HomeMy WebLinkAboutPSD-058-09Clarington REPORT
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PLANNING SERVICES
Meeting: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE n
Date: Monday, June 15, 2009 ~CSOIu~~~f~U"A'~v~~
Report #: PSD-058-09 File #: PLN 33.4 By-law #:
Subject: PORT GRANBY PROJECT - MUNICIPALITY OF CLARINGTON COMMENTS
ON THE DRAFT EA SCREENING REPORT
RECOMMENDATIONS:
It is respectfully recommended that the General Purpose and Administration Committee
recommend to Council the following:
1. THAT Report PSD-058-09 be received;
2. THAT Report PSD-058-09 be APPROVED as the Municipality's comments on the draft
Screening Report for the Port Granby Long-Term Low-Level Radioactive Waste
Management Project ;
3. THAT a copy of this report and Council's decision be forwarded to Natural Resources
Canada by June 17, 2009; and
4. THAT all interested parties listed in this report and any delegations be advised of
Council's decision.
" ~ Reviewed by:
Submitted by:
Davi J. Crome, MCIP, RPP Franklin Wu,
Director of Planning Services Chief Administrative Officer
JAS/FL/df
5 June 2009
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T (905)623-3379 F (905)623-0830
REPORT NO.: PSD-058-09 PAGE 2
1.0 BACKGROUND
1.1 The Environmental Assessment (EA) for the Port Granby Project, which has been
underway since 2001, has been undertaken by the Low Level Radioactive Waste
Management Office (LLRWMO). The Municipality, through Staff and the Municipal
Peer Review Team led by Hardy Stevenson and Associates, have reviewed and
commented on the numerous studies prepared as part of the EA. The EA process
has in large part been guided by a Legal Agreement between the Municipalities of
Clarington and Port Hope, and the Government of Canada. This Agreement defines a
number of key decision points in the EA process for both the Municipality and the
federal government, which are discussed below.
1.2 Council's Approval of a Qualified Concept -The first key decision for the
Municipality came in September 2004 when Council agreed with the LLRWMO's
recommendation that a concept involving the excavation and relocation of the Port
Granby wastes to a new engineered storage mound north of Lakeshore Road should
proceed through the EA process as the Qualified Concept for the Port Granby Project.
1.3 Council's Consent to a Preferred Option -The second key Municipal decision
occurred in June 2006 with Council's consent to the submission of a Preferred Option
to federal decision makers for review. In providing its consent, Council approved the
recommendations in Staff Report PSD-077-06 that the Environmental Assessment
Study Report (EASR) provided a sufficiently comprehensive assessment of the effects
of the Qualified Concept, and that the measures proposed to mitigate the effects of
the Project on area residents were appropriate. The staff report also included a
description of the Preferred Option to which Council gave its consent. A map
indicating the key elements of the project is attached hereto as Attachments 2A and
2B.
1.4 Council's Consent to the EA Screening Report - A third key decision point for the
Municipality will be Council's consent to the Project as described in the EA Screening
Report prepared by Natural Resources Canada (NRCan) and the Canadian Nuclear
Safety Commission (CNSC), the two Responsible Authorities (RAs) for the Port
Granby Project. The Screening Report contains the findings and conclusions of the
federal review of the EASR for the Port Granby Project. Under the provisions of the
Legal Agreement, Council must be satisfied that the Port Granby Project as described
in the Screening Report is substantially the same as the Project it agreed to in June
2006. Otherwise, the Municipality will have 90 days to notify the federal government
that it does not wish to proceed with the Project.
1.5 On April 27, 2009, Dave MacCauley from NRCan presented an overview of the draft
EA Screening Report to Council. The draft Report was released for public review on
May 4, 2009, with June 17, 2009 being the deadline for the submission of comments.
REPORT NO.: PSD-058-09 __ PAGE 3
2:0 PURPOSE OF REPORT
2.1 The first purpose of this is to advise Committee and Council of the results of the
Municipal Peer Review Team's and Staffs review of the draft EA Screening Report for
the Port Granby Project.
2.2 The second purpose of this report is to recommend specific comments on the draft EA
Screening Report for submission to the Government of Canada. These comments are
set out in Sections 4 and 5 and Attachment 5 of this report and include both Staffs
comments and the comments of the Municipal Peer Review Team.
3.0 DESCRIPTION OF PROJECT IN DRAFT EA
REPORT
3.1 The following description of the Port Granby Project is a summary of the information
provided in the Draft Screening Report, and focuses on three areas of the Project -the
Construction and Development Phase, the Maintenance and Monitoring Phase, and the
Socio-Economic Mitigation Strategy. ,
3.2 Construction and Development Phase
3.2.1 In general terms, the Port Granby Project as described in the draft EA Screening Report
is the same as the Project that Council consented to in June 2006; specifically:
^ The low level radioactive waste (LLRW) and marginally contaminated soils (MCS) at
the existing Port Granby Waste Management Facility (WMF) will be excavated and
relocated to a new Long Term Waste Management Facility (LTWMF) north of
Lakeshore Road and east of Elliott Road.
^ The LTWMF will consist of an above-ground engineered containment mound with a
low permeability composite base liner system and a low permeability composite
cover system. The mound will be approximately 10 ha in area and 8 m above
grade.
^ Approximately 432,000 m3 of waste, with a 15% contingency, will be excavated and
hauled by truck to the LTWMF on a new Inter-Site Route via a new Lakeshore Rd
underpass.
^ Construction materials will be delivered by trucks on the primary access roads
(south on Newtonville Road, east on Concession 1 and south on Elliott Road).
Oversized equipment unable to use the Elliot Road corridor would be directed south
on Newtonville Road to Lakeshore Road. Approximately 12,500 deliveries of
construction materials would occur during the six years of construction and
development.
^ Anew water treatment facility will be constructed north of Lakeshore Road to treat
all contaminated liquids collected at both the LTWMF and the existing WMF prior to
REPORT NO.: PSD-058-09 PAGE 4
discharge to Lake Ontario. This includes residual contaminated groundwater that
will be collected in the East Gorge.
^ Various measures have been proposed to mitigate the effects of the Project on
human health and the natural environment, such as dust suppression at both sites
and along the Inter-Site Route.
3.3 Monitoring and Maintenance Phase
3.3.1 There are no significant differences between the Preferred Option and the draft EA
Screening Report during the Monitoring and Maintenance Phase of the Project.
3.3.2 The LTWMF would be owned by the Government of Canada who would be responsible
for its operation and stewardship. The facility would require consecutive licences from
the CNSC throughout its service life, estimated at several hundred years.
Environmental monitoring, inspection, repair and maintenance would be performed
regularly to ensure that the pertormance objectives of the facility are maintained and to
ensure compliance with CNSC licence conditions. These could include groundwater
and surface water quality, air quality, leachate generation, and the functioning of the
cover and base liner systems. The leachate collection system and the water treatment
system will continue to operate, although the volume of leachate generated is expected
to significantly decrease.
3.3.3 The existing WMF will be backfilled with uncontaminated soils once all of the ih-situ
contaminated materials have been removed. Residual contaminated groundwater will
be collected by the East Gorge Groundwater Collection System and pumped to the new
water treatment facility prior to being discharged to Lake Ontario. Any decision to
remove the collection system would require an assessment of the effects to the aquatic
environment.
3.3.4 The actual end use of both the existing WMF and the LTWMF will be resolved during
the licensing phase, although a passive recreational use is assumed for both sites.
3.4 Socio-Economic Mitioation 5trategy
3.4.1 The Draft Screening Report outlines a number of measures to mitigate the socio-
economic impact of the Project. These measures are intended to address the impacts
on many aspects of the community, such as agriculture, property values, visual
landscape, school bus and agricultural traffic along transportation routes, and use and
enjoyment of property. Attachment 2 outlines all of the measures proposed in the Draft
Screening Report to mitigate the Socio-economic impacts of the Project, together with
all of the other mitigative measures proposed in the Screening Report.
3.5 Residual Adverse Effects and Follow-Uo Program
3.5.1 The Draft Screening Report also discusses the residual adverse effects of the Project.
These are the impacts that are predicted to remain after the implementation of
REPORT NO.: PSD-058-09 PAGE 5
mitigation measures. Attachment 3 provides a list of predicted residual adverse effects,
as well as an overview of those aspects of the environment where no residual adverse
effects are predicted.
3.5.2 The RAs have concluded in the Draft Screening Report that the adverse residual effects
related to the Port Granby Project will be minor, and that the Port Granby Project is not
likely to cause significant adverse environmental effects. This determination of the
significance of effects is based on the definition provided in the Canadian Environmental
Assessment Act which looks at the magnitude, extent, duration, frequency and
permanence of the effects.
3.5.3 The RAs also consider afollow-up program would be needed for the Port Granby
Project and have identified the preliminary requirements for development of such a
program. Specific elements of this program include:
Atmospheric Environment
^ Verification of the-concentrations of particulate-bound metals.
Groundwater Environment
^ Continued groundwater monitoring over the course of the project with additional
monitoring at the Pre-Construction Phase to evaluate groundwater elevations in
locations proximate to the LTWMF.
^ Groundwater monitoring will be undertaken at the existing WMF where impacts are
anticipated. Monitoring would begin in the Pre-construction Phase to augment
existing data at the site.
^ Measurements from monitoring wells and treatment ponds have been planned to
monitor groundwater and drainage water quality at the LTWMF beyond the design
life of the LTWMF.
^ Because of uncertainties in the assessment of surface water quality in the
nearshore zone of Lake Ontario caused by site groundwater seeps, the
concentrations of such releases will be verified.
4.0 GENERAL COMMENTS ON THE DRAFT EA SCREENING REPORT
4.1 The comments on the Draft Screening Report as presented by Staff and the Municipal
Peer Review Team are intended to compare the Project as described in the draft
Screening Report to the Preferred Option consented to by Council in June 2006, to
strengthen the Screening Report by identifying areas where greater clarity could be
provided, and to recommend further enhanced mitigation measures and follow-up
programs and activities to further minimize the potential effects for the local community.
REPORT NO.: PSD-058-09 PAGE 6
4.2 Staff and the Peer Review Team are satisfied that the draft Screening Report presents
a thorough review of the Port Granby Project, and the Project as described is
substantially the same as the Preferred Option. We agree with the majority of the
analysis and conclusions presented in the Report, in particular that, with the appropriate
mitigation measures and follow-up monitoring, the Project is not likely to cause
significant widespread adverse environmental effects.
4.3 However, there are a number of areas where the Draft Screening Report could be
strengthened, as follows:
^ The Report could have better acknowledged the various reports that will come
forward in the Detailed Design Stage. These documents are important for a
complete understanding of the environmental protection regime.
^ The mitigation measures and follow-up measures outlined in the Draft Screening
Report tend to understate those agreed to in references in the EASR and as
discussed by the LLRWMO and the Peer Review Team.
^ Some areas such as atmospheric emissions, (i.e. noise and dust mitigation) could
be strengthened.
^ In many areas, the RAs rely on 'adaptive management', whereas impact avoidance
would be the correct approach.
5.0 SPECIFIC COMMENTS ON THE DRAFT EA SCREENING REPORT
5.1 Improvements to Primary Access Route
5.1.1 The description of the Preferred Option consented to by Council indicates that the
LLRWMO will upgrade the roads along the primary access route to the appropriate
municipal standards to accommodate the truck traffic related to the Project. The draft
EA Screening Report states that there will be "upgrades and repairs to roadways and
intersections ...... to ensure that the transportation network would be suitable for the
expected volume of project-related traffic. Speck elements would include: chipping
and surface sealing of existing roads..".
5.1.2 Studies conducted by the LLRWMO through the EA concluded that Newtonville Road
and Concession Road 1 are structurally deficient and are not capable of supporting
current traffic loads or the increased traffic loads due to construction traffic. The
analysis recommended that these roads be upgraded prior to the construction phase.
5.1.3 It is the position of the Municipality of Clarington that those sections of Newtonville Road
and Concession Road 1 on the primary access route should be upgraded to appropriate
municipal standards by the federal government as part of the Port Granby Project. The
Municipality is concerned that chipping and surface sealing as proposed by the draft
Screening Report will not be sufficient to accommodate Project-related truck traffic and
that the road conditions will deteriorate even further. Poor road conditions on the
NO.: PSD-058-09 PAGE 7
primary access route will also increase the noise impacts on adjacent residents from
trucks traveling on these roads.
