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Home My WebLink AboutPSD-077-11 Leading the Way REPORT PLANNING SERVICES DEPARTMENT Meeting: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE Date: September 12, 2011 Resolution #: - 1/ By-law #: Report#: PSD-077-11 File #: PLN 26.15.3 Subject: REFURBISHMENT AND CONTINUED OPERATION OF THE DARLINGTON NUCLEAR GENERATING STATION MUNICIPALITY OF CLARINGTON COMMENTS — DRAFT SCOPING INFORMATION DOCUMENT RECOMMENDATIONS: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1. THAT Report PSD-077-11 be received; 2. THAT Council endorse the comments on the Draft Scoping Information Document for the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station as set out in the August 22, 2011 letter from the Director of Planning Services to the Canadian Nuclear Safety Commission, being Attachment 3 to Report PSD-077-11; and 3. THAT a copy of Report PSD-077-11 and Council's decision be forwarded to the Canadian Nuclear Safety Commission and Ontario Power Generation. Submitted by: aow__,, Reviewed by: — '� David J. rome, MCIP, RPP Franklin Wu Director, Planning Services Chief Administrative Officer JAS/FL/df 26 August 2011 CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T(905)623-3379 F (905)623-0830 REPORT NO.: PSD-077-11 PAGE 2 1. BACKGROUND AND PURPOSE OF REPORT 1.1 Ontario Power Generation (OPG) has initiated the approvals process necessary to permit the refurbishment of the four reactors at the Darlington Nuclear Generating Station (DNGS) and their continued operation to about 2055. Related activities will include site preparation, the construction of storage buildings and support buildings/structures, and the interim management of used nuclear fuel on-site. 1.2 On July 21, 2011, the Canadian Nuclear Safety Commission (CNSC) issued the "Draft Scoping Information Document for the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station" (Attachment 2). The CNSC also sent a letter to the Mayor inviting the Municipality to provide comments on the draft document by August 22, 2011, the end of the public comment period. 1.3 In order to meet the commenting deadline, the Director of Planning Services submitted a letter to the CNSC with the the Municipality's comments on the draft document (Attachment 3). The letter was reviewed by the Mayor prior to its submission. 1.4 The purpose of this report is to obtain Council's endorsement of the comments on the "Draft Scoping Information Document for the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station", as set out in Attachment 3. 2. OVERVIEW OF DRAFT SCOPING INFORMATION DOCUMENT 2.1 The purpose of the Scoping Information Document is to: • Establish the scope of the Environmental Assessment (EA) being careied out by OPG for the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station; and • Provide OPG with project-specific guidance for the conduct of environmental technical studies. 2.2 The draft document requires the EA to: • Describe the physical works and any specific undertakings related to the Project; • Describe the existing environment (atmospheric, surface water, aquatic, hydrogeology/geology, terrestrial, socio-economic, land and resource use, physical and cultural heritage, human health); • Identify any potential interactions between the Project and the environment; • Describe proposed measures to mitigate the adverse effects of the Project on the environment; REPORT NO.: PSD-077-11 PAGE 3 • Assess the cumulative effects of the Project with other projects and activities that may overlap with the Project temporally and geographically; • Determine any likely residual adverse effects after mitigation measures have been applied and the significance of those effects; • Describe a Follow-Up Program to verify predictions of environmental effects identified in the EA, to determine the effectiveness of mitigation measures, and to support the implementation of adaptive management measures to address previously unanticipated adverse environmental effects, and • Identify and discuss any lessons learned from the recent events at the Fukushima nuclear plant in Japan. 2.3 The Draft Scope Document notes that federal regulations require the Project to be subject to a Screening Level EA and proposes that the Project follow a complex (rather than a simple) screening track. Factors considered in this determination included the fact that no EA was prepared when the DNGS was originally built, and the increased level of public interest in nuclear-related projects and activities resulting from the events in Japan. 3. MUNICIPALITY'S COMMENTS ON DRAFT SCOPING DOCUMENT 3.1 The Municipality's comments on the Draft Scoping Information Document (Attachment 3) note that, in general terms, the factors and issues outlined in the document are appropriate for the Project as defined by OPG and achieve their intended purpose. 3.2 The letter also specifically commented on the events at Fukushima, noting that the evaluation of this event, together with other safety initiatives being undertaken by OPG and the CNSC, will help to ensure that the DNGS will continue to operate safely. This in turn will help to maintain and re-enforce the public's continued confidence in the safety of the Station. 3.3 As noted above, the Project will involve the interim storage of used nuclear fuel on-site. The letter noted that the Municipality is concerned that a long term storage facility for the used nuclear fuel will not be available by mid-century when the DNGS reaches the end of its operating life, In this regard, the Municipality supports the development of a long term management solution that would involve the used fuel being transported to a suitable facility off-site. 3.4 The letter noted a concern with the statement in the draft Document that "identified changes in socio-economic conditions ..... should be limited to those that are likely to result from the predicted changes that the project is likely to cause to the environment". Given the potential cumulative effects from all of the large construction projects to be undertaken in the vicinity of the DNGS, the Municipality is concerned that this provision may result in a less rigorous review of project-related changes to the socio-economic environment, such as traffic disruptions. REPORT NO.: PSD-077-11 PAGE 4 4. CONCURRENCE: Not applicable 5. CONCLUSION 5.1 Staff has found the draft Scoping Information Document to be generally appropriate for the Darlington Refurbishment and Continued Operations Project and recommends that the Municipality's comments on the document previously submitted to the CNSC be endorsed. 5.2 The Municipality has retained a team of consultants to peer review the draft Environmental Impact Statement (EIS) and supporting technical documents prepared by OPG for the Refurbishment and Continued Operations Project. Staff and the peer review team will be reporting to Council on the results of this peer review in Fall 2011. CONFORMITY WITH STRATEGIC PLAN The recommendations contained in this report conform to the general intent of the following priorities of the Strategic Plan: X Promoting economic development X Maintaining financial stability Connecting Clarington Promoting green initiatives X Investing in infrastructure Showcasing our community Not in conformity with Strategic Plan Staff Contact: Janice Szwarz, Principal Planner Attachments: Attachment 1: Glossary of Terms Attachment 2: Draft Scoping Information Document Attachment 3: August 22, 2011 Letter to CNSC List of interested parties to be advised of Council's decision: Andrew McAllister, Directorate of Environmental and Radiation Protection and Assessment John Peters, Ontario Power Generation Attachment 1 To Report PSD-077-11 GLOSSARY OF TERMS CNSC Canadian Nuclear Safety Commission DNGS Darlington Nuclear Generating Station EA Environmental Assessment EIS Environmental Impact Statement MPRT Municipal Peer Review Team OPG Ontario Power Generation Attachment 2 To Report PSD-077-11 Proposal by Ontario Power Generation for the Refurbishment and Continued Operation of the Darlington Nuclear. Generating Station-in the Municipality of Clarngton, Ontario Draft Scoping Information Document July 2011 CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario OVERVIEW INTRODUCTION OF PROJECT The Canadian Nuclear Safety Commission(CNSC)has received a Project Description [Reference 1 and 2] from Ontario Power Generation(OPG)for the proposed refurbishment and continued operation of the Darlington Nuclear Generating Station(DNGS) in the Municipality of Clarington, Ontario. Based on its review of the Project Description,the CNSC has determined that an EA must be conducted pursuant to the Canadian Environmental Assessment Act(CEAA). OPG's project is called the"Darlington Nuclear Generating Station(DNGS) Refurbishment and Continued Operation Project".and it is registered in the Canadian Environmental Assessment Registry under project>number 11-01-62516. PURPOSE OF SCOPING INFORMATION DOCUMENT The purpose of this Scoping Information Document is to: 1. Establish the scope of the EA being carried out,for OPG's DNGS Refurbishment and Continued Operation Project. 1. Provide OPG with project=specific guidance for the.conduct of the environmental technical studies. CONTACTS FOR THE ASSESSMENT Anyone wishing"to obtain additional'' rmation;or provide comments on any aspect of the EA berg conducted on the project may do so through the following CNSC staff contacts. Andrew McAllister Daniel Desjardins Environmental Assessment Specialist Senior Regulatory Program Officer Environmental Assessment Division. Darlington Regulatory Program Division Can Nuclear Safety,Commission Canadian Nuclear Safety Commission 280 Slater;Street, P.O. Box;_1046 280 Slater Street,P.O. Box 1046 Ottawa, Ontario K1P 5 S9.. Ottawa, Ontario KIP 5S9 Phone: 1-800=668-5284 Phone: 1-800-668-5284 Fax: (613) 995-50$6 " Fax: (613) 995-5086 Email: EA@a,cnsc-ccsn.gc.ca e-DOC 3734740 -i- CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation - Darlington Nuclear Generating Station, Clarington, Ontario Table of Contents OVERVIEW........................................................................................................................i 1. BACKGROUND .................................................................................................... 1 1.1 Project Description.................................................................................................. 1 1.2 EA Determination................................................................................................... 1 1.3 Project Coordination............................................................................................... 2 1.4 Delegation of Technical Studies................................................................................... 2 1.5 EA Project Schedule................................................................................................ 