Melgund Recreation, Arts and Culture
Public Comments Archive

14.2.3 Planned Work: Surface Bedrock and Deep Geology and Seismicity

Detailed Technical Assessment Report • Ref: REC-50OT-LAAO

Section Synopsis

Pages: 111-112

The provided text outlines the planned geological and seismic characterization activities for a proposed Deep Geological Repository (DGR). It identifies current data gaps in soil characterization, fracture zone geometry, and rock properties within the Revell batholith. The proponent details an iterative approach to geoscientific modeling, including future borehole drilling, 3D seismic surveys, and ongoing microseismic monitoring to address uncertainties regarding post-glacial faulting and radionuclide transport pathways.

Community Assessment Narrative

The text presents a technical roadmap for site characterization that acknowledges significant geological uncertainties while maintaining a tone of procedural confidence. A primary concern is the tension between the claim that only a 'limited amount of additional data' is needed for the initial license application and the subsequent list of substantial unknowns, such as the geometry of water-conducting fracture zones and the likelihood of post-glacial faulting. By labeling these critical safety factors as 'additional future planned work,' the proponent may be downplaying the fundamental importance of these data points to the initial Impact Statement's validity. The iterative nature of the 'Descriptive Geoscientific Site Model' is a standard scientific approach, yet in a regulatory context, it can create a 'moving target' for public and indigenous reviewers. There is a lack of transparency regarding the thresholds or 'stop-work' criteria if future data contradicts the current assumption of a 'low seismic hazard' region. Furthermore, the text focuses exclusively on technical data collection without addressing how these geological uncertainties might impact community perceptions of safety or the long-term integrity of the cultural landscape.

Corrective Measures & Recommendations

The proponent should provide a detailed matrix that explicitly links each 'data gap' to specific safety functions of the DGR. For instance, the 'gently inclined and water-conducting features' should be characterized with preliminary risk thresholds before the initial license application, rather than being deferred to future phases. This would ensure that the Impact Statement is based on a sufficiently robust baseline that accounts for the most credible worst-case scenarios of radionuclide transport through the geosphere. Additionally, the proponent must clarify the timeline and integration of the Probabilistic Seismic Hazard Assessment. To improve transparency and community trust, the results of the microseismic monitoring and the investigation into post-glacial faulting should be released in a plain-language format as they become available. This should include a clear explanation of how 'low seismic hazard' is defined and what specific geological findings would necessitate a fundamental redesign or relocation of the project components to protect the local environment and regional safety.

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 submitted 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 concerns regarding the uncertainty of fracture zone geometry and the properties of the Revell batholith directly support the IAAC’s theme of Geology, geochemistry, and geological hazards. The IAAC identifies a "Need for a detailed understanding of the rock formation... to determine if it is technically suitable to contain waste," which validates the community’s observation that water-conducting fracture zones could compromise the geosphere’s role as a primary containment barrier.

Furthermore, Melgund Township’s focus on "post-glacial faulting" and the need for a clear methodology to investigate recent fault activity aligns with the IAAC’s sections on Seismicity and Destabilization of geology and induced geological hazards. While the IAAC document broadly notes concerns about earthquakes and structural stability, the community’s assessment provides a more granular technical requirement, specifically calling for a Probabilistic Seismic Hazard Assessment and criteria for what constitutes a "significant hazard." This suggests that the community’s analysis not only supports the IAAC’s identified issues but provides the necessary technical depth to define the scope of the required Impact Statement.

A significant alignment is also found in the area of Groundwater and Surface Water. The community’s observation regarding the need for baseline hydrological mapping that connects surface water to deep fracture models directly reinforces the IAAC’s concern regarding the "Potential and cumulative effects on water" and "Radiological contamination of water." Both parties highlight the critical nature of surface-subsurface interactions. However, a notable gap identified by the community—which the IAAC touches upon only generally in Annex A: Project description—is the ambiguity between "initial" data for the license application and "future" data for "enhanced confidence." Melgund Township has flagged a specific risk that the Impact Statement may be submitted with incomplete data, a concern that warrants more explicit categorization within the federal assessment process to ensure public trust.

Recommendations

The working group recommendations emphasize the necessity of a detailed matrix that explicitly links identified data gaps to the specific safety functions of the Deep Geological Repository (DGR). By requiring the proponent to establish preliminary risk thresholds for features like "gently inclined and water-conducting features" prior to the initial license application, the community ensures that the safety case is built on a robust, verifiable baseline rather than deferred promises of future data. This recommendation directly addresses the IAAC’s identified issues regarding Long-term containment of waste and High uncertainty novel project potential for accidents and malfunctions by forcing a "worst-case scenario" analysis of radionuclide transport through the geosphere.