5.2 Prooertv Value Protection Program
5.2.1 The Draft Screening Report indicated that, as part of the socio-economic mitigation
strategy, the Property Value Protection (PVP) program would continue to be
implemented for the duration of the LTWMF Construction Phase and two years into the
Maintenance and Monitoring Phase. However, the Preferred Option approved by
Council included a provision that the PVP program be monitored with a view to
extending it beyond two years after the completion of the LTWMF if the market
demonstrates that project effects will last longer.
5.2.2 The termination of the program two years after the cessation. of construction activities
assumes that impacts on property values are only related to the construction phase of
the Port Granby Project. It is simply not possible at this stage to accurately predict
when the stigma effects of the LTWMF on property values will cease. As such, the
Draft Screening Report should be revised to indicate that the PVP program should be
continued until monitoring of property values in the area indicates that the LTWMF no
longer has an effect.
5.3 Mitigation Measures on Primary Access Route
5.3.1 Staff and the Peer Review Team have previously indicated to the LLRWMO that some
mitigation measures should be implemented prior to the Construction Phase.
Specifically, vegetative screening such as trees is required along the primary access
route to mitigate the visual, noise and dust impacts of construction truck traffic on
residents. We have suggested that any such vegetation should be planted as soon as
possible prior to the start of the Construction Phase.
5.3.2 The provision of vegetative screening on the primary access route was not specifically
detailed in the Preferred Option approved by Council, nor is it mentiohed in the Draft
Screening Report as a proposed mitigative measure. However, the Municipality
requests that the Screening Report be revised to specifically identify this vegetative
screening as a mitigative measure, and provide for its implementation prior to the start
of the Construction Phase.
5.4 Municipal Peer Review Team Comments
5.4.1 The Peer Review Team has made a number of specific comments on the Draft
Screening Report. These are detailed in Attachment 5 to this Report, while their full
report is provided in Attachment 6 (available for review in the Planning Services
Department). The following is a summary of the Peer Review Team's comments:
^ The Draft Screening Report needs to stress avoidance measures not just
monitoring measures.
^ The Screening Report requires a stronger water treatment recommendation.
REPORT NO.: PSD-058-09 PAGE 8
^ There needs to be a better understanding of end-use activities.
^ The Draft Screening Report needs to specifically address nuclear energy workers.
^ There needs to be a continual evaluation of the PVP program.
^ The definition of the lifespan of the geomembrane in the base liner of the LTWMF
needs to be refined.
^ Ensure taking trucks off the roads during school bus pick up times.
^ Review plans for the monitoring of off site emissions.
^ Ensure that local residents are involved in the monitoring process.
^ There is too much reliance on adaptive management; therefore there is a need to
utilize impact avoidance measures.
^ The Draft Screening Report comments need to be better informed by ongoing
studies.
^ There need to be specific management plans for homes (i.e. dust, noise) along
transportation routes.
^ The Draft Screening Report needs to address the crossing at the CNR line at Elliot
Road in relation to truck traffic.
5.4.2 Staff have reviewed and concur with the detailed comments provided by the Peer
Review Team. Some of their comments are similar in nature to mitigation measures
proposed in the Draft Screening Report. However, this serves to emphasize the
importance of these measures to mitigating the impact of the Project on the local
community.
6.0 CONCLUSIONS
6.1 The draft Screening Report presents a thorough review of the Port Granby Project, and
the Project as described is substantially the same as the Preferred Option. Staff and
the Peer Review Team agree with the majority of the analysis and conclusions
presented in the Report, in particular that, with the appropriate mitigation measures and
follow-up monitoring, the Project is not likely to cause significant widespread adverse
environmental effects.
6.2 The comments provided in this report are intended to ensure that the Project as
approved by the federal government, including mitigation measures, is substantially the
same as the Preferred Option consented to by Council. The comments are also
intended to strengthen the Screening Report and suggest additional mitigation
measures to further minimize the impact on the local community.
6.3 The RAs will review all comments submitted, make any revisions to the draft Screening
Report that they deem necessary, and issue a final EA Screening Report. Under the
provisions of the Legal Agreement, the parties to the Legal Agreement will have 60 days
from the issuance of the final Screening Report to determine whether the Project as
defined in the Screening Report is substantially the same as the Preferred Option, after
which each party shall have a further 30 days to decide if it does not wish to proceed
with the Project or an element of the Project.
REPORT NO.: PSD-058-09
PAGE 9
6.4 Staff and the Peer Review Team will review the final Screening Report and. report back
to Council with the results of this review and on-going discussions with area residents.
This next step is expected to occur in Autumn 2009.
Attachments
Attachment 1 - Glossary of Terms
Attachment 2A Map -Existing and Proposed Waste Management Facilities
Attachment 2B Map -Transportation Access Routes
Attachment 3 -Proposed Mitigative Measures
Attachment 4 - Predicted Residual Effects
Attachment 5 - Detailed Comments Municipal Peer Review Team
Attachment 6 - Municipal Peer Review Team Report (under separate cover)
List of interested parties to be advised of Council's decision
Joanne Smith Joanne McNamara
Christine Fahey Jane Lawrence
Vito Binetti Brian Layng
Wayne Boucher Rupert McNeill
Ray Coakwell and Frances Brooks Lorri and Stuart Munro
Walter Burman Tim and Laurel Nichols
Rosemary Cooper Dora Nichols
Marion and Stuart DeCoste Carole Owens
Frederic DeSourdy Garfield Payne
Robert Edgar James B. Robertson
Mel Edwards Linda and Paul Ryerse
Wilma Entwistle Sarwan Sahota
Penny Ewington Ken Shrives
Betty and Stephanie Formosa Barb and Dennis Spencer
Paulette Gerber John Stephenson
Lori Graham Brad and Penny Stripp
Frank Hart Rob & Kim Studt
Luanne Hill & Mike Mamonko Midori Tanabe
Susan Kinmond Harvey Thompson
Maria Kordas-Fraser Rosemary Tisnovsky
Marc Landry Stan Tisnovsky
Eric Leeuwner Julie Tutla
Gerry Mahoney and Bonnie McFarlane Richard Walker
Andrew McCreath Mary and Harry Worrall
Bev Oda
Attachment 1
To Report PSD-058-09
GLOSSARY OF TERMS
CNSC Canadian Nuclear Safety Commission
EA Environmental Assessment
EASR Environmental Assessment Study Report
LLRW Low Level Radioactive Waste
LLRWMO Low Level Radioactive Waste Management Office
LTWMF Long Term Waste Management Facility
MCS Marginally Contaminated Soils
NRCan Natural Resources Canada
PVP Property Value Protection
RA Responsible Authority
WMF Waste Management Facility
Attachment 2A
To Report PSD-058-09
ST.~W
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Lake Ontario
Existing and Proposed Waste Management Facilities
Attachment 2B
To Report PSD-058-09
Attachment 3
To Report PSD-058-09
PORT GRANBY PROJECT DRAFT EA SCREENING REPORT
PROPOSED MITIGATION MEASURES
HUMAN HEALTH AND SAFETY
Non-Radiological Effects -Workers
^ Health and safety program, including
level controls, etc.
use of equipment (eg. dust mask), noise
^ Comprehensive job training program.
^ Routine and frequent site condition inspection, practices and procedure
compliance audits.
^ Progressive discipline policy and process.
^ Comprehensive incident reporting, investigation, tracking and analysis.
^ Medical monitoring for workers in higher risk areas.
Non-Radiological Effects -Members of the Public
Mitigation measures would consist of, but are not limited to:
^ Evaluation of the appropriateness of mitigation measures to prevent or minimize
the potential public exposure to the effluents in the portion of Lake Ontario that
may be affected by treated effluent or bluff seepage, if needed.
• Noise reduction measures.
^ Schedule activities with highest noise levels during the middle of the day.
• Notify residents of the times and duration of activities that would result in noise
levels above 6 dBA.
• Appropriate safe design and construction of the road accessing ???? (words
missing), accommodating farm access and vehicle, project related traffic.
^ Optimization of off-site trucking activities.
• Orientation program focus on safety issues for truck drivers.
• Continued and consistent protocols for delivering information and receiving input
to/from residents in the Local and Regional Study Areas.
Radiological Effects -Workers and Members of the Public
^ In accordance with a CNSC licence, the proponent would be required to develop a
radiation protection program and to implement the principle of "As Low as
Reasonably Achievable" (ALARA) for the consideration of radiological health of
workers. As part of the program, the proponent would actively monitor radiation
doses.
SOCIO-ECONOMIC ENVIRONMENT
Population and Economic Base
^ Enhanced liaison with local farmers aimed at keeping farm operators aware of
Project works and activities, environmental monitoring results, peak traffic
periods, potential road closures and access restrictions, through the use of such
means as regular newsletters, special events notices, door-to-door notifications
when required and direct communications with the site manager.
^ The creation and implementation of a business activity enhancement program
aimed at maximizing local business opportunities and benefits of the Port Granby
Project.
Visual Setting
^ A landscaping and lighting plan aimed at minimizing the visibility of on-site
activities at the LTWMF.
Infrastructure
^ Continued implementation of the Property Value Protection program for the
duration of the LTWMF Construction Phase and two years into the Maintenance
and Monitoring Phase.
Community Services
^ Liaison with recreational user groups of the Waterfront Trail and Elliott Road
cycling, monitoring or naturalist groups aimed at keeping them aware of the Port
Granby Project works and activities, environmental monitoring results, peak traffic
periods, potential road closures and access restrictions.
^ Avoidance of project-related trucking during school pick-up/drop-off times along
recommended transportation routes.
Traffic and Transportation
^ Comply with half-load restrictions on applicable route;
^ Obtain approval from the Municipality of Clarington for the movement of wide or
heavy loads; approvals should be obtained a minimum of one week prior to each
occurrence.
^ Incorporate farm access and farm vehicle movement considerations into the
detailed design to promote better accommodation of farm vehicle operations
along the truck route.
^ Incorporate signalization, signage, pavement markings and traffic controls at
Elliott Road underpass to ensure safe operations of trucks in the narrow
underpass.
• Implement traffic control measures to ensure safety during the construction and
decommissioning of the underpass for the Inter-site road.
^ Provide signage for the underpass detour and any required stop controls.
^ Ensure at-grade rail crossing design incorporates wide lanes and shoulders,
maintains sightlines, gate and rail crossing control devices to ensure safe
operation of traffic at the crossing.
^ Incorporate contract clauses requiring all trucking contractors to demonstrate that
vehicles are regularly maintained and drivers are licensed and trained to ensure
safe operation of trucks.
^ Implement contract clauses to ensure trucks adhere to recommended
transportation routes, impose financial penalties for non-compliance to ensure
safe operation of trucks on local roads.
^ Implement an orientation program for truck drivers focused on safety issues along
the transportation routes.
^ Optimize offsite trucking activities through development of delivery timing
windows, use of convoys and material stockpiling to minimize disruption of local
residents and road users.
^ Design and deliver a contingency plan for traffic movement on Lakeshore Road in
the event of an accident involving LLRW 'to ensure appropriate emergency
response.
^ Provide advance notifications to local residents of trucking activities, particularly
for oversized loads.
^ Design and deliver a complaints reporting and resolution procedure specifically
related to truck traffic.
^ Repair damage to local roads caused by project-related traffic.
Residents and Communities
^ Implementation of a project communication program to keep residents
appropriately informed of project activities.
^ Modification of the LLRWMO complaint resolution process established under the
Legal Agreement to address environmental effects and issues that might be
raised, on a case-by-case basis, using atwo-tiered system.
^ Development of site-specific nuisance effects management plans for noise, dust,
odour and traffic management.
^ Communication with local residents to address loss of use and enjoyment of
property, including targeted communications with newcomers aimed at keeping
them informed of air quality and noise levels, environmental monitoring results,
schedule of Port Granby Project works and activities, and where to call for
answers to questions.
^ The implementation of mitigation measures, and an information program for
affected neighbourhoods to address loss of use and enjoyment of property,
including disclosure of monitoring, real-time reporting of noise and dust level
monitoring results, site inspection privileges.
^ An end use for the LTWMF that would maximize the potential to address effects
on community character.
^ The adoption of a "name" for the LTWMF that would not associate it with any
community.
