Environmental Protection Program

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Deep Geologic Repository Project for

Low- and Intermediate-Level Waste

Proposed by Ontario Power Generation Inc.

October 29, 2013

PMD 13-P1.3I

CNSC Staff Presentation

e-Doc 4217306 (PPT) e-Doc (PDF)

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Presentation Outline

• Environmental Protection Program Requirements • Environmental Protection Program – DGR Project

– Stormwater Management Pond – Groundwater Monitoring

– Baseline for surface water and aquatic biota – Noise monitoring and mitigation

• EA Follow-up Monitoring Program

• CNSC Independent Environmental Monitoring Program

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Environmental Protection Program

Requirements

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Environmental Protection Framework

CNSC Environmental Protection Regulatory Framework has four main components:

Regulatory Instruments Environmental Programs, Policies and Procedures in a Licence Compliance Verification Support for Decisions

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Canadian Nuclear Safety Commission

Environmental Protection Framework:

Regulatory Instruments

• Legislation

– Nuclear Safety Control Act and Regulations – Canadian Environmental Protection Legislation • Memoranda of Understanding

– Federal (Environment Canada, Fisheries and Oceans Canada, Transport Canada)

– Provincial

• Standards and Regulatory Documents – CNSC Guidance and Regulatory Documents – Canadian Standards Association Standards

Regulatory Instruments Licensing and Environmental Programs, Policies and Procedures Compliance Verification Support for Decisions

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Environmental Protection and the Nuclear

Safety and Control Act (NSCA)

• Under the NSCA, two of CNSC’s responsibilities are:

– direct protection of the environment

– regulatory responsibility for hazardous substances in addition to nuclear substances

• The NSCA contains numerous references to protection of the environment. Key obligations are to:

– prevent unreasonable risk to the environment – make adequate provision for the protection of the

environment

– take all reasonable precautions to control releases of

radioactive or hazardous substances within the site of the licensed activity and into the environment as a result of the licensed activity

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Environmental Protection and the NSCA

• Environmental baseline characteristics of the site and the surrounding area

• Documentation of releases of nuclear substances and hazardous substances to the environment

• The proposed measures to control releases of nuclear

substances and hazardous substances into the environment

• The proposed measures to prevent or mitigate the effects…

• Information program to inform persons living in the vicinity … of anticipated effects on the environment and the health and safety of persons

• Environmental Protection Policies and Programs

• Effluent and environmental Monitoring Programs

The Regulations under the NSCA contain more specific requirements related to environmental protection

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• Environmental Protection

– Release Control and Monitoring – Environmental Monitoring • Safety Analysis – Environmental Risk Assessment • Radiation Protection – Public • Management System

– Environmental Management System

• Waste Management

Environmental Protection Framework:

Programs, Policies and Procedures

Regulatory Instruments Licensing and Environmental Programs, Policies and Procedures Compliance Verification Support for Decisions

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Environmental Protection Framework:

Compliance Verification

• Desk Top Assessments of:

– Adequacy of programs

– Annual Performance Reports • Inspections • Audits / Investigations – EMS audits – Special investigations • Independent Environmental Monitoring Program Regulatory Instruments Licensing and Environmental Programs, Policies and Procedures Compliance Verification Support for Decisions

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Example – WWMF Compliance

Verification Results

• CNSC conducted an Environmental Management System Audit at WWMF in 2006

• CNSC regularly assess the WWMF’s

Environmental Protection Programs through desk top reviews

– Quarterly Operations Reports

– Annual Incinerator Emissions Reports

• CNSC Inspections do not focus specifically on Environmental Protection but sometimes look at environmental issues

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Environmental Protection Framework:

Support for Decisions

CNSC Research and Support Programs

• Current with leading edge science and

policies

– IAEA and UNSCEAR

– Scientific and technical literature

Regulatory Instruments Licensing and Environmental Programs, Policies and Procedures Compliance Verification Support for Decisions

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Stormwater Management Pond: Design

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Stormwater Management Pond:

Design Criteria

• The stormwater management pond and its outlet structure is designed to:

– Ensure that peak flows during construction for various storm events do not exceed current peak flows in the existing site ditch leading to Lake Huron

– Safely convey the peak outflow rate associated with a 24-hour 100-year storm event

– Provide 24 hours of sediment settling time from stormwater runoff associated with 25 mm of rainfall in 6 hours

– Ensure that the average annual Total Suspended Solids concentration in the effluent does not exceed 40 mg/L

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Stormwater Management Pond:

Inflow Sources

• Surface runoff from

the site

• Onsite precipitation

• Runoff from

temporary waste rock

pile

• Runoff from

permanent waste

rock pile

• Pumping from shafts

and underground

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Waste Water Management:

