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HomeMy WebLinkAboutCAO 01-05PICKERING REPORT TO EXECUTIVE COMMITTEE Report Number: CAO 01-05 Date: January 17, 2005 Everett Buntsma (Acting) Chief Administrative Officer Subject: NWMO Discussion Document 2, Understanding the Choices - City of Pickering's Comments to NWMO File: S~5610-011 Recommendation: That Council receive Report CAO 01-05 concerning the Nuclear Waste Management Organization's (NWMO) Discussion Document 2, Understanding the Choices. That Council confirm as the City's comments on Discussion Document 2, the Acting CAO's letter of December 20, 2004, including the peer review comments provided by Acres - Sargent & Lundy (see Attachments 1 and 2 to this Report), and that the NWMO make particular note of the following concerns in completing its work: The need to ensure a full and thorough assessment of the social, economic, and environmental impacts of on-site storage on host communities; b. The need to explicitly address issues related to community compensation and host community benefits; and c. The need to ensure adequate and effective community dialogue in the remaining phases of the work. That Council acknowledge receipt of the NWMO's letters dated January 10, 2005, to the Acting CAO and to the Canadian Association of Nuclear Host Communities (CANHC), responding to comments submitted on Discussion Document 2 (see Attachments 3 and 4). That Council request NWMO to provide continued peer review funding assistance to the CANHC to ensure the effective and ongoing participation of CANHC and its member municipalities in NWMO's remaining process. That a copy of this Report be forwarded to the NWMO, the Federal Minister of Natural Resources, the Ontario Power Generation, member municipalities of CANHC, M.P. Dan McTeague, M.P. Mark Holland, and M.P.P. Wayne Arthurs. Report CAO 01-05 Date: January 17, 2005 Subject: NWMO Discussion Document 2 Page 2 Executive Summary: The Nuclear Waste Management Organization (NWMO) released its second discussion document in September 2004. Discussion Document 2 describes the management options being considered in finding a solution for long-term storage of Canada's high level nuclear waste. To assist host municipalities in commenting on this document, the NWMO agreed to provide peer review funding through the Canadian Association of Nuclear Host Communities (of which Pickering is a member). In late November, the consulting team of Acres - Sargent & Lundy (ASL) was selected by the CANHC to undertake a peer review of Discussion Document 2. The ASL report was completed in mid December. It highlighted "potential gaps" in the NWMO Assessment Framework and provided possible ways of addressing these gaps. ASL also commented on various other issues and provided a set of recommendations. NWMO had asked for comments on Discussion Document 2 by the end of 2004. Because of this, the Acting CAO provided a letter to the NWMO in late December, attaching the ASL report as the City's preliminary comments on the Discussion Document. NWMO was also advised in the letter that City Council would be in a position to consider that matter early in 2005 (see Attachments 1 and 2). NWMO provided a response to the City, and to a letter from the CANHC in early January (see Attachments 3 and 4). This Report recommends that Council confirm to the NWMO that the Acting CAO's letter of December 20, including the ASL peer review comments, is the City's official position on Discussion Document 2. It also recommends that Council advise NWMO that in the remaining process, NWMO undertake a full and thorough assessment of the social, economic and environmental impacts of on-site storage on host communities, that they explicitly address issues related to community compensation and host community benefits, that they ensure adequate and effective community dialogue in the remaining phases of the work, and that they provide continued peer review funding assistance to the CANHC to ensure the effective and ongoing participation of CANHC and its member municipalities in NWMO's remaining process. Financial Implications: There are no financial implications on the City. NWMO covered the cost of ASL's peer review of Discussion Document 2. Report CAO 01-05 Subject: NWMO Discussion Document 2 Date: January 17, 2005 Page 3 Background: The Nuclear Waste Management Organization (NWMO) was mandated by the Nuclear Fuel Waste Act to identify and recommend a suitable option for long-term nuclear waste storage in Canada. The Act required a final report to be submitted to the Minister of Energy by November 2005. In November 2003, NWMO published Discussion Document 1: Asking The Right Questions. The City provided comments on Discussion Document 1. Discussion Document 2, Understanding the Choices, was released by the NWMO in September 2004 (an Executive Summary of this document was forwarded to Mayor and Council at that time). In October, in response to a previous request of the Canadian Association of Nuclear Host Communities (CANHC), the NWMO agreed to cover peer review consulting costs related to Discussion Document 2, to a maximum of $20,000. NWMO also indicated that subsequent funding might be available to CANHC for the peer review of reports issued in 2005, but could not make a definitive commitment at that time. Staff from the municipalities of Clarington, Kincardine, and Pickering conducted a selection process for a peer review consultant. The firm, Acres - Sargent & Lundy (ASL) was chosen in late November and immediately began work. By mid December, ASL completed its report on Discussion Document 2. Although a December 31 