Additionally, the recommendations advocate for the release of microseismic monitoring results and fault activity investigations in a plain-language format. This aligns with the IAAC’s guidance in Annex A regarding Public Engagement and Communication, which calls for clear and accessible information on safety and risks. By defining specific geological findings that would necessitate a fundamental redesign or relocation, the community’s recommendations provide a practical framework for the IAAC’s "criteria for project modification, suspension and reversal." These steps are essential for translating the broad concerns listed in the SOI into actionable regulatory requirements that protect the local environment and regional safety.

Key Claims

Additional data collection is required to address gaps in soil and overburden characterization for the initial license application.
Fractures in the geosphere are the primary potential pathway for radionuclide release.
The Project site is located in a region of low seismic hazard.
Up to 10 deep boreholes and 10 shorter exploration boreholes are planned for future characterization.
Ongoing microseismic monitoring is being used to determine the presence of active faults.

Underlying Assumptions

The Revell batholith is a suitable host rock despite currently unmapped water-conducting features.
Iterative modeling is sufficient to manage risks associated with radionuclide transport pathways.
Current seismic monitoring stations provide adequate coverage for a 50 km radius to establish a safety baseline.
Geological mapping and shallow geotechnical investigations can be successfully integrated with deep subsurface data at a later stage without invalidating initial impact predictions.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
Uncertainty regarding the geometry and properties of gently inclined fracture zones at depth. If water-conducting fracture zones are more extensive than assumed, the primary containment barrier (the geosphere) could be compromised. Preliminary 3D seismic results or a sensitivity analysis showing how different fracture geometries affect transport models.
Uncertainties remain regarding the likelihood and impact of post-glacial faulting. Post-glacial faulting could cause structural damage to the DGR or create new pathways for waste migration. A clear methodology for the 'investigation of potential recent fault activity' and specific criteria for what constitutes a significant hazard.
Ambiguity between 'initial' data for the license application and 'future' data for 'enhanced confidence.' The public may feel that the Impact Statement is being submitted with incomplete data. A definitive list of which geoscientific parameters are 'essential' versus 'supplemental' for the Impact Statement.
Details of the surface and near-surface environment, such as hydrology, are still needed to finalize the design. Surface-subsurface interactions are critical for understanding how a leak might reach the biosphere. Baseline hydrological mapping that connects surface water bodies to the deep fracture network models.

Working Group Recommendations

Environment

Mandate the integration of surface hydrology data with deep geological models to address the identified gap in 'details of the surface and near-surface environment.'

The filing notes that hydrology details are still needed to 'finalize the design' and 'protect the environment.' It is critical for Melgund to understand the connectivity between surface water bodies (used for fishing and recreation) and the deep geological fracture network. This integration is necessary to predict how potential surface spills during construction or deep leaks during operation might migrate through the environment, ensuring the protection of the watershed that the community relies upon.
ENV-063
Human Environment (People)

Demand a comprehensive emergency response and management plan specifically for the planned '10 deep boreholes and up to 10 shorter-length exploration boreholes' drilling program.

The Proponent plans significant industrial activity (drilling, logging, testing) involving heavy machinery and crews. Melgund Township is an unorganized territory with zero local emergency services (no fire, police, or ambulance). Any accident, spill, or injury occurring during this exploration phase cannot rely on local capacity, and response times from distant hubs like Ignace or Dryden are significant. The Proponent must demonstrate 100% self-sufficiency for emergency response during these field activities to ensure the physical safety of the community and workers.
HEP-090
Environment

Require a definitive methodology and specific 'stop-work' criteria for the investigation of 'potential recent fault activity' and post-glacial faulting.

The text acknowledges that 'uncertainties remain regarding the likelihood and potential impact of post-glacial faulting.' In an unorganized territory with no capacity to mitigate a containment failure, the stability of the bedrock is paramount. The assumption that the region has 'low seismic hazard' must be rigorously proven, not merely monitored. Establishing clear criteria for what constitutes a disqualifying fault hazard is essential to protect the long-term environmental integrity of the land and ensure the DGR does not compromise the physical safety of the area.
ENV-064
Environment

Request immediate characterization of 'gently inclined and water-conducting features' in the Revell batholith prior to the Impact Statement, rather than deferring this to future licensing phases.

The Proponent's submission explicitly identifies fractures as the 'primary potential pathway for radionuclide release' yet categorizes the study of their geometry as 'future planned work.' For Melgund Township, where residents rely entirely on untreated local aquifers and surface water, the integrity of the geological barrier is the only protection against contamination. Allowing the Impact Statement to proceed without a validated model of these water-conducting features creates an unacceptable risk of approving a site based on incomplete safety data. This gap must be closed to ensure the baseline data accurately reflects the vulnerability of local water systems.
ENV-062

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.