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HomeMy WebLinkAboutPSD-116-04 '""/;/ '!' Cl~mglOn REPORT PLANNING SERVICES Meeting: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE Date: Tuesday, September 21,2004 Report #: PSD-116-04 File #: PLN 33.4.6 H-61f: 0fJll-3Yg---of 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 followin9: 1. THAT Report PSD-016-04 be received; ,,,.;, '"ill; it 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. Submitted by: D vi . Crome, M.C.I.P., RP.P. Director of Planning Services Reviewed bY:'O ~_____~ Franklin Wu, Chief Administrative Officer JAS*FL *DJC*df 13 September 2004 CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1 C 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. 1.4 Staff and the Municipality's peer review team, led by Hardy Stevenson and Associates, 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 II is superior to Concepts IA and IB 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 IB should not be carried forward to the detailed effects assessment stage. The peer review team noted that these two 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 · th.e likelihood and cost of implementing a contingency plan should 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. Staff's position is based on a number of considerations, as follows: 1 . Staff is confident that the scientific evidence presented has demonstrated Concept /I 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 Council 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-D4 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 concems 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 a federal 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 defined as: "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-Q4 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 well, 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-Q4 PAGE 8 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 govemment 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 1 B 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 1 A 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. For Concept II, a dedicated access road between the site of the new facility would be built. A crossing at Lakeshore Road would be required, although it has not yet been determined whether the crossing of Lakeshore Road will be at-grade or below grade. For Concept 1 A and 1 B, 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 4.1 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 Govemment of Canada. Therefore, if the new Port Granby WMF, regardless of its location, is owned and operated by the Govemment of Canada, the Govemment 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 legislate respecting the subject of atomic energy. The 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-G4 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 Clarin9ton 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 - 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 Attachment 2 - 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 Scugog Road Hampton, ON LOB 1JO Mr. Glenn Case, Director Port Hope Area Initiative Low Level Waste Management Office 5 Mill Street South Port Hope, ON L 1A 2S6 Mr. Harvey Thompson 4720 Concession Road 6 R R #3 Newtonville, ON LOA 1JO Mr. Sarwan Sahota 4665 Lakeshore Road RR # 8 Newcastle, ON L 1 B 1 L9 Michael Ayre & Julie Jones Elliott Road RR # 8 Newcastle, ON L 1 B 1 L9 , 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 RR. # 8 Newcastle, ON L 1 B 1 L9 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. RR # 8 Newcastle, ON L 1 B 1 L9 Carole Owens Mrs. Jean Payne 4612 Highway # 2 RR # 1 Newtonville, ON LOA 1 JO Gord and Penny Ewington 4659 Lakeshore Rd. RR. # 8 Newcastle, ON L 1 B 1 L9 Ms. Barb Spencer 4563 Lakeshore 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 Mr. Ulrich Ruegger 540 Newtonville Rd. RR # 8 Newcastle, ON L 1 B 1 L9 Ms. Paulette Gerber Nichols Road RR # 8 Newcastle, ON L 1B 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 L 1 B 1 L9 Ms. Rosemary Tisnovsky 4617 Lakeshore 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 Gerry Mahoney and Bonnie McFarland 4548 Lakeshore Road RR # 8 Newcastle, ON L 1 B 1 L9 Mr. Stan Tisnovsky 4646 Lakeshore Road RR # 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 . II ATTACHMENT 2 II SI. LAWR \ ' ,E:tvCE: AND HUDSON RAILWAY CANADIAN'NA TIONAIC RAILWAY Cl <l: o cr: " en ;..J o :r: () Z I~ ,cr: w I~ $: o f- f- en <l: w LAKE ONTARIO ~ Lands to be acquired by The Government of Canada from Cameco Proposed Transportation Routes All Concepts - - Concepts IA and IB ....... Concept II i Peer Review of the Port Granby Project Feasible Concepts Report and the Qualified Concept Report September 2004 Prepared for: The Municipality of Clarington Prepared by: Hardy Stevenson and Associates Ltd. H A R D Y 364 Davenport Road Toronto, Ontario M5R 1K6 STEVENSON p: 416-944-8444 AND ASSOCIATES f: 416-944-0900 i i Executive Summary The Municipality of Clarington wants to ensure the cleanup and safe long-term management of the historic low-level radioactive waste currently stored at the Port Granby site and entered into an agreement in 2001 with the Government of Canada towards meeting this objective. In February 2004, the Low Level Radioactive Waste Management Office (LLRNVT\/fO), acting jas the project proponent on behalf of the Government of Canada, completed its Final Draft report on its selection of a Qualified Concept (QC) for the safe long-term management of the waste (referred to as the Port Granby Project). The LLRWN/10 reviewed three Feasible Concepts (Concept IA-On-site Management of Wastes with relocation of East Gorge wastes; Concept IB-On-site Management of Wastes with no relocation of waste;and Concept II-Relocation of Wastes to a New Long-Term Storage Facility to be located on the Cameco property north of existing waste management facility. The LLR)X/MO concluded that Concept II was the preferred concept for managing the waste located at the existing Port Granby site. The LLRXXTMO is now seeking Clarington Council's concurrence with this conclusion and is proposing to carry out a detailed effects assessment (i.e.,assessment of the environmental effects of implementing the project) of the QC as part of the Environmental Assessment Process. I The Municipality of Clarington's peer review team, led by Hardy Stevenson and Associates Limited, has carefully examined the Feasible Concepts and the Qualified Concept reports for the Port Granby Project. Based on the review of these reports and detailed discussions with the LLRWMO and their consultants, the peer review team agrees with the conclusions of the LLRWMO. Specifically,the team concurs that Concept II is superior to Concepts IA and IB and should be carried forward to the detailed effects assessment stage of the Environmental Assessment. Furthermore, it also recommends that Concepts IA and IB not be carried forward to the detailed effects assessment stage. During its review,the peer review team identified a number of issues related to the Qualified Concept that should be studied during the detailed effects assessment stage. These additional studies will help confirm that the project can be implemented safely and that the facility and related project components will operate as expected for the duration of the project. Peer Review of the Port Granby Project Feasible Concepts Report and the Qualified Concept Report i Hardy Stevenson and Associates Limited September 2004 Table of Contents Section Page Executive Summary i 1. Introduction 1 2. The Environmental Assessment Process 3 3. Overview of the Feasible Concepts / Qualified Concept 10 I 4. Analysis of the Feasible Concepts / Qualified Concept 14 5. Response to Residents' Concerns 24 6. Conclusions and Recommendations 31 7. References 34 Appendix A—Peer Review Methodology Appendix B—Description of the Peer Review Team Appendix C—Comment/Disposition Form for the Feasible Concepts Report Appendix D —Comment/Disposition Form for the Qualified Concepts Report Appendix E—LLRWMO Roundtable Minutes I Appendix F—Letter from Natural Resources Canada on 1978 FERRO decision Peer Review of the Port Granby Project Feasible Concepts Report and the Qualified Concept Report ii Hardy Stevenson and Associates Limited September 2004 i 1 . Introduction The Municipality of Clarington wants to ensure the cleanup and safe long-term management of the historic low-level radioactive waste within its boundaries. In this context, the low- level radioactive waste (LLRW) and marginally contaminated soils (MCS) currently stored near the shoreline of Lake Ontario at the Port Granby Waste Management Facility are to be managed in an environmentally safe and secure manner for the next several hundred years. These wastes,which total approximately 500,000 m3,resulted from the operation of the former Eldorado plant in Port Hope between 1955 and 1988. The site is currently owned ( and maintained by Cameco Corporation under license from the Canadian Nuclear Safety Commission. Following unsuccessful efforts over the past 20 years to find a suitable site elsewhere for the long-term management of the waste,the Municipalities of Clarington and Port Hope decided that local solutions were required. In March 1999,the Municipality of Clarington formed an advisory committee of local citizens to begin technical discussions on proposed conceptual designs for the long-term management of the waste. Two years later, the Government of Canada,the Municipality of Clarington, and the Town of Port Hope and the Township of Hope (the latter two now amalgamated into the Municipality of Port Hope), agreed on a plan for the cleanup and long-term safe management of historic,low-level radioactive wastes situated in their communities (Legal Agreement, 2001). With respect to the Municipality of Clarington,the legal agreement consists of the construction of a new Port Granby Long-term Low-Level Radioactive Waste Management Facility (Port Granby Project).A community-proposed project consisting of on-site management of waste with relocation of East Gorge waste at the existing Port Granby Waste Management Facility was proposed in the Agreement. An Environmental Assessment(EA) is required under the Canadian Environmental Assessment Act (CEAA) before decisions can be made for the implementation of the Port Granby Project. As required by the EA,an evaluation of alternative means of carrying out the project became mandatory. This evaluation became known as the Alternative Means Evaluation. In February 2004, the Low Level Radioactive Waste Management Office (LLRN.VMO), acting as the project proponent on behalf of the Government of Canada, completed its Final Draft report on its selection of a Qualified Concept(QC) for the Port Granby Project. The Qualified Concept Report (QC report) explains in detail the evaluation and comparison of three Feasible Concepts, described in the Feasible Concepts report (FC Report) completed in December 2003,and the selection of a QC for the long-term management of low-level f radioactive waste currently situated at the existing Port Granby site. The LLRNX/TO is now Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 1 Hardy Stevenson and Associates Limited September 2004 i proposing to carry out a detailed effects assessment (i.e.,assessing the environmental effects of implementing the project) of the QC as part of the Environmental Assessment Process. �I As agreed to in the Legal Agreement, the LLRWMO must consult the Municipality of Clarington on the outcome of these reports. The Municipality's peer review team,led by Hardy Stevenson and Associates Limited (HSA ), has completed a detailed review of the FC Report and the QC Report. On the basis of the foregoing,the peer review team has reached the same conclusion as the LLRWMO that Feasible Concept II is the preferred Qualified Concept that should advance to full review under the Environmental Assessment process. This report describes the peer review team's assessment of the Feasible Concepts and the Qualified Concept reports prepared by the LLRWMO for the Port Granby Project. It begins in Section 2 with a description of the Environmental Assessment Process, and follows with a summary of the three selected Feasible Concepts in Section 3. Our analysis of the Feasible Concepts and the Qualified Concept is found in Section 4 of this report. Section 5 summarizes our response to the specific concerns voiced by residents regarding the two reports and general concerns regarding the Port Granby EA process. Appended to this report is a description of the peer review methodology (Appendix A) and the peer review team members (Appendix B). Also appended are the comment/ disposition forms prepared by the peer review team and the subsequent responses from the LLRWMO regarding the FC and QC reports. The comment/disposition form for the Feasible Concept report is located in Appendix C,and the Qualified Concepts report in Appendix D. Finally, minutes from the LLRWMO's roundtable discussions with Clarington residents on the FC I and QC reports are included in Appendix E. 1 I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 2 Hardy Stevenson and Associates Limited September 2004 i [_i. The Environmental Assessment Process An environmental assessment (EA) is "a process to predict the environmental effects of proposed initiatives before they are carried out" (CEAA,2003: 5). In the context of the Port Granby Project,an environmental assessment is required under the Canadian Environmental Assessment Act(CEAA) since a federal authority (Natural Resources Canada) is providing funding for the project and a federal authority (Canadian Nuclear Safety Commission)will be providing a license for the operation of a waste management facility. The following subsections describe the EA process for the Port Granby Project,including steps taken before the EA began. 2.1 The Project Description - Initiating the EA Process In November 2001,the LLRWMO prepared a formal submission to seek approvals to undertake on-site management of existing LLRW and MCS at the existing Port Granby Waste Management Facility. This concept,known as Design Concept B2,was originally developed by the community and is described in the Legal Agreement. It would require in- place stabilization of low-level radioactive waste and marginally contaminated soil at the existing Port Granby waste management site with possible relocation of some wastes to an engineered above-ground mound within the site boundaries. This submission to federal authorities, known as the Project Description,initiated the EA process under the CEAA. It provides an overview of the various phases or elements of the project, including the construction,remedial works,long-term monitoring,and related activities. It also describes the engineering components to be designed and constructed as part of the project,which were based on a conceptual design proposed by the local community. Although now superseded by the identification and analysis of Feasible Concepts,the initial project description involved on-site management of the waste with the relocation of the waste located at the East Gorge site to a low profile engineered storage mound at the north end of the site. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 3 Hardy Stevenson and Associates Limited September 2004 i i 2.2 Scope of the EA - Describing the Requirements of the EA In response to the LLRNVMO's submission of the Project Description,the Responsible Authorities (RAs) for the Project (i.e.,Natural Resources Canada, the Canadian Nuclear Safety Commission,and the Department of Fisheries and Oceans Canada), determined that an EA was required. Subsequently, the federal authorities prepared a"Scope of the Environmental Assessment" document for the Port Granby Project. This document was finalized in July 2002, following comments from the public, including the Municipality of Clarington and its peer review team. The Scope Document provides specific direction to the LLRWMO about how to conduct and document the EA. It describes the project and the activities required to complete the project based on the Project Description and acknowledges that the project as described in the Project Description is at a conceptual level and is expected to evolve during the EA process. It requires the LLR)X7MC) to investigate "alternative means", or the various ways that the project could be implemented,as part of the EA. The document specifies that "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. The Scope also states that the construction and operation of a long-term waste management facility sited away from the Lake Ontario shoreline in the vicinity of the existing waste management site be considered as an alternative means of carrying out the Port Granby Project (NRCan, 2002). The Scope Document confirms that a "screening" level EA would be carried out for the Port Granby Project as required by the regulations of the Canadian Environmental Assessment Act.A"screening" level EA would involve a systematic assessment of environmental effects of a proposed project and the mitigation of adverse effects. However, the Scope also requires the LLRXX/A,IO to provide information to satisfy CEAA requirements for the more detailed "comprehensive" study. The Comprehensive study must address, among other things, alternative means of carrying out the project that are technically and economically feasible and their environmental effects. In effect,the additional study requirements identified in the Scope Document mean that the EA for the Port Granby Project is being conducted at a "comprehensive" level. 2.3 Four Technical Studies - Before the EA Began The legal agreement between the Government of Canada and the Municipalities of Clarington stipulates that the LLRWMO undertake four technical studies related to the on- Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 4 Hardy Stevenson and Associates Limited September 2004 i i site management of waste at the Port Granby site,which include: (1) the concentration of thorium-230 in the wastes located in the East Gorge; (2) groundwater flow through the East Gorge and contact with the wastes deposited in the middle till and lower sands area; (3) potential impacts of shoreline erosion control measures on other shoreline properties in the area; and (4) a contingency plan for the relocation of the wastes,including marginally contaminated soils, in the event of a system failure. Although these studies are not part of the formal EA process,they provide valuable background information that the LLRWMO used to evaluate and compare the various Feasible Concepts during the EA process (described in subsection 2.4). The peer review team reviewed each study and presented its findings to the Municipality of Clarington in June 2003 (refer to HSAL report,"Peer Review of Initial Studies Undertaken to Evaluate Port Granby Long-Term Low-Level Radioactive Waste Management Project"). In this report,the peer review team indicated that it agreed with the main conclusions of the four technical studies prepared by the LLRWMO. The four technical reports are summarized below. 2.3.1 The concentration of thorium-230 in the wastes located in the East Gorge Beak International Inc. (Beak')was commissioned by the LLRWMO to review and evaluate the data available on thorium-230 in LLRW with a separate focus on the Port Granby Waste Management Facility and two other sites in the Port Hope Area. With respect to the Port Granby waste,a key concern relates to the East Gorge waste,which comprises about 20 percent of the on-site waste (i.e., about 100,000 cubic metres). Relocation of this waste,if considered feasible,must take into account potential hazards and contamination problems due to the presence of thorium-230 in addition to other isotopes in the uranium decay chain in the waste. The study found that the concentration of thorium-230 in the East Gorge wastes is relatively high, that inhalation would be the most important exposure pathway,and that thorium-230 would be the most important radionuclide in terms of dust control and worker protection. However,the study concluded that the levels of thorium-230 present at the site would not preclude the waste excavation and handling that is necessary to construct and operate the long-term facility with normal operational controls against dust generation and exposure that would be required to protect the workers and the residents during any waste relocation. C Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 5 Hardy Stevenson and Associates Limited September 2004 i 2.3.2 Groundwater flow through the East Gorge and contact with the wastes deposited in the middle till and lower sands area Intera Engineering Limited ("Intera")was commissioned by the LLRWMO to: (a) study the potential for groundwater to infiltrate through the waste and leach the waste into Lake Ontario,and (b) make an assessment of transport of radioactivity from the site through groundwater. The study was intended to determine how effective the on-site management options would be in mitigating the groundwater transport of contaminants in the site. A key finding of Intera's report is that the ground water interceptor trench/sheet pile cutoff wall (on the northern side) proposed in the Project Description would be ineffective in capturing the upgradient groundwater flow and diverting it around the waste. Another key finding was that most of the contaminated ground water will directly bypass the planned leachate collection system, and ultimately discharge into the lake. Several remedial options are considered in the Intera report to improve the characteristics of the on-site management concept. None of the options evaluated provided complete containment of the contaminants. Due to the construction of a low permeability cover system over the site and a better groundwater diversion system,groundwater would move slowly but contaminants would still be released to the groundwater at above background concentrations for periods exceeding 500 years. 2.3.3 Potential impacts of shoreline erosion control measures on other shoreline properties in the area The LLRWMO retained W. F. Baird and Associates Coastal Engineers Limited ("Baird") to conduct an assessment of: (a) the effectiveness and feasibility of the proposed shoreline protection features over the life of the storage period,and (b) potential impacts the structures may have on adjacent shoreline and bluffs. The Baird study concluded that without the shoreline protection, the bluffs would erode by about 130 metres over a 470-year period and nearshore downcutting would be about 2.2 metres, leading to loss of waste to the lake. The study also noted that bluff recession is episodic,with periods of inactivity followed by periods of erosion. With a shoreline protection structure constructed at the waste management facility, the adjacent shoreline would continue to retreat and the protected area would form a promontory extending up to 130 metres into the lake. As a result, the shoreline protection i Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 6 Hardy Stevenson and Associates Limited September 2004 i i i i structure would need to be periodically extended as the adjacent shoreline recedes over the expected 500 year life of the project. In addition,the structure would need to be replaced at least once over the life of the facility. 2.3.4 A contingency plan for the relocation of the wastes, including marginally contaminated soils, in the event of a system failure Golder Associates Ltd. ("Golder")was commissioned by the LLRWMO to develop a conceptual Contingency Plan for the relocation of the Low-Level Radioactive Waste (LLRNIV) and associated Marginally Contaminated Soil (MCS) from the proposed on-site Waste Management Facility (Concept 132) in the event of a system failure. Golder noted that in the event of a gross failure to a key component of Design Concept B2, the LLRW and the MCS would potentially require relocation.The contingency plan for such an event proposed that the removed wastes be transported to a Contingency Waste Management Facility (WNIF) at an undetermined site within the local area but away from the lake. Golder recommended an Above-Grade Mound concept for the Contingency WMF with a low permeability cap/low permeability liner option as the design basis for the facility together with a collection/treatment system for the leachate throughout the service life of the mound. This recommendation is similar to the Feasible Concept II,which the LLRWMO selected as the Qualified Concept in subsequent studies. 2.4 Narrowing Choices — Development of the Feasible Concepts and Identification of the Qualified Concept Once the LLRWA/10 completed the four technical studies, it initiated the studies for the EA. The first major component of the EA is to identify the best concept for managing the waste from a technical, env=ironmental and socio-economic perspective. The concept that is identified through this process (the Qualified Concept) is then carried forward through the detailed effects assessment,which is discussed in Section 2.5 of this report. The process used to identify the Qualified Concept involves two major steps: (1) Developing the Feasible Concepts,and (2) Comparing the Feasible Concepts. At each step,there is a progressive narrowing of choices until the Qualified Concept is identified. The analysis and evaluation throughout this process involves a series of numerical weighting and rankings in order to determine die best approach for managing the waste. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 7 Hardy Stevenson and Associates Limited September 2004 In the first step, the LLRWMO identified potential approaches for managing the waste including: (1) on-site management of the wastes;and, (2) relocation of the wastes to a new facility. Each approach was then broken down into components required to achieve the overall approach, such as those required for waste excavation, transport, relocation, etc. For example,bluff stabilization is a component of the on-site management approach and three possible alternative means were identified to achieve this component: rockfill slope, reinforced fill slope,and vegetated soil slope. The alternative means for each component were then compared and the alternative means with the best score was identified. The LLRWMO then assembled three Feasible Concepts consisting of the preferred alternative means for each component which consisted of (1) Concept IA- On-site Management of Wastes with relocation of East Gorge wastes; (2) Concept IB - On-site Management of Wastes with no relocation;and (3) Concept II -Relocation of Wastes to a New Long-Term Storage Facility to be located on the Cameco Property North of Existing Waste Management Facility. In the second step,the three Feasible Concepts were subjected to further detailed evaluation to determine the Qualified Concept. More detailed descriptions of the three Feasible Concepts and the one Qualified Concept identified by the LLRWMO are presented in Section 3 of this report. The process that the LLRWMO used in each step is described in the Feasible Concepts Report and the Qualified Concepts report respectively. The peer review team undertook I an extensive analysis of these two reports,which is summarized in Section 4 of this report. l 2.5 Assessing the Environmental Effects of the Qualified Concept LLRWMO studies recommend that the best option for managing the waste involves moving the waste across Lakeshore Road on the Cameco site (the waste is currently stored on land owned by Cameco). Provided that the Municipality of Clarington concurs with the recommendation,the LLRWMO will complete a detailed assessment of the effects of the Qualified Concept on the environment. In the context of the Port Granby Project, the LLRNxrMO will examine effects related to: • Aquatic environment • Human health and safety • Atmosphere / air quality • Socio-economic environment • Geology and groundwater • Terrestrial environment Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 8 Hardy Stevenson and Associates Limited September 2004 i As of the date of this report,the LLRWMO had completed baseline characterization studies for all the areas listed above except for the socio-economic environment. These studies I describe the existing condition of the area in and around the Port Granby WMF. Once the LLRWMO begins the detailed effects assessment,they will further evaluate the baseline data in the context of the proposed concept and predict what changes to the existing conditions will occur based on construction and operation of the WMF at that site. If the studies indicate that the project will result in any significant adverse effects, the LLRWMO will examine how to mitigate, or lessen, those effects. 2.6 Documenting the Environmental Effects Once the assessment is complete, the LLRWMO will document the entire EA process in an Environmental Assessment Study Report, currently expected to be completed in early-to- mid 2005. The report will describe whether the project is likely to cause significant adverse environmental effects, taking into consideration appropriate mitigation measures.The LLRWMO will submit this report to the RAs (NRCan, CNSC,and DFO) and other expert federal authorities for review. In turn,the RAs will prepare a screening report to indicate their decision of whether to enable the project to be carried out.The decision would be contingent on the ability of the project to be implemented without significant adverse environmental effects. Once the Screening Report is released, the Municipality has the opportunity to review the Report and the RAs decision and determine if the Project, as approved, should proceed.The screening report is expected to be released in 2006. 2.7 Constructing and Operating the Waste Management Facility Provided that the RAs decide that the project can be carried out, construction and development of the waste management facility and the related components would take place over a period estimated to last five years. Once construction is complete,the WMF would be closed to accepting further waste. The LLRMWO would then begin the maintenance and monitoring stage of the project, which consists of long-term management, monitoring,and maintenance of the facility. These tasks would help to ensure that the facility performs as designed,and is in compliance with applicable licensing requirements and regulatory standards (LLRNXIMO,2001). C I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 9 Hardy Stevenson and Associates Limited September 2004 I 3. Overview of the Feasible Concepts / Qualified Concept i I This section describes the three Feasible Concepts and the Qualified Concept proposed by the LLRW vlO as a result of the alternative means assessment.The three concepts are referred to as Concepts IA, IB, and II. A site layout for each concept is included at the end of this section as Figures A,B,and C respectively. 