HomeMy WebLinkAboutCAO 14/99�,N-oF : 13 :
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REPORT TO COUNCIL
FRCMi Thomus J. Quinn , DATE: November 30, i999
Chief Administrntivc Officer
REPORT NUMBER: CAO 14-99
SUBIECT: Ontnrio Power Generntion Environmental Assessment
- DraR Scope of Assessment - Comments to AECB
- F;le, UT 3540
RECOMIv1ENDATION:
I. That Report to Council CAO 14•99, providing commenis on the Dra4 Scope of
Assessment preptucd by the Atomic Energy Control Eionrd (AECB; for the
Environmentel Assessment at Pickering Nucleur Genernling Slation, be received.
1. That AtWChment �2 to Report to Council CAO 14-99, entitled "Pcer Review Tenm
Comments on the DmR Scopc of AssessmcnP', be endorscd us the Town's comments on
lhc AECB's DruR Scope of Asscssmenl, nnd that u copy of Report to Council CAO
14-99, includins Attuchmcnt k2, bc fonvardcd to thc AECD for consideration in
preparing thc final Scopc of Asscssmcnt, nnd to ihc Ontnrio Powcr Gcncrution for
infomtation.
3, Thnt Attachments N3 and if4 to RcpoA to Council CAO 14-99, bcing thc Pccr Review
Tetun comments on two documents prcpnred by the Onlario Power Generntion as part of
the environmenwl nsscssmcnt proccss, be rcccived and fonvnrdcd to thc Atomic Gncrgy
Control Bourd nnd thc Oitnrio Powcr Gencmtion for infortnntion.
ORIGIN:
On November 2, 1999, n DreR Scope of Aseessment was rclenseJ by the AECA (Atomic Energy
Ccntroi Board) und received by the Town an November 8, 1999. AECB requested written
comments nn or befare December 2, 1499, The Town rcquestcd and rcceived nn exler�ion to
this submission date to December 10, 1999, in order that the matter could be dealt with at
Council's regular meeting of December 6, 1999.
AUTHORiTY;
Municipal Act, R.S.0.1990
FINANCIAL IMPLICATIONS:
There aze no financinl implicntions to the Town essociatcd with the uaceptancc of this Report.
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14 Report to Cowcil CAO t4-99 ` ' Date: November, 30,1999
SubJect: Ontario Poweraeneration Environmcntul Assr�P`rment
- DreR Swpe of Assessment - Commenis to AECB �`� I'
= File: UT 3540 � 7_. Pnac 2 of 6
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EXECUTIVBSUMMARY: 11li :
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In reviewing AECB's Draft Scope of Asscssment doi'iiment, the Towns' Pcer Rcvicw Team
were looking for a'well luid out, ccedible, cohemnt 'framework' for a comprchensive scientific
auessment of ihe environmental impact urising from the mstnrt of Pickering "A". Unfortunately,
tha Pecr Ra�•iew teem concluded that AECB's document does not provida such a framework.
The Teum noted thnt ths document suffers from poor orguni�ation and is incomplete und
' nmbiguous in various areas,
In addition, the Peer Reviow Team is concemed that the AECB chosc to permit a"screening
level" rnther than a"comprchensive" envirunmentel assessment. They nlso identified n number
of other signilicant problems with AECB's DmR Scope of Assessment, including the timeframe
for compledng the assessment, the need for a credibla public consultation process, tha need to
consider environmenWl impncts arising S'rom thc entire Pickering Nuclear opemtion, anJ the need
to ensurc thul other important scientific smdies tue completcd bcfore, or ns ptvt of, the
environmental assessment.
' This Rcport to Counoil provides an overvicw of AECB's Draft Scopc of Asscssment, and
summarius the Peer Revicw Team's kcy comments and rccommendations. Thc full mport of
the Peer Review Tcam is includcd es Attachment #2 to this Repon. It is rccommended that
Council endarse Attachment k2 us the Town's commenls on AECB's Dmft Scope of
Assessment.
In nddition, this Report to Council nlso includcs commcnts from lhe Pccr Review Team on two
documents recenUy releuscd by the Ontnrio Power Generntion (OPG) ns part of the
environmeninl assessmcnt process; (i) "Public and Stukchaldcr Consulmtion and
Communicntion", nnd (ii) "Origin, Understanding and Disposition of Ihc 160+ Issucs". It is
recommcnded thut Council rcceive thcsc commcnts nnd fon�ard them to Ihc AECB nnd OPG for
information. The fu{I rcports of thc Pccr Review Tctun on thcse documcnts are included as
AtWchments #3 nnd �4.
BACKaROUND:
This Repori to Councii is intended primarily to address the AECf3's DrnR Scope of Assessment
document, However, the Report nlso provides wmmenis on two documents recently released by
OPG as pnrt of its emironmentul assessment program, onc relaied to the OYG's proposcd
community consulmtion proccss, and the other related to OPG's intentions wnceming the 160+
issues identified in 1998 by u Commimity Working Group that wes involved with OPG in an
eariier Biophysicui Review of t�e nuclenr smtion.
For convenience, this Report is organized into four mnins sections, as follows:
1. Overview of AECB's DraR 3cope of Asscssment
2. Peer Review Team comments on AECB's DrnR Scope of Assessment
3. Peer Review Team commenis an OPG's Public and Stakeholder Consultution
end Communication
4, Peer Review Team comments on OPC}'s Odgin, Understending & Disposition
ofthc 160+lssucs.
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Report to Council CAO 14-99 Dnte: Novcmber, 30, 1999 l r�
Subject: Onlerio Power Qenerntion Envlronmental Assessmenl
- Dralt Scopc of Assessmont - Comments to AECB
. - File: UT 3540 ."aQe 3 of 6
L Overvlew of AECB'a Draft Scooe otAaaeaamcnH
Earlier this year, AECB was notified by OPG of its intcntion to apply for rcgulntor,� approvni far
lhc retum to service of Pickering "A". AECB responded to OPG thut before n regulntory
decision couid b: made on this mntter, nn environmenmi nssessment (EA) would first need to be
completed, pursuant to lhe Canadian Envlronnien�al Assessment Acl,
AGCB furlher ndvised thnt OPG Kas required to complete u Screening Environmental
Assessment. A� pnrt of this process, n Dmft Scope of Assessment wus prepared by AECB for
public comment.
AECB's DrnR Scope of Assessment is intended to provide guidnnce and direction to OPG on
completing the environmental assessment. 'Ihe document sets out to provide infortnation on n
numbcr of mnilers, including the rationnle for conducting a screening level assessmcnt, the scope
of the assessment, the nssessment proccss and schedule, and thc structure of the rcquired EA
roport.
Thc DrnR Scope of Assessment is dividcd into eight mnin sections. Sectian 6.0 outlines th:
scope of the ussessment. It requircs that the nssessment includc considemtion of the following:
• the environmcntul effects of the projcct, including thc cnvironmentnl effects of
malfunctions or accidents and cumulntive environmcntnl effccts;
• the significance of thcse cffects;
• commcnts from thc public tnat are reccivcd; nnd
• measurcs that are technicnlly and cconomically feasible ¢nd thnt �vould mitigate any
significant ndvcrsc cnvironmental cffccts of thc projcct.
In addition, the DmR Scopc of Asscssment also rcquircs that OPG givc considcrntion to thc
Following:
• n description of lhc projcct, including ils purposc;
• n description of thc cxisting environment cxpcctcd to bc uffectcd by the project;
• the progrnm for consullation with the communiry und other slukeholdcrs, and Cor
uddmssing issues thnt nre mised;
• the process for uddressing the public and technical issucs idcntificd during Ihe 1998
biophysicul teview;
• etTects on the capacity of rcnewable resources thnt ure likely to be affected by the
project; ond
• an ider,tifiaution of the dccommissioning plunning process for the facility.
It should also be noted that es part of the Druft Scope cf Assessment, AECB huve indicnted thut
it is lhe intention of the AECB Board to hold it's meeling to consider lhe EA document in thc
Town of Pickering, as requested previously by Town Council and the community.
2. Peer Revlew Team commente and AECFi's Dratt Scone of Asaesament:
The Peer Review Team made a number of significant commenis and rccommcndations on
AECB's DraR Swpe of Assessment document (see Attachment N2). Although all of Pccr
Rcview i evn's comments are cxtremely valid, tha following ore worth highlighting at this time.
• Rathcr than requidng a"screening Icvel" environmentnl osscssment, AECB should
requirc a"comprehensive" environmenwl nssessment 7'he resmrt project is ''
sufficient large and envfronmen�ally sensltive to wartant a comprchensive rcvicw.
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� G Report to Council CAO t4•99 Date; November, 30, 1999
Subject. OnGuio Powe: Denerffiion Environmentnl Assessment
- Dreft Scope of Assessment - Commenls to AECD
- File: UT 3540 Puae 4 of 6
• The timefrema of the environmrntal essessment should be extcnded to allow the
incorporn►ion of criticnl baselinc environmsnwl informetion, nnd the completion of
' ait relevant atudies and re�•iews (includir�g AECB's Cuncer Surveillence Program
and OPG's Ecologicei Ris4 Assessment 5tudy).
• The Dreft Scope's overall poor organi7ation and lack of u cleur Gamework crentes the
potential for conilicting inteiprelations of exncUy what work is required, The AECI�
should define precisely whnt is within the scope of the assessment. AECB should clarify
that ell public hcalth issues will be addressed in the EA.
• The long term environn:entnl impacis of the projcct should be assessed over the
"coninminating lifespan" of lhe fncility, not nn operntional lifespan determined by OPG.
The thirteen kcy recommendntions of 1ha Peer Review Teum are listed below.
L AECB should ensurc that the Final Scope is cleazly writtcn, systemutically strucwrcd and thnt each
speclfic requirement is carePolly identified and numbered.
2. AECB should recognlu the level of public concem, Ihe wide scope of outstonding environmenml
issues and significant dnta gnps nnd mise the assessment from n scrcening level lo comprehensive.
3. AECB should ensurc that the Ffnal Scope documcnt includes nll rcicvunl definitions. A glossary of
tertns and e Ilsting of ncronyms should bc attnchcd.
4. AECB should ensurc Ihat the Final Scope document conwins un explicil statement rccognizing �hot
the scopc af the envfronmentnl asscssmcnl includc environmentul impacts nrising from thc cntirc
Pickering Nuclenr Oenernting Station opemtion.
5. AECU should ensuro Aiat any issue(s) eppertnlning to identification of currently existing'baseline
onvironmentai conditiona' in Ihe Final Scope explicitly rccogniu the nuture of cxisting fmpTCts.
6. AECB should ensurc thnt OPd provide the Town of Pickcring with n comprehe�utve Ilsting of nll
ongaing or p(anned projecis that appertain to meacurcmeN of'environmenWl impacP along wilh the'
timetable for complelion of rcsults and interprctaifons.
7. AECB should onsure Ihat the Finnl Scopc contnins study nrcas that arc eppropriatc to specific
Individual discfplines nnd not loave OPQ and its consultanu lo determine (Ifmit) the extent of their
sludy.
8. AECB sho�ld ensure thet cansideratlon of camuletive environmental effects is consfdered for all
study ercas.
9. AECB should ensurc that thc tertn'sinkeholder' is ndcqualely defined in the Finel Scope and that ell
relevant stnkeholders nrc Included within the envlronmenlal assessmenl process.
10. AECB should ensuro �hat cumnt estimates of the operat(annl and conteminating life spans of PNOS
erc identitied In the Final Scopc and employ'contnminating lifcspan' as the Nmeframe far essessing
cumuletive end edverse environmental effecb.
I I. AECB should ensuro thet Ihe Final Scope explicitly recognlus and addresses the (ssue of public
health impacb.
12. ABCB should ereuro that Ihe Final Scope steta explicitl, that OPO ls committed lo addrcss ell
oubtending technicai issues arisfng from the Pickedng Bmironmentai Review of 1998 in the
environmentel es;essment
13. AECB should ensuro that a rcelislic qme(mmc be esleblished for thc environmental asscssment ro
nllow complotlon of e crcdibla public consultetion process, end esscesment of edcndOc data from
ituules alrcady undenvay or plenned.
Report to Council CA014•99 Date: November, 30,1999
SubJect Onterio Power Generndon Environmcntal Assessment
- Draft Scope of Assessment - Comments to AECB
• File: UT 3�40 Paue 5 of 6
3. Peer Revtew Team commente on OPG'a Public end Stakeholder Com�dtation pnd
Comrounicakioo
[n September 1999, OPG rcleused a document identifying its intent to consult with the public and
ather stukeholders duting tha environmentnl assessment process. To u ccrtain extcnt, this is a
work-in-progress, ns chnnges to the consultation process can be mnde ns thc EA proceeds.
G°G's document was forwarded to the Peer Review Team for revizw and comment. The
follo: ting is n summary of commenis rcccived from the Peer Review Team.
• The document focuses too much on wGat will be done nt the cxpense of hotiv it will be
nccomplished.
• Key stakeholders tue missing from the potential stukeholder list; this issue should bc
clerified once the geogrephical boundnries for lhe EA ure set.
• A list of acronyms nnd ubbrevintions is required to assist the public.
• Thero is a need for more information rcgarding the nnturc, purpose, and use of
interview datn.
• The rationale for inciuding mcdiu ns n stnkehaldcr should be includcd in the report.
• The follow-up process should be monilorcd, and the mcchnnism for the dclivcry of
follow•up malerial documented.
• Thc most effective typc of consulting to be used nt diftercnt stages of the process
should bc clnrified.