^ Complete removal and rehabilitation of the upgraded portions of Elliott Road to
pre-Project conditions (to the extent possible).
^ Complete removal of the underpass at Lakeshore Road and rehabilitation of the
areas affected by the underpass to pre-Project conditions (to the extent possible).
• Requesting a CNSC licence condition that provides explicit assurances that the
LTWMF and existing WMF cannot be used for any purpose other than the long
term management of a specific volume of historic LLRW from the Municipality of
Clarington to address effects on community character.
Heritage Resources
^ The proponent would conduct Stage 1 and/or 2 Assessments for the newly
acquired or designated properties on which project-related development would
occur.
^ The LLRWMO will implement a heavy machinery operator awareness program
regarding the identification and management of archaeological artefacts. The
program will be delivered by a licensed archaeologist and/or other local experts.
• If buried heritage resources were encountered, work would be immediately
suspended and the Ontario Ministry of Culture contacted. Work would only
resume with concurrence from the Ministry.
^ If human remains were encountered, work would be immediately suspended and
the Registrar or Deputy Registrar of the Cemeteries Regulation Section of the
Ontario Ministry of Consumer and Business Services would be contacted. The
archaeology unit and the local police would also be contacted to determine
whether the remains were prehistoric, historic, or modern and the circumstances
under which they were interred. Work would only resume with the concurrence
from the appropriate authorities.
ATMOSPHERIC ENVIRONMENT
Dust Control
^ Minimizing work areas containing contamination.
^ Applying dust suppressants.
^ Covering exposed areas and stockpiles.
• Ceasing activities under high wind concentrations.
^ Revegetation and management of LTWMF cells and excavation areas as soon as
practicable.
• Watering of unpaved roads and excavation areas.
• Vacuum sweeping and water flushing of paved roads as needed.
^ Preparation of a dust management plan as part of the Detailed Design Phase to
ensure mitigation is sufficient and requirements are met.
Noise Control
• All construction equipment would comply with the emission standards outlined in
NPC - 115 of the Ontario Model Municipal Noise Control By-law.
^ All construction activities would be limited to the daylight hours and will therefore,
vary according to the time of the year.
• Trucks and other heavy equipment would be equipped with properly-functioning
mufflers and tailgate banging would be avoided at activity sites.
^ Empty dump trucks would reduce their speed at construction sites and local
roads to avoid excessive cargo box and tray noise.
• Construction hoarding (ie. fencing around sites) would be erected where
practical
Radon and Particulate Radioactivity
^ Covering stockpiles and exposed areas overnight and on weekends using foam
agents, geotextiles or other appropriate materials.
^ The application of dust suppressants (including water and possibly chemical
suppressants).
^ Possible cessation of activities under high wind conditions.
^ Minimization of the working area containing contaminated materials.
^ The re-vegetation of completed cells and excavated areas as soon as possible.
GEOLOGY AND GROUNDWATER ENVIRONMENT
Soil Quality
• Efficient watering of unpaved roads and excavation areas, and vacuum sweeping
and water flushing of paved roads to prevent the accumulation of airborne
contaminants on surface soil during construction.
Groundwater Quality
• Groundwater quality at the LTWMF will be protected through the collection and
treatment of leachate. Groundwater contamination will be reduced at the existing
WMF with the removal of the waste and contaminated soils. Residual
contaminated groundwater will continue to be collected and treated until
monitoring determines that the groundwater can be discharged directly to Lake
Ontario.
AQUATIC ENVIRONMENT
Surface Water Quality
Treatment of contaminated water at the new water treatment facility will
significantly reduce the contaminant loadings from current treated effluent
discharges to the lake relative to baseline conditions, and improve lake water
quality near the existing discharge point.
A site-specific risk assessment including toxicity testing of the existing sediments
would assist in indicating the level of remediation, if any, that is required along the
Lake Ontario shoreline. If remediation activities are warranted for increased
arsenic and uranium levels, the prompt removal of excavation water after rainfall
events may be required to minimize the time the water is in contact with the
waste.
A transportation plan detailing a quick spill response would be in place to address
unexplained or unplanned events. Any fuel oil spilled to the creek will be cleaned
by high pressure washing of cobble and gravel if necessary to remove residual
product, thus allowing benthic invertebrates, fish and aquatic plant communities to
re-establish.
TERRESTRIAL ENVIRONMENT
Vegetation Communities
Relocation of the LTWMF stormwater management pond out of the cultural thicket
into an agricultural field, given that the agricultural field is of lower ecological
importance than the cultural thicket.
Development of asite-specific Landscape Plan by a qualified landscape architect
or biologist for terrestrial environment rehabilitation at each work site. The plans
would consider site-specific plantings with input from the local Conservation
Authority and the Municipality and provide for adequate input regarding
community needs and preferences.
Development of new vegetation communities at the LTWMF site rather than
simply re-creating pre-construction conditions, Any such plans would be subject
to CNSC licence requirements and the proposed end use identified for the site.
• Development of a Protection and Rehabilitation Plan for the fen vegetation near
the East Gorge. Prior to finalizing the remediation needs for this area, a survey of
the fen should be conducted to identify the extent of the vegetation community.
All reasonable efforts should be undertaken to preserve as much of the fen
vegetation as possible, This could include removing and re-introducing soil plugs
containing plant specimens together with their root systems to the excavated site
as part of the site rehabilitation and re-vegetation.
Wildlife Habitat and Wildlife Communities
• Vegetation clearing should not take place in migratory bird habitat during the
breeding season (March 30~h to July 23`x).
^ If work must be conducted within breeding bird habitat during the identified
breeding season for migratory birds, a nest survey would be conducted by a
qualified avian biologist immediately prior to the commencement of the work to
identify and locate active nests of species covered by the Migratory Birds
Convention Act. A mitigation plan would need to be developed to address any
potential impacts on migratory birds or their active nests, and forwarded for review
to Environment Canada -Ontario Region prior to implementation.
^ Features would be incorporated in the site-specific Rehabilitation Plan to re-
establish the structural habitat qualities and variability of site conditions.
Attachment 4
To Report PSD-058-09
PORT GRANBY PROJECT DRAFT EA SCREENING REPORT
ANTICIPATED RESIDUAL EFFECTS
HUMAN HEALTH AND SAFETY
Non-Radiological Effects -Workers
^ No residual adverse effects on non-radiological worker health and safety are
predicted.
Non-Radiological Effects -Members of the Public
Some residual adverse effects are predicted; however, these are not likely to be
significant.
Air Quality
^ Although there will be measurable changes in dust levels at all area and adjacent
resident locations, all 24-hour average concentrations of PM2,5 and PM,o will be
below established criteria.
^ Measurable changes in CO, NOZ and SOZ were predicted, but no exceedences of
established ambient air quality criteria for any of the parameters at any resident
location are expected.
^ No unacceptable health risks would occur as a result of the project works and
activities.
Non-Radiological COPC
^ The construction and operation of the new water treatment facility was identified
as having the potential to influence human health. The potential change in
health is attributed to the potential for exposure to Contaminants of Priority
Concern (COPCs) within the treated effluent plume in Lake Ontario during
construction and development as well as early life maintenance and monitoring.
^ A human health risk assessment was undertaken that considered all
environmental media where potential exposure existed. The conclusion of the
risk assessment was that any incremental risks associated with the Project would
.not pose an unreasonable risk to human health.
General Welht3eing
• Public attitude research indicates that 11% to 17% of survey residents stated
that their feelings of health and sense of well-being would decrease somewhat or
a great deal.
Radiological Effects -Workers
No residual adverse effects were predicted for the radiological health of workers.
In applying the ALARA principle, it is expected that the annual radiation dose for
workers can be reduced to below 10% of the CNSC dose limit averaged over any
five-year period of construction and development.
Radiological Effects -Members of the Public
^ No residual adverse effects were predicted for the radiological health of members
of the public.
During the Construction and Development Phase, the annual radiation dose
predicted to be received by adult members of the public in all scenarios (ie.
dietary intake, adjacency, special cases -vegetarian and home gardening, Lake
Ontario swimmer, fenceline observer, country foods diet) are not measurable.
The estimated total annual doses from all natural sources in combination with the
Port Granby project for adults, children and infants are below the national
averages of for these age groups.
During the Maintenance and Monitoring Phase, no interactions were identified
between members of the public and maintenance and monitoring activities,
including postulated malfunctions and accidents. For special case scenarios (ie
Lake Ontario swimmer, fenceline observer, country foods diet, casual hiker), all
estimated doses were either below existing conditions, not measurable and/or
below Provincial Water Quality Objectives.
SOCIO-ECONOMIC ENVIRONMENT
Population and Economic Base
• Relocation of one tenant farmer (on the site of the LTWMF).
Increased potential for out-migration of residents living in the Port Granby area
prior to and during the Construction and Development Phase.
^ Disruption to farm operations within the zones of influence and along
transportation routes.
Visual Setting
Changes in the quality of existing views within the LTWMF view shed during the
Construction and Development Phase and the Maintenance and Monitoring
Phase.
Infrastructure
^ Reduced residential property values during the Construction Phase in the order
of 2% to 8% within the likely zone of influence for the LTWMF and along
transportation routes. Lower property values near the LTWMF may extend into
the Maintenance and Monitoring Phase.
^ Increased turnover of residential properties within the likely zone of influence for
the LTWMF during the Construction and. Development Phase. Increased
turnover of properties may also be experienced during the Maintenance and
Monitoring Phase.
• Increased difficulties in marketing properties resulting in greater number of days
on the market during the Construction and Development Phase which may
extend into the Maintenance and Monitoring Phase.
Community Services
^ Disruption of local community and passive recreational activities undertaken
within the likely zone of influence for the Port Granby LTWMF, or along
transportation routes during the Construction and Development Phase.
Traffic and Transportation
• Disruption to some road .users, pedestrians and non-motorized traffic along the
recommended transportation routes and local roads due to perceived hazards,
detours and road closures.
Community Character
^ Changes in the use of property and reduced enjoyment of property among some
residents living within the likely zone of influence for the Port Granby LTWMF,
existing WMF and along transportation routes during the Construction and
Development Phase.
• Adverse changes to community character or image of the rural areas nearest the
LTWMF during the Construction and Development Phase.
Heritage Resources
• No likely residual effects on heritage resources are predicted as a result of the
Project.
ATMOSPHERIC ENVIRONMENT
Dust
^ Residual dust. impacts are not considered likely to occur. Occasional slight
exceedences of the Canada-wide standard for PM2,5 particulate emissions (30
micrograms/m3) may occur along the very edge of the existing WMF property
boundary.
Noise
^ There will be localized increases to existing ambient noise levels during the
Construction and Development Phase in close proximity to the Port Granby
sites. Taking into account the proposed mitigation measures, nuisance effects
associated with noise are predicted for some residents. These noise effects
would not be any different than any other construction activity. Best
management practices will minimize, as much as possible, these potential
effects.
^ Monitoring of actual noise levels related to the Project would be undertaken at
receptors near the Site Study Area. Monitoring will verify that mitigation
measures have been implemented and are effective.
Radon and Particulate Radioactivity
^ Residual adverse effects on radiological air quality are not considered likely to
occur.
GEOLOGY AND GROUNDWATER ENVIRONMENT
Non-Radiological Soil Quality
The predicted concentrations of arsenic and other non-radiological soils at the
LTWMF site perimeter are not considered measurable in terms of baseline
conditions.
Groundwater - LTWMF
During construction of the LTWMF, there would likely be no measurable changes in
the quality or quantity of groundwater and drainage water. Leachate and
precipitation that contacts the waste will be collected and treated, while unaffected
runoff would be directed to storm water management ponds for ultimate discharge to
Port Granby Creek.
In the long term, no adverse environmental effects to groundwater and drainage
water quality, quantity and flow are anticipated as the result of the Project. The
mound cover and baseliner, together with the leachate collection system, are
expected to effectively protect groundwater for several hundred years.
Groundwater-Existing WMF
Once the LLRW and MCS have been removed, residual groundwater is expected to
flow and flush out the system, resulting in improved groundwater quality as time
passes.
AQUATIC ENVIRONMENT
No residual adverse effects on sediment quality, fish communities and habitats and
benthic invertebrates or aquatic plant communities are predicted to occur as the
result of the Project.
TERRESTRIAL ENVIRONMENT
No residual adverse effects on vegetation communities, wildlife habitat and wildlife
communities are anticipated as a result of the Project.