3 2. SCOPE OF THE ENVIRONMENTAL ASSESSMENT.,<;... ............................ 4 2.1 Scope of the Project........................................................... ...............................4 2.2 Factors to be Considered in the EA........................ ............................... 6 2.3 Scope of the Factors............................................... ......................... 6 2.3.1 Spatial Boundaries of the Assessment,.,. ... `....... ..s ......................... 7 2.3.2 Temporal Boundaries of the Assessment........................... ................... 7 2.4 Assessment of Public Participation.... 8 2.5 Aboriginal Participation..................... ................ ...... ............... 9 2.6 Determining the Type of Screening EA Process :'................ 9 3. PROJECT-SPECIFIC INFORMATION REQUIREMENTS .............................. 10 3.1 Project Overview and Schedule „ .:.. ..................................... 10 3.2 Proponent Organization.......... ............... ............................. 10 3.3 Purpose of the Project............. ......................................................... 10 3.4 Physical Components and Activities of the Project. .......................................... 10 3.4.1 Site Preparation and Construction of New Structures .............................. 11 3.4.2 Refurbishment Activities......'. >......... ..... .............................................. 11 3.4.3 Normal,Operations, General Information and Design Characteristics..... 12 3.4.4 Potential Malfunctions and Accidents,,i�. ....................................................... 14 3.4.5 Decommissioning .............................................................. 14 3.5 Description of the Existing Environment ............................................................. 15 3.6 Constituents of Potential Concern ............................................................... ........ 17 Valued Ecosystem Components ................................................................... 17 4. ASSESSMENT AND MITIGATION OF ENVIRONMENTAL EFFECTS....... 18 4.1 Description of Assessment Methods..................................................................... 18 4.2 Identifying Project-Environment Interactions...................................................... 18 4.3 Identifying;Likely Changes to the Environment................................................... 19 4.4 Determining Likely Residual Adverse Effects..................................................... 19 4.5 Assessment of Effects of the Environment on the Project....................................20 5. ASSESSMENT OF CUMULATIVE EFFECTS..................................................21 6. SIGNIFICANCE OF THE RESIDUAL EFFECTS .............................................21 7. FOLLOW-UP PROGRAM...................................................................................22 8. REFERENCES .....................................................................................................24 APPENDIX A. ASSESSMENT OF PUBLIC PARTICIPATION...................................26 APPENDIX B. DETERMINATION OF THE TYPE OF SCREENING ........................29 APPENDIX C. PROJECT-ENVIRONMENT INTERACTIONS MATRIX...............- 31 - e-DOC 3734740- -I- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 1. BACKGROUND 1.1 Project Description On April 28, 2011, Ontario Power Generation(OPG)wrote and provided a project description to the CNSC,indicating their intent to refurbish and to continue to operate the four reactors at the Darlington Nuclear Generating Station (DNGS)with a view of extending their operating lives until about 2055 [Reference 1 and 21. In brief,the project description indicates that refurbishment will require that a number of major components in each reactor be inspected and serviced, including replacement as applicable, during a planned outage A key refurbishment activity will be removal and replacement of the fuel channel assemblies;and feeder pipes in the reactors. Following the planned outage for each reactor, the refurbished unit will be refuelled and returned to full power operation.No more than two reactors will be in refurbishment outages at any giv. briti ime. Ongoing operation after refurbishment, including ancillary systems;will.-On: e''routine scheduled maintenance activities and inspections. The on site Darlington Waste Management Facility will be expanded(i.e., additional storage buildings) to accommodate waste from refurbishment and continued operations. 1.2 EA Determination The DNGS site,is currently licensed'as Class t'Nuc lear Facility under Power Reactor Operating Licence (PROL 13,:14/2013) and the Darlington Waste Management Facility(DWMF) is licensed as a Class 1B Nuclear Facility under Waste Facility Operating:Licence (WFOL-W4-355.02/2012). In order for OPG to undertake the proposed activities required to refurbish and continue to operate the'DNGS, amendments to both the DNGS and DWMF licences pursuant to section 24(2) of the Nuclear Safety and Control Act(NSCA) are required. The,-amendment of.a licence is a power exercised under the authority set out in subsection 24(2) of the NSCA,which is listed as a `trigger' under the Lan,List Regulations_of the,Canadian Enviromnental Assessment Act(CEAA). Therefore, there is a `trigger'`pursuant to paragraph 5(1) (d)of the CEAA. The proposed refurbishment and continued operation of the DNGS is an undertaking in relation to physical work and, as such,is defined as a `project' pursuant to section 2(1) of the CEAA. There is both a `project' and a `trigger' for OPG's proposal, and the Exclusion List Regulations do not apply. Therefore, an environmental assessment(EA)is required to be conducted prior to the CNSC taking any licensing action. As this proposal is not listed on the Comprehensive Study List Regulations of the CEAA, a screening EA is required. e-DOC 3734740 - 1 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario If the Commission concludes from the EA that the project is not likely to cause significant adverse effects,taking into account the available mitigation measures, subsequent applications (i.e.,to amend the Power Reactor Operation Licence and/or the Waste Facility Operating Licence) would be evaluated under the provisions of the NSCA and its regulations prior to the Commission making any licensing decision. In addition to the EA, another element of refurbishment planning is that OPG is conducting an Integrated Safety Review(ISR) of the DNGS in accordance with CNSC RD-360 Life Extension of Nuclear Power Plants [Reference 3]. Incases where the decision is made to implement life extension and an EA is carried out, the results of the EA and the ISR are incorporated into an Integrated Implementation Plan that describes the program for.00rrective actions and safety improvement. 1.3 Project Coordination Pursuant to the CEAA Regulations Respecting the Coordination by Federal Authorities of Environmental Assessment Procedures and Requirements,the CNSC has consulted with other federal departments to determine whether they are likely to exercise a power, function, or duty under section 5 of the CEAA and/or whether they possess expert assistance that could be used during the assessment, in accordance with subsection 12(3):of the CEAA. The CNSC is a Responsible Authority(RA)under the CEAA .'identified for this screening. DFO has declared itself to be a likely RA because the continued operation of the DNGS, specifically the condenser cooling water system;will require an authorization under section 32 of the Fisheries Act,for the destruction,of fish by any means other than fishing (e.g., impingement)if ai.application for authorization is received. Section 32 of the Fisheries Act is a `trigger' under the Eaw List Regulations of the CEAA. Health Canada(HC),Natural;Resources Canada(NRCan)and Environment Canada(EC)have beeri.identified`as-Federal Authorities for the purpose of providing expert assistance to CNSC and DFO staff during the EA. CNSC will act as the Federal Environmental Assessment Coordinator for this EA. Thy,CNSC also consulted the Ontario Ministry of the Environment(OMOE)to determine whethertlere are provincial EA requirements under the Ontario Environmental Assessment Act and other provincial legislation that are applicable to the proposal.No provincial EA is required;however, CNSC staff will keep the OMOE informed throughout the EA process. 1.4 Delegation of Technical Studies The CNSC and DFO, in accordance with subsection 17(1) of the CEAA, delegate to OPG the conduct of technical support studies for the environmental assessment and the preparation of an Environmental Impact Statement(EIS)to be submitted to CNSC staff and DFO for review.When the EIS is accepted as satisfactory, CNSC staff,with the aid of DFO,will prepare an EA Screening Report and submit it to the Commission and DFO Habitat Team Leader for consideration and decision. e-DOC 3734740 -2- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 1.5 EA Project Schedule Pursuant to the approved process for complex screenings at the CNSC, the following steps, activities and timelines have been identified by CNSC staff and discussed with DFO, other federal authorities and the proponent. The EA Process Schedule(Table 1-1) is in accordance with CNSC INFO-0774 Environmental Assessment Screening Process at the CNSC. Table 1-1 EA Process Schedule Project Milestone Lead Responsibility Date Public review of Scoping CNSC July/August 2011 Information Document Submission of Commission CNSC September 2011 Member Document (CMD)on Scoping Information Document Commission Decision on Commission TBD Scoping Information Document Submission of EIS OPG December 2011 Review of EIS by Federal and RA(s) March 2012 Responsible Authorities Response to Review RA(s) April 2012 Comments Preparation of draft EA RA(s) June 2012 Screening Report Public Review of EA CNSC July 2012 Screening Report Review of EA Screening; RA(s) July 2012 Report by Federal and Res onsible.Autl orities Finalize EA Screenin ;Re Report, -RAs August 2012 Commmission Hearing on.SA Commission November 2012 Sere Report Responsible Authority RA(s) TBD Decision on EA Screening Report Commission Decsgn on EA Commission TBD Screening Report e-DOC 3734740 -3 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 2. SCOPE OF THE ENVIRONMENTAL ASSESSMENT 2.1 Scope of the Project In establishing the scope of a project for a screening environmental assessment under the CEAA,the physical works (e.g., facilities)that are involved in the proposal and any specific undertakings that will be carried out in relation to those physical works must be determined. The physical works in this case are the four reactor units at fihe DNGS and ancillary systems necessary for their operation through to about 2055. The proposed undertakings in relation to the physical works are the refurbishment and continued operation of