Groundwater Protection, Private Well Reliance, and Unorganized Territory Impacts in Melgund Township

This submission is informed by extensive comments and feedback collected from community members and local area residents living in the closest proximity to the proposed Deep Geological Repository (DGR) site. These perspectives were gathered during a series of public information sessions organized by Melgund Recreation, Arts and Culture, hosted by the Local Services Board of Melgund and community members from April 20-24, 2026. 

These engagement efforts were made possible through support from the IAAC Participant Funding Program, ensuring that the specific concerns of the unorganized communities and local peoples living closest to the site—often overlooked in regional planning—are directly integrated into the federal impact assessment process.

Context and Infrastructure Vulnerability

This submission provides a detailed assessment of the Draft Tailored Impact Statement Guidelines (DTISG) as they pertain to communities and local peoples in the unorganized territories of Melgund Township and the surrounding area. In accordance with the Summary of Issues (SOI), which identifies groundwater quality and human health as core concerns, this intervention highlights what we believe is a critical geographic oversight.

Residents of Dyment and Borups Corners operate within a zero-service infrastructure reality, where 100% of the population relies on private wells and cisterns. Unlike the neighbouring municipalities of Ignace or Dryden, these communities possess no municipal water backup. Consequently, the DTISG's current approach to Line 752 must be amended to recognize that for these specific receptors, groundwater is the sole critical infrastructure for human habitation. For these residents, any detectable negative change in water quality or quantity must be defined as a significant adverse effect due to the total lack of alternative supply.

Technical Gaps in Draft DTISG (Lines 749–759)

The Draft DTISG at Line 752 mandates that the proponent describe existing groundwater quality and its current and potential use. However, the current language is insufficiently descriptive for communities reliant on private wells.

The guidelines currently allow for a regional characterization of aquifers, which often utilizes aggregation bias by grouping Melgund with the broader Kenora Census Division. This methodology is scientifically inadequate for an impact assessment involving a deep geological repository.

As noted in the Summary of Issues regarding the interconnectedness of environmental components, we feel the DTISG must be updated to require a site-specific, receptor-based baseline. We would like to see the Proponent provide progressive characterization of the water table during the project lifecycle; for residents whose survival depends on a single well, a comprehensive, static baseline must be verified and made public prior to any site disturbance or blasting activities.

The Intersection of Water Security and Food Security

The Impact Statement must bridge the gap between Section 5.3 and Section 8.1 of the DTISG. In Melgund, water wells are the foundational element of the subsistence economy. Groundwater is utilized extensively for the processing and preservation of harvested game and fish, which are activities central to the recreational and food security lifeways of the region. If well water quality is compromised, the ability to safely process local food sources is destroyed. The DTISG must therefore mandate that the proponent assess the cascading impacts of groundwater degradation on regional food security, specifically citing the intersection of Line 752 and the socio-economic indicators in Section 8.0.

Assessment of Project Stressors: Blasting and Drawdown

The Draft DTISG must explicitly address the physical risks to private well integrity mentioned in the Summary of Issues under project activities and potential effects. Specifically, the construction of the DGR requires intensive blasting and high-volume industrial water usage. For the shallow residential wells in communities such as Dyment, Borups Corners and the surrounding local area, these activities pose two immediate threats: structural damage to well casings or fissure shifts caused by vibrations, and hydrogeological drawdown that could render wells dry. We recommend that the DTISG be amended to require stress-testing of the local water table against the project's peak industrial demand and a detailed vibration impact study specifically targeting the residential clusters within a 15-kilometre radius of the Revell Site.

Recommended Amendments and Mandatory Requirements

To ensure the Final TISG provides adequate protection, we propose several mandatory requirements be integrated into the Final Guidelines.

Regarding the amendment to Line 752 for a mandatory house-by-house baseline, the proponent must conduct a detailed hydrogeological audit of every private well and cistern within a 15-kilometre radius of the project, including seasonal water quality testing and flow-rate measurements. Furthermore, an amendment to Section 5.3 must require specific modelling of runoff and seepage from the Excavated Rock Management Area into the shallow aquifers used by Melgund residents, alongside a detailed mitigation plan for acid rock drainage.

In alignment with the concerns regarding long-term safety, forensic isotopic fingerprinting must be included in baseline testing for specific radionuclides and trace metals. This fingerprinting is essential to provide a scientific baseline that prevents the proponent from attributing future degradation to natural variations or pre-existing conditions.

Finally, the DTISG must require the proponent to outline a Water Security Guarantee within the Impact Statement. This must be a legally binding commitment to provide immediate, equivalent potable water and permanent well replacement for any household experiencing quantity or quality disruptions, regardless of whether the causal link is still under scientific review.

Strengthening Community Collaboration (Lines 1276–1281)

We request a critical amendment to Line 1276 of the DTISG. The current draft states the proponent should work with local municipalities and boards. For the residents of Melgund Township and the surrounding area, who live in the most immediate proximity to the Revell Site, this language is too permissive. Line 1276 must be amended to state that the proponent must work with the listed entities. Furthermore, this mandatory collaboration must extend to local peoples living in Melgund Township and the surrounding unorganized areas.

This collaboration must be supported by the provision of technical and financial resources to local communities and peoples closest to the site. This funding is required to enable the community to meaningfully participate the proponent’s data collection and to implement Community-Based Participatory Research (CBPR) as referenced in Line 1277. This includes training residents and local peoples in understanding and participating in water quality monitoring of their own private, communal wells and water sources, ensuring they have the capacity to meaningfully contribute to the requirements of Section 7 and Section 8.3.2.

Ethical Research Design and Co-Design Mandates

A fundamental deficiency in the current DTISG is the lack of a mandatory framework for ethical research design that prioritizes the agency of local receptors. To ensure the scientific integrity of the Impact Statement, the guidelines must be amended to require that all studies affecting Melgund Township and the surrounding area are co-designed with local residents and local peoples. Ethical research in this context means moving beyond consultation toward a partnership model where the community has a say in the parameters, timing, and methodologies of the studies.

Specifically, the DTISG must mandate that the proponent provides opportunities for local peoples living closest to the area to meaningfully participate in the co-design of monitoring programs and socio-economic impact assessments. Research should not be a proponent-led process imposed upon the community; rather, it should be an inclusive exercise where local knowledge—particularly regarding historical water patterns and subsistence land use—is treated with the same evidentiary weight as the proponent's technical modelling. This approach ensures that the research design is culturally appropriate, ethically sound, and grounded in the lived reality of the people most vulnerable to the project's long-term effects.

Conclusion

In the unorganized territories of Melgund and the surrounding area, groundwater protection is a prerequisite for the survival of the community. The IAAC must ensure that the Final TISG reflects the high stakes of private well reliance. By adopting these receptor-specific requirements, strengthening the language of community collaboration from "should" to "must," and mandating an ethical co-design approach to research, the Agency will fulfil its mandate to assess the health, social, and economic conditions of those most directly impacted by the Revell Site DGR project.

We thank the IAAC Participant Funding Program for supporting the community outreach, engagement, and information sessions that made the preparation of this technical submission possible. We also thank the IAAC and CNSC for leading information sessions with the communities, local peoples closest to the site.