HomeMy WebLinkAboutCAO 14-00�,116 ' Clfy o�
' REPORT TO COUNCIL
FROM: Thomos J. Quinn DATC: Octobcr I I, 2000
ChiefAdministmtive Officcr
REPORT NUME3GR: CAO 14-00
SUBIECT: Pickering Nuclenr Gcnerating Stution, Pickcring "A" Retum la Scrvicc
- Comments on the Finol Enviranmentul Asscssment Scrcening Rcport,
Volume 3; Addcndum
- Filc: UT 3540
RECOMMENDATION:
I. Thnl Council receive RcpoA lo Council CAO 14•00, which Reporl includes as
Attnchment No. I, commeNs from the City's Pecr Review Team on the final
Gnvironmentnl Assessmcnt Scrccning Rcport, Volumc 3: Addcndum, for the Retum to
Scrvicc oFPickcring "A".
2. That Council cndorsc lhc Pccr Rcvictv Tcam's cnmmcnts on thc final Gnvironmcntal
Assessment Screcning Re�wr1, Volume 3 anJ fonvard these comments to thc Canadinn
Nucicar Safcty Commissiun for considcmtion ut ihcir licaring on bccembcr 14, 2000.
3. That Council tccommcnd lo thc Cnnadiun Nucicar Sufcty Commission (CNSC) that it
rcfer the project lo thc Ilonoroble Da��iJ NiJcrsnn, Pedcrol Minister af the Gnvironment
requcsting that n fcderal pancl revicw or mcdinlinn proccss be initinted on ihc grounds
thnt Ihe review process undertuken by CNSC staff may not have been sulTiciendy
objcctivc, nnd that thc cxistcncc of significant dutu gaps in thc unJcrstnnding of thc
cnvironmcntnl conditions uround 1'NG5 calls into yucstion the conclusion reached by
CNSC stal� ihnt thc restart of PNGS "A" is not likcly to causc significunt ndvcrsc
cnvironmcNul cUccts.
4. Notwithstanding rccommcndation 3, in thc evcnt CNSC is inclincd to approvc thc
Gnvironmental Asscssmcnt, that Council rccommcnd to thc Commission Ihat il direct
CNSC stn(t'to rcvicw nnd revisc ihc planncJ follow-up progrnm as ncccssary, to ensurc il
uddrcsses ihc significant data gaps idcntificd by thc Ciry's Pccr Rcvicw Tenm, and
furthcr, ihat thc opproval of thc Ciry of Pickering bc obtaincd for thc reviscd follow•up
program prior to thc resinrt of PNGS "A".
5. Natwithslunding recommendntion 3, in order to protect the intcrests of the Ciry of
Pickering, lhal Council authoriu sWff to negoliate a Community Uenefits Agrcemcnl
with Ontnrio Power Generation on n without prejudice basis.
6. Thnt n copy of this Rcport to Council CAO 14-00 bc fonvnrdcd to thc Cnnadiun Nucleaz
Snfety Commission, Ihe Honornble David Anderson, Pedernl Minister of thc
Bnvironment, thc Ontnrio Powcr Gcncralian, and the Honourable Dnn McTcague, id.P.
Pickcring-Ajax-Uxbridge.
OR[GIN;
On August 31, 2000, the final Environmcntal Assessmcnl 5crcening Report, Volume 3:
Addendum, wns ofticially releuscd by the Canndiun Nuclear Snfety Commission (fomicrly
Atomic Encrgy Control Donrd) conccming the Relum to Scrvice of PNGS "A", Commcnis on
the finnl EA must be forwarded to thc Canudian Nucicur Snfety Commission by Novembcr 14,
2000 for considemtion nt thc Deccmbcr 14, 2000, public hearing.
� Report to Council CAO 14-00 Dnte: Octobi:r I I, 2000
' � �n7
Subject: Commenls on Finul BA Scrcening Report, Volume 3: Addendum I'age 2 of 7
AUTHORITY:
Canudlnn Environmenlaf Assessmnnl Acf
Nuclear Sajeq� nrtd Control Ac� (formerly ihc A�omtc Ener�,ry Conlrol Ac!).
FINANCIAL IMPUCATIONS:
Ontnrio Power Gcnemtion has agreed to cover the cost af the City's Pecr Review Team lo an
upset limit of 598,600 plus disbursements. Accordingly, there hnve becn no finnncial
implications to Ihe Cily for the Peer Review Tcam's parlicipation in tlic environmentnl
ossessment process, other than u E3,200 Council approved expenditure endy this ycar to revicw
the Final Scope of Assessmcnt (ihis work was bcyond what OPG had agrccJ to fund).
EXECUTIVE SUMMARY:
This Report coNr.ius the stuff und Peer Revie��� Tcam comments anJ recommendations an ihe
Environmentnl hsscssmenl Screcning Itcport, Volume 3: AJdendum, on ihe Retum to Service of
PNGS "A". Volumc 3, ulong with Volumcs I und 2 rcicascd enrlicr Ihis ycur, mukc up thc final
GA Scrcening Rcport for Ihis project.
7 he Revicw Tcam's comments un Volumes I unJ 2«•crc completed in June, and were fonvarded
at thnl limc to thc CNSC us thc Cily's cnmments on thc dr�ll GA (scc Rcport to Council CAO
12-00, and Council Rcsolution NIOG/00, ilem 8). 'fhc Rcvicw Tcam's commcnts on Volumc 3
nrc uttachcd as Auuchment No. I lo Ihis Itc�rt.
With respcct Io Volumc 3, Ihc Pccr Rc��icw T'eam noies Ihut Ihcrc il�rl`iliS lD hnvc bcen
significnnt collubomlion bcl�sccn CNSC stulT and OPG in prcpnring thc JacumcnL Thcy also
find that thc mnjority of responses in Volumc 3 arc inudcyualc or show paor Icvcls of
understanding of basic scicntific informalion. 'I'his scvcrcly compromiscs thc validity of Volumc
3 nnd the entirc environmcmnl assessmcnt.