these units until about 2055.' Decommissioning is not part of the scope of projdct; however, a description of the preliminary decommissioning plan will be required for this EA. Decommissioning will be subject to the requirements under the NSCA and a determination regarding the application of the.CEAA Will be made at that time. The scope of project will consider refurbishment activities, including: • Site preparation and construction of storage (eg ,interim storage of low and intermediate-level wastes) and s upport buildingslstritctures, generally within the Protected Area, including, . o Retube Waste Storage Buildings)(not within the Protected Area); o Heavy Water Storage Building (HWSB); o Offices,shops and changerooms; and o Other structures that may be necessary(e.g.,building to house volume reduction equipment):' • Refurbishment activities at each of the four reactor units comprising of the following activities: o Defuelling and dewatering of the reactor; o Management of heavy water during refurbishment, including transfer to the,Heavy Water Storage Building; • Replacement of reactor components, including fuel channel assemblies and;feeder pipes; • Repair,maintenance and upgrades of systems and components for balance of plant; • Preparation of low and intermediate-level refurbishment waste for storage; • Transfer of low and intermediate-level refurbishment waste on the Darlington site; and • Management of non-nuclear waste; e-DOC 3734740 -4- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario • Interim storage of low and intermediate-level irradiated component refurbishment waste at the DWMF or immediate transport off-site to the Western Waste Management Facility(WWMF) or another approved licensed facility for centralized storage in a certified container; • Transport off-site to the WWMF or another approved licensed facility for centralized storage of low and intermediate-level miscellaneous refurbishment waste; • Transport of materials, labour force and replacement components to the site; and • Refuelling and restarting the reactors. The scope of project will consider the following acti itics related to the continued operation of the refurbished power reactors until about 2055 and the subsequent achievement of a safe state of closure,including: • Continued operation of the refurbished reactor units and ancillary Support systems; • Management of operating low and intermediate=level'radioactive waste; • Construction of additional:storage capacity at the DWMF Darlington Used Fuel Dry Storage Facility(btTDSF) for the used nuclear fuel to be produced from the proposed continued operation of the DNGS units; • Interim storage of used fuel at the DUFDSF and the refurbishment waste at the DWMF;,.. • Conduct of ongoiilg maintenance and repair,which may include the replacement;of steam generators; • Management 0:f ongoing operational non-radioactive waste • Transport;of routme:.operationaY low and intermediate-level waste to the A WMF or long-term waste„management facility; and • Operational activities required to achieve a safe state of closure prior to ;.decommissionutig. In addition,the scope of project for this EA will also include the assessment of all waste management-related activities including waste reduction activities and decontamination`:' There are other projects and activities related to the DNGS which do not fall within the scope of the current project. These projects and activities have been the subject of other CNSC licences and include the expansion of low and intermediate waste storage capacity at the WWMF for routine operational and refurbishment wastes. A screening level EA for this increased capacity at the WWMF was completed and received a favourable EA decision from the CNSC on February 15,2006. It should be noted that the WWMF receives the routine operational wastes from all of Ontario's power reactors, including Darlington, and is also the e-DOC 3734740 -5 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario candidate site to receive for storage the low and intermediate level refurbishment waste from the Darlington refurbishment project. 2.2 Factors to be Considered in the EA The scope of the screening environmental assessment under the CEAA must include all the factors identified in paragraphs 16(1) (a)to (d) of the CEAA. These are: a) the environmental effects of the project, including the environmental effects of malfunctions or accidents 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 identified in a) above; c) comments from the public that are received MZ ordance with the CEAA and its regulations; and d) measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the project. The CEAA defines an"environmental effect"m respect of a project as: (a) "any change that the project may cause in the environment,including any change it may cause to a listed wildlife species, its critical habitat or the residences of individuals of that species; as.those terms are defined in subsection 2(1) of the Species 4Risk.Act, (b) any effect of any change referred.-to in paragraph(a) on (i) health and socioeconomic conditions; (ii)physical,and cultural heritage; (iii) the current use,of lands and resources for traditional purposes by aboriginal per sons': or (iv) any,structure, site or thing that is of historical, archaeological, paleontological or architectural significance, or (c) any change to the prof ect that may be caused by the environment,whether any such change or effect occurs within or outside Canada." Paragraph 16(1)(e)provides for CNSC discretion to require consideration of other matters ..'The CNSC has determined that the EA must include the purpose of the project(Section 3:3), as well as a preliminary design and implementation plan for a follow-up program(Section 7.0). Additional or more specific factors or issues to address in the EA may be identified during the conduct of the EA. 2.3 Scope of the Factors Pursuant to section 15 of the CEAA,the CNSC must determine the scope of the factors, or the extent to which the factors in the screening need to be considered in the EA. The scope of factors identifies the geographical, spatial and temporal boundaries of the assessment, conceptually bounded in both time and space. e-DOC 3734740 -6 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario Both the spatial and temporal boundaries will remain flexible during the assessment to allow the full extent of a likely environmental effect to be considered in the screening. For instance, should the results of modelling demonstrate that there is dispersion of a contaminant that is likely to cause an environmental effect beyond the boundaries identified, it will be taken into account in the assessment. 2.3.1 Spatial Boundaries of the Assessment The geographic study areas for this screening will encompass the areas of the environment that can be reasonably expected to be affected by project, or which may be relevant to the assessment of cumulative environmental effect, including to people; wildlife and non-human biota; land;Water; air and other aspects of the natural and human environment. Study area boundaries will be defined taking into account ecological,technical and social/political considerations. The following geographic study areas are suggested: The Site Study Area: Includes the facilities,buildings and infrastructure at the DNGS facility and the area within the 914 metre exclusion zone for the site which encompasses both land surface and part of Lake Ontario water surface. Local Study Area: Comprised of an area which hes'outside of the Site Study Area. It includes all lands encompassed within the 10 km Emergency Planning Zone as identified by Emergency Management Ontario, along with all of the Municipality of Clarington and the.easterly urbanized portion of the City of Oshawa It.aiso includes the stretch of Lake Ontario between the outer limits of the Local Study Area out to a distance of approximately 1 km from shore. Regional Study Area: Extends beyond the Local Study Area and can be defined as the area within which there is the potential for cumulative and socio-economic effects. It includes the municipalities that are within 20 km of the DNGS. Aquatically, it extends westerly along Lake Ontario to the Pickering Nuclear Generating Station(approximately 35 kms) and easterly for approximately 35 Ions, out to a distance of approximately 1 km from shore. 2.3.2 Temporal Boundaries of the Assessment The temporal boundaries for this assessment must establish over what period of time the project-specific and cumulative effects are to be considered. The initial time frame for the assessment will be the duration of the project;that is,the planned operational life of the DNGS through to 2055. Where effects of the project are anticipated to continue beyond the operation of the facility (for e-DOC 3734740 -7 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario example, as a result of environmental contamination from the project), then a time frame appropriate for describing the extent of the longer-term residual effects must be defined. For example, for cumulative effects,it is important to consider that the duration of response time of biological populations to recover typically extends beyond the time after which any project source term is mitigated or shut down since it takes time to remove any adaptation/acclimation. This effects response time can span several decades for long-lived species such as white sucker, round whitefish and lake sturgeon. 