• The purpose of the web site should bc clarificd.
� Newsletters are very useful and a widcly accessed source of infortnnlion.
• Is thcre an existing complainls datn basc that can bc anulyzcd to provide bnse linc
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4. Peer Review Team commenle on OPG's Oriein, Undcrotandine & D(�nusition of lhc
160+isaues
In October 1999, OPG rclenscd n dmil documcnt outlining how it inlends to uddrcss in thc EA,
the 160+ issues identified in 1998 by lhe Community Working Group thal was involved in the
OPG's Biophysicai Review of thc plant. Thc Pecr Revicw Team comments on this documcnt arc
sumtnarized bclow.
• The document does not provide the infortnation it claims to present, nor does it meet its
stated purpose "fo facillra�e pu6lic inp �t and lhus ensure each tssue is adequately
uddressed tn �he EA ".
• The document '�s not provide a�y'nfocmation rcgarding methodology, and no mention
is made of how identified issues wili be denit with.
• AECB's Final Scope needs to include the Independent Reviewer's comments on the 1998
Environmen�el Review, Volume I and II, in the list of sources of information available to
lhe publia
• The process used by the EA team for understanding the 160+ issues appears to be faidy
comprehensive,
• No mention is made of how cnch issuc will be denit with within tha EA. No explunution
is given as to tha methodology to be followed by Ihu EA team in detertnining whethcr an
issuc is judged to fall within the EA. As well, there is no mention of thc timeGwnc for
Ihe resolution of specific issues listed in the documcN,
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Report to Council CAO 14•99 Date; November, 30,1999
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a" g SubjecL• Onterio Powc^ Oaneration Environmcntal Asscssment
- Dmfi Scope of Assessment - Comments to AECB
- File. UT 3540 Paue 6 of 6
Conclusion:
Staff concur with the Pcer Review Teum's analysis, comments and recommendations with
respect to the AECB Draft Scope of Assessment, and thair commenis on OPd's "Pubiic and
Stakeholder Consultation and Commwication" document and "Origin, Understanding, 8c
Disposition of ihc 160+ Issues" document. .
It is recommended ihat Council endorse the Peer Review Teum report ss the Town's commenis
on the DrnR Scope of Assessment und fonvard these comments to AECB and OPG. It is also
recommended that Council receive the Peer Review Teum comments on the two associated OPG
documents, and fonvard these comments to ASCB and OPG for thcir information.
ATTACHMENTS:
1. DrnR Scope of Assessment Document
2. Peer Reviaw Tcam comments on PNGS "A" Retum to Scrvice, Drnft Scope of Assessmcnt
3. Peer Review Tenm comments Public and Stukeholdcr Consultation ond Communicution
4. Peer Revicw Teum comments Origin, U�dcrsWnding, & Disposition of thc 160+ Issues
P�P�d BY� Approved / Endorscd Dy:
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Gor c t o ias J. Quinn
r e t Co•ordinaror Chicf Administrntivc OlTiccr
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Thomas E. lym
Corpornte Projt end Pa •
Division Head
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oi as J. Quinn hief dmim tive 0 �cer '
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ATTRCHMENTN! �roa�om'a ��� ' Y� �9
:�EC:u ��n�c��i�c��te�•� 19
I'icicrriug Nudcai• CcncrnUng Slnlion':\' (NCS-A) Return lo Scn�icc:
Uraft Scopc uf Assessrocnl fur;m Cuvfronmcnuil Assessmenl (GA) Pursuant lu Uic
Ci�dudirm Eurimnuic�ihd:lrsessiuc�itArt (CEAA)
Onmrio Po�ver Generation (OPG) has notified the Atomic Energy Control Board I�ECD) of its
intention tu apply for regularory approval for die rcwrn to scR•icc of thc Pickerinc yGS-a
re�ctors at the Pickering NGS faciliry. The AECD has determincd that an em�iromnental
assessment must be completed in accordance with the (.i�uadin�i li�mirnnniu�iral.d.s.sds.rmunr.dc�
ICC•.�1A) before a regulatory decision on this licensing request can be made. There are several
steps to the CEAA process, includiny un initial one to es�ablish the scope of the project and the
I'acmrs ta be considered in the assessment. The "scope oFassessment" document provides OPG
with cuidance and direction fram the r1ECB on the basis for the conduct of the assessment, the
assessment process and schedule, and the strucwrins of the environmental assessment report to be
submiued to Ihc A[CD for re�•ie�v and decision.
The AC•CD is im�iting public comment on Ihe drafl scope of assessment document. Cupies of ihe
draft document mny be oEtained trom the AC•CD In�ernet �veb site (w1��v.aecb•ccca.�cca�, or
fiom the AECB contacts idemified rvithin the document. 11'ritten commeuts are in be submitted
tn the ;ntentiun of ihe contact nored bdow, prior to December'_. 1999
Pickcrin� NGS-A Lnvironmental Assessment.
�Ir. Bemard Richard, Program Spccialist
R�diation and Environmcntal Proicction Division
Atomic Energy Control Board
� ?30 Slater Street
', P.O. Oos IO�IG
Ottawa, Ontario hIP SS9
', Tcl: (613) 996-9997
', Fae:(G13)995-SOS6
! Interncr. richard.b n atomcon.gc.ca
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DRAI'f (November.2, 1999)
Pickering Nuclenr Generating StuAon 'A' (NGS-A) Return to Service:
Scope of Assasmeut for nn Enviranmenlal Assasmcnt (EA) Pursunnt to U�e CanaJtua
Envirunntenfal Asscssmenf Act (CEAA)
Atomic Energy Control Baazd (AECB)
Note: �~��
Onfario Po�ver Generation (OPC) has nodfied !he A►omic Energy Contral Board (AECBJ oj
iu lntendo:i ►o apply for regulalory approval jor the return 10 service ajthe Pickering NCS-a
rcaclurs at 1Ge Pickering NGSjucilify. Tl�e AECl3 has de�erudned tGat an environmental
assessinent must be couipleteJ in accordance ivil6 l6e Canadian Environuienlaf Assessmen�
Act (CEAA) 6ejore a regulalory decision an l/iis licensing request can be roade Tbere are
several steps �o t6e CEAr! process, including an initia/ one fo establisli (he scope ajt6e project
and the jactors to be considued in fhe assessnient
TLis draft document is in�ended as die basis jor co�uul�ation rvit6 �he community and
s�akeGolden in the prncess for esta6lisGing �he scope ojlhe assessment d�a! �vill be caiducleJ,
pursuant fo tGe CEM, jor d�e proposa! jrom OPCjor fGe re�urn to service ojlhe Hckeriug
NGS-A,
The AECB is inviting publlc caninuit on tliis drajt scope ojassessmerit docu�nent Capics oj
, �his draj� Jocunienf uray be o6mined jrontl6eAECUln�ernet ive6 site (i��v.aec6-cceagc.caJ,
or jruu� !6e ACClJ confac�s IJentifieJ at !Ge enJ uf tlits Jacument IVriften commenfs are (o
6c sabmitfed fo f/rose sanic conracfs priur lo Uccemher 2. /999.
1.0 Purposc '
This document provides Ontario Power Generation (OPG) with guidance and direction from the
AECB on the scope of the environmental assessment that must be completed to satisfy the
requircments of the Cauadiau E�rviratmenlalAueument Ac1(CEAA), as it applies to the
proposal from OPG Cor the return to service of the Pickering NGS-A facility. The scope of the
azsessment describes the basis for the conduct of the environmental assessment, and focuses the
assessment on relevant issues end concems. This document also establishes the assessment
process and schedule, and provides guidana ro OPG on how to structuro the environmental
assessment report to be submitted to the AECB for review and decision.
, While the guidelines provide tha basis for conducting the environmentai assessment and preparing
the assessment report, it is the responsibility of the proponent to provide sufficient information
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and analyses to allow evaluation of the patential advcrsa environmental ellects of the proposal.
The scope of assessment hus 6ecn drafted by tha AECD punuant to sections I5 and 16 of the
CEAA. .
2.0 Uackground
The operation of the Pickering NGS•A facility hu been regulated by the AECB since the 4
reactor units were commissioned in the early 1970s. The AECB regulatory process curcently
involves a renewal of the licence for the facility every two years. The licensing review conducted
as part of the licence renewal pracess includes an analysis of the safety and environmental
perCormance of the facility ovur the previous licensing period. The appointed members of the
AtomicEnergy Control Board (the Board) make the decision on the liance renewal, on the bazis ._.__ .
oFrecommendations &om AECB stat£und submissions Gom members of the pu6lic and interested
parties.
At the end of 1997, the Pickering NGS-A reactors were placed in a non-routine shut-down state
to comply with a licence condition regarding the enhanced shut-down system (SDSE), �nd to
initiate un OPG workplan to improve the safety and productivity of their nuclear operations. This
shut•down has been explicitly regulated by the AECB through a candition of the current operating
licence for the faciliry, issued pursuant to section 4 of the A�omlc E�iergy Control Regu/atioru
(AF.0 Regulations). The Pickering NGS•A operating licence remains valid for the Facility;
however, the reactors cannot be run at power without the prior approval of the AECB. Under
this licence, OPG may make certain improvemeats to the saCety systems and the environmental
protection programs of the facility. Operation of the Pickering NG5-B reacturs is regulated
through a separate licence issucd by the AECB, and is not af%cted by the cuRent licensing nction
for Pickering NGS-A.
In March 1999, OPG entered into discussions with the AC•CB on the possibility of rewming the
Pickering NGS-A reactor units to service in the year 20U0. Tlie AECB anticipates receiving a
licensing epplication from OPG for tlus proposal, later in 1999. The application will be subject to
a comprehensive licensing review by AECE3 stnff su that any such retum to service wauld occur
only in a manner that provides fur the protection of health, saCety and thc environment.
Regulatory approval of the application expected from OPG would involve nn amendment of the
curcent operating licence for Pickering NGS-A, pursuant to subsection 27( I) of the AEC
Regulations. This amendment would be made by the Board. It would remove tHe sn�:•down
state restriction and may propose licence conditions which would regulate the retum to service of
the Pickering NGS-A reacwrs.
3.0 Applicat(on of t�sr CunndYnn Environmental Asse�sment Act
AECB staff have received a notification letter and praject description &om OPG for the retum to
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service of the Pickering NGS•A.
The return to service of the Pickering NGS•A reactors has been detertnined by the AECB to be a
project as defined in subsection 2( I) of the CEAA. Acwrding to paragraph 5(1)(d) af the CEAA,
an environmental assessment is required before a federal authority exercises a regulatory duty that
is listed in the Law Lls1 Regula�lars under the CEAA.
The anticipated nmendment of tho Pickering NGS•A licence to allo�v the retum to service of the
facility will be made under a provision (ss. 27(1) of the AEC Regulattau) prescribed in the Lmv
Llsr Rel;ulutia�s, and thus constiwtes a'trigger' for the application uf the CEAA to this proposal.
The AECB is the Responsible Autharity (RA) under the CEAA in relation to the project.
The project docs not appear in the Ercluslat Lis1 Regula�iau under the CEAA, and thus there is
no exclusion &om the need to conduct an azsessment by these regulatiuns. No other exemptions
under the CEAA are considered applicable to this project. Furthermore, the project is not
described in the Comprehenslve Sludy Lfs� Reguloliau under lhe CEAA and thus, in accordunce
with subsection 18(I) of the CEAA, the AECB has n responsibility to ensure that a screening
assessment of the project is conducted, and that a screening report is prepared.
OPG has been notified of this detertnination by the AECB. The AECB liu delegated ro OPG the
conduct of the environmental assessment and the preparation of the drati screening report,
pursuant to subsection I?(I) of the CE4A.
A public registry for the project assessm�nt has been cstablished. Tlus incl�des identification of
the project assessmenl in the Federal Enviromnenlal Assessment Index (FEAl) which can be
accessed on the Intemet Web site of tha Agency (www,ceaa.gc.ca). The FGA1 reference number
is "I 8822".
The AECB, as the RA for lhc project, must ensuro thal lhe environmcntal nssessment is
conducted in accordence with the provisions of qu CEAA. Tlils includes determining the scope
of the proJect and the factors to be considered in thc nssessmcnt, rcviewing thc assessment repon,
and making a decision on the course ofactian to takc following this review, pursuant to
subsection 20(I) ofthe CEAA.
Pursuant to the FeJera! Cooruhml7ai Regularta�s undcr the CEAA, the Collowing federal
deFanments/agencies that are likely to have an interest in the review of this project have been
notified: Department of Fisheries nnJ Oceans (DFO); Hcalth Canada (HC); Natural Resources
Canada (NRCan), and Environment Canada (EC).
The Ontario Ministry ofEnvironment (OMOE) has been notified af the federal environmental
assessment to be conducted for this project. OMOE have indicated that there are no provincial
environmental assessment «quirements applicable to the proposal. OMOL stafihave indicated an
interest in panicipating in the technical reriew of the assessment.
3
. . � .. i - � . � � . . . ' . .
Thc Pickcring NGS�A project involves thc roturn ta scrvice of an existing, licensed facility; it does 23
not involve issues tliat would typically bc associated with the construction or aperation of a new
faciliry being licenced for thc first dme, The AECB considers thut tha environmrntnl assessment
issues and wncems that aro relevant to tha retum to service of the Pickering NGS•A facility can
be addressed efTectively and appropriately in the screening assessment that is required pursuant to
the CEAA. The environmentul assessment pracess that I�as been estublished for this project
includes opportunities for the input and participation of the community and other s�akeholders
that will provide for effective cansideration of public issues and concems.