Moreover, the Pccr Revicw'I'cam concludcs thot Volumc 3 fuils to odcyuately recognizc and
respond to concems rcgurding lhe existence of significnnl dnta gaps in Ihe unJerstnnding of
environmcnml conditions in and around PNGS. "fhc exisicncc of Jain gups undcrtnines the
credibility of thc conclusion rcuchcd by CNSC staff Iha1 ihc restart of PNGS "A" is not likcly to
cuuse significant advcrsc c�'ccls (Ihis conclusion may possibly bc corrcct, but it rnuy also
possibly be wrong). This siluntion demonslrates thc nccd for n fully indcpcndcnt review of thc
project.
SIafP recommend that Council cndorse the Pcer Review Tcam's comments on Volume 3 nnd
fonvard these comments to Ihe CNSC for consideration ut lhc December 14�h hcaring. ln
addition, it is rccommcndcd thnt becnuse of concems respccting the objectivity af thc revicw by
CNSC stnff, und lhe continued cxistence of significant data gups, Council ask the Commission lo
rcquest the Pedcrnl Minister of Environment lo refcr thc projcct to u mcdiator or review pancl in
accardunce wilh ihe Canadlun EnvJronmenlal �issessmenf Acf,
Notwithsmnding ihese primary recommendations, in orJcr to protcct thc Ciry's inicrcst, staff has
provided two nddilional rccommendutions for Council's considemtion. Pirst, thnt in the event
thc Commission is inclincd to approvc ihc EA, that CNSC staff bc dircctcd to rcvicw und rcvisc
thc planncd follow•up program as necessury, to cnsurc it addresses Ihc siQnificunt data gaps
identificd by thc Ciry's Peer Revicw Tcum, and that thc rcviscd program bc approvcJ by thc City�
of Pickcring prior to thc restarl of PNOS "A". And sccond, thnt stnfl' bc authoriud to begin
negotiating a Community Ocnefits Agrccment with Onmrio 1'owcr Gcnemtion on a without
prejudicc bnsis,
O�$ ,; Report to Council CAO 14-00 Datc: Octobcr I I, 2000
Subject: Comments on �inal EA Scrcening Rcpon, Volume 3: Addendum I'agc 3 of'7
DACK6ROUND:
The Environmental Assessmcnt Process
The operntion of the PNGS "A" fncility has bern regulnted by thc Canndian Nucicaz Safcry
Commission (fortnerly lhe Atomic Energy Control Bourd) since the four "A" reaclors bewme
operationnl in the early 1970's. At the end of 1997, thc PNGS "A" reactors werc placed in a
non-routine shutdown stntc.
In 1999, OPG rcquested pertnission to retum the Pickering "A" reactors to service. Purt of the
resmrt process involves the successful completian of n scrcening Ievel environmentul nssessmcnt
under the Canadinn Environmenlul Assessmc�i� Acl. If the EA is approved, OPG will lhen necd
to apply for nn appropriate opemting liccnse beforc bringing the PNGS "A" rcactors back to full
powcr.
Earlier this year, OPG and ils consultants (Golder Associates) preparcJ a two•volumc Draft
Environmenlul Assessmenl (GA) Report, along �vith a number of othcr lechnicnl backgraund
repods. Thesc documcnts werc rcicased in May for comment. Pollowing this, our I'ccr Rcvicw
Tcam prcpared comments on thcse documents, and in 1une, thc Pecr Review Tcam's commcnts
were endorscd by Council nnd fonvnrded to CNSC for wnsidemtion. Al the same timc, Council
requcsted ihc f'edeml Minister of Gnvironment to rcfer thc project to a review pancl or mediator
under the Canndi�m F.nvlrnnmenlnl Assesrmrru Acf, in orJer to address the concems raised by
thc Pcer Rcview Tcum. 'fhe Pcdeml Minister did not make a decision on this refertai rcqucst.
To complete the a5sessment proccss, in late August, CNSC stafl' rcleased a Volume 3:
Addendum to includc rcvisions, crratu, aJJitions und upcl�ucs lo Volumes I and 2. Taken
together, Volumes I, 2 and 3 make up the final IiA Srreening Rcport. It shoulJ be noted that
CNSC stnfT hnve Ihc responsibility of preparing Ihe lin.d GA. I lowevcr, Volumcs I nnd 2 of the
EA wcre prcparcd by OPG nnd ils consultants, «hilc only Volume 3 was prepared by CNSC
smff (but with input from OPG, OP(i's consultants, nnd ulhcrs, including lhc Gcological Society
of CanuJa nnd Nalural Rcsourccs Canada).
Comments on thc finnl GA will Ix considcrcJ by thc Commission on Dcccmbcr 14'h nt u public
hearing to be hcld in Pickcring. Pollowing thc hcuring, thc Commission will mnkc a decision.
Undcr thc Cnnndinn C:nviramicNnl As.se,ssmenl Arf, lhc Cammission has thrcc moin choices:
I. to acccpt lhc EA und allow thc projcct to procced lo thc liccnsing slugc;
2, to not uccept thc EA and nut ullow thc projcct to procced to the liccnsing stngc; or
3. to recommend to thc Pederal Minister of Ihc Environmcnt thut thc projcct bc
rcferred to n review pancl or mcdiator.
If refcrred, thc Fedeml Ministcr of the Environment hns thc nuthority to ncccpt thc rcqucst nnd
initiate a pnnel review or medintion proce5s. The Minister can nlso refuse the rcqucst and nsk thc
Commission to deal direcUy with Ihe concems.
If the Commission accepts lhe GA, lhe decision is final. Any further uclion would relnte to
conditions of approvnl nnd/or the subsequent licensing proccss. dy nccepting the EA, in cfTecl
thc Commission would bc agrecing wilh the CNSC staff rccommendntion thnl thc projcct is not
likcly to cnuse significant adversc environmcnlal effccts, taking inlo considcration thc proposed
mitignlion measurcs and planned follow•up progrnm.
If the EA is accepted, OPG expcct to be in n position to submit an applicalion for un opernting
license for PNOS "A" enrly in 2001. Wilh no dclays in the issuancc of an opcmting liccnsing, it
is OPa's intent to sturl onc PNGS "A" reactur by thc end of 2001.
