HomeMy WebLinkAboutCAO 09-02
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REPORT TO THE
COMMITTEE OF THE WHOLE
Report Number: CAO 09-02
Date: November 25, 2002
From:
Thomas J. Quinn
Chief Administrative Officer
Subject:
Draft Environmental Assessment Guidelines
Pickering (Nuclear) Waste Management Facility Expansion
File: UT 3521
Recommendations:
1. That Report CAO 09-02 regarding the Pickering (Nuclear) Waste Management
Facility Expansion be received;
2. That Council endorse Report CAO-09-02, including the comments provided by
Acres & Associated, as the City of Pickering's comments on the draft EA
guidelines for the Pickering (Nuclear) Waste Management Facility Expansion;
and
3. That Report CAO 09-02 be forwarded to the Canadian Nuclear Safety
Commission for consideration in finalizing the EA guidelines for the Pickering
(Nuclear) Waste Management Facility Expansion, and to the Ontario Power
Generation for information.
Executive Summary:
Ontario Power Generation (OPG) submitted notice to the Canadian Nuclear Safety
Commission (CNSC) of its intention to expand its existing on-site nuclear waste
management facility. The expansion will substantially increase the used dry fuel
storage capacity at the Pickering Nuclear Generating Station (PNGS) from
approximately 650 containers to over 1500 containers by 2016. The expansion is
needed to accommodate used fuel from the nuclear station to the end of its planned 40-
year service life.
The used fuel storage expansion is subject to a federal environmental assessment, as
well as an amendment to the existing CNSC operating licence. In late October, CNSC
released draft EA guidelines for a 30-day public review period. Staff asked CNSC for
additional time to review the guidelines and bring the matter before Council for
consideration, and was granted an extension to December 18th, 2002.
Report CAD 09-02
Date: November 25, 2002
Draft EA Guidelines
Waste Management Facility Expansion
Page 2
The consulting firm of Acres & Associated (Acres) was commissioned to provide
technical advice and assistance to staff in reviewing the draft guidelines. Among their
various recommendations (see Attachment No.2), Acres provides a number of
reasonable and appropriate modifications and enhancements to the guidelines. Of
note is the suggestion to use the term "temporary" when describing this project, to
ensure it is not misinterpreted as the long-term solution for nuclear waste storage. In
addition, because there are no guarantees that a permanent used fuel disposal facility
will be available at the end of the 40-year design life of the facility, Acres also requests
that the EA guidelines require more detailed consideration of the factors that affect the
long-term integrity of the containers.
Staff agree with the recommendations made by Acres. We also have an additional
comment to provide to CNSC. If approved, the proposed expansion to the existing
used fuel storage area at PNGS would more than double the amount of high-level
nuclear waste to be stored in Pickering. The EA guidelines must explicitly acknowledge
such cumulative effects, by ensuring that the environmental screening assesses the full
extent of impacts from the existing dry fuel storage at the plant, as well as the
expanded capacity.
It is recommended that Council endorse this Report as the City's comments on the draft
EA guidelines, and that a copy be forwarded to CNSC for consideration in finalizing the
guidelines.
Financial Implications:
OPG has agreed to cover the costs to the City for the review of the draft guidelines
provided by Acres (estimated to be approximately $5,000). OPG has also committed to
funding the City's peer review costs associated with the ensuing EA process, which is
expected to commence early in 2003.
Background:
When nuclear fuel comes out of a reactor at Pickering, it is initially stored in water filled
pools for a minimum of 10 years. After this period of time, the used fuel bundles can be
loaded into dry storage containers (DSCs) and transferred to a storage area elsewhere
on site. A single DSC has the capacity to hold up to 384 bundles of used fuel.
The existing dry fuel facility at PNGS (referred to as "Phase I") is located at the
southeast corner of the site. It has been in operation since 1996, and was constructed
as a temporary means of storing used nuclear fuel bundles until the federal government
finds a permanent solution to nuclear waste storage in Canada. The facility consists of
a warehouse building that has the capacity to hold approximately 650 dry storage
containers, and also includes a storage area that houses used nuclear reactor
components removed during the retubing of the PNGS A reactors.
Report CAD 09-02
Date: November 25, 2002
Draft EA Guidelines
Waste Management Facility Expansion
Page 3
It is estimated that the Phase I storage facility will reach capacity by 2007. OPG has
therefore given notice to CNSC of its intent to expand this facility in order to
accommodate the storage of used nuclear fuel until the end of the planned 40-year
service life of the station. This "Phase II" expansion would be located on PNGS
property, immediately east of the Phase I area (see location map on page 11 of the
draft guidelines). It would allow an increase in dry fuel storage capacity from
approximately 650 containers to an additional 500 containers by 2007 and a further 400
containers by 2016. In total, should the expansion be approved, there would be
approximately 1,500 containers on the Pickering site, holding an estimated 576,000 fuel
bundles.
To obtain permission to construct the new facility, DPG has applied to the CNSC for an
amendment to their current Waste Management Operating License. That application
requires an environmental screening to be conducted. The first stage of the process
requires CNSC to establish the EA guidelines. This Report addresses only this first
stage. Subsequent reports to the Mayor and Council will include status updates on the
progress of the environmental screening activities, a report on the final EA Screening
Report (including proposed comments from the City to CNSC), and a report on CNSC's
final decision on the licensing request.
The EA guidelines are administrative and project management directives that OPG and
CNSC must follow while conducting the EA. Draft guidelines were recently prepared by
CNSC and have been issued for public review and comment (see Attachment No.1).
The draft guidelines are supplemented by a detailed "Project Description" document
prepared by OPG (a copy of which is available for viewing through the CAO's Office).
To assist with the review and analysis of the draft guidelines, staff contracted Acres &
Associated (Acres), a consulting firm with technical experience in environmental
assessment. Acres also recently assisted the Municipality of Clarington with its review
of the draft EA guidelines prepared by CNSC for the Darlington Waste Management
Facility. A number of changes that Acres requested during the Darlington process have
been incorporated by CNSC into the draft guidelines for Pickering.
