Lake Huron Nuclear Waste Dump

[Oscar]

Feds punt nuke-waste bunker plan back to OPG

[ http://www.durhamregion.com/news-story/ ... ck-to-opg/ ]

April 7, 2017

TORONTO — A report affirming the shoreline of Lake Huron as the best place to bury radioactive waste failed to provide information the government had requested, federal environmental authorities say.

In a detailed letter and document sent to Ontario Power Generation, the Canadian Environmental Assessment Agency criticizes the utility's report as inadequate and asks it to try again — much to the delight of project opponents.

The impugned OPG report came after Environment Minister Catherine McKenna asked the utility in February last year for information on, among other things, the feasibility of burying the low or moderately radioactive waste elsewhere.

More . . . .

[Oscar]

About the Lake Huron Nuclear Waste Dump.

----- Forwarded message from Gordon Edwards <ccnr@web.ca> -----

Date: Tue, 11 Apr 2017 02:41:15 -0400
From: Gordon Edwards <ccnr@web.ca>
Reply-To: Gordon Edwards <ccnr@web.ca>
Subject: [cleangreensask] About the Lake Huron Nuclear Waste Dump.
To: Gordon Edwards <ccnr@web.ca>

Greetings:

I have some very good news on OPG’s proposed Lake Huron DUD (Deep Underground Dump).

History:

You may recall that Ontario Power Generation wanted to put all of the nuclear waste — excluding irradiated nuclear fuel — from all of its 20 nuclear power reactors into a deep underground dump (DUD) which they call a Deep Geologic Repository (DGR) less than a mile from Lake Huron, at Kincardine Ontario.

After two years of public hearings, the Joint Review Panel in 2015 recommended approval of the project. Normally the government would either accept or reject the recommendations of the panel within a few months.

Because of the 2015 federal election, the government’s decision was postponed. And because of the onset of Christmas, it was postponed again, until March 2016.

Then, in February 2016, Minister of Environment and Climate Change Catherine McKenna wrote a letter to OPG asking for more detailed information from OPG before making her decision:
(1) a comparative study of the effects of placing the DUD at some specific alternate location,
(2) a study of the cumulative environmental impacts if the irradiated nuclear fuel were also buried in the same general area near Kincardine,
(3) an updated account of mitigation measure planned by OPG for all postulated adverse effects.

In December 2016, OPG responded to the Minister’s requests with an extremely vague and general report that identified almost 70% of the land mass of Ontario as an “alternate location” and that did an equally poor job of addressing the Minister’s other questions as well. Public comments were invited on the OPG response, with a March 6 deadline. Here is a link to the CCNR submission: [ http://ccnr,org/CCNR_MOE_pack.pdf ]

Latest News:

Well, it didn't take long for the Minister to respond. On Wednesday, April 5, Minister of Environment and Climate Change Catherine McKenna issued a very strong set of new challenges to OPG regarding its plan to build a nuclear waste dump at Kincardine less than a mile from Lake Huron.

This will delay OPG for at least a year or two as none of these challenges are easily met. Professor Erika Simpson has summarized the main points for us (see below) and you can check these against the official communication from the CEAA (Canadian Environmental Assessment Agency) that is accessible at the link: [ http://www.ceaa-acee.gc.ca/050/document ... ent=118537 ]

Gordon Edwards, President
Canadian Coalition for Nuclear Responsibility
http://www.ccnr.org

----------------------

Erika Simpson wrote:

I have read the 15-page letter and copied the key sentences (from my perspective) into this email below to save you time.

My strong impression is that it will take OPG a few years – perhaps a decade - to come up with all the information that is now required. This means the Trudeau majority government will not have to make the decision. I suspect future governments also won’t want to do so given all the overwhelming problems identified in today’s letter.

Note that I have summarized in CAPS my impression before each numbered item, followed by the actual words from the attached letter, and the relevant page number.