3.1 Concept IA: On-Site Management of Wastes— Excavation of East Gorge Wastes This option involves long-term stabilization of most of the waste at the existing Port Granby Waste Management Facility (WMF),and is essentially an optimized version of the option that was conditionally endorsed by the Municipality of Clarington's Council in 1999. Up to 100,000 m3 of the waste would be relocated from the East Gorge area to a new storage facility within the site boundary to minimize the potential for groundwater contact with the waste. Waste would be excavated using conventional methods and equipment,and would be transported by truck. The trucks would be equipped with sealable tailgates and the waste would be covered during haulage to prevent spillage and dust generation. The new above-ground storage mound would be located in the north-west portion of the existing Port Granby WMF, and at this facility,the removed waste would be isolated with a low permeability composite base liner at the bottom and a multi-layer final cover system surrounding the waste. To prevent erosion of the shoreline and the bluffs at the existing NVMF site,a rock-fill toe berm would be constructed, supporting a bluff that would be reinforced with a vegetated soil slope. The toe berm would extend approximately 25 metres offshore and its highest point would sit approximately 12 metres higher than the normal water level of Lake Ontario. Initially, the toe berm would be 400 metres long, but periodic extensions at its flanks would be required as the adjacent unprotected shore recedes. The final length of the toe berm is estimated to be 760 metres. It is expected that in 500 years, the land on which the waste i facility is located will form a promontory extending up to 130 metres into the lake as the result of the continuing erosion of the adjacent shoreline. A low permeability cover system, a deep groundwater cut-off wall,and an upstream groundwater collection system would be required to stabilize and isolate the remaining waste at the Port Granby WAIF site (i.e.,the West Gorge Area and Central Plateau Areas). I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 10 Hardy Stevenson and Associates Limited September 2004 i I Existing impacted groundwater would be collected through an interceptor trench constructed across the mouth of the East Gorge, and subsequently treated in an on-site system. During construction, the surface water would be managed with surface ditching to sumps and pumping of the collected water to an on-site treatment facility. It is estimated that the construction of the new waste facility under Concept IA would require approximately 40,000 truckloads of construction material to be transported to the site. As well, standard highway haul trucks would be used to transport materials for all of the Feasible Concepts. The preferred route for these trucks was identified as entering from Highway 401 south on Newtonville Road,continuing east on Concession Road 1 and then south on Elliott Road (refer to Figure 5-2 in the Qualified Concept report to view all access route alternatives). An access route would cross Cameco's lands and Lakeshore Road to the existing site. The existing roadways and railway crossings and other infrastructure facilities along this route would be upgraded or reconstructed as required. Whether the crossing at Lakeshore Road would be at grade or below grade has not been determined at this point. I 3.2 Concept IB: On-Site Management of Wastes — No Waste Excavation This option is the same as Concept IA,with the exception that none of the waste would be excavated. As in Concept IA, a low permeability cover system,a groundwater cut-off wall and a groundwater collection system would be employed to isolate the waste. A toe berm and a vegetated soil slope would be used to reinforce the shoreline and the bluffs respectively. An interceptor trench and surface ditching to sumps would be used with a treatment system to treat existing impacted groundwater and surface water, respectively. It is estimated that the construction of the new waste facility under Concept IB would require the transportation of 40,000 truckloads of construction materials to the site. As noted above,the preferred transport route would be the same as for Concept IA. 3.3 Concept II: Relocation of Wastes to a New Long-Term Storage Facility on the Cameco Property North of the Existing Waste Management Facility This option involves relocation of all the wastes (approximately 500,000 m3) to a new facility on a portion of the Cameco property about 300 metres north of Lakeshore Road on the east side of Elliott Road. The facility would consist of an above-ground storage mound which would be 8 metres high at its highest point and have a 10 hectare footprint. The mound Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 11 Hardy Stevenson and Associates Limited September 2004 I i I would have a low permeability composite base liner, a low permeability cover system,and a system for collection / treatment of leachate. The waste would be excavated from the existing site using conventional methods and transported by covered and secured trucks to the new facility. Similar to Concepts IA and IB,an interceptor trench would be constructed at the existing waste management site to deal with residual impacted groundwater. Surface water would be managed with surface ditching to sumps. Impacted water would be pumped to a treatment facility at the new site. Since the waste would be relocated, the shoreline and bluffs would not need to be stabilized. The existing site would be filled,regraded, and seeded to create a natural setting. Construction materials would be transported to the new facility site using the same transportation route as in Concepts IA and IB. It is estimated that approximately 15,000 truckloads of construction material would need to be transported to the new site. A dedicated access route across Cameco's lands would be used to transport the waste and contaminated soils from the existing site to the new facility. It would also be used for transporting fill material from the site of the new facility to the existing site for regrading the waste excavation areas. If Concept II is eventually approved by the Responsible Authorities, the Government of Canada would purchase all of the lands currently owned by Cameco in the Port Granby area, including the lands occupied by the existing waste management facility. These landholdings total approximately 250 ha (620 acres). The appropriate end uses for these lands will be determined through further study and consultation with the Municipality and area residents. 3.4 The Qualified Concept The LLRNX/AIO subjected the three Feasible Concepts described above to a detailed comparative evaluation as documented in the Qualified Concept Report. This evaluation of the three Feasible Concepts resulted in the following weighted scores,with the highest score being the most preferred: Feasible Concept IA —238; Feasible Concept IB —282;and, Feasible Concept II —325. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 12 Hardy Stevenson and Associates Limited September 2004 i The comparative evaluation included an assessment of advantages and disadvantages, and of relevant issues and trade-offs for each concept.Based on these results, the LLRWMO j identified Feasible Concept II as the most suitable approach for implementing the Port Granby Project. Subject to the Municipality of Clarington's concurrence,this Concept will be further evaluated as to its environmental effects before the LLRWMO makes any decisions about submitting the project to the RAs for approval. I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 13 Hardy Stevenson and Associates Limited September 2004 LEGEND: ---- / ORIGINAL CONTOURS PROPOSED FINAL CONTOURS -- LAKE SHORE ROAD \_ ° / ° \ - FENCE LINE / - - - !_.-.-.-. - -'-' "'-` -"-'- •--•- "-' -_\ / ` r----- APPROX.EXISTING WASTE BURIAL TRENCH LOCATION • _ `- __° __ •-._ ACCESS ROAD AREA OF PROPOSED LOW PERMEABILITY COVER SYSTEM \\\ // I _ _ /'y������%L.- i'r��l -- _� \\ o ��/�� o ° "•-lI / \ / -i/ PROPOSED TOE BERM PROPOSED BLUFF STABILIZATION PROPOSED DITCH / E)usnNG TREATIAENT PONDS TO BE OECCIMMISSIONED PROPOSED GROUNDWATER DIVERSION SYSTEM (DEEP CUT-OFF WALL AND GROUNDWATER COLLECTOR TRENCH) \ - \,/ - � C i \ /,/ � C� `\ / _ \\ °/✓ -----__ ------ APPROXIMATE AREA OF LLRW EXCAVATION / \` - - I / ✓. \\. /' -_-\`\ / % / - A -A' CROSS-SECTION LOCATIONS L 21 NOTES: /' \\ i/ --- _ - - - - \ �� \<- < ,/ / `\ 1-DATUM IS UTM NAD 83,ZONE 17,TRANSLATED BY MARSHALL MACKLIN MONAGHAN FROM UTM NAD 27,ZONE 17. 2.FOR CROSS-SECTIONS A-A'AND B-B'REFER TO FIGURE B.4-2. 114 J 3.FOR DETAILS OF LOW PERMEABILITY COVER SYSTEM,TOE BERM,BLUFF STABILIZATION AND GROUNDWATER DIVERSION SYSTEM REFER TO FIGURE GROUNDWATER B.4-2. DIVERSION SYSTEM_--- yo°✓' N WELL AS LOW ---_ PERMEABILITY LINER AND COVER REFER TO FIGURE B.4-3. GROUNDWATER DIVERSION SYSTEM PROPOSED-TREATMEN/. LOCATION J/ REFERENCES: 1.MAPPING BASED ON TOPOGRAPHY PROVIDED BY ELDORADO RESOURCES LIMITED.,DRAWING NO.81059,SHEET 5,REV.1,DATED 1984-11-19,SITE GROUNDWATER DI EIR$IDN SYSTEM ourLEr sT PLAN LOCATING OBSERVATION WELLS,SLOPE MONITORING LINES,AND �ucTyriE I ————— / <— / / / \ \ PROFILE LINES,PORT GRANBY WASTE MANAGEMENT FACILITY,SCALE APPROX.AREA OF / � / \ 1:1,000. LLRW EXCAVATION - -� If (-50,000 m') \ PRO AREA OF - �� \\/ I 2.EXISTING WASTE BURIAL TRENCH LOCATIONS DIGITIZED FROM FIGURE LL R CAVATION °• /_\Im 2-4 TITLED,"GENERAL SITE PLAN SHOWING EXISTING WASTE BURIAL (_ m) / y? TRENCH LOCATIONS,PORT GRANBY WASTE MANAGEMENT FACILITY", DATED MARCH 1986,BASED ON DRAWING NO.81059,SHEET 6,REV.A, )/,GROUNDWATER DAN SIGN PROPOSED PROVIDED BY ELDORADO RESOURCES LIMITED. / /j / I \\ BEM OUTLET Sj CURE /% -- / TRE,A/fMENT PON \\ 3.EXISTING WASTE BURIAL TRENCH LOCATIONS 74,75,AND 76 AND WATER / GROUNDWATER DIVERSION SYSTEM / \\ \\ /// ,,/ / I -\\\,' ' - -\ //' '\ ,J// i `\ COLLECTION AND TREATMENT FEATURES,DIGITIZED FROM DRAWING NO. / DISCHARGE PIPE / /\ I •\ 8._- \ \,�,/ ---__ \ 81059,SHEET 6,REVISION D,TITLED'RESIDUE PIT LOCATIONS,WATER !/ / COLLECTION AND WATER TREATMENT FEATURES,PORT GRANBY WASTE C / `. / MANAGEMENT FACILITY-,DATED NOVEMBER 22,1984,PROVIDED BY 4o \ CAMECO CORPORATION. / j� GR IN VA4TER DI ON YSTE DISCHAF P PE Ry/ DRAFT INT `EPT R CH /' c�d� \ \ / 20 o 20 40 pe:-. _ __ \;- - -_ _' _ " Y •` __, ,\ ° \\ // � \ \ // \\ ' / // �O��i \\ _ %l /i SCALE 1:1000 METRES MH _ I \ m ROAD LA/CEONTAR/O W/L-75m y Associates Ltd. Golder Mississauga,Ontario,Canada PROJECT LOW LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE PORT GRANBY WASTE MANAGEMENT FACILITY TITLE SITE LAYOUT CONCEPTIA IN-SITU MANAGEMENT OF WASTES EXCAVATION OF EAST GORGE WASTES PROJECT: 021-1384(10) FILE:R1384B41.DWG DATE: NOV.17,2003 F I G U R E A &B CAD: FC DES: ..K ''MAC RVW: FSB DRAWING NUMBER REV LEGEND: ORIGINAL CONTOURS \ \ ° \\ PROPOSED FINAL CONTOURS 04iIESHORE ROAD _ - ` ` -�-•--'—'—'——'—'-'—'—'—' —'_%'—•-•—•-..—.—.—•--•—.—_._—.� / —.—.—.—— FENCE LINE •—'—'—•—•—.—.—p •—•—•—•—' 'L__J APPROX.EXISTING WASTE BURIAL TRENCH LOCATION �•ae. / - \\ f - - _- \\ -_ - --7 --- ---- , /� \\ 7 --- __ - —'—r ° / ACCESS ROAD \ / \ /•—• •—•—•—.—.—. L._._C� �_,_ __ \ ° / ° �-ll - - / AREA OF PROPOSED LOW PERMEABILITY COVER SYSTEM PROPOSED TOE BERM PROPOSED BLUFF STABILIZATION \ / EXISTINGITREATMENT PONDS \\ // TO 9E DECOMMISSIONED \ , ,/ `\ / \\ PROPOSED DITCH ------ PROPOSED GROUNDWATER DIVERSION SYSTEM (DEEP CUT-OFF WALL AND GROUNDWATER COLLECTOR 'TREATMENT ) \\ SEDIMENTATION \ / \ \/ °!� / ----- TRENCH) LAGOON LAGOON TIONS WL 111.3.) CROSS-SECTION LOA ------ If \\�// NOTES: // \\I\ /�a •—. .—. .—_, •_— _ \\ / - ' `\ -- °�° ��<`a�< ° %• \\ 1.DATUM IS UTM NAD 83,ZONE 17,TRANSLATED BY MARSHALL MACKLIN MONAGHAN FROM UTM NAD 27,ZONE 17. ----- --------------- --6--- ��� —j _ - 2.FOR CROSS-SECTIONS A-A'AND B-8'REFER TO FIGURE 65-2 GROUNDWATER 3-FOR DETAILS OF LOW PERMEABILITY COVER SYSTEM,TOE BERM,BLUFF DIVERSION SYSTEM.-. - STABILIZATION AND GROUNDWATER DIVERSION SYSTEM REFER TO FIGURE \\ GROUNDWATER DIVERSION SYSTEM/ PROPOSED-TREATMEN'' LOCATION / REFERENCES: 1.MAPPING BASED ON TOPOGRAPHY PROVIDED BY ELDORADO RESOURCES �-/�—_ i_- -- / - -1� \+ -- --- ,' / j� \ --1$ / LIMITED.,DRAWING NO.81059,SHEET 5,REV.1,DATED 1984-11-19,SITE GROU�WATER D RSION SYSTEM I ___ / ` a% _ ,' \\ I /' PLAN LOCATING OBSERVATION WELLS,SLOPE MONITORING LINES,AND OUTLET S7UCT I E / I J / a <— _ - / - / - / _ \ I PROFILE LINES,PORT GRANBY WASTE MANAGEMENT FACILITY,SCALE 1:1,000. 2.EXISTING WASTE BURIAL TRENCH LOCATIONS DIGITIZED FROM FIGURE 2-4 TITLED,-GENERAL SITE PLAN SHOWING EXISTING WASTE BURIAL TRENCH LOCATIONS,PORT GRANBY WASTE MANAGEMENT FACILITY", 41 \ / a DATED MARCH 1986,BASED ON DRAWING NO.81059,SHEET 6,REV A, \/' I \\ PROVIDED BY ELDORADO RESOURCES LIMITED. A /�GROUNDWATERD ION // / PROPOSED \ M OUTLET S CURE / T MENT PON \ _ /% / 7\ _ \ 3.EXISTING WASTE BURIAL TRENCH LOCATIONS 74,75,AND 76 AND WATER / GROUNDWATER DIVERSIbN SYSTEM !/ \\ �� //' / - - COLLECTION AND TREATMENT FEATURES,DIGITIZED FROM DRAWING NO. I \\/ ,' 1 \ %/ \•\ / \\ 81059,SHEET 6,REVISION D,TITLED-RESIDUE PIT LOCATIONS,WATER / DISCHARGE PIPE f - COLLECTION AND WATER TREATMENT FEATURES,PORT GRANBY WASTE C MANAGEMENT FACILITY",DATED NOVEMBER 22,1984,PROVIDED BY C \ CAMECO CORPORATION. N WATER DIv RSON -- - YSTEM DISC PPE DRAFT \ / ell INTE \EPT RY H 20 20 40 - -- / / \� %/ a \`\\---- - --_�✓_-- -'/� \\ ,/ ,\\�'�.\ \\ / ��> \ /� // - \\ __ / SCALE 1:1000 METRES — `\�� \ �`�a / \\\ �' ° •,\ \\ r / F / '3 _ Golder Associates Ltd. Mississauga,Ontario,Canada PROJECT LOW LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE PORT GRANBY WASTE MANAGEMENT FACILITY TITLE SITE LAYOUT 0 1 ACCESS ROAD CONCEPT IB IN-SITU MANAGEMENT OF WASTES / / NO RELOCATION OF WASTES PROJECT: 021-1384(10) FILE:R1384B51.DWG LAKEOWTAR/O - ' W/L-75m DATE: NOV.17,2003 <w �4,' \\ ,p`•/ \\ gj \\ �o°// °y',\ CAD: FC DES: FIGURE B 0 i o a j \\ CHK: RVW: FSB DRAWING NUMBER REV x X X X X x 1 x X x x x x X x � Is LLx CD 0 M (v 0 0 0 N 0 0 1) N 7 % O N O O Na i N U T p a / W ¢ w O Q ~ W O J a L� PROPOSED 917E ACCESS _ROAD PROPOSTD CONTRACTORSYAFW AND SITESERVICEAREA (REFER TO FIGURE 4.1A.1) M 029 OR 1�1 '% i X x --I x x I PROPOSED ECAVATION SOIL STOCMLE AREA (EXCESS SOIL TO BE USED TO REHABILITATE EXLSTING x WASTEMANAGEMENTAREAAFTE(WASTE REMOVAL) (REFER TO FIGURE 4,1.4-1) x x APPROX.SOUTHERN BOUNDARY OF UPPER GLACIAL TILL x X X_ X X X X x x J x % x Y G PROPOSED O cy 0( WASTE VO4CLE A.O'V \ \ ACCESSROAD °4"/' \ PROPOSED ACCESS ROAD \,` \ TO IDOSTING WASTE \11 MANAGEMENT AREA E>dsbng Port Granby Low•Laval Radioactive Waste Management Fadlity �e ❑ nNnm c - `\` �[+e \\ — - r EDSTrw –-- GATE i r FIGURE C Proposed New Mound Top of Final Cover Contours Port Granby Project Description of the Project for Environmental Assessment Purposes Legend Roads i-+;m-H'r Railway Contour Lines – X — Proposed Fence Line and Facility Boundary Proposed Buried Pipeline Proposed Top of Final Cover Contour Proposed Top of Final Cover Slope QCross-Section Locations in Plan Notes 1.Topographic Contours Have Been Recompiled in Metres with Contours Digitized from Figure 3.2 Entitled, "Plan of Lakeshore Road Disposal Site", Dated August 9, 1983, Golder Associates' Project 831-1135A, B, and C. 2. Topographic Contour Interval is 5 Metres. 3. For Details of Cross-Sections D-D'and E-E' Refer to Figure 4.1.8-2. 4. For Proposed Site Facilities Layout During Construction Refer to Figure 4.1.4-1. 0 100 200 300 Metres Scale 1:4,000 REFERENCES 1. NRVIS Base Data supplied by MNR(1998). Data reprojected to UTM NAD83, Zone 17. Produced by Stantec and Golder Associates Ltd. under Licence with the Ontario Ministry of Natural Resources. ©Queen's Printer for Ontario, 2003. Date: June 25, 2004 PORT HOPE AREA ,,AU 440 t1VITLurvE riLT.-Analysis of the Feasible Concepts / Qualified Concept Based on the peer review team's review of the FC and QC reports,we concur that the overall recommendations of the two reports are appropriate. Specifically,we have reached the following four conclusions: (1) The evaluation process used to develop the Feasible Concepts and to identify the Qualified Concept is robust and defensible; (2) Concept II is superior to Concepts IA and IB and should be carried forward to the detailed effects assessment stage of the Environmental Assessment; (3) Concepts IA and IB should not be carried forward to the detailed effects assessment stage; and, (4) Additional issues should be addressed during the detailed effects assessment stage. Each of these conclusions is discussed in greater detail below: I i 4.1 The evaluation process used to develop the Feasible Concepts and to identify the Qualified Concept is robust and defensible; Overall, the peer review team is satisfied that the methodology is robust and defensible for the purposes of identifying a preference between the Feasible Concepts. This methodology relies on three approaches to evaluation: (1) a numerical comparison of the Concepts based on predefined criteria; (2) an analysis of advantages and disadvantages;and (3) an analysis of relevant issues and trade-offs. I This methodology is similar to those used in other federal Environmental Assessment processes. By using a combination of qualitative and quantitative evaluation approaches,the LLRWMO is able to verify the numerical results. The LLRWMO also used several sensitivity analyses to ensure that the results of the numerical comparison were unaffected by changing the weighting of specific criteria. I i Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 14 Hardy Stevenson and Associates Limited September 2004 i 4.2 Concept II is superior to Concepts IA and IB and should be carried forward to the detailed effects assessment; The peer review team agrees with the LLRWMO's conclusion that Concept II is the most suitable of the three Feasible Concepts for the safe long-term management of the Port Granby wastes and should be carried forward as the Qualified Concept. Overall,the I Concept provides for better isolation of the waste over the long term,greater redundancy of system components, and easier monitoring,repair,and replacement. A detailed description of the advantages of Concept II is provided below. 4.2.1 Effectively isolates the waste over the duration of the project The peer review team concurs that the design of Concept II,including the liner, cover, i leachate collection / treatment system, and interceptor trench,will effectively isolate the waste from the environment. As well, Concept II minimizes the risk that leachate from the above-ground mound will leak into the environment or the lake, especially over a time span of several hundred years. This is accomplished by managing the waste away from Lake Ontario's shoreline, by siting the facility in an appropriate geological setting, containing the waste with state-of-the-art cover and liner technologies,and through design features that require minimal ongoing maintenance. Subject to approval by the Canadian Nuclear Safety I Commission,this concept will provide members of the public with access to the Lake Ontario shoreline in this area. 4.2.2 Provides greater redundancy and therefore less risk of failure The peer review team strongly agrees with the LLRWMO that engineered systems with fewer working parts and greater redundancy (i.e., parts that act as backup should other parts fail),as offered by Concept II, are preferred over systems with multiple dependent parts and therefore more likelihood of failure. The base liner, cover system,and leachate collection / treatment system for Feasible Concept II are intended to operate independently of one another.Thus, any one of the three systems working alone is designed to ensure that the waste will not contaminate the groundwater. The operation of the three systems to contain the wastes will significantly increase the reliability of the entire system. ,I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 15 Hardy Stevenson and Associates Limited September 2004 i 4.2.3 Allows for ease of monitoring, repair, and replacement of parts The peer review team accepts the conclusion of the LLRWMO that the facility associated with Concept II will be easier to repair than in other Feasible Concepts by virtue of the waste being isolated in an engineered containment located above ground. There is a large amount of experience with the design and construction of above-ground management technology used in this concept. Compared to Feasible Concepts IA and IB,the proposed design for Concept II therefore significantly improves the ease and safety of monitoring and repair. 4.2.4 Can be constructed and implemented safely The peer review team accepts the LLRWMO's analysis that various activities associated with constructing and implementing Concept II can be carried out safely. The major activities are the excavation,transportation and re-storing of the waste at the new site. Based on studies carried out to date by the LLRWMO, and experience at other low level waste sites in Canada and the United States,these activities can be carried out in a way that meets or exceeds Canadian Nuclear Safety Commission and other environmental requirements. 4.2.5 Will result in fewer impacts on the community from construction traffic than Concepts IA or IB The peer review team acknowledges that the construction of any of the Feasible Concepts will produce some undesirable effects in the local community. However,we concur with the LLRWMO that Concept II will result in the least impacts from truck traffic. Concept II requires less material to be transported than the other two concepts (approximately 15,000 truckloads for Concept II vs.40,000 truckloads for Concepts IA and IB). Since the amount of dust and noise generated is directly related to truck traffic volumes, Concept II will have less impact on the community than Concepts IA and IB. The peer review team is also confident that any impacts associated with construction traffic for Concept II,including I excavation and movement of the waste, can be effectively mitigated. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 16 Hardy Stevenson and Associates Limited September 2004 i 4.2.6 Is consistent with international approaches for managing similar low-level radioactive waste and marginally contaminated soils Throughout Canada and the United States, engineered mounds are used to safely store and manage low-level radioactive waste and marginally contaminated soils. The LLRWMO currently operates two such sites in Canada. While many of these facilities were designed and constructed in the last 10 years, several facilities have been operating safely for nearly 20 years. Technologies particularly with respect to liners have been improving in terms of durability and structural properties. The peer review team accepts the LLRWMO's conclusion that these facilities can be appropriately designed with state-of-the-art technology II for mound designs to last for the expected duration of several hundred years. I 4.3 Concepts IA and IB should not be carried forward to the detailed J effects assessment stage i Concepts IA and IB have been developed by the LLRWMO based on the community proposal for on-site management of the waste outlined in the Agreement. Despite several improvements to the on-site concept proposal discussed in the Reports,the peer review I team accepts the LLRWMO's conclusion that neither Concept IA nor IB will be able to perform as well as Concept II in safely and effectively containing the waste over the duration of the project. The proposed approaches for Concepts IA and IB are complex and require it multiple systems to function as designed over hundreds of years. Therefore,these concepts should not be carried forward to the detailed effects assessment. I In addition to the benefits discussed regarding Concept II, Concepts IA and IB do not l perform as well for the following reasons: 4.3.1 The difficulty of isolating the waste from ground and surface water I The waste is currently stored near the shoreline in trenches directly cut into native soil I without any liners for containing the waste.Leaving the waste on-site (or in place) requires that the waste be kept out of contact from both ground and surface water so that the waste does not flush out into the lake. Based on a report prepared by Intera Consultants in 2002, an interceptor trench across the mouth of the East Gorge would not be fully effective in dealing with impacted groundwater from across the whole facility, and would result in ongoing discharge of contaminants to the lake. I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 17 Hardy Stevenson and Associates Limited September 2004 f The peer review team concurs that the proposed groundwater cut-off wall will not prevent groundwater from contacting the waste. Similarly,we have concerns about the ability of the i cover system,which will be constructed on a slope at the East Gorge,to function effectively over the long term. The cover system is crucial to limiting the surface water from contacting the waste and ensuring that flushing of contaminants from the site does not occur. We are not aware of any other cases where such an approach has been adopted for long-term management of LLRW waste. 4.3.2 The likelihood and cost of implementing a contingency plan should the engineered systems fail Feasible Concepts IA and IB depend on all of the following components to work properly to prevent the waste from leaching into the groundwater or the lake: a low permeability cover system, a deep groundwater cut-off wall,upstream groundwater collection,and an interceptor trench with a leachate collection and treatment system. These Concepts also require elaborate measures to eliminate shoreline erosion (i.e.toe berm and bluff stabilization). The peer review team concurs with the LLRWMO that repair and replacement of the various components would need to occur regularly. Thus, the future risks and associated expenses would be significant. Should there be a gross failure of the system,the LLRWMO proposes an above-ground I' mound away from the lake (as in Concept II) as a contingency measure. This plan provides another supporting reason for recommending Concept II and suggesting that Concepts IA and IB not be carried forward to the detailed effects assessment stage. i4.3.3 The effects on Lake Ontario from managing the waste in-place The peer review team concurs with the LLRWMO that there is a risk of further impacting i Lake Ontario by managing the waste in place. As discussed above,the lack of a liner underneath the waste increases the risk of leachate leaking into the lake. In addition, the shoreline stabilization measures would involve major construction efforts. The toe berm, - which will extend 25 metres into the lake, is expected to increase environmental impacts on the lake, including impacts to fish habitat. This placement of rock fill in the lake will result in Harmful Alteration,Disruption or Destruction (IIADD) of fish habitat that will require mitigation and compensation. This may be an expensive and time-consuming process. The need to extend the toe berm as the adjacent shoreline recedes (which is estimated to be required every 30 years over the life of the project)would exacerbate these impacts, as would Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 18 Hardy Stevenson and Associates Limited i September 2004 i implementing any contingency plans to address any failure of the toe berm. Furthermore, these stabilization measures,including the toe berm,will need to be maintained every few decades and reconstructed at least once to ensure they are performing as intended over the life of the facility. I ,I 4.4 Additional issues should be addressed during the detailed effects I assessment stage While the peer review team concurs with the LLRWMO's assessment of Concept II as the 11 preferred or"Qualified" concept,we have identified issues that need to be addressed in the next phase of the Environmental Assessment. The peer review team recommends that additional analysis be completed during the detailed effects assessment stage of the Environmental Assessment to resolve these issues. The additional studies will help confirm I that the project can be implemented safely and that the facility and related components operate as expected for the duration of the project. Such studies should include the following: li 4.4.1 How to handle and excavate the waste The conventional excavation method that the LLRWMO is proposing may not be the best I method to deal with all of the low-level radioactive waste,some of which has a significant thorium-230 radioactivity (which is an inhalation hazard) and potential for dust emissions. I Although conventional methods of waste excavation may suffice for handling marginally (i contaminated soils, special procedures including enclosed excavation with filtered ventilation may be necessary to reduce the radiological risks for the public and the workers handling I LLRW to "as low as reasonably achievable" (ALARA) levels. We suggest that enclosed excavation option should be considered further unless the � LLRNX/TvIO can clearly demonstrate that special procedures discussed above are not needed for reducing radiological risks to ALARA. The LLRMMO has agreed to examine this issue further during the detailed effects assessment stage. �I I I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 19 Hardy Stevenson and Associates Limited September 2004 I i 4.4.2 How to remediate groundwater at the existing Port Granby site Currently,contaminants from the Port Granby waste management site are leaching into the groundwater system and ultimately into Lake Ontario. Once the waste has been moved to the north side of Lakeshore Road,the LLRWMO anticipates that the de watering during construction and flushing by natural groundwater flow will eliminate the need for long-term + collection of groundwater in the East Gorge. Based on our experience, collection of existing contaminated ground water from the East Gorge will likely require the operation of an interceptor trench and/or a ground water collection and treatment system for a substantial period of time. However,the solution developed to remediate the existing site must be based on the collection and analysis of data on the extent of the existing contaminated groundwater. The peer review team believes that this analysis must occur during the detailed effects assessment. 4.4.3 How the facility will be managed over the life of the project Due to the long life of the project of several hundred years,there is considerable uncertainty regarding how the facility will be operated during its lifetime and who will be responsible for its operation. During the detailed effects assessment stage,the LLRWMO needs to examine the types of human and financial resources and systems needed for long-term operation and ( maintenance, and answer questions such as the following: • How will an organization/ unit with the function to maintain the site be established (e.g., under an existing organization,its own organization,etc.)? • What training of staff is needed (first time and on a continuing basis)? • What will be done to ensure continuity/ reduce turnover of staff? What mechanisms are in place for succession planning? • How will organizational consistency be maintained? I ! ! • How will the long-term operation and maintenance of the facility be funded? iPeer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 20 Hardy Stevenson and Associates Limited September 2004 i 4.4.4 Placement of the above-ground mound within the Cameco lands When selecting a site for awaste management facility,a number of factors are typically examined,including the geology and hydrogeology of the site,the site's potential for environmental effects on air,water and biota,and social considerations such as the proximity to residents and businesses. Following discussions between the LLRWMO and the peer review team,the former agreed to modify the QC report to include a discussion of the site selection rationale. As a result,the QC report now provides a reasonable rationale for selecting the northern I portion of the site for the location of the WMF. During the detailed effects assessment,the peer review team will be seeking more information on geological and hydrogeological conditions underlying the location chosen for the WMF. 4.4.5 The suitability of a single liner for the above ground mound In the Qualified Concept Report,a single low permeability composite base liner is proposed ll as the preferred method of containing the excavated wastes for Concept II. The liner acts as a barrier between the wastes and the soil underneath the above-ground mound. I The peer review team believes that a double liner system should be examined further during the detailed effects assessment. The double liner system has the potential advantage with l respect to better leakage collection, monitoring,and detection. Using a double base liner also provides some redundancy (i.e.,if one of the liners fails,there is a second liner to contain the wastes) and greater reliability for the long term. Greater attention to the liner systems during the detailed effects assessment is appropriate because of the long life expected of the facility. I 4.4.6 Selecting routes for transporting construction materials The transportation of construction materials is an important consideration for the project 1I in terms of conventional hazards (e.g.,accidents) and their potential for effects on workers and the public.The QC report describes possible transportation routes for moving construction material to and from the NVNIF and provides an evaluation of the routes. 1I i During the initial review, the peer review team found that the final draft QC report did not adequately show how the routes were identified or how the routes were screened. The ` I I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 21 Hardy Stevenson and Associates Limited September 2004 I team made a number of suggestions on the evaluation of transportation routes regarding technical, environmental, economic, community and health and safety factors,including: a) The number of people living along haul routes, rather than the number of dwellings; b) How roadside property is used (i.e.,Do people along the haul route engage in farming or other activities affected by dust? How will businesses along the route be specifically impacted?); c) The distance from the road to the residence or business (as air quality impacts related to traffic decrease significantly with increased distance from the road); d) How pedestrian activity is accommodated (as this is related to potential I vehicular/pedestrian conflicts and pedestrian safety); e) Collision history,frequencies, types,and severity of collisions (this would be an indication of the likelihood of accidents and the safety,risk of the route); I i) The safety risk of level railway crossings (a safety assessment should be conducted by a qualified safety specialist for each crossing based on Transport Canada guidelines); g) Horizontal and vertical alignment(the design of the roadway affects collision potential and possible terrain restrictions); h) Cross-section characteristics,such as number of lanes and lane widths (as these affect collision potential and traffic operations/conflicts); i) Existing traffic operations deficiencies, roadway capacity and level of service (as these represent possible delays,traffic operations conflicts, etc.); j) Estimates about the number of truck trips that will be generated,in terms of daily trips, by what is carried,and truck size (the number of truck trips affects the magnitude of traffic operations and safety impacts);and, i k) Actual environmental impacts of required road improvements and haul operations. I Based on our subsequent discussion with the LLRNVTvIO,we found that they had already completed more detailed work in the identification and screening of alternative routes, specifically related to points d),g),h),i),and j) above. This work was not fully documented in the final draft QC report. The revised QC report should be revised to include the additional data and information as described above, including a more complete description j of the actual route identification and screening process conducted by the LLRNXIMO. i Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 22 Hardy Stevenson and Associates Limited September 2004 I i It is expected that a detailed evaluation will be undertaken early in the detailed effects assessment to strengthen and confirm the comparative evaluation of transportation routes. This additional evaluation will be peer reviewed when completed.The level of information will be of necessity greater than currently provided in the FC and QC Reports, and must address all of the factors described above. In addition,the EA process does not preclude the re-evaluation of other routes and route segments as the detailed effects assessment proceeds. 