Review of Section 14.6.2: Hydrogeology and Hydrogeochemistry
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
The Nuclear Waste Management Organization (NWMO) has outlined plans to complete additional baseline studies to support their initial licence application and Impact Statement. As detailed in the Initial Project Description, this work involves collecting data from shallow groundwater ‘nests’ and deep boreholes to characterize the local water systems. The proponent intends to develop an initial groundwater model by 2024–2025, utilizing geological and hydraulic information to understand the interface between surface water and groundwater. Furthermore, the plan includes ongoing quarterly or monthly sampling for Contaminants of Potential Concern (COPCs), including metals, nutrients, and radionuclides.
Underlying Assumptions
Our review of the proposed work identifies several implicit assumptions regarding the sufficiency of the baseline data:
- It is assumed that the current and planned locations of monitoring wells are spatially sufficient to represent the complex hydrogeology of the entire project area without explicit justification.
- The plan assumes that ‘gross alpha and gross beta’ screening is adequate for establishing a radiological baseline, potentially overlooking the need for specific isotope identification at this stage.
- There is an assumption that undefined ‘select study areas’ will be representative enough to capture the risks associated with semi-volatile organic compounds.
Community Assessment
Through our consultation process, we have identified critical gaps in the proposed methodology. A primary concern is the lack of spatial rationale for the placement of monitoring nests. Without maps or geological justifications explaining why specific locations were chosen, the community cannot independently verify the accuracy or representativeness of the resulting groundwater model. Furthermore, the reliance on gross alpha and beta measurements for radiological baselines is viewed as an oversimplification. This approach may miss low-level concentrations of specific long-lived isotopes that are critical for long-term safety assessments. Finally, the ambiguity surrounding how ‘select study areas’ are identified creates a risk of data cherry-picking, potentially ignoring sensitive zones where organic compounds or sewage effluent impacts might be most significant.
Path Forward
To ensure the integrity of the environmental assessment, we recommend the following corrective measures:
- Spatial Transparency: The proponent must provide a comprehensive mapping and rationale for all monitoring locations, explaining how they correspond to the repository footprint and potential contaminant migration pathways.
- Specific Isotope Monitoring: The baseline suite should be expanded beyond gross screening to include specific isotopes associated with used nuclear fuel, such as Iodine-129 and Cesium-137.
- Defined Criteria: Explicit criteria must be established for the selection of study areas regarding semi-volatile organic compounds to ensure the assessment is rigorous and inclusive.
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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