Loading...
HomeMy WebLinkAboutCAO 06-03 Cilq o~ REPORT TO 145 COMMITTEE OF THE WHOLE Report Number: CAO 06-03 Date: July 14, 2003 From: Thomas J. Quinn Chief Administrative Officer Subject: Pickering Nuclear Waste Management Facility Expansion City of Pickering's Comments on Draft EA Study Report File: 0-5260-002 Recommendations 1. That Report CAO 06-03, regarding the OPG Draft Environmental Assessment Study for the expansion of the Pickering Nuclear Waste Management Facility be received. 2. That the draft submission prepared by IER Planning, Research and Management Services, and Scimus Inc., attached as Attachment No.2 to this Report, be accepted as the City's comments on the OPG Draft Environmental Assessment Study for the expansion of the Pickering Nuclear Waste Management Facility. 3. That a copy of this Report, including the draft submission of IER/Scimus be forwarded to the Canadian Nuclear Safety Commission, Ontario Power Generation, the Canadian Association of Nuclear Host Communities, and the Nuclear Waste Management Organization for information. Executive Summary: Ontario Power Generation (OPG) is planning to expand the Waste Management Facility at the Pickering Nuclear Generating Station, to allow nuclear waste fuel to continue being stored at PNGS up to the end of the planned 40-year service life of the station. The expansion requires an environmental assessment (EA) under the Canadian Environmental Assessment Act. To assist in monitoring the EA process and reviewing EA documents, the City commissioned a consulting team lead by IER Planning, Research and Management Services, and Scimus Inc. (hereafter collectively referred to as illER") to provide peer review services. This Report provides IER's draft peer review comments on the Draft EA Study Report prepared by OPG. Staff concurs with the findings and conclusions of IER, and recommends that Council accept and forward the IER submission with this report to the Canadian Nuclear Safety Commission (CNSC) as the City of Pickering's comments on the Draft EA Study Report. 146 Report CAO 06-03 Date: July 14, 2003 Subject: Pickering Nuclear Waste Management Facility Expansion - City of Pickering's Comments on Draft EA Study Reports Page 2 Financial Implications: None. OPG has agreed to cover the City's peer review costs. Background: Ontario Power Generation proposes to expand the existing Waste Management Facility at the Pickering Nuclear Generating Station (PNGS) to accommodate the storage of used fuel from PNGS-A and PNGS-B to the end of the planned 40-year service life of the station. The expansion requires an environmental assessment (EA) to be completed in compliance with the Canadian Environmental Assessment Act. Under the Act, CNSC is the "responsible authority" for preparing the EA. CNSC has determined that a screening level assessment is required, and has delegated the. preparation of a draft EA study report to OPG. The Draft EA Study Report, and comments received on the Report, will be used by CNSC as the basis for preparing the final EA Screening Report for submission to the Commission. The purpose of the EA is to determine whether the expansion of the Waste Management Facility at PNGS is likely to cause significant adverse environmental effects, taking into account appropriate mitigation measures. After analyzing various options, OPG proposes that two new storage buildings be located at the southeast corner of the property, in an area that is currently used for outdoor storage of equipment and materials. If approved to proceed, OPG would be in a position to initiate site preparation and construction of the first new storage building in 2005-2007, and the second building in the 2014-2016 time period. At present there are two existing Waste Management Facility storage buildings at PNGS. They began operation in 1996 and 2001, and together are designed to hold up to approximately 650 dry storage containers (DSCs). By the end of 2007, it is anticipated that the existing buildings will have approximately one-year of dry storage container space remaining. The two new buildings that are proposed in the expansion would each be able to hold 500 additional DSCs. Each DSC is designed to hold up to 384 waste fuel bundles. Accordingly, should the expansion be allowed to proceed, PNGS in total would be capable of holding approximately 1650 dry storage containers and over 633,000 bundles of nuclear waste fuel for up to the next 50 years, unless the Government of Canada decides on an acceptable alternative solution for storing nuclear waste fuel during this time period1. . 1 The Nuclear Waste Management Organization (NWMO) was created under the federal Nuclear Fuel Waste Act to provide recommendations (within three years) to the Government of Canada on the long-term management of used nuclear fuel. The Government of Canada will then decide on an approach, and this decision would be implemented by the NWMO, subject to all necessary regulatory approvals. Report CAO 06-03 Date: July 14, 2003 Subject: Pickering Nuclear Waste Management Facility Expansion - City of Pickering's Comments on Draft EA Study Reports 147 Page 3 To assist in monitoring the EA process, and reviewing EA documents, the City commissioned a peer review consulting team (lER). OPG has agreed to cover the consulting costs for this peer review service. Following receipt of the City/IER peer review comments, CNSC will tabulate all of the comments that it receives from submitters and then will forward them to OPG for their review and response. OPG will formally address each of the comments with explanations, additional information, and/or a commitment to alter the project, etc. The City will subsequently have an opportunity to reply, with the assistance of IER, to OPG's responses. The entire process is intended to result in the completion of a final report that will be submitted to a CNSC public hearing ili 2004. In late June, the Draft EA Study Report and thirteen Technical Support Documents were released by OPG and distributed by CNSC. Attached for information purposes, is the Executive Summary of the Draft EA Study Report (see Attachment No.1). The complete Draft EA Study Report and all of the Technical Support Documents are available for viewing through the CAO's Office. IER has reviewed the Draft EA Study Report and Technical Support Documents (TSD), and have provided comments to the City. They have a number of "significant findings" and "detailed minor comments" (see Attachment No.2). In general, the Review Team found the EA to provide adequate documentation to support most of the findings and conclusions presented. The environmental conditions of the study area are adequately described, with some exceptions that are more fully described in IER's submission. The assessment of the selected Valued Ecosystem Components (VECs) was carried out in a manner consistent with the Canadian Environmental Assessment Act and current environmental practice, although it is not clear whether the public was involved in the selection of VECs. Assuming that OPG clarifies the inconsistencies identified and provides important missing information, the Review Team agrees that there would be no significant residual adverse environmental effects of the PWMF II project at the preferred Site, Area B, taking into account the identified mitigation measures. Below, is a summary of IER's other significant findings: 1. In the Socio-Economic Impact Assessment, a significant percentage of respondents indicated that they might change their decision to live in the community as a result of the project. The assessment also notes that respondents have concerns about the Pickering Nuclear Generating Station as a whole. This is the second temporary storage solution at the Station, and permanent storage may be an option considered for the future. This point, while outside the limited scope of the EA analysis for PWMF II, is most relevant in terms of the concentration of 148 Report CAO 06-03 Date: July 14, 2003 Subject: Pickering Nuclear Waste Management Facility Expansion - City of Pickering's Comments on Draft EA Study Reports Page 4 nuclear facilities and associated wastes within the Region of Durham and City of Pickering and the potential cumulative impacts that can affect the community. It will be extremely important to monitor public attitudes to ensure that perceptions do not lead to changing behaviour patterns. 2. It is strongly recommended that the City of Pickering and the Region of Durham be directly involved in the design and implementation of the follow-up and monitoring program to verify the accuracy of the EA study predictions. 3. Regarding the existing Geology, Hydrogeology and Seismicity environment, there were several omissions and inconsistencies in the groundwater monitoring data described in Appendix B of the TSD. In some cases the interpretation of results was questionable. These issues should be addressed in the revised EA Study Report, especially due to the presence of a closed landfill site located up-gradient of the proposed siting area. 4. The evaluation and selection of the project location was transparent and traceable but it could have been improved using a numerical ranking scheme. Also, complete and detailed information is not provided on public consultation activities associated with the selection of the project location. 5. During peak hours, existing traffic conditions at various intersections on Brock Road leading into the PWMF II siting area are described as unacceptable according to level of service standards. The Review Team is concerned that additional traffic generated by PWMF II construction activities will exacerbate existing traffic problems. 6. In some cases the Main EA document differs from the Technical Study Document (TSD) supporting the Main EA. These differences should be explained in the form of an appendix to the Main EA Report. 7. There are several instances where the objectives of the community and stakeholder consultations and communication program (CSCCP) do not appear to be fully satisfied, e.g., the Appendices in both the Draft EA Study Report and TSD had frequent omissions, incorrect references, hidden references and/or photocopying errors. Other areas of concern are presented in the main body of the peer review. 8. The description of the existing atmospheric environment is based on ambient air monitoring stations located some distance from the PWMF II facility. The follow-up and monitoring program should confirm that the baseline data is accurate. 9. The description of the existing terrestrial environment did not properly inventory breeding amphibians during dry periods nor did it provide sufficient data on the marsh wren. Report CAO 06-03 Date: July 14, 2003 149 Subject: Pickering Nuclear Waste Management Facility Expansion - City of Pickering's Comments on Draft EA Study Reports Page 5 10. With regard to the description and assessment of credible malfunction and accident scenarios, there are inconsistencies in the assumptions used to describe the bounding accident, and the dose calculation methodology appears to be based on PWMF I conditions (Phase II site location is considerably closer to the property boundary than the Phase I site location). 11. The cumulative effects assessment predicted that the effects on VECs do not possess a cumulative effects trigger. While the conclusions seem reasonable it will be extremely important to revisit these predicted effects during the follow-up and monitoring program, especially in light of the pending international airport located some 12 km. to the North of PWMF II and slated to open within ten years. 12. The Review Team recommends that several additional elements be incorporated into the follow-up and monitoring program. Staff concur with the IER's findings and conclusions, and recommend that Council accept the IER submission and forward it with this Report to CNSC as the City of Pickering's comments on the Draft EA Study Report. It is also recommended that a copy of this report, including the IER submission be forwarded to OPG, the Canadian Association of Nuclear Host Communities, and the Nuclear Waste Management Organization for information. Attachments: 1. 2. Draft EA Study Report Executive Summary (prepared by OPG) IER Draft Review of OPG Draft EA Study Report (submission to the City dated July 2003) Prepared By: Approved / Endorsed By: 2,/ " / /'.'I¡/ --- A.L. (Joe) Himwicks / Emergency Respons¡féoordinator /1 / ---I ~ Th mas J. Quinn Chief Administrative Officer rfVfl~ Thomas E. Melymuk Division Head, Corporate Projects & Policy Report CAO 06-03 150 Date: July 14, 2003 Subject: Pickering Nuclear Waste Management Facility Expansion - City of Pickering's Comments on Draft EA Study Reports Page 6 T JQ:tem:alh:kr Attachments Copy: Division Head, Corporate Projects & Policy Recommended for the consideration of Pickering City Council ATTACHMENT# \ TO REPORT#QhQ' cl9- c¿ \J~\ c~ \. 