4.0 Assa�ma�t Procas and Schedule
A summary of the key milestones for thu enviro�miental assessment of tha Pickering NGS-A
project is provided in Attachment L _._______. _�
This draft scope ofassessment document will be fivalized in consultation with tfie pubGc and other
smkeholders. Tnis step is expected to be completed by carly December 1999. The scope of
assessment will then be provided to OPG to guide the preparation ofthe screening report.
OPG is expected to compiete their ongoing EA studies and public consultation activities, and to
submit a preliminary draR uf the screening report to AECB stnff in late-lanuary 2000. That draft
will dacument the results of the environmen:al assessment. Following a technical review of the
preliminary draR by staf£of the AECB and the federal and provinciel agencies involved in the
assessment, AECB stafiwill make the draR screening report nvailablc for public revicw and
comment. Wriften comments from the public will be requested for early-May 2000.
Comments received will be addrassed by AECB staff, anJ revisians made to the screening report
; ns �ppropriate. It is the inlention of AECB stafito submil thc scrcening report nnd a summary of
public comments received on it to the Board in early-June 2U00, far consideration nt a subsequent
Board Meeting where the initial consideration of the Pickering NGS•A licensing application is to
be given. Thus, the screening report could be considered by ihe Board as enrly as their meeting in
June 2000,
However, this cannot be conlirtned until tlie AECB licensing review schedule for the licence
application to be submitted by OPG for the Pickcring NG5•A return to scrvicc has been
ostablished. The date for Board consideration of th; scrcening rcport will bc communicated to the
community and all stakeholders as soon as it is set,
In any event, it is the intention of the Board to hold its meeting, when ttie screcning report will be
presented by AECB sta(t'nnd considered by the Board, in the Town of Pickering. Interested
panies may make a submission and an appearance beFore the Board to provide additional
comment on tha screening report, in accordance with Board policy and procedure.
The Board decision on the course of action t� take in respect of the project, pursuant to
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subsection 20( I) of the CEAA, cauld be mudc following thc Bosrd Meeting where thc Decision
Board Member pocument_(BIvID) for the Pickering NGS•A licensing application is presented.
My decisian on tha licancc application will occur subsequent to the rssessment decision.
Notificetion of the proponent and the public of the course of action would be provided
immediately after the assessnicnt decision.
5.0 Scope of ProJect
The scope of the Pickering NGS•A project includes those operations and activities that ere
directly related to the retum to service and continued operation at power ofthe Pickering NGS-A
facility over its expected operational life. This involves on•site physicai systems, buildings, land
and infrastructure of the Pickering NGS•A facility, including the nucleaz steam supply system; the
turbine generaror system; the electric power systems; the nuclear sefery systems;.end ancillary
systems.
Given that the Pickering NGS-A facility is an existing, licensed facility, the scope of the project
does not include activities that would typically be associated with the constNCtion of a nuclear
facility or with the operation of a nuclear facility being licensed for the 6rst time.
6,0 Scope of Assessment
6,1 Generul '
The definitians oF"environment" and "environmental efl'ect", for She purpose of this
environmental essessment, have the meaning in section 2 of the CEAA. The term "cumulative
environmental effect" means cumulative environmental elTects that are likely to result from the
� project in combination with other projects or activities that have been or will be camed out. M
"environmental assessment" means an assessment of the environmental elTects of the project that
is conducted in accordance with the provisions of the CEAA and with tlus scope of essessment
document. The results of thc environmental azsessment will be documented in a screening report,
in accordance with the provisions of the CEAA and with tlus scope of assessment document.
The enviranmental assessment of the proposed project will include a consideration of the
Collowing fuctors identificd in subscctions 16(I)(a) to (d) o£the CEAA:
• the environmental effects of the project, including the environmental ef%cts of
malfunctions or accidents that may occur in connection with the project and any
cumulative environmental eflects that are likely to result Crom the project in combinatian
with other projects or activities that have been or will be carried out;
• the signif cance of the effects referted to in the foregoing point;
• comments from the public that are roceived in accordance with the CEAA and its
• 5
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�egulatioris, duniig the scoping, wnduct and review of the environmental assessment; and 25
• measures that are technically and economically feasible and that would mitigate any
signi6cant adverse environmental etTects af the project
In accordance with subsection t6(1)(e) of the CEAA, the assessment will uiso include a
consideration of the following mauers insofar as they relate ta the projecr.
• a description of the project, including its purpose;
• a description of the ewsting environment wlilch may reasonably be expected to be
afl'ected by the project;
• the program for consultation with the community and other stnkeholders on the project,
and Cor addressing issues that are raised that are within the scope of this assessment;
, • the process for addressing the public and tecimical issues that were identified during ihe
1998 Pickering Environmental Review; '
• requirements for monitoring and follow-up programs in respect of the project, including
their implementation;
• eECeats on the capacity of renewuble resources that are likely to be aft'ected by thc
project; and
• an identi6cation of the decommissioning planning process for the facility.
6.2 Scope of Ihe Fuctoro
Uescription of tlie proJect
The purpose of the project will be identified.
The description of tha project will reCer to the items identified in the project scope (Section S,0 of
this document), supported with appropriate maps and diagrams. Emphasis will be pluced on
describing those azpects of the project, including accidents and malfunctions, waste management
practices and radioactive and non-radioactive emissians, that could reasonably be expected to
affect the environment. The descriptions will be supponed with su�icient information to enable an
analysis of the potential internctions of the project with the environment. M identi6cation of how
potential environmentnl and man•made hazards have influenced the daign and operation of the
project will also be provided.
Given that Pickering NGS-A is an existing, licensed facility, a descriptian can be provided of the
6
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curcent radiation protcction, occupational health and safety, environmental protection and
emergency preparednus progrnms of the faciHty. Changes to theee programs that are needed as a
result of th,e proposed rotum to service can be identified in the "Mitigation Measures" section of
tho screening report. !f the proposed project pmceeds, these programs will be subject to further
evaluation under the AECB licensing review process.
Relevant infortnetion an the history end current status of the Pickering NGS-A faciliry must also
be provided,
Descriplion ojthe ezis�ing environment
The information used to describe the existing envirorunent wiil be in suH'icient detail to support
the identi6cation, assessment and detertnination of the signi6cance of potentiaUy adverse
environmental effects that may be caused by the project. Emphasis will be placed on describing
those aspects of the environment that could reasonabiy be expected to be aft'ected by the project.
The description of the baseline environmental conditions will present sufficient data and
information to establish nortns, trends and extremes, to the extent that such infortnation is
available. OPG can make use of existing infortnaEien and studies relevant to the project.
An ecosystem approach can be used in the description of the biophysi:al environment. The
description will include those valued ecosystem components (VECs), processes and interactions
that are considered likely to be e(%cted by the project. Components of the biophysical
environment that will be described include: meteorology, climate and air quality; geology and
hydrogeology; soil and graundwater quality; surface I�ydrology and water quality; aquatic ecology
and quality; terrestrial ecology and quality; and the radiation environment,
� The description ofthe socio•economic environment will include infortnation on the functioning
and structure of the socio-economic environment of the people end communities in the study area;
existing and planned land uses; heritage, cultural or urchaeological sites; and recreational sites.
The description can be limited to those aspects that could reasonably be expected to be aflected
by the project,
Spatia! anJ femporal boundaries
For purposes of overall environmental assessment of the proposcd project, including cumulativc
effects, OPG will use appropriate spatial boundazies (or geographic study areas) to encompass the
areas of the environment that would be directly aft'ected, or reasonably expected to be afiecled, by
the project, The following lhree geographic study areas are suggested (see Figure 1):
I. Si�eS�udyArea: This area includes all facilities, buildings and inhastructure at the Pickering
NGS site, including the licensed exclusion zone for the site,
?. l.ncnl SruJy Area; This area includes all lands within lhe Town of Pickering, the Town of
7
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27
' Ajae; and the eastern part of Toronto closest ta the Pickering NGS �ita
3. RcgionaJ Sludy Area: This arca includea lands ond communities around the Pickering NGS
sito that may reasonably be considered rdevant to assessment of cumulative eRbcts of the project.
Tlie purpose of different geogruphic boundaries ar study areas such as ►hese is to provide a basis
for assessing biophysical, socio•economic and cumulative environmental effects that is auHiciently
fle�ible to suit the di8'erent components of the environment that would be directly affected, or
n:asanab�y expected to be at%cted, by the project. The rationale for the detertnination of the
study areas must be provided.
The timeframe for the assessment will be the duration of operation of the Pickering NGS-A
facility following the retum to service. This timeGame should be clearly defined and the raGonale
for it provided by OPG. Within this timeframe, the focus will be on identifying those direct and
cumulalive enviranmental effects which have a reuonable probability of occurrence. In addition,
OPG will be expected to discuss the status of decommissioning planning for the facility; any
future appiication for decommissioning approval would be subject to a separate environmental
assessment.
Assessment ajpotendal environmenfal eJjecu
' The environmental assessment must present a systematic evaluation of how the project is likely to
cause changes in the study environment, ar�d how those changes to the environment could affect
the identiLed VECs, health and socio•economic canditions, physical and cultural heritage, current
use of lands end resources for traditional purposes by abariginal persons, or items oFhistorical,
archaeological, paleontological or azchitectural significance. In doing so, the assessment will:
• identify the changes expected to occur as a result of the project;
� assess these effects and their significance;
� descrihc and justify mitigation mcasuros and the plans for their implementation; and
• identify any residual et£ects of the project, ie., those e[%cts following mitigation, and
assess tha significance of those effects.
The methodology used to conduct the assessment must be described and justified. There will be a
clear explanation of how scientific, engineering and other know•ledge hns been used to reach the
conclusions of the study. My essumptions made must be clearly identified and justified. All
significant gaps of knowledge and understanding will be identified where they are relevant to the
principal conclusions of the assessment; any steps being taken by OPG to address these gaps will
also be identified.
OPG can make use of e:cisting information and studies related ta the project. This includes, for
e:cample, infortnation on the pazt operations of the Picke�ng NGS-A facility, and work conducted
as part of the 1998 Environmental Review of the Pickering NGS site.
28
The assessment wiU be based on the project as describcd, The scrcening rcport must outiine the
� process used to identify likely project-environment inieractions; and tho potentiai adverse ef�ecta
on the environment that may arise. OPG must also identify and describe the likelihaod oi possible
malfunctions and accidents that may bc assaciated with the faciliry, and the potential adverae
environmental effects of such events. The descriptiun will include the safery systems and
miugation measures that nave been estabiished by OPG i�i relation to these events, end thc
contingency measures in place to manage the eECects of any such events.
The description and evaluation of probabiliry and eflects of radiological malfunctions and
accidents can refer to the Pickering NGS•A 5afety Report and supporting analyses. More
specificaliy, the following will be ineluded:
• listing of frequency and/or public dose criteria specified in applicable AECB guides and
provincial Emergency Plan documentation, az well as OPG public safety goals;
• description and results of existing detertninistic analyses of a credible range of postulated
malfunctions and accidents, including discussion of the extent to which the anal��ses are
conservative, to demonstrate compliance with regulatory safety criteria;
• description and results of existing probabilistic risk analyses, to quantify the overall
magnitude of risk to the public;
• description of planned improvements to safety systems and procedures, including an
evaluation of their eH'ectiveness; and
�� summary of residual risk to the public, taking into accaunt all existing and planned OPG
m;tigation mea�ures plus contingency measuros under the provincial Emergency Plan,
compared to the applicable criteria.
Regazding potential conventional (non-radiolo¢ical) malfunctions and accidents, OPG will
describe the existing and planned mitigution mensures intended to minimize the likelihood and
ef%cts oftheir occurtenca. In addition, OPG will describe contingency plans and measures
intended to manage the effects of potential malfunctions and accidents if they occur.
The screeriing report must elso include a description of the arocess, factors and criteria used to
characterize likely environmental etfects, and to detertnine their significance Collowing epplicatian
of mitigation measures, Factors used in the characterization of the etTects, and their significance,
may include magnitude, duration, frequency, timing, probability of occuRence, ecological and
social conteM, geagraphic excent, and the degree to which the effects may be reversible. Criteria
for essessing the signiBcance oCthe environmental eflects may also include relevant federal and
provincial standards, guidelines and objectives for enviroiunental quality criteria (air, water, biota)
and for protection of human health (discharge limiu, radiation dose limits).
OPG must identify, characterize and assess the likely adverse cumulative environmental ef%c[s of
the project with the other nctivities or projects in tl�e study area, as identified in Attachment 2.
The approach and methodology used in the assessment of cumulative ef%cts must also be
described.
, 9
29
The putentiul eflects of the enyironment on tho project must be evaluated, and information
presented on how theso eflccts have been addreesed in.the design or operation plans of the
faciliry. Such efTects mey include those associated with natural or man•made hazerds, such ss
flooding, swere weather and seismic events.
OPG must aiso provida a wnsideration of the likely adve�se environmental effects on the capaciry
of renewable resources that are likely to be affected by the project.
Mirigadon mcasaru
OPG must describe the general and specific measures that it praposes to implement to mitigate
the likely adveroe environmental effecta ofthe project. This should include a description of
contingency measures that have been designed to addresaWcely.accidents and malfunctions that
could result in spilis ar unplenned releases of contaminants to the environment.
Some mitigation measures can be introduced in the "Project Description" seetion of the screening
report (eg., as standard operating procedures), with other more specific measures identified in the
azsessment of potential eftects. For clarity, ali mitigation measures which have been proposed for
the project can be summarized in one section of ;he report.
