HomeMy WebLinkAboutCAO 12-00G`,�y OF P/p,� 121
� Q
�
���� REPORT TO COUNCIL
FROM: Thomes ). Quinn DA7'E: June 20, 2000
Chief AdminisUntive Officer
REPORT NUMBER: CAO l2-00
SUBJECT: Pickering "A" Retum to Service
- Peer Review Teum Comments on Drnft Environmental Assessment
- File: iJ'T 3540
RECOMMENDATION:
l. That Council receive Report to Council CAO 12-00, which Report includes as
Attachment No. 1, commenis from the City's Peer Review Tenm. on the DraR
Environmental Assessment Report for the retum to service of Pickering "A".
2. Thut Council cndorsc the Pcer Revicw Tcam's comments on the Dmft Environmenml
Assessmcnt Report for the retum to scrvicc of Pickering "A" and fonvurd these
comments to thc Cunudinn Nuclenr Snfety Commission for consideration, nnd the Ontnrio
Power Generation for informntion.
3. Thut in light of thc Pecr Rcview Tcum's finding that it is not possible at the prcsent time
to support thc conclusion that the rcstnrt of PNGS-A is without significnnt adverse
environmentnl effects, Council requcst the federnl Minister of the Environment to refer
the project either to n Revicw Punel or to a Mcdiator, under the Canadtan EnvTronmenlal
Assessmen� Ac7, in ordcr to addrcss thc issucs nnd conccros miscd by the Pcer Review
Teum in response to thc DmR Environmcntnl Asscssmcnt Report, nnd in response to the
DrnR Scope of Assessment Document.
4, Thnt n copy of Report to Council CAO 12-00, be fonvurdcd to the Canndien Nuclear
Safety Commission, the Federni Minister of thc Environment, the Ontnrio Power
Genemtion, und the Honoumblc Dnn McTeague, M.P. Pickering•Ajax-Uxbridge.
OR[GIN: On May 1, 2000, a DraR Environmental Assessment Report was officielly
released by the Atomic Energy Convol Boazd (now Canadian Nuclenr Snfety
Commission) concerning the rctum lo service of Pickcring "A". Commcnts on
the Report tue requested to be fonvarded by June 30, 2000.
AUTHORITY: Canadian Envlronmental Assessnrent Act
Nuclear SuJery and Conlrol Act (fortnerly Atomtc Energy Confrol Acl)
FiNANCIAL IMPLICATIONS:
Oninrio Power Qenerntion hes agrced to cover the cost of the City's Peer Rcview Tea►n to an
upset limit of 598,600 plus disbursements. Accordingly, to dute, therc hnvc bcen no financial
implications to the Ciry for the Pcer Review Tcum's pnrticipation in the cnvirontnentnl
assessment process.
12 2 Report to Council CAO 12-00 Dntc, June 20, 2000
Subject: Pickering "A" Retum to Service Page 2
Peer Reviow Tenm Comments on Drait Environmental Assessment
EXECUTIVE SUMMARY:
This Report to Council summarizes the comments nnd conclusions of the City's Peer Review
Team concerning the Dcaft Environmental Assessment Report on the retum to service of
Pickering "A". The Peer Reviaw Team's full report on the matter is included as Attechment
No. 1. It is recommended that Council endorse the Peer Review Team's report end forward it to
the Cunadian Nuclenr Safery Commission for consideretion.
The Peer Review Team notes thut despite the volume of information prcsented in the Draft EA,
the mnterial is well written und user friendly. However, the Peer Review Teum also identifies the
presence o£significant data gaps, and therefore finds thnt it is "not possible ut the present time to
support the conclusion that the restnrt of PNGS-A is without significant ndverse environmental
effecls".
In light of this finding, it is recommended thnt Council rcquest the Fedeml Minister of the
Environment to refer the project either to a Review Pnnel or to a Medintor, under the Canadian
Envtronmenlal Assessment Acl. _
BACKGROUND:
On Muy 1, 2000, a DraR Environmcntal Asscssmcnt (EA) Rcport wus officially relensed by the
Atomic Energy Control Board (now the Cnnndian Nuclenr Snfcty Commission or CNSC). 'fhe
DrnR EA was subsequently fonvnrdcd to our Pecr Rcview Tenm for rcview und comment. A 60-
day rcvicw period hns been nllowed, and comments on thc Dratt EA must therefore be submitted
to the CNSC by lune 30. Cauncil will rccall that it mndc u fortnnl rcquest for a 60-day cxtension
to the public review period, but this requcst hus sincc been denied.
This Report to Cauncil providcs u brief ovcrvicw of thc DmR EA Repori and support
documentation, and thcn summarius our Pccr Rcview Team's principnl comments. The full
report of our Peer Review Team is included as Attnchment No. 1.
T6e Draft EA Report
The DrnR Environmentnl Assessment Rcport consists of two volumes:
• Volumc I: Main Report
• Volume 2: Appendices
Also availnble, but not part of the EA, ure nine Technicul Support Documenls and an Annex
Report on the 160+ issues thnt were identitied during the 1998 "Environmenwl Review" of the
Pickering Nucleur Generating Station.
The nine Technical Support Documents provide detailed informution on the following topics:
• Radiution and Redioactiviry;
• Atmosphere and Environment;
• Hydrology nnd Water Qunlity;
• Aquutic Emironment;
• Terrestrinl Environment;
• Qeology, Hydrogeology and Seismicity;
• Communiry and Swkeholdcr Consultation;
e Lnnd Resourccs; and
• Socio-economic Conditions.
Report to Council CAO 12-00 Dntc: June 20, 2000
Subject: Pickering "A" Return te Servicc Page 3 12 3
Peer Revicw Team Comments on Drnft Environmenml Assessment
Copics of the Dmft EA, Annax Report and ninc Technicni Support Documents ere availnble for
public reference ut libraries in Pickering, Ajwc, and Toronto (Scnrborough) as well as at the
Pickering Nuclenr Infortnntion Centrc. The Drnft EA is nlso uvailuble in electronic form on CD.
It should be noted thet nt this time, the Dratt EA Report is not n report of the Cnnadian Nuclear
Safery Cammission, CNSC staff will be conducting a detailed review of the Draft EA nt the
same time as other federal and provinciul govemment depurtments nnd the public. CNSC stafT
will then issue a Finnl EA Report for consideration of the Canndian Nuclear Safety Commission
(fortnerly AECB) once they are sntisfied thut all comments raised during this review period huve
been satisfactori►y uddressed.
Peer Review Team Comroen�i on DraR EA Renort
The Peer Review Team provides some general comments on the swcture of the Draft EA
Report. They note thnt the Report is well written, well organiud, clearly swctured, eusy to
nuvigate und user friendly. They also note that the figures nnd tnbles are cleur, well prcsented
and conveniently locuted.
The Pecr Review Teum nlso supports n conciiuion artived nt in the DmR EA thnt, based on
curtent knowledge of the biological effects of ionizing radiation, the retum to service of PNGS-A
should hnve negligible effect upon thc health of the generel public during normal operntions.
However, the Peer Review Tenm finJs that the DmII EA Report is incomplete with re�ard to the
annlysis of the geological setting of PNGS, scismic risk, ground and surfacc waters, (including
the wuters of Lakc Ontnrio) and lhe utmosphcric cnvironment. The Pcer Revicw Temm �otes that
the fnilure of the DmR EA Report to adequately recogniu thc cxistence of significnnt dam gaps
in the understnnding of curtent environmenml conditions nround PNGS undertnines the
credibility of the conclusions made by OPG as to thc abscnce of "nny significant adverse effects
of the project on the environment" nnd scvcrcly comprises the adequacy of the follow-up nnd
monitoring program. Thc Pcer Rcview Tcam fcels thc process of dccommissioning will also be
wenkencd by the same Inck of missing datn.
Some of the key commcnts of thc Pcer Rcview Tcum with respect to specific nrens of concern
within the DraR EA Report nre outlined below:
• There is insufTicient datn on the atmospheric environment to differentiate
contributions betwecn PNGS-A and PNGS-8, und nlso to differcntiate
cantributions of urbnn !raffic. They nlso fcel that OPG did not adequntely
model the dispersion plume distribution for hydrazine and tritium.
• There is luck of complete water tempemtum dam afier 1979, making it
� impossible to evulunte thc impact of the combined operation (PNGS-A and
PNGS-B) on fish temperature environmcnt. The dnta is too limited to do n
criticnl evaluntion of the plume on the distribution of fish hnbimt.
. The results of the sediment qunlity study were based on too faw samples and
no details were provided about the analyticnl methods used to determine the
chemistry of sediments. Also a number of these elements do not meet the
"lowest ellect level" for sediment quality guidelines.
• There is also not curtent dutu to describe the existing conditions with regnrd to
pinnkton communities in the study arcn. 'fhe effects of thcrtnnl plumcs nre
also based on questionnble his►orical dnta.
• The hydrogeologicnl nssessment is highly inadequntc, focusing on
groundwatcr insidc the site boundaries, but ignoring thc groundwutcr bcyond
RepoR to Council CAO 12-00 Dnte: June 20, 2000
. 12 4 Subject: Pickering "A" Retum to Servicc Pa�e 4
Peer Review Tenm Comments on Dmfl Environmental Assessment
the site boundnries. There is ulso no quantilative understnnding of water flow
within the site due to the complexity of the site, site altemtions and current
development.
• With respect to seismicity, there nre serious oversights (e.g, geological map
present in preliminnry drnft but removed fram dmfi EA documeni). Such dnw
hns bearings on the identificntion and enalysis of geological structures under
und neFU the plant thnt are capable of genernting earthquakes.
• Although infonnntion relating to mdiation exposure is considered acceptable,
the main heulth issues seem to be uround the psycho-socinl impucts of living
neur the plant. The role of psycho-socini fuctors in gcnemting physical
nilments has not been addressed.
• Dewiled resolution of muny of the 160 + issucs identificd during the 1998
Environmenml Review cannot bc resolved becnuse of the significnnt dntn gnps
in understanding the physical cnvironmcnt.
Bosed on the datn prcsented in the Drnft EA Rcport, the Pecr Revicw Tcam concludes:
l. OPG's knowlcdge of locnl and regionnl bascline environmentnl conditions
surrounding PNGS, including thc wutcrs of Lake Ontnrio, remnins incomplete
with rcgord to sevemi scientific disciplincs. Existing dnta do no� allow full
chnractcri7ntion of currcnt local and rcgional environmcntnl conditions nt und
surrounding Pickering NGS. Dcscriptions of existing atmospheric,
gcclogicnl, hydrologicul and hydrogcological conditions und aquntic
environmcnts are particularly inadequute.
2. Incomplete understnnding of existing cnvironmenwl conditions, in the view of
thc Peer Revicw Tcam, compromises crcdiblc dcterminution of thc currcnt
en�•ironmcntal impact(s) arising Gom thc operation of PNGS.
3. Incomplete understnnding of existing environmenWl conditions compromises
crcdible evaluntion of the future potential cumulntivic environmentnl impnct(s)
urising from the rc-swrt of thc PNGS-A fncility.
4. The conclusion reached by OPG thut °lhe rewm to service of PNGS•A is not
likely to result in nny significant ndversc effects on the environmenP' is not
ndequately supported by dala presented in the Drnft Environmental
Assessment Report.
5. The 160+ issues identified by the public community in 1998 tivough the
Pickering Environmental Review consultation process have bcen considered
in cursory fashion by OPG in the Drnft Gnvironmental Assessment Report.
Resolution of mnny issues, particularly those concemcd with the physicul
environment at, under nnd surtounding PNGS, are compromised by n Inck of
duw.
6. OPd nnd its consultnnts have mnde no substantive effort to improve th� DraR
Environmenml Assessment Rcport in response to the Revicw Tcnm's cnrlicr
comments on the Preliminary Dmft Environmental Asscssmcnt Rcpori.
Report to Council CAO 12•00 Dntc; June 20, 2000 i 2 rJ
Subject: Pickering "A" Retum to Service Page 5
Peei Review Tenm Comments on Draft Environmentnl Assessment
tn the finnl analysis, the Peer Review Tenm finds thnt it is not possible at the present time to
support the conclusion of OPG thnt the restnrt of PNGS-A is without significant adverse
environmental et%cts.
Sta(tCommeots
Staff concurs with the Peer Review Tenm's sinnlysis, comments und conclusions with respect to
the Draft Environmental Assessment. It is recommended that Council endorse thc Peer Review
Tenm's report as the City's comments on the Draft EA, und fonvard these comments to the
Cnnadian Nuclenr Safety Commission for considerution, and to the Ontnrio Power Genemtion for
information.
Council will nlso recall thnt on Mny 15'", 2000, Rcsolution #83/00 was passed advising (among
other things) thnt the City reserves its right to request thnt this malter be referred to a review
pnnel or lhird party mediator under the Canadian Environmenfal Assessmenf Acl.
In light of the concems rnised by our Peer Review Tcam, it is recommended thnt Council request
that the EA relntcd to the retum to service of PNGS-A be rcferred by the Federal Minister of the
Environment to n Review Panel or n Medintor, in order to nddress thc issues and concems raised
by our Pcer Review Teum, not only in thcir comments of Junc 2000 on the DraR Environmental
Assessment Report, but also in their commcnis of Novcmber 1999 on the Drnft Scope Of
Assessment Document.
ATTACHMENTS:
l. Peer Review Team commcnts of Junc 2000 on thc DraR Gnvironmcnwl Assessment Report
2. Pcer Revicw Team comments of November 1999 on the DraR Scope Of Assessment
Document.
Prepnred By: Approved / Endorsed By:
. ,
ordo �^ � omas J. Quinn
roj � o-ordinator Chief Administrative Oflicer
mes E. ely ilc
Division end, orporate Projects olicy,
JGR:jgr
Recommended for the consideration of Pickering
City Cowcil
��� ..
/ �/
omas J. Qui , Chi Admim tive 0 ar
� ItVtEPOR7S1C�o12-0O.DOC
, .. ._ .�...,... ,.. Y... ..,.. -. .-... . .,. - . . ,.. , . �. ... . . _.. ., , .. . . . . .. .
� ,
`� ln� � ' N�f ; � 'la (Y�}D 12-00
_ . � . �
• • . . 13W June 2000 � � '
� Par Rcview Team commcnts on: • ,. �
• � Pickedng A- Return to Service Environmental rl�aeument Report
Draft Submiseion,to r1ECB . .
' . ' • AprU 2000 . .
� PRT doc 009�.
,
Dr. N. Eylcs , Univecsity of Toronm
Dr. P. Chow-Fraser McMester Univeroity •
Dr. S. Ellion ' ' McMaster Univer�iry •
• Dr.CHEyles McMasterUniversity . ,
Dr.J.Harvey McMesterUniversity , ,
Dr. K Howard Univereity of Toronto .
• Dr. W. Morris McMaster Uaiveroity • •
Ivlr. M Doughty Administrative aasistaat; U of T ,
' � . , �
� 1
. ' ' . � r
• PURP03E OF THI9 DOCUMENI' � �
. Tho purpose of thls. dowment l� to present the Peu Revlew Team'a (PR1) review of the DraB 12 7
Eavironmaatal Assessment Raport (DEAR) released by Ontario Powu Generation (OPG) on �
Apri129th, 2000. The aubmission of DEAR is in responae to the requeat of the Aiomic Enugy
Control Board (AECB; now Canadian Nuclear Safety Camrtussion) for m Environmeatal
Asswsmaat priorto the restart ofPickcringNuclear Generating Station'A' facility (PNGS-A).
STRUCTIJRE OF THI3 AOCUMENT •
Ttda document u prefaced by geaeral comment� regerding tha context and criteria u�ecl by t6e
PRT to essess the DEAR, a ahort aummary scatement of the strengths and weaknesses of the
DBAR followed by speciSc wnclusians. Detailed comments, discipline by discipline, are '
ePPended. ' . .
CONTEXT OF'I� PRT'S REVIEW
The PRT's Review is made in the context of thrce documents:
1. The Final Scope Document as released by AECB in January 2000.
2. The PRT's reviow of an incomplete version of Sections 4.0 and 6.0 of the Preliminary
Draft Environmental Assessment Reporf (PDEAR) and submitted to the City of Pickering
by the PRT on December 16th, 1999 and Jaauary 21st, 2000 respectively (PRT docs 005
and 00�.
3. OPG's . responsa to PRT's review of PDEAR and addressed to the Corporation af the
City of Pickering (F'�e: NA44-07730 TS dated March 30th).
CRTTERIA USED BY PRT
In reviewing the DEAR, the PRT employed similaz criteria as used previously to guide its
assessment of the earGer PDEAR documenG The PRT sought to ariswer the following questions:
1. Do tha data presented in the DEAR allow fu!l duvocterlsnNon ofthe wrrent local and
regional emironmental conditions at and surtounding PNGS7
2. Do the data preseated in the DEAR permit detwmination of the current impact of the
opaation of PNdS on the surrounding local and regional eavironment7
3, Do the data preseated in the DEAR pwmit evaluation of the fulure potemiel cumulative
impact(s) of tho restart of PNGS-A on the surrounding local and regional
environment? .
4. Are the principal conclusions presented as to the environmental impact of the restart of
PNGS-A,'suppoRed by the data presrnted in the DEAR?
2
. .� . , .
�? 8 5, ' I� thcro a eyetematic ettempt to addreaa tho' 160 + ienuts' brought forwazd by the public •
community in the 1998 Pickering Gnvtronmmtel revicr�l
In addidoq the PRT employed a further criterion: • '
. 6, Have OPG and its consultantq adequately dealt with the concems identiSed by the PRT in •
, • their earlier reviews of the PDEAR in December 1999 end January 2000? ' '
. . OVERALL COMbIENT ON DEAR
Pickering Nuclear Generating Stadon has operated for neazly 30 years in a densely-populated
ngion and a thorough evaluetion of its impact on the surrounding environment and communiGes
is timaly and appropriata. The region swrounding PNGS is experiencing rapid urban development,
lies close to a major water body used for driniring water that is ahared with the U.nited States, and
includes na6onally signi6cant transpartation routes. Tho safe ope{adon ofPNGS is the subject of
a high level of public concem and discussion in the surrounding wmmunities. Environmental
evaluation ia a complac task and relevant environmentel infortnation must be available on
appropriato spatial seales ead timescales. Larga datasets have to be compiled, synthesised and
essessed and datagaps identiSed. The Draft Environmental'Assessment Report (DEAR) is the
largest systematic effort to do ao sincc PNGS was constcuctod. '
The PRT congatulates OPG and its consulting team on a substantial document that is on the .
whole well-written, is appropriately end clearly structured and, despite its size, is 'user friendly'..