deadline for comments had originally been established, because of scheduling issues, the NWMO agreed that the member municipalities of CANHC could submit their preliminary comments in December, and then obtain Council's formal position on the matter early in 2005. Accordingly, the Acting CAO submitted a letter to NWMO outlining Pickering's preliminary comments on Discussion Document 2, and attaching ASL's peer review report (see Attachments 1 and 2). ASL conducted a comprehensive review of NWMO's Discussion Document 2 and its reference materials. Their work was very helpful as it assisted with the identification of key issues and areas that municipalities should focus on at present and in the future. An Executive Summary of ASL's report is attached. In early January, the City received a written response from the NWMO as well as a copy of a similar letter NWMO sent to the CANHC (see Attachments 3 and 4). Both letters complimented the peer review work done by ASL, and thanked the CANHC, the City and Clarington for providing comments on NWMO's Discussion Document. The NWMO letter to the City also provided some assurance that community impact was a matter the NWMO would be addressing further as work progressed. The NWMO also commented on the matter of public consultation, and concurred with the importance of engaging local citizens in the work that they are conducting. The City was invited to provide input on how to improve the public consultation process in the future. Arrangements will be made with the NWMO to discuss this matter further. Report CAO 01-05 Subject: NWMO Discussion Document 2 Date: Januaw 17,2005 Page 4 Attached to the NWMO letter to CANHC was a table that provided comments on the key points raised by ASL in their peer review report. Like the comments that were directed specifically to the City's preliminary submission, NWMO acknowledged the value of receiving constructive input on Discussion Document 2. Their response answered some of the ASL questions and provided some of the information that was requested. In several cases, NWMO concurred with process improvements that were suggested by ASL. In summary, it would appear that the peer review activities that were recently completed have had merit, and that additional peer review funding should be provided by NWMO to CANHC to ensure the member municipalities can continue, to contribute to the process. The next phase of NWMO's work is critical, in that it will involve the completion of a number of studies of importance to the City leading up to the release of the Draft Final Report in the second quarter of 2005. That work will include issues associated with impacts on existing host communities and the potential for benefits if on-site storage is chosen. The NWMO final recommendation on a preferred long-term storage solution for Canada's nuclear high-level waste is due in November 2005 and will be forwarded to the Federal Minister of Energy for consideration. For Council's information, other Durham municipalities have provided comments to the NWMO with respect to this matter. Many of these comments are consistent with the positions put forward in this Report. However, City Council should be made aware that Regional Council has previously advised NWMO that it opposes the long-term storage of nuclear waste at existing reactor sites. Also, a staff report to Regional Council on Discussion Document 2 is under preparation, and we understand that it will again reiterate this position. Council should also be aware that both Clarington and the Town of Ajax have advised NWMO that they do not support the option of long-term storage at the existing reactor sites. To our knowledge Kincardine has not yet provided a response to NWMO. Attachments: 1. Executive Summary, Peer Review of Discussion Document 2, Understanding the Choices, prepared by Acres - Sargent & Lundy, December 2004. 2. Letter from Acting CAO to NWMO dated December 20, 2004. 3. Letter from NWMO to the Acting CAO dated January 10, 2(;)05. 4. Letter from NWMO to CANHC dated January 10, 2005. Report CAO 01-05 Subject: NWMO Discussion Document 2 Date: January 17, 2005 Page 5 Prepared By: Coordinator Approved / Endorsed By: Everett Buntsma (Acting) Chief Administrative Officer EB:alh:tem Attachments Copy: Chief Administrative Officer pR~cCk°m mended~' ~ n~rati°n °'1e~~ Thomas J.~3uinn C~iief Administrative Officer Nuclear Waste Management Organization Independent Peer Review of NWMO Discussion Document 2, "Understanding the Choices" Prepared for Canadian Association of Nuclear Host Communities SL-008414 December 2004 Acres-$&l. 55 East Monroe Street Chicago, IL 60603-5780 USA SL-OOg414-final.doc Project 11769-010 IATTACHMENT#I ..... TO REPORT s[-oo84 4 2. EXECUTIVE SUMMARY 2.1 OVERVIEW The NWMO was established under the Nuclear Fuel Waste Act (NFWA) to investigate approaches for raanag[ng Canada's used nuclear fuel. The Nuclear Fuel Waste Act requires the NWMO to recommend a preferred management approach to the Government of Canada by November 15, 2005. The NWMO will then implement the approach chosen by the Government. In order to provide an overview of used nuclear fuel and related issues in Canada, Appendix B contains nine fact sheets developed by the NWgMO that address topics such as the NWMO organization, what is "used nuclear fuel," the Canadian nuclear :regulatory framework, and the NWMO study process, among others. As noted in the NWMO's Fact Sheet 9, "The NWMO Study Process," the NWMO has committed to "develop collaboratively with Canadians a management approach that is socially acceptable, technically sound, environmentally responsible, and