HomeMy WebLinkAboutPSD-116-04 Addendum
Clw:iggron
REPORT
PLANNING SERVICES
Meeting:
COUNCIL
Date:
Monday, September 27,2004
Report #:
Addendum to PSD-116-04 File #:
PLN 33.4.6
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By-law #:
Subject:
PORT GRANBY PROJECT - SELECTION OF QUALIFIED CONCEPT
RECOMMENDATIONS:
It is respectfully recommended that Council adopt the following recommendations:
1. THAT Report PSD-116-04 and Addendum to PSD-116-04 be received;
2. THAT the Municipality of Clarington concur with the recommendation of the low level
Radioactive Waste Management Office that Concept II (relocation of the Port Granby waste to
an engineered storage mound north of lakeshore Road) should proceed through the
Environmental Assessment process as the Qualified Concept for the Port Granby Project;
3. THAT the Government of Canada be advised that the Municipality of Carington is opposed to
any waste, other than that associated with the existing Port Granby Waste Management Facility,
being accepted or stored at the new waste management facility or on any of the lands to be
acquired by the Government of Canada as part of the Port Granby Project;
4. THAT the low level Radioactive Waste Management Office continue to consult with the
Municipaiity of Clarington and affected residents regarding the mitigation of impacts from the
construction and operation of the new waste management facility; and
5. THAT a copy of Council's decision be forwarded to the low level Radioactive Waste
Management Office, Natural Resources Canada, the executive of the South East Clarington
Ratepayers Association and the interested parties.
Submitted by:
Reviewed by:
i)~~~
Franklin Wu,
Chief Administrative Officer
D vid:J Crome, M.C.I.P., R.P.P.
Director of Planning Services
JAS*Fl *DJC*df
23 September 2004
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T (905)623-3379 F (905) 623-0830
REPORT NO.: PSD-116-04 (Addendum)
PAGE 2
1.0 BACKGROUND
1.1 On September 21, a special meeting of the General Purpose and Administration
Committee was held at the Kendal Community Hall to consider Staff Report PSD-116-
04 regarding the selection of a Qualified Concept for the Port Granby Project.
Presentations were made by Mr. Dave Hardy, the Municipality's lead peer review
consultant and by representatives of the South East Clarington Ratepayers Association.
1.2 Committee resolved (Resolution # GPA 389-04) to refer Report PSD-116-04 to Staff to
prepare an Addendum for the Council meeting of September 27, 2004 to address the
comments made by the residents. This Addendum Report has been prepared in
response to Committee's direction.
2.0 STAFF RESPONSE TO COMMENTS SUBMITTED BY RESIDENTS
2.1 Community Support for In-Situ Management
2.1.1 Resident Comment
The 1978 FEARO Panel Report ruled that the area to the north of the Port Granby
Residue Area is not suitable for the storage of radioactive waste.
Staff Response
The Panel's report on Eldorado's proposal was submitted as a recommendation to the
Minister of State for the Environment and was not binding on either the Minister or
Eldorado. The Minister did not render a decision on Eldorado's proposal which was
ultimately withdrawn by the company.
Natural Resources Canada (NRCan) have provided a written opinion that the projects
are different and the earlier report has no bearing on the location of waste (Concept II)
on Cameco lands. Staff and the Peer Review Team agree with NRCan's position that
the Port Granby Project must undergo its own environmental assessment, and the
findings of the Review Panel do not preclude the consideration of waste management
options on the lands subject to Eldorado's previous proposal.
This issue is discussed in Section 5.1.1 of the Peer Review Report.
2.1.2 Resident Comment
The Port Granby LLRW Advisory Committee appointed by Council in 1999 unanimously
recommended that the Port Granby waste should be stored at the current site and that
there should be minimum disturbance of the existing waste. Council accepted this
recommendation.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 3
Staff Response
The 1999 Advisory Committee's decision to only consider in-situ management options
for the Port Granby wastes was not based on any scientific or technical studies.
Council's endorsement of in-situ management as its preferred option was conditional
upon the results of a detailed comprehensive environmental assessment and the
completion of four additional studies. The results of these four studies and the
environmental assessment work to date have identified significant concerns with the in-
situ management options. It is therefore appropriate and consistent with Council's
previous resolution for Council to reconsider its preferred management option for the
Port Granby wastes.
This issue is discussed in Section 3.2 of Report PSD-116-04.
2.1.3 Resident Comment
The people of south east Clarington strongly support the on-site solution for storage of
the radioactive waste at Port Granby. It is a "made in C/arington" solution and is the
best solution for the social, economic and environmental health of the (Port Granby)
community. The opposition of local residents to Concept /I should serve as a red-flag to
Council and stop further consideration of Concept /I.
Staff Response
Staff and the Peer Review Team are very aware of the resident's concerns with
Concept II and the rational put forward by SECRA and the residents for Concept lB.
Those concerns have now been examined and tested through extensive study by
numerous professional experts with a variety of areas of expertise. The studies looked
at the ability of each option to provide a safe and environmentally secure approach for
the long term management of the Port Granby wastes. Environmental assessment
studies specifically considered community impacts and social, economic and
environmental effects on local residents. The implementation of any of the three
Feasible Concepts will have some impacts on the local community.
While the loss of agricultural land is considered to be a significant impact of Concept II,
this Concept is expected to provide the benefit enabling access to the Lake Ontario
shoreline. Significant difficulties were identified with in-situ management. Concept IA
and IB in particular will generate significantly increased truck traffic in the community.
Staff and the Peer Review Team are confident that Concept II will have the least impact
of the three Feasible Concepts on the natural environment in both the short and long
term, and any impacts to the community can be effectively mitigated.
This issue is discussed in Section 5.1.5 of the Peer Review Report.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 4
2.2 Concerns with the Environmental Assessment Process
2.2.1 Resident Comment
Excavating the waste, moving it a distance of one kilometre and placing it in a mound, is
not functionally similar to a design requiring in-situ stabilization of the waste.
Therefore, it is an "alternative to" the project design.
Staff Response
The option endorsed by Council in 1999 and which forms the starting point for the
current EA process involves long term management of the waste using a combination of
above ground and in-situ stabilization. It specifically involved the excavation of the
waste from the East Gorge to a new storage mound on the south side of Lakeshore
Road. The construction of a storage mound on the north side of Lakeshore Road for a
all of the waste as proposed by Concept II, is therefore functionally similar to the base
project. The term "functionally similar" does not only refer to on-site management
approaches to managing the waste.
This issue is discussed in Section 3.2 of Report PSD-116-04 and Section 5.1.2 of the
Peer Review Report.
2.2.2 Resident Comment
The Port Granby Project should be subject to a comprehensive level Environmental
Assessment because of the radiation levels at the existing waste site. As well, the
continuing decay of Thorium-230 will cause the future concentration of Radium-226 and
the production of radon gas to increase.
Staff Response
The regulations to the Canadian Environmental Assessment Act determine whether the
EA fora project will proceed at a screening level, which is a self-directed study by a
Federal Authority where effects are likely to be anticipated, or at a comprehensive level,
which is the next highest level and directed by Environment Canada. One of the criteria
for making this determination for nuclear and related facilities relates to the activity level
of the radioactive material to be handled.
The radio activity level at the current Port Granby facility has been found to be below
the criteria set out in the regulation; therefore, a comprehensive level EA is not required.
Nevertheless, the Federal Responsible Authorities have augmented the scope of
the EA for the Port Granby Project so that the studies being undertaken are in
fact meeting the requirements of a comprehensive level study.
This issue is discussed in section 5.1.3 of the Peer review Report.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 5
2.2.3 Resident Comment
A comprehensive level assessment of both Concept /I and Concept IB should be
undertaken and the findings of this study submitted to an Environmental Assessment
Review Panel. Alternatively, both Concepts IB and /I should proceed through the
detailed effects assessment.
Staff Comment
All three Concepts were reviewed by the LLRWMO and deemed to be feasible.
However, compared to Concept II, Concepts IA and IB were seen to have many more
concerns. Of particular note is that in-situ stabilization of a radioactive waste site on a
dynamic eroding shoreline is unproven and has not been tried anywhere else in the
world. Also, the lack of a liner for the waste and the effectiveness of a ground water cut
off wall are addressed as possible points of failure for Concept IA and IB, if they were to
fail, the contingency plan is to then adopt Concept II.
In the next stage of the EA, Concept II will be very closely examined and inevitably,
problems will be identified and addressed. Rather than bring forward a second inferior
Concept as a solution to any problems identified with Concept II, the emphasis in the
next stage of the EA should be on identifying ways to improve Concept II. As such,
Staff and the Peer Review Team have advised Council that, because of the inherent
difficulties with the in-situ management options, neither concept IA or IB should proceed
through to the next stage of the environmental assessment process. '
This issue is discussed in Section 2.2.1 of Report PSD-116-04 and Section 4.3 of the
Peer Review Report
A Panel Review is the third approach to a Federal Environmental Assessment involving
a group of selected panellists reviewing the environmental assessment and rendering
an opinion. The decision about whether to convene a Panel to review the EA for the
Port Granby Project is a decision that would be made by the Government of Canada,
not Council. However, given the extent of the peer and expert review that the various
studies are subjected to through the EA process and the rigorous review and approval
process at the federal level, Staff do not see any added benefit from a Panel review.
2.2.4 Resident Comment
Council should order the LLRWMO to rework, in consultation with the community, its
conceptual design with respect to above-ground methods for storing the waste, the
method of transporting the waste and the location of the storage facility. The proposed
design is seriously flawed and will be highly detrimental to the health and safety of the
Port Granby community.
Staff Response
Staff and the Peer Review Team do not agree that the design of the storage mound
under Concept II is seriously flawed and will pose a hazard to area residents. Similar
REPORT NO.: PSD-116-04 (Addendum)
PAGE 6
mounds are already used successfully around the world.. A number of details with
respect to the mound have yet to be finalized (e.g. leachate collection and treatment)
and staff and the Peer Review Team must be satisfied that the interests of the
Municipality and its residents are protected before recommending that Council endorse
the final design (projected spring 2005).
The Municipality and the LLRWMO will continue to consult the residents about
improving the design of the storage facility and related matters such as transportation;
however, any suggested design change must be technically feasible and cannot
compromise the integrity of the waste management facility.
2.2.5 Resident Comment
The scoring of the three Feasible Concepts was biased in favour of Concept II. Council
should not accept the recommendation in Staff Report PSD-116-04 to endorse Concept
/I as the Qualified Concept for the Port Granby project. Council should order an
independent review of the LLRWMO's Feasible Concepts and Qualified Concepts
Reports and base its subsequent action on the outcome of that review.
Staff Response
Council has already provided for an independent review by the peer review team of the
Feasible Concepts and Qualified Concept Reports. The Peer Review Team has
provided its recommendation to Council. They found that the process and method of
scoring the three Concepts was unbiased, clear, explicit and traceable. The
assumptions underlying the scoring were reviewed by the Peer Review Team and were
seen to be sound. SECRA's disagreement with the Peer Review Team's conclusions is
not sufficient rationale for commissioning another peer review of the reports.
2.2.6 Resident Comment
Council is not obliged to approve a Qualified Concept, but could choose instead not to
move fOlWard with the Port Granby Project.
Staff Response
The existing Port Granby site is a source of pollution for Lake Ontario and has been an
ongoing problem for the Municipality for almost 50 years. The current process, if
completed, will provide a safe long term solution for the management of the wastes.
Council committed the Municipality to a clean-up process and a safe and secure
solution for the long term management of the waste for the existing and future residents
in the legal agreement.
REPORT NO.: PSD.116-G4 (Addendum)
PAGE 7
2.3 Concerns with Concept II
2.3.1 Resident Comment
The proposed method of storing the waste in an above-ground mound is technically not
suitable for the long term storage of radioactive waste.
Staff Response
Engineered storage mounds with durable liners and caps have been considered as the
best solution for managing low level radioactive waste and hazardous waste. There has
also been a great deal of scientific research and technological advancement in this field
in recent years, particularly with respect to the liners. The Peer Review Team is that the
Municipality can be confident that the engineered storage mound proposed under
Concept II will provide for safe storage of the waste for several hundred years and
possibly longer.
This issue is discussed in section 5.2.1 of the Peer Review Report.
2.3.2 Resident Comment
The waste should be stored in an above-ground concrete vault system covered by a
gently sloping earth cover.
Staff Response
Concrete vaults have been used in Europe and the United States for the storage of
radioactive waste for a number of years. In Canada, above-ground concrete vaults are
used by nuclear power generating facilities for the short term storage of used fuel rods.
They have proven to be successful and it is anticipated that they can last for centuries.