Mitigation measures can be described in terms of their purpose, timing and duration, feasibility,
anticipated eftectiveness, previously demonstrated pedortnance and potential risk of failure.
Communiry and stake%older cansul�adan - OPG program
OPG must estublish a public consultation progrum that kecps thc community and stakeholders
fully infortned of the proposed project, and provides reuonable opportunities Cor the issues,
concerns and comments of the public to be identified and considered in the enviranmental
assessment. This program shauld make use of the existing public communication and
participation activities of OPG, but should not necessarily be limited to those. The consultation
program should extend throughout tl�e entire enviranmental assessment process.
OPG must describe the objectives and methods of their public cansultation program in the
azsessment report. OPG must also identify and evaluate the results of their public consultation
program, end indicate how public issues and concems ware addressed. Plans for cuntinued
community and public consultation activities aRer the assessment process should be identified.
Public particfpadon - AECII program
The environmental assessment process established by the AECB, as the Responsible Authority for
the ussessment under the CEA� includes oppartunities for the public to participate in the
process. These include: establishment of a public registry for the project, pursuant to the
requirements of the CEAA; provision of information on the status of the assessment of the project
10
30 � '
via the AECB lntemet web•site; public review and comment on th(s draR scope of assessmenl
document; public reviaw and comment on thc drnft screcning roport which will document the
results of the environmenta) assessment; and comment to Ihr. Iioard on the BMD which provides
: the flnal scrcening report to ihe Board for their consideration.
These opportunities for public involvement ara identified funher in the "Assessment Process and
Schedule" section of this document.
The AECB stafihas appeazed before the Pickering Town Council to provide information on the
e�vironmental assasment process far the project, in recognition of the specific interests of the
Town of Pickering as the host community for the Pickering NGS. AECB staft'remain available to
appeaz before the Council upon request to discuss developments in lhe assessment process.
AECB siafi; in particular, aza willing to appear before Council to describe the content of the final
scope of assessment dacument and the screening report, at the times when those documents are
available for distribution ta the public.
Public anJ Iedmlcal issue manogemenf
OPG must discuss with the community and public stakeholders the menagement of the public and
technical issues that were identified for the overall Pickering NGS site during the 1998
Enviranmental Review. A listing of those issues, and a classification of each issue as to whether it
is within tha scope of this assessment or not, must bc provided. Those issues that are within the
scope of the assessment must be identi6ed, assessed and documented as part of the screening
assessment.
The remaining issues must be cleazly identified and addressed in an Annex to the screening repon.
Far any such issues that are not within the assessment scope, and which are not yet resolved at the
: time of the screening report submission, this Annex must provide clwr indication of how and over
what timeframe those issues are expected to be managed and resolved. In eddition, for any issues
that are within the nssessmont scope, and wluch are not yet rosolved at the time of the screening
report submission, OPG must provide rationale as to why it believes deferred resolution is
reasonable and acceptable. My action intended to address technical issues aRer submission of the
repon, eg., under a Monitoring and Follow-up Program, would be subject to the essessment and
compliance processes of the AECB.
Monitoring and foffoiwup progranu
, OPG must describe their proposal for monitoring and follow•up programs for the project,
including their objectives, cantent, implementation and reporting of results.
, Programs should be described for the monitoring of: environmental efiects; socio-economic
ell'ects; and cumulative effects. OPG must identify any proposed clianges or modifications to the
existing monitoring programs for the Pickering NGS site. M overvie�v of the content of the
�
31
programs (pprametero, locations, frequency, methods) will be provided; the details of the
programs would be subject to Porther regulatory rovicw during the liccnsing procesa that could
follow the environmentel assessment process, OPG will describe how the ro�ults af tl.e
monitoring programs arc to 6o used in thc managoment and operation of thc faciliry.
The proposal for a follow•up program will consider the need to provide a process for veriFying the
accuracy of the environmental assessment of the project and to deternone the effectiveness of
mitigation measures.
All monitoring end follow-up programs are to be designed to be integrated into the existing
compliance monitoring and licensing programs of the AECB, as they rolate to the Pickering NGS-
A faciliry.
7.0 DraH Screening Report �
Documentation of the results of the environmental assessment will be submitted to the AECB by
OPG in the fortn of a draft screening report. Following technical and public reviews oFthat draft,
ihe AECB staff will finalize the screening report and submit it to the Board for their codsideration
end decisian.
The screening report must provide the AECB with the information necessary to decide whether or
not the potentiel adverse environmental et�ects azsessed for the proposed project are signi6cant.
7he report must demonstrate how both the potential environmental e�'ects and related stakeholder
concems have been addressed, so that the decision makers can detemune whether the residual
effects are acceptable.
; The report should be written in the clearest language possible. Where the complexity of the issues
addressed requires the use of technical language, a glossary de6ning technical words and
acronyms should be inciuded. Maps, diagrams and charts should be provided wherever useful to
clarify the text.
The screening report should be kept concise and well organized. It should only contain
information directly relevant to environmental assessment decisions. Background and
supplementary intarmation, as far as possible, should be provided in annexes to the report.
The following titles may be used as a framcwork for the development of the report:
• Executive Summary
• Introduction
• Application af the CEAA
`Z
�.
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(�rx7 �u be pravided by AECD slafn
� � 5cope of the Project
'�� Scopc of the Environmental Assessmrnt
� � Purpose and Description of the Project
• Uescription of tha Existing Environment
• Environmental Efl'ects and Mitigation Measwa
� � Significance of Residual Effects
• Communiry and Stakeholder Consultation Program
• Monitoring and Follow-up Programs
t C�nclusions and Recommendations
(fert to be provided 6y AECD stajn .
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8.0 CunlucU far the A»u�ment
Anyone wishing ro review or comment on the direcdon given (o OPG in the draR "Scope of
' Assessmcnt" for the Pickcring NGS•A rewrn to service, or to obtain infarmation on the
assessment �t later steps in the CEAA process, can do so through the following wntactr. .
Mr. Robert Leblanc, Directar
Power Reactor Operations Division
Atomic Energy Control Boazd
280 Slater Strcet
P.O. Box 1046
Ottawn, Ontario K1P SS9
�Fax: (613) 995-5086 . ... - ---.�._ , ; ' .
u �
Mr. Barnard Richazd, Program Specialist
Radiation and Environmental Protection Division
Atomic Energy Control Board
280 Slater Street
P.O. Box 1046 '
Ottawa, Ontario KIP SS9
Phone:(6l3)996-9497
Fax:(613) 995•5086
Intemet: ricl�ard.u(a�atomcon.gaca
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Attaclunent I: Procus and Schedule for tUe Pickering NCS-A Envlronmenlal Aau�ament
Draft (26 Ocrober, 1999)
A. Determinulion of AppUcabillty of tlic CEAA:
• OPG submission of project description to AECB; Complu�e (/G JuU99J
•AECBstafi'detemunationofapplicabilityofCEAA: Complele(30Ju!/99J
• Notification of OPG of the AECB detemtination: Complele (!0 Aug/99J
• Notification of the CEA Agency of the AECB deterntination: Compie►e (/0 Aug/99J
• tJotification of Ontario provincial auti�orities of federal EA detertnina6on: Comple�e (!1
Aug,'99; 10Aug�99J
B. Initiation anJ Conduct ofAssessment:
• Establish PubGc Registry under CEAA for the project: Complele (!0 Aug/99)
• Notify other potential Federal Authorities (FA) of the AECB deternunation and solicit their
detemtination of their roles: No�ification complele (3 Aug/99); Respaues canplele
• AECB staff notification of OPG of FA detemtinations: Camplele
• AECB preparation of draft Scope of Assessment: 19 OcU99
• AECB distributiou of draft Scope of Assessment for FA and public review: 2 Nov/99
• Complrtion of FA review and public comment period: 1 Dec199
• AECB prepazation and distribulion of Scope of Assessment: 9 Dec/99
C. Documentulion and Submission of Screening Report
' • OPG subnuts preliminary draR of rcport to AEC9 stati': 2a Jaid00
• AECB staff and FA complete technical review of preliminary draft report: ! Mar/00
• AECB staffsubmit technical rcview concems to OPG: BNIar/00
• OPG revise and resubmit drait report to AECB staf£: 2,f hlar/00
• AECB staf�distribute draR screening report Cor public comment: 19 Mari00
• Completion oCpublic comment period: 3 hlayi00
• AECB staff coordinate revision of draR repon as appropriate: early,lu»e/00
• A6CB staff submit screening report, and summary repon on public conunents, to the Board as a
Board Member pocument (BivID), for their consideration, !3 Jw✓00 or larer"
D. AECB Decision and Follow-up Actians:
• AECB staffpresent the screening report, and public comments received on it, to the Board at
the Boazd Meeting where the Initial Consideration BMD for the Pickering NGS-A licensing
application is presented. lnterested parties may make a submission and an appearance before the
Board to provide comment on the environmental assessment BIvID. Board considers both the
screening report and the public comments received on it: 19 JuW00 or larer•
IS
35
� Bon�d decisian on the course of action ta take in respect of the praject, pursuant to ss. 20(I ) oF
the CEAA, following a Board Meeting subsequent to the Meeting noted a6ovc: Tu bc
d�rermmed' .
• AECB staff notifies OPG af the Boazd decision on course of action
� AECB provides public notice of the course of ection.
"Note: I� Js �l�e pracdce ojAECU smff �o su6nii� the rcreening report jar a praJect fo t6e
Qoard jor fhcir consideraflan at fhe Board Afeedng where fhe inUial canslderation ojll�e
Ucensing applicedon jor fhe proposal is givea
/t is the infendon ojAECU staJ)''to submit fGe screening repoR for tlie Pickering NCS-A
�.- projecl7o the Board in early-lune 1000, jor consiJaation af a substquenf Board hleeting
where fhe infda/ canslderadon ojthe Pickering NGS-A licensing oppllcadon Is �o be given.
Thus, the screening repoh could be cansldered as carly as t/ieir meeting in June 1000, but this
cannot be confrrmed until tl�alitenstng revinv sc/reJule jor Ihe licencc opp/icadon fo be
submitfeJ by OPGfo� the Pickertng NGS-A return fo service ltm been established The date
jor /�oard consideradon ojthe screening repuri ivill be communkated fo llle comntunity and
stakehofders as roon as it & set
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38 ATTACHMENT# 2 TOREPORTN,�'�`I—q`I
24-11-99 '
Dr. N. Byles t :
4993 Canso Drive , `
Claremont
ON L1Y lA8
Tel/Fax: 905-649-2544
ema11: eyles�scar.utoronto.ca
ATTENTION: Gordon Reidt / Tom Melymuk '
The CorporaHon of the Town of PickerIng
Fax:905-420-7648
,- ± Peer Review Team commenls
On
Draft Scope of Assessment Document for an
Bnvironmental Asaessment (EA) pureuant lo the Canadian Enviranmental
Assessment Act (CEAA)
Plckering Nuclear Generating Station'A': Return to Servlce
I
'Submitted to die Town of PIckering November 25th,1999
PRT - doc 002
t
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EXECUTIVE SUMMARY .
Tlie Draft Smpe of Assessment document lssued November 2nd by the Atomic
• Iinergy Control Doard contalns;
1) a ratlonale for a screening level environmentai assessment of the restart of
Plckering NGS-A faclllty. '
2) identifles the scope oE such an assessment by outllning a serles of atepa to
measure the envlronmental impact oF the restart, and;
3) provldes a Hmetable for such activitles and the completton of a Draft
ScreenIng Report by late January 2000.
The Peer Review Team f1nd, in general, that the Draft Scope document is poorly-
written, inrnmplete and ambiguous. It requlres considerable clariflcadon relating to
many issues. It does not provide a welt-structured or coherent framework for
measurIng envIronmental lmpact of the restart oE the Plckering NGS-A facility.
- The justlficaUon made by AECD for a screening level assessment, rather
than a much more thorough comprehensive assessment, is weak and dces not
adequately recogn(se that the proJect is large and envlronmentally sensItive.
- The draft scope does not clearly state wtilch issues are rvithin the scope of the
assessment neither does lt adequately define what lssues are outside the scope. Too
much has been left to the dlscretSon of OPG and It is not clear how the outstanding
160 + lssues that arose from the Pickering Environmental Review of 1998 are to be
dealt with. Health ls a key issue of publlc mncern and is inadequately addressed ln
the Draft Scope. The time(rame over wlilch environmental lmpacts are to be
. assessed is too short and is restricted to the operatlonal Iifespan of the fac(llty.
- The Hmetable for completion of the assessment and production of the Draft
Screening Report is (nadequate. There are signl(icant gaps in knowledge of
environmentnl conditions around Pickering NGS and the scientYfic credibility of the
assessment is compromised because fundamentat basel(ne data wiU not be available
unti! well after the �ssessment �nd Screening Report have been completed.
Key recornnterrdations made by the Peer Revtew Team are: that the AtomIc Energy
Control Doard be requested to change the status of the assessment from screening
level to comprehensive and extend the timeframe of the assessment to allow
incorporatlon of critical baseline environmental informatlon, The AGCD should
idenNfy and define preclsely those (ssues that are wltldn the scope of the assessment
and should apecify that long-term env3ronmental impacts be assessed over the
'contaminatIng llfespan' of the facility.