In general, the report is well organised and easy to navigate. In pert this is faciGtated by the ability
to review the main report as a.pdf file, which not only improves accessibiliry, but allows quick
cross-referencing and easy review of acronym� end glossary itema. Figures and tables throughout
the report are generelly clear, wep presented and conveNentiy located. Hecause of the clazity of
tha overall documeoy assessment of the adequacy of the database for each scientific disciplina is
easily facilitated.
Completeaess of the databaae
• Radloactive emU�iooa: The DEAR makes clear that the environmental databesc for
PNGS is most thorough with regard to monitoring for radioactive material in sta6on
emiaaions and in the surrounding emironment. For a number af years, OPG has
conducted routine measuremenq ofradioactiva emiasions end consequenAy, the database
is considerable. The methodology for converting these measurements into doses to �
members of tMe pubGc is well-estabGshed both in Canada and in the rest of tha world. Tha
PRT finds that there is no obvious environmental paihway that hes been ovedooked by
OPG. Although the PRT 6nds uncertaindes and inconsistencies in 'the parameters used by
OPG to arrive at dosea, it is higlily improbable that the doses are gossly in error. OPG �
and its wnsultants are covunended for dexnbing the basis for these dose wtimates in
some considerable detail. The PRT notw that utimated doses to ihe pubGc are a small
fraction of both the regulatory limits and natural background.
Consequently, the conclusion reached in the DEAR that, based upon cuaentlmowledge of tho
� 3
biological e@'ecte of ionizing radiadon, .the rehun to servico ofP(3NS-A ehould have �
• negligible affect upoh the health of the geaeral pubGc during nom�al operatione,;ia 12 9 '
supported by tha PRT. • , • ' .
However, the PRT notes that althoUgh radioactive emieaiona at PNGS appear to fall witLin
regulatory limits for allowable doaw to membera ofthe public, public health must be constdered ea
being more th�n simply the absence of diseare, It is represented by completa aocial, pfiyeical end
emotiona! vyell-being of the humen populadon aad es auch, thi� issuo in very poorly dealt
' ' with in the DE:AR
• Physical Environment: Tha PRT finds that the DEAR�is fricomplete with regard to
analysis of the geo!ogical setting ofPNGS, aeismic risk, ground and surfaca watera
('mcluding the'waters of Lake Ontario) and the atrr�ospheric enviroament. Present
understending of much of the physical and aquatic enviroaments surrbunding PNGS is
, patchy. Despite large amowts of data presented in the DEAR, thero is a geneta( inability
� to distill data to provide a meaningful statement a4 to'existing basefine condidons' as ..
required by the FLial Scopa of tho EA. Such conditions must ba well defined ifthey are to
provide a reasonably precise line, or starting point &om which futura changes and impacte
• can be reliably measured and evaluated The fact that this cannot be done for PNGS is '
largely becausa suitable environmental data were not collected during the conswction and
early years of operation of PNGS and data collected subsequenUy were wUected on an ad
hoc basis to satisfy speciSc'remedixl' investigutions. In the opinion of the PRT the
frequent /ack oJa c%ar bareline wlth respec! to several scien��c discipltnes remains the
mar( serlous deficiency oJthe DFilR and thus of !he evaluadan of the �mpacJ arlsing
from restart ofPNGS A. As a result, the conclusion as.to the absenca of any likely future �
adverse impacb on the surtounding environment arising from the restart of PNGS-A must
be teken lazgely on Wst. •
Fatluro to addreas environmental datagapa
The PRT highlightcd the pre�ence of significant data gaps in environmental knowledge regarding
tho existing environmental condidons surrounding PNGS in its earlier review of the PDEAR in
December 1999 and January 2000 (PRT docs 005, 00�. The PRT also identi6ed numerous areas
for improvement and clarificadon. This continues to be the most siguficant weakness of tho
current EA. The PRT is very disappointed in the lack of acGon taken by OPG and its consultants
to address such conceme on a detailed besis in the DEAR; aome concerns tiave been dealt with,
but most have been ignored and in some cases, less information is presented in thc DEAR than in
tha PDEAR. OPG's fortnal response to the concerns of the PRT with PDEAR is limited to a•brief
letter to the City ofPickering (dated March 30th 2000) that simply seeks to escribe such dategaps
to the fact thet tho PDEAR document was 'incomp(ete... and 8eld studies end data collection
were still in progress at the tima'.
The PRT also requested that OPG supply the Ciry of Pickerin$ with a comprehensive list of all
ongoing or planned environrhental projects. In responsq OPG submitted a list ofPickering .
Nuclear Projects rolated to measurement of potendai eavironmental effects (letter dnted March
4
13 0' lSth; Fi7e NA44-07730 TS). The PRT Ie concertied that the tLneframe for completion date of
ongoing eavironmental etudiea in moet caaea, exceede tha timefreme of tho currqn asaeeunrnt.
Tha PRT concluded ia ita earlier review of the PDEAR (PRT doc 005, p: 4; December 16th,
1999) that "In ordv to esses� the cumuladve efl'ecte of Pickbring NGS at the restart ofPickaing
NGS-A (as required by the Draft EA Scope) a eystematic end comprehensivo appmach ie needed
to data collection In order to identifj� tha ffiIl range of environmentel condi6ons ia and around
Pickering NGS.......simple wmpiladon of exieting data collceted prevtously for mOnitorL�g
pwposw and/or apeciHc remediel projecta is'inadequate a� substantial data gaps cen be identi6ed".
The failure of tLe DEAR to adequatety recognise the e:istence of eigntfteant datx gap� in
We understandlpg of turnat envirohmeotal condldon� around PNGS underminea the
. credibillty of the conclusfons made by OPG ns to t6e abaence of "any aignificant advene
etkcts af the project oa the eavironment" (p.13-3 Matn Report of DEAR) aud uve�relq
compromi�w the adequacy of the Plap for Follow-up and Monitoring Program (Section
11.0). . . .
The presence of signiScant data gaps and ebsence of a coherent environmental research and action
plan at PNGS that is fiilly cognisant o� end is designed to Sll existing datagaps, is a cause for
� concern, not only for the present EA, but for eny assessment of the likely environmental impacts
arising from eventual decommissioning of PNGS. The decommissioning exercise will ba weakened
by the same lack of data that circumscdbes the current EA •
� ` , 5�
' : PRIN�AL CONCL�T3ION3 ,ARI3ING FROM THE PRT'� REViEW OF DEAR 13 �. ,
• On the basis of deta presentod in the DEAR, the conciueions of the PRT are: .
� 1. � OPG'a la►owledge of local end regional baveline enviranmental wndiGone surrounding ••
PNGS, iucluding the watera ofLake Ontario, nmains inwmplete with regard to eeveral
acienti8o disaplina. Fatiadng data dv not alloyv liiU chazacterisation of aurent local and
regioael eavironmental conditions at md eurrounding Yickering NGS. Deacripdons of
. , exisdng aUnospheriq geological, hydrological and hydrogeological conditions and aquatic
environmenta ere partiwlerly inadequeto.
2. Incomplete unda�tanding of existing environmental conditions, in the view of tho PRT, '
compromises credible detemiinadon of the current enwonmental impact(s) arising &om
the operadon of PNGS. , • � .
3. Incomplete underatanding of adsting enwonmental condi6ons compromises crediblo
evaluation of the fiiture potential cumulative environmentel impact(s) arising &om the re-
start of the PNGS-A facility.
4. The conclusion reached by OPG that "the retum to semce ofPNGS-A is not likely to
result in any significant adverse e�'ects on the environmenP' (Section 13.0: Main'Report,
p. 13-3) is not adequately supported by data presented in the DraR Env�ronmental
Assessment Report (DEAR). � '
5. The' 160+ issues' identified by the pubGc communiry in 1998 through the Pickering
Environmental Review consuitation process have been considered in cursory fashion by
OPG in the DEAR. Resolution of many issues, particularly those concemed with the
' physical environment et, under and surrounding PNGS, is compromised by a lack of data.
6. OPCi and its consuitants have made no substantive effort to improve the DEAR in
response to the PRT'e earlier comments on the PDEAR.'
It �i the f5nding of t6e PRT ihat it v pot possible at the preaent time to aupport the
condueion of OPG that the rutart of PNGS-A t� without aignificant adverse enviroamental
diecW.
0
• 6
0
� 3 2 . DETAII,ED COIVII�IENT3 DISC7PLTNE BY DlSCIPLIIYE: .
. SEGITON �.0: PURpOSE pND DESCRIPI�ON OF PROJECT .
•. • Throughout Section 4.4, the DEAR malcay eavera( claims th8� ���y��, or that are
overty-optaniatic; ell aro of tha eame farmaG Examplw are:
• p 42expected to last beyond the rematning plenned operationel lifa:' (Sxtion 4.4.1, .
. ,"will ba in good condition and operate rcliably throughout the planned operationa(
lifa.. " (Sxtion 4.4.1.2, p. ¢20)
. "are capablo of performing throug}�odt tho remaining planned operational life.: "(Section
• , 4.4.1,3, p, 4-21) . • ,
"to ensuro that the boilers remsin serviceab(e" (Section 4.4.1.5, p 4-22), A dictionary
claims that "epsure" means to "to make sure; guarantee^, .
' .• The ahutdown systems forPNGS-Awill be *significanUy improved" be£ore rotuin to service.
What are the plans far PNGS-BT Or do they havo the improved shutdown systems7 (Sec6on
.4.4,4.3, p. 4-30) • •
• Refereoce is made to elevated tridtun levels in the groundwater adjacent fo the Irradiated Fuel
Bay (Secdon 4.6.3, p 4-60). The leaks aro to be repaired; no mention is made regarding
remedial actions to be taken.
t, • •
, ,..ry - ' ,
SEGTION S.Os CO7VIMUNTPy AND STAI�HOLD�R CONSULTATION �. 1�3
The PRT'e comments on the draft communi.ty consultation plan (PRT doc 001, aubmitted Nov 25,
, •] 999) ateted that while the plan looked useiiil, the documcnt wes 63s�ed toward what wea to be
donq and presented Gttle information as about haw. DEAR ia eubjcct to the same criticiam. •
• • For exemplq Tablo 5-8, Summcvy ojPubllc and O�her S�akeholder Co�csulla�ton Activldes
Gsts an extensive list oFconsultation activities taking various fornu (e.g., from newelettas to
Intemet sites) with a wida variety of stalceholdec� (see related Teble 5-2, Stakeholder Conleul
Lis�tj; however, theFe is no indication in tlus aection of how theso ecdvitiea were carried aut
nor whether or not they wera'successful' in meeting tha nxds/addressing the concern� of the
various stakeholders. '
• ThQ PRT rert�sins very uneasy about tha so-called'briefings�'mterviewa' held with lcey
stakeholder� and the related atatement (Table 5-8, 5-30) that "data froro the interviews were
; used as input to•the EA process and to improve tha consultation program." In short, •
. interviews with key stakeholders were apparently conducted and the results of tt,ese informed
both the community consultation progiam in general as weli es t6e Gst of key issues found in
Table S-7. How this occurred is not explained in the DEAR, Tha PRT is uncertain as to
whether or not the manner and approach used to consult with the wide variety of affected
' communitiw indeed addressed the issues of concem.
•.On a related point, on page 14 in the draft community consultation document, there is
discussion of the tracking data base which ".,.helps to demonstrate and document how the EA
has addressed public concerns and issues". This is related, to the quate in this section of the
DEAR (teken Gom the Scoping Document) which states that: OPG ahould maintain a list of
ell comments received and how they have bcen dealt with by the assessment team (5-2).
Appazently, (Section 5.1.6, and 5.1.6.1j this data base ofcomments has been used to provide
tho information in Table 5-7, Keylsswes and Fri Secttnns Where TheyAre To Be Addressed. .
Again, however, therc is no exptanation of how theso particular issues werc gleaned from the
data baae. On the basis of reviewing the minutes of various wmmittee meetings (CAC;
. DNHC; PLC) included in the technical documentaGon essociated with this section of tha
DEAR, the PRT concludw that the key issuw raised in the aforementioned table are
consistent with ihose the community are concerned about, given the project proposed.
,• The PRT withholds any conclusion as to whether or not the concerns raised have been
mitigated in any way by the responsw provided; there is simply no evidence provided on
which to judge the outcome. This lack of evaluation by OPG, as to �ie success of mitigation
measures in the eyes pf the pubGc community, is a aerious isaue as it goes to the centrel issuo
of pubiic safety. � .
•• Page 5-1, opening paragraph, 5naj sentrnce: 'Information from the pubGc and other
atakeholdere was used in the EA, as descdbed in Section 3.2'. In point of fact, Section 3,2
basically states that public wnsultation was done, but not how informadon was used.
• Table 5,2: day caze and senior centma are not included in the list of local service providers.
8
13 4��ON 6.2: RADiATION AND RADIOACITVITY '
'� • The &at refennca to UNSCEAR rocommondations ie given in Tabie 6.2-2, p. 6.2-4. Although
' theY are reforred to in the Technicel Support Document (TSD), they ehould alw be given
here. In the absence of AECB guidelines, it 3a reasonable to adopt these. FIowever, no
,, justi8cation ia given in thio eectioq and thero ts no IndIcation that the AECB accepts }bea�
recommendatIons. •
• In the casa of human,s, one aelects a cridcat grqup that is likely to receive the highest dose
• ,(Section 6.2,4, p. 6.2-10). This does nat seem to be the casc for VECs. However, this ia not a•
cridcal point as tha doses aza so negligible. • .
• Section 6.2.5 (p. 6.2-12) ignotes the fact that aome of the tridum emitted as water vapour
' becomes incorporated into organic molecules during photosynthesis or.during metaboic
processes. This organio-bound tritium (OBT� gives a higher dose per unit inteke of acGvity
�ian tritiated water. (The TSD indicates a Eactor of tivee). Reference in the TSD is made to
"raw data" from AEQ, that allows an "estimate" of the OBT in food. This is an area where
addidonal research should be conducted. Particulazly in the area of incorporation of OBT by
infants. .
,• It would be helpful if the DEAR described the pathway for tha isotope Into tha environment
(Table 6.2-5, p. 6.2-18). This would allow a better appreciation for the remedial measures to
be implemented and help in assigning priorities. For example, H-3 is found in the boiler
blowdown. How does it get there7 Through leaks in the heat exchanger7 If so, why are I-131
�and thd noble gases also•not found in the blowdownT Also, the table claims thet I-131 is found
in the exhaust system &om the UPP and Sulzer. Elsewhere, it is claimed that before upgradiag,
the water is purified using ion acchange columns to remove the C-14. The I-131 should also
be removed.
• It is claimed that I-131 in air hav not been meas�ired historically and so is not wnsidered a
major exposura pathway (Section 6.2.8, p. 6,2-19). One would hava mora confidence ifthe
' lower limit of detection for this isotope was giveq and how this Gmit compares with tho
industry standard. • • .
• It is cleimed that.'"There are no regulatory limits on tritium concentrations in air•against which
the mea'sured data can be compared"(Section 6.2.8.1, p. 6.2-20), This is incorcect, and similar
etatements are made in following aections. Thero are annuel dosa limits on individuals,
wheth«' they be workers or the pubGc. One can calculata the concentration of tridum in air �
tha+, if an individual wcre exposed to it for 2000 hours pa year (workers) or 8760 hours per
� year (public), Wrn the maximum pemussible annual dose would bo attained. Thi9
concentration is lrnown as tha Derived Air Concentradon (DAG� and was previously knowri at
• the Maximum Permissible Concentration (IvIPC). These values are given in ICRF documents
and frequently referted to in AECB documents and licenses. Moreoyer, station emission limits
� ue besed on these DACs; tha releases must be such that the wncentration at the boundary
does not exaed the DAC; these emission timiq are license conditions and so are rogulatory
. . 9 ,
. limits. So they may not be explicidy lisced 1n AECI3 regulationa, but thue are regulatory limits. 1� S
D�AR leavw the imprea�lon that there are ao atanderda or ref'erence values for air "
. conceatratioas end thua the haiard te negqg�'ble. � .. �
' DEAR cleima that there�are no roguletory limiW an radioactive perticulaee depoaition againet •
whtch the measured data can be compared (Section 6.2.8.3. P, 6.2-23). There are derived
limita based on the doae the public will receive. Othenviee, how could OPG detemtino their
• emission limiwT • .
• Just es there is a DAC for tritium; thcre ia a DAC for each raro gas (Section 6.2.8,4, p. 6.2-
23).
• Section 6,2.8,4 (p. 6,2-23) raisea serious quesdons conceming the self-consistency of OPG
environmbntal monitoring daia.
. Uaing a gamma monitoring system, the dose rates from two specific isotopes (argon-41 and
xenon-133) were measured for 8 months at a boundary site. All measurements were ]ess than
the lower limit of detection (LLD). OPG and ita consultents then cancluded that tho doso must
be less than the sum of the LLDs of the individual isotapes, or 0.28 Fgy, •
(Nole: Jhe suin of a sesles of ineasu�emenls, eqch ojwh/ch is less thcm the LLD, does not give
the overal/ upper /imif. For examp/e, ijfor a weel� a measure ts made ojdatly rainfall using
a Jechnlgue wlth a LLD oJ1 mm, the best esttmate for ihe amounl ojrainfal! dwtng the week
can not be "less lhan 7 mm': It must be some fractiwl of this Xowever,lhis is the technique
tlurt OPG ►ouNnely rrpp(tes to its measuremenls.)
