OPG Deep Geologic Repository Information Session Notes November 11, 2016 OPG Offices 700 University Avenue Toronto, ON OPG DGR Information Session Notes November 11, 2016 This page left intentionally blank OPG DGR Information Session Notes November 11, 2016 Table of Contents 1.0 Background ..................................................................................................................... 1 2.0 Meeting Agenda .............................................................................................................. 2 3.0 Participants ..................................................................................................................... 3 4.0 Information Session Notes............................................................................................... 4 4.1 Introductions ................................................................................................................ 4 4.2 Overall Review and Approval Process ......................................................................... 5 4.2 Presentation 1: Alternate Locations Environmental Effects .......................................... 6 4.3 Presentation 2: Transportation ....................................................................................12 4.4 Presentation 3: Updated Cumulative Effects Analysis .................................................16 4.5 Presentation 4: Mitigations Report ..............................................................................19 5.0 Additional Topics Raised.............................................................................................22 6.0 Final Comments from Participants ..............................................................................22 7.0 Thanking Participants and Next Steps ........................................................................23 Appendix A – Table Summarizing Post-Information Session Clarifications Appendix B – PowerPoint presentation OPG DGR Information Session Notes November 11, 2016 OPG Deep Geologic Repository Information Session Notes These notes are a compilation of questions and comments received during the OPG Deep Geologic Repository (DGR) Information Session that was held on November 11, 2016. Please note that this record of the meeting is not intended to be exhaustive and does not provide a verbatim transcript. It is meant to provide an overview of the nature and topics of discussion. In addition, names are not attributed to specific comments except for OPG’s staff and consultants. As was indicated by a few participants during and after the session, the comments by any participant should not necessarily be interpreted as representative of the views of other participants. The Power Point presentations are attached as Appendix B. Meeting Date, Time and Location Date: Time: Location: 1.0 November 11, 2016 8:30 a.m. to 4:00 p.m. 700 University Avenue Mini-Auditorium Mezzanine Level Toronto, ON Background OPG is in the process of seeking regulatory approvals for its long-term plan to manage low and intermediate level radioactive waste (L&ILW) in a deep geologic repository (DGR) at the Bruce Nuclear site in the Municipality of Kincardine. In 2012, the Minister of Environment and the President of the Canadian Nuclear Safety Commission (CNSC) established a Joint Review Panel (Panel). The Panel’s Environmental Assessment Report of May 6, 2015, concluded that constructing a DGR at the Bruce nuclear site is not likely to cause significant adverse environmental effects, considering existing and committed mitigation measures presented by OPG and those recommended by the Panel. On February 18, 2016, the Minister of the Environment and Climate Change, requested additional information from OPG, specifically to carry out three activities: (1) study the environmental effects of technically and economically feasible alternate locations including the additional off-site transportation; (2) update the analysis of the cumulative environmental effects of the project in light of the results of the Nuclear Waste Management Organization’s (NWMO) Phase 1 Preliminary Assessments; and (3) update the list of mitigation commitments for each identified adverse effect while identifying outdated and redundant commitments. Ontario Power Generation | 1 OPG DGR Information Session Notes November 11, 2016 OPG committed to providing the requested information by the end of 2016. Throughout 2016 OPG shared its proposed work plans and preliminary findings with the public, elected officials, communities of interest, and key stakeholders. The purpose of the November 11 information session was to provide details on OPG’s preliminary response to the Minister’s request and to hear comments from participants prior to OPG completing its work and submitting the final studies to the Canadian Environmental Assessment Agency. 2.0 Meeting Agenda The agenda was designed to inform participants about the DGR project and OPG’s preliminary findings in response to the Minister’s letter and to hear comments and receive input from participants before the response is finalized. The agenda appears below. Time Activity 9:00 a.m. Welcome / Opening Remarks 9:05 a.m. Introductions 9:10 a.m. Safety Message Facilitator’s Remarks Agenda Review Meeting Courtesies 9:20 a.m. Presentation: Alternate Locations Environmental Effects 10:10 a.m. Q&A and Discussion 10:45 a.m. Break 11:00 a.m. Remembrance Day Moment of Silence 11:02 a.m. Presentation: Off-site Transportation 11:30 a.m. Q&A and Discussion 12:00 p.m. Lunch Break 1:00 p.m. Presentation: Cumulative Effects and Mitigation Measures 1:30 p.m. Q&A and Discussion 2:15 p.m. Wrap up and Final Comments Adjournment Ontario Power Generation | 2 OPG DGR Information Session Notes 3.0 November 11, 2016 Participants People attending the workshop included a mix of: experts on environmental assessment; experts on nuclear waste management; Environmental Non-Governmental Organizations (ENGOs); and local resident and stakeholder groups. Information Session Participants 1. Eugene Bourgeois Inverhuron Committee 2. Dr. Ellen Dailey SOS Great Lakes 3. Dr. Brian Devitt Durham Nuclear Health Committee 4. Dr. Don Gorber IEC 5. Dr. Sandy Greer Individual Stakeholder 6. Charles Hazell SOS Great Lakes 7. Brennain Lloyd Northwatch 8. John Mann Individual Stakeholder 9. Theresa McClenaghan Canadian Environmental Law Association 10. Marti McFadzean Inverhuron Committee 11. Jill Taylor SOS Great Lakes 12. Linda Thompson Former Mayor of Port Hope 13. Dr. Gord Wichert SLR Consulting OPG Staff and Consultants 1. Lise Morton Vice President, Nuclear Waste Management 2. Kevin Powers Director, Corporate Relations and Communications - Nuclear 3. Paul Gierszewski 4. Donna Pawlowski 5. Gord Sullivan 6. Fred Kuntz 7. Vasile Bostan 8. Alyson Beal 9. Dave Hardy Director, Safety & Licensing, NWMO Senior Manager, Strategic Initiatives, Nuclear Waste and Decommissioning Manager, Deep Geological Repository Program Oversight Manager, Corporate Relations and Communications – Bruce County Section Manager Engineering, Nuclear Decommissioning Associate, Environmental Assessment Specialist, Golder Associates Principal, Hardy Stevenson and Associates Limited 10. Noah Brotman Senior Planner, Hardy Stevenson and Associates Limited 11. Jeremiah Pariag Planner, Hardy Stevenson and Associates Limited Ontario Power Generation | 3 OPG DGR Information Session Notes 4.0 November 11, 2016 Information Session Notes Throughout the presentations, participants were invited to provide comments and ask questions to clarify their understanding of the material. Comments, questions and responses were noted and can be found below. Questions are listed in chronological order and grouped according to topic. Notes were taken by Noah Brotman and Jeremiah Pariag and reviewed by Dave Hardy. Sub-headings have been added for ease of reading. Ontario Power Generation was asked to review the notes for technical accuracy. The draft information session notes were provided to the participants for their review and feedback. Some participants did not respond, one participant indicated that the notes were an accurate summary of the questions and answers and other participants provided comments on the draft notes. In addition to substantive comments, a few participants expressed their view that the draft notes did not represent a fair and full representation of the questions and answers. In particular, and as specifically requested by Northwatch, it does not accept the meeting report as provided by Hardy Stevenson and Associates Limited to be a fair and full representation of the discussions. These comments were reviewed by Dave Hardy, Noah Brotman and OPG’s staff. To extent that the comments were consistent with the understandings of Dave Hardy, Noah Brotman, Jeremiah Pariag and OPG’s staff, they are reflected in these notes. 4.0 Presentations 4.1 Introductions Dave Hardy welcomed everyone to the Information Session, thanked them for coming, and introduced Donna Pawlowski who provided OPG’s opening remarks. On behalf of OPG, Donna Pawlowski welcomed everyone and thanked them for participating in the Information Session. OPG appreciates the time participants have taken to learn about OPG’s preliminary findings in response to the Minister and is looking forward to receiving comments. OPG continues to work on the studies requested by the Minister, as such, any of the discussion points offered during the session are subject to change and may vary for the purposes of OPG’s final submission. Participants were invited to introduce themselves and organizations that they represent. Gord Sullivan provided a safety briefing on the meeting room and building emergency procedures. Dave Hardy reviewed the meeting courtesies, the agenda for the day, and explained how the Information Session would be facilitated. Participants asked clarification comments and questions about the process. A participant noted they are in attendance primarily for information gathering and will need to speak with their members before providing any specific feedback. Another participant stated that he/she are here to participate in an information session and the meeting today should not be considered to be a consultation event. A few Ontario Power Generation | 4 OPG DGR Information Session Notes November 11, 2016 participants noted that comments by any one participant should not necessarily be taken as representative of the views of others. Q: Why OPG is sharing information now? OPG committed to sharing the draft response before it was finalized and submitted. The preliminary findings are being shared with local municipal councils in the Bruce area at public council meetings, and to First Nations and Métis organizations (Saugeen Ojibway Nations (SON), Historic Saugeen Métis and the Métis Nation of Ontario). OPG felt that it would be a beneficial to also share preliminary findings with key stakeholders, such as organizations who had an interest in the Project. Q: Why OPG didn’t pick a venue where all stakeholders who have been involved in the Environmental Assessment (EA) and Joint Review Panel (JRP) processes could participate? The public was informed about the preliminary response to the Minister through municipal council presentations. OPG chose to invite representatives of key organizations involved in the EA and JRP who might be interested in receiving detailed information. The Toronto location was thought to be a reasonably central location for the range of organizations invited. Some of the invitations had to be directed to general information addresses. This was interpreted by some organizations as an overall invite to all of their members rather than inviting a single representative from their organization. We found that to be a learning process, some of those things could have been better done. A participant stated the participant had sent numerous emails to OPG and various Ministers about this issue (the DGR project) and has not had a response. The participant expressed frustration with OPG not answering emails. OPG stated the questions had been answered previously at hearings or in prior emails. Many of the questions were to the Minister and OPG cannot respond for the Minister. A participant asked if the Q&A and discussion required more time, would it be alright to take a shorter lunch break. Dave Hardy responded that the timing of the schedule would be flexible to allow for discussions to continue as needed. 