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INfRODUCTION
The Draft Scope of Assessment document for the Envlronnental Assessment
(issued by AEC� on November 2nd 1999),lslntended as a gulde and a framework
for a wide range of activlties by Ontario Power Generation (OPG), its consultants and
�" the publlc communIty over the next 9 months, The Draft Scope of Assessment sets
' out, in the broadest possible terms, the assessment whIch Ontario Power GeneraHon
must accomplish before the restart of Plckering NGS-A ts feaslble. The clariry of the
document is therefore, of considerable importance. It must be comprehensIve,
easily understood by the pub8c who are stakeholders in the process, yet lt must
provIde provide appropriate technical dtrection to OPG and its wnsultants.
Obfective of Peer Review Teaen: The crlterion which the Peer Revlew Team has
used in assessing the Draft Scope document is slmple; does it provlde a well-laid
out, credlble, coherent framework for a tho:ough scIenUfic assessment of the
env[ronmental Impact arising from the return to service of Pickering NGS-A? In
' brIef, we conclude that it does riof do so, The major weaknesses ln the document
. are oudined below and thlrteen recommendations are made regardtng the form and
content of the Final Scope.
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SPFCIFIC COMMHNTS AND CO�iCRRNS
j$,�J,[� Poor organisatfon of Draft Scope docunteut
Comment and concem; A major flaw of the Draft Scope document is that lt is not
well laid out or structured. It Is clumsilywritten and wordy. Indivldual paragraphs
ldentify multiple and different requirements tor compleUon of the environmental
assessment (EA) 6ut aone are nuriibered or lisled sysfeniaticalfy. Consequently,
there is no easy way to identify, cross-reference and address these requtrements and
subsequenfly track them through the EA process and OPG's EA Saeening Report.
The Draft Scope document does not provide a clear framework for the EA and
creates the potential for conflicting interprelations of exactly what is required and
what ls not. The Draft Scope document dces nut clearly define which issues are to
be addressed In the HA, and just as important, wtilch issues are out of bounds. Too
much has been left to the discretion of OPG in the interpretation of the DraEt Scope
and this creates an lnvltation for disagreement between aU Parties. �
Iiecommendation lo AECB:
1. AECB ehould ensure that the Final Scope is clearly wdtlen, systematicaily
atructured and that each speci(ic requirement is care[ully idenlifled and numbered.
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Sectian � 0 AT,,olicallon of the Canadian 8nvlronmenlal Aasessment Act (p, 2)
y�$,]IQ: AECQ' a rattonale jor acreentng level assessment
Comment and concern: The rationale (or a screcning level assessment as opposed to
a comprehertsive assessment relates to the statement made on page 4 of the Draft
Smpe document that "the project involves the return to servtce of an existtng,
Itcensed faciliry; it dces not lnvolve issues that would typically be assoclated with
the construcUon or operation of a new facllIty betng licensed for the �rst tlme". This
statement ls technically correct under the CEAA. '
The Draft Scope document goes on to say that "AECB considers that the
envIronmental assessment tssues and concerns that are relevant to the return of
servtce of the PIckering NGS-A facIlity can be addressed effectively and appropriately
in the screening level assessment." The Peer Revlew Team do not agrce with this
statement.
We emphastse that the "environmental assessment issues and concerns" that are
relevant to the return to servlce of the I'ickering NGS-A facility are tn fact,
extremely broad, complex, and encompass ussessniertt oj Ihe iutyact o� tlie o�eratiai
of tlie entire Pickering NGS sife ou the surrowiding biophysical euvironment (see
Section 6.0 Scope of Assessment, below). The Uraft Scope document alsa explic3dy
recognlses the issue of decommissioning.
Further, the cauae of the shutdown of Pickering NGS-A was a non-roulii�e situation
involv[ng an ageing reactor and the need for signi(icant sa[ety upgrades, The return
to servlce lnvolves considerable modifications to the existing facillty. These go well
beyond a almple'restarP.
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The ABCB Draft Document als� states (p. 3, para 3) as pazt of lts jusdficatton for a
screening level auessment, that "the project la not descdbed ln the Comprehenslve
Study List Reguladons under the CBAA". Agaln, thls !s tectuilcally wrrect and the
proJect (narrowly deflned as a'restazt of an exisdng facltlty') (s not listed. However,
the CBAA also states that a mmprehens[ve screening must be applied to '7arge and
environmentailysensiNve projects". We would draw attentlon once agaln, to the
broader circumstances and mncerns that prompted the closure of Pickering NGSA,
the locaUon of the fadlity in a densely populated area and the lilgh level of public
concern regardIng the safe operatlon of Pickering NGS. We also note that despite
the narrow definlUon of the p�oject, the environmental assessrrrent is Intended to
address a very wide range of addltionai environmental issues with regard to the
operat(on and cumulative envlronmental Impact of the enitrc PNGS operatlon
(induding decomm(ssioning). Consequently, lt can argued that the scope of the
project Is "large and environmentally-sensitIve". Additional clrcumstances
surroundtng the assesssment relate to the demonstrable lack of key basellne
environmental data (see Recommendations HG and 13). We note, further, that the
Responslble AuthorIty (AECB) has the optlon of reterring the project to n mediator
� or revtew panel "if warranfed Gy pu6lic concerns" (CGAA, Section 20). Given the
wlder circumstances surrounding the return tu service of Pickerfng NGS-A, the Peer
Review Team believe that the AGCD shauid exerclsc lts mandated optlon and
request that OPG undertake a comprcircuslvic envlronmental assessment.
Recommendalion to AR g
2. That AECB recognise the level of public concern regarding the safe aperaqon of
Plckedng NGS, the large number and wide range of oulstanding envlronmental
fasuea identified to date, the presence of aubstantlal gaps in baseline environmenWl
data needed to measure environmental Impact of lhe fac(lity, and raiae the level af
environmental assessment from a screening level to comprehensive.
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S.0 Sc�e oE Proiect (P• 5)
ISS.L�: Scope of Profect
Camment and concern: Under paragraph 1, the scope of the Plckering NGS-A
proJect is narrowly defIned as "ttwse operatlons that are dlrectly related to the return
of service and conUnued operation of power.... over its expected operational life".
Thls "lnvolves on-site physical systems, buIldIngs, land and tnfrastructure of the
Pickering NGS-A faclltty, including the nuclear steam supply systems; the turbine
generator system; electrlc power systems; the nuclear safery systems; and andllary
systems.... ".
The cnntentt�us statement here is "over its expected operadonal lIfe" whIch
ls cepeated on page 8 af the Draft Scope (para 3) where tt is stated that the
"timeframe for the assessment w111 be the duration of operation of the Pickering
NGSA facillty following the return to servlce". These statements constrict the
Umeframe of the project much too narrowly for the reason that the assessrnent ls
deslgned to identtfy long-term cumulative envIronmental impacts, Such impacts
may only be evldent after the operation of PNGS-A has ceased. This mncern is
addressed in detall by the Peer Rev(ew Team on pages 16 and 17.
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5.0 Stppe of Assesa_menc (p.5)
6.1 General
j�.�: Lack of approprlate dejiniNoas tn Draft Docume�d
Comment and concern: SectIons 6.0 and 6.1 state that the "deflnitlons of
envSronment and envlronmental effect for the purpose of thIs environmental
assessment, have the meanIng In secdon 2 of the CEP.A" but they are not provided
anywhere ln the Draft Scope document. The fa3luie to include these definitions in
the Draft Scope ls not helpful. The Draft Scope dacument should not rely on
another document that Is not widely availabie to the public for clarification of
defln(tions that are fundume�ital to the assessment,
Consultatlon of the CEAA web site offers the foilowing definitlons of
"environment' and "environmental effect" (taken from the Refe:ence Gu3de -
Determining Whether A ProJect is Llkely to Cause Signiflcant Adverse
Environmental Ef(ects; see <http://www.ceaa.gc.ca/publications/guides_e.htmx)
The Act def3nes the environntertt as: the components of the Garth, and includes
a) land, water and alr, including atl layers of the atmosphere,
b) all organlc and inorganic mattcr and Iiving organisms, and
c) the interacting natural systems that include components referred to In
paragraphs (a) and N).
Environnienfal eJ/ect means, in respect of a proJect,
a) any change that the project may cause in the environment, including any
effect of such change on health and socto-economic condittons, on phys(cal or
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�s
. cultural heritage, on the current use of lands and resources for tradiUonal
purposes by abor)gtnal persons, or on any structure, eite or thing that is of
hlstorlcal, archeological, paleontologlcal or architectural signlAcance, and
b) any change to the project that may be caused by the environment, whether
any such change occurs withln or outs[de Canada.
$�pmmendation to AECB
3. The AL�CB should ensure that ihe Flnal Scope document includes all relevant
definitiona of key terms. A glossary of terms and a lisUng of acronyms should be
attached.
jSSlIE: Scope of Assessme�►t
Comment and concems; Section 6.1 (paragraph 3) states that the "envlronmental
' assessment... wlll include a consideration of,.. the environmental effects of the
project, indud(ng the envlronmental effects of matfuncdons or accIdents" l.e
ongoIng actIviNes, Sectlon 6.2 (paragraph 1) repeats thls and broadens the scope still
further by stattng that "emphasis will be placed on describing those aspects of the
project, including acc[dents and malfunctions, waste management practices and
rad3oactive and non-radioacUve emissions that could reasonably be expected to
affect the evironment"
All these activit!es are clearly related to the routine operation of Pickering NGS-A,
not just fts restart, and indicate that the Scope of the Assessment is broad (see
� below).
The Peer Review Team notes that the environmental assessment must consider
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cumulative environmentai effects of the project "In combination with other
projects or acNvitles that have been or wlll be carrled out" (paragraph 4, p. 5). Such
proJects and acHv(Hes are llsted in Attachment 2 on page 17 and include Plekering
NGS�B operaUons, and waste management operatlons. It is clear that the Intent of
the EA•ls to assess the entire Pickering NGS operatlon although ttils is not expliclUy
stated in the Draft Scope document.
According ro the Draft Scope document, the Environmental Assessment wl(t also
consider outstanding Issues that arose from the Pickering Environmental RevIew of
1998. Signiflcant data gaps were IdentIfied In that review and OPG and Public
groups came up with a list of outstanding issues (referred to as the'160+ lssues'). On
p. il, under the section'Public and technical Issue management', explicit reference is
made to'publIc and technIcal issues that were identified for the overall PickerIng
NGS site during the 1998 Environmental Review'; this is a direct reference to the
'160 + issues'.
It ls very clear from the above, that despite lhe narrowness of the piojecf, the scope
` of the envlronmental nssessrrienf includes the environmental impact of the enHre
nuclear operaHon at PtckerIng NGS. This is not stated explIcitly in the Draft Scope
document.
Recommendatian to AECB
4. AECB should ensure that the F1na1 Scope document conWins an explicit
statement recognlsing that the scope of tlie environmental assessment includes
envlronmental impacts arlsing from the entfre Pickering Nuclear Generating
Station aperation.
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6.2 Scope of the factors (p. 6)
],SSII$; DeacrJptiox of the extsttng envTro�inteat (p.7)
Comment and concern: Plckering NGS has been ln operation for almost 30 years.
The Plckering Environmental Review of 1998 identtfied a number of, potential on-
site and off-site impacts arlsing from constructlon of the plant and Its subsequent
operation (see above). Such impacts are, as yet, poorly understood and the 1998
Environmental Review Identified more than 160 envIronmental issues raised by
the publlc mmmunlry and OPG that await further study. AECB requlre such issues
are to be addressed in the current EA, thus recognisIng that the envlronment of
Pickering NGS Is not prlstine but has already been impacted, However, the
existence of impacts is not recognIsed explicltly in the Draft Scope under the section
'Description of the existing envlronment'.
Reeommendation to AECB
` 5. AECB should ensure that any issue(s) apperlaining to identiEication of currently
existing'baseline environmental conditions' in the Ffnal Scope must explic(tly
recognise the nature of exisling impacts.
$¢1�dL751is: The status of ongoirtg studtcs; wlrcn will key results be availaLlel
Commenta and concerns: The Pickering Envlronmental Revlew of 1998 tdenNfied
serious data gaps regarding the impact of Pickering NGS on the surrounding
biophysical environment, Several stud(es were commissioned as a result of the
Review but will not be flnIshed until well after the EA process is completed (e.g,
Hydrogeological Study of the Pickering Nl: � SSte). Other studies that are planned
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include an Ecologlcal Rlsk Assessment (to ldentlfy lmpacts on aquaUc ecosystems), a
Fadllty Rlsk Assessment (to deal with chronic spIlls and leaks), and a Catastrophic
Rlsk Assessment (to deal wlth a sudden loss af coolant). The Peer Review Team la
unclear whether data froin other ongotng studles appertaining to seismic rlsk (e,g.,
aeromagnetIc surveys of the western end of Lake Ontario) and background radIation
(atrborne gamma surveys) will also be available for (nclusion in the present
environmental assessment. It Is our understandIng that many data wlll only be
avatlable well after completlon of the Draft Screening Report in mld-January 2000.
The Peer Review Team is also keenly aware that certaln studies that are central to
any env(ronmental assessment have not yet even Geen counuissimied (e.g., Cancer
SurveIllance study being proposed by Health Canada and AECB). ExIsting health
studies carrIed out to date are explicItly recognlsed as having "design limitations"
(Ms. M. Pietrusiak reportlng to Durham Nuclear Health Committee; September
24th,1999) whlch limlts the abiilty of OPG to identify health lmpacts wlthin the
assessment.