1 1 �I J� I I I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 23 Hardy Stevenson and Associates Limited September 2004 I i F77ponse to Residents' Concerns During the preparation of the Feasible Concepts and Qualified Concept reports, the LLRWMO met with residents of Port Granby and other areas of the Municipality of Clarington. Subsequently, a series of roundtables was convened by the LLRMWO to hear residents' concerns about the reports. The minutes of the roundtables are attached in Appendix E. The peer review team attended these meetings and heard the comments expressed by residents about the reports. Municipal Council and staff also recorded and shared additional concerns from residents throughout the EA process to date. While some concerns are i general in nature and apply to the EA process, others are specific concerns that directly bear on the selection of the Qualified Concept.The Peer Review Team has reviewed these concerns. The key concerns are addressed below. I I 5.1 General Concerns 5.1.1 Whether the 1978 FEARO Panel decision precludes the establishment of a waste management site on the north side of Lakeshore Rd. I In the 1970s, Eldorado Resources Limited (ERL) proposed to develop a refinery on lands immediately north of the existing Port Granby waste facility. Only the refinery wastes would be stored on a temporary basis in buried trenches on the same lands. The project was examined by a review panel established by the Federal Environmental Assessment and Review Office. The Panel recommended that the proposed refinery, or the proposed waste storage site on its own, not proceed at the Port Granby location. NRCan, as the lead Responsible Authority for the current EA,has provided a legal opinion as to whether the outcome of the 1978 Panel Review would preclude the current EA from examining the lands to the north of Lakeshore Road. In a letter dated November 22,2003, NRCan noted that the storage site proposed by ERL consisted of burial trenches for the i temporary storage (30 to 50 years) of refinery waste and relocated Port Granby waste. It was intended that this waste would then be relocated to a long-term facility. The Port Granby Project is intended to provide long-term management of historic wastes currently located at the Port Granby Waste Management Facility. NRCan concluded that the previous decision iwould have no bearing on the LLRWMO's examination of Concept II. A copy of NRCan's letter is attached to this report as Appendix F. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 24 Hardy Stevenson and Associates Limited i September 2004 The peer review team has reviewed the findings of the 1978 Panel Report and NRCan's P � P letter,and we concur with the Government's ruling that the 1978 decision does not preclude the LLRWMO from including the site across Lakeshore Road in the current EA process. In addition to the reasons cited by NRCan,we note that engineering techniques for the storage of low-level radioactive waste are considerably more advanced now as compared to 1978.As well, the threat of the surrounding area being industrialized as a result of the current proposal for a waste management facility is minimal. 5.1.2 The Qualified Concept is not an "alternative means" of carrying out the Project, but is an "alternative to"the Project The EA Scope for the Port Granby Project,as issued by NRCan, states that alternative means of carrying out the project will be investigated,while alternatives to the Project will not be considered. The Scope defines alternative means as being"the various ways,that are technically and economically feasible,that the project could be implemented which are local, j are for the management of the wastes over the long-term and are functionally similar to the project". Alternative means are defined as "alternatives that are not in the local area, that are not for the management of the wastes over the long-term and that are functionally different. A functionally different technology to above ground storage technology/on-site stabilization is considered to be an alternative to the project." The peer review team agrees with the LLRWMO that the Qualified Concept meets the definition and criteria for an"alternative means" and is consistent with the Scope Document. Concept II is located locally (i.e.,within the Municipality of Clarington),is technically and economically feasible as Section 4 of this report demonstrates, and is for management of the wastes over the long-term. Concept II is also functionally similar to the community-based proposal in that it involves the construction of an above-ground storage mound, and is intended to isolate the wastes from ground and surface water and prevent the leachate from entering Lake Ontario. Like the project in the project description, Concept II has been designed so that the waste is retrievable and that the engineered system can be monitored and repaired if necessary. "Alternatives to" the Project that are not functionally similar would instead involve solutions such as deep geological disposal or shipping the waste to a location outside the Municipalities,which have been removed from consideration in the EA process. I I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 25 Hardy Stevenson and Associates Limited September 2004 I i 5.1.3 The comprehensiveness of a screening level EA The regulations of the Canadian Environmental Assessment Act specify the type of review that a project must undergo. These include a"screening" level review,a"comprehensive" study,mediation,and a Panel review. The study requirements for each level of review are set out in the Act. Consistent with these regulations,it was determined by the RAs that the Port Granby Project would be subject to a"screening" level review. i According to the Canadian Environmental Assessment Agency (1995),a"screening" level EA must address: • the environmental effects of the project including cumulative effects,and the effects of possible accidents or malfunctions; • the significance of the environmental effects; I • technically and economically feasible measures that would reduce or eliminate any significant adverse environmental effects of the project; I • any other matter relevant to the screening that the Responsible Authority may feel is necessary for an accurate assessment of the environmental effects; I • public comments,if any. The Scope Document notes that"changes in the assessment process may be required that move the EA from a screening to a comprehensive study" (NRCan,2002: 2). Because of the potential for changes, the scope of the EA studies being conducted by the LLRWMO for the Port Granby Project are designed to meet the requirements of a Comprehensive Study. A"comprehensive" study builds on the factors considered in the screening assessment and examines in addition: • the purpose of the project; i • alternative means of carrying out the project that are technically and economically feasible as well as the environmental effect of any alternative means; i • the capacity of renewable resources that are likely to be significantly affected by the project; • public comments; 1 Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 26 Hardy Stevenson and Associates Limited September 2004 i • the need for,and the requirements of,any follow-up program. Based on our review of the FC and QC reports,it is clear that 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. 5.1.4 Guarantees from the federal government that additional waste will not be stored at the new waste management facility The Legal Agreement is categorical in defining the source of materials to be accommodated at the facility and any new initiatives to bring additional waste to the facility would require Municipal consent.The current proposal for the Qualified Concept is contingent on the waste materials defined in the Agreement and would not be able to accommodate new waste in its current configuration.As such,the peer review team agrees with local residents that the facility should be closed out once the materials defined in the Legal Agreement have been safely stored. We recommend that Clarington Council seek a guarantee from the Government of Canada that no additional waste from other areas would be stored on the lands that the government will be acquiring from Cameco. 1 5.1.5 Whether the community's image will suffer if a new waste management facility is i built The community of Port Granby has been living next to a waste management facility for J almost 50 years. Nearly 500,000 m3 of LLRW and MCS is currently located at this facility. Although the waste facility is currently being well-managed by Cameco and is secure for the short term, the location of the facility on a dynamic eroding shoreline and its inability to I effectively contain leachate is clearly unacceptable. In this regard,the existing facility poses an image problem for the community. The peer review team believes that Concept II,if properly implemented,will improve the community's image as compared to both the existing situation and the situation that would be created by the implementation of either Concepts IA or IB. Concept II will provide a resolution to the current management problem by providing effective long-term containment of the waste and by alleviating any long-term impacts on Lake Ontario. Since Concept II will not involve the construction of any shoreline stabilization measures, (unlike the on-site concepts) public access to the shoreline will be possible. It should also be I possible to effectively mitigate any visual impact of the new engineered mound north of Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 27 Hardy Stevenson and Associates Limited September 2004 1 Lakeshore Road through such measures as landscaping. Finally,with proper end-use decisions, the existing and new waste sites, including other lands to be acquired by the federal government,could be landscaped or structured to provide the end-use attributes desired by the community. 5.1.6 Whether on-site management option should be subject to the detailed effects j assessment As explained in Section 4 of this report,the peer review team agrees with the LLRWMO that neither Concepts IA nor IB should be carried through to the detailed effects assessment stage. I 5.1.7 The effects of the new waste management facility on the Port Granby community i The peer review team acknowledges residents' concerns about the potential effects of the construction and operation of the waste management facility on property values, enjoyment of property,and agricultural production. The Property Value Protection program has been established to address some of these impacts. We will be carefully reviewing the assessment of socio-economic impacts during the detailed effects assessment 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. I 5.2 Specific Concerns with Management Concepts 5.2.1 Little experience with engineered mounds for storing radioactive and chemical wastes Residents have expressed the concern that there is little experience with systems for storing radioactive and chemical wastes, and therefore there are considerable uncertainties associated with storing the waste in an above-ground mound. The LLRWMO has adequately cited a Inumber of precedents, both built and under construction, for this type of engineered mound for the long-term storage for similar radioactive wastes, including Fort 1\,1cMurray in Alberta and Weldon Springs in Missouri. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 28 Hardy Stevenson and Associates Limited September 2004 While the experience with these engineered mounds for radioactive waste is recent (i.e., within the past 25 years),no other technology or engineered solution has been in place any longer,given that radioactive waste has been managed for about that length of time.The technologies have been advancing over years,particularly with respect to polyethylene liners for the engineered mounds which are now expected to last several hundred years. The peer review team is confident that the Qualified Concept,with its redundant design features and appropriate long-term operation and maintenance programs,will provide for safe storage of ff the waste for several hundred years and possibly longer. I i 5.2.2 Build a deep open trench rather than groundwater cutoff wall Some residents felt that the deep groundwater cut-off wall associated with Concepts IA and IB is not a practical proposition, and should be replaced by a deep open trench concept. During the Alternative Means evaluation,the LLRWMO examined a number of options for controlling/ diverting groundwater,and determined that the cutoff wall was the most promising approach. While the peer review team is not confident that the cutoff wall will work as planned, as demonstrated by the Intera study,there is little evidence to support the view that a deep open trench will perform as designed. As well, the trench would generate an enormous volume of excess fill and would create an obvious visual intrusion into the community. I 5.2.3 Whether excavating the waste poses unacceptable risks to human health and the environment Residents shared a common concern that thorium-230 is a serious health risk and should not be excavated if at all possible. The peer review team agrees with the LLRWMO that the presence of thorium-230 in the waste does not preclude the waste handling necessary to construct the new waste management facility,as demonstrated by the analysis undertaken through the current EA process and past experience in other locations. We have recommended,however,that the enclosed excavation option should be considered to reduce 1. any effects on the workers and the public to ALARA,unless the LLRWMO can clearly demonstrate that these are not needed for reducing radiological risks to ALARA. i I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 29 Hardy Stevenson and Associates Limited September 2004 ,I r 5.2.4 Examine whether transportation of construction materials would be preferable by rail than by truck During the roundtables with the Southeast Clarington Ratepayers Association, the residents expressed their interest in examining rail as an alternative to trucking construction materials to the site. The LLRWMO subsequently revisited transportation of materials by rail in more detail and confirmed that truck transport is preferred. This additional work will be 1 documented in the final revision of the Feasible Concepts Report. The peer review team fagrees with this decision. I 1 I I I l 1 f I 1 Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports 30 Hardy Stevenson and Associates Limited September 2004 d Appendix A — Peer Review Methodology When reviewing Environmental Assessment Reports,HSAL uses a methodology defined by a series of questions. This professional methodology was adapted and applied to the review of the Feasible Concepts and Qualified Concept Reports.Answering these questions often involved detailed review of available supporting data and background reports. The key questions are: ( Purpose • Is the purpose of the EA work clearly stated and all issues and + impacts encompassed through the stated purpose? Methodology • Is the methodology sound enough to permit our objective review of the issues, data and facts? Are certainties and uncertainties of the EA studies openly and objectively stated? Are there Federal, Provincial and local standards,regulations and guidelines that have been overlooked? Data . Are relevant data and facts clearly and consistently used in the reports/ study? Are there data gaps? Can we trust the data? Issues • Have significant issues been overlooked during the EA process? Are there gaps arising from our examination of the issues? Are I gaps addressed to the point where the EA can move forward? Has the public identified additional issues or questions? Conclusions • Do the conclusions lead from the data? Are the conclusions supported by the research undertaken? If the peer review team examined the data would we reach the same conclusions? Are there areas where the Peer Review Team and LLRWMO consultants completely disagree? • What are our conclusions as a peer review team? What is our recommendation to the Municipality of Clarington? Following the review of the LLRNVMO's reports,the peer review team prepared detailed comments using the methodology described above. Once the team completed its comments,the Municipality submitted the comments to the LLRWl\,10. The peer review 1 Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports A-1 Hardy Stevenson and Associates Limited September 2004 i I team reviewed the comments jointly with LLRWMO consultants and staff and had the opportunity to discuss the comments and agree or disagree with the outcome of the joint review process. The completed disposition forms are included in Appendix C for the Feasible Concepts Report and Appendix D for the Qualified Concept Report. During the review,the peer review team: I, • Reviewed additional LLRWMO documentation related to the Port Hope Project EA. • Overall, sufficient data was made available to the peer review team to conduct their review; I • The peer review team has received documentation for most disciplines,and has requested more detailed data related to the comparison of transport routes; • Several LLRWMO environmental baseline characterization reports were in I the process of being completed during the peer review; i • Some data related to current conditions of the socio-economic and transportation environment in Port Hope is outstanding;and, • The peer review team will revisit the extent to which the analysis would change when the data is received during the upcoming detailed effects assessment. • Commented on the workplan of some LLRWMO studies before the studies were initiated; • Attended meetings of the Regulatory and Federal Authorities, offered opinions,and provided comments on various issues; • Attended all public meetings to understand local concerns,values and to listen to what I makes up the quality of life for Clarington residents; • Discussed issues raised by SECRA (South East Clarington Ratepayers Association) members,members of the former CAC (Community Advisory Committee) for the Municipality of Clarington,and members of the public;and, • Presented a summary of the team's comments at a public meeting and received additional comments from the public. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports A-2 Hardy Stevenson and Associates Limited September 2004 I Appendix B — Description of the Peer Review Team We have assembled a team of experts with the knowledge and experience to carry out the tasks associated with this project. The following team members are supporting the peer review of the Port Granby Project. David R Hardy, M.E.S.,M.C,I.P., R.P.P Dave is a Project Director and Principal of HSAL. He is a Social Scientist and i Environmental Planner with twenty-five years of nuclear waste management experience specific to public consultation and facilitation,socio-economic impact assessment and land use analysis. He is an expert on the socio-economic impacts and public consultation approaches for low and high level nuclear waste. Mohan Rao,Ph.D P.Eng J Mohan is Vice President of HSAL. Mohan is a nuclear physicist and engineer who has led teams of professionals for nuclear waste management for the majority of his career. Mohan I is an expert in Low Level Radioactive Waste (LLRW) management, spent field management,nuclear decommissioning with over forty years experience in nuclear generation,radioactivity and waste management. As a former Senior Advisor in the Nuclear Waste Management Division for Ontario Power Generation,he is intimately familiar with nuclear waste system planning,radioactivity management, Federal LLRW studies and the Low Level Radioactive Waste Siting Task Force studies. Dr. Murray Finkelstein Ph.D,MDCM j Murray is a physician and epidemiologist with twenty-five years experience in the design 1 analysis and reporting of epidemiologic studies of health effects of occupational environmental exposures. For twelve years,Murray was Ontario's representative on Atomic Energy Board of Canada's Medical Advisor's committee, and spent fifteen years as a member of Ontario Nuclear Emergency Technical Advisory Committee. Murray has lectured for the past four years at the universities of McMaster and Toronto on the health effects of ionizing and non-ionizing radiation.He has an active practice in family medicine. I Tyrone Gan, P.Eng Tyrone is the President and founder of iTrans, one of Canada's leading transportation planning practices. He was former vice-president of the transportation engineering practice for a major consulting firm. He has also held senior positions in government focusing on transportation and public transit planning. Tyrone has over twenty-five years experience in 1 Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports B-1 Hardy Stevenson and Associates Limited iSeptember 2004 i all aspects of transportation planning and transportation engineering,for the public sector and private sector across Canada and internationally. I Paul Bowen, P.Eng Paul is a Principal of Terraprobe Limited and an expert in geotechnical engineering, 1 hydrogeology, technical policy development,waste management and treatment, peer review and expert consultations and environmental site assessments. He has completed numerous landfill site assessments including an inventory of 120 abandoned landfill sites in Ontario that involved a detailed review of local and regional hydrogeologic conditions and detailed site inspections. Milo Sturm, P.Eng Milo is President of Shoreplan Engineering and has twenty two years experience in coastal engineering. He has managed a number of multidisciplinary waterfront studies and shoreline management plans. He as participated in a number of studies in close proximity to the study area. . ! Phil Niblett, M.Sc. Phil is the Founder and President of Niblett Environmental Associates (NEA) and has twenty-seven years experience as an aquatic biologist. His major area of expertise lies in the I evaluation of the effects of organic and inorganic compounds on aquatic resources. Since founding NEA he has completed or directed over 450 projects,including assessing the impact of urban and recreational developments ranging in size from a few hectares to 2400 hectares. Tony van der Vooren,Ph.D.,P.Eng., QEP Tony is the senior manager at AMEC and is responsible for all aspects of air resources and risk assessment. He has been involved in environmental issues for over twenty years in all industrial sectors. His expertise includes industrial air pollution control,permitting, regulatory review,risk assessment, environmental assessment and impact modeling. He has served as an expert witness on numerous occasions. Charlotte Young,Ph.D Charlotte brings to this assignment 20 years experience in policy and organizational development in the nuclear energy,natural resources and environmental field. She has an international reputation as a social impact specialist and a public consultation practitioner, researcher and facilitator. In addition, Charlotte has analyzed socio-economic conditions for environmental assessment and related programs. Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports B-2 Hardy Stevenson and Associates Limited September 2004 Marc Rose,M.E.S Marc Rose is an environmental planner and a trained mediator who has considerable experience managing projects. He is currently managing a group of technical experts who are providing the City of Toronto with strategic support for the Richmond Hill Oak Ridges Moraine Ontario Municipal Board hearing. For Ontario Power Generation, Marc managed a team of experts and helped to develop concepts of public participation that are appropriate for the long-term management of nuclear fuel waste. I 1 i i 1 I I I i Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports B-3 Hardy Stevenson and Associates Limited September 2004 Appendix C Comment / Disposition Form for the Port Granby Project Feasible Concepts Report J I It C I �I 1 I Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports Hardy Stevenson and Associates Limited September 2004 . PORT HOPE AREA , + INITYATTVE LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 3 of 7 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report—Volume 1 LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: ` January 2004 Low-Level Radioactive Waste Management Office Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Orga nization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi / P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Page No.& Type* G,T, Reviewer Comments Author's Disposition Status*" A, I, N Para No. E 5. Section T Packaging of LLRW and East Gorge waste in steel or PVC Packaging of wastes is not anticipated at this time, but it is 1 3.2.1.9, page drums may be a useful option for handling this waste. This acknowledged that if the need for it is identified during later stages it 3-11, para 1 could help in radiological control and in minimizing health and will be investigated. See also the dispositions for Comment#3. safety risks associated with waste removal,transportation and re-storing in the above ground mound. g. Section 3.2.1- T Instead of completely eliminating the pre-treatment of waste, The Corunna facility is not permitted to accept radiological N 9, Page 3-11 the LLRWMO should allow for some judgment as to whether contamination. In any event, it would not be a local solution contrary Para 4 some wastes could easily separated in-situ and transported to to one of the purposes of the project. the Coruna, Ontario landfill. Golder to review. 7. Section T That there is insufficient capacity for 100,000 m of East Golder to provide additional explanation. I 3.2.1.10, page Gorge waste at the Central plateau area does not seem 3-11, para 5 credible, given that East Gorge waste constitutes only 25%of the total waste. Furthermore,the waste could be accommodated(even if the space is inadequate)by increasing the mound height). There is some merit in re- configuring the waste at the existing site if possible instead of qoinq for a new site. Please check to confirm. g. Section T Why was only one option chosen for the storage facility for the See response to Comment#3 and#4. N 3.2.1.11, page East Gorge waste?Should this option not meet the 3-11, para 7 requirements based on detailed analysis for whatever reason (i.e., inability of the base liner to last 500 years),the project will be left with no option for the storage of this waste. Shallow burial trenches and structural vaults are widely used in the industry for LLRW and we feel that they should not be discounted until the above ground mound option has been fully assessed for feasibility for LLRW/East Gorge waste. There are also other design variations of above-ground mounds that have been used elsewhere such as storing of drummed waste on concrete surface and mounding the waste with engineered earth covers.Therefore, we suggest carrying forward more than one option. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGFCVoll PRTCommentsFINAL.doc Updated on September 10, 2004 APORE TTHOPE ARF-A LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 4 of 7 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report—Volume 1 LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: January 2004 Low-Level Radioactive Waste Management Office /fl Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24, 2004 Rick Rossi /` P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item No. Section, Page No.& Type* G,T, Reviewer Comments Author's Disposition Status** Para No. E A, I, N g. Section T Why was a double liner system not considered as an option? See response to Comment#4. N 3.2.1.12, page The double liner system seems to be the recent trend in the 3-11, last par@ industry for LLRW and hazardous wastes. The double liner system has the potential advantage with respect to better leakage collection as well as leakage monitoring and provides some redundancy and greater reliability for the long term. Greater attention to the liner systems during design will have long-term payoffs particularly with regard to the 500 year life expected of the facility. 10. Section T "Clayey"soil needs to be scientifically defined in terms its A definition will be added. I 3.2.1.12, Page ability to deliver low permeability. 3-12 Para 2 11. Section 3.2.2, T The Municipality requested in 2003 that the study area north The selected site is relatively close to the existing WMF and is not N Page 3-13 of Lakeshore Road be increased to include all lands owned by considered to be detrimentally affected by surrounding land uses. Para 4 Cameco north of Lakeshore. The LLRWMO agreed; however, Although a formal site selection exercise was(is) not considered the study area has been inexplicably reduced to what was necessary, other considerations(e.g., avoiding proximity to shown previously without any process to explain why. Other Environmentally Sensitive Areas, suitable set back from Lakeshore potential sites on the Cameco Lands across Lakeshore road Road and ease of access support the selection of the geologically (in addition to the north end of the property)should be suitable Lakeshore Road site. assessed, and if required, rejected for Concept II. No information is offered on remaining site soils for other locations, or strengths and weaknesses of alternative locations. If soils in the north part of the site are the determining criteria for Filter 2—Part 1,then Concepts 1A and 1 B would have been filtered out. 12. Section 3.2.2, T 'Enclosed excavation' has been defined as an onerous, time See response to Comment#3. A Page 3-14 consuming and expensive means. Examples of partial Table: 3.2.1-1 excavation and more cost effect enclosed excavation should Component 4 be presented. On this basis, enclosed excavation should survive as an acceptable Alternative Means. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGFCVol1 PRTCommentsFINAL.doc Updated on September 10, 2004 ,tA PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 5 of 7 oo JNXTL4aM Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report—Volume 1 LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: January 2004 Low-Level Radioactive Waste Management Office Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24, 2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item Section, Type" Page No.& G,T, Reviewer Comments Author's Disposition t atus** Status" Para No. E I, N 13. Section 3.2.2, T Further explanation is required on the rationale for selecting See response to Comment#4&#11. N Page 3-16 the northern potion of the site on the basis of the soils. As it Para 1 (and reads, the soils have low enough permeability to be selected Section as the preferred site, but the soils are too permeable to risk a 3.2.2.3) containment system of"No Base Liner and Clayey Soil Cover'. 14. Section T Same as Item 9 above. Option II provides for the possibility of See response for Comment#4. N 3.2.2.3, page segregating LLRW/East Gorge waste from the MCS.A double 3-16, para 5 liner system can be preferentially used for LLRW(if not all of the waste)if the above ground mound with single liner design is evaluated to be unacceptable. 15. Section T We are unable to replicate the cost figure of$24 million for Portable weather enclosures were considered in the evaluation. A 3.2.2.4, Page enclosed excavation. Enclosed excavation can be made less 3-16 expensive by portable weather enclosures(instead of a fully Golder to substantiate the$45/m3. Para 6 enclosed operation). Enclosed excavation could be superior to open excavation in terms of radiological control(particularly See response to Comment#3. Th-230 handling).With enclosed excavation, potential for contamination spread is not as great. There is also the public perception advantage with enclosed excavation. We suggest that enclosed excavation option should be carried further until radiological procedures for handling U-238 decay chain isotopes including thorium-230 clearly show that enclosed excavation is not needed or the potential health risks to workers from the trapping of Radon gas outweighs any benefits from enclosing the excavation. 16. Section 3.2.2.5 T It is not categorically clear that dewatering of at least some of See response to Comment#3. A page 3-17 the waste may not be needed.Also see comments in Item 4 para 2 above regarding the use of containers for handling the waste. Furthermore, in this option, there may be advantage to be gained by a screening procedure to eliminate non-impacted materials(soils specially)to reduce waste volumes to be relocated. 17. Section T No stabilization of shoreline is required. However, the site Agreed, The site will be restored so that excessive silt or other I 3.2.2.11 must be restored so that no excessive silt or other run off is runoff to the Lake is not generated. This will be clarified in the text. Page 3-19, generated by the site. This could be in violation of the para 2 Fisheries Act. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGFCVol1 PRTCommentsFINAL.doc Updated on September 10, 2004 PoRT AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 6 of 7 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report—Volume 1 LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: January 2004 Low-Level Radioactive Waste Management Office Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi r� P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item No. Section, page No.8; Type* G,T, Reviewer Comments Author's Disposition Status,* Para No. E A,I, N 18, Section T (Same as Item No. 17) See response for Comment#17. 1 3.2.2.12 Page 3-18, ara 4 19. Section T We suggest that enclosed excavation option should be carried See response for Comment#15. A 3.3.1.4, page forward as well for reasons mentioned in Item 15 above. 3-26, para 4 20. Section T It may be useful to consider double composite liners at least See response to Comment#4. N 3.3.1.5, page for LLRW/East Gorge waste from reliability and long term 3-26, last para safety considerations. See comments made earlier in Item 9. 