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REPORT TO 145
COMMITTEE OF THE WHOLE
Report Number: CAO 06-03
Date: July 14, 2003
From:
Thomas J. Quinn
Chief Administrative Officer
Subject:
Pickering Nuclear Waste Management Facility Expansion
City of Pickering's Comments on Draft EA Study Report
File: 0-5260-002
Recommendations
1. That Report CAO 06-03, regarding the OPG Draft Environmental Assessment
Study for the expansion of the Pickering Nuclear Waste Management Facility be
received.
2. That the draft submission prepared by IER Planning, Research and
Management Services, and Scimus Inc., attached as Attachment No.2 to this
Report, be accepted as the City's comments on the OPG Draft Environmental
Assessment Study for the expansion of the Pickering Nuclear Waste
Management Facility.
3. That a copy of this Report, including the draft submission of IER/Scimus be
forwarded to the Canadian Nuclear Safety Commission, Ontario Power
Generation, the Canadian Association of Nuclear Host Communities, and the
Nuclear Waste Management Organization for information.
Executive Summary:
Ontario Power Generation (OPG) is planning to expand the Waste Management Facility
at the Pickering Nuclear Generating Station, to allow nuclear waste fuel to continue
being stored at PNGS up to the end of the planned 40-year service life of the station.
The expansion requires an environmental assessment (EA) under the Canadian
Environmental Assessment Act. To assist in monitoring the EA process and reviewing
EA documents, the City commissioned a consulting team lead by IER Planning,
Research and Management Services, and Scimus Inc. (hereafter collectively referred to
as illER") to provide peer review services.
This Report provides IER's draft peer review comments on the Draft EA Study Report
prepared by OPG. Staff concurs with the findings and conclusions of IER, and
recommends that Council accept and forward the IER submission with this report to the
Canadian Nuclear Safety Commission (CNSC) as the City of Pickering's comments on
the Draft EA Study Report.
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Report CAO 06-03
Date: July 14, 2003
Subject: Pickering Nuclear Waste Management Facility Expansion
- City of Pickering's Comments on Draft EA Study Reports
Page 2
Financial Implications:
None. OPG has agreed to cover the City's peer review costs.
Background:
Ontario Power Generation proposes to expand the existing Waste Management Facility
at the Pickering Nuclear Generating Station (PNGS) to accommodate the storage of
used fuel from PNGS-A and PNGS-B to the end of the planned 40-year service life of
the station. The expansion requires an environmental assessment (EA) to be
completed in compliance with the Canadian Environmental Assessment Act.
Under the Act, CNSC is the "responsible authority" for preparing the EA. CNSC has
determined that a screening level assessment is required, and has delegated the.
preparation of a draft EA study report to OPG. The Draft EA Study Report, and
comments received on the Report, will be used by CNSC as the basis for preparing the
final EA Screening Report for submission to the Commission.
The purpose of the EA is to determine whether the expansion of the Waste
Management Facility at PNGS is likely to cause significant adverse environmental
effects, taking into account appropriate mitigation measures. After analyzing various
options, OPG proposes that two new storage buildings be located at the southeast
corner of the property, in an area that is currently used for outdoor storage of
equipment and materials. If approved to proceed, OPG would be in a position to initiate
site preparation and construction of the first new storage building in 2005-2007, and the
second building in the 2014-2016 time period.
At present there are two existing Waste Management Facility storage buildings at
PNGS. They began operation in 1996 and 2001, and together are designed to hold up
to approximately 650 dry storage containers (DSCs). By the end of 2007, it is
anticipated that the existing buildings will have approximately one-year of dry storage
container space remaining.
The two new buildings that are proposed in the expansion would each be able to hold
500 additional DSCs. Each DSC is designed to hold up to 384 waste fuel bundles.
Accordingly, should the expansion be allowed to proceed, PNGS in total would be
capable of holding approximately 1650 dry storage containers and over 633,000
bundles of nuclear waste fuel for up to the next 50 years, unless the Government of
Canada decides on an acceptable alternative solution for storing nuclear waste fuel
during this time period1. .
1 The Nuclear Waste Management Organization (NWMO) was created under the federal Nuclear Fuel
Waste Act to provide recommendations (within three years) to the Government of Canada on the long-term
management of used nuclear fuel. The Government of Canada will then decide on an approach, and this
decision would be implemented by the NWMO, subject to all necessary regulatory approvals.
Report CAO 06-03
Date: July 14, 2003
Subject: Pickering Nuclear Waste Management Facility Expansion
- City of Pickering's Comments on Draft EA Study Reports
147
Page 3
To assist in monitoring the EA process, and reviewing EA documents, the City
commissioned a peer review consulting team (lER). OPG has agreed to cover the
consulting costs for this peer review service.
Following receipt of the City/IER peer review comments, CNSC will tabulate all of the
comments that it receives from submitters and then will forward them to OPG for their
review and response. OPG will formally address each of the comments with
explanations, additional information, and/or a commitment to alter the project, etc. The
City will subsequently have an opportunity to reply, with the assistance of IER, to OPG's
responses. The entire process is intended to result in the completion of a final report
that will be submitted to a CNSC public hearing ili 2004.
In late June, the Draft EA Study Report and thirteen Technical Support Documents
were released by OPG and distributed by CNSC. Attached for information purposes, is
the Executive Summary of the Draft EA Study Report (see Attachment No.1). The
complete Draft EA Study Report and all of the Technical Support Documents are
available for viewing through the CAO's Office.
IER has reviewed the Draft EA Study Report and Technical Support Documents (TSD),
and have provided comments to the City. They have a number of "significant findings"
and "detailed minor comments" (see Attachment No.2).
In general, the Review Team found the EA to provide adequate documentation to
support most of the findings and conclusions presented. The environmental conditions
of the study area are adequately described, with some exceptions that are more fully
described in IER's submission. The assessment of the selected Valued Ecosystem
Components (VECs) was carried out in a manner consistent with the Canadian
Environmental Assessment Act and current environmental practice, although it is not
clear whether the public was involved in the selection of VECs.
Assuming that OPG clarifies the inconsistencies identified and provides important
missing information, the Review Team agrees that there would be no significant
residual adverse environmental effects of the PWMF II project at the preferred Site,
Area B, taking into account the identified mitigation measures.
Below, is a summary of IER's other significant findings:
1.
In the Socio-Economic Impact Assessment, a significant percentage of
respondents indicated that they might change their decision to live in the
community as a result of the project. The assessment also notes that respondents
have concerns about the Pickering Nuclear Generating Station as a whole. This is
the second temporary storage solution at the Station, and permanent storage may
be an option considered for the future. This point, while outside the limited scope
of the EA analysis for PWMF II, is most relevant in terms of the concentration of
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Report CAO 06-03
Date: July 14, 2003
Subject: Pickering Nuclear Waste Management Facility Expansion
- City of Pickering's Comments on Draft EA Study Reports
Page 4
nuclear facilities and associated wastes within the Region of Durham and City of
Pickering and the potential cumulative impacts that can affect the community. It will
be extremely important to monitor public attitudes to ensure that perceptions do not
lead to changing behaviour patterns.
2.
It is strongly recommended that the City of Pickering and the Region of Durham be
directly involved in the design and implementation of the follow-up and monitoring
program to verify the accuracy of the EA study predictions.
3.
Regarding the existing Geology, Hydrogeology and Seismicity environment, there
were several omissions and inconsistencies in the groundwater monitoring data
described in Appendix B of the TSD. In some cases the interpretation of results
was questionable. These issues should be addressed in the revised EA Study
Report, especially due to the presence of a closed landfill site located up-gradient
of the proposed siting area.
4.
The evaluation and selection of the project location was transparent and traceable
but it could have been improved using a numerical ranking scheme. Also,
complete and detailed information is not provided on public consultation activities
associated with the selection of the project location.
5.
During peak hours, existing traffic conditions at various intersections on Brock
Road leading into the PWMF II siting area are described as unacceptable
according to level of service standards. The Review Team is concerned that
additional traffic generated by PWMF II construction activities will exacerbate
existing traffic problems.
6.
In some cases the Main EA document differs from the Technical Study Document
(TSD) supporting the Main EA. These differences should be explained in the form
of an appendix to the Main EA Report.
7.
There are several instances where the objectives of the community and
stakeholder consultations and communication program (CSCCP) do not appear to
be fully satisfied, e.g., the Appendices in both the Draft EA Study Report and TSD
had frequent omissions, incorrect references, hidden references and/or
photocopying errors. Other areas of concern are presented in the main body of the
peer review.
8.
The description of the existing atmospheric environment is based on ambient air
monitoring stations located some distance from the PWMF II facility. The follow-up
and monitoring program should confirm that the baseline data is accurate.
9.
The description of the existing terrestrial environment did not properly inventory
breeding amphibians during dry periods nor did it provide sufficient data on the
marsh wren.
Report CAO 06-03
Date: July 14, 2003 149
Subject: Pickering Nuclear Waste Management Facility Expansion
- City of Pickering's Comments on Draft EA Study Reports
Page 5
10. With regard to the description and assessment of credible malfunction and accident
scenarios, there are inconsistencies in the assumptions used to describe the
bounding accident, and the dose calculation methodology appears to be based on
PWMF I conditions (Phase II site location is considerably closer to the property
boundary than the Phase I site location).
11. The cumulative effects assessment predicted that the effects on VECs do not
possess a cumulative effects trigger. While the conclusions seem reasonable it will
be extremely important to revisit these predicted effects during the follow-up and
monitoring program, especially in light of the pending international airport located
some 12 km. to the North of PWMF II and slated to open within ten years.
12. The Review Team recommends that several additional elements be incorporated
into the follow-up and monitoring program.
Staff concur with the IER's findings and conclusions, and recommend that Council
accept the IER submission and forward it with this Report to CNSC as the City of
Pickering's comments on the Draft EA Study Report. It is also recommended that a
copy of this report, including the IER submission be forwarded to OPG, the Canadian
Association of Nuclear Host Communities, and the Nuclear Waste Management
Organization for information.
Attachments:
1.
2.
Draft EA Study Report Executive Summary (prepared by OPG)
IER Draft Review of OPG Draft EA Study Report (submission to the City dated
July 2003)
Prepared By:
Approved / Endorsed By:
2,/
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A.L. (Joe) Himwicks /
Emergency Respons¡féoordinator
/1
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Th mas J. Quinn
Chief Administrative Officer
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Thomas E. Melymuk
Division Head, Corporate Projects & Policy
Report CAO 06-03
150
Date: July 14, 2003
Subject: Pickering Nuclear Waste Management Facility Expansion
- City of Pickering's Comments on Draft EA Study Reports
Page 6
T JQ:tem:alh:kr
Attachments
Copy: Division Head, Corporate Projects & Policy
Recommended for the consideration of
Pickering City Council
ATTACHMENT# \ TO REPORT#QhQ' cl9- c¿
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151
Ontario Power Generation Inc.
