Section Synopsis
Pages: 221-222The provided text outlines the preliminary hydrogeological assessment for a Deep Geological Repository project. It identifies potential impacts on groundwater levels and quality from underground development and surface facilities. The proponent claims that through an integrated water management system and the use of non-acid generating excavated rock, residual effects will be minimal. Although a conceptual groundwater model is currently incomplete, the proponent characterizes the risk of adverse environmental effects as 'low,' citing well-established mitigation strategies and regulatory oversight. The text also notes that hydrogeological changes may influence other factors such as surface water, fish habitat, and Indigenous land use.
Community Assessment Narrative
The submission exhibits a significant logical tension by concluding that residual risks to hydrogeology are 'low' while simultaneously admitting that the conceptual groundwater model—the primary tool for such a determination—is not yet completed. This 'conclusion-first' approach undermines the scientific rigor of the document, as it relies on industry experience and general assumptions rather than site-specific data. The assertion that drawdown effects will be limited to 'a few hundred metres' lacks a quantitative basis in the absence of the aforementioned model, making it difficult for reviewers to assess the potential impact on nearby wetlands or private wells.
Furthermore, the tone of the document is notably optimistic, frequently using terms like 'well-established' and 'not anticipated' to minimize perceived risks. While the proponent mentions sharing information with the Wabigoon Lake Ojibway Nation (WLON) and the Township of Ignace, the text describes a one-way flow of information rather than a collaborative or consultative process. There is no mention of how Indigenous Traditional Knowledge might inform the hydrogeological model or the definition of 'acceptable' risk. This lack of transparency regarding the data gaps and the reliance on future regulatory processes to fill those gaps may reduce public confidence in the assessment's objectivity.
Corrective Measures & Recommendations
The proponent should prioritize the completion and independent peer-review of the conceptual groundwater model before finalizing risk characterizations. This model must explicitly define the 'few hundred metres' of anticipated drawdown with high-resolution mapping and provide sensitivity analyses for various climate and geological scenarios. By providing the quantitative data that supports the 'low risk' claim, the proponent can move from speculative assertions to evidence-based conclusions, which is essential for a robust Impact Assessment.
To address social and cultural concerns, the proponent should establish a collaborative groundwater monitoring program that includes direct participation from the Wabigoon Lake Ojibway Nation and local community members. This program should go beyond 'sharing' results and instead involve these groups in selecting monitoring well locations and defining the thresholds for 'material departures' from baseline conditions. Integrating local and traditional knowledge into the hydrogeological framework will ensure that the assessment respects the cultural significance of water and provides a more comprehensive understanding of potential impacts on traditional land use.
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 Melgund Township community assessment of the proponent’s preliminary hydrogeological findings shows a high degree of alignment with the "Summary of Issues" (SOI) published by the Impact Assessment Agency of Canada (IAAC). Specifically, the community’s concern regarding the incomplete conceptual groundwater model directly supports the IAAC’s identified issue under Groundwater and Surface Water, which notes uncertainties regarding effects on watercourses and local drinking water sources. By flagging that the proponent has characterized risks as "low" despite lacking a completed, calibrated model, the Township’s analysis validates the IAAC’s broader concern in the Project Description section regarding how uncertainty and risk are characterized in the initial project documentation.
There is also a strong alignment regarding the geochemical behavior of excavated materials. The community’s observation that the proponent’s "no residual effects" claim relies entirely on the assumption that all rock is non-acid generating mirrors the IAAC’s specific issue under Geology, geochemistry, and geological hazards, which highlights concerns about acid rock drainage and metal leaching. The Township’s call for a detailed waste rock management plan and higher sampling density provides a technical pathway to address the "Geochemical behaviour of rock material" issue flagged by the Agency.
Furthermore, the community’s critique of vague spatial terms—specifically the "few hundred metres" of anticipated drawdown—addresses a significant gap in the proponent’s current submission. This supports the IAAC’s requirement for a better understanding of Potential and cumulative effects on water, including discharge rates and water levels. Without the high-resolution mapping requested by the Township, the "uncertainty related to project effects" cited in the Indigenous Peoples section of the SOI cannot be adequately resolved, as stakeholders remain unable to determine if specific culturally significant water sources fall within the impact zone.
Finally, the Township’s findings regarding the "notification-style" information sharing process align with the IAAC’s concerns under Adequacy of Indigenous engagement and Monitoring and institutional control. The community’s assessment identifies a discrepancy between the proponent’s current approach and the Agency’s expectation for meaningful, ongoing engagement and transparency in reporting monitoring results. The Township’s findings suggest that the current framework lacks the collaborative depth necessary to satisfy the IAAC’s focus on Indigenous-led assessments and the incorporation of local knowledge.
Recommendations
The working group recommends that the proponent be required to submit a completed, peer-reviewed conceptual groundwater model as a prerequisite for any further risk characterization. This recommendation directly addresses the IAAC’s concerns regarding "high uncertainty" and "novel project design" by replacing speculative "low risk" assertions with quantitative, evidence-based data. By requiring high-resolution mapping of drawdown contours and sensitivity analyses for climate scenarios, the Township ensures that the "Potential and cumulative effects on water" identified in the SOI are evaluated with the scientific rigor necessary for a federal impact assessment.
Additionally, it is recommended that a formal, collaborative groundwater monitoring framework be established that includes the Wabigoon Lake Ojibway Nation and Melgund Township as active partners rather than passive recipients of data. This recommendation is designed to resolve the IAAC’s identified issues surrounding "Social cohesion," "Adequacy of Indigenous engagement," and "Monitoring and institutional control." By involving local and Indigenous partners in selecting monitoring locations and defining thresholds for "material departures" from baseline conditions, the proponent can address the psychosocial health impacts and mistrust identified in the SOI, ensuring that the management of water—a resource of immense cultural and physical significance—is handled through a transparent and inclusive process.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| The conceptual groundwater model is planned but not yet completed. | Predicting low risk without a completed model prevents a rigorous scientific review of the project's impact. | The completed model, including calibration data and uncertainty analysis. |
| The term 'a few hundred metres' is used to describe the extent of drawdown without supporting data. | Vague spatial terms prevent stakeholders from understanding if their specific lands or resources are at risk. | Specific, mapped drawdown contours based on hydrogeological modelling. |
| Information sharing with Indigenous groups and the township is described as a notification process rather than a consultation. | A lack of collaborative monitoring can lead to mistrust and a failure to identify impacts on culturally significant water sources. | A framework for Indigenous and community-led groundwater monitoring and data verification. |
| The claim that residual effects on water quality are 'not anticipated' relies entirely on the assumption that all excavated rock is non-acid generating. | If the rock is not uniformly non-acid generating, groundwater quality could be permanently degraded. | A detailed waste rock management plan and a broader sampling density report for geochemical testing. |
Working Group Recommendations
Formally challenge the exclusion of the Local Services Board of Melgund from the list of entities receiving site-specific mitigation measures and monitoring requirements.
Request the immediate completion and peer review of the 'Conceptual Groundwater Model' to substantiate the claim that drawdown effects will be limited to 'a few hundred metres'.
Require the Proponent to demonstrate 100% self-sufficient emergency response capacity for failures within the 'integrated water management system' (e.g., pump failure, storage overflow).
Request the specific geochemical sampling density and methodology used to determine that all excavated rock is 'non-acid generating'.
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.