CUMULATIVE EFFECTS OF OTHER PROJECTS
Non-Radiological Effects
Air Quaiity
• It is unlikely that a cumulative effect of the Port Granby and Port Hope Projects
on non-radiological air quality would be measurable. Any cumulative dust effects
from local construction activities are short-term in nature and would largely be
expected to affect only receptors immediately adjacent to activities.
• Good management procedures will ensure any effects and therefore any
cumulative effects are minimized. No residual effects are expected.
Noise
• Noise associated with local construction activities would only be cumulative if
they were located within a few hundred metres of each other. These activities
are of short duration and would largely be expected to affect only receptors
immediately adjacent to the activity.
^ Good management procedures will ensure any effects and therefore any
cumulative effects are minimized. No residual effects are expected.
Socio-Economic Environment
^ Any cumulative effects resulting from other projects would likely not be of
sufficient magnitude to change the fundamental nature of the socio-economic
effects assessed or cause new types of effects.
Health and Safety
^ A residual cumulative adverse effect identified was the increased stress and
adverse effects to health and general well-being resulting from negative changes
to people's feelings of health and sense of well-being, feelings of personal
security and feelings of satisfaction with living in the community.
^ This adverse cumulative effect would be most evident in people living close to
the LTWMF or when residents think about living near a facility that handles
nuclear fuels. This effect may diminish over time if good communication and
public involvement are provided and a positive environmental and safety record
is maintained for the Port Granby Project.
Radiological Effects
^ There are several projects which overlap in time with the Port Granby project and
have the potential for radioactive emissions which might contribute to radiation
exposures in the Regional Study Area. However, there would not be measurable
cumulative effects on radiological air quality (radon concentrations and
radiological constituents associated with re-suspended dust).
Attachment 5
To Report PSD-058-09
PORT GRANBY PROJECT DRAFT EA SCREENING REPORT
MUNCIPAL PEER REVIEW TEAM COMMENTS
The following sections are the Municipal Peer Review Team's comments that relate to
specific sections in the Draft Screening Report.
A. Description of the Existing Environment and Environmental Effects
The EASR examines effects of the Project on the biophysical and human
environment. The Draft Screening Report addresses the existing, or baseline,
environmental conditions in the area surrounding and encompassing the current and
proposed waste management facility. In doing so, the Screening Report provides an
accurate account of the baseline conditions for the Port Granby Study Area. However,
there are a few minor areas where the description can be improved.
Page 17
Uranium needs to be added to the list of contaminants of greatest concern to be
consistent with the second sentence in this paragraph that discusses uranium.
Page 52
In the community profile, there is not a specific description of the Port Granby
community or its residents. It is important to evaluate the Project against the backdrop
of residents and businesses who have the greatest need to ensure the Project
management is sound. Port Granby should be defined as at the very least, the Port
Granby settlement (of multiple homes/ businesses) to/and or within the local study
area.
Page 71
The following effects on vegetation should be described fully in the Draft Screening
Report, and the following effects be more closely examined:
• The relocation of the LTWMF stormwater management pond;
New vegetative communities at the LTWMF, not just farm fields need to be
better analysed (e.g. the fen near east gorge); and
A landscape management plan for the LTWMF be enacted as an end use and
requires community and municipal input. Furthermore, end use planning is not
well acknowledged in the Draft Screening Report. In contrast, all parties have
spent considerable time and money identifying a preferred end use.
B. Atmospheric Environment and Effects
The atmospheric environment consists of non-radiological air quality, radiological air
quality, and noise. As part of the assessment, the Draft Screening Report also
discusses climate and meteorology and their effects on the Project. Overall, the report
provides a reasonable overview summary of the air quality aspects, mitigation and
monitoring developed for the Port Granby project. However, there are a few minor
areas where the description can be improved.
The Peer Review Team is concerned about the use of 'adaptive management' and
monitoring as the dominant waste excavation guideline. This approach leads to
accepting average exposure levels as opposed to an emphasis on avoiding exposure
incidents. Monitoring to .see if radiological contaminants have left the site is useful
after excavation has occurred but is an unacceptable method to be used while the
excavation is undervvay. The Peer Review Team recommends impact avoidance as
the rule governing the excavation. From this perspective, dust would be measured
and minimized at the excavation site. Measuring for fugitive dust at the fence line
involves acceptance of greater risk then necessary. Furthermore, monitoring to see if
dust has exceeded the site fence line is inadequate as a method of measuring
whether construction practices are sound.
Throughout the report there is discussion of needing a good Dust Management Plan
to ensure that there are no off-site impacts due to fugitive dust emissions. It is stated
that the plan will be developed as part of the Detailed Design Phase. We accept this,
but will continue to point out that the details of that plan are extremely important and
are the key to ensuring off-site impacts are minimized. All aspects of the plan,
including specifics on mitigation, monitoring (including real-time), complaint response,
corrective actions and record keeping will be very important. We recommend that the
Draft Screening Report strengthen recommendations to develop a Dust Management
Plan that controls dust at the source rather than at the Project fence line.
Additionally, the plan needs to consider whether dedicated trucks (e.g. watering
trucks) are needed for the waste areas and the haul route between sites. Given the
importance of mitigation in avoiding impacts, especially those that arise from dust,
there needs to be a more explicit discussion of the requirements for proper mitigation
plans in the Screening Report. In principle, particulate matter should not be leaving
the site boundary at any time.
Page 60
The report cites a `conservative approach' in terms of the worst month scenario being
averaged over the course of a year. However, it is not a conservative approach when
you take into account, for example, that wind born thorium should not leave the site
boundary over the course of a year. In relation to other atmospheric emissions, no
excedences are anticipated.
Page 62
Under particulate discussions, in the end of the paragraph, it is stated that National
Institute of Health and Safety (NIOSH) standards will be met. These are occupational
standards. The previous discussions between the Peer Review Team and the
LLRWMO about the management of particulates pertained to ambient air quality for
public exposure. The NIOSH statement seems out of place; or at least warrants some
further discussion and context (in a separate paragraph). If it is the intent to discuss
occupational levels in this section, then similar discussions are warranted for
conventional air contaminants and for metals.
Page 64
The discussion of particulate bound radionuclides indicates that this will be monitoring
by PM~o samplers. Typically metals and other particulate bound contaminants are
done by TSP (total suspended particulate), not PM~o. The approach to measuring
these contaminants needs to be reassessed.
Pages 65 and 67
The discussion of soil impacts of metals and radionuclides indicates that there are no
predicted impacts. On page 67, verification is considered through a 'robust sampling
design'. This is not defined. We agree that soil sampling after completion of the
cleanup should be undertaken to verify that no off-site dispersion of contaminants
have occurred. The `robust' sampling is not discussed in Section 12: Follow-Up
Program and should be. The rule should be no 'contamination of residential
properties'.
Pages 62 and 63
This section states that there may be a cessation. of activities during high wind
conditions. We find the conclusions of the Draft Screening Report on dust to be weak.
The Peer Review Team recommends that high wind scenarios should be anticipated
through an onsite meteorological station, and all excavation activities should not be
initiated if high winds are anticipated. Furthermore, this recommendation needs to be
part of the Dust Management Plan as part of the Detailed Design Phase.
Page 83
There are in depth studies on the potential noise impacts from the project in the EASR
that indicate some of the concerns with noise affecting the local community. The
areas where noise will be significantly higher than ambient noise levels and potential
effects to noise receptors should be specifically noted in the Draft Screening Report.
The report indicates that there is a 6d6 noise increase at a locator in the study area, a
12dB along the road, 15d6 at the intersection, which are all significant increases that
will affect the local community. Better methods of reducing noise should be
recommended in the Draft Screening Report. Methods of mitigating noise impacts for
residents, particularly along the haul route should be required. These methods should
include hedges, noise abatement windows, fencing and air conditioning.
C. Geology and Groundwater Environment
The Geology and Groundwater Environment for the Port Granby Project consists of
the physical characteristics associated with the site and the surrounding study areas.
These characteristics are geology, physiography, topography, stratigraphy, and
seismicity. The baseline study also examined non-radiological qualities associated
with groundwater flow, and the radiological and non-radiological qualities of
groundwater quality, drainage water quality, and soil quality.
Page 42
It is noted that there are no actively-used private water wells in the site study area.
The potential for future use of the ground water resource in the area should be noted.
There may be future development in the area which relies on the ground water
resource for water supply.
Section 9.3 a), paragraph 3, indicates "previous soil samples indicated surficial soils
exceeded MOE soil quality criteria for arsenic, cobalt, copper, nickel, lead, and
antimony in the wastes and mixed soils". This statement is confusing. It seems to
indicate that surface soils exceed the MOE quality criteria for these metals. It should
clearly indicate that there are no natural exceedances for metals in the area, however
the wastes and mixed soils associated with the current waste disposal site exceed
these standards.
A statement should be added that the exceedances of boron are naturally occurring
and not related to waste disposal. Additionally, the text of this section (g.3) of the
report does not clearly convey the location and nature of exceedences of the soil
quality standards for each of the areas discussed (site study area, regional study
area, local study area). Furthermore, it is difficult to determine if the exceedances are
related to the waste materials in the current landfill, former waste disposal practices,
or natural exceedances of various parameters which occur as a result of ambient
conditions. This should be clarified.
Page 43
The report notes that all ground water ultimately discharges into Lake Ontario.
Locally, ground water discharges into creeks (surface water) and does not discharge
into Lake Ontario. Also, it is difficult to understand the relevance of the information
presented in this section. Ground water hardness is a naturally occurring
phenomenon and is generally not relevant to the discussion. The source and nature of
the high sodium and chloride concentrations noted in the site study area should be
explained. Similarly, the source and nature of "other exceedances of Ontario Drinking
Water Standards (ODWS) Guidelines" in wells at the northwestern edge of the burial
area should be explained.
The discussion of drainage water quality is unclear. Does this refer to drainage water
quality in the local, regional, or site study area? The report notes that the water
contained within the ditches does not support aquatic resources. However, it is
important to note that the ditches ultimately drain into surface water features (such as
the creek or Lake Ontario) which do support significant aquatic resources. The nature
and source of the exceedances of Provincial Water Quality Objectives (PWOO)
criteria should be noted. Are they related to the existing Waste Management Facility
site, or ambient natural conditions?
Paragraph 3 of'Radiological Drainage Water Quality' is not clear. It indicates surtace
water samples were collected and analysed for uranium. The. subsequent sentence
indicates there was insufficient flow to collect samples for radionuclide analysis. Our
recollection is that samples have been collected at the seeps and analysed for the full
suite of radionuclides.
Pages 66 and 67
No issues have been raised about ground water flow and flushing. These issues
came up in the Water Treatment Memo and at a minimum, should be acknowledged
in the Draft Screening Report. In addition, while the Screening report is still tentative
on the water treatment technique, there is reference to the ion exchange method.
Given the extent of the study of water treatment methods after the EASR was
submitted, some reference to these reports and their conclusions would have been
expected (e.g. EASR -Appendix G, the Water treatment Memo and the EASR -
Addendum Review).
Page 66
The intent of the first sentence in paragraph 4 is not clear. It indicates the biggest
impact on water quality improvement is expected to occur during the early life of the
LTWMF. Are the RAs referring to clean-up of the existing facility, or construction of
the new facility? We are not aware there was any water quality improvement
associated with construction of the new LTWMF. Also, it is indicated that
Contaminants of Potential Concern (COPC) concentrations are expected to decline
due to flushing of contaminants from the aquifer. It should be noted that this flushing
is related to the existing facility and not the new facility. It should also be noted that
this flushing, while beneficial, will occur over a very long period of time.
It is stated that quantity and quality of ground water discharge into Port Granby Creek
during construction of the LTWMF is predicted to remain approximately the same as
baseline conditions. We disagree with this conclusion, as we have stated in our
previous review of the EASR document.
The purpose of the ground water monitoring program should be clearly stated. Any
.potential change in ground water elevations must then be used to assess potential
changes to base flow and impact to aquatic resources in the Port Granby Creek.
Page 67
It is stated in the 'Existing Waste Management Facility', paragraph 2 that a placement
of a 1 m thick soil cover will provide separation and reduce surtace infiltration and the
residually contaminated soils. This may not necessarily be a benefit as is stated. This
will serve to reduce the rate of flushing of contaminants.