economically feasible." The NFWA requires that the following three main management approaches must be studied: deep geological disposal, storage at nuclear reactor sites, and centralized storage. Other methods may also be considered. To undertake the study, the NWMO has "adopted an iterative study process, undertaken in phases to allow information, analyses, and thinking to be considered in a staged manner." Discussion Document 2 was developed and issued as part of this iterative and open process to summarize the progress so far and the next steps the NWMO is taking to arrive at its recommended management approach. ASL performed a broad review of Discussion Document 2 with the overall objective of identifying questions that are not currently being asked by either the NWMO or others reviewing the NWMO's process. The intent of the review was to identify key issues and areas that we recommend CANHC focus on as NWMO continues in their process. 2.2 RESULTS Discussion Document 2 is a high level document that contains a broad summary of the NWMO's activities since Discussion Document 1 was issued. As a summary document, it contains a significant number of references to other NWMO documents that address the topics and issues related to developing the recommendation for which management approach the Canadian government should use. These references are generally located on the NWMO web site. Appendix C provides the current site map of NWMO's web site for SL-008414-final.doc/121304 Project 11769-010 IATTACHMENT# TO Hr:PORT# --o i SL-008414 Final reference. Appendix D contains a reference table developed by ASL in its review of Discussion Document 2 that lists the web sites referenced in the document along with the related files posted on the web. The current assessment framework is derived from the original ten questions discussed in NWMO's Discussion Document 1, "Asking the Right Questions," and consists of eight objective and associated guiding principles and influences. The framework was developed by a multi-disciplinary Assessment Team assembled by the NWMO to develop a comparative analysis of alternate approaches. The NWMO's Assessment Team based their work on the ten questions posed in Discussion Document 1 and on the NWMO's engagement with Canadians and ongoing research and analysis activities. The eight objectives of the NWMO's current assessment framework are as follows: · Fairness · Public Health and Safety · Worker Health and Safety · Community Well-Being · Security · Environmental Integrity Economic Viability · Adaptability Based on the updated framework, the NWMO Assessment Team performed a comparative analysis of the three main management approaches by systematically comparing the approaches against the objectives using a multi- attribute utility analysis. The NWMO Assessment Team's report was issued in June 2004 and forms a significant basis for the information presented in Discussion Document 2. The NWMO has performed significant engagement activities and actively solicited a wide range of input on its work. The NWMO's engagement activities were designed to establish an informed dialogue with a wide range of stakeholders, ranging from the Canadian public at large to governments, business interests, and interested individuals. The NWMO has developed conceptual designs, cost estimates, transportation requirements, and preliminary project timelines for each of the main management approaches; these can be accessed on NWMO's web site as SL-008414-final.doc/121304 Project 11769-010 I ATTACHMENT# I TO REPORT 2-3 ~[~ SL-008414 ~,,"~ ~,,~,,,,, ............... ~.A,~..I'~_$ -"~_~.~, ~:L, Final noted in Appendix D. The conceptual designs and cost estimates are intended to provide sufficient detail to confirm the engineering feasibility of the management approaches to support the current phase of the NWMO's study, which is appropriate. The NWMO has arranged for independent reviews of these technical evaluations. The NWMO noted in Discussion Document 2 that these third-party reviews concluded that the designs are reasonable and feasible, that the cost estimates have been prepared in accordance with appropriate estimating methodology, and that the technical information as a whole is suitable for the options review and directional decision-making requirements of the NWMO. Based on the conceptual designs and cost estimates, the Assessment Team analyzed each of the three main management approaches within the current assessment framework. The resulting relative strengths and weaknesses of each approach is summarized in Figure E-1 (starting on page 7) in Discussion Document 2's Executive Summary (provided in Appendix F of this report to facilitate reference). The relative strengths and weaknesses are discussed in more detail in Section 4.3.2 below. The Assessment Team's report notes that the overall management of spent fuel in Canada is politically complicated. Under the Canadian constitution, energy policies and land management that involve the production of spent fuel are responsibilities of the provincial governments, while management of radioactive materials is the responsibility of the federal government. Discussion Document 2 notes that the NWMO will be focusing on implementation plans as their study moves forward and that implementation is a critical part of making a recommendation. The NWMO notes that the development of implementation plans will include, at a minimum, consideration of the following elements: · Oversight and monitoring systems · Ongoing societal involvement · Institutional design, including human resource capacity · Ownership and liability · Dispute management · Principles to guide site selection; and · Education and information programs. The NFWA states that the selected management approach will be implemented by the NWMO "subject to all of the necessary regulatory approvals." Discussion Document 2 contains implementation timelines for each of the SL-008414-final.doc/121304 Project 11769-010 . TO REPORT acres- a . three main management approaches. Siting and approval for each of the approaches is a critical element of each of the timelines. The NWMO has started to assess the regulatory framework within which the selected approach will be implemented. 