Section Synopsis
Pages: vii-viiiThis document outlines the regulatory framework and initial licensing phase for the proposed Deep Geological Repository (DGR) at the Revell site. It identifies the federal and provincial acts governing the project, such as the Impact Assessment Act and the Nuclear Safety and Control Act, and details the scope of the first license application, which focuses on site preparation, infrastructure development, and the construction of a worker accommodation camp.
Community Assessment Narrative
The NWMO's summary of 'Regulatory Oversight' is a classic example of using a blizzard of acronyms—IAA, NFWA, NSCA—to create a veneer of rigorous control while glossing over the immediate, disruptive realities for those of us in Melgund Township. By framing the project through high-level federal 'licensing requirements,' the document distances itself from the ground-level chaos of 'site clearing, grading, and terracing.' For residents in Dyment and Borups Corners, these aren't just regulatory checkboxes; they represent the arrival of heavy machinery, dust, and the permanent scarring of the landscape less than 10km from our front doors. The mention of 'general accordance' with REGDOC-1.2.3 is typical corporate hedging, providing the proponent with wiggle room while offering the community no specific guarantees on safety or noise limits.
Impacts on Local Recreation: The proposed scope of the initial license is a direct threat to the lifestyle of Melgund residents. 'Site clearing' and 'fencing' mean the loss of traditional land access for hunting and foraging. The 'primary access road' and 'worker accommodation camp' will inevitably lead to increased traffic and noise, shattering the acoustic environment essential for a successful hunt or a quiet weekend at the lake. We are particularly concerned about the 'worker accommodation camp' bringing hundreds of temporary residents who will compete for local fishing spots and potentially overwhelm the Dyment Recreation Hall, which is the heart of our small community. The document mentions a 'helipad' and 'Excavated Rock Management Area' without any acknowledgement of how the visual and noise pollution will degrade the camping and ATV trail experiences that define our region. If our trails are cut off by 'fencing' or 'utilities,' the NWMO is effectively seizing the recreational commons of Melgund without a word of compensation or alternative routing.
Corrective Measures & Recommendations
The NWMO must move beyond 'plain language' generalities and provide a Melgund-specific Impact Mitigation Agreement. This should include a legally binding commitment to maintain or reroute all existing ATV and snowmobile trails affected by the Revell site footprint and the primary access road. Furthermore, the proponent must provide a detailed noise and light pollution study specifically modeled for the residents of Dyment and Borups Corners, ensuring that the 'helipad' and 'worker camp' do not disrupt the rural character of our township.
To address the social strain, the NWMO should provide direct funding for the Dyment Recreation Hall to ensure it can withstand increased usage and remain a dedicated space for permanent residents. We also demand a 'Local Access Guarantee' that ensures site preparation activities do not restrict water body access for local fishers and hunters. The proponent must clarify what 'general accordance' means in practice and provide a transparent mechanism for Melgund residents to report and resolve regulatory grievances without having to navigate the bureaucracy of the CNSC.
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 assessment 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) on February 16, 2026. Specifically, the community’s concern regarding the construction and operation of a worker accommodation camp directly supports the IAAC’s identified issue under Infrastructure and Services: Effects of temporary workers on services and infrastructure. While the IAAC notes general concerns regarding the influx of workers and the adequacy of mitigation, Melgund Township provides critical local context by highlighting the vulnerability of volunteer-run services and the potential for the camp to overwhelm the township's social fabric. This validates the IAAC’s broader concern by identifying a specific, high-risk failure point in the proponent’s current planning.
Furthermore, there is a strong alignment between the community’s concerns regarding fencing and primary access roads and the IAAC’s section on Socio-economic impacts to land use. The IAAC explicitly identifies the need for information on how the project affects recreation, hunting, and existing roads. Melgund Township’s analysis supports this by flagging the likely severance of existing ATV and snowmobile trails. The community’s demand for a map of proposed fencing relative to local trails provides a concrete methodology for addressing the "need for information" cited in the SOI. Similarly, the community’s observations on site clearing and the Excavated Rock Management Area (ERMA) align with the IAAC’s themes of Terrestrial, riparian and wetland environments and Groundwater and Surface Water, specifically regarding altered drainage and construction-related runoff.
A notable gap exists where Melgund Township has identified a specific regulatory risk that the IAAC SOI touches upon only generally. The community’s critique of the proponent’s use of the term "general accordance" regarding REGDOC-1.2.3 suggests a potential bypass of rigorous licensing standards. While the IAAC’s Annex A: Project description mentions concerns about "clarity and transparency," the community’s finding is more technically precise, suggesting that the proponent may be seeking justifications for deviations from federal safety guides. Additionally, the community’s focus on noise and light pollution specifically modeled for Dyment and Borups Corners provides a granular level of detail that supplements the IAAC’s broader concerns regarding Human Health and Well-Being and Psychosocial health impacts.
Recommendations
The working group recommendations emphasize the necessity for the NWMO to transition from generalized "plain language" promises to a legally binding, Melgund-specific Impact Mitigation Agreement. This recommendation is designed to directly address the IAAC’s identified concerns regarding Socio-economic impacts to land use and Social cohesion and community wellbeing. By securing a "Local Access Guarantee" and a commitment to reroute recreational trails, the township can ensure that the "adverse federal effects" on social and economic conditions—as defined in the SOI—are mitigated through enforceable local protocols rather than vague proponent commitments.
To address the IAAC’s concerns regarding the Effects of temporary workers on services and infrastructure, the working group recommends direct, non-discretionary funding for the Dyment Recreation Hall and other local hubs. This ensures that the "social strain" identified in the community assessment is managed by bolstering existing infrastructure to withstand the influx of the temporary workforce. Finally, to resolve the ambiguity the IAAC noted regarding Monitoring and institutional control, the township recommends a transparent, local grievance mechanism. This would allow residents to resolve regulatory and environmental concerns directly, ensuring that the "general accordance" with regulations is replaced by local accountability and clear, site-specific thresholds for environmental protection.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Construction and operation of a worker accommodation camp. | A worker camp could overwhelm local volunteer-run services and change the social fabric of Melgund. | A detailed social impact assessment for Melgund Township and a plan for service augmentation. |
| Site clearing, grading, and Excavated Rock Management Area (ERMA). | Site clearing and rock management areas will permanently alter local ecosystems and drainage patterns. | Specific baseline data for the Revell site and clear thresholds for 'significant' environmental damage. |
| Application prepared in 'general accordance' with REGDOC-1.2.3. | The term 'general accordance' suggests the proponent may not meet the full rigors of the licensing guide. | A list of any deviations from REGDOC-1.2.3 and the justification for those deviations. |
| Development of non-nuclear supporting infrastructure including fencing and primary access road. | The primary access road and fencing will likely sever existing recreational trails. | A map of proposed fencing relative to existing local trails and a plan for maintaining land connectivity. |
Working Group Recommendations
Challenge the Proponent to demonstrate 100% self-sufficiency for fire, medical, and security services for the proposed worker accommodation camp and site preparation activities.
Request the inclusion of private residential wells in Dyment and Borups Corners within the hydrogeological baseline monitoring program for site preparation and water management facilities.
Demand the inclusion of 'Recreational Land Connectivity and Trail Access' as a Valued Component (VC) to assess the impact of fencing and the primary access road on local land use.
Require a site-specific noise and light pollution assessment for the Dyment and Borups Corners residential areas, specifically accounting for the proposed helipad and 24/7 worker camp operations.
Request a gap analysis identifying where the Proponent intends to deviate from the full requirements of REGDOC-1.2.3, given the use of the term 'general accordance'.
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.