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HomeMy WebLinkAboutPSD-073-09 Clarrin�ton REPORT Leading the Way PLANNING SERVICES Meeting: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE Date: Monday, July 6, 2009 Report#: PSD-073-09 File #: PLN 26.15 By-law#: Subject: DARLINGTON NEW NUCLEAR BUILD ENVIRONMENTAL ASSESSMENT MUNICIPALITY OF CLARINGTON PEER REVIEW COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT RECOMMENDATIONS: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1. THAT Report PSD-073-09 be received; 2. THAT Report PSD-073-09, including the peer review report prepared by Morrison Hershfield Limited (Attachment 1), be submitted to Ontario Power Generation as the Municipality of Clarington's comments on the Draft Environmental Impact Statement for the Darlington New Nuclear Build Project; 3. THAT Ontario Power Generation be thanked for providing the Municipality of Clarington with the opportunity to undertake a peer review of the draft Environmental Impact Statement prior to its submission to the Joint Review Panel; 4. THAT Morrison Hershfield be thanked for their efforts in completing the peer review in a timely manner; 5. THAT a copy of Report PSD-73-09 and Council's decision be forwarded to Ontario Power Generation and the Regional Municipality of Durham; and 6. THAT all interested parties listed in this report and any delegations be advised of Council's decision. CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T(905)623-3379 F (905)623-0830 Q ri�gton ing the Way REPORT PLANNING SERVICES Meeting: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE Date: Monday, July 6, 2009 ReSoku.T,+oyt41G pA - 4 vT - c>c� Report#: PSD-073-09 File #: PLN 26.15 By-law#: Subject: DARLINGTON NEW NUCLEAR BUILD ENVIRONMENTAL ASSESSMENT MUNICIPALITY OF CLARINGTON PEER REVIEW COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT RECOMMENDATIONS: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1. THAT Report PSD-073-09 be received; 2. THAT Report PSD-073-09, including the peer review report prepared by Morrison Hershfield Limited (Attachment 1), be submitted to Ontario Power Generation as the Municipality of Clarington's comments on the Draft Environmental Impact Statement for the Darlington New Nuclear Build Project; 3. THAT Ontario Power Generation be thanked for providing the Municipality of Clarington with the opportunity to undertake a peer review of the draft Environmental Impact Statement prior to its submission to the Joint Review Panel; 4. THAT Morrison Hershfield be thanked for their efforts in completing the peer review in a timely manner; 5. THAT a copy of Report PSD-73-09 and Council's decision be forwarded to Ontario Power Generation and the Regional Municipality of Durham; and 6. THAT all interested parties listed in this report and any delegations be advised of Council's decision. CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T(905)623-3379 F (905)623-0830 REPORT NO.: PSD-073-09 PAGE 2 ";7 Submitted by: 41,1zj Reviewed by: v' J. Voting MCIP, P F lin Wu, it ctor of P nning Se ices , i� Chief Administrative Officer JAS/FL/df 25 June 2009 I REPORT NO.: PSD-073-09 PAGE 3 1.0 BACKGROUND 1.1 In June 2008, the Government of Ontario announced that it had selected the Darlington Nuclear Generating Site operated by Ontario Power Generation (OPG) for the construction of up to four new nuclear reactors. OPG had already initiated the undertaking of an Environmental Assessment (EA) and the preparation of an Environmental Impact Statement (EIS) for the construction of new nuclear reactors at the Darlington site. 1.2 OPG advised the Municipality that, consistent with its established practice, funding would be made available to the Municipality of Clarington, as the host community, to retain qualified professionals to undertake a peer review of the EA for the new nuclear build project at the Darlington site. The results of the peer review are to be incorporated into the final draft EIS to be submitted by OPG to the federal government for approval. 1.3 In July 2008, Council authorized Staff to initiate formal discussions with OPG regarding the provision of funding for a peer review, to prepare a Terms of Reference for the peer review, and to issue a Request for Proposals for the undertaking of the peer review. 1.4 In October 2008, OPG confirmed its interest in funding a municipal peer review of the draft EIS and the Technical Support Documents (TSDs) for the new nuclear project at Darlington. The Municipality issued a Request for Proposals for the peer review and in January 2009, Council approved the proposal received from Morrison Hershfield. 2.0 SCOPE OF THE PEER REVIEW 2.1 The draft EIS that was peer reviewed consisted of the main EIS report as well as several discipline-specific TSDs. Although the EIS addresses a broad range of issues, the Municipality's peer review focused on the Municipality's core areas of interest, as follows: • Socio-economic environment (including community services, infrastructure improvements, municipal finance, employment opportunities, and community image); • Emergency preparedness; • Land use, cultural heritage resources and visual landscape; • Transportation (including increased road traffic and the potential impacts to the municipal road network); and • Natural environment (including terrestrial, aquatic, atmospheric, groundwater and surface water). REPORT NO.: PSD-073-09 PAGE 4 2.2 For each of the aspects of the environment identified above, the peer review evaluated how the EIS addressed: • the identification of the environmental effects of the project, including the environmental effects of malfunctions and accidents, the likely cumulative effects related to other projects or activities that have been or will be undertaken, and the significance of these effects; • the measures proposed to mitigate adverse environmental effects; • the requirements of a follow-up program in respect of the project; and • sustainable development, the precautionary approach, study strategy and methodology, and use of existing information. 2.3 The peer review began in February 2009 and required a significant time commitment from the peer review consultants, municipal staff, as well as OPG and its consultants. The peer review team and Staff provided numerous comments which were discussed at a series of technical sessions that occurred over a six week period from the end of March to mid-June. All of the comments have been dispositioned to the satisfaction of the peer review team and Staff. OPG has made significant revisions to the draft EIS in response to the comments made through the peer review process. 3.0 CONCLUSIONS 3.1 The peer review team has prepared a report that provides a comprehensive overview of the peer review process, the comments provided by the peer review team, and the disposition of these comments by OPG (Attachment 1). Staff have reviewed this report and concur with its contents and, as such, are recommending that it be submitted to OPG as the Municipality's comments on the EIS for the Darlington new nuclear build project. Attachments: Attachment 1 - Final Report: Peer Review for Darlington New Nuclear Build, Morrison Hershfield, June 2009 List of interested parties to be advised of Council's decision: Laurie Swami Paul Draycott a Zan M E 7 TAT I AT, 7z' Tic IRA es Peer Review for Darlington New Nuclear Build RFP 2008-75 1 rxdixg rie War EXECUTIVE SUMMARY Overview This undertaking involved a peer review of the Environmental Impact Statement (EIS) for the New Nuclear— Darlington Project (the "Project') proposed to be developed at the existing Darlington Nuclear site in the Municipality of Clarington, Ontario. The EIS and the Technical Support Documents (TSDs) that are referenced throughout this report were prepared by Ontario Power Generation Inc. (OPG), which is the owner of the Project site, the operator of the existing Darlington Nuclear Generating Station on the site (DNGS), and the proponent of the Project. An EIS is a document prepared by a proponent to allow a Joint Review Panel, regulators and members of the public to understand the Project, the existing environment, and the potential environmental effects of the Project. This EIS documents the environmental assessment (EA) that was conducted for the Project pursuant to the requirements of the Canadian Environmental Assessment Act (CEAA). The Final EIS Guidelines, dated January 2009, were issued on March 12, 2009. The purpose of the Guidelines is to identify for the proponent, OPG, the nature, scope and extent of the information that must be addressed in the preparation of the Environmental Impact Statement (EIS) for the Project. While the EIS Guidelines provide a framework for preparing a complete and accessible EIS, it is the responsibility of OPG to provide sufficient data and analysis on any potential environmental effects to permit proper evaluation by a joint review panel, the public, and technical and regulatory agencies. The Guidelines outline the minimum information requirements while providing OPG with flexibility in selecting methods to compile and analyze data for the EIS. OPG is required to prepare and submit an EIS that examines the potential environmental effects, including cumulative effects, of the site preparation, construction, operation, refurbishment if required, decommissioning and abandonment of the project, and that evaluates their significance. This information will be used by the joint review panel established pursuant to the Canadian Environmental Assessment Act and the Nuclear Safety and Control Act as the basis for a public review. The environmental assessment for the Project was completed under a bounding scenario due to the Vendor not having been selected by the Ontario Government. The selected, pre-qualified Vendors may use differing technologies that may result in different impacts to the environment. The bounding scenario accounts for these differences by considering the "worst-case" scenario of the effects from the various technologies and tends to over-emphasize the effects of the Project for assessment purposes. OPG anticipates that the EIS will be updated and revised once the Vendor is selected to capture the Vendor-specific information into the EIS. ■' '' 2 MORRISON HERSHFIELD �•���/� Peer Review for Darlington New Nuclear Build /C((j RFP 2008-15 /x•dlxg the Wayhr Peer Review The Municipality of Clarington, as the host community, retained Morrison Hershfield Limited to undertake a peer review of the EIS for the Project. The disposition of our formal peer review comments will be incorporated into the final EIS to be submitted by OPG to the federal government to obtain approval under the Canadian Environmental Assessment Act. The primary objective of our peer review was to ensure that the interests and concerns of the Municipality of Clarington, including its residents and its socio-economic and natural environments, have been properly identified in the preparation of the EIS for the Project and that any potential impacts were satisfactorily addressed through the development of sufficient mitigation. Morrison Hershfield based the peer review of the Project environmental assessment on an evaluation of how the EIS and the supporting technical documentation addressed: • The identification of the environmental effects of the Project, including the environmental effects of conventional malfunctions and accidents, • The likely cumulative effects related to other projects or activities that have been or will be undertaken, and the significance of these effects, • The measures proposed to mitigate adverse environmental effects, • The requirements of a follow-up program in respect of the Project, and • Sustainable development, precautionary approach, study strategy and methodology, and use of existing information The review of any and all issues relating to Radiation and/or Radioactivity was not a component of the peer review. Additionally, the technical supporting documentation as it pertained to Aboriginal Interests, Human Health and Nuclear Waste Management was also not a component of the peer review. The scope of the peer review work did not include a review of the information submitted by OPG to support the Licence to Prepare Site application, except where such information was common to the EIS and the Licence to Prepare Site application. Benefits of the Project A number of anticipated beneficial effects of the Project are likely to be realized during the life of the project. The Project will or is likely to: • Contribute to the maintenance of the social structure and stability of Local Study Area (LSA) communities and selected municipalities across the Regional Study Area (RSA); and serve as a positive contributor to the anticipated population growth in these areas because of the increased proportion of the population associated with it; IWIP g MORRISON HERSHFIELD •■��r/,�� Peer Review for Darlington New Nuclear Build J`1'/-`1Law RFP 2008-75 Leading the Wap • Create new apprenticeship opportunities that will generate a substantial number of new certified trades people available for the Project itself and/or Ontario's construction labour market subsequently; • Serve to maintain the skilled employment base of the energy sector throughout the RSA and LSA in the short term and contribute to the expansion of the skills base over the long term; • Be a catalyst for increased enrolment in post secondary educational programs that provide energy or nuclear related degrees or certificates and other training programs that support certification in a skilled trade; • Be a catalyst for increased local and regional economic development during each of its phases, and for further development of the Durham Energy Industry Cluster and the Clarington Energy Centre through the likely establishment of new business operations in the RSA that are involved in the nuclear service industry; • Create new direct, indirect and induced employment opportunities for existing and potential in-movers to the RSA and LSA and positively influence employment growth in these municipalities; • Create new business activity and opportunities due to increased spending associated with Project employment, and expenditures on goods and services; • Improve economic viability and increase investment in tourist accommodation businesses (i.e., hotels and motels) resulting in improved stock of tourist accommodations in the LSA; • Contribute to increased total household income throughout the RSA and LSA; • Contribute to increased rate of growth in property values and increased sales volumes in the LSA municipalities; • Increase municipal tax and other revenues; • Serve as a catalyst for the initiation of new housing developments in the Municipality of Clarington, the provincially-identified growth centres of the Cities of Pickering and Oshawa, and other communities within Durham Region; and • Promote diversification of the housing stock in the Municipality of Clarington. Peer Review Findings and Recommendations Overall, our review found that OPG has comprehensively addressed all aspects of this highly complex project. Our review has identified several areas within the EIS documentation, including traffic and transportation impacts, socio-economic impacts and follow-up monitoring, where a more fulsome analysis and/or commitment to developing adequate mitigation measures should be considered to sufficiently document and address the concerns of the Municipality of Clarington. Based on the findings of the Host Community Peer Review, Morrison Hershfield has identified the following key issues that we recommend the Municipality of Clarington remain mindful of as the Project progresses through subsequent phases. 1. The full range of potential impacts to the Municipality of Clarington from transportation and traffic effects associated with the Project will continue to ■ •fir 4 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build j� RFP 2008-15 t.oa;RS re.wey unfold as OPG gains additional insight into the selected Vendor's proposed construction strategies and methodologies. It is recommended that the Municipality of Clarington continue to work with OPG to identify any additional transportation and traffic impacts and develop appropriate mitigation measures where warranted. 2. The potential impacts to the Municipality of Clarington from socio-economic and municipal finance effects associated with the Project, as identified in the EIS, may change as OPG carries out follow-up monitoring to assess the predicted effects. It is recommended that the Municipality of Clarington continue to work with OPG to identify any changes in the predicted socio-economic and municipal finance effects, and that OPG, in consultation with the Municipality of Clarington, is responsive to such change and develops appropriate mitigation measures where warranted. 3. As the environmental assessment for the Project was completed under a bounding scenario due to the Vendor not having been selected by the Ontario Government, OPG and the selected Vendor will continue to develop site-specific details on the Project during the licensing phases for Site Preparation, Construction and Operation of the Project. It is recommended that the Municipality of Clarington continue to work with OPG to technically review the development of site-specific design details to ensure that any new or additional impacts to the Municipality of Clarington are identified and appropriate mitigation measures are developed. 4. OPG has made a strong commitment to conduct follow-up monitoring to assess the predicted effects of the Project, as it relates to the natural, social, and cultural environments, and the sufficiency of the applied mitigation measures. It is recommended that the Municipality of Clarington continue to work with OPG to help to develop the follow-up monitoring programs and provide input into OPG's Adaptive Environmental Management Strategy to cooperatively develop and ensure that the mitigation of impacts to the Municipality of Clarington remains responsive and effective. 5. Only the Project benefits that directly relate to the Municipality of Clarington's authority, such as property-based or operational municipal taxes and development charges, are certain. The Municipality of Clarington will be in competition for benefits such as employment opportunities, business development, economic growth of local businesses, and residential growth. It is recommended that the Municipality of Clarington continue to work with OPG to identify opportunities for additional direct benefits of the Project to accrue to the Municipality of Clarington. It is also recommended that the Municipality of Clarington develop an internal strategy to maximize the opportunities to realize these additional benefits. ► fir 5 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build ■'//��"'[� RFP 2008-15 Q dixS the War Subject to the commitments to future work on the part of OPG as identified in the EIS and subject to the recommendations for the continued monitoring of the predicted effects and the review of new, detailed Project information as it is developed by OPG and its selected Vendor, Morrison Hershfield is satisfied that the EIS for the Project was completed professionally and with a great effort to identify concerns to the Municipality of Clarington, communicate and consult with the Municipality of Clarington and to plan with an overall goal of minimizing, to the extent possible given the requirements of the Project, the impact on the environment. In our opinion, as the formal comments and dispositions demonstrate, OPG has gained additional insight from the thorough review undertaken by the Municipality of Clarington and Morrison Hershfield. The EIS has benefited from the additional insights and detailed analysis provided through this process, as evidenced by the many revisions and additions to the documents reviewed. The peer review process was transparent throughout and the results achieved are a testament to the professional and collegial approach exhibited by the Municipality of Clarington, OPG and its consultants and the Morrison Hershfield peer review team. ■ ■' °" 6 MORRISON HERSHFIELO Peer Review for Darlington New Nuclear Build RFP 2008-15 Qquowyon TABLE OF CONTENTS 1.0 INTRODUCTION..................................................................................................9 2.0 GLOSSARY OF DEFINED TERMS.................................................................... 12 3.0 PEER REVIEW TEAM........................................................................................ 13 4.0 PEER REVIEW TERMS OF REFERENCE........................................................ 16 4.1 PURPOSE OF THE PEER REVIEW.............................................................. 16 4.2 SCOPE OF THE PEER REVIEW................................................................... 16 4.3 PEER REVIEWAPPROACH.......................................................................... 19 5.0 PEER REVIEW FINDINGS.................................................................................20 I 5.1 AQUATIC ENVIRONMENT.............................................................................20 5.2 TERRESTRIAL ENVIRONMENT.................................................................... 22 5.3 HYDROLOGY AND SURFACE WATER QUALITY ........................................ 26 5.4 GEOLOGY AND HYDROGEOLOGY..............................................................29 5.5 TRAFFIC AND TRANSPORTATION ..............................................................32 5.6 ATMOSPHERIC ENVIRONMENT.................................................................. 35 5.7 PHYSICAL AND CULTURAL HERITAGE....................................................... 38 5.8 SOCIO-ECONOMIC ENVIRONMENT............................................................40 5.9 CONVENTIONAL ACCIDENTS AND MALFUNCTIONS ................................48 5.10 EMERGENCY PREPAREDNESS .................................................................. 51 5.11 ECOLOGICAL RISK ASSESSMENT.............................................................. 53 5.12 LAND USE ASSESSMENT................... ....... ............ .................................... 55 5.13 ENVIRONMENTAL IMPACT STATEMENT.................................................... 58 6.0 BENEFITS OF THE PROJECT.......................................................................... 66 7.0 PEER REVIEW RECOMMENDATIONS ............................................................ 67 ,• 7 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build `■`/`Z�,7w RFP 2008-75 Lecding(he Wap 8.0 LIMITATION OF REPORT.................................................................................. 69 9.0 CLOSING ........................................................................................................... 70 APPENDIX 1 ............................Formal Peer Review Comments and Disposition by OPG APPENDIX 2.....................................................................................Final EIS Guidelines ■' 'l 8 MORRISON HERSHFIELD LJ1t�lL �r.,rrF�n Peer Review for Darlington New Nuclear Build "-``■■``//�//`ILL�77���f j RFP 2008-15 r<ad�>rx one way 1 .0 INTRODUCTION Project Description The New Nuclear Darlington project will involve the construction and operation of up to four new nuclear reactors and associated buildings and facilities adjacent to the Darlington Nuclear Generating Station (DNGS) located in Clarington, Ontario (the "Project'). The new reactors, which will produce approximately 4,800 megawatts of electrical generating capacity, will be built on the eastern portion of the existing DGNS site. The principal buildings and facilities are grouped into three primary areas: the power block, the cooling system and the switchyard. The power block consists of the buildings housing the nuclear reactors and all associated facilities and equipment. Two methods of cooling water systems are being considered for the removal of heat from the reactor: 1) cooling towers; or 2) once-through cooling system which would draw water from, and discharge water to, to Lake Ontario. The total life span of the project, from construction to abandonment, is expected to be approximately 140 years. The Project is owned by the Ontario Government who has engaged Ontario Power Generation (OPG) to plan, construct and operate the facility. Environmental Assessment Authority The Project triggers the Canadian Environmental Assessment Act given that the proponent requires authorizations under section 24(2) of the Nuclear Safety and Control Act in order for the project to proceed. in addition, authorizations by: Transport Canada under paragraph 5(1)(a) of the Navigable Water Protection Act; Fisheries and Oceans Canada under subsection 35(2) of the Fisheries Act, and the Canadian Transportation Agency under subsection 98(2) and subsection 101(3) of the Canadian Transportation Act may also be required for this Project. All of these authorizations require that an environmental assessment be completed before any authorizations are granted that would enable the Project to proceed in whole or in part. On March 20, 2008, the federal Minister of the Environment announced his referral of the Project to a review panel pursuant to the Canadian Environmental Assessment Act, and indicated that the Canadian Nuclear Safety Commission (CNSC) and the Canadian Environmental Assessment Agency (CEAA) should pursue a joint environmental assessment process. A joint review panel under the Canadian Environmental Assessment Act and the Nuclear Safety and Control Act has been established to undertake an environmental assessment and regulatory review of this Project. The joint review panel for this project will evaluate information that relates to the environmental assessment. The joint review panel will also consider information submitted by OPG in support of their application for a Licence to Prepare Site for a Class 1 Nuclear Facility, in accordance with the requirements of the Nuclear Safety and Control Act and its regulations. ■ 9 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear 8-15 a�[,(�jj RFP 2008-75 teams,s.waJ The Province of Ontario's Environmental Assessment Act is not applicable to the environmental assessment being completed for the New Nuclear Darlington project. On September 5, 2008, the Canadian Nuclear Safety Commission (CNSC) issued the Draft Guidelines for the Preparation of the Environmental Impact Statement for the Darlington New Nuclear Power Plant Project (the Guidelines) for public comment. In order to expedite the peer review process, the Municipality of Clarington commenced the peer review on the basis of the Draft Guidelines. The Final EIS Guidelines, dated January 2009, were issued on March 12, 2009. The purpose of the Guidelines is to identify for the proponent, OPG, the nature, scope and extent of the information that must be addressed in the preparation of the Environmental Impact Statement (EIS) for its proposed New Nuclear Darlington project. Environmental Assessment Process OPG is required to prepare and submit an EIS that examines the potential environmental effects, including cumulative effects, of the site preparation, construction, operation, refurbishment if required, decommissioning and abandonment of the project, and that evaluates their significance. In addition, OPG is required to address all requirements for a Licence to Prepare Site detailed in Appendix 2 of the Guidelines. This information will be used by the joint review panel established pursuant to the Canadian Environmental Assessment Act and the Nuclear Safety and Control Act as the basis for a public review. While the Guidelines provide a framework for preparing a complete and accessible EIS, it is the responsibility of OPG to provide sufficient data and analysis on any potential environmental effects to permit proper evaluation by a joint review panel, the public, and technical and regulatory agencies. The Guidelines outline the minimum information requirements while providing OPG with flexibility in selecting methods to compile and analyze data for the EIS. The environmental assessment for the New Nuclear Darlington project was completed under a bounding scenario due to the Vendor not having been selected by the Ontario Government. The selected, pre-qualified Vendors may use differing technologies that may result in different impacts to the environment. The bounding scenario accounts for these differences by considering the "worst-case' scenario of the effects from the various technologies and tends to over-emphasize the effects of the Project for assessment purposes. OPG anticipates that the EIS will be updated and revised once the Vendor is selected to capture the Vendor-specific information into the EIS. OPG and the selected Vendor will continue to develop site-specific details on the project during the licensing phases for Site Preparation, Construction and Operation of the project. r 10 MORRISON HERSHFIELD � Peer Review for Darlington New Nuclear Build Q r.g `/`/iZ�7� RFP 2008-15 ,n.w.J Host Community Peer Review OPG made available funding to the Municipality of Clarington, as the host community, to undertake a peer review of the EIS for the New Nuclear Darlington project. The results of the peer review will be incorporated into the final EIS to be submitted by OPG to the federal government. The peer review was initiated in January 2009 under the Draft Guidelines until the release of the Final Guidelines in March 2009. A concordance was undertaken between the Draft and Final Guidelines to ensure that peer review work completed under the Draft Guidelines remained valid under the Final Guidelines. ■ MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build a�� RFP 2008-15 Q e;»r a.way 2.0 GLOSSARY OF DEFINED TERMS The following terms and acronyms used in the preparation of this report have the defined meanings as follows: CEAA Canadian Environmental Assessment Act CLOCA Central Lake Ontario Conservation Authority DFO Department of Fisheries and Oceans Canada DINGS Darlington Nuclear Generating Station EA Environmental Assessment EIS Environmental Impact Statement LSA Local Study Area is that area beyond the Site Study Area where there is a reasonable potential for direct effects on the environment, from any phase of the Project, either through normal activities or from possible accidents or malfunctions. The LSA includes all of the SSA, the lands within the Municipality of Clarington closest to it and the area of Lake Ontario adjacent to the Project site. MH Morrison Hershfield Limited MNR Ontario Ministry of Natural Resources OPG Ontario Power Generation Project The New Nuclear Darlington project RSA Regional Study Area is the area within which there is the potential for cumulative biophysical and socio-economic effects. This area includes lands, communities and portions of Lake Ontario around the DN site that may be relevant to the assessment of any wider- spread direct and indirect effects of the Project. SSA Site Study Area is the facilities, buildings and infrastructure at the Project site including the existing licensed exclusion zone for the site on land and within Lake Ontario, and particularly, the property where the Project is proposed. TSD Technical Supporting Document VEC Valued Ecosystem Component ,• off 12 MORRISON HERSHFIELD (Pubvigton Peer Review for Darlington New Nuclear Build RFP 2008.16 3.0 PEER REVIEW TEAM As a leading research, environmental, engineering, planning, design and construction firm with extensive and relevant project experience, Morrison Hershfield Limited (MH) was well positioned to fully scope the range of activities necessary to meet the project objectives while at the same time proactively identifying other concerns, challenges and opportunities, and examining them in the best interest of the Municipality of Clarington. MH staff is very familiar with complex multi-faceted and multi-jurisdictional undertakings and we provided the Municipality of Clarington with the following team of senior professional and technical specialists to compliment the Municipality of Clarington's professional staff in carrying out this peer review undertaking. Municipality of Clarington Professional Staff Ms. Janice Auger Szwarz, Senior Planner Special Projects (Project Manager) Mr. Franklin Wu, Chief Administrative Officer Ms. Nancy Taylor, Director of Financial Services Ms. Faye Langmaid, Manager Special Projects Mr. Tony Cannella, Director of Engineering Services Mr. David Crome, Director of Planning Services Mr. Bruno Bianchi, Municipal Engineer Mr. Gordon Weir, Director(Chief) of Emergency and Fire Services Morrison Hershfield Limited Professional and Technical Staff, Including our Partnering Consultants Mr. Paul Draycott, Principal, Director of Environmental Services and General Counsel (Project Manager and Environmental Technical Review Leader) Mr. Doug Hoffman, Senior Principal, Head of Civil Design and Engineering Principal in Charge (Senior Technical Advisor and Project Quality Control) Dr. David Tay, Senior Principal, Senior Nuclear and Peer Review Engineering Specialist (Emergency Preparedness Advisor) m r ,• `.-s 13 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build Q di �� RFP 2008-15 ng the W'aT Mr. Geoff Pound, Principal, Vice-President Infrastructure Engineering (Municipal Infrastructure Technical Review Leader) Mr. James Weir, Principal, Director of Transportation Operations and Engineering (Land Use and Transportation Technical Review Leader) Mr. John Grebenc, Principal, Director of Municipal Transportation and Engineering (Municipal Transportation Technical Review) Dr. Ali Mekky, Senior Transportation Policy and Planning Specialist (Transportation and Traffic Analysis Technical Review) Mr. Farooq Arshad, Principal, Senior Water Resources Engineering Specialist (Hydrology and Surface Water Technical Review) Mr. Larry Hennigar, Associate, Senior Water Resources and Municipal Infrastructure Engineering Specialist (Hydrology and Surface Water Technical Review) I Mr. Jonathan Veale, Environmental Assessment and Management Planner and Sustainability Strategist (Sustainability Technical Review) Mr. Robert Blakeney, Senior Sustainable Engineering Specialist (Sustainability Technical Review) Ms. Jennifer Bruin, Senior Environmental Assessment and Planning Specialist (Socio- Economic Technical Review) Ms. Erin McLachlan, Senior Terrestrial Ecology Specialist (Terrestrial Ecosystems Technical Review) Mr. Alan Wormington, Senior Ornithologist and Terrestrial Ecology Specialist (Terrestrial Ecosystems Technical Review) Ms. Deborah Crawford, Senior Marine and Freshwater Aquatic Biology Specialist (Aquatic Ecosystems Technical Review) Mr. Craig Binning (Hemson Consulting Ltd.) Senior Socio-Economic and Municipal Finance Specialist (Socio-Economic Technical Review Leader) Ms. Kelly O'Brien, (EDP Consulting Ltd.) Senior Socio-Economic and Employment/Business Specialist (Socio-Economic Technical Review) Mr. Mory Mortazavi (Peto MacCallum Ltd.) Senior Geoenvironmentalist and Hydrogeologist (Geology and Hydrogeology Technical Review) Mr. Michael Lepage (RWD/) Principal, Air Quality Program Director (Atmospheric Technical Review—Air) Iry i 14 MORRISON HERSHFIELD Q Peer Review for Darlington New Nuclear Build RFP 2008-15 ding(be rib) Mr. Scott Penton (RWDI) Principal, Senior Noise Engineering Specialist (Atmospheric Technical Review— Noise) Mr. Richard Unterman (Unterman McPhail Associates) Principal, Senior Cultural and Built Heritage Specialist (Cultural and Physical Heritage Technical Review) Mr. Andrew Murray (AM Archaeological Associates) Principal Senior Archaeologist (Physical Heritage Technical Review) Mr. Phillip Stewart (Pound Stewart Associates) Senior Planning and Policy Specialist (Land Use Technical Review) Ontario Power Generation and Consultant Professional Staff Mr. John Peters, Environmental Assessment Manager, Ontario Power Generation Ms. Donna Pawlowski, Manager, Strategic Planning & Extemal Relations, Generation Development, Ontario Power Generation Mr. Andrew Muller, SeniorAdvisor- Community Studies Generation Development — Licensing, Ontario Power Generation Mr. Dave Chin-Cheong, Section Manager, Environmental Assessment Generation Development, Ontario Power Generation Mr. Don Gorber, President and Director of Environmental Assessment Studies, Senes Consultants Limited Mr. Robert Doney, Environmental Assessment Manager, MMM Group r 15 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008.75 r.�ding iti�ney 4.0 PEER REVIEW TERMS OF REFERENCE 4.1 PURPOSE OF THE PEER REVIEW The Municipality of Clarington, as the host community, retained MH to undertake a peer review of the EIS for the Project. The disposition of our formal peer review comments will be incorporated into the final EIS to be submitted by OPG to the federal government to obtain approval under the Canadian Environmental Assessment Act. The primary objective of our peer review was to ensure that the interests and concerns of the Municipality of Clarington, including its residents and its socio-economic and natural environments, have been properly identified in the preparation of the EIS for the Project and that any potential impacts were satisfactorily addressed through the development of sufficient mitigation. A corollary objective of our peer review was, through discussion of the project and the interests and concerns of the Municipality of Clarington, to foster a greater understanding between OPG and the Municipality of Clarington so that the concerns, challenges and opportunities that will be realized during the future phases of licensing, detail design and operation can be addressed collegially and positively. 4.2 SCOPE OF THE PEER REVIEW On behalf of the Municipality of Clarington, MH undertook the following activities during the peer review process: 1. Reviewed the Technical Supporting Documents (TSD) and studies prepared as part of the federal environmental review, including the draft EIS, to identify potential issues of concern to the Municipality of Clarington for subsequent discussion with OPG and its consultants; 2. Met with the Mayor and all of the municipal Councilors to understand the concerns, challenges and opportunities facing the municipality that may interact with the project; 3. Attended meetings with the Municipality of Clarington, OPG and its consultants to discuss the EIS and Technical Supporting Documents. At these meetings, missing information, discrepancies and ambiguities in the TSDs and the draft EIS were discussed and clarified and areas in the TSDs and the draft EIS were identified where additional information or analysis was required; 4. Participated in a site tour of the proposed development site to understand the unique challenges for constructing the proposed facilities; ,, • 16 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 reds r•r w.J 5. Provided input into OPG's environmental assessment process, on behalf of the Municipality of Clarington, to benefit and add value to the EIS as it pertained to potential issues of concern for the Municipality of Clarington; 6. Provided advice to municipal staff to assist in understanding technical issues and reports; 7. Prepared a draft and final report of the peer review findings; and 8. Presented the peer review findings to Clarington Council. The Technical Supporting Documents reviewed under the Terms of Reference for this engagement included the following disciplines and key areas of focus under each discipline: Socio-Economic Environment • community services including fire and emergency services • infrastructure growth servicing capacity, including traffic and transportation • municipal finance • local employment opportunities and competition for skilled workers • local business opportunities and economic competition • local tourism and business impacts during construction • community image • recreational facilities impacts • public involvement and concerns with the project. Terrestrial Environment • wildlife habitat and corridor modification • removal or displacement of terrestrial species, including mammals, birds, amphibians, reptiles and insects • species at risk Hydrology and Surface Water Quality • surface water relocation and drainage • surface water runoff quality • shoreline coastal processes • lake circulation and water quality • thermal plume Aquatic Environment • shoreline infilling and modification ■ ■'' f ? 17 MORRISON HERSHFIELD QW4V19ton Peer Review for Darlington New Nuclear Build RFP 2008-15 • installation of intake and discharge structures • aquatic species entrainment and impingement • on-site aquatic habitat effects Geology and Hydrogeology • lowering of local ground water table • landfill and berm creation • stabilization of disturbed surfaces Land Use and Transportation • access to site for materials and personnel • rail and dock construction, if required • increased road traffic effects and accident frequency • transportation and disposal of conventional waste Atmospheric Environment • air quality • dust and noise during construction • cooling tower operation • noise and gaseous emissions during operation Physical and Cultural Heritage • impact to cultural heritage and archaeological sites • visual change to landscape Ecological Risk Assessment • effects on non-human biota Conventional Accidents and Malfunctions • construction accidents • spills of contaminants Emergency Preparedness • evacuation capabilities and procedures • emergency planning � r 18 MORRISON HERSHFIELD QYd � ��}^„ Peer Review for Darlington New Nuclear Build �wjj RFP 2008-15 g the Wn) The Environmental Impact Statement (EIS) reviewed under the Terms of Reference for this engagement included the following key components: • scope of the project for EA purposes • compliance with the Draft and Final EIS Guidelines • integration of the precautionary approach • sustainability • residual and cumulative effects impact assessment • approach and commitments to follow-up monitoring • regulatory requirements • benefits of the project 4.3 PEER REVIEW APPROACH Morrison Hershfield, at the direction of the Municipality of Clarington, based the peer review of the Project environmental assessment on an evaluation of how the EIS and the supporting technical documentation addressed: • The identification of the environmental effects of the project, including the environmental effects of conventional malfunctions and accidents, • The likely cumulative effects related to other projects or activities that have been or will be undertaken, and the significance of these effects, • The measures proposed to mitigate adverse environmental effects, The requirements of a follow-up program in respect of the project, and • Sustainable development, precautionary approach, study strategy and methodology, and use of existing information The review of any and all issues relating to Radiation and/or Radioactivity was not a component of the peer review. Additionally, the technical supporting documentation as it pertained to Aboriginal Interests, Human Health and Nuclear Waste Management was also not a component of the peer review. The scope of the peer review work did not include a review of the information submitted by OPG to support the Licence to Prepare Site application, except where such information was common to the EIS and the Licence to Prepare Site application. m• 19 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build !j Q RFP 2008-15 dia8 lde Way 5.0 PEER REVIEW FINDINGS The descriptions of the project components and project impacts for each of the technical disciplines reviewed are taken from the document Environmental Impact Statement, New Nuclear— Darlington Environmental Assessment(SENES Consultants Ltd. and MMM Group 2009). 5.1 AQUATIC ENVIRONMENT Aquatic Environment Project Components The technical supporting document Aquatic Environment— Existing Environmental Conditions Technical Support Document, New Nuclear-Darlington Environmental Assessment(Golder 2008) characterized the aquatic environment into the following environmental sub-components: • Aquatic Habitat: includes tributary watercourses and ponds on the Project site, and the adjacent areas of Lake Ontario. In these different areas, it is characterized by conditions of flow, current, bathymetry, temperature, substrates and water quality that influence its status with respect to the federal Fisheries Act (i.e., presence and types of fish habitat). Because the areas occupied by existing and future intake forebays will be artificially separated from Lake Ontario, they were not included in the assessment; and • Aquatic Biota: includes the communities of underwater plants and animals that occupy the aquatic habitat defined above. These include, depending on habitat conditions, periphyton, aquatic macrophytes, phytoplankton, benthic invertebrates, zooplankton and fishes. Aquatic biota may also include rare, vulnerable, threatened and endangered aquatic species. Aquatic Environment Project Impacts The likely effects on Aquatic Habitat will be primarily as a result of direct losses of habitat associated with physical development of the site and operation of the cooling/service water intake and discharge facilities. The Project will result in removal of the onsite ponds representing a net loss of onsite aquatic habitat. Approximately 400 m of the upper reaches of each of two intermittent tributaries of Darlington Creek will be lost and/or altered as a result of the Project. The Project may result in the degradation of fish habitat in the upper reaches of an intermittent tributary to Lake Ontario (west of Park Road) as a result of its re-alignment or removal. m 20 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 Leading fke Wq The Project will result in the loss of 44.8 ha of nearshore aquatic habitat in the area of lake infilling. The embayment created at the mouth of Darlington Creek between the Project infilling area and St. Marys Cement wharf may experience increased algae growth and entrapment due to less mixing of the nutrients from Darlington Creek, warmer temperatures and the protected nature of the embayment. The Project will result in localized loss of some VEC species (i.e., benthic invertebrates, round goby) within the construction area footprints of the lake infill and the cooling/service water intake and discharge structures. The Project will result in impingement and entrainment losses as a result of the once- through lake-water cooling option, and to a lesser degree, with the cooling tower option. Peer Review Findings Overall, Morrison Hershfield concurs with the findings of the Aquatic Environment Existing Conditions and Effects Assessment in that the fish habitat within the area of Lake Ontario proposed for infill is of marginal quality due to the high-energy environment along the lakeshore. Morrison Hershfield concurs that the loss of fish habitat associated with the proposed lake infill, notwithstanding the immense area of habitat that will be lost, is not significant in the context of the amount of similar habitat available in Lake Ontario. Morrison Hershfield further concurs that these and other impacts and effects to the aquatic environment can be mitigated to the extent feasible and compensated for where mitigation is insufficient. OPG will develop a comprehensive Fish Habitat Compensation Plan to satisfy the requirements of a Federal Fisheries Act Section 35 Authorization. Accordingly, there will be no residual effects to aquatic habitat and the residual effects to aquatic biota are not considered to be significant. Peer Review Comments Morrison Hershfield identified two issues that were forwarded to OPG for formal disposition. They are as follows: Comment: The Municipality desires to the extent possible that all fisheries compensation strategies be prioritized for and implemented within local Municipal watersheds or within the Municipal boundaries of Lake Ontario. Disposition:OPG expects some sort of fisheries compensation will occur with regulatory agencies as a result of habitat loss associated with the proposed lake infill and other in-water works. In negotiating the habitat compensation plan with the regulatory agencies, OPG will propose that compensation strategies be given priority to local municipal watersheds or 1 21 MORRISON HERSHFIELD y.ir ter/h Peer Review for Darlington New Nuclear Build �('■"`/'/�D�� RFP 2008-15 !<ading the N'wS within the municipal boundaries of Lake Ontario where practicable. However, the contents of the habitat compensation will likely be made by the DFO in collaboration with the MNR and other groups such as CLOCA which is beyond the control of OPG. Comment: Darlington Creek lies within the site study area and, under the bounding scenario, a crossing of the main channel is considered. The characterization of the existing conditions for this watercourse within the site study area relies solely.on dated secondary source information that does not assess the watercourse within the site study area for critical or sensitive aquatic habitat. We suggest a more current, site-specific study is required to adequately characterize the existing aquatic conditions for Darlington Creek on the site and to properly develop site-specific mitigation. Disposition:OPG also identified the need to assess the upper reaches of Darlington Creek. A detailed habitat assessment of the upper reaches has been initiated by OPG. The results of this assessment will be added to the findings of the previous assessment of the lower reaches and reported in the Technical Supporting Document and the Environmental Impact Statement. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.2 TERRESTRIAL ENVIRONMENT Terrestrial Environment Project Components The Technical Supporting Document Terrestrial Environment— Existing Environmental Conditions Technical Support Document, New Nuclear- Darlington Environmental Assessment(Beacon Environmental 2009) described and addressed the terrestrial environment in the context of the following environmental sub-components: • Vegetation Communities and Species: the basic habitat unit for many wildlife attributes and represents the most important element of ecosystem function; • Insects: the Monarch butterfly, a species of conservation concern migrates through the DN site in large numbers. In addition, many species of dragonflies and damselflies including provincially rare species have been attracted to the constructed and enhanced wetlands; • Bird Communities and Species: these are commonly used as indicators for the assessment of potential effects. They are relatively easy to survey, their status and behaviour are relatively well-understood and they can act as useful 1 22 MORRISON HERSHFIELD RFP 2008.15 Peer Review for Darlington New Nuclear Build Q40OWL-719ton surrogates for broader wildlife species that are more difficult to sample (e.g., secretive or nocturnal mammals); Amphibians and Reptiles: these are good indicators of the quality of wetland habitat as they often respond rapidly to changes in their environment. Ecologically, they represent an important link in the food chain and are also useful for measuring ecosystem health; • Mammal Communities and Species: these are an important element of the food chain. They range from small herbivorous mammals taken as prey by other animals to carnivores; and Landscape Connectivity: these are elements of the landscape that serve as corridors or linkages and support the movement and dispersal of flora and fauna through the landscape. Terrestrial Environment Project Impacts During the Site Preparation and Construction phase, effects on Vegetation Communities and Species will essentially be bounded by the direct losses of vegetation communities and species as a result of Mobilization and Site Preparation that will see extensive clearing and grubbing of the site to facilitate it development. The Project will result in the loss of an estimated 113 ha of Cultural Meadow and Thicket Ecosystem. The Project will result in the loss of an estimated 17 ha of Wetland and Thicket Ecosystem. The Project will result in the loss of rare plant species: Common Water Flax-seed, Cup Plant and Loesel's Twayblade. A rare species of dragonfly, Amber-winged Spreadwing, whose only known occurrence on the site is at Treefrog Pond, will be lost to the Project site. Clearing of the Project site will result in the loss of an estimated 74 ha of Monarch (and other) butterfly habitat. As a consequence of the removal of existing breeding bird habitat within the Project site, the Project will result in a decrease in the population of breeding birds on the site. As a consequence of the removal of the shoreline bluffs in the development area of the Project site, the Project will result in a decrease in Bank Swallow nesting habitat and overall colony size. 23 MORRISON HERSHFIELO Peer Review for Darlington New Nuclear Build RFP 2008-15 QKPOW-Poil Clearing of the Project site will result in the loss of an estimated 74 ha of migrant bird habitat. The presence of large (i.e., high) structures and buildings on the Project site, including and notably, cooling towers, will result in bird strikes causing injury and death to birds. The presence of security fencing on the Project site, including and notably, around the Protected Area, will result in bird entrapment causing injury and death to birds. Clearing of the Project site will result in the loss of an estimated 113 ha of Cultural Meadow and Thicket Ecosystem that is feeding and winter foraging area for raptors. The Project will result in the removal of three amphibian breeding areas (Treefrog Pond, Polliwog Pond and Dragonfly Pond). Clearing of the Project site will result in the loss of an estimated 113 ha of Cultural Meadow and Thicket Ecosystem that represents Meadow Vole habitat. Access for wildlife travel along the wildlife corridor extending east-west across the Project site is likely to be interrupted at points in time during the site preparation and construction phases. Peer Review Findings Overall, Morrison Hershfield concurs with the findings of the Terrestrial Environment Existing Conditions and Effects Assessment in that the terrestrial habitat within the Site Study Area is of improving quality due to the predominantly disturbed environment remnant from the DNGS construction. Morrison Hershfield further concurs that impacts and any effects to terrestrial habitat can be mitigated to the extent feasible and compensated for where mitigation is insufficient. Peer Review Comments Morrison Hershfield identified three issues that were forwarded to OPG for formal disposition. They are as follows: Comment: The loss of the Bank Swallow colony within the site study area represents a large percentage of the available shoreline habitat for this species within the local study area and the Municipality. The effects assessment has rationalized that there will be no residual effect from this loss as the effect is limited to the site study area. The site study area for this TSD was modified to include a piece of property, not belonging to the Project site. The mitigation proposed only is partially directed to the actual loss of the bank swallow colony on the site study area (artificial nesting habitat). We r - c""n 24 MORRISON HERSHFIELD • Peer Review for Darlington New Nuclear Build RFP 2008-15 LeaNlwy/1�Ray LJ suggest that a more fulsome explanation is required to rationalize the change in site study area for this technical discipline and to explain how the proposed mitigation deals specifically to address the loss of the local colony. Disposition:OPG has categorized the extent of loss related to active Bank Swallow burrows based on 2007 data. Monitoring of the colony continues. Although a residual effect was determined, it was further determined to be "Not Significant" in the context of the CEAA. The Site Study Area was modified to include colonies that are in general proximity to each other (Bank Swallow Evaluation area). This extended to the east (Wilmot Creek) and west (Oshawa Creek) until a substantive gap in colonies and between existing colonies was reached. This was rationalized in the TSD based largely on professional opinion and illustrated with mapping. Based on professional judgement, this is a more meaningful area for a species which has its breeding habitat more or less `confined' in this area to the lake Ontario shoreline area south of the ancient Lake Iroquois shoreline (approximately Taunton Road). The TSD explains that the suggested mitigation represents a range of measures that includes some innovative, direct and indirect approaches to address the removal of Bank Swallow burrows and nesting habitat that will be necessary in order for the project to advance. While we recognise that these suggested measures do not represent and exact "like-for-like" we also believe that a meaningful attempt has been made to provide tangible measures that will be to the long term benefit of the swallows. We respect the comments of the reviewer regarding the loss of habitat, however we respectfully disagree that compensatory or mitigative actions need always match exactly the nature of the loss. For example, compensation measures have been authorized with respect to fish and fish habitat that do not represent an exact like-for-like match, if the measures contribute to the long-term gains related to fish habitat. Comment: The assessment of the potential for bird strike mortalities on the cooling towers was completed using previous studies on other sites. We suggest that local conditions need to be analyzed and compared to the conditions on the comparison sites so that the predicted effects are more representative of the local environment. We suggest that follow-up monitoring should be conducted for bird strike effects to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. Disposition:OPG used a similar structural design on a Great Lakes shoreline and a peer-reviewed study for strike data. Further analysis of existing conditions at this location and comparative analysis with other locations for which ■ F6, 25 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build /V11U�LI11111��(,i(/1l■� RFP 2008-15 Lea @iag IFe Wa>• reasonably comparable data might be available is in our opinion, highly unlikely to result in a finding that bird strikes would be an order of magnitude higher. It is important to note that "comparable data" might be limited to vegetation and geographic analysis as radar data is unlikely to be available elsewhere for similar structures and locations. Therefore we submit that our ultimate conclusion would be unchanged. Any a priori determination of bird strikes is at best an estimate. We have recognised that towers would result in strikes of hundreds of birds; even in the unlikely event that this number were thought by others to be in the thousands (as it has been for example for the lit buildings of the downtown City of Toronto), it might be reasonably concluded that the effect would still be Not Significant in terms of bird populations. Should Cooling Towers be constructed at the Project site, OPG agrees that follow-up monitoring to confirm predicted results would be appropriate. Comment: There is an inconsistency between the Effects Assessment document and the EIS in that on page 24 of the TSD it is stated that the impacts from the management of stormwater are unlikely to result in a negative effect yet in Table 5.5-1 of the EIS the management of stormwater is listed as a Project work and activity that is likely to result in a measurable change to the terrestrial environment. We suggest that a review be undertaken to remedy the inconsistency. Disposition:The listing of"Management of Stormwater" in Table 5.5-1 was an error. The reference will be removed from the table. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.3 HYDROLOGY AND SURFACE WATER QUALITY Hydrology and Surface Water Quality Project Components The Technical Supporting Document Surface Water Environment— Existing Environmental Conditions Technical Support Document, New Nuclear— Darlington Environmental Assessment(Golder Associates 2009) described and addressed the hydrological and surface water environment in the context of the following environmental sub-components: • Lake Circulation: lake-wide circulation characteristics; near-shore lake current direction and velocity; water velocities and directions in the vicinity of cooling water intakes and discharges; and cooling water withdrawal volumes and rates; • Lake Water Temperature: lake-wide thermal regime; and nearshore mean temporal and spatial temperature variations; 1r 26 MORRISON HERSHFIELD Qviowlix �„-/-�„ Peer Review for Darlington New Nuclear Build 9ton RFP 2008-15 • Site Drainage and Water Quality: stormwater and liquid effluents from the site and the resultant receiving water quality; and • Shoreline Processes: processes that affect the nearshore conditions in the vicinity of the Project site (e.g., geomorphic setting and bathymetry; sediments; Lake Ontario water levels; wave conditions; and ice behaviour). Hydrology and Surface Water Quality Project Impacts Changes to current circulation patterns in Lake Ontario are likely as a result of alterations to the shoreline associated with lake infilling and a deflection of alongshore currents associated with operation of a once-through lake-water cooling system. These changes in and of themselves are not considered an adverse effect of the Project in terms of lake circulation, however the changes are considered further in terms of their likely consequential effect on Lake Water Temperature and Shoreline Processes. Warmer water temperatures than currently exist in Lake Ontario at the mouth of Darlington Creek are likely to result from the creation of the embayment between the infill area and the St. Marys Cement property. These changes in and of themselves are not considered to represent an adverse environmental effect in the Surface Water Environment, however changes in Lake Water Temperature were considered further in terms of impacts to the Aquatic Environment. Thermal discharges associated with the operation of the service water and cooling water systems will likely result in a measurable change in the turbulent mixing zone of the discharge diffuser, which is typically confined to less than 50 and 15 m east and west of the discharges for the once-through cooling option and the cooling tower option, respectively. These changes in and of themselves are not considered to represent an adverse environmental effect in the Surface Water Environment, however, changes in Lake Water Temperature were considered further in terms of impacts to the Aquatic Environment. The operation of the cooling tower option will result in the concentration of constituents in the water withdrawn from the lake and chemicals will be added to the tower process water to ensure performance objectives are met. These flows will be returned to the Lake. Stormwater, active liquid effluent systems and inactive liquid effluent systems will contain contaminants. However, changes in Lake Water Quality associated with these processes are not likely to be meaningful as the concentrations will meet regulatory requirements. The embayment created at the mouth of Darlington Creek between the NND infilling area and St. Marys Cement wharf may experience increased algae growth and entrapment due to less mixing of the nutrients from Darlington Creek, warmer temperatures and the protected nature of the embayment. Construction of the infill area coffer dam, as well as the cooling water intake and discharge for either cooling option is likely to result in turbidity in the lake water. Any m.! 27 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 QN-OWL.Y19ton turbidity created will be temporary in nature, and the extent of the turbidity plume will be limited because of the high-energy environment of the nearshore. Placement of the lake infill and construction of the cooling water intake and discharge structures will result in disturbance and loss of lake substrates. These changes in and of themselves are not considered to represent an adverse environmental effect in the Surface Water Environment, however the loss of lake substrates is considered further in terms of impacts to the Aquatic Environment. Peer Review Findings Overall, Morrison Hershfield concurs with the findings of the Hydrology and Surface Water Environment Existing Conditions and Effects Assessment in that the proposed site preparation, construction and operation of the Project offers negligible impacts to the existing environment when considered in terms of the mitigation measures proposed and mandated through regulatory approvals. Peer Review Comments Morrison Hershfield identified two issues that were forwarded to OPG for formal disposition. They are as follows: Comment: A relatively large area of lake infilling is proposed for this project. The reviewers agree that additional area needs to be made available for construction staging and materials storage. We suggest that a more fulsome explanation of the need for this infill be provided that compares the available area for construction staging with that used for the existing Darlington Nuclear Generating Station. This explanation should also incorporate the efficiencies accounted for through phased construction, current construction technologies and methodologies and the in-design strategies available for minimizing the extent of the infill. We suggest that there should be a commitment to further review of in-design mitigation measures to reduce the area of infill once a vendor has been selected and the vendor's construction needs are assessed. Disposition:OPG agrees that additional rationale for the bounding lakefill area would be useful to the reader. More information will be included in the description of the lakefill requirements in Chapter 2 of the EIS. The rationale will include a description of the role of the infill area through each phase of the project. Some of the key aspects of the lakefill rationale will include the extent of large modular components being transported to the site via lake barge or ship; the need for safe and secure conditions on the lake side of the power block foundations once the site has been excavated below lake level to bedrock; the need for sufficient security protection from public access on the lake side of the plant; and the need for additional operating island around the reactors in the event that cooling towers are ■ ■F �1 28 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 leading the Wb� required. The EIS also identifies the potential for stormwater management and settling ponds, shoreline gravel bars and splash pools for migratory birds during the operations phase of the project. The EIS will also outline how the specific extent and design of the lake infill will be documented as part of each licensing step, from site preparation when the initial lake filling will occur, through construction where the offloading and laydown of large equipment will occur, and through plant operation where site security, safety and increased site biodiversity will be described. Comment: Stormwater management is limited to a screening level assessment due to the vendor selection not being finalized. A more fulsome commitment to in-design mitigation criteria for water quality using Best Management Practices should become part of the Scope of Project. We suggest that follow-up monitoring should be conducted for water quality discharges to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced or there are issues of non-compliance with regulatory thresholds. Disposition:The Scope of Project does indeed address the requirement to ensure that stormwater discharges meet applicable quality standards. This has been reinforced through edits to EIS Section 2.5.9 (Stormwater Management) that include the commitment that Good Industry Management Practices will be applied to ensure that appropriate and effective stormwater control and management features are incorporated into all phases of the Project, and that all discharges from related facilities will meet applicable quality criteria. It can be expected that monitoring of site discharges will be an aspect of OPG's ongoing due diligence program; and this will include any specific quality monitoring requirements that may be required of approvals granted for the Project. Follow-up monitoring of the receiving system (Lake Ontario) has been recommended in the EIS. Currently, follow-up monitoring for on site stormwater has not been recommended based on water quality noted at DNGS and other nuclear sites. However, the appropriateness of monitoring will be addressed by the regulators and included in the Environmental Monitoring Plan as deemed necessary. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.4 GEOLOGY AND HYDROGEOLOGY Geology and Hydrogeology Environment Project Components The Technical Supporting Document Geological and Hydrogeological Environment— Existing Environmental Conditions Technical Support Document, New Nuclear- .. e5 29 MORRISON HERSHFIELD ■ �ppjll�lfj>,ytt Peer Review for Darlington New Nuclear Build Leering lFe B'a� (�Jl� RFP 2008-15 Darlington Environmental Assessment(CH2M HILL 2009) described and addressed the Geological and Hydrogeological Environment in the context of the following environmental sub-components: • Soil Quality: the physical and chemical characteristics of the surface and subsurface materials; • Groundwater Flow Regime: the rate of flow and volume of groundwater; and • Groundwater Quality: the chemical characteristics of the groundwater system. Geology and Hydrogeology Environment Project Impacts Based on comparisons to the current operations at DNGS, stormwater management facilities can potentially affect localized soil quality. Based on comparisons to the current operations at DNGS, stormwater management facilities can potentially affect localized groundwater quality. Tritium concentrations were found at a maximum concentration of about 500 Bq/L in shallow groundwater just beyond the DNGS Protected Area. It is inferred, therefore, that operation of the Project may increase the concentration of tritium in localized groundwater. Groundwater Flow conditions will be changed permanently by the Project. The most significant change will result from permanent dewatering necessary to facilitate the excavation and grading activities. Changes will also result from alterations to the topography and from new drainage system associated with the facility. These changes will result in consequential changes to existing flow and recharge characteristics. Some consequential changes will be beneficial in that they will serve to offset changes brought about by dewatering. Peer Review Findings Overall, Morrison Hershfield concurs with the findings of the Geological and Hydrogeological Environment Existing Conditions and Effects Assessment in that the proposed site preparation, construction and operation of the Project offers negligible impacts to the existing soil and groundwater quality and groundwater regime, both on the site and within the 1200 metre zone of influence. Peer Review Comments Morrison Hershfield identified one issue that was forwarded to OPG for formal disposition. It is as follows: r 30 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 tPaa;,Ig;a.woy Comment: Dewatering drawdown within the 1200 metre zone of influence was modelled. We suggest that the model is extremely sensitive to the input hydraulic properties and a more conservative (higher) value for soil permeability (i.e. the hydraulic conductivity K value) should be used to ensure that there will be no drawdown effects within the zone of influence, particularly for any potable water supplies within the zone. We suggest that follow-up monitoring should be conducted for drawdown effects within the zone of influence to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. Disposition:OPG is satisfied that the reviewer accepted the majority of the work with one exception. The reviewer has raised concerns with respect to the validity of the model to predict affects to well water users at the extremity of the zone where the water table may drop in elevation due to dewatering operations at the NND Project. OPG agrees that the model is sensitive to input parameters such as the hydraulic conductivity, among others. However, OPG believes that the model contains sufficient conservative elements and reflects the existing conditions. The groundwater flow model has been developed using representative i hydraulic properties for the aquifer and aquitards that make up the groundwater flow system for the area. During construction of the model, the hydraulic conductivity of the model layers have been adjusted to best match the existing water level data for the site, the stream flow in the area (i.e. Darlington Creek and other surface waters) and the recharge for the surface soils. The model is considered to be well calibrated because it represents the key elements of the physical system within a local context, the parameter values used in the model are within physically realistic ranges similar to values measured at the DIN site, and the model provides an acceptable match to observed data on both local and site scales. The predicted drawdown of approximately 1,200 m resulting from dewatering was evaluated using the groundwater flow model. There are several lines of evidence supporting the limited extent of drawdown resulting from dewatering. Comparisons between pre- and post- construction water levels for the DNGS indicate that the drawdown resulting from construction extends to distances on the order of 600 to 800 m. Similarly, the observed drawdown associated with the St. Marys quarry is isolated to the area immediately adjacent to the quarry (less than 500 m) (Golder, 2004). Field measurements during the pumping test indicate a low aquifer transmissivity (a measure of how much water can be transmitted horizontally), which will result in a tight, narrow drawdown cone. Given these comparisons to actual field measurements, the area of influence of the drawdown as depicted by the model simulations are ■' ' 31 MORRISON HERSHFIELD nyr;„ A� Peer Review for Darlington New Nuclear Build (j('■"�/-).��� RFP 2008-15 ' LeadixS Fe N'a7 considered to be reasonable representations of the drawdown that may occur due to dewatering. The nearest domestic wells are located at distances of about 1.5 kilometres form the approximate edge of the excavation for the dewatering. Therefore, the domestic wells are at the outer range of the drawdown cone and will experience the least amount of drawdown within the area of influence. For the dewatering work, the suggested follow-up monitoring will be included because OPG will need to obtain regulatory approvals that usually contain monitoring requirements to measure the extent of drawdown and confirm predictions within the zone of influence. Pre and post dewatering monitoring will assist in assessing whether any adverse effects that may result from the dewatering work at the Project occurred and was mitigated as necessary. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.5 TRAFFIC AND TRANSPORTATION Traffic and Transportation Environment Project Components The Technical Supporting Document Traffic and Transportation — Existing Environmental Conditions Technical Support Document, New Nuclear— Darlington Environmental Assessment(MMM Group 2009) described and addressed the Traffic and Transportation Environment in the context of the following environmental sub- components: • Transportation System Operations: operational efficiency and adequacy of all modes of transportation (i.e., road, rail, marine) relative to demand; and • Transportation System Safety: safety-related conditions associated with all modes of transportation (road, rail and marine). Traffic and Transportation Environment Project Impacts Notwithstanding system improvements that will be made by the jurisdiction responsible for the roads network, some intersections will experience decreased Levels of Service (LOS) in the future as a result of Project-related traffic. These conditions will be experienced primarily at intersections and in the roads network south of Highway 401 between Courtice Road and Waverly Road. Locations of increased collision occurrence have been identified in the LSA. The road safety audit conducted along major roadways within the LSA identified issues generally 32 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build Q RFP 2008-15 dixg the Way typical of those that can routinely be found in similar study areas. The most common concerns include pavement conditions, approach configurations, sightline issues and inadequate pedestrian facilities. Given that the Project will add traffic to the existing roadways and contribute to ongoing degradation of the roads system, there is an increased likelihood of collisions and/or other safety-related incidents. It is possible the some unknown quantity of surplus excavated soil may be exported from the Project site for disposal. Until a destination for such soil is known, specific haul routes for the transport vehicles are also unknown. However, the three northbound arterial roads in the vicinity of the Project site, Holt Road, Waverly Road and Courtice Road, Holt Road were selected for the assessment of effects. Depending on the frequency of truck trips, the CP Rail level crossing on Holt Road north of Highway 401 could contribute to an increased frequency of train/truck collisions. Peer Review Findings Overall, Morrison Hershfield was of the opinion that the traffic and transportation methodologies and subsequent analysis completed for this Project was not adequate to fully identify potential impacts to the Municipality of Clarington. Peer Review Comments Morrison Hershfield identified two key issues that were forwarded to OPG for formal disposition. The two comments are as follows: Comment. The transportation effects analysis did not assess the traffic impacts to the Municipality of Clarington from truck traffic resulting from off-site excess soil haulage or haulage of cofferdam and other materials to the New Nuclear Darlington site except for Holt Road. We suggest that a more fulsome analysis of municipal road impacts from these sources needs to be completed to adequately identify and quantify the impacts. Mitigation will need to be reviewed following the additional analysis. We suggest that follow-up monitoring should be conducted for transportation and traffic effects to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. Comment. The traffic operations analysis for both existing conditions and effects assessment was done at an individual unit level for various selected intersections within a designated area. We suggest that this level of analysis is insufficient to adequately identify the potential traffic and transportation impacts to the Municipality of Clarington and that a more fulsome network-style analysis, or equivalent level of effort, needs to be completed within a broader area of study. The area bounded by Regional Road 57, Courtice Road and Taunton Road is suggested. Link levels of service should be accounted for. Mitigation will need to be reviewed following the additional analysis. We suggest that follow-up monitoring ■ `= 33 MORRISON HERSHFIELD n y.� Peer Review for Darlington New Nuclear Build (�r( RFP 2008-75 Leadln8 fke wag should be conducted for transportation and traffic effects to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. Disposition:OPG conducted the Transportation and Traffic assessment within a study area considered to be appropriate for the size and scope of the project. Nevertheless, both reviewer's Comments 2 and 3 suggest that the detailed study area chosen for the Project was not large enough to allow detailed conclusions to be drawn to adequately identify and quantify the impacts on the municipal roads. The original study area for the New Nuclear Darlington Environmental Assessment was comprised of the road network bounded by Courtice Road (west), Baseline Road (north) and Regional Road 57 (east). The Existing Conditions and Effects TSDs were written based upon analysis conducted within this boundary. In discussions with the Municipality of Clarington, OPG agreed to conduct additional traffic studies in a larger or enhanced study area, to compliment the original studies performed. The larger study area will be bounded by Courtice Road (west), Highway 2 (north), Regional Road 57 (east) and Lake Ontario (south). The same work and analyses will be conducted in this enhanced study area that was conducted in the original study area. This additional work in the enhanced study area will assess the existing transportation infrastructure network, identify impacts from any future developments and outline any improvements to be implemented on the road network. The conclusions resulting from the analysis in the enhanced study area will be compared with those from the original study area (as described in the Existing Conditions and Effects TSD, and EIS). Any changes to the original conclusions will be identified and additional mitigation measures developed. This work is expected to be completed prior to the EA submission to Joint Review Panel. Although specific details in regards to soil haulage routes and material delivery is not accurately known at this time, once a vendor is selected for this project, offsite soil storage locations and suppliers of material for the project will be identified. At that time detailed analysis of the different traffic routes can be undertaken. The effects TSD describes the soil haulage scenario as the bounding condition being within 25km of the Project site. Mitigation measures provided in the EIS (Table 5.15-1) include development of a Traffic Management Plan. This Traffic Management Plan will be derived through collaboration with OPG, the Municipality of Clarington and the Region of Durham. The Traffic Management Plan will assist in identifying transportation system deficiencies. Regular discussions will be held to maintain the status of any issues that arise and 34 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 lsadixg Nee Wad identify new issues. The Traffic Management Plan will be used to deal with issues such as the soil haulage and material delivery concerns, when more specific information is known. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.6 ATMOSPHERIC ENVIRONMENT Atmospheric Environment Project Components The Technical Supporting Document Atmospheric Environment— Existing Environmental Conditions Technical Support Document,New Nuclear- Darlington Environmental Assessment(SENES Consultants Ltd. 2009) described and addressed the atmospheric environment in the context of the following Project sub-components: • Air Quality: the physical (climate and meteorology) and chemical characteristics (nonradiological only) of the airshed in the vicinity of the Project site; and Noise: sound level characteristics in the vicinity of the Project site. Atmospheric Environment Project Impacts With limited exception, the concentrations of the modeled contaminants in air are below their respective regulatory criteria. The exceptions, SPM at one receptor location and acrolein as a result of an elevated background condition. Based on the results of the modeling which considered very conservative bounding assessment scenarios, the changes in Air Quality as a result of the Project are not considered to represent an adverse environmental effect in the Atmospheric Environment. Some measurable increases to background concentrations of the contaminants are predicted at onsite and offsite receptor locations. Although within regulatory parameters (not including hydrazine which does not have a 24-hour AAQC), these increases were considered further in terms of pathways to Human Health, Non-Human Biota and VECs in the Terrestrial Environment and the Socio-economic Environment. Changes in conditions in the Atmospheric Environment associated with operation of cooling towers include meteorological (e.g., fogging, icing, water deposition), aesthetic (visual effects of vapour plumes) and physical (salt deposition). These changes are not considered to represent an adverse environmental effect of the Project in the Atmospheric Environment. Noise conditions in the vicinity of the residential receptors are largely related to background traffic, and to a lesser extent, the operations at St. Marys Cement. A moderate increase in sound levels is predicted during site preparation activities at the closest residence west of the Project Site. This will be of limited duration and only occur ■ 35 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 lea2ieg tpe We) during the day. The predicted increases in sound levels at the other residential receptors are negligible during all phases of the Project and are not considered to represent an adverse environmental effect in the Atmospheric Environment. Peer Review Findings Morrison Hershfield concurs with the findings of the Atmospheric Environment Existing Conditions and Effects Assessment in that the proposed site preparation, construction and operation of the Project offers negligible impacts to the existing atmospheric environment and that the mitigation measures identified are sufficient to negate any residual effects. Peer Review Comments Morrison Hershfield identified two key issues that were forwarded to OPG for formal disposition. The two comments are as follows: Comment: Notwithstanding the Project will be operated as a separate facility from the existing Darlington Nuclear Generating Station, the cumulative noise impacts of the existing operations and the proposed new operations should be considered together for the purposes of establishing a baseline for comparison. Noise mitigation must be applied whenever there is an excess of the established limit (not optional) and the effects assessment in Table 3.2-2 should be reviewed with this requirement in mind. Please review the Health Canada criteria on noise impacts from transportation sources to ensure that current criteria are used. Disposition:The Project site is considered to be a completely separate operation from the existing operation - existing conditions include the existing site. Sound levels from the Project site were assessed using both provincial and federal guidance. The provincial guidance document, NPC-205 (MOE. 1995b) establishes the sound level limits for stationary sources such as industrial and commercial establishments or ancillary transportation facilities affecting points of reception in Class 1 and 2 Areas (Urban). Potential impacts from the project, from sources such as construction equipment, are outside the scope of NPC 205. In light of this, more general criteria were sought for assessment of all project related noise sources (increase in local traffic, construction. Project operations). Federal guidance (Health Canada, 1989) and provincial land use guidance (LU 131 MOE 1997) were reviewed, as each provides a magnitude of relative sound level above background. Health Canada is currently in the process of developing a national guideline approach for examining potential environmental noise impacts for projects under the Canadian Environmental Assessment Act. However, these guidelines are in draft form and under considerable revision. Health Canada was contacted directly to request the draft version; however, they would not issue its m' 36 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build /(lZL7Wjl RFP 2008-15 �..va�ag ts.way release. While it is recognized that these are intended for application in transportation projects, these were adopted as indicators of potential noise effects for this Project on the basis that noise is a nuisance effect whether it be from transportation sources or otherwise, and the relative magnitude of the incremental increase (if any) should be applicable. Section 2.2.3 of the Baseline TSD has since been revised to include the above discussion and indicate that the NPC 205 limits have been adopted. These limits were adopted not to confirm compliance but rather as an indicator of potential effects of the Project. Section 5 (Noise Assessment) of the Baseline TSD has also been significantly revised. The section provides a summary review of the municipal, provincial and federal noise guidance documents considered in establishing assessment criteria. From the review the MOE guidance NPC-205 (MOE 1995b) for stationary sources appeared to be the most applicable for this assessment. However NPC-205 scope excludes construction activities that will contribute to the potential effects of the Project. A review of other guidance documents provided a suitable means to assess the impact of all sources of noise As discussed above, the assessment of the noise impact of the Project was performed per the criteria of MOE NPC 205 even though the guidance only applies to stationary sources of noise and construction noise is excluded in NPC 205. The Effects TSD Tables 3.2-2 and 3.2-3 have been revised to summarize the significance of incremental increases in noise levels according to the provincial and federal guidance (MOE 1997 and Health Canada 1989, respectively). Again, they typically to transportation projects, not industrial noise source assessments. However it was determined that in the absence of noise criteria values for all aspects of the Project, these indicators were deemed to be relevant for the Project. Comment: The Air Dispersion Model produced inconsistent results, particularly for upwind concentrations and background levels. Contributions for roadway and on-site sources appear to be understated. The result is that the effects analysis de-emphasizes the difference between the build and no- build scenarios and understates the attainment status of some receptors. We suggest that the modeling approach be reviewed and a validation exercise be performed. Instances of where local monitoring data differs from modeled data should be identified. Disposition:OPG has reviewed the modelling approach as suggested. The regulatory air dispersion model for existing facilities in Ontario is the O. Reg. 346 dispersion model. This model is the current regulatory model for the existing plant at DNGS. The Ontario Ministry of the Environment (MOE) implemented a new regulation in November 2005. Ontario Regulation Ir■ rii 37 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 Q404y9ton 419105: Air Pollution — Local Air Quality (O. Reg. 419) replaces O.Reg 346. MOE is using a phased approach for implementation the new regulation, with new facilities, such as the Project, required to comply with O. Reg. 419. The new O.Reg. 419 sets out new and updated effects based air standards and applies new Air dispersion models. The existing DNGS site is not required to update the model until 2020. The model preferred for use by the MOE is AERMOD. AERMOD is the model used to assess air quality effects associated with the Project. In order to have a baseline condition against which to assess the effects, the existing conditions were also modeled with AERMOD to allow a common basis against which to identify a change in the environment. AERMOD was used for the atmospheric dispersion modeling of the emissions from DNGS. AERMOD is a steady state Gaussian Plume model that provides options to model emissions from a wide range of sources. Dispersion modeling was conducted to determine the contribution of the emission sources to the local air quality. The model predictions were used in conjunction with the monitoring data to determine the appropriate contribution from upwind sources to add to the model predictions to determine the air quality concentrations as specific receptor locations. Various other emission and dispersion models were used, in addition to AERMOD, in the Air dispersion modeling work from this Project. These included Mobile6.2C, CAL3QHC, O.Reg. 346. Review of the modeling results has also been accepted as a useful verification step to take prior to finalizing the EIS. As a component of this review a validation exercise will be undertaken to illustrate for the roadways adjacent to the DN site, whether the AERMOD calculations agree with the CAL3QHC results for the same sources. At the same time, a confirmation of the appropriate upwind background concentrations will be completed and any gaps will be identified and the appropriate documentation revisions or studies will be performed. The conclusions of the assessment are not expected to change as a result of this work. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.7 PHYSICAL AND CULTURAL HERITAGE Physical and Cultural Heritage Project Components The Technical Supporting Document Physical and Cultural Heritage Resources— Existing Environmental Conditions Environmental Assessment Technical Support Document— New Nuclear- Darlington (Archaeological Services Inc. 2009) described r 38 MORRISON HERSHFIEI-O Q i��� Peer Review for Darlington New Nuclear Build (�Z�7�LL RFP 2008-15 ng the WaY and addressed physical and cultural heritage in the context of the following Project sub- components: • Archaeology: Aboriginal and Euro-Canadian resources comprising both sub- surface features and artifacts that pertain to archaeological sites (including marine archaeological sites) and areas of archaeological potential; and • Built Heritage and Cultural Landscape: Euro-Canadian resources pertaining to built heritage features such as architecture or above-ground structural remains and artifacts, or cultural landscape units such as farm complexes, roadscapes, waterscapes, railscapes, historical settlements, cemeteries or commemorative sites/plaques. A third possible sub-component, Paleontology, is not relevant for these EA studies due to the absence of identified physical heritage resources, such as paleontological sites, within the Project site. Physical and Cultural Project Impacts As a result of physical disturbance of the site during the Site Preparation and Construction Phases, three Euro-Canadian archaeological resources, identified as Site H1 (Brady, AIGq-83), Site H5 (Metcalf, AIGq-85) and Site H7 (Crumb, AIGq-86), will experience total displacement. . In the event that Project works and activities encroach into the area thought to be occupied by the Burk Cemetery, and Burk Pioneer Cemetery Monument and Plaque (BHF-1) the cemetery and the monument and plaque will be totally displaced. Peer Review Findings Overall and subject to the formal comments below, Morrison Hershfield was of the opinion that the physical and cultural heritage assessment methodologies and subsequent analysis completed for the Project appropriately categorized the predicted effects of impacts and was adequate to fully identify potential impacts to the Municipality of Clarington. Peer Review Comments Morrison Hershfield identified two key issues that were forwarded to OPG for formal disposition as follows: Comment: The analysis of existing cultural heritage resources was completed within the site study area only. We suggest that a more conservative boundary of 500 metres should be used to document existing conditions and determine potential effects. I 39 MORRISON HERSHFIELD QPeer Review for Darlington New Nuclear Build d (�( �LD�ll RFP 2008-15 ing the Wok Disposition:The reviewer accepted the assessment, but suggested an improvement to increase the assessment of the Site Study area by 500 m to ensure conservatism. As added benefit to the work completed for the Site Study area, OPG agrees to extend its documentation of existing cultural heritage resources, i.e. built heritage features and cultural landscapes, by 500 metres beyond the Site Study Area. This work was completed in May 2009 and will be reported in a TSD. Comment: Assumptions concerning the Burk Cemetery remain indeterminate. We concur with the need for additional research into this site to determine whether interred remains exist so that the proper mitigation can be developed. In the interim, we suggest that a very conservative zone of no disturbance be established for planning purposes. Disposition:The initial scope of the project included the removal of the Burk Pioneer Cemetery as it was thought that only the monument needed to be re- located. However, as the EA progressed, new findings increased the uncertainty regarding the possibility that internments may be present. As a result, the removal of the Burk Pioneer Cemetery was withdrawn from the scope of the NND Project. Nevertheless, OPG has completed both archival and genealogical research relating to the Burk Pioneer Cemetery. While members of the John Burk Jr. (ca 1786-1832) family were buried there (at least eleven interments are present), there are no records or transcripts indicating that any of the bodies have been transferred to another local cemetery. OPG will develop a long-term plan to protect the Burk Cemetery by including a buffer zone of 60 m around the known boundary of the cemetery to ensure its conservation. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.8 SOCIO-ECONOMIC ENVIRONMENT Socio-Economic Environment Project Components The Technical Supporting Document Socio-economic Environment—Existing Environmental Conditions Environmental Assessment Technical Support Document— New Nuclear- Darlington (AECOM 2009) describes the potential effects of the Project in the context of the following environmental sub-components and which are referred to as community assets. The description of the Socio-economic Environment applies the concept of"community wellbeing" as its overall analytical framework. This concept has been used as the basis for sociological, economic and sustainable development planning studies in Canada and internationally. m• om* 40 MORRISON HERSHFIELD n�n�n�zjn„ Peer Review for Darlington New Nuclear Build i�.a�As n�w•� (�(��( RFP 2008-15 • Human Assets: population and demographics, skills and labour supply, educational; health and safety, social services, and economic development services; • Financial Assets: employment, business activity, tourism, income, residential property values and municipal finance and administration; • Physical Assets: housing, municipal infrastructure and services; and community character; • Social Assets: community and recreational facilities and programs, use and enjoyment of property and community cohesion; and • Natural Assets: Atmospheric Environment, Surface Water Resources, Aquatic Environment, and Terrestrial Environment. For the purposes of the Socio-economic Assessment, the natural assets sub- component was detailed in separate TSDs. Socio-Economic Environment Project Impacts The Project may result in increased requirements for some municipal and social services, including fire, policing, emergency preparedness, health care and day-care. The increased requirements are small relative to the existing municipal and social services base and can reasonably be expected to be addressed through ongoing service expansions required as a result of routine development and supported by increased tax revenues associated with the Project. The Project is not expected to result in adverse environmental effects on economic development, tourism, agriculture, property values, or municipal revenues and finance. If the Project were to be implemented with natural draft cooling towers, it would result in a negative change in the character of communities in the LSA and RSA from where the cooling towers would be a prominent feature of the landscape, particularly in the immediate vicinity of the Project site. Reduced use and enjoyment of the community and recreational features on the Project site during the Site Preparation and Construction Phase. Nuisance-related effects (e.g., dust, noise, traffic) may impact some residents living along truck haul routes may experience disruption to their use and enjoyment of their property during the Site Preparation and Construction phase. If the Project were to be implemented with natural draft cooling towers, it would result in reduced enjoyment of private property in the RSA and LSA due to the visual dominance of the cooling towers on the landscape. Several socio-economic benefits were also identified as a result of the project and they are discussed in section 6.0. Benefits to the Municipality of Clarington from this project I r1rr 41 MORRISON HERSHFIELD I �r�ti/�� Peer Review for Darlington New Nuclear Build '/'`Yy0o RFP 2008-18 rrw;,r�a.w:y are certain only to the extent that Clarington has an authority to accrue such benefits, such as taxes or development charges. Peer Review Findings In general, the socio-economic effects analysis was thorough in scope however Morrison Hershfield was of the opinion that the socio-economic methodologies and subsequent analysis completed for this Project was not entirely adequate to fully identify potential impacts to the Municipality of Clarington. However, as the resolution of financial impacts to the Municipality of Clarington were confidential and not discussed within the framework of the peer review, Morrison Hershfield focused on the baseline existing conditions methodologies and non-financial socio-economic impacts. Peer Review Comments Morrison Hershfield identified seven key issues that were forwarded to OPG for formal disposition as follows: Comment: We suggest that the changes in the automotive sector are more than a "predicted cyclical slowdown"' and what is occurring is a major restructuring in the North American automotive sector. GM in Oshawa is evolving and the future is uncertain at this point and there should be an assessment of the potential impacts to the Municipality of Clarington with respect to competition for employment at the Project and the supply of materials from local businesses. Disposition:OPG agrees and additional information has been included in the Socio- Economic Existing Conditions TSD to recognize the major restructuring occurring in the North American auto sector. The Socio-Economic Environment Assessment of Environmental Effects TSD has been revised to recognize competition for employment for the Project is a provincially- wide phenomenon and not specifically focused in Clarington, Oshawa and is not specific to the auto sector. The TSD will recognize that job opportunities associated with the Project will be limited for auto sector employees, since the skill set and types of jobs are specific to nuclear energy. However, opportunities do exist for specialized trades (e.g. boilermakers, millwrights, crane operators, ironworkers) that the auto sector may have. These trades have a greater opportunity for employment opportunities. Additional information was added to the TSD to recognize the recommendations of the "Community Adjustment and Sustainability Strategy for Oshawa and Durham Region" responding to the changing economic structure of Durham Region; The Socio-Economic Existing Conditions TSD has been revised to clarify that Infrastructure Ontario is undertaking an evaluation of potential ■ °' l 42 MORRISON HERSHFIELD ny.jn�i{n„ Peer Review for Darlington New Nuclear Build RFP 2008.15 LeaGinB lke Wey vendors to construct the Project and that one part of the evaluation is the investment in Ontario (measured by total impact on the Ontario GDP). Some of this investment may occur in the LSA, including Clarington. However, many of the parts and supplies to be used in the construction phase of the Project are likely to be sourced outside of the LSA and that existing businesses that supply goods and services to the Project site are not likely to expand. Based on results from a Nuclear Service Supplier Survey, some nuclear service industry suppliers may choose to relocate to the LSA should the Project proceed. Comment: The day trip tourist market is an important component of the overall tourist market to Durham Region and the host community, Clarington (not just for parks, including Darlington Provincial Park, but also for downtown areas and tourist businesses). The importance of same-day visitors needs to be acknowledged and the predicted impacts on this economic resource assessed. Given the wide range of other competing locations for the day- trip market, anything that interferes with access to or the attractiveness of the host community could impact visitation levels. Decreased levels of tourists staying overnight in the area may translate into lower spending at tourist related attractions in the area. Tourism is a very competitive industry - tourists may choose to visit other areas where they have less competition for accommodations and will not be inconvenienced by any perceived or real impacts in the area (traffic congestion, noise) during construction. Attractions and services oriented to tourist markets in Clarington (not just the Darlington Provincial Park and Bowmanville downtown) may lose some business. We suggest that there needs to be a more fulsome assessment of the financial impacts on the host community from tourism diversion during construction and operation of the New Nuclear Darlington project. Disposition:OPG agrees that the day trip tourist market is an important component of the Durham and Clarington tourist economy. Additional information has been included to the Socio-Economic Environment Existing Conditions TSD recognizing the importance of the day trip tourist market and importance to downtown areas and tourist businesses. In addition, 2007 additional tourism data has been added to quantify the importance of the day tourist visits to Durham Region. The Socio-Economic Environment—Assessment of Environmental Effects TSD has been revised to acknowledge that businesses focused on tourism are vulnerable to tourist diversion. Additional analysis will be focused on this potential effect during the Site Preparation and Construction Phase of the NND Project when tourists may compete with construction workers for accommodation, and during the Operations Phase as a result of changes in community character should natural draft cooling towers be constructed. lrr• 43 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 �.Pfl�1'fls l�/l{YC' Although some tourist markets may lose business, we disagree that an assessment of financial impacts on Clarington from tourist diversion during construction and operation of the NND Project is necessary. Overall, the potential effects of the NND Project on tourist diversion are anticipated to be minor. This is supported by local study area stakeholder interviews that were conducted in which the majority of tourist operators indicated they had no concerns with the NND Project, and some mentioned that the project would be a benefit by bringing more people into the area and creating economic opportunities. Comment. The EIS discusses the "indirect effects" of the Project on school enrolment. It is unclear why this is considered an indirect effect; if the employees are a direct impact then perhaps the families should also be considered a direct impact. Nonetheless, the report provides some estimate of the enrolment growth based on the "population growth in the Rural Study Area and Local Study Area." It is unclear as to what the impact is of the Project both during the construction phase and the ongoing site operation. Nor is it clear if the growth in students, over the planning period, can be accommodated within the existing schools or whether new pupil places will be required. There is the potential of direct and indirect fiscal impacts to the School Board arising from the Project. Disposition:OPG disagrees that the family members (school children) should be considered a direct impact. The direct effect of the Project is the provision of employment opportunities. School enrolment is described as an indirect effect, as it is a result from the provision of employment opportunities. We do not recommend any additional changes. OPG agrees that the Socio-economic Environment Existing Conditions TSD should clarify what the impact of the Project has on school enrolment during the construction and operation phases. The TSD has been modified to acknowledge that increasing enrolment is being experienced by some schools boards operating in Clarington and that are indicators that there are increasing pupil accommodation needs in Clarington. The TSD indicates that this situation is the result of rapid population growth in the municipality over the past several years. The Socio-economic Environment Assessment of Environmental Effects TSD provides an estimate of the number of additional students that would need to be accommodated within the LSA, including Clarington and places this effect in the context of continued growth in population likely to be experienced in the future. The assessment concludes that the indirect effect of the Project is a small proportion of the anticipated municipal growth. An assessment of the ability of existing schools to accommodate student growth has not been undertaken, nor is it required. With respect to the ability of existing schools to accommodate the number of students r � ,, t' 44 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 Lexdixg the Way anticipated as an indirect result of the Project, the TSD reports on interviews with School Board officials. They provided insight as to how they routinely review and plan for additional or declining enrolment. Interviews with school board officials indicated that they did not anticipate that the Project would place additional demands on School Boards that could not be met through normal planning — but requested that OPG keep them informed about the Project schedule and anticipated workforce demands. OPG has committed to such information sharing. With respect to the fiscal impact on school boards, the assessment indicates that school boards and individual schools that are in decline stand to benefit from increased enrolment, while those that are anticipating increased enrolment will also benefit from increased funding and will be in a better position to implement their plans for new schools with more confidence. The TSD was revised to include a statement that existing fiscal mechanisms are available to assist with capital and operating costs of school boards (ie. Educational Development Charges for new development and municipal tax revenues for existing development). Comment: It is understood that the Project will provide on-site fire services; however, the new facility will create an increased demand on Clarington's Emergency and Fire Services. During the long construction phase there will be a significant increase in traffic to and from the site by construction employees, materials being delivered and removed from the site, and related activities. The increased activity will result in additional off-site incidents that will require a deployment of Clarington Emergency and Fire Services personnel, vehicles and equipment. Post-construction, the Project will continue to generate servicing needs related to the ongoing full-time employment at the new facility and the regular cycle of site and facility refurbishments at the site. Clarington is under significant pressure to expand fire service provision and historical services are not an adequate indicator of future need. The discussion on the impacts on Clarington's Emergency Services appears to be understated, as does the potential fiscal impact to the Municipality arising from these impacts. As the municipality grows and develops the Emergency and Fire Services department needs to expand buildings, vehicles, equipment and personnel to be able to respond at an appropriate level, and at acceptable response times, to a growing number of incidents. The EA indicates that the indirect demands of the Project will be addressed by the Municipality through increased household property taxes associated with the Project and other revenues (e.g. development charges)." No analysis or quantification is made to support this statement. Development Charges are only available to fund initial capital needs and do not provide monies to offset additional operating costs (ie. Fire). In ,•r 45 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 Leediwg the f{'ay addition, the historic service level restriction of the Development Charges Act results in development charges not fully funding growth-related fire service needs in Clarington. It is likely that the increased property assessment from households indirectly related to the Project, at the current Municipal tax rates, will not fully fund the associated increase in fire service costs. The report should include quantifiable analysis to support the suggestion that the Municipality's finances will not be adversely impacted and also an analysis as to when the Municipality will require the funding to supply additional services in comparison to when the Municipality will realize increases in tax revenues from the Project. Disposition:OPG recognizes that Clarington needs to expand its fire services (as evidence by Clarington's plans to hire additional fire services staff in the next several years) and that historical levels of services are not an adequate indicator of future need. The Socio-economic Environment— Existing Conditions TSD has been modified to clarify the current state of fire services in Clarington, the roles of Clarington's and OPG's fire services and relationships. The Socio-economic Environment -Assessment of Environmental Effects will note that it is a requirement of the Project Agreement that the Vendor (responsible for construction) must provide an emergency plan to the satisfaction of OPG regarding the provision for on-site emergency and fire response during the site preparation and construction phase. The size and other requirements for such a fire response service are not known at this time. The TSD will state that development charges collected by the municipality as part of new development in the municipality (including some buildings for the Project) as well as property taxes that OPG currently pays and will continue to pay will also be available to the municipality to support fire services. Monies for the ongoing maintenance of these services will be available from property taxes to be paid by OPG and other community members. The Host Municipality Agreement between OPG and Clarington is intended to address the indirect effects of the Project on municipal fire services. No additional analysis is required. Comment: We suggest that the Municipal Finance and Administration section of the report is inadequate for the Municipality to assess the fiscal impacts of the Project. The analysis and report doesn't quantify or examine the direct and indirect expenditure impacts of the Project and associated growth. The report provides some discussion and analysis of estimated additional I 46 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 leading fke ribs tax revenues that will be contributed by the Project and associated households. There is little to no support for these global tax revenue estimates or an allocation to the various municipal governments in the Regional Study Area and Local Study Area. More importantly, additional tax revenues are only one half of municipal fiscal impact analysis with the other half being the impact on municipal expenditures. The Municipality of Clarington has no way of determining the fiscal impact of the Project without a complete and thorough examination of the expenditure impacts. Clarington is facing significant fiscal issues but the report does not identify them. In 2008, Hemson Consulting completed a study on behalf of Clarington entitled Financial Impact Analysis of New Development. This study identified a number of important fiscal issues facing Clarington including service levels, capital budget constraints, forecast rising debt levels and significant upward pressure on tax rates - all of them important to be assessed in the context of the Project. Disposition:The Municipal Finance and Administration section of the Socio-Economic Assessment of Environmental Effects TSD was not intended to assess the fiscal impacts of the NND Project on the municipality. Fiscal impact assessment is commonly undertaken by municipalities for major developments. As noted by Hemson (2008) Section 5.3.8 of the Official Plan for the Municipality of Clarington provides for a fiscal impact analysis to be undertaken for large scale developments. The Host Municipality Agreement between OPG and Clarington is intended to address the indirect effects of the Project on municipal finances. No additional analysis is required. OPG recognizes Clarington's fiscal issues and the EIS and TSDs have being revised to recognize the fiscal situation of Clarington. The Hemson (2008) report referenced provides an analysis of residential development proposals and their cumulative effects on municipal services. Key conclusions from this report have been included in the Socio-economic Environment— Existing Conditions TSD. It is anticipated that workers at the Project will pay their share of property taxes, to provide for the level of service required to accommodate their needs. Comment: The Project will receive water supply and waste treatment from the Region. However, there is no analysis of the impact on the ability of Clarington to continue to grow once the required servicing capacity for New Nuclear Darlington has been taken out of the available Regional capacity. What will be Clarington's share of the remaining available Regional servicing capacity and is that sufficient to support the growth plans for the municipality? a 47 MORRISON HERSHFIELD QPeer Review for Darlington New Nuclear Build ding '■`�'/a��jj RFP 2008.15 (be ri'a) Disposition:OPG recognizes that the NND Project will utilize servicing capacity for water supply and sanitary sewer service from the Region. Based on discussions with Durham Region Works Department staff, servicing for the NND Project has been accounted for in its plans and as such, the new CWPCP has sufficient capacity to accommodate the project and allow for additional growth in Clarington. The Socio-economic Environment— Existing Conditions TSD has been modified to acknowledge servicing limitations in some areas of Clarington and notes that the Regional Works Department is currently undertaking a Master Water and Wastewater Servicing Strategy for Durham Region. This study identifies existing constraints on services and the potential means of addressing them, including planned expansions to water supply and sanitary sewage facilities. The Socio-economic Environment—Assessment of Environmental Effects TSD quantifies the additional direct and indirect demands on water and sewage and concluded that the NND Project and its associated population are not expected to place demands on municipal water and sewage systems that would exceed their existing or planned capacities. Comment: The discussion of municipal infrastructure should also assess the impacts, both financially and on the residents, from the loss of recreational opportunities and facilities such as the on-site soccer pitches and the Waterfront Trail. Disposition:OPG agrees that the discussion on the potential loss of recreational opportunities and facilities such as the on-site soccer pitches and the Waterfront Trail should be provided. This information is provided in Section 3.3,4.1 "Community Recreational Facilities and Programs" in the Socio-Economic Environment Assessment of Environmental Effects TSD. The Socio-economic Environment—Assessment of Environmental Effects TSD provides mitigation for such effects through the Host Municipality Agreement. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.9 CONVENTIONAL ACCIDENTS AND MALFUNCTIONS Accident and Malfunctions Project Components The Technical Supporting Document New Nuclear-Darlington Environmental Assessment Technical Support Document— Environmental Effects Assessment, Malfunctions, Accidents and Malevolent Acts (SENES Consultants Ltd. 2008) described 48 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build (j( Lea RFP 2008-15 dixg the Wa7 and addressed conventional accidents and malfunctions in the context of the following Project sub-components: • Site Preparation and Construction, and • Operations and Maintenance Accident and Malfunctions Project Impacts For each category of screened impact scenarios one or more conventional malfunction and accident scenarios were selected as the bounding scenario. The criterion for the selection of the bounding scenario was the extent of environmental interaction resulting from the event. The bounding scenario is expected to have a greater potential environmental effect than the other scenarios within the category. The screened impact scenarios include: • Accidents involving release of fuel into Lake Ontario; • Accidents involving release of fuel or oil onto land; • Accidents involving a release of chemicals; • Accidents involving the fall of heavy equipment; • Fire and explosion accidents; • Accidents involving the release of gases; • Accidents involving occupational health or personal injuries; and • Accidents involving a sediment release during dredging. Peer Review Findings Overall, Morrison Hershfield was of the opinion that the accident and malfunctions assessment methodologies and subsequent analysis completed for the Project appropriately categorized the predicted effects of impacts from conventional accidents and malfunctions and that, following the application of safe construction practices, on- site response capabilities and regulatory safety compliance, was adequate to fully identify potential impacts to the Municipality of Clarington. Peer Review Comments Morrison Hershfield identified one key issue that was forwarded to OPG for formal disposition as follows: 49 MORRISON HERSHFIEI-D Peer Review for Darlington New Nuclear Build RFP 2008-15 Leading Me Way Comment: The analysis of predicted construction injuries has been compared to any other construction project which does not appear to adequately quantify or qualify the construction accidents that will be likely realized during the construction of the New Nuclear Darlington site, in both terms of numbers (type and severity including fatalities) and duration (construction years). This more fulsome analysis of accidents needs to feed into the broader discussion on Socio-Economic, Human Health and the challenges that Clarington currently faces, and will face in the future, in providing emergency medical services. Disposition:The reviewer's concern that the comparison of accidents was not adequately addressed with respect to quantifying or qualifying construction accidents has been elaborated on in the TSD and EIS. The discussion of accidents resulting in personnel injuries has been expanded and clarified in the Malfunctions, Accidents and Malevolent Acts Technical Support Document (TSD) and the EIS. Clarification was provided that the rates of injury for employees working on the construction of NND facilities is expected to be equal to or less than those at other construction sites for jobs of similar duration and complexity in Ontario. The three primary categories of construction-related injuries at Ontario construction sites are injuries due to falling, from falling objects, and from electrical hazards. These are the same primary categories of injury to construction workers employed by OPG. This provides additional confidence in comparing the potential injury rates (see below) between Project construction work and other Ontario construction worksites. Historically, injury rates at OPG facilities compare favourably with those reported for construction work in Ontario. In response to the reviewer's comment, statistics have been added to the TSD and the EIS, and a comparison has been made between the All Injury Rate (AIR) for (a) all work in the construction industry in Ontario (data from the Construction Safety Association of Ontario (CSAO)), (b) all work done by contractors employed by OPG (where OPG is the constructor), and (c) all work done by OPG employees. In 2007, these numbers were 6.64, 2.08 and 1.12 injuries per 200,000 hours worked, respectively. (it is noted in the TSD that the definitions of AIR used by OPG and CSAO differ slightly, but the numbers are still able to be compared for the purpose of trending.) In addition, in 2007 in Ontario there were 1.96 lost time injuries per 200,000 hours worked in the construction industry. In this same time period, there were no lost time injuries to construction workers employed by OPG. The comparison of these statistics demonstrates that OPG workplaces are generally safe workplaces, and reflects the importance that OPG places on safe work. The OPG contractor will be required to prepare a Site- Specific Safety Plan that OPG will audit to ensure compliance with Health and Safety requirements in the Project Agreement with the contractor. ■'' 50 MORRISON HERSMFIELD Qan*w Peer Review for Darlington New Nuclear Build RFP 2008-15 OPG understands emergency medical services (EMS) are provided by the Region of Durham. Nevertheless, during the site preparation and construction phase of the Project, it is anticipated that the Vendor will provide EMS on the site to address triage incidents. Funding for EMS service off-site would be collected through existing fiscal mechanisms (ie. property taxes). OPG will include additional information on EMS in the Socio-Economic Assessment of Environmental Effects TSD to further address. Morrison Hershfield believes that the issue has been fully dispositioned and that it is considered closed. 5.10 EMERGENCY PREPAREDNESS Emergency Preparedness Project Components The Technical Supporting Document Emergency Planning and Preparedness (SENES Consultants Ltd. 2008) described and addressed evacuation planning and capabilities in the event of a nuclear accident in the context of the following Project sub-components: • 3 kilometre evacuation region - • 10 kilometre evacuation region • 15 kilometre "shadow" evacuation region '.. A detailed Evacuation Time Estimate (ETE) study was undertaken specifically for the Project to show that a safe evacuation could take place if a nuclear emergency were to occur. Evacuation time estimates were determined for the Emergency Planning Zone around the Project site; this includes the two evacuation regions of 3 km and 10 km, each of which is divided into Protective Zones. A total of 12 scenarios representing different seasons, time of day, day of the week, and weather were considered. Two temporal scenarios were evaluated: 2006 and 2025. Emergency Preparedness Project Impacts The Project impact relating to emergency preparedness is the potential that residents, employees and visitors within the evacuation zones could not evacuate safely within the prescribed 24-hour time limit. Peer Review Findings Overall, Morrison Hershfield was of the opinion that the emergency preparedness and evacuation time estimate methodologies and subsequent analysis completed for the Project appropriately identified the capabilities to meet the minimum evacuation time in the event of a nuclear accident, subject to the flawless coordination and execution of the provincial, regional, local and site emergency response plans. ir ■ 51 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build QWWM RFP 2008-75 Under the current level of emergency planning, there is ample buffer time available to comply with the prescribed 24-hour evacuation time limit Peer Review Comments Morrison Hershfield identified one key issue that was forwarded to OPG for formal disposition as follows: Comment: The analysis of emergency preparedness was well done and demonstrates that this project can be completed with more than adequate emergency preparedness and planning during all phases. We suggest that, notwithstanding there would be a negligible change in the final results, the model used to determine evacuation time should include a consideration for night traffic which results in an inherent reduction in capacity on its own. Disposition:Although the reviewer acknowledged that this TSD was well done, a suggestion to include evacuation time for night traffic was made. It is difficult to quantify the capacity reduction of a highway section due to night operating conditions since peak traffic flows rarely occur during darkness. However, night time traffic flows in the vicinity of highway work zones can best approximate the capacity reduction posted in the comment. A search for data yielded the study referenced below (based upon freeway work zones in Ontario). The study reported on a capacity reduction of around 7% during off-peak hours due to lighting condition (Day versus Night). The investigation included the effect of darkness on freeway traffic capacity through work zones on urban freeways. "This paper reports findings from recent investigations into freeway capacity at several reconstruction zones in Ontario, Canada. The aim is to provide guidelines for estimating freeway capacity at reconstruction sites. Findings are presented in two parts. The first involved results of individual investigations to estimate a base capacity at freeway reconstruction sites and the individual effect of several important factors that are believed to affect this capacity, namely; the effect of heavy vehicles, driver population, rain, site configuration, work activity at site, and light condition..." As part of our analysis, we estimated that rainy weather conditions would reduce highway capacity by 10 percent. Since the estimate of night time capacity reduction cited in the referenced paper is 7 percent, we believe that our adverse weather ETE estimates can be used to approximate the ETE values for night time evacuation conditions. No further analysis is warranted for EA purposes. 14• 52 MORRISON HERSHFIELO Peer Review for Darlington New Nuclear Build L�[ Il RFP 2008-15 /.ending(be Wa) Reference: "Guidelines for Estimating Capacity at Freeway Reconstruction Zones", Journal of Transportation Engineering, Volume 129, Issue 5, pp 572-577, September/October 2003. Morrison Hershfield believes that the issue has been fully dispositioned and that it is considered closed. 5.11 ECOLOGICAL RISK ASSESSMENT Ecological Risk Assessment Project Components The Technical Supporting Document Ecological Risk Assessment—Assessment of Environmental Effects Technical Support Document— New Nuclear— Darlington Environmental Assessment(SENES Consultants Ltd. 2009) describes the potential effects of chemicals and ionizing radiation on non-human biota. The Ecological Risk Assessment (ERA) Technical Support Document (TSD) differs from the TSDs relating to other environmental components in that it includes a compilation of the various factors within each of the other environmental components, namely, air quality, surface water quality, groundwater quality, and radiation and radioactivity in air and water, which are factors that may affect non-human biota. The consideration of ecological risk associated with non-human biota is described in the context of the following environmental subcomponents: • Terrestrial Biota • Non-Radiological • Radiological • Aquatic Biota • Non-Radiological; Radiological Ecological Risk Assessment Project Impacts The Project will not result in measurable changes to the non-radiological environment that will adversely affect the VECs identified for the non-human biota component of the environment considering the mitigation measures identified for the Surface Water, Air Quality and Geology and Hydrogeology components of the environment. The Project will not result in measurable changes to the radioactivity environment that will adversely affect the VECs identified for the non-human biota component of the environment considering the mitigation measures identified for the Surface Water, Air Quality and Geology and Hydrogeology components of the environment. , 14 53 MORRISON HERSHFIELD CPeer Review for Darlington New Nuclear Build RFP 2008-15 Peer Review Findings Morrison Hershfield concurs with the findings of the Ecological Risk Assessment in that the operation of the Project results in immeasurable effects to the Surface Water, Air Quality and Geology and Hydrogeology components of the environment. Peer Review Comments Morrison Hershfield identified one key issue that was forwarded to OPG for formal disposition as follows: Comment: Currently there is no commitment to conduct follow-up monitoring for non- human biota with respect to the ecological risk assessment. We suggest that follow-up monitoring should be conducted for non-human biota to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. Disposition:OPG agrees that a monitoring program should be developed to confirm predicted EA results. The Ecological Risk Assessment TSD concluded that no residual effects on non-human biota were expected as the result of the Project. Since CSA N288.4 "Standard for Environmental Monitoring at Class 1 Nuclear Facilities" is currently under development by industry and the regulator (CNSC), OPG anticipates the standard will apply to the NND project. N288.4, previously known as the "Guidelines for Radionuclides Monitoring in the Environment', was used to form the basic design for the Radiological Environmental Monitoring Program (REMP) that is currently being conducted at the Darlington Nuclear Generating Station. The new standard will require an Environmental Risk Assessment (ERA) to be performed for the Project to provide the basis for developing an Environmental Monitoring Program (EMP). The ERA will include both risks to humans and non-human biota from radiological and non- radiological constituents, and other stressors. Routine review and updating of the ERA is expected. As the reviewer indicated, if substantive changes (e.g. emissions, contaminants, etc) are identified, this program will serve as a means of monitoring the predicted ERA conclusions. Assessments of the EMP, which includes the REMP, will result in measures to rectify concerns as necessary. As future changes to the regulatory requirements and guidance are anticipated, the suggested follow-up monitoring will be included in the development of the EMP for the Project. Morrison Hershfield believes that the issue has been fully dispositioned and that it is considered closed. ■ 54 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build ■ ��� RFP 2008-15 Leading the Way 5.12 LAND USE ASSESSMENT Land Use Environment Project Components The Technical Supporting Document Land Use Environment— Existing Environmental Conditions Technical Support Document, New Nuclear—Darlington Environmental Assessment (MMM 2009) describes the potential effects of the Project on the land use environment in the context of the following environmental sub-components: • Land Use comprised of existing uses of land and policies, regulatory controls and patterns associated with those uses; and Landscape and Visual Setting comprised of landscapes, viewsheds, views and vistas of relevance to the Project. Land Use Environment Project Impacts The visual analysis has established that cooling towers associated with the Project will be a visually dominant feature in the landscape. The structures themselves will be highly visible in the case of natural draft towers, while mechanical draft towers will be less so as a result of visual screening afforded by topographic features. However, in both cases the vapour plumes that will emanate from the towers will be highly visible. The visual dominance of the cooling towers is likely to affect both the municipal planning regime and land use development patterns and opportunities, in the vicinity of the Project site. As the Project is developed and operated, the increased intensity of activities on the Project site is likely to result in changes to land use and development patterns that would transpire otherwise. As the intensity of use increases on the Project site, the existing as well as currently-proposed sensitive land uses surrounding the site will likely transition to employment and industrial uses. For emergency planning purposes, it can be expected that new sensitive land uses will be directed away from the Project site, which will result in a change to the land use and development patterns from those that would otherwise exist. The visual landscape on the Project site will be permanently altered as a result of the Project. Changes will result from several aspects of the Project, including the development of the Northeast Landfill Area, expansion of the existing Northwest Landfill Area and grading of the existing bluff formations on the lakefront. However, the greatest visual effect will be as a consequence of the existence and operation of cooling towers, either natural draft or mechanical draft since their vapour plumes are of similar geometry. The visual dominance of the cooling towers and associated vapour plume is likely to have a consequential effect on Land Use and was also considered for impacts to the socio-economic environment. 55 MORRISON HERSHFIELD QK10119ton Peer Review for Darlington New Nuclear Build RFP 2008-15 Peer Review Findings Overall, Morrison Hershfield concurs with the findings of the Land Use assessment in that the operation of the Project results in immeasurable effects to the land use planning regime within the local study area. Additional discussion on the potential effects of the visual landscape is discussed in the context of the socio-economic environment. Morrison Hershfield further concurs that the mitigation measures proposed will be somewhat effective in addressing likely effects of the Project on visual aesthetics, however visual effects of the natural draft cooling tower structures and the associated vapour plume released from either natural or mechanical draft cooling towers from offsite vantage points, including those at considerable distance, cannot be effectively mitigated. Morrison Hershfield further concurs that although there is an irreversible visual impact, the Project will not preclude the use and enjoyment of private or public property within the Municipality of Clarington and the magnitude of the impact is likely to further diminish over time as the structures become a familiar feature of the landscape and the Project establishes a positive track record. Peer Review Comments Morrison Hershfield identified two key issues that were forwarded to OPG for formal disposition as follows: Comment: The assessment of land uses within the 10 kilometre zone should clearly identify land uses that OPG would have concerns with based on issues such as, but not limited to, security or emergency preparedness. An assessment of those potential land use constraints should be completed to identify inconsistencies with and impacts to future plans for Municipal growth within the 10 kilometre zone. Disposition:OPG agrees that should there be a concern with specific land uses within the 10km zone that they be clearly identified. The 10 km land use assessment zone was used to assess potential effects of the Project on the existing, planned, future and long-term land uses in proximity to the Project site. At this time, OPG does not have concerns with respect to land uses within 10 km of the Darlington Nuclear Site and has not identified any land use constraints with respect to future plans for municipal growth within this distance based on the current and proposed land uses designated by the Durham Official Plan and Clarington's Official Plan and zoning by-law. The Provincial Nuclear Emergency Plan provides the off-site basis for emergency planning. This Plan requires OPG to support emergency planning and response for areas within a 10 km radius of all nuclear plants. Should future land uses be inconsistent with �r 56 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 QW.W.YM emergency planning needs for the Project, OPG will have opportunities to participate in the planning process under the Planning Act. Section 5.5 of the Canadian Nuclear Safety Commission's Regulatory Document RD-346 provides population and emergency planning considerations to support the achievement of safety goals. This includes an evaluation of population density and distribution, present and future use of land and resources, site characteristics, populations in the vicinity of the Project site that are difficult to evacuate or shelter, and the ability to maintain population and land-use activities at levels that will not impede the implementation of emergency plans. OPG has undertaken evacuation time estimate modeling to demonstrate that households and businesses can be safely evacuated within 10 km of the Project site through the life of the Project to respond to the CNSC's requirements. In addition, a mitigation measure identified in the Assessment of Environmental Effects TSD for Land Use is that the Region of Durham, the Municipality of Clarington, Emergency Management Ontario, Durham Emergency Management Office, and OPG would coordinate as required to address off-site emergency response provisions as they relate to sensitive land uses in proximity to the Project site. Comment: The measurement of population and employment change could be clearer as the percentage change is based on the future growth as compared to the base 2001 population and employment. In effect the population and employment are almost doubling during the forecast period based on the Provincial Growth Plan, Schedule 3. We examined the past and extrapolated the projected population and employment growth for Durham Region, based on 1996 to 2006 census data because this measures the past growth rates experienced by residents of the Region. When we compare this with the Growth Plan forecasts, we find the Growth Plan population forecasts are higher than the past and extrapolated growth rates, at approximately 4%. Whereas projected employment is approximately 50% higher than the Growth Plan employment forecasts at about 2031, in terms of population, this difference would be the equivalent of 30,000 more people by 2031 and 155,000 less jobs by 2031. In an overall context the objective of the Growth Plan is to intensify relatively more population and employment in the existing urban areas. We suggest the EA should recognize actual growth patterns experienced as well as forecasts to carry forward to both the land use and socio-economic effects assessments. Disposition:The EA utilized the Growth Plan forecasts, which municipalities are required to conform with, under the Places to Grow Act. These forecasts were used for the EA as they are representative of the population and employment that municipalities are planning for. We acknowledge that past trends are useful for analyzing changes over time. The Existing i 57 MORRISON HERSHFIELD C� Peer Review for Darlington New Nuclear Build RFP 2008-16 r�d;,.g rhr w•y Environmental Conditions TSD for Land Use considered land use change over a 1.5 year study period within 10 km of the Project site. The Existing Environmental Conditions TSD for Socio-Economic considered historic population change in the Municipality of Clarington. A mitigation identified in the Assessment of Environmental Effects TSD for Land Use is that OPG continue to engage in discussions with the Region of Durham and the Municipality of Clarington regarding future land use structure. This mitigation is to ensure that any effects of the Project on land use structure may be considered in collaboration with the appropriate municipalities through the planning processes. This may include such activities as the Official Plan Review. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. 5.13 ENVIRONMENTAL IMPACT STATEMENT Environment Impact Statement Project Components The Final EIS Guidelines, dated January 2009, were issued on March 12, 2009. The purpose of the Guidelines is to identify for the proponent, OPG, the nature, scope and extent of the information that must be addressed in the preparation of the Environmental Impact Statement (EIS) for the Project. i While the EIS Guidelines provide a framework for preparing a complete and accessible EIS, it is the responsibility of OPG to provide sufficient data and analysis on any potential environmental effects to permit proper evaluation by a joint review panel, the public, and technical and regulatory agencies. The Guidelines outline the minimum information requirements while providing OPG with flexibility in selecting methods to compile and analyze data for the EIS. OPG has prepared an EIS that examines the potential environmental effects, including cumulative effects, of the site preparation, construction, operation, refurbishment if required, decommissioning and abandonment of the project, and that evaluates their significance. The Environmental Impact Statement, New Nuclear— Darlington Environmental Assessment(SENES Consultants Ltd. and MMM Group 2009) consolidates and describes the potential effects of all of the technical disciplines discussed previously in addition to the following sub-components: • scope of the project for EA purposes • compliance with the Draft and Final EIS Guidelines • integration of the precautionary approach • sustainability • residual and cumulative effects impact assessment • approach and commitments to follow-up monitoring 58 MORRISON HERSHFIELD QVOWL-119ton Peer Review for Darlington New Nuclear Build RFP 2008-15 regulatory requirements benefits of the project Environment Impact Statement Project Impacts As the EIS consolidates and describes the potential effects of all of the technical disciplines discussed previously, only cumulative impacts are specifically discussed in the EIS. A total of 34 other projects and activities within the RSA were identified at the outset as having the potential to interact with the proposed Project. Of this total, eight are past or existing, four are certain or planned, and the balance (22) are considered reasonably foreseeable projects or activities. Residual adverse effects of the proposed Project were identified in the aquatic, terrestrial, visual landscape and socio-economic components/sub-components of the environment. Therefore, the assessment of potential cumulative effects focused on relevant VECs within these four areas of the environment. In all four areas, the cumulative effects were found to be such that no additional mitigation measures were considered to be necessary. Several beneficial effects, mostly related to the Socio-Economic Environment, were identified. These will serve to offset the residual and cumulative adverse effects identified. In addition, although no residual radiological health effects had been assessed as likely to result from the Project, this aspect of the Human Health component was examined further. The reason for this additional consideration was the general concern typically expressed by some members of the public that their health, safety and well-being may be affected by radiation and radioactivity from any nuclear project or operation. The cumulative doses to members of the public and workers were found to be low, well below regulatory limits, and thus no additional mitigation measures were considered to be necessary. Peer Review Findings Overall, Morrison Hershfield is of the opinion that the Environmental Impact Statement has been completed very professionally and with a great effort to identify concerns, communicate and consult with relevant stakeholders, and to plan with an overall goal of minimizing the environmental impact of this Project. In our opinion, the EIS has captured the intent and specified content of the Final EIS Guidelines. Peer Review Comments Morrison Hershfield identified several key issues that were forwarded to OPG for formal disposition as follows: Apr 59 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 QVILY19ton . Comment: The EA study has adequately addressed the Project site in the context of Regional sustainability; however there is little discussion of sustainability initiatives, goals or strategies on the Project site itself. We suggest that sustainability needs to be reviewed and assessed on a site-specific basis and that existing OPG sustainability policies and goals need to be incorporated into construction and operations for the Project. Greenhouse gas emissions should be an indicator for use in site-specific sustainability strategies and mitigation measures, and should be assessed as a residual effect in the absence of mitigation. Disposition:The reviewer is correct in noting that the consideration of Sustainability as presented in Section 6.1 of the EIS is framed in terms of the larger Local and Regional Study Areas. This is necessary to address the EIS Guidelines that require that the EIS address Sustainable Development in a context of Project effects on biological diversity; and the capacity of renewable resources that may be affected by the project to meet the needs of present and future generations (EIS Guidelines s. 2.4). This larger context for considering sustainability, however, is augmented by the discussion of OPG's sustainable development programs in EIS Section 2.10. In response to the review comment, that section has been enhanced with the following text: "The EIS Guidelines require that the proponent consider sustainability of the Project in terms of the extent to which biological diversity may be affected by the Project; and the capacity of renewable resources that are likely to be significantly affected by it. That assessment is presented in Section 6.1 of the EIS. To meet the requirements of the Guidelines, it is framed in a geographical context of the Local and Regional Study Areas. That broader framework is not intended to suggest that sustainability objectives will not be an important consideration also in the Site Study Area, and it is within the site context that operational protocols will be implemented with regard for promoting sustainability at a grass-roots level. OPG as the Project proponent and facility operator will work with other relevant stakeholders to promote sustainable practices throughout the Project. Examples of these practices include: • Compliance with all applicable regulations, standards, codes of practice, and the terms of licences and permits to be issued, and this EA concerning environmental effects management; • Implementation of the environmental management and monitoring programs as referenced in Sections 2.9.1, 2.9.2 and 2.9.3; and m■ • tss ' 60 MORRISON HERSHFIELO Peer Review for Darlington New Nuclear Build RFP 2008-15 /eadiag the Way • Continuation of the Biodiversity Plan currently in place at the Project site as described in Section 2.9.4 EIS Section 6.4 includes a discussion of greenhouse gas (GHG) in terms of its effect on climate change. Project-related emissions of GHG will result from both construction and operating equipment. The construction equipment used will comply with emissions regulations and the operating equipment (emergency generators and auxiliary steam boilers) will be state-of-the-art equipment and also meet emissions regulations. As noted above, the Project programs can be expected to include strategies for GHG emissions. Considering the foregoing, GHG emissions are not identified as an effect of the Project however, and also noted, programs and measures will be incorporated throughout the Project to control these emissions. Comment: The EIS is missing evaluations of degrees of uncertainty for the assessment of effects, as required under the EIS Guidelines. Disposition: EIS Section 3.2.7 (Precautionary Principle) has been edited to include the following text to further address issues of uncertainty in the evaluation: The Guidelines require that the EA consider the Project through application of a "careful and precautionary manner"in order to ensure that it does not cause significant adverse environmental effects. The Guidelines refer to the document "A Framework for the Application of Precaution in Science-based Decision Making About Risk" (NPCC 2003). As indicated in the framework, its purpose is to set out precautionary principles to guide decision-making where there is an absence of full scientific certainty. The EIS and the studies that it represents have been completed with regard for this precautionary principle"such that sufficiently confident decisions can be made to protect society's values and priorities. Key themes relative to this principle and which are carried throughout the EIS include that: • Qualified professionals fully experienced in their fields performed the work within a structured, organized approach; • industry standards and best practices, including peer review of technical programs were applied; I ■ rIF 61 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 leading the WaJ • Uncertainties inherent in the use of computer models were compensated through routine application of conservative Project design assumptions and model input parameters; • The use of bounding conditions for assessment of effects purposes will routinely result in over-estimates of likely effects with associated confidence that the likely effects are lower than those predicted; and The EA program will conclude with a comprehensive follow-up and monitoring program, including adaptive management as a key feature to respond to scientific uncertainty and provide for informed decisions and actives going forward. In addition, EIS Section 3.2.5 (Assessment of Likely Effects) has been edited to include the following: As has been described in preceding pages, in many respects, the assessment of effects was carried out using bounding conditions particularly with respect to the scope and nature of the Project work and activity being evaluated. Scientific uncertainty concerning the extent of potential effects is largely compensated for through the use of bounding conditions that typically reflect the outer range of possible conditions. The degree of uncertainty concerning the prediction of effects has been further reduced through the use of best practices by experienced professionals; incorporation of actual measurement data where available and applicable; use of approved models with a history of application; and the use of peer review throughout all stages of the EA to ensure that the science applied in the assessment was appropriate. A further and key element in reducing the uncertainty of predicted effects concerning the NND Project has been the availability of extensive data and operational experience from DNGS, a fully-functioning nuclear power station within the DN site with almost two decades of operational and environmental performance data. The database of directly-relevant information pertaining to DNGS has provided an important opportunity to benchmark and ground-truth the findings of the NND EA studies. Comment: The EIS guidelines require that any modification to the preliminary recommended Valued Ecosystem Components (VECs) be completed by the proponent following consultation with the public, Aboriginal people, 62 MORRISON HERSHFIELD Q40W.X n ton Peer Review for Darlington New Nuclear Build '/'`��� RFP 2008-15 federal and provincial government departments and relevant stakeholders. All VECs that have been modified from the EIS guidelines should be supported with a fulsome rationale and the details of the required consultations should be discussed. Disposition:Among other improvements made concerning the discussion of VECs, EIS Section 3.2.4 has been edited to include the following in response to the comment: A preliminary list of VECs was included in the EIS Guidelines (the list was unchanged between the draft and final Guidelines) with the direction that it be modified as appropriate by the proponent to consider input received during consultations with the public and other stakeholders. Although not specifically prescribed in the Guidelines but consistent with the selection framework described above, it would also be expected that final VEC selection would reflect actual existing conditions relative to the Project as determined through the baseline characterization studies. The process for selecting VECs began with a detailed comparison of the preliminary VEC list included in the Guidelines to those VECs that have previously been used for other EAs and related programs with relevance to the NND. An important consideration in this respect was the substantial base of experience concerning VEC selection available to drawn from as the starting point for choosing NND-specific VECs. This experience includes recent EAs for the refurbishment and continued operation of PNGS 8, for the used fuel dry storage facilities at both DNGS and PNGS, for the return to service of PNGS A, and the Port Hope and Port Granby Projects (that together form the Port Hope Area Initiative). The VECs and selection rationale for the above programs and the preliminary list in the (draft) EiS Guidelines were considered by the study teams conducting the individual baseline environment characterization program for various environmental components. A candidate VEC list was developed for each component and progressively refined based on the increasing knowledge of the existing environment relevant to the NND, the specific features of the Project(see Chapter 2), and how and the Project and the environmental would be likely to interact. Input to the selection of VECs was solicited from the public and other stakeholders. At Community Information Sessions held in the spring of 2008, OPG presented 22 environmental sub-components and 100 ■ r 63 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 Leading(kr WaJ environmental features representing candidate VECs and VEC indicators as identified through the above process, for public discussion and feedback. The VEC selection program was reviewed with Aboriginal groups and Metis organizations and their input solicited during the Aboriginal Information Sharing Session held in May 2008. The final list of VECs ultimately selected for use in the EA considered all public and stakeholder feedback (as discussed further in Section 10.3.1.3). Additional stakeholder input to the VEC selection program was contained in many of the responses by interested parties to the draft EIS Guidelines that were published for comment by the CNSC and the CEA Agency. More than 30 responses were received and published on the CEA Agency website. All were reviewed by the EA team and those that pertained to VECs were considered in establishing the final list of VECs to be used for the EA. The resolution of all comments received on the draft Guidelines concerning VECs is detailed in the individual sections throughout Chapter 4 where the final VECs are introduced. Comment: Table 11.3-1 does not appear to be complete with respect to all of the required regulatory requirements and, accordingly, there appears to be several monitoring requirements that are missing such as off-site dust migration during site preparation. Disposition: In the reviewed version of the EIS, the noted table did not effectively address its intended purpose. As presented, the table suggested that it tabulated a full list of regulatory requirements that would be invoked by the Project when, in fact, this was not its intended objective. The title of the table has now been changed to "Likely Monitoring Requirements Not Associated with EA Follow-Up"and introductory text added to make it clear that it summarizes a number of on-going monitoring programs not related to the EA follow-up program that will also be carried out, particularly during the implementation phases of the Project These programs will include those that may be required as licence conditions as well as others that may be conducted as aspects of OPG's due diligence. Those programs will complement the follow-up campaign and data will be shared to meet the collective requirements. Comment: We suggest that follow-up program elements should include dispositions on complaint resolutions and remedial works to address non-compliance issues (particularly with third party agreements and regulatory requirements), ineffective mitigation and/or unpredicted effects. Assumptions surrounding cumulative effects should be subject to follow- I 64 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build Q RFP 2008-75 isd tAe Way up monitoring of predicted results and remedial mitigation developed is necessary. Disposition: Introductory text has been added to Section 11 to clarify that the follow-up program is also intended to confirm that mitigation measures have been implemented and are being effective. As was already noted in the section, a related objective of the program is to confirm on an on-going basis, whether assumptions made during the EA remain accurate. Although not stated specifically, this would include assumptions made relating to cumulative effects as well. In addition, a discussion concerning Adaptive Management as relevant to follow-up monitoring will be applied. Specifically, adaptive management will be inherent in the design and implementation of the EA follow-up and monitoring (and related) programs. Prior to its implementation, the plan will be refined and designed in detail, with this design incorporating principles of adaptive management. Adaptive management will subsequently become a fundamental aspect of its implementation to ensure that the monitoring elements remain valid, appropriately encompassing, and responsive to the objectives, including as their focus may evolve over time. The monitoring programs themselves will be routinely re-evaluated and their scopes adjusted to consider such aspects as changing site conditions, or the need to re-focus on specific operational or environmental issues of uncertainty or concern. Finally, a section has been added in Section 11 that describes how the follow-up monitoring data will be managed and disseminated. Because follow-up monitoring is an integral element of the EA, all monitoring data will be provided to the RAs and other FAs that they may choose to designate. The final distribution of monitoring data will be determined in conjunction with finalization of the program itself, however, it is also likely that some aspects of monitoring information will also be provided to other stakeholders as appropriate. Although the form and frequency of the reporting will be determined as the program is finalized, it is reasonable to anticipate that the data will be assembled into a formal monitoring report and submitted on a regular basis. As has been noted, many of the follow- up program elements are likely to be merged with related monitoring programs so it will be likely that data collected during the program will also be distributed to other parties and agencies, based on the requirements of those programs. Morrison Hershfield believes that the issues have been fully dispositioned and that they are considered closed. rr__ r 65 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 LeaAing lbe Way 6.0 BENEFITS OF THE PROJECT A number of anticipated beneficial effects of the Project are likely to be realized during the life of the project. The Project will or is likely to: • Contribute to the maintenance of the social structure and stability of LSA communities and selected municipalities across the RSA; and serve as a positive contributor to the anticipated population growth in these areas because of the increased proportion of the population associated with it; • Create new apprenticeship opportunities that will generate a substantial number of new certified trades people available for the Project itself and/or Ontario's construction labour market subsequently; • Serve to maintain the skilled employment base of the energy sector throughout the RSA and LSA in the short term and contribute to the expansion of the skills base over the long term; • Be a catalyst for increased enrolment in post secondary educational programs that provide energy or nuclear related degrees or certificates and other training programs that support certification in a skilled trade; • Be a catalyst for increased local and regional economic development during each of its phases, and for further development of the Durham Energy Industry Cluster and the Clarington Energy Centre through the likely establishment of new business operations in the RSA that are involved in the nuclear service industry; • Create new direct, indirect and induced employment opportunities for existing and potential in-movers to the RSA and LSA and positively influence employment growth in these municipalities; • Create new business activity and opportunities due to increased spending associated with Project employment, and expenditures on goods and services; • Improve economic viability and increase investment in tourist accommodation businesses (i.e., hotels and motels) resulting in improved stock of tourist accommodations in the LSA; • Contribute to increased total household income throughout the RSA and LSA; • Contribute to increased rate of growth in property values and increased sales volumes in the LSA municipalities; • Increase municipal tax and other revenues; • Serve as a catalyst for the initiation of new housing developments in the Municipality of Clarington, the provincially-identified growth centres of the Cities of Pickering and Oshawa, and other communities within Durham Region; and • Promote diversification of the housing stock in the Municipality of Clarington. I 66 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build RFP 2008-15 rroe:�g u:wok 7.0 PEER REVIEW RECOMMENDATIONS Based on the findings of the Host Community Peer Review, Morrison Hershfield has identified several issues that we recommend the Municipality of Clarington remain mindful of as the Project progresses through subsequent phases. 1. The full range of potential impacts to the Municipality of Clarington from transportation and traffic effects associated with the Project will continue to unfold as OPG gains additional insight into the selected Vendor's proposed construction strategies and methodologies. It is recommended that the Municipality of Clarington continue to work with OPG to identify any additional transportation and traffic impacts and develop appropriate mitigation measures where warranted. 2. The potential impacts to the Municipality of Clarington from socio-economic and municipal finance effects associated with the Project, as identified in the EIS, may change as OPG carries out follow-up monitoring to assess the predicted effects. It is recommended that the Municipality of Clarington continue to work with OPG to identify any changes in the predicted socio-economic and municipal finance effects, and that OPG, in consultation with the Municipality of Clarington, develops appropriate mitigation measures where warranted. 3. As the environmental assessment for the Project was completed under a bounding scenario due to the Vendor not having been selected by the Ontario Government, OPG and the selected Vendor will continue to develop site-specific details on the Project during the licensing phases for Site Preparation, Construction and Operation of the Project. It is recommended that the Municipality of Clarington continue to work with OPG to review the development of site-specific design details to ensure that any new or additional impacts to the Municipality of Clarington are identified and appropriate mitigation measures are developed. 