2.3 KEY ISSUES AND RECOMMENDATIONS ASL identified several issues and corresponding recommendations during its independent peer review as summarized in the table below. The detailed results and discussion of these issues is presented in Section 4. Table 2-1 -- Issue and Recommendation Summary Issue Recommendation Assessment Framework Although the Assessment Team's report provides alternate weightings of the different overall objectives, it does not provide the weightings for the specific influence variables associated with each objective. As a result, ASL cannot determine how balanced the assessment framework is. The Assessment Team report notes that a practical strategy for implementing an overall management approach must take the political climate into account, and that this factor is outside the scope of the Team's assessment. The Assessment Team notes that "The assessment suggests it will be necessary to ensure.., that contingency plans are known and available should they be required, at least for the period in which active management of the waste is needed to ensure safety." The Assessment Team's report presents the results of their analysis in the form of composite scores, and does not seem to consider fatal flaws (that is, an issue or problem that would exclude a particular option from further consideration). The NWMO has not systematically engaged with groups that focus and represent public opinion, such as nuclear awareness groups or environmental groups. These groups may have specific agendas that may be counter to the NWMO's ultimate objective to implement a management approach once the Canadian government makes a decision based on the NWMO's recommendation. The NWMO should provide explanations of how political climate, contingency planning, fatal flaws, and relative importance of the objectives and specific influence variables were considered, so that it is possible in future work to confirm and evaluate the overall balance of the assessment framework. The NWMO should specifically solicit input from groups that focus and represent public opinion. In addition, or alternatively, the NWMO should develop an assessment of the positions of these groups, the influence they may exert on the process, the impact this influence could have on the recommended management approach, and what can be done to gain their input or otherwise address their positions. SL-008414-final.doc/121304 Project 11769-010 IATTACHMENT #. I TO REPORT Acres-$&L 2-5 SL-008414 Final Issue Recommendation There ~s a conflict between the desire of some stakeholders to "keep an eye on the waste" versus the scientific community's general preference for deep geological disposal. For example, a reactor site storage (or, to a more limited extent, centralized storage) keeps the issue and societal costs of nuclear waste more visible, and so provides an impetus for reducing the generation of this type of waste. A comparison was made to trash along the side of a road: if disposed in a landfill and out of sight, there is less of a constant reminder of the overall costs associated with creating the trash. This perspective would not necessarily be addressed by a technically focused comparative analysis and could significantly affect the current host communities due to its bias towards reactor site storage. The used nuclear fuel is retrievable in the two storage approaches, but by design is not retrievable in the deep geological disposal approach after the site is decommissioned. Discussion Document 2 does not fully address this issue, nor is it fully addressed in the Assessment Team's report, "Assessing the Choices." The NWMO study should ensure (1) that the conflicting desires of some stakeholders to keep the issue of used fuel visible versus the scientific community's general preference for deep geological disposal are given proper weight, (2) that the technical details of the selected management approach address this issue, and (3) that broader social values and motives (such as keeping used fuel disposal highly visible in order to highlight the issue) are considered. As part of the engagement process, the NWMO should consider establishing focus groups to identify specific concerns that people may have with "keeping an eye on the waste" (i.e., technical or social) to support fully addressing this issue. The NWMO should more fully address the issue of retrievability as it develops more detailed comparative analyses. Management Approaches Any changes to the weighting of the different objectives and corresponding factors used in the ongoing comparative assessment process will affect the relative strengths and weaknesses. The site selection process for deep geological disposal does not include as a limitation the challenges associated with establishing the geological suitability of potential sites. This issue is an ongoing concern in the United States with the Yucca Mountain project. There appears to be a discrepancy in the advantages and limitations relative to the objective for Adaptability. For