Further explanations should be provided regarding the nature of the ground water
monitoring at the existing WMF. As we have stated in previous reviews, there is
generally insufficient information available to characterize the ground water impacts at
the existing site. Further, site characterization must be undertaken before designing a
monitoring program for the site. Also, it should be clearly stated that there will be a
comprehensive ground water monitoring program put in place. Based on the ground
water monitoring program, the appropriate contingencies can be implemented.
Page 68
It is stated in 'Radiological Ground Water and Drainage Water Quality', paragraph 2
that no mitigation measures are required. To be clear, no mitigation measures are
required based on the current analysis. However, it should be clarified that there will
be a monitoring program to assess potential impacts and, in the event that there are
impacts, appropriate mitigation measures are available and can be implemented.
Page 93
The complete deterioration of the geomembrane liner at the base of the mound is
assumed by the RAs for the year 2150 (pg 93). Why is it assumed that the
geomembrane will not remain intact over time? This assumption in the Draft
Screening Report is less robust than was proposed in the EASR and subsequent
reports from LLRWMO consultants. If the assumption in the Draft Screening Report
prevails, stronger recommendations about mid-term repairs and remediation should
be required as a condition of approval.
D. Terrestrial and Aquatic Environment
For the purpose of the Port Granby Project, the Terrestrial and Aquatic Environment
consists of vegetation communities and species, wildlife habitats, wildlife
communities, and radioactivity in the terrestrial environment. The Aquatic
Environment includes a number of components associated with watercourses and
Lake Ontario. The Peer Review Team believes, in relation to our previous comments
from the Port Granby EASR (March, 2005), that the Draft Screening Report's
coverage of issues and adverse effects pertaining to the terrestrial and aquatic
environment have been adequately addressed.
Page 72
The Migratory Birds Convention Act (MBCA) is mentioned as directing Project
activities to address/mitigate breeding bird habitat. However, .the Screening report
should specify that bird habitat will be preserved in addition to upholding the tenets of
the MBCA.
E. Socio-Economic Environment and Effects
The socio-economic baseline is characterized in terms of its population and economic
base, land use and visual settings, community infrastructure, community services,
traffic and transportation, .municipal finance and administration, residents and
communities, archaeology and cultural heritage resources, and Aboriginal interests.
Socio-economic effects are of particular importance to the residents of Port Granby,
the Municipality of Clarington and the Peer Review Team. For example, it is important
to ascertain how noise and dust will affect the local community.
Overall, the Peer Review Team finds the information provided in the socio-economic
baseline information to be comprehensive and thorough. However, there are areas
in this section of the Draft Screening Report that could be defined in greater depth
with stronger recommendations.
Given the number of minor adverse effects resulting from the project, we suggest a
more explicit and thorough description of the identified mitigation strategies. The RAs
have limited their consideration of socio-economic effects to the definition under the
Canadian Environmental Assessment Act. Nationally, the Act continues to receive
criticism on this overly narrow definition.
A body of research has been completed in the EASR and in supporting documents for
the Port Hope and Port Granby Project regarding socio-economic effects and
mitigation measures. The Peer Review Team recommends that the measures in the
EASR be highlighted to follow up on action items in the Screening Report.
Examples of mitigation measures include the implementation of initiatives to avoid
and reduce real and perceived socio-economic effects from the Project, and the
implementation of measures to address the residual lose of use and enjoyment of
properties nearest to the facility. Additionally, new residents should be informed about
the Project, and a procedure should be implemented so that complaints regarding
truck traffic in the area can be reported and resolved. Residents should also have a
role in monitoring and reporting.
The measures recommended by the Peer Review Team are set out in Appendix A -
'Overview of Mitigation Measures'. These measures should be considered in the Draft
Screening Report. Furthermore, the Peer Review Team suggests a more explicit
description of the mitigation measures than are currently reported in the Draft
Screening Report. This should include specific programs that will be used to address
the identified adverse socio-economic effects of the project such as the business
activity enhancement program as mentioned in the Draft Screening Report (page 74).
Throughout the document there is mention of specific activities that should be
undertaken over the course of the Project's lifespan. For example, a description of
end use activities are referred to as being required (page 24). Yet, discussions of end
use activities are currently underway with the formation of the `End Use Committee'
that is made up of local community members, Municipality of Clarington Staff and the
LLRWMO Staff. The Screening Report should reference the program planning for end
use and require recommendations to be implemented.
Public oversight and community engagement will be an important contributor to the
success of the Project. In contrast to work completed by the LLRWMO, Municipality
and local residents, this critical component of project management is overlooked in
the Draft Screening Report. The Peer Review Team recommends that the Screening
Report specify requirements for:
• Designated community members to be given responsibility for community
liaison;
• Ongoing consultation and communication mechanisms; and
• The role of citizen liaison .groups in ensuring monitoring and mitigation
measures are sound.
Tourism (page 74)
The examination of effects on business in the Port Granby area has overlooked
tourism-based businesses. There also needs to be an emphasis on providing
opportunities for local and farm-based businesses when the site has been restored.
Housing and Property Values (Page 75)
The Property Value Protection (PVP) program has been implemented and has had its
successes. LLRWMO documents defining the PVP Program should be cited. In
addition, the Screening Report should require continuous improvements to the PVP
Program over time.
For example, the Draft Screening Report states that there will be reduced residential
property values and increased difficulties in marketing properties due to the project,
yet an increased amount of turnover of residential properties is expected. However,
the PVP Program should evolve to avoid this problem.
Traffic and Transportation
It is estimated that there will be the movement of 12,500 truck trips (pg 23) in the
Study Area per day during specific periods of the construction phase. The Draft
Screening Report acknowledges that the project will be potentially disruptive to the
local community. Mitigative measures need to be strengthened to minimise and
mitigate effects during the construction phase.
Because there will be disruption to road uses, pedestrians and non-motorized vehicle
traffic along the recommended traffic route (page 77), there needs to be a provision to
notify trucks and have a contract with trucking firms regarding school pick-up/drop off
times in the Draft Screening Report list of mitigative measures (See Appendix A for
examples). The Screening Report should specify that trucks should cease activity
during morning pickups and after school drop offs for local school children.
Also, the potential impacts of a large number of trucks crossing the CNR track level
crossing on Elliot Road is under-assessed in the Draft Screening Report. Signalized
gates should be installed.
F. Environmental Health and Safety
Human health and safety is being examined as part of the Draft Screening Report
because the activities that comprise site preparation, construction and operation of
the Port Granby Project have the potential to affect people. The Draft Screening
Report reviews the radiological health of workers, radiological health of members of
the public, conventional occupational health and safety, and conventional health and
well-being of members of the public. Overall, the Peer Review Team accepts the RA's
conclusions about the environmental health and safety effects as provided in the Draft
Screening Report. However, there are a few instances where greater clarity should be
given.
Although the As Low As Reasonably Achievable (ALARA) principle is mentioned in
the Screening Report, there is no section that specifically address its implications
when used as a principle for mitigation measures (as proposed in the report). The use
of the ALARA principle needs to be strengthened as a critical component of design
and operations.
Page 84
No radiological effects for members of the public are assumed in the Report. The
Peer Review Team agrees with the RA's that public health will not be affected by the
Port Granby Project.
Some wording in the Draft Screening Report is unclear. In Section 10.8(b), subsection
on Workers, the text states "within 20 percent of the CNSC dose limit ..." which
seems to be confusing terminology. Within 20 percent could mean at the 80 percent
level because that is within 20 percent of the limit. Does the text mean less than 20
percent? Two paragraphs below this text, the terminology is "below 10 percent ..."
Consistent terminology that is clear should be used. Please note that there are
several places in the document, where the terminology "within xx percent" is used.
Page 87
In regards to radiological health and safety, the text states that within 2 km of the
LTWMF, the concentrations of radon would be indistinguishable from background,
and simultaneously, radiological constituents in re-suspended dust are not
measurable beyond the 2 km zone. From this information, the text concludes "there
would not be measurable cumulative effects on radiological air quality." These
statements seem to negate one another and imply that within the 2 km zone, the
concentration would be above background and measurable for radon and re-
suspended dust, respectively. If any of the health receptor locations are within 2 km,
then there would be cumulative effects that should be addressed. To clear this matter
up, the conclusion discussion should instead, compare the predicted radon and
radionuclide concentrations to the radon reference level.
It should be noted that based on the results given in the Port Granby EASR section on
Atmospheric Environment Environmental Effects Assessment Report (pg5), Section
3.3.3, at all of the health receptor locations, the predicted radon concentrations are
well below the reference level, and the maximum predicted radionuclide levels are
well below Health Canada reference values, thereby indicating the dose impacts to
the public via these exposure pathways would be insignificant.
Page 87
The EASR considered the effects of the Project on a nuclear energy worker living in
the local study area, but the same considerations are not found in the Draft Screening
Report.
G. Recommended Follow-Up Program
The Draft Screening Report includes a description of a Follow-Up Program of
comprehensive and long-term environmental monitoring to ensure that the
pertormance and operational requirements of the LTWMF are met. In general, the
Peer Review Team supports the need for aFollow-Up Program. However, we feel
that more detail on the follow-up program is required to provide assurance that
specific areas where adverse effects have been identified will be undertaken in
partnership with the Municipality. The Peer Review Team would like the Draft
Screening Report to provide a commitment from the PHAI Transition Project Team
that atmospheric monitoring will occur in real-time, and there will be explicit
operational changes where conditions are not as predicted.
The Follow-Up section proposed monitoring for the minor predicted exceedences of
PMZ,S at the fence-line during construction. This is not adequate. Other emissions
(PM~o, metals, radionuclides etc) were modelled to show lower impacts, however
these lower impacts were based on very careful mitigation plans. As such, monitoring
of all key contaminants (PM~o, metals, radionuclides etc) is warranted to demonstrate
that the mitigation measures were implemented successfully and no impacts occur.
As noted above, this should also include soil measurements and should be closely
linked to the Dust Management Plan.
The LLRWMO had agreed previously to a commitment to use newer low emission off-
road equipment where practical. This commitment or mitigation recommendation is
not found in the Draft Screening Report.
Page 112
It is paramount for the PHAI Transition Team and the RA's to confirm and adopt the
Follow-Up Program before the issuance of a license. The program should be
incorporated into the facility license. Additional consultation is required.
Page 113
The Follow-Up Program states that an adaptive management approach will be utilized
for monitoring the site. As stated earlier, the use of the term 'adaptive management'
infers that changes will be made accordingly to the problems that will arise in the
future during the management and monitoring phase. Adaptive management is
reactive whereas many potential Project effects need to be managed in a proactive
manner. Without further description, an adaptive management approach can be
vague, thus a more detailed description of what adaptive management means for the
Port Granby Project is required.
Also, there is no specific mention of how uncertainty should be dealt with by the
LLRWMO and how the Follow-Up Program will be adapted to varied circumstances.
For example, if adaptive management is utilized when resource managers are
confronted with uncertainty when designing management strategies, they may accept
more risk than an 'impact avoidance' strategy.
Page 115
Mitigation Measures, item 4 (placing wind fencing around exposed stockpiles) -this
mitigation measure is not listed in the text on page 64, section 10.2(b). In addition, the
concept of mulching in item 6 is not discussed in the text on page 64. A detailed
description of the placement of wind fences and the role of mulching is required in the
earlier sections of the report.
Page 122
The follow-up program states that there is a need to `monitor radiation doses to
confirm accuracy of predictions' for members of the public. How is this accomplished?
Will this require random sampling of community members? The Draft Screening
Report should include a description of how radiation will be monitored in the follow up
program. Appropriate measures for identifying when further studies on local dose
rates are required should also be described. The Peer Review Team stresses that the
prime goal of the Project is to make sure that there are no increased radiation doses
among members of the public
Page 123
Table 12.2 for the Follow-Up Program notes that, as a socio-economic residual effect
after mitigation, there may be a voluntary out migration of residents from the locality.
A successful siting process entails that a facility makes the community better off with
the facility than before its construction. Thus, the `hollowing out' of a community as a
result of people leaving is not beneficial to the overall community well being. Further
demonstration is needed to improve monitoring and mitigation measures for local
residents (see Appendix A for mitigation measures).