151 Ontario Power Generation Inc. Draft EA Study Report Pickering Waste Management Facility Phase II Environmental Assessment EXECUTIVESU~RY 1.0 INTRODUCTION Ontario Power Generation Inc. (OPG) proposes to expand capacity of the existing Pickering Waste Management Facility Phase I (PWMF I) for additional interim storage of used fuel at the Pickering Nuclear (PN) site in southern Ontario. The PN property is located in the City of Pickering in the Regional Municipality of Durham on the northern shore of Lake Ontario, 32 km east of downtown Toronto and 21 km south-west of the City of Oshawa. There is insufficient space immediately adjacent to PWMF I to accommodate the required expansion. In addition, construction of the expansion adjacent to PWMF I would interfere with the operation and maintenance of the PN reactors. Therefore, OPG is proposing to construct and operate Pickering Waste Management Facility Phase II (PWMF II) at a separate nearby location within the PN site to provide the required additional storage capacity. The proposed expansion will not alter the basic purpose or function of the existing PWMF 1. The expanded facilities, will use the same storage technology as is currently in use in the existing, licensed PWMF I. OPG's plan from the outset was to develop the PWMF in two phases as the used fuel volumes at PN increased. The proposed Phase II project is the expansion of the used fuel dry storage component of the existing PWMF I to accommodate used fuel from Pickering Nuclear Generating Station A (PNGS-A) and PNGS-B to the end of their planned 40 year service lives. Decommissioning of PW.MF II is anticipated once all the used fuel has been transferred to a long-term waste management facility. The Canadian Nuclear Safety Commission (CNSC) is the federal authority responsible for the regulation of nuclear facilities in Canada. The siting, construction and operation of the facility would be authorized by the CNSC under subsection 24(2) of the Nuclear Safety and Control Act (NSCA). Licensing approval from the CNSC invokes a federal Environmental Assessment (EA) pursuant to Section 5(1) (d) of the Canadian Environmental Assessment Act (CEAA). The CNSC has determined that a screening level assessment is required for the proposed project. As the licensing body, the CNSC is the Responsible Authority (RA) under the CEAA for the purpose of this assessment. The CNSC has delegated the preparation of an EA Study Report to OPG. Once accepted, this report will be used by the CNSC as a basis for the preparation of the required Screening Report. The EAStudy Report is organized into 14 chapters. The highlights of Chapters 2 to 12 are provided in the following sections of this Executive Summary. Chapter 1.0 is an Introduction to the project, Chapter 13 is References and Chapter 14 is Abbreviations and Acronyms. ES-I June, 2003 152 ATTÂCHMENT# \ TO REPORT#~' ()lo-C>3 Pickering Waste Management Facility Phase II Qc (;) C\, .~ OntarioPower Generation Inc. Environmental Assessment. . ~ .. Draft EA Study Report 2.0 DESCRIPTION OF THE PROPOSED PROJECT This chapter provides an overview of used fuel dry storage at PN, project location, description of components of the proposed facility, the proposed works and activities, project schedule, waste management at the facility, a description of OPG's environmental, safety and monitoring programs, and a description of a conceptual decommissioning plan. Used Fuel Dry Storage Phases I and II The existing PWMF I Storage Buildings (1 and 2) together will hold up to 650 DSCs. The proposed PWMF II will have two identical Storage Buildings (3 and 4) each designed to .contain up to 500 DSCs for a total of 1000 DSCs. Site Location of Phase II A Site Options Study identified and analyzed the various options for locating the PWMF II within the PN property. The criteria used were potential impacts on present and future land use, impacts on operations and maintenance, traffic and material flows, health and safety, and security. The preferred siting option was a 13 ha PWMF II Siting Area located in the East Complex of the PN site on lands primarily used for outside storage, material lay down and parking, and adjacent to a small wetland and PN landfill areas. Components of Facility The DSC design used in PWMF I will continue to be used. It is a free standing reinforced concrete container, with an inner steel liner and an outer steel shell. It is made of two sub-assemblies, a lid and a base with provision for installing safeguard seals. The DSC has been designed to provide a storage life that will meet all shielding and containment integrity requirements over a minimum 50 year service life. The Storage Buildings will be single storey, commercial-type, pre-engineered or pre-cast concrete structures with a concrete slab-on-grade floor. The Storage Buildings will meet the requirements of the National Fire Code of Canada and the National Building Code of Canada. As a Class IB Nuclear Facility, the PWMF II will be provided with appropriate security and alarm systems to comply with CNSC security requirements. It will be located within a designated "protected area", bounded by a perimeter fence. The specialized Transfer Vehicle already in use at PWMF I will continue to be used to transfer loaded DSCs (weighing approximately 70 Mg) between PWMF I and PWMF II. The design speed of the vehicle is 4 krn/hr. Transfer routes and timeframes have been identified between PWMF I and PWMF II along with appropriate safety and security. Proposed Works and Activities The activities associated with the Site Preparation and Construction Phase are: ES-2 June, 20m ATTACHMENìT #~:!"OREPORT#QJ\O ciP.O'6 Pickering Waste Management Facility Phase II ~'~ C':>\ "1 Ontario Power Genemhon Inc. Environmental Assessment .. Draft EA Study Report . site clearing; . excavation; . site grading and compaction; . construction of foundation and inactive drainage system; . site service hook-ups; . construction of the storage buildings; . site paving and landscaping; . road construction and/or upgrading; and . installation of perimeter fence and security system. 153 The activities associated with the Operation Phase are: . Transferring loaded, seal-welded DSCs from the existing Processing Workshop or the PWMF I Storage Buildings to the new PWMF II Storage Buildings; . Operating and maintäining the PWMF II Storage Buildings; . Routine security and International Atomic Energy Agency (IAEA) inspections. Project Schedule Subject to EA approval from the CNSC, the proposed schedule for implementing the PWMF II Project is as follows: . Initiation of detailed design - Fall of 2004. . Site preparation and construction of Storage Building 3 - 2005 to 2007. . Operation of Storage Building 3 - 2007. . Construction of Storage Building 4 - 2014. . Operation of Storage Building 4 - 2016. 3.0 ASSESSMENT METHODOLOGY The assessment methodology follows the general requirements of CEAA and is reflected in each chapter of the report. This methodology requires that the project works and activities be considered to determine how each one may interface with, and affect, the environment. This is done by establishing temporal and spatial boundaries relevant to the project, identifying applicable environmental components (biophysical, cultural and social), and selecting the valued components (VCs) that represent important features of the environment as a focus of the EA study. The spatial boundaries include a Regional Study Area - the 10 km emergency planning zone (centered on the PN property), as identified by Emergency Management Ontario; a Local Study Area - areas within the municipal boundaries of the City of Pickering and the Town of Ajax south of Highway 401; and a Site Study Area - the PWMF II Siting Area and the area encompassed by the associated transfer routes. ESc3 June, 2003 ATTACHMENT # \ TO REPORT # ~o D.~- OS Pickering Waste Management Facility Phase II %4 aS~^ \, ,Ontario Power Generation Inc. 15 4 Environmental Assessment .. Draft EA Study Report 4.0 COMMUNITY AND STAKEHOLDER CONSULTATION AND COMMUNICATION The Community and Stakeholder Consultation and Communication Program (CSCCP) involved a series of coordinated activities and events throughout the EA study. Highlights included three EA Newsletters, Project Information Packages, three rounds of Open Houses each held in Pickering, Ajax, Scarborough East, and. Whitby, mailings of invitation cards and comment cards, three presentations to the Pickering Nuclear Community Advisory Council, toll-free information line, a website, and project information repositories The communication process with Aboriginal groups (six First Nations and Métis Nation) was undertaken through consultation with the appropriate contact persons and councils. All issues raised by stakeholders were recorded in a Stakeholder Comment Database and addressed either through the CSCCP and/or in the EA Study Report. 5.0 DESCRIPTION OF EXISTING ENVIRONMENT The Site Study Area is an industrial area containing a mix of uses including warehouses, machine shops, hazardous materials storage building, parking areas, material storage, access roads and drainage ditches. No soil contamination was found in the Siting Area; therefore, soil quality is considered acceptable for an industrial site. No watercourses traverse the Site Study Area and all but two of ten site catchments drain directly into Lake Ontario. In general, drainage is a mix of ephemeral swales, ditches, culverts and storm sewers containing minimal vegetation cover and wildlife habitat. The quality of stormwater was found to be generally consistent with that of typical urban runoff. The direction of groundwater flow beneath the Siting Area is towards the Lake Ontario shoreline; groundwater quality was measured to be within appropriate guidelines. The analysis of baseline conditions in the Regional, Local and Site Study areas is documented in nine Technical Support Documents (TSDs) and summarized in the EA Study Report. The following YCs were identified from the analyses: . Radiation and Radioactivity - members of the public and workers; populations of non- human biota. . Atmospheric Environment - residents at Durhamdale House (the closest residence). . Aquatic Environment - benthic invertebrates, emerald shiner and white sucker in Lake Ontario. . . Terrestrial Environment - red-winged blackbird, grey catbird, woodchuck, northern leopard frog, chokecherry, narrow-leaved cattail, and sandbar willow. . Socio-economic Conditions - population, business activity and tourism, housing and property values, recreational and community features, municipal finance, community character, use and enjoyment of property. ES-4 June, 2003 ATTACHMENT # \. TO REPORT #~ C')(y ~ CY3 155 Pickering Waste Management Facility Phase II v~ '5 c..,\' ~ Ontario Power Generation Inc. Environmental Assessment Draft EA Study Report . Physical and Cultural Heritage Resources - aboriginal structural remains, subsurface features and artefacts; historic architecture, structural remains, artefacts; agricultural landscapes. . Aboriginal Interests - employment and business opportunities, community character, hunting and fishing for subsistence. and economic purposes; archaeological resources, ceremonial sites, burial mounds or petroglyphs. No VCs were identified for Geology and Hydrogeology, and Land Use and Resources. 6.0 EVALUA TION AND SELECTION OF PROJECT LOCATION Using a conceptual facility layout to determine the area needed for the approximate footprint of the PWMFII, three alternative Site Areas were identified within the Siting Area (A-West; B-Centra1; C-East). The Site Areas were evaluated using factors such as shielding requirements, foundation conditions, building removal, stormwater drainage, construction disruptions, interaction with PN operations, and security considerations. Based on the technical evaluation, all of the Siting Area was found to be acceptable. However, Site Area B and its associated transfer routes was selected as the preferred site and was the. location most preferred by the public. 7.0 ASSESSMENT OF LIKELY ENVIRONMENTAL EFFECTS AND MITIGATION No potential effects on VCs from project works and activities were identified except for those related to radiation and radioactivity, land use, and socia-economic conditions. The evaluation for radioactivity indicated that the additional radiation dose from PWMF II to members of the public living, working or undertaking recreational activities outside the PN property boundary is expected to be a very small fraction of the dose from background radiation. As such, it will be indistinguishable from the temporal and spatial variations in radiation levels. Also, the estimated doses to workers during normal operations of PWMF II were determined to be within appropriate guidelines and regulatory limits. Public concern was raised with respect to views of the proposed facility from theW aterfront Trail which passes by the eastern boundary of the PN property. With .the proposed construction of a natural berm and/or planting of a mature tree screen, the visibility of the facility will be minimized, resulting in improved natural character of views overall. A net positive effect for the City of Pickering will result from the project as a consequence of increased tax revenue generated by the presence of new buildings on the PN property. An additional net benefit will result from the implementation of. the proposed Stormwater Management Concept which will improve the. existing wetland habitat and increase biodiversity in the area immediately east of the PWMF II. Also assessed were likely effects of the environment on the project, and likely effects of the project on sustainable use of renewable and non-renewable resources. No adverse environmental effects were identified. ES-5 June, 2003 156 ATTAcHMENT# \ TO REPORT#~ d19,c"3, Pickering Waste Management Facility Phase II 9~ ls; 0\ ~ Ontario Power Generation Inc. Environmental Assessment . Draft EA Study Report 8.0 DESCRIPTION AND ASSESSMENT OF CREDIBLE MALFUNCTIONS AND ACCIDENT SCENARIOS Credible malfunctions and accidents, both non-radiological and radiological, were screened for likely effects during construction, on-site transfer of DSCs and DSC storage operations. The screening identified a single "bounding event" for evaluation: on-site traffic accident involving a Transfer Vehicle. Radiation doses to workers, the public and non-human biota from suchan accident are expected to be below acceptable levels. 