' Report to Coudcil CAO 14•00 Datc: Octobcr I I, 2000
Subject: Comments on Finnl EA Screening Report, Volume 3: AdJendum ,, � n9
tabc4of7
CNSC Slaff Comments and Recommendafions
The CNSC stafT repoA on the EA for the restnrt of PNGS "A" wus rcleased in September, und
was presenled on October 5'" lo lhe Canadinn Nuclear Safcry Commission. At the October 5'"
meeting, ihe Commission did not comment on ihe report, or nsk any questions of CNSC staff.
All discussion of the matter was deCerted to the public hcaring in Pickering on Decembcr 14'",
The following summarizes the position of CNSC staff.
• An EA under the Canadinn Envlronmenral Assessmenl Act docs not represcnt the cnd of the
environmenWl impact management process. An EA is a planning excrcise that ollen requires
cureful follow-up to verify the predictions of environmental e(Tects und ta ensurc
ef'fectiveness oF impact mitigation measures. This is why the devclopment of a follow•up
program wns rcquircd as part of thc scope af assessment. Por the rcstart of PNGS "A", the
subsequenl licensing and compliance process provides nn uppropriate framcwork in which to
ensure a follow-up program is implemented.
• The Screcning Report meeis nll of the rcquiremenis of CGAA and the scopc of nssessmcnt.
Certnin issucs idcntificd by some revicwers arc be}•ond the scopc of ihe nssessmcnt, and
therefore wcrc not requircd to Ix adJresscd in the finul �A. �These issues reluted to ihe need
for and altcmalives to thc project; the selection of se��cre ncciJent scrnarios for assessment;
ihc nccd to asscss outstanding sa(cty issucs relalcd lo generic uclion items; and thc need to
assess "planncd" improvcmcn�s to �: madc prior lo thc rcturndo•scrvicc oF 1'NGS "A".j
• At the cndicr scoping stage, a rcferral of ihe projecl to a fedeml revicw pancl or medintor
woulJ havc bccn prctnaturc. I laving complcted thc rcvicw, a rcfcrral to a rcvicw pancl or
medintor remains um��arrantcJ.
• Allhough cnvironmcntal sluJics and investigations necd to continuc at PNGS, there is
su�cicnt infommtion nvailabic lo makc rcasonahlc prcdictians about thc ovcrall likclihoad
and significuncc of eftects. 'I'he infi�rmation availahle provides an adcquate basis for
assessing cnvironmcnlal cl'fccts for thc puryx�sc of nn assessmrnt under CGAA, nnd lhc EA
hns bccn abic lo iJenlify the IikclihooJ und significancc of the ndversc effects with
rcusonnblc ccrtainty.
• Conceming the 160 issucs prcviously identificJ by Ihc public, no significant udversc eUects
on ihe environmcnt werc identifieJ in thc review of Ihesc issucs. Sevcral of ihcse issucs will
continuc to bc monilurcd by CNSC s1afT:
• Residual ndverse cumulativic efTccts ure not likely lo have a significant efTect on valued
ecosystcm compancnls or on humans. In addition, suflicicnt Icchnology and cxpericncc will
be availoble for the fumre decommissioning of PNGS "A",
In the finnl analysis, CNSC smff concludcs thut the projccl, taking into uccount tl�e nppropriate
mitigating mcnsures, is not likely to cnuse significnnt ndversc environmcntal effects. Thcy
recommended thut the Commission accept the conclusions of the EA, and nllow the projeet to
proceed to lhe licensing stuge under the Nucleur Sajery and Conlrol Act.
In terms of the planned fallow-up program, CNSC staff recommends thut it be further delailcd in
consultation with local community groups, and integmtcd into the subscquent licensing nnJ
complianee process. The main components of the follow•up progrnm ure outlincd in Volume I
of the EA Rcport (see Attuchment No. 2). Thc program included 14 activities to bc implementcd
prior to the rcstnrl of PNGS "A", and 18 nctivities to bc implemcntcd aflcr rcstart.
Peer Revtew Team Comments and RccommenJaHona
Thc Pecr Rcview Tcam has recently revicwed and commenlcd on Volumc 3 of thc GA (Sea
Atlachment No. I). Thcy provided both ovcrall commenls and spccific commcnts by discipline.
• RepurF to Councii CAO 14-00 Datc: October I I, 2000
01 �. Subject: Comments on Finnl EA Screcning Report, Volume 3: Addemlum Pugc 5 of 7
Thesa comments should be considcred in addition to thc comments provided by the Review
Twm on Volumes I and 2(see Report to Council CAO 12-00).
Wilh respect to Volume 3, the Peer Revicw Tenm's overall comments nrc providcd undcr four
muin headings. A summary of these comments Collows.
i. Authorshia: CNSC staff claim to be tha °nuthor' of Volume 3. Howcver, the
responsibility for praviding technical comments was largely deleguted to OPG and its
consultnnt. CNSC staff then edited ihese rcsponses. This diminishcs uny third parly
independence of the regulutor (CN3C) from the proponent (OPG). It does not nllow
for nn imparlial urm's-length revicw of OPG's work, and compromiscs the credibility
of the conclusions.
2. Adequacv of Resoonses: No defuifrd responses urc providcd in Volume 3 to many
complex issues und concems. Responses are short, brief and �vilhout supporting
nrgument. As well, seveml responses show inadcquatc comprehension of ihe
scicntific issues involveJ and Ihc significunce of existing data gaps.
3. Seleclion of Commcnts: CNSC stnll� indicatcs Ihat all comments rcccivcd are
included in Volumc 3, along wilh thc CNSC stafT responsc to cach of thc commcnts.
In fact, many comments have becn cxcludcJ Gom Volume 3 or have been severely
edited. Responses arc provided only lo selecleJ comments.
4. Need for an indcncndent 1'ancl Re�•iew: 'fhc Pccr Rcvicw 1'cam has fundamental
concems with ihe nbsence of an objeclive re�•icw of thc responses lo comments made
on the drafl environmcntal ussessmcnl. Mnny issucs have nat been addresscd
aJcquately, or in an objcctivc faahion bccausc responscs arc providcd primarily by
the proponcnt. lliis undermincs the credibility of the GA process and provides
furthcr justification for an Indcpcndent Puncl Rcvicw whcrc comcntious issucs can bc
diswsscd and resolveJ in a subslanlivc and objcctivc manncr.