Source Reduction and Treatment

• Source reduction techniques

– Ammonia reduced by best blasting techniques

– Saline groundwater treated with an evaporator

• Treatment

– Monitoring of pond water before discharge will determine the treatment technique

chosen

– Options prior to discharge include aeration and reverse osmosis

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Stormwater Management Pond: Discharge

• Discharge criteria are essentially provincial and

national water quality guidelines

• Compliance with the discharge criteria meets

section 36(3) of the

Fisheries Act

• CNSC and Environment Canada staff

recommend acute and chronic toxicity testing

before discharge (

Undertaking #47

)

• These tests will provide further assurance of

compliance with 36(3) of the

Fisheries Act

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Stormwater Management Pond:

Impacts on Wetlands and Groundwater

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Shallow to Intermediate Groundwater

Monitoring Network

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Intermediate and Deep Groundwater

Monitoring Network

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CNSC Staff’s Assessment of OPG’s

Groundwater Monitoring Network

• Information sufficient for Environmental Assessment and Licensing decisions

• Additional information to be collected if project proceeds:

– design an adequate groundwater monitoring well network that includes upgradient wells

– assess the migration of a tritium plume and its interaction with proposed shafts

– propose a contingency plan should the tritium plume reach the shaft before shaft collars are installed

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Baseline for Surface Water and

Aquatic Biota

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Baseline - Surface Water and Sediment

Quality

• Baseline information sufficient for Environmental Assessment and Licensing decisions

• Additional information being collected if project proceeds

– Additional baseline surface water and

sediment quality data at Un-named drainage ditch and MacPherson Bay

• CNSC staff recommend that OPG collect additional baseline sediment and water quality (CNSC

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Residual Effects on Water Quantity and

Flow

• Residual effects on water quantity and flow of the DGR Project

– 31% flow reduction (or 2.5 L/s) in the North Railway Ditch

due to drainage diversion to the SWMP

– 114% flow increase (or 12.2 L/s) in the un-named drainage

ditch emptying into MacPherson Bay during site preparation and construction

– 61% flow increase (or 9.2 L/s) in the un-named drainage

ditch emptying into MacPherson Bay during operation phase

• CNSC staff recommend that OPG verify EA

predictions on flow reduction in North Railway Ditch and Stream C (CNSC Recommendation #8)

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Aquatic Biota – Baseline

• Baseline data for the aquatic environment included recent field study results and

referenced existing data sources from the Bruce Nuclear site

• Additional quantitative fish and fish community baseline data, including lake whitefish in Lake Huron, were provided in response to Panel Information Requests

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Aquatic Biota – Effects

• No measurable changes to VECs in Stream C were predicted

• No measurable changes to VECs in Lake Huron and embayments were predicted as effluent

discharge meeting regulatory discharge criteria • The residual adverse effects on fish habitat loss

(< 1.6%) in the South Railway Ditch and disturbance of burrowing crayfish habitat

(0.01%) are determined not significant as the affected area is localized

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Lake Whitefish Monitoring at the Bruce

Nuclear Site

• Monitoring Programs in place at the Bruce

Nuclear site address the following areas:

– Population Structure & Thermal Stress

– Population Modelling & Intake Entrainment – Egg Survival Threshold Criteria

– Bruce A Refurbishment EA Follow-up Monitoring

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Aquatic Biota – Whitefish Results

Results:

• Impingement 9-year average of 135 lake whitefish but declining last five years reflecting lake-wide trends

• Spawning habitat mapped and multi-year adult spawner surveys showed lowest relative habitat use at

MacPherson Bay

Ongoing and Planned :

• Lake whitefish population spatial extent (genetics, diet, tagging)

• Effects of thermal plume on whitefish eggs

• Impingement and entrainment, analysis of winter

spawning habitat temperatures and biological data from adult spawners

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Aquatic Biota – Bruce Nuclear Site

Comprehensive Monitoring

• Offsite radiological Environmental Monitoring in human exposure pathways

• Fish Monitoring Programs record catches for all fish species (impingement, entrainment, angler harvest, scientific gill netting)

• Updated Bruce A and B Environmental Risk Assessment investigates all stressors

• Long-term monitoring of status of local indicator cold-water and warm-water species since

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Aquatic Biota – Interactions with Ontario

Ministry of Natural Resources

• Bruce Nuclear Site Sportfishing survey

design and analysis

• Lake whitefish fin clip monitoring at

reference sites

• Attend annual meetings whitefish research

and EA follow-up

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Noise

• Residual Socio-Economic Effect

– Reduced enjoyment of private property at Baie de Doré

– In-design mitigation planned

• Follow-up Monitoring Program

– Confirm predictions and mitigation measures

• CNSC relies on expertise from Health

Canada

– No recommendations from Federal Government beyond what OPG has

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EA Follow-up

Monitoring Program

(EA FUMP)