Draft EA Study Report
Pickering Waste Management Facility Phase II
Environmental Assessment
EXECUTIVESU~RY
1.0
INTRODUCTION
Ontario Power Generation Inc. (OPG) proposes to expand capacity of the existing Pickering
Waste Management Facility Phase I (PWMF I) for additional interim storage of used fuel at the
Pickering Nuclear (PN) site in southern Ontario. The PN property is located in the City of
Pickering in the Regional Municipality of Durham on the northern shore of Lake Ontario, 32 km
east of downtown Toronto and 21 km south-west of the City of Oshawa.
There is insufficient space immediately adjacent to PWMF I to accommodate the required
expansion. In addition, construction of the expansion adjacent to PWMF I would interfere with
the operation and maintenance of the PN reactors. Therefore, OPG is proposing to construct and
operate Pickering Waste Management Facility Phase II (PWMF II) at a separate nearby location
within the PN site to provide the required additional storage capacity. The proposed expansion
will not alter the basic purpose or function of the existing PWMF 1. The expanded facilities, will
use the same storage technology as is currently in use in the existing, licensed PWMF I.
OPG's plan from the outset was to develop the PWMF in two phases as the used fuel volumes at
PN increased. The proposed Phase II project is the expansion of the used fuel dry storage
component of the existing PWMF I to accommodate used fuel from Pickering Nuclear
Generating Station A (PNGS-A) and PNGS-B to the end of their planned 40 year service lives.
Decommissioning of PW.MF II is anticipated once all the used fuel has been transferred to a
long-term waste management facility.
The Canadian Nuclear Safety Commission (CNSC) is the federal authority responsible for the
regulation of nuclear facilities in Canada. The siting, construction and operation of the facility
would be authorized by the CNSC under subsection 24(2) of the Nuclear Safety and Control Act
(NSCA). Licensing approval from the CNSC invokes a federal Environmental Assessment (EA)
pursuant to Section 5(1) (d) of the Canadian Environmental Assessment Act (CEAA). The CNSC
has determined that a screening level assessment is required for the proposed project. As the
licensing body, the CNSC is the Responsible Authority (RA) under the CEAA for the purpose of
this assessment.
The CNSC has delegated the preparation of an EA Study Report to OPG. Once accepted, this
report will be used by the CNSC as a basis for the preparation of the required Screening Report.
The EAStudy Report is organized into 14 chapters. The highlights of Chapters 2 to 12 are
provided in the following sections of this Executive Summary. Chapter 1.0 is an Introduction to
the project, Chapter 13 is References and Chapter 14 is Abbreviations and Acronyms.
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Pickering Waste Management Facility Phase II Qc (;) C\, .~ OntarioPower Generation Inc.
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2.0
DESCRIPTION OF THE PROPOSED PROJECT
This chapter provides an overview of used fuel dry storage at PN, project location, description of
components of the proposed facility, the proposed works and activities, project schedule, waste
management at the facility, a description of OPG's environmental, safety and monitoring
programs, and a description of a conceptual decommissioning plan.
Used Fuel Dry Storage Phases I and II
The existing PWMF I Storage Buildings (1 and 2) together will hold up to 650 DSCs. The
proposed PWMF II will have two identical Storage Buildings (3 and 4) each designed to .contain
up to 500 DSCs for a total of 1000 DSCs.
Site Location of Phase II
A Site Options Study identified and analyzed the various options for locating the PWMF II within
the PN property. The criteria used were potential impacts on present and future land use, impacts
on operations and maintenance, traffic and material flows, health and safety, and security. The
preferred siting option was a 13 ha PWMF II Siting Area located in the East Complex of the PN
site on lands primarily used for outside storage, material lay down and parking, and adjacent to a
small wetland and PN landfill areas.
Components of Facility
The DSC design used in PWMF I will continue to be used. It is a free standing reinforced concrete
container, with an inner steel liner and an outer steel shell. It is made of two sub-assemblies, a lid
and a base with provision for installing safeguard seals. The DSC has been designed to provide a
storage life that will meet all shielding and containment integrity requirements over a minimum 50
year service life.
The Storage Buildings will be single storey, commercial-type, pre-engineered or pre-cast concrete
structures with a concrete slab-on-grade floor. The Storage Buildings will meet the requirements
of the National Fire Code of Canada and the National Building Code of Canada.
As a Class IB Nuclear Facility, the PWMF II will be provided with appropriate security and alarm
systems to comply with CNSC security requirements. It will be located within a designated
"protected area", bounded by a perimeter fence.
The specialized Transfer Vehicle already in use at PWMF I will continue to be used to transfer
loaded DSCs (weighing approximately 70 Mg) between PWMF I and PWMF II. The design speed
of the vehicle is 4 krn/hr. Transfer routes and timeframes have been identified between PWMF I
and PWMF II along with appropriate safety and security.
Proposed Works and Activities
The activities associated with the Site Preparation and Construction Phase are:
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June, 20m
ATTACHMENìT #~:!"OREPORT#QJ\O ciP.O'6
Pickering Waste Management Facility Phase II ~'~ C':>\ "1 Ontario Power Genemhon Inc.
Environmental Assessment .. Draft EA Study Report
. site clearing;
. excavation;
. site grading and compaction;
. construction of foundation and inactive drainage system;
. site service hook-ups;
. construction of the storage buildings;
. site paving and landscaping;
. road construction and/or upgrading; and
. installation of perimeter fence and security system.
153
The activities associated with the Operation Phase are:
. Transferring loaded, seal-welded DSCs from the existing Processing Workshop or the PWMF I
Storage Buildings to the new PWMF II Storage Buildings;
. Operating and maintäining the PWMF II Storage Buildings;
. Routine security and International Atomic Energy Agency (IAEA) inspections.
Project Schedule
Subject to EA approval from the CNSC, the proposed schedule for implementing the PWMF II
Project is as follows:
. Initiation of detailed design - Fall of 2004.
. Site preparation and construction of Storage Building 3 - 2005 to 2007.
. Operation of Storage Building 3 - 2007.
. Construction of Storage Building 4 - 2014.
. Operation of Storage Building 4 - 2016.
3.0
ASSESSMENT METHODOLOGY
The assessment methodology follows the general requirements of CEAA and is reflected in each
chapter of the report. This methodology requires that the project works and activities be considered
to determine how each one may interface with, and affect, the environment. This is done by
establishing temporal and spatial boundaries relevant to the project, identifying applicable
environmental components (biophysical, cultural and social), and selecting the valued components
(VCs) that represent important features of the environment as a focus of the EA study.
The spatial boundaries include a Regional Study Area - the 10 km emergency planning zone
(centered on the PN property), as identified by Emergency Management Ontario; a Local Study
Area - areas within the municipal boundaries of the City of Pickering and the Town of Ajax south
of Highway 401; and a Site Study Area - the PWMF II Siting Area and the area encompassed by
the associated transfer routes.
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June, 2003
ATTACHMENT # \ TO REPORT # ~o D.~- OS
Pickering Waste Management Facility Phase II %4 aS~^ \, ,Ontario Power Generation Inc.
15 4 Environmental Assessment .. Draft EA Study Report
4.0
COMMUNITY AND STAKEHOLDER CONSULTATION AND
COMMUNICATION
The Community and Stakeholder Consultation and Communication Program (CSCCP) involved a
series of coordinated activities and events throughout the EA study. Highlights included three EA
Newsletters, Project Information Packages, three rounds of Open Houses each held in Pickering,
Ajax, Scarborough East, and. Whitby, mailings of invitation cards and comment cards, three
presentations to the Pickering Nuclear Community Advisory Council, toll-free information line, a
website, and project information repositories The communication process with Aboriginal groups
(six First Nations and Métis Nation) was undertaken through consultation with the appropriate
contact persons and councils. All issues raised by stakeholders were recorded in a Stakeholder
Comment Database and addressed either through the CSCCP and/or in the EA Study Report.
5.0
DESCRIPTION OF EXISTING ENVIRONMENT
The Site Study Area is an industrial area containing a mix of uses including warehouses, machine
shops, hazardous materials storage building, parking areas, material storage, access roads and
drainage ditches. No soil contamination was found in the Siting Area; therefore, soil quality is
considered acceptable for an industrial site. No watercourses traverse the Site Study Area and all
but two of ten site catchments drain directly into Lake Ontario. In general, drainage is a mix of
ephemeral swales, ditches, culverts and storm sewers containing minimal vegetation cover and
wildlife habitat. The quality of stormwater was found to be generally consistent with that of
typical urban runoff. The direction of groundwater flow beneath the Siting Area is towards the
Lake Ontario shoreline; groundwater quality was measured to be within appropriate guidelines.
The analysis of baseline conditions in the Regional, Local and Site Study areas is documented in
nine Technical Support Documents (TSDs) and summarized in the EA Study Report. The
following YCs were identified from the analyses:
.
Radiation and Radioactivity - members of the public and workers; populations of non-
human biota.
.
Atmospheric Environment - residents at Durhamdale House (the closest residence).
.
Aquatic Environment - benthic invertebrates, emerald shiner and white sucker in Lake
Ontario. .
. Terrestrial Environment - red-winged blackbird, grey catbird, woodchuck, northern
leopard frog, chokecherry, narrow-leaved cattail, and sandbar willow.
.
Socio-economic Conditions - population, business activity and tourism, housing and
property values, recreational and community features, municipal finance, community
character, use and enjoyment of property.
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June, 2003
ATTACHMENT # \. TO REPORT #~ C')(y ~ CY3 155
Pickering Waste Management Facility Phase II v~ '5 c..,\' ~ Ontario Power Generation Inc.
Environmental Assessment Draft EA Study Report
. Physical and Cultural Heritage Resources - aboriginal structural remains, subsurface
features and artefacts; historic architecture, structural remains, artefacts; agricultural
landscapes.
. Aboriginal Interests - employment and business opportunities, community character,
hunting and fishing for subsistence. and economic purposes; archaeological resources,
ceremonial sites, burial mounds or petroglyphs.
No VCs were identified for Geology and Hydrogeology, and Land Use and Resources.