4.2 Overall Review and Approval Process Donna Pawlowski described the DGR project and provided background information about the approvals process to date, the details of the Minister’s request and the description of alternate locations. Information was also presented on the activities to be completed in 2016. A Decision on the EA and Construction Licence should occur in 2017. The work packages were described. Donna Pawlowski stated that OPG is continuing to work on the study requested by the Minister. Q: What are the expectations for the CNSC regarding public consultation in the event that OPG gets a positive decision (from OPG’s perspective)? Ontario Power Generation | 5 OPG DGR Information Session Notes November 11, 2016 If there is a positive response from the Minister (i.e. if the EA is approved), the submission will go back to the JRP and they will have 90 days to come back with a ruling on the licence to prepare the site and construct. Q: If the JRP panel has been dissolved, who will be reviewing and making decisions? The process after the Minister’s decision and prior to the licensing of the L&ILW facility is yet to be determined. Q: Does this mean that there would be no public review of what is being submitted to the Minister? OPG will provide its submission to the Canadian Environmental Assessment Agency (the Agency) and they would conduct a public review. Q: The participant asked if the matter would need to be remanded back to the JRP to hold a hearing. The Minister has instructed that the JRP would not be needed to conduct a review. They would reconvene once the Agency public review is completed. If the Minister accepts the EA, the JRP would be involved in the licensing determination. Q: Does this mean that the Minister would be reviewing without public input? The Minister will be holding a public review and comment process through the Agency, who have been instructed to hold that public review. Q: Why won’t the JRP be doing this review? Another participant responded that the JRP had been released by the Minister and would therefore not be meeting again until reconvened. Q: Why won’t there be a public hearing process? This is a question that would be more appropriately directed to the Agency as they will be responsible for the approval process. OPG doesn’t have information about the intended process. Q: The Minister made three simple requests of OPG. Has OPG been in communication with the Federal government to know if their approach is an appropriate answer to the Minister’s questions? OPG has reviewed all correspondence with the Minister and the Agency, and OPG is following their directions. 4.2 Presentation 1: Alternate Locations Environmental Effects Alyson Beal (Golder) presented the methodology used to assess the environmental effects, and the preliminary findings for alternate locations. Information was presented on the geologic Ontario Power Generation | 6 OPG DGR Information Session Notes November 11, 2016 regions, economic and technical feasibility criteria. Key environmental features typical of a reference location were described. The potential environmental effects were presented in terms of valued components. This was followed by a description of the basis for the effects assessment. Environmental effects were described using the example of aquatic, geologic and hydro-geological effects for sedimentary and crystalline locations. Conclusions were described and overall preliminary findings about increased environmental effects were presented. The following questions and comments were provided. Process Used To Identify Locations Q: Has OPG considered a specific reference location and do they view this as the actual site that will be evaluated? What is the difference between identifying a reference location and doing a full site search process? The request of the Minister was to study actual locations. If a full siting process were undertaken, it would essentially be starting the entire DGR approval process over again. It was also noted that OPG can’t simply select an alternate location and announce it without consulting with the local communities. There would need to be a full multi-year site search to identify a willing community. Q: What information would OPG rely on in their description of alternate sites? Is there any intention to rely on any of the Step 3, Phase II assessments from NWMO? Golder stated they relied on published information (as it is presented today) but would not be relying on NWMO Step 3, Phase II assessments. Q: The Ivy School of Business prepared a report for Kincardine in 2004 which identified 7 willing host communities for the DGR, Kincardine being one of them. None of that information was presented at the hearings or to the community of Kincardine. The report was not tabled in municipal council. Were any of those actual sites considered in this alternative review that is going to the Minister? Those sites were not considered. A participant commented that if OPG were to identify a specific location they would end up with a community group challenging the decision and pulling the plug on the DGR. The participant stated, not naming a specific location was a political decision. Q: Will socio-economic effects be a criterion that OPG must meet? Socio-economic effects are not an area of Federal jurisdiction and as such there are no applicable regulations. However commitments pertaining to socio-economic effects would be included. Another participant stated CEAA is focused on environmental and species impacts, but does not look at social impacts. They stated there isn’t enough consideration about the human impact side, particularly in relation to differences between locations in remote areas vs. population centres like southern Ontario. Ontario Power Generation | 7 OPG DGR Information Session Notes November 11, 2016 Nature and Specificity of Locations Q: Are those representative examples, actual specific locations rather than theoretical composite locations that describe general geologic features? The locations are actual locations. Reference features would be used to describe a geologic region. A participant observed that what OPG has done is start originally with a specific site (Bruce Power site), but are now looking at general theoretical alternatives. It was suggested that the site search should have identified representative locations based on criteria that address the specific concerns/complaints that came out of the review process up this point. They stated, the question should be “are there different sites that would address the concerns that have been raised?” A participant stated the question of “synthetic vs. real location” is important because sometimes local site peculiarities can overwhelm the general characterization of overall areas. Also, there was difficulty understanding OPG’s characterization because there isn’t a comparison of crystalline and sedimentary locations against the Bruce site itself. OPG responded that the full report examines and compares all three locations (the two geologic locations and the Bruce nuclear site). The intent of the presentation is to give a general sense of how the work to assess environmental effects was done. Another participant stated, the fact that Kincardine came forward as a host community might be what muddied the waters in this process. If OPG had originally done a full Province site search, this process would have gone very differently. Because Kincardine came forward the original study was done specifically on that site. A participant raised the example of Port Hope in reference to the feasibility of the L&ILW being hosted by a community that is involved in the NWMO APM siting process. The participant stated that in Port Hope, 30 years was spent trying to find another community to take their low-level radioactive waste. The waste was dirt and not equipment, rags, or construction materials. In the case of Port Hope, the community actually came back and said that they needed to deal with it themselves and not push it on another community. Port Hope residents wanted to deal with their own waste. However, the decision was also made that the Port Hope facility would not receive any other waste from any other locale. This was a very important factor for the community. For this reason, from NWMO’s perspective, it should not be assumed that those potential host communities would simply add additional types of waste. This would have a significant impact on the process. Q: Why is a location not within 120m of any provincially significant wetlands one of the key environmental features defining the location of the repository? The 120m requirement is in the Provincial Policy Statement and represents best practices established by the Province. A participant commented, in their opinion, OPG had stated that no significant adverse effects were likely, but studies to determine the significance had not been completed. The participant Ontario Power Generation | 8 OPG DGR Information Session Notes November 11, 2016 also asserted that OPG had concluded that the JRP already accepted the project because there would not be any significant effects. In the participant’s opinion, there is no clear definition of significance in the relevant legislation. OPG responded that many of the detailed studies and quantitative analyses of significant adverse effects were already completed as part of the EA. For the response to the Minister, they are being referenced where applicable to the assessment of alternate locations. There are regulatory expectations and requirements for stormwater ponds and all of the regulatory requirements would be met. Q: Will OPG be showing a map of the specific locations? Maps would be used in the response. The study looked at the characteristics of locations as generalities, but a full site search would need to be done in order to identify specific sites. It would be inappropriate to identify specific communities without a full engagement program being undertaken. Q: Will the location would be in the Great Lakes Basin? Golder responded that both the sedimentary and crystalline locations were in the Great Lakes Basin. [After the meeting OPG clarified that the locations would be in either the Great Lakes or Arctic/Hudson Bay watersheds.] Q: Why couldn’t OPG have just let the NWMO undertake their Adaptive Phased Management (APM) site search and simply combine the DGR facility onto a single site? In the original thinking for the response to the Minister the possibility of approaching the NWMO APM communities was considered. However, it was ultimately determined that introducing the idea of a secondary site search for a potential DGR location could potentially undermine the current APM process in those communities. A participant stated, society has a responsibility to deal with nuclear wastes and it should be one process for both the DGR and APM facilities. OPG responded that the legislation is clear that the NWMO is responsible for dealing with the used fuel waste. Q: Is an opportunity is being missed to partner with NWMO? The scope of the response to the Minister