21. Section T We suggest carrying forward a second option should the See response to Comment#8. N 3.3.2.1, above ground option fail during detailed analysis. See page 3-29, arguments in Item 8 above. ara 1 22. Section 3.3.2.2 T Double composite liners should be considered for LLRW See response to Comment#9. N page 3-28, component of the waste. See item 9. ara 2 23. Section 3.4.2, T The report cites additional studies being required to confirm It is acknowledged that the results of the"additional studies" may N Page 3-33, the acceptability of leaving the East Gorge waste in place. confirm that FC IB may not be feasible. However due to the Para 5 What studies? When will they be completed? Will the recommendation of implementing FC II in the Qualified Concept evaluation weighting and ranking be revisited when those Report(because of its overall superiority),the extra cost and effort studies are completed? This work should be completed in associated with the"additional studies" is not warranted. advance of the qualified concept selection such that there is little risk of choosing a potentially unfeasible option. It is undisputed that a groundwater diversion system would be required under FC IA and FC IB. Construction and operation of a groundwater diversion system, regardless of the details of the system is a complex undertaking for the Port Granby WMF and for a number of reasons as brought out in the evaluation, contributes to the lower scoring results. Further studies of the groundwater diversions stem are therefore not needed at this stage. 24. Section 3.4.2, G It is not correct to say that Concept 1 B is essentially the same Other than the presence of the East Gorge waste,the concepts are N Page 3-33, as Concept IA except for the presence of East Gorge waste. the same in terms of design considerations, safety response and Para 5 They are fundamentally different in design considerations, consequence of failure of covers and cut-off walls. safety response and consequences of failure of covers and cut-off walls. * Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author, I:Incorporated Comment, N:Not accepted by author Filename:PGFCVol1 PRTCommentsFINAL.doc Updated on September 10, 2004 PoRTHoPEAPPA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 7 of 7 ,{ do& INITIATIVE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report—Volume 1 LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: January 2004 Low-Level Radioactive Waste Management Office Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi /y �C P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 lNo Section, Page No.& Type* G,T, Reviewer Comments Author's Disposition Status" A,1, N Para No. E 25. Fig. 3.4-5 G The critical aspect of Concept IB is managing East Gorge An appropriate cross section will be provided. I wastes in-situ. The lack of an appropriate cross-section suggests that this aspect of Alternative II was not provided a complete analysis before the evaluation was completed. The lack of this data significantly inhibits our ability to replicate the conclusions reached. 26. Fig. 3.4-6 G Given earlier comments about soils on the Cameco lands,the The support information will be provided in the report. I absence of a cross section of soils under the proposed North site is a major weakness of the report. How different are the soils for 1A, 1 B and II? 27. Overall G Some of the scores after the evaluations were complete were See response to Comment#3. A comment very close. Nonetheless, only one alternative mean was selected for each Component of the various Feasible Concepts. The authors should consider the option of carrying forward more than one alternative mean if the scores were fa i rly close(e.g., < 10%difference). This block should be completed following discussions regarding author's disposition of reviewer's comments. *Note: Signatures are required priorto approval of this completed form Reviewer's Signature Date Author's Signature Date n:\active\2002\1300\021-1384 phai engin,support\engineenng tasK 10\qualined conceptsyune 04,comments\pggc comments_ricKlgvi-u4 fury uy.doc Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision — Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGFCVol1 PRTCommentsFINAL.doc Updated on September 10, 2004 PoRTo ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 1 of 16 Peer Review Comment/Disposition Form Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date. Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item No. Section, Page No.& Type* G,T, Reviewer Comments Authors Disposition Status** A,I, N Para No. E 1. Appendix B, T During the review of the Alternative Means methodology,the It was assumed that for the life of the project(500 years)there would be N Section B.2.2, Municipality of Clarington commented that indicator F2-T3 should no loss of institutional control. Page B-9, address'minimal maintenance'so as to assure the Municipality Table B.2.2-1 that there will be a minimal need for long term institutional control. All appropriate Alternative Means will be properly constructed to Row 2 While the Indicator: 'compatible with minimizing the release of minimize the release of contaminants over the lifetime of the facility. contaminants from the facility"is acceptable,the issue of institutional control from a human resources,funding, and corporate memory perspective has not been addressed. 2. Appendix B, T We are unable to trace the rationale for re-weighting all of the All numbers were weighted equally as they were added together before N Section B.2.3.4, economic indicators at 33%vs 41%, 28%and 31%as indicated they were assigned a score of 1 to 5. The weightings were changed Page B-14 by the Workshop. The workshop clearly indicated that Capital because it assumed that all appropriate Alternative Means would be Table B. 2.3.4-1 Cost should receive a higher weighting. We agree with the properly constructed in a fiscally responsible manner. conclusion (para. 3)that people interpreted capital cost to mean Structural vaults were eliminated because they did not pass the the best possible facility. Yet,the altemative means of structural question, Is it economically feasible? For Filter 2—Part 1, economically vaults(a better facility)are eliminated on the basis of capital cost. feasible was defined as"does it cost less than %of what the And, base liner systems requiring significant future replacement government is likely to spend on the entire project($23M)". Structural costs for major repairs are carried forward on the basis of their vaults were expected to costs>$20M. economics. This consequence appears to be the opposite of There is no planned replacement of the base liner during the lifetime of what the community indicated in the Workshop. the facility. The other Alternative Means which involved"no base liner" were considered in this indicator but were eliminated because they were not technically feasible. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author Filename:PGFCVo12PRTCommentsFI NA L.doc Updated on September 10, 2004 PoRT Hon APYA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 2 of 16 ►u!0 INrrmnw Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Type* Status** No. Page No.& G,T, Reviewer Comments Author's Disposition A,I, N Para No. E 3. Appendix B p. T Technical Indicator DCE-T2 measures the number of years a A single composite liner(i.e.,geomembrane/compacted clay I 29 particular alternative means will operate without a significant composite)would have the same service life(i.e.,operational life)as a deterioration in its performance. We are unable to find evaluative double composite liner, provided that the geomembrane component is data comparing the length of time of operation of a single vs.a chemically compatible with the LLRW leachate. For the Port Granby double base liner system. We are also unable to find any data Project,the LLRW leachate is considered to be compatible with the on the length of operation of the clay cap for East Gorge in-situ geomembrane as the leachate does not contain significant stabilization for Alternative 1 B. concentrations of compounds such as chlorinated organic solvents which can prematurely breakdown the molecular structure of the geomembrane. In this case,the service life of the composite liner would be controlled by the gradual chemical oxidation of the HDPE polymer comprising the geomembrane. Both the geomembrane in the primary and secondary composite liners would deteriorate simultaneously and at similar rates underthis mechanism, resulting in similar service lives for a single verses double composite liner. Based on service life projections published by the US EPA(2002),it is expected that the service life of single composite and a double composite liner would be on the order of hundreds of years. Although not expected for the Port Granby Project,for cases where leachate has the potential to prematurely deteriorate the geomembrane, the double composite liner could provide a longer time frame of leachate containment. This relates to the lag time for full strength leachate to reach the secondary liner(i.e.,the leachate must first deteriorate the primary geombembrane and then migrate through the primary compacted clay liner before it reaches the secondary geomembrane liner). The lag time is dependent on the rate of reaction of the leachate with the primary geomembrane and the rate of migration through the primary compacted clay liner. We are not aware of any scientific data in the literature that actually quantifies this lag time and corresponding difference in service life of a single composite versus double composite liner under this type of scenario. The service life of a clay cap for the East Gorge waste under Concept I (in-situ stabilization of East Gorge Waste)is expected to be relatively short(i.e.years to tens of years)due to cracking under differential settlement and freeze/thaw cycles. This is a major disadvantage of a clay cap compared to a geomembrane cap which is much more flexible/ductile than compacted clay and resistant to freeze/thaw. Text will be added to the report to make this more clear. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision — Disposition Status Code-A:Accepted by Author, I: Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 JL = PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 3 of 16 IMTM VE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: I Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: AF Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Page No.& Type* G,T, Reviewer Comments Author's Disposition Status** A,I, N No. Para No. E 4. Appendix B p. T Technical Indicator DCE-C2 defines non-affected lands as'not Comment noted. The definition of non-affected lands will be reworded 1 30 part of the present waste site" The CNSC licensed site is not as'those lands not part of the currently CNSC licensed site(existing referenced;instead the Ontario Environmental Assessment Act is WM F)'.The scores are not affected. cited. Under the Ontario Environmental Assessment Act,the site would be all of Cameco's Port Granby contiguous land holdings and thus,would be the same for Alternative IA, IB and 11. A better definition is required. 5. Appendix B p. T Technical Indicator DCE-F3 states that contingency costs involve 1)Replacement of the liner is not considered necessary and would not N 31 a high degree of uncertainty. The Indicator needs to be further be practical as it would require removal of all of the waste. defined to also state that there are areas where there is also a high degree of certainty: 1)the base liner will have to be replaced 2)Preliminary costs for a single composite base liner is provided in the once or twice over the 500 year period. We have difficulty seeing Fact Sheets for the component"Containment System for Relocated where data is available on the cost of liner replacement or cap Wastes". The cost for a double liner system would be approximately replacement is available.2)Similarly,we are unable to find data twice that of the single composite liner. We were unable to obtain any on the full cost comparison of the single liner vs. double liner vs. information on costs for an earth-mounded concrete vault type structural vault. 3)We can also safely assume that placing a clay containment system. We expect however that the cost to construct the cap over the East Gorge Wastes(Concept IB)on a slope will structural vault system for 500,000 m3 of waste would exceed$20M require cap replacement on a fairly regular basis. The costs of cap replacement have not been addressed. 3)A clay cap is not being considered for the East Gorge Wastes under Concept IB. The proposed cap involves a geomembrane liner,granular layers, general soil fill and topsoil. Costs for the cap construction and maintenance are provided in the Qualified Concept Report. Note that the finished slope for East Gorge under Concept IB would be at 4(H):1(V)or flatter,which will ensure overall stability of the low permeability cover system. g G As a general comment,we would recommend that the weighting As the common components in FC IA and FC IB are the same,there is N and ranking clearly distinguish between Concepts IA and IB. no need to repeat the same information. Each Fact Sheet should have two separate sections individually focusing on IA and IB. 7_ Appendix C 1.1.i T The discussion of"Issues"pertaining to the toe berm has not The toe berm would be keyed into the lacustrine clay unit to minimize A addressed the potential for undercutting, and potentially high the potential for undercutting. A preliminary estimate of the required maintenance costs have not been calculated in the fact sheet. depth of the key was identified in the Baird report but would need to be No information has been provided on the expected lifetime confirmed at the detailed design stage of the project This is noted duration of the toe berm. under the discussion of"Data Needs"on the Fact Sheet. It is acknowledged that the lifespan of the toe berm is uncertain but it can be stated with certainty that it would have to be replaced at least once during the life of the facility. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N: Not accepted by author Filename:PG FCVo12PRTCommentsF INA L.doc Updated on September 10, 2004 NMAT EE AREA Document Title: Port Granby Feasible Concepts Report Volume 2:Ap Issued by(author): Golder Associates Reviewed by: Dave Han P.Eno.. Paul Bowen, P.E Item No. 8. 9. 10. 11. Section, Page No.& Para No. )Dendix C 1.1 Appendix C 1.1.ii Appendix C 1.2.i. Appendix C I.2. iii a., Milo S Type* G,T, E LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Project Environmental Assessment PHAI Report No. pen dices LLRWM O-03710-ENA-13002 Ltd. Date: Issued to: January 2004 Low-Level Radioactive Waste Johan Rao, Organization: Hardy Stevenson and Associates Limited P.En q. Reviewer Comments T The unit costs used on page 3 of 3 for armour stone and rip rap do not reflect current market prices. Current prices may be as much as double those shown. T I (Same as Item 8 T There needs to be a discussion on how the rockfill slope would function to address bluff stabilization of East Gorge wastes for Concept 1 B, and how it would need to interact with the clay cap covering the East Gorge Wastes. T There needs to be a discussion of how the vegetated soil slope would interact with the clay cap for the East Gorge wastes for IB The subject clay cap must extend to the Lake to achieve the required grades. Would the vegetated slope vs. other bluff stabilization methods be more or less subject to the freeze thaw cycle? 12. Appendix C T 1.2.iv 13. Appendix C 1.3.i T There needs to be further analysis/discussion of how the'natural slope'alternative means would work with the in-situ management of wastes in the East Gorge for Concept 1 B. How would a clay cap function with a natural slope? Concept I will, in part, require in-situ management of East Gorge wastes on a slope and hilly topography. Regarding the low permeability cover for Concept IB,we are unable to come to the same conclusion that"...for the Port Granby site,little surface preparation would be required to construct the final cover over the wastes." With little surface preparation, how can we be assured that the cover will function as planned for the duration of the project? Rev/Draft No. Od4 gement Office Date: March 24, Author's Disposition It is acknowledged that the costs for the armour stone were validated as acceptable in 2002 and that these costs may have risen since then. However,this would strengthen the recommendation of proceeding with FC Il.As these costs do not affect FC 11, no additional investigations or revisions are necessary at this time. See response to Comment#8. The rock fill bluff stabilization would extend to the west wall of the East Gorge to protect the East Gorge wastes(e.g.see Figure B.5-1 of the Qualified Concept Report). Specifics on the connectonlnteraction between the rock-fill and low permeability cover system are beyond the scope of the Feasible Concepts Report and are not included. By filling in the lower part of the East Gorge to Elev. 87 m as part of the toe berm construction,the low permeability cover system would not have to extend to the Lake(refer to Drawing B.5-1 of Qualified Concept Report). The slope of the final cover in the East Gorge would be 4(H):1(V)or less which is stable. Specifics on the connectionMteraction between the rock fill and the low permeability cover system are beyond the scope of the Feasible Concepts Report. The vegetated slope would be more sensitive to freeze,thaw and surficial sloughing. To account for this,the vegetated slope would be flatter at 3.5(H):1(V)versus,for example,the rock-fill slope which would be at 2(H):1(W .The natural(existing)slope alternative would not work with the in-situ management options for the reasons noted under"Issues"on the Fact Sheet. This alternative did not pass Filter 2—Part 1. It is acknowledged that the results of this additional work may further discount this option. However due to its present disqualification,the associated extra cost and effort is not warranted.Also see response to Comment#11. * Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N:Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 Status'" A, I, N A A N N N N Page 4 of 16 Date: January 2004 Contract Supervisor: Rick Rossi r� September 14,2004 Author's Disposition It is acknowledged that the costs for the armour stone were validated as acceptable in 2002 and that these costs may have risen since then. However,this would strengthen the recommendation of proceeding with FC Il.As these costs do not affect FC 11, no additional investigations or revisions are necessary at this time. See response to Comment#8. The rock fill bluff stabilization would extend to the west wall of the East Gorge to protect the East Gorge wastes(e.g.see Figure B.5-1 of the Qualified Concept Report). Specifics on the connectonlnteraction between the rock-fill and low permeability cover system are beyond the scope of the Feasible Concepts Report and are not included. By filling in the lower part of the East Gorge to Elev. 87 m as part of the toe berm construction,the low permeability cover system would not have to extend to the Lake(refer to Drawing B.5-1 of Qualified Concept Report). The slope of the final cover in the East Gorge would be 4(H):1(V)or less which is stable. Specifics on the connectionMteraction between the rock fill and the low permeability cover system are beyond the scope of the Feasible Concepts Report. The vegetated slope would be more sensitive to freeze,thaw and surficial sloughing. To account for this,the vegetated slope would be flatter at 3.5(H):1(V)versus,for example,the rock-fill slope which would be at 2(H):1(W .The natural(existing)slope alternative would not work with the in-situ management options for the reasons noted under"Issues"on the Fact Sheet. This alternative did not pass Filter 2—Part 1. It is acknowledged that the results of this additional work may further discount this option. However due to its present disqualification,the associated extra cost and effort is not warranted.Also see response to Comment#11. * Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N:Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 Status'" A, I, N A A N N N N POi�RTT�HOP AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 5 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item No. Section, Page No.& Type* G,T, Reviewer Comments Author's Disposition Status" Para No. E A,I, N 14. Appendix C 1.3.i T Regarding the list of sample landfill sites, and the use of geo Use of geomembranes and geosynthetic clay liners for final cover at N synthetic clay(GCL)liners,there needs to be data on: 1)what is landfill sites dates back to about 20 years at most. We are not aware of the age of each site; 2)to what extent has each site maintained any failures of these components at the listed sites. integrity; 3)what is the operating cost for repairing the liner? Typical costs for liner installation are provided in the Fact Sheet. Costs How would GCL work on areas of significant slope encountered for repair are dependent on the area requiring repair and can be in Concept IB? approximated based on the installation costs provided. Refer to response to Comment#11 regarding the cover slope in the East Gorge. 15. Appendix C T While East Gorge wastes are mentioned,there needs to be a We doubt that in-situ vitrification can occur on the East Gorge slopes N 1.3.iii discussion of whether in-situ vitrification can occur on slopes under Alternative IB.The concern regarding geotechnical stability of the pertaining to Altemabve 1 B. East Gorge slopes during the vitrification operation is stated under "Issues"on the Fact Sheet. No further discussion is warranted here. 16. Appendix C T We are unable to find information on whether in-situ soil mixing We doubt that in-situ mixing can be carried out on the East Gorge I 1.3.v would be feasible for In-situ management of East Gorge wastes slopes under Alternative IB. The disturbance/bulking of the waste consistent with 1 B. How was this considered? associated with the mixing would likely result in slope failure, particularly along the west slope of the East Gorge. This comment will be added to the Fact Sheet for in-situ mixing. 17. Appendix C 1.5 T Technical data should be provided as to why the In-situ We do not know for sure whether an in-situ Permeable Reactive Barrier N iv Permeable Reactive Barrier might not be able to treat anticipated can treat the short term contaminant fluxes exiting via the East Gorge, contaminant loads in the short term. What scale of loads is nevertheless,this is a valid issue particularly for Concept I I where expected in the short-term? Are there labor field examples groundwater fluxes through the East Gorge could be on the order of demonstrating the barrier's limitations in treating high-volume 10,000 m3/year. We are not aware of any specific lab or field examples loads? directly applicable to the hydrogeological conditions and groundwater quality at Port Granby. 18. Appendix C T The Port Granby LLRW is different than uranium tailings and The results of the Beak report on Thorium-230 indicate that the waste N 1.7.i sludges.These consist of a wide range of LLRW from radium and can be handled safely using standard hazardous waste remediation uranium processing circuits. Thorium-230,which exists in practices.At this stage of the design,this is sufficient.The overall particularly high levels in the East Gorge waste, may require purpose of the alternative means process is to narrow down the specialized radiological control procedures(air filtration, description of the project to provide a basis for the detailed effects respirators etc)that are best provided using enclosed excavation. assessment. Descriptions of the various altemative means must be These same procedures are more difficult to incorporate with an developed so that the comparison can identify which are preferred.As open excavation procedure.Thus enclosed excavation should be described in the methodology,these descriptions are done at several carried forward as part of the Feasible Concepts. If only open stages in increasing level of detail. It is understood that during the excavation is carried forward, how do you propose to protect the detailed effects assessment as well as the Licensing phase it may be excavating area from dust, rain and control spread of Thorium- determined that the design of some features of the project may need to 230 to the environment? be revised. Consideration of alternatives at various stages is common to any engineering project * Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author,I:Incorporated Comment, N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 PORTHOPEAREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 6 of 16 /AW+ IAIITIA'IM Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: � + Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item No. Section, page No.& Type* G T, Reviewer Comments Author's Disposition Status** Para No. E A,I, N 19. Appendix C T Excavation of LLRW if done properly with HEPA filters and See response to Comment#15 in Volume 1. A 1.7.ii monitoring should help in reducing and monitoring worker exposure,which is uncontrolled in an open excavation.This alternative requires evaluation and comparison with open excavation alternative in more detail.The costs quoted appear to be based on a single large enclosure,which is expensive. Smaller portable enclosures can be expected to reduce the cost of this option. 20. Appendix C T 'No excavation'option requires a conceptual safety analysis to Agreed. The Fact sheet will be revised to incorporate this comment. I 1.7.iii demonstrate that any long-term flushing of the contaminants from the site is acceptable. Furthermore,there could be greater design requirements on the cover system and the groundwater interception methods since this option does not have a baseliner below the East Gore waste. 21. Appendix C T Costs of ongoing repairs and O&M of East Gorge in-situ The costs in question are provided on the Fact Sheets for"Clean-up of N 1.7.iii management of the wastes,and the costs of collection and Existing Impacted Groundwater'(e.g.,see Fact Sheet 1.5.iii). These treatment of contaminated groundwater are missing. These costs costs have been included in the ranking and weighting of Alternative should be brought forward to the ranking and weighting of Means of impacted groundwater clean-up. In the Qualified Concept alternative means. Report they are included in the evaluation of the alternative concepts. 22. Appendix C 1.8.i T For truck transportation of East Gorge wastes,facilities are Regarding FC 11: A required for truck decontamination and health physics support to Waste will be deposited into the new mound directly after it is monitor radioactivity. Excavated soil should not be left deposited excavated.There will be no need for storage. on an access road without proper cover(tarps, etc)to prevent the waste from wetting due to rain and snow, and blow-over due to CNSC regulations will be confirmed during the Licensing phase. Past wind. Preferably,there should be a warehouse type facility for LLRWMO experience indicates that these regulations can be met. storing the waste if the waste is going to be held in store for days. Also check conformance to any CNSC regulations on the Containerization of wastes will remain available as an option in the transportation of radioactive materials. event it is needed to mitigate potential adverse effects that are identified during the detailed effects assessment. The problem with the wet and soft,sticky consistency of the waste may require the use of containers(drums, barrels)for transporting this waste. Directly loading this waste into the transporter may lead to severe truck contamination problems. Containers will also eliminate double handling of the waste. 23. Appendix C T Enclosed conveyors could be useful if the distance is small and Agreed, however the stated features with using trucks offer significant A 1.8.ii automation is planned particularly including features such as advantages that outweigh those for conveyors. waste sorting/screening. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author File name:PGFCVo 12P RTCommentsFI NA L.doc Updated on September 10, 2004 PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 7 of 16 ' ►UN O Imu"am Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi /{ P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. I September 14,2004 Item No. Section, Page No.& Type* G,T, Reviewer Comments Author's Disposition Status' Para No. E A, I, N 24. Appendix C 1.8 G There needs to be a more thorough discussion about the issue of The overall purpose of the Alternative Means process is to narrow down A loading,transporting and unloading the waste. None of the the description of the project to provide a basis for the detailed effects arguments for or against any of the proposed methods appears to assessment. Descriptions of the various Altemative Means must be be overly compelling. As well,the transportation of the waste developed so that the comparison can identify which are preferred.As cannot be considered in isolation of how Lakeshore Road will be described in the methodology,these descriptions are done at several crossed—ie.will a culvert/underpass be built or at surface. The stages in increasing level of detail. It is understood that during the benefits and disadvantages of various options for crossing detailed effects assessment as well as the Licensing phase it may be Lakeshore Road may warrant specific consideration. determined that the design of some features of the project may need to be revised. Consideration of altematives at various stages is common to any engineering roject. 25. Appendix C T There is no statement here regarding whether East Gorge waste We expect that dewatering of the excavated East Gorge Waste,for I 1.9.iiii (the part that is below the water table)would require dewatering example by pressure filtering,will not be required. Furthermore, due to prior to transport, their sticky/clayey consistency,the East Gorge wastes are not amenable to dewatering. The Fact Sheet will be revised to incorporate this comment. 26. Appendix C T The use of containers to load the excavated waste could be See response to Comment#G24. A 1.9.iv considered to improve safety and handling particularly Thorium- 230 wastes.Also,waste sorting/screening could potentially reduce the volumes of LLRW to be stored. 27. Appendix C T The Alternative Means of either Pre-Treatment or No Pre- See response to Comment#E24, N 1.9.iv Treatment should be modified to include AM's for Partial Pre- Treatment or Partial Separation of the wastes. If a significant volume of segregated waste was found during excavation, it would be prudent to keep it separated in the landfill cells. 28. Appendix C T How has it been determined that there is not enough space at A conceptual design for a mound containing 100,000 m of East Gorge I 1.10.ii this location for the East Gorge waste? Has increasing the height waste was presented in SENES/Golder(1999). Using AutoCAD, it was of the mound been considered? Has it been taken into account determined that a mound footprint of approximately 200 m east-west by that the mound can extend over the refilled East Gorge site or 125 m north-south,with an excavation depth of approximately 5.5m towards the West Gorge site.This option has the merit that the (average)would provide the required storage volume. There is East Gorge waste will be managed by reconfiguration at the sufficient space at the north end of the existing facility to accommodate same site rather than seeking a second site. a mound of this size,without encroaching on the refilled East Gorge area or the West Gorge. Note that encroaching on the refilled East Gorge area would require temporary storage of the waste while the filling is carried out, and then double handling the waste in order to move it back to this area. This is not desirable. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author File name:PGFCVo12P RTCommentsFI NA L.doc Updated on September 10, 2004 PoxI T�HOP AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 8 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P,P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Type* No. Page No.& G,T, Reviewer Comments Author's Disposition Status** Para No. E A,I, N 29. Appendix C T Why is a double liner system not considered for the base liner? A double composite liner system is not expected to significantly improve N 1.11.i This option needs to be carefully assessed in terms of long-term the overall performance of the leachate containment system relative to conceptual safety, liner and cap durability and long-term a single composite liner for both Concepts IA and I I which involve a commitments required to maintain the facility in a safe state. mound. A double composite liner was therefore not considered in the development of the Feasible Concepts. Detailed modeling for the performance of the leachate containment system will be carried out under the detailed effects assessment of the EA to confirm that the single composite base liner is adequate. If the modeling shows that a double liner is required, it will be included in the detailed design stage of the project. 30. Appendix C T Engineered lined trenches(with waterproofing)with drummed The excavation depth required to contain the wastes would be about N 1.11.ii storage could provide a suitable alternative to the engineered 12 m. For concept IA,the high groundwater table and permeable mound. Problems due to insufficient space could be overcome by nature of the Upper Sands necessitates extensive dewatering to increasing the depth of the trenches. achieve such an excavation depth. The collected groundwater would likely require treatment. For Concept II,the greater excavation depth results in removal of a large portion of the low permeability native,till deposit, reducing the potential for natural attenuation of contaminants in the unexpected event of failure of the engineered containment system. These disadvantages outweigh the advantage of a smaller mound height above grade. 