OVERLY LIMITED CRITERIA OF OPG STUDY: Based on OPG’s study, the Agency finds that the selection of the preferred alternative locations is based on limited criteria, and that differences among locations that have not been clearly described. (page 2)

INCONSISTENT TERMINOLOGY: The Agency notes that OPG does not use consistent terminology when characterizing potential adverse environmental effects or a consistent approach when determining if a potential residual adverse environmental effect is likely to be significant. In order to evaluate the validity of OPG's conclusions, it is necessary to understand how the terms are used. (p. 3)

DID NOT ANSWER THE QUESTION OPG WAS SUPPOSED TO ANSWER: Although the criteria appear adequate and are generally acceptable, it remains unclear how the comparative assessment of the alternate locations demonstrates why one location is preferred over the other. (page 4)

OPG APPROACH AND RATIONALE IS GROSSLY INSUFFICIENT: Use a systematic approach (e.g. weighting, scoring and/or qualitative lines of reasoning) that clearly demonstrates the relative importance of the relevant criteria (feasibility criteria, risk, cost, and environmental effects) to the conclusion about the preferred location. (page 4)

SEISMIC FACTORS MUST BE FIGURED OUT: With respect to geological stability, OPG defined its threshold as “older than 1 million years”. However, focusing the threshold on seismicity rather than age may allow OPG to refine the area included within the alternate locations to those of low seismic hazard. (page 5)… …Provide a discussion to clarify whether the alternate locations could be refined based on seismicity and gas pressure. OPG should consider adapting the range of environmental conditions for VCs based on these additional criteria.(page 5)

CONSTRUCTION PROBLEMS COULD CAUSE ENVIRONMENTAL EFFECTS FROM EMISSIONS: it is expected that all activities would need to make use of temporary power generation until the time that the site is connected to the power grid. However, the Report does not discuss the need for the use of fossil fuels for incremental works and activities at alternate locations, or the potential for environmental effects from additional emissions, including GHGs. (page 6)

LEACHING AND ACID PROBLEMS OPG DIDN’T CONSIDER NOR DID THE FEDERAL PANEL CONSIDER: IR 1.6 Surface Water Rationale: Section 5.2.1 of OPG’s “Environmental Effects of Alternative Locations” report states that it is assumed that waste rock in the crystalline alternative location would not be acid generating. However, the Ontario Ministry of Natural Resources and Forestry ecozone and ecoclassification system (Crins et al. (2009)) indicates that, of the 9 ecoregions identified within the Ontario Shield ecozone, all but one are characterized by a geologic substrate that has low to moderate acid buffering capacity.

Information Request:
• Provide a comparative analysis for the risk of acid generation and metal leaching in the sedimentary and crystalline geologic locations.
• Given the variability of environmental conditions in both alternative locations, discuss whether there is a potential for environmental effects from acid generation or metal leaching of waste rock beyond those assessed in the EIS. If yes, identify any additional mitigation measures necessary beyond those identified in the EIS. (page 6)

HEATING UP THE LAKE IS A POTENTIAL PROBLEM OPG NEEDS TO CONSIDER: The Agency notes that the report does not discuss the incremental effects to freshwater species caused by warm water effluent discharges into colder waterbodies. (page 6)

BUILDING ON EXISTING NUCLEAR SITE COULD BE BIGGER PROBLEM THAN OPG THINKS: It is unclear whether the baseline radiation from the existing Bruce Power stations has been taken into account in the comparative analysis of alternate locations. (page 7)

RADIATION EFFECT ON NON-HUMAN BIOTA NOT CONSIDERED: The report also states that appropriate mitigation measures would be implemented to mitigate effects on workers. No consideration of the potential effects of naturally occurring radioactive materials on non-human biota is presented. Finally, in the alternate sedimentary location, the presence of unchartered and abandoned oil and gas wells is not discussed in the report as a potential risk to radionuclide containment. (page 7)

NOW OPG NEEDS TO MEASURE AND DESCRIBE ALL TYPES OF MALEVOLENT AND DISRUPTIVE SCENARIOS EVEN IF OPG SAYS THEY ARE LOW RISK: Information Request: Provide a discussion with respect to malfunctions and accidents to inform the comparative analysis among alternate locations.