example, Adaptability was noted as being a weakness of deep geological disposal. However, the deep geological disposal approach had the same or higher performance value score compared to the other approaches in the analysis of Adaptability. Potential changes in the relative strengths and weaknesses should be reviewed as the comparative analysis process continues. Consideration should be given to the effect associated with confirming the technical suitability of potential sites (such as schedule delays and cost impacts). This discrepancy should be clarified or otherwise resolved as the comparative analysis process continues. SL-008414-final.doc/121304 Project 11769-010 IATTACHMENT# I , TO REPORT# ,-- I .......... ~ 2-6 ~[~ SL-008414 '-- Acres-S& Final Issue Recommendation The relative strengths and weaknesses of the different management approaches as discussed in Discussion Document 2 do not provide an indication of how they might be affected by potential technical changes. Social effects on communities and siting issues are not mentioned in the limitations for reactor site storage even though the current host communities were not selected based on their suitability for extended storage. The analysis notes technical limitations for at-reactor storage (such as proximity to large bodies of water), but does not note any social disadvantages. Discussion Document 2 does not discretely analyze the impacts of the separate management approaches on the current host communities. The strengths and weaknesses noted by the NWMO in Discussion Document 2 do not mention or appear to account for a comparative assessment of the risks related to the different approaches. The comparative risks include both technical risks (such as the impact of postulated accidents) and financial risks (such as changes in the assumed discount rates used in the financial models). The sensitivity analyses conducted as part of the NWMO's ongoing comparative analysis process should consider changes in key technical assumptions. (It should be noted that the Assessment Team's sensitivity analysis addresses broader changes in future conditions; this recommendation is intended to apply at more of a technical design level.) The ongoing comparative analysis should specifically assess the overall impact of the selected management approach on the current host communities to ensure that they are afforded the same considerations and potential benefits as new host communities. Relative technical and financial risks should be identified and considered during the ongoing detailed comparative assessments that the NWMO is currently performing. Implementation Plan Background paper 7-8 notes that any proposal to postpone a decision on a preferred long-term option would itself have significant implications and may be deemed worthy of a review panel. Many of the problems and delays in the implementation of major projects with significant environmental implications stem from the failure to correctly identify all the required permits and permit application requirements associated with a given project. The NWMO should ensure that the implementation plans developed for the separate management approaches include comprehensive and specific permitting schedules that define which permits are required, when they are required, how long it takes to apply for and obtain them, and who has to make the application. Possible conflicts or uncertainties regarding the legal jurisdiction of different government agencies should be identified. SL-OO8414-final.doc/l 21304 Project 11769-010 I I ATTACHMENT # I TO REPORT I ................ 2-7 SL-008414 Acres-$&L Fina! Issue RecOmmendation Problems and delays can also stem from determined opposition from one or more stakeholders (such as environmental groups or elected officials) when the EA and applications are reviewed. It should be noted that technical issues (engineering, conceptual designs, etc.) or costs are frequently not the critical parameters that determine a project's success or failure. The assessment performed by the Assessment Team is not specific with respect to the choice of economic region for a centralized storage facility or geologic repository. The NWMO's ongoing efforts will focus on developing characteristics that would be appropriate in choosing specific economic regions for deep geological disposal and centralized storage approaches. As the implementation plans are developed, the resulting details could affect the comparative assessments of the different management approaches performed up to that point. Although a phased approach is reasonable and has significant advantages, in ASL's experience, it has the potential of negatively affecting the overall effective implementation of a project. ASL's earlier recornmendation about the need to engage groups that focus and represent public opinion should be pursued in recognition that they may provide valuable information for the NWMO's implementation plans in terms of identifying potential opposition, assessing the primary concerns of potential opponents, and developing mitigation measures to address these concerns. In addition to supporting site selection, the NWMO should ensure that site-specific issues and considerations are identified and addressed within the associated implementation plans. The NWMO should ensure that the comparative assessments are updated and re-evaluated as required to be consistent with the planned irnplementation details. The NWMO should ensure that the overall project implementation plans include key project milestones where "go - no go" decisions are made, as well as points where designs are finalized, or "frozen," to enable the project to proceed with minimal potential for design changes. To be able to capitalize on new technical or other advances, the design parameters associated with the selected management approach should be developed and selected to maximize overall system flexibility. Last page of Section 2. SL-008414-final.doc/121304 Proj oct 11769-010 PICKERING i AT']'ACHMENT# TO J Picketing Civic Complex One The Esplanade Picketing, Ontario Canada L1V 6K7 Direct Access 905.420.4660 cityofpicketing, com OFHCE OF THE CHIEF ADMINISTRATIVE OFFICER Department 905.420.4648 Facsimile 905.420.6064 cao@city, pickering, on.ca December 20, 2004 Liz Dowdeswell President Nuclear Waste Management Organization 49 Jackes Avenue, First Floor Toronto, ON M4T 1E2 Subject: Discussion Document 2, Understanding the Choices Preliminary City of Pickering Comments File: S-5610-011 On behalf of the City of Pickering, I would like to thank you and the Nuclear Waste Management Organization for providing funding for peer review consulting services to the Canadian Association of Nuclear Host Communities (CANHC). The consulting team of Acres-Sargent & Lundy (ASL) have greatly assisted the CANHC member municipalities in developing comments on Discussion Document 2, Understanding the Choices. I am writing to you to provide a set of Pickering preliminary comments on Document 2 so as to meet the NWMO December 31, 2004 deadline. Please find enclosed a CD containing the Final Report and supporting documents that ASL provided to the CANHC. The following preliminary comments will be incorporated into a report that will be presented at the Pickering January 17, 2005 Council Meeting. NWMO will be notified, in writing, of the results of that Meeting. We agreed with Acres-Sargent & Lundy (ASL) that Document 2 is "reasonable and appropriate and supported by the reference documents..." ASL has identified several "potential gaps" in the assessment framework and offered what seem like reasonable recommendations for NWMO to consider in the future. ASL recommended, "host communities be afforded the same considerations and potential benefits as new communities." We support ASL's recommendation and their comments. NWMO needs to more specifically address issues, related to the potential negative impact that long-term on-site storage might have on current nuclear host communities. In addition, NWMO should identify and report on the positive social and economic impacts that host communities might face. ASL drew our attention to the following wording in the NWMO Assessing the Options report: "The siting policy may also include benefits to a host community to compensate that community for taking on the burden associated with used nuclear fuel wh/le a Understanding the Ch A CHMENT TO REPORT -Preliminary City of PicKenng L;omments December 20, 2004 Page 2 much wider population shares the benefit." We agree with that statement and will actively address that matter in future submissions to NWMO. ASL highlighted the fact that the NWMO background paper 7-8 suggested that "any proposal to postpone a decision on a preferred long-term option would in itself have significant implications and may be deemed worthy of a review panel' environmental assessment (EA). We agree with that suggestion and further suggest that the On-site Reactor Storage option should also require a panel review EA as is contemplated for the other two options under consideration for long-term storage. Treating on-site storage in any other way would simply be inappropriate and unfair to the existing host communities. ASL recommended that NWMO specifically "engage nuclear awareness and environmental groups" as part of the public consultation process. We agree with their rationale and supporting arguments for that suggestion. Although ASL has briefly addressed the overall process of public consultation in their Report to CANHC, we would like to further comment on the Iow attendance count that NWMO has experienced while recently conducting four sessions in Picketing. Our observations indicate that more work is needed to inspire Picketing and area residents to become involved in the work that NWMO is undertaking next year. Once again, thank you for supporting our efforts to comment on the NWMO Discussion Document 2. The City of Pickering looks forward to reviewing and commenting on NWMO's work during 2005. Being afforded the opportunity to obtain peer review consulting services next year will again be essential to our success in providing meaningful input on this very important topic. Yours truly/,., EB:alh Enclosure Copy: Everett Bun' (Acting) Mayor Ryan Members of Council Chief Administrative Officer Division Head, Corporate Projects & Policy City Clerk Community Emergency Management Coordinator CANHC member municipalities Administrative Officer ,., TO REPORT NUCLEAR WASTE SOCI~T~ DE GEST!ON MANAGEMENT DES DECHETS ORGANIZATION NUCL~-AIRES January l O, 2005 Liz DowdE Tel 416.9 ;well PRESIDENT 4.9814 ext 222 ~vdeswell@nwmo.ca Mr. Everett Buntsma Chief Administrative Officer (Acting) City of Pickering One The Esplanade Pickering, ON L1V 6K7 Dear Mr. Buntsma: RE: Preliminary City of Pickering Comments to Acres-S&L review of the NWMO Discussion Document 2: "Understanding the Choices"- Letter dated December 20, 2005 Thank you for your timely response with the City of Pickering's preliminary comments to the Acres-S&L review of Discussion Document 2: "Understanding .the Choices." The viewpoints of the citizens of current host communities are important to the NWMO in its ongoing study. The attached letter sent to Mayor Glenn Sutton, Chair of the Canadian