is focused on approvals at the Bruce site. Coordination and combination with NWMO is a larger strategic conversation that was not in the scope of this work. Q: If the NWMO is studying 21 communities, why isn’t OPG studying more communities for the L&ILW facility? The NWMO is looking for a willing host community and is studying geology and other factors. In the case of the L&ILW DGR, Kincardine came forward as a willing host community. OPG reminded the participant that this was covered at the JRP hearing and it is in the public record that Kincardine came forward. This was challenged, discussed, and ultimately upheld in the hearing. Ontario Power Generation | 9 OPG DGR Information Session Notes November 11, 2016 Q: Were any of the NWMO communities used as case studies? The NWMO communities were not used in this study. Q: OPG has claimed that Kincardine is the best spot for spent fuel, does this undermine the NWMO? OPG responded that this statement was not accurate and that the DGR facility is not being designed for used fuel and will not have any used fuel located in the DGR. Project Definition and Waste Characteristics Q: What does OPG mean by the statement that the DGR capacity “may be doubled”. Part of the application was to look at whether there is enough quality rock to double the size of the DGR. The current plan for the DGR is to store 200,000 cubic metres (m3) of Low and Intermediate Level (L&IL) waste. OPG previously said that in the future (2050s), they would consider increasing the size of the DGR to include OPG decommissioning wastes. That proposal would have technical reviews, geology reviews, another public hearing process and licensing reviews. Q: Why not do both at the same time? If OPG is already going through the effort now, why not go the whole way and build a full-sized facility? In hindsight there may be advantages to approaching it differently. Because the process has been going for a long time (started in 2004) the decision was made to get the first 200,000 m3 approved and conduct the studies and initiate the approvals process to expand at a later date if necessary. Q: If the studies have been done, why not just revise the application to be for the full 400,000 m3 now? There is confidence in the technical analysis for the area needed for the first 200,000 m3, but those studies have not been done for the expanded area. Also, the waste management process is about responsible phasing. It is logical to take the current existing waste that is well characterized, build the DGR for that material, and then learn from the development process. In the future, as refurbishment and decommissioning processes proceed, there will be an increasing amount of knowledge that will help refine the understanding and influence the decision about whether to expand or build elsewhere for the second 200,000 m3. Since a decision on expansion is not necessary today, gaining more knowledge before making that decision is advisable. A participant commented there has always been a struggle with the issue of how far to take the EA at this point and how far to take it in the future. For that reason, a phased approach was taken. The participant stated, there is a danger in getting things approved for 50 years in the future in that the EA process doesn’t provide for an iterative approach that builds on learnings over time. There needs to be a balance between making complete decisions early and developing and refining those decisions over time. Ontario Power Generation | 10 OPG DGR Information Session Notes November 11, 2016 Q: Douglas Point is owned by AECL. Is AECL planning to have their waste stay above the ground forever? Why haven’t those wastes been accommodated in the DGR and why isn’t AECL partnering with OPG? If OPG is taking the position that Low and Intermediate Level Waste should be below the surface, why is AECL taking a contradictory position? OPG pointed out that the purpose of the upcoming submission is to respond to the Minister’s request and that revisiting the overall basis of the project was not within the scope of work. Q: Have the specific radionuclides been identified for the first 200,000 m3 and is there a different set of radionuclides for the second 200,000 m3? Work has been continuing on the characterization of radionuclides for the first 200,000 m3. Specific details will be needed to be known for the full safety assessment (needed for the operating licence). Information on later phase radionuclides will be studied in detail. Q: Will those studies identify specific radionuclides? Radionuclide identification was done at a general level in order to talk about feasibility, but further detailed study will be required for the full safety assessment. At the moment, the safety case is around the operations and refurbishment waste and OPG understands the radiological characteristics of those wastes quite well. Additional comment. A participant stated OPG appears to have said elsewhere to the regulator that decommissioning wastes will not be going to the facility. But before the hearing for this DGR, the participant asserted that OPG had stated without qualification that they intended to put the decommissioning waste in the DGR. The participant stated there are two competing realities. Other approvals appear to be obtained on the basis of there being a plan for the decommissioning waste, challenging the credibility of the process. Q: What impact will the heat generated by L&ILW have on groundwater? The thermal design of the L&ILW facility is not a defining feature. Q: Is OPG looking at alternate means of dealing with the waste such as storing it above ground and allowing radiation to degrade? 80% of all radioactive materials to be dealt with are low level waste that would not benefit significantly from being allowed to degrade (for 30 years) prior to disposal. The intermediate level waste would not degrade significantly during storage. Q: Has OPG done further work after the submission of the 2011 Environmental Impact Statement (EIS) and follow-up questions in the Independent Experts Panel Report? There is an ongoing waste characterization plan and OPG understands what waste streams need refining. There has been an opportunistic data collection program, meaning that readings are taken whenever waste streams are opened up and there is access to previously inaccessible systems. This characterization will occur up to and beyond achieving the operating license. The waste characterization program will be discussed in the operating license process. Ontario Power Generation | 11 OPG DGR Information Session Notes November 11, 2016 Q: In 2002 OPG said to Municipal Council that no waste would be reclassified. In OPG’s 2002 annual report it was stated that type 3 intermediate wastes have the same features as used fuel waste and should be combined with fuel in an APM. But the DGR is intended to have type 3 intermediate wastes. Does this mean that type 3 wastes have been reclassified? It now appears that the type 3 waste is going to be located with L&ILW. When did that change occur and is it a reclassification? No reclassification of the wastes has occurred. Only low and intermediate level waste is to be emplaced in the DGR. No used fuel will be emplaced. Further, this discussion of waste types is not relevant to today’s discussion of OPG’s submission to the Minister. A participant stated this is relevant because the Michigan Waste Act was incorrectly interpreted in the hearing. The participant believed it was implied that low and intermediate waste could be buried on site when next to a power generating station. According to the participant, the Michigan Waste Act does not permit that in Michigan. The participant asserted, if we are talking about this being in the Great Lakes Basin, then there is the potential of leakage that would be a major cross-border issue. Assessment of Effects Q: Given that OPG will be continuing to develop their understanding of conditions right up until the construction of the site, does that mean that OPG doesn’t really have a clear vision of what the effects will be? Conditions are understood and were reviewed at the hearing. For some radionuclides scaling was used. It’s not that OPG doesn’t have the data, but rather it is a matter of honing in on that data and making sure it is accurate by continuing to review it. Fundamentally the waste hasn’t changed significantly over the years of operation, so there is a good understanding of the characteristics of existing wastes. Also the start of the decommissioning process gives OPG a chance to study previously inaccessible systems and to help improve waste characterization. It is a matter of improving our understanding and building on existing knowledge Q. Might crayfish be impacted? We think that crayfish at an alternate location may be impacted. Additional comment: A participant stated that they felt serious concern whether any conclusions could be made about significance of adverse effects at this time. 4.3 Presentation 2: Transportation Gord Sullivan (OPG) presented the incremental transportation costs and risks, covering: the scope of the study; key planning assumptions; cost estimating methodology; the transportation related activities for alternate locations including the nature of the containers; and the transportation related risks. Photos and diagrams were used to describe the LLW waste streams. A diagram describing the effects of the reference plan compared to the activities for alternative locations was presented. Information on the total incremental packaging and Ontario Power Generation | 12 OPG DGR Information Session Notes November 11, 2016 transportation costs was also presented. An analysis showing conventional and radiological incremental packaging and transportation risks at the Western Waste Management Facility (WWMF) was provided. In addition, risks during transportation were also presented. Transportation risk management findings were provided including a summation of OPG’s record of safe transportation. Findings of the study of alternative locations with respect to transportation were also provided. It was concluded that from a transportation perspective, the Bruce Nuclear site remains the preferred location. Percent of packages needing to be over packed Q: Can OPG give a comparison of transportation between the Bruce site and the two alternate regions. Specifically, what amount of packages would need to be over packed for the alternate site as compared to existing? There would be repackaging at the Western Waste Management Facility (WWMF) site. The process currently proposed would have to take the current waste out of the ground, transfer it to a transportation container, and then unload at the new location Q: How has the level of effort changed and how much over packing would be done for the alternate sites. At a crystalline site there is the potential, if the site has rock fractures, to do additional work to remediate the package to ensure that it is safe inside the rock. Additional barriers Q: Why would additional barriers be needed on the new site but not for transportation? While it is known that additional processing or packaging may need to be done for a crystalline site, it has not been specified whether that work would be done at the WWMF or at the new site. OPG clarified that it is intended to over pack the containers as necessary at the WWMF. There will be some effort involved in over packing LLW containers and significant more effort in over packing ILW containers. The exact effort would have to be determined in more detailed studies. Q: What extra processing would be needed to repackage on the Bruce site prior to transportation of materials? Carbon 14 would be the focus of extra processing. As well, if sending to a crystalline