2.4 Assessment of Public Participation In accordance with section 18(3) of the CEAA,the CNSC is responsible for determining the need for and level of public participatiori:of a project. Based on the public participation criteria and rationale(Appendix A), OPG's DNGS Refurbishment and Continued Operation Project was,determined o require public participation. In addition, it has been determined that CNSC's Participant Funding Program will be made available for OPG's DNGS Refurbishment'and.Continued Operation Project in order to give the public,Aboriginal groups and other stakeholders the opportunity to request funding from the CNSC to participate in its EA process. It is anticipated that such funding would be made available leading up to the development of the EA ScreemngReport and subsequenti.public hearing. . The CNSC will perform the following public participation activities: Post Notice of Commencement of EA on both the CNSC website and the Canadian Envirournental Assessment Registry once federal coordination is completed, • Post notice of availability.;of draft Scoping Information Document and allow a 3Q-day,.review and comment.period anticipated for July/August 2011; + Post notice.of availability of participant funding to review the draft EA Screening Report and participate in the public hearing; Award participant funding if appropriate; • Post notice of availability of draft EA Screening Report and allow a 30-day revievw sand corbinent period, anticipated for July 2012; • Post hearrngnotice,to allow interested parties the opportunity to participate in the one-day public hearing on the EA Screening Report.; and • Conduct a one-day public hearing on the EA Screening Report. Other public participation opportunities (e.g., workshop) may arise if deemed necessary. Notification to interested parties of these other potential public participation opportunities will happen in a timely fashion. Details on public consultation activities being undertaken by OPG can be found at: hllp://www.opp-.co!iVpower/nuclear/refurbishment/dn getinvolved.asp e-DOC 3734740 - 8- CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 2.5 Aboriginal Participation Aboriginal groups whose potential or established Aboriginal or treaty rights may potentially be adversely affected by the project will be provided with project specific information. The CNSC, as Crown Consultation Coordinator, will engage with any interested Aboriginal group to share information and address concerns on behalf of the federal government. The EA process is flexible, and intended to ensure that all concerns raised will be addressed. Interested Aboriginal groups will also be able to comment on the draft Scoping Information Document and draft EA Screening Report during the planned public review>,periods for these documents. The EIS should include a description of OPG's Aboriginal Engagement Program. 2.6 Determining the Type of Screening EA Process Criteria are used to determine whether screening EAs at the CNSC can follow a simple or complex track; depending on the potential risk that the proposal..would have on the environment and the anticipated level of public interest. Taking into consideration the criteria and supporting rationale.(Appendix B),the anticipated level of public interest(Appendix C), and other factors (see below), CNSC staff proposes to follow the"complex"screening track for OPG's DNGS Refurbishment and Continued on Project. Other factors that were considered,in this determination a r e as follows: • The existing DNGS facility has-not been subjected to an EA previously. • The events of Fukushima have elevated the level of public interest in nuclear related projects and`activities. • OPG's DN08 Refurbishment and Continued Operation Project represents a large scale project(e g.', iii terms of costs,time to complete, etc.). e-DOC 3734740 -9 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 3. PROJECT-SPECIFIC INFORMATION REQUIREMENTS 3.1 Project Overview and Schedule The EIS must identify and characterize the undertakings and the activities in relation to those undertakings that are required for the proposed project. An overview of the proposed project,together with a proposed schedule for all phases of the project is required. 3.2 Proponent Organization The EIS will include a detailed description of OPG, including its ownership, organization and structure. This description will al°so include the relevant organizational and management structure, and staff qualificationrequirements with emphasis on safety and environmental;rnanagement programs, 3.3 Purpose of the Project The"purpose of"the project is defined as what;is ao be achieved by carrying out the project. The screening report will provide a clear and comprehensive statement of the purpose of the project. The need for the electricity to be generated by OPG would involve consideration of broader public policy issues that are under the authority of the Province of Ontario and over which the CNSC has no regulatory—authority. Consequently this matter is not within the.,scope of this`EA. Similarly,the separate questions of"alternatives"to the project for generating electricity such as by building a hydroelectric facility or conserving energy are matters under the authority ..the of Ontario and are beyond the CNSC's legislated mandate and.control underthe NSCA. Furthermore,this is an EA for a specific project,;rather than for a policy direction. "Alternative means" of carrying out the project such as location,or alternative means of refurbishing components are not relevant green DNOS is an existing facility of a particular design. 3.4 Physical Components and Activities of the Project An adequate description of the project is necessary to permit a reasonable consideration in.the screening of the environmental effects of the project. The main objective of the project description is to identify and characterize those specific components and activities of the project that have the potential to interact with, and thus result in a likely change or disruption to the surrounding environment, during normal operations and during malfunctions and accidents. The description of the project will include and elaborate upon,the items identified in the project scope, supported with appropriate maps and diagrams. The description of the project will include a proposed schedule for the staged restart and return to service of the DNGS units. To ensure a conservative assessment approach,it should be assumed that all four DNGS reactor units will e-DOC 3734740 _ 10- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario continue operating through to about 2055. The maximum effects of operation would therefore be assessed even though all units may not be actually operating simultaneously during the entire period. The DNGS is an existing licensed facility with an operating history. Actual environmental performance information, in addition to future performance predictions,will therefore be considered in describing the characteristics of the project to the extent that it is relevant to the assessment. The description of the physical components and activities of the project will refer to, and elaborate on the items identified in the scope of the project(see Section 2.1). The following information addressing the refurbishment and the continued operation phases of the project will be provided in summary form; where applicable,reference maybe made to more detailed information. 3.4.1 Site Preparation and Construction of New Structures il Site preparation and construction of new structures should include but not be limited to: • Excavation, site grading, compaction,pavmg, arid construction of foundations and structures; and • The toxicity and characteristics,of any chemicals, additives or speciality construction materials required(uicluding their designation under the Canadian Environmental Protection Act(1999)). 3.4.2 Refurbishment Activities Refurbishment activlties at each of the:four reactor units should include but not be limited to: Defuelling(e,g.,remoyal.of fuel using fuelling machines) and dewatering of the reactor; Management,of heavy.water during refurbishment, including transfer to the HWSB to be constructed within the Protected Area; • Replacement o f.reactor components, including fuel channel assemblies and feeder pipes; • Modifications to containment structures to facilitate replacement of reactor components; • Repair,maintenance and upgrades of systems and components for balance of plant; • Preparation of low and intermediate-level refurbishment waste for storage, including volume reduction processing; • Transfer of low and intermediate-level refurbishment waste on the Darlington site; • Management of non-nuclear waste; e-DOC 3734740 - 11 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario • Interim storage of low and intermediate-level irradiated component refurbishment waste at the DWMF or immediate transport off-site to the WWMF or another approved licensed facility for centralized storage in a certified container;. • Transport off-site to the WWMF or another approved licensed facility for centralized storage of low and intermediate-level miscellaneous refurbishment waste; • Transport of materials, labour force and replacement components to the site; and • Refuelling and associated operations (e.g.,refill primary heat transport and moderator systems, and system commissioning); • Returning reactors to full power; and. • The condenser cooling water system. 3.4.3 Normal Operations, General Information and Design Characteristics General information, design characteristics'and normat;operations should include but not be limited to: • the location of the project;' • the planned operational life(justified on a unit-by-unit basis where applicable); • the basic configuration,layout, shape, size, design and operation of the facility, • a description of normal operations for the DWMF,Heavy Water Storage Building,Tritium Removal Facility as well as any new infrastructure to be constructed fnr.this'prole ct inside the protected area; • 'the key operational`components and activities of the plant(following completion d refurbishment work) and ancillary systems, including a discussion of Component.age and wear issues where relevant to future environmental performance and reliability; • the key components of the plant and its 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 and accidents; • identify and describe engineered and administrative controls,including use of an approved margin of subcriticality for safety, which would assure that the entire (out of reactor)process will be subcritical under normal and credible abnormal conditions—accidents or accident sequences—that have frequency of occurrence equal to or greater than one in a million years; • a discussion of past events that are relevant to the assessment of future environmental performance and reliability; e-DOC 3734740 - 12- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario • maintenance,repairs, cleaning and decontamination during planned shutdowns and outages,including replacement of steam generators if necessary; • the stored inventories of radioactive and other hazardous materials used as part of the project,including locations and storage methods, and criticality control plans; • the estimated activity in Bq of the waste that will be generated and stored at each of the waste management areas as a result of refurbishment; • the sources,types and quantities of radiological and non-radiological waste, including hazardous waste, predicted to be generated by the project; • the on-site processes for the management of radioactive and non-radioactive waste, including hazardous waste, such as collection,handling and transportation, to be generated by the project; • the sources, quantities,physical and Chemical characteristics, and'points of release from the project of routine radiological and non-radiologicatemissions and effluents, including thermal(heat)fi* • the area of exposure to the,physical effects of the discharge jets and intake structure associated with the.condenser cooling water system; • the predicted doses to workers,including doses to contract workers,involved with the operations and activities that are within the scope of this project; • the sources and characteristics oflany fire hazards; • the sources and characteristics of any noise, odour, dust and other likely nuisance effects from the project; • results of past emission anal of fluent.monitoring at the DNGS site as relevant to establishing a pre-projecfi environmental baseline and making future predictions of environmental performance. Limitations in the coverage and/or accuracy of past monitoring'information should be discussed; • the predictions of future emissions and effluents from the project under `normal operating;conditions; • the sources and characteristics of any potential risks (including radiological risks)lto Workers, the public or the environment from the project; • key operational procedures relevant to protection of workers,the public and the enviromment relating to the project, including the criticality control program; and • a description of the relevant organizational and management structure, and staff qualification requirements with emphasis on safety and environmental management programs; and • end of operational activities to achieve a safe state of closure prior to decommissioning, including but not limited to: e-DOC 3734740 - 13 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation-Darlington Nuclear Generating Station, Clarington, Ontario • removal of fuel from reactor; and • draining and drying of reactor. 