77ie Peer Reoietu Teant questtons !be vnlidily nnd credibility of any envirainietdnl
assesssinent, and condusions rclafiiig fo 'environnicuful iinpnct' uj Pickeri��g NGS,
i�such nu assessment does not Liclude all relrvnnt sclenfific informntiai, The Peer
Revlew Teams questions whethcr sufficient information exlsts wlth regard to
cutrent baselIne envlronmental conditions to allow a thotough env3ronmental
assessment.
Recommendatfon to AECB
6. AECD ahould ensure that OPG provide the Town of Pickering wlth a
cotnprelrensive list of all ongotng orNlan�icd projects appertaining lo measurement
of'environmental impact' with a tlmetable for compledon of resuits.
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- g�lated Iss�e: IdentificaUon and definition of valued ecosyalem components
The semnd paragraph under'Description of extsting envlronment' on page 7 of the
Draft Smpe refers to an "ecosystem approach" to the descrlption of the biophysical
envfronment that includes identifIcaHon of "valued ecosystem components
(V6Cs)". The Draft Scope fails to provlde adequate definitton of "ecosystem" or
"VEC" and does not address the issue of whether human beings are constdered a
valued ernsystem componenL RecommendatIon H 3 of the Peer Review Team
requests AECB to include definitions of all key lenns In the Final Scope document.
Under "description of soclo-economic environment" (paragraph 3) reference ts
made to "functioning and structure of the socIaeconomIc envlronment of the
people" but it Is not stated whether th3s Includes public health. It is not at all clear
where and How human health and psycho-socIal impacts are to be addressed In the
EA since these are not explicitly listed ln the EA Draft Smpe document. The issue of
'health' ls missing endrely from'Description of GxisNng Gnv(ronment' (p. 7) but Is
llsted subsequentty under "Assessment of Potential envIronmental cffects" on p. 8
` of the Draft Scope document. Thls creates a serious ambiguity in the Draft Scope
document because lf there is no clear requirement by AECD for OPG to assess
extsting health mndiNons among the pubitc community, it is very unclear how any
potential envlronmental effects of the project can be reallsttcally assessed. The issue
of publfc health is addressed below on pages 17-18 by the Peer Revlew Team with an
approprlate recommendaUon (# 11).
13
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5.1
jSS11$: Spatia! and ttuipo►al boundarJes of erivfroamc�ttal aaseasme�it
Comment and Concern: There are maJor problems wlth det(nitions of the spatlal
and temporal Ilmits of the BA being suggested by the AECB Draft Scope document
(pp. 7-8). AECB identUy three'suggested' geographlc study areas desfgned to
"encompas;, the areas of the envlronment that wouid be directly affected, or
reasonably expected to be affected, by the project" (p. 7, paragraph 6).
We fully agree wIth the comment made on p. 8(paragraph 2) that any deflnIHon of
sh�dy area must be "sufflclently flexible to su3t the different components of the
envIronment that would be dIrectly affecled, or reasonably expected to be affected, by
the project." In other words, the size of study areas will change according to the
particular environmental issue under rnnsideratton; for example, the study area
approprlate for conslderatton of environmental effects arlsing from airborne
releases of tritlum will be much larger than say those arising from tritium leaks to
groundwater below the plant.
` Three'suggested'spatlal boundarles are Indlcated by ACC6;
1. Site Study Area,
2. Local Study Area, and
3. Regional Study Area.
Of the three, only the Site Study Area (1) has any well-de(ined meaning as it extends
to the lmmedlate site boundary of the Pickering NGS site.
In wntrast, the ratlonale used to dc�ne study areas 2 and 3 are not provided by
AECB and the proposed areas are a mixture of polltical boundaries (e.g the Towns of
Pickering and Ajax) and poorly-defined geographic areas (e.g,, "the eastern part of
Toronto closest to the Pickering NGS site"), Neither study area has any reai
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signif(cance for an environmental assessment of Plckedng NG5 and both fall to
make expUcit reference to assodated waterbodies such as Lake Ontario. The Peer
Revlew T=am is puzzled why reference to "cumulative efEects of the proJect" is only
mentloned In regard to the Regional Study Area.
Recommendations to AECB
7. AECB should ensure tltat the Final Scope contains study areas that are
appropriate to specific individual dlsciplines and not leave OPG and Its consultants
lo determine (Ilmit) the extent of their study.
8. AECB ahould ensure that cumulative envtronmental effects wlll be consldered
for all study areas.
IIelated issue: Identtficatioa of stakeliolde�s and pbystcnl works and activities
Comment and cancern: Deflning the spatial extent of the GA is a critical part of the
Final Scope document because the size of the geographic area determines the
identtficatton of relevnnt sfakeholders and ony physical works and nctivities H�at
must Ge f�tcluded fn fhe EA process. OPG are required "to establish a public
consultatfon program that keeps staiceliolders and the public fully lnformed of the
proposed project and provIdes reasonable opportunities [or the Issues, rnncerns, and
coiYUnents of the public to be ldentlfied and considered ln the envlronmental
asseasment" (p. 10, paragraph 6). Nowhere In the Draft Scope document is lhe term
'stakeholder' defIned; nelther can the full range of stakeholders be identlfled until
the study areas have been establIshed. The Peer Revlew Team's concern ls that
15
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appropriate study arcas suill only Ge iderdlfted Inte !ri flic assess�uen! and that
potenUal key st�keholders wlll bc excluded. The same concerns apply to
determination of the range of Physical Works and Activfties ro be lncluded wlthln
the acope of the Assessment that are iisted on p, 17 of the Draft Scope document.
Recommendation !o A . B
9. AECB ahould ensure that the term'stakeholde�' Is adequately deftned in the Ftnal
Scape and that all relevant stakeholdera are lncluded wtthfn the environmental
assessment process.
ISSUE: Tbnefrawe for assessing ei�virauuentn! impact.
Comment and concern: The suggested timeframe for idenHfying adverse
envlronmental effects in the Draft Scope !s too short. P,8 (para 3) of the Draft Scope
states that "the timeframe for the assessment will be the duration of operation of the
PlckerIng NGS-A facility following the return to servlce", Yet, the same paragraph
goes on to say that the "focus wlil be on identifying those direct and cumulatIve
environmental effects", Cumulative environmental effects are likely to be
s3gnlficant we(1 beyaid the operational lifespan of Pickering NGS. The Peer Review
Team questions whether there can be a realistic consideration of cumulative effects
when the tlmeframe ls limlted to the relatively short operalionnl lije of Pickering
NGS-A. By definition, cumulative effects are long ferru and may well be evldent
only after the operaUonal life of Pickering NGS-A Is compieted. The Draft Scope also
states that the EA must Include the long term envlronmental effects of
decommissiontrtg of both PIckering NGS-A and B, activit(es whIch are
unambtguously post-operation. It is appropriate to note the relevant provIncial
16
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environmental guidellnes on the stting of landfllls, where the concept of
'contaminattng lifespan' [s applied, and wlilch extends for hundreds of years after
the landflll has closed its operations (OntarIo Ministry of Energy a1d Environment).
in�i i, �� i :�x�l��
10. AECB ahould ensure that current estimates of tlie operattonal and
contaminating lifespans of t•NGS are identified in the Final Scope and employ
'contaminating lifespan' as the timeframe for assessing cumulative and adverse
environmental effects.
1SSUE: Asseasinerd of poteatial envtronrneiital efjects (p. 8)
Comment and concern; ThIs section states that the GA must systematically evaluate
how the project is lIkely to cause changes in the env(ronment and how such
changes could affect "the idenNfied VECs, health, and socio-economic condltlons..,.,"
Potential impacts on public health are the most significant environmental effects of
the project and are the subject of lntense public concern. However, there is no
direcHon given in the Draft Scope document as to how public health issues should
be addressed. The Pccr Reviczu Team lias notcd olhcr inndequncies mith regard to
tMe DmJt Scope docume�it's frendnerd of Ihe issue of public henith (see n6ove, p, 13).
PublIc comments by OPG (Pickering News Adverliser, Nov. 24th) indicate that "in
evaluating the effect of the Plckering Nuclear Station on human health, the
env[ronmental assessment an the facility will be limited to shuwIng its emIsslons
do not exceed those permitted under law". This statement demonstrates that OPG's
17
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lnterpretation of the contents of the Draft Scope document is rather dlfferent from
that of the Peer Revlew Team. The Druft Scope document identifles (p. 8) the
; requlrement of OPG to consider "how changes to the emironment" (arising from
the proJect) " could affect .... health".... The Peer Review Team interpret thts to
. mean that apectEic health studies pertalnIng to the exlsting health envlronment and
the potenGal lmpacts of the proJect are to be assessed by OPG.
N� �nn i�ETf�i i : • ;
11. The AECB should ensure that the Final Scope explicitly recogniaes and
adequately addresses the Issue of public health impacts wltliin the enviranmental
asseasment.
iSSUE; PuGfic mid tecHiitcal tssuc rnaungemcut (p.11)
` Thls aspect of the Draft Scope is particularly confusing and requIres clarifIcatlon. As
part of the EA, OPG are requested to ldentify how the 160+ public and tectu►ical
issues arls(ng from the Pickering Environmental Review of 1998 wlll be addressed.
In July 1999, OPG committed to address ench issue in the EA process, a comm(tment
re-emphastsed 1n November 1999 as part of the Draft Report 'Origin, Understanding
and DIsposiNon of 160+ Issues' (OPG, 3rd November, p,2).
Despite the apparent confirmatton of lntent by OPG to address all lssues, the Draft
Scope allows OPG to ciassIfy each issue "as to whether It ls wIthin the scope of this
assessment or not" (line 4, ist para). Issues that OPG consider to be outside the scope
of the EA can be deferred and 1lsted ln an Annex to the EA Report. Moreover, of the
lssues that are considered by OPG to be ►uilhirt the scope of the EA, deferred
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resolut[onls stUl possible (2nd para, line 5). This contradlction between what OPG
has atated'publically and what ls to be actually followed In practIce is hardly wlthin
the spirit of the commltment to address nll issues w[thln the present L'A, The
existing pollcy of AECB allows OPG too much flexibllity ln thelr lnterpretation of
how to deal with the 160 + Issues.
Recammendation to AECB
12. AECB should ensure that the Flnal Scope atates expltcilly that OPG is committed
to address all outatanding technical issuea arising from the Plckedng
Envlronmental Review of 1998 in the environmental assessment.
j�,Q(�: Process and achedule for the Picker(ng NGS•A Envitanmental Assessment
(p,15)
The most unacceptable aspect of the Draft Smpe dcnument ie the timetable allowed
by AECD for the EA Process. In Uie opinion of the Peer Review Team, it is�nr too
sbort to allotu the Hmrauglt nnd euhnncrd reuiew fhat Itas 6cen promised Gy OPC.
The AECB will receive publIc comments on the Draft Scope of Assessment In early
December 1999 and intend to complete their rev3sion of the Draft Scope ln a single
week. Gtveit the problents witb !hc documen! idenfi�ed Hcrcin, it cnii bc questloi�ed
whetlier an ade�uately-worded Fi�;ul Scove can �e yroduced in suclt a sbort tinie.
Once the Final Scope document has been released by AGCB, OPG and its consultants
have s!x tueeks (whIch lncludes the Christmas break) to conslder the contents of the
FInal Scope and the public comments they have recelved and to then produce a
}
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Draft Screening Report to AECB by late January 1999. This w1U aummarise the
resulte of the enHre Snvironmental �4aeaement. T6e Peer Revtew Ttarn constder
t6Js an tnadequate ttntejmitte jor a lhorou�h and acfenttficallycredtble atudy.
Many key studies, designed to fill substantIal data gaps Identifled in the
Envlronmental Revtew of 1998, are stilt beIng planned or conducted and results wlll
not be ready until after the EA Report has been completed. This creales tlie
percepiton that•AECB is rushing the cidire process to satisfy tlie shorbterm business
needs of OPG and undem�ines publtc confidenre nnd t6e scienti�c credibility of the
assessment.
It Is dlsturbing to the Peer Revlew Team to learn jrant the rncdia that OPG and its
consultants feel that the majorlty of work has already been done on the EA and that
it is not necessary lo wait for the AECB tu finalize 3ts scope (Pickering News
Advertiser, October 24th,1999. p. �. This statement appears to suggest that OPG and
its consultants do not feel obliged to be bound or gulded by the contents of thr. Final
Scope document. This demeans the role of the public and stakeholders as real
' particfpants ln the process, by sugges8ng that comments received during the pubilc
consuladon process are not regarded as signIficant
It Is the optnlon of the Peer Review Team that the present timeframe does not
permIt OI'G and lts consultants to complete a thorough Envlronmental Assessment.
Recommendation to AECB ,
13. The AECB should ensure that a realislic tlmeframe be establlshed for the
environmental assessment to allow completion of a.redibie public consultatlon
proceas, and assessment of sctentifIc data from studles already underway or pianned.
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List of Recommendatlons to AECB
1. AECB should ensure that the Final Scope is cleady wrltten, systematically
structured and that each speciflc requfrement ls carefully identlfled and numbered,
2. That AECB recognise the level of public concern, the wide srnpe of outstandIng
environmental tssues and sign3f[cant data gaps and raise the assessment from a
screening level to comprehensive.
3. AECB should ensure that the Final Scope document includes all relevant
deflnItions. A glossary of terms and a lisUng of acronyms should be attached.
4. AECB shouid ensure that the Pinal Scope document contaIns an explIcit
statement recognlsing that the scope of the environmental assessment include
envlronmental impacts adsing from the entire Pickering Nuclear Generating
Station operation.