9.0 ASSESSMENT OF CUMULATIVE ENVIRONMENTAL EFFECTS There were no likely adverse residual effects identified for the PWMF II Project. However, in response to comments received from the public, the cumulative effects assessment was broadened in scope to include the cumulative effects of radiation and radioactivity; that is,. the effects of radiation dose on three VCs - members of the public, workers and non-human biota. Twelve other projects on and. around the PN property were analyzed for possible cumulative environmental effects on the VCs. The estimated cumulative doses to the most exposed members of the public; to workers and to non-human biota, are expected to be well below acceptable levels. 10.0 PROPOSED MITIGATION AND PLAN FOR FOLLOW~UP AND MONITORING PROGRAM Mitigation measures were used in two ways on the PWMF II Project to minimize potential adverse environmental effects: . Mitigation measures which are part of the basic project design. These "in-design" mitigation measures were assumed at the outset of the EA study and were identified in the various assumptions made in the assessment of the Project Warks and Activities. They include such measures as radiation shielding for the Storage Buildings, and the development of a Starmwater Management Plan for PWMF II. . Additional feasible mitigation measures identified during the EA study. These include modifications to the Stormwater Management Plan for PWMF II to enhance the East Wetland, and the visual screening of the facility from viewpoints along the Waterfront Trail through berms and planting of mature trees. A preliminary follow-up and monitoring program was defined to verify the accuracy of the EA study predictions, and to confirm whether the proposed mitigation measures are effective. Some of the monitoring activities will be part of normal existing monitoring programs for PN and PWMF I; others are specifically developed for PWMF II. The latter activities will be incorporated into PN'sINWMD's overall environmental management system. Details of the program will be developed in response to the CNSC's direction and in consultation with other stakeholders as appropriate. ' ES-6 June, 2003 ATTACHMENT #\ TO REPORT # £l~() D (p- 0'3> Pickering Waste Management Facility Phase II %"\ a~' ~ OntariDOrPaOrtWEerAGSetnuedraytiRoenplont15 7 Environmental Assessment - - ~ 11.0 SIGNIFICANCE OF RESIDUAL"ENVIRONMENTAL EFFECTS There are no residual adverse effects that were required to be advanced for .consideration of significance. However, the scope of the chapter was expanded to include a summary of human health and safety considerations. The World Health Organization's definition of health as "a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity" was used in the overall approach to assessment of human health and safety in this EA study. No adverse effects on human health from non-radioactive emissions are expected. No effects on the safety of workers and the local public, or on the general well-being of the public are anticipated. Radiation doses from PWMF IT are estimated to be indistinguishable from background and should not result. in health effects on members of the public, workers and non- human biota. 12.0 CONCLUSIONS OF THE ASSESSMENT The results of the assessment identified no significant residual adverse environmental effects of the PWMF IT project, assuming the PWMF II is located within Site Area B, taking into consideration the identified feasible mitigation measures. Site Area B was selected for environmental and engineering reasons. and was.preferred by the public. The three alternative Site Areas (A, B and C) are located in close proximity to one another in highly modified industrial lands with minimal natural habitat. Accordingly, the site selection process identified only minor environmental and technical differences among the three Site Areas. Therefore, all would be acceptable to accommodate PWMF II with the application of different levels of mitigation measures. The final project design is not expected to be very different from the conceptual design used in the EA study. Minor differences in design that may be required are not expected to result in any significant adverse effects on the environment. OPG recommends that the CNSC accept the conclusions as the basis for the preparation of its Screening Report under the Canadian Environmental Assessment Act. ES-7 June, 20m 158 ATTACHMENT # Q) TO REPORT# CÀo- otc.- ~~~ % \a~ ~ß Draft Review of Ontario Power Generation Draft Environmental Assessment Study Report For the Pickering Waste Management Facility II Project Conducted by IER - Planning, Research and Management Services and Scimus Inc. In association with North-South Environmenta/lnc. 7501 Kee/e Street, Suite 300 Concord, Ontario L4K 1 Y2 July 2003 ATTACHMENT #~TO REPORT # ~-cto- a ~ Review By IER of Ontario Power Generation \:h. Q Ç'::"\<eL Draft Environmental Assessment Study Report . ~ c::" C:YC.::/ Pickering Waste Management Facility Phase II July 2003 15 9 EXECUTIVE SUMMARY IER and SCIMUS Inc., in association with North-South Environmental, were retained by the City of Pickering to undertake a peer review of the Draft Environmental Assessment (EA) of the Proposed Pickering (Nuclear) Waste Management Facility II Project. In general the Review Team found the EA to provide adequate documentation to support most of the findings and conclusions presented. The environmental conditions of the study area are adequately described with some exceptions which are more fully described in this peer review. The assessment of the selected Valued Ecosystem Components (VECs) was carried out in a manner consistent with the Canadian Environmental Assessment Act and current environmental practice although it is not clear whether the public was involved in the selection ofVECs. Assuming that the proponent clarifies the inconsistencies identified and provides important missing infonnation, the Review Team agrees that there would be no significant residual adverse environmental effects of the PWMF II project at the preferred Site Area B taking into account the identified mitigation measures. Our key findings are as follows. 1. In the Socio-Economic Impact Assessment, a significant percentage of respondents indicated that they might change their decision to live in the community as a result of the project. The assessment also notes that respondents have concerns about the Pickering Nuclear Generating Station as a whole. This is the second temporary storage solution at the Station, and pennanent storage may be an option considered for the future. This point, while outside the limited scope of the EA analysis for PWMF II, is most relevant in tenns of the concentration of nuclear facilities and associated wastes within the Region of Durham and City of Pickering and the potential cumulative impacts that can affect the community. It will be extremely important to monitor public attitudes to ensure that perceptions do not lead to changing behaviour patterns. 2. It is strongly recommended that the City of Pickering and the Region of Durham be directly involved in the design and implementation of the follow-up and monitoring program to verify the accuracy of the EA study predictions. 3. Regarding the existing Geology, Hydrogeology and Seismicity environment, there were several omissions and inconsistencies in the groundwater monitoring data described in Appendix B of the Technical Study Document (TSD). In some cases the interpretation of results was questionable. These issues should be addressed in the revised EA Study Report, especially due to the presence of a closed landfill site located up-gradient ofthe proposed siting area. 4. The evaluation and selection of the project location was transparent and traceable but it could have been improved using a numerical ranking scheme. Also, complete and detailed infonnation is not provided on public consultation activities associated with the selection of the project location. IER & SCIMUS Inc. in association with North-South Environmental i 160 12. ATTACHMENT # c9 TO REPORT #~ -C:k~:s Review By IER of Ontario Power Generation Q S \' Q.. Draft Environmental Assessment Study Report ~ C> &~:> Pickering Waste Management Facility Phase II July 2003 5. During peak hours, existing traffic conditions at various intersections on Brock Road leading into the PWMF II siting area are described as unacceptable according to level of service standards. The Review Team is concerned that additional traffic generated by PWMF II construction activities will exacerbate existing traffic problems. 6. In some cases the Main EA document differs from the Technical Study Document (TSD) supporting the Main EA. These differences should be explained in the form of an appendix to the Main EA Report. 7. There are several instances where the objectives of the community and stakeholder consultations and communication program (CSCCP) do not appear to be fully satisfied, e.g., the Appendices in both the Draft EA and TSD had frequent omissions, incorrect references, hidden references and/or photocopying errors. Other areas of concern are presented in the main body of the peer review. 8. The description of the existing atmospheric environment is based on ambient air monitoring stations located some distance from the PWMF II facility. The follow-up and monitoring program should confirm that the baseline data is accurate. 9. The description of the existing terrestrial environment did not properly inventory breeding amphibians during dry periods nor did it provide sufficient data on the marsh wren. 10. With regard to the description and assessment of credible malfunction and accident scenarios, there are inconsistencies in the assumptions used to describe the bounding accident and the dose calculation methodology appears to be based on PWMF I conditions (Phase II site location is considerably closer to the property boundary than the Phase I site location). 11. The cumulative effects assessment predicted that the effects on VECs do not possess a cumulative effects trigger. While the conclusions seem reasonable it will be extremely important to revisit these predicted effects during the follow-up and monitoring program, especially in light ofthe pending international airport located some 12 kID. to the North of PWMF II and slated to open within ten years. The Review Team recommends that several additional elements be incorporated into the follow-up and monitoring program. IER & SCIMUS Inc. in association with North-South Environmental ii ATTACHMENT #~ TO REPORT #~O,ek,- ~~ % '-\ C>~ C)~ 161 TABLE OF CONTENT 1.0 EXECUTIVE SUMMAR Y... ...................... ........ ............................... ..... ..... ..... ....... ..... ............ ....... i INTR 0 D U CTI 0 N.. .......................... .......................... ............ ..... .......... ............... ......... 1 1.1 1.2 1.3 1.4 2.0 Purpose of the Review .................................................................................................. 1 Scope of the PWMF II Project..................................................................................... 1 Scope of Assessment...................................................................................................... 2 Scope of the Review ...................................................................................................... 3 SIGNIFICANT FINDINGS OF THE DRAFT ENVIRONMENTAL ASSESSMENT 2.1 STUD Y REPORT............ ................. ..................... ...... ..................... ..... ..... ..... ..... ......... .......... ....... 4 Execu tive Summary......................... .......................... ....... ..... .......... ......... .......... .......... 5 2.2 2.3 2.4 2.5 2.6 2.6.1 2.6.2 2.6.3 2.6.4 2.6.5 2.6.6 2.6.7 2.6.8 2.6.9 2.7 2.8 2.9 2.10 2.11 3.0 In trod u ction ............. .... .................... .......................... ....... ... ................. ........... ........ ...... 5 Description of the Proposed Project............................................................................ 5 Assessment Methodology.............................................................................................. 5 Community and Stakeholder Consultation and Communication ............................ 6 Description of the Existing Environment ................................................................... 7 Radiation and Radioactivity Environment..............................................................7 Atmospheric Environment....................................................................................... 7 Hydrology, Water Quality and Aquatic Environment............................................. 7 Terrestrial...........................................""""""""""""""""""""""""""".............. 8 Geology, Hydrogeology and Seismicity.... ....... ............................ ............. .............. 8 Land Use................................................................................................................. 9 Socio-Economic Conditions.................................................................................... 9 Physical and Cultural Heritage Resources........................................................... 10 Aboriginal Interests.............................................................................................. 10 Evaluation and Selection of Project Location .......................................................... 10 Assessment of Likely Environmental Effects and Mitigation................................. 