6.0
EVALUA TION AND SELECTION OF PROJECT LOCATION
Using a conceptual facility layout to determine the area needed for the approximate footprint of the
PWMFII, three alternative Site Areas were identified within the Siting Area (A-West; B-Centra1;
C-East). The Site Areas were evaluated using factors such as shielding requirements, foundation
conditions, building removal, stormwater drainage, construction disruptions, interaction with PN
operations, and security considerations. Based on the technical evaluation, all of the Siting Area
was found to be acceptable. However, Site Area B and its associated transfer routes was selected
as the preferred site and was the. location most preferred by the public.
7.0
ASSESSMENT OF LIKELY ENVIRONMENTAL EFFECTS AND
MITIGATION
No potential effects on VCs from project works and activities were identified except for those
related to radiation and radioactivity, land use, and socia-economic conditions. The evaluation for
radioactivity indicated that the additional radiation dose from PWMF II to members of the public
living, working or undertaking recreational activities outside the PN property boundary is expected
to be a very small fraction of the dose from background radiation. As such, it will be
indistinguishable from the temporal and spatial variations in radiation levels. Also, the estimated
doses to workers during normal operations of PWMF II were determined to be within appropriate
guidelines and regulatory limits.
Public concern was raised with respect to views of the proposed facility from theW aterfront Trail
which passes by the eastern boundary of the PN property. With .the proposed construction of a
natural berm and/or planting of a mature tree screen, the visibility of the facility will be minimized,
resulting in improved natural character of views overall. A net positive effect for the City of
Pickering will result from the project as a consequence of increased tax revenue generated by the
presence of new buildings on the PN property.
An additional net benefit will result from the implementation of. the proposed Stormwater
Management Concept which will improve the. existing wetland habitat and increase biodiversity in
the area immediately east of the PWMF II.
Also assessed were likely effects of the environment on the project, and likely effects of the project
on sustainable use of renewable and non-renewable resources. No adverse environmental effects
were identified.
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Pickering Waste Management Facility Phase II 9~ ls; 0\ ~ Ontario Power Generation Inc.
Environmental Assessment . Draft EA Study Report
8.0
DESCRIPTION AND ASSESSMENT OF CREDIBLE MALFUNCTIONS
AND ACCIDENT SCENARIOS
Credible malfunctions and accidents, both non-radiological and radiological, were screened for
likely effects during construction, on-site transfer of DSCs and DSC storage operations. The
screening identified a single "bounding event" for evaluation: on-site traffic accident involving a
Transfer Vehicle. Radiation doses to workers, the public and non-human biota from suchan
accident are expected to be below acceptable levels.
9.0
ASSESSMENT OF CUMULATIVE ENVIRONMENTAL EFFECTS
There were no likely adverse residual effects identified for the PWMF II Project. However, in
response to comments received from the public, the cumulative effects assessment was broadened
in scope to include the cumulative effects of radiation and radioactivity; that is,. the effects of
radiation dose on three VCs - members of the public, workers and non-human biota. Twelve other
projects on and. around the PN property were analyzed for possible cumulative environmental
effects on the VCs. The estimated cumulative doses to the most exposed members of the public; to
workers and to non-human biota, are expected to be well below acceptable levels.
10.0
PROPOSED MITIGATION AND PLAN FOR FOLLOW~UP AND
MONITORING PROGRAM
Mitigation measures were used in two ways on the PWMF II Project to minimize potential adverse
environmental effects:
.
Mitigation measures which are part of the basic project design. These "in-design"
mitigation measures were assumed at the outset of the EA study and were identified in the
various assumptions made in the assessment of the Project Warks and Activities. They
include such measures as radiation shielding for the Storage Buildings, and the
development of a Starmwater Management Plan for PWMF II.
. Additional feasible mitigation measures identified during the EA study. These include
modifications to the Stormwater Management Plan for PWMF II to enhance the East
Wetland, and the visual screening of the facility from viewpoints along the Waterfront
Trail through berms and planting of mature trees.
A preliminary follow-up and monitoring program was defined to verify the accuracy of the EA
study predictions, and to confirm whether the proposed mitigation measures are effective. Some
of the monitoring activities will be part of normal existing monitoring programs for PN and
PWMF I; others are specifically developed for PWMF II. The latter activities will be incorporated
into PN'sINWMD's overall environmental management system. Details of the program will be
developed in response to the CNSC's direction and in consultation with other stakeholders as
appropriate. '
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11.0
SIGNIFICANCE OF RESIDUAL"ENVIRONMENTAL EFFECTS
There are no residual adverse effects that were required to be advanced for .consideration of
significance. However, the scope of the chapter was expanded to include a summary of human
health and safety considerations. The World Health Organization's definition of health as "a state
of complete physical, mental and social well-being and not merely the absence of disease or
infirmity" was used in the overall approach to assessment of human health and safety in this EA
study. No adverse effects on human health from non-radioactive emissions are expected. No
effects on the safety of workers and the local public, or on the general well-being of the public are
anticipated. Radiation doses from PWMF IT are estimated to be indistinguishable from
background and should not result. in health effects on members of the public, workers and non-
human biota.
12.0
CONCLUSIONS OF THE ASSESSMENT
The results of the assessment identified no significant residual adverse environmental effects of the
PWMF IT project, assuming the PWMF II is located within Site Area B, taking into consideration
the identified feasible mitigation measures. Site Area B was selected for environmental and
engineering reasons. and was.preferred by the public.
The three alternative Site Areas (A, B and C) are located in close proximity to one another in
highly modified industrial lands with minimal natural habitat. Accordingly, the site selection
process identified only minor environmental and technical differences among the three Site Areas.
Therefore, all would be acceptable to accommodate PWMF II with the application of different
levels of mitigation measures.
The final project design is not expected to be very different from the conceptual design used in the
EA study. Minor differences in design that may be required are not expected to result in any
significant adverse effects on the environment.
OPG recommends that the CNSC accept the conclusions as the basis for the preparation of its
Screening Report under the Canadian Environmental Assessment Act.
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ATTACHMENT # Q) TO REPORT# CÀo- otc.- ~~~
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Draft
Review of Ontario Power
Generation
Draft
Environmental Assessment
Study Report
For the Pickering Waste
Management Facility II
Project
Conducted by
IER - Planning, Research and
Management Services and Scimus Inc.
In association with North-South
Environmenta/lnc.
7501 Kee/e Street, Suite 300
Concord, Ontario
L4K 1 Y2
July 2003
ATTACHMENT #~TO REPORT # ~-cto- a ~
Review By IER of Ontario Power Generation \:h. Q Ç'::"\<eL
Draft Environmental Assessment Study Report . ~ c::" C:YC.::/
Pickering Waste Management Facility Phase II
July 2003 15 9
EXECUTIVE SUMMARY
IER and SCIMUS Inc., in association with North-South Environmental, were retained by the
City of Pickering to undertake a peer review of the Draft Environmental Assessment (EA) of the
Proposed Pickering (Nuclear) Waste Management Facility II Project.
In general the Review Team found the EA to provide adequate documentation to support most of
the findings and conclusions presented. The environmental conditions of the study area are
adequately described with some exceptions which are more fully described in this peer review.
The assessment of the selected Valued Ecosystem Components (VECs) was carried out in a
manner consistent with the Canadian Environmental Assessment Act and current environmental
practice although it is not clear whether the public was involved in the selection ofVECs.
Assuming that the proponent clarifies the inconsistencies identified and provides important
missing infonnation, the Review Team agrees that there would be no significant residual adverse
environmental effects of the PWMF II project at the preferred Site Area B taking into account
the identified mitigation measures.
Our key findings are as follows.
1.
In the Socio-Economic Impact Assessment, a significant percentage of respondents
indicated that they might change their decision to live in the community as a result of the
project. The assessment also notes that respondents have concerns about the Pickering
Nuclear Generating Station as a whole. This is the second temporary storage solution at
the Station, and pennanent storage may be an option considered for the future. This
point, while outside the limited scope of the EA analysis for PWMF II, is most relevant in
tenns of the concentration of nuclear facilities and associated wastes within the Region of
Durham and City of Pickering and the potential cumulative impacts that can affect the
community. It will be extremely important to monitor public attitudes to ensure that
perceptions do not lead to changing behaviour patterns.
2.
It is strongly recommended that the City of Pickering and the Region of Durham be
directly involved in the design and implementation of the follow-up and monitoring
program to verify the accuracy of the EA study predictions.
3.
Regarding the existing Geology, Hydrogeology and Seismicity environment, there were
several omissions and inconsistencies in the groundwater monitoring data described in
Appendix B of the Technical Study Document (TSD). In some cases the interpretation of
results was questionable. These issues should be addressed in the revised EA Study
Report, especially due to the presence of a closed landfill site located up-gradient ofthe
proposed siting area.
4.
The evaluation and selection of the project location was transparent and traceable but it
could have been improved using a numerical ranking scheme. Also, complete and
detailed infonnation is not provided on public consultation activities associated with the
selection of the project location.
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5.
During peak hours, existing traffic conditions at various intersections on Brock Road
leading into the PWMF II siting area are described as unacceptable according to level of
service standards. The Review Team is concerned that additional traffic generated by
PWMF II construction activities will exacerbate existing traffic problems.
6.
In some cases the Main EA document differs from the Technical Study Document (TSD)
supporting the Main EA. These differences should be explained in the form of an
appendix to the Main EA Report.
7.
There are several instances where the objectives of the community and stakeholder
consultations and communication program (CSCCP) do not appear to be fully satisfied,
e.g., the Appendices in both the Draft EA and TSD had frequent omissions, incorrect
references, hidden references and/or photocopying errors. Other areas of concern are
presented in the main body of the peer review.
8.
The description of the existing atmospheric environment is based on ambient air
monitoring stations located some distance from the PWMF II facility. The follow-up and
monitoring program should confirm that the baseline data is accurate.
9.
The description of the existing terrestrial environment did not properly inventory
breeding amphibians during dry periods nor did it provide sufficient data on the marsh
wren.
10.
With regard to the description and assessment of credible malfunction and accident
scenarios, there are inconsistencies in the assumptions used to describe the bounding
accident and the dose calculation methodology appears to be based on PWMF I
conditions (Phase II site location is considerably closer to the property boundary than the
Phase I site location).
11.
The cumulative effects assessment predicted that the effects on VECs do not possess a
cumulative effects trigger. While the conclusions seem reasonable it will be extremely
important to revisit these predicted effects during the follow-up and monitoring program,
especially in light ofthe pending international airport located some 12 kID. to the North
of PWMF II and slated to open within ten years.
The Review Team recommends that several additional elements be incorporated into the
follow-up and monitoring program.