The following summurius thc Pccr Revicw'('cam' s specific comments by individual discipline.
Hvdro�eolo�;v: Thcre is Iess than an adequate understanding of thc hydrogeology at PNGS
and thcre is no cvidcncc that thc roles of kcy fcatures urc quantitalivcly understood. There
arc also crrors in thc intemrctation of basic hydro6wlogical infortnation. It is Jiflicult to
accept the report's conclusions with any levcl of confidenee.
Radioactivitv: The Pccr Review Tenm continues to have doubts about the precise accurncy
of thc results. Neverthcless, the estimates ure conservative [thc scnsitivity of somc
monitoring equipment rcsults in highcr than actual readings] and lhe existing mdiution
environment hns been well characterized. Consequcntly, the CNSC cnn justifinbly conclude
that with regard to mdioactivity, the restari will not significantly impact the environmcnt
under nortnal opemting conditions.
Eurthauuke Risk: This rcmnins a very scrious issue. Therc is a lack of npproprintc
gcological dam on which to base dcfinitive stntcments of enrthquakc probability and scismic
risk. 7'hc Screening Rcport docs not appcur to rccognizc or ncccpt this largc and patcntially
serious duW gup. The vnlidity af the probability estimutes of enrthqunkes at, or in the vicinity
of PNGS is sevcrcly compromised. Thc existcnce of lurge datn gaps in understanding thc
geologicul setting and earthquuke risk at PNGS cnn only bc rcsolvcd by indepcndenl lhird
pMy scrutiny.
Aquatic Diotn and Lake Imoacts: The inndequucy of rcsponses in Volume 3 to comments
mnde on the lack of dnta conccming thc aquutic environmcnt surrounding PNdS simply
underscores the existcnce of significunt data gaps, Rcsponses nrc ulso difficult to asscss
• Report to Council CAO 14•00 Qatc: October I I, 2000
Subject: Comments on Finul EA Scrcening Report, Volumc 3: Addendum Pnge 6 of 7 O 11
because of considemble editing and reinterprctntion of what the Pecr Review Tcam slated
eurlier and whnt wns originaily reported in the Dmtt EA report. It is also clear that the
deficiencies mised by the Peer Review Team with regard to the use of historical Jata havc
not been uddressed. Of concem nlso is the rntiunule for excluding information on pinnkton
nnd mnerobenthos. Volume 3 does not shed any new light on any of the issues and concems
previously raised.
Public Heulth lssues: The nssessment of public health concems has been minimal at best.
Essentially, the response to identified concems is to point to planned follow-up studies. As
well, muny af the rcsponses to earlier comments rcgarding the lack of inethoJologicnl Jetail
are very weak. Standard reporling systems um not always lhe most uppropriutc reporting
mechanisms, particulnrly when trying to communicate to a broud lay audiencc.
In conclusion the Peer Review Team reitemtes thnt Volume 3 fails to ndequotely recognize nnd
respond to concems rcgarJing the cxistence oF significant datu gaps in the understanding of
environmental conditions nround PNGS. This siluation undermines thc credibility of ihe
conclusiom m�Je by CNSC that the restart will not hnve nny significant ndverse effects on the
environment.
Staff Commcuts
StaR' concur with the Peer Review Team's linding and conclusions conceming Volume 3 of the
EA, parlicularly wilh respccl to thc upparcnt lack of "objcctivity" on bchalf of CNSC in
rcviewing OPG's work, as wcll us with res�xct to the conlinucJ existencc of dala gaps in
environmcntal knowlcdgc and infurmation.
Staff thcrcforc has ta•o kcy recommcndations for Council's wnsidcration:
• That Council enJorsc thc Rcvicw 'I'cam's rc�rt and fonvnrd it to the Canadinn Nuclear
Sufcry Cammission for considcration al thc Dcccmbcr 14'h hcuring in Pickcring; and
• That Council rcquests the CNSC to nfcr thc maticr to thc Federul Ministcr of the
Environment Cor nn indepcndent panel rcview or mcJi�tion process under the Canadian
Envrrnnr.rrnlul Assessment Art.
A slrong nrgument could bc put fonvard to thc Commission in support of thc recommcndution
For an indepenJcnt panel rcview or mcdiulion process. I lowcvcr, despitc our best efforts, there is
still n possibility lhat the Commission may rcjcct Pickering's position, and instead, inkc the
ndvise of ils sw(f. Approval of thc EA would allow thc projcct to proceed to thc licensing stnge.
Further input of the City would then conccivably be rcstricted to discussions on the proposed
follow-up progmm outlined in Volume 1, potentially at Ihe discrction of CNSC stn(f.
[n order to protect the City's intercst, it is therefore nlso appropriate nt this time for Council to
consider un additionnl recommendation in ihe event the EA is approved. Should this happen,
staff recommend thnt Council rcquest thc Commission to dircct its statf to revisc the planncd
follow-up program ns necessury, to ensure it addresses the significnnt datn gaps identificd by the �
City's Yecr Review Teum, and also, to obinin the upprovAl of lhc City of Pickering for thc
revised program prior to the restart of PNGS "A".
One additionnl mntler should nlso bc addresscd at this timc. Council will rccall thnt in March of
this yenr OPG relcascd u report on the economic impacts of the Darlington and 1'ickering
Nuclenr Genemting Stations. Juck Gurtley Consulting undertook a peer revicw oF thut rcport for
tlie Ciry. A number of valid commenis werc mndc by Garticy, including the obscrvution thnt os
thc host municipulity, Pickcring should considcr ncgoliating u fortnnl agrccment with OPG, such
ns whot waa done in ihe casc of Darlington. An ngrccment bcnvecn Pickcring und OP(i, among
other multcrs, could address the fuct that PNGS providcs rclativcly small cconomic bcnefits to
thc City. It could alsa denl with thc issue of adcqunte compensalion for thc uscd dry fucl stomge
facility located at PNOS.
� Repo�tto Council CAO 14-00 Qute: October i I, 2000
012 �' • '
Subject Comments on Finnl EA Screening Report, Volumc 3: Addendum Pagc 7 of 7
It is thercfore niso suggested that n recommendntion ba endorscd by Council uuthorizing staff to
begin negotiuting u Community Benefits Asreement with OPO on a withaut prejudice basis.