11 Description and Assessment of Credible Malfunctions and Accident Scenarios.. 13 Assessment of Cumulative Environmental Effects .................................................. 13 Follow-up and Monitoring ............... ............ ............ ............ ..... ..... ..... ............. .......... 14 DETAILED MINOR COMMENTS................................................................................ 15 ATTACHMENT # ~ --- TO REPORT #e:.,~.dD- C~ Review By IER of Ontario Power Generation % ('\ Q 16 2 Draft Environmental Assessment Study Report c- -:S c>-\ ~U Pickering Waste Management Facility Phase II July 2003 1.0 INTRODUCTION 1.1 Purpose of the Review IER and SCIMUS Inc. in association with North-South Environmental (hereinafter collectively referred to as "IER"), were retained by the City of Pickering to undertake a peer review of the Environmental Assessment ofthe Proposed Pickering (Nuclear) Waste Management Facility II Project. The documentation included a Main Report (including five appendices), an Introductory Document to the Technical Support Documents (TSDs) and 12 separate TSDs. The City of Pickering intends to provide the Canadian Nuclear Safety Commission (CNSC) with written comments relating to the Environmental Assessment (EA) of the Proposed Pickering Waste Management Facility II (PWMF II) project. The City wants to ensure that the economic, financial, social, cultural and environmental interests of the municipality and its residents are satisfactorily protected. The peer review was conducted so that City staff can produce documentation for City Council to consider as part of its submission to CNSC. For this stage of the review, IER was required to perform the following activities: 1. Conduct a peer review of reports and studies prepared and submitted by Ontario Power Generation (OPG) and CNSC staff to the CNSC in fulfilling the requirements of the final Environmental Assessment Guidelines; 2. Provide technical comments and advice to municipal staff and Council to assist in understanding the content of technical reports; and 3. Attend a Y2 day workshop with City and OPG staff to review the project. The first two activities were completed and reported herein. The third activity was a workshop which took place Tuesday, May 27,2003. 1.2 Scope of the PWMF II Project The CNSC is the authority responsible for the regulation of nuclear facilities in Canada. The CNSC has determined pursuant to Section 5(1)(d) of the Canadian Environmental Assessment Act (CEAA) that a federal environmental assessment (EA) is required before it can provide OPG with an authorization to initiate the different on-site activities that comprise the PMWF II project. In May of 2003 the CNSC issued the "Final EA Guidelines (Scope of Project and Assessment) for the Environmental Assessment of the Proposed Pickering Waste Management Facility, Phase II, Pickering, Ontario." OPO has prepared an EA Study Report designed to meet the requirements of the EA Guidelines and to describe in detail the EA conducted for the proposed PWMF II project. IER & SCIMUS Inc. in association with North-South Environmental 1 Review By IER of Ontario Power Generation ATTACHM~~T #t: "l ~gRT #~,ctD-ö3 Draft Environmental Assessment Study Report <:::::' 16 Pickering Waste Management Facility Phase II. July 2003 3 In the EA Guidelines, the CNSC determined that the scope of the PWMF II project was as follows: The physical works involved in this project are the storage buildings to be built for the dry storage containers; all facilities, systems and activities required for the construction and operation ofPWMF Phase II; and the facilities, systems and activities involved in the transfer of loaded welded DSCs from PWMF I to the storage buildings in PWMF II. While decommissioning is not part of the project, a preliminary decommissioning plan for PWMF II will be included in the assessment. Associated operations and activities that are within the scope of the project include: . Preparation of the site and construction of the storage buildings 0 Site clearing, excavation, grading and compaction 0 Construction of foundation and inactive drainage system 0 Site service hook-ups 0 Construction ofthe storage buildings 0 Site paving and landscaping . Preparation of systems and facilities involved in the transfer of loaded welded DSCs 0 Road construction and/or upgrading 0 Transfer of loaded welded DSCs from the Processing Building or Storage Buildings in PWMF I to the Storage Buildings in PWMF II . Installation of perimeter fence and security system 0 Facilities and systems for maintaining security ofthe site . Operation and maintenance of the PWMF II 0 Radiation and security monitoring, inspection and maintenance 1.3 Scope of Assessment The scope of assessment identifies the factors to be considered in the EA. The scope of a screening assessment under the CEAA must include all the factors identified in paragraphs 16(1)(a) to (d) of the CEAA, and, as provided under paragraph 16(1)(e), any other matter that the CNSC requires to be considered. Paragraphs 16(1)(a) to (d) require the following factors be included in the screening: . "the environmental effects of the project, including the environmental effects of malfunctions or accidents, that may occur in connection with the project and any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out; . the significance of the effects identified above; . comments from the public that are received in accordance with the CEAA and its regulations; and IER & SCIMUS Inc. in association with North-South Environmental 2 ATTACHMENT #.¿t_TO REPORT #C~ .~ ct.o-~'3 Review By IER of Ontario Power Generation \::h."\ ~ é;;)ð. Draft Environmental Assessment Study Report "~ C) '0 164 Pickering Waste Management Facility Phase II July 2003 . measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the project." In accordance with sub-section 16(1)(e) of the CEAA, in the EA Guidelines the CNSC required that the following additional factors be included in the screening: . the purpose of the project; . various sites within the PWMF II siting area; . various waste transfer routes; . the need for, and requirements of, a follow-up program in respect of the project; and . the capacity of renewable resources that are likely to be significantly affected by the project to meet the needs of the present and those of the future. 1.4 Scope of the Review In response to the direction from the City of Pickering and to detennine whether the EA Study Report meets the CEAA requirements, the review team focused on the following: ~ ~ ~ ~ Compliance with the EA Guidelines Significant gaps in the infonnation contained in the documentation Methodology Results and Conclusions of the Assessment According to Section 1.4.1.2 of the Main EA Study Report, "the EA Study Report is based on a series of technical supporting documents which provide the detailed technical infonnation used in the EA study. Although the supporting documents are not part of the EA Study Report per se, they are referenced throughout the EA Study Report and contain useful supporting and background infonnation that may be of interest to a reader wishing more detailed infonnation on any ofthe technical components of the EA study. The TSDs were completed in Spring 2003. Completion ofthis EA Study Report required additions and/or revisions to some of the infonnation in the TSDs. Where there are differences between the TSDs and the EA Study Report, the latter should be regarded as being definitive. The TSDs comprise a series of 13 separate reports: one introductory document; one of each of the nine components of the environment that were defined and adopted for the EA study, plus one each for: malfunctions and accidents; cumulative effects; and community and stakeholder consultation and communication. The TSDs present the detailed results of the EA study, including the assessment of the environmental effects," As such, IER's review focused on the Draft EA Study Report and the findings presented in this report are based on that review. In some cases the relevant section of the TSD was referenced. The Draft EA Study Report is organized into two sets of comments. The first set of comments provides our significant findings in the same sequence as the Sections of the Main EA, i.e.: ~ Executive Summary IER & SCIMUS Inc. in association with North-South Environmental 3 ATTACHMENT # 6) TO REPORT #Qf'Qo(P-o:S Review ByIER oj Ontario Power Generation Q e:, ö~ &ð 165" Draft Environmental Assessment Study Report ~ _. Pickering Waste Management Facility Phase II July 2003 ~ Introduction - Section 1.0 ~ Description of the Proposed Project - Section 2.0 ~ Assessment Methodology - Section 3.0 ~ Community and Stakeholder Consultation and Communication - Section 4.0 ~ Description of the Existing Environment - Section 5.0 ~ Evaluation and Selection of Project Location - Section 6.0 ~ Assessment of Likely Environmental Effects and Mitigation - Section 7.0 ~ Description and Assessment of Credible Malfunctions and Accident Scenarios - Section 8.0 ~ Assessment ofCurnulative Effects - Section 9.0 ~ Proposed Mitigation and Plan for Follow-up and Monitoring Program - Section 10.0 ~ Significance of Residual Environmental Effects - Section 11.0 ~ Conclusions ofthe Assessment - Section 12.0 The second set provides further detailed comments. For each of the above sections of the Environmental Assessment, the environment is represented by the following components: ~ Radiation and Radioactivity ~ Atmospheric Environment ~ Hydrology, Water Quality and Aquatic Environment ~ Terrestrial Environment ~ Geology, Hydrogeology and Seismicity ~ Land Use and Resources ~ Socio-Economic Conditions ~ Physical and Cultural Heritage Resources ~ Aboriginal Interests While the Review Team concentrated its effort on the Main EA, a comprehensive review was also performed on the TSDs to ensure traceability. 2.0 SIGNIFICANT FINDINGS OF THE DRAFT ENVIRONMENTAL ASSESSMENT STUDY REPORT In general the Review Team found the EA to provide adequate documentation to support most of the findings and conclusions provided. The environmental conditions of the study area are adequately described and the assessment of the selected VECs was carried out in a manner consistent with the Canadian Environmental Assessment Act and current environmental assessment practice, although it is not clear whether the public was involved in the selection of VECs. Based on the information provided, the Review Team agrees that there are no significant IER & SCIMUS Inc. in association with North-South Environmental 4 ATTACHME~#~ TO R.EPORT #ÇAQ-ok,-o3 Review By IER of Ontario Power Generation ~ .::'\.0. 16 6 Draft Environmental Assessment Study Report C "J ~) Pickering Waste Management Facility Phase II July 2003 residual adverse environmental effects of the PWMF II project assuming the PWMF II is located within Site Area B, taking into consideration the identified mitigation measures. The comment provided is, however, subject to clarifications or provision of further information with respect to several areas within the Draft EA. In some cases information was missing or the interpretation of results was unclear. Our major observations are as follows. 2.1 Executive Summary As indicated in Section 2.11 "Follow-up and Monitoring Program", it is strongly recommended that the City of Pickering be involved in the design and implementation of the follow-up and monitoring program to verify the accuracy of the EA study predictions and to confirm whether the proposed mitigation measures are effective (ES-6, last paragraph). In the summary of "Significance of Residual Environmental Effects" (ES- 7, first paragraph), the report indicates that no adverse effects on human health from non-radioactive or radioactive emissions are expected. Human health includes mental and social well-being which are both linked to perception. This underscores the importance of sustained on-going monitoring to assure stakeholders of "no adverse effects". 2.2 Introduction In the first paragraph of Section 1.4.1.2 (pages 1-8), it is stated "where there are difference between the TSDs and the EA Study Report, the latter should be regarded as being definitive". This demonstrates a lack oftraceability. An Appendix explaining the differences and/or errata should be added to the Final EA report. 2.3 Description of the Proposed Project The level of detail and the scope of the description is acceptable. It is sufficient to allow proper consideration of issues related to potential impacts within the temporal boundaries. This section contained a clear discussion ofthe interface of this project with the long-term waste management program as part of the discussion of future decommissioning. The total capacity ofthe storage buildings is 1654 Dry Storage Containers (DSC' s), only 7% more than the total number ofDSC's expected. This does not appear to provide sufficient contingency against unforeseen problems (Section 2.2.1, page 2-1) 2.4 Assessment Methodology The Review Team found the assessment methodology to be acceptable and consistent with the requirements of the Canadian Environmental Assessment Act. IER & SCIMUS Inc. in association with North-South Environmental 5 ATTACHM~# cD TO REPORT #~ .