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TABLE OF CONTENT
1.0
EXECUTIVE SUMMAR Y... ...................... ........ ............................... ..... ..... ..... ....... ..... ............ ....... i
INTR 0 D U CTI 0 N.. .......................... .......................... ............ ..... .......... ............... ......... 1
1.1
1.2
1.3
1.4
2.0
Purpose of the Review .................................................................................................. 1
Scope of the PWMF II Project..................................................................................... 1
Scope of Assessment...................................................................................................... 2
Scope of the Review ...................................................................................................... 3
SIGNIFICANT FINDINGS OF THE DRAFT ENVIRONMENTAL ASSESSMENT
2.1
STUD Y REPORT............ ................. ..................... ...... ..................... ..... ..... ..... ..... ......... .......... ....... 4
Execu tive Summary......................... .......................... ....... ..... .......... ......... .......... .......... 5
2.2
2.3
2.4
2.5
2.6
2.6.1
2.6.2
2.6.3
2.6.4
2.6.5
2.6.6
2.6.7
2.6.8
2.6.9
2.7
2.8
2.9
2.10
2.11
3.0
In trod u ction ............. .... .................... .......................... ....... ... ................. ........... ........ ...... 5
Description of the Proposed Project............................................................................ 5
Assessment Methodology.............................................................................................. 5
Community and Stakeholder Consultation and Communication ............................ 6
Description of the Existing Environment ................................................................... 7
Radiation and Radioactivity Environment..............................................................7
Atmospheric Environment....................................................................................... 7
Hydrology, Water Quality and Aquatic Environment............................................. 7
Terrestrial...........................................""""""""""""""""""""""""""".............. 8
Geology, Hydrogeology and Seismicity.... ....... ............................ ............. .............. 8
Land Use................................................................................................................. 9
Socio-Economic Conditions.................................................................................... 9
Physical and Cultural Heritage Resources........................................................... 10
Aboriginal Interests.............................................................................................. 10
Evaluation and Selection of Project Location .......................................................... 10
Assessment of Likely Environmental Effects and Mitigation................................. 11
Description and Assessment of Credible Malfunctions and Accident Scenarios.. 13
Assessment of Cumulative Environmental Effects .................................................. 13
Follow-up and Monitoring ............... ............ ............ ............ ..... ..... ..... ............. .......... 14
DETAILED MINOR COMMENTS................................................................................ 15
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1.0
INTRODUCTION
1.1
Purpose of the Review
IER and SCIMUS Inc. in association with North-South Environmental (hereinafter collectively
referred to as "IER"), were retained by the City of Pickering to undertake a peer review of the
Environmental Assessment ofthe Proposed Pickering (Nuclear) Waste Management Facility II
Project. The documentation included a Main Report (including five appendices), an Introductory
Document to the Technical Support Documents (TSDs) and 12 separate TSDs.
The City of Pickering intends to provide the Canadian Nuclear Safety Commission (CNSC) with
written comments relating to the Environmental Assessment (EA) of the Proposed Pickering
Waste Management Facility II (PWMF II) project. The City wants to ensure that the economic,
financial, social, cultural and environmental interests of the municipality and its residents are
satisfactorily protected. The peer review was conducted so that City staff can produce
documentation for City Council to consider as part of its submission to CNSC.
For this stage of the review, IER was required to perform the following activities:
1.
Conduct a peer review of reports and studies prepared and submitted by Ontario Power
Generation (OPG) and CNSC staff to the CNSC in fulfilling the requirements of the final
Environmental Assessment Guidelines;
2.
Provide technical comments and advice to municipal staff and Council to assist in
understanding the content of technical reports; and
3.
Attend a Y2 day workshop with City and OPG staff to review the project.
The first two activities were completed and reported herein. The third activity was a workshop
which took place Tuesday, May 27,2003.
1.2
Scope of the PWMF II Project
The CNSC is the authority responsible for the regulation of nuclear facilities in Canada. The
CNSC has determined pursuant to Section 5(1)(d) of the Canadian Environmental Assessment
Act (CEAA) that a federal environmental assessment (EA) is required before it can provide OPG
with an authorization to initiate the different on-site activities that comprise the PMWF II
project. In May of 2003 the CNSC issued the "Final EA Guidelines (Scope of Project and
Assessment) for the Environmental Assessment of the Proposed Pickering Waste Management
Facility, Phase II, Pickering, Ontario." OPO has prepared an EA Study Report designed to meet
the requirements of the EA Guidelines and to describe in detail the EA conducted for the
proposed PWMF II project.
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In the EA Guidelines, the CNSC determined that the scope of the PWMF II project was as
follows:
The physical works involved in this project are the storage buildings to be built for the dry
storage containers; all facilities, systems and activities required for the construction and
operation ofPWMF Phase II; and the facilities, systems and activities involved in the transfer of
loaded welded DSCs from PWMF I to the storage buildings in PWMF II. While
decommissioning is not part of the project, a preliminary decommissioning plan for PWMF II
will be included in the assessment.
Associated operations and activities that are within the scope of the project include:
.
Preparation of the site and construction of the storage buildings
0 Site clearing, excavation, grading and compaction
0 Construction of foundation and inactive drainage system
0 Site service hook-ups
0 Construction ofthe storage buildings
0 Site paving and landscaping
.
Preparation of systems and facilities involved in the transfer of loaded welded DSCs
0 Road construction and/or upgrading
0 Transfer of loaded welded DSCs from the Processing Building or Storage
Buildings in PWMF I to the Storage Buildings in PWMF II
.
Installation of perimeter fence and security system
0 Facilities and systems for maintaining security ofthe site
.
Operation and maintenance of the PWMF II
0 Radiation and security monitoring, inspection and maintenance
1.3
Scope of Assessment
The scope of assessment identifies the factors to be considered in the EA. The scope of a
screening assessment under the CEAA must include all the factors identified in paragraphs
16(1)(a) to (d) of the CEAA, and, as provided under paragraph 16(1)(e), any other matter that the
CNSC requires to be considered.
Paragraphs 16(1)(a) to (d) require the following factors be included in the screening:
. "the environmental effects of the project, including the environmental effects of malfunctions
or accidents, that may occur in connection with the project and any cumulative
environmental effects that are likely to result from the project in combination with other
projects or activities that have been or will be carried out;
. the significance of the effects identified above;
. comments from the public that are received in accordance with the CEAA and its regulations;
and
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.
measures that are technically and economically feasible and that would mitigate any
significant adverse environmental effects of the project."
In accordance with sub-section 16(1)(e) of the CEAA, in the EA Guidelines the CNSC required
that the following additional factors be included in the screening:
. the purpose of the project;
. various sites within the PWMF II siting area;
. various waste transfer routes;
. the need for, and requirements of, a follow-up program in respect of the project; and
. the capacity of renewable resources that are likely to be significantly affected by the project
to meet the needs of the present and those of the future.
1.4
Scope of the Review
In response to the direction from the City of Pickering and to detennine whether the EA Study
Report meets the CEAA requirements, the review team focused on the following:
~
~
~
~
Compliance with the EA Guidelines
Significant gaps in the infonnation contained in the documentation
Methodology
Results and Conclusions of the Assessment
According to Section 1.4.1.2 of the Main EA Study Report, "the EA Study Report is based on a
series of technical supporting documents which provide the detailed technical infonnation used
in the EA study. Although the supporting documents are not part of the EA Study Report per se,
they are referenced throughout the EA Study Report and contain useful supporting and
background infonnation that may be of interest to a reader wishing more detailed infonnation on
any ofthe technical components of the EA study. The TSDs were completed in Spring 2003.
Completion ofthis EA Study Report required additions and/or revisions to some of the
infonnation in the TSDs. Where there are differences between the TSDs and the EA Study
Report, the latter should be regarded as being definitive.
The TSDs comprise a series of 13 separate reports: one introductory document; one of each of
the nine components of the environment that were defined and adopted for the EA study, plus
one each for: malfunctions and accidents; cumulative effects; and community and stakeholder
consultation and communication. The TSDs present the detailed results of the EA study,
including the assessment of the environmental effects,"
As such, IER's review focused on the Draft EA Study Report and the findings presented in this
report are based on that review. In some cases the relevant section of the TSD was referenced.
The Draft EA Study Report is organized into two sets of comments. The first set of comments
provides our significant findings in the same sequence as the Sections of the Main EA, i.e.:
~ Executive Summary
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~ Introduction - Section 1.0
~ Description of the Proposed Project - Section 2.0
~ Assessment Methodology - Section 3.0
~ Community and Stakeholder Consultation and Communication - Section 4.0
~ Description of the Existing Environment - Section 5.0
~ Evaluation and Selection of Project Location - Section 6.0
~ Assessment of Likely Environmental Effects and Mitigation - Section 7.0
~ Description and Assessment of Credible Malfunctions and Accident Scenarios -
Section 8.0
~ Assessment ofCurnulative Effects - Section 9.0
~ Proposed Mitigation and Plan for Follow-up and Monitoring Program - Section
10.0
~ Significance of Residual Environmental Effects - Section 11.0
~ Conclusions ofthe Assessment - Section 12.0
The second set provides further detailed comments.
For each of the above sections of the Environmental Assessment, the environment is represented
by the following components:
~ Radiation and Radioactivity
~ Atmospheric Environment
~ Hydrology, Water Quality and Aquatic Environment
~ Terrestrial Environment
~ Geology, Hydrogeology and Seismicity
~ Land Use and Resources
~ Socio-Economic Conditions
~ Physical and Cultural Heritage Resources
~ Aboriginal Interests
While the Review Team concentrated its effort on the Main EA, a comprehensive review was
also performed on the TSDs to ensure traceability.
2.0 SIGNIFICANT FINDINGS OF THE DRAFT ENVIRONMENTAL
ASSESSMENT STUDY REPORT
In general the Review Team found the EA to provide adequate documentation to support most of
the findings and conclusions provided. The environmental conditions of the study area are
adequately described and the assessment of the selected VECs was carried out in a manner
consistent with the Canadian Environmental Assessment Act and current environmental
assessment practice, although it is not clear whether the public was involved in the selection of
VECs. Based on the information provided, the Review Team agrees that there are no significant
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residual adverse environmental effects of the PWMF II project assuming the PWMF II is located
within Site Area B, taking into consideration the identified mitigation measures.
The comment provided is, however, subject to clarifications or provision of further information
with respect to several areas within the Draft EA. In some cases information was missing or the
interpretation of results was unclear. Our major observations are as follows.
2.1
Executive Summary
As indicated in Section 2.11 "Follow-up and Monitoring Program", it is strongly recommended
that the City of Pickering be involved in the design and implementation of the follow-up and
monitoring program to verify the accuracy of the EA study predictions and to confirm whether
the proposed mitigation measures are effective (ES-6, last paragraph).