Tha staff negotiating team woulJ include the Chief Administrativc Officer, the Director,
Corpornte Services & Treasurer; the Division Head, Corporata Projects & Policy; and Reble,
Ritchie, Green und Ketcheson, the City's legnl counsel.
ATTACHMENTS:
1. Peer Review Team comments on Volume 3: Addendum to the Final GA.
2, PNGS "A" Retum to Service — Follow•Up Program (from Volume I of the EA)
Prepared By:
�
v \
Go o tdt
P jc Co•ordinntor
Tho� u
k
Division HcaJ, Corpomtc Projecls ' licy
T1Q:jgr
Attachment
Copy: Dircctor, Corporalc 5crvices & Treasurcr
Division Hcad, Corpomtc Projccts & Policy
Reble, Ritchie, Grcen nnd Ketcheson
Recommendcd for thc considerntion of Pickcring
City Council
omas J. Quinn, Chicf Admimstra vc Officcr
i.�rioutrrx�aerraowercuw.uix:
Approved / �ndorscJ By:
l
umas J. Quinn
Chicf Administmtivc Officer
• • ATTACHMENT� � TOAEPOATIf���4-°°
� ' ' Q��o� �0 013
October 2nd, 2000
�Ctly of Pickering Pccr Review Tenm Comments on:
Pickering A- Return to Service Envirunmental Assessment
Screening Report
Volume 3: Addendum
PRT doc 011
Dr. N. Eyles University of Toronta
Dr. P. Chow-Fraser McMaster University
Dr. S. ElUolt McMnster Un(verstly
Dr. C.H. Eyles . McMester Uatversily
Dr. J. Hurvey McMaster University
Dr. K. Howard University ot Toronto
Dr. W. Morris McMester Universily
Mr. M. Doughty AdminLsiraHve Asststent, University of Toronto '
�
,
• • ATTACHMEMIf � TO REPOAI#�O �4'OO
0�4� ' � ' p�a o� �d
OVERALL COMMENT
1. Authorship
The Addendum states that it consists of thc CNSC's responses lo outside comments o� OPG's
DraR Environmental Assessment Rcpan (DGAR) implying third party, independcnt scrutiny.
This creates the impression of nn impanial arm's length review by CNSC. This is not the case
as OPG and Golder l�nve provrded the respon.res to thc majoriry of aulside technical
comments. In other cascs, responscs appear to have lxcn wrilten by ihc CNSC such as when it
is sWtecl in several responses (e.g. N 397), that there will not be a full environmental revlew,
that all issues have been aJdresscd and that existing data and methocfology are udequalc. In
nddition, therc is Ihc vcry conNsing siwation whcrc CNSC apparcntly responds to commenis
by the CNSC itsclf (c.g., pp.l-58). Presumably, lhis is CNSC e�liring of OPG's response to
comments by CNSC siu(f.
Page I-2 of Volumc 3 stales "As permiltcd unJer Seclion 17 oF the CGAA, CNSC dcicgated to
OPG thc developmcnt of preliminary responscs to nil CNSC staff comments and many
of the other technical commcnls raisccl during ihe revicw of draR CA Rcport. CNSC staff have
reviewed, flnalised and accepteJ the responses". The Screening Report, Volumc 3 Addendum,
is published under thc authorship of the Canadian Nucicar Safety Commission. Responsc N28
for example, cicarly slates that "as this is a CNSC Repart...". liowever, most of the volume
has bcen prepared by OPG/Colder,
Thc PRT suggest Ihat the Ciry of Pickering critically revicw Ihe wording of Ihe Decision, dated
Sth September, 2000 (entitled Pickering NGS-A Cnvironmental Asscssment) from the
Directorate of Reactor Regulatiou nnd Directorate of Environmental and Human Performance
Assessments, to members of the Canadian Nuclear Safety Commission (CNSC File N 26-1-4-
IS-1), On page 18 (Section 7, Public Consultation Process) it states that "stnkeholders have
expressed concerns about what they view as wide gaps in critical intormation that preclude
reasonable assessment conclusions". Funhermore, "CNSC staff have adJressed these issues in
the EA and Addendum". This apparently is not the case as the ruponses provided in thc
Addendum wete writtcn largciy by 01'G and Colder. Note also that "CNSC staff receivni
requests from the public to refer the project to the Minister of Environment for a referral to an
independent panel....CNSC staff wnsidered such a referral was premature, and that issues
raised could be adequately addressed by tlie CNSCstaJjin the Screening Report". Again, this
is not correct since by their own admission, CNSC sta(f mcrcly edited und accepteci
OPG/Goiders responses, ls the conciuding statement "Having camplcted the Scrcening Repon,
CNSC staff bctleves that a referral to a review panel ramains unwnrrantcd" mada by CNSC or
OPG/Golder?
The PRT would arguathat CNSC should have proceedal to Ict OPa address outside concerns
raised by the PRT, stakeholders and olher agencies in a sepurate Report and then dccided
. ' . . ATTACHMENT� � TO AEPORTt��P6? �4•oc� 015
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itself, at arm's length in the role of an independent ndjudicator, whether OPG's responses were
appropriate and whether all concems had been properly addresseJ. Dccause this was not donc,
any pretence of a third party 'review' by CNSC must be laid to rest since the official CNSC
response is appnrendy the work oJ�he proponen�.
Thc PRT urges ihe Ciry of Pickering to ascertain exactly ivho authored the "CNSC" responses
jor ench ojlhe 584 responses lisred in Volume 3, There is thc outwnrd appearnnce of a
partnership betwecn OPG and CNSC which is fun�amentally at alds with Ihc fair, unbiasecl
�ssessment process demanded by, and pramiscd to the Pickering community.
2. Adequacy ot responscs
No de�nlled responses are provided in Valume 3 to the many complex issues and concerns
raised by the PRT, outsiJe agencics and s�akeholders. Responses are short, brief and the words
'adequale','su(ficient' 'appropriate' aro usecl repeatcdly to descrihe the existing OPG database
without supporting argument. This is Jespite thc PRT and others having providcd lengthy
detniled revicws idcnti(ying significant Jatagaps in ihc environmental database for PNGS and
its surcoundings.