ö{g-ö ~ Review By IER of Ontario Power Generation \ a 0;' ~ Draft Environmental Assessment Study Report r Pickering Waste Management Facility Phase II '- July 2003 167 2.5 Community and Stakeholder Consultation and Communication Key concerns raised by the public at the first and second Open Houses included: ~ Safety of interim storage of used fuel in their community; ~ The lack of a long-term solution for the disposal of nuclear fuel; and ~ Opposition to any long-term storage of used fuel on the PN site and a desire to participate in future discussions of the long-term options (P. 4-9, 3rd paragraph) This demonstrates the need for ongoing dialogue with affected stakeholders through an existing vehicle such as the Community Advisory Committee. The objectives of the CSCCP appear to have been met in general. There are some instances where it is not clear whether the objectives have been fully met; these are discussed below. The outreach area is broad and inclusion of known stakeholders from outside the area on the mailing list is appropriate. The types of stakeholders included in the project are clearly identified in the bulleted list on Page 4-3. However, the list of stakeholders in Appendix C is considerably smaller than that suggested by the list on Page 4-3. The distinction should be made between the stakeholder mailing list (which would have hundreds of contacts on it) and the list of key stakeholders to be contacted directly for scoping interviews - which appears to be what is represented in Appendix C. There was found to be incomplete information in the report. The Appendices in both the Draft EA Report and the TSD had frequent omissions, incorrect references, hidden references and/or photocopying errors. These are identified in Section 3 of this peer review. The omissions are the most important aspect, as the lack of specific information does not enable a full assessment of the details of information provided to the public and agencies and information received in response to be able to confirm OPG's consultation results. Specific instances of missing information are contained in Section 3. The decision to cancel the two EA workshops that had been planned in the Community and Stakeholder Consultation and Communication Plan appears to have been made without sufficient effort to determine if there was interest at the times that the workshops were to have taken place (rather than at any initial interviews). A workshop for municipal representatives, with a written invitation to other stakeholders at the time of the proposed workshop would have been a viable alternative to addressing an initial lack of interest in a later workshop. Secondly, the CAC should not have been used as a vehicle for providing workshop information to stakeholders, since it was identified as a stakeholder that would have provided periodic updates in any case. A more detailed discussion is included in Section 3. IER & SCIMUS Inc. in association with North-South Environmental 6 168 . . ATTACHMENT #~ TO REPORT~#<::>lo-CJS Review By IER of OntarIO Power Generation ~ '\ \' ",---0... Draft Environmental Assessment Study Report .~ \ a T '-..Yl.....:) Pickering Waste Management Facility Phase II July 2003 2.6 Description of the Existing Environment This Chapter of the EA describes existing environmental conditions and is based on the following nine Technical Support Documents: ~ Radiation and Radioactivity; ~ Atmospheric Environment; ~ Hydrology, Water Quality and Aquatic Environment; ~ Terrestrial Environment; ~ Geology and Hydrogeology; ~ Land Use and Resources; ~ Socio-Economic Conditions; ~ Physical and Cultural Heritage Resources; and ~ Aboriginal Interests. The Review Team's comments are based on the content of the Main EA Report but are supported, in some cases, by issues identified in the TSDs. While the intent of the Main EA Report was to be a stand-alone document, the TSDs are referred, where appropriate, to improve the traceability ofthe assessment process. 2.6.1 Radiation and Radioactivity Environment The existing radiation and radioactivity environment is adequately described. 2.6.2 Atmospheric Environment The Main EA concludes "However, for the purposes of the study, the air quality in the Site Study Area can be represented by the air quality in the Regional Study Area". Atmospheric monitoring is not conducted in the vicinity ofthe Siting Area and the results ofthe atmospheric environmental assessment rely on the closest ambient air monitoring stations located in Scarborough (almost 20 kID. SW) and Oshawa (20 kID. NE). Furthermore, as shown in Table 4.2.1.1-1 ofthe TSD (P. 9), there are no Total Suspended Particulate or Inhalable Particulate data identified East ofthe Siting Area. It is normal EA practice to describe existing atmospheric conditions using local monitors. Ifthese are lacking, as in the case of PWMF II, then temporary monitors would be established to confirm that Regional data are appropriate especially for a facility the size ofPNGS. At the very least, the future monitoring program should be capable of confirming the conclusions of the EA. Also, dustfall is missing from the list of air quality constituents considered. The EA report should explain why this parameter was not included. 2.6.3 Hydrology, Water Quality and Aquatic Environment Section 5.4.2 of the Main EA Report discusses varying levels of erosion on the Lake Ontario shoreline immediate south of the Siting Area and the TSD discusses the catchments where erosion occurs. The Review Team could not find any discussion of any remedial work which IER & SCIMUS Inc. in association with North-South Environmental 7 . . . ATTAcHM~T#~ TO REPORT#~-o~-a~ Review By IER of OntarIO Power GeneratIOn ' D~aft l!n vironm ental Assessment Study Report ~ \~ o~ ~ß 16 9 PICkering Waste Management Facility Phase II July 2003 would be undertaken for those catchments exhibiting erosion, especially those associated with stormwater discharges from PWMF II. 2.6.4 Terrestrial The existing Terrestrial environment is adequately described with the exception of improper inventories of breeding amphibians during a dry period and insufficient data on the marsh wren. Some details are described in Section 3. 2.6.5 Geology, Hydrogeology and Seismicity Under Section 5.6.4 of the Main EA Report and Section 4.2.2.3 of the TSD "PN East Complex Soil and Groundwater Quality", results of groundwater sampling and analysis are discussed based on the data presented in Appendix B of the TSD. The Review Team found several omissions and inconsistencies in the data in Appendix B and the interpretation of same, as follows: . Wherever silver was analyzed as part of groundwater monitoring the detention limit was always higher than the GUCSO Table B criteria. This should be explained in the Main EA. . The Main EA should explain why GUCSO Table B criteria were used instead of the conventional suite of groundwater parameters. . On P. 5-29 of the Main EA under the section entitled "Groundwater Quality", it is stated that groundwater quality within the site study area does not exceed GUCSO Table B criteria. Table B-2 of the TSD identifies two monitoring wells within the siting area which show exceedances of Vinyl Chloride, Lead and Mercury. This discrepancy should be explained, especially given the fact that the siting area is directly down gradient ofthe East Landfill using inferred direction of shallow groundwater flow shown in Figure 4.2.3-3 of the TSD. . The analysis of groundwater quality for Round 1 shown in Table B-2 ofthe TSD is missing PCB's and Phenols for all monitoring locations reported. This information is important due to the presence of PCB storage facilities and the up-gradient closed landfill sites. . Section 4.2.2.6 on P. 11 of the TSD indicates that soil and groundwater samples ITom monitors RGM-51 and RGM-52 were analyzed for PCB, PH, metals, TPH, VOCs, cresols and phenol compounds. Table B-2 of the TSD does not show metals, PCB, TPH, VOCs, cresols and phenols compounds in the analysis of groundwater quality. . The last full paragraph on P. 13 of the TSD indicates "Wells OPG - MW-3, OPG-MW-5, OPG-MW-6, OPG-MW-61 and OPG-MW-7 are located down gradient ofthe East Landfill and monitor groundwater conditions between it and Lake Ontario (Figure 4.2.5.2). The analytical results for samples collected from these wells confirm that the East Landfill does not have an effect on groundwater quality (Appendix B)". These results could not be found IER & SCIMUS Inc. in association with North-South Environmental 8 170 ATTACHMENT # c;) TO REPORT#otx:>~e:l9-aS Review By IER of Ontario Power Generation ~ f' ß Draft Environmental Assessment Study Report '6 \ ~ 6~ & Pickering Waste Management Facility Phase II July 2003 in Appendix B. The Review Team therefore cannot confinn the acceptability of groundwater quality in the Siting Area. . With respect to Section 4.2.3.5 "East Site Garage" groundwater analysis of samples ITom RGM-19 and RGM-19B was missing key parameters such as Benzene, Total Hydrocarbons and several other organics. The above concerns make it unclear whether there is presently soil and groundwater contamination ITom off-site influences such as the East Landfill, the Inert Fill Sites and other facilities. Since contaminants may be migrating from these sites in the groundwater system, which has been shown to flow predominantly in a southward direction under the Siting Area, it is important to have an adequate assessment of this potential impact throughout the duration of the project. This is identified as a need for follow-up and monitoring in Section 2.11. 2.6.6 Land Use Section 5.7.2.2 ofthe Main EA and Section 4.2.2.1 ofthe TSD do not indicate whether the Pickering Zone By-law M2- Industrial Zone includes the storage of spent nuclear fuel as a pennitted use. This should be clarified. The Main EA does not describe the existing traffic operations in the vicinity of PWMF II. This is described in the TSD (P. 25) and is judged to be significant because key intersections on Brock Road are currently operating at unacceptable levels of service. Also, Section 4.2.3 of the TSD states that "From a transportation perspective, the PMWF II site is readily accessible by existing roads". This statement is inconsistent with the levels of service described above. 2.6.7 Socio-Economic Conditions The negative perception of the Pickering nuclear facilities is not adequately described. The following observations can be made. . In Section 5.8.1, it is quite evident from the infonnation in the report that a substantial number of people (somewhere between 21 % or 27%) - think about the PNGS on a regular basis and how it affects their sense of health, safety and well-being. These are large segments of the community population who have at the least perception concerns about the existence of the full Pickering Operation. This comes to the fore during the EA public consultation for the waste facility. As an issue, it is extremely important to acknowledge this high percentage of concern and to take steps to address the perceptions. While the EA report and the Socio-Economic TSD acknowledge issues of perception and stigma, it is noted that these issues are not directly relevant to the socio-economic impact analysis based on the existing legislation. While this is technically correct, it is important to recognize these issues of concern as they can and do lead to people potentially changing behaviour patterns as a direct result of a project or proposal. It appears to us that the limiting definition of social impacts in the tenus of reference and in the CEA Act does not lead to full consideration of what is a substantial social concern. IER & SCIMUS Inc. in association with North-South Environmental 9 . . . t\nl\CHMEN~c9 TO AEPORT#CÞc-O<O-a~ Revlew By IER of OntarIO Power GeneratIOn \ b\" a-I 71 Draft Environmental Assessment Study Report ,......" 0 ~ ~G Pickering Waste Management Facility Phase II '- July 2003 . On page 4-22 ofthe Socio-Economic TSD, the table Most Negative Attributes, points out that the nuclear plant in general tenns was considered a negative attribute. It was one of the top three. With respect to issues that negatively affect the image ofthe community, the nuclear plant was the most important issue at both the local and regional study areas. When one excludes those who could not name a negative issue affecting image, it is approximately 25% of the respondents in the local study area indicating that the nuclear plant negatively affects the image of the community. . On page 6 of Appendix D of the Socio-Economic TSD, it is noted that the Pickering station is not a dominant issue in the local and regional study areas. While this is correct in one sense, it is not in another when it is noted in some sections of the survey that the nuclear station in fact is something that affects people sense of well being. It is a concern for 21 % ofthe local area respondents (which is the highest) as well as 18% at the regional level (second highest). This has not been given proper weight in the analysis based on table 2, page 8. . The analysis on page 11 of Appendix D of the Socio-Economic TSD, dealing with issues that most negatively affects image ofthe community states that no one issue dominates. However, out of the issues that are presented, there are two major issues - one being crime and the other being nuclear stations dangers. The nuclear station is the most frequently mentioned issue. 2.6.8 Physical and Cultural Heritage Resources The physical and cultural heritage resources described are relevant for predicting environmental effects likely to result from the PWMF II project. 2.6.9 Aboriginal Interests The existing environment for Aboriginal interests was adequately described. 