Besed on Imown tritium emissions and measurements of the tritium concentration at the same
boundary locadon, an empirical dtlution factor can then ba determined. This diluGon factor, in
conjunction with the known release of rare gases, allows OPG to calwlate a dose from the
rare gases at that point. This dose, calculated in the same manner as for doses to the pubGc,
ovorestimates the dose obtained from the gamma monitoring eystem by about a factor of 30; it
could be evm a larger factor if a more sensible method were used to obtain a limit &om�the
gamma measurements, •
OPG and iy con�ultankt then rcfer to theae roeasuremenb aa proof that they are '
probably overatimaUng the dose to the pubifc by about a factor of 10.
Some questions raised by this methodology are : Why wera only Xa133 (5.2 d) and.�Ar.ql
(1.83 h) measured by gamma spectroscopy7 Why not include Xe-135 (9.1 h), I{r-85. (11 y),
Kr-85m (4,48 h), Kr-88 (2.8 h)?
Does OPG know tho actual mix of rere gas isotopes released7 OPG generally refera to
emissions of rare gases in teims of MeV-Bq/m'. (Note: 10 Bq/m' of a rare gas emitting a 1
MaV gemma cay, or 5 Bq/m' of a rare gas emitting 2 MeV average gamma ray energy can ba
both described es 10 MeV-Bq/m' of a rare gas and eitfier wili givc the same dose to an �
individual immersed in a cloud of this gas). Perhaps tlieir mcesurements, wing cc�mpensated
detectars, cannot discriminate between.isatopa 6ut give the product of the concentration aad
energy, which is sufficient for dose calailations. Ifthis is Uue, how were only Ar-41 and Xo-
133 selected for measurement7
10
• 136 Most lmportantly, how can titia diacrepency botween calculaBon end measurement be •
� resolved? • . .
. First, assume the ganuna ray meaauremenW are correct.
•' 'Are. the ompirical d'ilution factoro In errorl If ao, either the esdmated rdeese ratea of
tnGUm aro in error, or the environmentel measurementn of tritium in air are in erro�,
If tha empirical diludon factoro ara coaect, then either the OPG valua for the releaae
rates of rare gases ere in eROr or their method for calculnting doses to the pubGc &om �
• rare geses ia in error.
: Altematively, assume the gamma ray measurements ere in error. .
. Then the Samma ray spectroscopy measurements were incorrect. These txhniques ere
used to assay many other parameters, such as amount ofI-131 released or in
• environmental eamp�es, Th�ye measurements then alsa muat be in doubt '
: • If the spectroscoPY BYstem was operated cotrectly, then either not ell the isotopes
were analyzed or tLe calculadons were incorrect. • .
The documentation provided in DEAR doe� not attempt to reaolve thi� dlscrepancy.
However, thb dLscrepancy Indicatea that erroneous mea�urementa are beiog made,
elther in t6e eropirfcal, dlluUon factoro, or t6e rdease ratea, or in t6e gamma
apectroscopy. This must be addraud. • . .
• Once every year, ppG takes a grab water sample from Lake Ontario (Section 6,2.9.1, p. 6.2=
25). Routine sampling oE WSPs is conducted, and efDuent monitoring also occurs, The utiliry
of this grab sample measurement is uncertain; the sampling ts non-representative and adds .
nothing to doso calalations. The �esulcs presented in the TSD (page 6.2-31) indicate that the
concentration for the discharge channels in 1998 were more than tivee timea @ffiat for 1997 and
1996; the concentration at Du�ns Crcek was about twice that of 1997 and 1996. No �
explanation is given for thesc elevated Ievels, nor is one possible based on a singla
measurement. �ither the sampling regime ahould be changed or this measurement not made.
• Tha last two sentences qf Section 6.2.10,1, (p 6.Z 2� are not self-wnsistent ("...detectable
lavels of Ca60 in many of the sediments samp�es collected &om tho PNGS-A and PNGS-B
discharga channel........Cobalt-60 was not detected in sediments„&om the PNGS-B discharge '
, channel")
, •• OPG analyzes for tissue Gee tritium water (TF'I'V� but not for organic bound tridum (Sec6on
6.2.11.1, p. 6.2-30), During cooldng, the tridated water caa boil offor exchange with coaking
water and not be iagested. On the other hand, the OBT could romaia and be ingeste.d, It
would appear that both forn�u of tritium ahould be enalyud for in vegctation.
' The half-life of I-131 is 8.05 days. OPG composites weekly saropjes apmilk into a monttily
sampla for analysis and Snds tha milk contains I-131 below en unspecified LLD (Section .
6.2.11.2, p, 6,2-32). Tha delay between end of collection and anelysis is not sptci6ed, but
considerable radioective decay of the I-131 will have occurred, pre theso decay coRe�aons
taken into account when the LLD is specifiedp
' The apperent overestimate in dou &om the rare gases is al►uded to in Section 6.2.13.1(p. 6.2-
11 '
3�. Until the diacrepancy botweon the gartuna ray sp�acopy mesu►reme�a and uae of 1�,�•
empirical diludon factors and rere ges emiaeion is explained, euch refumcea ere not merited. •
� It ia atated fn Section 6.2.13.1 (p, 6.2-3�, that thero is an appuent decreaso in doae to the
' criticat groups over the Isst decade. Table 6.2-20, page 6.2-50 in the TSD, shows that the •
doua wera graltv in 1998 then in 1997, and �rcatu in 1997 than in 1996.
Sectlon 7.2.1: Likely effects of the ProJect - ItadtaHon and Radioaetivity
� Table 7.2.1-1, p 7.2-3 . See previous referepce to Table 6.2-2, p.6.2-4 about use of
UNSCEAR recommendations. .
� The rare gas emissions for Unit 2, is about a factor of 1001ess than far the other three units
(Table 7.2.1-2, p. 7.2-�. On the othbr hand, the emission of tridum is at least a factor of two
geater, and I-]31 is about a factor of ten geatar than the other three units. This unusual
pattem. of releases is not explained.
• Tha dosa to tha nesting b'vds is canservative since tha noble gases will not be an infinite cloud
at this distance (Section 7.2.�.2, p. 7.2-8).
• The conclusion that "groundwatv quality in the Local Study Area will not differ from historic
levels..:' (Section 7.2.1.6, p. 7.2-1� is not justified since it has not been demonstrated that t6e
remedial measures will remove the possibility of tha wntaminated ground water on site from
migating off aite. . • .
• In estimating likely effats on tha general pubGc (Section 7.2.1.7, p. 7.2-20), OPG uses �
empirical diludon factors derived from tritium date to estimate doses from the rare gases,
radioiodine, and'particulates at the boundary sites. This tacidy assumes that the releasa points
for the raze gasa (for example) and their relative intensides are the same as for tho release of •
triGum. Since tritium is rcleased from somo points that the rare gasw are not released from (i.e
IFB-A, UPP-B, Servia A, Sulzer A, Annex V�, end the distribution is quite different (see
Table 7.2,1-2, p. 7,2-�, this appears to bo a faulty assumption.
One factor has not been mendoned, eicher by OPG or by SENES. Doses from the rare gases
ara calculated on the baais of inimernion in an in6nite hemisphere. This is truo only if the .
• plume is much greater than 120 m in diemeter for M-41, the dominant rare gas. It has not
been demonstrated that this is tho case at the boundery. The effect of a 6nite plumo would be .
to lowa the calailated dose; oddly enough, this point has not ban raised nor hes it been
advenced es a possible explanation for the discrepancy betwan the gamma spectroscapy dose
measurements and calculated doses.
' 12
C .
•.
6ectioa 7.3.3 Effab of patulated nuclear accident dota to non-human 6lota aad
1�$ Sectloa 13.0: Conciwion ot Ontaiio Power Gweration
• Sation 13 atatea (p.13-2) that assessment wesmade ofmalfimctions end accidwta and releaaes of'
radioactive and non-radioactive materiala including representative nuclear accidente involving
aovere damage to tho reactor wre. This eection goes on to state that the effecta of such acadwts
on the general public and non-hwnan biota ere judged not to be aigni6cant becaune the predicted
. frequrncy of nuclear accidenW is low md ffie predIcted effect� on the public ere tielow regulatory
levels. ' .
The PRTSnds it extremely di�cu(t to wnfum or deny the basis on which calwla6ons for accideat
canditions are mado ea no specific data or txhnical documentation aro provided in DEAR.
Technical eupport document (TSD): Radiation and radioactfvity
Sections 6.2, 7.2.1, and 7.3,3 aze very similar.to the corresponding sxtions in the Main Report,
but contain additional information and tables. Consequendy� the comments regazding tfie Main
Repod will bc equally applicable to the TSD. The added sections did not warcant comments.
APPENDIX C
• It is claimed that the noble gas radionuclides have half-lives of less than one day (C.3, p. G
� 50). This is incorrect. In fact, great paicu are takrn to describe the measurements of the •
gamma ray dose rates at the boundary &om Xe-133 which has a half-life af 5.2 days. Kr-85
has a half-life of 11 years. ,
� It is ciaimed that the higher reported emissions from PNGS-A in 1996, 1997, and 1998
resulted &om using tho cortected (higher) flow rates in the exheust (C.3, p. C=� .(Emission �
in Bq/s ia the product of the flow rate in m'/s and the measured concentration from the
sampler in Bq/m�.
Are aimilar inereaaes to come from PNGS-B or are the flow rates corcect for PNGS-B7 If
correct, why the diH'erence in emissions from the two? �
• Will doses to tha pubGc be corrected to take into account incorrecdy reported emissions in the
P�? .
� It is claimed that "the beta activity of the residue is measured with a sodium iodide
detectoi"(C.3, p. G�. This must be en error, sodium iodide detectors are used to measure
gamma,rays; gross beta activity is tradidonaUy irieasured with a proportional counter. Such an
egregious error casts doubt on the credibiliry of the author, ' '
13
APPENDIX D . � ' . , 13 9
�� Tablw D.2-4, D.2-S, page A3: Xo-138 Ja miuing from both tables, although ite daughter Ca-
. 138 ia included in Table D.2-S. Although iW helf•life ia ahoct (14 min), its yield te large,
The calculations in thie chapta are based on etanderd methodology and there ia no reason to '
doubt the results. . '
APPENDIX E
A+ diecussed in previous aections, doses at the boundary to tho critica! goups en based on
empirical dilution factora &om tritium measurements. Thero is doubt, because of different eourcw
for the rare geses and different relative intensides.&om each location r�ladve to triGum, that these
can be directly applied to the noble gases but they are:1'here is also the uncertainty that the plume
• can be considered aemi-in6nite at the boundary. � • •
For population doses, OPG assumes a ground level virtual emission sourco located at the centre of
the sita. Use is made of actuel meteorological data to calalate dilution factors out to 100 lm�. '
SEPiES used the same meteorological data in conjunction with actunt stack heights, locations,
diameters, aad exit temperatures and veloaties to calculate diludon factors a� to ffio
model. It is found that OPG overestimatw the concentration &om 3-5 km, and is m agreement
beyond thaG SENES then calculated the dilution factors using the same assumpGons es OPG, but
using ISC-3 rather tltan the CSA rt�odel that OPG used, and found good agreement. They
conclude that the doso estimates Bom OPG are 6kely to be conservative.
Great emphasis is made an the agrament between the models. However, there are actual
measurements of diludon factors at the boundary (Figure E-1). There is ao attempt to compare
the calculated values with the measured valua. This would have been a aimpla way to validate the
celculadons. The boundary stations in Figure E-1 are not identified, and so the resder caiu�ot
roeke the comparison. This oversight ehould be rectiSed. The fact that two modds agtee does not
necessarily imply thet the models reDect r�ality; only wmparisons with measurements wiU do that.
APPENDIX F
• The Nota for Tabla F.3 (page F-3) indicate that the dose conversion factor from ICRP-72 for
'the noble gasa is based on Ar-41 only. This ie not lilcely if the units aro in Sv/y pu
Bq.MoV/m'. Also, the dose convaeion fector used by OPG is less than the ICRP-72 value,
implying a lower doae for the seme conuntration.
• Fnuta and vegetables are assume to wme from the backyard (10°/a) and 90% from "station9
farther than 31an" (Poins 3, p F-4), How much furtha?
• It is not clear how the dose from organic bound tritium (OB� ia handled (Point 1, p. F-S). .
The text impGes tl�at the dose from tissuo 8ea wata tri6um (TFW'1� is calculated, and thm an
14 '
:t,t'. . � ,.; � �. . _ . . .�..:._,, ,�,_..�:�.:..'� � .
� 4 O ��b0�15�'/o added to account for the OBT. It b not clear to tvhich pathways th�
eorrection ia mede. •
� • A eimplc relationehip between meaaured triGum and G14 in milk end vegetaGon end
emiesion� of tridum and G14 Is uaed ro estimate Ina�enW doeq duo to the requn �.
• •. service ofPNGS-A (F,S, p, F-9). A great deal of e@'ort went inta cala1� �uuon fector�;
�Y � they not usal to calculate theae paremetero end comp�e the calculated resulta µ�it�
the actual meaaurements? Thia would verify thc model wed to calculate doses on-aite.
' Earlier ln the DBAR it was st�� ��e OBT way 50'/ of We TFWT dose, It ia not clear
bo�' the "raw data provided In an �a, rcpott on tritium in food" (F.S, p. F-10) is ueed to
calculate doses, and why the previou� approach is not uaed.
.
• ' 15 ' •
� .
I
I
SLGTION 6.3: �xn�osr��uc Exvrnorn�rrr �. � 141,
StMlon 6�3.6: Dercwrpdan ojcrisdng Condldona � •
• At the "oa-site° station tho aIr tlanperature waa recocdcd at anly one height. Thia meann tl�at it
would be impoasible to detennine when temperaWre invenione occurred. Since these eventa •
have dramedc offecta on eir pollutidn it ia essentlal thntthey bo de6ned. 7liere /s no dlscu,ulon
fn �he Jlnal �aJt document oJlhe tmporkurce oJJemperalure lmerslonz
� The variation of temperature at a number of eta6ons is well-defined. Fsut nowhere ia there a�ry
discussion of a•thertne! gradient relative to tho lazger urbanised centre of Toronto. , .
� Thero aro no data describing diumal variation of wind direcdon end velocity. This is important
for the aasessment of the consequences of a leak. For example, the wind roses preseated in
�g. 6,3-5 show that SW and E winds l�ave higher vdocity than N winds. Hence, in the case of
a leak, there is a signi6cant probability that contaminants would be blown over Pickering
rathlr than out over the lake,
� No results aze presented in any of the Bgures for the Pickuing Air Quality station.
• Most of the plots pruent annual loedings for the selected period between1988 and1997. Data
should be presented for the entire 1971 to 1999 period. .
• The data base regarding the existing atmospheric environment is based on analysis of annuel
loadings. Hence, it is impossible to detertnine any source apportionmen� To be able to
differentiate source contributions it is necessary to have observations at a frequency that is
greater than the &equency of the pollution event. On the basis of the informadon provided io
the DEAR it is impossiblc to detemtine whethcr the Air Quelity loadings aro related to PNGS
or H'ighway 401.
• All of th� plots present "measured 8 hour average" concentration values. A more meaningfui
measuro would be to present the lotal wmulative loading at each stadoa This approach
would provide a total ef%ct for each location .
• Appendix C- Air Quality Bazeline Data - clearly demonsuatw that the region surrounding
PNGS already has a very serious eir potlution problem TSP and Nox levels are used to deSne
air qualiry aa poor. The increazed traffic �ow associated with the restart ofPNGS-A will make
this worse. •
• Dispwsion piume modelling. Thae ere a number of problems regarding the input paremeeers
used in the dispasion plume models. For exampie, the models used to develop predictive
di�tribution mapa for the expected dispersion plumd of hydcaane show that some residentia!
aroas, especielly to the NNE and the WNW ofPNGS-A wit! be impacted by these plumea. .
Hydraune releases occur over a very ahort time period and it is aitical to know the exact '
rclationship between wind directioq wind veloaty and time in order to modd plume
distn'bu6on. The infonnation required to estabGsh this rolationship is not presented in DEAR
If the wind ie blowipg from the SSW at the time of a hydrar�ne releau, thn imp� �y, �
�14 2 much luga than thac estimated bp y�e current modela.
� Systematic aroro in modcl calailati,onn. Table E.2.19: "Predlcted va. obaerved lnontlily .
. averago 4ridum concentrationa iu air using 1992 daily em3asions data" exhibita aome very
aitical aad strangly repeatable patterns. For most of tho aitw with aigni6cam tritium loadinge
iCentr�l meintenancq Montgomay Park, and East Doundary) t6a predicted loadings for
winter montlu (DeC„ 7au, geb, Mar) ���a ��e observed value�, while for the aumma
� moaths (MaY� J►m0. Jul� Au& S�Pt, Oct) the obstrved values ere higha' than the pndided
values. This cleariy indicates that there are aome systanatic errora in the model calculations
� aad that the input paramecera ►uve not ban adequately controped. Perheps the most
dgni6cant difference betwea� winter aad summer in the importana of lake effect breaw,
Thwe would be muc6 greater in summer and could produce plumes that are much Iarger than
those indicated by the model mep� pracaited in the Atmoaphaic Environment TSA, ApPendix
G• TWs discussion is also relevant to tt�e hydraune problan since both hydraane and tritium
occa�r as toxic plumes emanating 5nm PNGS that ere modified as a consequence of wind
direction and veloaty.
• Disper�ion models presented in the Atrnospheric Environment TSD (Appendix G) show thac
tri6um releases &om PNGS have formed a plume that exteads to the NNE &om the power
P���• �e nature of the plume is currendy de6ned on the besis of a very limited number of
observadon points. Actua] measurements of Tritium loadings are quoted as being +/- Sp�/.. �
tbis aituadon, knowledge ebout the nature of the plume can at but be described as cursory.
Even the most realistic models become meaningless whrn one is only attempting to modd a
limited number of observations points, Atmospheric Environment TSD table E.2-19 shows
that many of the differences betwan the obsmed and predicted valuay modolled exceed
300'/.. This indicatea that the currrnt database is insufficient to give eny meaningfui estimate
of the possible future cumulative efects of tritium releases,
In aummary, aa atmoepderfc plume of tritium b released by PNGS. Bued on the
informatlon provided in tdi� report t4ere �:
� • ianuliicient informatton to documeat t6e geometry of the tritium pluma
• ao tnformallon on the dally e6aoga In t6e geometry of thb plume.