4. OPG has made a strong commitment to conduct follow-up monitoring to assess the predicted effects of the Project, as it relates to the natural, social, and cultural environments, and the sufficiency of the applied mitigation measures. It is recommended that the Municipality of Clarington continue to work with OPG to help to develop the follow-up monitoring programs and provide input into OPG's Adaptive Environmental Management Strategy to cooperatively develop and ensure that the mitigation of impacts to the Municipality of Clarington remains responsive and effective. 5. Only the Project benefits, enumerated in Section 5, that directly relate to the Municipality of Clarington, such as property-based or operational municipal taxes and development charges, are certain. The Municipality of Clarington will be in competition for benefits such as employment opportunities, business ■ f 67 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build �( ■I/ZL7(,(�(j RFP 2008-15 r.�em8 rae wer development, economic growth of local businesses, and residential growth. It is recommended that the Municipality of Clarington continue to work with OPG to identify opportunities for additional direct benefits of the Project to accrue to the Municipality of Clarington. It is also recommended that the Municipality of Clarington develop an internal strategy to maximize the opportunities to realize these additional benefits. 6. Subject to the commitments to future work on the part of OPG as identified in the EIS and subject to the recommendations for the continued monitoring of the predicted effects and the review of new, detailed Project information as it is developed by OPG and its selected Vendor, Morrison Hershfield is satisfied that the EIS for the Project was completed professionally and with a great effort to identify concerns to the Municipality of Clarington, communicate and consult with the Municipality of Clarington and to plan with an overall goal of minimizing, to the extent possible given the requirements of the Project, the impact on the environment. •" 68 MORRISON HERSHFIELD Peer Review for Darlington New Nuclear Build (�(�w RFP 2008-15 i Leading+he Wad 8.0 LIMITATION OF REPORT This report has been prepared pursuant to a contract with the Municipality of Clarington and is for the sole use of the Municipality of Clarington for the sole purpose of conducting a peer review of the environmental assessment study for the development of the Project by the Ontario Government to identify potential impacts to the Municipality of Clarington and to conduct an analysis of the sufficiency of the measures proposed to mitigate potential impacts to the Municipality of Clarington. Morrison Hershfield Limited, its servants, employees, officers, or agents accepts no responsibility to any person or entity other than the Municipality of Clarington in connection with this report. Morrison Hershfield Limited has conducted this peer review of the environmental assessment study for the development of the Project using documentation of the date and version provided by Ontario Power Generation and/or its consultants. Morrison Hershfield Limited, its servants, employees, officers, or agents accepts no responsibility to any person or entity for information, documented or otherwise, developed by Ontario Power Generation and/or its consultants that differs in date or version from the documentation provided, for documentation not provided to Morrison Hershfield Limited, or for documentation provided but not reviewed by Morrison Hershfield Limited under the terms of reference for this contract. Morrison Hershfield Limited, its servants, employees, officers, or agents accepts no responsibility to any person or entity for the use of this report in conjunction with any other process including but not limited to any review, negotiation, agreement, endorsement or approval, that Morrison Hershfield Limited has not participated in fully and received full disclosure. W 69 MORRISON HERSHFIELD I Qa0 �i}�� Peer Review for Darlington New Nuclear Build ,1.119to RFP 2008-15 d,As:n.wos 9.0 CLOSING Morrison Hershfield has appreciated the opportunity to be able to complete this peer review of the draft EIS and Technical Support Documents on the New Nuclear Darlington project on behalf of the Municipality of Clarington, which has benefitted both the Municipality of Clarington and OPG in preparing a complete and comprehensive environmental assessment. In our opinion, the EIS was done very well and, as the formal comments and dispositions demonstrate, OPG has gained additional insight from the thorough review undertaken by the Municipality of Clarington and Morrison Hershfield. The EIS has benefited from the additional insights and detailed analysis provided through this process, as evidenced by the many revisions and additions to the documents reviewed. The peer review process between the Morrison Hershfield peer review team, the Municipality of Clarington and OPG was transparent throughout and the results achieved are a testament to the professional and collegial approach exhibited by all involved. Morrison Hershfield completed the full scope of the peer review within the targeted schedule and within the limits of the agreed budget. Accordingly, and subject to the limitations of the peer review and the recommendations contained herein, the Host Community Peer Review, conducted by Morrison Hershfield Limited on behalf of the Municipality of Clarington of the environmental assessment undertaken by OPG for the Project, is closed. Respectfully submitted on June 26, 2009 by; ?C-4 - - Paul Draycott, Esq., CCEP Project Manager- Host Community Peer Review Director of Environmental Services and General Counsel Morrison Hershfield Limited m 70 MORRISON HERSHFIELO APPENDIX 1 FORMAL PEER VIEW COMMENTS AND OPG DISPOSITION CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REVIEW DOCUNIENT lXwFVPTioN Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-495.4304 Reviewer's Organization Mordson Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: New Turn t (Drawing Document t OOrI orae REvIEWER'S CommENTVAUTHOR'S DISPOSITION DISPOSMON BY AuniOR AND page,Paragraph number, REv1EWER ate. 1 Ecological Risk CurrenNy Mere is no commihnent to conduct follow-up monitoring for non-human biota with respect to / Assessment— the ecological risk assessment. We suggest that follow-up monitoring should be conducted for non- Aed by Reviewer Environmental Impact human biota to confirm predicted results and to identity remedial mitigation measures where changes Statement Table 11.32 In predicted results are evidenced. es ❑No Disposition: OPG agrees that a monitoring program should be developed to confirm predicted EA results. The Ecological Risk Assessment TSD concluded that no residua) effects on non-human biota were expected as the result of the New Nuclear at Darlington (NND)project. Since GSA N288.4 Standard for Environmental Monitoring at Class f Nuclear Facildies'is currently under development by industry and the regulator (CNSC). OPG anticipates the standard will apply to the NND project. N298.4. previously known as the 'Guidelines for Radionuclides Monitoring in the Environment", was used to form the basic design for the Radiological Environmental Monitoring Program(REMP)that is currently being conducted at the Darlington Nuclear Generating Station. The new standard will require an Environmental Risk Assessment (ERA) to be performed for the NND facility to provide the basis for developing an Environmental Mondodng Program (EMP). The ERA will include both risks to humans and non-human blots from radiological and non-radiological constituents,and other stressors. Routine review and updating of the ERA is expected. As the reviewer indicated, if substantive changes (e.g. emissions, contaminants, etc) are Identified, this program will serve as a means of monitoring the predicted ERA conclusions. Assessments of the EMP which Includes the REMP will result in measures to rectify concerns as necessary. As future changes to the regulatory requirements and guidance are anticipated, the suggested follow-up monitoring will be included in the development of the EMP for the NND facility. 2 Transportatlon Existing The transportation effects analysis did not assess the traffic impacts to the Municipality of Clarington Conditions and Effects from truck traffic.resulting from off-site excess soil haulage or haulage of cofferdam and other 1 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REviEw DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone i extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Umded—Host Community(Municipality of Cladngton)Peer Review Sections Reviewed: Document Title: Ram# Document o-ordi Locatim al REVIEWER'S COMMENTSIAUTHOR'S DISPOSITION DlsposmON By AUTHOR AND (Drawing co-ordkietaa, page,paragraph number, REVIEWER etc. Assessment Technical materials to the New Nuclear Darlington site except for Halt Road. We suggest that a mare fulsome Acc ted by Reviewer Support Document(TSD) analysis of municipal road impacts from these sources needs to be completed to adequately identify Yes ❑No —General Comment with and quantify the impacts. Mitigation will need to be reviewed following the additional analysis. We no specific page reference suggest that follow-up monitoring should be conducted for transportation and traffic effects to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. Disposition: This comment and the following Comment#3 are considered to be related issues.The disposition of both Comments 2 and 3 can be found in the Comment#3 Disposition. 3 Transportation Existing The traffic operations analysis for both existing conditlons and effects assessment was done at an Conditions and Effects individual unit level for various selected intersections within a designated area. We suggest that this Accq0ted by Reviewer Assessment TSDs— level of analysis is insufficient to adequately identify the potential traffic and transportation impacts to rtr General Comment with no the Municipality of Clarirglon and that a more fulsome network-style analysis, or equivalent level of Yes ❑No specific page reference effort,needs to be completed within a broader area of study. The area bounded by Regional Road 57, Courtice Road and Taunton Road is suggested.. Link levels of service should be accounted for. Mitigation will need to be reviewed following the additional analysis. We suggest that follow-up monitoring should be conducted for transportation and traffic effects to confirm predicted results and to identify remedial mitigation measures where charges in predicted results are evidenced. Disposition: OPG conducted the Transportation and Traffic assessment within a study area considered to be appropriate for the size and scope of the project. Nevertheless, both reviewer's Comments 2 and 3 suggest that the detailed study area chosen for the New Nuclear at Darlington project was not large enough to allow detailed conclusions to be drawn to adequately identify and quantify the impacts on the municipal roads. The original study area for the New Nuclear Darii on Environmental Assessment was comprised of the road network bounded by 2of41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW Doet�uPxT D6scslPn m Reviewer's Name Paul Drayc tt—Project Manager Telephone/extension Date:May 22,2009 416-PeerR04 ReVleWer's-Organization Morr son Hershfield—Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: tlem If Document o-ardmn REVIEWER'S COMMENTSIAUTNOR'S DISPOSITION DISPOSITION BY AUTHOR AND (Drug co-ordlname. Page,Paragraph nurnbor, REVIEWER W4 Counice Road (west), Baseline Road (north) and Regional Road 57 (east). The Existing Conditions and Effects TSDs were written based upon analysis conducted within this boundary. In discussions with the Municipality of Cladngton.OPG agreed to conduct additional traffic studies in a larger or enhanced study area,to compliment the original studies performed.The larger study area will be bounded by Courtice Road(west), Highway 2(north), Regional Road 57 (east)and lake Ontario (south). The same work and analyses will be conducted in this enhanced study area that was conducted in the original study area.This additional work in the enhanced study area will assess the existing transportation infrastructure network, klentify impacts from any future developments and outline any improvements to be implemented on the road network. The conclusions resulting from the analysis in the enhanced study area will be compared with those from the original study area (as described in the Existing Conditions and Effects TSD, and EIS). Any changes to the original conclusions will be identified and additional mitigation measures developed. This work is expected to be completed prior to the EA submission to Joint Review Panel Although specific details in regards to soil haulage routes and material delivery is not accurately known at this time, once a vendor is selected for this project, offsite soil storage locations and suppliers of material for the project will be identified.At that fime detailed analysis of the different traffic routes can be undertaken. The Effects TSD describes the soil haulage scenario as the bounding condition being within 25km of the NND site. Mitigation measures are provided in the EIS (Table 5.15-1) includes development of a Traffic Management Plan.This Traffic Management Plan will be derived through collaboration with OPG,the Municipality of Clarington and the Region of Durham. The Traffic Management Plan will assist in identifying transportation system deficiencies. Regular discussions will be held to maintain the status of any issues that arise and identity new issues. The Traffic Management Plan will be used to deal with issues such as the soil haulage and material delivery concerns,when mores cific information is 3of41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW 09PC14!ENT DESCRIPTION Reviewer's Name Paul Draycott-Project Manager Telephone extension Date:May 22,2009 416-4954304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Kwnm i. Document Location REVIEWER'S COMMENTs/AUTHOR'S DISPOSITION DISPosmoN syy AUTHOR AND ra (Dwing coordinates, RFvIEWER page,paragraph number, etc. known. 4 Hydrogeological Effects Dewatedng drawdown within the 1200 metre zone of influence was modelled. We suggest that the Assessment TSD— model is extremely sensitive to the input hydraulic properties and a more conservative(higher)value Acted by Reviewer General Comment with no for soil permeability(i.e.the hydraulic conductivity K value)should be used to ensure that there will be Yes 0 No specific page reference no drawdown effects within the zone of influence,particularly for any potable water supplies within the zone. We suggest that follow-up monitoring should be conducted for drawdown effects within the zone of influence to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced- Disposition: OPG is satisfied that the reviewer accepted the majority of the work with one exception. The reviewer has raised concerns with respect to the validity of the model to predict affects to well water users at the extremity of the zone where the water table may drop in elevation due to dewatering operations at the NND Project. OPG agrees that the model is sensitive to input parameters such as the hydraulic conductivity,among others. However, OPG believes that the model contains sufficient conservative elements and reflects the existing conditions. The groundwater flow model has been developed using representative hydraulic properties for the aquifer and aquitards that make up the groundwater flow system for the area. During construction of the model, the hydraulic conductivity of Me model layers have been adjusted to best match the existing water level data for the site, the stream flow in the area (i.e. Dadington Creek and other surface waters)and the recharge for the surface soils. The model is considered to be well calibrated because it represents the key elements of the physical system within a local context, the parameter values used in the model are within physically realistic ranges similar to values measured at the DN 4of41 FEocel:t LARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT itle: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final tal Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOQUMENP DESCRIPTION ame Paul Draycolt-Project Manager Telephone/exten sion Date:May 22,2009 416.495-4304 rganization Morrison Hershfield Limited -Host Community(Municipality of Clarington)Peer Review viewed: Document Title: ( t LO�"ate REVIEWER'S COMMENTS/AuTHOR'S DISPOSITION DISPOSITION By AUTHOR ANO Page,paragraph number, REVIEWER etc. site,and the model provides an acceptable match to observed data on both local and site scales. The predicted drawdown of approximately 1,200 m resulting from dewatering was evaluated using the groundwater flow model. There are several lines of evidence supporting the limited extent of drawdown resulting from dewatering. Comparisons between pre-and post-construction water levels for the DNGS indicate that the drawdown resulting from construction extends to distances on the order of 600 to 800 m. Similarly,the observed drawdown associated with the St.Marys quarry is isolated to the area immediately adjacent to the quarry (less than 500 m) (Golder, 2004). Field measurements during the pumping test indicate a low aquifer transmissivity(a measure of how much water can be transmitted horizontally),which will result in a tight,narrow drawdown cone. Given these comparisons to actual field measurements, the area of influence of the drawdown as depicted by the model simulations are considered to be reasonable representations of the drawdown that may occur due to dewatering. The nearest domestic wells are located at distances of about 1.5 km from the approximate edge of the excavation for the dewatering. Therefore,the domestic wells are at the outer range of the drawdown cone and will experience the least amount of drawdown within the area of influence. For the dewatering work, the suggested follow-up monitoring will be included because OPG will need to obtain regulatory approvals that usually contain monitoring requirements to measure the extent of drawdown and to confirm predictions within the zone of influence. Pre and post dewatering monitoring will assist in assessing whether any adverse effects that may result from the dewatering work at the NND Proiect occurred and mitigated as necessary. 5 Accidents and The analysis of predicted construction.injuries has been compared to any other construction project � Malfunctions Effects TSD which does not appear to adequately quantify or qualify the construction accidents that will be likely ccetRed by Reviewer Table 3.6-1 and Generally realized during the construction of the New Nuclear Darlington site, in both terms of numbers (type I..L�.IY: and severity including fatalities) and duration (constructon years). This more fulsome analysis of as 0 No I.accidents needs to feed into the broader discussion on Socio-Economic, Human Health and the 5of41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) PREVIEW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone I extension Date: May 22,2009 416-495-4904 Reviewer's Organization Morrison Hershfield UmhGd-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document rite: aaa Item a (Drawing" "t��� REv1EWER'S COMMENTSIMTHOR'S DISPOSITION DtSPOsmoN ev Au7HoR AND page,paragraph number, REviEWER arc. challenges that Clarington currently faces, and will face in the future, in providing emergency medical services. Disposition: The reviewer's concern that the comparison of accidents was not adequately addressed with respect to quantifying or qualifying construction accidents has been elaborated on in the TSD and EIS. The discussion of accidents resulting in personnel injuries has been expanded and clarified in the Malfunctions, Accidents and Malevolent Acts Technical Support Document (TSD) and the EIS. Clarification was provided that the rates of injury for employees working on the construction of NND facilities is expected to be equal to or less than those at other construction sites for jobs of similar duration and complexity in Ontario. The three primary categories of construction-related injuries at Ontario construction sites are injuries due to falling, from falling objects, and from electrical hazards. These are the same primary categories of injury to construction workers employed by OPG. This provides additional confidence in comparing the potential injury rates (see below)between NND construction work and other Ontario construction worksites. Historically, injury rates at OPG facilities compare favourably with those reported for construction work in Ontario. In response to the reviewer's comment, statistics have been added to the TSD and the EIS, and a comparison has been made between the All Injury Rate(AIR)for(a)all work in the construction industry in Ontario(data from the Construction Safety Association of Ontario (CSAO)),(b)all work done by contractors employed by OPG(where OPG is the constructor),and (c) all work done by OPG employees. In 2007,these numbers were 6.64,2.08 and 1.12 injuries per 200,000 hours worked, respectively. (It is noted in the TSD that the definitions of AIR used by OPG and CSAO differ slightly, but the numbers are still able to be compared for the purpose of trendin In addition, in 2007 in Ontario there were 1.96 lost time injuries per 200,000 hours 6of41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager I Telephone/extension Date:May 22,2009 416-495.4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: nB1p (Drawing�ayr �aaaaaaa REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DIsPoSmoN BY AUTHOR AND pegs,paragraph number, REVIEWER Mc. worked in the construction industry. In this same time period. there were no lost time injuries to construction workers employed by OPG. The comparison of these statistics demonstrates that OPG workplaces are generally safe workplaces, and reflects the importance that OPG places on safe work. The OPG contractor will be required to prepare a Site Specific Safety Plan that OPG will audit to ensure compliance with Health and Safety requirements in the NND Project Agreement with the contractor. OPG understands emergency medical services(EMS)are provided by the Region.Nevertheless, during the site preparation and construction phase of the NND Project,ft is anticipated that the vendor will provide EMS on the site to address triage incidents. Funding for EMS service off site would be collected through existing fiscal mechanisms(i.e.,property taxes).OPG will Include additional information on EMS in the Socio-Economic Assessment of Environmental Effects TSD to further address. 6 Emergency Preparedness The analysis of emergency preparedness was well done and demonstrates that this project can be TSD—General Comment completed with more than adequate emergency preparedness and planning during all phases. We Ac ted by Reviewer suggest that,notwithstanding there would be a negligible change in the final results,the model used to Ves No determine evacuation time should include a consideration for night traffic which results in an inherent reduction in capacity on its own. 7of41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REviEw DOGUMEw DEscRoMoN Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-4954304 Reviewer's Organization Morison Hershfield limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Item (D�rewi�oaordUetes, REVIEWER'S COMMENfs/AUTHoR'S DISPOSITION DlsPosmoN By AUTHOR AND page,paragraph number, REVIEWER etc- Disoositiow Although the reviewer acknowledged that this TSD was well done,a suggestion to Include evacuation time for night traffic was made. It is difficult to quantify the capacity reduction of a highway section due to night operating conditions since peak traffic flows rarely occur during darkness. However, night fine traffic flows in the vicinity of highway work zones can best approximate the capacity reduction posted in the comment. A search for data yielded the study referenced below(based upon freeway work zones in Ontario). The study reported on a capacity reduction of around 7% during off-peak hours due to lighting condition (Day versus Night). The investigation included the effect of darkness on freeway traffic capacity through work zones on urban freeways. 'This paper reports findings from recent investigations into freeway capacity at several reconstruction zones in Ontario, Canada. The aim is to provide guidelines for estimating freeway capacity at reconstruction sites. Findings are presented in two parts. The first involved results of individual investigations to estimate a base capacity at freeway reconstruction sites and the individual effect of several important factors that are believed to affect this rapacity,namely;the effect of heavy vehicles, driver population,rain,site configuration,work activity at site,and light condition..." As part of our analysis,we estimated that rainy weather conditions would reduce highway capacity by 10 percent. Since the estimate of night time capacity reduction cited in the referenced paper is 7 percent, we believe that our adverse weather ETE estimates can be used to approximate the ETE values for night time evacuation conditions. No further analysis is warranted for EA purposes. Reference: "Guidelines for Estimating Capacity at Freeway Reconstruction Zones", Journal of Transportation Engineering,Volume 129, Issue 5,pp 572-577.September/October 2003. 8 of41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Rt 1/ItEW DQRUfA NJ!7 :r�41i TIReviewer's Name Paul Draycott-Project Manager ephone extension Date:May 22,2009 ass a 04 Reviewer's Organization Morrison Hershfield Umted—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Kwn i ��Loc on REv1EWER'S COMMENTS/AUTHOR'S DISposir ioN DISPOSTON 6Y AuTHoR ANo f g ti page,paragraph number, REVIEWER etc. 7 Physical and Cultural The analysis of existing cultural heritage resources was completed within the site study area only. We Heritage Resources TSD suggest that a more conservative boundary of 500 metres should be used to document existing Acc ted by Reviewer --Section 2.2.3.1 conditions and determine potential effects. Yes C]No Disposition: The reviewer accepted the assessment,but suggested an improvement to increase the assessment of the Site Study area by 500 m to ensure conservatism. As added benefit to the work completed for the Site Study area,OPG agrees to extend its documentation of existing cultural heritage resources,i.e.built heritage features and cultural landscapes,by 500 metres beyond the Site Study Area. This work was completed in May 2009 and will be reported in a TSD. 8 Physical and Cultural Assumptions concerning the Burk Cemetery remain indeterminate. We concur with the need for Heritage Resources TSD additional research into this site to determine whether interred remains exist so that the proper Ac led by Reviewer —Section 3.2.2.1 mitigation can be developed, In the Interim,we suggest that a very conservative zone of no disturbance be established for planning purposes. Yes No 9of41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW I,?QCUMENI"DE9CRIPliQal Reviewer's Name Paul Draycott-Project Manager Telephone/extens on Date:May 22,2009 416.495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: RBm,a Document Location REVIEWER'S CommENTs/AuTHOR'S DisposrnoN OfsPosmoN ay AUTHOR AND (Drawing co-ordlnatee, REVIEWER Page,paragraph number, etc. Disposition: The initial scope of the project included the removal of the Burk Pioneer Cemetery as it was thought that only the monument needed to be re-located.However,as the EA progressed,new findings increased the uncertainty regarding the possibility that internments may be present.As a result,the removal of the Burk Pioneer Cemetery was withdrawn from the scope of the NND Project. Nevertheless, OPG has completed loth archival and genealogical research relating to the Burk Pioneer Cemetery. While members of the John Burk Jr.(ca 1786-1832)family were burled there(at least eleven interments are present),there are no records or transcripts indicating that any of the bodies have been transferred to another local cemetery. OPG will develop a long-tern plan to protect the Burk Cemetery by including a buffer zone of 60 m around the known boundary of the cemetery to ensure its conservation. 9 Aquatic Environment Darlington Creek lies within the site study area and under the bounding scenario a crossing of the Existing Conditions and main channel is considered. The characterization of the existing conditions for this watercourse within Acc tad by Reviewer Effects TSDs—Section the site study area relies solely on dated secondary source information that did not assess the Yes ❑No 3.1.1 watercourse within the site study area for critical or sensitive aquatic habitat. We suggest a more current,site-specific study is required to adequately characterize the existing aquatic conditions for Darlington Creek on the site and to property develop site-specific mitigation. 10 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REv1EW AQCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone!extens on Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review - Sections Reviewed: Document Title: Lfnrt Document Location REVIEWER'S COMMENTS/AuTHoR'S DISPOSITION DiSPosmoN By AUTHOR AND (Drawing cooMinates, REVIEWER page,paraWaph number, etc. Dismitiom Based on an eadier draft of the Aquatic Environment Existing Conditions TSD,the reviewer identified that the small portion of Dadington Creek which crosses the NND Project site could benefit from an updated assessment.Considering the work completed to assess the aquatic environment across the site and in the lake,this suggestion was considered to be incremental,but important. - OPG also identified the need to assess the upper reaches of Dadington creek. A detailed habitat assessment of the upper reaches has been initiated by OPG.The results of this assessment will be added to the findings of the previous assessment of the lower reaches and reported in the TSD and EIS. 10 Aquatic Environment We concur with the findings of the Aquatic Environment Existing Conditions and Effects Assessment in Existing Conditions and that the fish habitat within the area of Lake Ontario proposed for infiil is of marginal quality due to the Acc tad by Reviewer Effects TSDs—General high-energy environment along the lakeshore. We concur that the loss of fish habitat associated with Yes ❑No Comment the proposed lake infiil,notwithstanding the immense area of habitat that will be lost,is not significant in the context of the amount of similar habitat available in Lake Ontario. We further concur that impacts and effects to fish habitat can be mitigated to the extent feasible and compensated for where mitigation is insufficient. The Municipality desires that all fisheries compensation strategies be prioritized for and implemented within local Municipal watersheds or within the Municipal boundaries of Lake Ontario. 11 of 41 CLARINGTON MUNICIPAL PEER REVIEW -- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) RmEw-PinumENT OF ON Reviewer's Name Paul Draycoft—Project Manager Telephone/extension Date:May 22,2009 altar Reviewer's OrgeMzatlOn Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Peer Review Sections Reviewed: Document Title: ' (Drawing Ineo ord atti, REVIEWER'S COMMENTs/AuTHOR's DISPOSITION DISPOSri10N sY AUTHOR AND page.paragraph number, REVIEWER etc. Disposition: OPG is pleased that the reviewer concurs with the assessments. OPG expects some sort of fisheries compensation will occur with regulatory agencies as a result of habitat loss associated with the proposed lake infill and other in-water works.In negotiating the habitat compensation plan with the regulatory agencies,OPG will propose that compensation strategies be given priority to local municipal watersheds or within the municipal boundaries of Lake Ontario where practicable.However,the contents of the habitat compensation will likely be made by the DFO in collaboration with the MNR and other groups such as CLOCA which is beyond the control of OPG. t 1 Atmospheric Environment The Air Dispersion Model produced inconsistent results,particularly for upwind concentrations and Existing Conditions TSD— background levels. Contributions for roadway and on-site sources appear to be understated. The Acc ted by Reviewer Section 4.2.4.2 result is that the effects analysis de-emphasizes the difference between Me build and no-build Yes ❑No scenarios and understates the attainment status of some receptors. We suggest that the modelling approach be reviewed and a validation exercise be performed. Instances of where local monitoring data differs from modelled data should be identified. Disposition: OPG has reviewed the modelling approach as suggested. The regulatory air dispersion model for existing facilities in Ontario is the O. Reg.346 dispersion model.This model is the current regulatory model for the existing plant at Darlington.The Ontario Ministry of the Environment(MOE)implemented a new regulation in November 2005.Ontario Regulation 419/05:Air Pollution—Local Air Quality(O. Reg.419)replaces O.Reg 346.MOE is using a phased approach for implementation the new regulation,with new facilities,such as NND,required to comply with O. Reg.419.The new O.Reg. 419 sets out new and updated effects based air standards and applies new Air dispersion models.The existing Darlington site is not required to update the model until 2020.The model preferred for use by the MOE is AERMOD. 12 of 41 CAALINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REVIEW POCUNIENT DESCRIPTION Reviewer's Name 1 Paul Draycott-Project Manager Telephone/extension Date:May 22,2009 Reviewer's Organization Morrison Hershfield Limited 416-495-4304 -Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: tiaras g t�(mew Mat es, REVIEWER'S C.OMMENTs/AuT110R'S DISPOSITION DISPOSITION BY AUTHOR AND pat0.pa's~number, REVIEWER ate. AERMOD is the model used to assess air quality ettects associated with the Project.In order to have a baseline condition against which to assess the effects,the existing conditions were also modeled with AERMOD to allow a common basis against which to identity a change in the environment. AERMOD was used for the atmospheric dispersion modeling of the emissions from DNGS.AERMOD is a steady state Gaussian Plume model that provides options to model emissions from a wide range of sources. Dispersion modeling was conducted to determine the contribution of the emission sources to the local air quality.The model predictions were used in conjunction with the monitoring data to determine the appropriate contribution from upwind sources to add to the model predictions to determine the air quality concentrations as specific receptor locations. Various other emission and dispersion models were used,in addition to AERMOD,in the Air dispersion modeling work from this project.These included Mobile6.2C,CAL34HC,O.Reg.346. Review of the modelling results has also been accepted as a useful verification step to take prior to finalizing the EIS. As a component of this review a validation exercise will be undertaken to illustrate for the roadways adjacent to the DN site,whether the AERMOD calculations agree with the CAL30HC results for the same sources. At the same time,a confirmation of the appropriate upwind background concentrations will be completed and any gaps will be Identified and the appropriate documentation revisions or studies will be performed. The conclusions of the assessment are not expected to change as a result of this work. 13 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott- Project ManagerTelephone'a 4 ension Date:May 22,2009 416.495-4304 Reviewer's Organization Morrison Hershfield Umfted-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Item t Document Locatlon REvIEWER'S COMMENTS/AtrrmOR'S DISPOSITION - DISPOSITION ey AuTHOR AND (Drawing co-ordinates, REVIEWER page,paragraph number, etc. 72 Atmospheric Environment Notwithstanding the New Nuclear Darlington project will be operated as a separate facility from the Existing Conditions TSD- existing Darlington Nuclear Generating Station,the cumulative noise impacts of the existing operations Ac pted by Reviewer Section 2.2.3.2 and and the proposed new operations should be considered together for the purposes of establishing a yes ❑No Effects Assessment TSD baseline for comparison. Noise mitigation must be applied whenever there is an excess of the —Table 3.2-2 established limit(not optional)and the effects assessment in Table 3.2-2 should be reviewed with this requirement in mind. Please review the Health Canada criteria on noise impacts from transportation sources to ensure that current criteria are used. Disposition: The NND site is considered to be a completely separate operation from the existing operation- existing conditions include the existing site. Sound levels from the DN site were assessed using both provincial and federal guidance. The provincial guidance document,NPC-205(MOE, 1995b) establishes ttre sound level limits for stationary sources such as industrial and commercial establishments or ancillary transportation facilities affecting points of reception in Class 1 and 2 Areas (Urban). Potential impacts from the project,from sources such as construction equipment,are outside the scope of NPC 205.In light of this,more general criteria were sought for assessment of all project related noise sources(increase In local traffic,construction,NND operations). Federal guidance (Health Canada, 1989)and provincial land use guidance(LU 131 MOE 1997)were reviewed,as each provides a magnitude of relative sound level above background.Health Canada Is currently in the process of developing a national guideline approach for examining potential environmental noise impacts for projects under the Canadian Environmental Assessment Act. However,these guidelines are in draft form and under considerable revision. Health Canada was contacted directly to request the draft version;however,they would not issue its release. While it is recognized that these are intended for application in transportation projects.these were adopted as indicators of potential noise effects for this Project on the basis that noise is a nuisance effect whether it be from transportation sources or otherwise,and the relative magnitude of the incremental increase(if any)should be applicable.Section 2.2.3 of the Baseline TSD has since been revised to include the above discussion 14 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REv1EW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott— Project Manager Telephone/extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Item# Document REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DISPOSITION ev AUTHOR AND(Drawing a et« pegs,paragraph number, REVIEWER etc. and indicate that the NPC.205 limbs have been adopted.These limits were adopted not to confirm compliance but rather as an Indicator of potential effects of the project. Section 5(Noise Assessment)of the Baseline TSD has also been significantly revised.The section provides a summary review of the municipal,provincial and federal noise guidance documents considered in establishing assessment criteria. From the review the MOE guidance NPC-205(MOE 1995b)for stationary sources appeared to be the most applicable for this assessment. However NPC- 205 scope excludes construction activities which will contribute to the potential effects of the project.A review of other guidance documents provided a suitable means to assess the impact of all sources of noise. As discussed above,the assessment of the noise impact of the NND was performed per the criteria of MOE NPC 205 even though the guidance only applies 10 stationary sources of noise and construction noise is excluded in NPC 205. The Effects TSD Tables 3.2.2 and 3.2-3 have been revised to summarize the significance of incremental Increases in noise levels according to provincial and federal guidance(MOE 1997 and Health Canada 1989,respectively). Again,they typically apply to transportation projects,not industrial noise source assessments.However it was determined that in the absence of noise criteria values for all aspects of the project,these indicators were deemed to be relevant for the project. 15 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REVIEIIY UMENT D SCRIP.TION Reviewer's Name Paul Draycott—Project Manager Telephone i extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield limited-Host Community(Municipality of Cladngton)Peer Review Sections Reviewed: Document Title: Tarn# (Drawing Document �M, REVIEWER'S COMMENTS/AUTHOR's DiSPOSIT oN DIsPOsmON BY AuTHOR AND Patter Para~ntanbw, REVIEWER etc. 73 Terrestrial Environment The loss of the Bank Swallow colony within the site study area represents a large percentage of the Existing Conditions and available shoreline habitat for this species within the local study area and the Municipality. The effects Acc ed by Reviewer Effects TSDs—General assessment has rationalized that there will be no residual effect from this loss as the effect is limited to Yes ❑No Concern the site study area. The site study area for this TSD was modified to include a piece of property,not belonging to the New Nuclear Darlington site. The mitigation proposed only is partially directed to the actual loss of the bank swallow colony on the site study area(artificial nesting habitat). We suggest that a more fulsome explanation is required to rationalize the change in site study area for this technical discipline and to explain how the proposed mitigation deals specifically to address the loss of the local colony. Disposition: OPG has categorized the extent of loss related to active Bank Swallow burrows based on 2007 data. Monitoring of the colony continues.Although a residual effect was determined,and it was further determined to be"Not Significant'in the context of the CFAA. The Site Study Area was modified to include colonies that are in general proximity to each other(Bank Swallow Evaluation area).This extended to the east(Wilmot Creek)and west(Oshawa Creek)until a substantive gap in colonies and between existing colonies was reached.This was rationalized in the TSD based largely on professional opinion and illustrated with mapping. Based on professional judgement,this is a more meaningful area for a species which has its breeding habitat more or less. 'confined'in this area to the lake Ontario shoreline area south of the ancient Lake Iroquois shoreline (approximately Taunton Road). The TSD explains that the suggested mitigation represents a range of measures that includes some innovative,direct and indirect approaches to address the removal of Bank Swallow burrows and nestin habitat that will be rhecessa in order for the r 'ect to advance.While we r ise that 16 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REviEW DOCUMENT DEscRIPT1oN Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 14 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: neat s (Drawing w�ordinatea, REv1EWER'S CommE,NTs/AUTHows DISPOSITION DISPOSITION BY AUTHOR AND page,paragraph number, REVIEWER etc. these suggested measures do not represent and exact"like-for-like"we also believe that a meaningful attempt has been made to provide tangible measures that will be to the long term benefit of the swallows.We respect the comments of the reviewer regarding the loss of habitat,however we respectfully disagree that compensatory or mitigative actions need always match exactly the nature of the loss.For example,compensation measures have been authorized with respect to fish and fish habitat that do not represent an exact like-for-like match,if the measures contribute to the long-term gains related to fish habitat, 14 Terrestrial Environment The assessment of the potential for bird strike mortalities on the cooling towers was completed using Existing Conditions TSD— previous studies on other sites. We suggest that local conditions need to be analyzed and compared qcc ted by Reviewer Table 2.2-5 and Table 3.4- to the conditions on the comparison sites so that the predicted effects are more representative of the 2 local environment. We suggest that follow-up monitoring should be conducted for bird strike effects to Yes ❑No confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced. 17 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental impact Statement for the New Nuclear-Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REVIEW DocumENT DEscRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 a16-495.4304 RBVieWWs Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Rem i (Drawing co-ordinates, REVIEWER'S Ct761MENTSIAUTNOR'S DISPOSRIQN DISPOSITION sy Aun4OR AND P"%pamgrw numer, REVIEWER etc. Disposition: OPG used a similar structural design on a Great Lakes shoreline and a peer-reviewed study for strike data.Further analysis of existing conditions at this location and comparative analysis with other locations for which reasonably comparable data might be available is in our opinion,highly unlikely to result in a finding that bird strikes would be an order of magnitude higher. It is important to note that "comparable data"might be limited to vegetation and geographic analysis as radar data is unlikely to be available elsewhere for similar structures and locations.Therefore we submit that our ultimate conclusion would be unchanged.Any a priori determination of bird strikes is at best an estimate.We have recognised that towers would result in strikes of hundreds of birds;even in the unlikely event that this number were thought by others to be in the thousands(as it has been for example for the id buildings of the downtown City of Toronto),it might be reasonably concluded that the effect would still be Not Significant in terms of bird populations. Should Cooling Towers be constructed at the NND site,OPG agrees that follow-up monitoring to confirm predicted results would be appropriate. 15 Terrestrial Environment There is an inconsistency between the Effects Assessment document and the EIS in that on page 24 Effects TSD—Section of the TSD it is stated that the impacts trom the management of stormwater are unlikely to resuh in a 3.2.3 negative effect yet in Table 5.5-1 of the EIS the management of stormwater is listed as a p work Acc ted by Reviewer and activity that is likely to result in a measurable change to the terrestrial environment. We suggest Yes ❑No that a review be undertaken to remedy the inconsistency. Disposition: The listing of*Management of Stormwater"'in Table 5.5-1 was an error.The reference will be.removed from the table. 18 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW 09PUM9ur 0escolPTION Reviewer's Name Paui Draycoti-Project Manager Telephone I extension Date:May 22,2009 416-4954304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: ham r oocument Locagon REVIEWER'S COMMENTS/AUTtioWs DISPOSITION DISPOSITION BY AUTHOR AND (Drawing coordinates, REVIEWER page,paragraph number, etc. Surface Water Effects A relatively large area of lake infilling is proposed for this project. The reviewers agree that additional TSD—General Comment area needs to be made available for construction staging and materials storage. We suggest that a Acc ted by Reviewer more fulsome explanation of the need for this infill be provided that compares the available area for Yes ©No construction staging with that used for the existing Darlington Nuclear Generating Station. This explanation should also incorporate the efficiencies accounted for through phased construction, current construction technologies and methodologies and the in-design strategies available for minimizing the extent of the infill. We suggest that there should be a commitment to further review of in-design mitigation measures to reduce the area of infill once a vendor has been selected and the vendor's construction needs are assessed. Disoosition: OPG agrees that additional rationale for the bounding lakefill area would be useful to the reader. More information will be included in the description of the lakefill requirements in Chapter 2 of the EIS. The rationale will Include a description of the role of the infili area through each phase of the project. Some of the key aspects of the lakefill rationale will include the extent of large modular components being transported to the site via lake barge or ship;the need for safe and secure conditions on the lake side of the power block foundations once the site has been excavated below lake level to bedrock;the need for sufficient security protection from public access on the lake side of the plant;and the need for additional operating island around the reactors in the event that cooling towers are required. The EIS also identifies the potential for stormwater management and settling ponds,shoreline gravel bars and splash pods for migratory birds during the operations phase of the project. The EIS will also outline how the specific extent and design of the lake infill will be documented as pan of each licensing step, from site preparation when the initial lake filling will occur,through construction where the offloading and laydown of large equipment will occur,and through plant operation where site security,safety and increased site biodiversity will be described. 19 of 41 CLALINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Umfted-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: stern• (Drawing Document Location REVIEWER'S COMMENTs/Aumi:l'S DISPosrrm DISPOSIVION BY AUTHOR AND REVIEWER page,paragraph number, eta 17 Surface Water Effects Stormwater management is limited to a screening level assessment due to the vendor selection not TSD-General Comment being finalized. A more fulsome commitment to in-design mitigation criteria for water quality using Acc tad by Reviewer Best Management Practices should become part of the Scope of Project. We suggest that follow-up Yes []No monitoring should be conducted for water quality discharges to confirm predicted results and to identify remedial mitigation measures where changes in predicted results are evidenced or there are issues of noncompliance with regulatory thresholds. Disposition: The Scope of Project does indeed address the requirement to ensure that stormwater discharges meet applicable quality standards. This has been reinforced through edits to EIS Section 2.5.9 (Stormwater Management)that include the commitment that Good Industry Management Practices will be applied to ensure that appropriate and effective stormwater control and management features are incorporated into all phases of the Project,and that all discharges from related facilities will meet applicable quality criteria. It can be expected that monitoring of site discharges will be an aspect of OPG's ongoing due diligence program;and this will include any specific quality monitoring requirements that may be required of approvals granted for the Project. Follow-up monitoring programs are located in the EIS(Chapter 11). Follow-up monitoring of the receiving system(lake Ontario)has been recommended in Table 11.6-2 of the EIS. Currently,follow- up monitoring for on site stormwater has not been recommended based on water quality noted at DNGS and other nuclear sites. However,the appropriateness of monitoring will be addressed by the regulators and included in the Environmental Monitoring Plan as deemed necessary. 18 Land Use Effects TSD- The assessment of land uses within the 10 kilometre zone should clearly identify land uses that OPG Section 3.1.2 and 4.1.2 would have concerns with based on issues such as,but not limited to,security or emergency Accepted by Reviewer preparedness. An assessment of those potential land use constraints should be completed to idenfity 20 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Titie: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: ftem s Document location REv1EWER's COMMENTs/AUTNOfl's DISPOSITION DlsposmoN BY AuntoR AND (Drawing coordinates, REvtEWER page,Paragraph number. etc. inconsistencies with and impacts to future plans for Municipal growth within the 10 kilometre zone. Yes No Disocrr0on: OPG agrees that should there be a concern with specific land uses within the 1 Okm zone that they be clearly identified. The 10 km land use assessment zone was used to assess potential effects of the NND Project on the existing,planned,future and long-term land uses in proximity to the ON site. At this time,OPG does not have concerns with respect to land uses within 10 km of the Darlington Nuclear Site and has not identified any land use constraints with respect to future plans for municipal growth within this distance based on the current and proposed land uses designated by the Durham Official Plan and Clarington's Official Plan and zoning by-law. The Provincial Nuclear Emergency Plan provides the off-site basis for emergency planning.This Plan requires OPG to support emergency planning and response for areas within a 10 km radius of all nuclear plants. Should future land uses be inconsistent with emergency planning needs for the NND Project,OPG will have opportunities to participate in the planning process under the Planning Act. Section 5.5 of the Canadian Nuclear Safety Commission's Regulatory Document RD-346 provides population and emergency planning considerations to support the achievement of safety goals. This _ includes an evaluation of population density and distribution,present and future use of land and resources,site characteristics,populations in the vicinity of the ON site that are difficult to evacuate or shelter,and the ability to maintain population and land-use activities at levels that will not impede the implementation of emergency plans. OPG has undertaken evacuation time estimate modeling to demonstrate that households and businesses can be safety evacuated within 10 km of the ON site through the life of the NND Project to respond to the CNSC's requirements. In addition,a mitigation measure identified in the Assessment of Environmental Effects TSD for land Use is that the Region of Durham,the Municipality of Clarington, Emergency Management Ontario,Durham Emergency Manaclement Office and OPG would coordinate as required to address off-site emergency response 1 21 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REifi W WUMWT,DESCRIPTION . Reviewer's Name Paul Draycott- Project Manager Telephone/extension Date:May 22,2009 416-495.4304 Reviewer's Organization Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Tide: Item# Document Location REviEwER's Com uENTS/AuTHOR'S DISPOSITION DisposmON By AUTHOR AND (Crewing coordinates. REviuwER page.paragraph number, etc. provisions as they relate to sensitive land uses in proximity to the DN site. 19 Land Use Existing The measurement of population and employment change could be clearer as the percentage change Conditions TSD-Section is based on the future growth as compared to the base 2001 population and employment. In effect the Acc led by Reviewer 3.2.3.1 population and employment are almost doubling during the forecast period based on the Provincial Growth Plan,Schedule 3. We examined the past and extrapolated the projected population and Yes ❑No employment growth for Durham Region,based on 1996 to 2006 census data because this measures the past growth rates experienced by residents of the Region.When we compare this with the Growth Plan forecasts,we find the Growth Plan population forecasts are higher than the past and extrapolated growth rates,at approximately 4%. Whereas projected employment is approximately 50%higher than the Growth Plan employment forecasts at about 2031,in terms of population,this difference would be the equivalent of 30,000 more people by 2031 and 155,000 less jobs by 2031.In an overall context the objective of the Growth Plan is to intensity relatively more population and employment in the existing urban areas.We suggest the EA should recognize actual growth patterns experienced as well as forecasts to carry forward to both the land use and socio-economic effects assessments. 