2.7 Evaluation and Selection of Project Location The site evaluation process was transparent, traceable, replicable (for the most part) and consistent in the evaluation and decision making process. The Review Team has the following comments: Step 1 (P. 6-1) should have fully described the Site Option Study rather than Section 2.2.3. The process described in Step 1 was confusing. Analysis reflected in Table 6.4-1 could have been improved using a numerical ranking scheme. IER & SCIMUS Inc. in association with North-South Environmental 10 172 ATTACHMENT # á) TO R.fPORT # CÞcu~<o- ö¿;S Review By IER of Ontario Power Generation \::h... \ () G ~ ~ Draft Environmental Assessment Study Report . Z~ Pickering Waste Management Facility Phase II July 2003 In Section 6.4.2.2, Public Consultation During the Site Selection Process, complete and detailed information is not available on information presented to the public at open houses or received from them at these events. Similarly, there is only incomplete information on discussions at key CAC meetings where preferences on a Site Area were established. This information is critical to dispel the possible perception that the decision on a preferred site area was made in advance of the public consultation on the three options. 2.8 Assessment of Likely Environmental Effects and Mitigation With respect to Section 7.3, "Radiation and Radioactivity, a brief summary of the shielding calculation methodology and results should be included as an Appendix to the EA or in the TSD. Regarding Section 7.4.2 "Noise", it is indicated that as long as the equipment utilized for the construction project is in compliance with the sound emission standards, the construction activity is considered to be in compliance from a noise perspective. It is, therefore, important to perform the necessary noise tests during the operation of this equipment to ensure compliance. Regardless, a formal complaint response system should be established, if it isn't already in place, to respond to any concerns the public may bring forward. With respect to the Terrestrial (Section 7.6) and Aquatic (Section 7.5.1) wildlife, it is agreed that the proposed works are not likely to affect terrestrial or aquatic wildlife, with the caveat that: . Further investigations should confirm that there are no amphibians breeding on the site, and that fish are not present when water levels are maximum (a site visit should be made after frogs begin calling in the region, approximately early April). . The issue of marsh wren breeding or non-breeding in the East Wetland should be clarified (if breeding, marsh wren should be added to VECs). . The issue of sediment deposition in the East Wetland should be addressed, and the sediment and erosion control plan should include the issue of sediment deposition in the East Wetland. The conclusion that there are not likely to be measurable effects of construction on aquatic life, terrestrial wildlife, vegetation, natural heritage features seems reasonable given the developed nature of the site. The issue of sediment deposition in the East Wetland during construction is dismissed in this report in the Aquatic Environment section (Page 7-19). However, in the TSD aquatic section it notes that the Terrestrial TSD would deal with the issue of sediment deposition in the East Wetland, as there is no aquatic life present in this wetland. The Terrestrial TSD did not address this issue. The ranking of VECs is not very useful. More weight should be given to species of specialized habitat whose environment could be affected by the proposed works, as this reflects the priorities IER & SCIMUS Inc. in association with North-South Environmental 11 ATTAcHMENT# ~ TO REPORT#C>A.c-~b-~::S Review By IER of Ontario Power Generation ~ \1 (\ Q. Draft Environmental Assessment Study Report ' ~ U? Ö ~ c;JC) 1 7 3 Pickering Waste Management Facility Phase II July 2003 of municipal and provincial agencies. For example, marsh wren is listed as one ofthe inhabitants ofthe East Wetland (though its presence there as a breeding bird needs to be clarified). If the stormwater control measures planned (creation of ponds where the East Wetland now stands as in Figure 7.5-1) are implemented, the habitat for this species, which consists of cattail marsh, would be eliminated. Marsh wren is considered Regionally significant in the Greater Toronto Area (according to TRCA) and is on the list of priority species of conservation concern for Durham Region. Great Homed Owl should also be added to the list of VECs, as it is important as an "apex predator". In Section 7.8.3, it is not clear whether earth-moving operations during site preparation will involve off-site truck movement. If so, the impact of this on local traffic should be addressed. Also, it is stated that trips of construction workers are expected to have negligible effects on transportation Levels of Service (LOS) both in terms of duration and extent. The Review Team questions the reasonableness of this statement given the already highly unacceptable Level of Service at key intersections on Brock Road, i.e. is it reasonable to make a highly unacceptable traffic situation slightly worse? In Section 7.9.1.2, it is stated that approximately 19% ofthe respondents in the Local Study Area and 24% in the Regional Study area indicated they might change their decision to live in the community as a result of the project (a significant percentage). The subsequent analysis notes that there are concerns about the safety of the Pickering Nuclear Generating Station as a whole rather than the PWMF II. It is important to recognize that there is a need to build a positive image of the facility within the community, particularly in light of the longer term future disposal and the fact that this is the second temporary storage solution and permanent storage on site may be a reality in future years. This point, while outside the limited scope ofthe EA analysis for PWMF II, is most relevant in terms of nuclear facility and waste concentration in Durham Region and the City of Pickering and the potential cumulative impacts that can affect community image/stigma and safety and contingency planning concerns. It may indeed be the reason for a relatively high percentage of people being concerned about the facility because of the perception that temporary storage may become permanent. On June 16,2003 the Nuclear Waste Management Organization made a presentation to Pickering Council and stated that one of the options for long-term management of nuclear waste was to store it on the site where it is generated. It is, therefore, not surprising that people are expressing a higher degree of concern than might be warranted by the specific project that is currently under consideration. The public attitude surveys should have included the following additional information: . Identification of employees of OPG or the Pickering facility. This may have been useful because there may be as many as 5% ofthose drawn randomly could have some direct relationship with OPG or Pickering and analysing their responses separately could be enlightening. For example, removing their responses from the general survey for analysis may have provided a somewhat different picture of peoples' issues and concerns. . Gender data. . Distance from facility. IER & SCIMUS Inc. in association with North-South Environmental 12 174 Review By IER of Ontario Power Generation Draft Environmental Assessment Study Report Pickering Waste Management Facility Phase II ATTACHMENT # (~ TO REPORT #~-ðlD-O~ ~ \\ o~ é;)ß .~ July 2003 2.9 Description and Assessment of Credible Malfunctions and Accident Scenarios There is inconsistency in the assumptions of the bounding accident: . In Section 2.3.3.3, it is stated that "..escort .. and traffic and pedestrian restriction would be applied to each transfer of a loaded DSC to the PWMF II.". Why is this accident even considered for the bounding accident rather than dismissed as incredible? . It is agreed that the consequences (100% release of gaseous radionuclides in DSC) of a bounding accident are extremely conservative and incredible (probability < 10-6); however, there appear to be some assumptions made in the dose calculations that are less than conservative (eg two minutes for NEW exposure; if injured may be difficult to extract one-self; non-NEW excluded because of low probability but low probability consequences are assessed for NEW because dose acceptable). The Dose calculation methodology is for PMWF Phase 1. It appears the same ADFs are used for Phase II as for Phase I even though it is considerably closer to the site boundary (Appendix D of Radiation and Radioactivity TSD). The predicted dose to the member of the public at the site boundary was 0.1 .!Sv for Phase I (assuming 10% fuel element failure) and 1 .!Sv for Phase II (assuming 100% fuel element failure) indicating that the same ADFs were used. It is indicated in Section 8.2.4 (P. 8-7) that construction activities will involve best management practices (BMPs) and environmental management plans (EMPs) for all aspects with potential to effect the environment. The City of Pickering should have access to these plans and they should review them if they have not already. 2.10 Assessment of Cumulative Environmental Effects A key requirement under CEAA is for a project proponent to assess the contribution of proposed project effects on VECs, and to consider the contribution ofthese effects in combination with other effects from other projects and activities on the VECs. Effects can be caused by past, current or existing and foreseeable future projects or activities. Relatively speaking this is a new dimension to the art and science of environmental assessment and the understanding and application of this EA component is evolving. The Review Team considers the presentation in the EA Study Report, regarding the project's specific contribution to cumulative environmental effects to be generally acceptable, based on the selected VECs, although it is not clear whether the public was involved in the selection of VECs. The EA Study Report does provide a description in Section 9.0 of other projects and activities within the regional study area with respect to radiation and radioactivity. The description identifies both past projects and ongoing and foreseeable future projects. IER & SCIMUS Inc. in association with North-South Environmental 13 Review By IER of Ontario Power Generation Draft Environmental Assessment Study Report Pickering Waste Management Facility Phase II ATTACHM ENT ~ TO REPORT # ~ do - ~ C' \ß ~\ ~ß 175 July 2003 The assessment of each ofthe VECs in Section 9.0 as to whether a cumulative effects assessment consideration is warranted and useful. In these sections the proponent provides the rationale for determining if there is a cumulative effects consideration or trigger for each VEc. The Review Team generally agrees with the rationale and conclusion provided by OPG, based on the information provided and assessments presented within the EA Study Report. In particular, the conclusions that the predicted effects on the VECs do not possess a cumulative effects trigger are reasonable. Our conclusions are dependent on the implementation of the commitments by OPG to all mitigation and monitoring and other measures that make up the Follow-up and Monitoring Program as presented in Section 10.0. For example, Table 9.2-1 indicates that there are no likely adverse residual effects with respect to socio-economic conditions. It will be extremely important to follow-up on this environmental component not only to confirm the assumptions inherent in the analysis but also to recognize a new airport which could be operational in Pickering within 10 years. Also, in the Assessment of Likely Environmental Effects and Mitigation, it is stated in terms of off-site traffic, that the additional 50 vehicles per day during the Site Preparation and Construction Phase is not expected to be noticeable. It should be noted that traffic levels of services on Brock Road leading into the PNGS are already unacceptable and any increase in personal vehicles as well as potential truck movement could result in a cumulative effect. 2.11 Follow-up and Monitoring The following should be incorporated into the Proposed Monitoring Program. Public surveys should be conducted after storage building three is in service but also in the first year after storage building four is in service. In addition, a clear protocol on the planning and implementation of contingency measures, involving the City of Pickering and Durham Region should be developed in this stage. Follow-up monitoring should include a recommendation to inventory habitat for amphibians at the site. This should be done at the time most appropriate for detecting breeding of some of the most sensitive species: in early to mid April and again in May, particularly early in the season for leopard frogs. Follow-up monitoring should also include a survey to note if the great horned owl is still present. IER & SCIMUS Inc. in association with North-South Environmental 14 176 ATTACHMENT # Ö) TO REPORT#QJ\C-C(çC:S Review By IER of Ontario Power Generation ~ \ C;:¡. ~ e:, Draft Environmental Assessment Study Report \'.:~ \ \ ~ ~ . Pickering Waste Management Facility Phase II July 2003 Follow-up monitoring should include a recommendation to confinn that habitat for fish does not occur at the site in the East Wetland. This should be done after the snow melt in April when water levels are at a maximum. The probability of an aircraft accident involving PWMF II should be re-evaluated in the event of the construction of a new international airport in the vicinity of Pickering. Since the Storage Buildings will meet the requirements of different codes, standards and bylaws that are unlikely to sustain the impact of an airline crash, it is important to confinn that this remains an incredible event. The u.S. Nuclear Regulatory Commission is currently studying this issue for nuclear plants in the vicinity of major airports. The effect of the additional personnel vehicles and earth moving trucks on the traffic on Brock Road should be monitored during the construction phase. Dust and noise monitoring should be conducted during the construction phase to ensure levels are acceptable. Monitoring of groundwater from East Landfill and Inert Fill Sites should be conducted throughout the project as required. Monitoring of sediment loading on the wetland should be conducted during the construction phase. 