area with fractures, additional measures would need to be taken to ensure protection. Packaging facility at mid-point Q: Could OPG make the decision to keep the waste at Pickering or Darlington long-term. This cannot be done under the current licence. Additional comments: Ontario Power Generation | 13 OPG DGR Information Session Notes November 11, 2016 A participant commented that if the alternate site for the DGR would be located in between the Bruce and Darlington, the waste materials would be better sent to the site for packaging than having Darlington send it to the Bruce for packaging and then back to the DGR site for storage. They stated, locating a packaging facility at a mid-point between the two facilities would be an overall cost savings for transportation to avoid duplicating a repackaging facility. A participant commented that if OPG is going to consider transportation, the focus needs to be on the routes to be taken. The participants believes that, if this is a true alternate site analysis, there needs to be some information available on routes or the full picture of transportation effects isn’t being seen. OPG responded that, with respect to existing waste, half of the first 200,000 m3 intended for the DGR is already at the Bruce site. As well, if the decision is made to construct the DGR at an alternate location and transport material, the facility would only be operational by 2045 or 2055, at which point 150,000 m3 will be at the Bruce site. Q: OPG is selling the APM on the fact that the used fuel can safely be moved off site, but selling the DGR on the benefit of the L&ILW being able to remain on site. The participant asked whether this was contradictory. The more material that is transported the greater the cost. As well, the representative from NWMO noted that transportation factors are only a small part of the decision to locate the APM facility and finding a willing host community with appropriate geology is a far more important factor. Costs and record keeping Q: What percentage of the total cost for the project would the additional transportation represent? It will cost around $1 billion to get the facility operational under the current proposed plan. The projected transportation costs of $0.4 to $1.4 billion would be an additional incremental cost. Q: How it is possible that transportation could cost $1.4 billion while the originally proposed facility would only cost $1 billion? This is the estimate developed by Energy Solutions Canada and is being internally reviewed. Q: Is it being peer reviewed? Cost data was developed by Energy Solutions Canada and is being reviewed internally at OPG. Q: Will OPG keep an up-to-date public record of the radionuclides that are be transported, given that there is a wide diversity of radionuclides that can affect different plants and animals in different ways? If OPG was required to look for an alternate location that would involve transportation, it would uphold the commitment made in the hearings to be transparent and open and put this information on the website. It was also noted that all commitments made can be found in the Ontario Power Generation | 14 OPG DGR Information Session Notes November 11, 2016 Commitments Report. Also, while the waste characterization process is ongoing, the grouping in transportation packages does not change that characterization. Q. Does the cost include the cost of additional/new programs to notify communities along the routes? There would be a cost associated with amending the emergency response plan to incorporate new communities and first responders. It was not included in the cost estimate. Q: Has OPG had the radionuclide data peer reviewed? There are independent experts looking at the radionuclide material as well and providing guidance to ensure that everything being done is well referenced and traceable. Types of transportation packages Q: How many different types of transportation packages will be required and how many of those different designs are currently certified? OPG’s current fleet of transportation packages includes: 8 IP2/Type A freight containers; and 7 smaller Type A containers. Additional IP2/Type A freight containers will be purchased in 2017 and 2018. As well there are multipurpose packages and core component packages to transport ILW that equal 14 Type B packages. [Updated information provided by OPG]. Q: Does OPG have packaging that has already been certified for all of the waste groups currently in storage? There are not currently certified packages for all types of waste. Q: Which packages still need to be designed and certified? Packages will need to be designed for ILW originating from Tile Holes and Bruce Power Refurbishment re-tube waste components. Q: Could you clarify what you mean by saying the transportation packages on the slide were “non-accessible”? OPG clarified that the reference was to “non-processable” materials. Q: Could the steam generators remain unsegmented for transportation? Transporting the unsegmented material would require an extremely large transport vehicle that would be very slow and would require significantly more time to move, in part because of the weight limits on the roads. Steam generators are considered low level radioactive waste. Ontario Power Generation | 15 OPG DGR Information Session Notes November 11, 2016 Modes of Transport Q: OPG has talked about road transport only and that in 1999 Bruce County approved rebuilding the deep-water port. Did OPG consider using water transportation for the crystalline locations? Water transportation was not considered. 4.4 Presentation 3: Updated Cumulative Effects Analysis Paul Gierszewski (NWMO) provided an overview of: the NWMO APM process. Alyson Beal (Golder) presented the CEAA 2012 requirements; the overall approach to analyzing cumulative effects; and examples of the findings relating to specific effects. Cumulative effects were described and assessed based on consideration of an APM DGR in Huron-Kinloss, South Bruce or Central Huron. The examples of surface water and noise cumulative effects were described. The analysis considered overlap of effects, spatial overlap and temporal overlap. It included radiological malfunctions and accidents. Breadth of the Cumulative Effects Analysis and Methodology Q: Is the Minister’s request clear that OPG is not being asked to look at NWMO sites? The Minister’s request was to look specifically at cumulative effects of sites within SON’s traditional territory. Q: Would it be less risky and less costly with a single combined DGR for both L&ILW and high level waste? This question was not within the scope of study for responding to the Minister’s request. Q: Is this presentation referring to the NWMO’s Step 2 Initial Screening or the Step 3 Phase 1 Preliminary Assessment? It is from the Step 3 Phase 1 Preliminary Analysis. Q: Why didn’t OPG consider the costs and risks of the “unnecessary” transportation of spent fuel having to be transported off site? The cumulative effects of transporting used fuel off site were captured in the EIS and included in that analysis. Q: When will the community have a referendum on locating the DGR within the Bruce Nuclear Site? OPG responded that this was not the focus of this meeting. Q: Will the additional 200,000 m3 of waste be included on this chart? Ontario Power Generation | 16 OPG DGR Information Session Notes November 11, 2016 The additional 200,000 m3 is not included on the chart. Expansion of the DGR to accept the additional waste was included in the EIS as a reasonably forseeable project and it has been included in the cumulative effects section of the EIS. This study is only looking at the incremental effects of what is on record. Q: Does this analysis consider radiological aspects as well as others? OPG responded that it does. Q: Why aren’t animals (wild or farm) aren’t being considered in the noise analysis given that it is an agricultural area and there are a lot of animals? Will this be added/ included? The participant added that international studies in recent years have taken an ecosystem approach looking at more than just the endpoint effects. Another participant expressed a concern as the Minister said to look at cumulative effects on something that already had a residual effect. OPG responded that the methodology for assessing cumulative effects was to look at the residual effects of the DGR Project on Valued Ecological Components (VECs), but no residual effects on animals were identified. For that reason it has not been a focus of the presentation today. Q: What is OPG’s understanding about how to update cumulative effects analyses when CEAA or EIS requirements are updated? OPG is following the current CEAA requirements including their latest draft technical guidance. Q: Has the approach taken by OPG been grandfathered-in, or will future changes to CEAA change the approach? OPG responded that they follow the rules that are in place at the present time. A participant commented that the geographic boundaries were too restrictive to begin with, and it should be assumed that any industrial proponent would be doing the most up-to-date practices. The participant stated, when old assumptions are updated it should be expected that OPG would keep to the new and improved standards. A participant stated there is a lot of talk in Europe about the risks of having all nuclear facilities located in one place. They are moving toward the view that facilities should not be located closer than 20 km apart for security and safety reasons. The participant observed, in the original hearings and report from OPG they looked at terrorism, and the participant was wondering whether security and terrorism threats were examined as a cumulative effect. OPG stated they have not included malfeasance or terrorism in this analysis. Q: Does OPG’s conclusion of no adverse effect take into account mitigation measures? OPG’s conclusion of no residual adverse effect does take into account mitigation measures. Q: A previous information request had enquired about the possibility of turning off the back-up alarms on trucks that are dealing with rock waste. OPG had said that they would Ontario Power Generation | 17 OPG DGR Information Session Notes November 11, 2016 look to the Ministry of Labour to see if that was possible, but no response has been received. Since the alarm sound can be a significant source of noise pollution for a large area, has this been considered as a possible mitigation measure? Another participant responded that currently in Ontario it is illegal to not have a back-up alarm on such vehicles, and that it is common practice in environmental assessment to not consider those alarms when looking at potential noise impacts. Q: The EIS does not mention construction explosion noise that could startle people or cause a loss of hearing. How have you looked at the noise effects of construction explosions on people? The noise effect of construction explosions had been considered, and no adverse effects on human health (such as deafness) were identified. Q: In a situation in which accidents or malfeasance occurs and situations of combined errors occur (such as explosions or fire), has OPG considered the cumulative effects of combined events? The EIS examined the releases as a result of a fire and an explosion. OPG also looked at how the environment could impact the project and examined the potential impact of flooding on the project in the EIS. For this study we looked at common-cause accidents such as glaciation. Q: Was stigma part of the cumulative effects? Stigma was not looked at as a cumulative effect in this analysis since it was covered in the EIS and was not found to be a residual adverse effect. Q: Does the law state that the two facilities can’t be combined? OPG