Another concern is the level of lechnical expertise shown by many responses to comments
involving complex issucs. Scveral responscs show inaJequatc comprehcnsion of the scientific
issues involved and thc significance of cxisling dalagaps. This is particularly apparent with
regord to assessmcnt of thc Aquatic Environment surrounding PNCS and
Geology/}lydrogcology and Seismicity (see detailed commcnts below).
3. Select(on of commenls
Volume 3 of the Environmentai Assessment Screaning Report ("Addendum") contains the
statement on page G-1 that the report presents "all comments received by the Canadian
Nuclear Safery Commission from agencies, the public, and other stakeholders along with the
CNSC response to each of the commenls", The PRT notes that, in fact, full writtcn statcments
submitted by the PRT and other stakehoiders on carlicr Preliminary and Draft Environmenlal
Assessment Reports do not appear in Volume 3. The statemenl.a have been severely edited;
responses nre provided only to selected comments.
4, Need far Independent Poncl Review
The PRT has fundamental concerns with the absence of an objective review of tha responses of
OPG/Golder to comments made by outside ugencies and stakeholders on ihe DGAR. in
prcsenNng a Screening Report which has been substantivcly wdtten by the proponent
(OPG/Golder), CNSC appear to bc acting in a partini and biased manncr. Many issues havc
not been addressed udequately, or in an objecdvc fashion, becausc responses are providM
3
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primarily by the proponent. This undermines the credibility of the EA process and provides
further justifica►ion for an Independcnt Panel Review whcre contentious issues can be
discussed and resolvecf in a substantive and objective manncr.
SPEC[FIC COMMENTS BY DISCIPLINE
Hydrogcology
It is clear, after review of both the Sitc•widc Ilydrogcology Rcport and 'CNSC' responses to
concerns ralscd on scveral occasions by the PRT, that an adcquatc understanding of the
hydrogeology nt PNCS remains ;u elusivc as ever. Thcre is no qucstion that on immcnse
volume of dnta has becn amassed in ihc coursc of the work nnd it is encauraging to note that
thc consulting team recognises the multi•layer hydrogeological system at Ihc site, and
acknowledges the potential influence of construction activities e.g fill and sub-surface pipes on
the hydrogeological behaviou� of thc systcm. hevcnhcicss, while thcse important faclors nre
documented, there is no evidence presenleJ in thc re�ns Ihat the roles of these key fcatures
are r�uantitarively undersloal. GrounJwalcr fluxcs arc not well known nnd grounJwater flow
velocities, confidently tabulated to three significant figures, werc calculatcd using total
porosity (a valuc of 25% basnl nn 12 laboralory measuremcnts) instead of e(fective porosity.
While ihis is unlikely lo bc a problem for sanJ and gravcl materials wherc total anJ cffective
porosities will bc similar, it will likcly resull in scrious underestimates of flow velociry where
fracturo (low and wnduit flaw is occurring.
Quantitative issues aside, it is also disturbing to note some fundamental errors in the
interpretation of basic hydrogeological information. For example, the water table map
presented in Figure 4-26 incorrectly implies that grounJwater can "branch out" from a singlc
flow line. it is also suggested that the Easl landfill represents a"recharge area" by vinue of the
mound that occurs beneath it i.e. thut high gradients are iodicative of high flows.
Unfortunately, this is not always so. In the first place mounding will naturaliy occur betwecn
two discharge points even under conditions of evenly distributed recharge. Furthermore, high
gradients can also indicate low permeability media, a fact conveniently used by the consultants
to suggest limited inflow of groundwater into Lake Ontnrio (Page 4•44, paragraph S). While it
remains possible Uiat qic Easl landfiii represents a key recharga area, equally well it may not.
Until very basic issues such as the distribution of nquifer recharge on the site can ba
established, it is difficult to accept the repon's conclusions with any level of confidence.
Rad(oactivity
No maJor sources of radiation have been overlookal. 7'he PRT continues to have dou6ts about
the accuracy of the results but notes, ance egain, that estimotes are conservative end thc
exisUng radiadon cnvironmont has been well charactcriscd. in rcgnrd ro rndioucNvity and dosc
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to the public, the'CNSC' can justifiably claim that that the restnrt will not significantly impact
the environment under normal operating condilions.
Eorthquake risk
This remains n very s�rious issue of contention. At heart, is a lack of appropriatc geological
data on which to base definitive statements regarding estimates of earthquake probabiliry and
seismic risk at PNGS. The Screening Report does not nppear to recognise, or accept, this
Inrge and potentially serious datagap. Thc City should notc that OPG's own geological
consultant (Natural Resources Canada, n fecicrai agency) also rnise this issue (H486).
The central fact, not Jisputccl by cithcr OPG or CNSC, is that a major Precambrian slrucmrc
(the CMBDZ) lics direcUy under PNGS. This structurc continues southward into
Pennsylvania where it has generated recent earthquakc activity suffici^.nt to close (temporarily)
a US nudear power siatian, OPG's information rcgarding thc nawre of the structure below and
in the vicinity of PNGS is IimitcJ to a sLigfe deep boreliole. This is unacccplable and allows no
determination as to whether thcrc is any Jisplacemcnt of strata across the strucwre. Figurc
6.7-Ib (regional beJrock gcology; Pickering Nucicar sitc) in Volume 3 is misleading. How is
the precise geographic position of the CMUUZ, shown as a dashed line on lhat figure,
conslraineJ on the basis of onc boreholel Note that Ontario Geological Survcy Map 2544
depicts the the CMEiDZ az a'faull iraceable in thc subsurface' pnsstng direc�ly beloiv PNGS.
In lhis regard, thc PRT notes that Of'G's/Goldcrs work was not been (ormally reviewed by
geologisis employcd by the Ontario Gcological Survcy which is a major omission.
It follows that the very limited data available, regarding the characicr and precise position of
the CMBDZ close to PNGS, do not allow ihe comment made in responsc N 231, that "tha decp
basement structures havc no app�irent relationship to seismicity". US experience would indicate
that this statement is incortect nnd that thc validity of the probability estimates of eanhquakes
at, or in the vicinity of PNGS is severely compromiseJ.