Association of Nuclear Host Communities, and copied to the mayor of each of the member communities comments generally on their recommendations. That will, I believe, address a number of the points raised in your letter. In particular, you will note specific reference to further work on assessing the costs, risks and benefits to communities affected and the development of implementation plans. When the government has made a decision about the approach, any project would of course be subject to an environmental assessment, during which there would again be opportunity for citizen engagement. In regards to the low attendance at the recent Information and Discussion Sessions in Pickering, we believe that citizens in nuclear host communities and provinces have unique insights about nuclear waste management. We will therefore continue to provide opportunities for their active involvement in the work of the NWMO. Any suggestions you have with respect to engagement activities to be implemented following publication of our Draft Study Report this Spring, would be welcomed. Fax 416.934.9091 'Foil Free, 1.866.249.6966 49 Jackes Avenue First Floor Toronto Ontario Canada M4T1E2 www.nwmo.ca Thank you again lbr your comments, l look forward to the response of the Pickering City Council following their meeting on January 17, 2005. Yours truly, Elizabeth Dowdeswell President Enclosure wmo I ATTACHMENT# , January l0,2005 Mayor Glen Sutton Town of Kincardine 1475 Concession #5, RR #5 Kincardine, ON N2Z 2X6 Dear Mayor Sutton: RE: Acres-S&L Report for CANHC "Independent Peer Review of NWMO Discussion Document2, "Understanding the Choices" I have received a copy of the Acres-S&L Report "Independent Peer Review of NWMO Discussion Document 2, "Understanding the Choices" prepared for the Canadian Association of Nuclear Host Communities. I have also received individual comments from the municipalities of Clarington and Pickering which I understand are in the process of being forwarded to their respective councils in the next few weeks. Our Discussion Document 2 was intended to spark exactly this kind of thoughtful commentary and I certainly look forward to any additional comments that may be forthcoming from CANHC and each member community. Since we issued Discussion Document 2 we have completed significant additional work. Consequently, I thought it might be helpful to make a few general comments on the recommendations of the Acres-S&L Peer Review. (See the attached table.) You might find this of use in assessing their observations and recommendations. Please let me know if we can be of further assistance in clarifying points. We will appreciate your continuing comment and collaboration as we synthesize all of the inputs to our study and prepare our Draft Study Report for release in the Spring. Sincerely, Elizabeth Dowdeswell President CC. Maire Maurice Richard, Town of B6cancour Mayor Norm McFarlane, City of Saint John Mayor John Mutton, Town of Clarington Janice Swarz, Municipality of Clarington Mayor Ann Aikens, Town of Deep River Mayor David Ryan, City of Pickering Mayor Len Simpson, Town of Pinawa Tom Melymuk, City of Pickering 1.866~249,59~5 nwtTl© IATTACHMENT # q TO REPORT Assessment Framework AgL Recommendation Comment The NWMO should · There are approximately 240 influencing factors that have been considered provide explanations of under the eight objectives in this assessment, an average of 30 per objective. how political climate, Reviewing these factors will allow you to assess whether or not all of the contingency planning, fatal important factors have been considered. The Assessment Team built its flaws, and relative assessment framework and provided its assessment as an application example, importance of objectives not as the definitive assessment. In making it public as we have, our desire is and specific influence that others are able to think through the factors on their own and from that, and variables were considered, we can learn about the relative importance of the factors. Doing so will so that it is possible in strengthen the assessment. future work to confirm and evaluate the overall balance · The issue of whether there is a threshold of performance below which a of the assessment management approach becomes unacceptable is not addressed in depth and framework, directly, per se, in the Assessment Team's work. Conceivably, it is possible that a management approach may score low on an objective but still be considered a good approach because performance, on that objective is not deemed critical. If an approach scored very highly on all eight objectives the interpretation would be clear: since the management approach meets all the objectives which Canadians said is important, the management approach meets the needs of Canadian society and so is a good approach. However, none of the management approaches ideally meets all of the objectives. Therefore a judgement needs to be made, and it is suggested that this is ultimately a societal judgement, as to whether the mix of advantages and limitations of an approach is sufficient to warrant implementation. The NWMO should solicit · From the inception of its study, NWMO has engaged Canadians from a wide input from groups that variety of citizen and expert based groups. Face to face meetings were held focus and represent public with many of these groups at the inception of the study as part of our opinion. (This point is "conversations about expectations." Feedback on NWMO's first discussion repeated by ASL under "3. document was solicited by engaging many of these groups in a series of Implementation Plans.") national