The report also mentions that a random sample of residents should occur as a
method of implementing a public attitude survey. In the past when such surveys have
been taken by the LLRWMO and their consultants, residents who have not been
contacted have requested their opinion be included in the survey. An over sampling of
all households in the Port Granby Study Area would address these concerns about
the public attitude research.
H. MITIGATION MEASURES RECOMMENDED BY THE PEER REVIEW TEAM
Recommendations for "Population and Economic Base"
1. Communicate frequently and openly with local farmers to keep them aware of
Project activities.
2. Design and deliver a program that maximizes local business opportunities and
benefits.
Recommendations for "Land Use and Visual Setting"
3. Minimize the visibility of on-site activities at the facility by landscaping on-site
and with lights.
Recommendations for "Community Services"
4. Communicate frequently and openly with recreational groups who use the area
near the facility to keep them aware of Project activities.
Avoid trucking during school group pick-up/drop off times along recommended
routes.
Required for "Traffic and Transportation"
6. Design access roads so that farm vehicles can move through the area during
construction (e.g., consider road and shoulder width).
7. Install signals, gates, signs, pavement marks, and traffic controls at Elliot Road
underpass. At all at-grade rail crossings: incorporate wide lanes and shoulders;
maintain site lines; install, as necessary, gate and signal, at rail crossing
controls.
8. Ensure safety of the underpass for the Inter-site Route (e.g., provide temporary
detour around the immediate construction site, have stops or traffic lights at the
underpass construction site).
9. Add signs and any required stop controls for the underpass detour.
10. Have contract clauses that ensure all trucking contractors regularly maintain
their vehicles and train their drivers.
11. Implement contract clauses to ensure trucks stay on recommended
transportation routes. Impose fines if they do not.
12. Provide an orientation for truck drivers so they can drive safely along the
transportation routes.
13. Schedule off-site truck driving to minimize disruption (e.g:, deliver during
designated times, use convoys, stockpile materials).
14. Design and deliver a contingency plan for traffic on Lakeshore Road in case of
an accident to ensure that emergency services can respond appropriately.
15. Notify all local residents in advance about trucking activities, particularly for
oversized loads.
16. Operate a procedure so that complaints regarding truck traffic can be reported
and resolved.
Required for "Municipal finance and administration"
17. Carry out Part B of the Legal Agreement to ensure that the LLRWMO pays for
project-related road improvements; capital costs related to the facility; and on-
going communications and related project expenses.
18. Implement Part B of the Legal Agreement, to ensure that LLRWMO pays for
administrative costs.
Recommendations for "Residents and communities"
19. Implement initiatives to avoid, reduce, or redress real and perceived adverse
socio-economic effects and enhance beneficial effects of the Port Granby
project.
20. Set up a two-tier complaints system.
21. Implement measures to address the residual loss of use and enjoyment of
properties nearest to the Facility. These measures would include developing
management plans for noise, dust, odour and traffic; and establishing
thresholds for when contingencies are implemented (e.g., temporarily stopping
work, curtailing offsite transportation activities, and imposing fines and
penalties to contractors who do not comply with requirements).
22. Keep new comers informed about the Project
23. Inform neighbours about results of monitoring for noise and dust, and allow a
designated neighbourhood representative to inspect the site.
24. Provide an end-use for the area that makes the most of passive recreation.
25. Develop an appropriate "name" for the facility.
26. Request that the CNSC license explicitly assure that the LTWMF and the
existing WMF can be used only for the purpose of managing a specific volume
of historic LLRW from the Municipality of Clarington over the long term.
27. Completely remove and rehabilitate the upgraded portions of Elliot Road to
pre-Project conditions (to the extent possible).
28. Completely remove the underpass at Lakeshore Road and rehabilitate the
areas along Lakeshore Road affected by the underpass to pre-Project
conditions (to the extent possible).
Attachment 116
PORT GRANBY LONG-TERM
LOW-LEVEL RADIOACTIVE WASTE
MANAGEMENT PROJECT
REVIEW AND RECOMMENDATIONS
TO THE MUNICIPALITY OF CLARINGTON
ON THE DRAFT SCREENING REPORT (MAY 2009)
Prepared By
Hardy Stevenson and Associates Limited
364 Davenport Road
Toronto, Ontario
M5R 1K6
June 2009
~~~~~J~
ANA AS~IA°7'ES
Table of Contents
1.0 Introduction ....................................................................................................... 1
2.0 Peer Review Methodology ................................................................................. 2
3.0 General Comments ................................................................... .......................... 3
4.0 Specific Comments .................................................................. .......................... 4
4.3 Geology and Groundwater Environment ............................. .......................... 7
4.4 Terrestrial and Aquatic Environment .................................. .......................... 9
4.7 Environmental Health and Safety ........................................ .........................11
4.8 Recommended Follow-Up Pxogram .................................... .........................13
5.0 Conclusions and Recommendations ................................................................14
Municipal Peer Review -Draft Screening Report: Port Granby Long Term Low-Level
Radioactive Waste Management Project
Executive Summary
This report presents to the Municipalitq of Clarington Council the results of the Municipal
Peer Review Team (MPRT) review of the Draft Screening Report (DSR) fox the Poxt
Gxanbv Long-Term Low-Level Radioactive Waste (LLRW~ Management Project. The Part
Granby Draft Screening Report presents the conclusions from the Responsible Authorities
(RA's) regarding the Part Granby Environmental Assessment (EA) as documented in the
Environmental Assessment Study Report (Er1SR). The MPRT report provides comments on
the DSR's assessment and conclusions of the issues pertaining to the atmospheric
environment, geology and groundwater, the socioeconomic environment and human health
and safety.
Among the many issues important to the Municipality of Clarington, hvo stand out: 1) what
axe the conclusions of the RAs in terms of the review of the EASR completed by the Low
Level Radioactive Waste Management Office (LLRWMO) and, 2) does the Project as
defined in the DSR differ from the Municipality's preferred option? The MPRT concludes
that the DSR presents a thorough review of the Project and agrees with the majority of the
analysis and conclusions. We also agree with the conclusion of the DSR that with
appropriate mitigation measures and follow-up monitoring, the Project is not likely to cause
significant u~despread adverse etivixonmental effects. The MPRT does, however,
recommend a strengthening of impact avoidance and mitigation measures to further
minimize the potential effects for the local community.
1.0 Introduction
The Port Granby Draft Screening Report (DSR) contains the conclusions from the
Responsible Authorities (RA's) regarding the Environmental Assessment Study Report
(EASR) fox the Poxt Granby Long-Term Low-Level Radioactive Waste (LLRW)
Management Project.
The Port Granby Project is based on a community proposal developed by the Municipality
of Clarington in 2001. The purpose of the Port Gxanbv Project is to clean up and provide
appropriate local long-term management of LLRW and marginally contaminated soils in the
Municipality of Clarington. Also, to relocate the waste from the existing site fox management
in an environmentally safe and socially acceptable, suitably constricted and appiopxiately
controlled site fox the long term. Therefore, the Port Granby Project depicts the preferred
alternative fox the long-term management of the historic radioactive wastes in the
Municipality of Clarington. As part of the regulatory process an Environmental Assessment
(EA) is required under the Canadian Environmental Assessment Act (CEAA). The RA's for
the EA process are the Canadian Nuclear Safety Commission (CNSC) and Nataral
Resources Canada (NRCan).
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The DSR was prepared in response to the Environmental Assessment Study Report (E.ASR)
and was prepared by' the RA's. The RA's used the information provided in the EASR to
make a determination under the CEAA whether ox not the project will cause significant
adverse environmental effects, taking into account mitigation measures.
The scope of the project under the CEAA refers to the components of the proposal and
undertakings of the project (site preparation, construction, management, operation of the
waste management facility). The DSR presents the RA's findings on the environmental
effects predicted to occur as a result of the Project. They assessed the following
emrixonmental components: atmospheric, geological and groundwater, aquatic, terxestsial,
socio-economic, Aboriginal interests, human health and safety, accidents and malfunctions
and cumulative effects. The environmental assessment predicts that the Project will result in
many em-ixonmental benefits as well as some adverse effects that can be addressed by
mitigative measures. The RA's conclude that the Poxt Granby Project will not cause
significant environmental effects. As a result, they recommended the approval of the
Project. A follow up program is also recommended in the DSR.
Generally, the peer review team agrees with the majority of the analysis and conclusions of
the DSR and that with appropriate mitigation measures and follow-up monitoring, the
Project is not likely to cause significant adverse environmental effects. This MPRT report
provides recommendations fox strengthening the Screening Report, providing greater clarity
and offers recommendations to further enhance mitigation and follow-up program and
acti~nties.
Oux comments axe structured in a manner that systematically addresses the specific sections
of the Draft Screening Report:
• General Comments
• Project Scope
• Description of the Existing Environment and Environmental Effects
• Atmospheric Environment
• Geology and Groundwater Environment
• Terrestrial and Aquatic Environment
• Socio-Economic Environment
• Human Health and Safety
• Follow-up Program
2.0 Peer Review Methodology
In the review of the DSR, the MPRT considered the implications of the Legal Agreement
that was signed between the Town of Port Hope, the Township of Poxt Hope (now the
Munucipality of Port Hope) and the Municipality of Clarington with the Minister of Natural
Resources in 2001. The Agreement provided the legal basis for the long term solution for
MPRT Review of the Draft Screening Report
Haxdv Stevenson and Associates Limited
June 2009
radioactive waste management which lead to the creation of the Port Hope Area Initiative
~~~•
The Legal Agreement stipulates that the Municipal acceptance of the Screening Repart
should be based on the following:
• The Municipality is consulted on Alternatives.
• LLRVUMO to submit 1? ASR after consulting with Clarington.
• Claxington must give written consent to preferred option (which Clarington did in
200'x.
• The option recommended for approval does not differ from the Municipality of
Clarington's preferred option.
This report is intended to provide a basis fox formal Municipal comments on the DSR. An
important consideration is whether the Project as defined in the DSR continues to support
the preferred option. Fox example, the recommended option would be consistent with the
components such as the capillary layer that was approved by the Municipality continues to
be brought forward and described in the DSR.
In reviewing how the RA's assessed the EASR, we also determined whether the DSR would
be able to clearly address the following considerations:
• Is the problem properly understood in the DSR?
• Is the project properly described?
• Has the existing environment been adequately described and understood?
• Is the constmction process properly described?
• Do the RA's agree with the LLRWMO in relation to off-site environmental effects
to the Municipality of Clarington and Poxt Granby residents?
• Axe monitoring requirements recommended in the DSR adequate?
• Do the RA's adequately specify design features for health, safety and environmental
control?
• Has the DSR over xehed upon information gaps being addressed in the Detailed
Design stage through reports and protocols that axe still to come (e.g. Part Granby
Environmental Monitoring Plan, Detailed Environmental Protection Plan)?
3.0 General Comments
Overall, the biPRT concludes that the DSR has a comprehensive understanding of the
EASR and the studies. The analysis has addressed many important details. The Project and
the problem axe properly understood in the DSR. The DSR could have better acknowledged
reports that will come forward in the Detailed Design Stage, but are none the less important
fox a complete understanding of the environmental protection regime. Mitigation measures
and follow up measures tends to understate those agreed to and reference in the EASR and
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discussed by the LLRWNIO and MPRT. Additionally, some areas such as atmospheric
emissions, while sound, could be strengthened. In many areas, the RA's rely on `adaptive
management', whereas `impact avoidance' would be the correct approach. The MPRT
concludes that that DSR should be supported and endorsed by the Municipality.
Recommended additions to the DSR should be forwarded to the RA's fox their
consideration.
4.0 Specific Comments
The following sections axe the MPRT comments that relate to specific sections in the Draft
Screening Report
4.1 Description of the Existing Environment and Environmental Effects
The EASR examines effects of the Project on the biophysical and human environment. The
DSR addresses the existing, ox baseline, environmental conditions in the area surrounding
and encompassing the current and proposed waste management facility. In doing so, the
DSR provides an accarate account of the baseline conditions fox the Port Granby Study
Area. However, there axe a few minor areas where the description can be improved.
Page 17
Uranium needs to be added to the list of contaminants of greatest concern to be consistent
with the second sentence in this paragraph that discusses uranium.
Page 52
In the community profile within the DSR, there is not a specific description of the Port
Granby community ox its residents. In the opinion of the MPRT, it is important to evaluate
the Project against the backdrop of residents and businesses who have the greatest need to
ensure the Project management is sound. Port Granby should be defined as at the very least,
the Poxt Granby settlement (of multiple homes/ businesses) to/and ox within the local study
area.