5. AECB should ensure that any Issue(s) appertainIng to ldentlftcatlon of currenUy
ex[sUng'basellne envlronmental conditions' in the Final Scope expllciGy recognIse
the nature of existing Impacts.
6. AECB should ensure that OPG provide the Town of Plckcring wlth a
compre6ensive ][sting of all ongoing or plm�ned projects that appertain to
measurement of 'envtronmental impact' along wlth the timetable for completion of
results and Interpretations.
7. AECB should ensure that the Flnal f'icope contains study areas that are
approprlate to speclflc [ndlvldual discipltnes and not leave OPG and its consultants
to determine (IImit) the extent of thcIr study.
8. AECB should ensure that consideraUon of cumulative environmental effects Is
mnsidered for al! study areas.
9. AECB should ensure that the term'stakeholder' Ss adequately deflned 3n the Final
Scope and that ali relevant stakeholders are included wIthin the environmenta!
assessment process.
10. AECB should ensure that current estimates of the operational and
contaminating lifespans of PNGS are ldentiEied in the Final Scope and employ
'contaminatIng IIfespan' as the timeframe for assess[ng cumulative and adverse
envlronmental effects.
11. AECS should ensure that the Final Scope explicl8y recognises and addresses the
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lssue of publlc health lmpacts.
12. AHCD should ensure that the Flnal Scope states expUdtly that OPG Is comniltted
to address all outstanding technIcal lssues ar(eing from the Plckering
Hnvironmental Revlew of 1998 ln the envlronmental assesament.
13. AECB should ensure that a reaBstIc tlmeframe be establ[shed for the
envlronmentat assessment to allow completIon of a aedible public consultadon
process, and assessment of scIenHflc data from studles already underway or planned.
Peer Rev(ew Team members:
Dr. N. Eyles (Leader)
Dr. P. Chow•Fraser '
Dr. S. Elliott
Dr. C,H. Eyles
Dr. J. Harvey • :
Dr. K.W.F. Howard
` Dr. W. Morrfs
,-_
25th November 1999
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sO ATTACHMENTq 3 TOREPOpTN C!ro ��-9/�'
' ' 23-11-99 '
. Dr. N. Eyles
'.�4993,Canso Drivc
Cleremunt, Ontedo
LIY IA8
TcUFax:905•649-2544
email: eylesQscar,utoronto,ca
_ ATTENTlON: Cordon ReiJt/Tom Mclymuk
The Corporauon of Ihc Town of Pickering
Fax: 905-4204648
, tf
Peer Review Team commenls ons
- Plckcring A: Itelurn tu Scrvice
Environmental Asaca�ment
►.'I�n for
� Publlc apd SlakehulJcr
Consullaltan and Communlcalion
Navi�ion 2 - Octobcr 22,1999
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Submiued to thc Town of Pickering
Novembcr 25,1999
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Ceueral commeaf�:
Overnll, this document provides u useful plun fur a public and stakeholder wnsultation program,
However, thc document focuses rnther tou hcuvily on delniling wlrut wiil be Jonc in lhe
progrnm, nt the expense of expinining huw it will be nccomplished. This is well illustmted by the
slalemenl mdde on p. 18 thut Ihc esinblishment of a tmckinb dnwbasc "helps to Jemonstrele and
documcnt how thc EA hns addresscd public wnccros nnd issucs..: '. This is n bold stalement
which telis whul will bc done, but says nolhing ubout l:ow il will be done, and provides no
information about how wc cun judge the success of the proccss. In our expericnce, the how is
just as, if not more, importwrt than the wlrul.
Specllic commenb:
1. Stakehoidero: A rntiunulc detniling how slakeholdcrs nre dcfined nnd identificd would be
useful. Some obvious kcy stakeholders are missing liam Ilie Polenlial StakcholJers list (Table
2). These are:
- Provincinl Health Ministry
- day cnre centres (should bc identificd under local scrvice providers)
Other potentinl smkcholdcrs will only be upparcnt whcn thc gcogrnphicnl limits of spccific study
arcas wilhin the EA hnve becn Jetermincd
1. Abbrev(aUan�/acronyms: Thc dceument MUST includc n list of ubbrevintions and
acronyms lo hclp thc public.
3. Interviews: Thcre is no cicar sensc of purpose ur use for tlie planneJ stakcholder interviews.
It is not cicur whclhcr the plan is for a team of imcrviewcrs to intervicw a singlc inJividual Gom
each of the slnkeholdcr groups, ur morc Ihan une individual from cnch group. Given Ihe
sensitiviry of thc lopic and naturc uf thc qucslions, intcrvicwccs muy not bc wmfortublc
dccluring a position, cspccially if thcy fcd that thcy mny bc hclJ to that position in thc futurc.
7herc !a u generu! neeJjor nmre ir j�rmurlon �egurdiiig d�e nu�ure, pi�r�wse und use � f Uirervlew
da�a.
4. Med(a: The iJen of inedia treining for slakcholders is n very goal ane. Thc mcJia (especially
thc prinl media) nrc thc numbcr onc sourcc of information for lhc gcncml public around
environmentnl nssessmenl issucs. I lowcvcr, tho mcJin should not nccessarily bc ucn ns a
srakeholder in the proccss. Swdics show Ihnl some community rcsidents distrust thc media us
much ns they distrust the proponent
�/�e rutlonule jur indudrng dre nmdiu us• u s�ukehufder shuuld be ii�cJuded in Ihc re�wrl.
5. Follow up: Several limes in lhe repod, Ihe clnim is made Uint "Queslions and neeJs for
infortnntian will bc followcd up promptly. ". This rcully neccls to bc monitorcd and thc
mechanism for delivery of follow up material docwnented.
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b. CommuoiCy Opeo IIouae Nl: Community Open Housc N I sounds morc likc a public meeting
tha�i nn `opcn housc', Thcre is a largc litcrawrc on which rypc of wnsulting proccss is most
efCective at dit�erent stuges in the process, with which type of pubiic unJ nround whnt kind of
issue. Therc necds to bc clurification on this poinG
7. Web aite: The web site is an excellent ideu. it should be set up with a mechanism whereby
lhe public can comment on/respond directly to Uwt sitc. It is not cicar Gom Ihe document
whether this is so. At the time of writing this revicw, lolc in thc public wnsullation process, it is
h r or not the web site is actuall in o ration. Conse uenlly, ihe value of the
not cettain whei e 9
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b itc ma be limited.
wc s y
& Newsletten: NewsleQers are a useful and widcly accessed source of information for
communiry residcnts. Howcvcr, sludics hnvc shown that thc public oQen distrust nny
substontive messages wntained in newsletters when they nre sponsored by the proponcnt.
Despite this, U�ey nre n very useful of commwiicnting information about the swtus of the
process, timing nnd locution of public meetings and how individunls can providc input to the
process.
9. Complaiole dalabaycT Is there an existing complaints dalabase that cnn be analyscd, perhaps
geogrnphicnlly, and uscd lo providc basclinc-typc informntion7 This would bc vcry uscful.
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ATTACHMENT#�TOREPOaTq� �y'9%
�x.tt-� 63
Dc N. Eyles
4993, Caiuo Drive
Claremont, Ontnrio
LIY IA8
TeUEax;905�649•2544
email: eylesQscar.uloronlo.ca
ATI'ENT►ON: Cordon Reidt /Tom Melymuk
Thc Corpomtion of thc Town of Pickering
Fnx: 905�420-7648
Peer Revlew Team commenfs an:
PICKERING A - NE'1'URN'1'U SERVICE '
Origiq, UaJcrolanJing aad
: DUpoaU(on of
1GO+ Luue�
Revteton 3 - Nuvcrobcr 3,1999
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Cenenl rnmmeal: Thc documant cntiAcJ "Origin, Undcrswnding nnd Disposition uf I60+
Issues" (DruR - Ravision 3), preparcd by thc Environmental Assessmcnt Tewn (EA Team),
is essentinlly a rcwording of the 160+ issucs rniscd by tiic Communiry Working Qroup (CWO)
und OPa during Ihe 1998 Gnvironmcninl Rcvicw. It docs not proviJc Ihc informnlion it claims
to prcscnt, nor dces it mect its stated purpose "to faciliwtc public input and thus cnsurc thnt cach
issue is aJequately addresseJ in the EA."(p. � j.
Specific commenta:
L Intraluction
The intraluction states that the document provides:
"- a description of the process bcing useJ to morc compicicly undcrstnnd cach issue for
EA purposes
- the mcthodology bcing follow�ed by the GA Tcam to address cnch issuc; nnd
- n detuiled listing of the issues nnd indicntion of where they wiil be adJresscd in the EA
documenis."(p. t)
However, lhe document dces nol providc nny infortnntion regurding Ihe melhalolo�y followed
by the EA Team lo uddress each issuc (second bulict nbovc), only tlie methalolobry uscd to
reword cnch issuc. Thcrc is no mcnlion of how any of thc issucs iJcntificd will uclually bc dcnit
with in thc EA.
The document clnims to be useful ta thc vnrious swkcholders involvcd in thc Pickering NGS•A
Return to Service EA by allowing them °to identify euch issuc anJ fullow its disposition
throughout thc cnviromncntul asscssment prcecss." (p. I). Howcvcr, bccausc thcrc is no
discussion of how issucs �vill bc Jcalt with, thc documcnt complcicly fnils in ils aim to bc uscful
to slnkeholders intcresleJ in following thc'dispasition' of issucs through the GA process. It will
only be possible for slnkcholdcrs lo track the 'Jisposition' of issucs once thc Dra(t BA RepoA is
published.
2. Ilow thc'166f� ia+uc�' came about
Three volumcs ofthe Environmcntnl Rcview rcport are listcd us sources of information
ref;nrding the 160+ issues iJcntificd by Uie CWa and OPG. Howevcr, two of thcsc volumcs
(Volumes I and 2) were discrcdited by Ihe Independent Reviewer as presenting unsubstantiated
wnclusions nnd a discluimcr wus udJed to thc fronlispiccc of each lo slntc lhnt they werc nol
endorsed by Ihe CWG. The [ndepcndent Rcviewer's commen4s on Volumcs 1 nnd 2 should bc
addcd to this lisl of sources of infortnntion avnilublc to Ihc public. It is mislcading to simply
dircct the public to a series of dceuments Uiul were essentinlly'rejecled' by independent scrutiny
in 1998.
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3. Proce� for EA Tcam undentanding of lhc le�uee
Thc documenWtiun of this proccss nppcurs to bc fuirly comprchcnsive.
4. M1fethalology far addre�ing the IU6� la�un
A slatement is mnde in lhc documcnt that "it is now possibic lo delcrtninc whcre nnJ how each
issue will bc addrcsscd in the GA process."(p.4). Thc document lhen charts the origin and
underslnnding of the IGO+ issues (Tnblc, p. I-40), but mukes no mention of Irow euch issue will
be addressed in the EA. The Iengthy table prescnteJ un pagcs I through 40 (note: page
numbering is incortect - lhere nre two sets of pages I throuyli 4) dcscribcs cnch of thc issues
listed in the 1998 Environmenwl Review Report, provides rcwording of thc issuc into u numbcr
of slatemenWqueslions, identifics tha seclion of Ihe EA Rcport in which tiie issue will be
addressed and idenlifics the 'origin' of Ihe issue • buf lhere !s no Jescripfiu�i ofltow eudr issue
wlll be udJressed in !he L•'A process. This is u vcry scrious omission ns, to fulfill the stnted
purpose of the document "to fnciliwle public input and Ums ensurc that cach issue is adequntcly
addresseJ in the EA." (p. I), an cxplannlion of how thc issuc is to be dcull with is ncccssary.
A further Onw in the Jocument is thal therc is no cxplonution as lo the melhaiolobry followcd by
the GA Team to dctertnine whcther or not an issue isjudged to fall within thc scope of thc GA.
A(low clwrl providcd lo illustrntc the mcthoclolobry uscd (pA), shows Ihnt issucs urc first
considercd to either full within the Scope uf the GA pra;ess ar not. Thuse issucs not juJged W
foll within thc scopc nro included in nn Anncx Itcpod; thosc issucs that aro within thc scopc of
the EA ure idcntificd as eilhcr 6cing fully resalvcd within thc timc fmmc of thc EA, or wilhin
lhe time frnme of moniloring nnJ fullow-up programs. Huwcver, the ducumenl providcs no
direction us to how issues ure'juJged' lo be within the scope uf lhe assessment.
For exun7ple: Issue 121 'Effects on Iocnl biotn und watcr fowl duc to thermal adJition to Lnkc
Ontnrio' - Why is the monitoring of biophysical clTccts under this issue considereJ in tlw Mnex
Repon? 7'he EA Tcnm providcs no cxpinnation ns tu why Ihe monitoring aspccts are not lo be
included in thc EA Report.
Tho statement thnt "Issues considercd lo be wiAiin thc sco�x: of lhe nssessmcnl are idcnlificd as
cithcr being resolvcd within thc timcfrnmc of Ihc GA studics, or in thc moniloring anJ follow•up
pro�ram which will bc recommcndcd" (p.4) is wrong. Thcrc is no mention of thc timefrnme for
resolulion ofspccific issues muJc in this docwncnt. AlUiough the flow chnrt shuws that issues
wilhin lhe scope of the assessmcnl urc lo be classificJ as eithcr bcing fully resolved within thc
timefmme ofEA studies, or fully n:solvcJ within tlic timel'rume of monilorin�follow•up
progrums, this clussificntion oFissues is nol prescnleJ here.
