The definition of 'reasonable' in ALARA is subjective and includes 'economic' and 'practical' considerations. | The ALARA principle allows for pollution if the cost of preventing it is deemed too high, which could lead to environmental degradation near Melgund. | A clear, numerical definition of what constitutes an 'unreasonable' risk and a commitment to prioritize health over cost. |
| The 'safety case' is presented as a finished product for dialogue rather than a collaborative investigation. | Melgund residents may feel their concerns are being managed rather than addressed if the 'safety case' is the only basis for dialogue. | Independent, community-funded technical reviews of the safety case specifically for Melgund Township. |
| Vague commitments to 'environmental monitoring' without specifying locations or parameters. | Monitoring programs can be intrusive and may not cover the specific areas where locals hunt, fish, or recreate. | A detailed map of proposed monitoring stations and a list of all substances to be tracked, including non-radioactive hazardous materials. |
| The 'graded approach' allows for less oversight on activities deemed 'lower risk' by the regulator. | The 'graded approach' could mean that the impacts most felt by locals (noise, dust, traffic) receive less regulatory oversight than the nuclear aspects. | Clarification on which project activities will be subject to 'lower' oversight and how local nuisances will be managed. |
Working Group Recommendations
Challenge the Proponent to demonstrate 100% self-sufficiency in emergency response capacity for the Revell site, including fire suppression, emergency medical services, and hazardous material spill response.
Request a technical justification for the application of the ALARA principle where 'economic' and 'practical' considerations might be used to justify radioactive or hazardous releases into the local watershed.
Request a detailed map and list of proposed environmental monitoring stations, specifically identifying locations within Melgund Township and the Revell area used for local harvesting.
Demand that the 'Safety Case' include a specific assessment of the 'stigma effect' on local property values and the long-term viability of the Dyment Recreation Hall.
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.