However. concrete vaults are not a practical alternative for the storage of the Port
Granby wastes, given the volume of waste and contaminated soils that need to be
stored (approximately 500,000 cu. m). The resulting mound would be considerably
higher and the footprint considerably larger than with the engineered storage mound
proposed under Concept II without providing any safety advantage. The use of
concrete vaults to store the waste and contaminated soils was examined by the
LLRWMO through its development of the Feasible Concepts and, as a result of this
review, was eliminated from further consideration. Staff and the Peer Review Team
agree with the LLRWMO's assessment that concrete vaults do not offer any advantages
over an engineered storage mound.
2.3.3 Resident Comment
Enclosed excavation should be used when removing the waste from the existing site to
minimize the potential for the dispersal of radioactive material.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 8
Staff Response
The excavation of the wastes under an enclosed structure, employing positive air
pressure and filters, would minimize the dispersion of airborne dust and vapours,
Thorium 230 and radon gas into the exterior air. It would also allow for continued
excavation operations during inclement weather. However, the LLRWMO has
indicated that the uneven terrain in the East Gorge Area, where the contaminants of
greatest concern are located, would make the use of an enclosure difficult. As well, an
enclosed excavation would allow radon gas released from the waste to accumulate
inside the enclosure, potentially increasing worker exposure. Enclosure may increase
occupation hazard from Radon and Thorium 230, however, filtering should capture
Thorium 230.
If the excavation area were not enclosed, the radon gas would disperse into the ambient
air but not pose a problem for either workers or residents. Monitoring for dust
suppression and Thorium 230 will be ongoing and measures can and will be taken to
avoid dispersal of Thorium 230 (i.e. foam spray).
Enclosed excavation was examined as an alternative means during the development of
the Feasible Concepts and ultimately rejected by the LLRWMO in favour of open
excavation. Nevertheless, the Peer Review Team has recommended that enclosed
excavation should be further evaluated during the detailed effects assessment stage
(see Sections 4.4.1 5.2.3 and 6.3 of the Peer Review Report), and the LLRWMO has
agreed. The LLRWMO will examine other means of controlling the dispersal of
radioactive material such as foam dust suppression, should they detenmine that
enclosed excavation is not feasible.
2.3.4 Resident Comment
Is it possible to effectively protect residents and their lands from airborne radioactive
materials during the excavation of the waste?
Staff Response
The protection of human health and the natural environment are paramount
considerations for the Municipality, the LLRWMO, and the federal agencies responsible
for ultimately approving the Port Granby Project. Each of these agencies will be
undertaking a thorough review to ensure that the waste at the Port Granby site can and
will be excavated and moved safely. The process will be strictly regulated as
demonstrated by a recent site clean-up in Port Hope. The Peer Review Team agrees
with the LLRWMO that the presence of Thorium-230 in the waste and the consistency
of the waste does not preclude its excavation and transportation but, as noted earlier,
has requested that enclosed excavation be given further consideration.
This issue is discussed in Sections 4.4.1, 5.2.3 and 6.3 of the Peer review Report.
REPORT NO.: PSD-116-G4 (Addendum)
PAGE 9
2.3.5 Resident Comment
The dumping of radioactive waste in a mound without a well-designed temporary cover
system is totally irresponsible.
Staff Response
During the next stage of the EA, the LLRWMO will be evaluating a number of methods
to temporarily cover and stabilize the waste after its placement in the new storage
mound. Methods being considered include soil and the use of spray-on foams. Staff
and the Peer Review Team will review and provide comments on this issue.
2.3.6 Resident Comment
New materials should be transported to the new waste management facility by rail
rather than by trucks using local roads.
Staff Response
The primary advantage of using rail in theory is that it would eliminate truck traffic on
local roads and the associated impacts on area residents. However, the LLRWMO's
review of this issue found that the only suitable site in the local area for the construction
of a rail siding is west of the Newtonville Road interchange. Trucks would still be
required to transport the materials from the rail siding to the site of the new waste
management facility, thereby eliminating any benefit to the local community from using
rail.
Rail transport was evaluated during the development of the Feasible Concepts and
eliminated based on this review. At the request of area residents, the LLRWMO re-
examined the issue during the detailed transportation review but came to the same
conclusion that rail transport does not reduce the impacts on area residents. The Peer
Review Team has indicated that they agree with the LLRWMO's position on this matter. .
There will be an impact from trucks carrying construction material on local residents.
However, the number of trucks to bring in construction material associated with Concept
II would be significantly lower than the number required for either Concepts IA or IB
(15,000 vs. 40,000) since Concept II does not require the extensive shoreline protection
works associated with the other concepts. During the detailed effects assessment, the
LLRWMO will be meeting with area residents, Municipal staff and the Peer Review
Team to discuss possible measures to mitigate the impact of truck traffic on area
residents.
Staff acknowledge that waste will have to be transported from the existing facility to the
north side of Lakeshore Road. The various ways of minimizing the impact of this
transportation and the type/technique of transport will be examined as part of the next
phase of the EA.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 10
The issue of rail transport and the identification of truck transportation routes is
discussed in Section 3.5 of Report PSD-116-04 and in Sections 4.4.6 and 5.2.4 of the
Peer Review Report.
2.3.7 Resident Comment
The soils north of Lakeshore Road are vel}' sandy and not suitable for locating a
radioactive mound.
Staff Response
The area proposed for the location of the new storage mound is underlain by a relatively
low permeability glacial till. This layer of till is the same as the Middle Till layer in the
current waste site which has shown to be a barrier to the downward migration of
contaminated groundwater. The LLRWMO has indicated that this till will serve as a
suitable base for the mound liner and leachate collection system and, because of its low
permeability, will also serve as an effective natural back-up in the event of a leak
through the base liner system.
The Peer Review Team does not specifically disagree with the LLRWMO's rationale for
the proposed location of the new mound. However, the team has recommended that
additional work be undertaken through the detailed effects assessment that would
provide a more thorough analysis and documentation of the geology and hydrogeology
associated with Concept II, in particular the conditions underlying the proposed location
for the mound (see Section 6.3 of Peer Review Report).
2.3.8 Resident Comment
The proposed leachate collection ponds for the new mound under Concept /I would be
located vel}' close to Port Granby Creek and any accidental spill will flow into the creek.
Staff Response
The LLRWMO has advised that the final details of how leachate from the new facility will
be treated have not yet been determined. Several feasible options being considered
include collecting the leachate in the storm water management ponds on-site or
pumping the collected leachate to the temporary (i.e. 25 years) treatment facility that will
be required on the existing waste site to deal with residual contaminated groundwater.
This approach is feasible since the new storage mound would only generate
appreciable amounts of leachate in its first few years of operation. In the longer tenm,
leachate volumes are expected to be negligible but an environmentally safe treatment
approach will need to be identified through the next phase of the EA process. Staff and
the Peer Review Team will continue to monitor this issue and will ensure that the
leachate collection and treatment method eventually selected will protect the natural
environment and the health of local residents.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 11
2.3.9 Resident Comment
The construction of a trench and deep cut-off wall to the north of the existing site,
together with an impermeable cap on the site, will effectively prevent precipitation and
groundwater from contacting the waste. If the waste can be kept dry, the contaminants
will not move and leach out into the lake.
Staff Response
This approach was evaluated through the development of the Feasible Concepts and a
number of disadvantages were identified. For example, the open trench may in fact
induce reversal of the groundwater flow paths in the upper layers of the site, resulting in
potential migration of contaminated groundwater into the trench. As well, the density of
the underlying soil layers would preclude the installation of the deep cut-off wall to the
necessary depth. The Peer Review Team is also not confident that the trench and cut-
off wall will perform as planned. Finally, the trench would require the relocation of
Lakeshore Road and would have a very visible impact on the local community. For
these reasons, neither staff nor the Peer Review Team support the construction of the
trench and cut-off wall.
This issue is discussed in Section 5.2.3 of the Peer Review Report.
2.4 Impact on the Local Community
2.4.1 Resident Comment
The continued presence of the waste management facility will permanently devalue
property values in the local area. The Property Value Protection Program does not
address the longer term impacts on property values. There will be a greater impact with
Concept 1/ since the existing waste site poses little danger to the health and safety of
local residents. Council is requested to negotiate with the Govemment of Canada to
address the issue of compensation for property owners.
Staff Response
The residents acknowledged in their submission that the Municipal Property
Assessment Corporation (MPAC for Ontario) has recognized for many years that the
presence of the existing waste site has a negative impact on local property values, and
has allowed a 20 percent reduction in the market value assessments for properties in
the area. Studies will be undertaken through the detailed effects assessment stage of
the EA to determine what impact the new waste mound north of Lakeshore Road will
have on property values over the longer term. Staff recognize the residents' concerns
and will recommend additional actions on the part of the Municipality if necessary, when
the results of the appropriate studies are available and have been reviewed by the Peer
Review Team.
This issue is addressed in section 3.6 of Report PSD-116-04 and Sections 5.1.5 and
Section 5.1.7 of the Peer Review Report.
REPORT NO.: PSD-116-04 (Addendum)
REVISED
PAGE 12
2.4.2 Resident Comment
What steps is the Municipality taking to ensure that no new radioactive waste is brought
on to the new waste site at a future date?
Staff Response
The legal agreement on the Port Granby Waste Management Facility explicitly provides
for a limitation on the materials that are to be accommodated in each of the three
Facilities which are to be constructed by Government of Canada. In Clarington's case
Schedule 1, Part B (p. 38) provides:
"Materials to be accommodated:
. the Facility will accommodate approximately 500,000 cubic metres of Cameco
Waste - Port Granby at the Port Granby Low-Level Radioactive Waste
Management Facility, including approximately 100,000 cubic metres of
calcium fluoride, neutralized raffinate and marginally contaminated soils and
contaminated industrial trash from t1he East Gorge of the current site
. in addition, the Facility will accommodate any Historic Low-Level Radioactive
Waste located within the Municipality of Clarington as identified by surveys to
be performed by Canada."
The latter point provided for other wastes that may be identified t1hrough the EA process.
To date, a small amount of contaminated soil has been identified due to a truck accident
in hauling waste to Port Granby.
The Municipality's Solicitor is of the opinion that the Agreement precludes Canada or an
assign of Canada who takes title with notice of the Three Party Agreement from
accommodating low-level radioactive waste in the re-engineered Port Granby Waste
Management Facility which was not located in Clarington on the date of the Agreement,
March 29, 2001.
The only way that other wastes could be acoommodated at Port Granby would be by
the agreement of Council and the Govemment of Canada. Council has consistently
stated it opposition to accepting additional waste at the new waste management facility.
By adopting recommendation 3, the position is confirmed again.
It should be noted, however, that the legal agreement does not preclude the
Government of Canada from operating a radioactive waste facility in another part of the
Municipality.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 13
2.5 Resident Involvement in the Process
2.5.1 Resident Comment
SECRA needs financial support from the Municipality to obtain independent legal and
technical advice on a number of issues related to the Port Granby Project.
Staff Response
Council is responsible for protecting the interests of all Clarington residents, including
the members of SECRA. It is not the Municipality's policy to accord any financial
assistance to individual residents or ratepayers groups in respect of a position,
regardless of whether that position is in support of or in opposition to the Municipality's
position.
2.5.2 Resident Comment
What happened to the annual report produced by the Port Granby Community Advisory
Committee and the recommendations in it? Council should re-establish the CAC since
it is the most effective method for ensuring community involvement in the process.
Staff Response
The CAC's report was received by Council in January 2004 and referred to staff. In
March 2004, Council, through its consideration of Staff Report PSD-020-04, resolved to
not re-establish the CAC and requested the LLRWMO to consult with the broader
community and SECRA.
The LLRWMO is continuing to consult with the residents in the Port Granby area, staff
and the Peer Review Team attend all public consultation events. In particular, a series
of facilitated roundtables in the spring provided a very effective forum for residents to
discuss their concerns with the LLRWMO and the Municipality. With the fonmation of
SECRA, there is an organized voice for resident input making the CAC redundant.
2.5.3 Resident Comment
The LLRWMO and the Municipality are not listening to the concerns of area residents
and residents have been shut out of the decision-making process.
Staff Response
With regard to decision making, the selection of the qualified concept is the first
milestone requiring a municipal decision. Not only did council hear delegations from
residents but held a special GPA meeting with an independent facilitator. The
Municipality and the Peer Review Team have consistently listened to the concerns of
area residents as demonstrated by the number of issues discussed in Report PSD-116-
04 and the Peer Review Report. For example, the Peer Review Team has requested
that enclosed excavation be examined in response to residents' concerns with airborn
REPORT NO.: PSD-116-04 (Addendum)
PAGE 14
contamination. However, staff and the Peer Review Team have a professional
responsibility to Council and the greater public interest and therefore do not always
agree with the views of residents.