31. Appendix C T The cost of the structural vault needs to be compared on an Replacement of the base liner will not be performed nor is it required. N "apples to apples"basis against the cost of the liners. If the liners The geomembrane at the base of the mound would not be accessible will need to be repaired/replaced more frequently over the 500 for repair/replacement once the waste is in place. We note, however, year period,then the ongoing capital cost of the liner AM could be that the primary purpose of the geomembrane liner is to contain approaching that of the structural vault. The structural vault leachate generated during the construction phase. It will therefore have should be brought forward as a part of the Qualified Concept. served its primary purpose before its life has expired. Over the long- term,the primary method of preventing the generation and exfiltration of leachate from the mound is the cap system which would be similar for the structural vault and the lined mound altematives. Nevertheless,we expect that the base geomembrane liner will continue to function as an effective diffusion/hydraulic barrier over the long-term(i.e., hundreds of years—based on service life projections published by the US EPA, 2002)and contribute to the performance of the overall leachate containment system. 32. Appendix C G Details regarding the"waste storage package should be provided See response to Comment#11. N 1.11.iii —ie.size, material. durability, etc. 33. Appendix C 1.12 G Given the permeable soils for Concepts 1A and 1 B, a double liner See response to Comment#i29. N should be assessed. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 -Ai PoRr HOPE ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 9 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Type* Status" No. Page No.& G,T, Reviewer Comments Author's Disposition A,I, N Para No. E 34. Appendix C 1.12 G We are concerned with the over reliance on references to landfill Example of above ground mounds for radioactive wastes,which I designs as a basis of comparison. Many of the landfills incorporate low permeability liners and cover systems, are provided in referenced by the LLRWMO are already leaking. And,the Appendix B of the Qualified Concept Report These sites will be noted Ontario MOE 1998 standard is still in the trial stage in terms of on the Fact Sheet. whether it is sufficient to prevent long-term off-site contamination. The waste at Port Granby is not IC&I waste or municipal waste. The closest comparative landfill in terms of comparable material is in Coruna and now being managed by Clean Harbours. Its main advantage is not the liner, but many metres of clay. 35. Appendix C 1.12 G The Description of the low permeable composite base liner is See response to Comment#31. N incomplete. If one assumes a 100 year service life for the liner, the definition should discuss how the liner will be replaced at year 100,200, 300,400 and so on. We anticipate that liner replacement will be complicated by the expected urbanization of the surrounding lands over the next 500 years. The EA needs to address how the liner would be replaced in an urbanized environment,similar to the homes around the Britannia landfill in Peel Region. 36. Appendix C T The Fact Sheet appropriately points to the need to assess the The results of standardized geomembraneichemical compatibility tests N 1.12.i compatibility(i.e. service life)between the geosynthetic materials reported in the literature(e.g., USEPA 2002 and Koerner 1994),support and the waste leachate" We agree. So much so that,this is a that HDPE is compatible with the high pH and the types of dissolved fundamental scientific analysis that should be well understood salts in leachate derived from Port Granby wastes. Further research before confirming the feasibility of a single liner, double liner or will be carried out during the detailed affects assessment of the project structured vault. to provide additional support for the compatibility between the geomembrane and the Port Granby leachate. 37. Appendix C T The total cost of the low permeability liner may be a factor of 4 See response to Comment#31. N 1.12.i too low if there is a need to replace the liner over the 500 year life of the facility. We believe that a cost of$14 million over its service life to be more realistic. * Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 PORT HOPEARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 10 of 16 , ►�!,' INnmkT» Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: / Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item Section, page No.& Type* G,T, Reviewer Comments Author's Disposition Status** A, I, N No. Para No. E 38. Appendix C T There needs to be considerably more discussion of leachate The Alternative Means assessment assumed that the leachate N 1.12.i collection systems as part of the Alternative Means. For the collection system would consist of a granular blanket with perforated Containment System for Excavated East Gorge Wastes,we are collection pipes over the full base area of the mound as this is what is unable to identify an examination of which systems are more or used in all modem landfill facilities including hazardous waste facilities. less robust,are more expensive over the long term, and require Any other type of system,such as french drains or a geonet are much more or less institutional control over the planned life time. less robust and not appropriate given the design life of the facility. The only possible variations on the leachate collection system are the type of granular material used(i.e.,clear stone versus sand)and pipe/sump lay-out, both of which are detailed design issues. 39. Appendix C T Barge handling could be made more efficient if roll-on/roll-off It is acknowledged that ro/ro containers would make barge transport A 1,13.ii containers are used which can be hauled away by trucks at the more efficient but the requirement for constructing a dock many meters barge terminal.This will save multiple handling of construction into the lake outweighs this consideration. materials required otherwise. 40. Appendix C T Support facilities may need to include health physics(radiological Agreed. The Fact Sheet will be edited to include radiological control I 1.14J control)facilities to provide ongoing support to workers.Truck facilities and truck decontamination facilities as part of the site support decontamination facilities also may be required. How will the facilities. Regarding FC 11-further details have recently been open areas for processed materials and clean soil be protected developed in the Project Description for the EA phase.Additional details from the weather? will be developed during detailed engineering. 41. Appendix C T The description lacks detail on the long term institutional liabilities The$3.3M represents the net present value of annual monitoring and N 1.16.i and costs associated with this Alternative Means. The estimated reporting at$100,000/yr over 500 years at 3%ROL Long-term $100k monitoring cost per annum is totaled to$3.3 million. maintenance and monitoring will be the responsibility of the federal However, 'long term'under this concept is the 500 year life of the government and it is reasonable to assume that human resources are facility,and thus,the costs would appear to be much higher. A able to provide this care. Costs for human resources are included in discussion of whether and how human resources are able to the annual cost noted above. provide long term institutional controls is required. Costs of human resources need to be addressed. 42. Appendix C T What are the base assumptions for the annual operating cost of The estimated annual operating cost for remote monitoring and regular A 1.16.ii remote monitoring compared to regular site inspections? site inspection/monitoring are approximate and are based on our experience on other projects such as the development of a remote groundwater monitoring network including central data management system for 38 Conservation Authorities in Ontario. 43. Appendix C T There may be ways of engineering accessible tunnels for visual While cameras can be used for inspecting leachate collection pipes for N 1.16.iii monitoring that would be more likely to pass the filters,such as encrustation and structural damage,they would not be of any use for smaller tunnels for remote cameras. Was such an option monitoring contaminant migration from the base of the mound. This considered? option was therefore not considered for long-term environmental monitoring. C G The report should explain why this site was rejected earlier in the Text will be added under the"Issues"section. I [Z47JAppendix 11.1 J 1978 FEARO Panel Report and what makes it suitable now. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 11 of 16 /AUtd'o INITIATIVE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: � + Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24, 2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item Section, Type* Status*" No. Page No.& G,T, Reviewer Comments Author's Disposition A, I, N Para No. E 45. Appendix C G The Fact Sheet comments that locating the storage facility in an CNSC regulations will apply. A 11.1.1 off site location will require designating the area as a waste storage area under applicable regulations. What are those regulations? 46. Appendix C G A double liner should be considered as an alternative mean and See response to Comment#4 from Volume 1 and comment#31 of this N 11.1.i assessed. The Above Ground mound should be more document. The above ground mound will not need to be reconstructed. appropriately described as requiring to be reconstructed over its design service life. 47. Appendix C T In addition to the North End of the Property,alternative storage The north-west portion of the Cameco property is considered the most N 11.1.i facility locations should be considered. appropriate location for the mound due to presence of relatively low permeability glacial till which would reduce the rate/extent of contaminant migration in the event of leakage through the base liner system. This low permeability till layer is not present in the east and south portions of the property and therefore these areas were not considered any further. Also, locating the mound at the north-west end of the property would reduce its visual impact from view points along Lakeshore Road. 48. Appendix C G Indicate if the two cells proposed are for segregating LLRW and The two cells are not for segregating LLRW and MCS. The cells simply I 11.2.i the MCS or for any other purpose. allow the base liner system to be constructed in two stages so that each stage can be fully covered by at least 1.5 m of waste(and therefore protected from frost damage)prior to the onset of freezing conditions. If the entire base area of the mound is constructed during the same construction season, it is quite possible that areas of the base liner would not be covered by waste in time to protect the liner from frost damage. 49. Appendix C T In addition to capital costs for the trenches, a long term The long-term operational costs(e.g.,for cap maintenance and N 11.2.ii operational cost comparison should be calculated. leachate collection/treatment)would be fairly similar to those for an above ground mound. Comparison of operational costs would not change the outcome of the evaluation of these two altemative means and is therefore not considered necessary. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 A xPoi� THHoP AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 12 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 I Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item Section, Type* Status** No. Page No.& G,T, Reviewer Comments Author's Disposition A,I, N Para No. E 50. Appendix C G Burial trenches appear to have been eliminated as a viable The design considered for the burial trench had all the waste placed N 11.2.ii alternative means on the basis of one design only. There would below grade and only the final cover extending above grade. A lower also appear to be benefits in using trenches—eg. lower profile, profile was not considered as this could over the long-term result in loss storage of the waste in smaller quantities so that, If something of positive draining over the surface of the cap, particularly given the fails, only a portion of the waste is affected, etc. Additional potential for waste settlement. A loss of positive drainage would result Alternative Means for burial trenches should be considered. in higher infiltration through the cap and hence higher leachate generation. This disadvantage of a lower profile trench outweighs any advantages relating to a reduced visual impact. Secondly, storage of waste in smaller quantities means multiple trenches and therefore a larger foot print for the waste storage area which would not fit within the zone of the low permeability glacial till at the north west portion of the site(i.e.,the preferred area for storage of waste—see response to Comment#47). 51. Appendix C T An"apples to apples"cost comparison is required for the long See response to Comment#31. N 11.2.iii term costs of the Structural Vaults vs.the Base Liner. The Base Liner(above ground mound)will require reconstruction several times over its design life. 52. Appendix C G How was the budget for the construction of the new Waste For the purpose of assessing Alternative Means,the approximate N 11.2.iii Management Facility established? If the construction budget is to budget for construction of the WMF was approximately$20M based on be used as a criterion for eliminating alternative means,then the capital cost estimates reported in SENES/Golder(1999). We more information should be provided. arbitrarily adopted the criterion that if the alternative means for an individual component was greater than 50%of this amount(i.e., >$1 OM),then it was eliminated. This is considered a reasonable approach. 53. Appendix C T As with other storage alternatives,there needs to be an Agreed. The Fact Sheet will be revised to incorporate this comment. I 11.2.iii examination of the ability to berm and screen the vault,similar to the screening discussed for the mound. 54. Appendix C T The construction of the vaults is noted to be"time consuming". See response to Comment#31. N 11.2.iii How does this compare to the time required for building and reconstructing the above ground mound due to the failure of a single liner? 55. Appendix C T We are unable to identify a description of a leachate collection See response to Comment#38. N 11.2.iii system for this option. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author,I:Incorporated Comment, N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 PoRr HOPE AREA INnmkTrvE Document Title: Port Gra Feasible Concepts Report Volume 2: Issued by(author): Golder Associa Reviewed by: Dave Ha P.Eng., Paul Bowen, P. Item Section, No Page No.& Para No. 56, Appendix C 11.3.iii LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Project Environmental Assessment PHAI Report No. endices LLRWMO-03710-ENA-13002 K.r.r., ur. ivionan ;j., Milo Sturm, P.En Type* G,T, E Date: Issued to: January 2004 Low-Level Radioactive Waste M Organization: Hardy Stevenson and Associates Limited Reviewer Comments T IInformation is needed as to whether the Cambridge and Nic Centre Landfills are currently leaking. 57. Appendix C T While open excavation may be suitable for MCS, it may not be so 11.4.i for LLRW/East Gorge waste due to higher levels of radioactivity and Thorium-230 presence. Enclosed excavation and specially devised procedures may be necessary to reduce radiological site contamination and better assure worker safety and safety of nearby residents. Open excavation option should be further reviewed in the above context. 58, Appendix C T Enclosed excavation for LLRW/East Gorge waste should be 11.4.ii further assessed and compared to open excavation in terms of worker and public safety. 59. Appendix C T Use of containers as a loading step for LLRW/East Gorge waste 11.5.iv should be explored because of its advantages with respect to handling certain wastes(LLRW),contamination control and storage.Also,waste sorting and screening could help in removing non-impacted materials from the waste stream potentially reducing waste volumes. 60. Appendix C T What is the basis for the statement under"Advantages"that the 11.5.iv waste is co-mingled? Consistent mixing of the waste cannot be assumed. 61. Appendix C T Health physics support,truck decontamination facilities and 11.6.i possibly covered storage for wastes being held could be considered. 62. Appendix II 6 ii As noted earlier, more detail needs to be provided regarding each of the proposed transport methods so that issues such as difficulty of handling the waste can be adequately compared. 63. Appendix II 7 iii No details are provided regarding either the Interceptor Trench or the on-site treatment system. Rev/Draft No. Date: Od4 I January 2004 Bement Office Date: March September 14,2004 Author's Disposition These sites have no base liner and were operating for many years prior to placement of the GCL final cover. A leachate mound and groundwater contamination already existed prior to cap placement. The purpose of the cap was to minimize further groundwater contamination. Leakage of leachate that existed prior to cap placement is a given. We are not aware of any problems associated with the performance of the GCL cap at these sites. See response to Comment#18 response to Comment#18. Use of containers for waste handling/transport will remain an option in the event there is a need to mitigate potential adverse effects that are identified during the detailed effects assessment. Sorting and screening of waste was not considered as this additional handling of the waste would increase the duration of waste excavation/handling and increase dust generation. It is agreed that consistent mixing of the waste can not be assumed. The basis of the statement is that by placing the waste in lifts such that lifts of soft waste are overlain/underlain by more competent waste,there is the benefit of improved support of equipment transporting and spreading the wastes on the mound. Health physics support and truck decontamination facilities were considered. It is anticipated that storage of wastes will not be needed. The details are sufficient for the purposes of comparison evaluation. More details will be developed as needed during detailed effects and licensing phases.Also see response to Comment#24. See response to Comment#62. Further details can also be found in Appendix B of the Qualified Concept Report. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 Page 13 of 16 //67 Status** A,I, N I Z N A W Z POi�RT E ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 14 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: I Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: fj Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi '{+C P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14, 2004 Item Section, Type* Status" No. Page No.& G,T, Reviewer Comments Authors Disposition A,I, N Para No. E 64. Appendix 118 i Is there any information as to how long the treatment ponds For Concept 11, it is envisioned that the existing treatment ponds at the N would need to operate? Has their longterm remediation been Port Granby facility would need to be operated throughout the waste addressed? excavation period(approximately three year period)and then remediated. Remediation of the existing treatment ponds is addressed in Appendix B of the Qualified Concept Report. 65. Appendix C G There has been no discussion with Clarington over the proposed It is agreed that further discussion with Clarington will be needed in later A 11.9.i end use of the site. Site remediation should be considered in the stages of design. context of what the site will eventually be used for. 66. Appendix C G There has been no discussion with Clarington over the proposed The source of fill for rehabilitation of the existing Port Granby WMF will N 11.9.ii end use of the site. The proposed source of substantial amounts be the spoil from the base excavation for the new mound at the new of fill should be discussed in the description of the Alternative LTWMF north of Lakeshore Road. It is envisioned that approximately Mean. 115,000 m3 of fill will be transported form the new LTWMF and spread as a 1 m layer over the waste excavation area(11.3 ha)after general regrading of this area to promote surface water drainage(refer to Appendix B of the Qualified Concept Report). 67. Appendix C 11 iii It seems optimistic that there are no issues if the shoreline It is assumed that all contaminated soils pursuant to the cleanup criteria N remains natural. This assumes complete removal of all the will be removed.Also see response to Comment#30 of the Qualified LLRW and MCS. Ongoing erosion could potentially be a Concept Report. problem if some LLRW or MCS remains. It would affect the viability of any system required for the on-going collection and treatment of residual groundwater. 68, Appendix C T Facilities for personnel radiological monitoring should be included The suggested facilities will be included. Details to be determined A 11.14.i to support worker safety requirements. during later design stages. 69. Appendix C T (Same as Item 38) See response to Comment#38. N 11.17.i 70. Appendix C 11 E The current proposal is for trucks to use the northern portion of Agreed.The text will be revised to indicate the preferred recommended I 13 i Elliott Road, not Nichols Road. route. 71 Appendix D- T We are not able to reach the same conclusion regarding how F2- In conjunction with a low permeability cover system over the waste, A Tables Identifier T3(minimizing the release of contaminants)can occur with the both the rockfilled slope and the vegetated soil slope can limit the 1.2.i. rock filled slope or vegetative soil slope for the in situ cover of release of contaminants. For this reason,they both passed Indicator East Gorge Wastes(IB). Would any of the covers address in-situ F2-T3. Note that for this indicator, it was not required that the management of the wastes? Alternative Mean on its own minimize contaminant release. 72. Appendix D - T We are unable to trace the analysis leading to the conclusion that In-situ soil mixing passed F2-T2 because it has been successfully A Tables Identifier the In-Situ Soils mixing or the Low Permeability Cover System applied at hazardous waste sites. The low permeability cover system 1.3.i would work for the in situ cover of East Gorge Wastes(IB)for passed F2-T3 because of its much higher reliability compared to the Indicators F2-T2 and F2-T3 respectively. other alternatives. It is recognized, however,that repair may be required when there is large differential settlement of the waste. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author,1:Incorporated Comment,N: Not accepted by author File name:PGFCVo12PRTCommentsFINAL.doc Updated on September 10, 2004 N HOPE AREA ,AWO LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 15 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: + Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Type* Status** No. Page No.& G,T, Reviewer Comments Author's Disposition I, N Para No. E 73. Appendix D— G It is not clear why extraction wells were eliminated. Its score is Extraction wells were eliminated because they are more susceptible to N Tables less than 1%lower than the interceptor trench score. clogging and therefore require more maintenance than the interceptor Identifier II 7 trench. 74. Appendix D— T The table referring to on-site management and the location of the For Filter 2—Parts 1 and 2,the management of East Gorge Wastes A Tables Identifier storage facility appears to overlook the in situ management of was treated as a separate component of Approach I (On-site 1.10.iii wastes in the East Gorge. Perhaps there should be a specific Management of Wastes), rather than as a separate Approach. For Alternative Means—1.10.iii assessing the component"Location of Storage Facility"it was assumed that the East Gorge wastes would be excavated. 75. Appendix D— T There is no"apples to apples"cost comparison of the structural See response to Comment#31. N Tables Identifier vaults(F2-EC1 compared to the above ground mound and 1.11.iii shallow burial trenches. We suggest that the structural vaults be carried forward to the Qualified Concept analysis. 76. Appendix D— T (Same as Item 63) See response to Comment#63. N Tables Identifier 11.2.iii 77. Appendix D T The costs calculations for Enclosed Excavation appear to be The costs for Enclosed Excavation assume progressively removing the N Tables 11.4.ii based on an overly complex definition of the project. We expect waste under a moveable,pressurized shelter. This in not overly that simpler ways of enclosing the excavation are available for complex. However, it greatly reduces the rate of excavation and Indicator F2-EC1. We suggest that the structural vaults be therefore increases the costs. See also response to Comment#24 of carried forward to the Qualified Concept analysis. the Qualified Concept Report. 78. Appendix D T We are unable to arrive at the same conclusion that the in situ See response to Comment#71. A Filter 2—Part 1 stabilization of waste in the East Gorge for 1 B for rock filled or F2-T2,T3,T4 vegetative slopes will be able to minimize the release of contaminants from the facility—either during or post-construction. 79. Appendix E G The screening matrices may need to be revised based on the The changes to the Fact Sheets identified in our responses will not N Filter 2—Part 2 comments made on Fact Sheets. Filter F2-R2 for the no affect the screening matrices. Further analysis of the no excavation excavation option(capability to meet regulatory requirements option is provided in the Qualified Concept Report. after construction)requires further analysis. It is noted on the sheets as not applicable(n/a) 80. Appendix E G It is difficult to replicate in a consistent manner the application of An independent weighting of IA versus IB is presented in the Qualified N Filter 2—Part 2 the filters that clearly distinguishes 1A from 1B. Would a second Concept Report. and independent weighting of 1A and 1 B yield similar scores? 81. Appendix E G The potential end use of the site should not even be considered Alternative Means for end use were given consideration during this N Filter 2 as a criterion because it does not affect the viability of any of the stage to comply with the direction given in the EA Scope. It is Identifier 1116 Feasible Concepts, acknowledged that it may be premature to identify certain aspects of end use atthis stage and that end use will likely evolve overthe lifes an of the facility. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 .A PORT HOPE AREA ,{►WW INITrATnT LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 16 of 16 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: approval of this completed form Feasible Concepts Report Volume 2:Appendices LLRWMO-03710-ENA-13002 Od4 I January 2004 Date Issued by(author): Golder Associates Ltd. Date: Issued to: Contract January 2004 Low-Level Radioactive Waste Management Office Supervisor: Reviewed by: Dave Hardy, R.P.P., Dr. Mohan Rao, Organization: Hardy Stevenson and Associates Limited Date: March 24,2004 Rick Rossi r{�C P.Eng., Paul Bowen, P.Eng., Milo Sturm, P.Eng. September 14,2004 Item Section, Type" Status' No. page No.& G,T, Reviewer Comments Author's Disposition A,I, N Para No. E 82. General E Pages in the Appendices should be numbered to make it easier Page numbers were avoided to allow page additions and/or deletions N comment to reference comments. easier. This block should be completed following discussions regarding author's disposition of reviewer's comments. *Note: Signatures are required prior to Reviewer's Signature Date approval of this completed form lJ� ScSy07Z�'�I�� Zo-c Y Author's Signature Date n:iacove,.zuuzN-i suuwz-i--1604 pnai engin.suppomengmeenng rasK laquaimea concepisyune u4,commencsNpggc commentk ncKzgv -u4�u1y ua.aoc Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision — Disposition Status Code-A:Accepted by Author, I: Incorporated Comment, N: Not accepted by author Filename:PGFCVol2PRTCommentsFINAL.doc Updated on September 10, 2004 1 i Appendix D — Comment / Disposition Form for the Port Granby Project Qualified Concept Report I i i Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports Hardy Stevenson and Associates Limited September 2004 i PoxI T H T AREA AxE LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Peer Review Comment/Disposition Form Page 1 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd, Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& Type G,T, E Reviewer Comments Author's Disposition Status Para No. A,I, N 1. Section 1.1, G The statement"...the project proponent(LLRWMO)may choose to LLRWMO is following the direction set out by the RAs in regard to doing I Page 1, use the Qualified Concept..."opens up the question as to how the the detailed effects assessment on the Qualified Concept that emerged as Para 4 concept will be selected if the proponent does not choose the "best"through the evaluation process. LLRWMO has no option or ability to Qualified Concept following the evaluation. To be more accurate, choose. It is acknowledged thatthe Municipality of Clarington has the the sentence should be revised as follows:"... the project proponent ability to request another concept proceed to subsequent stages. However, (LLRWMO)will use the Qualified Concept identified in this report as it is not deemed necessary to include that extra information in the report the basis for a Project Description and subsequent detailed Following completion of the Phase 2 consultation activity the sentence will environmental effects assessment, provided that the selected be revised as follows,"The project proponent(LLRWMO)will use the Concept is agreed to by the Municipality of Clarington" Qualified Concept identified in this report as the basis for a Project Description and subsequent detailed environmental affects assessment." 2. Section 2.2.1.1, G Indicator DCE-T2 is based entirely on the number of components. Indicator DCE-T2 is NOT"based entirely on the number of components". N Page 9, The number of components is not a good indicator of the Rather, it is based on"the number of major components expected to Para 2 and 3 requirement for maintenance, repair or replacement. Some require significant regular maintenance,significant intermittent repair and components(such as a soil cover system)are intrinsically simpler complete replacement over the design life of each Concept". While it is and require less maintenance than other components(such as a agreed that complexity and other aspects of components can affect the leachate collection and treatment system). The indicator should be reliability of the concept this level of detail is beyond the scope of the modified to account for this. present comparative evaluation. Thus, it is not considered necessary to redo the evaluation(scoring)at this time. 3. Section 2.2.1.1, G Indicator DCE-T3 is based on ease of monitoring. Given that all of The term"functionally similar"is considered to apply at a"high"level in this N Page 9, the concepts, by definition,are functionally similar, it can be context. There are components unique to FC IA and IB(e.g.,shoreline Para 4 expected that there will be little significant difference in the ease of stabilization and groundwater diversion)that are considered more difficult monitoring. All concepts will have essentially the same monitoring to monitor for long-term integrity.These factors support the higher scores components. for FC II as described. 4. Section 2.2.1.1, G This indicator parameter seems to be too broad. Since all of the It is agreed that it is unlikely that an FC would undergo"several attempts". A, I Page 10, concepts, at this stage, are supposed to be feasible it is unlikely that However,the lack of experience with FC IA and IB supports a lower score Para 2 the rankings that suggest that"the installations may be unsuccessful for these concepts. Based on the sub-indicator score descriptors, a score or require several attempts"would ever apply. As is noted of 2"very limited experience"would be more appropriate for FC IA and IB. subsequently with other indicators,there is a level of precision The scoring will be changed accordingly. implied by the indicators which is not warranted by the level of detail currently available for each of the concepts. Comment Type—G: General content comment,T:Technical Revision,E:Editorial Revision °' Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 -&"PORT HOPE ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 2 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Od3 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No Section, Page No.& Gyp Reviewer Comments Author's Disposition Status** A,I, N Para No. 5. Section 2.2.1.2, T DCE-C1 It is agreed that the definition could be changed to include passive A Page 11, The definition of"retum lands to beneficial use"is defined recreation and park use. As recreational use of the WMF is subject to Para 3 specifically as agricultural use. The definition should also include confirmation from the CNSC during the licensing phase,the amount of return lands to passive recreation and park use as was done later. land available for recreational use is not certain. If it is permitted by the For example, in Table 3.1, 'Summary of Features—End Use'(page CNSC, all concepts would receive a score of 5(all land returned to 22), all of the end uses for IA, I and II are similar and beneficial as beneficial use)and the preference for FC II would be strengthened. If passive recreation and parkland. This definition should also CNSC does not allow recreational use,then the scores as assigned would specifically refer to returning waterfront lands to public use. The apply. No change required to the report at this time. limited definition of agricultural use biases the evaluation of Concept II in that only this Concept affects the use of agricultural lands. 