Comments on the Draft EA Guidelines
Acres' reviewed that draft EA guidelines prepared by CNSC. Their observations and
comments on the guidelines are attached as Attachment No.2, and are summarized
below.
General Observations
1.
CNSC should use the term "temporary" in describing this project so that in time it
does not become the permanent solution for the disposal of nuclear waste. As
well, additional information is needed on the long-term integrity of the dry storage
containers.
Report CAD 09-02
Date: November 25, 2002
Draft EA Guidelines
Waste Management Facility Expansion
Page 4
2.
The City of Pickering needs to be directly involved in the review process. It
should not be categorized as part of the general public.
3.
The draft guidelines contain a certain amount of duplication and ambiguity in
terminology, and the sequential steps do not closely mirror the CEAA process.
Specific Comments
1,
The terms "environmental assessment", "assessment", "screening", and
"screening assessment" appear throughout the document and the use of so
many similar terms is confusing. The appropriate single term "environmental
screening" should only appear since that is the type of assessment that is being
undertaken.
2.
The word "temporary" should be included when referring to this project, in order
to ensure it is not misinterpreted as the permanent solution to nuclear waste
storage (section 2.0 Background).
3.
The phrase "potentially significant adverse" should be included to the wording
that addresses environmental or public concerns (section 3.0 Application of the
Canadian Environmental Assessment Act).
4.
Three locations are being considered by OPG for the construction of the new
Waste Management Facility within an area of the PNGS site. Therefore, the EA
Guidelines should include wording that addresses the review of alternate sites
and waste transfer routes (section 8.0 Factors to be Considered in the
Screening).
5.
Reference to "Malfunctions and Accidents" is appropriate but not in this Item
because it already appears in another area of the Draft Guideline (section 9,0
Assessment Methodology).
6.
The long-term integrity of the dry storage containers (DSCs) possess concern
and therefore the Guidelines should include a requirement to address the
following (section 9.0 Assessment Methodology):
a)
Thermal stress induced concrete cracking (heat from the decay of
radioactivity in the used fuel);
Radiation induced concrete deterioration such as radiolysis of
moisture in concrete;
Concrete aging;
Corrosion and hydriding of metal components in the DSC.
b)
c)
d)
Report CAO 09-02
Date: November 25, 2002
Draft EA Guidelines
Waste Management Facility Expansion
Page 5
7.
Discrepancy exists between the Draft Guidelines and the Project Description
regarding the Preliminary Decommissioning Plan. The Guidelines appropriately
include the requirement for such a plan while the Project Description does not.
The same holds true for some additional matters like inventories of nuclear
substances, other hazardous materials, etc. (section 9.0 Assessment
Methodology).
8.
Considerable duplication regarding the significances of effects appears in Item
9.0 and should be better organized to place the items in sequential order.
(section 9.0 Assessment Methodology).
9.
The EA Guidelines require a statement that confirms that emergency
management issues are to be specifically and appropriately addressed by the EA
without compromising the need for secrecy. (section 9.0 Assessment
Methodology).
10.
The steps that are listed note the involvement of federal and provincial
authorities and public and should also include reference to municipalities in
regarding to their roles in the EA (section 10 Environmental Assessment
Process).
Additional Comment On The Draft EA Guidelines
Staff concur with the observations and comments provided by Acres. We have also
reviewed the draft EA guidelines and have an additional recommendation for the
consideration of CNSC.
The project, as described, is an expansion to the existing dry fuel storage facility at
PNGS. It allows for the on-site storage of up to 900 dry fuel containers. Yet the
expansion should not be viewed as a "stand-alone" project. If approved, it would more
than double the number of dry fuel storage containers permitted at PNGS to over 1500
containers.
In addition to Acres comments, it is therefore requested that CNSC amend the EA
guidelines to explicitly acknowledge this fact, and require the EA process to include an
assessment of the potential cumulative impacts caused by the expansion, taking into
consideration the existing dry fuel storage facility on site, and the environment impacts
associated with the existing facility.
Report CAO 09-02
Date: November 25, 2002
Draft EA Guidelines
Waste Management Facility Expansion
Page 6
Attachments:
1.
Draft EA Guidelines (Scope of Project and Assessment) Environmental
Assessment of the Proposed Pickering Waste M~nagement Facility Phase II
Pickering, Ontario
2.