3.4.4 Potential Malfunctions and Accidents The discussion and evaluation of potential malfunctions and accidents should include the following: • an identification and discussion of any past abnormal operations, accidents and spills to the extent that they are relevant to the current assessment for the purpose of identifying accident and malfunction scenarios; • a description of postulated accident sequences leading to radiological release that could occur with a frequency greater than 10 6 per year considering as appropriate internal events,internal hazards, external'hazards and human- induced events, including an explanation of how these events were identified, and any modeling that was performed, for the purpose of this environmental assessment; • a description of specific criticality events,,(out of reactor) and a demonstration that consequences of the events do not violate criteria established by international standards [Reference 4] and national guidance [Reference 5] as a trigger for a temporary public evacuation; • a description of specific conventional„malfunction and accident events that have a reasonable probability of occurring_during the'life of the project, including an explanation of how.fhese.events - ere identified for the purpose of this environmental assessment'; . • the source,'quant ty mechanism,pathway,rate, form and characteristics of contammants.and other materials (physical, chemical and radiological) likely to be release( the surrounding environment during the postulated malfunctions and accidents, 01:`` an assessment of potential health and environmental effects resulting from the release of coiritaminatid.n during any postulated malfunction or accident; • any contingency;,clean-up or restoration work in the surrounding environment that.would be required during, or immediately following,the postulated malfunction and accident scenarios; and • an rdentifrcation and discussion of any lessons learned from the events at Fukushima to the extent that they are relevant to the assessment of malfunctions and accidents for this project. 3.4.5 Decommissioning A preliminary decommissioning plan for the facility will be included in the assessment. The preliminary plan will document the preferred decommissioning strategy, including a justification of why this is the preferred strategy. It will also include end-state objectives,the major decontamination, disassembly and remediation e-DOC 3734740 - 14- CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario steps; the approximate quantities and types of waste generated; and an overview of the principal hazards and protection strategies envisioned for decommissioning. 3.5 Description of the Existing Environment A description of the existing environment is needed to determine the likely interactions between the project and the surrounding environment and, conversely,between the environment and the project. Both the biophysical environment and the socio-economic(human, cultural) environment are to be considered. 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 .n.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 should,mclude results from studies-.done prior to any physical disruption of the environment due to initial site,clearing activities planned as part of the site preparation phase. The baseline description must include characterization of environmental conditions resulting from historical and present activities in t :local and regional study area(see Section 5 Assessment of Cumulative Effects). An inventory of radiological and non-radiological contaminants at the DNGS site should be:included. The EIS must compare baseline data with applicable federal,provincial,municipal or other legislative requirements, standards, guidelines or objectives (e.g.,Reference 6 and 7). An initial screening of lik m ely project-environment interactions will be used in identifying the relevant components of the environment that need to be described. The environmental components should be further divided into environmental sub- components as appropriate. In general,the environmental components that are typicall ;described in the various study areas may include,but are not necessarily limited to: Atmospheric..Environnient: • radioactivity in the atmospheric environment; • air quality (physical and chemical); • noise/dust; and • meteorological conditions. Surface Water Environment(on-site and Lake Ontario): • radioactivity in surface water and sediments; • surface water and sediment quality(physical and chemical); • surface hydrology(flow/level); and e-DOC 3734740 - 15 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario • drainage alteration. Aquatic Environment(on-site and Lake Ontario): • radioactivity in aquatic biota; • aquatic biota; and • aquatic habitat. Hydrogeology/Geology: • radioactivity in groundwater(e.g., tritium); • groundwater quality (physical and chemical); • hydrogeology; • geology and geotechnical data(including human-made geotechnical structures) ; and • seismic activity. Terrestrial Environment: • radioactivity in terrestrial environment; • vegetation communities and species; • wildlife habitat and species, and_ • soil quality (chemical and physical),,aud. . The description of the human components of the above environment may include, but should not,necessarily be limited<ao Socio-economic Condifid66s: • communitiesand population; • employacnent and business activity; • comniun�ty:infrastructure and services; • regional health,services and public health infrastructure; and • transportation system. Land and Resource Use: • use of lands and resources for traditional purposes by aboriginal persons; • other uses (e.g., recreational,forestry,hunting,trapping); and existing and planned use of water resources (e.g., drinking or recreation). Physical and Cultural Heritage: • archaeology; and • cultural landscapes. Human Health: • radiation dose to general public; • radiation dose to workers; • radiation dose to the critical group; e-DOC 3734740 - 16- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario • chemical exposure to public; • chemical exposure to workers; and • physical hazards. The required level of detail in the description of the existing environment will be less where the potential interactions between the project and various components of the environment are weak or remote in time and/or space. Existing information(e.g.,baseline data,traditional knowledge,etc.)may be used to describe the environment.Where relevant existing information is significantly lacking, additional research and field studies may be required to'complete the screening assessment. CNSC staff will review any work done by OPG to fill identified gaps in information as progress is being, de . 3.6 Constituents of Potential Concern Constituents of potential concern(COPC8 are the contaminants that could potentially be released to the environment as a result.of the proposed project, and may cause a change to one or more of the environmental components.Any relevant COPCs must be identified in the description of the existing environment. To assess effects on the biophysical environment,'it is necessary to identify the criteria against which the effects of COPCs will be measured. These criteria are collectively called the criteria of assessment. Several types of criteria may be used including published guidelines that are intended to be protective of all species and toxicity reference,.values that are species specific and used to assess the risks of potential effects. Where toxicity reference values are used,preference is given to peer-reviewed sources.` 3.7 Valued Ecosystem Components The_assessment of environmental effects on the biophysical environment focuses o valued`ecosystem components (VECs). VECs are environmental attributes or components identified as having a legal, scientific, cultural, economic or aesthetic value. The term"VEC"is sometimes applied to all components of the environment including air, land, soil, water, aquatic and terrestrial plants and animals and people,., VECs in the existing environment will be identified and used as specific assessment end points. Measurement end-points will be identified, as appropriate,, Explicit calculation of radiation doses to non-human biota should be performed with recognized approaches and software tools. Details of transfer parameters and their validation for site conditions should be well-documented. Site-specific data, and/or authoritative data sources, should be used to support model structure and parameter choices. Particular attention should be paid to the choice of food chain transfer factors for VECs,which can vary by orders of magnitude in different environments for different species. e-DOC 3734740 - 17- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario Use of any software tool is acceptable if it can address risks to VECs explicitly or by reasonable analogy. If the approach of Environment Canada&Health Canada [Reference 8] is not used, the model structure and implementation should be described in detail. It is not acceptable to simply refer to a software handbook. A few representative worked examples of simple dose calculations starting with media and/or food concentrations should be presented,regardless of the approach taken, to allow independent validation. 