Analysis of Section 24: Environmental Management System
This article is part of a series exploring the views and perspectives of youth, artists and community members working with the Melgund Integrated Nuclear Impact Assessment Project. This initiative is a climate entrepreneurship and arts-based community recreation program, developed through community consultation, engagement participation in the integrated impact assessment process for the NWMO’s proposed Deep Geological Repository for nuclear waste fuel.
What is Proposed
In the context of the Initial Project Description, the NWMO outlines a company-wide Environmental Management System (EMS). This governance structure aims to minimize environmental effects through mitigation measures, follow-up monitoring, and strict compliance with CNSC regulatory documents and CSA standards. A central pillar of this proposal is “adaptive management,” which the proponent describes as a systematic process for continuously improving practices and addressing unanticipated effects throughout the project’s lifecycle.
Underlying Assumptions
- Sufficiency of Undefined Technology: The proposal assumes that the phrase “best available technology and techniques economically achievable” is a sufficient standard without providing specific examples or criteria for what constitutes “best” in this context.
- Infallibility of Adaptive Management: It is assumed that adaptive management can successfully mitigate any unforeseen adverse effect, potentially downplaying the need for absolute certainty in pre-project predictions.
- Internal Governance Adequacy: The text assumes that a governance structure limited to the NWMO and regulators is sufficient, implying that direct community or Indigenous oversight is not required for effective environmental protection.
Community Assessment
Our review identifies significant gaps in the proposed EMS. While the commitment to regulatory compliance is noted, the reliance on “adaptive management” as a catch-all solution is concerning. Without a framework outlining the limits of this approach—specifically what constitutes an “unacceptable” impact—there is a risk that this mechanism could be used to bypass rigorous impact prediction. Furthermore, the governance structure appears entirely internal. There is a notable absence of Indigenous Knowledge and traditional land use considerations in the monitoring design. Excluding the community from the oversight process risks failing to protect culturally significant environmental features and may erode social license.
Path Forward
To ensure the safety and trust of the community, we recommend the following corrective measures:
- Define Action Levels: The proponent must provide a detailed Adaptive Management Plan that defines specific “action levels” and “triggers” for intervention, ensuring unforeseen effects are rigorously anticipated rather than left to future discretion.
- Community Integration: The EMS must explicitly integrate Community-Based Monitoring and Indigenous Knowledge.
- Collaborative Oversight: A collaborative process should be established where local communities and Indigenous groups participate in selecting monitoring sites and interpreting data.
About the Integrated Assessment Process
The federal Impact Assessment Agency of Canada (IAAC) has formally launched the integrated impact assessment process for the proposed Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project, a major national infrastructure initiative led by the Nuclear Waste Management Organization (NWMO).
The proposed underground repository is designed to permanently contain and isolate used nuclear fuel in a secure geological formation. Wabigoon Lake Ojibway Nation and the Township of Ignace have been selected as host communities for the project. The site is located approximately 21 kilometres southeast of Wabigoon Lake Ojibway Nation and 43 kilometres northwest of Ignace, Ontario, near Highway 17.
According to project materials, the repository would provide permanent storage for approximately 5.9 million bundles of used nuclear fuel. The full lifecycle of the project is expected to span roughly 160 years, including site preparation, construction, operations, closure, and long-term monitoring.
Integrated Federal Review
Major nuclear projects in Canada are subject to an integrated assessment process jointly led by the Impact Assessment Agency of Canada and the Canadian Nuclear Safety Commission (CNSC). This “one project, one review” approach is intended to streamline regulatory oversight while ensuring rigorous evaluation of environmental, health, social, economic, and Indigenous rights impacts.
Under this framework, IAAC oversees the impact assessment requirements under the Impact Assessment Act, while the CNSC regulates nuclear safety under the Nuclear Safety and Control Act. The CNSC will issue the initial site preparation licence and manage all subsequent nuclear licensing for the project’s duration.
The integrated assessment also includes a focus on potential impacts on Indigenous Peoples, including rights, land use, cultural practices, health, and socio-economic conditions. Where potential adverse effects are identified, the process is intended to identify mitigation measures to reduce or avoid harm.
Public Comment Period Now Open
The first public comment period for the project is currently open and will run until February 4, 2026. During this phase, the public is invited to provide feedback on the Summary of the Initial Project Description submitted by the NWMO. Submissions received during this period will inform IAAC’s summary of issues, which will guide the next stages of the impact assessment. All comments submitted become part of the public project record and are posted to the federal Impact Assessment Registry.
This plain-language summary is provided by ECO-STAR North and Art Borups Corners to support public engagement.
Disclaimer: The views and perspectives expressed in this article are solely those of the independent arts program led by ECO-STAR North and Art Borups Corners. They do not reflect the official positions of the Nuclear Waste Management Organization (NWMO) or the Government of Canada.
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