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Initial Scope of OPG’s EA Follow-up

Monitoring Program

• A follow-up program is mandatory under the

Canadian Environmental Assessment Act

(CEAA)

• Preliminary Follow-up Monitoring Program

plan was provided in the EIS

• Developed in accordance with CSA

standards, CNSC regulatory standards and

guides

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EA Follow-up Monitoring - Activities

• An EA follow-up monitoring activity is used to

verify a specific prediction or conclusion of the

EIS

• The monitoring activity:

– has a finite duration

– monitors or measures a specific effect or lack of effect

• The activity is to be discontinued:

– when the prediction has been confirmed – at the end of a pre-determined period

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Baseline Studies

• Baseline studies:

– provide a benchmark to test project effects – determine the need for additional

pre-construction or pre-operational monitoring

• Baseline data must be obtained prior to

construction

• Further baseline data may be required if

background data is found inadequate

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Development and Implementation of a

Follow-up Monitoring Program

Review/Revise the Preliminary EA FUMP

Develop preliminary sampling plan consistent

with CSA Standards

Review EA FUMP with FAs and other regulatory bodies

Review EA FUMP with stakeholders

Accept EA FUMP

Report on EA FUMP, as required

Develop detailed sampling plan consistent with CSA

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Example – Development and Implementation

of a Follow-up Monitoring Program (cont’d)

Step 1: Review/Revise the Preliminary

EA FUMP

• OPG in consultation with CNSC

• Table 12.2-1 of the EIS outlines the proposed

monitoring by project phase, objective, frequency and location

• CNSC staff recommended additional follow-up program elements in PMD 13-P1.3

• OPG will be required to update the initial table with any recommendations made by the Panel, if the project is approved

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Example – Development and Implementation

Step 2: Develop preliminary sampling plans

consistent with CSA Standards

• To be conducted by OPG

• CSA standards provide the overall guidance for design and implementation of monitoring

programs

• Detailed design will be determined once program is accepted (number and specific location of

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EA FUMP Step 2 Example –

Atmospheric Environment

• CNSC Recommendation #14: CNSC staff recommend that OPG monitor NOx (nitrogen oxides) and

particulates as part of the EA FUMP to confirm predictions of the EIS

Monitoring

activity Monitor air quality

Objective Confirm predictions, mitigation and effect

Criteria EIS maximum predictions

Frequency

Continuous monitoring, log hourly averaged recordings, Data will be downloaded quarterly

Duration Site preparation and construction phase

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Example – Development and Implementation

Step 3: Review EA FUMP with federal

authorities and other regulatory bodies

• To be conducted by CNSC

• CNSC will coordinate with the federal and provincial authorities

• A federal authority may assist in the design of a follow-up program and the review of the data obtained

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Example – Development and Implementation

Step 4: Review EA FUMP with identified

stakeholders

• To be conducted by CNSC

• Appropriate stakeholders to be identified based on past CNSC practice

• Consultation could include:

– receiving comments through the CNSC website and direct mail outs

– holding technical meetings with interested parties

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Example – Development and Implementation

Step 5: Accept EA FUMP

• To be conducted by CNSC • As per Licence Condition 1.2

– Documents that require acceptance by CNSC staff

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Example – Development and Implementation

Step 6: Develop detailed sampling plans

consistent with CSA Standards

• To be conducted by OPG • Elements to be considered:

– Objectives

– Information required to meet the objectives – Spatial and temporal boundaries

– Method and frequency of data collection

– Performance or acceptance criteria to be used – Implementation plan

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Example – Development and Implementation

of a Follow-up Program (cont’d)

Step 7: Report on EA FUMP, as required

• To be conducted by OPG

• EA follow-up reports to be submitted annually to CNSC

• Additional mitigation measures may be required if results of follow-up monitoring are not within EA predictions

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Summary

• Licence requirement for EA Follow-up

Monitoring Program

• Review and acceptance by CNSC staff

required before licensed activities begin

– Federal, provincial and stakeholder

involvement in the review process

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Independent Environmental

Monitoring Program

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Overview and Objectives

• In 2012, CNSC initiated an Independent Environmental Monitoring Program (IEMP) • The objectives of the IEMP are to:

– assess the level of risk on the health and safety of humans and the environment from contaminants and physical stressors of concern

– independently verify licensee’s environmental performance

– post the environmental data on the CNSC Web site

• These objectives will be achieved independently of licensees’ EA monitoring programs

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CNSC IEMP Development Process