3.0 DETAILED MINOR COMMENTS The following are minor detailed comments on the various sections of the EA report and relevant TSDs. Main EA Document On Page 2-3, Section 2.2.3: There is confusion as to whether sites reduced to 5, (line 4 paragraph 2) or 6 (line 7, paragraph 2). The discussion of how sites were reduced to final three is also confusing. Page 2-7, Section 2.3.1.1: The Maximum sheath temperature of the used fuel (175OC) should be given here to allow reader to see the margin that exists. Presently this infonnation is buried in Appendix D of the Radiation and Radioactivity TSD. Page 2-8, Section 2.3.1.2: Mention is made in section 2.3.1.1 that temperatures under 300°C and the presence of helium restrict the release of radio nuclides into the DSC cavity. These factors also limit corrosion of the steel inner lining. However, there is no monitoring of these conditions IER & SCIMUS Inc. in association with North-South Environmental 15 ATTACHMENT ~ TO REPORT #CJ\~- ~C~ Review By IER of Ontario Power Generation c.J;:~ ~ &B Draft Environmental Assessment Study Report ~ CY~ - 1 7 ~7 Pickering Waste Management Facility Phase II ç July 2003 in the Inspection, Maintenance and Aging Management plan. It appears that all efforts are focused on the outer liner. Some monitoring of inner conditions should be considered, especially in preparation for future fuel retrieval prior to conditioning for disposal. P. 2-9, Section 2.3.1.3, last bullet: It would be useful to know the intensity and duration ofthe fire considered. Page 2-14, Section 2.3.3.3, second last sentence: This appears to indicate that there will be restrictions on other traffic during the transfer of DSCs from the PWMF I to PWMF II. These would drastically reduce the probability ofthe bounding accident discussed in Section 8.3.4. P. 2-15, Section 2.3.4.1, second paragraph: Same comment as Page 2-14 above. Page 3-13, Section 3.9.1, last paragraph - Mentions consideration of probability in nuclear accidents. Should specify both non-radiological and radiological in both construction and operations phases. The text in Section 4.2.3 indicates that the notification letters introduced the EA study team, asked the recipient about a possible interest in a briefing, and included an invitation to attend an open house. The sample notification letters in Appendix C do not include this information. Page 4-6 of 4.2.5 Stakeholder Contacts and Scoping Interests indicates, "A list ofthe preliminary stakeholders and groups contacted to determine their interest in the project, the subsequent meetings or discussions that were held and the issues or topics raised are provided in Appendix C." None of these items are provided in Appendix C. There is no indication of which stakeholder groups had meetings with the EA team, when, and the results. This information is important, since the meetings were not only intended to identify issues from the organization's perspective but also to determine their interest in attending an EA workshop, which was later cancelled due to these responses. Section 4.2.6.1 indicates that the first newsletter included information on the siting area and the three layout options. A review ofthe newsletter (provided as part ofthe Project Information Package in Appendix C) indicates that a map ofthe siting area was included, but no indication or description ofthe 3 layout options was included. Section 4.2.6.2 indicates that the second newsletter described the differences among and presented the preliminary evaluation results for the three alternative site areas. The newsletter in Appendix C indicated that "OPG had now completed the Site Areas Evaluation and selected the preferred site location for building the PWMF II." Thus, recipients of the newsletters would have had no opportunity to comment on the three layout options until a decision on the preferred option had been made. The newsletter did indicate that the decision was made with input from the CAC and participants at a round of open houses. The description of the first newsletter in Section 4.2.6.1 should be reworded to indicate that the description of the three options was not in this newsletter. A copy of the third newsletter is not included in the Information Package in Appendix C and should be added. IER & SCIMUS Inc. in association with North-South Environmental 16 ATTACHMENT #~ TO REPOR. T#~-alo-c3 Review By IER of Ontario Power Generation ~ \ \. &ð 1 7 8 Drafl Environmental Assessment Study Report ð (;) a ..~ Pickering Waste Management Facility Phase II July 2003 The description of each round of open houses in Section 4.2.8 refers the reader to Appendix C for the report on each open house. The report on the first round of open houses indicates that: . A sample ofthe invitation card and maps of the distribution area are included in Appendix A; . A sample of the advertisement is included in Appendix B . A sample invitation letter is included in Appendix C; . The 14 information panels from the open house are provided in Appendix D; . A sample Comment an Evaluation form is provided in Appendix E; and . A full listing of the written comments and questions provided on the Comment and Evaluation forms as well as some typical verbal questions, comments and concerns responded to by the EA consultants and OPG representatives is included in Appendix E. None of these materials are provided in their respective appendices for the first, second and third round of open houses. In the first round of open houses the key missing item is the information on the 14 information panels, for the reviewer to be able to confirm that the three layout options were in fact described for public input. In the report on the second round of open houses it indicates (Page 5) that open house visitors were invited to provide comments on the evaluation ofthe three alternative site locations. Yet, the report indicates that the results of the evaluation were being presented at this open house (Page 1 ). With the missing information in hand, it may be possible to dispel the potential perception that a decision on the layout alternative had already been made in advance of the second round of open houses. The report on the third round of open houses indicated that there were no objections raised to the selection of Site Area B, but again the listing of comments was not available in the Appendix. Section 4.2.9 indicates that two EA study workshops were planned, but due to the finding that only municipal representatives were interested in attending one workshop proposed for the Fall of 2002, these were cancelled, and, in lieu of the workshops, three presentations were made to the CAC, an existing stakeholder group. It is difficult to determine if this decision was appropriate, in the absence of information on: which stakeholders were consulted, how contact was made, when in the process the contacts were made, in what manner the workshop was discussed and with what information given to participants. Without this information, the perception exists that the consultation program was unnecessarily abbreviated. Also, a workshop for municipal representatives, with a written invitation to other key stakeholders would have been a viable alternative approach. No information is provided on why a second EA workshop that was planned was not held. The three presentations to the CAC would have been appropriate in any case, without the CAC being viewed as a substitute for two EA workshops. Also, was there an intent to include the public in these workshops? Section 4.2.9 (last paragraph) states that a summary of the discussions at the CAC presentations were provided, but such a summary in the text is only available for the last CAC presentation. Appendix C does contain a copy of one of the presentations made to the CAC, but it is undated IER & SCIMUS Inc. in association with North-South Environmental 17 Review By IER of Ontario Power Generation Draft Environmental Assessment Study Report Pickering Waste Management Facility Phase II ATTACHMENT# ~ TO REPORT#ef~..o..a(o-G~ ~~@ o~ ~ß 179 July 2003 and some pages begin with "continued" where the original page on the topic appears to be mISSIng. Section 4.2.9.2 (October 2002 - EA Update and Evaluation of Site Areas) indicates that details of the CAC input into the site selection process are provided in Section 6.4.2.2 ofthis report. This is the first mention in Section 4.0 that some results of the consultation program are located in a different chapter - consultation results not only from the CAC, but also from the first two rounds of open houses. Such hidden reference to (important) additional consultation information elsewhere in the Draft EA Report is confusing. A review of Section 6.4.2.2 follows at the end of the review of Section 4.0. Table 4.4-1 should indicate the meeting dates and names of stakeholders for the stakeholder contacts and scoping interviews in May-June 2002, July-August 2002 and September 2002. Section 5.2 is much better focused than the Radiation and Radioactivity TSD. The TSD contains much extraneous material. The existing noise environment described in Section 5.3.3 of the EA is based on conservative assumptions and not recent monitoring according to the TSD (Section 4.2.3.2 on P. 14 of the TSD). In addition, under Section 5.0 "Assessment of Likely Environmental Effects and Mitigation ofthe TSD, the proponent correctly points out that as long as equipment utilized for the construction project is in compliance with the appropriate sound emission standards then the construction activity is considered to be in compliance from a noise perspective. This demonstrates the need for noise monitoring of construction equipment during that phase of the follow-up and monitoring program. Also, as discussed in Section 5.2.2.2 of the TSD, the noise levels generated by the DSC transfer vehicle should be confirmed. In Section 5.4.3.3 ofthe Main EA, it is not clear why stormwater quality results were compared against Provincial Water Quality objectives since these objectives apply to receiving streams (creeks, rivers or Lake Ontario). The text should also explain whether Durham Region administers stormwater effluent guidelines as part of its municipal bylaws and whether these guidelines, if they exist would apply to this EA. In Section 5.4.4.1, sediment quality in the Regional and local study areas is discussed. The text indicates that some parameters exceeded the MOE 1997 Guideline for Use at Contaminated Sites in Ontario (GUCSO). Section 4.4.2 "Regional Study Area Sediment Quality" and Section 4.4.3 "Local Study Area Sediment Quality" from the Hydrology, Water Quality and Aquatic Environment - TSD correctly compare sediment quality to the Provincial Sediment Quality Guidelines and don't make reference to the GUCSO criteria. This difference should be explained. In Table 5.8-1, Valued Components for Environmental Assessment lists community character and use and enjoyment of property as two sub-components but, in fact, they are also tied to image and perception both of residents in the Pickering area as well as those who look at Pickering "from the outside". IER & SCIMUS Inc. in association with North-South Environmental 18 180 Review By IER of Ontario Power Generation Draft Environmental Assessment Study Report Pickering Waste Management Facility Phase II ATTACHMENT #~ TO REPORT #~ö-c(o-~~ Q~~3 a~ ~ - July 2003 Page 7-3, Section 7.3.1.2 Identified Mitigation Measures: Sentence is incomplete. With respect to Section 7.13, "Assessment of Likely Effects of the Environment on the Project", it would be helpful in the section on "Tornadoes" (P. 7-50) and Earthquakes (P. 7-51) to elaborate on the nature and extent oftornadoes and earthquakes and the design features ofthe PWMF II to withstand such conditions. On Page 7-30, it is unclear whether the site preparation earthworks of 600 tonnes/day (Table 2.1- 1) will involve off-site truck movement. Cumulative Effects TSD In the Cumulative Effects TSD, the Sewage Treatment plant adjacent to the proposed site was not mentioned and the potential of a New Pickering Airport within the next decade should be taken into account in the technical study or the EA. This is relevant in tenns the range of socio- economic pressures and activities that will be occurring within the regional study area and will also be affected to the local study area. In addition, it further elevates the public issue regarding security and the need to ensure contingency plans are in place to deal with any eventuality. Hydrology, Water Quality, and Aquatic Environment TSD In Section 5.2 ofthe TSD (P. 37, 3rd paragraph) the text indicates that background values for a number of metals in near shore sediment exceed the Lowest Effect Level of the Provincial Sediment Quality Guidelines but the magnitude is not discussed. The text goes on to explain that minor exceedances are considered "marginally polluted" and that direct management action is required only when concentrations exceed the Severe Effect Level. The text should include a discussion of the magnitude of the exceedance. Table 3.0 on P. 5 ofthe TSD indicates that Construction Phase Stonnwater Management and the Operations Phase will not interact with "Groundwater Recharge". Given that there will be hardening of surfaces by grading and paving thereby increasing runoff and decreasing infiltration, there will be potential interactions and these should be identified on Table 3.0. This discussion would also apply to Table 7.1-1 ofthe Main EA Report (following P. 7-2). Page 3 - Could add that there were no habitats. which warranted more intensive sampling, if that is the case. Page 12 - Site visit appears to have been made in August, when all habitat on site could be expected to be dry. Page 29 - 32, rationale for selection ofVECs in table 4.8.1-1 is reasonable, but could add additional factor: habitat specificity, to identify whether proposed development is likely to eliminate species with highly specific habitat requirements. IER & SCIMUS Inc. in association with North-South Environmental 19 Review By fER of Oot.,io Pow" Geo"atio. ATTACHMENT # ~ TO R EPORF~ . ölD - 02, Draft Environmental Assessment Study Report ~ ~ c ¿;) .) 