is following all law and regulations as required. As well, the specific design for a L&ILW facility, is different from what will be required for a high-level waste storage facility. There are different materials, different radionuclides, different safeguards, and different containment systems. Even if you had the same site and the same rock, you would end up having to build two distinct facilities on the same site. There is actually very little shared infrastructure between those two facilities. Temporal Overlap Q: Regarding the “Consideration of Temporal Overlap” PPT slide, is OPG intending to complete the chart (see PowerPoint deck in Appendix A) or is that the way it will be presented? The intent of that chart was to be illustrative for this meeting’s purposes. Consideration of Adjacencies and Watershed Effects Q: Has OPG looked at the overall cumulative effects on Lake Huron? Ontario Power Generation | 18 OPG DGR Information Session Notes November 11, 2016 No major hydrological changes were anticipated to Lake Huron. A participant commented that the most obvious place for cumulative effects would be in relation to transportation because, from the point of view of residents, the biggest annoyance will always be trucks on the highway. A participant commented that the JRP did not want to discuss transportation of the used fuel, so that was off the table at the hearings. OPG responded that the cumulative effects analysis for the DGR on the Bruce nuclear site had looked at the potential interaction with other projects. In total, 31 different projects were examined, including transporting the used fuel off the Bruce nuclear site. Q: Could OPG provide a map that shows the watershed and how the two facilities would impact each other cumulatively? [New question was asked before a response could be provided.] Q: In impact analysis, how does OPG consider adjacencies in the definition of cumulative effects? What is being presented is an example. The scale of cumulative effects is defined for each individual component. For hydrology for example, the cumulative effects were looked at on a watershed scale. Other valued components have their own scale. 4.5 Presentation 4: Mitigations Report Paul Gierszewski provided an overview of the Mitigations Report, explaining how the mitigation commitments have been tracked and combined thematically to reduce duplications. Examples of commitments were provided. Participants were provided with an explanation of how the commitments have been addressed up to this point. Clarifications about Commitments Q: Can OPG confirm that commitments and mitigations from both Licensing and the EA are being included? As per the Minister’s request, OPG stated it is updating the list of mitigation commitments for each identified adverse effect, while identifying outdated and redundant commitments. The 2014 report includes all of the commitments and as OPG gets into the licensing process the commitments will be carried forward for review by the CNSC. There are other commitments relating to non-environmental regulations such as management and design. Q: Could you provide an example of non-environmental commitments? The particular specification for a winch was given as an example of a non-environmental commitment. Ontario Power Generation | 19 OPG DGR Information Session Notes November 11, 2016 Q: The packaging requiring review by the CNSC is being worked on now but they won’t see it until after the Minister’s decision? What is being responded to here is the Minister’s request regarding commitments that have an adverse effect on the environment. If the Minister approves the EA, OPG will subsequently move forward with the licensing process. Q: What is the status of the geoscience verification program? Are the commitments in the mitigation report? The commitments for the geoscience verification are in the commitments report. Q: Has OPG completed any commitments since the end of the hearing that will be reported on in this package or in the CNSC application package? There were a few commitments that the JRP wanted to see as part of the site preparation and construction application. Those will be part of the CNSC package. Q: Will OPG be maintaining a commitments inventory to ensure that they are tracked and traceable? This inventory exists and will continue to be maintained. Q: The new mitigations report is a consolidation of all 900 commitments. Could you clarify if OPG is only reporting to the Minister on only the CEAA 2012 Adverse Effects Report? There is a report which contains all 900 commitments made during the hearing, but not all of those commitments are related to environmental effects. Those commitments that are not associated with environmental effects will not be in this update of the Mitigations Report. A participant stated, hearing about the 900 commitments is concerning because OPG has to do 900 things to perfection for this project to work and this is why their family doubts the project. Q: Is OPG still committed to doing the commitments from Revision 2 and how this is being tracked? Revision 2 is being tracked and is available on the website and OPG will ensure that all commitments are carried forward. Q: It is worrisome that if the mitigation measures fail and the follow-up program only comes after the fact, then wouldn’t there be potential health effects prior to identifying a failed mitigation measure? There is certainty based on the ongoing monitoring. Q: A lot of computer modelling is used in the analysis; will OPG be identifying what models have been used? Each computer model has various criticisms and benefits that should be well understood. Ontario Power Generation | 20 OPG DGR Information Session Notes November 11, 2016 In the original EA there was modeling done and all of those models were in the reports in the EA process and were examined in the hearings. Additional Comments: A participant stated that it may be too late to detect potential harm until after mitigation measures are carried out. Who Holds Liability? Q: In the event of major failure with significant health impacts, who would pay the damages and who is ultimately responsible? There is an amount of money set aside by waste producers that would cover liability. As well, there is the Nuclear Liability Act. OPG is aware that the Nuclear Liability Act is currently being revised by the Federal Government but are not sure whether it had been completed and passed at this point. [OPG clarification after the meeting – the Act has been revised.] Q: Who would be liable if there are construction related damages? The construction site and overall project would have insurance. Q: Is OPG self-insured under the Province? OPG is self-insured in certain areas, and acquires additional insurance when needed. Monitoring Currently in Place Q: Eight water wells have been dug on the Bruce site to monitor ground water. Has OPG been looking at the tritium plume on the site? Those wells are monitored on a regular basis and there has not been an increase in tritium observed in those wells. Q: Regarding the questions raised during the hearing about adequately sizing stormwater ponds to deal with high water level events and climate change, have the findings been updated? OPG is still of the opinion that the pond as designed is adequate to even deal with the maximum level and Environment Canada would be consulted with regards to this issue. A participant stated that in their recollection the testimony from OPG indicated that the pond would not be adequate. [OPG clarification after the meeting - OPG committed they would review the design of the SWMP going forward]. Ontario Power Generation | 21 OPG DGR Information Session Notes 5.0 November 11, 2016 Additional Topics Raised Q: Is it OPG’s position that there would be no difference between the operational and decommissioning sites? This material was already addressed and documented in the JRP hearing. Q: Is OPG was aware of what is happening with the repository in Sweden? They have pulled back their design and are now considering whether the facility needs to be 5 miles deep. OPG responded that they were not aware of any changes in the Swedish licensing process. [OPG clarification after the meeting there has been no significant change to the Swedish plans for their repository.] 6.0 Final Comments from Participants Dave Hardy asked the participants to share any final thoughts or comments that they might have, with a focus on how this meeting went and how it could be improved in the future. The participant’s final comments can be summarized as follows: • A participant stated this was a very good meeting and should happen again. The only thing to change was to hold the session in a less noisy room with microphones to help hear each other better. This participant also stated that people attending have various concerns and issues and most comments were not actually related to OPG’s response to the Minister. Where you (OPG) have comments that are focused on the report to the Minister, OPG should integrate them. What you (OPG) are hearing is that things are unclear and people want more information. • Another participant stated, this was a valuable exercise. The OPG staff that came to speak were real and honest. The problem is that unless OPG can address the concern about moving it away from the Great Lakes that is going to remain as a major concern. This process has gone far down the road without listening to our input that could have helped guide this process and more easily reach a better result. The participant said the transportation issue is not one they can buy into at this point. He/she stated they understood the information presented, but this has not provided the reasonable answers that we were looking for. And the fact that OPG is not moving away from the Great Lake does not move them away from their issue of greatest concern. • A participant added, this has been an interesting discussion and they didn’t regret having spent the time. It was useful in understanding where OPG is going in terms of their response. However, they stated they feel that it has not been useful or helpful. OPG is setting aside some commitments. They were concerned that private CNSC and OPG negotiations were not being discussed openly. Ontario Power Generation | 22 OPG DGR Information Session Notes November 11, 2016 • A participant stated he/she want to hear from the leaders, including the Minister and others. The participant stated they never had problems with OPG staff and consider them as friends, but they stated they wanted to hear from the leaders. • Another participant stated, when someone at the meeting today expresses opinions about a preferable approach, it should not be taken as speaking for all in attendance. The participant was uncertain that the appropriate answer is simply to move the DGR away from the Great Lakes and then to conclude everything will be fine. Also, they stated a proper environmental assessment process was needed and that this has simply not occurred. This is very difficult to fix now. • A participant stated the meeting was dismissive and OPG weren’t really paying attention to concerns. The participant stated, they know that this is about OPG’s response to the Minister, but those living there are the ones who will be impacted. He/she stated, if OPG is serious about wanting to get this project going, you’re going to need to start listening to the people. • From another participant, the participant wants to hear a clear statement from OPG that this is dangerous stuff to deal with, but they’re doing the best they can. Instead he/she didn’t hear one bad thing about this process and OPG isn’t acknowledging the problem. In addition, he/she asked questions about longstanding concerns relating to human health which is very important. He/she stated, if OPG wants to have support going forward, there will need to be openness and willingness to address the concerns. If OPG doesn’t want to address these concerns, then we will keep fighting the DGR. • A participant stated that they were thinking about how to bring flexibility and adaptability to a relatively rigid process. Things are relatively far along, so OPG should keep an eye for how flexibility of process can be increased going forward. 