It is Council's responsibility, as the elected representatives of the residents of
Clarington, to make decisions on behalf of the Municipality and all of its citizens.
Council is assisted by Municipal staff in the discharge of these responsibilities and for
the Port Granby Project, by the technical expertise provided by the Peer Review Team
led by Hardy Stevenson and Associates. The federal government's provision of
financial assistance has allowed the Municipality to retain the Peer Review Team and to
devote significant staff resources to the Port Granby Project to ensure that the interests
of its residents are protected.
2.5.4 Resident Comment
What are the plans to involve the community for the end use of these lands?
Staff Response
The LLRWMO has plans to involve both the Municipality and local residents in
developing end use plans for the site of the new waste management facility, the existing
waste site, and the balance of the lands to be acquired by the Government of Canada.
The LLRWMO has already suggested that passive recreational uses and parkland
would be appropriate end uses. However, the Canadian Nuclear Safety Commission
will have the final authority on end use for the existing and new waste sites.
3.0 CONCLUSIONS
3.1 The EA process is a rigorous process that examines impacts and the mitigation of
impacts. As part of the legal agreement, the Municipality and Federal Government
committed themselves to the EA process. The legal agreement also set out three
milestone decision-making points. Selecting a qualified concept is the first of the
milestones. The second milestone will be the review of the detailed effects assessment
(anticipated in Spring 2005). The third and final milestone will be the approval of the
Screening Report after it has been reviewed and approved by the Regulatory Agencies.
At that point in time, anticipated in 2006, the Municipality has the ability to veto the
project if they do not agree with the Regulatory Agency recommendations.
3.2 The majority of concerns voiced by the residents at the Special Committee meeting on
September 21, 2004 have been raised previously and are discussed in Report PSD-
116-04 and/or the Peer Review Report. Many of the concerns will be addressed as
additional studies are undertaken through the environmental assessment process and
as the design of Concept II is finalized. Taking Concept II as the sole qualified concept
through the Detailed Effects Assessment allows the Municipality to maximize the rigor
that the different aspects of the proposal will be evaluated on.
REPORT NO.: PSD-116-04 (Addendum)
PAGE 15
3.3 Staff and the peer review team appreciate the ongoing interest, comments and
concerns of the residents and will continue to meet with SECRA and the residents
throughout the process to understand their concerns to ensure that they are addressed
as part of the mitigation efforts put forward in the EA process and during construction of
the facility, when it occurs.
Attachments:
Attachment 1 - Report PSD-116-04
Attachment 2 - Peer Review Team Presentation
Attachment 3A - SECRA Executive Presentation (Sarivan Sahota)
Attachment 3B - SECRA Executive (Harvey Thompson)
Attachment 3C - SECRA Executive (John Stephenson)
List of interested parties to be advised of Council's decision:
Ms. Sharon Baillie-Malo
Uranium and Radioactive Waste Division
Natural Resources Canada
580 Booth Street
Ottawa, ON K1A 7K8
Mr. Vito Binetti
4545 Concession Road 4
Newtonville, ON LOA 1 JO
Mr. Glenn Case, Director
Port Hope Area Initiative
Low Level Waste Management Office
5 Mill Street South
Port Hope, ON L 1A 2S6
Ray Coakwell and Frances Brooks
17 Lakeshore Road
RR. # 8
Newcastle, ON L 1 B 1 L9
Ms. Rosemary Cooper
4822 Reid Road
Orono, ON lOB 1 MO
Mr. Sarwan Sahota
4665 Lakeshore Road
RR. # 8
Newcastle, ON L 1 B 1 L9
Mr. Robert Edgar
471 East Townline Rd.
RR # 8
Newcastle, ON L 1 B 1 L9
Mr. John Stephenson
5300 Old Scugog Road
Hampton, ON LOB 1JO
Gord and Penny Ewington
4659 Lakeshore Rd.
RR # 8
Newcastle, ON L 1 B 1 L9
Mr. Harvey Thompson
4720 Concession Road 6
Orono, ON LOB 1 MO
Michael Ayre & Julie Jones
Elliott Road
RR # 8
Newcastle, ON L 1 B 1 L9
Betty and Stephanie Formosa
4657 Concession Road 1
Newcastle, ON L 1 B 1 L9
REPORT NO.: PSD-116-04 (Addendum)
PAGE 16
Ms. Paulette Gerber
Nichols Road
RR. # 8
Newcastle, ON L 1 B 1 JO
Ms. Barb Spencer
4563 Lakeshore Road
RR # 8
Newcastle, ON L 1 B 1 L9
Ms. Lorri Graham
4673 Concession Road 1
RR # 8
Newcastle, ON L 1 B 1 L9
Mr. Ulrich Ruegger
540 Newtonville Rd.
R.R. # 8
Newcastle, ON L 1 B 1 L9
Maria Kordas - Fraser
4570 Lakeshore Rd.
RR. # 8
Newcastle, ON L 1 B 1 L9
Brian and Penny Stripp
4652 Lakeshore Road
R.R. # 8
Newcastle, ON l1 B 1 L9
Gerry Mahoney and Bonnie McFarland
4548 Lakeshore Road
RR # 8
Newcastle, ON L 1 B 1 L9
Ms. Rosemary Tisnovsky
4617 Lakeshore Rd.
RR #8
Newcastle, ON L 1 B 1 L9
Mr. Andrew McCreath
18 Wolseley Street
Toronto, ON M5T 1A2
Mr. Stan Tisnovsky
4646 Lakeshore Road
RR # 8
Newcastle, ON L 1 B 1 L9
Mr. Rupert McNeill
4679 Lakeshore Road
RR # 8
Newcastle, ON L 1 B 119
Mary and Harry Worrall
1134 Elliott Road
R.R # 8
Newcastle, On L 1 B 1 L9
Tim and Laurel Nichols
826 East Townline Road
R.R # 8
NEWCASTLE, ON L1B 1L9
Luanne Hill
306 Newtonville Road
RR. # 8
Newtonville, On LOA 1 JO
Carole Owens
485 East Townline Road
R.R # 8
Newcastle, ON
L 1 B 1 L9
Ken Shrives
44 Carveth Crescent
Newcastle, ON L 1 B 1 L9
Mrs. Jean Payne
4612 Highway # 2
R.R # 1
Newtonville, ON LOA 1 JO
JoAnne McNamara
Office of Bev Oda, M.P.
P.O. Box 9
Bowmanville, ON L 1 C 3K8
REPORT NO.: PSD-116-04 (Addendum)
PAGE 17
Donna, Paul and Stephen Grant
4651 lakeshore Road
RR # 8
Newcastle, ON L 1 B 1 L9
Dora Nichols
825 Nichols Road
RR # 8
Newcastle, ON L 1 B 1 L9
O. Karacsonyi
4447 Concession Road 4
RR. # 8
Newtonville, ON LOA 1 JO
Jane Lawrence
3654 East Townline Road
RR # 8
Newtonville, On LOA 1 JO
James B. Robertson
440 East Townline Road
RR # 8
Newtonville, On LOA 1 JO
Wilma Entwisle
4672 Highway 2
RR # 8
Newtonville, On LOA 1 JO
Susan Kinmond
201 East Townline Road
R.R # 8
Newtonville, On LOA 1 JO
Wayne Boucher
4579 Concession Road 1
R.R.#8
Newtonville, ON LOA 1 JO
Eric Leeuwner
3334 Morgan's Road
R.R # 8
Newcastle, ON L 1 B 1 L9
Brian Tayng
4636 Highway 2
RR # 8
Newtonville, ON LOA 1 JO
Richard Walker
4381 Lakeshore Road
R.R. # 8
Newcastle, ON L 1 B 1 L9
Frank Hart
4576 Concession Road 1
R.R. # 8
Newtonville, ON LOA 1JO
Linda and Paul Ryerse
1211 Lakeshore Road
R.R. # 8
Newcastle, ON L 1 B 1 L9
Cl!J!ilJglOn
ATTAC_HMENT 1
REPORT
PLANNING SERVICES
Meeting:
GENERAL PURPOSE AND ADMINISTRATION COMMITTEE
Date:
Tuesday, September 21, 2004
Report #:
PSD-116-04
File #: PlN 33.4.6
By-law #:
Subject:
PORT GRANBY PROJECT - SELECTION OF QUALIFIED CONCEPT
RECOMMENDATIONS:
It is respectfUlly recommended that the General Purpose and Administration Committee recommend to
Council the following:
1. THAT Report PSD-016-04 be received;
2. THAT the Municipality of Clarington concur with the recommendation of the low level
Radioactive Waste Management Office that Concept II (relocation of the Port Granby waste to
an engineered storage mound north of lakeshore Road) should proceed through the
Environmental Assessment process as the Qualified Concept for the Port Granby Project;
3. THAT the Government of Canada be advised that the Municipality of Clarington is opposed to
any waste other than that associated with the existing Port Granby Waste Management Facility
being accepted or stored at the new waste management facility;
4. THAT the Low level Radioactive Waste Management Office continue to consult with the
Municipality of Clarington and affected residents regarding the mitigation of impacts from the
construction and operation of the new waste management facility;
5. THAT a copy of Council's decision be forwarded to the low level Radioactive Waste
Management Office. Natural Resources Canada, the executive of the South East Clarington
Ratepayers Association and the interested parties.
LJ.,
Submitted by: ~
D i . Crome, M.C.I.P., RP.P.
Director of Planning Services
Reviewed by:
Franklin Wu,
Chief Administrative Officer
JAS*Fl *DJC*df
13 September 2004
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L1C 3A6 T (905)623-3379 F (905) 623-0830
REPORT NO.: PSD-116-04
PAGE 2
1.0 BACKGROUND
1.1 The Port Granby Project, as part of the larger Port Hope Area Initiative, began with the
legal agreement entered into by the Government of Canada and the Municipalities of
Clarington, Port Hope and the former Hope Township in 2002. The purpose of the
Project is to provide safe, long term management of the low level radioactive waste
currently stored at the existing Port Granby Waste Management Facility (WMF). In
accordance with the agreement and federal law, the Low Level Radioactive Waste
Management Office (LLRWMO), designated as the proponent for the Port Granby
Project, initiated the Environmental Assessment (EA) for the Project.
1.2 A key component of the EA process is the identification and evaluation of Alternative
Means of undertaking the Project. Through this process, the LLRWMO identified three
possible approaches (called Feasible Concepts) for the long term management of the
waste, as follows:
. Concept IA - in-situ management of the waste with relocation of waste in the East
Gorge to a new storage mound on-site;
. Concept IB - in-situ management with no relocation of waste; and
. Concept II - relocation of all the waste and marginally contaminated soils to a new
above ground storage mound on lands north of Lakeshore Road away from the
lake, and the clean-up and rehabilitation of the existing WMF.
The LLRWMO undertook an extensive analysis of the three Feasible Concepts to
determine the best concept for the safe long term management of the low level
radioactive waste. The selected concept is called the Qualified Concept.
1.3 Under the terms of the legal agreement, the LLRWMO must consult with the
Municipality on the outcome of the Alternative Means process. On February 9, 2004,
Mr. Glenn Case, the Project Director for the Port Hope Area Initiative, advised
Committee that Concept II had achieved the best score and recommended that this
concept be selected by Council as the Qualified Concept for the Port Granby Project.
If Council concurs with this recommendation, the other two Feasible Concepts will no
longer be considered in the EA process and Concept II will proceed to a detailed effects
assessment.
~.4 Staff and the ~,1unicfpa!ity's peer revievv' team, fed by Hardy Stevenson and :~,Ssoci2tes,
have undertaken an extensive review and analysis of the Feasible Concepts and
Qualified Concept Reports. The peer review team has also held detailed discussions
with the LLRWMO and its consultants. As a result of this review, the peer review team
has indicated in their report (Attachment No.1) that they have reached the same
conclusion as the LLRWMO that Concept II is superior to Concepts IA and IB and
should be carried forward to the detailed effects assessment as the Qualified Concept
for the Port Granby Project
REPORT NO.: PSD-116-04
PAGE 3
1.5 The purpose of this report is to assist Committee and Council in determining whether to
concur with the recommendation of the LLRWMO that Concept II should be approved
as the Qualified Concept for the Port Granby Project.
2.0 REVIEW OF FEASIBLE CONCEPTS AND QUALIFIED CONCEPTS
2.1 Key Conclusions of Peer Review
2.1.1 The peer review report provides a detailed overview of the three Feasible Concepts
(Section 3) and the team's comments on the Feasible Concepts and Qualified Concepts
Report (Section 4). Based on this review, the peer review team reached four key
conclusions, as discussed below.