22 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental impact Statement for the New Nuclear- Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REvlicW DMUMSNTDESFRiPSiOD+ Reviewer's Name Paul Draycott-Project Manager Tetephwte i extension Date:May 22,Zoos 415-495-4304 Revi @war's Organization Morrison Hershfield Limited-Host Community(municipality of Clarington)peer Review Sections Reviewed: Document Title: Item If Document Looatlon REviEWER's COMMENTS/AUTmOR'S DISPOSMON DISPosrTION BY AUTHOR AND (Drawing co-ordlnatoa, REVIEWER page,paragraph number, ate. Disposition: The EA utilized the Growth Plan forecasts,which municipalities are required to conform with,under the Places to Grow Act. These forecasts were used for the EA as they are representative of the population and employment that municipalities are planning for. We acknowledge that past trends are useful for analyzing changes over time. The Existing Environmental Conditions TSD for Land Use considered land use change over a 1.5 year study period within 10 km of the DN sae. The Existing Environmental Conditions TSD for Socio-Economic considered historic population change in the Municipality of Clarington. A mitigation identified in the Assessment of Environmental Effects TSD for land Use is that OPG continue to engage in discussions with the Region of Durham and the Municipality of Clarington regarding future land use structure. This mitigation is to ensure that any effects of the NND Project on land use structure may be considered in collaboration with the appropriate municipalities through the planning processes. This may include such activities as the Official Plan Review. 20 socto-Economlc Existing We suggest that the changes in the automotive sector are mote than a"predicted cyclical slowdown" / Conditions TSD and and what is occurring is a major restructuring in the North American automotive sector.GM in Oshawa r 4ted by Reviewer Effects—General is evolving and the future is uncertain at this point and there should be an assessment of the potential C�J y'as ❑No Comment Impacts to the Municipality of Clarington with respect to competition for employment at New Nuclear Darlington and the supply of materials from kcal businesses. Disposition: OPG agrees and additional information has been included in the Socia-Economic Existing Conditions TSD to recognize the major restructuring occurring in the North American auto sector. The Socio- Economic Environment Assessment of Environmental Effects TSO has been revised to recognize competition for eme[oymant for the NND Project is a provincially-wide phenomenon and not 23 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REviEw DocuMENT DESclaIPTIoN Reviewer's Name Paul Draycott- Project Manager Telephone/extension Date:May 22,2009 416-495.4304 Reviewer's Organization Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: tam a t��9� REviEWER's CQMMENTs/Amoi:t's DISPOSITION DlsPosnWN ay AUTHOR AND page,paragraph number, REVIEWER etc. specifically focused in Clarington,Oshawa and is not specific to the auto sector. The TSD will recognize that job opportunities associated with the NND Project will be limited for auto sector employees,since the skill set and types of jobs are specific to nuclear energy. However,opportunities do exist for specialized trades(e.g.boilermakers,millwrights,crane operators,ironworkers)that the auto sector may have. These trades have a greater opportunity for employment opportunities. Additional information was added to the TSD to recognize the recommendations of the'Community Adjustment and Sustainability Strategy for Oshawa and Durham Region"responding to the changing economic structure of Durham Region; The Socio-Economic Existing Conditions TSD has been revised to clarify that Infrastructure Ontario is undertaking an evaluation of potential vendors to construct the NND Project and that one part of the evaluation is the investment in Ontario(measured by total impact on the Ontario GDP). Some of this investment may occur in the LSA,including Clarington. However,many of the parts and supplies to be used in the construction phase of the NND Project are likely to be sourced outside of the LSA and that existing businesses that supply goods and services to the DN site are not likely to expand. Based on results from a Nuclear Service Supplier Survey,some nuclear service industry suppliers may choose to relocate to the LSA should the NND Project proceed. 21 Socio-Economic Existing The day trip tourist market is an important component of the overall tourist market to Durham Region Conditions TSD and and the host community,Claangton(not just for parks,including Darlington Provincial Park,but also A led by Reviewer Effects—General for downtown areas and tourist businesses).The importance of same-day visitors needs to be Yes ❑No Comment acknowledged and the predicted impacts on this economic resource assessed.Given the wide range of other competing locations for the day-trip market,anything that Interferes with access to or the attractiveness of the host community could impact visitation levels. Decreased levels of tourists staying overnight in the area may translate into lower spending at tourist related attractions in the area. Tourism is a very competitive industry-tourists may choose to visit other areas where they have less competition for accommodations and will not be inconvenienced by any perceived or real impacts in the area traffic congestion,noise during construction. Attractions and services oriented to tourist 24 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEWDMUMENT.D Scf—ppilON Reviewer's Name Paul Draycott—Project Manager I Telephone i extension Date:May 22,2009 416-495-0304 Reviewer's Organization Morrison Hershfield Umited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: tram a Document Location REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DISPOSmoN BY AuTHoR AND (Drawing co o dkmtea, REviEWER page,Paragraph number, ate. markets in Clarington(not just the Darlington Provincial Park and Bowmanville downtown)may tore some business. We suggest that there needs to be a more fulsome assessment of the financial impacts on the host community from tourism diversion during construction and operation of the New Nuclear Darlington project. Disposition: OPG agrees that the day trip tourist market is an important component of the Durham and Clarington tourist economy. Additional information has been included to the Socio-Economic Environment Existing Conditions TSD recognizing the importance of the day trip tourist market and importance to downtown areas and tourist businesses. In addition,2007 additional tourism data has been added to quantity the importance of the day tourist visits to Durham Region. The Socio•Economic Environment—Assessment of Environmental Effects TSD has been revised to acknowledge that businesses focused on tourism are vulnerable to tourist diversion. Additional analysis will be focused on this potential effect during the Site Preparation and Construction Phase of the NND Project when tourists may compete with construction workers for accommodation,and during the Operations Phase as a result of changes in community character should natural draft cooling towers be constructed. i Although some tourist markets may lose business,we disagree that an assessment of financial impacts on Clarington from tourist diversion during constriction and operation of the NND Project is necessary. Overall,the potential effects of the NND Project on tourist diversion are anticipated to be minor. This is supported by local study area stakeholder interviews that were conducted in which the majority of tourist operators indicated they had no concerns with the NND Project,and some mentioned that the project would be a benefit by bringing more people into the area and creating economic opportunities. 25 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SWEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REviEw DOCUMENT DESCRIPTIoN Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416.495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Item If Document Location REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DISPOSnWN ay AUTHOR AND (Drawing cc-orainetw. REvlEwERR alg%pangraph number, ale. 22 Socio-Economic Existing Pages 88.90 discuss the"indirect effects"of the New Nuclear Darlington project on school enrolment. Conditions TSD Section It is unclear why this is considered an indirect effect; lt the employees are a direct impact then perhaps Ac tad by Reviewer 3.3.1.3 the families should also be considered a direct impact. Nonetheless,the report provides some Yes ❑No estimate of the enrolment growth based on the"population growth in the Rural Study Area and Local Study Area."It is unclear as to what the impact is of the New Nuclear Darlington both during the construction phase and the ongoing site operation. Nor is it clear if the growth in students,over the planning period,can be accommodated within the existing schools or whether new pupil places will be. required. There is the potential of direct and indirect fiscal impacts to the School Board arising from the New Nuclear Darlington Disposition: OPG disagrees that the family members(school children)should be considered a direct impact. The direct effect of the NNO Project is the provision of employment opportunities. School enrolment is described as an indirect effect,as it is a result from the provision of employment opportunities. We do not recommend any additional changes. OPG agrees that the Socio-economic Environment Existing Conditions TSD should clarify what the impact of the NNO Project has on school enrolment during the construction and operation phases. The TSD has been modified to acknowledge that Increasing enrolment is being experienced by some schools boards operating in Clarington and that are indicators that there are increasing pupil accommodation needs in Clarington. The TSD indicates that this situation is the result of rapid population growth in the municipality over the past several years. The Socio-economic Environment Assessment of Environmental Effects TSD provides an estimate of the number of additional students that would need to be accommodated within the LSA,including Clarington and places this effect In the context of continued growth in population likely to be experienced in the future. The assessment concludes that the indirect effect of the NND Project is a small proportion of the antic i ated municipal 26 of 411 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DMUMENT.DESGRIPrl2w Reviewer's Name Paul Draycott—Project Manager Telephone I extension Date:May 22,2009 416-ass-a3oa Reviewer's Organization Morrison Hershfield Umited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: hem r Dominant location REVIEWER'S COMMENTS/AUTNOR'S DISPOSITION DISPOSITION BY AuiHQR AND (Drawing co-mrdbretes, REVIEWER page,paragraph number, Mc. growth. An assessment of the ability of existing schools to accommodate student growth has not been undertaken,nor is it required. With respect to the ability of existing schools to accommodate the number of students anticipated as an indirect result of NND Project,the TSD reports on interviews with School Board officials. They provided insight as to how they routinely review and plan for additional or declining enrolment. Interviews with school board officials indicated that they did not anticipate that the NND Project would place additional demands on School Boards that could not be met through normal planning—but requested that OPG keep them informed about the Project schedule and anticipated workforce demands. OPG has committed to such information sharing. With respect to the fiscal Impact on school boards,the assessment indicates that school boards and individual schools that are in decline stand to benefit from increased enrolment,while those that are anticipating increased enrolment will also benefit from increased funding and will be in a better position to implement their plans for new schools with more confidence. The TSD was revised to include a statement that existing fiscal mechanisms are available to assist with capital and operating costs of School Boards(i.e.,Educational Development Charges for new development and municipal tax revenues for existing development). 23 Socio-Economic Existing It is understood that New Nuclear Darlington will provide on-site fire services;however,the new facility Conditions TSD Section will create an increased demand on Clarington's Emergency and Fire Services.During the long Ac pted by Reviewer 3.3.1.4 construction.phase there will be a significant increase in traffic to and from the site by construction Yes ❑No employees,materials being delivered and removed from the site,and related activities.The increased activity will result in additional off-site incidents that will require a deployment of Clarington Emergency and Fire Services personnel,vehicles and equipment.Post-construction,New Nuclear Darlington will continue to generate servicing needs related to the ongoing full-time employment at the new facility 27 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) F;EVIEW 0OCIJMENT.DESCR!?7'10101 Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-496-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: hero► Dooument t•oeadon REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DISPOSmON sy AUTHOR AND (Drawing coordinates, REVIEWER page,paragraph number, em. and the regular cycle of site and facility refurbishments at the site. Ciarington is under significant pressure to expand fire service provision and historical services are not an adequate indicator of future need. The discussion on the impacts on Clarington's Emergency Services appears to be understated, as does the potential fiscal impact to the Municipality arising from these impacts.As the municipality grows and develops the Emergency and Fire Services department needs to expand buildings, vehicles,equipment and personnel to be able to respond at an appropriate level,and at acceptable response times,to a growing number of incidents. The EA indicates that the indirect demands of the New Nuclear Darlington Project will be addressed by the Municipality through increased household property taxes associated with the New Nuclear Darlington Project and other revenues(e.g.development charges)."No analysis or quantification is made to support this statement. Development Charges are only available to fund initial capital needs and do not provide monies to offset additional operating costs fie.Fire). In addition,the historic service level restriction of the Development Charges.Act results in development charges not fully funding growth-related fire service needs in Clarington.It is likely that the increased properly assessment from households indirectly related to New Nuclear Darlington,at the current Municipal tax rates,will not fully fund the associated increase in fire service costs. The report should include quantifiable analysis to support the suggestion that the Municipality's finances will not be adversely impacted and also an analysis as to when the Municipality will require the funding to supply additional services in comparison to when the Municipality will realize increases in tax revenues from New Nuclear Darlington. Disposition: OPG recognizes that Cladngton needs to expand its fire services(as evidence by Clarington's plans to hire additional fire services staff in the next several years)and that historical levels of services are not an adequate indicator of future need. The Socio-economic Environment— Existing Conditions TSD has been modified to clan the current state of fire services in Clarington,the roles of Clarin 's and 28 of 41 CLARINGTON MUNICIPAL PEER REVIEW— DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Wow w DOCUMENT RasmPTIQN Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: ram 9 ( co-cation as REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DlsPosmoN BY AUTHOR AND REVIEWER Page,paragreph number, ete. OPG's fire services and relationships. - The Socio-economic Environment-Assessment of Environmental Effects will note that it is a requirement of the Project Agreement that the Vendor(responsible for construction)must provide an emergency plan to the satisfaction of OPG regarding the provision for on-site emergency and fire response during the site preparation and construction phase. The size and other requirements for such a fire response service are not known at this time. The TSD will state that development charges collected by the municipality as part of new development In the municipality(including some buildings for the NND Project)as well as property taxes that OPG currently pays and will continue to pay will also be available to the municipality to support fire services. Monies for the ongoing maintenance of these services will be available from property taxes to be paid by OPG and other community members. The Host Municipality Agreement between OPG and Clarington is intended to address the indirect effects of the NND Project on municipal fire services. No additional analysis is required. 24 Socio-Economic Existing We suggest that the Municipal Finance and Administration section of the report is inadequate for the Conditions TSD Section Municipality to assess the fiscal impacts of New Nuclear Darlington. The analysis and report doesn't by Reviewer AgI 3.32.6 quantity or examine the direct and indirect expenditure impacts of the NND and associated growth. The report provides some discussion and analysis of estimated additional tax revenues that will be Yes C1 No contributed by New Nuclear Darlington and associated households. There is little to no support for these global tax revenue estimates or an allocation to the various municipal governments in the Regional Study Area and Local Study Area. More importantly,additional tax revenues are only one half of municipal fiscal impact analysis with the other half being the impact on municipal e nditures. 29 of 41 CAARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DoCtIMEWT DESCRIPTION Reviewer's Name Paul Draycott-Project Manager Telephone/extension Date:May 22,2009 416-495-4304 Reviewer's Organisation Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: Kern If Document Location REVIEWER'S COMMENI's/AmoR's DISPosmoN DISPosmoN sy AuTHOR AND (Drawing c"rdhwAos, REVIEWER pages Paragraph number, etc. The Municipality of Clarington has no way of determining the fiscal impact of the New Nuclear Darlington project without a complete and thorough examination of the expenditure impacts. Clarington is facing significant fiscal issues but the report does not identify them.In 2008,Hemson Consulting completed a study on behaff of Clanngton entitled Financial Impact Analysis of New Development This study identified a number of important fiscal issues facing Clarington including service levels,capital budget constraints,forecast rising debt levels and significant upward pressure on tax rates-all of them important to be assessed in the context of New Nuclear Darlington. Disposition: The Municipal Finance and Administration section of the Socio-Economic Assessment of Environmental Effects TSD was not intended to assess the fiscal impacts of the NND Project on the municipality. Fiscal impact assessment is commonly undertaken by municipalities for major developments. As noted by Hemson(2008)Section 5.3.8 of the Official Plan for the Municipality of Clarington provides for a fiscal impact analysis to be undertaken for large scale developments. The Host Municipality Agreement between OPG and Cladngton is intended to address the indirect effects of the NND Project on municipal finances. No additional analysis is required. OPG recognizes Clarington's fiscal issues and the EIS and TSDs have being revised to recognize the fiscal situation of Clarington. The Hemson(2008)report referenced provides an analysis of residential development proposals and their cumulative effects on municipal services.Key conclusions from this report have been included in the Socio-economic Environment—Existing Conditions TSD. It is anticipated that workers at the NND Project will pay their share of property taxes,to provide for the level of service required to accommodate their needs. 25 SociaEconomic Existing New Nuclear Darlington will receive water supply and waste treatment from the Region. However, Conditions TSD Section there is no analysis of the impact on the ability of Clarington to continue to grow once the required Accepted by Reviewer 3.3.2.2 servicing capacity for New Nuclear Darlington has been taken out of the available Re ional capacity. 30 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Revim DOctiMENT DBScR rnw Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date: May 22,2009 416-495-0304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: hen'• (Drawing ino, REVIEWER'S COMMENTs/AUTHOR'S DISPOSITION DlsPosmoN BY AUTHOR AND page,pub nwnber, REVIEWER etc. What will be Cladngton's share of the remaining available Regional servicing capacity and is that M Yes No sufficient to support the growth plans for the municipality? Disposition: OPG recognizes that the NND Project will utilize servicing capacity for water supply and sanitary sewer service from the Region. Based on discussions with Durham Region Works Department staff, servicing for the NND Project has been accounted for in its plans and as such,the new CWPCP has sufficient capacity to accommodate the project and allow for additional growth in Clarington. The Socio-economic Environment—Existing Conditions TSD has been modified to acknowledge servicing limitations in some areas of Clarington and rotes that the Regional Works Department is currently undertaking a Master Water and Wastewater Servicing Strategy for Durham Region. This study identifies existing constraints on services and the potential means of addressing them,including planned expansions to water supply and sanitary sewage facilities. The Socio-economic Environment—Assessment of Environmental Effects TSD quantifies the additional direct and indirect demands on water and sewage and concluded that the NND Project and its associated population are not expected to place demands on municipal water and sewage systems that would exceed their existing or planned capacities. 26 Socio-Economic Existing The discussion of municipal Infrastructure should also assess the impacts,both financially and on the Conditions TSD Section residents,from the loss of recreational opportunities and facilities such as the on-site soccer pitches Ac led by Reviewer 3.3.2.2 and the Waterfront Trail Yes ❑No Disposition: OPG a rees that the discussion on the Potential loss of recreational opportunities and facilities such 31 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REVIEW DOCUMENT DESC ON Reviewer's Name Paul Draycott—Project Manager Telephone f extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: hem 0 Document Locetlon (thawing co*rdkV t % REVIEWER'S COMMENTWAUTHOR'S DISPOSITION DISPosmON sy At11NgR AND Peg%IWagraph number, etc. REVIEWER as the on-site soccer pitches and the WatedroM Trail should be provided. Thls information is provided in Section 3.3.4.1 "Community Recreational Facilities and Programs"in the Socio-Economic Environment Assessment of Environmental Effects TSD. The Socio-economic Environment— Assessment of Environmental Effects TSD provides mitigation for such effects through the Host Municipality Agreement. 27 Environmental Impact The E.4 study has adequately addressed the New Nuclear Dadtngton site in the context of Regional Statement— in sustainability;however there is little discussion of sustainability,initiatives,goals or shategias on the Comment New Nuclear Darlington site Itself. We suggest that sustainability needs to be reviewed and assessed Ac pted by Reviewer on a site-specific basis and that existing OPG sustainability,policies and goals need to be incorporated Yes []No into construction and operations at New Nuclear Darlington. Greenhouse gas emissions should be an indicator for use in site-specific sustainability,strategies and mitigation measures,and should be assessed as a residual effect in the absence of mitigation. Disoostttorc The reviewer is correct in noting that the consideration of Sustainability,as presented in Section 6.1 of the EIS is framed in terms of the larger Local and Regional Study Areas. This is necessary to address the EIS Guidelines which require that the EIS address Sustainable Development in a context of Project effects on biological diversity;and the capacity of renewable resources that may be affected by the project to meet the needs of present and future generations(EIS Guidelines s.2.4). This larger context for considering sustainability,however,is augmented by the discussion of OPG's sustainable development programs in EIS S.2.10. In response to the review comment,that section has been enhanced with the following text: 'The EIS Guidelines require that the proponent consider sustainability of the Project in terms of the extent to which biological diversity may be affected by the Project,and the capacity of renewable resources that are likely to be significantly affected by it. That assessment is presented in Section 6.1 32 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REvIFW DOCUMFXT DFSCF11PT12N Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22.2009 416.495-4304 Reviewer's Organization Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Tide: 1101"9 i REVIEWER'S CoMMENTs/At1THOR's DisPOSITION DISPOSmGN 13Y AUTHOR AND Pam pare"Ph number, REVIEWER atc- of the EIS. To meet the requirements of the Guidelines,it Is framed in a geographical context of the Local and Regional Study Areas. That broader framework is not intended to suggest that sustainability objectives will not be an important consideration also in the Site Study Area,and it is within the site context that operational protocols will be implemented with regard for promoting sustainability at a grass-roots level. OPG as the Project proponent and facility operator will work with other relevant stakeholders to promote sustainable practices throughout the Project Examples of these practices include: • Compliance with all applicable regulations, standards, codes of practice, and the terms of licences and permits to be issued, and this EA concerning environmental effects management; • Implementation of the environmental management and monitoring programs as referenced above in Sections 2.9.1,2.9.2 and 2.9.3; • Continuation of the Biodiversiry Plan currently in place at the DN site as described above in Section 2.9.4; EIS Section 6.4 includes a discussion of greenhouse gas(GHG)in terns of its effect on climate change. Project-related emissions of GHG will result from both construction and operating equipment. The construction equipment used will comply with emissions regulations;and the operating equipment (emergency generators and auxiliary steam boilers)will be state-of-the-art equipment and also meet emissions regulations. As noted in the new text above,NND programs can be expected to Include strategies for reducing GHG emissions. Considering the foregoing,GHG emissions are not identified as an effect of the Project,however,and also as noted,programs and measures will be incorporated 33 of 41 CLARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) RFsti'lE UM :LIESCRiRTioN: . Reviewer's Name Paul Draycott— Project Manager Telephone/extension Date:May,22,2009 ats-a9sa3oa Reviewer's Organization Morrison Hershfield Umiled-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Tide: In`n r (Drawing ooay atM REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DnWosmoN BY AUTHOR AND Page,paragraph number, REVIEWER ate. throughout the project to control these emissions. 28 Environmental Impact The EIS is missing evaluations of degrees of uncertainty for the assessment of effects,as required Statement-Section 3.2.7 under the EIS Guidelines. Acc led by Reviewer Disposition: Yes ❑No EIS Section 3.2.7(Precautionary Principle)has been edited to include the following text to further address issues of uncertainty in the evaluation: The Guidelines require that the EA consider the Project through application of a'careful and precautionary manner-in order to ensure that it does not cause significant adverse environmental effects. The Guidelines refer to the document A Framework for the Application of Precaution in Science-based pecision Making About Rtsk"(NPCC 2003). As indicated in the framework,its purpose is to set Out precautionary principles to guide decision-making where More is an absence of lull scientific certainty. I The EIS and the studies that it represents have been completed with regard for this precautionary principle'such that sufficiently confident decisions can be made to protect society's values and priorities. Key themes relative to this principle and which are carried throughout the EIS include that • Qualified professionals fully experienced in their fields performed the work within a structured, organized approach; • Industry standards and best practices,including peer review of technical programs were applied; • Uncertainties inherent in the use of computer models were compensated through routine 34 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REviEw Ot1GUMENT OESGRIPTIoN Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 41e-495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Cladnglon)Peer Review Sections Reviewed: Document Title: INrn k Document Location REv1EWER'S COMMENTSIAt1TwR'S DISPOSITIoN DisposmoN ay AunfoR AND (Drawing co-ordlnatsa, REviEwER page'para~numbar, etc. application of conservative Project design assumptions and model input parameters; • The use of founding conditions for assessment of effects purposes will routinely result in over- estimates of likely effects with associated confidence that the likely effects are lower than those predicted,•and • The Fes(program will conclude with a comprehensive follow-up and monitoring program,including adaptive management as a key feature to respond to sciendfic uncertainty and provide for informed decisions and actives going forward. In addition,EIS Section 3.2.5(Assessment of likely Effects)has been edited to include the following: As has been described in preceding pages,in many respects, the assessment of effects was carried out using bounding conditions particularly with respect to the scope and nature of the Project work and activity being evaluated. Scientific uncertainty concerning the extent of potential effects is largely compensated for through the use of bounding condfions that typically reflect the outer range of possible conditions. The degree of uncertainty concerning the prediction of effects has been further reduced through the use of best practices by experienced professionals;incorporation of actual measurement data where available and applicable;use of approved models with a history of application;and the use of peer review throughout all stages of the EA to ensure that the science applied in the assessment was appropriate. A further and key element in reducing the uncertainty of predicted effects concerning the NND Project has been the availability of extensive data and operational experience from DNGS,a fully-functioning nuclear power station within the DN site with almost two decades of operational and environmental 35 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT FDDCIu,,J ment Title: Technical Supporting Documents and Environmental impact Statement for the New Nuclear—Darlington Final onmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOCUMENT DESCRIPTIONwer's Nam Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416-495.4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: town 0 Document LnaebOn REvIEWER'S COMMENTS/At1THOR'S DISPOSITION DIBPosmoN BY AuTHoR AND (Drawing co-ordinates, REVIEWER page,paragralib number, ate. performance data. The database of directly-relevant information pertaining to ONGS has provided an important opportunity to benchmark and ground-truth the findings of the NND EA studies. 29 Environmental Impact The EIS guidelines require that any modification to the preliminary recommended Valued Ecosystem Statement—Table 4.5-1 Components(VECs)be completed by the proponent following consultation with the public,Aboriginal Acc ed by Reviewer people,federal and provincial government departments and relevant stakeholders. All VECs that have Y� No been modified from the EIS guidelines should be supported with a fulsome rationale and Ute details of the required consultations should be discussed. Dismsition: Among other improvements made concerning the discussion of VECs,EIS Section 3.2.4 has been edited to include the following in response to the comment: A preliminary list of VECs was included M the EIS Guidelines (the list was unchanged between the draft and final Guidelines) with the direction that it be modified as appropriate by the proponent to consider input received during consultations with the public and other stakeholders. Although not specifically prescribed in the Guidelines but consistent with the selection framework described above, it would also be expected that final VEC selection would reflect actual existing conditions relative to the Project as determined through the baseline characterization studies. The process for selecting VECs began with a detailed comparison of the preliminary VEC list included in the Guidelines to those VECs that have previously been used for other 54s and related programs with relevance to the NND. An important consideration in this respect was the substantial base of experience concerning VEC selection available to drawn from as the starling point for choosing NND- specific VECs. This experience includes recent EAs for the refurbishment and continued operation of PNGS B,for the used fuel dry storage facilities at both DNGS and PNGS, for the return to service of 36 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear—Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEw P=uMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,zoos 416-495-4304 Reviewer's Organization Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: item a Document Locatkm REVIEWER'S COMMENTS/AUTHOR'S DISPOSITION DlsvosmoN BY AUTHOR AND (Drawing co-ordinates, REVIEWER page,paragraph number, etc. PNGS A,and the Port Hope and Port Granby Projects(that together tone the Port Hope Area Initiative). The VECs and selection rationale for the above programs and the preliminary list in the(draft)EIS Guidelines were considered by the study teams conducting the individual baseline environment characterization program for various environmental components. A candidate VEC list was developed for each component and progressively refined based on the increasing knowledge of the existing environment relevant to the NND,the specific features of the Project(see Chapter 2),and how and the Project and the environmental would be likely to interact. Input to the selection of VECs was solicited from the public and other stakeholders. At Community Information Sessions held in the spring of 2008, OPG presented 22 environmental subcomponents and 100 environmental features representing candidate VECs and VEC indicators as Identified through the above process, for public discussion and feedback. The VEC selection program was reviewed with Aboriginal groups and MAtis organizations and their input solicited during the Aboriginal Information Sharing Session held in May 2008. The final list of VECs ultimately selected for use in the EA considered all public and stakeholder feedback(as discussed further in Section 10.3.1.3). Additional stakeholder input to the VEC selection program was contained in many of the responses by interested parties to the draft EIS Guidelines that were published for comment by the CNSC and the CEA Agency. More than 30 responses were received and published on the CEA Agency website. All were reviewed by the E4 team and those that pertained to VECs were considered in establishing the final list of VECs to be used for the EA. The resolution of all comments received on the draft Guidelines concerning VECs is detailed in the individual sections throughout Chapter 4 where the final 37 of 41 CAARINGTON MUNICIPAL PEER REVIEW- DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear— Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REviEw DOCUMENT DipSCRIPT14N1 Reviewer's Name Paul Draycott— Project Manager Telephone/extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Cladngton)Peer Review Sections Reviewed: Document Tittle: Item• rumen t co-ordinates, REVIEWER'S COMMENTSIAuTmoR'S DISPOSITION DlsPosmoN ev AUTHOR AND page,Paragraph number, REVIEWER etc. VECs are introduced. 30 Environmental Impact This table does not appear to be complete with respect to all of the required regulatory requirements Statement—Table 11.3-1 and,accordingly,there appears to be several monitoring requirements that are missing such as off- 9 eq 9 Ac pled by Reviewer site dust migration during site preparation. Disposition: Yes ❑No In the reviewed version of the EIS,the noted table did not effectively address its intended purpose. As presented,the table suggested that it tabulated a full list of regulatory requirements that would be invoked by the Project when,in fact,this was not its intended objective. . The title of the table has now been changed to Vkefy Monitoring Requirements Not Associated with EA Follow-Up"and introductory text added to make it clear that it summarizes a number of on-going monitoring programs not related to the EA follow-up program that will also be carried out,particularly during the implementation phases of the NND. These programs will include those that may be required as licence conditions as well as others that may be conducted as aspects of OPG's due diligence. Those programs will complement the follow-up campaign and data will be shared to meet the collective requirements. 31 Environmental Impact We suggest that follow-up program elements should include dispositions on complaint resolutions and Statement—Table 11.3.2 remedial works to address noncompliance issues(particularly with third parry agreements and Ac ted by Reviewer regulatory requirements),ineffective mitigation and/or unpradicted effects. Assumptions surrounding yes ❑No cumulative effects should be subject to follow-up monitoring of predicted results and remedial mitigation developed is necessary. 38 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact statement for the New Nuclear—Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final REviEw DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone I extension Date:May 22,2009 416-495-4304 Reviewer's Organization Morrison Hershfield Limited—Host Community(Municipality of Clanngton)Peer Review Sections Reviewed: Document Title: than i (Drawing co-ordinates, REVIEWER'S COMMENTSIAUTHOR'S DISPOSITION DISPOSITION BY AUTHOR AND Page'peragrsph number, REVIEWER etc. Disposition, Introductory text has been added to Section 11 to clarify that the follow-up program is also intended to confirm that mitigation measures have been implemented and are being effective. As was already noted in the section,a related objective of the program is to confirm on an on-going basis,whether assumptions made during the FA remain accurate.Although not stated specifically,this would include assumptions made relating to cumulative effects as well. In addition,a discussion concerning Adaptive Management as relevant to follow-up monitoring will be applied.Specifically,adaptive management will be inherent in the design and implementation of the FA follow-up and monitoring(and related)programs. Prior to its implementation,the plan will be refined and designed in detail,with this design incorporating principles of adaptive management. Adaptive management will subsequently become a fundamental aspect of its implementation to ensure that the monitoring elements remain valid,appropriately encompassing,and responsive to the objectives,including as their focus may evolve over time. The monitoring programs themselves will be routinely re-evaluated and their scopes adjusted to consider such aspects as changing site conditions, or the need to re-focus on specific operational or environmental issues of uncertainty or concern. Finally,a section has been added in Section 11 that describes how the follow-up monitoring data will be managed and disseminated. Because follow-up monitoring is an integral element of the FA,all monitoring data will be provided to the RAs and other FAs that they may choose to designate. The final distribution of monitoring data will be determined in conjunction with finalization of the program itself,however,It is also likely that some aspects of monitoring information will also be provided to other stakeholders as appropriate. Although the form and frequency of the reporting will be determined as the program is finalized,it is reasonable to anticipate that the data will be assembled into a formal monRoring report and submitted on a regular basis. As has been noted,many of the 39 of 41 CLARINGTON MUNICIPAL PEER REVIEW - DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR - DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear- Darlington Final Environmental Assessment(Draft for Municipal Peer Review Purposes Only) REVIEW DOCUMENT DESCRIPTION Reviewer's Name Paul Draycott—Project Manager Telephone/extension Date:May 22,2009 416495.4304 Reviewer's Organization Morrison Hershfield Limited-Host Community(Municipality of Clarington)Peer Review Sections Reviewed: Document Title: ftwn# (��e�s� REVIEWER'S COMMENTSIAUTHOR'S DISPOSITION DI&POSmON eY AuTKoR AND page,pars~number, REVIEWER ete. follow-up program elements are likely to be merged with related monitoring programs so it will be likely that data collected during the program will also be distributed to other parties and agencies,based on the requirements of those programs. 32 Environmental Impact Overall,we felt that the environmental assessment and impact study has been completed very � / Statement-General professionally and with a great effort to identity concerns,communicate and consult with relevant ted by Reviewer Comment stakeholders,and to plan with an overall goal of minimizing the environmental impact of this project. We are confident that the outstanding concerns identified above will be disposifioned with the same Yes ❑No degree of care and attention. Disposition: OPG appreciates the opportunity to have Clarington undertake a peer review of the Draft EIS and Technical Support Documents,to assist OPG in preparing a complete and comprehensive environmental assessment, As the comments and dispositions demonstrate,OPG has gained additional insight from the through review undertaken by the Host Community. The EIS has benefited from the additional insights and detailed analysis provided through this process,as indicated by the many revisions and additions to the documents reviewed. Commante submitted by RovWAw to Author. Pau: May 22,2009 . Cotnpiet4d Dlapowm Fotm submtmo by Author to ft a tlptp: John Peters,FA Manager,OPG June 5,2009 40 of 41 CLARINGTON MUNICIPAL PEER REVIEW — DRAFT OPG RESPONSES FOR REVIEW COMMENT AND DISPOSITION SHEET NEW NUCLEAR — DARLINGTON ENVIRONMENTAL ASSESSMENT Document Title: Technical Supporting Documents and Environmental Impact Statement for the New Nuclear-Darlington Environmental Assessment(Draft for Municipal Peer Review Purposes Only) Final Act of nlapoeltlon by lievlewer Reviewer ftnsbA Ind108tiny v Aa9e; OptY;: June 16,2009 Instructions: Reviewer/Commenter • Complete Reviewer's Name, Organization, and telephone. • Complete Reviewer's Comments section(s). Document location description is sufficiently specific to allow others to find the referenced words or drawing location. Comment is specific, if possible, to aid in resolution. Words from documents may be pasted into comment section. • To add new rows, uses "copy and paste". Author • Completes disposition section of form for each item. • Enters name and date in area "Comment Dispositions submitted for Reviewer Acceptance" 41 of 41 APPENDIX 2 FINAL EIS GUIDELINES MARCH 12, 2009 Guidelines for the Preparation of the Environmental Impact Statement for Ontario Power Generation's Darlington New Nuclear Power Plant Project January 2009 January 2009 Guidelines for the Preparation of the EIS TABLE OF CONTENTS PART 1 -INTRODUCTION........................................................................................ 1 1. CONTEXT............................................................................................................. 1 1.1 Purpose of the Guidelines............................................................................ 1 1.2 Environmental Assessment and Regulatory Process................................ 1 1.3 Preparation and Review of the EIS............................................................2 2. GUIDING PRINCIPLES.....................................................................................4 2.1 Environmental Assessment as a Planning Tool ........................................4 2.2 Public Participation and Aboriginal Engagement....................................4 2.3 Traditional Knowledge................................................................................5 2.4 Sustainable Development............................................................................6 2.5 Precautionary Approach............................................................................. 6 2.6 Study Strategy and Methodology...............................................................7 2.7 Use of Existing Information........................................................................8 3. PRESENTATION OF THE EIS ............................................................................9 3.1 Environmental Impact Statement Summary............................................9 4. SCOPE...................................................................................................................9 4.1 Scope of the Project.....................................................................................9 4.2 Factors to be considered in the EIS.......................................................... 12 PART H-CONTENT OF THE EIS......................................................................... 14 5. CONTEXT........................................................................................................... 14 5.1 Setting.......................................................................................................... 14 5.2 Project Overview and Purpose................................................................. 14 5.3 Proponent.................................................................................................... 14 5.4 Environmental Assessment and Regulatory Process and Approvals.... 14 5.5 International Agreements......................................................................... 15 6. PUBLIC PARTICIPATION.............................................................................. 15 6.1 Aboriginal People....................................................................................... 16 6.2 Government Agencies................................................................................ 16 6.3 Stakeholders............................................................................................... 16 6.4 Other Public Participation........................................................................ 16 7. PROJECT JUSTIFICATION............................................................................ 17 7.1 Purpose and Need for the Project............................................................. 17 7.2 Alternatives to the Project......................................................................... 17 7.3 Alternative Means of Carrying out the Project...................................... 17 8. DESCRIPTION OF THE PROJECT............................................................... 18 8.1 General Information and Design Characteristics................................... 18 8.2 Site Preparation .........................................................................................20 8.3 Construction...............................................................................................21 8.4 Operation and Maintenance.....................................................................22 8.5 Modifications..............................................................................................23 - i - January 2009 Guidelines for the Preparation of the EIS 8.6 Decommissioning and Abandonment.......................................................24 8.7 Waste and Used Fuel Management..........................................................24 8.8 Malfunctions,Accidents and Malevolent Acts........................................24 8.9 Environmental Protection,Policies and Procedures..............................25 9. ENVIRONMENTAL ASSESSMENT BOUNDARIES...................................25 9.1 Spatial Boundaries and Scale....................................................................26 9.2 Temporal Boundaries................................................................................27 9.3 Valued Ecosystem Components................................................................28 10. EXISTING ENVIRONMENT...........................................................................32 10.1 Biophysical Environment..........................................................................34 10.2 Socio-economic Conditions.......................................................................37 11. EFFECTS PREDICTION, MITIGATION MEASURES AND SIGNIFICANCE OF RESIDUAL ADVERSE EFFECTS..............................39 11.1 Effects Prediction.......................................................................................39 11.2 Mitigation Measures..................................................................................40 11.3 Significance of Residual Adverse Effects................................................. 41 11.4 Biophysical Environment..........................................................................42 11.5 Socio-economic Effects..............................................................................46 12. ACCIDENTS, MALFUNCTIONS AND MALEVOLENT ACTS.................49 12.1 General Considerations.............................................................................49 12.2 Nuclear Accidents......................................................................................49 12.3 Conventional Accidents.............................................................................51 12.4 Malevolent Acts..........................................................................................51 13. CUMULATIVE EFFECTS................................................................................52 14. CAPACITY OF RENEWABLE RESOURCES..............................................53 15. FOLLOW UP PROGRAM................................................................................53 16. ASSESSMENT SUMMARY AND CONCLUSION........................................55 17. REFERENCES.................................................................................................... 55 APPENDIX 1 —Glossary and Acronyms APPENDIX 2—High Level Guidance for Applications for Licence to Prepare Site - ii - PART I - INTRODUCTION 1. CONTEXT 1.1 Purpose of the Guidelines The purpose of this document is to identify for the proponent, Ontario Power Generation(OPG), the nature, scope and extent of the information that must be addressed in the preparation of the Environmental Impact Statement(EIS) for its proposed New Nuclear Power Plant project (the OPG Darlington NNPP project) for the creation of approximately 4,800 MW of electrical generation capacity. The proponent will prepare and submit an EIS that examines the potential environmental effects, including cumulative effects, of the site preparation, construction, operation, refurbishment if required, decommissioning and abandonment of the project, and that evaluates their significance. In addition, the proponent will address all requirements for a Licence to Prepare Site detailed in Appendix 2 of this document. This information will be used by thejoint review panel established pursuant to the Canadian Environmental Assessment Act and the Nuclear Safety and Control Act as the basis for a public review. While the EIS guidelines provide a framework for preparing a complete and accessible EIS, it is the responsibility of the proponent to provide sufficient data and analysis on any potential environmental effects to permit proper evaluation by a joint review panel, the public, and technical and regulatory agencies. The EIS guidelines outline the minimum information requirements while providing the proponent with flexibility in selecting methods to compile and analyze data for the EIS. Exchanges between the proponent and other government organizations, Aboriginal people and stakeholders, where appropriate, are encouraged to ensure that the EIS responds adequately to these guidelines. 1.2 Environmental Assessment and Regulatory Process On September 20, 2006, OPG wrote to the Canadian Nuclear Safety Commission (CNSC) indicating its intent to initiate the regulatory process to prepare a site, construct and operate up to four new nuclear reactors on the existing OPG Darlington Nuclear Site within the Regional Municipality of Durham in Ontario. The proposed OPG Darlington NNPP would generate up to 4,800 MW of electrical generating capacity for supply to the Ontario grid. The OPG Darlington NNPP project includes site preparation, construction, operation, decommissioning and abandonment of up to four new nuclear reactors. Operations would involve activities required to operate and maintain the NNPP, including management of all conventional and radioactive wastes. The EIS will consider the potential environmental effects, including cumulative effects, of all phases of the project. The proponent is considering a range of reactor designs, but has not yet decided on a specific technology. It is anticipated that the OPG Darlington NNPP would have an approximate 60-year operating life and could include a mid-life refurbishment. - 1 - i January 2009 Guidelines for the Preparation of the EIS The principal buildings and structures are grouped into three primary areas: the power block, the cooling system and the switchyard. The power block consists of the buildings housing the nuclear reactors and all associated facilities and equipment. Two methods of cooling water systems are being considered for the removal of heat from the reactor: 1) cooling towers; or 2)once-through cooling system which would draw from, and discharge, to Lake Ontario. A new switchyard may be required to transmit electricity from the power station to the provincial grid. The project triggers the Canadian Environmental Assessment Act given that the proponent requires authorizations under section 24(2) of the Nuclear Safety and Control Act in order for the project to proceed. In addition, authorizations by: Transport Canada under paragraph 5(1)(a)of the Navigable Water Protection Act;Fisheries and Oceans Canada under subsection 35(2) of the Fisheries Act; and the Canadian Transportation Agency under subsection 98(2) and subsection 101(3)of the Canadian Transportation Act may also be required for this project. All of these authorizations require that an environmental assessment is completed before any authorizations are granted that would enable the project to proceed in whole or in part. On March 20, 2008,the Minister of the Environment announced his referral of the OPG NNPP to a review panel pursuant to the Canadian Environmental Assessment Act, and indicated that the CNSC and the Canadian Environmental Assessment Agency(CEAA) should pursue a joint environmental assessment process. A joint review panel under the Canadian Environmental Assessment Act and the Nuclear Safety and Control Act is being established to undertake an environmental assessment and regulatory review of this project. The joint review panel for this project will evaluate information that relates to the environmental assessment. The joint review panel will also consider information submitted by OPG in support of their application for a Licence to Prepare Site for a Class 1 Nuclear Facility, in accordance with the requirements of the Nuclear Safety and Control Act and its regulations. The Province of Ontario's Ministry of the Environment indicated on April 5, 2007 that its legal position was that the province has no mandate to make nuclear facilities subject to the Ontario Environmental Assessment Act. As such, it did not foresee having any environmental assessment responsibility. However, the Province did indicate its desire to remain informed about the progress of the federal environmental assessment so that it could understand the potential implications for projects in the provincial domain. 