Acres & Associated Draft EA Guidelines Comments to City of Pickering
Prepared By:
Approved I Endorsed By:
~
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(~ AL., oe) Hunwicks
-Y'} \I '--Emergency Response Coordinator
Thomas E. Me ymuk r/
Division Head, Corp rate Projects & Policy
T JQ:ah
Attachments
Copy: Division Head, Corporate Projects & Policy
J:\P&ECOISHARE\UTIL\UT3521\Draft Guidelines Report to Committe of the Whole,2,doc
Recommended for the consideraf on of
Pickering City Council
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Draft EA Guidelines
(Scope of Project and Assessment)
Environmental Assessment of the Proposed
Pickering Waste Management Facility
Phase II
Pickering, Ontario
\
Prepared by the Canadian Nuclear Safety Commission
October 2002
2.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0
13.0
l4.0
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TABLE OF CONTENTS
1.0
PURPOSE......................................................................... .......... ..... ............. 3
BACKGROUND.................................. ........................................................ 3
3.0
APPLICATION OF THE CANADIAN ENVIRONMENTAL
ASSESSMENT ACT........................................................................................ 4
IDENTIFICATION OF OTHER FEDERAL AND PROVINCIAL
EXPERT DEPARTMENTS .......................................................................... 5
DELEGATION OF ASSESSMENT STUDIES TO ONTARIO POWER
GENERATION........ ............................................ .......................................... 5
PUBLIC REGISTRY..................... ................................................................ 5
SCOPE OF THE PROJECT .......................................................................... 6
FACTORS TO BE CONSIDERED IN THE SCREENING ......................... 6
ASSESSMENT METHODOLOGY.............................................................. 7
9.1 Structure of the Screening Report...................................................... 7
9.2 Specific Information Requirements ................................................... 8
9.2.1 Proj ect Description................................................................... 8
9.2.2 Spatial & Temporal Boundaries of the Assessment ............ 10
9.2.3 Description of the Existing Environment ............................ 13
9.2.4 Assessment and Mitigation of Environmental Effects.......... 14
9.2.5 Assessment of Cumulative Effects ...................................... 17
9.2.6 Assessment of the Effect on the Capacity of Renewable
Resources ................................. ............................................ 17
9.2.7 Significance of the Residual Effects ..................................... 17
9.2.8 Stakeholder Consultation ............ ................... ..... ........ ......... 18
9.2.9 Follow-up Program .. ........... ............................. ..... ........ ....... 18
ENVIRONMENTAL ASSESSMENT PROCESS................. ....................... 19
CONCLUSIONS AND RECOMMENDATIONS FOR DECISION.......... 20
CONTACTS FOR THE ASSESSMENT .................................................... 20
REFERENCES............................................................................................ 20
GLOSSARY OF TERMS.......................... .................................................. 21
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1.0
PURPOSE
The purpose of this document is to provide guidance on the scope of the environmental
assessment (EA) to be conducted of the proposed Pickering Waste Management Facility
(PWMF) Phase II Project in Pickering, Ontario. The facility proposed by Ontario Power
Generation Inc (OPG) would be an expansion of the existing PWMF to accommodate used fuel
from Pickering Nuclear Generating Stations (PNGS) A and B to the end of the planned 40-year
service life of the PNGS. OPG has submitted a project description for the proposal to the CNSC.
A federal environmental assessment is required under the provisions of the Canadian
Environmental Assessment Act (CEAA). Under the CEAA, the scope of the project and the
scope of the factors included in the assessment are to be determined by the Responsible
Authority which in this case is the Canadian Nuclear Safety Commission (CNSC).
The EA Guidelines will describe the basis for the conduct of the EA, and focus the assessment
on relevant issues and concerns. The document will also provide specific direction to the
proponent, OPG, on how to document the technical environmental assessment study which will
be delegated to them by the CNSC staff pursuant to subsection 17(1) ofthe CEAA. In addition,
the Guidelines will provide a means of communicating the CNSC's environmental assessment
process to stakeholders.
2.0
BACKGROUND
Ontario Power Generation Inc. submitted notice to the CNSC of its intention tq apply for a
licence to construct a waste management facility for the dry storage of used fuel; to transfer
loaded welded Dry Storage Containers (DSCs) from pWMF I to the new storage facility; and to
operate and maintain the storage buildings comprising the facility.
The PWMF Phase II construction, if approved, would be authorized by an amendment of an
existing licence for the Class 1B Nuclear Facility, pursuant to subsection 24(2) of the Nuclear
Safety and Control Act (NSCA). The transfer of loaded welded DSCs would also be authorized
through an amendment to this licence. OPG must comply with the requirements of the NSCA
and its regulations.
The environmental assessment to be completed under CEAA will provide part of the information
that the CNSC will use in considering OPG's licence application. The application will also be
subjected to a thorough evaluation under the provisions of the NSCA and its regulations. That
includes a detailed safety review and a licensing process that affords the public the opportunity
to provide input to the Commission prior to any licensing decision being made on the proposed
construction.
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Description of the Existing Environment
Assessment and Mitigation of Environmental Effects
- description of assessment methodology
- effects of construction
- effects of normal operations, malfunctions and accidents, and natural hazards
Cumulative Environmental Effects
Significance of Residual Effects
Stakeholder Consultation
Follow-up Program
Conclusions and Recommendations for Decision
References
Specific Information Requirements
9.2.1
Project Description
The screening report will include a clear and comprehensive statement of the purpose of the
project. In this case, the purpose of the PWMF Phase II Project is to provide additional capacity
for the dry storage of used fuel bundles.
An adequate description of the project is necessary to permit a reasonable consideration in the
screening of the environmental effects of the project. The project description will be a thorough
description of the operational, physical, chemical and radiological characteristics of the facility.
It will include a proposed schedule for the construction, operation and on-going maintenance of
the facility. It will include a description of the activities involved in the transfer of used fuel
bundles in welded DSCs from the processing building or storage buildings of Phase I to the
PWMF Phase II, and of the additional infrastructure required for these activities to occur.
Furthermore, the project description will include a detailed description of Ontario Power
Generation, including its ownership, organization, structure and technical capabilities.
The main objective ofthe project description is to identify and characterize those specific
components and activities that have the potential to interact with, and thus result in a likely
change or disruption to, the surrounding environment, during construction, during normal
operations, during malfunctions and accidents.
Construction and Normal Operations
The following information will be provided in summary form; where applicable, reference may
be made to more detailed information:
the location of the project components;
the basic configuration, layout, shape, size, design and operation of the facility and
supporting infrastructure
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the size ofthe Phase II storage facility based on the projection of used fuel volumes
expected to arise from the operation of the PNGS;
a description of the transportation operation including a description of the transporter
used to transfer the loaded containers to the PWMG Phase II
a description of any necessary road construction or upgrades
site preparation and construction activities
the inventories of nuclear substances and other hazardous materials to be stored at the
facility, including locations and storage methods;
the sources, types and quantities of radioactive, hazardous and non-hazardous waste
predicted to be generated by the project;
the on-site processes for the collection, handling, transport, storage and disposal of
radioactive, hazardous and non-hazardous wastes to be generated by the project;
the predicted sources, quantities and points of release from the project of emissions
and effluents containing nuclear substances and hazardous materials;
the sources and characteristics of any fire hazards;
the sources and characteristics of any noise, odour, dust and other likely nuisance
effects from the project;
the key components of the facility relevant to environmental performance and safety
during the siting and construction activities, and during the subsequent operations;
the sources and characteristics of any potential risks to workers, the public or the
environment from the project;
key operational procedures relevant to protection of workers, the public and the
environment relating to the project;
the predicted doses to workers involved with the associated operations and activities
that are within the scope of this project;
the key components of the facility and its physical security systems (excluding
prescribed information) that are relevant to management of malfunctions and
accidents that may occur during the siting and construction activities, and during the
subsequent operations; and
a description of the relevant organizational and management structure, and staff
qualification requirements with emphasis on safety and environmental management
programs.