1 . The evaluation process used to develop the Feasible Concepts and to
identify the Qualified Concept is robust and defensible. In particular, the
LLRWMO used several sensitivity analyses to ensure that the results of the
numerical comparison were unaffected by changing the scoring of specific
criteria.
2. Concept 11 is superior to Concepts IA and 18 and should be carried forward
to the detailed effects assessment of the Environmental Assessment. In
reaching this conclusion, the peer review team identified the following
advantages of Concept II:
. effectively isolates the waste over the duration of the project
. provides greater redundancy and therefore less risk of failure
. allows for ease of monitoring, repair, and replacement of parts
. can be constructed and implemented safely
. will result in fewer impacts on the community from truck traffic than Concepts
IA and IB
. is consistent with international approaches for managing similar low level
radioactive waste and marginally contaminated soils.
3. Concepts IA and 18 should not be carried forward to the detailed effects
assessment stage. The peer review team :lOted that these rIVo concepts are
complex and require multiple systems to function as designed over hundreds of
years, and will not be able to perform as well in safely and effectively containing
the waste as Concept II. A number of disadvantages with Concepts IA and IB
were specifically identified, as follows:
. the difficulty of isolating the waste from ground and surface water
. the likelihood and cost of implementing a contingency plan shouid the
engineered systems fail
REPORT NO.: PSD-116-04
PAGE 4
. the effects on Lake Ontario from managing the waste in-place. (eg. Potential
leakage of leachate, construction and regular extension of toe berm).
4. Additional issues should be addressed during the detailed effects
assessment stage. While the peer review team concurs with the LLRWMO's
recommendation regarding Concept II as the Qualified Concept, they have also
identified a number of issues that need to be addressed in the next phase of the
EA, as follows:
. how to best handle and excavate the waste
. how to best remediate groundwater at the existing Port Granby site
. how to best manage the facility over the life of the project (hundreds of years)
. confirming the location for the above-ground mound within the Cameco lands
. the examination of a single liner vs. a double liner for the above ground
mound
. selecting routes for transporting construction materials.
2.2 Key Conclusions of Staff Review
2.2.1 Staff have also reviewed the Feasible Concepts and Qualified Concept Reports and
have participated in many discussions with the peer review team, the LLRWMO and
their consultants, and area residents. As a result of this review and these discussions,
Staff agree with the conclusions of both the peer review team and the LLRWMO that
Concept II should be approved as the Qualified Concept for the Port Granby Project and
should proceed through the detailed effects assessment stage. Staff also agree with the
peer review team recommendation that Concepts IA and IB should not proceed through
to the next stage of the EA. Staffs position is based on a number of considerations, as
follows:
1. Staff is confident that the scientific evidence presented has demonstrated
Concept II to be the best option of the three Feasible Concepts for the safe
long term management of the waste. The consultants retained by the
LLRWMO to undertake the various EA studies are highly qualified and
recognized experts in their respective fields, as are the members of the
Municipality's peer review team. in-depth discussions with the LLRWMO's
consultants and the peer review team have confirmed that their respective
conclusions are technically and scientifically sound.
2. There are a number of inherent difficulties with Concepts IA ands IB and
therefore neither of these concepts should proceed through the detailed
effects assessment. In-situ management of the waste will require the
construction and on-going maintenance of several highly complex systems (eg.
ground water diversion trench/cut-off wall, leachate collection, shoreline
stabilization, impermeable cover). It will not be possible to install a liner beneath
the waste and no back-up systems would be present should any of these
REPORT NO.: PSD-116-04
PAGE 5
systems fail, resulting in a potential loss of waste to the lake. The complexity of
the in-situ management approach makes it more prone to significant failure. It is
also possible that, even if all of the systems operate as planned, some
contamination could continue to discharge to the lake.
Staff also have serious reservations about recommending a management option
for low level radioactive waste that is essentially unproven. There is no example
in the world where low level radioactive waste is being effectively and safely
contained in a dynamic shoreline environment. Staff is also concerned with the
visual impact of the shoreline stabilization works, in particular the toe berm which
is expected to extend approximately 25 m (82 ft) into the lake and, on the shore
would sit up to 12 m (39.4 ft) higher than the normal water level of the lake. An
additional concern is that the protected waste site would eventually become a
promontory extending into the lake as the adjacent unprotected shoreline erodes
and that over the life of the project (hundreds of years) significant shoreline and
maintenance work will be required.
Given these concerns and the availability of a less complex more reliable option
for managing the waste, Staff do not recommend that either Concepts IA or IB be
moved forwarded to the detailed effects assessment phase of the EA.
3.0 OVERVIEW OF RESIDENTS' CONCERNS
3.1 General Concerns
3.1.1 Many of the residents in the Port Granby area have expressed concerns about the EA
process in general, the selection of the Qualified Concept, and the potential impact of
construction and operation of the new long term storage facility on property values and
community character. A series of facilitated "roundtables" with the community were held
in Spring 2004 to ensure that residents had the opportunity to express and discuss their
concerns with the LLRWMO, Municipal staff and the peer review team. Section 5 of the
peer review report provides a detailed discussion of many of the concerns expressed by
residents. Staff has additional comments on the residents concerns, as presented
below.
3.2 Only In-Situ Management of the. Waste Should be Considered
3.2.1 Residents have expressed the opinion that the EA process should only consider in-situ
management options for the waste since this was the concept recommended by the
Port Granby LLRW Advisory Committee in June 1999, endorsed by Council in August
1999, and eventually described in the legal agreement with the Government of Canada.
The validity of this opinion must be determined in order for Council to make a decision
regarding the proposed Qualified Concept.
3.2.2 The Port Granby LLRW Advisory Committee was appointed by Councii in January
1999. Staff Report CD-6-99 indicated that Natural Resources Canada would retain a
consultant to study options, at a conceptual level, for the development of a long term
REPORT NO.: PSD-116-04
PAGE 6
storage facility within Clarington. The Advisory Committee was appointed to provide
direction to the consultant and to provide public input on the options under review. The
Committee, which consisted entirely of residents, directed the consultant not to
undertake any work on concepts that involved relocation of the waste to another site.
As a result, the Committee's report, which was submitted to Council in June 1999, only
discussed in-situ management options.
3.2.3 In August 1999, Council resolved to endorse Option B2 (in-situ management with
relocation of the East Gorge waste to an on-site storage mound) subject to the results of
a detailed comprehensive environmental assessment. In addition, Council requested
four additional studies to address the following matters:
. the concentration of Thorium-230 in the East Gorge wastes,
. groundwater flow through the site,
. impacts related to shoreline erosion control, and
. a contingency plan for the relocation of the wastes in the event of system failure.
These studies, which were completed in June 2003, identified significant concerns with
in-situ management of the waste. These studies are discussed in greater detail in
Section 2.3 of the peer review report.
3.2.4 The Port Granby Project, as afederal project and as required by the legal agreement, is
proceeding under the Canadian Environmental Assessment Act (CEAA). This process
requires that a specific project be defined and that alternative means of carrying out the
project be investigated. The EA Scope document, which sets out the matters that must
be addressed in the EA, defines alternative means as:
"the various ways, that are technically and economically feasible, that the project
could be implanted which are local, are for the management of the wastes over
the long-term and are functionally similar to the project as proposed in the project
description."
The EA Scope also states that alternatives to the project need not be considered. In
this regard, alternative to are definedas:
"alternatives that are not in the local area, that are not for the management of the
wastes over the long-term and are functionally different ways to meet the project
need and achieve the project purpose. The RAs are, therefore, not asking the
proponent to investigate alternatives to the project, such as sites outside the local
area, interim storage technologies or deep geologic disposal".
3.2.5 The residents have expressed the opinion that the proposed Qualified Concept is not
functionally similar to Option B2, and as such should not be considered because it is an
alternative to and not an alternative means to the project as endorsed by Council and
incorporated into the legal agreement. However, the peer review report (Section 5.1.2)
agrees that the proposed Qualified Concept (Concept II) meets the definition and
criteria for an alternative means and is consistent with the EA Scope document. The
peer review team notes that Concept II is functionally similar to the original proposal in
that involves the construction of an above-ground storage mound, is intended to isolate
REPORT NO.: PSD-116-04
PAGE 7
the wastes from ground and surface water and prevent the leachate from entering Lake
Ontario. As well, Concept II, like the original proposal, has been designed so that the
waste is retrievable and the engineered systems can be monitored and repaired if
necessary.
3.2.6 It is also important to note that the legal agreement with the Government of Canada
recognizes that the management option endorsed by Council in 1999 is at a conceptual
level and that alternate ways of carrying out the Project are to be investigated through
the EA process. The agreement also states that the new facility will be located on
Cameco's lands in Clarington and at a location at or approximate to the site of the
existing facility. In addition, the Municipality's solicitor has advised that the legal
agreement "was intended by the parties to it to be a living document that would order'
their relations respecting the clean-up and long-term safe management of low level
radioactive waste... It commits the parties to the Environmental Assessment and
Regulatory Review processes rather than to the Base Case as a specific project....".
3.2.7 Given the above, it is clear that the in-situ management option endorsed by Council in
1999 forms the starting point for the federal EA process and that the proposed Qualified
Concept constitutes an alternative means to the Project. In this regard, Council can
accept Concept II as the Qualified Concept for the Port Granby Project.
3.3 Acceptance of Additional Waste at the New WMF
3.3.1 The residents have expressed a concern that, if the new engineered storage mound is
built as recommended by the LLRWMO, low level radioactive or hazardous waste from
other areas will also be stored at the new facility. One of principal foundations of the
current process is that only the waste associated with the current Port Granby WMF will
be stored at the new facility. Council's position on this issue is clearly reflected in its
resolution of August 29, 1999 which states that no additional waste from other sites
should be received and stored at the new Port Granby facility. As weil, the legal
agreement clearly defines the source of materials to be accommodated at the new
facility and, as such, any new initiatives to bring additional waste to the site would
require municipal consent (see Peer Review Report, Section 5.1.4).
3.3.2 In order to reinforce Council's position on this matter, staff is recommending that the
resolution adopted by Council reaffirm the Municipality's opposition to additional waste
being accepted at the new Port Granby WMF.
:3.4 Negative impact on the community's image
3.4.1 Residents have expressed a concern that the construction of a new waste management
facility north of Lakeshore Road will have a negative impact on the community's image.
In this regard, staff agree with the comments of the peer review team (Section 5.1.5 of
the peer review report) that the Port Granby community has been living next to a waste
management facility for almost 50 years and that the current facility's inability to
effectively contain the waste poses an image problem for the community. Concept II, if
properly implemented, would improve the community's image as compared to both the
existing situation and the situation that would be created with the implementation of
REPORT NO.: PSD-116-04
PAGE B
either Concepts IA and lB. The effective use of landscaping will help to mitigate the
visual impact of the new storage mound.
3.4.2 Under the terms of the legal agreement, the Government of Canada is required to
acquire the lands necessary for the proper construction and operation of the new Port
Granby WMF. The Government has negotiated an Agreement of Purchase and Sale
with Cameco Corporation for all of their land holdings in the Port Granby area, totalling
approximately 250 ha (620 acres). As indicated on Attachment NO.2 to this report, the
lands to be acquired include the existing WMF and the site of the proposed new facility
north of Lakeshore Road, as well as additional lands in the area. The federal
government will assume title to the lands once the Canadian Nuclear Safety
Commission (CNSC) has issued a construction licence for the new WMF. The
LLRWMO has indicated that the acquisition of all of Cameco's land holdings would not
be required for the implementation of either Concept IA or lB.
3.4.3 The LLRWMO has indicated that the use of the lands outside of the existing and future
WMF will be determined in consultation with the community. Of particular note is the
potential for the existing waste site and the adjacent waterfront property to the east to
become available for public access and use, although portions of the existing waste site
may not become accessible for a few decades until residual contaminated groundwater
is completely flushed from the site. As well, the new WMF may not be accessible to the
public. Nevertheless, the potential exists for the Government of Canada and the
community to work together to create a waterfront open space that enhances the
character of the Port Granby area and provides a benefit to existing and future
residents of the Port Granby area and the whole community.
3.5 Impact of Truck Traffic
3.5.1 Residents have expressed a concern regarding the impact of truck traffic during the
construction phase of the Project. It is estimated that Concept II would require
approximately 15,000 truckloads of construction material, while Concepts 1A and 1B
would each require 40,000 truckloads. Over a two year period, this translates to
approximately 35 trucks per day for Concept II and approximately 100 trucks per day for
Concepts 1A and 1 B.
3.5.2 For all of the concepts, the LLRWMO has recommended that construction materials be
brought in by truck from the Highway 401 interchange at Newtonville, east on
Concession Road 1, and then south on Elliott Road to the north end of the new facility.
