Section Synopsis
Pages: 124-125The provided text outlines the planned hydrogeological, hydrogeochemical, hydrological, and water quality baseline studies for a proposed Deep Geological Repository (DGR). The Nuclear Waste Management Organization (NWMO) details the use of shallow monitoring wells and deep boreholes to characterize groundwater systems and develop a site model by 2024–2025. The plan includes regular sampling of groundwater and surface water for various Contaminants of Potential Concern (COPCs), including radionuclides and metals, alongside meteorological and flow measurements to establish environmental baselines for regulatory licensing.
Community Assessment Narrative
The text presents a technical overview of baseline data collection activities, yet it exhibits several areas where clarity and transparency could be improved. While the document lists specific monitoring frequencies and parameters, it lacks a clear rationale for the spatial distribution of the monitoring 'nests' and boreholes. This omission makes it difficult to assess whether the sampling network is truly representative of the complex hydrogeological environment surrounding a 1,000-meter deep repository. Furthermore, the mention of 'select study areas' for semi-volatile organic compounds without defining the selection criteria introduces a level of ambiguity that may be perceived as a lack of transparency or potential bias in the sampling design.
From an ethical and community engagement perspective, the reliance on 'gross alpha and gross beta' as the primary radionuclide indicators in the baseline phase is a notable simplification. For a project involving used nuclear fuel, stakeholders may expect more granular data on specific isotopes of concern. The narrative also fails to address how the monitoring program will adapt to extreme weather events or long-term climate shifts, which could significantly impact the 'quarterly or monthly' sampling reliability. Overall, while the tone is professional and descriptive, the document functions more as a list of tasks than a comprehensive strategy, leaving significant gaps regarding the scientific justification for the chosen methodologies.
Corrective Measures & Recommendations
The proponent should provide a comprehensive spatial rationale and mapping for all current and planned monitoring locations. This should include a detailed explanation of how the placement of shallow 'nests' and deep boreholes corresponds to the repository's footprint and potential contaminant migration pathways. By clarifying why specific locations were chosen and others were not, the proponent can improve the transparency of the groundwater model and build greater confidence in the baseline data's integrity.
It is also recommended that the proponent expand the baseline radionuclide suite beyond gross alpha and beta measurements to include specific isotopes associated with used nuclear fuel, such as Iodine-129 and Cesium-137. Additionally, the proponent should explicitly define the criteria for 'select study areas' regarding semi-volatile organic compounds and treated sewage effluent. Providing a clear framework for these selections will ensure that the environmental assessment is seen as rigorous and inclusive of all potential socio-economic and environmental impacts.
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 technical findings and public comments provided by 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 oversimplification of radiological baseline parameters directly supports the IAAC’s theme of Radiological Conditions, particularly the sub-issue of "Radiological contamination of water." While the IAAC identifies a general concern regarding potential effects on groundwater systems and aquifers, Melgund Township provides the necessary technical depth by flagging the proponent’s reliance on gross alpha/beta screening. The community’s observation that this approach may miss long-lived isotopes like Iodine-129 validates the IAAC’s call for a better understanding of the "types and amounts of radiological releases" and their long-term environmental effects.
Furthermore, Melgund Township’s critique of the proponent’s groundwater-surface water interface methodology aligns with the IAAC’s section on Groundwater and Surface Water, specifically the "Potential and cumulative effects on water." The IAAC notes concerns regarding hydrological regimes and ecosystem components; Melgund Township’s analysis identifies a specific technical gap in how the proponent intends to characterize the interface where contaminant transport is most critical. This suggests that the proponent’s current plan may not yet meet the IAAC’s expectation for a "detailed understanding" of the site’s hydrological characteristics.
There is also a strong alignment regarding the transparency and integrity of data collection. Melgund Township’s concerns about the "lack of spatial rationale for well placement" and the "ambiguity in the selection of study areas" for organic compounds directly mirror the IAAC’s requirements under Other Key Issues, specifically "Monitoring and institutional control." The IAAC emphasizes the need for transparency in reporting monitoring results, while the community assessment warns that vague selection criteria could lead to "cherry-picking" data. By flagging these issues, Melgund Township is providing evidence that supports the IAAC’s broader concern regarding "uncertainty related to project effects" and "missing baseline data," as noted in the Indigenous Peoples and Accidents and Malfunctions sections of the SOI.
Recommendations
The working group recommends that the proponent move beyond generalized baseline descriptions and provide a rigorous, map-based spatial rationale for all monitoring locations. This documentation must explicitly link the placement of deep boreholes and shallow monitoring nests to the specific geological fractures and potential migration pathways identified in the repository footprint. By addressing this technical gap, the proponent will fulfill the IAAC’s requirement for a "detailed understanding of the rock formation" and provide the community with the transparency necessary to independently verify the 2024–2025 groundwater model.
Additionally, it is recommended that the baseline sampling protocol be expanded to include a comprehensive suite of site-specific radionuclides, such as Cesium-137 and Iodine-129, rather than relying on gross screening. This adjustment is essential to address the IAAC-identified concerns regarding "Radiological effects to the environment" and "Radiological effects on health." Establishing a high-resolution isotopic baseline now is the only way to ensure that any future deviations during the construction or operational phases can be accurately detected and mitigated, thereby protecting the long-term health and socio-economic well-being of Melgund Township and surrounding regional communities.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Lack of spatial rationale for well placement. | Without knowing the spatial distribution of wells, the accuracy of the 2024-2025 groundwater model cannot be independently verified. | Maps and geological justifications for the specific locations of monitoring nests. |
| Oversimplification of radiological baseline parameters. | Relying on gross alpha/beta may miss low-level concentrations of specific long-lived isotopes critical for long-term safety assessments. | A detailed list of specific radionuclides to be monitored beyond gross screening. |
| Ambiguity in the selection of study areas for organic compounds. | Vague terms like 'select study areas' can lead to accusations of 'cherry-picking' data or ignoring sensitive zones. | Defined criteria for how 'select study areas' are identified and prioritized. |
| Limited detail on the groundwater-surface water interface study methodology. | The interface between surface and groundwater is critical for contaminant transport; the text mentions it but doesn't explain the methodology for characterizing it. | Specific technical protocols for how the interface monitoring will be conducted. |
Working Group Recommendations
Request the specific geological and spatial rationale for the location of the three shallow well 'nests' and six deep boreholes to validate their representativeness for the 2024-2025 groundwater model.
Require detailed technical protocols for how the 'groundwater-surface water interface' will be characterized and monitored, beyond the general description provided.
Request clarification on the source and location of the 'treated sewage effluent' parameters (e.g., total coliforms) currently being monitored in the surface water quality program.
Challenge the sufficiency of using 'gross alpha and gross beta' as the primary radiological indicators and formally request the inclusion of specific isotopes (e.g., Iodine-129, Cesium-137) in the baseline water quality program.
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.