7.0 Thanking Participants and Next Steps Donna Pawlowski thanked the participants for attending the information session. She added that having comments from stakeholders is important as OPG completes the response to the Minister. OPG will continue to consult with residents and stakeholders in the upcoming weeks as OPG finalizes the response. Ontario Power Generation | 23 OPG DGR Information Session Notes November 11, 2016 Appendix A: Table Summarizing Post-Information Session Clarifications Will the location would be in the Great Lakes Basin? Golder responded that both the sedimentary and crystalline locations were in the Great Lakes Basin. After the meeting OPG clarified that the locations would be in either the Great Lakes or Arctic/Hudson Bay watersheds. How many different types of transportation packages will be required and how many of those different designs are currently certified? OPG’s current fleet of transportation packages includes: 8 IP2/Type A freight containers; and 7 smaller Type A containers. Additional IP2/Type A freight containers will be purchased in 2017 and 2018. As well there are multipurpose packages and core component packages to transport ILW that equal 14 Type B packages. Updated information provided by OPG. In the event of major failure with significant health impacts, who would pay the damages and who is ultimately responsible? There is an amount of money set aside by waste producers that would cover liability. As well, there is the Nuclear Liability Act. OPG is aware that the Nuclear Liability Act is currently being revised by the Federal Government but are not sure whether it had been completed and passed at this point. OPG clarified after the meeting that the Act has been revised. Regarding the questions raised during the hearing about adequately sizing stormwater ponds to deal with high water level events and climate change, have the findings been updated? OPG is still of the opinion that the pond as designed is adequate to even deal with the maximum level and Environment Canada would be consulted with regards to this issue. A participant stated that in their recollection the testimony from OPG indicated that the pond would not be adequate. OPG clarified after the meeting that OPG committed to reviewing the design of the SWMP going forward. Is OPG was aware of what is happening with the repository in Sweden? They have pulled back their design and are now considering whether the facility needs to be 5 miles deep1. OPG responded that they were not aware of any changes in the Swedish licensing process. [OPG clarification after the meeting there has been no significant change to the Swedish plans for their repository.] Ontario Power Generation | 24 OPG DGR Information Session Notes November 11, 2016 Appendix B: Ontario Power Generation | 25 OPG’s Deep Geologic Repository Project – Response to the Minister’s Requests November 11, 2016 Stakeholder Information Session Information Session Details Welcome and Introductions Safety • Emergency exit locations • Evacuation procedures Location of bathrooms Food and beverages Silence cell phones please Remembrance Minute of Silence • 11:00 a.m. Overview of materials in folder 2 Note taking Agenda Time 9:00 a.m. 9:05 a.m. 9:10 a.m. 9:20 a.m. 10:10 a.m. 10:45 a.m. 3 Activity Welcome / Opening Remarks Introductions Safety Message Facilitator’s Remarks Agenda Review Meeting Courtesies Presentation: Alternate Locations Environmental Effects Q&A and Discussion Break Agenda Time 11:00 a.m. 11:02 a.m. 11:30 a.m. 12:00 p.m. 1:00 p.m. 1:30 p.m. 2:15 p.m. 4 Activity Remembrance Moment of Silence Presentation: Off-site Transportation Q&A and Discussion Lunch Break Presentation: Cumulative Effects and Mitigation Measures Q&A and Discussion Wrap up and Final Comments Adjournment Meeting Courtesies Respectful discussion, presentation of information and sharing of ideas. Please ask for clarifications if needed for statements by either OPG or other participants. Will ask to clarify jargon. May ask to clarify your point to ensure accurate notetaking. Will be checking with Noah from time to time to ensure that he has correctly noted matters in the minutes. Ensuring everyone has a chance to comment. 5 Introduction to the Deep Geological Repository 6 OPG’s Deep Geologic Repository (DGR) OPG’s plan for the long term management of its nuclear waste, is a Deep Geologic Repository at the Bruce Nuclear site. The DGR will safely store all low and intermediate level waste from OPG’s nuclear facilities 680 meters underground in an impermeable geologic formation. OPG is currently seeking Regulatory Approval for the Project 7 2011 • • Background Following years of studies, OPG submitted a 15 volume Environmental Assessment report Federally appointed independent Joint Review Panel established Four years of technical reviews and 33 days of extensive public hearings 2015 • The Panel concluded “that the project is not likely to cause significant adverse environmental effects “ and stated that: The Bruce Nuclear site is appropriate Worker and public health and safety will be protected The DGR project will not affect Lake Huron 2016 • • 8 Federal request for additional information: 1. Study the effects of alternate locations; 2. Analyze the cumulative effects of locating a used fuel repository close to OPG’s DGR; and 3. Update the list of OPG’s commitments to mitigate any identified effects. OPG will complete the work and submit information by December 31, 2016 2017 - Decision on EA/Construction Licence (TBD) Today’s Session OPG response to the Minister’s Request: • Package #1: #1a Study of Alternate Locations – Environmental Effects and Transportation #1b Study of Alternate Locations – Incremental Transportation Costs and Risks • Package #2: Updated Cumulative Effects and • Package #3 Consolidated Mitigation Commitments OPG continues to work on the study requested by the Minister. Please note that any of the discussion points offered today are subject to change and may vary for the purposes of OPG’s final submission. 9 Information Request #1a Study of Alternate Locations – Environmental Effects 10 Study of Alternate Locations: Regional Study Approach OPG adopted a regional study approach, focusing on two geologic regions in Ontario: A sedimentary rock formation; and A granite rock formation Economic and technical feasibility criteria were developed Thresholds applied where applicable Reference locations were described, representative of key environmental features in those regions 11 Consistent with feasibility criteria Feasibility Criteria: Technical Technical Criteria Rationale Evaluation Factors Is there suitable host rock? Can the host rock support long-term containment and isolation? The volume of competent rock is sufficient to host and enclose the repository. The hydrogeological, geochemical and geomechanical characteristics of the host rock promote containment and isolation of the wastes. The host rock is geologically stable and resistant to expected geological and climate change processes. The geological setting supports site characterization. The strength and geomechanical properties of the rock are favourable for construction and operation of underground facilities. 12 Feasibility Criteria: Thresholds Technical Feasibility • Sufficient rock volume for a repository holding 200,000 m3 of as-packaged wastes, and for future doubling of capacity. • Host rock mass has low hydraulic conductivity such that contaminant transport in the rock mass is very slow. • Host rock compressive strength greater than the in-situ rock stresses. • Chemically reducing conditions at repository depth. • Seismically quiet location. 13 The Alternate Project: Phases and Timelines Sedimentary Location 14 The Alternate Project – Basis for Effects Assessment Same base project works and activities as for DGR Project at Bruce Nuclear site Incremental works and activities associated with: Design and implementation of a site selection process; Acquisition of property (240 – 900 ha) Additional site infrastructure (e.g., security, power, access) Transport of waste containers to alternate location Receipt and temporary storage facilities for containers at alternate locations • Additional activities at WWMF for extended storage • • • • • Not included in effects assessment but considered an incremental cost 15 Key Environmental Features Sedimentary Alternate Location Crystalline Alternate Location Geology is comprised of a layer of glacial drift, Geology is defined by a layer of glacial drift, overlying thick sequences of sedimentary rock, which sit upon crystalline basement bedrock Fractures are expected to be sparse Hydraulic conductivity profile similar to that of the Bruce site Area of low seismic hazard Small rivers or streams in the vicinity. Repository facilities not located within 120 m of provincially significant wetland 16 and lake and river sediments (i.e. clay, silt and sand) overlying the crystalline rock Typically fractured, the repository design may require engineered barrier systems Trend for decreasing hydraulic conductivity with depth in the Canadian Shield. Low seismic hazard Numerous small water bodies in the area as is typical of the Canadian Shield, defined wetlands cover a small percentage of the surface area. Some areas may be transiently wet in the spring. Repository facilities not located within 120 m of provincially significant wetland Surface water quality generally good with limited human influence. Environmental Effects – Valued Components Environmental Component Atmospheric Environment Air quality Noise levels Surface Water Surface water quality Surface water quantity and flow Aquatic Environment 17 Valued Component (VC) Aquatic habitat Aquatic biota Terrestrial Environment Vegetation communities, including upland and wetland Wildlife habitat and biota Geology and Hydrogeology Soil quality Groundwater quality Groundwater flow Radiation and Radioactivity Humans Non-human biota Land and Resource Use Use of lands and resources Screening for Potential Interactions Aquatic Environment Sedimentary Location Project Works and Activities DGR at Alternate Location Aquatic Environment Aquatic Habitat Aquatic Biota Site Preparation ● ● Construction of Surface Facilities ● ● Excavation and Construction of Underground Facilities ● ● Site Selection and Licensing Transportation of Waste Packages to DGR Above-ground Transfer of Waste Underground Transfer of Waste Decommissioning and Closure Postclosure of the DGR Facility Presence of the DGR Project Waste Management Support and Monitoring of the DGR Life Cycle Workers, Payroll and Purchasing 18 ● Environmental Effects Sedimentary Location – Aquatic Effects Aquatic Habitat and Biota • Location is generally well drained. Most watercourses are cool to coldwater and are considered to be more sensitive to disturbances than warmwater systems. • Effects on the aquatic environment are most likely during the site preparation and construction phase. • Assumes no encroachment on wetlands or streams, although some supporting habitat for aquatic species such as burrowing crayfish may be removed. • Changes to water quality may affect aquatic habitat and biota throughout construction and operations phases. Discharge to a small, local receiving waterbody is assumed. Discharges would meet criteria established considering aquatic toxicity thresholds. 