Fer Concept ii, a dedicated access road between the site of the new facility would be
built. A crossing at Lakeshore Road would be required, althou9h it has not yet been
determined whether the crossing of Lakeshore Road will be at-grade or below grade.
For Concept 1A and 1B, trucks would continue south on Elliott Road and then travel
east on Lakeshore Road to the existing site. All of the concepts will require that the two
rail crossings and the required portions of Elliott Road, which is currently unopened, to
be upgraded to accommodate the truck traffic (see Attachment 2).
REPORT NO.: PSD-116-04
PAGE 9
3.5.3 The peer review report (Section 4.4.6) addresses the issue of transportation routes and
has requested the LLRWMO to provide more information on the potential impacts to the
local community, including environmental effects and health and safety considerations.
The residents have also requested the LLRWMO to investigate the feasibility of using
rail to transport construction materials. The llRWMO has agreed to review this option
during the detailed transportation evaluation. Both Staff and the peer review team
(Section 5.2.4) agree with this decision.
3.5.4 The construction of any of the proposed management concepts will require significant
truck traffic on local roads, and the impact on the local community from this traffic was
identified by Council in its August 1999 resolution as a specific point of concern.
However, Staff agree with the comments of the peer review consultant (Section 4.2.5)
that the impacts from truck traffic associated with Concept II will be significantly less
than those associated with either Concepts IA or lB.
3.6 Economic and Quality of Life Impacts
3.6.1 Residents are also concerned about the potential economic impacts on the local
community from the construction and operation of the new long term waste facility, as
well as the impact on their quality of life and normal enjoyment of property. Staff note
that the Property Value Protection (PVP) Program, established through the legal
agreement, is intended to mitigate some of the economic impacts of the Port Granby
Project, (eg. reduced price on sale of property). Staff acknowledge that the PVP
Program does not address all of the impacts associated with the Project. For example,
the Program is not intended to compensate property owners for potential quality of life
impacts and the loss of enjoyment of property during the construction period.
3.6.2 As part of the detailed effects assessment which forms the next stage of the EA
process, the LLRWMO will be undertaking an assessment of these types of impacts and
determining how the impacts can best be mitigated. As noted by the peer review report
(Section 5.1.7), the Municipality's peer review team will be carefully reviewing the
LLRWMO's assessment of socio-economic impacts to determine if the impacts on the
local community can be properly mitigated during the construction phase and the long
term operation of the new waste facility.
4.0 DISCUSSION OF LEGAL ISSUES RELATED TO CONCEPT II
4c 1 Amendment to Legal Agreement
4.1.1 As indicated earlier, the legal agreement between Clarington and the Government of
Canada commits the parties to the Environmental Assessment and Regulatory Review
process rather than a specific project. The Government of Canada, acting through the
LLRWMO, is required to perform all of the work necessary and incidental to the
advancement of the Port Granby Project. Through this work, the Proponent may identify
and assess alternate ways of carrying out the Project. The agreement provides for the
LLRWMO to submit the preferred alternative means to the relevant authorities for
REPORT NO.: PSD-116-04
PAGE 10
review, provided that the written consent of the Municipality to that alternative means is
obtained.
4.1.2 Since Concept II was identified as the proposed Qualified Concept for the Port Granby
Project through the EA process, the Municipality's solicitor has advised that an
amendment to the legal agreement is not required for Concept II to replace in-situ
management as the preferred management option for the Port Granby Project.
4.2 Amendment to Municipal Planning Documents
4.2.1 The Durham Region Official Plan and the Clarington Official Plan both designate the
existing Port Granby Waste Management Facility as Special Policy Areas. The related
policies support the removal of the waste and the rehabilitation of the site to uses
compatible with waterfront open space. Similarly, Comprehensive Zoning By-law 84-63
imposes a special exception zone that only permits the site to be used for conservation
and forestry uses or "public uses" which are discussed in Section 4.2.3 below.
4.2.2 The lands on the north side of Lakeshore Road on which the proposed new storage
facility (Concept II) would be located are designated Permanent Agricultural Reserve
and Prime Agricultural Area by the Region and Clarington Official Plans respectively.
By-law 84-63 zones the lands as Agriculture. The construction and operation of a waste
management facility is not listed as a permitted use on these lands by any of the
documents. The issue of whether municipal planning documents need to be amended
to permit Concept II to proceed must therefore be addressed.
4.2.3 A municipal Official Plan legally binds the municipality, local boards and commissions,
but does not bind higher levels of government such as the Government of Canada.
Similarly, the Government of Canada is not bound in law by the provisions of any
municipal by-law, including a zoning by-law. In addition, Comprehensive Zoning By-
law 84-63 (Section 3.18) specifically states that the provisions of the by-law shall not
apply to prohibit the use of land for the purpose of a public service provided by a
number of public bodies, including the Government of Canada. Therefore, if the new
Port Granby WMF, regardless of its location, is owned and operated by the Government
of Canada, the Government will enjoy Crown Immunity from the provisions of municipal
planning documents.
4.2.4 As well, the Constitution Act, provides the Government of Canada with the exclusive
authority to !egislate respecting the subject of atomic energy. T~e CNSC is responsible
for the regulation and licensing of construction and operation of all nuclear installations
including nuclear waste facilities, under the Canadian Nuclear and Control Act. As such,
any restriction that municipal documents impose on a nuclear facility, whether it is
owned by a private corporation or the Government of Canada, would be unconstitutional
and void and therefore could not be enforced.
4.2.5 Based on the above, it is apparent that it is not a legal necessity for the Official Plans
and the zoning by-law to be amended to permit Concept II to proceed. Council may
choose to initiate the appropriate amendments to the Clarington Official Plan and
REPORT NO.: PSD-116-04
PAGE 11
Zoning By-law or it may include amendments as part of a comprehensive review, to
ensure that the documents accurately reflect what is ultimately approved by federal
regulators. Council may also choose to request the Region of Durham to amend its
Official Plan. However, any amendments to municipal planning documents should be
deferred until the completion of the Environmental Assessment and Regulatory Review
process when the precise characteristics of the approved project will be known.
4.2.6 Any amendments to the Durham Region Official Plan, the Clarington Official Plan or
Zoning By-law would be made pursuant to the Ontario Planning Act. As such, upon
Council approval of the amendments, any person would have the right to appeal to the
Ontario Municipal Board respecting any or all of the amendments. However, for the
same reasons discussed in Sections 4.2.3 and 4.2.4 above, the Ontario Municipal
Board could not override the decision by the federal authorities and prohibit the
construction and operation of the new Port Granby WMF.
5.0 NEXT STEPS
5.1 Once a Qualified Concept has been identified for the Port Granby Project, the LLRWMO
will undertake a detailed effects assessment of that concept. This assessment will
focus on the anticipated impacts of the project on human health and the social,
terrestrial, aquatic, atmospheric, and economic environments and how these impacts
can best be mitigated. The LLRWMO has already initiated the detailed effects
assessment for Concept II. The draft results of the detailed effects assessment are
expected to be released for public review and comment late in 2004.
5.2 The LLRWMO will compile the detailed effects assessment of the Qualified Concept,
along with the results of a number of other studies, into an Environmental Study Report.
This Report is currently expected to be released early in 2005 for municipal and public
review and comment and, once finalized will be submitted by the LLRWMO to the
relevant federal authorities for review. The legal agreement requires the LLRWMO to
consult with and obtain the written consent of the Municipality to that option prior to
submitting the Environmental Study Report to decision makers for review. This step is
expected to occur at the end of March 2005.
5.3 The federal Responsible Authorities (RAs) for the Port Granby Project, which includes
Natural Resources Canada and the CNSC, will review the Environmental Study Report
with the assistance of other federal agencies such as Health Canada, Environment
Canada and Transport Canada. The RAs will document this review in a Screening
Report and indicate whether the project should be implemented. Once the Screening
Report is released, the legal agreement provides the Municipality with the opportunity to
review the report and the RA's decision and determine whether or not the Project, as
approved by the RAs, should proceed. The Screening Report is expected to be
released in 2006.
REPORT NO.: PSD.116-04
PAGE 12
5.4 Once municipal consent to the project is obtained, the LLRWMO would seek the
appropriate regulatory approvals to permit the Project to be implemented. This would
include a construction license from the CNSC. Construction of the new facility and the
rehabilitation of the existing WMF is expected to take about five years.
6.0 CONCLUSIONS
6.1 The selection of a Qualified Concept for the Port Granby Project represents a significant
milestone in the resolution of the long standing problem with the existing waste
management facility. Staff and the peer review team are confident that the selection of
Concept II as the Qualified Concept for the Port Granby Project is in the best interests
of the Municipality and the existing and future residents, including those who live in the
local area.
6.2 It is recognized that the local community will bear the greatest impact from the
implementation of the Project; however, the impacts related to Concept II are less than
those associated with in-situ management of the waste. There are still a number of
steps to be completed in the EA process and the concerns of residents will continue to
form part of the peer and staff review of the many reports and studies yet to be
undertaken. .
Attachments:
Attachment 1 -
Attachment 2
Peer Review of the Port Granby Project - Feasible Concepts and the
Qualified Concepts Report, Hardy Stevenson and Associates Ltd., August
2004 (under separate cover)
Lands to be acquired by the Government of Canada from Cameco
Corporation
List of interested parties to be advised of Council's decision:
Ms. Sharon Baillie-Malo
Uranium and Radioactive Waste Division
Natural Resources Canada
580 Booth Street
Ottawa, ON K1A 7K8
Mr. John Stephenson
5300 Old Scu909 Road
Hampton, ON LOB 1JO
Mr. Harvey Thompson
~\1r. 'Glenn Case, Dirsc~or
472~ Concession Road 6
Port Hope Area Initiative
Low Level Waste Management Office
5 Mill Street South
Port Hope, ON L 1A 2S6
R. R. #3
Newtonville, ON lOA 1 JO
Mr. Sarwan Sahota
4665 Lakeshore Road
R.R. # 8
Newcastle, ON L 1 B 1 L9
Michael Ayre & Julie Jones
Elliott Road
R.R. # 8
Newcastle, ON L1B 1L9
REPORT NO.: PSD-116-04
PAGE 13
Mr. Vito Binetti
4545 Concession Road 4
Newtonville, ON LOA 1 JO
Mr. Rupert McNeill
4679 Lakeshore Road
RR # 8
Newcastle, ON L 1 B 1 L9
Ray Coakwell and Frances Brooks
17 Lakeshore Road
R.R # 8
Newcastle, ON L 1B 1L9
Ms. Rosemary Cooper
4822 Reid Road
Orono, ON LOB 1 MO
Tim and Laurel Nichols
826 East Townline Road
RR # 8
NEWCASTLE, ON
Mr. Robert Edgar
471 East Townline Rd.
R.R # 8
Newcastle, ON L1B 1L9
Carole Owens
Mrs. Jean Payne
4612 Highway # 2
R.R. # 1
Newtonville, ON LOA 1JO
Gord and Penny Ewington
4659 Lakeshore Rd.
R.R # 8
Newcastle, ON L181L9
Ms. Barb Spencer
4563 Lakeshore Road
R.R # 8
Newcastle, ON L 1 B 1 L9
Betty and Stephanie Formosa
4657 Concession Road 1
Newcastle, ON L 1 B 1 L9
Mr. Ulrich Ruegger
540 Newtonville Rd.
RR # 8
Newcastle, ON L 1B 1L9
Ms. Paulette Gerber
Nichols Road
R.R.#8
Newcastle, ON L1B 1JO
Brian and Penny Stripp
4652 Lakeshore Road
RR # 8
Newcastle, ON L 1 B 1 L9
Ms. Lorri Graham
4673 Concession Road 1
R.R.#8
Newcastle, ON L1B 1L9
Ms. Rosemary Tisnovsky
4617 Lakeshore Rd.
R R #8
Newcastle, ON L 1 B 1 L9
R.R.. #8
Mr. Stan Tisnovsky
4646 Lakeshore Road
R.R. # 8
Newcastle, ON L 1 B 1 L9
Maria Kordas - Fraser
4570 Lakeshore Rd.
Newcastle, ON L 1 B 1 L9
Gerry Mahoney and Bonnie McFarland
4548 Lakeshore Road
R.R. # 8
Newcastle, ON L 1 B 1 L9
Mary and Harry Worrall
1134 Elliott Road
RR. # 8
Newcastle, ON L 1 B 1 L9
Mr. Andrew McCreath
18 Wolseley Street
Toronto, ON M5T 1A2
ATTACHMENT 2
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Proposed Transportation Routes
All Concepts
- - Concepts IA and IB
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ATTACHME~n 2
Feasible Concepts and
Qualified Concept
Report
Overview of Presentation
. The Peer Review Team
. Today's Milestone
. Peer Review Mefhodology
. Peer Review Process
. Synopsis or llRWMO Analysis
. Significant Areas of Agreement with LlRWMO
. Issues for LlRWMO to Address in Next Stage
. Peer Review Response to Resident Comments
. Recommendations
Peer Review Team
. Dave Hardy, RPP
. Marc Rose, MES
. Dr. Mohan Roo
. Dr. Murray Finketstein
. TyroneGan,P_Eng
. Paul Bowen, P .Eng.