• no information on the meteorological facton that la0ueace the distributlon of the
trlttum.
• DEAR indicates thet a rccrnt eirbome spectral gemma survey, showed that ouuide of the mein
PNGS complex, the Primary sources of gamma radiation are aasociated with naturally
o�airrin8 aources of IC, U and Th in sedimenW. gowe�,er, this same survcy aiso showed that
��Id conantrations over PNGS ere at �east 1 px highe� th� o�� �e DarWigton NGS. T6e
S�a survey indicates that additionel coppa ahieiding in the ceiling of the Darlington plant
hes resu�ted in the reduced levd of16IY emissiaro, No mention of this problem at PNGS is
included in the DEAR. .
o►+anu�on�n�u� ,�r,„orphat� u,vJronment . � � 14 3 .
The atmoap6eria environment data u presanted in tbe DEAR ere wwatiafactory ae it doea not:
• contein auffiaent inCornietton tp differentiate wntn'butio►u from PNGS-A from PNGS- �
B.' ' •
• wntain auffident Wbmmtion to allow diffaentiation of contribudo►u �om PNGS and urban
traffic to Air Quality.
• wmpare total loadings betwan statione. Hencq it is not pos�ible W detemiine if Pickering haa
worse, or better air quality than urban Toronto.
• provide azry infomiation on the duration of c6ronic concentratioa events, or if these aze
associated with temperatwe inversiona. � . '
� adequately model dispersion plume distn'budon for tritium and hydraane. Inaufficient data are
available to det«mine the meteorological factors that influence the distribution of the tridum,
docummt the geometry of the t:itium plume, or the daily chenges to the geometry of tho
plwne, Signi6cant diaaepencies orist behvea► observed and predicted concentrations of
trttium. ' .
0
� . • .. � � ' I8 . . .. . . . � . . .
• SE�TlON 6.4: HYDROLOGY AND WATER QUALTI'Y
144 � �.
Seetion 6.,.7.2 Water Temperaturo
The �rst task of OPCi and iW consultents wae to descdbe exiating condiGone bt the Sito and
Local atudy areas. They soughf to describe tho "embirnt baaeline condidona" (p. 20,
Hydrology and Water Quelity TSD), which aro thoso thaf adst in the near-shoro and wluch
aro affected by tho operation ofPNGS-B. The mosl dlrect, scfent�ca/ly de.Jens►b!e means to
achieve thls is to corduct a cwrenR properJy cleslgned jield monito�ing p�ogram. OPG and
ita consultants decided not to undwtake such a fidd survey, but instead choso to uae a series
of hfstoric surveys to "admate" existing conditiot�,t. In acientific etudies, oae would only
choose thla route if actual measurements were not possible. TFie rationale presented for using'
historic data is es follows:
An eMensive datasei �cists documendng the thermal plume between 1971 and 1979
when only PNGS-A w,�s in operation (Period A), and they also have data behvcen
1986 and 1988 when both PNGS-A and B wero in operation (Period A+B), What
they wented to do was to take observaGons from Period A and "subtracP' them from
those of Pwiod �A-B, to dcrive an estimate of current conditions (Period B).
In considering the effects that a re-start of A would have on cxisting conditions, ihe
estimate of "Period B" was sdded to "Period A", instead of making inferences from data
collected during "Period A+B",
Problema of t6L� approach .
Use of the word "ambient" to describe "surzounding" conditions is a problem. The case being
made in support of minimel or negligible effect on surFace water temperature distribution is
premised on an accurete assessment of "x=degrees above ambient". 'Ambient baseline
condidons' were originally described as those conditions that exist in the near-shore area
affected by the operadon of PNGS-B. This is confusing as it is not clear as to exactly where
'ambient' conditions were measured. It appears that a comparison was made between data
collected within tho "affected areas" (within 3-km of PNGS) with data collected outside
(poasibly at the stadon cortwponding to Fig. 6.4-9) to detertnine "x-degrees abovo ambient".
A cleara and more wrrect way to denotc these dnta is'k-degrees ebove baseline" to signal
that thwe are chenga in tcinperatures due to the operadon of the PNGS.
The second major problem stems from impropu documentation of inethods, locatioa of
atations, number of stations, frequency of ineasurements, etc. essociated with Period A Ther�
is �a conspicuous absence of any infomietion on how these datn wero wllected. Contrast this '
against the situa6on for Period A+B, Wa know that there were 12 plumes exemined over 3
years (1986 to 1988), and the plumw wae deterntined &om data collected at 10 stadons '
(where exacdy is not indicated), and that they were collected continuously (legend oFFig. 6.4
13). This is more informative but not altogether useful for the critical evaluation of how
representative these data are. For aamplq 12 plumes over three yeara translatw to one per
season on average, hardly suffiarnt to capture the iahaent variability demonstrated from
Period A
19
• Tho third maJor problerii le the Lnproper ecrutiny of which defa ere eppropdate tor. inclwion 14 5
Dudng 1971 to 1973, the four PNGS-A reactoro sequen6ally became bpFretional, and were '
operating ac >80'/o capacity aRer jg74. To make the raulte menntngful, data from 1971 to
1973 sliould have been exciuded eince the affacts ofPN4S-A when ail or nearly,all of t6em �
ara operational aro of prime intere�t. Along tf�ia eame line'of reasouing, it ia difficult to '
detarmiae the usaftilnws of including the 1986 W 7988 data eince it wes noted that not all of
the PNGS-A reacton wera operationel during thie time, Ifgreater effort hsd been exprnded .
to factor out the effect of variable capaciry during these timo perioda, tho analyeia might bave .
been more credible. ' �
�• The fourth tnajor problem etems from tha confusing wey in which the data ere preser►ted end
used. As an eicample, Fig. 6.4-8 (Hydrology and Water Quality TSD, text p. 21) is •
supposedly showing "year.to-year variation ofmonttily water temperature" at "an embi�t
locadon offPNGS" .!n fact, &om the legend of thls Sgure, theso ara �compoaito values from
•'"7-14 sites in Lake Ontario offPNGS" collected continuously (every seq every minutq every
hou�l?7) from 1971 to 1988, It is curious that data pertaining to both Period A and Period
.. A+B weia included, for it eim�ly wnfounds the'v analysis. However, far from being useless,
thess data provide informadon about tha stratification characteristics at the local study area ('if
in fact these stadons arc located within t}ic 31an ranga of tha PNGS). Relevant temperatures �
for each month at each depth from the Sgures can be replotted to derive a temperature
isopleth (Fig, 1), It is clear from this exercise that "embient" waters offPNGS exhibited little
or no therma! sUatiBcadon t}voughout the year, except in winter, when there is only a weak
inverse suatiScation. This is clearly a departure &om the conditions in Lake Ontario, 31an �
o@shore (Fig. 6.49), which showed evidence of strong stratiHcation in mid-summer for at
• least 1987 and 1988. Tha consulcants themselves acknowledge (p. 21 Hydrology and Water
Qualiry TSD): • .
"VerGcai thermal scrati6cation of ambient lake water is a noticeable feature ofLake Ontario,
In summer, stable temperature stratfiication generally occurs with warmer water at the surface
and cooler water in the bottom Iayer."
Therefore, although there Lt condualve ev(dence that operatloa of PNGS (both A aad B,
and A alone) 6aa led to databilizat(oa of the therma! regime in the atudy area, thi� wae
not even mcntioaed in the DEAR. •
� In addition to nof explaining how'k.degrees atove embienP' hes tieen derived to plot Fig. 6.4-
10, DEAR does not explain what the percentages in brackets rofer to. If theso arc a
breakdown of the wind diiectiona, thrn thera are 30% unaccounted for in this figure. The
� quesdons that wma to mind ere: What period of time is represented by each plume (over an
hour, a dayl) How wae the plumes derived? What pararneters were used? Were these
perameters esdmeted or measured7 How meny plume-days were estimated/descn'bed in total7
These are important questions to enswer because thie Sgure is uxd to derive the estimated
areal exfent of t�ermal plumes from the operatioa ofPNGS-A (Fig. 6,4-11). It is important to
know how the areal extent wes actually detertnined, how many plumes wero involved, how
variabla tha data werq what the error estimates are, and most imporcendy� what wece the
actual temperatures? Without actually knowing t6e raage of temperatura e:perleaced �t
20
.�. 4 6 the itudy alte, It L impoiaible to evaluate the lmpact of We com6tned oper�tion on tLh
, temperafnre preferend�. , . ,
� EFig,l. Tmnperacure Iaopleth uaing daGt intapolated �om Fig 6.4-8 ' . .
� Temperature Isopleth for data, interpolated from Fig. 6,48
"Ambierrt water off PNGS"
u
.y
�
�
� -B
-8
•10
•12
- o a 10 72
' Month
• Besides calculating the areat extent of tho plume, it ls also important to esteblish the
amount oftime each region of the study erea experiences the plume each year, The timing
of the eastedy or weaterly plume ia just as important a perameter as the area] extent
because location oflethal or inhibitory temperatures near the mouth of the marohes
.(Frenchmati Bay and �Iydro Marsh) during the spring could a@'ect tha spawning runs end
migraGon of Ssh. Unfortunatdy, none of this infortnation cculd be gleaned from tha
DEAR. There is a rather simplistic treatment under two differont acenarios--cold-weather
and warm-weaiher conditions, where the wnsultanta con�luded that unda cold-weathu
conditions, thermal plumes tend to extaid eastward while under werm-weather condi6ona
(60.70% of the time), plumw extend mostly to the west (50% of the timo--that is, on1y
hatf of the time). In t6e oplaion of the PRT�.tLe intormaHon i� too warse for auy
critical evaluntion of ffie eil'ect of t6e plume on the dbtributtoa of fuh habltat '
. . Z1 � .
0
• Probably We most canfuaing enpect of the appronch ueed in DEAR to'charactaise the 14 %'
thertnel plume was trying to underetand how informadon obtained during Paiod A waa
acWallp °subtracted" from thoae collected during Period A+B to generate nn,tnterim •
� . gaph Thia graph should have illustrated the ueal extent of plumw under cunent
condidoae (Period B), a wmparable greph to Fig, 6.4-10 (Period A). Since euch a graph
. Is not actually ahown, it ia not poasible to detertnine the validity of �g. 6.4-13. Similariy,
tho reador is oupected to tako et faco value tho wtimatw of nreal extenta of thernial plumes
presented in Table 6.4-8, p. 23 (FIydrology and Watv Quality). Here, it is etated that
current conditiona whilo PNGS•B ia opecatIng alone ehould produce a thermal plume with
p mexim�m ereal extent (de6ned by the 2°C above ambient contour) of4,500 ha, which ie
. only about 20% lar$er than that caused 6y PNGS-A operating alone. However, in Table
• '?.2,3-3 (p. 55 Hydrology and Watv Quality and p. 7.2-42 Main Report), the estimate for
PNGS-B only, was downgraded to 4,000 tia, and it wes estimated that the combined
PNGS-B end PNGS-A will produce an areal extent of only 4,500 ha There ia no further �
� explanation of the inconsistenaes; but a subsequent paragraph notes: ' .
....However, during tho synoptic surveyg, not.all of the units wera in. '
operation at PNGS-A ...This rango doublea that when PNGS-A or PNGS-
B was in operadon alone. Therefore, the incremental effect of PNGS-A
opeiation is conservatively estimated as doubling the existing effect in terms
of the lake surface area affected by the plumes at any given time.
If all acPlanations are accepted, the conclusion should be that the combined operaGon of
' PNGS-A and B would effectivdy doubie the areal extent of the thertnai plume &om an
estimated 4,500 ha to 9,000 ha A statement to this efl'ect, spelling out 9,000 ha is never •
seen in this portion of the report, and there is no reference to this anywhere else. WGat •
remains is Table 7.2.3-3, showing that tho operation ofPNGS-B and A combined would
result in a maximum areal excent of 4,500 ha.
. Comparison of Fig. 6.4-13 (estimated areal extent of plume when onlyPNGS-B is
. operational) with Fig. 7.2.3-5 (estimated areal extent of thecmal ptume when both PNGS.
A and PNGS-B are fully operational), does not idendfy differonces consistent with a
doubling of azeal extent av indicated in the text. 7111s inconsislency 6ehveen fgures mul
text, from sectlon to secNon, tn the absence oJany detailed explmurHon of inethadola�,
seriously erodes 1he cred/blllry ojthe work � '
• Finally, OPC3 and its consultants have ignored trends towards progessively lower water
levela in tha Great Lakes and warmer temperaturw in tha summa and winter over tha past
• two decadea. By using historic data from the 70's and 80's in their model, they have
already biased the'v estimates in 6vour.of a"coole�' scenario. By not providing a
mechanUm to account for warmer and probably more atormy conditioos in tLe
Great Iakes, the DEAR may aeriously underoUmate the poteaUal impact oCthe •
reatart atPNGS-A on aquANc biota. .
22
� � • Secdon 6.4.t.3; Vyatar baLwce � . .
14 $� Thq water balance ie a 8uidammW olement In ury hydrological enely�Sa. In eeaence a.
water balence providoe a quantitative descripdon of each water component in the nawra!
hydtologic cycle, On the a�aumptlon that water Ie nather croated nor deatroyed within tl►e
. cycle but eimply changea etate or movea &om one compertment to mother, the water
bnlaece exercise is an e�sentiel meane of domanatracing tha; a(! the hydrolo�ical -
components are properly accounted for. ''
For exainplq a reasonable expectation of the DEAR is that it wiU con6dently deecribe the
• eventual fate oftritium that is documented to occqr in prxipitation et elavated
concentrations (Sxdon 6.2.8.2) throuEhout all three study areas, That ie, it ahould
explain how much of the water (and entrained tdtium) recharges, how much wis off end
how much �eturns to the atmosphere es evaporation or evapohanspiration. Ai present, a
watu balance is provided only for the aite atudy area; tha othv study area9 are ignored,
Moreover, the ona wacer belance provided lacks support data (e.g. where does the value
for actual evaporation coma from?), expGciUy ignores goundwater recharge, and, in umu
of the natural components, does not balance weU. Sinee the water balana is
eubsequently."used in Section 7.2 ae n basi� for asswaing tLe efkctr of the return to
project" (Section 6.4.8.3, p.45), full redras of thLt isaue u critical. "'
Section 6.4.7.4�Background Lake Water Quality . . .' .
• BaseGne water quality data for surface water are seriously lacking to the extent that '
incremental impacta resulting &om the restarc ofPNGS-A will, in many cases, be �
impossiblo to assess, PNGS is a major potential source of organiq inorganic and
radioacGve contaminants in close proximity to critical sources of drinking water
'(supplying probably 20°/a or more of Canadians). Despite this, baseline water queliry data
for the tivee atudy areas are variable and inconsistent at best and absent or missing •
pertinent pazameters at worst, For exemple; "inactive" backgound water qusliry for Lake
Ontario includes just 10 parameter�, all inorgenic (Table 6.4-13), On Novembcr 7J3, 1999,
a ono-time event study wav pedormed es part of tha PNGS-A return to servlce EA, in
order to checnically characterize storm water runoff&om the site. It provided analysis for a
wmmendable and moro realistic 140+ "inactive" chemical pacametero. Unfodonately, it
was conducted for an unusually high 46mm rainfaU event (representing over 5% afthe
total annua( precipitation), rendering the exercise essentially worthless as an indicator oF
background water quality. For acample, given the large volumo of water available for
diludon, it is hardly eurprising that thc results show non-detection for many parametere .
and strong compGance with MISA discharge limits.
A comparabie 140+ "once only" az�alysis (October 12, 1999) also exisW for aeveral other
. surFaa water sitp (fiydrology and Water Quality TSD - ApPendix B), but given the
atrong likelihood ofseasonal var9ability� �t is yueniooable whether these sampley can be
wnsidered represeatative of the backgound wndidons so essentiel to the EA. In
esaence, the surface water quality data presented ta DEAR aro w6olly inadequate
for rdiably utabli�hlag baedine environmental cond(don��in tde vicinity ofPNGS.
• ' 23
'• • Background data far radionuclldee are coetained in aavual eectiona ofthe report ' 1 Q 9
('mcluding 6.2 md 6.4) . In geacni, background concenVntlone of radtonuclida ere .
measured rogutarly at cnaJor,lake-baeed wata wPP�Y Planu, but there ara no background
data for rndionucltdea in aur&ce watu ln the local snd rogional atudy ueas mywhae nocth
of the Leke Ontario ahorclina This !s clemly a serious omlulon. � ,,
� Seedon 7.2.3 Hydrology and Water QuaUty Envlronment - Iikely e1Tab
. •� Watu quelity modele RMA2 and RMAI l are uud in the DEAR to almulate both exiating
and fLture PNGS condidons. Modelling is a powvful techniquq but can nevu fiiliy '
represent the real aystem aince the model code u invariebiy besed on 'a numba of
potendelly limiting assumpdons. With good data end adequate calibration to demoastrete
. � the model's viability, the'model can be used to investigato numaous futuro acenarioa.
i�erein the problem lies. Adequaze caL'bration agaiiist reUabla Held data is essential if the .
model ie to he tnuted. None of the colourful simulations shown in Figures G2 through G •
25 (Hydrology end Wata Quality TSD, Appendix C) have eny saentific standing until
model caL'bration can be fuUy demonstrated. •
OvaaU commene - Nydrology ond Wato Qualfty
Tjie description of the existing hydrological regime (i.e. surfaca water) is unsatisFsctory. Tha
catchments (wateraheds) are identi6ed, and rivedsueam flows for each of theso catchments are
tabulated. However, baseline watu quality data are scant, water balance data are severely lacking
and the modd used for predicting plume migntion Iacks essendal calibration data.
, See also overeil commenb for Section 6,5 Aquadc Environment mede bdow.
� 24 ' �
. SE4TIOPi 6.5: AQUATZC ENVIItONMEIVT .