The blanket statement (response N 167) that "structural geology is not dealt with at length becausc
The City af Pickering should nscenain from CNSC exactly who authored this response us it
shows inadequate understanding of fundamental geologicai principles.
Curiously, thc 5creening Repon refers to "open fractures in the Precambrian strata nt depth"
(Response N 485). Iust what precisely ure these? T6c same response also k�cusscs on
Prccambrian strat�� ",:xposecl in the Muskoka-HaliDurton outcrop belt" i.e many tens of
kilometres nonh of FNGS. What is the relevnnce of this response to site conditions in nn�!
around PNCSI If th�: authors of ti�c responae wish to include outcrop areas distent to PNGS
why not refer to the known faulting ;hut a(fsets the precnmbrinn and much younger ovcrlying
strata in tha viciniry of Burleigh Fails !i.c., the work of Sanford)7 The authors of this repsonse
erc aimply being selcetive with availeble information in deciding which datn are appropriute
and which are not. Othor "misleading" (comment N 484) and "ettaneous" (comment M 488)
stetements in DEAR are highlighled by Natural Resources Cannda in their rcview of thc
geology and seismiciry secdon.
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The PRT has read the Sub-appendix K.3-3 (Scismic 1lazard and Seismic Design Issuc:
Submission to Senate Sub-Commiltee) included in Volume 3 nnd noles that many responses to
geological und seismic issues at PNGS reveal extremely poor undcrstnnding of basic concepts.
The PRT slands by its concerns raiseJ in commcnt N231. The situation, where the Scrcening
Report refuse ta accept the eriatence of large data gaps in understanding the geological setting
and earthquake risk ut PNGS, can only be resolvecl by independen! third party scrutiny.
Aquutic bfola and lakc impacts
Thc res�nses in Volume 3 to Ihe many and suhslantial PRT comments on tha lack of
underslanding of thc nquatic environment surrounding PNGS simply underscore the existence
of substantial dnta gaps. Unfortunatcly, it is evcn more difficult now to critically assess the
responses of Golder/OPC/CNSC bccausc therc has bccn considerablc ediling and re-
interprclalion of what was statal by thc PRT, and what was reportcd in DEAR.
The Screening Report continucs to perpclualc thc notion Ihat thcrc arc "30 years of exlensive
historical datn" which arc just as good ns (if not beuer than) current data for documenting
cxisting conditions. Thair statement on p. 70 summarizes lheir position:
"...A�ry plece oJhisloricaf dnrn is iuefid und helpjd br rmderstnn�ling mid dejning die diermal
plrom� � crs".
This statement is faulty from many standpoints as the vahre of historical data depcnds
completely an the �unliry of the data, not just the quan�iry. When data are eombined
inappropriately, or misrepresented, they can lead to biased conclusions. When methods are
not properly documenled, it is not even possiblc to ascertain their validity. The data from
"historical lake water temperarore moniroring associaled with lhe operntion of PNGS", which
extended over a period of 26 years from 1971 to 1997, are only valuabie if the methods arc
clearly documented, and we know w/rere the data were collected, when they w�re collceted,
and have a measure of their variaGiliry. The PRT have asked repeatedly for better
doccmcntation and this was not forthcoming in Volume 3.
It is clear that neither OPG/Golder have begun to address the deficiencies rnised'oy the PRT
with regard to the use of historical dam. The problcm has been raised to an even l;ighcr levcl
by blanket references in Volume 3 to "extensive historical data" (on p. 67):
"The EA used approzlmalely 30 years ojexrenslvc htstorlcal dnta, Habltat dmraaeiizarion,
knowledge ojhabltnt use nnr/ Ilje Hts�ory processes of VEC and olher species, ns we�7 ns tHe
data colleded Jrom /999 jallhvinrerJield surveys ".
The "extensive historical data" that nre alludcd to certninly cannot refer to field surveys, 7'hc
� • • ATTACNMENT# � TOREPORT���y�
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oniy fish survey that had been conductcd over tha past 30 years (besides thc ill-timed 1999
fnll/winter survay) took place in 1985 and 1986 (as part of a Ph.D ihesis by T. Stephenson).
This exact response is duplicated on p. 6910 defend the lack of baseline data on aquatic biota.
The PRT nlso haz a problem with the Screening Report's rationale for excluding informxtion
on plankton anJ macrobenthos. It is stated (on p. 70) ihat "...the plankton and mncrobenthos
communities are important components of the aquatic ecosystem nnJ anything that affects the
lower fooJ wcb mny potentially aflect the upper trophic Icvcis..."; despitc this, they excludcd
plankton nnd macrobentlios Gom thcir report because VGCs only included fish taxa, which
"integratecl res�nsc to effects at lower trophic Icvels", Flowever, as part of the jolloivr�p
monitoring, they propose lo include Ihc lower trophic levcis in the monitoring program
because thcy may be better "early warning" indicaiors �han fish. The PRT nsks just how ure
they going to comparc the post-slart-up data in tl�c absencc oF any prc•slart-up dala? lf
macrobcnthos anJ plankton are wonhy of being monitorcd a(ter thc start up, why arcn't they
worlhy of being monitorcd now7 flow can changes be idcntifiecl without baseline information?
(Table 6.5-4a). These are thc minimum, maximum and mcan data for each month ovcr the
monitoring period, In preparing this iabic, OPG again ignored thc PRT's objections to the
indiscriminant nmalgamation of Jala without fully documcnting thc assumplions.
Keeping in mind that thcre were di(fercnt operational conditions during the period 1971 to
1988:
• 1971 to I973; four PNGS•A reactors sequentially became operalional
• 1974 to 1979: all PNCS-A rcaclors operated at >80% copaciry
• 1986-58: both PNGS-A and B in operation. �
And thnt data were collected in di(ferent ways through the perial:
• (according to p. 2l of April 2000 DEAR) 7 to 14 stations were sampled from 1970 to
1988 (Fig. 6.4-8)
• temperatures continuously measured (but intervals not indicated)
• at three different water depths (1-2m; 8m and 12 m).