1.3 Preparation and Review of the EIS The EIS guidelines were prepared by the CEAA and the CNSC, in consultation with Fisheries and Oceans Canada(DFO), Transport Canada and the Canadian Transportation Agency. An EIS is a document prepared by a proponent that allows ajoint review panel, regulators, members of the public and Aboriginal groups to understand the project,the existing environment, and the potential environmental effects of the project. The proponent must also provide, as outlined in Appendix 2, all information required to support the licence to prepare site application for the joint review panel, as a panel of the -2 - it January 2009 Guidelines for the Preparation of the EIS Commission, to consider and render a licensing decision under the Nuclear Safety and Control Act. The proponent will prepare an EIS that addresses the requirements of these guidelines for submission to the joint review panel that will be established for this project. The EIS will then be made available to the public and stakeholders for a comment period on whether the EIS is in conformity with these guidelines. The joint review panel will determine whether additional information is required before convening public hearings. The EIS that is made available for public and stakeholder comment should not contain: • information that could cause specific,direct and substantial harm to the proponent, to a witness or specific harm to the environment by the disclosure of; • information that involves national or nuclear security; • information that is confidential (i.e., financial, commercial, scientific, technical, personal or other nature),that is treated consistently as confidential, and the person affected has not consented to the disclosure; or • information that is likely to endanger the life, liberty or security of a person through its disclosure. The proponent must inform the joint review panel in writing for a determination as to whether specific information requested by these guidelines should be submitted to, and retained by the joint review panel, as confidential. Such requests must contain as much detail as possible about the information to be kept confidential and provide a rationale for the request. All requests, as well as the joint review panel's determinations respecting the requests, will be made available on the project's online public registry. Following public hearings,the joint review panel, as a panel of the CNSC, will prepare and submit a report that includes, but is not limited to,the rationale, conclusions and recommendations of the joint review panel relating to the environmental assessment of the project, including any mitigation measures and follow-up program. This joint review panel report will be submitted to the Minister of the Environment to the Ministers of the Responsible Authorities. The report will be made available to the public at that time. The government will then respond to the joint review panel's report. The Government of Canada's response to the joint review panel report will be made available by the CEAA. Subsequent to the Government of Canada response, the joint review panel will render a licensing decision for a Licence to Prepare Site under the Nuclear Safety and Control Act. 3 January 2009 Guidelines for the Preparation of the EIS 2. GUIDING PRINCIPLES 2.1 Environmental Assessment as a Planning Tool Environmental assessment is a planning tool used to ensure that projects are considered in a careful and precautionary manner in order to avoid or mitigate the possible adverse effects of development on the environment and to encourage decision-makers to take actions that promote sustainable development and thereby achieve or maintain a healthy environment and a healthy economy. The environmental assessment of this project must, in a manner consistent with those purposes, identify its possible environmental effects; propose measures to mitigate adverse effects; and, predict whether there will be likely significant adverse environmental effects after mitigation measures are implemented. 2.2 Public Participation and Aboriginal Engagement Public participation' is a central objective of the overall review process. Public participation provides the public and organizations with a fair opportunity to contribute to the planning of projects that may affect them; allows proponents and federal authorities to better understand and address public concerns and priorities; reduces the potential for adverse environmental effects by identifying community knowledge and Aboriginal traditional knowledge that may be applied in the environmental assessment; and builds greater public trust in the environmental assessment process. Meaningful public participation requires the proponent to address concerns of the general public regarding the anticipated or potential environmental effects of the project. In preparing the EIS,the proponent is required to engage residents and organizations in all affected communities, other interested organizations, and relevant government agencies. The proponent must provide in the EIS the highlights of this engagement, including the methods used,the results, and the ways in which the proponent intends to address the concerns identified, including a summary of issues raised during such engagement. Another objective of the overall review process is to involve potentially affected Aboriginal people in order that the environmental assessment can identify any changes that the project may cause in the environment and the resulting effects of any such changes on the current use of lands and resources for traditional purposes by Aboriginal persons. The proponent must ensure that it engages with Aboriginal people that may be affected by the project and that have asserted or have established Aboriginal rights, ' As described in CEAA's Public Participation Guide(May 2008),terms such as"participation," "consultation,""involvement"and"engagement"are often used interchangeably,although they may mean different things to different people.These guidelines endeavour to use these terms in a manner that is consistent with the`Public Participation Terminology' described in this CEAA Guidance. -4 - January 2009 Guidelines for the Preparation of the EIS Aboriginal title or treaty rights. In preparing the EIS, the proponent must ensure that Aboriginal people have the information that they require in respect of the project and of how the project may impact them. The proponent is required to describe in the EIS how the concerns respecting Aboriginal people will be addressed. That description must include a summary of discussions, the issues or concerns raised, and should consider and describe any asserted or established Aboriginal rights, Aboriginal title and treaty rights. The EIS must document the potential impact of the project on asserted or established Aboriginal rights, Aboriginal title and treaty rights, and the measures to prevent or mitigate those potential impacts. Meaningful involvement in the environmental assessment takes place when all parties involved have a clear understanding of the proposed project as early as possible in the review process. Therefore,the proponent is required to: • continue to provide up-to-date information describing the project to the public and especially to the communities likely to be most affected by the project; • involve Aboriginal people in determining how best to deliver that information (e.g., the types of information required, translation needs, different formats,the possible need for community meetings); and • explain the results of the EIS in a clear and direct manner to make the issues comprehensible to as wide an audience as possible. 2.3 Traditional Knowledge Traditional knowledge, which is rooted in the traditional life of Aboriginal people, has an important contribution to make to an environmental assessment. Traditional knowledge refers to the broad base of knowledge held by individuals and collectively by communities that may be based on spiritual teachings, personal observation and experience on land and sea or passed on from one generation to another through oral and/or written traditions. This tradition is dynamic, substantive, and distinct living knowledge. Traditional knowledge, in combination with other information sources is valuable in achieving a better understanding of potential impacts of projects. Traditional knowledge may, for example, contribute to the description of the existing physical, biological and human environments, natural cycles, resource distribution and abundance, long and short- term trends, and the use of lands and land and water resources. It may also contribute to project siting and design, identification of issues, the evaluation of potential effects, and their significance, the effectiveness of proposed mitigation, cumulative effects and the consideration of follow-up and monitoring programs. Certain issues relevant to the review process are firmly grounded in traditional knowledge, such as harvesting, cultural well-being, land use, heritage resources, and others. Although the basis for traditional knowledge and science-based knowledge can differ, they may on their own or together, contribute to the understanding of these issues. - 5 - January 2009 Guidelines for the Preparation of the EIS The joint review panel will promote and facilitate the contribution of traditional knowledge to the review process. It is recognized that approaches to traditional knowledge, customs and protocols may differ among Aboriginal communities and persons with respect to the use, management and protection of this knowledge. The joint review panel will consider the views of communities and traditional knowledge holders during the joint review process and determine which information should be kept confidential. The proponent must incorporate into the EIS the traditional knowledge to which it has access or that it may reasonably be expected to acquire through appropriate due diligence, in keeping with appropriate ethical standards and without breaching obligations of confidentiality. Alternatively,the proponent may facilitate the presentation of such knowledge by persons and parties having access to this information to the joint review panel during the course of the review. If requested by an Aboriginal people,the proponent should cooperate with that people to develop a mutually agreed-upon arrangement for the Aboriginal people themselves to provide traditional knowledge throughout the joint review process, either by themselves or in collaboration with the proponent. 2.4 Sustainable Development Sustainable development seeks to meet the needs of present generations without compromising the ability of future generations to meet their own needs. Environmental assessment provides a systematic approach for identifying, predicting and evaluating the potential environmental effects of projects before decisions are made. In addition, environmental assessment provides the means to identify mitigation measures for adverse effects. Environmental assessment promotes sustainable development and contributes to decision-making that can ultimately provide net ecological, economic and social benefits to society. A project that is supportive of sustainable development must strive to integrate the objective of net ecological, economic and social benefits to society in the planning and decision-making process and must incorporate citizen participation. T he project, including its alternative means, must take into account the relations and interactions among the various components of the ecosystems and meeting the needs of the population. The proponent must include in the EIS consideration of the extent to which the Project contributes to sustainable development. In doing so, the proponent must consider, in particular: • the extent to which biological diversity may be affected by the project; and • the capacity of renewable resources that are likely to be significantly affected by the Project to meet the needs of present and future generations. 2.5 Precautionary Approach One of the purposes of environmental assessment is to ensure that projects are considered in a careful and precautionary manner before authorities take action in connection with them, in order to ensure that such projects do not cause significant adverse environmental - 6 - 1 January 2009 Guidelines for the Preparation of the EIS effects. The precautionary approach recognizes that a lack of full scientific certainty should not be used as a reason to postpone decisions where there is a potential for high level of risk or irreversible harm. The document"A Framework for the Application of Precaution in Science-based Decision Making About Risk" [Reference 1] sets out guiding principles for the application of precaution to science-based decision making. The framework aids the decision-maker to assess whether precautionary decision-making is in keeping with Canadians' social, environmental and economic values and priorities. The proponent must indicate how the precautionary principle was considered in the design of the Project in at least the following ways: • demonstrate that all aspects of the project have been examined and planned in a careful and precautionary manner in order to ensure that they do not cause serious or irreversible damage to the environment and/or the health of current or future human generations; • outline and justify the assumptions made about the effects of all aspects of the project and the approaches to minimize these effects; • evaluate and compare alternative means of carrying out the Project in light of risk avoidance, adaptive management capacity and preparation for surprise; • demonstrate that in designing and operating the project, priority has been and will be given to strategies that avoid the creation of adverse effects; I • provide that contingency plans explicitly address worst-case scenarios and include risk assessments and evaluations of the degree of uncertainty; • identify any proposed follow-up and monitoring activities, particularly in areas where scientific uncertainty exists in the prediction of effects; and • present public views on the acceptability of all of the above. In doing so,the proponent shall consider the guiding principles set out in the "Framework for the Application of Precaution in Science-based Decision Making About Risk". 2.6 Study Strategy and Methodology The proponent is expected to observe the intent of the EIS guidelines and to identify all environmental effects that are likely to arise from the project(including situations not explicitly identified in these guidelines), the mitigation measures that will be applied, and the significance of any residual adverse effects. It is possible that the EIS guidelines include matters that, in the judgement of the proponent, are not relevant or significant to the project. If such matters are omitted from the EIS,they must be clearly identified in the EIS with appropriate justification so that the public and other interested parties have an opportunity to comment on this judgement. Where the joint review panel disagrees with the proponent's decision, it may require the proponent to provide additional information. - 7- January 2009 Guidelines for the Preparation of the EIS The proponent must explain and justify methods used to predict impacts of the project on each valued ecosystem component(VEC), which includes biophysical and socio- economic components, the interactions among these components and on the relations of these components within the environment. The information presented must be substantiated. In particular, the proponent must describe how the VECs were selected and what methods were used to predict and assess the adverse environmental effects of the project on these components. The value of a component not only relates to its role in the ecosystem, but also to the value placed on it by humans. The culture and way of life of the people using the area affected by the project may themselves be considered VECs. In describing methods,the proponent must document how it used scientific, engineering, traditional and other knowledge to reach its conclusions. Assumptions must be clearly identified and justified. All data,models and studies must be documented such that the analyses are transparent and reproducible. All data collection methods must be specified. The uncertainty, reliability and sensitivity of models used to reach conclusions must be indicated. The sections in the EIS regarding existing environment and potential adverse environmental effects predictions and assessment must be prepared using best available information and methods, to the highest standards in the relevant subject area. All conclusions must be substantiated. The EIS must identify all significant gaps in knowledge and understanding where they are relevant to key conclusions presented in the EIS. The steps to be taken by the proponent to address these gaps must also be identified. Where the conclusions drawn from scientific and technical knowledge are inconsistent with the conclusions drawn from traditional knowledge, the EIS must contain a balanced presentation of the issues and a statement of the proponent's conclusions. 2.7 Use of Existing Information In preparing the EIS, the proponent is encouraged to make use of existing information relevant to the project. When relying on existing information to meet the requirements of various sections of the EIS guidelines,the proponent must either include the information directly in the EIS or clearly direct(e.g., through cross-referencing)the joint review panel to where it may obtain the information. When relying on existing information, the proponent must also comment on how representative the data are, clearly separate factual lines of evidence from inference, and state any limitations on the inferences or conclusions that can be drawn from them according to the criteria for information quality set out in section 2.6 of the EIS Guidelines. For instance: • assumptions must be clearly identified and justified; • all data, models and studies must be documented such that the analyses are transparent and reproducible; • the uncertainty, reliability and sensitivity of models used to reach conclusions must be indicated; • conclusions must be substantiated; and • the studies must be prepared using best available information and methods, to recognized standards of good practice in the relevant subject area. - 8 - January 2009 Guidelines for the Preparation of the EIS 3. PRESENTATION OF THE EIS For clarity and ease of reference,the EIS should be presented in the same order as the EIS guidelines. However, in certain sections of the EIS,the proponent may decide that the information is better presented following a different sequence. The EIS must include a guide that cross-references the EIS guidelines with the EIS so that points raised in the EIS guidelines are easily located in the EIS. In the interest of brevity,the EIS should make reference to, rather than repeat, information that has already been presented in other sections of the document. A key subject index would also be useful and should reference locations in the text by volume, section and sub-section. The names of the proponent's key personnel and/or contractors and sub-contractors responsible for preparing the EIS must be listed. Supporting documentation can be provided in separate volumes, and referenced by volume, section and page in the text of the EIS. The proponent must submit the EIS and all supporting documents in hard copy and in an electronic format to facilitate intereet access and for record keeping and review. The proponent must present the EIS in the clearest language possible. However, where the complexity of the issues addressed requires the use of technical language, a glossary defining technical words and acronyms must be included. The proponent should provide charts, diagrams and maps wherever useful to clarify the text, including perspective drawings that clearly convey what the developed project site would look like. Information required to support the application for the Licence to Prepare site must clearly cross-reference the EIS where appropriate. 3.1 Environmental Impact Statement Summary The proponent must prepare a plain language summary of the EIS that provides the reader with a concise but complete overview of the EIS. 4. SCOPE The following section outlines the scope of the project and the factors to be assessed. 4.1 Scope of the Project Pursuant to subsections 15(1)(b) and 15(3)(b) of the Canadian Environmental Assessment Act,the Minister of the Environment is proposing that the scope of the project include the site preparation, construction, operation, decommissioning and abandonment of the project components and activities proposed by OPG as described in "OPG New Build Project Environmental Assessment—Project Description" [Reference 2]. - 9 - January 2009 Guidelines for the Preparation of the EIS The scope of the Darlington NNPP Project includes site preparation, construction, operation, decommissioning and abandonment of up to four new nuclear power reactors for the production of up to 4,800 megawatts of electrical generating capacity for supply to the Ontario grid. Operations would involve activities required to operate and maintain the Darlington NNPP, including management of all conventional and radioactive wastes. The Province of Ontario is considering a range of reactor designs. It is anticipated that each new reactor constructed would have an approximate 60-year operating life and could include a mid-life refurbishment depending on the reactor design technology chosen by the proponent. The project includes up to four units, consisting of the following principal components: • Reactor Building—contains the reactor vessel, fuel handling system, heat transport system, moderator, reactivity control mechanisms, shut down systems and containment; and • Turbine Generator Powerhouse—contains the turbines, generators and related systems and structures that convert steam from the operation into electrical energy. The project also includes the following shared facilities between reactors: • Condenser Cooling Systems and Structures: including cooling towers or the once- through cooling system with all of its associated submerged intake, forebay and discharge systems; • Low and Intermediate Level Waste Management Facility (on or off-site); and • Expansion of the existing Darlington Waste Management Facility for storage of used nuclear fuel or construction of a new facility. Ancillary activities that may be required include the transportation of low and intermediate level waste to be managed offsite at an appropriate licensed facility. The following describes activities expected to be undertaken: Preparation Phase: Site preparation includes the following activities needed to construct the new nuclear reactors and associated physical works listed above: • construction and enhancing of on-site roads,which would connect to local roads and provincial highway 401 as appropriate,to provide access to the site; • re-establishment of a rail line spur if required; • construction of a wharf if required; • construction of parking lots and laydown areas; • construction site fencing; • removal of existing trees and vegetation if necessary; - 10 - i January 2009 Guidelines for the Preparation of the EIS • shoreline stabilization and lake infilling, coffer dam construction; • realigning intermittent stream channels and draining some wet areas across site; • earthmoving activities including cutting, filling, grading construction areas, creating berms and stockpiles; • installation of necessary infrastructure such as power,water main, sewage systems, surface water drainage, storm water sewers; and • bedrock excavation for foundations. Construction: Construction includes the following activities needed to construct the new nuclear reactors and associated physical works listed above: • installation of bedrock piles; • expansion of the switchyard; • receipt and management of materials and components for installation; • installation of the intake and outfall to Lake Ontario; • construction of cooling towers if required; • construction of the reactors, power house buildings, structures, and systems; • removal of construction debris to a licensed facility, including any hazardous waste created during construction; • testing and commissioning of systems and structures; • landscaping; and • final site fencing and security system installation. Operation and Maintenance Phase: The operation phase includes all of the work and activities that occur during routine operation and maintenance of the new nuclear reactors and associated buildings, structures and systems. This phase consists of the 60-year timeframe over which the nuclear power station is expected to generate electricity. Commissioning a new nuclear power plant consists of the following general activities: verification and qualification of systems, pressure testing of vessels, fuelling of reactor; pressure testing of containment building, approach to criticality, approach to full power; testing of the reactor core physics, verification of control systems, connection to the grid, operational testing and full power operation. Some commissioning activities, specifically those that take place without fuel in the reactor core, may be authorized during the construction phase. Following commissioning, the activities to be undertaken include the operation and maintenance of plant systems including nuclear steam supply systems,turbine generator and feedwater systems, electrical power systems, nuclear safety systems, ancillary systems, systems for maintaining facility security, activities associated with the maintenance program, materials handling systems, solid waste handling systems and administration and support systems. - 11 - January 2009 Guidelines for the Preparation of the EIS Operation and maintenance activities can be categorized as follows: • operation of equipment for production of electricity; • verification, sampling,testing and maintenance during operation at power; • maintenance,repairs, cleaning, and decontamination during planned shutdowns and outages; • on-site transportation and handling of fuel, including defuelling and refuelling of the reactor; • management of low and intermediate waste and spent fuel waste within the reactor building, and the transfer of wastes and used fuel for interim or long-term storage; • management of hazardous substances and hazardous waste; and activities relating to environmental protection and radiation protection programs; and • activities required to achieve a safe state of closure prior to decommissioning. During this phase,the assessment would include consideration of the effects associated with mid-life refurbishment for CANDU-type reactors as well as the effects relating to outages to refuel or refurbish boiling water and pressurized water-type reactors. Decommissioning and Abandonment Phase: Decommissioning activities will commence after the last reactor has permanently ceased operation, all the fuel has been transferred out of the reactor to storage, and the reactor drained and dried. Decommissioning will then begin with a period of safe storage activities to allow the radioactivity of reactor components to decrease. Decommissioning may commence with a period of safe storage activities to allow the radioactivity of reactor components to decrease. Decommissioning activities can be conceptually summarized as follows: transfer of fuel and associated wastes to interim storage; decontamination of plant; flush purging of equipment and systems; removal of surface decontamination of facilities or equipment; dismantling and removal of equipment and systems; demolition of building;and site restoration. Few activities are expected to be carried out for the abandonment phase of the project, since the purpose of this phase is to move from the achieved"end-state"of the decommissioning phase to the abandonment phase, which is basically an"unlicensed state". The activities related to this phase are basically to provide the results of the decommissioning and the results of the environmental monitoring programs to demonstrate that the"site"can be made available for re-use and will no longer be under CNSC regulatory oversight. 4.2 Factors to be considered in the EIS The Minister of the Environment is proposing that the following factors be considered in the EIS in order to adequately understand and assess the potential effects of the project. 12 January 2009 Guidelines for the Preparation of the EIS a. the environmental effects of the project, including the environmental effects of malfunctions, accidents or malevolent acts that may occur in connection with the project and any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out; b. the significance of the effects referred to in (a); c. comments that are received during the environmental assessment; d. measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the project; e. purpose of the project; f. need for the project; g. alternatives to the project; h. alternative means of carrying out the project that are technically and economically feasible and the environmental effects of any such alternative means; i. measures to enhance any beneficial environmental effects j. the requirements of a follow-up program in respect of the project; k. the capacity of renewable resources that are likely to be significantly affected by the project to meet the needs of the present and those of the future; and 1. consideration of community knowledge and Aboriginal traditional knowledge. 13 - January 2009 Guidelines for the Preparation of the EIS PART II- CONTENT OF THE EIS Part II of the EIS guidelines provides specific instructions for the content of each section in the EIS. The EIS as a whole must reflect the Guiding Principles in Section 2. 5. CONTEXT This section must orient the reader to the EIS.by briefly introducing the geographic setting, the project,the underlying rationale for the project, the proponent, the federal joint review panel process and the content and format of the EIS. 5.1 Setting This section must provide a concise description of the geographic setting in which the project is proposed to be constructed, describing its proximity to Lake Ontario, any parks or ecologically significant areas, and the Municipality of Clarington. This section must also outline current use of lands, waters and resources, including those used for traditional purposes by Aboriginal persons that may be affected by the project and those lands, waters and resources related to established or asserted Aboriginal rights. Maps at appropriate scales to illustrate the regional setting must be included. The description must be focused on those aspects of the environment important for understanding the potential environmental effects of the Project. A brief description of current regional land and water uses is required to integrate the natural and human elements of the environment in order to explain the interrelationships between the physical and biological aspects and the people and their communities. 5.2 Project Overview and Purpose The proponent will briefly summarize the Project, its purpose, location, scale, components, activities, scheduling and costs. A more detailed description of the project is provided for in Section 8. 5.3 Proponent This section must introduce readers to OPG with summary information on the nature of the management structure and organizational accountability for the: • design, construction, operation and modification, and decommissioning of the project; • implementation of environmental mitigation measures and environmental monitoring; and • management of potential adverse environmental effects. 5.4 Environmental Assessment and Regulatory Process and Approvals For the purposes of the environmental assessment, the proponent must: - 14 - i January 2009 Guidelines for the Preparation of the EIS • identify the planning context for the environmental assessment of the project; • discuss government policies, regulations, and land use plans that have a bearing on the project; • identify the requirements for the environmental assessment under the Canadian Environmental Assessment Act, the Nuclear Safety and Control Act and Regulations,the Fisheries Act and the Navigable Waters Protection Act; • summarize and discuss the approach, including the role of regulatory bodies, to ensure compliance with existing federal and provincial environmental legislation such as the Nuclear Safety and Control Act, Migratory Birds Convention Act, Fisheries Act,Species at Risk Act, Canadian Environmental Protection Act, 1999, the Lakes and Rivers Improvement Act and the Endangered Species Act; • summarize the main steps in the environmental assessment process and the main approvals required to undertake the project; and • describe the role of the EIS in the overall environmental assessment and regulatory process. The joint review panel will also be collecting information and evidence to support OPG's application for a Licence to Prepare Site for a Class 1 Nuclear Facility, in accordance with the Nuclear Safety and Control Act and its regulations. These requirements are described in Appendix 2 of these guidelines. 5.5 International Agreements The proponent must summarize and discuss in the EIS the implications of any applicable international agreements, designations, or action plans, their implications and relationships to the planning and regulatory processes described in Section 5.4, and how they may influence the project or its environmental effects. The location of the facility on the shores of a transboundary watershed requires specific attention be paid to the Canada-U.S. Air Quality Agreement,the Great Lakes Water Quality Agreement and other such binational treaties and agreements. 6. PUBLIC PARTICIPATION Involvement of Aboriginal peoples, government agencies, non-governmental organizations, and other interested parties is a central objective of the overall review process. In preparing the EIS,the proponent must demonstrate how it has engaged(i.e., shared information with, and gathered input from) interested parties that may be affected or have an interest in the project, in keeping with the Guiding Principles in Section 2 of the Guidelines. The following key issues must be summarized in the EIS: • the types of support provided to communities, organizations and individuals involved in the public participation process. • the role of public engagement in identifying VECs, issues, effect prediction and mitigation. - 15 - January 2009 Guidelines for the Preparation of the EIS • an explanation of how the results of that engagement influenced the design of the project; and • a description of the principles and methods that will be employed to provide information to, obtain input from or otherwise engage communities and groups regarding the project activities over the lifespan of the project. 6.1 Aboriginal People The EIS must describe the proponent's involvement of any Aboriginal people that may be affected by the project, especially those Aboriginal people claiming Aboriginal rights, title or established treaty rights at the location or in the vicinity of the project. This description must include a summary of the history of the proponent's relationship with Aboriginal people with respect to the OPG Darlington Nuclear Site in general and the project in specific. The EIS must describe the objectives of and the methods used for Aboriginal group engagement, issues or concerns raised through such engagement and any details not otherwise subject to confidentiality agreements, including a summary of the discussions,paper and electronic correspondence and meetings held. Details may include date and time, agenda, summary of discussions and a description of how the proponent has addressed the issues or concerns raised by Aboriginal people. 6.2 Government Agencies The EIS must describe the proponent's involvement of provincial and federal government ministries, departments or agencies and local governments which should include the Municipality of Clarington and other communities in Durham Region, Peterborough County, Simcoe County and Northumberland County as appropriate. The EIS must describe the objectives of such engagements,the methods used, issues raised during such engagements and the ways in which the proponent has addressed these issues. 6.3 Stakeholders The EIS must describe the proponent's involvement of stakeholders (e.g., local businesses, neighbouring residences, cottagers, outdoor recreational interests and environmental non-government organizations). The EIS must describe the objectives of such engagement,the methods used,the issues raised and the ways in which the proponent has addressed these issues. 6.4 Other Public Participation The EIS must describe any other public engagement undertaken by the proponent prior to submitting the EIS. The Canadian Environmental Assessment Act does not exclude the public outside of Canada,thus the EIS should describe any public participation opportunities for non-Canadians. This description must identify the objectives of such engagement, outline the methods used, and summarize the issues raised by the public, and the ways in which the proponent has addressed these issues. 16 January 2009 Guidelines for the Preparation of the EIS 7. PROJECT JUSTIFICATION 7.1 Purpose and Need for the Project The proponent must clearly describe the need for the proposed new nuclear power plant. This description must define the problem or opportunity the project is intending to solve or satisfy and should establish the fundamental justification or rationale for the project. The proponent must describe the purpose of the project by defining what is to be achieved by carrying out the project. The"need for" and"purpose of the project should be established from the perspective of the project proponent and provide the context for the consideration of alternatives in Sections 7.2 and 7.3 below. 7.2 Alternatives to the Project An analysis of alternatives to the project must describe functionally different ways to meet the project's need and achieve the project's purpose from the perspective of the proponent. This section must therefore identify and discuss other technically and economically feasible methods of producing electricity other than the construction and operation of the OPG Darlington NNPP that are within the control and/or interests of OPG. As an assessment of provincial energy policy is not within the terms of reference of this joint review panel, the alternatives to the project need not include alternatives that are contrary to Ontario's formal plans or directives. However,the EIS must explain where this rationale has been applied to exclude consideration of possible alternatives to the project. For each identified alternative to the Darlington NNPP that are within the control and/or interests of OPG,this section of the EIS must explain how the proponent developed the criteria to identify the major environmental, economic and technical costs and benefits of those alternatives, and how the proponent identified the preferred project based on the relative consideration of the environmental, economic and technical benefits and costs. This must be done to a level of detail which is sufficient to allow the joint review panel and the public to compare the project with its alternatives. 7.3 Alternative Means of Carrying out the Project The EIS must identify and describe alternative means to carry out the project that are, from the perspective of the proponent, technically and economically feasible. The EIS must also describe the environmental effects of each alternative means. In describing the preferred means, the EIS should identify the relative consideration of environmental effects, and technical and economic feasibility. The criteria used to identify alternative means as unacceptable, and how these criteria were applied, must be described, as must the criteria used to examine the environmental effects of each remaining alternative means to identify the preferred alternative. 17- January 2009 Guidelines for the Preparation of the EIS To the extent that these alternative means are feasible for the proponent,this may include the following: • siting of new nuclear reactors in different locations within the existing site; • siting of new nuclear reactors in locations outside the existing site; • switchyard design; • reactor design technology, taking into consideration megawatt electrical MWe output, moderator, coolant, and fuel enrichment; • condenser cooling water system(cooling towers or intake/discharge of lake water through underwater tunnels, including direct and indirect once-through systems and recirculating systems consisting of wet, dry or hybrid system cooling towers with natural or mechanical air circulation); • waste management strategies for low and intermediate level radioactive waste and used fuel; and • timing options for various components and phases of the project. 8. DESCRIPTION OF THE PROJECT The project description must address all phases of the project, within the scope outlined in Section 4, in sufficient detail to allow the assessment of potential adverse environmental effects and take into account public concerns about the project. The proponent must describe the project as it is planned to proceed from site preparation through to construction, operation and maintenance (including any potential modifications or refurbishment that may be required during operation), decommissioning and abandonment. The description must include a timeline for all phases of the project, including preliminary decommissioning and abandonment plans. Where specific codes of practice, guidelines and policies apply to items to be addressed,those documents must be cited and may be included as appendices to the EIS. The following information addressing the construction and operational phases of the project must be provided in summary form; where applicable, reference may be made to more detailed information. 8.1 General Information and Design Characteristics Information to be provided in the EIS must include: location of the project; • general description of all reactor design technologies being considered, including associated buildings and infrastructure; • process and timetable for tender, selection and construction of the proposed reactor, and anticipated operational life; • detailed siting requirements for the proposed new reactors, including any relevant criteria endorsed by the CNSC, and whether the chosen site meets the criteria of CNSC Regulatory Document RD-346"Site Evaluation for New Nuclear 18 - January 2009 Guidelines for the Preparation of the EIS Reactors" [Reference 3] and consideration of the applicability of any local, regional and provincial land use or urban development policies, programs and plans to the proposal; • description of the physical requirements for the proposal, including existing and proposed exclusion zones and the protective zone, general reactor requirements, including for health and safety, nuclear safeguards and security, supply of fuel, spent fuel management and waste management and infrastructure requirements, including roads and car parking, other buildings, water service,wastewater services, electricity, gas, and telecommunications; • specific locations of proposed reactors and of associated buildings and infrastructure; • infrastructure requirements and facilities for the site preparation, construction, operation and maintenance of the proposed facility; and • a description of the relevant organizational and management structure, and staff qualification requirements with emphasis on safety and environmental management programs. For each reactor design being considered, include information on the: • basic configuration, layout, shape, size, design and operation of the facility; • performance specifications, design philosophy, reactor type, plant configuration, and all structures, systems and components important to safety; • safety characteristics; • planned operational life; • description of any special commissioning or'start-up'procedures and requirements; • requirements for refurbishment; • ageing and wear issues and management of these issues, where relevant to future environmental performance and reliability; • physical security systems (excluding prescribed information), designed specifically to isolate the project from the surrounding environment, or to prevent, halt or mitigate the progress or results of malfunctions, accidents or malevolent acts; • engineered and administrative controls, including the use of an approved margin of sub-criticality for safety, which assure that the entire(out of reactor)process will be sub-critical under normal conditions and credible abnormal conditions— accidents or accident sequences—that have a frequency of occurrence equal to or more than one in a million years; • stored inventories of radioactive and other hazardous materials, including locations and storage methods, and criticality control plans; • sources, types and quantities of radioactive and non-radioactive waste, including hazardous waste, predicted to be generated; - 19 - January 2009 Guidelines for the Preparation of the EIS • processes and facilities for the management of radioactive and non-radioactive waste, including low, intermediate and spent fuel waste, conventional, sanitary and hazardous wastes, to be generated by the project, including processes such as collection, handling, storage and transportation; • sources and characteristics of any fire hazards; • sources and characteristics of any noise, odour, dust and other likely nuisance effects from the project; and • sources and characteristics of any potential risks(including radiological risks)to workers, the public or the environment from the project. 8.2 Site Preparation The EIS must include a description of permanent or temporary structures that will be constructed to support site preparation. Details of general construction practices, hours of operation and proposed construction schedules should also be provided. Under the Nuclear Safety and Control Act's Class I Nuclear Facilities Regulations, a Licence to Prepare Site does not permit physical work activities directly related to construction of nuclear power plant structures, systems and components. Subject to this limitation, the EIS should describe the site preparation phase of the project for the following physical works and associated physical activities: • clearing of vegetation, grubbing, stripping of top soil, grading; • excavating, drilling and blasting; • installing of site services including fencing, exterior lighting and security systems, construction roadways, parking lots and of an area for the management of construction waste; • installing coffer dams, dewatering, blasting and infilling part of Lake Ontario including the placement of fill and identification of the types of fill proposed for the infilling and shoreline stabilization; • constructing the docking facility; • trenching for the installation of service pipelines; • installing temporary construction support facilities (warehouses, concrete mixing plants); • developing on-site facilities for the storage and management of construction waste; • topsoil and overburden storage areas; • site access roads(including gradient) and linkages to public roadways; • storage areas for hazardous substances and hazardous waste; • watercourse crossings and diversions, including wetland alteration; • visual effect management(e.g., landscaping, screening mounds and plantings, use of existing features, photographic records); • managing potentially contaminated groundwater produced during excavations and surface runoff management; -20 - January 2009 Guidelines for the Preparation of the EIS • description of any work that will be undertaken outside of normal working hours, including a description of the nature of work and of the machinery that will be required; • size of construction workforce; • extent of earthmoving, building demolition/relocation, vegetation clearance and other site preparatory works, including arrangements to minimise unnecessary clearance and disturbance; • construction standards,techniques and site management arrangements, including for on-site storage and handling of construction and other(e.g., fuel, oil) materials; • arrangements for disposal of construction wastes during and following site preparation; • arrangements for storm water and erosion/ sedimentation control; and • risk management(e.g., contingency plans for uncontrolled release of substances, emergency response plans). To enable consideration of OPG's Application for a Licence to Prepare Site by the joint review panel, the proponent must also provide information in accordance with the Nuclear Safety and Control Act and Regulations in support of that application. These requirements are listed in Appendix 2 of these guidelines. 8.3 Construction The proponent must describe all activities to be undertaken during this phase of the project, including timing of work program, duration of construction phase, including lead times, which may include: • blasting/dredging and redistribution or removal of substrate material associated with construction of the intake/discharge tunnels; • installation of pilings; • construction of the switchyard; • construction of cooling towers; • noise and dust generation; • disposal of construction wastes during and following construction; • arrangements for storm water and erosion/ sedimentation control and other environmental protection activities; • continued installation of site services including plant security fencing and security systems; • installation of towers and transmission lines between the power block and the switchyard and between the switchyard and the provincial grid system and other associated switchyard gear; - 21 - January 2009 Guidelines for the Preparation of the EIS • transportation by road or water of building construction materials and associated installation of plant internal components (e.g., reactor components, steam generators, steam supply piping, turbines, electrical power systems, fire protection system,water piping, sewage handling and treatment equipment, lighting); and • post-construction site rehabilitation. This description must include the following: • an identification of any work that will be undertaken outside of normal construction hours, including a description of the nature of work and of the machinery that will be required; • the size of construction workforce; • the extent of earthmoving, building demolition/relocation, vegetation clearance and other site preparatory works, including arrangements to minimise unnecessary clearance and disturbance; and • the application of construction standards,techniques and site management arrangements, including for on-site storage and handling of construction and other (e.g., fuel, oil)materials. 8.4 Operation and Maintenance The proponent should describe all activities to be undertaken within this phase of the project, including commissioning activities, approach to full power and planned maintenance outages. Material management plans must also be described, including issues relating to transportation such as mode and route of transport,type of material and quantities to be transported. Description of the operation and maintenance phase and timeframe of the project and of the associated activities should include, but are not limited to: • the commissioning activities such as general verification of equipment and systems, fuelling of reactor; • pressure testing of containment building, approach to criticality and eventually to full power and connection to the grid; • the operation and maintenance activities required for systems such as the nuclear steam supply system,turbine generator and feed water systems, cooling water systems, electrical power systems, nuclear safety systems, ancillary systems, systems for operating and maintaining facility security, activities associated with the maintenance program, materials handling systems, solid waste handling systems and administration and support systems; • activities associated with mid-life refurbishment for CANDU-type reactors as well as activities relating to outages to refuel or for the refurbishment of light water reactors; • operation of equipment for production of electricity; 22 January 2009 Guidelines for the Preparation of the EIS • verification, sampling, testing and maintenance during operation at power; • maintenance, repairs, cleaning, and decontamination during planned shutdowns and outages; • fuelling and refuelling of the reactor; management of low and intermediate waste and used fuel, including transfer to interim or long-term waste storage facilities; • past events that are relevant to the assessment of future environmental performance and reliability: • the sources, quantities and points of release from routine radiological and non- radiological emissions and effluents, including thermal (heat)releases; • the area of exposure to the physical effects of the discharge jet and intake suction; • where applicable, characterization of the waste, including estimated activity in becquerels, that will be generated and stored at each of the waste management areas as a result of operation and any future refurbishment; • predictions of future emissions and effluents from the project under normal operating conditions; • standard design features and key operational procedures relevant to protection of workers, the public and the environment relating to the project, including the nuclear criticality safety program; • operations workforce, composition of workforce and any infrastructure requirements; • systems for operating and maintaining the facility security program; • emission and effluent control, treatment and monitoring and environmental monitoring; • non-radioactive waste handling, storage and disposal; and • activities relating to environmental protection and radiation protection. The end of operational activities to achieve a safe state of closure prior to decommissioning should include, but are not limited to: • removal of fuel from reactor; and • draining and drying of reactor 8.5 Modifications The proponent must describe the management approach to, and conceptual plans for, potential modifications to the project, including expansion or early discontinuation. The proponent must specify the conditions or potential risks which would necessitate modifications to the project. The proposed process to follow when proposing modifications to the project should be described and include a description of plans for informing the public. 