and regional stakeholder dialogues, a process which is being repeated to solicit comment on NWMO's second discussion document. The NWMO continues to meet with many of these groups to brief them on our work and to solicit comment on an ongoing basis. Several of these groups have also participated in other NWMO initiatives (such as the Scenarios Exercise, E- dialogues, Traditional Knowledge workshop, Public Information 8: Discussion sessions) or posted submissions. This engagement will continue until our final report is submitted. The NWMO should ensure · The NWMO understands that for many Canadians the question of how best to (1) that the conflicting manage used nuclear fuel in the long term is one which must be viewed within a desires of some broader context, whether that is support or opposition to nuclear power, stakeholders to keep the concerns about the environment, or industry jobs. This is in part why NWMO issue of used fuel visible attempted to engage stakeholders in a discussion of values. We believe that 416.93~.9~t4 ;:~: 416,934,95,26 1.866.249,6966 I ATTACHMEN'r#_M- TEl REPORT nwmo versus the scientific values are instrumental in determining objectives against which the community's general management approaches would be assessed finding common ground. Since preference for deep social acceptability is a concem in any recommendation the NWMO will make geological disposal are all of these perspectives must be considered. given proper weight, (2) that the technical details of the selected management approach addresses this issue, and (3) broader social values and motives (such as keeping used fuel disposal highly visible in order to highlight the issue) are considered. Use of focus groups. · The NWMO has used focus groups to explore various issues over the course of the study to date and appreciates your suggestion on further opportunities to use this tool as we move forward with the study. We will be addressing ongoing public engagement in our recommendation to government. Retrievability. · This is an important issue and will be fully addressed in our recommendation to government. 2. Management Approaches ASL Recommendation Comment Potential changes in the · The sensitivity analysis that has been undertaken by the Assessment Team relative strengths and suggests that only extreme changes in weightings change the overall results of weaknesses should be their analysis. Through our ongoing work on the comparative assessment, we reviewed as the are continuing to understand the range of strengths and weaknesses of each comparative analysis approach, however as you suggest, we will be revisiting this issue as our work process continues, proceeds. Consideration should be · The possibility of schedule delays and cost ovemtns has been considered but given to the effect we will revisit this point. It is an important consideration in the identification associated with confirming of schedules for implementation, implementation plans and cost estimates the technical suitability of associated with each approach. potential sites (such as schedule delays and cost impacts). Adaptability. · This point has caused confusion for a number of people. The Assessment Team is preparing a clarification note and we will be further dealing with this issue in our Draft Study Report. The NWMO expects and welcomes further dialogue on this issue, since it is such an important issue from the public perspective and 416.93tl.9514 416.934~9526 I A'I'I'ACHMENT TO REPORT wmo will be key to the acceptability of any approach which the NWMO recommends. Sensitivity analysis · We are considering the issue of variation of fuel volume and will address this addressing technical issue more thoroughly in our Draft Study Report. The question of how to changes (cost or design ensure that any recommendation the NWMO makes is robust is a matter of parameters such as fuel continuing investigation and work. volume). Impact on current host · From the inception of our study, citizens and communities alike told us how communities important the perspective of current host communities is in understanding the issues and identifying appropriate solutions. The observation made will receive further consideration in our Draft Study Report. Relative technical and · As required by the legislation, we are currently undertaking a comprehensive financial risks, review of costs, benefits and risks as a supplement to the work of the Assessment Team. The results of this analysis will be reported in our Draft Study Report. 2. Implementation Plans ASL Recommendation Comment Inclusion of permitting · Discussion Document 2 did not articulate detailed implementation plans. These schedules; possible will form a key component of our Draft Study Report. We appreciate all of the conflicts or uncertainties suggestions made below and will address them specifically in the next report. regarding the legal jurisdiction of different government agencies Inclusion of site-specific · It should be reinforced that our study will not select a site. Nevertheless, we issues and considerations anticipate addressing site specific issues in a generic way in proposing how our recommendations might be implemented effectively. Ongoing up-dating of the · This will be addressed in our Draft Study Report. comparative assessment Inclusion of key · Such points are essential and will be included in our draft recommendations. milestones, go-no go decision points, design finalization points Development of design · This point will be addressed in our draft recommendations. parameters to maximize overall system flexibility. 416,93~k~814 416.934,9526 www.nwmo.~;a