The discussion should include the following:
• Describe the differences among disruptive scenarios;
• Discuss the potential environmental effects from accidents and malfunctions during all phases of the project on-site and during off-site waste transportation; and
• Provide a description of the disruptive scenarios (including inadvertent human intrusion, undetected major fracture, and shaft failure) in relation to post-closure safety for both sedimentary and crystalline locations. (page 8 )

ALSO FIGURE OUT THE COST OF RAIL TRANSPORTATION AND HOW TO MAKE ROAD AND RAIL TRANSPORTATION COMPLETELY SAFE: Provide a discussion to clarify the key criteria that support the selection of road over rail transportation and clarify whether there would be important differences in cost, risk, and potential environmental effects. (page 8 )

ACQUIRE INPUT FROM INDIGENOUS GROUPS (NOT JUST ONE NATION) ON POSSIBLE ENVIRONMENTAL AND CULTURAL EFFECTS : Information Required: As per the Agency's draft technical guidance "Assessing the Current Use of Lands and Resources for Traditional Purposes under CEAA 2012", and taking into account the input provide by Indigenous groups, identify the potential effects of any change caused to the environment for each alternative location and provide a comparative qualitative analysis on:
• health and socio-economic conditions,
• physical and cultural heritage,
• the current use of lands and resources for traditional purposes, or
• any structure, site or thing that is of historical, archaeological, paleontological or architectural significance. Provide a discussion of whether constructing the Project at an alternate location would reduce the risk or harm on potentially affected Indigenous groups in the preferred Project area. (page 10)

WILL INCREASED FRAGMENTATION OF THE SEDIMENTARY LOCATION AFFECT TRADITIONAL LAND USE?: Rationale: OPG’s “Environmental Effects of Alternate Locations” report (page 29) states that no measureable changes to soil quality, groundwater quality or groundwater flow are likely outside the immediate footprint of the DGR at the sedimentary location. Given that the preferred location at the Bruce site it is an existing Nuclear facility, it can be reasonable concluded that there may be no measurable changes to these VCs. However, given that the alternate sedimentary location would have to be cleared and excavated, it is difficult to understand that there would be no changes.

Information Request:
• Provide a brief discussion on the potential effects of the terrestrial environment as a result of clearing and excavation at the sedimentary location.
• Discuss how increased fragmentation of the sedimentary location will affect traditional land use in the area. (page 10)

ALSO LOOK AT ALTERNATIVE LOCATIONS AND FIGURE OUT THEIR INDIGENOUS USES FOR THE ALTERNATIVE LOCATIONS, THEIR ENVIRONMENTAL AND CULTURAL EFFECTS AND COMPARE THE TWO LOCATIONS: IR 1.15 Indigenous Interests Rationale: The concepts of land removal, current land use activities and access are important to understanding potential impacts to Indigenous rights and interests. Despite the range of environmental conditions presented for the two alternate locations, the description of land and resource use in the “Environmental Effects of Alternate Locations” report is nearly identical. Information Request: Provide a description of the land and resource uses for the alternative locations that highlight the unique characteristics of these locations from the perspective of Indigenous peoples (e.g. land availability for traditional uses, access, etc.). (page 10)

AND IF OPG GETS ALL THAT DONE, WHICH COULD TAKE YEARS AND MILLIONS OF DOLLARS, OPG MUST FIGURE OUT THE SYNERGY AND THE INCREMENTAL EFFECTS OF ALL THIS:
Information Request:
• Provide a discussion of other types of cumulative environmental effects as a result of the interaction between two or more effects or activities from the APM DGR project and the Project; and,
• Discuss the potential for smaller, incremental effects from both projects, when combined, to have the potential to have adverse effects over time. (12)