23 January 2009 Guidelines for the Preparation of the EIS 8.6 Decommissioning and Abandonment A preliminary decommissioning plan for the facility must be included in the EIS. The proponent should refer to CNSC Guide G-219, "Decommissioning Planning for Licensed Activities" [Reference 4] for more details. The discussion should identify the preferred decommissioning strategy, including a justification of why this is the preferred strategy. It must also include end-state objectives, the major decontamination, disassembly and remediation steps; the approximate quantities and types of waste generated; and an overview of the principal hazards and protection strategies envisioned for decommissioning. The description of decommissioning activities (e.g., planning envelopes and work plans) can be provided at a conceptual level, but this description must include: • transfer of fuel and associated wastes to interim or long-term licensed storage facilities; • security measures for alerting against sabotage to hazardous radioactive waste during interim or long term storage • any flushing/purging of equipment and systems; • removal of surface decontamination from facilities or equipment; • dismantling and removal of equipment and systems: • demolition of buildings; • management and disposal of conventional, radioactive and other hazardous waste arising from decommissioning; and, • remediation and restoration of the site. 8.7 Waste and Used Fuel Management In addition to the project-phase specific requirements for waste provided in the preceding subsections,the EIS must present the proponent's proposed plan for the disposition of all radioactive and hazardous wastes and used fuel. The proponent's activities related to the site preparation, construction, operation, decommissioning and abandonment of low and intermediate level waste management facilities, and used fuel storage facilities, must be described. Where this plan identifies that radioactive or hazardous wastes or used fuel are expected to be managed by an organization other than the proponent, the EIS must describe at a conceptual level the methods that can be used to ensure that these materials are managed in a manner the protects health, safety and the environment. 8.8 Malfunctions,Accidents and Malevolent Acts Information on accidents and malfunctions, including intentional malevolent acts are necessary to permit consideration of relevant environmental effects in the environmental assessment. A summary of information on malfunctions and accidents should be presented in this section of the EIS. A separate section of the EIS should provide more -24 - January 2009 Guidelines for the Preparation of the EIS details regarding the information requirements relating to accidents, malfunctions and malevolent acts as per Section 12.0 of these guidelines. 8.9 Environmental Protection,Policies and Procedures Paragraph 3(g) of the Class I Nuclear Facilities Regulations stipulates that application for a Licence to Prepare Site shall contain the proposed environmental protection policies and procedures. CNSC Regulatory Standard S-296, "Environmental Protection Policies, Programs and Procedures at Class I Nuclear Facilities and Uranium Mines and Mills" (March 2006) [Reference 5] and Regulatory Guide G-296, "Developing Environmental Protection Policies, Programs and Procedures at Class I Nuclear Facilities and Uranium Mines and Mills"(March 2006) [Reference 6] provide more information regarding these requirements. The fundamental direction of these regulatory documents is towards the establishment, implementation and maintenance of an Environmental Management System(EMS)by the proponent that meets the requirements of ISO 14001-2004 "Environmental Management Systems—Requirements with Guidance for Use" in the context of Canadian environmental protection policy and regulation and the specific environmental protection requirements of the Nuclear Safety and Control Act and its regulations. The proponent must therefore submit its proposed environmental protection policies and procedures(i.e., EMS documentation) and demonstrate that the EMS will carry forward the results of the environmental assessment so that it covers the Site Preparation, Construction and Operational phases of the project. The EIS should describe how the mitigation measures described through Sections 11 through 14 of this document, and the Follow-up Program described in Section 15 of this document would be integrated into the EMS. 9. ENVIRONMENTAL ASSESSMENT BOUNDARIES Scoping establishes the boundaries of the environmental assessment and focuses the assessment on relevant issues and concerns. By defining the spatial and temporal boundaries, a frame of reference for identifying and assessing the environmental effects associated with the OPG Darlington NNPP Project will be established. Different boundaries may be appropriate for each VEC. A description of the boundaries of the proposed project in a regional context showing existing and planned future land use, current infrastructure and proposed improvements to these infrastructure, including transportation (all modes),power distribution corridors and lines, urban areas and water supplies(individual and community), must be provided. A description of any traditional land use any established or asserted Aboriginal rights, Aboriginal title or treaty rights from Aboriginal people within the wider regional context should be provided. Sensitive areas including wetlands, critical habitats as defined under the Species at Risk Act and archaeological sites found within the regional context must also be described. - 25 - I January 2009 Guidelines for the Preparation of the EIS 9.1 Spatial Boundaries and Scale In determining the spatial boundaries to be used in assessing the potential adverse and beneficial environmental effects, the proponent must consider, but not be limited to,the following criteria: a. the physical extent of the proposed project, including any offsite facilities or activities; b. the extent of aquatic and terrestrial ecosystems potentially affected by the project; c. the extent of potential effects arising from noise, light and atmospheric emissions; d. the extent to which traditional land use, asserted or established Aboriginal rights, Aboriginal title or treaty rights could potentially be affected by the project; e, lands used for residential, commercial, industrial, recreational, cultural, and aesthetic purposes by communities whose areas include the physical extent of the project; and f. the size,nature and location of past, present and reasonably foreseeable projects and activities which could interact with items b), c), d) and e). These boundaries must also indicate the range of appropriate scales at which particular baseline descriptions and the assessment of environmental effects are presented. The proponent is not required to provide a comprehensive baseline description of the environment at each scale, but must provide sufficient detail to address the relevant environmental effects of the project and the alternative means. The EIS must contain a justification and rationale for all boundaries and scales chosen. The geographic study areas for the EIS must encompass the areas of the environment that can reasonably be expected to be affected by the project, or which may be relevant to the assessment of cumulative environmental effects. Study areas must encompass all relevant components of the environment, including people, non-human biota, land,water, air and other aspects of the natural and human environment, notably, current use of land and resources by Aboriginal persons for traditional purposes. Study boundaries must be defined taking into account traditional knowledge, ecological, technical, social and political considerations. The following geographic study areas should serve as the basis developing project-and effect-specific study areas: • Site Study Area: the Site Study Area includes the facilities, buildings and infrastructure at the OPG Nuclear Site, including the existing licensed exclusion zone for the site on land and within Lake Ontario, and particularly the property where the OPG Darlington NNPP is proposed. • Local Study Area: the Local Study Area is defined as that area existing outside the Site Study Area boundary, where there is a reasonable potential for direct effects on the environment from any phase of the project, either through normal activities or from possible accidents, malfunctions or malevolent acts. The Local Study Area should include all of the OPG Nuclear Site and the lands within the - 26 - January 2009 Guidelines for the Preparation of the EIS Municipality of Clarington closest to it, as well as the area of Lake Ontario adjacent to the facility. The boundaries must change if appropriate following an assessment of the spatial extent of potential effects. • Regional Study Area: the Regional Study Area is defined as the area within which there is the potential for cumulative biophysical and socio-economic effects. This area includes lands, communities and portions of Lake Ontario around the OPG Nuclear Site that may be relevant to the assessment of any wider-spread direct and indirect effects of the project. 9.2 Temporal Boundaries In characterizing the environmental effects of the project, the proponent must consider the current baseline environment and environmental trends within the study area. The description of the existing baseline and the environmental trends should include a consideration of past projects and activities carried out by the proponent and/or others within the regional study area. In describing and predicting the environmental effects of the project, the proponent must cover the period from the start of any site preparation activity associated with the project through construction, operation, including maintenance and repairs, and refurbishment, where applicable, and eventual decommissioning and abandonment. In assessing cumulative environmental effects within the study area, the proponent must consider the effects of the project in combination with other past, present and future projects that are either"certain" or"reasonably foreseeable"as defined in CEAA's "Addressing Cumulative Environmental Effects under the Canadian Environmental Assessment Act" [Reference 7]. As is the case for the determination of spatial boundaries, the temporal boundaries must indicate the range of appropriate scales at which particular baseline descriptions and the assessment of environmental effects are presented. At a minimum, the assessment must include the period of time during which the maximum effect is predicted to occur. "Maximum"refers to the greatest change from baseline conditions to what is predicted and should be bounding across reactor types. The approach taken to determine the temporal boundary of assessment should take into account the following elements: • hazardous lifetime of the contaminants, including those associated with waste and used fuel, or with releases to the environment during both normal operation and postulated accidents, malfunctions and malevolent acts; • duration of the operational period; • design life of engineered barriers; • duration of both active and passive institutional controls; and • frequency and duration of natural events and human-induced environmental changes (e.g., seismic occurrence, flood, drought, glaciation, climate change). -27- January 2009 Guidelines for the Preparation of the EIS 9.3 Valued Ecosystem Components The EIS must describe the general criteria used to identify VECs that may be affected by the project. The EIS must identify the methods used to predict and assess the effects of the project on VECs, and explain the criteria used to assign significance ratings to any predicted adverse effects. The spatial and temporal boundaries used in the assessment may vary as appropriate, depending on the VEC. Table I presents a preliminary list of VECs for each environmental component of the assessment. This list of VECs should be modified as appropriate by the proponent in the EIS, following consultations with the public, Aboriginal people, federal and provincial government departments and relevant stakeholders. Table 1: Preliminary List of Valued Ecosystem Components by Environmental Component �„ . s' v Alewife Biological Lake Trout Biological Aquatic Biota/Fish American Eel Biological Community White Sucker Biological Round Whitefish Biolo ical Emerald Shiner Biological Benthic Invertebrates (crayfish) Biological Aquatic Habitat Lake Ontario near shore Physical On site a uatic habitat Physical Lake water circulation Physical Surface Water Lake water temperature Physical Environment Lake water quality Physical Lake shoreline processes Physical Atmospheric Air—particulates Physical Environment Air—chemicals Physical Noise Physical Shallow groundwater quantity and Physical Geology and quality Hydrogeology Deep groundwater quantity and Physical quality Soil Physical Vegetation and Shrub bluff Habitat • Grass of Parnassus Biological • Buffalo Berry Biological Wetlands • Bur-reed Biological • Pond Weed Biological Woodlands -28 - I January 2009 Guidelines for the Preparation of the EIS nh • Cedar Biological • Sugar Maple Biological Migratory bird habitat • Area of woodland habitat Biological Winter raptor feeding and roosting area • Area of meadow Biological • Area of cedar thicket Biological Breeding birds • Yellow Warbler Biological • American Robin Biological Birds Waterfowl • Bufflehead Biological • Mallard Biological Bank Swallow colon • Bank Swallow nest holes Biological Amphibians Amphibians • Northern Leopard Frog Biological • Green Frog Biological • American Toad Biological Terrestrial mammals • Meadow Vole Biological • Eastern Cottontail Biological Mammals • Short-tailed Weasel Biological • Red Fox Biological Aquatic mammals • Muskrat Biological Planned land use Human/Socio-economic Land use and development Human/Socio-economic opportunities off-site Nuclear emergency infrastructure Human/Socio-economic /plans & procedures Land Use and Visual Nuclear emergency Human/Socio-economic Setting infrastructure/equipment Physical features related to the Human/Socio-economic property Major viewpoints Human/Socio-economic Visibility from highway Human/Socio-economic Shoreline visual aesthetics Human/Socio-economic Transportation Road traffic volumes and safety Human/Socio-economic Roads stem operational efficiency Human/Socio-economic Rail traffic volumes and safety Human/Socio-economic - 29 - January 2009 Guidelines for the Preparation of the EIS W UN _ Rails stem operational efficiency Human/Socio-economic Marine traffic volumes and safety Human/Socio-economic Marine system operational Human/Socio-economic efficiency Aboriginal structural remains or Human/Socio-economic subsurface features Resources from the pre-historic era Human/Socio-economic 11,000 B.C.to A.D. 1680 Aboriginal artifacts Human/Socio-economic Physical and Cultural Historic architecture or structural Human/Socio-economic Heritage Resources remains Historic-period artifacts Human/Socio-economic Resources from the historic period Human/Socio-economic cite A.D. 1680 to 1900 Historic cemeteries Human/Socio-economic Agricultural landscapes Human/Socio-economic Population and demographics Human/Socio-economic Income Human/Socio-economic Population and Employment Human/Socio-economic Economic Base Business activity Human/Socio-economic Commercially-zoned properties Human/Socio-economic and/or businesses Taxes Human/Socio-economic Tourism related business Human/Socio-economic Tourism Potential for stigma Human/Socio-economic Municipality's vision, strategies, Human/Socio-economic and plans Agriculture Fanning activity Human/Socio-economic Availability of agricultural land Human/Socio-economic Economic Value of goods and services Human/Socio-economic Development Housing and propeay values Human/Socio-economic Real property values Human/Socio-economic Community Municipal infrastructure and Human/Socio-economic Infrastructure services Type and availability of municipal Human/Socio-economic services Community Services Recreational and community Human/Socio-economic features/resource use Community facilities and activities Human/Socio-economic potentially affected by nuisance effects dust, noise,traffic Recreational fishing Human/Socio-economic Trails and natural areas Human/Socio-economic - 30- January 2009 Guidelines for the Preparation of the EIS Educational facilities Human/Socio-economic Educational facilities Human/Socio-economic Educational services and Human/Socio-economic opportunities Health and safety facilities and Human/Socio-economic services Health-related services and facilities Human/Socio-economic Health care facilities and services Human/Socio-economic Social services Human/Socio-economic Municipal finance and Human/Socio-economic Municipal Finance administration and Administration Municipal tax(and other)revenues Human/Socio-economic and expenditures Members of the public Human/Socio-economic Nearest residents Human/Socio-economic Users of the waterfront trail Human/Socio-economic Users of the soccer fields Human/Socio-economic Human Health and Users of Darlington Provincial Park Human/Socio-economic Radiation and Recreational users of surface water Human/Socio-economic Radioactivity (including Lake Ontario Source drinking water Human/Socio-economic Transportation system safety Human/Socio-economic Workers Human/Socio-economic On-site non-nuclear workers Human/Socio-economic On-site nuclear energy workers Human/Socio-economic Community character Human/Socio-economic Residency tenure Human/Socio-economic Residents and Use and enjoyment of property Human/Socio-economic Communities Potential effects in other Human/Socio-economic environmental components in noise, dust and traffic effects relative to baseline Community characteristics Human/Socio-economic Hunting and fishing for subsistence Human/Socio-economic Fishing, trapping and traditional Human/Socio-economic harvesting and collecting for Aboriginal Interests economic purposes Prehistoric archaeological Human/Socio-economic resources, ceremonial sites, burial mounds or petroglyphs Aboriginal structural remains, Human/Socio-economic artefacts or subsurface features - 31 - January 2009 Guidelines for the Preparation of the EIS 10. EXISTING ENVIRONMENT This section of the EIS must provide a baseline description of the environment, including the components of the existing environment and environmental processes,their interrelations and interactions as well as the variability in these components, processes and interactions over time scales appropriate to this EIS. The proponent's description of the existing environment must be in sufficient detail to permit the identification, assessment and determination of the significance of potentially adverse environmental effects that may be caused by the project, to adequately identify and characterize the beneficial effects of the project, and provide the data necessary to enable effective testing of predictions during the follow-up program. The baseline description must include characterization of environmental conditions resulting from historical and present activities in the local and regional study area(see Section 13 Cumulative Effects). The EIS must compare baseline data with applicable federal, provincial, municipal or other legislative requirements, standards, guidelines or objectives. This description must include, but not necessarily be limited to,those VECs, processes, and interactions that either were identified to be of concern during any workshops or meetings held by the proponent, or that the proponent considers likely to be affected by the project. In doing so, the proponent must indicate to whom these concerns are important and the reasons why, including social, economic, recreational, and aesthetic considerations. The proponent must describe the nature and sensitivity of the area within and surrounding the project and any planned or existing land and water use in the area. The proponent must also indicate the specific geographical areas or ecosystems that are of particular concern, and their relation to the broader regional environment and economy. This includes, but is not limited to, a detailed description of those areas of Lake Ontario potentially affected by the project. Relevant information about the VECs is to be presented graphically to document physical and biological (e.g., home range) characteristics. In describing the physical and biological environment,the proponent must take an ecosystem approach that considers both scientific and traditional knowledge and perspectives regarding ecosystem health and integrity. The proponent must identify and justify the indicators and measures of ecosystem health, social health and integrity it uses. These must be related to project monitoring and follow-up measures. For the biological environment, baseline data in the form of inventories alone is not sufficient for the joint review panel to assess effects. The proponent must consider the resilience of species populations, communities and their habitats. The proponent must summarize all pertinent historical information on the size and geographic extent of animal populations as well as density. Habitat at regional and local scales should be defined in ecological mapping of aquatic and terrestrial vegetation types and species - 32 - January 2009 Guidelines for the Preparation of the EIS (e.g., ecological land classification mapping). Habitat use should be characterized by type of use(e.g., spawning, breeding, migration, feeding, nursery, rearing,wintering), frequency and duration. Emphasis must be on those species, communities and processes identified as VECs. However,the interrelations of these components and their relation to the entire ecosystem and communities of which they are a part must be indicated. The proponent must address issues such as habitat, nutrient and chemical cycles, food chains, productivity,to the extent that they are appropriate to understanding the effect of the project on ecosystem health and integrity. Range and probability of natural variation over time must also be considered. In describing the socio-economic environment, the proponent must provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect the people and communities in the study area in a way that recognizes interrelationships, system functions and vulnerabilities. A description of the rural and urban settings likely to be affected by the project should be provided. Information on existing and projected population densities and distributions in the region, including resident populations and transient populations, must be provided by project phase, and for the entire life of the project. Information such as present and future use of land and resources, including transportation infrastructure, public health infrastructure and services (municipal water treatment for domestic use or human consumption, wastewater treatment, landfill), housing and housing values, commercial fisheries in the area, recreation and tourism should also be provided to the extent that this information is required to assess potential adverse effects of the project on human health and socio- economic conditions in the area, and to assess the effects of the environment on the project. The proponent must also describe any agreements with the surrounding municipalities or other jurisdictions regarding emergency plans or protective actions. Traditional activities carried out by Aboriginal people must be described by the proponent. The proponent should provide information that would include a description of traditional dietary habits and dependence on country foods and harvesting for other purposes, including harvesting of plants for medicinal purposes. The analysis should focus on the identification of potential adverse effects of the project on the ability of future generations of Aboriginal people (up to seven generations)to pursue traditional activities or lifestyle. If the background data have been extrapolated or otherwise manipulated to depict environmental conditions in the study areas, modeling methods and equations must be described and must include calculations of margins of error and other relevant statistical information, such as confidence intervals and possible sources of error. The proponent should refer to CNSC Regulatory Document RD-346, "Site Evaluation for New Nuclear Reactors" [Reference 3], for more examples on the type of information which would be required in this section of the EIS. - 33 - January 2009 Guidelines for the Preparation of the EIS 10.1 Biophysical Environment 10.1.1 Geology and Geomorphology The EIS must describe the bedrock and quaternary/surficial geology, geomorphology (including coastal processes), topography, petrology, geochemistry, hydrogeology and geomechanics for the region and the area that will be disturbed by the Project. The EIS must also examine the global catalogue of earthquakes in stable continental regions, with specific emphasis on eastem Canada. The EIS must describe the structural geology, such as fractures and faults, at the site and within the local and regional study areas. Geotechnical properties of the overburden must also be provided, including shear strength and liquefaction potential, to allow the assessment of slope stability and bearing capacity of foundations under both static and dynamic conditions. The geological model of all overburden and bedrock units through to the uppermost Precambrian unit should be described for the regional, local and site scales. When extrapolation is required in order to derive these stratigraphic sequences,the degree of uncertainty and the need for additional field investigations to reduce this uncertainty should be discussed. The EIS must describe and assess any geotechnical and geophysical hazards within the study areas, including consideration of subsidence, uplift, seismicity and faulting, as well as consideration of the possibility of movements of the ground surface(including co seismic rupture) and earthquake ground motions. The EIS must also assess these hazards by extrapolating the risk of an earthquake near the site from the risk of an earthquake in similar stable continental regions worldwide. Specific information on the effects of past earthquakes on existing nuclear power plants in Canada is to be provided. Where appropriate, the narrative descriptions should be supplemented by illustrations such as maps, figures, cross sections and borehole logs. 10.1.2 Surface Water This section of the EIS must describe all surface water features, surface water quality, hydrology and sediment quality at the site, local and regional study areas. The description must include delineation of drainage basins at the appropriate scales and include a description of hydrological data such as water levels and flow rates collected over the years. The proponent must describe hydrological regimes, including seasonal fluctuations and year-to-year variability of all surface waters and assess normal flow, flooding, and drought properties of water bodies as well as the interactions between surface water and groundwater flow systems. The proponent must describe all surface water sources used for drinking water in the area, including source water intakes for drinking water treatment facilities. Coastal geomorphology should be documented including lakefront bluffs, the characteristics of the shoreline, near-shore zone, off-shore zone and coastal currents. The proponent must adequately document the water quality of all surface water demonstrating the use of appropriate sampling and analytical protocols, for the range of analytical parameters with the potential to be influenced by the project. This information should be presented using tables, maps and figures to provide an appropriate - 34 - January 2009 Guidelines for the Preparation of the EIS understanding of surface water characteristics and conditions at the site, local and regional scales. 10.1.3 Groundwater This section of the EIS must describe hydrogeology at the site, local and regional study areas. The description should characterize the physical and geochemical properties of all hydrogeological units in the overburden and the bedrock(from the ground surface down through to the uppermost Precambrian unit). Units should be characterized as aquifers or aquitards, and the description of each unit should include its geochemistry as well as the delineation of vertical and lateral permeabilities and directions of groundwater flow. Groundwater recharge and discharge areas should be identified(including discharge areas in Lake Ontario), and groundwater interactions with surface water should be described in detail. A conceptual and numerical hydrogeologic model that discusses the hydrostratigraphy and groundwater flow systems should be presented. The assessment must describe anticipated or potential changes to groundwater flow and quality related to any interactions with surface waters. The EIS must provide a description of baseline ground water quality at the site and local study area. The EIS must also describe local and regional potable groundwater supplies, including their current use and potential for future use. 10.1.4 Terrestrial Environment This section of the EIS must describe the terrestrial species at the site and within the local and regional study areas, including flora, fauna and their habitat. The EIS must describe any wildlife corridors and physical barriers to movement that exist within the project area. Any biological species of natural conservation status at a federal, provincial, regional or local level and their critical habitats should be identified. All protected and conservation areas established by federal, provincial and municipal jurisdictions (e.g., wilderness areas, parks, sites of historical or ecological significance, nature reserves, federal migratory bird sanctuaries and wildlife management areas, and municipal protected water supply areas) must be identified. Sites within the local or regional study area subject to contamination from previous nuclear or non-nuclear industrial activities may require baseline characterization of radionuclide and hazardous substance levels within soil, vegetation and non-human biota. Field surveys should be described in terms of representativeness of the target populations, the design for allocation of samples in space and time, measurement methods and results. 10.1.5 Aquatic Environment This section of the EIS must describe the aquatic and wetland species at the site and within the local and regional study areas, including a description of the flora, fauna and their habitat. The proponent should seek from relevant authorities, such as DFO and the - 35 - January 2009 Guidelines for the Preparation of the EIS Ontario Ministry of Natural Resources, any available information on aquatic and wetland species and habitat for the local and regional study areas. In addition,the proponent will need to undertake independent studies to gather the necessary information as necessary. The description of the existing aquatic environment should include observed changes to food chain and food web dynamics as a habitat component as this relates to fish populations as a result of existing operations. In addition, the description should include how these impacts have affected fish movement, migration, spawning and nursery periods on a local and regional level. The proponent must provide detailed habitat mapping in order to understand habitat usage by fish within the study area. This information must include depth profiles, substrate mapping, water temperature profiles, and a description of potential and known habitat usage (i.e., nursery, rearing, feeding and migratory) by fish that occur in the study areas. The fish habitat assessment and inventory must include the area below the High Water Mark, as detailed in DFO Factsheet-Fish Habitat and Determining the High Water Mark, as this area functions as fish habitat seasonally and in years of higher water levels in Lake Ontario. The EIS must identify any biological species of natural conservation status (e.g., rare, vulnerable, endangered,threatened, and uncommon) at a federal, provincial,regional or local level and their critical habitats. A summary of results and interpretation must be provided for the on-going monitoring of entrainment and impingement of aquatic biota at the existing stations. 10.1.6 Ambient Radioactivity The EIS must describe the ambient radiological conditions at the site and within the local and regional study areas. The EIS must provide information on the existing conditions in this regard, including an inventory of sources,their activity levels, and their origin (natural or anthropogenic), for all environmental media including air, soil, food,water, aquatic sediments, plant and animal tissue in the appropriate subsections of the EIS. Humans and non-human biota exposed to ambient radioactivity must be assessed for all relevant routes of exposure (both internal and external exposure scenarios). Information on radiation levels to which workers and members of the public are exposed to must be provided. This must also include consideration of consumers of country food whose exposure pathways may differ due to cultural norms, including any dietary characteristics of Aboriginal peoples. A description of the current radiological monitoring, management programs, and special studies including a detailed summary of the results of those programs, must be provided in the EIS. - 36 - January 2009 Guidelines for the Preparation of the EIS 10.1.7 Climate, Weather Conditions and Air Quality The EIS must describe the climate conditions at the site, local and regional study areas. The EIS must also provide a description of seasonal variations in weather conditions within the above-noted study areas,to allow the assessment of effects on the project. Meteorological information provided should include air temperature, relative humidity, precipitation,wind speed and direction, atmospheric pressure, solar radiation, and describe the occurrence of weather phenomena including events such as tornadoes, lightning, temperature inversions and fog. Special consideration must be given in the analysis of extreme and rare meteorological phenomena. Uncertainties must be described and taken into account when discussing the reliability of the information presented. The influence of regional topography or other features that could affect weather conditions in the study areas must be described. A description of the ambient air quality in the study areas must be provided, with emphasis on those parameters for which there will be radiological and non-radiological emissions resulting from the project. 10.1.8 Noise The EIS must describe current ambient day time and night time noise levels at the site, in the local study areas, and include information on its source(s), geographic extent and temporal variations. The description must also provide ambient noise levels for other areas which could be affected by the project, such as through increased traffic along transportation corridors to and from the site during construction,particularly at residences and sensitive sites (e.g., hospitals, schools, day-cares, seniors' residences, and places of worship). 10.2 Socio-economic Conditions In describing the socio-economic environment, the proponent must provide information on the functioning and health of the socio-economic environment, encompassing a broad range of matters that affect the people and communities, including Aboriginal communities, in the study area. 10.2.1 Economy The EIS must describe the general socio-economic conditions at the local and regional study areas. The proponent should describe population and community distribution and density in the regional study area. The description should include the proximity of the project to affected communities, fluctuations in population and population attributes (age groups, employment). A description of the local and regional economies should also be provided, including workforce and employment. Information must be provided on the available labour supply and rates of employment in the surrounding communities and region. 37 January 2009 Guidelines for the Preparation of the EIS 10.2.2 Land Use and Value The EIS must describe land use in the local and regional study areas. The proponent should identify past, current and planned land use(s) of the study areas or beyond,that may be affected by the project. This must include a description of the current and planned operations on the OPG Nuclear Site, and a discussion of existing land-based infrastructure that is likely to be affected by the project, such as sewer and water treatment distribution systems, wells and waste management areas. A description of commercial fisheries that could be affected by the project should be provided. Estimates of the current and projected value of the recreational and tourist industry (e.g., hunting, fishing, hiking, parks, kayaking, cottages along the shores of Lake Ontario) for the study areas should be provided. A description of current or of proposed future local,regional or provincial land use or urban development policies, programs and plans should also be provided. 10.2.3 Aboriginal Lana Aquatic Area and Resource Use In keeping with the Guiding Principles in Section 2 of these guidelines, the EIS must describe land use at the site and within the local and regional study areas. The proponent should identify the lands, waters and resources of specific social, economic, archaeological, cultural or spiritual value to Aboriginal people, including MBtis that assert Aboriginal rights or title or treaty rights or in relation to which Aboriginal rights or title or treaty rights have been established and that may be affected by the project. The EIS must identify traditional activities, including activities for food, social, ceremonial and other cultural purposes, in relation to such lands, waters and resources with a focus on the current use of lands,waters and resources for traditional purposes. Traditional land use may include areas where traditional activities such as camping, travel on traditional routes, gathering of country foods (hunting, fishing, trapping, planting and harvesting) activities were carried out. Spiritual sites should also be considered as a traditional use activity of significance to Aboriginal people. 10.2.4 Land-based Transportation The EIS must describe the existing conditions of the proposed modes and routes of transportation(e.g., provincial highways, arterial highways, on-site access roads, railways)that will be used throughout the development. The EIS must provide information on the existing types and volumes of traffic and a description of the areas through which trucks will travel, in particular residential or school areas. 10.2.5 Navigable Waters This section of the EIS must identify any navigation use or issues along Lake Ontario, or any other waterbodies that may be affected by the project. Information on location (latitude and longitude), width, and depth must be provided where appropriate. - 38 - January 2009 Guidelines for the Preparation of the EIS 10.2.6 Human Health This section of the EIS must describe the current health profiles of the communities likely to be affected by the project. The proponent should examine the aspects of human health that are defined by the World Health Organization, and include consideration of physical health and well-being and associated emotional, social, cultural, and economic aspects. The EIS must provide information on population health of the communities in the regional study area. A description of community and public health services available to the residents of communities and to Aboriginal people in the regional study area must also be included. In keeping with the Guiding Principles in Section 2 of these guidelines, a discussion on Aboriginal people's health-related traditional activities, including the accessibility to spiritual sites within regional study area, should also be included. Health-related traditional activities could include gathering of country foods for consumption (hunting, fishing, trapping, planting and harvesting of plants for medicinal purposes) and activities of spiritual significance. Information on current consumption of country foods and its quality by food type, amounts consumed, parts consumed(whole body as opposed to a specific organ)by Aboriginal people must be provided where available. 10.2.7 Physical and Cultural Heritage Resources The EIS must identify any terrestrial and aquatic areas containing features of historical, archaeological, paleontological, architectural or cultural importance. A description of the nature of the features located in those areas must be provided. Particular attention must be given to Aboriginal cultural, archaeological and historical resources since there is documented evidence of the presence of such resources in the study areas. 11. EFFECTS PREDICTION,MITIGATION MEASURES AND SIGNIFICANCE OF RESIDUAL ADVERSE EFFECTS 11.1 Effects Prediction This section must contain a description of any changes in the environment caused by the project, including the effects of these environmental changes on health and socio- economic conditions, physical and cultural heritage, current use of lands and resources for traditional purposes by Aboriginal persons, and any structure, site or thing that is of historical, archaeological, paleontological or architectural significance. Specific attention must be given to interactions between the project and the identified VECs. This section must also include changes to the project caused by the environment. Each environmental change must be described in terms of whether it is direct or indirect and positive or adverse. Where no change is predicted,this should be noted. The EIS must describe comprehensive analyses of both the short and long term effects of the project on the environment. The proponent must indicate the degree of uncertainty in predicting the environmental effects identified. When numerical models - 39 - January 2009 Guidelines for the Preparation of the EIS are used(e.g., a quantitative ecological risk assessment model, a population level ecological risk assessment model) scientific defensibility must be demonstrated by performing model verification (e.g., peer review of model theory), calibration (e.g., adjusting key parameters to site-specific data), validation(e.g., comparison of predicted to observed), sensitivity and uncertainty analysis. Risk modelling of VEC exposure to releases of radionuclides, or hazardous substances (including thermal) shall be determined through the use of upper bounding scenarios or a combination of expected average releases and an upper bounding scenario. The proponent is expected to employ standard ecological risk assessment frameworks that categorize the levels of detail and quality of the data required for the assessment. These tiers are as follows: • Tier 1: Qualitative (Expert opinion, literature review, and existing site information); • Tier 2: Semi-quantitative (Measured site-specific data and existing site information); and • Tier 3: Quantitative (Recent field surveys and detailed quantitative methods). Thus, if the Tier 2 assessment still indicates a potential for effects for valued receptors then a Tier 3 assessment would need to be conducted to reduce the level of uncertainty. If the risk characterization component is uncertain this may necessitate the probabilistic modeling of the population level consequences of the proposed project. An accepted approach to population-level ecological risk assessment and it use in environmental decision-making has been developed through recent scientific work. This approach includes a determination of when a population-level risk assessment is warranted (Tier 1 and Tier 2 assessments),the consideration of exit criteria, and a determination of the value of the assessment [Reference 8]. The consideration of views from the public and Aboriginal groups, including any perceived changes attributed to the project, must be recognized and addressed in the assessment method. When completing effects predictions,the potential for climate change influences over the predicted 60 year of operations should be considered (e.g., influence on thermal effects from cooling water releases). 11.2 Mitigation Measures i Mitigation is the elimination, reduction or control of the adverse environmental effects of the project, and includes restitution for any damage to the environment caused by such effects through replacement, restoration, compensation or any other means. The proponent must describe general and specific measures intended to mitigate the potentially adverse environmental effects of the project. The proponent must indicate which measures respond directly to statutory or regulatory requirements. -40 - January 2009 Guidelines for the Preparation of the EIS All proposed mitigation must be described by project phase, timing and duration. Information must be provided on methods, equipment, procedures and policies associated with the proposed mitigation. The proponent must discuss and evaluate the effectiveness of the proposed measures and assess the risk of mitigation failure and the potential severity of the consequences of such failures. Information must be provided on similar mitigation methods used with similar projects and the degree of success achieved. The proponent must indicate what other mitigation measures were considered, including the various components of mitigation and explain why they were rejected. Trade-offs between cost savings and effectiveness of the various forms of mitigation must be justified. The proponent must identify who is responsible for the implementation of these measures and the system of accountability. For species at risk defined by the federal Species at Risk Act, pursuant to subsection 79(1) of that Act, Responsible Authorities under the Canadian Environmental Assessment Act must notify the appropriate federal Minister if any listed wildlife species, its critical habitat or the residences of individuals of that species may be adversely affected by the project. Pursuant to subsection 79(2) of the Species at Risk Act, if the project is carried out, Responsible Authorities must also ensure that measures are taken to avoid or lessen those effects and to monitor them; these measures must be taken in a way that is consistent with any applicable recovery strategy and action plans. Therefore, the proponent must include information in the EIS that will allow the Responsible Authorities to meet this requirement. Compliance monitoring verifies whether required mitigation measures were implemented. Compliance monitoring on its own does not satisfy the requirements for a follow-up program described in Section 15, but serves to track conditions or issues during the project lifespan or at certain times. For each environmental component potentially affected by the project, the EIS must describe any proposed monitoring programs that will be designed. 11.3 Significance of Residual Adverse Effects The proponent is expected to take all reasonable precautions to protect the environment. Hence, all reasonable means (e.g., best available technology economically achievable and keeping radiation doses as low as reasonably achievable) are expected to be used to eliminate or mitigate adverse environmental effects. Any residual adverse effects persisting despite proposed mitigative activities are to be assessed as to their significance. The EIS must identify the criteria used to assign significance ratings to any predicted adverse effects. The EIS must contain a detailed analysis of the significance of the potential residual adverse environmental effects it predicts. It must contain clear and sufficient information to enable the joint review panel and the public to understand and review the proponent's judgment of the significance of effects. The proponent must define the terms used to describe the level of significance. - 41 - January 2009 Guidelines for the Preparation of the EIS The proponent must assess the significance of predicted effects according to the following categories: • magnitude of the effect; • geographic extent of the effect; • timing, duration and frequency of the effect; • degree to which effects are reversible or mitigable; • ecological and social/cultural context; and • probability of occurrence. In assessing significance against these criteria, the EIS must, where possible, employ relevant existing regulatory documents, environmental standards, guidelines, or objectives such as prescribed maximum levels of emissions or discharges of specific hazardous agents into the environment or maximum acceptable levels of specific hazardous agents in the environment. If the level of an adverse environmental effect is less than the standard, guideline, or objective, it may or may not be significant. The EIS must avoid repetition by identifying the potential adverse environmental effects, the proposed mitigation measures and the significance of the effects after mitigation measures have been taken into account, on each VEC, both biophysical and socio-economic, in the same discussion. A summary of the effects, mitigation and significance associated with each VEC should be provided in tabular format to provide clarity and ease of reference. The EIS must clearly explain the method and definitions used to describe the level of the adverse (e.g., low, medium, high) for each of the above categories and how these levels were combined to produce an overall conclusion on the significance of adverse effects for each VEC. This method should be transparent and reproducible. 11.4 Biophysical Environment 11.4.1 Geology and Geomorphology The EIS must describe any changes to the environment resulting from the removal of bedrock, unconsolidated deposits, soils or sediments that are disturbed, and stockpiled, or used for construction purposes. The EIS must also include an assessment of changes to coastal processes and features (e.g., changes to shoreline morphology due to construction as well as changes through erosion and sediment transport)with a particular focus on potential effects of the increased flow from condenser cooling water or other discharges to surface waters and the proposed infilling of Lake Ontario. 11.4.2 Surface Water The EIS must identify and characterize all liquid emissions, including but not limited average and maximum emissions from point sources, planned discharges, fugitive releases, deposition from airborne particulates, and surface runoff, which have the -42 - January 2009 Guidelines for the Preparation of the EIS potential to be generated during any phase of the project. A description of how these emissions could affect surface water quality and an indication of what will be done to avoid or mitigate adverse environmental effects must be provided. The proponent is to document the proposed monitoring or follow-up programs designed to assess the effects of the project on surface water features, including measured parameters, sampling methodologies, locations and frequencies, and performance criteria against which the impacts of the site activities will be evaluated. 11.4.3 Groundwater For all phases of the project,the EIS must describe and assess any effects the project may have on the groundwater regime including the quantity and quality of groundwater, and provide details of how the effects on groundwater will be avoided or mitigated. Modeling should be used as required to develop and support effects predictions. The proponent is to document the proposed monitoring or follow-up programs designed to assess the effects of the project on groundwater, including measured parameters, sampling methodologies, locations and frequencies, and performance criteria against which the impacts of the site activities will be evaluated. 11.4.4 Terrestrial Environment For all phases of the project,the EIS must describe the effects of the project on terrestrial fauna and flora and include a full accounting of effects on species of natural conservation status and their habitat. This effects evaluation should be based on results of field monitoring studies and predictions from an ecological risk assessment. It must be clear how predicted effects to the biota exposed to the project stressor compare to the expected "reference condition" for unexposed biota on a biological population basis taking into account natural variation. Potential effects may include but are not limited to: • effects of loss of terrestrial habitat and the quality of lost habitat for relevant species; • disturbance of feeding, nesting or breeding habitats; • physical barriers to wildlife; • disruption, blockage, impediment and sensory disturbance(e.g., noise and light effects)of daily or seasonal wildlife movements (e.g., migration, home ranges); • direct and indirect wildlife mortality; • reduction in wildlife productivity; and • contaminant exposures through environmental and food-chain transport. The proponent is to document the proposed monitoring or follow-up programs designed to assess the effects of the project on the terrestrial environment including potential sampling media and/or indicator species, measured parameters, sampling methodologies, locations and frequencies, and performance criteria against which the impacts of the site activities will be evaluated. -43 - January 2009 Guidelines for the Preparation of the EIS 11.4.5 Aquatic Environment For all phases of the project,the EIS must describe the effects of the project on aquatic fauna and flora and include a full accounting of effects on species of natural conservation status and their habitat. This effects evaluation should be based on results of field monitoring studies and predictions from an ecological risk assessment. Potential effects may include but are not limited to: • effects on habitat, including aquatic vegetation and sensitive areas such as spawning grounds,nursery areas,winter refuges and migration corridors; • effects on aquatic species, including rare and/or sensitive species; • effects of blasting on fish and fish habitat on local aquatic systems; • contaminant exposures through environmental and food-chain transport; • effects of impingement/entrainment on biota; • effects of infilling on loss of fish habitat and changes to productive capacity; • effects of thermal plume(s) on fish habitat, health and behaviour; • effects from the release of potential contaminants within cooling water such as blowdown constituents, biocides or anti-corrosion chemicals on aquatic biota; • a description of mitigation/compensation options; and • effects on wetlands. Results of historical baseline studies and on-going monitoring of events with respect to the changes observed in aquatic species as a result of current and past operations of existing nuclear reactors will play a key role in determining future effects of new reactors. Description of potential effects must include changes to food chain and food web dynamics as a habitat component as this relates to fish populations. Particular attention must be placed on the effects to any existing sport fishing and Aboriginal commercial fishing industry. Any works that involve significant infilling into Lake Ontario require an assessment of alternatives to avoid the infill as per the 'Hierarchy of Preferences' direction in the DFO's Policy for the Management of Fish Habitat. Any works that will result in a harmful alteration, disruption or destruction of fish habitat will be required to have a fish habitat compensation plan to meet the `no net loss' policy objectives. The assessment of potential effects to fish and fish habitat arising from the lake filling must be done using DFO's Habitat Alteration and Assessment Tool (HAAT). The HAAT model must also be used as part of the assessment to evaluate if the compensation plan meets DFO's long term policy objective to achieve a net gain in productive capacity of fish habitat. The proponent must describe proposed mitigation measures to reduce or eliminate effects from impingement and entrainment of aquatic biota through water withdrawal, and from subsequent release of a heated effluent, in consideration of the requirements to assess alternative means of undertaking the project. The assessment of the possible mitigation measures must include the use of closed-cycle cooling systems and the application of a -44 - January 2009 Guidelines for the Preparation of the EIS standard approach velocity at the intake screens (e.g., as applied at Canadian hydroelectric facilities). 