Page 71
The following effects on vegetation should be described fully in the DSR. We recommend
that the following effects be more closely xefexenced:
• The relocation of the Long Term Waste Management Facility (LTWMF) storxnwatex
management pond;
• New vegetative communities at the LTWMF, not just farm fields, need to be better
xefexenced in the DSR (e.g. the fen near east gorge); and
• A landscape management plan fox the LT~SUMF will be enacted as an end use and
requires community and municipal input. Furthermore, end use planning is not evell
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acknowledged in the DSR. In contrast, all parties have spent considerable time and
money identifying a preferred end use.
4.2 Atmospheric Environment and Effects
The atmospheric environment consists ofnon-radiological air quality, radiological air quality,
and noise. As part of the assessment, the DSR also discusses climate and meteorology and
their effects on the Project. Overall, the xepoxt provides a reasonable over7ew stuiunary of
the air quality aspects, mitigation and monitoring developed for the Part Granby project.
However, there are a few minor areas where the description can be improved.
The bIPRT is concerned about the use of `adaptive management' and monitoring as the
dominant waste excavation guideline. This approach leads to accepting average exposure
levels as opposed to an emphasis on avoiding exposure incidents. Monitoring to see if
radiological contaminants have left the site is useful after excavation has occurred but is an
unacceptable method to be used while the excavation is underway. The MPRT recommends
impact avoidance as the rule governing the excavation. From this perspective, dust would be
measured and minimised at the excavation site. Measuring fox fugitive dust at the fence line
involves acceptance of greater risk then necessary. Fuxthexxnoxe, monitoring to see if dust
has exceeded the site fence line is inadequate as a method of evaluating whether construction
practices axe sound.
Throughout the xepoxt there is discussion of needing a good Dust Management Plan to
ensure that there axe no off-site impacts due to fugitive dust emissions. It is stated that the
plan u=ill be developed as part of the Detailed Design Phase. We accept this, but will
continue to point out that the details of that plan axe extremely important and axe the key to
ensuring off-site impacts are minimi>ed. All aspects of the plan, including specifics on
mitigation, monitoring (including real-time), complaint response, corrective actions and
record keeping will be very important. We recommend that the DSR strengthen
recommendations to develop a Dust Management Plan that controls dust at the source
rather than at the Project fence line.
Additionally, the plan needs to consider whether dedicated trucks (e.g. watering trucks) axe
needed fox the waste areas and the haul route between. Given the importance of mitigation
in avoiding impacts, especially those that arise from dust, there needs to be a more explicit
discussion of the requirements fox proper mitigation plans in the screening xepoxt In
principle, particulate matter should not be leaving the site boundary at any time.
Page 60
The xepoxt cites a `conservative approach' in terms of the worst month scenario being
averaged over the course of a year. However, it is not a conser=ative approach when you
take into account, fos example, that wind born thorium should not leave. the site boundary
over the course of a year. In relation to other atmospheric emissions, no exceedences axe
anticipated.
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Page 62
Under particulate discussions, in the end of the paragraph, it is stated that National Institute
of Health and Safety (NIOSH) standards will be met. These axe occupational standards. The
previous discussions between the MPRT and the LLRWMO about the management of
particulates pertained to ambient air quality fox public exposure. The NIOSH statement
seems out of place; ox at least warrants some farther discussion and context (in a separate
paragraph). If it is the intent to discuss occupational levels in this section, then similar
discussions axe warranted fox conventional air contaminants and fox metals.
Page 64
The discussion of particulate bound radionuclides inclicates that this will be monitoring by
PM10 samplers. Typically metals and other particulate bound contaminants axe done by TSP
(total suspended particulate), not PM10. The approach to measuring these contaminants
needs to be reassessed.
Page 65 and 67
The discussion of soil impacts of metals and radionuclides indicates that there axe no
predicted impacts. On page 67, verification is considered through a `robust sampling design'.
This is not defined. We agree that soIl sampling after completion of the cleanup should be
undertaken to verify that no off-site dispersion of contaminants have occurred. Note: The
`robust' sampling is not discussed in Section 12: Follow-Up Program and should be. The rule
should be no `contamination of residential properties'.
Pages 62, 63
This section states that there may be a cessation of activities during high wind conditions.
We find the conclusions of the DSR on dust to be weak. The MPRT recommends that high
wind scenarios should be anticipated through an onsite meteorological station and
monitoring. Excavation activities should not be initiated if high winds are anticipated.
Furthermore, this recommendation needs to be part of the Dust Management Plan as part of
the Detailed Design Phase.
Page 83
There are ui depth studies on the potential noise impacts from the project in the EASR as
provided by SENES that indicate some of the concerns with noise affecting the local
community. The areas where noise will be significantly higher than ambient noise levels and
potential effects to noise receptors should be specifically noted in the Screening Report.
The xepart indicates that there is a 6dB noise increase at a locator in the study area, a 12dB
along the road, 15dB at the intersection, which axe all significant increases that will affect the
local community. Better methods of reducing noise should be recommended in the
Screening Report during the follow-up stage. Methods of mitigating noise impacts fox
residents, particularly along the haul route should be required. These methods should include
hedges, noise abatement windows, fencing and air conditioning.
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4.3 Geology and Groundwater Environment
The Geology and Groundwater Environment for the Port Granby Project consists of the
physical chazacteristics associated with the site and the surrounding study areas. These
characteristics are geology, physiography, topogxaphp, stratigxaphy, and seismicity. The
baseline study also examined non-radiological qualities associated with groundwater flow,
and the radiological and non-radiological qualities of groundwater quahty, drainage water
quality, and soil quality-.
Page 42
It is noted that there are no actively-used private water evells in the site study azea. The
potential fox future use of the ground water xesoarce in the area should be noted. There may
be future development in the area which relies on the ground evater resource fox water
supply.
Section 9.3 a), paragraph 3, indicates "previous soil samples indicated surficial soils exceeded
MOE soil quality criteria for arsenic, cobalt, copper, nickel, lead, and antimony in the evastes
and mixed soIls". This statement is confusing. It seems to indicate that surface soils exceed
the MOE quality criteria fox these metals. It should cleazly indicate that there aze no natural
exceedances fof metals in the area, however the wastes and mixed soils associated with the
current waste disposal site exceed these standards.
A statement should be added that the exceedances of boron are naturally occurring and not
related to waste disposal. Additionally, the text of this section (9.3) of the xepoxt does not
clearly convey the location and nature of exceedences of the soil quality standards fox each
of the areas discussed (site study area, regional study area, local study area). Furthermore, it is
difficult to determine if the exceedances are related to the waste materials in the current
waste management site or natural exceedances of various parameters which occur as a result
of ambient conditions. This should be clarified.
Page 43
The xepoxt notes that all ground water ultimately discharges into Lake Ontario. Locally,
ground water dischazges into creeks (surface water) and does not discharge into Lake
Ontario. Also, it is difficult to understand the relevance of the information presented in this
section. Ground water hazdness is a naturally occurring phenomenon and is generally not
relevant to the discussion. The source and nature of the high sodium and chloride
concentrations noted in the site study area should be explained. Similarly, the source and
nature of "other exceedances of Ontario Drinking Water Standards (ODWS) Guidelines" in
wells at the northwestern edge of the burial area should be explained.
The discussion of drainage water quality is unclear. Does this refer to drainage water quality
in the local, regional, or site study area? The report notes that the water contained within the
ditches does not support aquatic resources. However, it is important to note that the ditches
ultimately drain into surface water features (such as the creek ar Lake Ontario) which do
support significant aquatic resources. The nature and source of the exceedances of Provincial
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Water Quality Objectives (PWQO) criteria should be noted. Axe they related to the existing
Waste Management Facility site, or ambient natural conditions?
Paragraph 3 of `Radiological Drainage Water Quality' is not clear. It indicates surface water
samples were collected and analysed fox uranium. The subsequent sentence indicates there
was insufficient flow to collect samples fox radionuclide analysis. Oux recollection is that
samples have been collected at the seeps and analysed fox the full suite of radionuclides.
Pages 66, 67
No issues have been raised about ground water flow and flushing. These issues came up in
the Water Treatment Memo and at a minimum, should be acknowledged in the Screening
Report. In addition, while the Screening report is still tentative on the water treatment
technique, however there is reference to the ion exchange method. Given the extent of the
study of water treatment methods after the EASR was submitted, some reference to these
reports and their conclusions would have been expected (e.g. EASR -Appendix G, the
Water treatment Memo and the EASR -Addendum Review).
Page 66
The intent of the first sentence in paragraph 4 is not clear. It indicates the biggest impact on
water quality improvement is expected to occur during the early life of the Long Texm Waste
Management Facility (LTWMF). Are the RA's ieferxing to clean-up of the existing facility, or
construction of the new facility? We axe not aware there was any water quality improvement
to the existing facility associated with construction of the necv LTWMF. Also, it is indicated
that Contaminants of Potential Concern (COPC) concentrations are expected to decline due
to flushing of contaminants from the aquifer. It should be noted that this flushing is related
to the existing facility and not the new facility. It should also be noted that this flushing,
while beneficial, will occur over a very long period of time.
It is stated that quantity and quality of ground water discharge into Poxt Granby Creek
during construction of the LTWMF is predicted to remain appxoximatelp the same as
baseline conditions. We disagree with this conclusion, as we have stated in our previous
review of the EASR document
The purpose of the ground water monitoring program should be clearly stated. Any potential
change in ground water elevations must then be used to assess potential changes to base
flow and impact to aquatic resources in the Poxt Granby Creek.
Page 67
It is stated in the `Existing Waste Management Facility', paragraph 2 that a placement of a 1
m thick soil cover will provide separation and reduce surface infiltration and the residually
contaminated Bolls. This may not necessarily be a benefit as is stated. This will sere to
reduce the rate of flushing of contaminants.
Further explanations should be provided regarding the nature of the ground water
monitoring at the existing Waste Management Facility site. As we have stated in previous
reviews, there is generally insufficient information available to characterize the ground water
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impacts at the existing site. Farther site characterization must be undertaken before
designing a monitoring program fox the site. Also, it should be clearly stated that there will
be a comprehensive ground water monitoring program put in place. Based on the ground
water monitoring program, the appropriate contingencies can be implemented.
Page 68
It is stated in `Radiological Ground Water and Drainage Water Quality', pazagxaph 2 that no
mitigation measures axe required. To be dear, no mitigation measures axe required based on
the carxent analysis. However, it should be clarified that there will be a monitoring program
to assess potential impacts and, in the event that there axe impacts, appropriate mitigation
measures axe available and can be implemented.
Page 93
The complete deterioration of the geomembxane liner at the base of the mound is assumed
by the RA's fox the year 2150 (pg 93). Why is it assumed that the geomembxane will not
remain intact over time? This assumption in the DSR is less robust than was proposed in the
EASR and subsequent reports from LLRWNIO consultants. If the DSR assumption prevails,
stronger recommendations about mid-term repairs and xemediation should be required as a
condition of approval.
4.4 Terrestrial and Aquatic Environment
Fox the parpose of the Port Granby Project, the Terrestrial and Aquatic Environment
consists of vegetation communities and species, wildlife habitats, wildlife communities, and
radioacti~rity in the terrestrial environment. The Aquatic Environment includes a number of
components associated with watercourses and Lake Ontario. In relation to our previous
comments from the Poxt Granby 1? ASR (Mazch, 2005), we believe that the DSR's coverage
of issues and adverse effects pertaining to the terrestrial and aquatic environment have been
adequately addressed.
Page 72
The Migratory Birds Convention Act (MBCA) is mentioned as directing Project activities to
address/mitigate breeding bird habitat. However, the Screening report should specify that
bird habitat will be preserned in addition to upholding the tenets of the MBCA.
4.6 Socio-Economic Environment and Effects
The Socio-economic baseline is chazactexized in terms of its population and economic base,
land use and visual settings, community infxastmcture, community serc-ices, traffic and
transportation, municipal finance and administration, residents and communities,
archaeology and cultural heritage xesoarces, and Aboriginal interests. Socio-economic
effects axe of paxticulaz importance to the residents of Port Granby, the Municipality of
Claxington and the MPRT. For example, it is important to ascertain how noise and dust will
affect the local community.