6. Section 2.2.1.2, T DCE-C2 As environmental effects were evaluated in the evaluation of N Page 12, The definition of"prevent adverse of detrimental effects on adjacent Environmental Indicators and as the concepts represent passive Para 1 or nearby lands or communities"is a narrow definition of community management strategies, analysis of DCE-C2 focused on the degree of impact. Given the possible need for liner replacement, as part of visual obstruction posed by each of the Feasible Concepts in the long-term long-term management, and given the likelihood of built up occasional disruptions caused by long-term maintenance activities were settlements in close proximity to the Concept over the long term, not included in the analysis(see also disposition of Comment#7). local communities will experience many more impacts than visual impact or truck traffic. The definition should be expanded to include: housing effects,dust, noise and disruption effects. 7. Section 2.2.1.2, T DCE-C2 Indicator DCE-C2 considered nuisance(disruption)posed by truck traffic I Page 12, Is it valid to group short-term construction effects and long term only during the construction phase of the project. Occasional disruptions Para 1 effects in the same indicator, as these effects are quite different in caused by long-term maintenance activities were not included in the their nature and magnitude? Short-term effects for all 3 concepts analysis. It is agreed that such disruptions would be less for FC[[than for are somewhat similar. However,with Concepts 1A and 1B, long FC IA and IB. It is also agreed that the sub-indicator"Nuisance from Truck term effects will include the effects related to regular maintenance Traffic"(Section 4.1.2.2,page 34. para 3)will be redefined as"Nuisance and replacement of the considerable engineering works on the site; from Construction Activities", recognizing that environmental effects were these same long term effects will not be present on the same scale evaluated in the evaluation of Environmental Indicators. with Concept 11. 8. Section 2.2.1.2, G DCE-C2 It should be noted that this indicator question was added in response to I Page 12, Footnote—explain why the assessment uses the definition of specific input received at a public workshop,which used the specific words Para 1 "adverse effects"from the Ontario Environmental Assessment Act ... prevent adverse or detrimental effects on adjacent lands of communities". As a broad meaning can be attached to the term"adverse effects"and no definition is provided in the CEAA,the widely accepted definition from the Ontario Environmental Assessment Act was used. This fact will be footnoted in the report. Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision •` Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author File name:PGQCCommentsFINAL.doc Updated on September 10,2004 / Poxes�HOPEAREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 3 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi r{! Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& Type* G,T, E Reviewer Comments Author's Disposition Status** A, I, N Para No. 9. Section 2.2.1.2, G DCE-C3 While it is agreed that it does sound paradoxical,the economic benefit to A Page 12, Direct economic benefit to the community appears to be larger for the community is an established community factor used in other Para 4 concepts that are inherently complex and expensive to build. Given assessments.As a point of clarification, large concepts that are inherently that what is required is an economical option (that is simple and complex and expensive are more likely to require specialist, non-local safe), it seems paradoxical to use this as an indicator. A better contractors which would minimize the economic benefit to the community; explanation of the rationale for using this indicator would be simple concepts could more likely be implemented by local contractors. welcome. The measure of potential economic burden to the community in the long If this indicator is used,it should also include a measure of the term is captured in the consideration of indicator question DCE-EC2. potential economic burden to the community(i.e., potential maintenance costs to the Municipality in the long term) 10. Section 2.2.1.2, T DCE-C3 As stated in the report"The measure of this indicator was the magnitude of A Page 12, The scaling of economic benefitto the community is confusing. For direct expenditure value(dollars)in the community". All concepts are Para 5 example,what does"High"mean? What's high to one person may expected to be about equal in magnitude and were scored accordingly. not be to others—does High mean high numbers of dollars? 11. Section 2.2.1.3, G DCE-HH1 It is agreed that a quantitative evaluation would require a H&S effects I Page 13, It appears difficult to evaluate the Human Health and Safety analysis. However, it is considered that sufficient information is available Para 2 indicator without at least a conceptual health and safety effects for a present qualitative,comparative evaluation. A H&S effects analysis analysis of the concepts,which does not appear to have been will be carried out as part of the environmental effects assessment of the undertaken at this stage. Qualified Concept (See also Disposition of comment#13). 12. Section 2.2.1.3, G DCE-HH1 It is agreed that a better definition of these terms is warranted.The report I Page 13, The use of the words"change"and"effect"should be clearly will be revised accordingly. Para 3 defined. For example,what is the difference between a"barely measurable change not likely to cause an effect", and a"measurable change not likely to cause an effect"? If there is a change but it causes no effect than it is not a significant change which should be evaluated in the analysis. Similarly,the consequence(or adversity) of the effect should be discussed. Not all effects are adverse or significant. Comment Type—G: General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POK RTT HOP AxFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 4 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office / Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, September 10, 2004 Charlotte Young Item No. Section, Page No.& Type* G,T, E Reviewer Comments Author's Disposition Status" A,I, N Para No. 13. Section 2.2.1.4, G DCE-EN1 and EN2 Although the effects assessment(on the Qualified Concept)has not been I Page 13 It appears difficult to evaluate the Environmental Indicator without a completed,the authors(discipline experts)of the Environmental Baseline quantitative assessment of environmental effects,which does not Characterization Studies(TSAs),who for the most part will be conducting appear to have been undertaken so far. the effects assessment,were thoroughly involved in the present evaluation and assignment of scores.The TSAs agreed that the level of rigour in the analysis was sufficient for this comparative assessment. A statement will be added in the report to explain this. 14. Section 2.2.1.4, G It is not clear what each of the scores for environmental components See Disposition of comment#12. I Page 14, mean (e.g,what does"interaction"mean?). There needs to be a Para 3 better explanation of the differences between the scores. 15. Section 2.2.1.5, T DCE-EC1 and EC2 The geomembrane at the base of the mound would not be accessible for N Page 14 Both the capital cost or operating and maintenance cost of the repair/replacement once the waste is in place. We note, however,that the concept should be defined to include the cost of liner replacement or primary purpose of the geomembrane liner is to contain leachate repair, possibly once or twice over the 500 year life of the facility for generated during the construction phase. It will therefore have served its a single liner. For example, Fact Sheet B.3.ii of the Port Hope primary purpose before its life has expired. Over the long-term,the primary Feasible Concepts Report indicates that a single liner is accepted by method of preventing the generation and exfiltration of leachate from the MOE to last at least 150 years, and a double liner is accepted to last mound is the cap system. Nevertheless,we expect that the base at least 350 years. Liner replacement should not be seen as a geomembrane liner will continue to function as an effective Contingency Cost. diffusion/hydraulic barrier over the long-term(i.e., hundreds of years— based on service life projections published by the US EPA,2002)and contribute to the performance of the overall leachate containment system. 16. Section 2.2.1.5, T DCE-EC2 Over the long-term there may be significant events that cause the net N Page 14, For long-term projects involving hundreds of years,comparing total present value method to be invalidated(i.e., extreme devaluation of Last Para operating and maintenance cost on the basis of'net present value' currency caused by war, hyperinflation,etc.)but it is still considered the is not a fair method of identifying long-term costs. Costs in current best method that is available. Costs in current dollars would over- dollars may be more representative of the long-term commitments emphasize the long-term maintenance component and therefore required. strengthen the case for Concept II.This would further discount the in-situ options. Comment Type—G: General content comment,T:Technical Revision, E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POE RTT HOP ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 5 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi �I Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& Type* G,T, E Reviewer Comments Author's Disposition Status"* A, I, N Para No. 17. Section 2.2.1,5, E DCE-EC3 Agreed, an explanation of the contingency cost with a sample calculation I Page 15, The meaning of this paragraph is not clear. An example calculation will be provided as follows: Para 2 should be provided for clarity(i.e.calculation of the contingency "For the matrix evaluation,the contingency cost was estimated as the full cost). cost of implementing the Contingency Plan multiplied by the probability of implementing the Contingency Plan based on professional judgement. For example, if the capital cost of implementing a Contingency Plan(e.g. relocation of all waste to a new facility)is estimated at$25M and the probability of having to implement the Contingency Plan over the design life of the facility is 10%,then the contingency cost for the matrix evaluation would be$2.5M(i.e.,$25M x 0.10)". 18. Section 2.2.2, T Section 2.2.2.1 needs to conclusively explain the weights used for A clarification will be added to Section 2.2.3 as follows: I Page 15-6 the economic indicator. This appears to be absent from the Table "Unlike the other indicator groups,the Economic Indicator group did not and Text. have a weighting factor applied to the scores for the individual indicator questions. Instead,the capital, operating/maintenance and contingency cost were added to give a total cost(in Net Present Value)for each concept. The Concepts were then assigned a weighted score calculated as: Total Cost of Concept in Net Present Value 6— x 3 Median Total Cost Amongst the Three Concepts) With this method, a concept which has a total cost equal to the median cost of the three concepts, is assigned a score of 3.0 whereas a concept with a total cost equal to say 1.2 times the median cost is assigned a score of 2.4. Comment Type—G:General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 .A "=PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 6 of 36 /AWO IAIIT7ATIVE Document Title: Port Granby Project Environmental Assessment .PHAI Report No. Rev/Draft No. Date: LLRWMO-03710-ENA-13003 Od3 January 2004 Qualified Concepts Report Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Septembelr 10, 2004 Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, Charlotte Young Reviewer Comments Authors Disposition Status*" A,I, N Item Section, page No.8� yp Type No. Para No. G,T, E An example calculation for the use of the Economic Indicator should Agreed, an example calculation for the use of the Economic Indicator will I 19. Section 2.2.2.1, E Page 15, be provided for clarity. Also,the rationale for the calculation used in be provided in Section 2.2.3 as follows: "For example,if the sum of capital, operating/maintenance and Para 1 this indicator should be provided. contingency costs were$40M,$35M and$30M for Concepts IA, IB and 11, respectively,then the median cost would be$35M and the score for Concept IA would be 2.6,i.e., 6- 1x3. (35 J J This approach for the Economic Indicator provides a simple means of benefiting concepts having a lower total cost,while not overly penalizing those of higher cost. This will be stated in Section 2.2.3. Explain what"scores"and"weights"mean and how they differ, or An explanation will be provided. 20. Section 2.2.3, G Page 16, provide a reference to reports that define them. Para 2 Add"across all three concepts"just after"ranked"in the sentence in The sentence will be revised as follows:"The score for each concept was used to determine its ranking within the three concepts...". l 21. Section 2.2.3, E Page 17, the second paragraph. Para 2 While the individual Indicator weightings(Table 2-1)are expressed as a l 22. Section 2.2.3, Page 17 E Table 2-2 Add"%"in first column (same comment for Table 4-2 on p.24). percentage they were actually applied as a decimal (e.g., 16.7%was applied as 0.167),the Indicator Group weightings(Table 2-2 and Table 4- 2)were applied as whole numbers.A footnote will be added to explain this. Based on the I NTERA Report(2002), an interceptor trench across dealing It is acknowledged that the best feasible method of dealing with impacted still may not fully prevent radioactive discharge to the lake. I 23. Section 3.1, T Page 18, the mouth of the East Gorge may not be fully effective in with impacted groundwater from across the whole facility, and could groundwater Intera conducted a study in 2003 which investigated a cut-off wall to the Para 2 result in radioactive discharge to the lake.The INTERA study did not middle till.The text will be corrected and the accompanying letter report the effectiveness of a ground water cut-off system into the will be added to the reference list.The studies conducted to date are establish middle till unit. Additional details should be provided regarding the sufficient to support the comparative evaluation,especially since the concept provides a greater improvement to the existing means of dealing with the existing impacted ground water. recommended impacted groundwater.The effect of existing impacted groundwater as well as development of details for managing it after source waste material is removed,will be addressed in the detailed effects assessment and the subsequent engineering phases. * Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision ** Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 -h" o Pi ��� LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 7 of 36 ,AO Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: I Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Officef%;� Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young INo Section, No.& Gyp Reviewer Comments Author's Disposition Status** A,I, N Page Para No. 24. Section 3.1, T The proposed conventional excavation method may not necessarily Based on the results of the Th-230 report by Stantec,the radiological A Page 18, be the best method to deal with the East Gorge Waste due to its concerns can be addressed with conventional open-air hazardous waste Para 2 Thorium-230 radioactivity(which is an inhalation hazard). Enclosed excavation control methods.The detailed affects assessment will fully excavation(i.e.temporary portable enclosures at the work site)with evaluate this concern and will identify any mitigation methods are alternate venting and high efficiency particulate air filtration could better excavation approaches that may be necessary. Enclosed excavation reduce dust loading and potentially improve public and worker would be given further consideration. safety. Will there be a need to dewater the waste,and if there is, how will it No pre-treatment(e.g., dewatering)of the waste is proposed. be done? 25. Section 3.2, G This paragraph refers to an unpublished INTERA study. It appears The unpublished report will be provided to the Peer Review Team. In the A Page 18, this study is key in establishing the feasibility of on-site management analysis, it was conservatively assumed that this feature would perform Para 6 of the wastes,yet the results have not been provided and it has not satisfactorily. It is acknowledged that the results of the"additional studies" been peer reviewed. Further,this section of the report indicates that may confirm that this is not the case rendering FC IB not feasible. "additional studies will be required to confirm the acceptability of However due to the recommendation of implementing FC II (because of its leaving the East Gorge LLRW in place". This suggests that until overall superiority),the extra cost associated with the"additional studies"is further study is done, Concept 1 B may not be feasible. Why was not warranted. this concept carried forward as a feasible concept without these studies and confirmation of its feasibility? The reasons for carrying Concept IB forward were discussed in the Feasible Concepts report. 26. Section 3.2, G The Report states that Concepts IA and IB are essentially similar. It is agreed that there are some differences between the concepts.The A, I Page 19, However, it would appear that design and performance relevant performance aspects are addressed in Section 4.The first First Para requirements for Concept IB would be considerably more stringent sentence will be revised as follows"...waste would not be required, in terms of cover design, leachate control requirements and physical construction aspects of Concept IB are essentially the same ...". demands on the groundwater diversion system. The concepts differ significantly in other details. 27. Section 3.3, G The report states that the site north of Lakeshore Road was Text will be added to explain the following."The effort by Eldorado in the I Page 19, originally considered in the 1980s by Eldorado Resources, but does 1980s was cancelled before an EA was conducted as a result of federal Para 2 not give any details. Some explanation as to the outcome of that EA intervention and a directive to find another site"away from Lake Ontario". and why it is not considered relevant to the current process would This preceded the Siting Task Force process,which was unable to secure be useful. an alternate site away from Lake Ontario."Reference Sharon Bailie-Mato letter and add these points Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision •• Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGOCCommentsFINAL.doc Updated on September 10,2004 PORT HOPE AP.EA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 10 of 36 ,AWW INITTAi1VE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, September 10,2004 Charlotte Young Item Section, Page No.& Type E Reviewer Comments Author's Disposition Status** A,I, N Para No. , 32. Section 4 G The chapter is well compiled and comprehensive.We are pleased to A statement will be added to Table 4-4 to identify ease of decommissioning I see the use of three approaches to evaluation, as an advantage of Concept 11. The following is our overall comment on this section: It is agreed that a reader could incorrectly assume that the score ratios directly correlate to a measurement of improvement between concepts. • Consideration should be given for the ease of decommissioning The alternative means evaluation methodology was performed to a the concepts at the end of the service life of the WMF substantial level of rigour,with the intention of identifying a preference (Concept 11 will be much easier to decommission than concepts between concepts, not to accurately measure the degree to which one IA and IB), concept is better or worse than another. To reinforce the conclusion of the • The simple presentation of the scores may not provide an scoring method,several sensitivity analyses were performed. A statement adequate idea of how much better or worse any of the concepts to this effect will be added to the text in Section 4.1. are. For example,the difference between 1A and II is 87 points, which represents a 36.5%increase over IA. 33. Section 4.1.1.1, G Shoreline The Authors consider shoreline protection to be a bigger issue than do the A, I Page 25, A rating of 1 (Worst Possible rating)for Concepts IA and IB is Reviewers. However, it is agreed that a score of 2 for FC IA and IB would Para 3 extreme.This type of work is carried out regularly with no more care be reasonable. The report will be revised accordingly. required that any other type of civil infrastructure construction. Maintenance is required for all civil infrastructure works. A more moderate rating in this category is appropriate. 34. Section 4.1.1.1, G Bluffs It is agreed that the site itself(i.e.,the plateau area and gorges)must be A Page 25, No stabilization of shoreline or bluffs is required. However,the site stabilized(e.g., grassed)to control runoff and erosion. Last Para must be restored so that no excessive silt or other run off is generated by the site. This could be in violation of the Fisheries Act. 35. Section 4.1.1.1, G Groundwater As previously noted,the results of the Intera study will be provided to the N Page 26, The requirement for establishing the groundwater diversion system Peer Review Team. It is undisputed that a groundwater diversion system Para 1 cannot be confirmed until the results of the INTERA study has been would be required under FC IA and FC IB. Construction and operation of a reviewed. groundwater diversion system, regardless of the details of the system is a complex undertaking for the Port Granby WMF and for a number of reasons as brought out in the evaluation, contributes to the lower scoring results. In the analysis,it was conservatively assumed that the groundwater diversion system would perform satisfactorily. It is acknowledged that the results of the"additional studies"may confirm that this is not the case rendering FC IB not feasible. However due to the recommendation of implementing FC II (because of its overall superiority), the extra cost associated with the developing further details is not warranted. Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment, N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PIr Rrr E� LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 11 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item Page Section, No.& GT, E Reviewer Comments Author's Disposition Status** A,I, N Para No. 36. Section 4.1.1.1, T Surface Water See disposition for Comment#33. The score will be revised to 2 for FC A, I Page 26, As with shoreline stabilization works,we do not agree that the 1A and 1 B. Para 4 engineering works required for control for surface water and erosion are complex, and merit a ranking of"1". 37, Section 4.1.1.2, In the discussion of maintenance,repair and replacement,there is Disagree,see disposition for comment#2. N Pages 27 and no analysis of how complex the required work would be. There 28 seems to just an adding up of the components that would require attention—this approach would seem to under-estimate the extent of work required for certain concepts. 38. Section 4.1.1.2, T Maintenance These are important considerations; however for this comparative N Page 27, Elaborate on the types of human resources needed for maintenance evaluation they were only needed to be addressed at a high level. It can be Para 5 —consider adding a category about human resources/organizational inferred that the selection of the lower maintenance concept(discussed in capacity under this section for each concept—sub-indicators/ this section)supports this high level evaluation at this stage.These questions include: considerations will , however,be considered in more detail as part of the subsequent environmental effects assessment phase of the EA and/or the a. How will an organization/unit with the function to maintain the detailed design stage of the project. See also disposition to comments#37 site be set up(e.g., under an existing organization, its own and#2. organization, etc.)? . b. What training of staff is needed(first time and refresher)? c. What will be done to ensure continuity/reduce turnover of staff/ what mechanisms are in place for succession planning? d. How will organizational consistency be maintained? Same comments apply to repair and replacement(p. 28) Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author,I:Incorporated Comment,N:Not accepted by author File name:PGQCCommentsFINAL.doc Updated on September 10,2004 POD � LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 12 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Page Type* G,T, E Reviewer Comments Author's Disposition Status" A,I, N Para No. 39. Section 4.1.1.2, T Maintenance See disposition of Comment#30. Although the length of time required for N Page 28, As noted previously,collection of existing contaminated ground treatment of existing groundwater in FC II does need to be confirmed, Para 1 water from the east gorge will require operation of an interceptor there is confidence that it will be much shorter than for FC IA and I B, due trench and ground water treatment for some period of time,for all of to: i) removal of the contaminant source(i.e.,the LLRW and MCS), the concepts(including Concept 2). This should be clearly stated ii)removal of impacted groundwater by dewatering during waste and considered. The ranking suggests that Concept 1A will be four excavation and iii)a faster rate of"wash-out"of residual impacted times more difficult to maintain than Concept 2 simply because it groundwater in the absence of a groundwater diversion system and low has more major components. This is not the case. The additional permeability cover system. Further analysis will be performed during the maintenance requirements for Concepts 1A and 1 B will essentially detailed affects assessment. be limited to the bluff and shoreline stabilization works. These may also be required,to some degree,to permit long-term collection of The authors consider that maintenance of the bluff and shoreline existing impacted ground water in the area. stabilization measures under FC IA and IB will be a major consideration. This section of the report then goes on to state that it is anticipated that the de-watering during construction and flushing by natural ground water flow will eliminate the need for long-term collection of ground water in the east gorge. This must be substantiated through further analysis. 40. Section 4.1.1.2, T Replacement Disagree,see also response to Comment#37. The indicator is N Page 28, The likelihood of the requirement for replacement is not strictly "substantially complete replacement". Thus the"likelihood of failure"is Last Para related to the number of components in each of the concepts. It is independent of area. more directly related to other factors such as"the likelihood of failure given the nature of the engineering system", and the size of the system(i.e.the actual area of cover). Thus, a cover of one-hectare area may be more likely to require partial replacement than a cover of 0.5 hectare area. 41. Section 4.1.1.3, T Groundwater Monitoring the performance of an unlined facility above and immediately N Page 30, There is little significant difference in the ground water monitoring adjacent to a surface water body is more difficult than monitoring a lined Para 1 requirements between each of the concepts. The performance of facility on gently sloping ground. The assigned scores reasonably reflect the low permeability cover for Concepts 1A and 1 B could be this difference. assessed through measurement of leachate volumes, as is proposed for Concept 2. There is no significant difference between any of the concepts with respect to this criterion. * Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision *' Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PIivi �AuA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 13 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item Page Section, No.& G,T, E Reviewer Comments Author's Disposition Status** A, I, N Para No. 42. Section 4.1.1.3, T Air Agreed that it would be easier to surround the site for FC 11;it is also A Page 30, Air monitoring for Concept II will be slightly better than for the other agreed that this is a minor difference. No changes required. Last Para two FCs. Often monitoring is set up to capture upwind and downwind concentrations. Concept II location makes it slightly easier to"surround"the site. Proximity to the shoreline for the other two concepts could make this more difficult. This is a minor difference and probably does not warrant a change in scoring. 43. Section 4.1.1.3, T Physical Integrity Agreed. However due to the shorter-term requirement for a collection A Page 31, Monitoring of physical integrity may also be required for the system under FC 11 (see disposition of Comments#30),the preference to Para 2 collection system for existing contaminated ground water in the East FC II is further reinforced. No changes required. Gorge. Further information must be provided to determine if this monitoring will be required for each of the concepts. 44. Section 4.1.1.4, G By definition, none of the feasible concepts should be"novel'and See disposition of Comment#4. The scores for FC IA and IB will be A, I Page 32, "untested". This indicator is somewhat misleading. It is clear that revised to 2"very limited experience". Para 1 there is no experience with any type of waste management system for the time frame anticipated for this project(i.e.500 years). Further, although many examples are provided for low-level radioactive waste systems that have been constructed,all of these have been built in the recent past, and have less than 20 years of operating history. This indicator suggests that if a waste management facility has been built and operated successfully for a short period of time then this contributes significantly to the reliability of the system in the long term. This indicator should be restated, since it is misleading in its current form. The scoring for this criterion is similarly misleading with respect to Concepts 1A and 1 B. The scoring suggests that"this has hardly ever been done before and often require several attempts at installation and/or adjustment"again, if this were true,then the concepts could not be considered as feasible. 45. Section 4.1.1.4, G The word"recreational"should be deleted from the description of the Agreed,the sentence will be revised as requested. I Page 32, surface water body. Lake Ontario is certainly important for many Para 2 reasons, not just recreational. Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment, N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 APoRI AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 14 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Od3 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. page ion� Type* G,T, E Reviewer Comments Author's Disposition Status"* A,I, N Para No. 46. Section 4.1.2.1, T The definition of"return lands to beneficial use"is overly narrow. In See disposition to comment#5. A Page 33, addition to agricultural land uses, recreational and parkland should Para 5 be seen as beneficial uses to the community, including the return of waterfront land. Feasible Concept II should be rated higher and the score for the community indicators should be reassessed. 47. Section 4.1.2.2, T Usual Obstruction The Reviewer's comment is valid. The score for FC II will be revised to 4 A, I Page 34, Based on other information that the LLO has provided,the storage "low effect"and the text will be revised appropriately to reflect review Para 3 mound in Concept I I would not be that visible and certainly not as comment. obtrusive as the shoreline works. There is a lot of potential for landscaping to shield the mound in Concept II that is not reflected in its score. 48. Section 4.1.1.2, T Nuisance from Truck Traffic Agreed. However it is considered that the assigned scores accurately A Page 34, Given that Concepts 1A and 1 B will create about 2.5 times as much reflect the degree of nuisance—see also disposition of comment#7. Para 4 traffic as Concept Il,the difference between their scores is surprisingly low. 49. Section 4.1.3, T Radiation Dose to Workers The assigned scores are considered to accurately describe the N Page 36, One of the main routes of potential exposure will be through significance of the indicator. Concept IA was scored equally to Concept II Para 2 contactlingestion with contaminated materials(e.g. dusts).The because it would involve excavation of most of the highest activity level potential for exposure is greater with increased waste handling.As LLRW. such, Concept 11,which requires more waste handling than Concept IA,should have a lower score. 