�15 O secdon 6.s.7.3 Scii'tmwt Quallty ' .
Tho discassion of run-off, ur groundwater eeepage impact on the ohemiatry of eediments in gydro
, Mareh ie of very IL�tited valuo for a number of reasorw:
� The atudy ie based on tho resulta &om only aoven samplw, f}vee of whch are supposed W
, be roPresentative of background', and four ere�used to locate possible leachate impacts.
• ' This is an inadequate measuremeat beaie.
� • The nport provides no details on!ho analytica] mqthod that was used to detemiine the
chemistry of the sediments. •
• Most importantly there are a number of elements that do NOT meet the Lowest EBect
Level for aediment quality guidelines, end 1'OC and TIIN both exceed the 3evere Effax
' Level guidelines.� .
• Table 6.5-9 also shows that there is a downstream increase in As, Cu, Phos, and locally
Zn. Thero are ar, insufficient number of observations to determino if these differences are
stadstically significant. However, this suite of elements is most compatible with leac6ate
chemistry. • . • .
Sectioa 6:5.7.4:.PLytopianklon, Zooplanktop, and Periphyton •
OPG and ib wnsultants havo chosen not to collect field data to descn'be current conditions with
regard to plankton communiQes at tha local rtudy area Instead, they make the following
statement (p. 6.5-22 Main Report, p. 40, Aquatic Environment TSD):
' "The large, lako-wide changes 1n pinnkton communities and the highlY-variable
naturo of tho populadona in the Site and Local Swdy Areas make it extremely
di�cult to evaluate effects of tha return to service on this component of the
ecosystem Therefore, this assessment is focussed on Ssh VEC species, assumieg
that the VEC specia will integrate the responses of lower vophic levels and wiU
ahow effects tn en appropriato timo-frame ao as to allow additiona( midgatlon if
n��, ��
There are a numbe.�c of problems with this approach; , •
• F'ust, the thermal plumes are probably more variable in nature than aro planktan
distribudon, and yet the consultants aought to characterize the thermal regime because it is
one of the main forcing functions of the ecosystem. The PRT argues that desexipbon of
the wrrent status of the plankton commw�ty is equally important, not only because this
was sPeciScally asked for in the'i 60+ issues; but aiso because they are at the base of the
food web, and anything that wil! affxt them a+ill ultimately affect the upper trophic levels.
The lack otan a�asmwt on the lower food web in DEAIt y uuacceptabla
. 25 •
�
� .,
• It ia not eu�cient to uae hiatodc deta In the forebsy (entrained plankton) to infer wlut ue 151. �,
Iilcely to exfet tn t6e nearnhoro regions offPNCiS. The fact thet the watere in thie near= �
ahoro rogion are conatenYry mixed (not atradfied; Fig. 1) may have implications on the
wmmunity dynemics. Diatoms that tend to disappear becauae they eink out into the
hypolimnion would beneH► i.o a mixed system, wherw apecies that tend to peak near the
metalimnion would be at a �isadvantage. •Thera may be other accompanying ehiRe in the
zooplanlRon �hat track the algae. Knowing how the rest of Lake Ontario hae chenged, �
urespectivo oftho operation ofPNG3; is useft�l only aRer it is known what actually aciata
• in fhe local study area. It is inappropriate to infer what is lilcely to be present in the atudy
� area from studies performed elsewhero iu I,ake Ontario. Possible chaagw in biomaas,
communify atcuchue and species composidon aro all important aspects of the plankton
• that should bo assessed. • , ,
SceHoa 6:5.7.4: Fi�h .
To assess the cunent Ssh wmmunity in the affected azeas w}tile only PNGS-B is in operation, the
� consulcants wisely chose to conduct field surveys, However, they did so only in late fall and early
winter, missing the spring auuuner end early fall distributions. Moreover, there were no winter
surveys to ascertain and quantify ttie extent of habitat uu by certain taxa (only presumed).
Nevertheless, tha field aurveys were well implemented. The methods and locadons of sampling
pointv are clearly documented and the data presented and accompanying statistical analyses ara
acceptable.
Tha consultants also present a very useful table showing tcmperature preferenda for the VEC taxa
at different life atagw (Tablo 6,5-13, p. 45 Aquatfc Environment TSD). It is difficult to verify the
accuracy of interpretations regerding the lilcely e6ects of the thermal plume on habitat (Tabte
8.2.4-2; p, 88 Aquatic Environment TSD) because nowhere in the documents ara the actua! raw
temperaturw given at variaus times of the year at diffuent locadons in the local study azea.
Nevertheless, using the intortnation presented for three of the fish taxa, it is possible to evaluate
the effects of the combined operadons ofPNGS-A end B on these populations (Tablc.la below).
The rango of temperatures through tho seaeon aro gleaned &om the consultant's discussion.
• Overell, it appean thve would be detrimentel effaxs on the 6sh during the spring end
summer months end that only in winter would there be some brne6t to the smallmouth
. bau. Both the norttiern pike and walleye may move o@'shorc, and there is no evidence
. that they ovenvinter in the ��earahore.
(Followingpage: Table la Stimmary of predicted eBects on 6sh populadons in the a@'ected
areat. Asterisk indicates temperature required for spawning. T m positive e@'ect; .
. yanegative effect; 0= neuUal effect, prrowe in brackets indicate the effed asssutried to
be probablc by wnsultant, but aot vai6ed:.
. 26
u
�._ .-.. -- ... . � . : . . �. . . ... . '--� . . .. . . . � . . .
1,52
�
. . Life �ta�e
. E:pacea
' ' , ' . Tempmituro
Fi�h tuon •' Seaion � � Ran e
• Adult Juvenile Fry Egg
, � (��•�'� (25-30•�. (25-30'� . . .
IS•C�
Smallmouth Apr to Jun T ,, .� 12-21
Basi
Julto Sep .. 0 0 22-28
Oct to (T) (T) unavaiiable
. Dec •
Jan to Mar. (T)' ' (T) unavailable
' . Life stage ' . '
^ ' . Temperaturc
. , Range '
Fis6 tazonE Sta�on
Adult' Juvenlle Fry Egg
. �.sa•c� (l9-zi•c� tla-2s•c�. c9->>•�
�.ia•c•
Northern Ptke Apr to Jun • 12-21
• � (toohigh •
veloci
Jul to Sep 22-28
Oct to (T) unavailable
Dec
Jan to Mar ' (T) . . unavaiiable
Life etage
E:pected •
• Temperature
FLt6 tuonE Swoa Ran c
Adult Jwenile Fry . Egg .
(20�27•� (26-30'G� (22-24•G� (9•15•G� .
5-10'C� .
27
R'alleye . Aprto ' . � •1�21
" Jun �
, 7ul to Sep . 0 . 0 ' 22-28
Oct to . (T) (T) unavaflable
Dec .
Jan to Mar unavailable
Tablc la wnk
However, DEAR reaches e somowhat differmt conclusion on tho basis of these data (Table 8.2:4
2, p; 88, Aquatic Environmeat TSD). They conclude t6at: ' •
� thero would be overall positive effects for all three fish acamined, due primarily to the
increased rearing, feeding and (presumed) ovenvintering habita�
� Adverse eHbcts od epawning during the spting wera discounted. Whae northero p'�ce is
concerned, the only fish that will spawn in Frenchman's Bay end Hydro Mareh, the
increase in temperatures of even 2°C (depending on the actual baseline temperature) may
tnhibit their migra6on and prevent spawning, and aithough this is not the only habitat
available for northem pike to spawn, apawning and nursery habitat has been lost at an
alartning tate in setded areas.of the Great Lakes end it is unacceptable to consider losing
any more.
The cansultent's assessment is biaud by insuffident survcy data during the dmes of Wc year when
apawning, hatching and rearing takes place. At iasue is elso the accuracy of the projected thermal
plumw from operation of PNGS-A and B, which have an effect over and above any anticipated
increase in global tanperatures of several degrees over the next severai decades . Displacement of
pike from local marsh areas as a result of increac�d water temperatures may not be reversible if'
othv Sah (e.g. carp) £ill the ecological niche. .
Overoll eommenfi oqualic environment
T6o PRT hava a number of reservations in eccepting the conclusiona reached in Section 6.5
Aquatic Environment.
� T6ere ue iwulFicient data on aqnadc biota and wster temperaturea to document
"e�tfng budine" condit(oa� at the site and local study arw. Except for a tato-
• faWearly-winter Ssh �rvey, The DEAR does not include any other fidd information to
document "embient baseline condidoas" (p. 20 Hydrology� and Water Quality TSD), w6ich
aze the near-shore conditiom affated by tha operation ofPNGS-B (and PNGS-A w 1ay-
up wndition). The ova- reliana on historic infomiatioq oftrn inappropriately
acrutinized, is one of the most swiow flaws in the overall approach used to evaluatioa oF
28 .
0
53
�� �Y �`'�s ofthe themul regtme on the local atudy eroae. It ie not velld to forcgo aa
� 15 4 esaesammt of the plankton snd macrobenthoa eimply becauae they are "high(y variebie", ,
� The deciaion W includo eny VEC ahould not be based on coavenience in data collectiaA
and interpntadon, but rather tha imporlance of thet component within the ecosyrtem;
clearly tho lower food web in tho local etudy ena is a very important componrnt of the
natural environment. • � • . •
T6ere v inwnitatent documoutaUon of aurvey methode and raulb. In all caus�
methods anployed, location of eampling aites, frequency of eampling, etc. pertaining to
inf'um�ation collected prior to 1990 (i.e, temperaturq phytoplankton, zooplanktoa) are
dleturbingly acarce and inadequatdy documented in the actual report, whaeas thoae
pertaining to the most recent surveys (o.g. Fsh aurveya in pquatic Em+ironmmt TSD, p.
47-48 ia 1998 and 1999) are exhaustivety covered.
' Motha notable di8'errnce is the large amount ofraw (good quality) data reported for thc
recent surveys that are completely lacking for tha historic surveya. If the complete
methods can be found in the references, they ahould bo distilled and induded in the
� Technical Support Documen� •
� Approprlate atatLBcal tab and valld comparlsoa� were aot used to draw
canclusiaus: The conchuions that are drawn in many cases are not aupported by any
atabatical tests. In sevoral cases� it is difficult to judge if the data from two differrnt time
paiods should even be compared. No margins of emor wero reported with estimates,
Thae is insufficient infortnation to detertnindassess the eppropriateness of data
manipulations.
• Coudwion� regarding t4e ePkcts of therwal plume� rely on use oCquationable
Lvtoric data to generate estimates, when d'vect field measurements could have ban
obtained. Hence, the DEAR dow not provide accurate represwtation of changes in the
thtrtnal regime of the affected area �yhich are critical to propv auessmmt of likdy effects
on biota
• The DEAR doa aot taclude rn auwment of likely elTecb on the plankton or
IDACfOf/lOii107.
• Asiwment of likely eRecb oa tde tiah communtty arc inndequate u they an baaed
on a lato-6ll fdd aurvey. This atsessment does not recognize seasonai digerences a
Ssh distn'bution, particulady during che spring and aurtuner when temperatures excced �
temperature prefercnda end epproach lethel Gmits for meny taxa.
29
SEGTiON 6.6: �►��xFSxxw,. Exvmoxn�rrr 15 5;
The aection on Terrestriel Enviconment ia aati�factory and the generai coacluaione aeem W be
valid Tha PRT accepts that the biophyslcal inveatory is a fairly accurate repreaentatioa of what
acista at the locat study areas. The watw quality data obtained in the local wetlnnda ead nearahoro
areas aro consistent with the result's from other 6eld surveys in Lake Ontario. '
SECPiON 6.7 GEOLOGY, HYDROGEOLOGY AND SEISMICiTY
T6o hydrogeologicel aspects of tho docwnent (contained in Section 6.7 - Geology, Hydrogeology
end Seismicity) are descdbed and evaluated in the DEAR quito separately from the hydrology
(which is contained in Section 6.4). Thia is somewhat unfortunate, as the hydrolagy and
hydrogeology of the re��on are inextricabiy linked. •
Scetlon 6.7.6 Geolodical aad 6ydroEeologicnl aetting
Overall, the hydrogeologiul asaasmwt b regarded by the PRT a� hig6ly inadequate.
DEAR's Veatment of the geology end hydrogeology focuses alROSt acclusively on the plant iuelf
(Site Study Area) and shows Gttle or no regard for the goundwater flow system bryond the sita
bounderies (.e. within the Local Study Area and Regional Study Area). It ahows scant regard for
the importance of graundwater in the Province t+.+ a resource and, in tertns ofgroundwater's
contaminent tranvport role, tends to raiu as many quution� as it answers. To provide a
satisfactory assessmrnt of potential impacls, wnter resources need to be fuliy quantified. With
respu:t to water movement, documrntation should indude a comprehensive evaluation of
ditections, fluxea, and travel velocities. Bas..line chemistry must extend to all dissolved and
suspended materiel (organic and inorganic - including radionuclides) that could conceivably be
released by the PNGS. Given the importance of the Project and the high level of
pubGeJstekeholder concem and interest (es shown by the importance of'water' concems in the
'160+ iuua Gst) , it is reasonnble to expect such data and infortnadon be available for the Site
Study Area, Local Study Area and Regional Study Area i.e. all areas in which water resources
wuld potendally be affected by the amularive �Q'ecu of retuming PNGS-A to service. In the case
of bauline chemistry it is vitaUy unportant that tne datatet be large and comprohensivo enough to
eilow incrementel impacts of the projed and ongoing activides at PNGS to be reliably evaluxted.
Major iuues that need to be addressed include:
Croundwaio Beyond the Si�e Baundary: Page 3 of the Hydrology end Water Quality .
Technical Support Document (Section 6.4,1, bullet 1) corsectly da('me.c �he Regional Study
Area aa encompassing "uirface water rcsouras chat could potendally ie affected by the
amuladve effects of rcturning PNGS-A to urvice". Clexrly, if surface water ia at risk
tha► groundwater, which is repleaished from the aurface, must also be at dsk; thus it ia
ess«idal that the hydrogeological condi6on� be &Ily documented for bo:h the Regional
Study and Local Swdy Area+. With the aception of a shallow groundwater devation
mep for the Local Study Area (Figure 6.7-8), the DEAR victuaUy ignorw groundwata
beyond the site boundary.
For arrnnple: the hydrogeological framework / hydrostratigraphy of the .
30
15 6 cegion ia not do6ned, tho aquifu/ aquitard euccession is not provided and
no�data on aquifer/equitud propertiw are given (Kh, ICv, effective •
poroaities, storage otc. j. There ue no rogional hydreuUc head data, no
regional9ow mape, no recharge eatimatea, and not evm a genaal .
discu�ion ofthe way the aquifer system behaves in a ngionel coatexi (e.g.
tho regional flow dymamica end the leaky behaviour o�the aquitarda). Some
recQgnidon is given (qualitadvely) for the fracture charecteristica of the
•balrock acjuifer, but no mention ia made of the fracdire flow chatacteriatice
of the titLs (beyond the site, at least) and the naturo of the hydrauGc
interaction between aquifa(a) in the bedroc� and aquifera in the aur5dal
. deporiU. Mention is made oftha Oak Ridgw Moraine as a recharga aource, .
but lhae is no regard for the signiScant recharge t6at also takes plaa
. through near surface 6nc-grained aediments. No rechargo data are
provided; nor are thue azry eatimates of groundwater flux. Moreover, there
. is ao widence thet the proponent has givea any consideration to the large
• volume oFhydrogeological data available for tho area including numerous
publicadocu, npwu end several research theses. ,.
• The virwal absence of hydrogeological detail beyond the site boundary reprcsents a
. , aerious DEAR omissioa It is not aufficient to dismiss groundwater in the Local and
.Regional Study Areas by the statement (Section 6.7.6.2) that "till layus ........... protect
sources of potable water from surf'ace contamination". Thia dang«ously inaccurate
• assumption, popular over 20 years ago, is now completdy outdated. Research has aince
danonstrated that signiScant flow can take place tfvough tilis, especially near-surfaa tills
oFsouthern Ontario which are &equeadp sandy and fractured.
It in essential that the DEAR fully acknowledges the importana o£groundwater resources
and provida a futl quantitative asaessment of groundwater �ow and background
groundwater qualiry in ALL tfva study areas. Essendal information largely absent from
tho DEAR and ultimately requ'ued for aU tiva recognised atudy areas include:
a) a review of groundwater undertakings in both the Locnl and
Regional Smdy ereas daaunenting potentially affected users.
b) a full review of pertinent geology and groundwater Gterature.
c) hydrogeological maps and sections nnd sections ahowing the
loca! and regionel hydrostradgraphy md aquifer/aquitard
relationshipe.
� tabulation of aquifa and aquiterd properties. •
e) description of local and regional flow aystans indicating both
directlons of groundwater flow and antidpated travel time�.
� aasessment of aquifw recl�arge and groundwater fluxw.
� background groundwatc quality inciuding radionuclida. .
h) fiili evaluntion of potrntial impacta.
In addition there are xrious incoruistrnaa betwan the local graundwater water
condidons map �gure 6,7-8) and the shellow groundwater 9ow in overburdm map
(Figure 6.7-23) which nad to be recti6af.
31
Si1e l�ydrogeolo�: A number of the criddsmi levelled at the hydrogeologial aseaimeat 15 7
of the Y;ocal and Region�l Study Aras can dso be directed to the eite lrydrogeotogy.
Som� acicaowledgmnmt is made in this aa;tiioa thet the uppa put af the till is
weatheredlBactured, and limital hydraulic conductiviry data are providod for the major
geological units, Mit noue of tho dau arc pulled togetha inw a rigoroua interpretatioa
Questioa+ t6at seriowly nad to be eddressed indude: '
How does rahargp vary aaoss the aiteT •
• What is the recharge rate7 •
What are tho groundwatu fluxes?
Are the groundwater P.uxea consistent with the hydraulic gradicnta
and mcasured valuw of hydrnulic wnductivit�l
What aro Wo groundwater travel times7
To whaf adeut ia the shallow flow systan connaxcd to the deep
. flow systan7•How much water moves betwan the two systana and
ie thin tranefer consistrnt across t6e aite?