11.4.6 Radiological Conditions For all phases of the project, the EIS must describe, in the appropriate sections, any changes to radiation and radioactivity present in the terrestrial and aquatic environment, the atmosphere, and to workers and members or nearby communities as a result of the project. Any mitigation measures to reduce adverse environmental effects must also be described. The proponent is to document the proposed monitoring or follow-up programs designed to assess the effects of the project related to the releases of radionuclides to the environment, including potential sampling media and/or indicator species, measured parameters, sampling methodologies, locations and frequencies, and performance criteria against which the impacts of the site activities will be evaluated. 11.4.7 Atmosphere The EIS must identify and characterize all atmospheric emissions, including but not limited to average and maximum emissions from point sources, planned discharges, and fugitive emissions, including greenhouse gases, expected to be generated during any phase of the project. Modelling incorporating site-specific atmospheric characteristics(e.g., shoreline fumigation) is to be completed to assess potential influences on air quality, and the transport of atmospheric contaminants and any associated exposure of humans and non-human biota. The EIS is to indicate what will be done to avoid or mitigate any potential adverse environmental effects and assess the risks associated with any residual emissions. A comparison of the Project's incremental contribution to total national and provincial emissions on an annual basis is to be provided. The proponent is to document the proposed monitoring or follow-up programs designed to assess the effects of the project related to atmospheric releases and associated air quality, including measured parameters, sampling methodologies, locations and frequencies, and performance criteria against which the impacts of the site activities will be evaluated. 1].4.8 Noise and Vibrations For all phases of the project, the EIS must describe the predicted effects(with rationale) of any change in day time or night time noise or vibration levels on terrestrial and aquatic species and on workers and nearby residents and communities for all phases of the project. Include a description of any tonal or impulsive noise that may occur, particularly during construction. The methods to be used to monitor noise and vibration levels must also be described. -45 - January 2009 Guidelines for the Preparation of the EIS 11.4.9 Effects of the Environment on the Project The EIS must describe the potential effects that the environment may have on the project. The assessment must take into account how local lake conditions and natural hazards, such as severe weather conditions and external events (e.g., flooding, tornado, fire and seismic events) could adversely affect the project. Longer-term effects of climate change must also be discussed up to the projected abandonment phase of the project. Consideration of applicable climate elements must include, but not be limited to: • an estimate of its importance to the project; • an estimate of how sensitive the project is to variations of this element; • a discussion of climate data used; and • change in lake level. The sensitivity of the project to long-term climate variability and effects must be identified and discussed. The CEAA Procedural Guide, "Incorporating Climate Change Considerations in Environmental Assessment: General Guidance for Practitioners", [Reference 9] provides guidance for incorporating climate change considerations in an environmental assessment. 11.5 Socio-economic Effects This section of the EIS must describe the predicted changes to health and socio-economic conditions, physical and cultural heritage and current use of lands and resources, including those used for traditional purposes by Aboriginal people that result from any changes the project may cause in the environment. 11.5.1 Economy For all phases of the project, the EIS must describe the expected effects on the regional study area's economy, including effects on employment and economic sectors such as commercial, retail and recreational sectors. It should also describe what measures are within the proponent's control to avoid or mitigate adverse economic effects. 11.5.2 Land Use and Value This section of the EIS must describe the predicted effects (with rationale)that the proposed development will have on the existing and planned operation on the Darlington Nuclear Site as well as on other land and water uses, including tourism, changes in aesthetics, education, and recreational opportunities caused by the construction, operation and modification of the project in terms of increased noise levels, lowered air and water quality, alteration or visual and topographic characteristics of the area. -46 - January 2009 Guidelines for the Preparation of the EIS For all phases of the project,the ETS must describe the expected effects or pressures on, but not limited to, land use, the housing market(including local and regional residential rental market), property taxes, and property values within the Local and Regional Study Areas, as well as any additional areas that might be defined by the Protective Zone. 11.5.3 Aboriginal Traditional Land Use The EIS must identify any change that the project is likely to cause in the environment and any effect of any such change on the use of lands and resources for traditional purposes by any Aboriginal group including, but not limited to, effects to hunting, trapping, fishing and gathering. For each effect, the EIS must specify; where possible, the particular area that may be affected. The EIS must identify any concerns raised by Aboriginal people about the project or other past or present means of storing or disposing of nuclear waste, and regarding the cumulative effects of the project in combination with any other over these areas. 11.5.4 Land-based Transportation For all phases of the project, the EIS must describe the expected effects on transportation infrastructure in the regional study area. The discussion on the predicted effects (with rationale) to local and regional traffic volumes and road conditions, including provincial highways, arterial highways, on-site access roads and railways, should be provided. Information on the potential effects on the areas, through which trucks will travel, such as residential or school areas, should also be included. The proposed methods for avoiding effects on the existing transportation infrastructure should be described. 11.5.5 Navigable Waters The EIS must identify potential effects on navigability on Lake Ontario and other water bodies that may be affected by the project. 11.5.6 Human Health The EIS must provide a discussion on the potential effects of the project on the physical, mental, and social well-being of workers, the public and communities. The information must include, but not be limited to,the following: • an analysis of the effects of the project on the health and safety of all workers, including the possible effects from malfunctions or accidents; • the predicted doses to workers, including doses to contract workers, and to members of the project resulting from activities within the scope of this project; • a description of quantitative risk assessment modeling conducted, where necessary, for any malfunctions and accidents; • an assessment of the project's potential effects on human health from all contaminants or other substances released from the project, as well as direct exposure to radiation,through all potential exposure pathways; and • potential effects of noise generated from the project on human receptors within the study area. - 47 - January 2009 Guidelines for the Preparation of the EIS The effects of the project on local and regional health services and public health infrastructure (water supplies for domestic use and sewage treatment)must also be described. 11.5.7 Physical and Cultural Heritage Resources If it has been determined that sites of historical, archaeological, paleontological or architectural importance exist,the potential effects of the project on these sites and on any physical and cultural heritage resources must be identified and discussed. The proposed measures to preserve, protect or recover these resources must be described. 11.5.8 Natural Resources The workforce required for this project, especially during the construction phase,would be considerable; therefore,the likely effects of the workforce on the biological environment must be discussed. Increased sport fishing pressure and increased traffic raising wildlife road kill rates should be taken into consideration. _48 _ January 2009 Guidelines for the Preparation of the EIS 12. ACCIDENTS, MALFUNCTIONS AND MALEVOLENT ACTS 12.1 General Considerations For the purposes of the assessment, accidents and malfunctions may be separated into three categories and defined as follows: • Nuclear accidents, consisting of all accidents and malfunctions with radiological consequences. These accidents may be further subdivided into nuclear accidents directly involving the reactor core(such as serious damage to the reactor core), nuclear accidents involving other on-site nuclear power plant facilities that contain radiological substances (including the storage of spent fuel waste and radioactive waste handling facilities), and nuclear accidents related to the off-site transportation of low and intermediate-level radioactive wastes. Accidents that do not directly involve the reactor core include criticality events associated with the nuclear fuel. • Conventional accidents, consisting of all other accidents and malfunctions resulting in releases of non-radiological contaminants and other materials. • Malevolent acts, consisting of those physical initiating events or forces(e.g., theft, diversion, civil disorder, fires, explosions, aircraft crashes)that could result from acts of sabotage or terrorist acts. For each category of accidents and malfunctions, one or more limiting source terms must be defined. Sufficient quantitative information must be provided on all radioactive and hazardous substances that could be released to the environment in significant quantities. The description must include the safeguards that have been established by the proponent to protect against such occurrences and the contingency procedures in place. Accident management typically relies heavily on the evacuation of personnel and of the population, as required. The proponent must demonstrate that the requirements for adequate infrastructure to support evacuation of personnel and the population can be met. The need for any necessary administrative measures must also be identified together with the responsibilities of organizations other than the proponent. The proponent must provide a description of any contingency, clean-up or restoration work in the surrounding environment that would be required during, immediately following or in the long-term after, the postulated malfunctions and accidents, including the manner in which the related costs would be covered. 12.2 Nuclear Accidents The EIS must identify and describe the probability of possible malfunctions or accidents associated with each reactor design considered and with other facilities in the nuclear power plant that contain radiological substances and must consider the potential adverse environmental effects of these events. 49 January 2009 Guidelines for the Preparation of the EIS The proponent must credibly demonstrate that it meets the safety goals defined in CNSC Regulatory Document RD-337, "Design of New Nuclear Power Plants", [Reference 10], with some margin on frequency, consequence or both. These safety goals are meant to ensure that the risk posed by a nuclear power plant to members of the public living near the plant is small compared with the risks to which they are normally exposed, and the releases they describe are bounding for all designs. Two safety goals are defined in CNSC Regulatory Document RD-337, to protect the environment and the health and safety of workers and public: • a small release frequency(SRF). The SRF addresses releases of radioactive material that would trigger temporary evacuation of the population within a few kilometres of the plant in order to prevent unacceptable health effects as a result of limited reactor core damage with impaired containment; and • prevent unacceptable health effects as a result of severe reactor core damage and failure of containment. Each safety goal comprises a limit, as follows: • SRF -The sum of frequencies of all event sequences that can lead to a release to the environment of more than 1 x1015 Bq of I-131 is less than 1:100,000 per reactor year. • LRF - The sum of frequencies of all event sequences that can lead to a release to the environment of more than 1x1014Bq of Cs-137 is less than 1:1,000,000 per reactor year. The proponent must provide a high-level safety analysis supported by sufficient design information to demonstrate to the satisfaction of the joint review panel or its technical support staff that the accident behaviours of the various designs being proposed are understood, such that their consequences can be predicted with sufficient confidence. The required level of design information is: • site characteristics including natural hazards; • technical outline of the nuclear power plant including: • plant layout; • qualitative descriptions of all major systems, structures and components (SSCs)that could significantly influence the course or consequences of principal types of accidents and malfunctions; • qualitative descriptions of the functionality of the SSCs important to safety; • quantitative information on the performance and reliability characteristics; • qualitative descriptions of principal types of accidents and malfunctions to identify limiting credible sequences including external hazards(natural and human-induced), design basis accidents and beyond design basis accidents, including severe accidents; - 50 - January 2009 Guidelines for the Preparation of the EIS • scoping calculations of limiting accident sequences to provide estimates of impact; and • system level probabilistic safety assessment, or an equivalent level and type of information. The limiting source terms must consider accident sequences that could occur with a frequency greater than 10-6 per year. For those sequences having frequencies less than I per year but sufficiently close to this frequency, the proponent should provide the rationale for screening them out from further analysis. For nuclear accidents directly involving the reactors, the frequencies denote the frequencies per reactor year of operation. A description of specific (out of reactor)criticality events must be provided along with a demonstration that consequences of the events do not violate criteria established by international standards [Reference 11] and national guidance [Reference 12] as a trigger for a temporary public evacuation. 12.3 Conventional Accidents The EIS must identify and describe the probability of possible malfunctions or accidents associated with the project, and describe the potential adverse environmental effects of events which result in non-radiological releases. The proponent must provide, for all phases of the project,the following information on conventional accidents: • an identification and discussion of any past abnormal plant operations, accidents and spills to the extent that they are relevant to the current assessment; • a description of specific malfunction and accident events that have a reasonable probability of occurring during the life of the project, including an explanation of how these events were identified for the purpose of this environmental assessment; and • a description of the source, quantity, mechanism, rate, form and characteristics of non-radiological contaminants and other materials (physical and chemical) likely to be released to the surrounding environment during the postulated malfunctions and accidents, including a description of emissions originating from the operation of emergency back-up diesel generators during prolonged outages. 12.4 Malevolent Acts The EIS must address potential environmental effects that could result from intentional malevolent acts. While intentional malevolent acts are not accidents, the proponent must compare the environmental effects resulting from malevolent acts with the environmental effects identified for both accidents involving radiological substances (Section 12.2) and conventional accidents (Section 12.3). The EIS must describe the consequences of malevolent acts as either bounded by environmental effects of nuclear and conventional accidents described in the EIS, or where necessary identify where the consequences of the malevolent act are greater. - 51 - January 2009 Guidelines for the Preparation of the EIS 13. CUMULATIVE EFFECTS The proponent must identify and assess the cumulative adverse and beneficial environmental effects of the project in combination with other past, present or reasonably foreseeable projects and/or activities within the study areas. The approach and methods used to identify and assess cumulative effects must be explained. The CEAA Operational Policy Statement OPS-EPO/3- 2007, "Addressing Cumulative Environmental Effects under the Canadian Environmental Assessment Act" [Reference 7], provides further guidance for conducting cumulative effects assessment. The assessment of cumulative environmental effects of the project must include the following, but may also address other items: • Identify the VECs, or their indicators, on which the cumulative effects assessment is focused, including the rationale for their selection. Present spatial and temporal boundaries for the cumulative effect assessment for each VEC selected. Emphasize VECs with special environmental sensitivities or where significant risks are involved. • Identify the sources of potential cumulative effects. Specify other projects or activities that have been or will be carried out that could produce environmental effects on each selected VEC within the boundaries defined, and whose effects would act in combination with the residual adverse effects of the project. • Evaluate the likelihood of development by the proponent or others that may appear feasible because of the proximity of the project's infrastructure. Limit assessment to cumulative effects on the physical, biological, and human environments that are likely and for which measurable or detectable residual adverse effects are predicted. A reasonable degree of certainty should exist that proposed projects and activities will actually proceed for them to be included. Projects that are conceptual in nature or limited as to available information may be insufficiently developed to contribute to this assessment in a meaningful manner. In either case, provide a rationale for inclusion or exclusion. The EIS must describe the analysis of the total cumulative effect on a VEC over the life of the project, which requires knowledge of the incremental contribution of all projects and activities, in addition to that of the project. The EIS must include different forms of effects (e.g., synergistic, additive, induced, spatial or temporal) and identify impact pathways and trends. Potential environmental effects on a VEC are not necessarily the result of one project. While a project-specific assessment of cumulative effects is not responsible for assessing all external environmental effects; the cumulative effects assessment must consider how a project-specific environmental effect, or suite of project-specific environmental effects, would interact with these external factors. The EIS must make clear the contribution of - 52 - January 2009 Guidelines for the Preparation of the EIS the project to a total potential cumulative effect, and place potential cumulative project effects in an appropriate regional context, considering regional plans, community conservation plans, species recovery plans, management plans, objectives and/or guidelines in an integrated manner in order to understand the aspirations of people and communities in the region. In assessing the cumulative environmental effects of this project in combination with other projects and/or activities, the proponent must identify any changes in the original environmental effects and significance predictions for the project. The proponent must also discuss the effectiveness of the proposed mitigation and/or other restitution measures and the response to such changes, as well as the implications for monitoring and follow- up programs as described in section 15. This section must provide a brief historical overview of the timelines of the construction, commissioning and operating periods of various facilities at the OPG Darlington Nuclear Site beginning with the first construction in 1981. An example is available on pages 8-9, figure 10 of the December 2000, `Bruce Ecological Effects Review Summary"(OPG 2000), [Reference 13]. 14. CAPACITY OF RENEWABLE RESOURCES The EIS must describe the effects of the project on the capacity of renewable resources to meet the needs of the present and those of the future. The EIS must identify those resources likely to be impacted by the project, and describe how the project could affect their sustainable use. The EIS must also identify and describe any criteria used in considering sustainable use. Sustainable use may be based on ecological considerations such as integrity, productivity, and carrying capacity. 15. FOLLOW UP PROGRAM The proponent must include a framework upon which environmental monitoring, including environmental effects monitoring where relevant, and follow-up actions will be based throughout the life of the project, should the project proceed. A follow-up program must be designed to verify the accuracy of the environmental assessment and to determine the effectiveness of the measures implemented to mitigate the adverse environmental effects of the project. The follow-up program must be designed to incorporate pre-project information which would provide the baseline data, compliance data such as established benchmarks, regulatory documents, standards or guidelines, and real time data which would consist of observed data gathered in the field. As part of the follow-up program, the proponent must describe the compliance reporting methods to be used, including reporting frequency, methods and format. Environmental assessment effects predictions, assumptions and mitigation actions that are to be tested in the follow-up and monitoring programs must be converted into field- testable monitoring objectives. The monitoring design must include a statistical evaluation of the adequacy of existing baseline data to provide a benchmark against - 53 - January 2009 Guidelines for the Preparation of the EIS which to test for project effects, and the need for any additional pre-construction or pre- operational monitoring to establish a firmer project baseline. The proponent must propose a schedule for the follow-up program. The schedule should indicate the frequency and duration of any required environmental effects monitoring. This schedule would be developed after statistical evaluation of the length of time needed to detect effects given estimated baseline variability, likely environmental effect size and desired level of statistical confidence in the results (Type 1 and Type 2 errors). The description of the follow-up program must include any contingency procedures/plans or other adaptive management provisions as a means of addressing unforeseen environmental effects or for correcting exceedances as required to comply or to conform to benchmarks, regulatory standards or guidelines. The follow-up program must describe roles and responsibilities for the program and its review process, by both peers, the public and Aboriginal people. The EIS must provide a discussion on the need for, and requirements of a follow-up program and include: • the need for such a program and its objectives; • a tabular summary and explanatory text of the main components of the program including: a description of each monitoring activity under that component; which of the three follow-up program objectives the activity is fulfilling (l. confirm mitigation, 2. confirm assumptions, 3. verify predicted effects); the specific statement from the environmental assessment that goes along with that generic objective and will be the focus for that activity (e.g., follow-up objective: verify predicted effects; environmental assessment effect: no adverse effects at the population level for white-tailed deer because of vehicle strikes due to increased traffic within the site study area); and, the specific monitoring objective for that activity(e.g., record occurrence of vehicular collisions with deer on-site to verify predicted environmental effects). • how it would be structured; • roles to be played by the proponent, regulatory agencies, government representatives, Aboriginal people, non-government organizations, citizens' groups and others in such a program; • possible involvement of independent researchers; • the sources of funding for the program; and • information management and reporting. - 54 - January 2009 Guidelines for the Preparation of the EIS The follow-up program plan must be described in the EIS in sufficient detail to allow independent judgment as to the likelihood that it will deliver the type, quantity and quality of information required to reliably verify predicted environmental effects(or absence of them), confirm environmental assessment assumptions and confirm the effectiveness of mitigation. 16. ASSESSMENT SUMMARY AND CONCLUSION This section of the report must summarize the overall findings with emphasis on the main environmental issues identified. 17. REFERENCES 1. Canadian Privy Council Office. "A Framework for the Application of Precaution in Science-based Decision Making about Risk". ISBN 0-662-67486-3 Cat. no. CP22- 70/2003 2. OPG. "Project Description for the Site Preparation, Construction and Operation of the Darlington B Nuclear Generating Station Environmental Assessment'April 2007. 3. CNSC Regulatory Document RD-346 "Site Evaluation for New Nuclear Reactors", Canadian Nuclear Safety Commission, Ottawa,November 2008. 4. CNSC Regulatory Guide G-219, "Decommissioning Planning for Licensed Activities"Canadian Nuclear Safety Commission, Ottawa, June 2000. 5. CNSC Regulatory Standard S-296, `Environmental Protection Policies, Programs and Procedures at Class I Nuclear Facilities and Uranium Mines and Mills", Canadian Nuclear Safety Commission, Ottawa, March 2006. 6. CNSC Regulatory Guide G-296, "Developing Environmental Protection Policies, Programs And Procedures At Class I Nuclear Facilities And Uranium Mines And Mills" Canadian Nuclear Safety Commission, Ottawa, March 2006. 7. CEAA Operational Policy Statement OPS-EPO/3- 2007, "Addressing Cumulative Environmental Effects under the Canadian Environmental Assessment Act", Ottawa, November 2007. 8. Bamthouse, L.W., W. R. Munns Jr. and M. T. Sorensen. 2008. "Population-Level Ecological Risk Assessment'. CRC Taylor and Francis,NY. Society of Environmental Toxicology and Chemistry. 9. CEAA Procedural Guide, "Incorporating Climate Change Considerations in Environmental Assessment: General Guidance for Practitioners",prepared by: The Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment, November 2003. 10. DRAFT CNSC Regulatory Document RD-337, "Design of New Nuclear Power Plants", Canadian Nuclear Safety Commission, Ottawa, 2008. 11. Food and Agriculture Organization of the United Nations,International Atomic 55 - January 2009 Guidelines for the Preparation of the EIS Energy Agency, International Labour Organization, OECD Nuclear Energy Agency, Pan American Health Organization, United Nations Office for the Co-Ordination of Humanitarian Affairs, World Health Organization, "Preparedness and Response to Nuclear or Radiological Emergency, Safety Requirements", Safety Standards Series No. GS-R-2, IAEA, Vienna,Austria, 2002. 12. Health Canada, "Canadian Guidelines for Intervention during a Nuclear Emergency", Document H46-2/03-32E, Ottawa, Ontario,November 2003. 13. Ontario Power Generation 2000. "Bruce Nuclear Power Development Ecological Effects Review". December 2000. Ontario Power Generation. CNSC Record Center, EDOCS #3078531. - 56 - APPENDIX 1 Glossary and Acronyms Appendix 1 Glossary and Acronyms Abandon—The act of a nuclear facility moving from a licensed to unlicensed state. Aboriginal Peoples—Defined in Section 35 of the Constitution Act, 1982 as including Indian, Inuit and Metis people Aboriginal Rights-Those rights of Aboriginal peoples which are not found in treaties or land claims agreements. Aboriginal Title- The form of land ownership belonging to Aboriginal people and the rights coming from the aboriginal relationship with land. Aboriginal Traditional Knowledge -Aboriginal traditional knowledge (ATK) is knowledge that is held by, and unique to Aboriginal peoples. It is a living body of knowledge that is cumulative and dynamic and adapted over time to reflect changes in the social;economic, environmental, spiritual and political spheres of the Aboriginal knowledge holders. It often includes knowledge about the land and its resources, spiritual beliefs, language,mythology, culture, laws, customs and medicines. It may be considered in the environmental assessment of a proposed project. The term traditional ecological knowledge (TEK) is often used interchangeably with the term Aboriginal traditional knowledge (see, ATK). However, TEK is generally considered to be a subset of ATK that is primarily concerned with knowledge about the environment. Aquatic Environment—The components related to, living in, or located in or on water or the beds or shores of a water body, including but not limited to all organic and inorganic matter, and living organisms and their habitat, including fish habitat, and their interacting natural systems. Beyond Design Basis Accident(BDBA) -An accident less frequent and more severe than a design basis accident. CEAA- The Canadian Environmental Assessment Agency. Country Food -A diet of local meat and fish and wild plants gained through subsistence harvest. Darlington New Nuclear Power Plant (Darlington NNPP) -the new nuclear reactors proposed by OPG. Design Basis Accident(DBA) -Accident conditions against which a nuclear power plant is designed according to established design criteria, and for which the damage to the fuel and the release of radioactive material are kept within authorized limits. Ecological Risk Assessment -The process that evaluates the likelihood that adverse ecological effects may occur or are occurring as a result of exposure to one or more stressors. This definition recognizes that a risk does not exist unless: (1)the stressor has an inherent ability to cause adverse effects, and (2) it is coincident with or in contact with the ecological component long enough and at sufficient intensity to elicit the identified adverse effect(s). - 1 - Appendix 1 Glossary and Acronyms Entrainment- Occurs when fish (as defined in the Fisheries Act) are drawn into a water intake and cannot escape. Environmental Assessment-Environmental assessment is a process for identifying project and environment interactions, predicting environmental effects, identifying mitigation measures, evaluating significance, reporting and following-up to verify accuracy and effectiveness. Environmental assessment is used as a planning tool to help guide decision making, as well as project design and implementation. Environmental Effect-As defined in the Canadian Environmental Assessment Act. Exclusion Zone -A parcel of land within or surrounding a nuclear facility on which there is no permanent dwelling and over which a licensee has the legal authority to exercise control. (from Class I Nuclear Facilities Regulations). Impingement- Occurs when entrapped fish (as defined by the Fisheries Act) are held in contact with the intake screen and are unable to free itself. Joint Review Panel-A Review Panel appointed pursuant to the Canadian Environmental Assessment Act. NSCA-the Nuclear Safety and Control Act. OPG-Ontario Power Generation Project-The proposal to construct and operate up to four new nuclear reactors. Proponent-Ontario Power Generation. Protective Zone-The area beyond the exclusion zone that needs to be considered with respect to implementing emergency measures. This includes consideration of such matters as population distribution and density, land and water use, roadways, and consequence and evacuation planning(from RD-346) Species at Risk—As defined in the federal Species at Risk Act. Terrestrial Environment—The components related to, living on, or located on the Earth's land areas, including but not limited to all organic and inorganic matter, living organisms and their habitat, and their interacting natural systems. Treaty Rights- Rights arising from the terms of a treaty. VEC -Valued Ecosystem Component. -2 - APPENDIX Nuclear Safety and Control Act and its Regulations High Level Guidelines for Applications for Licence to Prepare Site I Appendix 2 CNSC Act and Regulations High Level Guidelines The proponent must provide all information required under the Nuclear Safety and Control Act and Regulations relating to an application for a Licence to Prepare Site. The proponent must demonstrate compliance with the following and with any other requirements cross-referenced in the provisions outlined below. Nuclear Safety and Control Act— Subsection 24(4) (available at http://Iaws.justice.gc.ca/en/showdoe/es/N-28.3/bo-ga:s 8-gb:s_24//en#anchorbo-ga:s_8- gb:s_24) 24(4)No licence may be issued, renewed, amended or replaced unless, in the opinion of the Commission, the applicant: (a) is qualified to carry on the activity that the licence will authorize the licensee to carry on; and (b)will, in carrying on that activity, make adequate provision for the protection of the environment,the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. General Nuclear Safety and Control Regulations All regulations serve to address Subsection 24(2) of the NSCA. Information in the application shall demonstrate compliance with the NSCA and associated Regulations. Although the application is for a Licence to Prepare Site,the application should also show high level planning information towards Construction and Operation activities since a large number of related activities have either long lead times or direct ties back to site preparation activities. The following table outline, to the applicant, CNSC's expectations for information to be submitted to meet the requirements of the Nuclear Safety and Control Act via the General Nuclear Safety and Control Regulations and the Class I Nuclear Facilities Regulations. Note that further guidance on the Nuclear Security Regulations is not included here due to its potentially prescribed nature. Applicants must approach the CNSC separately on this issue. Where the information provided to meet these expectations is contained in a part of the Environmental Impact Statement, reference may be made to the relevant section(s) in order to avoid duplication. - 1 - Appendix 2 CNSC Act and Regulations High Level Guidelines General Nuclear Safety and Control Regulations(GNSCR) Section REquirement Expectations 3(1)(a) the applicant's name and Self explanatory. business address 3(1)(b) the activity to be licensed The activity is"Site Preparation". `Purpose' and its purpose provides high level description of the planned NPP including: • number of units, • capacity, • type(s)/make(s) of reactor being considered, and • ultimate purpose(s) of the plant(e.g., electrical power production, hydrogen, desalination, process steam for external process use) If subsurface preparation of the plant footprint will be executed under the Licence to Prepare Site, sufficiently detailed information about the plant footprint is submitted in order to demonstrate adequate preparation of the subsurface against the human-induced and external hazards assessed during the site evaluation phase. 3(1)(c) the name, maximum Typically, there is no handling of radioactive quantity and form of any substances during site preparation activities nuclear substance to be except for any construction-related tools that encompassed by the licence would be under existing CNSC nuclear substance and device licences. 3(1)(d) a description of any nuclear The plant description should include: facility, prescribed • list of plant types/designs under equipment or prescribed information to be consideration ; encompassed by the licence ' the scheduled completion date and anticipated commercial operation date of z Subsurface preparation does not include installation of pilings or other structures meant to support or add strength to future NPP foundational structures.Drainage trenches and cable tunnels may be permitted with the provision that additional reviews will be required for the Licence to Construct stage if the structures will be credited in NPP safety analyses. 3 Not mandatory information for the Licence to Prepare Site. This information is expected by CNSC as part _ of the Environmental Assessment process. - 2 - Appendix 2 CNSC Act and Regulations High Level Guidelines General Nuclear Safety and Control Regulations (GNSCR) Section Requirement Expectations each unit; • for each of the above designs, total estimated capacity to be considered in the Environmental Assessment including core thermal power levels(both rated and design 4), the corresponding net electrical output(if applicable) for each thermal power level; • the type(s) of primary reactor coolant system and ultimate heat sink types(s) being considered; • the type(s) of cooling systems, intakes, and outflows being considered; • the type of containment structure(s) being considered. NOTE: per Sections 19, 20 and 21 of the General Nuclear Safety and Control Regulations: For prescribed equipment or prescribed information to be encompassed by the licence, everything that currently exists or will be kept for the duration of the licence is described in the application.Note that 21 (1) (c) includes security-related information whether kept on site or not. 3(1)(e) the proposed measures to Activities under a Licence to Prepare Site ensure compliance with should not involve radioactive dose to either the Radiation Protection workers or the public with exception to work Regulations and the done with tools that would be under existing Nuclear CNSC nuclear substance and device licenses. Security Regulations Nuclear Security Regulations apply to activities under a Licence to Prepare Site. Per Nuclear Security Regulations Section 2: °Rated power is defined as the power level at which the plant would operate if licensed.Design power is defined as the highest power level that would be permitted by the plant design and that is used in some safety evaluations. - 3 - Appendix 2 CNSC Act and Regulations High Level Guidelines General Nuclear Safety and Control Regulations (GNSCR) Section Requirement Expectations This Part applies in respect of (a)category I, II and III nuclear material, and b a nuclear ower plant. 3(1)(f) any proposed action level Site specific: "Green-field" sites that are not for the purpose of section 6 in proximity to other nuclear facilities, and of the Radiation Protection where there will be no handling of radioactive Regulations materials during site preparation activities have no need to establish Action Levels. 3(1)(g) the proposed measures to The following information is included in a control access to the site of Nuclear Security Implementation Plan the activity to be licensed submission: and the nuclear substance, 0 physical access control plans(e.g., fence prescribed equipment or type and height, types of alarms etc.); prescribed information 3(1)(h) the proposed measures to ' Security organization information; prevent loss or illegal use, ' Program for control of prescribed possession or removal of information (e.g., security drawings); the nuclear substance, • Program for developing and prescribed equipment or implementing a site access clearance prescribed information system for individuals requiring unescorted access to areas/processes where prescribed information is used or stored; • Program for security of information technology; • Security Threat Assessment studies/ reports; • Security response plans, including interfaces with outside agencies(e.g., local police, OPP, RCMP); • security personnel training plan. 3(1)(i) a description and the Generally, all data submitted in an application results of any test, analysis for Licence to Prepare Site supports the site or calculation performed to evaluation process and will be evaluated substantiate the during the Environmental Assessment information included in the process. application the name, quantity, form, The following information is submitted: origin and volume of any hazardous waste management program radioactive waste or • details specific to site preparation hazardous waste that may result from the activity to activities; 4 Appendix 2 CNSC Act and Regulations High Level Guidelines General Nuclear Safety and Control Regulations (GNSCR) Section Requirement Expectations be licensed, including • a statement of commitment, with project waste that may be stored, timelines, to develop Radioactive and managed, processed or Hazardous Waste programs with a long- disposed of at the site of term view to NPP operation, the activity to be licensed, decommissioning and abandonment. and the proposed method Programs are developed and reviewed for managing and disposing during early plant construction, however of that waste environmental risks from Radioactive and Hazardous Waste will be evaluated during the Environmental Assessment process) 3(l)(k) the applicant's The application demonstrates that there are organizational management sufficient competent resources in the structure insofar as it may Applicant's organization to ensure bear on the applicant's compliance with the NSCA and associated compliance with the Act Regulations. and the regulations made under the Act, including For Site Preparation activities: the internal allocation of functions, responsibilities The application should demonstrate: and authority • the applicant's organization has demonstrated project process ownership and adequate project oversight; and • the relationship between the applicant's organization and contracting companies performing site preparation activities is clearly described. The following site preparation organizations are adequately described: • Project Office (site preparations project oversight and regulatory compliance); • Health and Safety; • Security; • Environmental Assessment and Compliance Assurance; • Quality Assurance and Auditing; • Training(qualification of site preparation staf(). 5 - Appendix 2 CNSC Act and Regulations High Level Guidelines General Nuclear Safety and Control Regulations (GNSCR) Section Requirement Expectations Planning for future licensing phases: The future Operating Organization is named and described for the purposes of the Environmental Assessment. High level descriptions of the planned formation and development of construction and operating organizations and a statement of commitment, with project timelines, to provide more organizational details as the project progresses are required. In addition, the primary agents or contractors for the design, construction, and operation of the nuclear power plant are identified. The principal consultants and outside service organizations (such as those providing audits of the QA program) are listed. The division of responsibility is delineated among the reactor/facility designer, architect-engineer, constructor, and operator. 3(1)(1) a description of any The Financial Guarantee under the Licence to proposed financial Prepare Site adequately addresses restoration guarantee relating to the of the site required as a result of the proposed activity to be licensed activities should the project be abandoned. 3(1)(m) any other information Information may be requested by CNSC staff required by the Act or the the Commission Secretariat and/or the regulations made under the Review Panel Secretariat to support the Act for the activity to be application for Licence to Prepare Site. licensed and the nuclear substance, nuclear facility, prescribed equipment or prescribed information to be encompassed by the licence 3(1)(n) at the request of Commission, any other information that is necessary to enable the Commission to determine - 6 - Appendix 2 CNSC Act and Regulations High Level Guidelines General Nuclear Safety and Control Regulations (GNSCR) Section Requirement Expectations whether the applicant (i) is qualified to carry on the activity to be licensed, or (ii)will, in carrying on that activity, make adequate provision for the protection of the environment,the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. 15(a)(b)(c) Every applicant for a Self explanatory. licence and every licensee shall notify the Commission of (a) the persons who have authority to act for them in their dealings with the Commission; (b)the names and position titles of the persons who are responsible for the management and control of the licensed activity and the nuclear substance, nuclear facility, prescribed equipment or prescribed information encompassed by the licence; and (c)any change in the information referred to in paragraphs (a) and (b), within 15 days after the change occurs. 7 t Appendix 2 CNSC Act and Regulations High Level Guidelines Expectations for Contents of an Application for Licence To Prepare Site Class I Nuclear Facilities Regulations Section Requirement Expectations 3(a) a description of the site The application includes the following information of the activity to be (diagrams as appropriate): licensed, including the • Survey diagrams/descriptions of the land on location of any which the site will exist (e.g., province, county/ exclusion zone and any town, lot#,proximity to highways, distance structures within that from nearest town(s)); zone • Proximity to bodies of water and other 3(b) plans showing the landforms of note; location, perimeter, areas, structures and Proximity to large man-made structures(e.g., systems of the nuclear rail lines, major highways, other nearby facility commercial facilities); • Layout(s)of plant, large cooling structures, switchyard and support buildings within an exclusion zone. 3(c) evidence that the Acceptable evidence includes proof of ownership applicant is the owner (copy of land title/deed) or a letter of permission of the site or has from the owner of the land for eventual construction authority from the and operation of the facilities described per 3(b) of owner of the site to Class I Nuclear Facilities Regulations in the carry on the activity to application for Licence to Prepare Site. be licensed 3(d) the proposed quality The application includes a comprehensive assurance program for submission showing quality assurance plans and the activity to be program covering all activities to be performed licensed under the Licence to Prepare a Site, including the implementation plan, a detailed scope of activities, a schedule for the activities and encompasses a demonstration that the applicant's service providers and vendors have an acceptable QA program/meet the requirements for an acceptable QA program; 3(e) the name, form, This requirement is specific to the activities characteristics and proposed to be performed under the Licence to quantity of any Prepare Site. See Section 1 of Class i Nuclear hazardous substances Facilities Regulations for definition of hazardous that may be on the site substances. The effects of these substances are while the activity to be considered in the environmental assessment. licensed is carried on - 8 - Appendix 2 CNSC Act and Regulations High Level Guidelines Expectations for Contents of an Application for Licence To Prepare Site Class I Nuclear Facilities Regulations Section Requirement Expectations 3(f) the proposed worker The application contains program details such as a health and safety high level program implementation plan. policies and procedures The application demonstrates that: • the site health and safety program is under the direct oversight of the proponent; • the program will be managed by an adequately staffed and competent health and safety organization; • the program development and implementation plan will be complete and processes, procedures and auditing can be executed if the Licence to Prepare Site is granted. 3(g) the proposed The application contains policy and procedure that environmental demonstrate: protection policies and • the program is under the direct oversight of the procedures proponent; • the program will be managed by an adequately staffed and competent organization; • processes, procedures and auditing can be executed if the Licence to Prepare Site is ranted. 3(h) the proposed effluent The proposed effluent and environmental and environmental monitoring programs for site preparation activities monitoring programs are to be aligned with the environmental protection program. The program demonstrates: • the program is under the direct oversight of the proponent; • the program will be managed by an adequately staffed and competent organization; • support of mitigation strategies dispositioned in the Environmental Assessment process; • compliance with accepted quality assurance standards. 9 - Appendix 2 CNSC Act and Regulations High Level Guidelines Expectations for Contents of an Application for Licence To Prepare Site Class I Nuclear Facilities Regulations Section Requirement Expectations 3(i) if the application is in Self explanatory. respect of a nuclear facility referred to in paragraph 2(b) of the Nuclear Security Regulations(see below),the information required by section 3 of those Regulations; 2 (b) a nuclear facility consisting of a nuclear reactor that may exceed 10 MW thermal power during normal operation. 30) the proposed program The application demonstrates that: to inform persons living • the program is under the direct oversight of the in the vicinity of the site proponent; of the general nature , and characteristics of the program is managed by an adequately the staffed and competent organization; anticipated effects on • the program development and implementation the environment and the plan is complete and processes, procedures and health and safety of auditing are being executed prior to the persons that may result Commission hearing for the Licence to Prepare from the activity to be Site. licensed The program implementation plan includes: • population to be covered by the program, • methods of consultation, and • methods of establishing and maintaining quality assurance of data. Evidence and data shall been submitted showing open consultation with all representatives of the community. In addition, all comments captured (resolved and unresolved) and strategies for addressing the comments are documented. lo - I Appendix 2 CNSC Act and Regulations High Level Guidelines Expectations for Contents of an Application for Licence To Prepare Site Class I Nuclear Facilities Regulations Section Requirement Expectations 3(k) the proposed plan for A submission showing detailed decommissioning the decommissioning of strategies and plans(including budgets) for all the nuclear facility or of activities to be performed under the Licence to the site Prepare Site such that the site can be returned to a green or brown field state (as appropriate) in the event the project is cancelled. 4 (a) a description of the site The application needs to contain: evaluation process and • a comprehensive description of the methods of the investigations work to determine the suitability of the site. and preparatory work that have been and will • a clear description of activities proposed to be be done on the site and completed under the Licence To Prepare Site, in the surrounding area including proposed mitigation strategies to be considered in the Environmental Assessment • program implementation plans for all programs • consideration is given to site preparation activities that may have a negative affect on site characteristics or intensify the effects of natural external and human induced events evaluated during the site selection process. • a program for evaluating physical characteristics that may be discovered during site preparation activities and may differ from assumptions or research presented during the Environmental Assessment phase. • all site preparation activities and mitigation measures will conform with the outcomes of the Environmental Assessment. 4 (b) a description of the These effects are considered as part of the site site's susceptibility to evaluation process and in the Environmental human activity and Assessment. natural phenomena, including seismic events,tornadoes and floods - 11 - Appendix 2 CNSC Act and Regulations High Level Guidelines Expectations for Contents of an Application for Licence To Prepare Site Class I Nuclear Facilities Regulations Section Requirement Expectations 4 (c) the proposed program A program for determining environmental baseline to determine the characteristics of the site and the surrounding area is environmental baseline implemented for the Environmental Assessment. A characteristics of the connection between the Environmental Assessment site and the surrounding baseline program and the long term environmental area monitoring program is demonstrated to determine environmental effects during both site preparation activities and succeeding licensing phases. 4 (d) the proposed quality At the time of initial application for a Licence to assurance program for Prepare Site,the application includes the quality the design of the assurance program that was used, or that will be nuclear facility used for the design of each reactor type being considered. 4 (e) the effects on the The effects and mitigation strategies are considered environment and the as part of the site evaluation process and are health and safety of reviewed during the Environmental Assessment. persons that may result from the activity to be Effects and mitigation strategies are required for the licensed, and the physical activities to be carried out under the Site measures that will be Preparation licence. taken to prevent or mitigate those effects - 12 - }