. Milo Sturm, P.Eng.
. Phil Niblett. M.Sc
. Dr. Tony van der
Voooen
. Dr. Charlotte Young
. Other staff and
associates
Today's Milestone
. lLRWMO narrowed the concepts and selected a
preferred concept for managing the waste
. Comprehensive fev1ew by Peer Review Team
completed
. Peer Review T earn agrees with lLRWMO
recommendation
. We recommend that Council endorse the Qualified
Concept and endorse the lLRWMO moving forward
to the next Phase of the EA: Detailed Effects
Assessment
Waste Management Objective
. Low level radioactive wastes and marginally
contaminated soils are currently stored near the
shoreline
. Contaminants are currently leaking into lake Ontario
. Design and construction of tong term waste
management facjllty
. Removal of contaminated sediments from East
Gorge
. Remediation of groundwater contaminated lands
Peer Review Methodology
. Are the conclusions supported by the research?
Are there data gaps? Can we trust the data?
. Are certainties and uncertainties of the EA studies
openly and objectively stated?
. Have signiflcant issues been overlooked during the
EA process?
. Haye cumulative effects been thoroughly
understood?
. Are there Federal, Provincial and local standards,
regulations and guidelines thai are overlooked?
Peer Review Process
. Reports were received and reviewed
. Comments were submjtted to lLRWMQ via
disposition forms
. Meetings occurred between specialists to explain.
review nature of disagreemenl and/or exchange
additional infonnanon
. lLRWMO consultants and staff reviewed comments
and stated whether they agreed or not
.. Presentations to residents and SECRA
. Peer Review Team listened to public comments and
suggestions .
Synopsis of LLRWMO
. Three Feasible Concepts considered
. Review of two options for shoreline
remediation
Range of transportation routes ana lysed
. Several options considered for remediation
of contaminated soils
Feasible Concept '1A'
. long-term stabilization of most of the wastes
at the existing Port Granby WMF
. On~site management of wastes - excavation
of East Gorge wastes
. East Gorge wastes relocated above ground
to a new storage facility at the existing Port
Granby WMF
Feasible Concept '1 B'
. On-site management of wastes - no waste
excavation
. Waste isolated by a low permeability cover
system. a groundwater cut-off wall and a
groundwater collection system
. Requires transport of 40,000 truckloads of
construction materials to construct the new
facility
Feasible Concept '2'
. Relocation of wastes to a new long-term storage
facility on the Cameco property north of the existing
waste management facility
After reviewing the Concepts. Concept 2 is seen
to be most suitable approach fOT implementing
the Port Gra[lby Project and in the peer review
team's opinion, it should be carried forward to
the detailed effects assessment
Significant Areas of Agreement with
LLRWMO
With Concept 2, the facility is in an appropriate
geological setting_
Waste is contained with state-of-the-art cover and
liner technologies and isolated for many hundred
years.
Engineered systems have fewer working parts and
greater redundancy_
Increased reliability of the entire system and less risk
of failure.
Significant Areas of Agreement with
LLRWMO
Excavation, transportation, and re-storing of the
waste at the new site will meet or exceed
Canadian Nudear Safety Commission and other
environmental requirements.
Qualified Concept is consistent with international
approaches for managing similar jow-Ievel
radioactive waste and marginally contaminated
soils.
Issues for LLRWMO to Address During
the Net Effects Analysis
Further consider enclosed excavation options to
reduce the radiological risks for the public and the
workers handling LLRW.
Examine the extent of contaminated groundwater,
and develop a strategy to remediate groundwater at
the existing Port Granby site.
Establish and evaluate appropriate ways to
minimize, mitigate and monitor potential airborne
contamination impacts.
Issues for LLRWMO to Address During
the Net Effects Analysis
Assess geological and hydrogeological
conditions underlying the location chosen for
the WMF. .
Examine how institutional control of the
facility will be managed over the life of the
project.
Evaluate a double base liner for containing
wastes.
Issues for LLRWMO to Address During
tl1e Net Effects Analysis .
Further evaluate transportation routes for
moving construction materials.
- Effects on residents, businesses and roadside
properties along haul routes
- Pedestrian and vehicular safety
- Existing traffic operations defJci~ncies, roo.away
capacity and level of service
- Environmental impacts of required road
improvements and haul operations
Summary Agreement
LLRWMO agreed with most of OUf comments
Where there wasn't agreement. after
discussion and clarification, we agreed the
document did not have to be revised
For transparency, we left our original
comment unaltered
Resident Comments and Peer Review
Team Responses
The Peer Review Team consulted with
SEeRA members, the former CAe and
members of the Clarington public.
. Some concerns are general and apply to the
EA process.
. Others are focused on the selection of the
Qualified Concept
Comment and Response
Whether the 1978 FEARO Panel decision opposing
the Eldorado Refinery and waste management site
precludes the establishment of a waste management
site on the norlh side of Lakeshore Rd.
The projects are diffen:~"'lt ~':RCan amj the Peer
Review Team agree that t~ 1978 decisfc!'! does not
preclude the LlRWMO from including a site across
Lakeshore Rd. in the current EA process.
. Comment and Response
The Qualified Concept is not an ~a"emative means~
of carrying out the Project. but is an ~aftemative to"
the Project.
We don't agree_ The Qualified Concept meets the
definition and criteria for an "altemative means. as it
is located locally, is tedmicalty and economically
feasible. and manages the wastes over the long
term. An .altemative to' would involve options such
as long tenn disposal, caverns or treating the
wastes.
Comment and Response
The comprehensiveness of a screening leve' EA
The studies conducted to date for this EA meet the
requirements of a "comprehensive' study and
consequently exceed the requirements for a
screening level of study.
Comment and Response
There should be a guarantee from the federal
govemment that additiomaJ waste should not be
stored at the waste manf3gement facility.
We agree that the facility should be closed once the
matena!s have been safely s!ored. Clar~ngton
Gounal should reaffirm its commitment to not accept
additional wastes al the new site or any of the land
owned by Camero.
Comment and Response
The community's image will suffer if a new waste
management facility;s built
If propeny implemented, Concept 2 will improve the
community's image compared to Concept 1A or 1 B.
Concept 2 will not involve the construction of any
shoreline stabilization measures, and will mitigate
any visual impact of the new engineered mound
through landscaping.
Comment and Response
Whetheroo-$ite management options 'fA' and '1B' should be subjed
'0 the delaiIed effM:is assessment
The Peer ReYiewTeam recommends lball'leitber Concepts 1A or 1 B
should he carried through \0 the detailed effects a~~essmenl stage
OP!ions tA Bnd-la.are comp""'. wi;1 require 'eg~iar repair Bnd
millnlenance_ Mull,plesyslemsmlJslwon...
Both have risks d....lolea..ingmateriBlolllheblufl/slope
en..ironment
Thestlorelinealldbluffstab~izalion "",,,Bsllres are majorcons\ruc1ion
Pf'OjeCls
1Aand1Bwouldn<>lha....aline'ilndthewaslewooJdbeinconlact
wilhgroondwater.
Comment and Response
Potential effects of the construction afld operation of the waste
management fadfity {)II property values, enjoyment of property,
and agriculturaf prodnction
Property Values Proteclion program has been established 10
address some of these impacts.
The Peer Review Team wi. be reviewing the assessment of
~micimoacls durilKl the detailed effects assessment
10 oetermine if the impaclS can be mitigated during Ihe
construction phase and iong term operation 01 the new waste
facility.
Comment and Response
There is little experience with systems storing
radioactive and chemical wastes, and there are
considerable uncertainties associated with storing
the waste ;n an abov&-f}round mound.
The LLRWMO has cited a number of precedents,
built and under construction, for this type of
engineered mound, induding Fort McMurray in
Alberta and Weldon Springs in Missouri.
Comment and Response
A deep groundwater Cllt-off wall is not a practical
proposition, and should be replaced by a deep open
trench concept.
The trench would generate an enormous volume of
excess fill and create a visual intrusion into the
community. There is little evidence to support the
view that a deep open lrench will perform as
designed.
Comment and Response
Excavating the waste poses unacceptable risks to human
health and the environment
The peer review team is confident that the waste can be moved
safely The LLRWMO has experience in moving waste in Port
Hope and other Canadian venues.
We have l'!sked th!!t i!fl e!'ld~d eY.C!:1va!!of! Qptjon De
considered by the LlRWMO in the net etfeclS analysiS to
reduce any effects on the WOl1<;ers and the public.
Peer Review Recommendation
Concepl2 is most suitable- 10 be carried through 10 the detailed
effects assessment It
isoIaleslhe source materials and contaminated soils
has" ~ner
provides safe Iong-lerm management of the waste in a secure
facility
has less impact 00 the <x:mrnunily on lhe shott term and 1009 term
is 1he00tionlnO<ikelytallil!conlaminatetlleenvironment DVer
tnelongle<m
requires less cooslruction If'IaIerial
retlllTlSlhecurrentWMFsiletobeneficiallar1dandshore~neuses
;seasj....-ID~sionatlbeendofservicelile
Recommendation
The Peer Review Team confirms its support
for the LLRWMO to carry forward to the
detailed effects assessment Concept 2:
Removing the contaminated source materials
from the current site and relocating to the
Cameco site across the road.
Remediating remaining contaminated
groundwater at the current site.
Port Granby Project
ATTACHMENT3J'
1
Port Granby Project
1. History
Eldorado Nuclear Limited, a Government of Canada Corporation, started dumping
radioactive waste from its refmery at Port Hope during 1950's.
On July 7, 1976, Atomic Energy Control Board issued an order requiring Eldorado
Nuclear Limited to discontinue the further disposal of radioactive waste at the existing
Port Granby Residue Area effective 31 January, 1977 and to manage the area thereafter
in perpetuity in accordance with requirements of the Board. Also, submit to the Board by
1 December, I 976,detailed plans and schedules for decommissioning of the residue
area.
In 1977, Eldorado submitted a proposal for removing the radioactive waste from the Port
Granby site and move it to the north side of Lakeshore Road into a new storage facility.
In 1978, an Assessment Review Panel established by Federal Assessment Review Office
(FARO) rejected the proposal to store the nuclear waste on the north side of the
Lakeshore Road, the Panel ruled that the area to the north of Port Granby Residue
Area is not suitable for storage of radioactive waste.
During the 1980's, the Port Granby Community and the Municipal Council demanded
that the radioactive waste must be moved out of the municipality. In response to this
demand, in the fall of 1987, the Natural Resources Canada proceeded to set up a Sitting
Task Force in order to find a Host Community willing to receive the radioactive waste
from Port Granby and Port Hope. In 1995, after many years of work and millions of
dollars of expenditure, the Sitting Task Force failed to find a community which was
willing to receive the waste.
In 1998, Natural Resources Canada initiated a plan for fmding a Local Solution for
suitable storage of the radioactive waste. The Municipality of Clarington established the
Port Granby Low-Level Radioactive Waste Community Advisory Committee (CAC) to
fmd a Local Solution for long-term safe storage of the waste at Port Granby.
The CAC began its work in January, 1999 and submitted its report to the Clarington
Council in June, 1999. The Community Advisory Committee unanimously recommended
that the radioactive waste at Port Granby should be stored at the current site; requiring
minimum disturbance of the existing wastes and minimum movement of the materials off
site (Clarington Local Solution). The Committee rejected the proposal to excavate the
waste and move it into an Engineered Mound on the north side of Lakeshore Road.
2. Port Granby Project
The Municipality of Clarington accepted the recommendation of its Community
Port Granby Project
2
Advisory Committee for On-Site storage of the radioactive waste. In the fall of 1999,
Natural Resources Canada and the Municipality of Clarington concluded a legal
agreement under which new Port Granby Waste Management Facility is defined as the
activities and structures contemplated by the conceptual design approach referred to as
Conceptual Design B, Option 2 in the Port Granby LLRW Advisory Committee Report
titled "Report on Conceptualization of On-Site Low-Level Radioactive Storage Facility
Designs for the Port Granby WMF dated June 28, 1999" (Report PD-95-99) as received
and approved by the Council of Clarington for referral to Canada (Resolution dated
August 30, 1999).
Under the legal agreement, the parties agreed to an environmental assessment of the
proposed design before proceeding to the engineering design stage of the project.