Malfunctions and Accidents
This section should include:
a description of specific important malfunction and accident events that have a
reasonable probability of occurring during the life of the project, including an
explanation of how these events were identified for the purpose of this environmental
assessment;
a description of the source, quantity, mechanism, rate, form and characteristics of
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contaminants and other materials (physical, chemical and radiological) likely to be
released to the surrounding environment during the postulated malfunction and
accident events; and
a description of any contingency, clean-up or restoration work in the surrounding
environment that would be required during, or immediately following, the postulated
malfunction and accident events.
Preliminary Decommissioning Plan
A preliminary decommissioning plan for the facility will be included in the assessment. The
preliminary plan will document, as appropriate, the preferred decommissioning strategy and end-
state objectives; the major decontamination, disassembly and remediation steps; the approximate
quantities and types of waste generated; and an overview of the principal hazards and protection
strategies envisioned for decommissioning. However, as indicated in section 7.0, long term
waste management options will not be included. The long-term management of radioactive
waste, including irradiated nuclear fuel, is being developed through separate federal legislation.
9.2.2 Spatial and Temporal Boundaries of the Assessment
The consideration of the environmental effects in the screening needs to be conceptually
bounded in both time and space. This is more commonly known as defining the assessment
study areas and time frames, or spatial and temporal boundaries of the screening.
The geographic study areas for this screening must encompass the areas of the environment that
can be reasonably expected to be affected by the project, or which may be relevant to the
assessment of cumulative environmental effects. Study areas will encompass all relevant
components ofthe environment including the people, land, water, air and other aspects ofthe
natural and human environment. Study boundaries will be defined taking into account
ecological, technical and social/political considerations.
The following geographic study areas are suggested:
Site Study Area: The Site Study Area includes PWMF II Siting Area and the area
encompassed by the associated transfer routes. (Figure 1).
Local Study Area: the Local Study Area is defined as that area existing outside the
site study area boundary, where there is a reasonable potential for
immediate impacts due to either ongoing normal activities, or to
possible abnormal operating conditions. It includes the facilities,
buildings and infrastructure at the Pickering NGS site, including
the licensed exclusion zone for the site on land and within Lake
Ontario The outer boundaries of the Local Study Area encompass
an area that includes lands within the City of Pickering, the town
of Ajax, and the eastern part of Toronto closest to the Pickering
NGS site, as well as a portion of Lake Ontario abutting, and used
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by, those communities for such activities as recreation, water
supply and waste water discharge. The boundaries may change as
appropriate following a preliminary assessment of the spatial
extent of potential impacts (Figure 2).
Regional Study Area: the Regional Study Area is defined as the area wherein there is
at least the potential for cumulative and socio-economic effects,
and it includes the lands, communities and portions of Lake
Ontario around the Pickering NGS that may be relevant to the
assessment of any wider-spread effects of the project (Figure 2).
The temporal boundaries for this assessment must establish over what period of time the project-
specific and cumulative effects are to be considered. The initial time frame for the assessment
will be the duration of the project; that is, the planned duration of the construction and operation
phases, and of decommissioning based on a preliminary decommissioning plan.
Both the study areas and time frames will remain flexible during the assessment to allow the full
extent of a likely environmental effect to be considered in the screening. For instance, should the
results of modelling demonstrate that there is dispersion of a contaminant that is likely to cause
an environmental effect beyond the boundaries identified above, it will be taken into account in
the assessment.
9.2.3 Description of the Existing Environment
A description of the existing environment is needed to determine the likely interactions between
the project and the surrounding environment and, likewise, between the environment and the
project. Both the biophysical environment and the socio-economic (human, cultural)
environment are to be considered.
An initial screening oflikely project-environment interactions will be considered in identifying
the relevant components of the environment that need to be described.
The general components of the environment that should be described in the various study areas
include, but should not necessarily be limited to:
.
meteorology and climate;
air quality;
nOIse;
physiography and topography;
soil quality;
geology;
seismic activity;
hydrogeology;
groundwater quality (physical and chemical);
surface hydrology;
surface water quality (physical and chemical);
.
.
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aquatic ecology; and
terrestrial ecology.
.
The description of the human components of the above environment should include, but should
not necessarily be limited to:
.
population (including relevant demographic characteristics);
economic base;
community infrastructure and services;
renewable and non-renewable resource use;
existing and planned land use;
health;
heritage, cultural and archaeological sites;
recreation areas; and
use of lands and resources for traditional purposes by aboriginal persons.
.
.
.
.
.
.
.
.
Valued Ecosystem Components (VECs) in the existing environment will be identified and used
as specific assessment end-points. VECs are environmental attributes or components identified
as having a legal, scientific, cultural, economic or aesthetic value. The VECs proposed in the EA
methodology for this project will be reviewed and accepted by CNSC staff in the early phases of
the EA study.
The required level of detail in the description of the existing environment will be less where the
potential interactions between the project and various components of the environment are weak
or remote in time and space.
Relevant existing information may be used to describe the environment. Where that information
is significantly lacking, additional research and field studies may be required to complete the
screening assessment. Any work done by OPG to fill identified gaps in information will be
reviewed by CNSC staff as progress is being made.
9.2.4 Assessment and Mitigation of Environmental Effects
The consideration of environmental effects in the screening will be done in a systematic and
traceable manner. The assessment methodology will be summarized. The results of the
assessment process should be clearly documented using summary matrices and tabular
summaries where appropriate.