In the summary of "Significance of Residual Environmental Effects" (ES- 7, first paragraph), the
report indicates that no adverse effects on human health from non-radioactive or radioactive
emissions are expected. Human health includes mental and social well-being which are both
linked to perception. This underscores the importance of sustained on-going monitoring to
assure stakeholders of "no adverse effects".
2.2
Introduction
In the first paragraph of Section 1.4.1.2 (pages 1-8), it is stated "where there are difference
between the TSDs and the EA Study Report, the latter should be regarded as being definitive".
This demonstrates a lack oftraceability. An Appendix explaining the differences and/or errata
should be added to the Final EA report.
2.3
Description of the Proposed Project
The level of detail and the scope of the description is acceptable. It is sufficient to allow proper
consideration of issues related to potential impacts within the temporal boundaries.
This section contained a clear discussion ofthe interface of this project with the long-term waste
management program as part of the discussion of future decommissioning.
The total capacity ofthe storage buildings is 1654 Dry Storage Containers (DSC' s), only 7%
more than the total number ofDSC's expected. This does not appear to provide sufficient
contingency against unforeseen problems (Section 2.2.1, page 2-1)
2.4
Assessment Methodology
The Review Team found the assessment methodology to be acceptable and consistent with the
requirements of the Canadian Environmental Assessment Act.
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2.5
Community and Stakeholder Consultation and Communication
Key concerns raised by the public at the first and second Open Houses included:
~ Safety of interim storage of used fuel in their community;
~ The lack of a long-term solution for the disposal of nuclear fuel; and
~ Opposition to any long-term storage of used fuel on the PN site and a desire to
participate in future discussions of the long-term options (P. 4-9, 3rd paragraph)
This demonstrates the need for ongoing dialogue with affected stakeholders through an existing
vehicle such as the Community Advisory Committee.
The objectives of the CSCCP appear to have been met in general. There are some instances
where it is not clear whether the objectives have been fully met; these are discussed below.
The outreach area is broad and inclusion of known stakeholders from outside the area on the
mailing list is appropriate.
The types of stakeholders included in the project are clearly identified in the bulleted list on Page
4-3. However, the list of stakeholders in Appendix C is considerably smaller than that suggested
by the list on Page 4-3. The distinction should be made between the stakeholder mailing list
(which would have hundreds of contacts on it) and the list of key stakeholders to be contacted
directly for scoping interviews - which appears to be what is represented in Appendix C.
There was found to be incomplete information in the report. The Appendices in both the Draft
EA Report and the TSD had frequent omissions, incorrect references, hidden references and/or
photocopying errors. These are identified in Section 3 of this peer review. The omissions are the
most important aspect, as the lack of specific information does not enable a full assessment of
the details of information provided to the public and agencies and information received in
response to be able to confirm OPG's consultation results. Specific instances of missing
information are contained in Section 3.
The decision to cancel the two EA workshops that had been planned in the Community and
Stakeholder Consultation and Communication Plan appears to have been made without sufficient
effort to determine if there was interest at the times that the workshops were to have taken place
(rather than at any initial interviews). A workshop for municipal representatives, with a written
invitation to other stakeholders at the time of the proposed workshop would have been a viable
alternative to addressing an initial lack of interest in a later workshop. Secondly, the CAC should
not have been used as a vehicle for providing workshop information to stakeholders, since it was
identified as a stakeholder that would have provided periodic updates in any case. A more
detailed discussion is included in Section 3.
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2.6
Description of the Existing Environment
This Chapter of the EA describes existing environmental conditions and is based on the
following nine Technical Support Documents:
~ Radiation and Radioactivity;
~ Atmospheric Environment;
~ Hydrology, Water Quality and Aquatic Environment;
~ Terrestrial Environment;
~ Geology and Hydrogeology;
~ Land Use and Resources;
~ Socio-Economic Conditions;
~ Physical and Cultural Heritage Resources; and
~ Aboriginal Interests.
The Review Team's comments are based on the content of the Main EA Report but are
supported, in some cases, by issues identified in the TSDs. While the intent of the Main EA
Report was to be a stand-alone document, the TSDs are referred, where appropriate, to improve
the traceability ofthe assessment process.
2.6.1 Radiation and Radioactivity Environment
The existing radiation and radioactivity environment is adequately described.
2.6.2 Atmospheric Environment
The Main EA concludes "However, for the purposes of the study, the air quality in the Site Study
Area can be represented by the air quality in the Regional Study Area". Atmospheric monitoring
is not conducted in the vicinity ofthe Siting Area and the results ofthe atmospheric
environmental assessment rely on the closest ambient air monitoring stations located in
Scarborough (almost 20 kID. SW) and Oshawa (20 kID. NE). Furthermore, as shown in Table
4.2.1.1-1 ofthe TSD (P. 9), there are no Total Suspended Particulate or Inhalable Particulate data
identified East ofthe Siting Area. It is normal EA practice to describe existing atmospheric
conditions using local monitors. Ifthese are lacking, as in the case of PWMF II, then temporary
monitors would be established to confirm that Regional data are appropriate especially for a
facility the size ofPNGS. At the very least, the future monitoring program should be capable of
confirming the conclusions of the EA. Also, dustfall is missing from the list of air quality
constituents considered. The EA report should explain why this parameter was not included.
2.6.3 Hydrology, Water Quality and Aquatic Environment
Section 5.4.2 of the Main EA Report discusses varying levels of erosion on the Lake Ontario
shoreline immediate south of the Siting Area and the TSD discusses the catchments where
erosion occurs. The Review Team could not find any discussion of any remedial work which
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PICkering Waste Management Facility Phase II July 2003
would be undertaken for those catchments exhibiting erosion, especially those associated with
stormwater discharges from PWMF II.
2.6.4 Terrestrial
The existing Terrestrial environment is adequately described with the exception of improper
inventories of breeding amphibians during a dry period and insufficient data on the marsh wren.
Some details are described in Section 3.
2.6.5 Geology, Hydrogeology and Seismicity
Under Section 5.6.4 of the Main EA Report and Section 4.2.2.3 of the TSD "PN East Complex
Soil and Groundwater Quality", results of groundwater sampling and analysis are discussed
based on the data presented in Appendix B of the TSD. The Review Team found several
omissions and inconsistencies in the data in Appendix B and the interpretation of same, as
follows:
.
Wherever silver was analyzed as part of groundwater monitoring the detention limit was
always higher than the GUCSO Table B criteria. This should be explained in the Main EA.
.
The Main EA should explain why GUCSO Table B criteria were used instead of the
conventional suite of groundwater parameters.
.
On P. 5-29 of the Main EA under the section entitled "Groundwater Quality", it is stated that
groundwater quality within the site study area does not exceed GUCSO Table B criteria.
Table B-2 of the TSD identifies two monitoring wells within the siting area which show
exceedances of Vinyl Chloride, Lead and Mercury. This discrepancy should be explained,
especially given the fact that the siting area is directly down gradient ofthe East Landfill
using inferred direction of shallow groundwater flow shown in Figure 4.2.3-3 of the TSD.
.
The analysis of groundwater quality for Round 1 shown in Table B-2 ofthe TSD is missing
PCB's and Phenols for all monitoring locations reported. This information is important due
to the presence of PCB storage facilities and the up-gradient closed landfill sites.
. Section 4.2.2.6 on P. 11 of the TSD indicates that soil and groundwater samples ITom
monitors RGM-51 and RGM-52 were analyzed for PCB, PH, metals, TPH, VOCs, cresols
and phenol compounds. Table B-2 of the TSD does not show metals, PCB, TPH, VOCs,
cresols and phenols compounds in the analysis of groundwater quality.
.
The last full paragraph on P. 13 of the TSD indicates "Wells OPG - MW-3, OPG-MW-5,
OPG-MW-6, OPG-MW-61 and OPG-MW-7 are located down gradient ofthe East Landfill
and monitor groundwater conditions between it and Lake Ontario (Figure 4.2.5.2). The
analytical results for samples collected from these wells confirm that the East Landfill does
not have an effect on groundwater quality (Appendix B)". These results could not be found
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in Appendix B. The Review Team therefore cannot confinn the acceptability of groundwater
quality in the Siting Area.
.
With respect to Section 4.2.3.5 "East Site Garage" groundwater analysis of samples ITom
RGM-19 and RGM-19B was missing key parameters such as Benzene, Total Hydrocarbons
and several other organics.
The above concerns make it unclear whether there is presently soil and groundwater
contamination ITom off-site influences such as the East Landfill, the Inert Fill Sites and other
facilities. Since contaminants may be migrating from these sites in the groundwater system,
which has been shown to flow predominantly in a southward direction under the Siting Area, it is
important to have an adequate assessment of this potential impact throughout the duration of the
project. This is identified as a need for follow-up and monitoring in Section 2.11.
2.6.6 Land Use
Section 5.7.2.2 ofthe Main EA and Section 4.2.2.1 ofthe TSD do not indicate whether the
Pickering Zone By-law M2- Industrial Zone includes the storage of spent nuclear fuel as a
pennitted use. This should be clarified.
The Main EA does not describe the existing traffic operations in the vicinity of PWMF II. This
is described in the TSD (P. 25) and is judged to be significant because key intersections on Brock
Road are currently operating at unacceptable levels of service. Also, Section 4.2.3 of the TSD
states that "From a transportation perspective, the PMWF II site is readily accessible by existing
roads". This statement is inconsistent with the levels of service described above.
2.6.7 Socio-Economic Conditions
The negative perception of the Pickering nuclear facilities is not adequately described. The
following observations can be made.
.
In Section 5.8.1, it is quite evident from the infonnation in the report that a substantial
number of people (somewhere between 21 % or 27%) - think about the PNGS on a
regular basis and how it affects their sense of health, safety and well-being. These are
large segments of the community population who have at the least perception concerns
about the existence of the full Pickering Operation. This comes to the fore during the EA
public consultation for the waste facility. As an issue, it is extremely important to
acknowledge this high percentage of concern and to take steps to address the perceptions.
While the EA report and the Socio-Economic TSD acknowledge issues of perception and
stigma, it is noted that these issues are not directly relevant to the socio-economic impact
analysis based on the existing legislation. While this is technically correct, it is important
to recognize these issues of concern as they can and do lead to people potentially
changing behaviour patterns as a direct result of a project or proposal. It appears to us
that the limiting definition of social impacts in the tenus of reference and in the CEA Act
does not lead to full consideration of what is a substantial social concern.
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.