19 Environmental Effects Sedimentary Location – Aquatic Effects Aquatic Habitat and Biota • Blasting activities have the potential to cause an indirect on aquatic VCs through changes in vibrations levels. Blasting management strategies would be employed to minimize predicted levels at aquatic spawning habitats in the region. Blasting management plan would be established to ensure vibrations levels during blasting are protective of applicable Fisheries and Oceans Canada (DFO) thresholds. • Mitigation measures for aquatic habitat also expected to be protective of biota • Considering mitigation, no significant effects on the aquatic environment are likely. Mitigation requirements may be slightly higher in magnitude discharging to a smaller waterbody. 20 Environmental Effects: Sedimentary Location – Aquatic Effects Valued Component Aquatic Habitat Effects as Compared to DGR ↔ Mitigation Requirements ▲ Comments Effects on aquatic habitat are likely to be similar at both sites The magnitude of effects may be slightly higher, or additional mitigation may be required, at the alternate location if discharged to a smaller watershed. Aquatic Biota 21 ↔ ↔ Effects on the aquatic environment are likely to be similar at both sites Environmental Effects: Crystalline Location – Geology and Hydrogeology Project Works and Activities DGR at Alternate Location Geology and Hydrogeology Soil Quality Groundwater Quality Groundwater Flow/ Transport ● ● ● ● ● Site Selection and Licensing Site Preparation Construction of Surface Facilities Excavation and Construction of Underground Facilities ● Transportation of Waste Packages to DGR Above-ground Transfer of Waste Underground Transfer of Waste Decommissioning and Closure ● ● ● Post-closure of the DGR Facility ● ● ● Waste Management ● ● ● Support and Monitoring of the DGR Life Cycle ● ● ● Presence of the DGR Project Workers, Payroll and Purchasing 22 Environmental Effects: Crystalline Location – Geology and Hydrogeology Site Preparation and Construction Phase • Hydrogeology has the potential to be affected by site preparation and construction activities. • Potential effects relate to construction dewatering and the resulting zone of influence due to pumping and management of pumped groundwater, which will have direct and indirect effects on overburden and shallow bedrock groundwater quality and solute transport. • Construction of additional site infrastructure to access the site may also have an interaction with shallow groundwater flows. Taking into consideration the variable bedrock terrain in the region, excavation or blasting for road cuts may be required. • Localized dewatering may be required in the vicinity of excavations. 23 Environmental Effects: Crystalline Location – Geology and Hydrogeology Operations and Post-closure phase • During operations, the project has the potential to continue to affect groundwater flow from dewatering of underground facilities; however, volumes of water to be managed are likely to be much smaller during operations, and therefore, the potential for effects further reduced. • Active groundwater flow in bedrock is generally confined to shallow localized fractured systems, and is dependent on the secondary permeability associated with the fracture networks. • Groundwater flow at depth at a crystalline rock location may exhibit some advective flow through a fracture network, in zones where fractures are present, rather than exhibiting entirely diffusion dominated flow. Additional mitigation may be required as part of the crystalline rock location • Potential effects are also identified during the postclosure phase. • Given groundwater flow regimes in a crystalline rock environment, unlikely to result in significant adverse effects on geology and hydrogeology. 24 Environmental Effects: Crystalline Location – Geology and Hydrogeology Valued Component Soil Groundwater Quality Groundwater Flow 25 Effects as Compared to DGR Mitigation Requirements ↔ ↔ • Effects on soil quality are expected to be similar ▲ • Residual effects on groundwater quality are expected to be similar between sites; additional mitigation may be required as part of the crystalline rock location ▲ • Residual effects on groundwater flow are expected to be similar between sites; however, additional mitigation may be required. ↔ ↔ Comments Environmental Effects Overall Preliminary Findings Increased Environmental Effects include: • Increased effects on air quality, including greenhouse gases, during waste transportation from the WWMF to the alternate location • Increased effects on noise levels due to likelihood of quieter background levels at the alternate locations • Adverse effects on vegetation communities from increased clearing during site preparation and construction of surface facilities and supporting infrastructure, including access roads • Adverse effects on wildlife communities due to establishment of a new site with associated indirect effects from vegetation loss and habitat fragmentation • Effects on traditional and non-traditional land use due to establishment of a change in land use, traffic from waste transport and workers, and indirect nuisance-related effects relative to background levels 26 Information Request #1b Incremental Transportation Costs and Risks 27 Transportation Study: Scope Focus of the Transportation Study • To determine the incremental costs and risks for transportation packaging of the entire inventory of L&ILW and its transport on public roads to alternate locations • The complete inventory of waste at 2045/2055 is stored in approximately 54,000/57,000 containers • The total volume of LLW is ~ 138,000/146,000 m3 • The total volume of ILW is ~ 10,000/11,000 m3 28 Transportation Study: Key Planning Assumptions All shipments are made by truck transport on public roads Transportation schedule aligned with retrieval activities Activities considered in this report comply with CNSC, Transport Canada, and MTO requirements for packaging type and specifications Waste characteristics assumptions aligned with current L&ILW DGR Safety Case This estimate is a Class 5 Estimate according to AACE classification Four distances considered • 100 km, 500 km (2045 DGR in service date); • 1000 km, 2000 km (2055 DGR in service date) 29 Transportation Study: Cost Estimating Methodology Costs included in the estimate are limited to the incremental costs for: • Packaging for transportation • Road transportation from WWMF to alternate locations (labour, tooling, and equipment) Waste Stream grouping used to assimilate the common characteristics to simplify methodology. • Determine the nature and number of transport packagings • Re-packaging was added where required to render containers “road ready” Cost estimate developed for each of the 12 waste stream 30 groups (4 LLW and 8 ILW groups) Cost adjustment factors are used for each waste stream to account for uncertainties Reference Plan vs Incremental Activities for Alternate Locations 31 LLW Waste Streams WWMF LLSB (DGR Ready): 2045 2055 38,287 35,105 containers containers 6,150 shipments 6,508 shipments LLSB (Not DGR Ready): 2045 2055 12,227 containers 2,446 shipments Bruce SG Segments: 2045 2055 416 segments 416 shipments Trench Waste: HX Segments: 2045 LLW Volume: 138,000 m3 32 2055 LLW Volume: 146,000 m3 2045 2055 1,926 containers 241 shipments 2045 2055 31 intact HX’s 31 shipments 20 HX segments 20 shipments ILW Waste Streams - 1 WWMF IC-2 TH with Fixed Liners: 2045 2055 17 containers 17 shipments IC-2 TH with Removable Liners: 2045 2055 66 containers 66 shipments Quadricell Storage Units with Resin Liners: 2045 2055 115 resin liners 98 shipments IC-18 with THEL: IC-12/IC-18 Resin Liners: 2045 ILW Volume: 10,000 m3 33 2055 ILW Volume: 11,000 m3 2045 616 containers 616 shipments 2055 698 containers 698 shipments 2045 2083 resin liners 1770 shipments 2055 2289 resin liners 1945 shipments ILW Waste Streams - 2 IC-2 Grouted Tile Hole Liners: 2045 2055 43 containers 43 shipments 34 Bruce RWCs 2045 2055 712 containers 712 shipments Darlington RWCs 2055 2045 474 containers 474 shipments Transport Packagings 35 Container Outbound Shipments 36 Total Incremental Packaging and Transportation Costs 37 Transportation Cost Development Major Cost Categories 38 Transportation Risk Management OPG transports over 800 consignments of radioactive material every year • Over approximately 500,000 kilometres. OPG has been safety doing so for over 40 years and has never had an accident resulting in a radioactive release or a serious personal injury. Safe performance is due to our Nuclear Management System: • Radioactive Materials Transportation Program • Processes and programs to ensure OPG achieves its safety objectives, continuously monitors its performance against these objectives, and fosters a health and safety culture. 39 Packaging and Transportation Incremental Risks At WWM and Alternate Locations • Conventional Risks: Increased probability for vehicular accidents during: – Delivery of new transportation containers to WWMF – Movement of heavy equipment needed to load/unload waste – Movement of workers and good • Radiological Risks: Increased dose exposure due to: – Additional waste handling (repackaging more, more steps) – Additional waste processing 40 Packaging and Transportation Incremental Risks During transportation • Vehicular related risks Potential human health affects due to increased levels of vehicular emissions Potential for injuries and/or fatalities • Cargo Related Risks Exposure of low levels of ionizing radiation (during routine transportation and during accidents) – During routine transportation – external dose from packages – During transportation related accidents – release of radioactive material via multiple environmental pathways 41 Study of Alternate Locations Overall Findings 42 Study of Alternate Locations Findings More environmental effects occur at the Alternate Locations due to: • Installation of site infrastructure and equipment for receiving and interim storage of waste • Additional waste packaging and transportation • Additional GHG emissions during a long transportation campaign Mitigation measures are expected to eliminate, minimize, or control the majority of these effects. • No significant adverse effects are expected 43 Study of Alternate Locations Findings Packaging and transporting waste to an Alternate Location would result in: • An increase in transportation risks: 22,000 shipments on public roadways. • A cost impact in the range of $0.4 - $1.4B Longer distances have highest potential cost This doesn’t include additional project costs from re-starting the program Overall, the Bruce Nuclear site remains the preferred location 44 Information Request #2 Updated Cumulative Effects Analysis 45 Updated Cumulative Effects Analysis: NWMO APM Process APM DGR for used fuel • Federal approved plan • Multi-year process • No sites have been identified • No community has volunteered to accept the project • No detailed design / safety / environmental assessment • NWMO has committed to working with local communities, including SON • Process would include identifying, assessing and mitigating effects 46 Updated Cumulative Effects Analysis: Map of Municipalities For purpose of responding to 47 Minister, an APM DGR is assumed located somewhere in HuronKinloss, South Bruce or Central Huron Would be at least 20 km from OPG DGR Project as per NWMO published descriptions and safety case studies Would be sited and designed to be safe; would meet all discharge criteria at APM DGR site boundaries Potential effects as per NWMO Phase 1 assessments CEAA 2012 Requirements Cumulative environmental effects described and assessed based on consideration of an APM DGR in Huron-Kinloss, South Bruce or