• Developed based on guidance found in CSA standard N288.4-10

• US EPA Guidance on Systematic Planning Using

Data Quality Objectives Process will be used to

develop performance and acceptance criteria • Individual sampling plans for each facility were

designed based on:

– licensees approved Environmental Monitoring Programs

– Environmental Risk Assessments

– licensee environmental performance – issues of public concern

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Systematic Planning Process for the

Development of the IEMP

Each sampling plan is being developed using a

systematic planning process:

1. Describe study objectives

2. Identify information required to meet objectives 3. Define boundaries of the IEMP and

site-specific sampling plans

4. Develop data collection and analytical approaches 5. Specify performance / acceptance criteria

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Stakeholder Involvement

• To date, CNSC staff have not had direct

involvement with stakeholders in developing

sampling plans

• Consideration of parameters that have been

brought up during public hearings have been

taken into account

• CNSC staff will hold meetings with communities

to identify public concerns to incorporate the

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Example - 2013 Bruce Power Sampling

Campaign

• Samples of air, soil, grass,

surface water, local

produce, milk, fish, and meat were obtained

• Sample locations included

publically accessible areas such as beaches and

parks. Both near field and reference sites were

considered

• Laboratory analysis will

measure tritium,

Carbon-14, radioactive iodine, gross gamma and gross beta

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Objectives

• Confirm sub-surface geological and

geotechnical conditions

• Verify and complete the details of the

DGR design

• Support DGR Safety Case

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Verification Activities and Timing

• OPG proposed geoscientific verification activities: – Geological Characterization – EDZ characterization – Excavation response – In situ stress measurement – Geochemical and microbiological characterization – Sealing material demonstration

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Verification Activity – Geological

Characterization

• Geological Characterization (geological mapping and geophysics)

– Verify stratigraphy and geological structures – Characterize the rock mass

– Provide a permanent record of rock structure and quality

– Optimize the ground support

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Verification Activity – EDZ Characterization

• Objectives:

– Characterize and verify the extent and evolution of the EDZ – Obtain some

geomechanical

properties of the EDZ – Characterize EDZ

permeability

• Phase: construction, operation, and

decommissioning

Proposed borehole configuration for EDZ characterization

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Verification Activity – Excavation Response

and Up-scaling Geomechanical Testing

• Objectives:

– Monitor rock response to the excavation of the shaft and lateral

openings to confirm their stability

– Confirm DGR

excavation design – Verify the rock mass

properties

– Confirm shaft liner design and optimize ground support

• Phase: construction

Deformation array in shaft

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Verification Activity – In-situ Stress

Measurement

• In situ stress measurement by overcoring and under-excavation tests to: – Verify estimates of the in situ stresses – Verify the design of

the repository level openings – Inform layout modification • Phase: construction

Under-excavation test Overcoring measurement

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Verification Activity – Geochemical and

Microbiological Characterization

• Purpose:

– Verify the geochemical characteristics and ages of mineral infill

– Verify the geochemical characteristics of groundwater

– Verify estimated rock matrix diffusion coefficients – Verify multiphase flow and transport properties and

mechanisms

– Characterize microbial activity and its influence on DGR performance

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Verification Activity – Seal Performance

• Sealing material

demonstration, in support of the safety case

– Demonstrate long term hydraulic, structural and chemical performance of the sealing materials – Study seal interaction

and compatibility with the rock mass and its EDZ

• Phase: construction and operation and beyond if necessary

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CNSC Review of the Proposed

Geoscientific Verification Plan (GVP)

• OPG has adequately planned the verification activities needed to achieve the objective of the GVP

• The verification activities would address or reduce uncertainties associated with geoscientific aspects of the DGR and the DGR safety case

• The plan does not contain the details of all verification activities with respect to contents, methods, equipments, schedule, and procedures

• A detailed geoscientific verification program would be developed and submitted to CNSC for review and

acceptance if the project is approved

• CNSC has made several recommendations that are related to the verification activities

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DGR Safety Case Update

• During the DGR Construction Phase

– Results from the GVP will be compared with the conditions in the bounding scenarios of the safety assessment

– Where the results are less conservative, the effect on safety will be assessed

– Where the effect is significant, the DGR safety case will be updated

• For an Operating Licence for the DGR

– The DGR safety case will be updated with the results from the GVP collected during construction

– DGR safety case will be updated at each operating licence renewal or when there is a proposed change to the licence that affects the safety case

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CNSC Compliance Verification Program

• If the DGR is licensed to proceed, CNSC staff will as part of the compliance verification program:

– verify the acceptability of the technical program for implementing the GVP

– monitor the licensee’s implementation of the GVP through the construction phase

– verify that the repository level design adequately take into account the GVP results

– assess the GVP results and verify that they are within the bounds of the safety case

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CEAR 1655)

(Undertaking #47