181 Pickering Waste Management Facility Phase II July 2003 Socio-Economic TSD In the Socio-Economic TSD, pg. 5-17, there is reference to the mobility data for the City of Pickering and other communities in Southern Ontario but the data is not provided. This is a general comment as there are some other instances where the actual data should be included in the Appendices so one can verify the conclusions that are drawn. A typographical error appears in Table 5.3.1-1 on page 5-26. The title of the table should refer to "PWMF II" instead of "DUFDS". On page 15 of Appendix D of the Socio-Economic TSD, the analysis states that people do not think more frequently about living near the PNGS based on proximity to the Station; and that women do state more concern than men, but there are no data provided to back up these conclusions. Public Consultation TSD The list of stakeholders in Table 3.3-1 who were sent notification letters which also suggested they would be contacted for a briefing included federal and provincial government representatives. Assuming that follow-up telephone calls were made (there is no record), did all the federal and provincial representatives decline a briefing on the project? The results of contacts with federal and provincial departments and ministries should be included in Table 3.5- 1 in the TSD. It is indicated (on Page 10, in the full paragraph) that local environmental organizations and ratepayer organizations were initially telephoned, not sent notification letters that introduced the project and asked if they would be interested in an interview or briefing. Such letters may have sparked the organization's interest before the telephone messaging contact began. The consultation plan in Appendix A was not followed regarding the contacting of stakeholders for potential interviews or briefings. In Table 6.1, 33 contacts were identified for possible briefings and 21 for possible interviews. In the summary of contacts (including federal and provincial government representatives, Council briefings, MP and MPP contacts) a total of37 organizations were contacted for either a briefing or interview. Also, in Section 4.2.2 of the consultation plan it indicates that briefings would be given to educational institutions. No record of such contacts is included in the summary of contacts. On Page 14 (last sentence in the section), the reference should be to Appendix E, not F. On Page 18 (last paragraph in Section 3.8.1.2) it states that samples ofthe notification letter, advertisement, invitation card, comment and evaluation form and a copy of the display panels are in the Report on the First Round of EA Open Houses, June 2002, located in local libraries. Similarly, in Section 3.8.1.3 reference is made to written and verbal questions and comments in Appendix E of the report on the first round of open houses. These samples of communication IER & SCIMUS Inc. in association with North-South Environmental 20 182 ATTACHMENT #~TO REPORT#~o~clo-<s3. Review By IER of Ontario Power Generation "5 \ ¿;)~ Draft Environmental Assessment Study Report ç:y C :;J Pickering Waste Management Facility Phase II July 2003 pieces and summary of comments for all three rounds of open houses are not available in any of the documentation provided for review. This infonnation should be presented in both the Draft EA Report and the TSD. On Page 30 (last sentence in Section 3.9) it states that copies of the CAC presentation slides are included in Appendix G of the TSD. Two of the three presentations are found in Appendix F (not G), and are provided with the minutes of the CAC for the meetings at which the presentations were discussed. The minutes would have provided useful infonnation on the discussions at the CAC, but only every second page is provided. Thus, the discussion on the straw tally that was said to detennine the CAC's preference for Site Area B could not be verified. Similarly, only every second page ofthe presentations is provided. No minutes are provided with the presentation for the third CAC presentation in March 2003. In Appendix A: Community and Stakeholder Consultation and Communication Plan - Section 4.4 describes the two workshops that were planned for "stakeholders and individuals with a high level of interest in and commitment to participation in the PWMF II EA." The letters of invitation to these workshops (even to detennine a level of interest) were apparently not sent. Both workshops were cancelled in favour of holding three presentations to the CAC (which were expected in any event through the plans for ongoing stakeholder contact described in Section 4.2.5 ofthe consultation plan). The decision to cancel the two workshops and use ofthe CAC as a substitute needs to be called into question. Terrestrial Environment TSD On page 3-4, dates for field investigations are too late for inventories of breeding amphibians (specifically frogs): these must be done in mid-April to early June. Breeding amphibians likely one of the most sensitive groups in the vicinity and should have been surveyed properly, given that they may travel between breeding habitat (e.g. the Hydro Marsh) and terrestrial habitat on the property. It is not possible to detennine from the Methods whether previous work (e.g. for Pickering A Return to Service) was done at the correct time for amphibian surveys; the report should state that the surveys were done at the correct times if so. On page 3, Natural Heritage System should have additional bullet: alteration oftrophic structure that supports significant elements (not just effects on vegetation communities, should include insect communities and rodent communities as well) On Page 5, methods note that breeding bird surveys were conducted at 0630 to 1030: breeding bird atlas and Canadian Wildlife Service protocols state surveys should start at 0500 and end at 1000. IER & SCIMUS Inc. in association with North-South Environmental 21 ATTACHMENT # rS:J TO REPORT#~-O~- G:S Review By IER of Ontario Power Generation ~ é) lo ~ \' 18 Draft Environmental Assessment Study Report ~ ~ ('"~~ 3 Pickering Waste Management Facility Phase II July 2003 On Page 5, Broader Regional status should have been assessed according to the Toronto and Region Conservation Authority (TRCA) list of fauna species of concern in the Greater Toronto Area as well. This list is specifically applicable to the rapidly urbanizing areas around Toronto. On Page 5, figure numbers are wrong: references on page 5 to local and regional study areas are to figures 2.2-1 to 2.2-3, figures numbered 2.3-1 to 2.3-3. On Page 5, references 0290 and 0291 are missing from References list (Section 9: list only goes up to 0289). On Page 10, relevance of local study area and regional study area to these evaluations is obscure. The two most significant features in the local study area (as shown in Figure 2.3-2) are Frenchman's Bay and the Hydro Marsh. The statement here that "in the local study area, most of the vegetation has been removed as the land has been developed since the time of European settlement", and the subsequent discussion, do not highlight the significance (considerable, especially given the urban setting) of these areas at all. These areas are also missed in the Regional evaluation table (Table 4.1-1). On Pages 13-14, mention of area (ha) of each of these vegetation blocks would be helpful in determining habitat significance. On Page 15, no mention of whether amphibians use the marsh for breeding: because it's not known? (noted that no standing water present, but study team didn't look in April-May when it could be expected to provide habitat for breeding amphibians). There is no appendix listing amphibian species, though a few are noted in the section on Herpetofauna (page 18). On Page 16, green heron and black-crowned night heron L3 (significant) in TRCA. On Page 17, under marsh: black-throated green warbler and marsh wren, noted in marsh habitat, are both significant (L3) in TRCA. Text mentions that they were migrants, but the species list in Appendix C does not distinguish migrants from breeding species. There is no mention of other field visits to detect migrants, the only field visit recorded in Methods was on June 25 which is a time suitable for breeding birds. If the marsh wren was noted during this visit, it was in suitable habitat at a suitable time of year and should be considered a possible breeder. Marsh wren is significant in Durham Region and in TRCA Greater Toronto Area list. On what basis is Northern mockingbird a regionally significant species? Reference 0297 not in reference list. It's considered L4 (not significant) on the TRCA list. On Page 23, Table 4.5-1: 2. Ecological Importance: should add to "critical component of ecosystem (e. g. apex predator or dominant prey species)" 4. Conservation Status 1 =add Regionally rare according to TRCA IER & SCIMUS Inc. in association with North-South Environmental 22 184 Review By IER of Ontario Power Generation Draft Environmental Assessment Study Report Pickering Waste Management Facility Phase II ATTACHMENT # c:{) TO REPORT # ~-c.k>-a3> %~\ a~ é;)ß July 2003 5. Degree of Exposure c) breeds in the study area: should receive more weight if yes, because of vulnerability of eggs/nestlings/fledgelings 6. Habitat specialist should have higher weight Not much weight is given to species that nonnally are of concern to municipality and province, e.g. those that have the most stringent habitat requirements and are most likely to be lost as a result of development. On Page 25, Table 4.5-3 What is the basis for inclusion of candidate VEC species in this table? Great homed owl, green heron, black-throated green warbler, willow flycatcher, are mentioned in text but not included in this table: all could be candidate VECs, and there is no consistent rationale for excluding them (e.g. black-throated green and marsh wren were both said to be migrating, yet marsh wren was included while black-throated green warbler was excluded). The great homed owl should not be dismissed so summarily: it was confinned breeding according to the text (page 16). It is not always possible to detennine what criteria birds use to select habitat, but ifthey fledge young, it was presumably the right choice of habitat however atypical it seems to the human observer. On Page 25, Table 4.5-3- Generally, this table is not very useful. Selection criteria for VECs has given the most weight to the most common and adaptable species that are likely to be least affected by development, contrary to the direction usually taken by the province and by municipalities. Dependence on specific habitats, especially for breeding, should have more weight because loss of specific habitat, and therefore loss of a species that depends on that habitat, may have regional implications. It is not obvious how the species are ranked in this table, as many organisms have the same score but are in different parts ofthe table, and there are many species that have the same score as the chosen species. (Ranking in table 4.5-3 has apparently been ignored anyway and a species that is 1ih on the list has been chosen as the upland representative VEC). Page 28 should add red-tailed hawk or great homed owl to selection ofVECs, given that importance of apex predator is stressed in Table 4.5-1 (section 2), and that red-tailed hawk ranked highest on table 4.5-3 See comments for marsh wren under Page 17, marsh wren should be a VEC if it is a breeding speCIes. On Page 32, potential for sediment-laden runoff during construction to enter adjacent natural (especially wetland) habitat should be considered here. Page 32-33, Section 5.2.1.1: could consider recommending confining construction to fall and winter to avoid impacts of earthworks on wildlife IER & SCIMUS Inc. in association with North-South Environmental 23 ATTAcHMENT# c.:) TO REPORT#ffi2-ato. a3> Review By IER of Ontario Power Generation ~ ~<C ~ 0. Draft Environmental Assessment Study Report '6 r::::Y~ a &(,~) 1 85 Pickering Waste Management Facility Phase II July 2003 Need recommendation for an erosion and sediment control plan to control runoff to natural areas during construction. On Page 38, should the diamond in the Natural Heritage System column oftable 5.2.3-1 be a square? (if not, should put this symbol in the legend). On Page 39, it would be useful to evaluate the effects on the apex predator as an additional VEC (great homed owl or red-tailed hawk): these species may hunt for small mammals etc. on the open part ofthe site. IER & SCIMUS Inc. in association with North-South Environmental 24