AND THEN OPG NEEDS TO PROVIDE A CREDIBLE RISK ASSESSMENT OF ALL TYPES OF WHAT IF SCENARIOS, NOT A SUPERFICIAL RISK ASSESSMENT THAT GLOSSES OVER HUMAN INTRUSION: IR 2.3 Accidents, Malfunctions and Malevolent Acts Rationale: OPG states on page 36 of the “Updated Analysis Cumulative Environmental Effects” report that several disruptive or “what if” scenarios (i.e., inadvertent human intrusion, shaft seal failure, poorly sealed borehole, and vertical fault) are unlikely to occur, so the risk of occurrence remains low for those locations. Although the probability of occurrence of a hazardous event may be low, the magnitude of the impact on the environment or human health can still be high. A risk assessment should include the magnitude of the event and the probability of occurrence in order to understand the overall risk. The Agency also notes there is a limited discussion on the potential long-term release of contaminants should remediation or emergency response not occur in a timely manner (e.g. staff no longer on site, resource not available, etc.).

Information Request:
• Provide a risk assessment that discusses the severity (catastrophic, severe, moderate, low, minor, none) and the probability of occurrence (very unlikely, unlikely, possible, very possible, certain) of accidents, malfunctions and malevolent acts.
• Discuss the potential effects on the environment and human health of a possible long term release of other radionuclides via water sources if the failure of both the APM DGR project and the Project at the Bruce site occurs, due to a common or unrelated cause(s) (page 12)

DID WE SAY CUMULATIVE? REMEMBER OPG MUST FIGURE OUT CUMULATIVE EFFECTS AND ALSO ROCK FORMATIONS CONNECTED ACROSS REGIONS AND THE MOVEMENT OF WATER: When effects of the two projects overlap in time and in space there is potential for cumulative environmental effects. These effects are assessed and mitigation measures are identified in the “Updated Analysis Cumulative Environmental Effects” report; however, the report concludes that any cumulative adverse environmental effects related to post-closure migration of radionuclides in deep groundwater systems would be unlikely. The report also identifies a potential for adverse cumulative environmental effects for the environment components of radiation and radioactivity related to deep ground water systems. Specifically, radionuclide diffusion from the two repositories could eventually reach more active ground water systems in the Cambrian sandstone and Guelph Formation, which are connected across the region. The consequences of such movement could have potentially adverse effects. Taking this into consideration, it is unclear why VCs directly related to geology and hydrogeology were not assessed further in the cumulative environmental effects assessment. Further, an assessment of the ecological risk due to C-14 and H-3 on a number of terrestrial species with large habitat ranges, including mammals, such as white tailed deer and resident bird species such as wild turkey, was not conducted. Information Request: Discuss measures that are available for identifying and monitoring potential effects on groundwater quality from post-closure migration of radionuclides. Provide a narrative discussion of the potential cumulative effects from the APM DGR project and the Project on appropriate non-human biota VCs. (page 13)

OPG ALSO MUST TRY TO SAVE THREE SPECIES THAT ARE NOT THERE - BUT COULD MOVE THERE: IR 2.5 Species at Risk Rationale: As part of the site preparation and construction activities of the Project, wetland 3 would be infilled. Snapping Turtles have been observed in this wetland, and Environment and Climate Change Canada (ECCC) advised that it could be possible for Eastern Ribbonsnake and Eastern Milksnake individuals to move into the Bruce DGR site. These potential residual effects from the Project were not assessed in combination with the potential effects from the three proposed APM DGR sites. Information Request: Provide an assessment of the potential cumulative environmental effects on the terrestrial environment that includes impacts on wetlands and species at risk, specifically the Snapping Turtle, Eastern Ribbonsnake and Eastern Milksnake. (page 13)