W6y does the mapping of potential non-radiaoactive contaminadon
for aoil and groundwata (Fig 6.7-2) exdude lerge atorage ueasl
• Furthermoro, muc6 of the site is backfilled with granular material and the aubsurface is
permeated with pipa and ducU. What are the 6ydrogeologicai propaties of the fill
materie!? To what extrnt do aubeurface pipes and ducts provide preferentiel pathways for
groundwater flovJ! How much wata mova via these features and how fastT i.e. what are
the fluxes and travd timos7
• BadEgmund Groundwala Qaality: A considerable volume of groundwater qualiry data is
pm+ided but Focuses almost acclusively on the site itsdf. It is essentiel that compreheasive
dntasets be provided for the Local and Regional Study Area�, fully documenting
Lackground groundwater queliry for all dissolved constituents (organic and inorganic -
including radionuclidee) that could conceivably be rdeasa! by the PNGS. •
• A large ut of water qualiry data is made available for the Site Study Area Flowever, much
of t}ti� databau was not devdoped in any systematic, proactive fashion but instead appeaza
to ha:�e :�r��tted incrementally during the past decade as variow spills end plumes were
chased eround ihe site.
• Background conditions for tritium in groundwatu are reasonably well pres�nted.
However, the contamination of groundwatat by tritium on thc site should be put in
perspective (see aations 6.7.7, a4, p 6.7-28; 62, p 6.7-29; �4, p 6.7-31 in Main Report).
Tha station rdeases about 10" Bq/y to the eir. Evaporetiaa of the groundwater is not a
problan for doses to We gmeral public vin the eir pathwaye, but rather would be sa
occupational problan for tha workrn. The poteatial hazerd from wntaminated
groundwater is obviousiy off site �ow into adjacau water bodies and conwnination of
drinking water ia nearby well+. Thia anphasizes the necessiry of detertnining the
groundwatu flow pattans and initiatiog rcmedial measures. The Provinaal lunit for
drinldng water ia 7,000 BqlL; tritium concentratiom in groundwatv on the site are
th.ousands of titries greater than this.
32
'15 8•• �� f��� ���°8 6a�6round wuu quality on �ito for any other chexmcal
• P°f°m�a �ha° ti'idum. As indiate,d aEovg it u Inaimbent upon DEAR to provide a
• ���Y P�sc line, or eterdng poiat frons which t6ture changa in groundwuer quality
(on end off-site) can be reliably masured and ovaluated.. With the mdating detaset tlus
impoa+iblo to do. Fuat and farcmost, additional data ere requ'ued to provide affidmt data
for rc,liabte application ofatatistical techniquw. It i� also necessary to presrnt watet quaGty
data as a xriea of maps (as was dane with Uitium) to ahow rcgional variatioru and tre.ndi.
Tha �� d�e8ram� used to present she inorganic chanistry �ro higfily inappropriate for
th° ta�k at hand since they anly provide relativu concentradons of majar iona end not
ebso�ute concentrations. It should also be noted that the diagrems are not plottcd
eccording to the nortnal convenGon end lack eoala for the tabe showing toW dissolved
aolida, � .
Overail commwt: 6ydrogeology
It L� eoncluded th�t t6e 6ydrological �nd hydrogeologlcal componwM of the Enviroamental
A�a�mwt areinadequate aod requlre cousiderable additional data aad analya�.
Sufian 6.7.8 Sebmfcity
Thia section is ono of the weakest in the DEAR documrnt end is loss corripleto than the version
prcsented in the earlier PDEAIt documrnt; furthamorc, it is replete with contradictory and
aimpGstic statemrnts. OPG and iU consultants demonstratr only the briefest understanding of the
st►uctural geology in the vianity of PNGS and of the magnitade of earthquakes that could be
expectedlocally orregionally.
Assessment of the probabiliry of large (magnitudc � earchquakes in the westem I.ake
Ontario region is based only in the very simplest of statistical estimates (bnce every
thousand years' or' 1 in 1,000 per yeaz'; p, 6,7-36, Main Report) that are nowhere
aupported or jwtiiied by real data Sation 6.7.8.1 nates conuadictorily that'the westem
Lake Ontario region experiences an earttiquakc of M=S or lcrger approximately ona
every hundred yrms. Which statemrnt is coRece? ]n an area of only very recent historical
measurement of earthquakw, how are these nodonal utimata arrived atp
Secdon 6.7.8.2 (Main Iteport and Geology, Hydrology and Sasmiciry TSD) atatea thec the
nview level earthquake (e notional earthquake that might ocau locally) would
accommodate evrnb such as an M-6 earthqueke within about 25 km (ofPNGS) or an
M�7 earthquake within 50 km. Givee tho PreseAa ofpoody undc.stood faults along the
Rouge Vallry and ba•cmwt structura (the Central Metasedimentary Bdt Bouadary Zon�
C�IDB� under !::e plant, w6y not consida a M=7 evsnt closo to the plent7 P. 6.7-38
indad does recogni�e this poufbility whaa it is stated that 'larga evenq cannot be ruled
out'. The PRT wishes to know why OPG and its consultants ere being hig}�y aelective in
identifyin8 possble eveats and their locatioa The aame section goq on to aay, without
any juati6catioq that 'the seismic hazard hat been well established'. Thls !s demontbubly
rmbue as che next aa:tion (6.7.8.3) states thac the faults along the Rouge VaUey'have not
been wdl documented to date in tanu of ailxr thar dates �r War geneais'. The PRT
33
. notes that atudIe� are arra�tly under wey to resolve ehe origin of these ehucpues and 15 9,
detertnine t6e impicadoaa for eeismic Hek anatyeis. UntU such work has beai completed
. � and Pea'reviewed the atatemeat claim3ng tl�at'seismic 6azerd hae been well establiehed' ia
• mialeading. . . . . , '
• The supporlinggeo%glca! documenlallon jos !he dlscussio» oJselsmlc rlsk fs /nadequak.
Flgure 6.7-4 atrangely dod not ehow any of the et:ucture within the Precambrian
• . basement despita much mapping by the Onterio Geological Survey and othero. Baaic •
information such ea dip data are missing from Figure 6.7-1. It (s not clear what Figure 6.7-
4 is hying to ahow7 What is the origin of the distinct downward atep in the Shadow Lako
Fom�ation d'uectly below PNGS7 This feaWre requirw analysis a+ abrupt changes ia the
elevation of geological strata aro commonly assoaated with the offset of atrata horizons by
fauits.
� The PRT is very wncerncd that OPG and its consultants hAva removed &om DEAR the
geological map presented in PDEAR showing the deep basement stcucture below and in
the vicinity of PNGS. This map is of consideroble significance to the EA as it was the only
depiction ofthe locadon of seismogenic structures such av the CbIDBZ close to PNGS.
Neither is an}+ additional map prarnted in the DEAR that shows the locadon or geology
of the faulb in tl�e Paleozoic and Quatemary geology along the nearby Rouge Vatley.
These are serious oversights as such data has direct bearing on tha identi5cation and
analysis of geological sWctures under and near the plent that are capabie of generating
earthquakes. The lack of a systematic and clear methodology for the investigadon of the
local end regiona! geological conditioro azound PNGS ia disturbing to tho PRT. •
34
160 9EGTION 6.ar�xn x�soutecFS .
The PRT haa two wggeations rogarding the LAAID RESOURCES axtion ofDEAR.
' Faat, additional informatton that would be ueeful in thia aection ie the rclative locatioa of
'aenritIve' Imd uses, both existing and planned lend uaq with rwpat to the 7ocai area'
• •(de8nad aa PNOS plw the 914m exclusion zone). While thae are dnacripdona ofadsting
land uses in Sxdon 6.8.6.1, theae descriptions do not anawa tho very eimple queation of.
kow ciwe to the local area inight one 5nd residential.developments and/or otha ea�sitive
•. lead usea (wngregnte care faaGtid; day cares; unioro antrea)�
• Second ia the related queatiou oP. what is the futwe planned land u�e for tha uea7 For
exampiq ue there approved plens of aubdivisioaa on Sle which are going to c6ange t,5e
nature of resideada! and related land use patterns dose to the local arca as defined?
' NcitLer of thpe quation� are an�ered in DEAR aad t6b i� n major omi�ioa. ,
. 35
: , i:
.r:.._ . , • ; .
• � SEGTiON 6.9: soc�aECOrroMac Goxnrr�o�is 16 i�•
' The adstonce ofPNGS withL� their wmmunity ia a mnJc r conam to a luge proportion of
residenb both In Pickering and beyc �d. This ia evidenced in aeveial of the community wrveya
undertaken iu preparing this aection ofthe report and overall, the EA team hea done a reasonable •
job in both eddrnsaing the commenta made by the PRT on PDEAR and aeaeaeing the iewe rrioro .
' d6nerally, In the opWon of the PRT, the veraion of eocio-economic impacte asseaunmt in DEAR
is mucb unproved and hes addresau, savual of the commente made by the PRT.
• Por example, addidonal methodological detail for the'pubGc sttitudw reaearch' ia
provided, although not in the Main Report itsel� but in the Socio-Economic TSD. It ia
usefltl to have copies of the interviews and aurveya provided in the TSD. Howeva, eome ,
of the methodological detail ahould elso be provided in tha PEAFt summary. Thi� can be
proyided in a briefparagraph and should inciude at least;
' - sample �iu ..
- whrn the data were collccted •
- by whom the data were cc'!acied
• - the mcc}►od of data collection (tdephone, in person interview, etc)
- how the data were recorded and analysed
Unfortunately, for all aspects other than public attitude.a research, this infortnatian is not provided
either in the Main Report or in the Socio-Economic TSD.
Several other comments made by the PRT on PDEAR have been ignored.
• For example, the tables in the DEAR reporE only percentages with no n's in the tables at
all. This partial reporting of information continues to make it difficult to interpret the �
6ndings in any comprehensive way. The PRT suggested that DEAR include the wmber of
physicians and other health care providers (acpressed as a rate) under'medical care
facilities'; this information is not found in the current version of the document.
OP(� and iU consultants have clearly conceptualized and framed the principal socioeconomic
issues to be addressed (cFSection 6.9.2,5 and Figure 6.9.3). However geps remain in the
operationalization and measurement of socioeconomic impacts of the proposed restart:
• - p. 6.9-18; the document etates: "Local realtors in Pickering indicated that PNGS has not
� influenced the number of sales a9 the tumover of properties aearest PNGS appears to be
comparable to other communities and neighbourhoods in tha City of Pickering." If this is
�true, this is a statement ofgreat import to the community but no evidence is provided to
si�pport this statemenG Overall, the conclusions drawn ebout property valUes and tha
effects ofPNGS ere not well-supported and suffer from.lack of inethodological detail.
Tablo 6.9-8: this table.describes Bequency of uso of perks, beaches and trails. The total
sample siu (determined from tho TSD) was anly 53 end no information is prosented as to �
when the survey was coaducted, by whom, how often, on what days of the weekbr
.time(s) of the year.
Further, substandelly mora data wae wllected and aggregated than are reported in this
Sectian, including'other concana' about the restart, which included `health', 'safety' end
'lack of ciedibility'. T6ey are reported in small numbero but given the siu of the samplq
. 36
�
. 1 G 2 ti�., te noc eurpa,u,8. _ , , .,
' • • Sxdon 6.9.IO.ls The DBAiCihiee that•'"fhe dnts indicato Uut PNGS (a en Imporwit
•• feature that de6nea community character in the rdidy ueae, but not the dominant m►e."
Ciranted, tht� 1s a judgment c�ll, but on the badt of the datn reported in Table 6.9-12
• (which indicate that PN(3S ie the number ane dieike reported), thb,atatanent requira •
jw68cation. • •
+
. 37 t '
� :�
,. �
7' x
i;F -
t rM
� " q
. � E•, - _�;r #y '
i 4 'j tf
� � ` R � {
�
�` �r4 � , zy
: ,� �� ,� . �.1� � : -f a � � � a
t �
' x sf'. � , r - �r'. ¢ .
k r>, :.� �, 4 31 � 7� E . L } '..�' i l.
/ 'F .
� '' 1 ;i y$ F'
;� ` F` � � � ^�, J �� f}
_ � �A: t .' � \JA �i t ,Y y .
�.. S {
_ t �. .!x �.. G . J - ��
y }_ � v i ° `ij
t ��; � � r ; � ;'' i F *
- : i s!� .-n} w r..(.Jr's,�#r�q
�; i�..i�t._ ,�ti.'.= .s� a.�i'.: vZ.
gT : t_: ��. $ �rd Y S $-fr
i....utiR�4.ii ..-.m.., .}..t...tx .�.ta'L rr,4�. ._.—':za '',,...:#..L�I . -. .. , .. . .
SEGTION 10: CONSIDEMTIONS OF HUMAN HEAI.TH ' • • 16 3.
The F'ic�al Scope daximeat ieaued by AECB in Jenwry.2000 indicated thnt the Snal EA
dowment would include a review and anelyeia of health etudia undertaken in the vicinity
of PNQS. The rather briet Sadon 10 of the DEAR aod Appen,diz F do not
constftute iuch A revlew. .
The EA team he� conceptualized the potmdal human health impacta in a reseonable
manner (Figure 10.2-1) but the PRT disagew with coramenta vrhich accompany the
conceptud fiamework end, in particular, the comment related lo psychologicaUatrws-
related impacts (p, 10•1). It may not be possible to identify epec6c effecta of the effax of
the retum to service of PNGS-A but thae is a substandel intanational literature on the
psychosacial impacts of enwoamental exposure situations which the EA team has missed.
Thia Gterature is highly appropriste to the caso of a nuclear generating facuility within an
urban community. This Gterature descrves attention sinco recognition of thr. community's
psychological anxieties and conams will go a long way to establishing credibility of the
EA
Tho PRT would argue that the appnrently ill-deSnod wmmunity health concems C.e.,
anxieties end conams about future health/potential health impacts; impacts on quality of
life en�! well being) are indeed those of most concem to the public and yet are the health
concems being directly ignored by the EA team, apparently because it is very difficult to
study them. T'hey are complex and difficult issues but not impossible to study. Health is
represented by.complete social, physical and emotional well-being,'not simply absence of
disease (Worid Health Organiration 1978), and has been more recenqy defined as 'a
resourca for everyday living which helps individuals copc with, managq and even change
theu environment' (World Health Organization 1986). More importantly, tha recent
Conad/mr Hmulbook on Neallh Impact Assessmenl(1999) produced by Heahh Canada
and Environment Canada includu both the physiological AND tha psychosocial
componente oFhealth in its definitian. This reIlecta not only evolving models and
deSnitiona of health (see above) but atso the empirical evidenco for the relaGonship
between psychosociel and physiological hcalth as evidenced by many internadonal peer-
reviewed scientific atudies,
Overal! commenfs: Humon Hcalfh
DBAR focusses acclusively ort physiologieal aspects of health, despite recent guidelines on
undertaking environmental health risk assessments that are based on mounting evidence of a
relationship between the physiological and psychosociel .components of health. It ia the view of tha
PRT that the psychosoaal impacts being reported by communiry residents (reduced feelings of
personal security end levels of satisfaction; worties and concems about futwe heaith) are an ,
important and legitimate compbnent ofthe heslth and well-being oftha local and regional
populadons. They continue to ba ignorod in tha environmental assessment despite avsurances to .
the public that such is'suw tvill Fo addressed (i.o issue 120; Table 3.1-1). The PRT agrees that "
some residents have and may continue to experienca some anxiety ar loss of feelings of personel
�aecurity dudto the project" (7.2-105). The PRT notes that some groups report grcater concems .
than othera (e.g,, naw residonts, those living in closest pro�dmity to PNGS, women and parents of
+,
38 .
1�6 4°�'��i-'�� �a,�;��.2-103). Such Juuee need to be eddreeeod end �ccounted for in tny .
midgadon mwutea. Ox the bub of t6e very Ilmited data �nd waly�i� prqeat� � Dg,AB,
the pu6�ic wql copUaue to 6ave real eupcern� about iafety and pu6Uc LetlW Impact�
(aetu.al or perceived� praeat or futuro) utrtaQ from the opentlon ofPNCB and tLe '
propoied reatart of PNGS-A. . .
r.
' � .
;
. � - 't, �t� -
� -:�t � � .. ,
. �- ' �1,j � -
a r.`
� 1� �
• ��:...
' S.` � r
� �. 39_ �
} � `
;
;
�
' ;°
e � r ' * � � � � � � �
` s � ���3 � � �:�. .
� . �� j � ! �t . z .
f
t 4 � � q � . ( 3 4 `f ;
_ a '� ' ,� F � � t , ,� �, a
�+ �v t � y m E "� (
t t \ R �:� � .y � y :: 4 ; f ; �: .
; �..1� ; '� -. � ik , 1 4 �Q s �y� �{.�'e� 1 '� � �� � S} � i'
���- t �a J Y �6Y � t F� f 1-a � ���. t� f�..�� 4 S .a i�� ..
.-r , .�. ... .... J'-i _.. ..,, ... .. >'-l':. ,., .. . ,�..� _ . .._... '.I�..�. . _.., . -
.''��-_' ;'
�
. . -�
SEGTYpN 11: PLAN FOR FOLLOW-UP AND MONITORING PaOGRAM ' 16 5,�
Thi� acction provides en overview of the steps to be taken to vuify tha wncludon of the EA
proccaa as to the abaence of any adverae envtronmental impect, end to impleaunt mitigation
measurp if impactt chould become epparenG TP�e PRT arreaa that the daiQu o[ any foUo�r up
p4m and monttoring program tuch iu that depieted in Table 11.3.16 premature �fven t6e
gapa in undentanding of wvironmeatal eondfdoni Idwlitied by We PRT. My follow-up
plaa has to ba based on identification of environmentai data gaps and specific areas of concem.
Table 11.3.1 requires eubetantial modi6cation in the light of the PRTa detailed comments made on
n'discipline by discipGne' besis above.