4. ASSESSMENT AND MITIGATION OF ENVIRONMENTAL EFFECTS 4.1 Description of Assessment Methods The consideration of enviromnental effects in the screening should be done in a systematic and traceable manner. The assessment methodology will be summarized in the screening report. The results of the assessment process should be clearly documented using summary matrices and tabular summaries"where appropriate. In describing methods,the proponent must document how it used scientific, engineering,traditional and oiherlcnowledge to reach its conclusions. Assumptions must be clearly identifed,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 as must be prepared using best available information andmethods;'to the highest standards in the relevant subject area. All conclusions must be substantiated.,._ In.preparing the EIS; the,,proponent is encouraged to make use of existing information relevant to the project(e.g.,Reference 9). When relying on existing information to meet the requirements of various sections of the Scoping Information Document,the proponent must either include the information directly in the EIS or provide-a summary and clear direction(e.g.,through cross- referencing)to where the information can be obtained. 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. 4.2 Identifying Project-Environment Interactions The initial stage of the assessment requires the identification of project activities that may interact with the biophysical environment or socio-economic environment during project implementation and during relevant malfunctions and accidents.The identification of potential interactions is performed using a Project-Environment Interactions Matrix(Appendix Q. Those interactions that could adversely interact with the environment will be identified through the EA e-DOC 3734740 - 18- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario process. The assessment of environmental effects would then involve predicting and evaluating the likely implications of these project activities to determine which interactions have the potential for likely adverse effects. A preliminary table of project-environment interactions is provided in Appendix C. This matrix illustrates where the project may potentially negatively interact with the environment. The development of this matrix is based on CNSC staff experience with the site, experience with assessments of similar projects (e.g., Pickering Refurbishment and Continued Operation EA), and knowledge of the project description. It is expected that OPG will update this table and use it .o form`the basis of assessment. Information on the pathway that a potential contaminant may take to get to a specific habitat should be provided in a conceptual site model diagram that represents cause-effect pathways so risk can be calculated [Reference 10 and 11]. 4.3 Identifying Likely Changes to the Environment The second step in the assessment is to describe the resulting changes that likely would occur to the components of the environmentand VECs as a result of the identified interactions with the project. Identified changes in socio-economic conditions and various aspects of culture, health,heritage, archaeology and traditional land.and resource use should be limited to those that,are likely to result from the predicted changes that the project is likely to caus0 to 4 1 environment 4.4 Determining Likely Residual Adverse Effects The third step m the a ssessment Js,to identify and describe mitigation measures that may be.applied to each likely adverse effects (or sequence of effects), and thiit are teChmeally and'`economically feasible. 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 mitigateYadverse environmental effects. For example, for aquatic habitat and,biota,thermal plume effects as well as intake withdrawals of aquatic biota are both.an historical operations and continued operations effect that has been reduced;but not eliminated by the unique designs of the existing submerged offshore intake and diffuser, and will require assessment in the EIS. 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 e-DOC 3734740 _ 19- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario recovery strategy and action plans. Therefore,the proponent must include information in the EIS that will allow the Responsible Authorities to meet this requirement. Mitigation strategies should reflect avoidance,precautionary and preventive principles; that is, emphasis should be placed on tempering or preventing the cause or source of an effect, or sequence of effects,before addressing how to attenuate,reverse or compensate'for an effect once it occurs. The proponent shall consider the guiding principles set out in the Franiework for the Application of Precaution in Science-based Decision Making About Risk[Reference 12]. Where the prevention of effects cannot be assured, or the effectiveness of preventive mitigation measures is uncertain, further mitigation measures in the form of contingency responses, including emergency response plans, will be described and considered through the follow-up program(S66-on 7.0). Those effects to the environment that would remain after the implementation of mitigation measures should be identified as residual.effects. Any residual effects identified should 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 re stdual••adverse environmental effects it predicts. It must contain clear and sufficient.information to enable the CNSC and the public to understand and review the proponent's judgment of the significance of effects. The proponent must define the terms used'to deserlbe'the level of significance. 4.5 Assessment of Effects of the Environment on the Project The assessmentmust also take into account;how the environment could adversely affect the project;for example,from severe weather, geotechnical hazards or seismic events. The assessment must also take into account any potential effects of climate change on the project, including an assessment of whether the project might be sensitive to changes in climate conditions during its life span. Guidance can be found on-the.Canadiau Environment Assessment Agency website [Reference 13]. An identification and discussion of any lessons learned from the events;at Fukushin a to the extent that they are relevant to the assessment of effects o f the environment on the project should be included. This part of the as will be conducted in a step-wise fashion, similar to that described for the foregoing assessment of the project effects. The possible important interactions between the natural hazards and the project will be first identified, followed by an assessment of the effects of those interactions,the available additional mitigation measures, and the significance of any remaining residual adverse environmental effects. e-DOC 3734740 -20- CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 5. ASSESSMENT OF CUMULATIVE EFFECTS The effects of the project must be considered together with those of other projects and activities that have been, or will be carried out, and for which the effects are expected to overlap with those of the project(i.e., overlap in same geographic area and time). These are referred to as cumulative environmental effects. The effects of multiple stressors (e.g.,radiological,non-radiological,temperature) on receptors should also be considered. An identification of the specific projects and activities considered for the cumulative effects assessment will be included in the screening report. Emphasis should be placed on those projects that have occurred orare.,occurring and on future projects that are either `certain' to proceed or are reasonably foreseeable. The information available to assess the environmental effects from other projects can be expected to be more conceptual and less detailed as those effects become more remote in distance and time to the project, or where information about another project or activity is not available. The_consideration of cumulative environmental effects may therefore be at a more general level of detail than that considered in the assessment of the direct project-environment interactions. Where potentially significant aduefse cumulative effects are:.identified, additional mitigation measures may be necessary 6. SIGNIFICANCE,OF THE RESIDUAL EFFECTS The prece.drrrg steps in the screening will consider the significance of the environmental effects of the project on the environment; of the natural hazards on the project; and of other proiects-and,actvities that could cause cumulative effects. The criteria forp, gingand describing the significance of the residual(post- mitigation) effects will include the following categories: magnitude, duration, frequency,timing, and probability of occurrence, ecological and social context, geographic extent, and degree of reversibility. Existing regulatory and industry standards and guidelines are relevant as points of reference for judging significance.However,professional expertise and judgement should also be applied in judging the significance of any effect. All applicable federal and provincial laws must be respected. The EIS must clearly explain the method and definitions used to describe the level of the adverse effect(e.g., low,medium,high)for each of the categories in the above paragraph,and how these levels were combined to produce an overall conclusion on the significance of adverse effects for each VEC. This method must be transparent and reproducible and should clearly discriminate between sources in the published literature and professional judgment. e-DOC 3734740 -21 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario The analysis must be documented in a manner that readily enables conclusions on the significance of the environmental effects to be drawn. The CNSC (an RA) and DFO (likely RA)must document in the screening report a conclusion,taking into account the mitigation measures, as to whether the project is likely to cause significant adverse environmental effects. 7. FOLLOW-UP PROGRAM In general, the purpose of a follow-up program is to: • verify predictions of environmental effects identifiiWn the environmental assessment; • determine the effectiveness of mitigation measures in order to modify or implement new measures where required, and' • support the implementation of adaptive_management measures to address previously unanticipated adverse environmental effects. The EIS will contain a preliminary design and implementation plan fox the follow-up program that provides the following. • the purpose of each element of the follow-up program(i.e.,to verify predictions, or to ensure mitigation measures are effective); • what would be monitored; • monitoring locations; • schedule (i.e., frequency and duration of monitoring); • monitoring objective.in relation to the specific`'EA finding, assumption or mitigation to be verified. • contingency procedures/plans or other adaptive management provisions as a means of addressing unforeseen environmental effects or for correcting ,exce.edances as required"to com ply'or to conform to benchmarks,regulatory standards or;guidelines; and • the responsible.department;that would receive the information and determine a course of action„if required. The proposed schedule would be developed after statistical evaluation of the length oftime 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). In addition, as part of adaptive management,the EIS will describe how OPG will determine if the continued operation of the DNGS is affecting species at risk, given, for example, the rapidly changing Lake Ontario ecosystem and ongoing and future recovery strategies, action plans or management plans (e.g.,Atlantic salmon,Lake sturgeon). 