Tha additional data provided in Volume 3 does not address any oF tha foilowing questions:
1. P�hat measures were taken to ensure an unbiased representation of each year's
conditions when there had been up to twice as muny stations established in certnin years
(this was not mentiontti in the DEAR) compared to athers7
2. How were data combined to yield a single temperature eslimate when data for thrce
difFerent depths were evnilable7
3, What is the justification for combining years when only PNaS-A were in operntion
(1971-1979) with data whcn both were in operation (1986•88)7
7
• � ATTACHMENT#�TOAEPORT#S�.4��\-�
020 ' ' tZj 8 0� \o
4. What dces "continuous" measurement entaii7 Hourly or daily7 For daily valucs, what
time of day werc vatues recordcYl7
5. Where were thc stations locatecl? What is meant by ambient Iocations7 Did thu location
of thcse stations changc from year lo year7
In adJition, monthly statistics indicating minimum, maximum and mean temperalures
throughout the year are not as useful as "numbcr of degree days abovc crilicai temperature"
for the various flsh species. By providing morc tables ihat show the 'conclusions' reachecl by
OPG regarding potcntial temperature e(fecis on Ihc ecology of lhc VECs (i.e. Tublc 7.2.4-3a
to 9a nnd materials relcaseJ to the public as part of Opcn Ilouses in May anJ lune 2000),
without showing the 'results' for criiical review (i.e. n graph or labie that shows exceedances
for cach species), OPG arc in c(fcct saying: 'Irust me, lhere are no cffects',
The PRT concludcs with regard lo aquatic biology that thc responscs in Volumc 3 sheJ no ncw
light on any of the issucs and concems previously raised.
Public flcolth Iaaues
Gsscntially, OPGs rcsponse ta an•going/fulurc hcnilh (broadly defincd) conccros rnised by thc
PRT and othcrs is to point to pinnncd fol low•up stuJics. As u result, a lot is riding on thesc if on-
going public health conccros arc going to be genuinely monitored. See for example # 303, rnised
by the CAC, us wcll as thc likcly cnvironmcntal effects (p, FI•G). Sce nlso comment N16R p. 63
which promises "additional public ultitudes rescarch to be conducted to guage psychosocial
impacts".
Many of the rcsponses to PRT's comments regurding lack of inethodologicnl detnil nre vcry
wcak. Typically, Volume 3 states thnt nny infortnalion the PRT asked for is in a tcchnicul
appendix somewhere. However, in most instances the informntion the PRT was asking for tvas
not provtded !n a �eclinical appendJx; if it had been, the PRT wauld hnve simply uskcd Cor it to
be brought forward to the muin document. The second rype of response involves the clnim ihnt
the consultants were simply following conventional EA practice and/or the stnndntd rcporting
mcchnnism of the consulting firm (e,q., response lo conccrn N181). This respnnce is iruly weal:;
standerd reporting mcchanisms nrc not by definition thc most appropriatc rcponing mechnnisms,
puniculnrly when trying to communicnte to n broad lay nudience.
With respect to the response to concem #182 (Inck ofmcthodological detail re: cconomic
impacts), a refercnce document is refcrtcd to which the PRT did NOT rccciva Re: NI84, the
OPO response is missing the point. Tha paint is NOT ihc small sample sizc but mther the fact
that the concerns bcing ruiscd (health, safety, lack of credibility) were bcing fgnored in thc rcport.
PRT hus stated on severnl occasions that the assessment of public hcalth concerns is minimul nt
best. This ts undcrscorcd by the OPas rcsponse to comment 11301 (p.128). Continuing conccros
8
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around pubiic health ure rnised by a numbcr of outsidc ngencies including the CAC nnd thc
Durham MoH (see especially comments !�]88-390),
OVERALL FINDINGS OF PRT W1TH REGARD TO VOLUME 3
1. Tha PRT finds that the majority of responses madc to comments raised by the CNSC,
outside ngcncies und thc pubiic presented in Volumc 3 are inaJequate and shaw poor
Icvels of unJcrstending of basic scientific informadon. The PRT cannot identify thc
nuthorship of many respanses; most nppcar to be the work of the proponent
(OPG/Golder) raiher than CNSC. Tho absence of scientifically credible responses to
complex issues and comments raiseJ by outsidc stakeholJers and the PRT severcly
compromises thc validity of Volume 3 and the entire environmenlal nssessment.
2, Given tliat only selected comments by outside agencies and stakeholders were
respanded to in the Volume 3 Jocument and not all of the 160 + issues raised during
thc 1998 Pickering Environmcmal Revicw werc addressed, thc PRT cannot agrec with
the statement made in the Scrcening Rcpart that:
"CNSC slaff Jocs not bclicvc that thcrc arc outstanding
issucs that have not bcen aJdresscd by the cnvironmental
assessment" (CNSC response M 397).
Or the statcment that:
"... the environmemal assessment is extensive and detailed, and covers
all the issues relevant lo this study, including the concerns of
communities and residents near the facility."(CNSC Responsc N 397).
3. The PRT emphasises that the conclusions presented in Valume 3, and any
enviranmenlai action plans, rcmedial and mitigntive measures identifled by
OPG/Golder during the course of the EA Process, are based on knowlcdge which is
inadequate, The PRT has made this comment rcpeatedly in its earlicr revicws of the
Preliminary DraR (PDEAR) and Draft Gnvironmental Asscssment Reports (DEAR).
'ff�at the exiscence of such datagaps has either not been recognised or is disputed by
OPC/CNSC underminas ihe credibiliry of any canclusions, action plans and mitigative
measures issued by CNSC or OPG.
In conclusion, thc PRT reiterutes that Volume 3 fails to adcquately rewgnise and
respond to concerns regarding the existence of significant dnla gaps in the
• underslanding of emironmentnl condilions In and around PNOS. This s(tuadon
undermines the credibility of the conclusion mada by CNSC es to the'absence af
s(gnificant adverse aFfects of tha reswrt of Plckedng'A' on the cnvironmcnt'. Thc
g
,� • ATTACHMENi#_�__.TOAEPORT#S����-oo
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condusion is possibly correct 6ut it is also possibly wrong. This demonstrates the need
, for a fully independent review where data gaps can be addressed. The present process is
flawed by epparent collaborntion betwcen CNSC (the Responsible Authoriry) and OPG •
(the proponent).
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