Assessment of Effects Caused by the Project
The assessment will be conducted in a manner consistent with the following general method:
1) Identify the potential interactions between the project activities and the existing
environment during construction and normal operations, and during identified relevant
malfunctions and accidents.
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Specific attention will be given to interactions with the identified VECs.
In this step, the standard design and operational aspects from the project description that
prevent or significantly reduce the likelihood of interactions occurring with the environment
should be reviewed. Opportunities for additional impact mitigation measures are addressed
in step 3 below.
2) Describe the resulting changes that likely would occur to the components of the
environment and VECs as a result of the identified interactions with the project.
Each environmental change must be described in terms of whether it is direct, indirect,
positive or adverse.
Identified changes in socio-economic conditions and various aspects of culture, health,
heritage, archaeology and traditional land and resource use may be limited to those that are
likely to result from the predicted changes that the project is likely to cause to the
environment. The consideration of public views, including any perceived changes attributed
to the project should be recognized in the assessment methodology.
For each identified effect, the predicted magnitude, duration, frequency, timing, probability
of occurrence, ecological and social context, geographic extent, and the degree of
reversibility, should be considered in determining if it is a likely adverse effect.
Quantitative as well as qualitative methods may be used to identify and describe the likely
adverse environmental effects. Professional expertise and judgment may be used in
interpreting the results of the analyses. The basis of predictions and interpretation of results,
as well as the importance of remaining uncertainties, will be clearly documented in the EA
study report.
3) Identify and describe mitigation measures that may be applied to each likely adverse effect
(or sequence of effects), and that are technically and economically feasible.
Mitigation strategies should reflect precautionary and preventive principles. That is,
emphasis should be placed on tempering or preventing the cause or source of an effect, or
sequence of effects, before addressing how to reverse or compensate for an effect once it
occurs.
Where the prevention of effects cannot be assured, or the effectiveness of preventive
mitigation measures is uncertain, further mitigation measures in the form of contingency
responses, including emergency response plans, will be described.
Where cost/benefit analyses are used to determine economic feasibility of mitigation
measures, the details of those analyses will be included or referenced.
4) Describe the significance of the environmental effects that likely will occur as a result of
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the project, having taken into account the implementation of the proposed mitigation
measures.
The criteria for judging and describing the significance of the residual (post-mitigation)
effects will include: magnitude, duration, frequency, timing, probability of occurrence,
ecological and social context, geographic extent, and degree ofreversibility. Specific
assessment criteria proposed in the EA methodology for this project will be reviewed and
accepted by CNSC staff in the early phases of the EA study.
Existing regulatory and industry standards and guidelines are relevant as points of reference
for judging significance. However, professional expertise and judgement should also be
applied in judging the significance of any effect. All applicable federal and provincial laws
must be respected.
The analysis must be documented in a manner that readily enables conclusions on the
significance of the environmental effects to be drawn. The CNSC, as the responsible
authority for the EA project, must document in the screening report a conclusion, taking into
account the mitigation measures, as to whether the project is likely to cause significant
adverse environmental effects.
Assessment of Effects of the Environment on the Project
The assessment must also take into account how the environment could adversely affect the
project; for example, from severe weather or seismic events. The assessment must also take into
account any potential effects of climate change on the project, including an assessment of
whether the project is sensitive to changes in climate conditions during its life span.
This part of the assessment will be conducted in a step-wise fashion, similar to that described for
the foregoing assessment of the project effects. The possible important interactions between the
natural hazards and the project will be first identified, followed by an assessment of the effects of
those interactions, the available additional mitigation measures, and the significance of any
remaining likely adverse environmental effects.
Assessment of Effects of the Project on the Capacity of Renewable Resources
The assessment must also take into account whether the likely project-related environmental
effects will impact on the capacity of renewable resources to meet the needs of the present and
those of the future.
The potential interactions between the project and the environment will be identified and
assessed in order to determine the likelihood of interactions between the project and resource
sustainabili ty.
16
ATTACHMENT# \ TO REPORT#QJ\Q-(§\-C:l~
% \\~&\
9.2.5 Assessment of Cumulative Effects
The effects ofthe project must be considered together with those of other projects and activities
that have been, or will be carried out, and for which the effects are expected to overlap with
those of the project (i.e., overlap in same geographic area and time). These are referred to as
cumulative environmental effects.
An identification of the specific projects and activities considered in the cumulative effects will
be included in the Screening Report. In general, the cumulative effects assessment will consider
the combined effects of the project with the neighbouring or regional industries and other
developments.
The information available to assess the environmental effects from other projects can be
expected to be more conceptual and less detailed as those effects become more remote in
distance and time to the project, or where information about another project or activity is not
available. The consideration of cumulative environmental effects may therefore be at a more
general level of detail than that considered in the assessment of the direct project-environment
interactions.
Where potentially significant adverse cumulative effects are identified, additional mitigation
measures may be necessary.
9.2.6 Assessment of the Effects on the Capacity of Renewable and Non-renewable Resources
The assessment must also take into account whether the likely project-related environmental
effects will impact on the capacity of renewable and non-renewable resources to meet the needs
of the present and those of the future.
The potential interactions between the project and the environment will be identified and
assessed in order to determine the likelihood of interactions between the project and resource
sustainability.
9.2.7 Signifìcance of the Residual Effects
The preceding steps in the screening will consider the significance of the environmental effects
of the project on the environment, the natural hazards on the project, project malfunctions and
accidents, and other projects and activities that could cause cumulative effects.
The screening will consider all of these effects in coming to a final conclusion as to whether the
project, taking into account the mitigation measures, will likely cause significant adverse
environmental effects. The CNSC, as the responsible authority, will document this conclusion in
the screening report.