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CORPOMTB PqOMQ710N8 AND
'.1-12'�N ' . � ECONOMIC OHVELOPMBN
RECEIVED:
NI.E NO.:
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ATTBNT[ON: G. Reidt/ T. Melymuk
The Corpora8on of the Town of Pickering '
From: N. Eyles
Peer Review Team
Re: Pickering NGS-A Restart Environmentai Assessment
Additional commenfs by Peer Review Tenm
Subsequent to our submission of our review of the Draft Scope document to the
Town on 25th November, the Peer Revtew Team have the following addlttonal
comments and observations. These comments have been prompted by our
examinadon of correspondence between AECB and OPG and by publtc statements
made by representatives of OPG at a communIty workshop held (n Plckering on the
27th November.
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; A) COMPLfiTENESS OF DRAFf SCOPH DOCUMENT
Page 17 of the Drafl Scope document (Attachment 2: Physical Works and Activities
to be considered in cumutattve effects analysis) I(sts the related act{vities that mlght
be impacted by Plcker(ng NGS-A restart. OPG are requIred to assess any negaUve
tmpacts on those acHvltles, Included in that list is the radiological effects of
Darlington NGS,
In an AECB letter to RJ. Strickert dated June 9, 1999 (AECB File k 26-1-4--0-0), the
last paragraph states " we stlll awalt a response to the Einal item in Reference 4,
� namely the potential negatire lmpacls oj qie restart a� fhe implementation of Ihe
I1P initiatives at your other nuclear genernfing sfntions" (our Itallcs).
The Peer Revtew Team is concerned that assessment of negative impacts (arIsing
from the re•slurt of Pickering NGS-A) on the Druce NGS is not specifically listed
under Attachment 2 of the Draft Scope document. Clearly, the document ts
Inmmplete.
The Peer Review Team notes, 3n addition, the AECB Draft Scope document dces not
reflect recent effort by the Canadian Envlronmental Asses�ment Agency to Tuiden
the scope of Identlfication of 'related acNvities'. According to the new Operational
Poltcy Statement issued by the Canadlan En;�ironmental Assessment Agency in
March 1999, IdenHficallon of'related activities' as set out in the Agency's 1994
reference guide "may not always be adequate" especially in areas experienctng "raptd
development' and where "particular environmental sensitiv(ties or r(sks are
involved". TMese qualifications are higl�ly pertinenf fo tHe rnyidly ur6anizing
Du�ham Reg7on and indicnfe fo 16e Peer Revinu Team !6a! nn tnadrqunte ►evel of
e%�ort has been used by AECB in idenfifyrng 'relnted nctivities' tlmt st�rround
Pfckering NCS.
2
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'llic Tawn of Plckedng ehould request from AECB a detailed listing of any
addiHonal requiremenb made of UPG (by AECB) that aze not speciflcaliy identtEfed
in lhe AECB Draft Scope document. The latter ia clearly incomplete and doea not
meet recent CEAA guidelines requidng a auEEidently broad idenNficatiun of'related
acNvities' appropdate to a rapidlygrowing urban area.
B) RBASONS FOR PICKERING NGS-A SHUTDOWN: SIMPLE 'MAINTENANCE'
OR FUNDAMENTAL SAFETY CONCERNS7
The same AECB letter of June 9th,1999, has considerable bearing on the underlying
reasons for the shutdown of Pickertng NGS-A in 1997. At that time, the shutdown
was attrlbuted sfmply to'inadequate resources' available to OPG run all reactors.
But, the results of the Integrated Performance Assessment presented to the then
Utillty's Board of Directors found 'min3mally acceptable standards' that were well
below induslry norms and referred to a'sort of nuclear cult' among senior
management. There were, in addition, problems In meeting the deadline for
instaliing an additional reactor fast shutdown system which would if allowed to
conttnue by Itself would have resulted In a shutdown of PNGS-A, The Peer Review
Team concludes that there were fundamental safety concerns leading up to the
shutdown of A; the reasons for the latter do not appear to be simply 'housekeeping'
as malntatned by OPG.
Further, the Town of Pickering should note that the AECe letter of June 9th 1999
(p.2, para 2) contains the striking statement that "T6ere nre nreas where Pickering
NGS-A does not meet current safety sfnndards and where the orlginal requirements
are not satIsfactory. AECB staff therefore believes that upgrades are required:' Tltis
fs wriffen nearly two years after !he shutdown whlch was, and still ts being
portrayed by OPG as stmply a'housekeeping fssue'. The letter gces on to tdentify the
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���ture of the technlcal upgrades requlred to make PNGS•A safe.
� Note too, the more recent letter (23-9-99) from AECB to the Udlity's Board (only
copted to Mayor Arthurs, one month later on October 22; file N1-8-21-0) that states in
• regard to the attempts by OPG to remedy the operaHonal fallings IdenHfied by the
Integrated Performancc Assessment (that had ldentIfied minlma! sub•par operating
standards) that OPG's efforts do "not appear to have targeted any corrective acHons
to the weaknesses Identified in the common cause analysis", The letter goes on to '
draw• attention to s(milar concerns voiced (n an earller AECB letter to OPG (June 21,
1999) and the need for AECB to "conduct an evaluation" to assess the quality of
OPG's correcttve actions.
Thc Peee Revtew Team urges the Town of Plckedng to request fmm AECB and OPG
a full detailed atcount of lhe specific safety concerns that resulled in the shutdown
of PNGS-A in 1997. The Town should further request documeutatlon as to what
safety concerns have been addressed and to identify those cancerns that sfill await
action.
D) BACKGROUND TO AECB'S AEQUEST FOR AN ENVIRONMENTAL
ASSESSMENT FOR THE RESTART OF PICKERING tJGS-A
The Peer Review Team has reviewed correspondence between OPG and AECB as to
the need for an environmenta! review. We make the following observations.
i) In a letter dated May 14th 1999 to RJ. Strlckert, AECD argued that the restart of
PNGA-A requlres an amendment to the existing License which under article 27(1) of
the AEC Regulattons, automatically triggers CEAA. The reasoning cited by AECB is
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that'the prolonged shutdowd of PNGS-A does not quaiify as 'repair and
maintenance.' The.Town shou�d note the reasons given by AECB under secHon B
above where fundamental safety concerns arE identifled.
il) In OPG's response to AECB, Mr. G,C Andognini in a letter to Mr. R LeBlanc,
(then Director; AECB) dated June 18th 1999, stated that ln OPG's opinion, appltcation
of the CEAA was not necessary. He stated that the shutdown and restart of PNGS-A
is intended to improve safety and performance and thus does not quaUfy as a
'project' under CEAA.
In support of his argument, Andognini cited 'an opinion from an outstde law firm'
sought by OPG. In this opInion, Roger Cotton, acting for Tory Tory DesLauriers &
BInnIngton, made the case that all the activlties related to the physical works
assoclated wtth the PNGS-A restart "fall withln maintenance and tepait" (letter
dated May 25th,1999 to OPG). Therefore, in his considered opinion, the resumptIon
of servlce of PNGS-A is not subject to CEAA. He argued that the existing License
already provides for operaHon and such activity includes repairs and preVentive
maintenance and reasonable improvements. Cotton cited other legal decisions
where maintenance was upheld to include the obligation to correct a structural
defect. In other words, a full•scale review is not warranted.
Cotton pointed out that if AECB's reasoning is foilowed "any uininfcnnnce and
rryatrs fhat require a si�ufdown nnd resumplion of service could lead fo nn
nssessment of the enfire operntion". This he argues is a negative message to
commercial and industrial activity in Canada.
Andognlni's letter continues to state that "An Environmental Review Report and
an Env[ronmental Action ['lan were produced to fulEill Ilcence condiNon A,H.S. The
Environmental ActIon Plan Is now being implemented". Further, 'since we have
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recently completed a thorough revlew of environmental issues lmportant to
PIckedng; we do not understand what beneflt might result from another
envlronmental assessment". Further, "We tncluded the communtty in that review
and and are ImplemenHng the recommendations".
ili) Finally, in response ro Andogninl, M. Taylor (Act(ng Dtrector General, AEC6) In
a letter dated July 8th,1999 emphasises the'prolonged shutdown perlod' for
Plckering NGS-A and reaffirmed that the Screening Level Assessment is requtred.
Concems of Peer Review Team.
The Peer Review Team has two conrerns.
The fIrst ls that the Chtef Nuclear Officer for OPG has not, apparently, been
informed of the Umitations of Plckering Environmental Review of 1998 and the
community concerns wlth the credibillty of that review which ultimately lead to
dlsclalmers being added to the consultant's work. The Pickering Environmental
Review of 1998 was incompiete in many important aspects and significant data gaps
were idenHEled by the pub8c communtty and Independent Reviewer. Andognlni !s
Incorrect in describing the 1998 Review as 'thorough'.
Second, the deciston of the AECB not to accept OPG's argument that the restart of
Pickering NGS-A can be regarded as'maintenance' reinforces the observation of
fundamental safety concerns identified by the Peer Review Team under section B
above.
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C) AfiCB'S TIMCsTABLB FOR ENVIRONMBNTAL ASSESSMENT
The letter of June 9th from AECB to Strickeit at OPG revlews OPG's planned scope
of engineeririg work necessary to restart PNGS-A. Thls is part of the Licensing
Requirement for Return of Secvice of Pickering-A NGS which relates to detailed
engineering/technical issues (note: this is outslde the scope of the envIronmental
assessment under CEAA). AECB agree with the nature of the engtneedng upgrades
1denHf3ed by OPG. OPG are to make a format application to AECB and this process
has the same Hmeframe as for the Environmental Assessment, But, the second
' page of the letter states categorically, that AECB may not be able to give the required
. approvals ln Hme because "the proJected period may not be adequate" and "it is
possible that further work w111 be ldentlfied as requtred, whicb wil! delay the return
to service".
The Peer Rev(ew Team urges the Town of Plckering to seek clariEication from AECB
why it is that AECB conslders that a'thorough' Environmental Assessment can be
completed, be revIewed by AECB and a decision made tvhen technlcal issues being
addressed in a separate licensing submission to AECB ln all likelihood cannot be
processed tn the same Nmeframei The Peer Review Team has identifled major
ambigultIes in che AECB Draft Scope document issued for the Envlronmentat
Assessn•..�nt which wlll mean delay in issuin6 a revised Final Scope. That scope
should, in addltion, tdentify additlonal :vork requirements needed to be completed
by OPG. .
The limeframe jor an EA is rmt dicfnted Gy CEAA 6ut is set by fHe Responsible
, AutHority in f6ls case fhe AECB. The Tomn of Pirkering should note thnt Hie AECe
Ietter of June 9th, 1999 strongly suggests, Gy irnplicatiai, that Hie timejrnroe that
AECB itself Mas set for the Environn�ental Assessment o� tlie return to service of
Ptckering NGS-A cannot be rnet. Tlils underscores t6e need ldenHfied 6y the Peer
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Revfew Team in its document of Nouern6er 25t6, to extend tbe time�rame aj tlie
assessmen! fo fncoryorate results of ongotng studles,
COMMENTS ARISING FROM PURLIC WORKSHOP NOVEMB6R 2TfH, 1999
A public consultatlon workshop was held ln Pickering at St. Martins Angllcan
church on November 27th by OPG. The workshop was sparsely attended by the
public (4 attendees) Includtng two cepresentatives (rom the Community Advisory
Council (CAC) the principal public consultative body estabiished by OPG for the
Envlronmental Assessment. The workshop was convened by Golder.
Issues for dlscussion centred on whether pubitc health issues and emergency
preparedness would be consldered under the current EA. The Peer Revtew Team is
concerned that responses were given by OPG that flafly conlrndicfed earlier
responses gtven to the RevIew Team by OPG and Its cansultants in a workshop held
at McMaster University on November 18th and in the medla. At the public
workshop held tn Pickering, OPG stated that publlc health issues were to be
included; thls is opposite to OPG's statement to the media (Pickering News
Advertiser, November 24th) that OPG would simply ensure that Pickering NGS
would meet existing regulatory emission standards and thus assume that there was
no risk to the public.
At McMaster, OPG answered that emergency preparedness was not included in the
EA ('we leave that to the police'); in contrast, at the pub8c workshop, OPG stated that
emergency preparedness was to be included. The Peer Review Team is willing to
allow for miscommunicallons but comments at the public workshop created the
clear impression that OPG and thetr consultant alter their responses according to the
audience. In the mind of the Peer Review Team thls also underscores the
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ambiguiHes inherent In the Draft Scope document already noted by the Peer Revlew
Team in their submission to the Town dated November 25th, 1999.
Other discussions at the Pickering workshop focussed an the identiftcatian of
valued ecosystem rnmponents. These are (mportant as OPG's rationale is 'protect
these and the rest of the ecosystem wlll be protected'. The Peer Revlew Team has
maJor reservallons as to the scientific methodology used ro identify specific VEC's
and will be looking to a full JusHflcaHon from the consultant. In addltion, Golder
provided a chart of risk assessment (oE VEC's) based puzely on qualltatatve,
�subjective inferences; the Peer RevIew Team is concerned that no quantitattve risk
assessment based on real world data is being conducted.
These and other concerns wlll be addressed in detail tn the Peer Review Team's
revlew of OPG's Preliminary Draft Environmental Assessment Report.
Peer Review Team members '
Dr. N. Eyles (Leader)
Dr. P. Chow-Fraser
. Dr. S. Ell[ott
Da C.H. Eyles
Dr. J. Harvey
Dr. K.W.F. Howard --
Dr. W. MorrIs
1-12-99
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