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 effects (or e-DOC 3734740 -22- CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario absence of them), confirm environmental assessment assumptions and confirm the effectiveness of mitigation. The CNSC licensing and compliance program and DFO's authorization process, if required, along with signed agreements/MOUs with provincial and federal authorities will be used as the mechanisms for ensuring the final design and implementation of any follow-up program and the reporting of program results. e-DOC 3734740 -23 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 8. REFERENCES I. OPG Letter,D. Reiner(OPG)to P. Webster(CNSC), "Proposed Refurbishment and Continued Operation of Darlington NGS—Project Description for Environmental Assessment", April 28, 2011. e-DOC: 3715868. 2. OPG Report, "Project Description: Darlington Nuclear Generating Station Refurbishment and Continued Operation Project—Environmental Assessment", OPG Report#NK38-REP-07730-10001_0 April 2011. e-DOC: 3715869. 3. CNSC Regulatory Document 360—Life Extension of Nuclear Power Plants. February 2008. ISBN 978-0-662-47492-0; Cat:No. 0673-3/4-360E-PDF. 4. Food and Agriculture Organization of the United Nations,International Atomic Energy Agency, International Labour Organizations OECD Nuclear Energy Agency,Pan American Health Organization,United nations Office for the Co-Ordination of HumanitariallAffairs, World Health Organization, "Preparedness and Response to Nuclear or.Radiological Emergency, Safety Requirements", Safety Standards Series No; o. ,GS-R-2,IAEA,Vienna, Austria, 2002. 5. Health Canada, "Canadian Guidelines for Intervention.during a Nuclear Emergency", Document 1146�2/0342E,.Ottawa, Ontario,November 2003. 6. Canadian Council of Ministers;of the Envioonment 2009. Canadian Environmental Quality Guidelines.http://cegde.ccme.ca/ 7. Ontario Ministry of.the Enviromment 2009. Forms,Manuals and Guidelines. hqp://www.ene.goy ou.ca/eplpubl6ations/forms/index.php 8. Environment Canada&Health Can4da'(2003) "Priority Substances List 2 Assessment Report:;Releases of Radionuclides from Nuclear Facilities (Impact on Non human Biota)';;Environment Canada and Health Canada, Ottawa,Canada— 4DOC: 3397890. 9. OPG Report; 'Environmental Impact Statement: New Nuclear—Darlington Environmental Assessment NK054-REP-07730-0029. September 2009. e- bOC: 3437533 10. Canadian Council of Ministers of the Environment(COME) 1996, "A Framework for Ecological Risk Assessment: General Guidance", Canadian Council'4f Ministers of the Environment(CCME),The National Contaminated Sites Remediation Program,Report PN 1195 e-DOC 3397684. 11. Canadian Council of Ministers of the Environment(COME) 1997, "A Framework for Ecological Risk Assessment: Technical Appendices", Canadian Council of Ministers of the Environment(CCME),the National Contaminated Sites Remediation Program,Report PN1274 - e-DOC: 3397691. 12. 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—e-DOC: 3397689. e-DOC 3734740 -24- CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation-Darlington Nuclear Generating Station, Clarington, Ontario 13. The Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment 2003. Incorporating Climate Change Considerations in Environmental Assessment: General Guidance for Practitioners. hgp://www.ceaa- acee.ge.ca/default.asp?lang=En&n=A4lF45C5-1 e-DOC 3734740 -25 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario APPENDIX A. ASSESSMENT OF PUBLIC PARTICIPATION Evaluation of Criteria Assessment Criteria None Low Moderate High 1. There is an indication of existing or likely public interest in : a. the type of project b, the location of the project or c. the ways the project might affect the kk�, community. 2. The stakeholders who may be interested have a history of being involved. ,* 3. The project is likely to generate conflict between environmental and social or economic values of concern to the public Ak, X, 4. The project could be perceived as having the potential for significant adverse environmental effects (including cumulative environ e tal effects and effects of malfunctions and acciden °, 5. There is potential to learn from comm knowledge or Aboriginal traditional knowl e. 6. The direct and indirect environmental eff&o the project and their signiS9121gre uncertai 7. The project has not ban subs o other pub AM participation proce g: prop e scope and coverage that would mee SC i actives. Count nu . o a arks ch column 0 3 1 3 Multip y: I& 71W x 0 x 1 x 2 x 3 Tota fo h column is 0 3 2 9 Add totals f overall s a of: 14 Rationale for determination Criterion 1. a. The New Nuclear at Darlington (NND)project that went through 3 weeks of public hearings through a Joint Review Panel process (April 2011) allowed for the engagement of the public,Aboriginal groups and other interested parties. Given this recently completed process along with the events at Fukushima, the CNSC is aware of existing and continuing high level of public interest in nuclear-related projects. e-DOC 3734740- - 26 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG-Refurbishment and Continued Operation-Darlington Nuclear Generating Station, Clarington, Ontario Rationale for determination b. The CNSC is aware of existing public interest concerning current and proposed activities at the DNGS site, especially when taken in combination with the proposed NND project to be located adjacent to the DNGS facility. c. The project is not anticipated to negatively affect the community. OPG's NND EIS determined that few adverse effects were expected on the socio-economic environment; rather,positive effects were anticipated related to economic development. Criterion 2. The Darlington NND project received over 200 written submissibns from interveners during the public hearing phase. Similarly,the Pickering B Refurbishment and Continued Operations EA, completed in 2009 generated a lot of pubiic 'interest It is anticipated that many of the same interveners will be interested in participating in the DNGS Refurbishment and Continued Operation EA. Local stakeholder involvement in the NND project`was;,generally supportive based on what OPG had documented in its EIS and through what was bard during the public hearings. Criterion 3. During the NND JRP, a number of interveners were.opposed to the tise of nuclear power as a means to generate electricity and advocated use of other alternative energy sources (e.g., wind, solar,biomass, etc.). These concerns were, u-ther exacerbated by the events at Fukishima. Criterion 4. During the NND JRP hearings,with the backdrop of the events of Fukushima, many concerns were raised by interveners regarding potential malfunctions and accidents and their consequences- related human health effects. As well, the operation of the condenser cooling water system(e:g.�,impingement and entrainment)was a project element that=many interveners highlighted as having serious environmental effects. Criterion S There is no indication of relevant traditional knowledge at this time based on the disturbed nature of the DNGS site and information that was put forth during the NND JRP process. Criterion 6. Based on OPG's project description,previous EAs (i.e.,NND project,Pickering B Refurbishment and Continued Operation), and CNSC's knowledge of ongoing operations of the DNGS,the environmental impacts, as well as likely mitigation to be required are general well understood. Those elements were there may be a degree of uncertainty, include: the impacts to aquatic biota from the operation of the condenser cooling water system; and malfunctions and accidents. The uncertainty arises more from the fact that CNSC staff has yet to review the analyses, etc. that will support the assessment of effects in e-DOC 3734740 -27- CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario Rationale for determination these areas. Criterion 7. The NND JRP process represented a very thorough public participation process; however, elements of this project were not specifically included. Although OPG is actively engaging the public on this project, this would not completely meet the CNSC objectives. Given the anticipated public interest, this project will be subject to a CNSC project-specific public participation process. As a result of the scan above, is public participation appropriate in the circumstances of this screening-level EA? Yes or No ❑ If yes, indicate the level of participation required,based on Ahe tabulated score. None ❑ Low Q, Moderate High El Oto2 3to7 8to14 15 to 21 e-DOC 3734740 -28 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document-Proposal by OPG-Refurbishment and Continued Operation- Darlington Nuclear Generating Station Clarington, Ontario APPENDIX B. DETERMINATION OF THE TYPE OF SCREENING Evaluation of Criteria Criteria_Evaluation Questions for Simple Yes/True Uncertain No/False Screenings 1. The site is well characterized, as are its programs. 2. The proposed project is related to an existing licensed facility. 3. The proposed project represents an incremental change to the overall facility. 4. The environmental performance of the existing licensed activities meets CNSC expectations. 5. The proposed project is based on technology that is known to the proponent and CNSC staff. 6. The proposed project would only require mitigation measures with which the proponent has a demonstrated familiarity, and/or that are considered standard technology within the industry. 7. The proposed project likely does not introduce project-environment interactions.that cannot Ye mitigate � 1 ndard or proven technology. 8. B on potenti ect environment tions,the pro d project is not likely to pose significant a se effects on the health of wor nd the pub cumulative effects, or those that T arise as esult of accidents or malfunction . Rationale for determination 1. The site is well characterized through its existing programs and through the NND JRP process. No changes are proposed to the way the DNGS facility is currently operated. 2. The proposed project is located on an existing licensed facility. e-DOC 3734740- - 29 - CEAR 11-01-62516 July 2011 Draft Scoping Information Document- Proposal by OPG- Refurbishment and Continued Operation- Darlington Nuclear Generating Station, Clarington, Ontario 3. The proposed project consists of activities (i.e.,refurbishment and continued operations) that represent an incremental change to the overall licensed facility. 