17
ATTACHMENT # \ TO REPORT # ~ -D'\- ~~
~ \~~&\
9.2.8 Stakeholder Consultation
The assessment will include notification of, and consultation with, the potentially affected
stakeholders, including the local public. Various media will be used to inform and engage
individuals, interest groups, local governments and other stakeholders in the assessment. Ontario
Power Generation will be expected to hold appropriate public consultation meetings. The
stakeholder consultation program of Ontario Power Generation will be continuously monitored
by the CNSC staffthroughout the environmental assessment process.
Throughout the environmental assessment process, various stakeholders, including the following,
will be consulted:
federal government
provincial government
local government
established committees
general public
First Nations and aboriginal communities
neighbouring residents
local businesses
non-government organizations and interest groups
The Screening Report will contain a summary review of the comments received during this
environmental assessment process. The Screening Report will indicate how issues identified
have been considered in the completion of the assessment, or where relevant, how they may be
addressed in any subsequent licensing and compliance process.
The CNSC will also establish a public consultation process in the review and decision-making
process for the Screening Report. This will include opportunities for the public to review and
comment to CNSC staff on the draft Screening Report, as well as to comment and make
interventions before the Commission on the final Screening Report.
9.2.9 Follow-up Program
A preliminary design and implementation plan for a follow-up program will be included in the
Screening Report.
The purpose of the follow-up program is to assist in determining if the environmental and
cumulative effects of the project are as predicted in the Screening Report. It is also to confirm
whether the impact mitigation measures are effective, and to determine if any new mitigation
strategies may be required. The design of the program will be appropriate to the scale of the
project and the issues addressed in the EA.
18
ATTACHMENT# \ TO REPORT #Ç.k¿.C~-~~
% \~ C>~ <S> \
If a licence is issued to Ontario Power Generation under the NSCA, the CNSC licensing and
compliance program will be used as the mechanism for ensuring the final design and
implementation of any follow-up program and the reporting of program results. The program
would be based on regulatory principles of compliance, adaptive management, reporting and
analysis.
10.0
ENVIRONMENTAL ASSESSMENT PROCESS
The following points indicate the key steps likely to be followed by CNSC staff during the
environmental assessment process. Some steps have already been completed:
.
Determination of the application ofCEAA to the project, including application of the
Federal Coordination Regulation; establishment of Public Registry; and stakeholder
notification (completed)
.
Preparation of working draft of EA Guidelines; distribution of draft EA Guidelines to
proponent and federal and provincial authorities; receipt of comments from federal and
provincial authorities and preparation of draft for public comment (completed)
.
Distribution of draft EA Guidelines for public comment (in progress)
.
CNSC staff review and disposition of comments received; revision of Draft EA Guidelines
for submission to the Commission of CNSC; Commission of CNSC approval of EA
Guidelines
.
CNSC staff delegation of consultative and technical studies to the proponent
.
Distribution of draft EA study report to review team (CNSC staff, federal and provincial
authorities); revision, as appropriate, ofEA study report; CNSC staff preparation of draft
screening report
.
Public review and comment on draft screening report; CNSC staff review and
dispositioning of public comments; CNSC completion of screening report;
.
CNSC staff preparation of screening report CMD for Commission consideration; Public
notification of Commission Hearing
.
CMD presentation of screening report to Commission Hearing (Day 1)
Commission Hearing (Day 2)
Commission Hearing Record of Decision
.
.
19
ATTACHMENT# \ TO REPORTit~-o~-c~
% @~ C)~ ~\
CONCLUSIONS AND RECOMMENDATIONS FOR DECISION
11.0
The Screening Report will present a conclusion by CNSC as to whether the project is likely to
cause significant adverse environmental effects, taking into account the appropriate mitigation
measures. CNSC staff will make recommendations to the Commission on taking decisions on the
environmental assessment and project-related public concerns, consistent with section 20 of the
CEAA. Decisions by the Commission will be made through Commission hearing procedures.
11.0
CONTACTS FOR THE ASSESSMENT
Anyone wishing to obtain additional information or provide comments on any aspect of the
environmental assessment being conducted on the proposed construction and operation of the
Pickering Waste Management Facility Phase II may do so through the following CNSC staff
contacts:
Ms. Heather Humphries
Environmental Assessment Specialist
Processing Facilities and Technical Support Division
Canadian Nuclear Safety Commission
280 Slater Street, P.O. Box 1046
Ottawa, Ontario K1P 5S9
Phone: 1-800-668-5284
Fax: (613) 995-5086
Internet: ceaainfo@cnsc-ccsn.gc.ca
Ms. Kay Klassen
Licensing Officer
Canadian Nuclear Safety Commission
280 Slater Street
P.O. Box 1046
Ottawa, Ontario K1P 5S9
Phone: 1-800-668-5284
Fax: (613) 995-5086
Internet: ceaainfo@cnsc-ccsn.gc.ca
20
ATTACHMENT# \ TO REPORT#~-o~\-Q)&
~~\ ~~ ~\
12.0
REFERENCES
1.
Letter, R. Dicemi (OPG) to C. Maloney (CNSC), January 31, 2002. "Intent to Construct
Phase II o/the Pickering Waste Management Facility".
2.
Letter, K.E. Nash (OPG) to K. Klassen (CNSC), June 12,2002. Pickering Waste
Management Facility Phase II Project - Project Descriptionfor Environmental Assessment
Scoping", with attached report, "Pickering Waste Management Facility Phase II Project-
Project Description (June 2002).
13.0
GLOSSARY OF TERMS
1.
"environmental effect" means, in respect of a project,
(a) any change that the project may cause in the environment, including any effect of any
such change on health and socio-economic conditions, on physical and cultural heritage,
on the current use of lands and resources for traditional purposes by aboriginal persons,
or on any structure, site or thing that is of historical, archaeological, paleontological or
architectural significance, and
(b) any change to the project that may be caused by the environment,
whether any such change occurs within or outside Canada.