On page 4-22 ofthe Socio-Economic TSD, the table Most Negative Attributes, points out
that the nuclear plant in general tenns was considered a negative attribute. It was one of
the top three. With respect to issues that negatively affect the image ofthe community,
the nuclear plant was the most important issue at both the local and regional study areas.
When one excludes those who could not name a negative issue affecting image, it is
approximately 25% of the respondents in the local study area indicating that the nuclear
plant negatively affects the image of the community.
.
On page 6 of Appendix D of the Socio-Economic TSD, it is noted that the Pickering
station is not a dominant issue in the local and regional study areas. While this is correct
in one sense, it is not in another when it is noted in some sections of the survey that the
nuclear station in fact is something that affects people sense of well being. It is a concern
for 21 % ofthe local area respondents (which is the highest) as well as 18% at the
regional level (second highest). This has not been given proper weight in the analysis
based on table 2, page 8.
.
The analysis on page 11 of Appendix D of the Socio-Economic TSD, dealing with issues
that most negatively affects image ofthe community states that no one issue dominates.
However, out of the issues that are presented, there are two major issues - one being
crime and the other being nuclear stations dangers. The nuclear station is the most
frequently mentioned issue.
2.6.8 Physical and Cultural Heritage Resources
The physical and cultural heritage resources described are relevant for predicting environmental
effects likely to result from the PWMF II project.
2.6.9 Aboriginal Interests
The existing environment for Aboriginal interests was adequately described.
2.7
Evaluation and Selection of Project Location
The site evaluation process was transparent, traceable, replicable (for the most part) and
consistent in the evaluation and decision making process. The Review Team has the following
comments:
Step 1 (P. 6-1) should have fully described the Site Option Study rather than Section 2.2.3.
The process described in Step 1 was confusing.
Analysis reflected in Table 6.4-1 could have been improved using a numerical ranking scheme.
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In Section 6.4.2.2, Public Consultation During the Site Selection Process, complete and detailed
information is not available on information presented to the public at open houses or received
from them at these events. Similarly, there is only incomplete information on discussions at key
CAC meetings where preferences on a Site Area were established. This information is critical to
dispel the possible perception that the decision on a preferred site area was made in advance of
the public consultation on the three options.
2.8
Assessment of Likely Environmental Effects and Mitigation
With respect to Section 7.3, "Radiation and Radioactivity, a brief summary of the shielding
calculation methodology and results should be included as an Appendix to the EA or in the TSD.
Regarding Section 7.4.2 "Noise", it is indicated that as long as the equipment utilized for the
construction project is in compliance with the sound emission standards, the construction activity
is considered to be in compliance from a noise perspective. It is, therefore, important to perform
the necessary noise tests during the operation of this equipment to ensure compliance.
Regardless, a formal complaint response system should be established, if it isn't already in place,
to respond to any concerns the public may bring forward.
With respect to the Terrestrial (Section 7.6) and Aquatic (Section 7.5.1) wildlife, it is agreed that
the proposed works are not likely to affect terrestrial or aquatic wildlife, with the caveat that:
.
Further investigations should confirm that there are no amphibians breeding on the site,
and that fish are not present when water levels are maximum (a site visit should be made
after frogs begin calling in the region, approximately early April).
.
The issue of marsh wren breeding or non-breeding in the East Wetland should be
clarified (if breeding, marsh wren should be added to VECs).
.
The issue of sediment deposition in the East Wetland should be addressed, and the
sediment and erosion control plan should include the issue of sediment deposition in the
East Wetland.
The conclusion that there are not likely to be measurable effects of construction on aquatic life,
terrestrial wildlife, vegetation, natural heritage features seems reasonable given the developed
nature of the site.
The issue of sediment deposition in the East Wetland during construction is dismissed in this
report in the Aquatic Environment section (Page 7-19). However, in the TSD aquatic section it
notes that the Terrestrial TSD would deal with the issue of sediment deposition in the East
Wetland, as there is no aquatic life present in this wetland. The Terrestrial TSD did not address
this issue.
The ranking of VECs is not very useful. More weight should be given to species of specialized
habitat whose environment could be affected by the proposed works, as this reflects the priorities
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of municipal and provincial agencies. For example, marsh wren is listed as one ofthe
inhabitants ofthe East Wetland (though its presence there as a breeding bird needs to be
clarified). If the stormwater control measures planned (creation of ponds where the East
Wetland now stands as in Figure 7.5-1) are implemented, the habitat for this species, which
consists of cattail marsh, would be eliminated. Marsh wren is considered Regionally significant
in the Greater Toronto Area (according to TRCA) and is on the list of priority species of
conservation concern for Durham Region. Great Homed Owl should also be added to the list of
VECs, as it is important as an "apex predator".
In Section 7.8.3, it is not clear whether earth-moving operations during site preparation will
involve off-site truck movement. If so, the impact of this on local traffic should be addressed.
Also, it is stated that trips of construction workers are expected to have negligible effects on
transportation Levels of Service (LOS) both in terms of duration and extent. The Review Team
questions the reasonableness of this statement given the already highly unacceptable Level of
Service at key intersections on Brock Road, i.e. is it reasonable to make a highly unacceptable
traffic situation slightly worse?
In Section 7.9.1.2, it is stated that approximately 19% ofthe respondents in the Local Study Area
and 24% in the Regional Study area indicated they might change their decision to live in the
community as a result of the project (a significant percentage). The subsequent analysis notes
that there are concerns about the safety of the Pickering Nuclear Generating Station as a whole
rather than the PWMF II. It is important to recognize that there is a need to build a positive
image of the facility within the community, particularly in light of the longer term future disposal
and the fact that this is the second temporary storage solution and permanent storage on site may
be a reality in future years. This point, while outside the limited scope ofthe EA analysis for
PWMF II, is most relevant in terms of nuclear facility and waste concentration in Durham
Region and the City of Pickering and the potential cumulative impacts that can affect community
image/stigma and safety and contingency planning concerns. It may indeed be the reason for a
relatively high percentage of people being concerned about the facility because of the perception
that temporary storage may become permanent. On June 16,2003 the Nuclear Waste
Management Organization made a presentation to Pickering Council and stated that one of the
options for long-term management of nuclear waste was to store it on the site where it is
generated. It is, therefore, not surprising that people are expressing a higher degree of concern
than might be warranted by the specific project that is currently under consideration.
The public attitude surveys should have included the following additional information:
. Identification of employees of OPG or the Pickering facility. This may have been useful
because there may be as many as 5% ofthose drawn randomly could have some direct
relationship with OPG or Pickering and analysing their responses separately could be
enlightening. For example, removing their responses from the general survey for analysis
may have provided a somewhat different picture of peoples' issues and concerns.
. Gender data.
. Distance from facility.
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2.9 Description and Assessment of Credible Malfunctions and Accident
Scenarios
There is inconsistency in the assumptions of the bounding accident:
. In Section 2.3.3.3, it is stated that "..escort .. and traffic and pedestrian restriction would
be applied to each transfer of a loaded DSC to the PWMF II.". Why is this accident
even considered for the bounding accident rather than dismissed as incredible?
. It is agreed that the consequences (100% release of gaseous radionuclides in DSC) of a
bounding accident are extremely conservative and incredible (probability < 10-6);
however, there appear to be some assumptions made in the dose calculations that are less
than conservative (eg two minutes for NEW exposure; if injured may be difficult to
extract one-self; non-NEW excluded because of low probability but low probability
consequences are assessed for NEW because dose acceptable).
The Dose calculation methodology is for PMWF Phase 1. It appears the same ADFs are used for
Phase II as for Phase I even though it is considerably closer to the site boundary (Appendix D of
Radiation and Radioactivity TSD). The predicted dose to the member of the public at the site
boundary was 0.1 .!Sv for Phase I (assuming 10% fuel element failure) and 1 .!Sv for Phase II
(assuming 100% fuel element failure) indicating that the same ADFs were used.
It is indicated in Section 8.2.4 (P. 8-7) that construction activities will involve best management
practices (BMPs) and environmental management plans (EMPs) for all aspects with potential to
effect the environment. The City of Pickering should have access to these plans and they should
review them if they have not already.
2.10 Assessment of Cumulative Environmental Effects
A key requirement under CEAA is for a project proponent to assess the contribution of proposed
project effects on VECs, and to consider the contribution ofthese effects in combination with
other effects from other projects and activities on the VECs. Effects can be caused by past,
current or existing and foreseeable future projects or activities.
Relatively speaking this is a new dimension to the art and science of environmental assessment
and the understanding and application of this EA component is evolving.
The Review Team considers the presentation in the EA Study Report, regarding the project's
specific contribution to cumulative environmental effects to be generally acceptable, based on
the selected VECs, although it is not clear whether the public was involved in the selection of
VECs.
The EA Study Report does provide a description in Section 9.0 of other projects and activities
within the regional study area with respect to radiation and radioactivity. The description
identifies both past projects and ongoing and foreseeable future projects.
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The assessment of each ofthe VECs in Section 9.0 as to whether a cumulative effects assessment
consideration is warranted and useful. In these sections the proponent provides the rationale for
determining if there is a cumulative effects consideration or trigger for each VEc. The Review
Team generally agrees with the rationale and conclusion provided by OPG, based on the
information provided and assessments presented within the EA Study Report. In particular, the
conclusions that the predicted effects on the VECs do not possess a cumulative effects trigger are
reasonable. Our conclusions are dependent on the implementation of the commitments by OPG
to all mitigation and monitoring and other measures that make up the Follow-up and Monitoring
Program as presented in Section 10.0.
For example, Table 9.2-1 indicates that there are no likely adverse residual effects with respect to
socio-economic conditions. It will be extremely important to follow-up on this environmental
component not only to confirm the assumptions inherent in the analysis but also to recognize a
new airport which could be operational in Pickering within 10 years.
Also, in the Assessment of Likely Environmental Effects and Mitigation, it is stated in terms of
off-site traffic, that the additional 50 vehicles per day during the Site Preparation and
Construction Phase is not expected to be noticeable. It should be noted that traffic levels of
services on Brock Road leading into the PNGS are already unacceptable and any increase in
personal vehicles as well as potential truck movement could result in a cumulative effect.
2.11
Follow-up and Monitoring
The following should be incorporated into the Proposed Monitoring Program.
Public surveys should be conducted after storage building three is in service but also in the first
year after storage building four is in service. In addition, a clear protocol on the planning and
implementation of contingency measures, involving the City of Pickering and Durham Region
should be developed in this stage.