4. Under the direction of the CNSC, OPG has continued to make adequate provisions for the protection of the environment. In making these provisions, OPG has met CNSC expectations in environmental performance. However, thermal plume effects on aquatic habitat and biota as well as intake withdrawals of aquatic biota are both an historical operations and continued operations effect that has been reduced but not eliminated by the unique designs of the existing submerged offshore intake and diffuser. 5. CNSC staff is familiar with the technology being presented in this project, given the existing operations at DNGS and the fact that several other nuclear power plants are undergoing refurbishments. OPG and/or the industry,is,familiar wit$all other project components. 6. OPG and/or industry are familiar with the potential mitigation measures requited for the refurbishment and continued operation of the DNGS:,, 7. Any new project-environment interactions are expected to,;:be adequately mitigated with standard and/or proven technology. 8. At this stage of the EA, it appears that this project is not likely to cause significant adverse effects on the health of workers and the public, cumulative effects, or those that may arise as a result of accidents or malfunctions. The EA will identify all potential project-environment interactions and confirm that the project is not likely to cause significant adverse.effects. However, an EA has never been completed for the DNGS site, including malfunctions and accidents. As a result of the scan* above, is a simple screening appropriate in the circumstances? *The criteria identified in the..above scan are meant to guide CNSC staff. Other factors can influence staff's recommended type of screening. In the case of OPG's DNGS Refurbishment and Continued Operation project,the heightened public interest in nuclear- related activities as a xesult of the events at Fukushima; the absence of a previous EA for the DNGS facility; and the Scale of the proposed project are all other factors that have contributed to CNSG staff's recommendation that the project proceed as a complex screening. YES or NO [� e-DOC 3734740 - 30- CEAR 11-01-62516 c cr a F asn puuZ, •c - m +, U id y n I L LI I_: 17 n I_1 LI ❑ o ° szpadS Puu jsalgsH OPIPUM satoodS ❑ ❑ ❑ ❑ ❑ ❑ ❑ c W 2y sallmituzuio�. oijuja2an m WINUH pug ujoig Di i3nbd n ❑ u ❑ ❑ n n I_I L- n aci q ' w ❑ ❑ .❑ 'Q ❑ ❑ ❑ ❑ ❑ Q ,Uiieno rajuM puu a2L>6ruzQ � W z 0.1mm0duial E-1 u n C 0 0 c d uoijuittoi[D oliujup a3IuZ m - - MO(3 ❑ ❑ o 010 /a2.iugoaj iolumpunwo � � o >~ �Cj!junb.i3juiApunojD ❑ ❑ O c iTOS ❑ ❑ U X sia3I.to/A of sasoQ uoljuipug ❑ ❑ ❑ ❑ C] ❑ '❑ .. ID ' cco ~ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Q c oilgnd of sosoQ uorjuipu2l c C: a juOLuuo.�tnug 42010320ap�iH El ❑ O Q El ❑ Z O ❑ 1-1 ❑ ❑ ❑ Iuauiuozrnug Iulzjsa.131 ❑ ❑ ❑ V a oponbd/nivAk omyaiS ❑ ❑ ❑ ❑ ❑ ❑ jUOWUO.nnug oijaudsourab ❑ ❑ ❑ ❑ u F- 0 W Z a ❑ ❑ ❑ ❑ ❑ o ❑ ❑ ❑ o Z c asio1l CL 0 ❑ n n ❑ u u u n L� a LU Q w 1A?Iona i?v D O a .� > D Cd `! b °' o o Z o m W c N b LLI Cd U w 0 V bq o Z d 3 Cd °o o N L cd y (1) H q G Y O N O X W C G O O N O O CO p A N O O ❑bt Z W t N N 'Cd N N fd O y W O Attachment 3 To Report PSD-077-11 Leading the Way August 22, 2011 Mr. Andrew McAllister Environmental Assessment Specialist Directorate of Environmental and Radiation Protection and Assessment Canadian Nuclear Safety Commission P.O. Box 1046, Station B Ottawa, ON KIP 5S9 Dear Sir: RE: REFURBISHMENT AND CONTINUED OPERATION OF THE DARLINGTON NUCLEAR GENERATING STATION MUNICIPALITY OF CLARINGTON COMMENTS - DRAFT SCOPING INFORMATION DOCUMENT FILE NO.: PLN 26.15.3 Further to your letter dated July 21, 2011 to Mayor Adrian Foster, please accept this letter as the comments of the the Municipality of Clarington on the Draft Scoping Information Document for the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station. As noted in the Overview, the purpose of the Scoping Information Document is to establish the scope of the EA to be undertaken for the Project, and to provide OPG with project-specific guidance on the conduct of technical studies for the EA. The Municipality finds that, in general terms, the factors and issues outlined in the Draft Document are appropriate for the Project as defined by OPG and, as such, achieve their intended purpose. The Municipality does however have a number of specific comments on the Draft Scoping Information Document, as noted below. 1. Recognition of recent events at Fukushima Japan The Darlington Nuclear Generating Station has operated safely within our community for two decades and we anticipate that the Station's exemplary record will continue to the end of its operating life. Nevertheless, the recent events at the Fukushima nuclear plant in Japan have heightened public concern with the safety of all nuclear generation facilities, including the Darlington plant. CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T 905-623-3379 Andrew McAllister, Environmental Assessment Specialist—August 22,2011: Page 2 In this regard, the Municipality, notes that the Draft Scoping Document acknowledges the effect that the Fukushima incident has had on public interest on the safety of the Darlington Station, and that the Document specifically requires the EA to identify and discuss any lessons learned from these events as they relate to the assessment of malfunctions and accidents for the Project. This evaluation, together with the Integrated Safety Review and other initiatives by OPG and the CNSC, will help to ensure that the Darlington Station will continue to operate safely for the remainder of its operating life. This in turn will serve to maintain and re-enforce the public's continued confidence in the safety of the Station. 2. Long Term Management of Used Nuclear Fuel The Draft Scoping Document outlines the various 6ctivities related to the continued operation of the refurbished power reactors until about 2055 and the subsequent achievement of a safe state of closure. These activities include the construction of additional storage capacity at the Darlington Used Fuel Dry Storage Facility for the interim storage of used nuclear fuel to be produced from the continued operation of the reactor units at Darlington. The Document also indicates that decommissioning of the Darlington Station is not part of the scope of the current project, but requires a preliminary plan to be prepared. This Plan is to include, among other matters, end-state objectives and an overview of the principal hazards and protection strategies envisioned for decommissioning. The Municipality acknowledges the process being undertaken by the Nuclear Waste Management Organization (NWMO) to identify and develop a suitable site for the long term storage of used nuclear fuel from Canada's nuclear generating facilities, and that it is OPG's intention to transfer used nuclear fuel from the Darlington site to this facility. i We also recognize that the closure and decommissioning of the Station will be subject i to separate study and approval requirements. However, given the challenges faced by the NWMO , the Municipality is concerned that a long term storage facility for used nuclear fuel will not be available by mid-century when the Darlington Station reaches the end of its operating life. The Municipality supports the development of a long term management solution that would involve the used fuel being'transported to a suitable facility off-site. 3. Public Participation The Draft Scoping Document indicates that the Project was determined to require public participation. Section 2.4 outlines-the public participation activities that the CNSC will perform, while Appendix A discusses the process and the rationale used to determine that the Project will be subject to a CNSC project-specific public participation process. However, there is no requirement that OPG, as the proponent, is to undertake public consultation.- The Draft. Scoping Document should be revised to require OPG to Andrew McAllister, Environmental Assessment Specialist—August 22,2011:Page 3 describe its communications and consultation program and to provide a summary of any issues or concerns identified by the public. 4. Type of Screening EA process Section 2.6 and Appendix B of the Draft Document discuss the criteria and the factors considered in determining the type of Screening EA process that the Project should be required to follow, CNSC staff has proposed to follow the "complex" screening track for the Project. The Municipality does not disagree with CNSC staff's conclusion and welcomes the more rigorous review that will likely be required of the complex screening track.' However, there is no discussion in the Draft Document or a reference to another document that would enable the reader to understand the differences between a simple and complex screening track and to determine if, in fact, the conclusion by CNSC staff is appropriate.. 5. Identifying Likely Changes to the Socio-Economic Environment Section 4.3 of the Draft Document deals with the second step in the assessment process, which is the description of any likely changes to components of the environment and Valued Ecosystem Components resulting from interactions with the Project. This section goes on to state: "Identified changes in socio-economic and various aspects of culture, health, heritage, archaeology and traditional land and resource use should be limited to those that are likely to result from the predicted changes that the project is likely to cause to the environment." The intention of this requirement is not clear. The Municipality is concerned that this provision would result in. project-related changes to the socio-economic environment being addressed differently and less rigorously than project-related changes to the bio- physical environment. This is of particular concern when considering the potential cumulative effects on the socio-economic environment, such as nuisance effects from increased traffic and traffic disruptions, as a result of the number of large construction projects scheduled to take place in Clarington during the same period that .the Darlington Project will be underway. The Municipality welcomes this opportunity to provide our comments on the Draft Scoping Information Document for Darlington Refurbishment and Continued Operation Project. Please note that these comments will be forwarded to Clarington Council for Andrew McAllister, Environmental Assessment Specialist—August 22,2011: Page 4 endorsement at its next meeting on September 19, 2011; a copy of Council's decision on the comments will be forwarded to you. Sincerely, pd- . rom]--am, CIP, RPP Director of Planning Services DJC:df cc: Mayor and Members of Council Franklin Wu, Chief Administrative Officer A.C. Cannella, Director of Engineering Services Nancy Taylor, Director of Finance Faye Langmaid, Manager of Special Projects