Examining gaps in the Revell DGR hydrogeological risk screening
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
In the Initial Project Description, the Nuclear Waste Management Organization (NWMO) outlines potential impacts on groundwater levels and quality resulting from the construction and operation of the Deep Geological Repository. The proponent acknowledges that underground development could alter the hydrogeological regime but claims these risks will be managed through an integrated water management system and standard environmental design features. Because extensive testing suggests the excavated rock is non-acid generating, the proponent anticipates that residual effects on water quality will be minimal. Consequently, the project characterizes the risk of adverse environmental effects on hydrogeology as "low," predicting that groundwater drawdown will be spatially limited to within a few hundred metres of the underground workings.
Underlying Assumptions
Our analysis of the technical submission identifies several key assumptions that support the proponent’s "low risk" conclusion:
- Modelling Timing: It is assumed that a risk rating can be accurately assigned before the conceptual groundwater model is completed or calibrated.
- Geochemical Uniformity: The assessment assumes that all excavated rock will be consistently non-acid generating, negating the need for complex contaminant transport analysis at this stage.
- Mitigation Efficacy: There is an assumption that standard industry best practices will automatically prevent material departures from baseline conditions without site-specific validation.
- Information Flow: The process assumes that "sharing" monitoring results with the community and Indigenous groups is equivalent to active consultation or collaborative oversight.
Community Assessment
The most significant observation from our review is that the conceptual groundwater model—the primary tool for predicting how water moves through the site—is planned but not yet completed. Without this model, the characterization of the project as "low risk" lacks a rigorous, evidence-based foundation. The text uses vague spatial terms, such as "a few hundred metres," to describe the extent of groundwater drawdown. This lack of specificity prevents local landowners and stakeholders from understanding if their specific lands, wells, or resources are within the zone of influence.
Furthermore, the reliance on the assumption that all waste rock is non-acid generating requires a detailed waste rock management plan to ensure groundwater quality is not permanently degraded. From a social perspective, the current framework describes a notification process rather than a partnership. A lack of collaborative monitoring can lead to mistrust and a failure to identify impacts on culturally significant water sources, particularly those vital to the Wabigoon Lake Ojibway Nation.
Path Forward
To address these deficiencies, we recommend that the proponent prioritize the completion and independent peer review of the conceptual groundwater model before finalizing any risk characterizations. This model must explicitly define the anticipated drawdown with high-resolution mapping rather than vague estimates. Additionally, the proponent should move beyond simple information sharing to establish a collaborative groundwater monitoring program. This program must include direct participation from local community members and Indigenous partners in selecting monitoring well locations and defining the thresholds for what constitutes a "material departure" from baseline conditions.
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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