Plckering A Iteturn to Servtce Anuez Report: 7s�ua from Pickering Environmental Revlew
The Pickering Environmentel Review of late 1998 Involved a community consultation program to
identify environmentel issues of concern to the pubGc with regazd to the rnvironmental impact of
Picicering NGS. The Gst of issues arising from that program has wme W be known as the'160+
issuzs'. The arrrnt EA includes e process for understanding acreening and addressing each issue
as called for in the Final Scope docurt�ent Ttus procus is dealt with in a separate Annex Report
to DEAR. A summary of responses to the'160 + issues' is also listed in Appendix D. A very
aubstential number of issuw deals with curtent conditions and potendal impacts on the biophysical
c, vironment Table 3.1.1(Guide to the Disposition of the 160 issues) atludes frequently to the
Geology, Hydrogeology and Seismicity Technical Support Document. Given the substantial
datageps apparent in that document, the PRT does not wnsider that biophysical issues have been
saiisfactorily addressed in the EA document. Additionaily, a prime issue of considerable pubGc
concern (health) has largely been ignorcd in the assessment (see above). . .
40 _ ' ' • .
; �;r
s <
aE
y i
1 � � 1` k ly
i i 5
�� c._ ... .... sy '` tl � L{ ., i.. " .as.....?�� ...5�.. _a ��.�:.. `Y...1 t� .,� . . . . . .
�- _ _� 1. � - � � �
166 �' �►ApNYI�1T# z TOi�0AT1 r-�P d2-oa
. za-�i-�9
Dr. N. f:yles �
4993 Cnnso Drive
Claremont ,
ON L1Y lA8
Tel/Fax:905-649-2544
email: eyles�scar.utoronto.ca
ATTBNTION: Gordon Reidt / Toar Melymuk
The CarporaHon of the Town of Pfckering
Fax:905-420-7648
Pecr Review Teaw cumments
On
Draft Scnpe uf Assessmenl Dncuuient tor az�
Envlronmental Assesement (EA) pursuant to tl�e Canadian Bnvironmental
Assessment Act (CLAA)
Pickedng Nuclear Genenling Slaliui�'A': Relurn to Servlce
Submitted to the Town of PlckerLig November 25d�,1999
PRT-doc002
1
? F-
s r
f �
�
.i� z
, , t,..` . . _ i� . + �
167
EXECUTIVE SUMMARY
The Draft Smpe of Assessment document lssued November 2nd by the Atomic
Energy Control Doard contaIns;
1) a ratlonale for a screei�[ng level environmental assessment of the restart of
PIckering NGS-A factlity.
2)ldentlfIes the scope of such an assessment by oudlning a series of stepa to
measure the enviroiunentat impact of the restart, and;
3) prov3des a Umetable for such activiUes and the completion of a Draft
Screening Report by late January 2000.
The Peer Review Team find, Sn general, Uiat tlie Draft Scope document ls poorly-
written, incomplete and ambiguous. lt requires considerable clarification relating to
many issues. It does not provide a well-structured or coherent [ramework for
measuring environmental impact of the restart of the Pickering NGS-A facility.
- The justificaUon made by AECD for a screentng level assessment, rather
than a much more thorough compreliei�sive assessment, Is weak and dces not
adequately recognise that the project is large and enviro►unentally sensitive.
-'fhe dra[t scope does not clearly state tivhich issues are within the scope of the
assessment neither does It adequatcly deflne what issues ure outslde the scope, Too
much has been left to the discretion of OPG and it is not clear how the outstanding
160 + issues that arose from the Pickering Gnvirunmental Review of 1998 are to be
dealt wlth. Health is a key issue of public concern and is inadequalely addressed in
the Draft Scope. The timeframe over wludt environmental Impacls are lo be
assessed is too short and (s restr(cled to the apentional llfespan oE tlte facility.
- The timetable for cotnpletion of the assessment and productIon of the Draft
Screening Report Is inadequale. Tliere are significant gaps l�t knowledge of
envIronmental condltlons around Pickering NGS and the scienti[ic credlbility of the
assessment is compromised because Eundamental baseline data wlll not be avnilable
until well a(ter the assessment and Scrcening Report have been completed.
Key recouioien�intior�s made by the Peer Review Team are: that the Atomic Energy
Control Board be requested to change the status of the assessment from screenIng
level to comprehenstve and extend the tiuieframe of the assessment to allow
Incorporation of critIcal baseline environmental InformatIon. The AECU should
identify and defIne precIsely those issues Uiat ace within the scope of the assessment
and shouid specify that long-term envlronmental impacts be assessed over the
'contam[nating lifespan' of the facility.
2
.ry
:. . �. �. ." .
, �.
:t _
. . _.
. :.. .. .�..: � - .; -� :. a
.. ��. t.� . . .�.r �- � , ;. � � '. _
♦ ':
.�, . .. l•. � .. .-.'i . . . .,.i - -' i. . : . �.� . , '
168
INfRODUCTION
The Draft Scope of Assessment docuuient for the Environmental Assesament
(tssued by AECD on November 2nd 1999), ls intended as a gutde and a framework
for u wIde range of activltIes by Ontario Power Generatlon (OPG), its consultants and
the public community over the next 9 months. The Draft Scope of Assessment sets
out, ln the broadest posstble terms, the assessment whtch OntarIo Power Generation
must accomp.:sh before the restart of Pickering NGS-A is feasible. The clarIty of the
document is therefore, of consIderable importance. lt must be comprehenslve,
easlly understood by the public who are stakeholders ln the process, yet it must
provide provide appropriate technIcal dfrection to OPG and Its consultants.
OGjective of Peer Revfew Teni�e The criterion which the Peer Review Team has
used in assessing the DraEt Scope docwnent is sfmple; does it provide n well-laid
out, credible, coherent framework for a thorough scIentlfic assessment of the
environmental Impact arlstng frum the return to serv3ce of Pickering NGS-A? In
brIef, we conclude that it does iiot do so. The major weaknesses in the document
are oudlned below and ttilrteen recomuiendatioi�s are made regarding the form and
conlent of the Flnal Scope.
3 '
�
a,
;,� ;, ,r
�
�f J
* � 1
` t .
� 2
a Y '
J i x ' } .
.�[. , u�... t c��:� Fc .a..asY ��_.. ,.., i�,. ?�... �.... , _ .... . �... :.... , . . . . . .
169
•.MJ •��u'►Yh:►� •► 'l►
j$,�jj�; Poor orgaatsatia� of Draft Scope docuineat
Comment and concern: A major flaw of tlie Draft Srnpe document Is that it ta not
well laid out or structured. It is clumsily-written and wordy. Individual paragraphs
IdenUfy multiple and different requ[rements for completion of the envlronmental
assessment (EA) 6ut na►e are nuui6cred or listed systenmtica►ly. Consequently,
there Is no easy way to identify, cross-reference and address these requlrements and
subsequently track them through the EA process and OPG's fiA Screening Report.
The Draft Scope document does not provlde a clear frainework for the EA and
creates the polential for conflicting inlerprelatio�u of exactly what is required and
what is not. The Dratt Scope document does not clearly define which issues are to
be addressed In the GA, and just as important, wlucli issues are out oE bounds, Too
much has been left to the discretion of Ol'G in the inlerpretat3on of the Draft Scope
and this creates an invltation for disagreement betwecn all parties.
RecommendaHon to AECt3:
1. AECB should ensure tltat the FInal Scape is cleatly writteu, systentatically
structured and that each specitic requiren►eul is care[ully IdenlIfled and numbered.
4
, � � � �
y: _
i: k
! �
4 _
t _ t fi
t
F t .f Y �
'� + /
< R ` !.
. t x �v��. �._ i.� �� fe :r., . }_�!� ... — ...: . ~��.� . . . . .� ._ .
170
,�p,�jon 3.0 Aplicallon of I:�e anadi�n nv(r �umenl-1 Asa aqment Act (p. Z)
�]J�: AECB's ratioua/e jor acrceuing leve! assessn►cnt
Comment and concern: The rationale fe� a screeaing level assessenent as opposed to
a conipre6ensive assessment relates to tl�e statement made on page 4 of the Draft
Scope document that "the project Involves die return to servlce of an existIng,
licensed facility; it dces not Involve issues diat would typically be assodated wIth
the mnstruction or operation of a new facility being licensed for the first time". This
statement is technlcally correct under the CGAA. '
The Draft Scope docutnent gces on to say U�at "AGCD considers that the
envIronmental assessment issues and concer�u that are relevant to the return of
service of the Pickering NGS-A facility can be addressed effectively and appropriately
in the screening level assessment." The 1'eer Review Team do not agree with this
statement.
We emphasise that the "environmentai assessment lssues and concerns" that are
relevant to the return to service of tiie I'ickering NGS-A facility are in fact,
extremely broad, compiex, and encumpass nssessn+cut uf llie irupact of the ope�alion
oj the entire Pirkering NCS sife on llic sunuunding biopliysicnl ciroiraunent (see
Section 6.0 Scope of Assessment, below). The Draft Scope document also expllcItly
recognlses the issue of decommissioning.
Further, the cause of the shutdown of Pickering NGS-A was a non-rouliae situation
lnvolving an ageing reactor and the need for signlfIcanl safety upgrades. The return
to servtce Involves considerable modifications lo the existing facility. These go well
beyond a simple'restart'.
5
! ti.:,
y�
. � ,. ... F�.. . . . ... » . .. .. ....M - _.- . . . ..
171
The AfiCB Draft Document also states (p. 3, para 3) as part of Its juatification for a
screening level assessment, that "the proJect is not described in the ComprehensIve
Study List RegulaUons under the CEAA". Agaln, thls is tecludcally correct and the
project (narrowly de(ined as a'restart of an exisflng facility') is not 1lsted. Iiowever,
�,
the CEAA also states that a comprehenslve screening uiust be applied to "large and
envlronmentally-sensitive projects". We would draw attention once again, to tt+�s
broader clrcumstances and concerns that prompted the closure of Plckering NGS-A,
the location of the facility in a densely populated area and the hlgh level of public
concern regarding the safe operation of Pickering NGS. We also nole that despite
the narrow deMition of the project, the enviromnental nsscssuiertt ts intended to
address a very wide range of additional enviro�unental issues with regard to Uie
operation and cumutative environmenlal impact of the enlire PNGS operatIon
(induding demmmisstoning). Consequentiy, it can argued that the scope of the
project Is "large and environmentaliy-sensitive". Additional circumstances
sutrounding the assesssment relate to the demonstrable lack of key baseline
environtnental data (see liecommendations tIG and 13). We note, further, that the
Responslble Authority (ABCD) has the optiun of re(errtng lhe project to a mediator
or review panel "if warranfed by pu�lic cuncerris" (CCAA, Section 20). Given the
wider clrcumstances surrounding the retum lo service of Pickering NGS-A, the Peer
RevIew Team believe that the ACCU should exercise its mandaled opt3on and
request that OPG undertake a coinprclicr,siuc em�lronmental assessment.
fI• �nn �tFTl�i � : �
2. That AECB recognise the level of publle cwicern regardtng the safe operatton of
PIckedng NGS, the large nuu►bec and wlde range of oulstanding environmental
lssues identified to date, the presence uf substantial gaps fn baselfne environmental
data needed to measure environmental impact of tl�e facllity, and raise the level of
envIronmental assessment from a screenliig level to comprehenslve.
6
.
t --
_ , _ . . .. , .. , � . , . . . . .. � • . .
172
S.0 Scupe af Proieet (p. 5)
ISSUE: Scope of Project
Comment and concern: Under paragraph ], Uie scope of the Pickering NGS-A
project is nacrowly deflned as "those operaUons that are dIrectly related to the return
of servlce and continucd operation of puwer.... ovcr ils expected operationai life".
This "involves on-site physical systems, buildings, land and infrastructure of the
PIckerIng NGS-A facility, including the nuclear slea�n supply systems; the turbine
generator system; electric power syslems; the nuclear safety systems; and andllary
systems.... ".
The contentious statement here is "over its expected operational life" which
is repeated on page 8 of the Draft Srnpe (para 3) wlicre it is stated that the
"timeframe for the assessment will be tlie duration of operation of the Pickering
NGS-A facility following the return to service". Tliese statemenls constrict the
timeframe of the proJect much too narrowly (or the reason that the ussess�nent is
designed to identify long-term cumulative enviraunental Impacts. Such impacts
may only be evIdent a(ler the operation of I'NGS-A has ceased. Tlds rnncern is
addressed in detall by the i'eer Review Team on pages 16 and 17.
�
. . . -.- , , .�', :- :_' ,<.. . . ;...
� � � �', �
� -
.��
;�`�
�� .. : . , . .,„ ,
. :=
,.; , , ,:, : .
, , , ..
- ... _ . . . . . � .., , -;_; . . . :
6.0 Seope of Assessment (p. 5)
�__ i r
173
�;: Lack of approprlate deji��itiuns b� Drujt Ducuuicnt
Comment and concern: Sections G,0 and G.1 state thai the "definitions of
environment and environmental ef(ect for the purpose of ttils environmental
assessment, lu�ve the mcaning in section 2 u( lhc CCAA" but tltey are not provided
anywhere in the Dra[t Srnpe documenG The failure to include these definitions in
the Draft Scope is not helpful. Tlie Draft Scope document should nol rely on
another document that is not widely available lo tlie public (or clarification of
deflnitions that are jundamr�rtul lo the assessment.
Consultatlon of the CEAA web site offcrs the fulluwing defi�utiuiu of
"envLrontnent' and "environmental e(fect" (taken (rom the Reference Guide -
Determ�ting Whether A Project is Likely to Cause Significant Adverse
Envlronmental Effecls; see <http://www,ceaa.gc.ca/publications/guIdes_e.htm>:)
The Act defines the envirunnicnt as: the components of the Garth, and includes
a) land, water and air, InduJing all layrrs of the atmospherc,
b) all organic and inorganic maticr and living organisms, and
c) the interacting natural syslems that lnclude components referred to tn
paragraphs (�) and (b),
Eitviro►inienlal ejject means, in respect of a project,
a) any change that the proJect may cause in the environment, including any
effect of such change on heallh and sodo-economic cond[tions, on physicai or
8
`,
':;, �
,
;��
,�°
,
174
cultural heritage, on die current use uf lands and tesources !or traditional
purposes by aborlginal persons, or o�L any struclurn, site oc tlting that Ss of
historical, archeological, paleontologlcal or arclilteclural sig��lficance, and
b) any change to the project tiu�t niay be caused by du environment, wlietlier
any such change occurs within or outside Ca�wda.
� �iin ��. �i � +���i��
3. The AECB should eiuure tliat lhe Fiiial5cupe ducument inctudes ali relevant
definitions of key tenns. A glossary uf lerms aad a listing ut acrunyms should be
attached.
15SUE: Scope of Assessment
Comment and concerns: Sectiun G.1 (paragraph 3) states tliat the "environmental
assessment... w311 include a consideration oL.. lhe environmental e((ects of the
project, induding the enviromnental e((ecls of malfunctions or accidents" i.e
ongoing activitfes. Section G.2 (pacagraph 1) repeals tlus and broadens tlte srnpe still
further by staNng that "emphasis will be placed on describing those aspecls of the
project, including acddents and malfunctions, waste management practices and
radioaclive and non•radioactive emissio�u tliat could reasonably be expected to
affect the evlronment."
All these activities are clearly related to tlie routine operatiai of Pickering NGS-A,
not just Its restart, and indicate that the Scope of tlie Assessment is broad (see
below).
The Peer Rev3ew Team notes that the envirunmental nssessn+ent must consider
9
cumulative enveronmental e(tecls of the project "in mmbination wI!3: other
projects or activIdes that have been or will be carried out" (paragraph 4, p. 5). Such
projects and activiUes are Ilsted in Attaclunenl 2 on page 17 and indude Pickering
NCS-fi operaUons, and waste management operatlons. It Is clear lhat the inlent of
the EA is to assess lhe culirt I'ickering NGS operation althougli this is not explicitly
stated in lhe Draft Scope document.
According to the Uraft Scope document, the Gnvirun►nental Assessment will also
consider outstanding Issues that arose from the I'ickering Cnvironmental Review of
1998. Signiflcant dala gaps were idenUtied in that review and OPC and Yublic
groups came up wilh a Iist of outstanding issucs (re[erred to as the '160+ issues'). On
P. 11, under the section'Pubtic and tectuiical issue manage►nent', explicit reference is
made to'public and lechnical issues that were identified foc tlie overaU 1'ickering
NGS site during the 1998 Gnviro►mienfal lieview'; Uus is a direct reference to the
'160 + issues'.
lt is very clear from lhe abuve, lhat despite the narrowness uf the �rrojccf, the scope
of the environmental ussessinrn! includes lhe enviro�mienlal impact of die entire
nudear operation at 1'ickering NGS. 'flds is nut staled explicitly in the Draft S.ope
document.
Recommendalion lo AECQ
4. AECB should ensure that lhe Final Scupe document cunlains an explicit
statement recognising that the scope uf llie environmenlal assessment Includes
environmental lmpacts arising fro�n the entire Picicering Nuclear Generating
Station nperaUon.
10
�;
, " _ ,; �,, _
�'. , ,
175
176
6.2 Scope of lhe tactors (p. 6)
tQ� Deurtptlo�� oj tl�e exiating ei►vironuiu�t (p.7)
Comment and concern: Pickering NGS I�is been in operaUon for almost 30 years.
The Pickering Environmental Revlew of 1998 [denliRed a number of potentlal on-
site and off-site impacts arising from conslruction of Uie plant and its subsequent
operalion (see above). Such impacts are, as yet, poorly understood and lhe 1998
Gnvironmental Review identi[Ied more than IGU environmental issucs raised by
the pubUc mmmunity and OPG that await (urll�er study. AGCII require sucli lssues
are to be addressed in lhe c�:rrent EA, lhus recognlsing tiwt the environment of
P(ckedng NGS is not pdstin� b�t has already been impacted. I-iowever, the
existence of impacts is not rrcognised explicitly in tlie Du�ft Swpe under lhe seclion
'Desaiplion oE thc rxisUng cnvIronment'.