21
ATTACHMENT' ~ TO AEPORT#Qk¿~c~-C\
% \ 0 S; Lc, i;,~~~jateð
Environmental Scientists
and Consulting El1gineel's
November!3, 2002
File: 2002-5897 - 5,()
City of Pickering
Pickering Civic Complex
One The Esplanade
Pickering, Ontariø
LlV 6K7
Attention;
Mr At. (Joe) Hunwícks
Emergency Response Coordinator
Re:
PEER REVIEW
DRAFT ENVIRONMENTALASSESSMENT GUIDELINES FOR
PROPOSED PICKERING WASTE MANAGEMENT FACILITY (pHASE II)
DcaI' Mr, llunwicks:
Please find attached onr comments on thc "Draft El1vironmental Assessment Guidelines" documcnt
(October 2002) that the Canadian Nuclear Safety Comll1ÎsS10n (CNSC) prepared for Ontario Power
Generation (OPG)in connection with the Proposed Pickering Waste Management Facility (Phase 11).
In general, our comments are threeÜ)ld,
Our first general comment concems tbe fact that this project is designed to be a temporary solution
until a long term solution is fOtl11d for the disposal of the PNGS-A and -13 waste Inaterials,
Therefore, 0) we are urging adoption of the teml tempormy in describing this project in the EA
documents so that il1 time it docs 11ot become the permanent solution and (ii) are requesting that
infolmation be pro'vided in the EA documentsconceming the factors that affectlong-tenll integrity
ofthc DSCs,
Our second general comment is in reference to the Municipality being a separate entity from the
general public, The Municipality is, and needs to be, direedy involved in the review process and in
our opinion should not be categorized in the GuideJines or subsequent fA documents a.<; part of the
general public,
Our third general comment concems the Ü'amework of the Draft Guidelines versus the CEAA
process, Although "ve are comfortable that the Guide! ines are suH1cient and adequate to ensure that
the EA documents wiIJ be prepared in accordance with the CEAA process, we are of the view that
there is a celtain amount of duplication and am biglli ty in terminology in the Guidelines and that the
sequential steps do not closely mim.1r the CEAA process, Therefore, we fee] that the Guidelines
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November 13, 2002
The City of Pickering. 2
occasionaHy rnakc it more difficult for the person to ul1derstand the CEAA 11'amework that is
being provided to OPG Îll preparing their EA documents,
We hope our cornments are of assistance in addressing the concerns of the Municipality, and in
fo1111uJating your Staff Report and reply to the CNSC
Pleï!Sc do not hesitate to COtltact me at (905) 374-4470, should you have any questions concemìng
the above
Yours truly,
ACRES & ASSOCIATED ENVIRONMENTAL LIMITED
~~~,ø
Bruce G. Bennett, M,Sc,
Project Manager
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ACRES & ASSOCIATED ENVIRONMENTAL LIMITED
COMMENTS ON "DRAFT ENVIRONMENTAL ASSESSMENT GUIDELINES"
FOR PROPOSED PICKERING WASTE MANAGEMENT FACILITY (PHASE II)
1
GENERAL COMMENTS
We note throughout the document that the terms "environmental assessment",
"assessment", "screening", and "screening assessment" appear to be used
interchangeably. It would reduce the confusion to municipal staff, councilors and the
public at large if the term "environmental screening" could be used throughout to make it
very clear to all concerned that the CNSC has determined that this is an "environmental
screening" (rather than "a comprehensive study") in accordance with the requirements of
the Canadian Environmental Assessment Act (CEAA).
2
COMMENTS ON "2.0 BACKGROUND"
We recommend that the first sentence of this Section be modified to read ". . . to apply
for a licence to construct a temporary waste management facility for the dry storage of
used fuel; to transfer. . . . . comprising the facility, until a permanent disposal facility
becomes available. "
The City of Pickering (the Municipality) acknowledges that this proposed facility is
Phase II of the originally planned expansion of the existing Pickering Waste Management
Facility (PWMF-I). Nevertheless, the purpose of this facility is to accommodate used
fuel from the Pickering Nuclear Generating Station -A and -B until such time as a long-
term management facility becomes available. In our opinion, emphasizing the word
temporary is consistent with:
. the statements made in the last paragraph of Section 7.0 of the Draft EA Guidelines
whereby, on page 6, it is stated that "The long-term management of radioactive waste,
including irradiated nuclear fuel, is being developed through separate federal
legislation" and "Consequently, it is premature to examine long-term waste
management alternatives as part ofthe scope of this project", and
. the statements made under Section 9.0 of the Draft EA Guidelines whereby, on page
10, it is stated that long-term waste management options will not be considered as
part of the Conceptual Decommissioning Plan for the reasons stated above.
3
COMMENTS ON "3.0 APPLICATION OF THE CANADIAN
ENVIRONMENTAL ASSESSMENT ACT"
We suggest the following modification to the first sentence of the last paragraph of
Section 3.0 of the Draft EA Guidelines: "At this time, CNSC staff is not aware of any
potentially signifrcant adverse environmental effects or public concerns. . . " This
CJ.p .~
ATTACHMENT # N TO REPORT It 0,\-
ACRES & ASSOCIATED ENVIRONMENTAL LIMITED % ~ O-\.l..o. C8I-
COMMENTS ON "DRAFT ENVIRONMENTAL ASSESSMENT GUIDELINES"
FOR PROPOSED PICKERING WASTE MANAGEMENT FACILITY (PHASE II)
clarifies for municipal staff, councilors and the public at large more precisely what would
warrant a referral to a mediator or review panel as per CEAA Section 25.
4
COMMENTS ON "4.0 IDENTIFICATION OF OTHER FEDERAL AND
PROVINCIAL EXPERT DEPARTMENTS"
No comments on content/wording of this section.
5
COMMENTS ON "5.0 DELEGATION OF ASSESSMENT STUDIES TO
ONTARIO POWER GENERATION"
No comments on content/wording of this section.
6
COMMENTS ON "6.0 PUBLIC REGISTRY"
No comments on content/wording of this section.
7
COMMENTS ON "7.0 SCOPE OF THE PROJECT"
No comments on content/wording of this section.