Follow-up monitoring should include a recommendation to inventory habitat for amphibians at
the site. This should be done at the time most appropriate for detecting breeding of some of the
most sensitive species: in early to mid April and again in May, particularly early in the season for
leopard frogs.
Follow-up monitoring should also include a survey to note if the great horned owl is still present.
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Follow-up monitoring should include a recommendation to confinn that habitat for fish does not
occur at the site in the East Wetland. This should be done after the snow melt in April when
water levels are at a maximum.
The probability of an aircraft accident involving PWMF II should be re-evaluated in the event of
the construction of a new international airport in the vicinity of Pickering. Since the Storage
Buildings will meet the requirements of different codes, standards and bylaws that are unlikely to
sustain the impact of an airline crash, it is important to confinn that this remains an incredible
event. The u.S. Nuclear Regulatory Commission is currently studying this issue for nuclear
plants in the vicinity of major airports.
The effect of the additional personnel vehicles and earth moving trucks on the traffic on Brock
Road should be monitored during the construction phase.
Dust and noise monitoring should be conducted during the construction phase to ensure levels
are acceptable.
Monitoring of groundwater from East Landfill and Inert Fill Sites should be conducted
throughout the project as required.
Monitoring of sediment loading on the wetland should be conducted during the construction
phase.
3.0
DETAILED MINOR COMMENTS
The following are minor detailed comments on the various sections of the EA report and relevant
TSDs.
Main EA Document
On Page 2-3, Section 2.2.3: There is confusion as to whether sites reduced to 5, (line 4 paragraph
2) or 6 (line 7, paragraph 2). The discussion of how sites were reduced to final three is also
confusing.
Page 2-7, Section 2.3.1.1: The Maximum sheath temperature of the used fuel (175OC) should be
given here to allow reader to see the margin that exists. Presently this infonnation is buried in
Appendix D of the Radiation and Radioactivity TSD.
Page 2-8, Section 2.3.1.2: Mention is made in section 2.3.1.1 that temperatures under 300°C and
the presence of helium restrict the release of radio nuclides into the DSC cavity. These factors
also limit corrosion of the steel inner lining. However, there is no monitoring of these conditions
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in the Inspection, Maintenance and Aging Management plan. It appears that all efforts are
focused on the outer liner. Some monitoring of inner conditions should be considered, especially
in preparation for future fuel retrieval prior to conditioning for disposal.
P. 2-9, Section 2.3.1.3, last bullet: It would be useful to know the intensity and duration ofthe
fire considered.
Page 2-14, Section 2.3.3.3, second last sentence: This appears to indicate that there will be
restrictions on other traffic during the transfer of DSCs from the PWMF I to PWMF II. These
would drastically reduce the probability ofthe bounding accident discussed in Section 8.3.4.
P. 2-15, Section 2.3.4.1, second paragraph: Same comment as Page 2-14 above.
Page 3-13, Section 3.9.1, last paragraph - Mentions consideration of probability in nuclear
accidents. Should specify both non-radiological and radiological in both construction and
operations phases.
The text in Section 4.2.3 indicates that the notification letters introduced the EA study team,
asked the recipient about a possible interest in a briefing, and included an invitation to attend an
open house. The sample notification letters in Appendix C do not include this information.
Page 4-6 of 4.2.5 Stakeholder Contacts and Scoping Interests indicates, "A list ofthe preliminary
stakeholders and groups contacted to determine their interest in the project, the subsequent
meetings or discussions that were held and the issues or topics raised are provided in Appendix
C." None of these items are provided in Appendix C. There is no indication of which stakeholder
groups had meetings with the EA team, when, and the results. This information is important,
since the meetings were not only intended to identify issues from the organization's perspective
but also to determine their interest in attending an EA workshop, which was later cancelled due
to these responses.
Section 4.2.6.1 indicates that the first newsletter included information on the siting area and the
three layout options. A review ofthe newsletter (provided as part ofthe Project Information
Package in Appendix C) indicates that a map ofthe siting area was included, but no indication or
description ofthe 3 layout options was included. Section 4.2.6.2 indicates that the second
newsletter described the differences among and presented the preliminary evaluation results for
the three alternative site areas. The newsletter in Appendix C indicated that "OPG had now
completed the Site Areas Evaluation and selected the preferred site location for building the
PWMF II." Thus, recipients of the newsletters would have had no opportunity to comment on the
three layout options until a decision on the preferred option had been made. The newsletter did
indicate that the decision was made with input from the CAC and participants at a round of open
houses. The description of the first newsletter in Section 4.2.6.1 should be reworded to indicate
that the description of the three options was not in this newsletter. A copy of the third newsletter
is not included in the Information Package in Appendix C and should be added.
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The description of each round of open houses in Section 4.2.8 refers the reader to Appendix C
for the report on each open house. The report on the first round of open houses indicates that:
. A sample ofthe invitation card and maps of the distribution area are included in Appendix
A;
. A sample of the advertisement is included in Appendix B
. A sample invitation letter is included in Appendix C;
. The 14 information panels from the open house are provided in Appendix D;
. A sample Comment an Evaluation form is provided in Appendix E; and
. A full listing of the written comments and questions provided on the Comment and
Evaluation forms as well as some typical verbal questions, comments and concerns
responded to by the EA consultants and OPG representatives is included in Appendix E.
None of these materials are provided in their respective appendices for the first, second and third
round of open houses. In the first round of open houses the key missing item is the information
on the 14 information panels, for the reviewer to be able to confirm that the three layout options
were in fact described for public input.
In the report on the second round of open houses it indicates (Page 5) that open house visitors
were invited to provide comments on the evaluation ofthe three alternative site locations. Yet,
the report indicates that the results of the evaluation were being presented at this open house
(Page 1 ). With the missing information in hand, it may be possible to dispel the potential
perception that a decision on the layout alternative had already been made in advance of the
second round of open houses. The report on the third round of open houses indicated that there
were no objections raised to the selection of Site Area B, but again the listing of comments was
not available in the Appendix.
Section 4.2.9 indicates that two EA study workshops were planned, but due to the finding that
only municipal representatives were interested in attending one workshop proposed for the Fall
of 2002, these were cancelled, and, in lieu of the workshops, three presentations were made to
the CAC, an existing stakeholder group. It is difficult to determine if this decision was
appropriate, in the absence of information on: which stakeholders were consulted, how contact
was made, when in the process the contacts were made, in what manner the workshop was
discussed and with what information given to participants. Without this information, the
perception exists that the consultation program was unnecessarily abbreviated. Also, a workshop
for municipal representatives, with a written invitation to other key stakeholders would have
been a viable alternative approach. No information is provided on why a second EA workshop
that was planned was not held.
The three presentations to the CAC would have been appropriate in any case, without the CAC
being viewed as a substitute for two EA workshops. Also, was there an intent to include the
public in these workshops?
Section 4.2.9 (last paragraph) states that a summary of the discussions at the CAC presentations
were provided, but such a summary in the text is only available for the last CAC presentation.
Appendix C does contain a copy of one of the presentations made to the CAC, but it is undated
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and some pages begin with "continued" where the original page on the topic appears to be
mISSIng.
Section 4.2.9.2 (October 2002 - EA Update and Evaluation of Site Areas) indicates that details
of the CAC input into the site selection process are provided in Section 6.4.2.2 ofthis report.
This is the first mention in Section 4.0 that some results of the consultation program are located
in a different chapter - consultation results not only from the CAC, but also from the first two
rounds of open houses. Such hidden reference to (important) additional consultation information
elsewhere in the Draft EA Report is confusing. A review of Section 6.4.2.2 follows at the end of
the review of Section 4.0.
Table 4.4-1 should indicate the meeting dates and names of stakeholders for the stakeholder
contacts and scoping interviews in May-June 2002, July-August 2002 and September 2002.
Section 5.2 is much better focused than the Radiation and Radioactivity TSD. The TSD contains
much extraneous material.
The existing noise environment described in Section 5.3.3 of the EA is based on conservative
assumptions and not recent monitoring according to the TSD (Section 4.2.3.2 on P. 14 of the
TSD). In addition, under Section 5.0 "Assessment of Likely Environmental Effects and
Mitigation ofthe TSD, the proponent correctly points out that as long as equipment utilized for
the construction project is in compliance with the appropriate sound emission standards then the
construction activity is considered to be in compliance from a noise perspective. This
demonstrates the need for noise monitoring of construction equipment during that phase of the
follow-up and monitoring program. Also, as discussed in Section 5.2.2.2 of the TSD, the noise
levels generated by the DSC transfer vehicle should be confirmed.
In Section 5.4.3.3 ofthe Main EA, it is not clear why stormwater quality results were compared
against Provincial Water Quality objectives since these objectives apply to receiving streams
(creeks, rivers or Lake Ontario). The text should also explain whether Durham Region
administers stormwater effluent guidelines as part of its municipal bylaws and whether these
guidelines, if they exist would apply to this EA.
In Section 5.4.4.1, sediment quality in the Regional and local study areas is discussed. The text
indicates that some parameters exceeded the MOE 1997 Guideline for Use at Contaminated Sites
in Ontario (GUCSO). Section 4.4.2 "Regional Study Area Sediment Quality" and Section 4.4.3
"Local Study Area Sediment Quality" from the Hydrology, Water Quality and Aquatic
Environment - TSD correctly compare sediment quality to the Provincial Sediment Quality
Guidelines and don't make reference to the GUCSO criteria. This difference should be
explained.
In Table 5.8-1, Valued Components for Environmental Assessment lists community character
and use and enjoyment of property as two sub-components but, in fact, they are also tied to
image and perception both of residents in the Pickering area as well as those who look at
Pickering "from the outside".
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Page 7-3, Section 7.3.1.2 Identified Mitigation Measures: Sentence is incomplete.
With respect to Section 7.13, "Assessment of Likely Effects of the Environment on the Project",
it would be helpful in the section on "Tornadoes" (P. 7-50) and Earthquakes (P. 7-51) to
elaborate on the nature and extent oftornadoes and earthquakes and the design features ofthe
PWMF II to withstand such conditions.
On Page 7-30, it is unclear whether the site preparation earthworks of 600 tonnes/day (Table 2.1-
1) will involve off-site truck movement.
Cumulative Effects TSD
In the Cumulative Effects TSD, the Sewage Treatment plant adjacent to the proposed site was
not mentioned and the potential of a New Pickering Airport within the next decade should be
taken into account in the technical study or the EA. This is relevant in tenns the range of socio-
economic pressures and activities that will be occurring within the regional study area and will
also be affected to the local study area. In addition, it further elevates the public issue regarding
security and the need to ensure contingency plans are in place to deal with any eventuality.