Recommendatlon to AECD
5. AECB should ensure lhat any issue(s) apperlaiuing lu identlficallon of currently
exlsting'baselfne envirunmenlal condiUuns' in tlie final Scope must expllcitly
recognlse the nature of existing impacts.
LlCl�tedlH9sts; Tlte stntus of onyuing sludics; w6cn wil! kcy residls be avnilaGle7
Comments and concerns: The Pickering BnvIronntental Review of 1998 identified
serious data gaps regarding the impact of Pickering NGS on the surrounding
biophys(cal environment. Several studles were commissioned as a result of the
Review but will not be ftnlshed until well after the GA process is completed (e.g,
Hydrogeological Study of the Pickering NGS Site). Other studies that are planned
11
, ,`
�. ,�� :
t:
, r .'t'. , + �
� � 177
Include an ficologtcal Rlek. Assessment (to identify impncts on aquatic ecosystems), a
Faclllty Rlsk Assessment (to deal wtth clvoiilc spills and leaics), and a Catustrophlc
RIsk Asaessment (to deal wlth a sudden loss of coolant). The Peer Revlew Team is
undear whether data From other ongoing stud3es appertalning to seismic rlsk (e.g.,
aeromagnetic surveys of lhe western end of Lake Ontario) and background radIatlon
(airborr..e gamma surveys) will aiso be avaIlable for incluslon in the present
environmental assessmei�t. It is our understanding that many data wil� only be
available well after complet[on of the Draft Screening Report in niId-Jan4;.ry 2000.
The Peer Review Team Is also keenly aware that certaln studtes that are central to
any envIronmental assessment Jiave not yet eueir bee�i comntissionecl (e.g,, Cancer
SurveIllance study being proposed by Health Canada and ACCU). Gxisting health
studles carried out to dale are explIcitly recugiilsed as having "design limItations"
(Ms. M. Pietrusiak reporting to Durliam Nuclenr Heallli Committee; September
24th, 1999) w}ilch limits the ability of OPG to fdentify health lmpacts witliln the
ossessment.
T6e Peer Review Teap� qi�estions !be validily mid crediGility of r�ny envtrattttental
nssesssment, and conclusiolis relnliug to 'enairuanienfu! impnct' of Pickering NGS,
ij sucit an nssessu�ent does nvt include nif relevu�d scieutific injurn�atta�. The Peer
Revlew Teams questians wliether sufficient in(ormation exlsts with regard to
current baseline envlronmental condit(ons lo allow a thorough env3ronmental
assessment. '
l�ecommendatlon to AECB
6. AECB ahould ensure lliat OPG provlde tlie Town of Pickering wlth a
co�irpre6ettsTve Ilst of all argoing or pinnued projects appedaining to nteasurement
of'envlronmental impact' wIth a tlmetable fur cumpletion of results.
12
�:¢
.; ;
1'78 ,
j�j��IS�l1e; Identlficalion aiid definttion uf valued ecosyslem components
The second paragraph under'Descrlption of ex(sting envlronment' on page 7 of the
Draft Scope refers to an "ecosystem npproach" to the descrIption of the bIophysical
environment that includes Identiflcation of "valued ecosystem components
(VECs)". The Draft Swpe fatls to provide adequate definitlon of "ecosystem" or
"VEC" and does not address the issue of wl�ether human beings are considered a
valued ecosystem component. Recoinmendation 113 of the Peer RevIew Team
requests AECB to include definitIons of nll ke� lenus in the Pinal Scope document.
Under "descripHon of socio-eca�omic environment" (paragraph 3) reference ls
made to "functioning and structure of the socio-economic envfronment of the
people" but it Is not staled whether lhis includes publIc health. It Is not at all clear
wliere and liow human healUi and psycho-soclal impacts are to be nddressed fn the
EA since these are not explicltly lisled in the GA Draft Smpe document. The issue of
'heaith' Is missIng entirely from 'Descriptlon of Gxlsting Gnvironment' (p. 7) but is
listed subsequently under "Assessment of potenlial env3ronmental ef[ects" on p. 8
of the Draft Scope document. Ttils creates a serious ambiguity in the Draft Scope
document because if there 3s no clear requirement by AECU for OPG to assess
existtng health conditions among the public community, it is very unclear how any
potenNal environmental effecls of the project can be rea8stic.�lly assessed. The lssue
of public health Is addressed below on pages 17-18 by the Peer Revlew Team wIth an
appropriate recommendatlon (11 11),
13 .
, _ . ,�:.. , .. `... _
!79
1$,�8: Spatinl nad teu►poral 6vu��derles of enviruume�ital asseasnreot
Comment and Concern: There are maJor problems w(th deflntdons of the enatfal
and temporal llmits of the BA being suggested by the AGCD Uraft Scope docutnent
(pp. 7-S). AECB ldentify three'suggested' geographic study areas deslgned to
"encompass the areas of the envIronment that would be directly affected, or
reasonably expected to be affected, by the project" (p. 7, paragraph 6).
We fully agree with the comment made on p. 8(paragraph 2) that.any defInlUon of
study area must be "sufficiently flexible lo suit the different components of the
environment that would be dIrectly affecled, or reasonabiy expected to be affected, by
the project" In other words, the size of sludy areas will change according to the
partIcular environmental Issue under consideration; for example, the study acea
approprlate for consideration of enviroiunental e(fecls arising from atrborne
releases of tritium wlll be much larger lhan say those arising from tritium leaks to
groundwater below the plant.
Three'suggested' spatial boundaries are indicated by AGCD;
1. Site Study Area,
2. Local Study Area, and
3, Regional Study Area.
Of the three, only the Site Study Area (1) has any well-def(ned meaning as it extends
to the immediate sIte boundary of the Plckering NGS site.
In contrast, the rationale used to define study areas 2 and 3 are not provided by
AECB and the proposed areas are a m(xture of polltIcal boundaries (e.g the Towns of
PIckering and Ajax) and pootlydeflned geographtc areas (e.g,, "the eastern part of
Toronto closest to the PIckering NGS sIle"). Nelther study area has any real
14
180
sIgnlficance for nn envtronmentnl nssessment of Plckering NGS and both faIl to
make expllcit reference to nssodated waterbodies such as Lake Ontario. The Peer
Review Team is puzzled why reference to "cumulattve effects of the proJect" Is only
menHaned In regard to the Regional Study Area.
Recommendations to AECB
7. AECB ahould ensure that Uie Final Scope contafns study areas lhat are
appropriate to apecifIc individual disciplfnes and aot leave OPG and its consultants
to determine (limtt) the extent of llieir atudy.
e. AECB ahould ei►sure U�at cumulative environmental effects will be constdered
for all atudy areae.
Related iesue: Identi�catton of atake6ulders nnd physicn! worka and activfties
Comment and concern: Defining the spalial exlent of tlie GA is a critical part of the
Final Scope document because the size of tiie geographic area determines the
identi�cntion of relevnnt stnke6olders nitd nny pb�sicnl ruorks ni�d nctivittes tltnt
must 6e incltrded fn q�e EA process. OPG are required "lo establish a public
consultatlon program that keeps stakeholders and the public fully informed of the
proposed project and provldes reasonable opportunitles for the Issues, concerns, and
comments of the publIc to be identified and considered In the environmental
assessment" (p. 10, paragraph 6). Nowhere in the Draft Scope document ls the lerm
'stakeholder' defined; neither can the full range of stakeholders be identIfied until
the study areas have been established. The Peer Review Team's concern ts that
15
181
appropriate study nreas wtll only 6e ldentifred lute tn the nsseasineut and that
potentfal key stakeholdera wUl be excluded. The same concerns apply to
determinatlon of the range of Physical Works and ActivlUes to be Included wtthIn
the scope of the Assessment that are Ilsted on p. 17 of the Draft Scope document.
Recommendation to AECU
9. AECB ahould ensure tliat tlie lerm'stakeliulde�' ia adequately defined ln ttie Ftnal
Scope and that all relevant stakel�olders are lncluded wfthin tlie environmentai
assessment procese.
j,��j�: Tiin¢frame for assessing enviraniicntnl ioipact.
Camment and concern: The suggested timeframe Eor ldentifyIng adverse
environmental efEects in the Draft Scope is tvo short. P.e (para 3) of the Draft Scope
states that "the timeframe for the assessment will be the duration of operation of the
Pickering NGS-A facility foltowing the return to service". Yet, the same paragraph
goes on to say that the "focus wlll be on identifying those direct and cumulati�•e
envlronmentai effects". Cumulative environmental effects are likely lo be
signifIcant wel! Geyond the operational lifespan of Pickering [VGS. The Peer Review
Team questions whether there can be a realistic consideration of cumulative efEects
when the tlmeframe is limited to the relatively short opzraltonal life of Pickering
NGS-A. By definition, cumulative eE[ects are long term and may well be evident
only nfter the opera8onal life of PIckering NGS-A is completed. The DraEt Scope also
states that the EA must (nclude the long term environmental effects of
decommissloning of both PIckering NGS-A and B, activitIes which are
unamblguously post-operation. It Is appropriate to note the relevant provincial
16
�.
. - . � �y. .. . . . - .
18� .
environmental guidellnea bn the eiUng of landfllls, where the concept of .
'contaminating lifeapan' Is npplied, and wl�lch extends for hundreds of years after
the landfill has closed its operations (Ontario Mlnlstry oF Energy and Environment).
t• �����•��. �� : • s
10. AECB ehould ensure titat current eslimates of tlie operatIonal and.
contaminating 1Sfespans of PNGS are identified In lhe Final Scope and employ
'contaminating lifespan' as the timeframe fur assessing cumulative and adverse
environmental effects.
j��; Assessnreut of poteutra! uwiroiaucatal cjjccts (p. 8)
Comment and concern: This section states that the GA must systematically evaluate
how the project ts likely to cause changes in tlle envlronment and how such
changes coWd affect "the identified VECs, liealth, and socio-economIc condltlons.... "
PotentIal impacls on publlc health are the most signiticant environmental effects of
the project and are the subject of intense publlc concern. However, there ls no
directlon g[ven 3n the Draft Scope document as to how public health Issues should
be addressed. Tite Pcer Review Tcnui lins nofed oHier inadequncies wiq� rcgard !o
the DrnJt Scope docuruen!'s trea�nicnt oj !he issue o/ public IienitH (see a6oue, p. 13).
Public comments by OPG (Pickering News Advertiser, Nov. 24th) indicate that "in
evatuating the ef[ect of the Plckering Nuclear 5tatlon on human health, the
environmental assessment on the facillty wlll be iltnited to showing its emisstons
do not exceed those permitted under law". This stalement demonstrates that OPG's
17
;
183
lnterpretation of thc contents of the Drnft Scope document Is rather different from
that of the Peet Review Team. The Draft 5cope document idenUfIes (p. 8) the
requlrement of OPG to consider "how changes to the envlronment" (arising from
the project) " could af(ect ,,,. health".... The Peer Revlew Team interpret this to
mean that specIflc health studies pertaiiung to tlie exlsting health envlronment and
the potendal tmpacts of the proJect are to be assessed by OPG.
Recommendation to AECB
11. The AECB ahould ensure that the Flnal Scope explicilly recognises and
adequately addreasea the Issue of public heallli impacts w•ithin the environmental
asseasmen�
ISSUE: PuGlic and teclmicnl issi�c innnngciucnt (p.11)
Ttils aspect of the Dra(t Scope Is particularty confusing and requfres clariflcation. As
part of the EA, OPG are requested to ldenttfy how lhe 1G0+ public and technical
issues arIsing from the Pickering Gnvlronmental RevIew of 1998 will be addressed.
In July 1999, OPG committed to address encl� issue !n the EA process, a commltment
re�mphasised ln November 1999 as part of the Draft Repoct'C�rigin, Understanding
and Disposition of 160+ issues' (OPG, 3rd November, p.2),
DespIte the apparent conflrmation of intent by OPG to address all issues, the Draft
Scope allows OPG to classify each lssue "as to whether it ls withln the scope of this
assessment or not" (line 4, lst para). Issues that OPG consider to t�e outside the scope
of the EA can be deferred and listed in an Annex to the GA Report. Moreover, of the
issues that are considered by OPG to be within the scope of the EA, deferred
18
�
{1 ����
i
` 184 ' �!
resolution Is atlll posslble (2nd para, Ilne 5). Tlils contradiction between what OPG
has stated publlcally and what ls to be actually followed tn practice Is hardly wittiln
the spirit of the commitment to address nl! issues witliln the present EA. The
existing pollcy of AECB allows OPG too much flexIblllty in their Interpretation of
how to deal with the 160 + Issues.
Recommendation to AEC'rt
12. AECB should ensure that the Flnal Scupe states expliciUy that OPG is commllted
to address all outstanding technical issues arising froui tlie Ptckering
Environmental RevIew of 1998 in tlie enviroiimental assessment.
ISSUE: Process and ecliedule for the Plckering NGS-A Environmental Assesament
(p.15)
The most unacceptable aspect of the Dra(t Scope document is the tlmetable allowed
by AECB for the EA Process. In the opInion of the Peer Review Team, it is fnr too
siiort !o allow the t6oroirgh nnd enlimiccd revieTU llmt /ins Gcen proniised by OPC.
The AECD will receive public comments on tlie Draft Scope of Assessment in early
December 1999 and intend to complele tlieir revision of the Dra[t Scope in a single
week. Giaen the proGleuis wilh the docu�uent idenlified herein, it can 6e questioned
rulietber nn ndequntely-worded Final Scope ceut be produced in such n short lime.
Once the Final Scope document has been released by AGC[i, OPG and its consultants
have six weeks (which indudes the Christmas break) to consider the contents of the
FInal Scope and the publIc comments they have recelved and to then produce a
19
r;;
r —
185
Draft Screening Report to AECD by late January 1999. Thls wlll summarise the
resulta'of the;entlre Bnvlronmental AasessmenL Tbe Peer Revtew Tea�n conaider
lhfs ar� inadequnte tirneJrnr»e for a t6orough aud acie�ttt�cally-credt6le study.
Many key studies, designed to fill substantial data gaps identified in the
&nvironmental Review of 1998, are still being pianned or conducted and results wlli
not be ready untll nfter the EA Report has been completed. This creates the
perception that AECD is rusliing N�e enlire process to sntisjy the sliort-ternt business
needs oj OPG and underntines pu6lic confidence aad the scienti�c credi6llity of Nre
assessment.
It is disturbing to the Peer Review Teaui to learn�rom tlie n�edia that OPG and its
consultants feel that the majority of wurk has already been done on U�e EA and that
it ls not necessary to wAlt for the AECB io finali-..; ;•w scupe (Pick�ring News
Adverttser, October 24th,1999. p. 7). This stalement appears to suggest that OPG and
its consultants. do not feel obliged to be bound or guided by the contents of the Final
Scope document. ThIs demeans the role of lhe public and stakeholders as real
parHcipants in the process, by suggesting that comnlents received during the public _
consuladon process are not regarded as significant.
It is the opinIon of the Peer Review Tcam tliat tlie present timeframe does not
permit OPG and Its consultants to complete a tliorough GnvIronmental Assessment.
Recommendation to AECB .
13. The AECB stiould ensure that a realistic timetrame be established for the
envfronmental assessment to allow comptetion of a credibie publte consultatton
process, and assessment of acientific dala from sludies already underway or pianned.
20
:r.. '. _
186
Liat of Recommendatlons to ASCR
1. AfiCB should ensure that the F3na1 Scope Is clearly wrltten, systematically
structured and that each specIflc requ3rement ls carefully [dentified and numbered.
2. That AECB recognise the level of publle concern, the wide scope oE outstandfng
environmental lssues and significant data gaps and raIse the assessment from a
screening level to comprehensive.
3. AECB should ensure that the Final Scope document [ncludes all relevant
definitions. A glossary of terms and a listing of acronyms should be attached.
4. AECB should ensure that the Pinat Scope document contains an expliclt
statement recognising that the scope of the enviroiunental assessment include
envIrontnental lmpacts arlsing from the entire Picker3ng Nuclear Generattng
Statlon operation.
5. AECB should ensure that any Issue(s) appertalnSng to ldentification of currently
exlstIng'basellne environmentat conditions' in the Pinai Scope explicidy recognise
the nature of existing impacts.
6. AECB should ensure that OPG provide the Town of Plckering with a
contpreltensive IIsting of all ongotng or vlunaer! projects that appertain to
measurement of 'environmental impact' along with the timetable for completion of
results and Interpretal(ons.
7. AEC[3 should ensure that the Tinal Scope contai�u study areas that are
approprla±e to speciflc individual disciplines and not leave OPG nnd its consultants
to determine (ltmlt) the extent of their study.
8. AECB should ensure that coitslderatlon of cwnulative environmental effects is
considered for all study areas.
9. AECU should ensure that the term 'stakeholder' ls adequately defined (n the Final
5cope and that all relevant stakeholders are included within the envIronmental
assessment process.
10. AECB should ensure that current estimates of the operational and
contaminating lifespans of PNGS are identified in the Final Scope and employ
'contaminating llfespan' as the timeframe for assessing cumulative and adverse
environmental effects.
11. AECB should ensure that the Final Scope expiicItly recognises and addresses the
21
5.• ._ ' �# "��r,?� . , - .. �
g... t
187
_
lssue of publlc health Impacts:
12. AECB should ensure that the Flnal Scope states expllcitly that OPG Is committed
to address all outstanding technIcal issues arlsing from the P3ckering
' Bnvtronmental Review of 1998 in the environmental assessment.
13."AECB should ensure that a reallstic tlmefratne be established for the
environmental assessment to allow completion of a credible publlc consultallon
process, And assessment of scienttfic data from studies already underway or planned.
Peer Review Team members:
Dr. N. fiyles (Leader)
Dr. P. Chow-Fraser
Dr. S. 8lliott
Dr. C.H. Eyles
Dr. J. Harvey
Dr. K.W.F. Howard
Dr. W. Morrfs
25th November 1999
22
�,
FT
. r �Y �',�� i• .
i r
. . - .. - �.- . .
.;
. . . � � , . . -.:1' ' , .. '
. � i . . . ' �. :... ..
i
�: tAyc .WtiFr 5