8
COMMENTS ON "8.0 FACTORS TO BE CONSIDERED IN THE
SCREENING"
We feel that it is important that the Draft EA Guidelines acknowledge that there are three
sites within the siting area and alternative methods (i.e., transfer routes) to be considered
and assessed. Therefore, we recommend that the first sentence of the third paragraph be
modified to read ". . . the CNSC will also consider the purpose of the project, the
alternative sites within the PWMF II siting area, alternative transfer routes, the need for,
and requirements of, a follow-up. . . "
9
COMMENTS ON "9.0 ASSESSMENT METHODOLOGY"
We disagree with the last paragraph of Section 9.2.1 regarding the main objective of the
project description. In our opinion, the main objective of the project description is to
simply describe the project (as it already has in the second paragraph of Section 9.2.1)
and not for the reasons provided in the last paragraph of this section. Therefore, we feel
that Section 9.2.1 should only include the "Construction and Normal Operations" and
"Preliminary Decommissioning Plan" subsections. In our opinion, the inclusion of the
"Malfunctions and Accidents" subsection as part of the project description is
inappropriate and is more correctly placed (as it already is) in Section 9.2.5 (Assessment
and Mitigation of Environmental Effects).
We are concerned about the long-term integrity of the dry storage containers (DSCs) over
time since there is no guarantee that a permanent used fuel disposal facility will be
Page 2 of 4
~c~
ACRES & ASSOCIATED ENVIRONMENTAL LIMITED ATTACHMENT #tTO REPORT#~
Sc>~ La.
COMMENTS ON "DRAFT ENVIRONMENTAL ASSESSMENT GUIDELI S"
FOR PROPOSED PICKERING WASTE MANAGEMENT FACILITY (PHASE II)
available even at the end of the 40-year design life ofthe DSCs. Therefore, on pages 6/7
of the Draft EA Guidelines under the "Construction and Normal Operations" of
Subsection 9.2.1, we would like to see reference made to the provision of more detailed
information concerning the factors that affect long-term integrity. These include:
. Thermal stress induced concrete cracking (heat from the decay of radioactivity in the
used fuel)
. Radiation induced concrete deterioration such as radio lysis of moisture in concrete
. Concrete aging
. Corrosion and hydriding of metal components in the DSC
There appears to be a discrepancy between the Draft EA Guidelines and the Pickering
Project Description Report (#92896-REP-0770 1-0000 I, June 2002) regarding inclusion
of the Preliminary Decommissioning Plan in the EA. Section 9.2.1 ofthe Draft EA
Guidelines states "a preliminary decommissioning plan for the facility will be included in
the assessment". However, Section 2.6 of the Project Description Report states
"decommissioning is not part ofthe scope of the proposed PWMF II Project EA" and
makes reference to the preliminary decommissioning plan of the existing PWMF 1.
While this might be acceptable, the apparent discrepancy with the Draft EA Guidelines
should be resolved.
Some of the requirements stated in Section 9.2.1 (Project Description) of the Draft EA
Guidelines do not appear to be included in the Project Description Report (June 2002
version), such as inventories of nuclear substances and other hazardous materials to be
stored at the facility, description of malfunction and accident events. We assume the
Project Description section of the EA report will include all the requirements of the EA
Guidelines.
There is considerable duplication regarding the significance of effects as noted in
Subsections 9.2.4 (2), (4) and 9.2.7. It is recommended that the discussion regarding
significance of effects should be removed from Subsections 9.2.4 (2) and (4) and
incorporated into Subsection 9.2.7 since this is the appropriate sequence of events, i.e.
significance is only determined on residual effects after application of mitigation, where
feasible. Therefore:
. On page 15 of the Draft EA Guidelines under Subsection 9.2.4 (2), the third
paragraph commencing "For each identified effect, the predicted magnitude,
duration, frequency, timing, . . . " should be removed because this is the procedure
for identifying the significance of effects.
. Subsection 9.2.4 (4) should be removed in its entirety and the three paragraphs
comprising this subsection should be incorporated into Subsection 9.2.7
"Significance of the Residual Effects".
Page 3 of 4
~,
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ACRES & ASSOCIATED ENVIRONMENTAL LIMITED ATTACHMENT #'-4' TO REPORT#.QS;L
~ ~a,~ LD
COMMENTS ON "DRAFT ENVIRONMENTAL ASSESSMENT GUIDELlNÈ~
FOR PROPOSED PICKERING WASTE MANAGEMENT FACILITY (PHASE II)
Recent events have also highlighted the issue of preparedness/response to unforeseen
events (i.e., safeguards against nuclear material diversion or terrorist attacks). It is
recognized that this issue is of utmost concern to both OPG and the CNSC and that the
preparedness/response to these events is a high security matter and not for the public
record. Nevertheless, we feel that a statement is needed in the Draft EA Guidelines that
confirms that this very sensitive issue has/is being addressed by OPG and the CNSC.
10
COMMENTS ON "10.0 ENVIRONMENTAL ASSESSMENT PROCESS"
We recommend the following changes to wording of some of the steps that are listed in
this section to acknowledge the direct participation of the Municipality in the review
process.
. Preparation of working draft of EA Guidelines; distribution of draft EA guidelines
to proponent and federal and provincial authorities; receipt of comments from
federal and provincial authorities and preparation of draft for municipal and
public comment (completed)
. Distribution of draft EA Guidelines for municipal and public comment (in
progress)
. Distribution of draft EA study report to review team (CNSC staff, federal and
provincial authorities) and the Municipalities; revision, as appropriate, ofEA
study report and issue to relevant federal, provincial and municipal agencies, and
public notification; CNSC staff preparation of draft screening report
. Municipal and public review and comment on draft screening report; CNSC staff
review and dispositioning of municipal and public comments; CNSC completion
of screening report
11
COMMENTS ON "11.0 CONCLUSIONS AND RECOMMENDATIONS FOR
DECISION"
No comments.
Page 4 of 4