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June 2009
Overall, the MPRT fmds the information provided in the socio-economic baseline
information to be comprehensive and thorough. However, there axe areas in this section of
the DSR that could be defined in greater depth with stronger recommendations.
Given the number of minor adverse effects resulting from the project, we suggest a more
explicit and thorough description of the identified mitigation strategies. The RA's have
limited their consideration of socioeconomic effects to the definition under the Canadian
Environmental Assessment Act. Nationally, the CEAA continues to receive criticism on this
overly narrow defuution.
A body of research has been completed in the EASR and in supparting documents for the
Port Hope and Port Granby Project regarding socio-economic effects and mitigation
measures. We recommend that the measures in the EASR be highlighted to follow up on
action items in the Screening Report. Examples of mitigation measures include the
implementation of initiatives to avoid and reduce real and perceived socio-economic effects
from the Project, and the implementation of measures to address the residual lose of use and
enjoyment of properties nearest to the facility. Additionally, necv residents should be
informed about the Project, and a procedure should be implemented so that complaints
regarding truck traffic in the area can be reported and resolved.
Residents should also have a role in monitoring and reporting. See Appendix A - `Overview
of Mitigation Measures' for HSAL's recommended measures. These measures should be
documented in the Screening Report. Furthermore, we suggest a more explicit description of
the mitigation measures that axe currently reported the DSR. This should include specific
programs that will be used to address the identified adverse socio-economic effects of the
project such as the business activity enhancement program as mentioned in the DSR (page
74).
Throughout the document there is mention of specific activities that should be undertaken
over the course of the Project's lifespan. Fox example, a description of end use activities axe
referred to as being required (page 24). Yet, discussions of end use activities axe currently
underway with the formation of the `End Use Committee' that is made up of local
community members, Municipality of Clarington Staff and the LLR~Y~MO staff. The
Screening Report should reference the program planning fox end use and require
recommendations to be implemented.
Public oversight and community engagement will be an important conuibutox to the success
of the Project. In contrast to work completed by the LLRWb10, Municipality and local
residents, this critical component of project management is overlooked in the DSR. We
recommend that the Screening Report specify requirements for:
• Designated community members to be given responsibility fox community liaison;
• Ongoing consultation and communication mechanisms; and
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The role of citizen liaison groups in ensuring monitoring and mitigation measures axe
sound.
Page 74
Tourism
The examination of effects on business in the Poxt Granby area has overlooked tourism-
based businesses. There also needs to be an emphasis on providing opportunities fox local
and farm-based businesses when the site has been restored.
Page 75
Housing and Properly I~alues
The Property Value Protection (PVP) program has been implemented and has had its
successes. LLRWt~lO documents defusing the PVP Program should be cited. In addition, the
Screening Report should require continuous improvements to the PVP Program over time.
Fox example, the DSR states that there will be reduced residential property values and
increased difficulties in marketing properties due to the project, yet an increased amount of
turnover of residential properties. However, the PVP Program should evolve to avoid this
pxo6lem.
Traffzc and Tranpartatian
It is estimated that there will be the movement of 12, 500 truck trips (pg 23) in the Study
Area over six years during the construction phase. The DSR acknowledges that the project
mill be potentially disruptive to the local community. Mitigative measures need to be
strengthened to minicxuse and mitigate effects during the construction phase.
Because there will be disruption to road uses, pedestrians and non-motorised vehicle traffic
along the recommended traffic route (page 77), there needs to be a provision to notify trucks
and have a contract with trucking firms regarding school drop off times in the DSR's list of
mitigative measures (See Appendix A fox examples). The Screening Report should specify
that trucks should cease activity during morning pickups and after school drop offs fox local
school children.
Also, the potential impacts if a large number of trucks crossing the CNR track level crossing
on Elliot Road is under-assessed in the DSR. At a minimum, signalised gates should be
installed.
4.7 Environmental Health and Safety
Human health and safety is being examined as part of the DSR because the activities that
comprise site preparation, construction and operation of the Poxt Granby Project have the
potential to affect people. The DSR reviews the radiological health of workers, radiological
health of members of the public, conventional occupational health and safety, and
conventional health and well-being of members of the public. Overall, the MPRT accepts
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the RA's conclusions about the environmental health and safety effects as provided in the
DSR, however, there aze a few instances where greater clarity should be given.
Although the As Low As Reasonably Achievable (ALARA) principle is mentioned in the
Screening Report, there is no section that specifically address its implications when used as a
principle for mitigation measures (as proposed in the report). The use of the ALARA
principle needs to be strengthened as a critical component of design and operations.
Page 84,
No radiological effects fox members of the public axe assumed in the Report. The MPRT
agrees with the RA's that public health will not be affected by the Poxt Granby Project.
Some wording in the DSR is unclear. In Section 10.8(6), subsection on Woxkexs, the text
states "within 20 percent of the CNSC dose limit ..." which seems to be confusing
terminology. Within 20 percent could mean at the 80 percent level because that is within 20
percent of the limit. Does the text mean less than 20 percent? Two paragraphs below this
text, the terminology is "below 10 percent ..." Consistent terminology that is clear should be
used. Please note that there are several places in the document, where the terminology
"within xx percent" is used.
Page 87
In xegazds to radiological health and safety, the text states that within 2 km of the LT\X/b4F,
the concentrations of radon would be indistinguishable from background, and
simultaneously, radiological constituents in xe-suspended dust axe not measurable beyond the
2 km zone. From this information, the text concludes "there would not be measurable
cumulative effects on radiological air quality." These statements seem to negate one another
and imply that within the 2 km zone, the concentration would be above background and
measurable fox radon and re-suspended dust, respectively. If any of the health xeceptox
locations axe within 2 km, then there would be cumulative effects that should be addressed.
To clear this matter up, the conclusion discussion should instead, compare the predicted
radon and radionuclide concentrations to the radon reference level.
It should be noted that based on the results given in the Poxt Granby EASR section on
Atmospheric Environment Environmental EffectsAsressment Report (PGS), Section 3.3.3, at all of the
health xeceptox locations, the predicted radon concentrations aze well below the reference
level, and the maximum predicted radionuclide levels aze well below Health Canada
reference values, thereby indicating the dose impacts to the public via these exposure
pathway s would be insignificant.
Page 87
The I;ASR considered the effects of the Project on a nuclear energy worker living in the
local study area, but the same considerations axe not found in the DSR.
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4.8 Recommended Follow-Up Program
The DSR includes a description of a Follow-Up Program of comprehensive and long-term
environmental monitoring to ensure that the performance and operational requirements of
the LT'~~IMF are met. In general, the MPRT support the need fox aFollow-Up Pxogxam.
However, we feel that more detail on the follow-up program is required to provide assurance
-that specific areas where adverse effects have been identified will be undertaken in
partnership with the Municipality. The MPRT would like the Screening Report to require a
commitment from the PHt1I Transition Project Team that. atmospheric monitoring will
occur in real-time, and there will be explicit operational changes where conditions are not as
predicted.
The Follow-Up section proposed monitoring fox the minor predicted exceedences of P1iI2.5
at the fence-line during construction. This is not adequate. Other emissions (PM1Q metals,
radionuclides etc) were modelled to show lower impacts, however these lower impacts were
based on very careful mitigation plans. As such, momtoxing of all kev contaminants (PM10,
metals, radionuclides etc) is warranted to demonstrate that the mitigation measures were
implemented successfully and no impacts occur. As noted above, this should also include
soil measurements and should be closely linked to the Dust Management Plan.
LLRWb4O agreed previously to a commitment to use newer low emission off-road
equipment where practical. This commitment ox mitigation recommendation is not found in
the DSR.
Page 112
It is paramount fox the PHAI Transition Team and the RA's to confirm and adopt the
Follow-Up Program before the issuance of a license. The program should be incorporated
into the facility- license. Additional consultation is required.
Page 113
The Follow-Up Pxogxam states that an adaptive management approach will be utilised fox
monitoring the site. As stated earlier, the use of the term `adaptive management' infers that
changes will be made accordingly to the problems that will arise in the future during the
management and monitoring phase. Adaptive management is reactive whereas many
potential Project effects need to be managed in a proactive manner. Without further
description, an adaptive management approach can be vague, thus a more detailed
description of what adaptive management means fox the Port Granby Project is required.
Also, there is no specific mention of how uncertainty should be dealt with by the LLRWTvIO
and how the Follow-Up Program will be adapted to varied circumstances. Fox example, if
adaptive management is utilized when resource managers axe confronted with uncertainty
when designing management strategies, they may accept more risk than an `impact
avoidance' strategy.
Page 115
IVlitigation Measures, item 4 (placing wind fencing around exposed stockpiles) -this
mitigation measure is not listed in the text on page 64, section 10.2(6). In addition, the
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concept of mulching in item 6 is not discussed in the text on page 64. A detailed description
of the placement of wind fences and the role of mulching is required in the earlier sections
of the report.
Page 122
The follow-up program states that there is a need to `monitor radiation doses to confirm
accuracy of predictions' fox members of the public. How is this accomplished? Will this
require random sampling of community members? The DSR should include a description of
how radiation will be monitored in the follow up program. Appropriate measures fox
identifying when further studies on local dose rates axe required should also be described.
The MPRT stresses that the prime goal of the Project is to make sure that there are no
increased radiation doses among members of the public.
Page 123
Table 12.2 fox the Follow-lip Program notes that as a socio-economic residual effect after
mitigation, there may be a voluntary out migration of residents from the locality. A
successful siting process entails that a facility makes the community better off with the
facility than before its construction. Thus, the `hollowing out' a community as a result of
people leaving is not beneficial to the overall community well being. Further demonstration
is needed to improve monitoring and mitigation measures fox local residents (see Appendix
A fox mitigation measures).
The report also mentions that a random sample of residents should occur as a method of
implementing a public attitude survey. In the past when such surveys have been taken by the
LLRWn10 and their consultants, residents who have not been contacted have requested
their opinion be included in the survey. An over sampling of all households in the Poxt
Granby Study Area would address these concerns about the public attitude research.
5.0 Conclusions and Recommendations
During our review of the DSR, the MPRT considered: 1) the conclusions of the Regulators=
Authorities in terms of the review of the EA and, 2) if the Project as defined in the DSR
differs from the Municipality's preferred option? The MPRT accepts the RA's analysis
provided in the DSR. Fuxthexmoxe, the MPRT note that the DSR recommends the approval
of the Project and that the Pxojectas described in the DSR reflects the Project that has been
accepted by the Municipality. We do not anticipate any significant adverse effects from the
Project.
There axe many areas of the DSR that can be strengthened. We recommend the requirement
of a more thorough and comprehensive follow-up program in order to confirm the accuracy
of predictions of environmental effects and effectiveness of mitigation measures.
Fuxthexmoxe, the DSR should highlight provisions that minimize impacts on the community
and residents. The MPRT has confidence that the necessary commitments will be
implemented. The role of the Municipality and the community in delivering mitigation and
monitoring that has been prevalent thorough the EA process should be reiterated in the
IviPRT Review of the Draft Screening Report tq
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report. We recommend that the DSR should require the proponent to further involve the
community in an oversight role in obtaining feedback on the effectiveness of the mitigation
measures and the monitoring and follow-up strategies.
Summary ofMPIZT l~ecommendatianc•
1)T he Screening Report (SR) needs to stress avoidance measures not just monitoring
measures;
2)T he SR requires stronger water treatment recommendations;
3)T here needs to be a better understanding of end-use activities;
4)Th e SR needs to specifically address nuclear energy workers living in the azea;
5)T here needs to be continuous improvement of the PVP program;
6)R eftne the definition of the geomembxane liner's lifespan;
7)Follo w through with taking trucks off the roads during school bus pick up tunes;
8)Mea sure and monitor dust emissions at source versus at the fenceline;
9)E nsuxe that local residents are involved in the monitoring process;
10) There is too much reliance on adaptive management over impact avoidance;
11) The SR comments should acknowledge other relevant studies (Detailed Design
Document, Remediation Verification Protocol, Environmental Management and
Protection Manual, etc.);
12) There need to be specific impact management plans fox homes along transportation
routes
13) The Public Attitude survey methodology should over sample local residents; and
14) The SR needs to prescribe improved safety measures for the crossing at the CNR
line at Elliot Road in relation to truck traffic.
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