50. Section 4.1.3, T Radiation Dose to Public It is agreed that the increased risk exists,but due to the tight controls to be I Page. 37, Since Concept II requires the waste material to be moved across a placed on excavating and transporting waste,it is likely to be Para 3 public access road and more waste is moved that Concept IA,there inconsequential. The assigned scores are considered correct due to the is an increased risk of exposure to waste materials. Concept II following explanation. should have a lower score than Concept IA. "The pre-defined score descriptors do not allow for the consideration of actual differences in potential impact for concepts given the same score. For example,any two concepts that are scored"interaction, measurable change likely, not likely to cause an affect'could actually have significant differences in measurable changes,but as long as those changes were less than an adverse effect,they would not be differentiated using this scoring system.This differentiation would occur in the advantages/ disadvantages analysis." This will be explained in the report. Comment Type—G:General content comment,T:Technical Revision, E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PoRT HoP AREA, LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 15 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date.. Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item Section, Page No.& GT, E Reviewer Comments Author's Disposition A N Para No. ' 51. Section 4.1.3, T Public Health and Safety It is difficult at this stage assess the point at which the volume of traffic N Page 37, The discussion downplays the adverse effect of the additional truck starts to cause affects.The decreased volume of traffic in FC II is reflected Para 2 traffic related to Concepts 1A and 1 B—there are very few effective in the score. mitigative measures to deal with the adverse effects of increased truck traffic on local roads,as evidenced by the impacts related to landfill operations. More serious consideration needs to be given to the volume of truck traffic and the substantial differences between 1A/1B and ll. 52. Section 4.1.3, T Occupational Health and Safety (See disposition of Comment#33). Although various types of shoreline N Page 37, The construction of similar bluff and shoreline stabilization works is stabilization works have been implemented along the Lake Ontario Para 3 commonplace along Lake Ontario shoreline. It is not considered a shoreline,they are not known to be of the scope required under the in-situ significant risk from an Occupational Health and Safety standpoint. concepts(e.g., last for hundreds of years).There is rationale therefore that the work for FC IA and IB is much less commonplace and provides more As noted previously,the ranking of the indicators should be more risk than normal. clearly explained. It is not clear how a rank of 2(measurable change likely not likely to cause an effect)is significantly different As in the disposition of Comment#12:"It is agreed that a better definition of I than a ranking of 4(interaction but no likely measurable change). these terms is warranted.The report will be revised accordingly." Why is a measurable change significant if it does not cause an effect? 53. Section 4.1.4 G The report should include anticipated benefits that will result from The goal of the evaluation is to compare the concepts with each other to A each concept.The text focuses on adverse or lack of impacts, rather identify a preference as opposed to compare them with the status quo.The than benefits. primary benefit of all concepts would be essentially equal i.e. cleaning up the site. Other less significant benefits would develop but would not influence a change in the Qualified Concept recommendation. Some of these lesser benefits have been identified in the discussion on advantages /disadvantages. 54. Section T Non-Radiological Air Quality This indicator refers primarily to on-or near-site air quality and thus on-site N 4.1.4.1.1, Concept II requires substantially less material to be transported than trucking activities. It is considered that the assigned scores accurately Page 39, the other two concepts. (250,000 m3 vs 750,000 m3 of construction describe the significance of the indicator. Para 2 material). Since dust and noise impacts are directly related to truck traffic volumes,this should be recognized in the score. Concept II should have a significantly higher score than the other two concepts. Comment Type—G:General content comment,T:Technical Revision, E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 WiA y PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 16 of 36 '0 INITL T VE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& GT E Reviewer Comments Author's Disposition Status Para No. , A, I, N 55. Section G The authors have not separated short term(construction)impacts Section 4.1.4.1.3 deals specifically with construction phase activities. It is N 4.1.4.1.3, from longer term impacts.While clearing of vegetation and agreed that Concepts IA and IB will result in longer term impacts as Pages 42-43 concomitant effects on wildlife habitat will occur for all three options described.These specific concerns referred to are captured in Section during construction,the longer term impacts are not the same. 4.1.4.2.3. Concept I I will allow for the rehabilitation of the shoreline vegetation and only disturbs cropland. Concepts IA and IB will result in longer term impacts on the shoreline area and impact wildlife functions including movement corridors. 56. Section T Ground Water Flow An explanation will be added. FC IA and IB will have a"measurable but I 4.1.4.1.4, What is the definition of an adverse effect on ground water flow? If not adverse effect'on groundwater and FC II will have a"barely Page 44, there is no use of the ground water resource in the area and the measurable but not adverse effect'on groundwater. Para 2 ground water does not impact surface water habitat,then changes to the groundwater flow are not significant. This needs to be better explained. Similarly,the potential impact between ground water and surface water interaction should also be explained. Will an adverse effect actually be created? 57. Section T Ground Water Quality In all cases, it is agreed that there will be no adverse effect. The present N 4.1.4.1.4, None of the concepts are noted as likely to cause an adverse effect scoring reflects this fact. The authors consider the present scoring Page 44, to ground water quality. If there is no adverse effect,then there is accurately describes the anticipated significance of each indicator. Para 4 no significance associated with a change in ground water quality. It appears that all concepts should receive the same score. A similar issue is noted for soil quality on Page 45, radiological ground water quality on Page 48,sediment quality on Page 50, and fish communities, habitat and benthic communities on Page 51. 58. Section G Define the existing service base. (Actually paragraph 2).An example of the services referred to is given in 1 4.1.4.1.5, parenthesis. However the sentence will be revised to make it clearer. Page 46, Para 3 59. Section T Community Facilities.Services. and Infrastructure should describe A clarification will be added. I 4.1.4.1.5, utilities(gas,electric,telecommunications)that currently exist and Page 46, are expected to exist in the future. The same comment applies to Para 2 Section 4.1.4.2.5(Socio-Economic Conditions—p.54). Comment Type—G: General content comment,T:Technical Revision, E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 API P RTH ARPA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 17 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi ��� Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, page No.& Type G,T, E Reviewer Comments Author's Disposition Status*„ A,I, N Para No. 60. Section T Employment And Economic Base It was agreed that there would be a temporary disruption of traffic on the N 4.1.4.1.5, Include the comment that"Feasible Concept II will temporarily scenic Lakeshore Road. However no employment or economic base was Page 46, disrupt traffic on the scenic Lakeshore Road"(which was deleted identified that would be affected.The disruption has been captured under Para 4 from the earlier version of report)as there will definitely be disruption the same section dealing with impact to recreation. with the volume of trucks expected. 61. Section T Housing and Property Values The indicator refers to housing values in monetary terms. Due to the I 4.1.4.1.5, The scoring for this criterion should be 3 or 4,not 5, as even with existence of the Property Value Protection Program all concepts were Page 47, property values protection,there will be disruption to housing in scored equally in respect to potential impacts on property values. Para 2 general(e.g., more trucks,concerns about safety for street Disruption to housing in non-monetary terms(i.e.quality of life etc.)is an crossings),rather than only an effect on property values. important consideration and will be considered in greater depth during the detailed effects assessment. A new parameter should be added under Socio economic conditions to address the impact on people's day-to-day enjoyment of their Disruption to housing"will be added in the paragraph under Societal " properties and the surrounding area. The parameter for Societal Values. Values addresses this to some extent, but not as fully as it should. 62. Section T Radiological Air Quality See disposition for Comments#49 and#50. The assigned scores are N 4.1.4.1.6, Dust and release of volatile radioactive materials are the major considered to accurately describe the significance of the indicator. Page 48, routes for impacting air quality.The extent of'emissions'will be Para 4 directly related to the quantity of waste handled. As well,the waste will need to be transported for a slightly longer distance in Concept 11. As such, Concept IA,which requires less waste handling than Concept 11,should have a higher score. 63. Section Non-Radiological Air Quality and Noise While it is agreed that FC IA and IB will require more active maintenance A 4.1.4.2.1, Concepts IA&IB should be scored lower—there will be than will FC II,the authors consider that the presently assigned scores Page 49, considerably more maintenance in the long term associated with accurately describe the significance of this indicator for all concepts Para 5 these concepts than with II (i.e.,the hauling in of new construction ("interaction but no likely measurable change"). materials as key systems need to be repaired or replaced, as well as the removal of any components that need to be replaced). 64. Section G Demographics We disagree. Although it is true that the existing WMF has existed for N 4.1.4.2.5, Page The statement that the"existing population"has lived side-by-side many years and it is directly visible from Lakeshore Road, local residents 54, para 5 with a similar WMF"would probably be hotly disputed by the generally seem to be"comfortable"with its presence/condition. Perhaps residents. The existing site is"out of sight,out of mind". The report we could change the word"similar"to"radioactive". needs to acknowledge and discuss the residents'concerns, including that additional waste would be accepted in the future. The residents'concerns regarding the potential for additional waste are acknowledged and discussed under Section 4.3,Table 4-5. Comment Type—G: General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 Po�RTTHHoP Axe LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 18 of 36 ,AWO Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item No. Section, Page No.& Type* G,T, E Reviewer Comments Author's Disposition Status** A,I, N Para No. 65. Section Recreation The following statement will be added:"Although it still needs to be I 4.1.4.2.5, There should also be a discussion of making the existing WMF confirmed by the CNSC whether the land occupied by LLRW could be Page 55, available for public use under IB. As well,with the federal used recreationally, it is very likely that recreational use would be an option Para 3 government purchase of the entire Cameco holdings,there is some for the remediated portion of the site as well as for other federally acquired potential for additional parkland in the area. property." 66. Section T Housing and Property Values N 4.1.4.2.5, Add a citation for the claim about adverse effects to property values. Since the present conditions will be improved,then property values in the Page 56, Other clean-ups often show negative effects to property values long term will not be negatively affected. Para 1 It should be noted that the indicator question on housing and property values pertains to potential adverse effects over the long-term. Any short- term(e.g. during clean-up)will be mitigated by the Property Value Protection program. 67. Section G Aboriginal Interests The report and the associated scoring are based on the potential for N 4.1.4.2.5, While the existing site may have been an area of traditional hunting traditional hunting to occur based on preserving habitat notthat there is Page 57, in the past,we would like to see the data indicating that the Port data to indicate it occurs currently or that it will occur in the future. Para 1 Granby area is currently,or will be an area of traditional hunting. 68. Section 4.1.5.1, G Why were the costs of road and bridge upgrades not included? Are Yes,they are essentially equal for all of the concepts so it would not have A Page 59, they common for each of the concepts? had an impact in the relative scoring. Para 1 69. Section 4.1.5.1, G Capital costs presented here are in part based on toe berm It is acknowledged that the costs for the armour stone were validated as A Page 59, estimates provided in Table B.4-1 and Table B.5-1 in Appendix B. acceptable in 2002 and that these costs may have risen since then. Para 1 The unit costs for armour stone and rip rap in this table do not reflect However,this would strengthen the recommendation of proceeding with current costs. There was a substantial increase in the cost of FC II.As these costs do not affect FC ll,no additional investigations or armour stone supply last year. The current market prices for armour revisions are necessary at this time. stone are approximately double those used in the tables Comment Type—G: General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 P RHOPE�A LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 19 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office � Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi � Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item NO. Section, Page No.& Type" G,T, E Reviewer Comments Author's Disposition Status— A,I, N Para No. 70. Section 4.1.5.3, The report acknowledges that there could be several causes leading A detailed analysis was not performed to determine the likelihood for A Page 59, to invoking the Contingency Plan. The example of an"Act of God"is implementing the contingency plan; it was based on engineering Para 3 cited. Yet,the earlier Contingency Concepts report and peer review judgement.Although the difference is 5%itwas conservatively judged that of the same both express the view that Concept B2 had significant FCs IA and I B would be approximately twice as likely as FC II to require risks due to lesser causes such as failure of the cut-off trenches and contingency measures to be implemented.A more detailed analysis is not contaminant transport through groundwater. considered necessary at this comparative level. A revisiting of the assumption of the likelihood of implementing It is impossible to predict with any certainty what the regulatory regime contingency plans for Feasible Concepts IA and IB compared to might be in 150 years and thus to determine the level of effort required for Feasible Concept II due to these more probable and significant obtaining approvals.The large amount of uncertainty provides support to events would be welcome. Specifically,wouldn't there be more than implementing an option that has a lower likelihood of requiring contingency a 5 percent difference in likelihood and difference in cost between implementation.As this concurs with the recommendation for FC II no the Contingency Concept being implemented for IA and IB vs. 11? extra effort is required at this time. How was the likelihood of implementing the contingency plan (10% for Concepts 1A and 1 B and 5%for Concept 2)derived? These The method of determining the expected cost is explained in seem to be quite arbitrary figures, particularly if they include as Sections 2.2.1.5 and Section 4.1.5.3. The explanation will be expanded noted subsequently in the paragraph acts of God,war,changes in upon and a sample calculation provided. regulation, policy or preference. Would the failure of Feasible Concepts IA and IB require a new EA if the failure occurred 150 See also disposition of Comment#17 years from now in what could be a very different setting from that which exists today? It is clear that other, less expensive and disruptive contingency would be available. Also,the implementation of this contingency would likely require a new approvals process. The method of determining the cost of the contingency is not clear. The example cost calculation should be provided. The report currently seems to state that the contingency for Concept 1 A(i.e.relocation to a new waste management facility similar to Concept 2)could be implemented for$2,500,000. This should be clarified. Comment Type–G: General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PORIRTTHOP AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 20 of 36 ,AWO Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No. Type* G,T T E Reviewer Comments Author's Disposition t ** St atus Para No. , , I, N 71. Section 4.2.1, T Technical Considerations It is acknowledged that the results of the"additional studies"may confirm A Page 62, The table states"the ability of Concept 1 B to sufficiently limit that FC IB may not be feasible however due to the recommendation of Table 4-3 contaminant loading to Lake Ontario must be confirmed by implementing FC II the extra costs associated with the"additional studies" additional modelling(i.e.technical feasibility must be confirmed to a is not warranted. See Comment#25. higher level of confidence). This suggests that there has been insufficient work to confirm that Concept 1 B is a feasible concept. It is fundamental that this work must be completed before Concept 1 B can even be considered as a feasible concept and carried forward in the analysis. 72. Section 4.2.1, E Health and Safety Considerations Agreed. The word"perceived"will be deleted. I Page 62, This comment seems to juxtapose actual health and safety Table 4-3 considerations with perceived radiation risk. The two are quite different. 73. Section 4.2.1, T Environmental Considerations Both FC IA and IB could adequately protectthe environment. For FC IB, N Page 62, The pair-wise comparisons are very useful in understanding the pros the East Gorge slopes will be at a final grade of approximately 5(H):1(V) Table 4-3 and cons of concepts. However,we cannot come to the same and will be buttressed by raising the base elevation of the East Gorge near conclusion that IB is neutral on the matter of environmental the existing reservoir by approximately 5 m(see Figure B.5-1). We considerations compared to IA. We see IB has having larger consider this to be a stable condition for the East Gorge LLRW over the environmental risks over the long term because the approach is long-term. Furthermore, excavation of wastes along a slope is not an untried and the East Gorge Wastes are on a slope. untried approach. We therefore consider Concepts IA and IB to be neutral on the matter of environmental considerations. 74. Section 4.2.1, T Environmental Considerations No waste handling is already included under Health&Safety A Page 62, The list should include the advantage of no waste handling,which Considerations. Table 4-3 would therefore decrease potential air quality impacts. 75. Section 4.2.2, G Community Considerations Agreed,this will be added to the current advantage"Less effect on cultural I Page 63, Advantages of Concept II should include more publicly accessible landscape in long-term". Table 4-4 shoreline Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision '� Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 .�"'?PoKrHopEAREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 21 of 36 ,1WilO Irrnrn'r1vE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi �� ' < Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. on Secti , page on& Type G,T, E Reviewer Comments Author's Disposition � t lu N, Para No. 76. Section 4.2.2, E Technical Considerations The in-situ management options have already been optimized. N Page 63, Table 4 The use of redundant systems for leachate protection is seen as an The reliance on multiple independent systems is an inherent aspect of the -4 advantage for Concept 2. The design of Concept 1 B could be in-situ options and refers to the shoreline protection,bluff stabilization, low changed to include the use of redundant systems. The volume of perm cap and groundwater diversion barrier systems. Redundant systems marginally contaminated soils has not defined, but it is not clear how for each of these would make the concept much more costly. The in-situ this is a significant technical consideration. concepts cannot be redesigned to include a liner. Since the relocation concept involves essentially a single waste isolation system, redundancy can be built in, e.g., geo-membrane and clay components in the liner. The incomplete definition of volume of MCS poses a small disadvantage in that there is small riskthat the exact mound size may be moderately larger than design even though a contingency amount has already been applied. 77. Section 4.2.2, E Community Considerations The burden on future generations may be manifest in a number of ways, A Page 63, The advantage of"minimizes burden on future generations"is not including the monetary component,which is included under economic Table 4-4 clear. Is this related to economic considerations? considerations. Community considerations include reduced disruptive effects, administrative responsibility, etc. 78. Section 4.2.2, E Health and Safety Considerations Agree. A Page 63, The term"perceived"should be replaced with the phrase"increased Table 4-4 potential for". Waste handling will increase the risk, even if well managed. Furthermore, our review of Section 4.1.3 has been unable to identify Removing the term"perceived"should solve this concern. Concept II was I that"perceived"risk has been discussed as a factor. We suggest rated lower than IB for radiation risk to the public in Section 4.1.3 that given the findings of your analysis, Concept II is neutral compared to Concept IB. 79. Section 4.2.2, T Environmental Considerations Agreed,these will be added. I Page 63, The list of disadvantages should include the negative element of Table 4-4 handling more waste,thereby increasing potential air quality impacts. As well, Concept II has less construction material handling this should be listed as a positive—less environmental impact. 80. Section 4.2.2, G Environmental Considerations As Concept II involves the removal of all waste and MCS,there will be no A Page 63, It is not clear how Concept 2 will result in more improvement in on-going potential source of contamination. Further,there will be no low Table 4-4 ground water quality as compared to Concept 1 B. permeability cover to inhibit infiltration and"flushing"of contaminants out of the system and no groundwater cut-off to inhibit lateral groundwater flow and resulting"flushing"of contaminants. " Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POE RTTHoPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 22 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office ,Z Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi 'ACC Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, September 10, 2004 Charlotte Young Item Section, Page No.& Type* Reviewer Comments Author's Disposition Status"" No. Para No. G,T, E A, I, N 81. Section 4.2.2, T The comparison states that Concept IB is favourable to Concept II Agreed. However see the disposition to Comment#5. A Page 64, on the basis of Community issues. However,this largely rests on Para 2 the inability to return the site to agricultural land. As stated above, if the ability to return the site to recreational uses is given higher consideration, Concept II would perform well against Concept IB for this factor. 82. Section 4.3, G Can the perception of greater short-term effects(because of waste Quite likely, but we won't know the details until the effects assessment A Page 65, movement in Concept II)also be offset by demonstrating that the work is completed. Table 4-5, Row risks are negligible through analysis and sound radiological 1 controls? 83. Section 4.3, The following trade off should be added: Return of Lake Ontario Agreed,this will be added. I Page 65, shoreline to public use(which will balance out against the loss of Table 4-5, Row agricultural land) 2 84. Section 4.3, E Please clarify whether the LLRWMO is the Waste Management The 2nd sentence of the 3rd bullet will be revised as follows"In this regard a I Page 65, Organization responsible for finding a disposal facility for Canada's separate agency,created by the waste producers,is responsible for Table 4-5, Row ongoing LLRW(as the text appears to indicate), or whether the finding ...". NWMO's mandate is the management of used fuel. 3 waste producers,through the Nuclear Waste Management Organization (NWMO)are responsible for developing disposal facilities for Canada's ongoing LLRW. 85. Section 4.3, E In the"disposition"column,add a citation for point 3 regarding The following text will be appended to the To bullet"Refer to Section B.3 I Page 65, international experience and solutions to historical LLRW problems. for further discussion of experience with managing LLRW in other Table 4-5, Row jurisdictions." 3 86. Section 4.3, G The point about protecting the environment is not unique to this It is agreed that it is not unique. It is however included to emphasize that N Page 67, option,so it shouldn't be included here. the purpose of the contingency plan is to protect the environment. Table 4-5, Row 2 87. Section 5 G It is not clear, if Options IA or IB are selected,whether the road Although it is stated at the bottom of page 67 that a single route will be I through the Cameco lands to the north of Lakeshore Road would applicable for all three concepts,the following sentence will be added at still be considered. Even if the federal government is not intending the end of the paragraph for clarification"For FC IA and IB the haul route to purchase the land,the LLO could lease an easement through the would therefore include the portion of roadway proposed for the waste haul lands for a temporary construction access road. route under FC I I." Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author File name:PGQCCommentsFINAL.doc Updated on September 10,2004 A RPORT AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 23 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item Page Section, No.& G,T, E Reviewer Comments Author's Disposition Status** A,I, N Para No. 88. Section 5.1.1, E It is suggested that trucks may access the site using Wesleyville This option was considered but was eliminated later in the report.To be N Page 69, Road—this option was eliminated and therefore reference to it considered it must be included at this earlier portion. Table 5-1, Row should be removed from the table. 2 89. Section 5.1.2, T The following additional criteria regarding the transportation route It is agreed that these additional criteria and analysis may provide a more N Page 70, evaluation would be welcome: How many people(rather than robust evaluation. However the recommendation for the preferred route Table 5.2 dwellings)live along the haul routes? How is roadside property would not likely be affected by modifying the indicator.The land uses in the (front yards, driveways)used? Do people engage in farming or local area and adjacent to the potential routes are relatively consistent and other activities affected by dust? non-varied(mainly farming with some housing). However, a detailed environmental effects assessment of the Qualified Concept, including the preferred transportation route will be carried out as part of a subsequent phase of the EA process.This detailed effects assessment will be available for peer review by the Municipality.As with all aspects of the project, if any are found to cause residual adverse effects on the environment then mitigative measures(including use of other routes) would be implemented.This comment will be addressed as part of that assessment and/or during the detailed design phase of the project. 90. Section 5.1.2, T Weights for Sub-Criteria See Response to Comment#89. N Pages 70-72, Evaluation sub-criteria(for each of the main criteria)are implicitly Table 5.2 given equal weight It is inappropriate to give equal weights to many of the sub-criteria. For example, under Health and Safety Criteria, the Number of Intersections and Number of Level Railway Crossings are given equal weight—each crossing is scored with 1 point. From a traffic engineering perspective,this is not appropriate.A level rail crossing would have greater risk than a minor intersection; therefore, a level rail crossing should be given significantly greater weight.All sub-criteria should be explicitly reviewed as to their relative weights,for all of the evaluation criteria. 91. Section 5.1.2, T Scorinq Factors It is understood that the applied method is somewhat subjective. However, N Pages 70-72, Rather than using artificial"points"in scoring the alternatives, it it must be remembered that the purpose of the evaluation is comparative in Table 5.2 would be more appropriate in the detailed analysis to use actual real nature. In other words, a simple evaluation is sufficient. A full detailed measures,such as km,for all sub-criteria. effects assessment will be performed subsequent to the alternative means process to address specific concerns about potential adverse effects due to transportation(see also disposition for Comment#89). * Comment Type—G: General content comment,T:Technical Revision,E:Editorial Revision *` Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POIi AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 24 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. pSecti o.,8� Type* G,T, E Reviewer Comments Author's Disposition Status" A, I, N Para No. 92. Section 5.1.2, T Estimates should be provided about the number of truck trips that A conceptual estimate of the number of truck trips is included in Table 5-1 1 Pages 70-72, will be generated, in terms of daily trips, by what is carried,and truck of the report. It should also be noted that this refers to aggregate deliveries Table 5.2 size. This comment refers to all of the criteria,but is not a separate (about 99%of the identified trucking).Additional trucking(for less than 100 criterion.The number of truck trips affects the magnitude of impacts deliveries over the entire construction period)will be required for oversized and hence the relative importance of certain criteria. loads(i.e. large equipment)that may be unable to access through the underpass at the CPR line on Elliott Road.These additional trips will be explained in Table 5-1. 93. Section 5.1.2, T Health and Safety Criteria—Posted Speed Limit Due to the considerably higher number of residences and other uses along N Page 70, Posted Speed Limit is not an appropriate measure of pedestrian Lakeshore Road(which has a short segment of asphalt Table 5.2 activity. Furthermore,the risk to pedestrians is not only related to the boulevard/crosswalk)and Wesleyville Road there is strong agreement amount of pedestrian activity, but also how well pedestrian activity is between the reviewers and authors that routes using those segments are accommodated(e.g.sidewalks, boulevards,traffic signals). not preferable.As the other routes utilize common segments(with similar characteristics)of Newtonville Road and Concession 1 there is very little comparative difference regarding this concern. Health and Safety will be further evaluated on the preferred route during the detailed effects assessment.As mentioned in Comment#89, if it is found that there are residual adverse effects on the environment then mitigative measures (including use of other routes)would be implemented. 94. Section 5.1.2, T Health and Safety Criteria—Number of Intersections and Total Please refer to the disposition for Comment#89 and#93. N Page 70, Lenqth of Access Route Table 5.2 Number of Intersections is an overly simplified and not an appropriate measure of the likelihood of accidents,since collision potential is highly dependent on the design of and traffic controls at individual intersections.A more appropriate and accurate approach would involve assessing collision history,frequencies,types, and severity of collisions along the altemative routes.This approach would also replace the sub-criteria involving Total Length of Access Route. 95. Section 5.1.2, T Health and Safety Criteria—Number of Level Railway Crossings Please refer to the disposition for Comment#89 and#93.There is only I The number of level railway crossings, alone is an insufficient Page 70, one level railway crossing along this route at CN Rail. It has been identified Table 5.2 measure of risk. Ideally,a qualified safety specialist should conduct through discussion with CNR that this crossing would need to be upgraded a safety assessment for each level railway crossing,based on and that it is feasible to be meet CNR's requirements.Additional Transport Canada guidelines. documentation will be added to the report. 96. Section 5.1.2, T Health and Safety Criteria—Road Geometry Please refer to the disposition for Comment#89 and#93.Also see the N Page 70, Collision potential is affected by the horizontal and vertical alignment discussion from URS Cole Sherman in Appendix D.3 regarding horizontal Table 5.2 of the access roads.This sub-criteria should be added. and vertical alignment Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POK RTT�H�ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 25 of 36 ,AWO Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young I No Section, No.