Natural Resources Canada appointed the Low-Level Radioactive Waste Management
Office (LLRWMO), Port Hope, as proponent and required them to conduct an
environmental assessment for the project as specified under the Federal Environmental
Assessment Act.
The Low-Level Radioactive Waste Management Office began its work during the spring
of 2001 and issued a Project Description for Port Granby Project in November of2001.
According to the project description, a fundamental objective of the project design is to
minimize disturbance of the existing waste and minimize movement of the materials off
site as a result of construction. The main project components include:
. An engineered bluff stabilization structure;
. A groundwater diversion system;
. An impermeable cover system for the central plateau.
The people of south east Clarington strongly support the On-Site solution for
storage of the radioactive waste at Port Granby. It is a made in Clarington solution
and is the best solution for the social, economic and environmental health of the
community.
3. Environmental Assessment Process
The environmental assessment process calls for developing alternate means of carrying
out the project without changing or undermining "fundamentals" agreed upon in the
conceptual design of the project. It was expected that LLRWMO was to study possible
alternate means for On-Site solutions for storage of the waste. LLRWMO has made little
or no effort to develop an On-Site solution.
In 1999, the Port Granby LLRW Community Advisory Committee appointed Golder
Associates as consultants and Mr. Case, on behalf of Golder Associates, became the
chief advisor to the Committee. Mr. Case proposed the "Port Hope Solution" to the
Committee, i.e. the waste at Port Granby should be excavated, moved to the north of
Lakeshore Road and placed in an above-ground mound. The Committee rejected the
"Port Hope Solution" and asked Mr. Case to develop an On-Site solution. Mr. Case and
Golder Associates, under the guidance of the committee, proceeded to develop the
Port Granby Project
3
conceptual design for Port Granby which is the basis for the legal agreement between
C]arington and Canada.
Natura] Resources Canada appointed the LLRWMO to carry out the environmental
assessment for the Port Granby Project and the Port Hope Project. Meanwhi]e, Atomic
Energy Canada hired Mr. Case to direct the environmental assessment for both projects.
Since taking office Mr. Case and his team have shown a clear and open bias against the
On-Site solution for Port Granby project. Studies relating to the project has been Jess than
adequate, in order to undermine the design for the On-site solution. It was not a surprise
to us that Mr. Case and his team chose the option to excavate the radioactive waste, move
it to a mound on the north side of Lakeshore Road as a preferred option.
We re-iterate that this option was proposed by Mr. Case in 1999 and was rejected
by the Commnnity Advisory Committee and the Clarington Council.
Mr. Case and his team have completely ignored the views of the local residents and have
deliberately undermined the environmental assessment regulations. Under the EA rules,
the "a]ternate means" of carrying out the project should be functionally similar to the
proposed design. Excavating the waste, moving it a distance of one kilometer and
placing it in a mound, is not functionally similar to a design requiring in-situ
stabilization of the waste. Therefore, it is an "alternative to" the project design.
In our opinion, the proposal to excavate the waste; move it out of the current facility, and
place it in a mound, is a clear violation of environmental assessment regulations. We
need financial help from the Municipality in order to obtain an independent legal opinion
on this point.
Furthermore, the Ju]y 2002, "Scope of the Environmenta] Assessment for the Port
Granby Long Term Low Leve] Radioactive Waste Storage Project",(paragraph 3.]),
states that if the waste is moved from the currently licensed facility, and if the
radioactivity of the waste exceeds 100 TBq(which we understand is the case), then a
comprehensive study by the Responsib]e Authorities is required. We would like the
Responsib]e Authorities to undertake a comprehensive environmental assessment review
of the Port Granby Project We expect LLRWMO to disagree with our position. In that
event, this matter would require a technical and legal opinion in order to find an answer.
4. LLRWMO Preferred Option
LLRWMO is determined to impose the "Port Hope So]ution" on the people of south east
C]arington with its preferred option to excavate the radioactive waste at Port Granby,
move it kilometer to the north side of the Lakeshore Road and place it in an above-
ground mound.
Our community has many serious concerns with this proposal:
Port Granby Project
4
A. Above-Ground Mound
The proposed method of storing the waste in above-ground mound is technically not
suitable for long-term storage of radioactive waste. There are instances where such
systems have failed as the lining is prone to rupture; also, the lining system will most
likely fail in less than 300 years This method of storing waste is cheap and is mainly
used for storing municipal waste.
A much superior method of above-ground storing of radioactive waste is Above-Grade
Concrete Vault System which employs a series of reinforced concrete vaults or silos to
contain the waste. The vaults are constructed on a base liner system to collect and control
leachates during operations. On completion of waste placement operations, a gently
sloping earth cover is constructed over the vaults and an engineered cover system similar
to that for the Above-Grade Mound is installed (see attached diagram). Above-
Grade Vaults are currently being used in France. The Concrete Vault System is more
costly than the above-grade mound system proposed by LLRWMO.
B. Excavating and Transporting Waste
The proposed method of excavating and transporting the radioactive waste is
unacceptable to our community. There is a clear danger to the public in excavating the
radioactive waste using an open-pit method and the use of trucks to transport it. Any
human error, negligence or equipment failure could result in dispersal of the radioactive
material over a wide area causing serious environmental problems. Therefore, a totally
enclosed excavation, transportation, and placement system is needed.
Furthermore, dumping of radioactive waste in a mound without a well designed
temporary cover system, is a totally irresponsible plan. The concrete vault system should
also be totally enclosed when placing the waste in it.
Transportation of new materials to the facility should be carried out by using CN Rail
instead of transporting the materials by road which will have a serious negative impact on
local residents and the general public.
C. Mound Site
The site chosen by LLRWMO for constructing the toxic mound poses a very serious
threat to the health and safety of the local residents. Leachate collection ponds will be
located close to Port Granby Creek. Any accidental spill will flow into farmland and Port
Granby Creek. We have been informed by the LLRWMO that the treated leachates will
be pumped into Lake Ontario at a distance of one kilometer. Any system failure will be
harmful to the farmers and residents living along the Creek. Ifthe Above-Ground Mound
System fails (which is probable), it will cause a major environmental disaster.
Furthermore, the Cameco lands on the north side of Lakeshore Road are very sandy in
nature. A site with several feet of top sandy soil is not suitable for locating a radioactive
Port Granby Project
5
mound.
A suitable location for a properly constructed concrete vault system, is the field across
the Lakeshore Road just to the north ofthe current facility. At this location, any system
failure will be far less harmful to local farmers and residents as the contaminants will
flow directly towards Lake Ontario.
The proposed preferred option is altogether a new project as it has no resemblance to the
Port Granby Project as described in the legal agreement. This new project will
permanently contaminate a tract of very good farmland.
5. Permanent Harm to Property values
Natural Resources Canada's failure to remove the radioactive waste at Port Granby out of
the Municipality of Clarington and the decision ofthe Municipality to accept the waste
(reversing its earlier decision to ask Canada to remove the waste from Clarington), has
permanently devalued the nearby residential and farming properties.
Under the legal agreement, the Municipality negotiated a Property Value Protection
Program. This program only covers the negative impact on property values during the
planning and construction phase of the project, and is very limited in scope( i.e. under
this program, a property owner must sell his\ her property and then apply for
compensation; a disagreement between parties could result in many years of legal
dispute. )
This program does not address the issue of permanent devaluation of properties
around the Radioactive Waste Management Facility at Port Granby.
It should be noted that the impact of the On-Site Solution on property values is
minimal compared to a plan requiring the excavation of the waste, transporting the waste
and placing it in a mound. The current facility poses very little danger to the health and
safety of local residents. Excavation of waste, movement of the waste and its storage in a
mound, creates a permanent threat to the safety of area residents. This untested method of
storing the radioactive waste has a good probability of failure. When this storage system
fails or the collection ponds overflow, toxic radioactive chemicals will migrate into
farming lands and through Port Granby Creek into Lake Ontario, causing a major
environmental disaster. This permanent threat will have a serious negative impact on the
area property values.
For many years, The Ontario Property Assessment Corporation (OPAC) has recognized
that the presence of radioactive waste at Port Granby has negative impact on property
values of surrounding area. OPAC has allowed a reduction of twenty percent on the
market value assessment of properties to property owners who apply for reconsideration
of their property assessment value, thereby lowering the municipal tax by twenty percent
on these properties.
Port Granby Project
6
It should be noted that the total market assessment value within the Project Area (farm
and residential properties surrounding Port Granby Facility) is approximately 200 million
dollars. This figure does not include the properties situated on east side of East Townline
Road which are part of Port Hope.
Under the legal agreement, LLRWMO requires a written consent from the Municipality
of Clarington for any alteration to the agreed upon project design (On-Site Solution).
Before considering its consent to an alteration to the agreed design, We, the people of
South East Clarington respectfully ask the Municipality to enter into negotiation with
Natural Resources Canada in order to address the issue of compensation to the property
owners with regard to permanent harm to property values due to the permanent storage of
radioactive waste at Port Granby.
6. Questions and Issues
The people of South East Clarington are looking for unbiased answers to a number of
question relating to the Port Granby Project. To obtain answers to some of these question,
we need financial support from the Municipality.
(a) In 1978, Environmental Assessment Panel ruled that the area to the north the Port
Granby Radioactive Waste Management Facility is unsuitable for storage of radioactive
waste. Is Natural Resources Canada in breach of the law by proposing to locate the
radioactive waste on the north side of Lakeshore Road? We need an independent
legal opinion regarding this matter.
(b) The Port Granby Project design requirement is to minimize disturbance of the existing
wastes and to minimize movement of materials off site as a result of construction. The
Project Site has the same property boundary as the existing 18-hactare (approximately 44
acres) Port Granby Waste Management Facility.( Port Granby Project Description 2001
November, pages 4 and 6).
Is the proposal to move the waste one kilometer away "an alternate means" of
carrying out the project or it is "an alternative" to the original proposal?
Is Natural Resources Canada in Violation of Canadian Environmental Assessment
Act by proposing to move the waste?
We need a legal opinion by an experienced environmental lawyer in order to determine
the legality of the proposal to move the waste out of the Port Granby Waste Management
Facility.
( c) From the beginning ofthe environmental assessment process LLRWMO has worked
closely with the Municipal consultants-Hardy Stevenson and the Planning Services
Department. It is our view that all of them have made very little effort to advance the On-
Site solution as agreed in the legal agreement. Our Municipal consultants are consultants
Port Granby Project
7
to the Municipality of Port Hope, and they are also working with Golder Associates and
other consultants on the Environmental Assessment ofthe Darlington Used Fuel Dry
Storage Project. The Port Hope Project is entirely different from the Port Granby Project.
Are the consultants in a conflict of interest? Why are they promoting the Port Hope
Solution for Port Granby? Why did Hardy Stevenson rubberstamp the arguments
put forward by the LLRWMO for justifying their choice for the preferred option?
Why did the Planning Services Department completely concur with the Hardy
Stevenson report in such a haste? Is our Planning Services Department receiving a
bad advice from its consultants?
There may be a case for an independent investigation to find answers to these questions.
(d) The residents are concerned about the presence of high levels of Thorium-230 in the
waste. Also, airborne Thorium-230 radiotoxicity is 50 times higher than that of Radium-
226. Is it possible to effectively protect the residents and their lands from airborne
radioactive materials during the excavation of the waste?
It should be noted that the Hardy Stevenson does not have a single person on their staff
who is experienced in the process of excavating and transporting the type of radioactive
waste present at Port Granby.
It is known to LLRWMO that the radium process wastes in the East Gorge are very
radioactive and has a consistency of tooth paste. It would be very difficult to excavate
this waste and maintain air and surface contamination control during transportation.
It is not known what kind of radioactive chemical soup will result in excavating various
types of radioactive wastes and mixing them in a mound.
(e) In the spring of2004, during our discussions with LLRWMO on the merits of its
preferred option, it was suggested to Mr. Case that LLRWMO should carry out a
comprehensive environmental assessment study for both options; the in-situ option and
the option to move the waste across the road. Mr. Case agreed to this suggestion provided
the Municipality of Clarington request this course of action. Why did the Municipal
Staff not follow this course of action which has full support of the community?
Mr. Case and his team have stated that the in-situ option provides a good solution to
store the waste but the option to move the waste is better. In order to determine which
option is better, an independent and unbiased opinion is needed. We suggest that
LLRWMO undertake a comprehensive environmental assessment study of both options
and fmdings of this study be submitted to an Environmental Assessment review Panel
set up under the Canada Environmental Assessment Act, for a decision.
(f) In the fall of2002, the Council established the Port Granby Community Advisory
Committee as provided for under the legal agreement. The CAC met once a month to
receive reports relating to Port Granby Project from LLRWMO and the Municipal
Consultants, and discuss issues relating to the project. The CAC produced an annual
Port Granby Project
8
report in October,2004, with a series of recommendations to the Council. What
happened to the report and the recommendations contained in it?
