Section Synopsis
Pages: 242-245The provided text outlines the NWMO's approach to assessing and mitigating health impacts on non-Indigenous populations for the Deep Geological Repository project. It distinguishes between direct health effects, which it claims are managed exclusively under the Nuclear Safety and Control Act (NSCA) and the Canadian Nuclear Safety Commission (CNSC), and indirect effects related to biophysical and social determinants of health. While acknowledging that project activities could initially result in moderate to high adverse effects on health via air quality, noise, and social changes, the proponent concludes that standard mitigation measures and corporate policies will reduce all residual risks to a negligible level.
Community Assessment Narrative
The document exhibits a significant reliance on jurisdictional partitioning to limit the scope of the Impact Assessment Act (IAA). By asserting that direct health effects are the sole province of the NSCA, the proponent risks creating a fragmented assessment where the holistic 'one project, one assessment' principle is undermined. This approach assumes that the CNSC's licensing process will satisfy all public concerns regarding health, potentially overlooking the integrated socio-economic and biophysical health pathways that the IAA is designed to capture. Furthermore, the tone is notably optimistic, frequently using terms like 'well-established' and 'high level of confidence' to describe mitigation strategies that have not yet been applied to this specific local context. There is a logical tension between the admission that local communities lack sufficient substance abuse and addiction services and the subsequent claim that the project's impact on these issues will be 'negligible.' The reliance on internal corporate mechanisms, such as a 'Code of Conduct' and 'Employee Assistance Programs,' to mitigate broad regional social issues like gender-based violence and substance abuse appears unsubstantiated. These measures address workplace behavior but do not necessarily account for the complex, off-site social dynamics introduced by a large, non-local workforce and increased disposable income in a vulnerable regional setting. The transition from 'moderate to high' potential effects to a 'negligible' residual risk rating lacks a transparent, evidence-based bridge, appearing more as a predetermined conclusion than a rigorous derivation.
Corrective Measures & Recommendations
The proponent should provide a more integrated health impact assessment that bridges the gap between the NSCA's radiological focus and the IAA's broader social health mandates. Specifically, the NWMO must demonstrate how it will support regional health and social infrastructure, given the acknowledged lack of existing services. Relying on internal employee programs is insufficient for mitigating community-wide impacts; therefore, a formal commitment to funding or augmenting local mental health and addiction services should be detailed to justify the 'negligible' risk claim. Additionally, the proponent should conduct a more granular analysis of the 'accommodation camp' model's impact on local social safety. This should include specific, measurable agreements with local law enforcement and social service providers to monitor and respond to potential increases in gender-based violence and substance abuse. The current reliance on a corporate Code of Conduct is an internal administrative tool and does not constitute a comprehensive community-level mitigation strategy. Evidence from comparable large-scale infrastructure projects should be cited to validate the effectiveness of these proposed social mitigations.
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 "Summary of Issues" (SOI) published by the Impact Assessment Agency of Canada (IAAC), particularly regarding the social and health implications of the Deep Geological Repository (DGR) project. The Township’s concern regarding the proponent’s dismissal of direct health effects under the Impact Assessment Act (IAA) in favor of the Nuclear Safety and Control Act (NSCA) directly mirrors the IAAC’s inclusion of "Radiological effects on health" and the specific guidance in Annex A regarding the need for "Monitoring health impacts." The community’s call for a transparent mapping of how these two regulatory frameworks will integrate supports the IAAC’s requirement for the proponent to clarify how issues will be addressed through existing legislative frameworks.
A significant point of validation exists between the community’s observations on social safety and the IAAC’s section on "Infrastructure and Services." Melgund Township’s critique of the proponent’s reliance on an internal "Code of Conduct" to mitigate regional gender-based violence and substance abuse aligns perfectly with the IAAC’s flagged concern regarding the "potential increases in gender-based violence" and the "adequacy of mitigation measures for these effects." The community assessment provides a necessary local lens, arguing that a "negligible" impact rating is unsubstantiated if local services are already at capacity—a sentiment echoed in the IAAC’s "Social cohesion and community wellbeing" and "Psychosocial health impacts" categories.
Furthermore, the community’s identification of a gap in the proponent’s socio-economic mitigation planning—specifically the lack of a plan to augment limited local mental health and addiction services—supports the IAAC’s concerns under "Emergency preparedness" and "Effects of temporary workers on services." While the IAAC SOI identifies these as broad areas of concern, the Melgund Township analysis provides the technical justification for why the proponent’s current "negligible" risk conclusion is viewed as unsubstantiated. The community’s demand for a transparent methodology regarding the determination of risk levels for social variables highlights a specific evidentiary gap that the IAAC SOI also alludes to in its request for information on the effectiveness of proposed mitigations.
Recommendations
The working group recommends that the proponent move beyond internal administrative tools, such as corporate Codes of Conduct, and instead develop a comprehensive, community-level health and social mitigation strategy. This strategy must bridge the current gap between the CNSC’s radiological focus and the IAA’s broader social health mandates. To address the issues identified in the IAAC’s "Infrastructure and Services" section, the proponent should establish formal, legally binding agreements with local law enforcement and social service providers. These agreements should include specific funding commitments to augment local mental health and addiction services, ensuring that the influx of temporary workers does not degrade the health outcomes of the existing population.
Additionally, it is recommended that the proponent provide a granular, evidence-based analysis of the "accommodation camp" model, citing case studies from comparable large-scale infrastructure projects to validate their claims of "negligible" risk. This analysis should include a transparent methodology for determining social risk levels, as requested in the community’s technical observations. By shifting from internal policies to external, community-integrated support systems, the proponent can better align with the IAAC’s requirements for adequate mitigation and address the Township’s concerns regarding the long-term sustainability of local social infrastructure.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Dismissal of direct health effects under IAA based on NSCA overlap. | The exclusion of direct health effects from the IAA process may lead to a lack of transparency and public trust in the overall impact assessment. | A mapping of how NSCA health assessments will be integrated into the public IAA registry to ensure a holistic review. |
| Reliance on internal 'Code of Conduct' to mitigate regional gender-based violence and substance abuse. | If local services are already limited, a 'negligible' impact is unlikely without significant external investment, regardless of corporate codes. | Specific data or case studies showing how these measures protect the broader community, not just the worksite. |
| Acknowledgment of limited local addiction and mental health services without a plan to augment them. | The project may exacerbate existing service gaps, leading to decreased health outcomes for the current population. | A detailed socio-economic mitigation plan that includes capacity building for local health and social service providers. |
| The 'negligible' risk conclusion for social determinants appears unsubstantiated. | The risk matrix may underestimate the actual impact if the 'likelihood' or 'degree' of social effects is higher than the proponent assumes. | A transparent methodology for how the risk levels in Table 19.16 were determined for social variables. |
Working Group Recommendations
Require the Proponent to establish a formal funding mechanism to augment regional mental health and addiction services, moving beyond internal Employee Assistance Programs (EAP).
Demand the Proponent provide a comprehensive plan for 100% on-site emergency medical, fire, and mental health crisis response capacity for the project site and accommodation camp.
Request the Proponent provide localized, site-specific modeling for air quality, noise, and vibration impacts that accounts for the near-zero baseline of the Melgund unorganized territory.
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.