MORE REQUESTS ON INDIGENOUS INTERESTS AND A BURIAL SITE PLUS OPG MUST FIGURE OUT A WAY TO FACTOR IN LOCAL ENJOYMENT: It appears that Indigenous interests were not included in the updated analysis of cumulative effects. Section 7.9.2.2 of the EIS [OPG 2011a] states that the Project is likely to diminish the quality or value of activities undertaken by Aboriginal peoples at the Jiibegmegoong burial site located at the Bruce nuclear site. This occurs as a result of changed aesthetics, noise and dust. However, the assessment of the overall local enjoyment of the area does not discuss factors other than increased ambient noise, which was previously discussed in section 5.5 Noise Levels of OPG’s “Updated Analysis of Cumulative Effects” report, and focuses on the Baie du Dore residences in particular.
Information Required:
• Provide a definition of the term ‘Local Enjoyment of the Area’ that reflects the environmental component Cultural Heritage (Indigenous Heritage Resources).
• Provide a discussion on the potential environmental interactions identified for the APM DGR project that could act cumulatively with the residual effects identified for Indigenous interests. (page 14)

FINALLY THERE IS THE PROBLEM OF EARTHQUAKES WHICH WAS OVERLOOKED AND OPG DIDN’T EVEN DO THAT RIGHT: IR 3.1 Clarification of MIT-P-02 Rationale: MIT-P-02 indicates that “All underground facilities (office, tunnel, emplacement room) will be constructed in accordance with the seismic requirements of the latest edition of the National Building Code at the time of the construction.” Given that there are no specific seismic requirements in the National Building Code for underground facilities, this statement is ambiguous. Information Request: Provide a revised version of MIT-P-02 to clarify how in-design mitigation measures for underground facilities will integrate seismic requirements. (page 15)

From: Deep Geologic Repository Project/ Projet de stockage de déchets radioactifs[CEAA\ACEE] [mailto:CEAA.DGR.Project-Projet.DGR.ACEE@ceaa-acee.gc.ca]
Sent: Wednesday, April 05, 2017 9:28 PM
Cc: Deep Geologic Repository Project/ Projet de stockage de déchets radioactifs[CEAA\ACEE] <CEAA.DGR.Project-Projet.DGR.ACEE@ceaa-acee.gc.ca>
Subject: Deep Geologic Repository Project/Project de stockage de déchet radioactifs - Notice to Interested Parties/Avis aux Parties Intéressées

Deep Geologic Repository (DGR) Project for Low and Intermediate Level Radioactive Waste

Interested Parties

The Canadian Environmental Assessment Agency has requested additional information from Ontario Power Generation following its technical review of the Response to the request by the Minister of Environment and Climate Change. The technical review included a comment period to receive the views of the public, Indigenous groups, and expert federal departments and ran from January 18 to March 6, 2017.

The request is available on the Canadian Environmental Assessment Registry Internet Site (Registry) at the following location: [ http://www.ceaa-acee.gc.ca/050/document ... ent=118537 ]

For information on the DGR project, please visit the Canadian Environmental Assessment Registry (the Registry) website at canada.ca/ceaa, reference number 17520. Interested Parties are encouraged to check the Registry regularly to view documents related to the additional information. All records produced, collected or submitted in respect of the environmental assessment will be considered public and posted on the registry unless they are excluded for reason of privacy, confidentiality or security.

You are receiving this message as a member of the distribution list for the environmental assessment of the Project. If you would prefer not to receive emails regarding the environmental assessment, please send a message to [ CEAA.DGR.Project-Projet.DGR.ACEE@ceaa-acee.gc.ca ].

Sincerely,

Deep Geologic Repository Project
Canadian Environmental Assessment Agency
160 Elgin Street, 22nd Floor
Ottawa, ON K1A 0H3
CEAA.DGR.Project-Projet.DGR.ACEE@ceaa-acee.gc.ca