The CAC was very useful to the community for providing a regular contact with the
Municipality and LLRWMO for information and discussions on matters relating to the
Port Granby Project. Since early June, we have had no contact with LLRWMO. Their
promised new communication plan was designed to mislead the Council and the
community.
It is of vital importance to our community that the views of the community are taken into
consideration in the design and construction of the new radioactive waste management
facility. In designing the new facility , a great deal of care is needed for proper lining,
sensing and monitoring systems.
We feel that the most effective method for ensuring that the community is actively
involved in the design and construction phases of the project, is for the Council to re-
establish the Port Granby Project Commnnity Advisory Committee. If the past is any
guide, we cannot depend on the goodwill ofLLRWMO for facilitating active
participation of the our community in the design and construction phase of the project.
LLRWMO has failed to establish a satisfactory system of communication with our
community. Our community has been ignored and shutout from the decision making
process. Decisions have been made behind closed door without paying any attention to
the concerns of our people.
(g) Our community is deeply concerned about the future use of Came co lands. Now, the
title to some ofthe Cameco lands has been transferred to 164112 Canada Inc., what is the
plan for future use of the Canada and Cameco lands? What steps the Municipality is
taking to ensure that no new radioactive waste is brought on to this site at a future
date? What are the plans to involve the community for the end use of these lands?
7. Community Needs
Our community needs help from our Municipal Council( our government of the people,
for the people). The Natural Resources Canada has a clear agenda, to move the
radioactive waste out ofthe current facility. The preferred option in its present form
developed by LLRWMO is totally unacceptable to the people of south east Clarington.
Following is a list of our community needs for which we require help from the Council:
I. We ask the Council not to give consent to either ofthe two options( in-situ option or
option to move). Instead, we ask that the Council request the Natural Resources
Canada to undertake a comprehensive environmental assessment study of both
options and appoint an Environmental Assessment Review Panel for a final
decision.
The Council should order LLRWMO to rework, in consultation with the community, its
Port Granby Project
9
conceptual design with respect to above-ground method for storing the waste, the method
of transporting the waste and the location for storage facility. The proposed design
concept is seriously flawed and will be highly detrimental to the health and safety of our
community.
II. We request that the council authorize the South East Clarington Ratepayers
Association to obtain legal and technical assistance in order to fmd answers to a number
of question in this submission; and the Council provide a reasonable a amount of funds
for this purpose.
III. We request that the Council re-appoint the Port Granby Project Community Advisory
Committee so that our community has regular and effective representation for the on-
going development of the Port Granby Project.
IV. We request that the Council order the development of a plan which guaranties that no
new radioactive waste will be deposited on the Federal and Cameco lands at any future
date. Such a plan must be legally binding on all concerned parties, and the plan should
include a consultation process with the community regarding the future use of these
lands.
V. We request that the Council examine the issue of permanent devaluation of properties
due to the failure of the Natural Resources Canada to remove the radioactive waste from
Port Granby and further serious harm to property values which will result if the waste is
moved to the north side of the Lakeshore Road; and placed in a poorly designed storage
facility .We ask the Council to direct the Municipal Administration to enter into
negotiations with the Natural Resources Canada(in consultation with the community
representatives) in order to resolve the matter of property devaluations around Port
Granby.
VI. We request that the Council should not accept the staffrecommendation "that the
Municipality of Cia ring ton concur with the recommendation of the Low Level
Radioactive Waste Management Office that Concept II (relocation of the Port Granby
waste to an engineered storage mound north of Lakeshore Road) should proceed through
the Environmental Assessment process as the Qualified Concept for the Port Granby
Project"(pSD-116-04).We ask the Council to order an independent review of the Low
Level Waste Management Office Feasible Concepts Report and Qualified Concept
Report, and base its subsequent action on the out come of that review.
We, the people of South East Clarington beseech you, our Council for your help.
ATTACHMENT 38
Presentation to Council Scptembe<" 21. 2004
Mayor Mutton and Councillors,
As this Council is lIMlre of wide gulfbetween the people of Port Grnnby and the l'roponmt on bow to
manage the WlIStes at Port Granby. one side wanting a on-site soIulion and the otiIor side proposing a off,.
site solution I am here to-day to recommend to this Council that you aslc the l'roponmt of the Port Ciranby
Project to carty two concepts forward to the detailed effiocts .; ~ ,~.~ , that is Concepl 11 and Concept
1 B. When the detlliled effects assessment is completed on bolh ooucepts, they should be ,JU,,,", to
mediator or a review panel to determine which is the best """""l'I" This method ......Id JIl"O"" once and fur
all, which of the two concepts is the best solution for the Port Granby wasIes. This is the ooIy &ir way to
approach this problem furthe people of Port Granby,
Another the reason fur this request is that Coucepl: 11 n=ived 325 points and ConcepllB n=ived 2S2
points in the scoring system used in the Qualilied Coocept Report, there are ooIy 43 points l>etlwm the
two concepts. There is ooIy about 14% diffurenre between the two concepts and this IePes a"""'Y IlIIIIDW
IlUIIgin for erroL At the work shops that I attended we wel'e aslc to assign values to diflUan liK:tors that
affucl the area near Port Granby, 1 found that these values wel'e very suijective and by ''''''!li,,!!: the
numbers assigned to eaclt rnclor the out come could be some what dilfel'elll.
Another reason is that Concept lB an on-site solution is a doable ~ and it is what the people of Port
Gnmby want and that alone should carty some weigb1 with this council, also by am:ying the two CI:lIlf.lqIt
forward it will demonstrate to the people mosl affected, that this Council has their inIeresl at heart. aft..- all
our govermnenls should be for the people by the people
The proponents of this project are asking this Council to accept Coocept II and cany it forward to the
next phase of the pmcess without providing any iofunoation on the _ ofgrouodwater, the make-up
of land, (I.e. is the ground clay, sand, silt). No infomWion on bow the wasleure to be JDOV<:d _ the
mad safely, moving the wastes by dump truck to a site across the road is not safe. The ~ is astiog
this oouocil to pass a resolution to carry Coneeplll to the nexI. pbase on blind fi1ilIL
Thank You
ATTACHMENT 3C
PROPOSITIONS ADOPTED BY THE 1999 CAC. COMMITTEE
at the first and second meetings of that committee
1) DO NOT EXCAVATE ONE SHOVELFUL OF WASTE
2) THE WASTE WILL NOT MOVE FROM ITS PRESENT
LOCATION IF IT IS KEPT DRY.
These propositions were the foundations of the designs
submitted to council in the 1999 Report.
/jJ~rational \olicy Statement Addressing "Need for", "Purpose
wysiwy g://11/http://www.ceaa-acee.gc.ca/OOl1/0002/addressing....e.ht
...
Canadian EnvIronmental
Assessment Agency
Agence canadie:nne
d'ovaluation envlronnement:ale
Canada
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Operational Policy Statement
October 1998
OPS-EPOI2 - 1998
Addressing "Need for", "Purpose of" ..Alternatives to" and "Alternative
Means" under the Canadian Environmental Assessment Act
1. PURPOSE
This operational policy litaternent has been issued by the Canadian
Environmentai Assessment Agency (the Agency) to provide clarification and
guidance to responsible authorities (RAs) conducting environmental
assessments under the Canadian Environmental Assessment Act (the Act).
This operational policy statement is related to consideration of:
. the "need for" the project (Paragraph 16(1 )(e));
. the "purpose of" the project (Paragraph 16(2)(a));
"alternatives to" the project (Paragraph 16(1 )(e)); and
. "alternative means" of carrying out the project that are
technically and economically feasible and the environmental
effects of any such alternative means (Paragraph 16(2)(b)).
The policy statement provides definitions and general guidance bnwhen and
how these factors shOUld be considered in an environmental assessment
conducted under the Act.
The need for guidance from the Agency arises from concerns about the
inconsistent application of the above-mentioned provisions by different RAs,
and from opportunities to strengthen the application of EA under the Act to
promote planning practices that support sustainable development.
ENVIRONMENTAL ASSESSMENT AS A PLANNING TOOL
This guidance on 'alternatives to" and "alternative means" addresses EA
(under the Act) as a decision-making planning tool, rather than as a project
impact assessment tool.
The approach links considerations of "need for" the project, "purpose of" the
project, "alternatives to" the project and "altemative means" of carrying out
the project, in the early stages of project planning, and before irrevocable
decisions on the project are made. In this way, the RA and/or proponent will
be in a better position to define potential solutions to a problem, and to
establish the viability of alternatives. Importantly, their consideration will also
help to establish the conditions under which certain effects mayor may not
be justified under the circumstances, should such a detennination be
subsequently required.
3. PROCEDURAL GUIDANCE
I of7 4/1 512002 Ll4 PM
'ALTERNATIVE MEANS' defined as:
"THE VARIOUS WAYS THAT ARE TECHNICALLY AND
ECONOMICALLY FEASIBLE, THAT THE PROJECT CAN BE
IMPLEMENTED AND CARRIED OUT"
'ALTERNATIVES TO' defined as:
"FUNCTIONALLY DIFFERENT WAYS TO MEET THE PROJECT
NEED AND ACHIEVE THE PROJECT PURPOSE"
The wording in the Peer review Report:
"Alternative means must be technically and economically
feasible, are local, are for the management of wastes over the
long term, and are functionally similar to the project as
proposed in the Project Description
Appendix 2
Evaluation of Feasible Concepts
A comparative analysis of the three feasible concepts is, without doubt, a
complex matter. The procedure adopted by the Proponent was as follows:
1) Indicator categories were identified and listed in the form of general headings.
2) Each indicator category was expanded into a number of sub-categories, in the
form of questions.
3) Each question was further broken into two or more subjects which were then
subject to comparative analysis.
Numerical ratings were assigned to each subject using 1 as the indicator of a
severe adverse effect, and 5 as no effect.
Indicator categories included: Technical, Community, Human Health and Safety,
Environmental, and Economic.
An Example is set out below:
The Technical Indicator was sub-divided into 4 questions; the first of which was:
"What level of confidence is there that the concept will be compatible with Site
Features"? (This question then appears to have been adjusted, in so far as it
became "what are the constraints imposed by the site upon the design of the
concept"?)
The Site factors imposing constraints were listed as:
Shoreline
Bluffs
Ground water
Surface Water
Waste Properties.
The impact of each filter was then rated with a score of 1 to 5; 1 meaning
maximum adverse impact, 5 meaning no impact.
It is my opinion that the factors affecting the scoring, were in most cases biased
infavor of excavating the wastes by claiming that the process' used to construct
(for example) a toe berm, were specialized and/or needed special engineering
techniques, thus awarding a lower rating. Similarly the process of excavating the
East Gorge wastes were equated with excavating the whole site (100,000 cubic
meters versus 500,000 cubic meters), which I have rated by considering
excavating the Plateau Area and the West Gorge, in addition to the East Gorge.
The scoring of this sub-category by the Proponent and by myself is shown
below:
Concept
Shoreline
Bluffs
Ground Water
Surface Water
Waste Excavation
East Gorge
Plateau
West Gorge
Total
Average Score
Proponent's score
1A 1B 2
1 1 5
3 3 5
1 1 4
1 1 3
2 4 2
My Score
1A 1B 2
3 3 5
3 3 5
2 2 3
2 2 2
1 5 1
5 5 3
5 5 3
21 25 22
3.0 3.6 3.1
8 10 19
1.6 2.0 3.8
The above average scores were then added to the average scores for the other
indicator questions in this cate90ry, to obtain a total score for this indicator
group.
This total score was then multiplied by a weighting factor derived at the March
29th '03 Workshop, (which I don't believe is necessarily correct, but which I do not
want to challenge at this point in time) to arrive at a weighted average score for
the indicator group.
The average score of each group of the indicator questions were multiplied by
their assigned weighting factors and then added together. The new figures in
each indicator cate90ry were then multiplied by a second weighting factor-
again derived from the March 29th Workshop, then the results were added
together to arrive at the total score of each feasible concept to determine the
qualified concept. Again I do not accept that these weighting factors are
necesarily correct (examples being 'what proportion of the total sum available for
the task should be spent building the facility' ?; 'what proportion of the total sum
available for the task should be retained for maintenance in the future' ?), but I
do not want to challenge these numbers at this time.
In conclusion I want to say that I have tried hard to arrive at a fair assessment of
this one indicator question. I have arrived at an answer which is quite different
from that reached by the proponent. This is the reason why I think we have to
challenge the conclusion reached by the proponent, that excavating and moving
the waste to a new site is the optimum solution.