Hydrology, Water Quality, and Aquatic Environment TSD
In Section 5.2 ofthe TSD (P. 37, 3rd paragraph) the text indicates that background values for a
number of metals in near shore sediment exceed the Lowest Effect Level of the Provincial
Sediment Quality Guidelines but the magnitude is not discussed. The text goes on to explain that
minor exceedances are considered "marginally polluted" and that direct management action is
required only when concentrations exceed the Severe Effect Level. The text should include a
discussion of the magnitude of the exceedance.
Table 3.0 on P. 5 ofthe TSD indicates that Construction Phase Stonnwater Management and the
Operations Phase will not interact with "Groundwater Recharge". Given that there will be
hardening of surfaces by grading and paving thereby increasing runoff and decreasing
infiltration, there will be potential interactions and these should be identified on Table 3.0. This
discussion would also apply to Table 7.1-1 ofthe Main EA Report (following P. 7-2).
Page 3 - Could add that there were no habitats. which warranted more intensive sampling, if that
is the case.
Page 12 - Site visit appears to have been made in August, when all habitat on site could be
expected to be dry.
Page 29 - 32, rationale for selection ofVECs in table 4.8.1-1 is reasonable, but could add
additional factor: habitat specificity, to identify whether proposed development is likely to
eliminate species with highly specific habitat requirements.
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Socio-Economic TSD
In the Socio-Economic TSD, pg. 5-17, there is reference to the mobility data for the City of
Pickering and other communities in Southern Ontario but the data is not provided. This is a
general comment as there are some other instances where the actual data should be included in
the Appendices so one can verify the conclusions that are drawn.
A typographical error appears in Table 5.3.1-1 on page 5-26. The title of the table should refer
to "PWMF II" instead of "DUFDS".
On page 15 of Appendix D of the Socio-Economic TSD, the analysis states that people do not
think more frequently about living near the PNGS based on proximity to the Station; and that
women do state more concern than men, but there are no data provided to back up these
conclusions.
Public Consultation TSD
The list of stakeholders in Table 3.3-1 who were sent notification letters which also suggested
they would be contacted for a briefing included federal and provincial government
representatives. Assuming that follow-up telephone calls were made (there is no record), did all
the federal and provincial representatives decline a briefing on the project? The results of
contacts with federal and provincial departments and ministries should be included in Table 3.5-
1 in the TSD.
It is indicated (on Page 10, in the full paragraph) that local environmental organizations and
ratepayer organizations were initially telephoned, not sent notification letters that introduced the
project and asked if they would be interested in an interview or briefing. Such letters may have
sparked the organization's interest before the telephone messaging contact began.
The consultation plan in Appendix A was not followed regarding the contacting of stakeholders
for potential interviews or briefings. In Table 6.1, 33 contacts were identified for possible
briefings and 21 for possible interviews. In the summary of contacts (including federal and
provincial government representatives, Council briefings, MP and MPP contacts) a total of37
organizations were contacted for either a briefing or interview. Also, in Section 4.2.2 of the
consultation plan it indicates that briefings would be given to educational institutions. No record
of such contacts is included in the summary of contacts.
On Page 14 (last sentence in the section), the reference should be to Appendix E, not F.
On Page 18 (last paragraph in Section 3.8.1.2) it states that samples ofthe notification letter,
advertisement, invitation card, comment and evaluation form and a copy of the display panels are
in the Report on the First Round of EA Open Houses, June 2002, located in local libraries.
Similarly, in Section 3.8.1.3 reference is made to written and verbal questions and comments in
Appendix E of the report on the first round of open houses. These samples of communication
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pieces and summary of comments for all three rounds of open houses are not available in any of
the documentation provided for review.
This infonnation should be presented in both the Draft EA Report and the TSD.
On Page 30 (last sentence in Section 3.9) it states that copies of the CAC presentation slides are
included in Appendix G of the TSD. Two of the three presentations are found in Appendix F (not
G), and are provided with the minutes of the CAC for the meetings at which the presentations
were discussed. The minutes would have provided useful infonnation on the discussions at the
CAC, but only every second page is provided. Thus, the discussion on the straw tally that was
said to detennine the CAC's preference for Site Area B could not be verified. Similarly, only
every second page ofthe presentations is provided. No minutes are provided with the
presentation for the third CAC presentation in March 2003.
In Appendix A: Community and Stakeholder Consultation and Communication Plan - Section
4.4 describes the two workshops that were planned for "stakeholders and individuals with a high
level of interest in and commitment to participation in the PWMF II EA." The letters of
invitation to these workshops (even to detennine a level of interest) were apparently not sent.
Both workshops were cancelled in favour of holding three presentations to the CAC (which were
expected in any event through the plans for ongoing stakeholder contact described in Section
4.2.5 ofthe consultation plan).
The decision to cancel the two workshops and use ofthe CAC as a substitute needs to be called
into question.
Terrestrial Environment TSD
On page 3-4, dates for field investigations are too late for inventories of breeding amphibians
(specifically frogs): these must be done in mid-April to early June. Breeding amphibians likely
one of the most sensitive groups in the vicinity and should have been surveyed properly, given
that they may travel between breeding habitat (e.g. the Hydro Marsh) and terrestrial habitat on
the property.
It is not possible to detennine from the Methods whether previous work (e.g. for Pickering A
Return to Service) was done at the correct time for amphibian surveys; the report should state
that the surveys were done at the correct times if so.
On page 3, Natural Heritage System should have additional bullet: alteration oftrophic structure
that supports significant elements (not just effects on vegetation communities, should include
insect communities and rodent communities as well)
On Page 5, methods note that breeding bird surveys were conducted at 0630 to 1030: breeding
bird atlas and Canadian Wildlife Service protocols state surveys should start at 0500 and end at
1000.
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On Page 5, Broader Regional status should have been assessed according to the Toronto and
Region Conservation Authority (TRCA) list of fauna species of concern in the Greater Toronto
Area as well. This list is specifically applicable to the rapidly urbanizing areas around Toronto.
On Page 5, figure numbers are wrong: references on page 5 to local and regional study areas are
to figures 2.2-1 to 2.2-3, figures numbered 2.3-1 to 2.3-3.
On Page 5, references 0290 and 0291 are missing from References list (Section 9: list only goes
up to 0289).
On Page 10, relevance of local study area and regional study area to these evaluations is obscure.
The two most significant features in the local study area (as shown in Figure 2.3-2) are
Frenchman's Bay and the Hydro Marsh. The statement here that "in the local study area, most of
the vegetation has been removed as the land has been developed since the time of European
settlement", and the subsequent discussion, do not highlight the significance (considerable,
especially given the urban setting) of these areas at all. These areas are also missed in the
Regional evaluation table (Table 4.1-1).
On Pages 13-14, mention of area (ha) of each of these vegetation blocks would be helpful in
determining habitat significance.
On Page 15, no mention of whether amphibians use the marsh for breeding: because it's not
known? (noted that no standing water present, but study team didn't look in April-May when it
could be expected to provide habitat for breeding amphibians). There is no appendix listing
amphibian species, though a few are noted in the section on Herpetofauna (page 18).
On Page 16, green heron and black-crowned night heron L3 (significant) in TRCA.
On Page 17, under marsh: black-throated green warbler and marsh wren, noted in marsh habitat,
are both significant (L3) in TRCA.
Text mentions that they were migrants, but the species list in Appendix C does not distinguish
migrants from breeding species. There is no mention of other field visits to detect migrants, the
only field visit recorded in Methods was on June 25 which is a time suitable for breeding birds.
If the marsh wren was noted during this visit, it was in suitable habitat at a suitable time of year
and should be considered a possible breeder. Marsh wren is significant in Durham Region and in
TRCA Greater Toronto Area list.
On what basis is Northern mockingbird a regionally significant species? Reference 0297 not in
reference list. It's considered L4 (not significant) on the TRCA list.
On Page 23, Table 4.5-1: 2. Ecological Importance: should add to "critical component of
ecosystem (e. g. apex predator or dominant prey species)"
4. Conservation Status 1 =add Regionally rare according to TRCA
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5. Degree of Exposure c) breeds in the study area: should receive more weight if yes, because of
vulnerability of eggs/nestlings/fledgelings
6. Habitat specialist should have higher weight
Not much weight is given to species that nonnally are of concern to municipality and province,
e.g. those that have the most stringent habitat requirements and are most likely to be lost as a
result of development.
On Page 25, Table 4.5-3 What is the basis for inclusion of candidate VEC species in this table?
Great homed owl, green heron, black-throated green warbler, willow flycatcher, are mentioned
in text but not included in this table: all could be candidate VECs, and there is no consistent
rationale for excluding them (e.g. black-throated green and marsh wren were both said to be
migrating, yet marsh wren was included while black-throated green warbler was excluded).
The great homed owl should not be dismissed so summarily: it was confinned breeding
according to the text (page 16). It is not always possible to detennine what criteria birds use to
select habitat, but ifthey fledge young, it was presumably the right choice of habitat however
atypical it seems to the human observer.
On Page 25, Table 4.5-3- Generally, this table is not very useful. Selection criteria for VECs has
given the most weight to the most common and adaptable species that are likely to be least
affected by development, contrary to the direction usually taken by the province and by
municipalities. Dependence on specific habitats, especially for breeding, should have more
weight because loss of specific habitat, and therefore loss of a species that depends on that
habitat, may have regional implications.
It is not obvious how the species are ranked in this table, as many organisms have the same score
but are in different parts ofthe table, and there are many species that have the same score as the
chosen species.
(Ranking in table 4.5-3 has apparently been ignored anyway and a species that is 1ih on the list
has been chosen as the upland representative VEC).
Page 28 should add red-tailed hawk or great homed owl to selection ofVECs, given that
importance of apex predator is stressed in Table 4.5-1 (section 2), and that red-tailed hawk
ranked highest on table 4.5-3
See comments for marsh wren under Page 17, marsh wren should be a VEC if it is a breeding
speCIes.
On Page 32, potential for sediment-laden runoff during construction to enter adjacent natural
(especially wetland) habitat should be considered here.
Page 32-33, Section 5.2.1.1: could consider recommending confining construction to fall and
winter to avoid impacts of earthworks on wildlife
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Need recommendation for an erosion and sediment control plan to control runoff to natural areas
during construction.
On Page 38, should the diamond in the Natural Heritage System column oftable 5.2.3-1 be a
square? (if not, should put this symbol in the legend).
On Page 39, it would be useful to evaluate the effects on the apex predator as an additional VEC
(great homed owl or red-tailed hawk): these species may hunt for small mammals etc. on the
open part ofthe site.
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