Section Synopsis
Pages: 114-115This section of the Initial Project Description outlines the baseline data for topography, surficial soil, and sediment at the proposed Deep Geological Repository site. The topography is characterized as typical Canadian Shield with a high-resolution LiDAR survey completed. Soil studies indicate that 70% of the area is exposed bedrock or thin sediment, with baseline sampling showing some metal exceedances attributed to local geology. Sediment sampling at 23 sites also revealed naturally elevated metal concentrations, though some organic compound analyses were hindered by detection limits higher than regulatory guidelines. The proponent considers topography studies complete but plans further soil and sediment data collection.
Community Assessment Narrative
The provided text presents a technical overview of the physical environment but exhibits several weaknesses regarding data robustness and transparency. A primary concern is the proponent's reliance on a relatively small sample size—40 soil samples and 23 sediment sites—to characterize a project of this magnitude. While the text attributes various chemical exceedances (such as chromium, iron, and hexavalent chromium) to 'natural geology,' it lacks the comparative geochemical data or statistical rigor to definitively separate anthropogenic or historical impacts from natural background levels. This 'natural' attribution appears as a recurring bias that may prematurely dismiss potential environmental risks.
Furthermore, there is a notable technical failure regarding the detection limits for polycyclic aromatic hydrocarbons (PAHs) and semi-volatile organic compounds in sediments. The admission that laboratory detection limits were higher than or equal to sediment quality guidelines renders the current 'below detection' results scientifically inconclusive. From an ethical and transparency perspective, the document lacks any mention of how these baseline conditions intersect with Indigenous land use or traditional ecological knowledge. The focus is strictly on biophysical metrics, ignoring whether the 'naturally elevated' metals in soil and sediment affect the safety of traditional food sources or cultural practices in the area.
Corrective Measures & Recommendations
The proponent should immediately rectify the technical deficiency regarding sediment analysis by re-sampling and utilizing high-resolution laboratory methods with detection limits significantly lower than the most conservative federal and provincial guidelines. Without conclusive data on PAHs and semi-volatile organic compounds, the baseline remains incomplete, preventing an accurate assessment of future project-related contamination. This is a critical step to ensure regulatory compliance and public trust in the environmental monitoring framework.
Additionally, the NWMO should expand the soil sampling program to include deeper profiles beyond the current 0.3-meter limit and increase the total number of sampling locations to ensure statistical significance across all identified ecosites. To improve the socio-economic and cultural relevance of the data, the selection of future sampling sites should be co-developed with local Indigenous communities. This would ensure that areas of high cultural or subsistence value are prioritized, and that the 'naturally elevated' claims are validated through a transparent, peer-reviewed geochemical characterization that is accessible to the public.
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 analysis of Melgund Township’s public comments against the IAAC Summary of Issues (SOI) reveals a high degree of alignment, particularly regarding the inadequacy of baseline environmental data and the necessity for Indigenous inclusion in technical studies. The community’s finding that laboratory detection limits for sediment were higher than regulatory guidelines directly supports the IAAC’s identified issue under the Indigenous Peoples section regarding "Uncertainty related to project effects," which specifically cites "limited, inaccurate, or missing baseline data" as a primary concern. Furthermore, the community’s observation that the current soil sampling density and depth (0.3m) are insufficient validates the IAAC’s theme on Geochemical behaviour of rock material, where there is a stated need to understand potential environmental effects through metal leaching and geochemical reactions.
A significant alignment is also found in the Socio-Economic Conditions section of the SOI, which highlights the "need for community-led baseline data collection." Melgund Township’s critique of the proponent’s "naturally elevated" metal claims and the subjective determination that topography studies are "complete" underscores a gap in transparency and verification. The community’s assessment suggests that without more rigorous, peer-reviewed geochemical characterization, the proponent cannot meet the IAAC’s requirement for "transparency in reporting monitoring results" listed under Monitoring and institutional control.
There is a notable gap where the community assessment provides a higher level of technical specificity than the SOI. While the IAAC flags general concerns about "Radiological effects to wildlife" and "Fish and Fish Habitat," Melgund Township identifies a specific technical failure regarding PAHs and semi-volatile organic compounds due to insensitive laboratory methods. This community finding serves as a critical evidence-based validation of the IAAC’s broader concern regarding the "adequacy, clarity, and transparency of the Project Description" mentioned in Annex A. Additionally, the community’s call for co-developing sampling sites with Indigenous Nations aligns with the IAAC’s requirement for the "Consideration of Indigenous Knowledge" in project planning and assessment.
Recommendations
The working group recommends that the proponent immediately address the technical deficiencies identified in the sediment and soil baseline programs. Specifically, the proponent must commit to a re-sampling initiative that utilizes high-resolution laboratory analysis with detection limits set significantly below federal and provincial quality guidelines. This action is necessary to resolve the "Uncertainty related to project effects" identified in the IAAC Summary of Issues. By establishing a scientifically defensible baseline for PAHs and organic compounds now, the proponent can ensure that future monitoring during the construction and operational phases—as requested in the IAAC’s Annex A—is capable of detecting project-related impacts versus pre-existing conditions.
Furthermore, it is recommended that the sampling framework be expanded to include deeper soil profiles and a higher density of sampling locations to ensure statistical significance across the Canadian Shield topography. To align with the IAAC’s emphasis on Indigenous engagement and the "Current use of lands and resources," the selection of these new sampling sites should be co-developed with local Indigenous communities. This collaborative approach will ensure that the baseline data reflects areas of cultural and subsistence importance, thereby addressing the IAAC’s concern regarding potential interference with the exercise of Indigenous rights and providing the "community-led" validation essential for public trust in the Impact Statement.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Laboratory detection limits for sediment were higher than or equal to available quality guidelines. | Inconclusive data on PAHs prevents a true baseline from being established, making it impossible to detect future project impacts. | Re-sampling and analysis using more sensitive laboratory equipment and methods. |
| Limited sample size and shallow sampling depth (0.3m for soil). | Small sample sizes (40 soil, 23 sediment) may not capture the full range of variability or localized 'hot spots' of contamination. | Increased sampling density and deeper soil profile analysis. |
| Lack of integration with Indigenous knowledge or traditional land use data. | The assessment ignores whether 'naturally elevated' metals impact the safety of traditional land use activities. | Consultation with local communities to align sampling sites with areas of cultural or subsistence importance. |
| Subjective determination that topography studies are 'sufficiently complete'. | Declaring a study 'complete' prematurely may lead to gaps in the Impact Statement if new topographical concerns arise during construction. | Justification for why no further topographical monitoring is required during the site preparation phase. |
Working Group Recommendations
Request a screening-level Human Health Risk Assessment (HHRA) specifically for the 'harvested' ecosites where soil metal exceedances were identified.
Require the Proponent to re-sample sediments and utilize laboratory methods with detection limits strictly lower than federal/provincial quality guidelines, specifically for polycyclic aromatic hydrocarbons (PAHs) and semi-volatile organic compounds.
Request justification for the cessation of topography baseline studies, specifically requiring an analysis of how the 'long, narrow valleys' and 'structural features' identified in the text influence surface drainage toward Mennin Lake.
Challenge the Proponent to provide geochemical evidence (e.g., isotopic analysis or regional background comparisons) validating the claim that exceedances of metals (Aluminum, Chromium, Hexavalent Chromium, etc.) in soil and sediment are solely 'natural' and 'reflect the local geology.'
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.