& G,T, Reviewer Comments Author's Disposition Status*" Page Para No. E A,I, N 97. Section 5.1.2, T Health and Safety Criteria—Road Cross-Section Please refer to the disposition for Comment#89,#93 and#96. During the N Page 70, Collision potential is affected by the cross-section characteristics of detailed effects assessment and the subsequent preliminary engineering Table 5.2 the access roads, such as number of lanes and lane widths.This phase the need for left turn lanes and traffic signals will be evaluated. sub-criterion should be added. Consideration should be given to constructing left turn lanes at points where trucks will be turning—i.e. Newtonville/Concession 1. Also, it may be appropriate to consider traffic signals to minimize the potential for truck//passenger vehicle collisions. 98. Section 5.1.2, T Health and Safety Criteria—No Sub-Criteria for Roadway Please refer to the disposition for Comment#89,#93 N Page 70, Operational Deficiencies Table 5.2 There is no sub-criterion dealing with roads that have existing traffic operations deficiencies. 99. Section 5.1.2, T Technical Criteria—Terrain Restrictions Please refer to the disposition for Comment#89,#93 and#96. N Page 71, This sub-criterion should be split into two. One sub-criteria would Table 5.2 address the horizontal and vertical alignment of the road 100. Section 5.1.2, T Technical Criteria—No Sub-Criteria for Roadway Capacity and Please refer to the disposition for Comment#89 and#93. N Level of Service Page 71, Table 5.2 A missing sub-criterion is impact on roadway capacity and level of service.Access routes that are already close to capacity and have poor levels of service should be considered in the analysis. 101. Section 5.1.2, T Environmental Criteria—Railway Crossings and Bridges Please refer to the disposition for Comment#89 and#93. N Page 71, Firstly it is unclear what new railway structures or bridge widenings Table 5.2 are required. Secondly,the rationale and need for these structures has not been explained.Thirdly,to assess the environmental impacts associated with railway crossings and bridges,the report uses 5 points per crossing. Rather than using this artificial criterion to represent environmental impacts,we recommend that the actual environmental impacts be shown in the analysis.This would provide far greater accuracy in assessing the actual impacts of these improvements. Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PORI T HonAx �a LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 26 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization:Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, page No.& Type G,T, E Reviewer Comments Author's Disposition Status A,I, N Para No. 102. Section 5.1.2, T Environmental Criteria—Length of Access Road Requiring Upgrade Please refer to the disposition for Comment#89&#96. For the preferred N Again,the report does not state what road sections need upgrading, Page 71, route, it has been identified that the Elliott Road segment will require major Table 5.2 the rationale and need for the upgrading, and the nature of the reconstruction.The impact of this work will be evaluated in the detailed upgrading. Since this sub-criteria is intended to measure effects assessment. environmental impacts,we recommend analyzing the actual environmental impacts,,rather than using an artificial and inaccurate criterion based on road length. This comment also applies to the sub-criterion—Length of Access Road adjacent to sensitive environmental area or woodlot. 103. Section 5.1.2, T Community Criteria-Number of Residences Please refer to the disposition for Comment#89. It will be stated in the I Page 72, Number of residences is used as a surrogate for population report that all buildings along all of the routes and specifically the Table 5.2 exposure. It should be confirmed that this is appropriate for the preferred route are of the single-family type. route assessment. Are there any multiple resident buildings along the route? 104. Section 5.1.2, T Community Criteria-Number of Residences Please refer to the disposition for Comment#89. In addition, it will be I Page 72, Has all potential new housing construction (within the time frame of stated in the report that there are no new significant housing developments Table 5.2 the construction activities)been identified and assessed? planned along the preferred route. 105. Section 5.1.2, T Community Criteria-Number of Residences Please refer to the disposition for Comment#89. In addition, it will be I Page 72, The distance from the road to the residence is important. On some stated in the report that the rejected routes all have residences that are Table 5.2 rural roads, residences are built very close to the road edge; others closer to the road than the residences along the preferred route.The were associated with farming operations and could be some preferred route has only three residences that are within 30 m of the road. distance from the road. Air quality impacts related to traffic One of these is on Newtonville Road which is common to all other decrease significantly with increased distance from the road. Given Clarington routes.The Lancaster, Nichols and Lakeshore Rd segments all the relatively few number of receptors along the routes,this should have residences with less than 15 m setbacks. have been considered in the haul route comparison. Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PI ORTHHOP ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 27 of 36 MUTrVE ,AWO Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. page ion, Type* G,T, E Reviewer Comments Author's Disposition Status** A,I, N Para No. 106. Section 5.1.2, T Community Criteria-Number of schools, community centres... As stated in the associated explanation(on page 77)except for Route 5 N Scoring for this group of receptors should be different from Page 72, there are no schools,community centres or recreational facilities along any Table 5.2 residential receptors. Schools are in during the day(major time for of the proposed routes.As route 5 was already determined as the least construction activity)and there is a much greater potential for preferred there is no impact on the evaluation. exposure(e.g.children in the playground)than at residential receptors. Churches are typically used on weekends and evenings when construction activity is not occurring. These should have a lower score than schools. Other potential facilities and residences need to be re-scored in a similar perspective. 107. Section 5.1.2, T Number of schools, community centres... Please refer to the disposition for Comment#89. There are no sand and N Page 72, Table There should also be recognition that different businesses could be gravel pits or open air restaurants on any of the alternative transportation 5.2 affected by traffic in different ways. If one of the businesses is a routes. sand and gravel pit,there would be no impact from traffic dust emissions. On the other hand, if the business is an open air restaurant,the impacts would be much greater. 108. Section 5.2.1.1, E Add%to column heading on"weighting"so that the reader knows The use of percentages for the Indicator Group weightings was I Page 75, what the numbers mean. intentionally avoided so that the final scores would be in the range of 100 Table 5-4 to 500.Additional text will be added to make this clearer. 109. Section 5.2.1.1, G We question why Route 5,which follows Lakeshore Road from the The segment in question is"Segment P"which is rated a high constraint. A Page 75, east, has the best terrain ranking, as the grade associated with the However,when the segments are combined,the overall terrain ranking for Para 2 valley near Townline Road is very steep. Route 5 is best. 110. Section 5.2.1.2, T Number of Residences Subdivision Plan 173 is very stable with no increased development for A, I Page 76, Since Subdivision Plan 173 is mentioned in the text as a significant many years and none planned in the foreseeable future(controlled by Para 3 feature, are there implications for an increased number of houses municipal by-laws).The text will be corrected to indicate that the area is that might be associated with the Plan and factored into the socio- east of Boundary Road. economic evaluation? We also believe that Plan 173 is east of Boundary Road in Port Hope, not west as indicated in the text. 111. Section 5.2.1.2, E Number of Livestock Operations The following text will be added to the end of the paragraph",the least of A, I Page 76, Please clarify that route 3 had the least operations by specifically all the routes." Para 5 stating this in the text. Comment Type—G: General content comment,T:Technical Revision,E: Editorial Revision " Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 WPORT HOPEAREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE NW INITrMW Page 28 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-0371 0-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& Type G T E Reviewer Comments Author's Disposition Status" Para No. ' A,I, N 112. Sections 5.2.1.3, T Human Health and Safety and Environmental Please refer to the disposition for Comments#89. N and 5.2.1.4 These two criteria are also strongly influenced by road length and receptors along the routes. For example,routes going past schools will present a greater safety risk than some other routes,yet this is not explicitly stated in the text and is not considered to be part of "human health and safety"but instead is considered under "community". Similarly,the environmental impacts increase with longer haul routes and with the number of receptors along the route,yet this is not considered under the"environmental indicators"it is only considered under"community". It is recognized that it would be inappropriate to double or triple count the same indicators in different criteria, but this should be discussed in the text and should then be recognized in the importance of the specific criteria and indicator. This might need to be reassessed with respect to how the weights and scores were derived. Was it understood as these scores and weights were developed that some of the safety and environmental indicators are actually part of the'community'criteria? 113. Section 5.2.1.3, T Posted Speed Limit Please refer to the disposition for Comment#89. N Page 78, Operational speed limits should be used rather than posted speed Para 1 limits, as many people will drive what they feel comfortable with. 114. Section 5.2.1.4, Number of Railway Bridges Requiring New Construction or This indicator specifically concerns railway bridges and there are no A Page 79, Upgrading bridges that require new construction or upgrades for Elliott Road. It is Para 3 The Elliott Road route also requires upgrading of rail crossings. acknowledged, however,that the Elliott Road route requires upgrading of a rail crossing. This is considered under the indicator pertaining to length of access roads requiring new construction and/or upgrading and the number of level railway crossings. 115. Section 7.0, G From a natural environment perspective,we recommend that the Agreed, arrangements have been made to augment the baseline A Page 82 baseline data study design be modified to collect data which will be characterization studies where necessary. more relevant to assessing potential impacts of this option and provide information necessary to develop a relevant monitoring program. * Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision ** Disposition Status Code-A:Accepted by Author, I:Incorporated Comment, N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 pO ARFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 29 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-0371 0-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& Type G,T, E Reviewer Comments Author's Disposition Status** t Para No. I, N 116. Appendix A-2, G The definition of the term"Long Term"should be reconsidered. The text"at least 500 years"will be replaced with"several hundred years". I Page A-5 While the concepts could arguably be considered as long term(i.e., durable for several hundred years),it may be difficult to demonstrate a 500-year life for the concepts. 117. Appendix B, G As a general comment,the previous experience is related only to Although the other facilities have been operating for a limited number of N Section B.3 the successful relocation of low level wastes to a new facility. In years,they do provide valuable precedents for the operation and most cases,the facilities either have not been completed or have construction phases as well as the background research conducted in the less than 10 years of operating experience. Therefore,these selection of their containment systems.This coupled with the advancement facilities could not provide any meaningful information regarding the of technologies in non-LLRW examples provides a strong basis for long-term(500 year)operating characteristics of a new facility,than proceeding with this project. can be gained from any other source(i.e.comparison to other types of waste management facilities that do not include low level radioactive waste). 118. Appendix B, G A fuller description of the structure of the purpose-build cell for The description provided is considered sufficient for this comparative level A Section 67, residuals management would be welcome. The complete of evaluation. A more detailed description will be provided as required for Pages B-6&B-7 characterization of the package coagulation plant and discussion of the detailed effects assessment. the environmental implications of various water treatment systems is required in order to assess net environmental effects. 119. Appendix B, G It should be made clear that the Passmore site is an interim holding The first paragraph of Section B.3.2.5 explicitly identifies the Passmore site N Section B.3.2.5, site only and not a long-term management site. Further,this type of as an interim site.Although it is an interim site, its construction is similar Page B-17 waste management site is not directly similar to that found at Port (but simpler)to that proposed for Port Granby wastes and therefore does Granby. provide useful precedence in above ground mound methodologies and technologies. * Comment Type—G:General content comment,T:Technical Revision, E:Editorial Revision ** Disposition Status Code-A:Accepted by Author, I: Incorporated Comment, N: Not accepted by author File na me:PGQCCommentsFINAL.doc Updated on September 10,2004 Aft PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE , VO� INITIMVE Page 30 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office ,//'7 Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi /0S Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item No Section, Page No.& T e* G,T, E Reviewer Comments Author's Disposition Status** A,I, N Para No. 120. Appendix B, T Has the low permeability cover system been evaluated to confirm LLDPE was chosen over HDPE because it has a greater elasticity and A Section BAA acceptable rates of infiltration for ensuring that flushing of therefore performs better under tensile stresses imparted by differential Page B-23, contaminants from the site is not a concern? settlement of the waste.Although the cover will be installed with strict Last Para quality control enforcement,it is standard conservative engineering Given that the cover system includes a low-density polyethylene practice to assume a very small amount of imperfections(i.e., pinholes). geomembrane(LLDPE),what is the source of moisture percolation The noted moisture percolation rate of 5 mm/year relates to leakage of (though expected to be less than 5 mm/year)?Will a high-density atmospheric moisture through such defects. We assumed 2.5(1.0 mm membrane(HDPE)perform better in reducing infiltration?Why was dia.)pinholes per hectare based on Giroud and Bonaparte(1989)to arrive an LLDPE chosen rather than an HDPE? at this preliminary estimate of percolation rate through the cover geomembrane. This magnitude of infiltration rate is considered sufficiently low such that flushing of contaminants is not a concern. The primary mechanism of contaminant release from the waste will be by diffusion which is driven by concentration gradients rather than by moisture percolation rate through the waste. 121. Appendix B, T As noted previously,the INTERA study must be reviewed to See disposition for Comments#23,#25,#35. A Section B.4.5, determine the requirement for the ground water diversion system. Page B-24 Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POE RTT HOP AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 31 of 36 mm Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item Page Section, No.& „ GT, E Reviewer Comments Author's Disposition A lu N* Para No. + 122. Appendix B, T Has the soil-bentonite cut-off wall been evaluated to confirm its Controlling groundwater flow by the use of a soil-bentonite cut-off wall is A, I Section 6.4.5, acceptability to adequately control groundwater?Has this common practice in waste containment design (e.g.see Sharma and Page B-25, technology been used elsewhere to control groundwater?How Lewis, 1994). Construction of the soil-bentonite cut-off wall would involve Para 2 would you ensure the durability of this wall in an underground excavating a 0.6 to 1.0 m wide trench extending through the Upper Sands environment? How would this wall be constructed('cut and cover'or and Lacustrine Silt Units and keyed into the low permeability Middle Till some other method)? Unit(approximately 20 m—25 m depth). The excavation would be carried out using an extended arm backhoe to about 20 m and then a clamshell to greater depths where required. During the excavation,the trench is kept full with bentonite slung,which stabilizes the trench wall. As the excavation advances,it is backfilled with an engineered soil-bentonite mixture(2 inch to 6 inch slump),which is prepared on the ground surface adjacent to the trench. The soil-bentonite backfill displaces the bentonite slurry as it is pushed into the trench. The cut-off wall is then capped with approximately 1 m of soil to protect against frost, erosion and desiccation. The cut-off wall is expected to be durable over the design life of the facility as it is comprised of soil minerals which are at the end point of their weathering cycle. Furthermore,the wall would not be susceptible to cracking under earthquake vibrations due to its plasticity and firm(rather than stiff/brittle)consistency. The performance of the wall would be verified by means of groundwater level monitoring downgradient of the wall (i.e. between the wall and the buried wastes)and comparison of the measured groundwater levels to modelling predictions derived using the design hydraulic conductivity of the wall. 123. Appendix B, T As noted previously,the clean-up of existing impacted groundwater As previously noted,although the length of time required for treatment of A Section B.4.6, is a key component for which more information must be obtained. It existing groundwater in FC II does need to be confirmed,there is sufficient Page B-25, is important to understand the time frame for which the system must confidence that it will be much shorter(short-term)than in FC IA and I Para 2 operate, and the associated maintenance works that will be (long-term)(see also disposition of Comment#30). Further analysis will required. be performed during the detailed affects assessment. 124. Appendix B, T Has the proposed procedure for excavation of East Gorge waste Based on the results of the Th-230 report by Stantec,the radiological A Section 4.8, been reviewed in terms of radiological risks, particularly thorium-230 concerns can be addressed with conventional open-air hazardous waste Page B-26 dust emissions?Does the procedure take into account the need to excavation control methods.The detailed affects assessment will fully reduce radiological risks to a level'as low as reasonably achievable evaluate this project activity and will identify any specific mitigation (ALARA)'? methods that may be necessary.The excavation procedure details will be developed during the Licensing phase.ALARA will be followed. Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision "' Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PORT HOPE AREA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 32 of 36 ww Imn T VE Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Od3 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young Item Page Section, No.& G,T, E Reviewer Comments Author's Disposition Status"" A, I, N Para No. 125. Appendix B, T One of the key contingencies for the new landfill is maintenance of It is agreed that pre-treatment of some of the wastes may need to be A Section B.4.10, the cover,which may be required as a result of settlement of the considered to ensure that adequate compaction is achieved. This will be Page B-27 waste. Pre-treatment of the wastes to improve their physical confirmed during the more detailed subsequent phases of engineering strength and minimize settlement of the cover should be considered. design. 126. Appendix B, T Earlier STF studies(STF Tech. Bib. No.389B, 1994)concluded that The STF studies assumed long-distance off-site waste transport over A Section B.4.10, containerization of the wastes would be a requirement since it public roads. Page B-27, provided a high level of control and isolation for the removal and Para 2 transportation of the wastes.Why have the current procedures During the initial stages of the alternative means evaluation it was rejected any containerization of wastes as a pre-treatment option? concluded that containerization of the waste is not required. However this option will remain available in the event it is needed to mitigate potential adverse effects. 127. Appendix B, T Why is a dual HDPE liner system not considered even though it is Based on our experience in modelling and monitoring of contaminant A Section B.4.13, superior in terms of leakage detection and provides some transport through liner systems and natural soil deposits,we consider that Page B-28, redundancy? Has the proposed composite base liner system been a single composite liner is sufficient in this case. For the proposed mound Para 3 evaluated in terms of infiltration and durability? How was the design,the low permeability cap represents the primary defence against thickness of the clay liner(0.75 m)chosen(for hazardous landfills in long-term exfiltration from the mound—the exfiltration can not be any the U.S. clay liners are required to be 3 feet thick)? greater than the infiltration through the cap,which would be on the order of millimetres per year. The performance of the cap would be verified by Has the effect of freeze-thaw episodes been taken into account in monitoring the amount of leachate that is pumped from the leachate the design of the cover system? collection system and by monitoring the leachate level with the mound. If required, based on the monitoring results,the cap is accessible for repair/replacement without disturbing the waste. The composite HDPE/compacted clay liner and the underlying 8 m to 12 m of relatively low permeability native till are considered more than adequate to protect against contaminant transport(primarily by diffusion)to the underlying more permeable sand and silt deposits. This expectation is based on the extremely low diffusivity of inorganic contaminants through HDPE, and the ability of the clay liner and underlying till to adsorb many of the contaminants found in the waste.This would be verified by means of conductivity sensors beneath the liner(over tens of years)and by groundwater monitoring wells(over the long-term). Comment Type—G: General content comment,T:Technical Revision, E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POE R TT HOPE Axe LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 33 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Od3 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office le� Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, September 10,2004 Charlotte Young Item No. Section, Page No.& Type* G,T, E Reviewer Comments Author's Disposition Status** A, I, N Para No. A secondary base liner system(i.e.adopting a double composite liner design), is not expected to significantly improve the overall performance of the leachate containment system in this case and therefore was not considered. There is no legislation in Canada that requires the use of a prescriptive base liner design, as is the case in the United States. Instead, it is common practice to carry out a site-specific design which takes into account the types of contaminants,the hydrogeological characteristics of the site and the potential for natural attenuation as an added level of defence against off-site contaminant impacts.A second liner would provide little benefit,would add significant cost, make the mound higher and/or deeper,would increase the construction time and cause significant increases in construction material transport along with the associated impacts. Detailed modelling for the performance of the leachate containment system will be carried out under the detailed effects assessment of the EA to confirm that the single composite base liner system is adequate. Ifthe modelling shows that a secondary liner system is required, it will be included in the detailed design stage of the project. The thickness of 0.75 m used for the compacted clay component of the base liner system is the current standard for Municipal Solid Waste(MSW) Landfill design in Ontario and is based on the extensive literature on clay liner construction, monitoring and performance modelling. While it is recognized that MSW has different types of contaminants compared to the Port Granby wastes, many of the contaminants in MSW(e.g.chloride, VOCs, organic acids and phenols)are typically more mobile through compacted clay than the LLRW contaminants such as Rae+, arsenic and thorium. Therefore,the 0.75 m liner thickness is expected to be adequate for the Port Granby WMF. As noted above,the adequacy of the overall design will be assessed as part of the detailed effects assessment and the thickness of the clay liner can be increased,if required. Freeze thaw episodes will not effect the performance of the cover system as an infiltration barrier for the reason that the geomembrane component (i.e.the primary hydraulic barrier)is not susceptible to frost damage;even if it was, it is covered by 2.3 m of soil/rock which is much greater than the potential frost penetration depth. Comment Type—G: General content comment,T:Technical Revision, E:Editorial Revision Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 PoRT H�oP APYA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 34 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen,Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi f11: Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10,2004 Charlotte Young iNo Page Section, No.& Gyp Reviewer Comments Author's Disposition Status** A,I, N Para No. 128. Appendix B, T Given that the HDPE liner acts as a key hydraulic barrier for the While the base HDPE liner will be the primary leachate containment I Section 8.4.13, long-term engineered containment of the waste, is it appropriate to element during the operating period until the final cap is constructed,we Page B-29, characterize the primary function of the HDPE liner as a short-term agree that it will continue to act as a diffusion/hydraulic barrier over the Para 1 one,i.e.restricting exfiltration during waste placement until the final long-term and contribute to the performance of the overall leachate cover is completed? containment system. The text on Page B-29 will be edited to reflect this. 129. Appendix B, G Retention of all construction records and waste inventories is It is agreed that more discussion is required in this regard.This will be A Section 8.4.17, required to be maintained in durable format for future use in done in subsequent stages of the project and is not considered to affect Page B-30 refurbishing or decommissioning of the facilities.All long-term the alternative means evaluation. monitoring records should also be maintained in proper format for 500 years. Permanent markers should be considered so that knowledge of the site details is not lost Some discussion on the final decommissioning of the site(at 500 years)is required. 130. Appendix B, T As noted previously,the excavation and relocation of the wastes to It is agreed that other less extreme maintenance type measures(repeated A Section B.4.18, a new facility is extreme. It is more likely that other less extreme repairs, partial reconstruction)would be attempted(under a long-term Page 31 contingency plans will be required. monitoring and maintenance program)before the ultimate contingency plan (relocation)is implemented.The Legal Agreement required the development of a contingency plan in the event of system failure.This is taken to mean general concept failure. 131. Appendix B, G Would the implementation of the Contingency Plan for IA and IB It is impossible to predict with any certainty whatthe regulatory regime A Section 8.4.18, also require anew Environmental Assessment study? Has this cost might be in 150 years and thus to determine the level of effort required for Page B-32 been fully reflected in terms of the long term cost liabilities of obtaining approvals.Any associated costs were therefore not accounted Concept IA and IB? for in the contingency cost Based on current requirements, it appears reasonable to assume that an EA could be required for FC IA and IB but would probably not be required for FC ll. Accordingly, if an EA cost of $10,000,000 is assumed,it would increase the contingency cost of FC IA and IB by$1,000,000(contingency cost x likelihood). Thus the total cost of FC 1A, 1 B and II would be about$45 million,$36 million and$32 million respectively. This would change the scores for the three concepts to 2.3, 3.0 and 3.4 respectively(i.e., no change in ranking) 132. Appendix B, It is stated that the on-site treatment of leachate from the east gorge Yes,the lower collection rate of 2,000-4,000 M3/year for Option 1A and A Section B-4.20, collection system will be on the order 2000 to 4000 cubic metres per 16 relates to the installation of the low permeability cover over the existing Page B-32 year. Later in the report on Page B-53, Section 8.6.2.1,this volume wastes and the installation of the upgradient groundwater diversion is stated as 3000 to 6000 cubic metres per year. Is this the result of system. the installation of a cover over the existing wastes in Concepts 1A and 1 B? * Comment Type—G:General content comment,T:Technical Revision,E:Editorial Revision ** Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 -A"PORT HOPE APFA LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 35 of 36 ,*d♦ INMMW Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Od3 January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office �/' Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm, Tony van der Vooren, September 10,2004 Charlotte Young Item Page Section, No.& * G,T, E Reviewer Comments Author's Disposition Status** A,I, N Para No. 133. Appendix B.5.4, T Please see comment provided earlier on the low permeability cover Please see disposition for Comment#120. A Page B-35 system for Concept IA. 134. Appendix B.5.5, T Please see comment provided earlier on the groundwater diversion Please see disposition for Comment#121. A Page B-36 system for Concept IA. 135. Appendix B, G Are the requirements for collection and treatment of the existing The requirements would be similar for Concepts IA and IB. While the N Section B.5.6, impacted ground water the same for Concepts 1A and 1 B? Are they collection system itself would be similar for Concept 11,the time required to Page B-36 also the same Concept 2? collect the impacted groundwater would be considerably less and the pumping rate considerably higher—see also disposition of Comment#30. 136. Appendix B, G The O&M cost items for Concepts IA and IB are identical. Given There is previous experience in placing low permeability caps on slopes. A Section B.5.15, that Concept IB involves untried capping techniques on a slope,the Although the capping on the slope would be engineered to require little Page B-42 maintenance costs for the capped East Gorge wastes(IB)will likely maintenance,it is agreed that it may result in slightly increased be much greater than the maintenance for the consolidated wastes maintenance costs. However,the major O&M costs associated with associated with IA. Concepts IA and IB involve maintenance of the shoreline and bluff protection works. 137. Appendix B, T Why was a single composite base liner chosen for Concept II Please see disposition for Comment#127. A Section B.6.3, despite the fact that this concept consists of total relocation of all Page B-44 LLRW and MCS and as such could be the most restrictive option in terms of containment requirements? 138. Appendix B, T Please see comments provided earlier regarding waste excavation Please see disposition for previous comments. A Section B.6.5, for Concept IA. Page B-45 139. Appendix B, G The expected life of the base HDPE liner of("...hundreds of years') See disposition of Comment#15. N Section B.6.5, needs to be specified. Fact Sheet B.3.ii of the Port Hope Feasible Page B-45 Concepts report indicates that a single liner is accepted by MOE to last at least 150 years, and a double liner can be expected to last at least 350 years. If the accepted life is 150 years,wouldn't liner replacement be necessary at that time? See disposition for Comment#127 Also,the same Port Hope Fact Sheet states, "Depending on the waste loading on the base liner, MOE Regulation for New Landfill Sites requires double composite liner design. Hazardous waste landfill sites in the United States(Subtitle C landfills)are also required to be constructed with double composite liner systems." How does the Port Granby site differ in characteristics from the double liner requirements elsewhere? Comment Type—G: General content comment,T:Technical Revision, E:