Central Huron Considered updated guidance since EIS filing: • Canadian Environmental Assessment Agency’s Operational Policy Statement Assessing Cumulative Environmental Effects under CEAA, 2012 • Draft Technical Guidance for Assessing Cumulative Effects under CEAA, 2012 Includes consideration of potential cumulative effects of malfunctions and accidents 48 Overall Approach IDENTIFY RESIDUAL ADVERSE EFFECTS OF THE PROJECT Section 3 Is an adverse effect likely on a VEC from the DGR Project? DESCRIBE POTENTIAL ADVERSE EFFECTS OF THE APM PROJECT Valued component-focused narrative c Section 4 Is the APM project likely to affect the same VECs? YES NO DESCRIBE SPATIAL AND TEMPORAL BOUNDARIES FOR THE VEC What is the most applicable scale to assess cumulative effects? DESCRIBE POTENTIAL CUMULATIVE EFFECTS Are adverse effects likely beyond those already considered in the EIS? IDENTIFY MITIGATION AND MONITORING LIKELY TO BE REQUIRED ASSESS SIGNIFICANCE OF ADVERSE CUMULATIVE EFFECTS (If required) 49 Section 5 (by VEC) discussion Cumulative effects analysis considers whether in concert with potential effects of the APM Project these adverse effects could significantly affect valued components For the purposes of the assessment have assumed that potential effects are residual effects Residual Adverse Effects: OPG DGR Project 50 Environmental Component Residual Adverse Effect Surface water - Terrestrial environment Loss of eastern white cedar due to site clearing Aquatic environment Loss of aquatic habitat in ditches due to bridge construction Air quality Increase in some air pollutants due to industrial activity Noise Increase in noise levels Socio-economic Reduction in enjoyment of nearby property due to increased noise level Human health Increase in acrolein levels in air (from diesel equipment) Radiation and radioactivity Radiological emissions (although no residual adverse effect) Reduction in flow in North Railway Ditch Increase in flow in Interconnecting Drainage ditch Consideration of Temporal Overlap The two projects overlap temporally, although their site preparation and construction phases are likely to occur at different times 51 Updated Cumulative Effects Analysis: Hydrology Residual adverse effects of the DGR Project identified in existing engineered channels (i.e., North Railway Ditch and drainage ditch at Interconnecting Road) Potential effects from the APM DGR identified on surface water flow • Site clearing, construction dewatering, and management of surface water drainage, stormwater, and wastewater • These activities may contribute to a change in flow in local drainage areas in the vicinity of the selected site Thus, the APM DGR is likely to have both overlap in the type of effect (i.e., affect the same VC, surface water flow), and overlap in time with the residual effects of the DGR Project. 52 Updated Cumulative Effects Analysis: Hydrology Mitigation measures will be in place to limit effects • Compliance with applicable regulations and permitting requirements • Siting and design would seek to avoid or mitigate effects on surface water quantity and flow The APM DGR would not in any event be within the same watershed as the DGR Project Cumulative residual effects on surface water quantity and flow are unlikely 53 Updated Cumulative Effects Analysis: Noise Levels Residual adverse effects identified during site preparation and construction and decommissioning phases at closest receptors (approximately 1 km from the DGR Project site) Potential effects from the APM DGR identified on noise levels • Site selection, construction, operation, and decommissioning and closure all require equipment and activities that generate noise emissions • For APM construction-like activities will continue through operations • Transport of used fuel may also generate noise (~2 trips per day) Both projects are therefore likely to affect the same VC 54 Updated Cumulative Effects Analysis: Noise Levels Timing of effects are unlikely to overlap • Construction activities for DGR Project may be complete in advance of APM Construction Mitigation measures included in both projects to limit the extent of effects to within 1-2 km of Project activities • Best management measures to ensure both projects they meet regulatory limits and guidelines (e.g., MOECC guidelines for noise or equivalent), and municipal bylaws, as applicable at receptor locations The APM DGR will be at least 20 km from the OPG DGR Cumulative effects on noise levels are unlikely as a result of the APM DGR 55 Updated Cumulative Effects Analysis: Non-Radiological Malfunctions and Accidents EIS considered a bounding non-radiological spill • From a vehicle accident, failure of on-site storage equipment (i.e., a storage tank) or operational errors Potential effects of a spill would be contained within the DGR Project or APM DGR site • Measurable changes to soil and groundwater quality from a spill are possible • In the unlikely event a spill would reach a waterbody, it would be confined to the onsite drainage ditches, where it can be contained in advance of a release to the environment (e.g., to Lake Huron) Spills would be responded to quickly, and remedial actions put in place to limit effects on the environment No adverse cumulative effects likely 56 Updated Cumulative Effects Analysis: Radiological Malfunctions and Accidents During the postclosure phase, there were only a few scenarios where effects could approach or exceed criteria • For example, inadvertent drilling of a borehole into the repository horizon or a substantive failure of shaft seals If one of the above scenarios occurred at the OPG DGR site after several hundred years, the main potential radiological consequence would be the release of gaseous carbon-14 • The effects of this would be of highest magnitude around the OPG DGR site, as it would rapidly disperse in the atmosphere • At that time in the future, the APM DGR would also be closed and sealed and it is expected that there would be no measurable additional radioactivity at surface due to the APM DGR Therefore, there would be no adverse cumulative effects likely 57 Updated Cumulative Effects Analysis: Findings The results of the assessment showed that cumulative adverse effects are unlikely given the distance and limited extent of the environmental effects of both projects. In addition a cumulative environmental effect as a result of malfunctions and accidents from both projects is also unlikely. As a result, no new residual adverse cumulative effects were identified, and an assessment of significance was not required. 58 Information Request #3 Mitigations Report 59 Mitigations Report: Commitments OPG has tracked all commitment statements made in its 2011 submission documents and over 3 years of public review and Hearings (“OPG will …”) Documented in the Consolidated Commitment Lists Report Over 900 listed in the 2014 (R2) Report • Most of these are repeated commitments, but made in different places and times • About 3/4 are associated with mitigating and monitoring environmental effects 60 Mitigations Report Mitigations Report includes: • Mitigation measures included in facility plans, and identified in the conduct of the EA, • Monitoring commitments to confirm that mitigation measures are effective and effects are as predicted, • Mitigation and monitoring activities identified in CEAA’s proposed conditions as accepted by OPG. Consolidates into approximately 150 main commitments • Supported by about 500 detailed commitments Also identifies commitments that have been completed to date or have been updated 61 Mitigations Report Mitigations Report: Structure Mitigations are grouped by related Valued Ecosystem Components Groupings: Geology Hydrology and Surface Water Quality Terrestrial Environment Aquatic Environment Radiation and Radioactivity Atmospheric Environment Aboriginal Interests Socio-Economic Environment Human Health Ecological Features 62 Mitigations Report: Example #1 VEC: Hydrology and Surface Water Quality - Surface Water Quality • Main Commitment: All stormwater runoff from the DGR Project site, including the WRMA, will be collected into drainage ditches that flow into the stormwater management pond. • Detailed Commitments: • Site will be graded to capture all stormwater collected on site • Vegetated perimeter ditches will control sediment loading in the pond • An oil/water separator (i.e. stormceptor) will control hydrocarbon releases, Total Suspended Solids and metals associated with TSS • A temporary water treatment plant … will be located in the vicinity of the shafts to receive water pumped from underground in the event that there will be abnormally high concentrations of oil, grease and/or grit in the water. • … 63 Mitigations Report: Example #2 VEC: Hydrology and Surface Water Quality - Surface Water Quality • Main commitment: Water sampling and testing is proposed to confirm that all water released from the DGR Project site via the stormwater management pond has concentration levels below certificate of approval discharge criteria • Detailed commitments: • Final water quality criteria for the effluent from the pond will be developed as part of the Ontario Environmental Compliance Approval • OPG will, prior to construction, submit to the CNSC a plan for treatment of all water destined for discharge from the stormwater management pond • Samples will be collected quarterly at a minimum throughout the site preparation and construction phase as described in the EA Follow-up Monitoring Program document • … 64 Mitigations Report: Example #3 VEC: Radiation and Radioactivity - Humans • Main Commitment: Waste Package Receipt, Transfer and Handling procedures and processes will be implemented • Detailed Commitments: • All waste packages sent to the DGR will be checked against the DGR waste acceptance criteria, which will include measuring the waste package dose rate to ensure it is within specified limits • OPG will prepare an inspection protocol for waste containers, beyond visual inspection, that must be followed before their placement in the DGR • At no time will radioactive waste be transferred in the main cage while personnel are being concurrently transferred in the auxiliary cage under normal operating conditions • … 65 Mitigations Report: Example #4 Examples of Completed Commitments: 66 Shaft pilot programs, which are to be established prior to excavation and construction. Completed in 2011. Pilot boreholes drilled at shaft locations. Grouting trials to confirm feasibility of surface-based grouting. Completed in 2012 Installation of a shallow groundwater monitoring program. Completed in 2012 with additional 8 monitoring wells. Specification of the geoscientific verification to be done in the ventilation shaft (in addition to the main shaft) Completed in 2014 Response to Minister’s Request Next Steps 67 DGR Next Steps OPG is on track to provide the Canadian Environmental Assessment Agency the requested information in December. • OPG will incorporate feedback/comments from this round of public/stakeholder review • OPG will post the final submission information on our web site This new, additional information supports the current plan for OPG’s DGR at the Bruce Nuclear site as a safe and cost effective long-term management solution. 68 Canadian Environmental Assessment Agency Next Steps The Canadian Environmental Assessment Agency will announce plans for a public review of OPG’s work prior to a decision on the Environmental Assessment. They have announced public funding is available to review: • OPG’s submission, • the report the Agency will prepare following its analysis of the additional information; and • potential conditions with which OPG must comply, if the project is allowed to proceed. 69
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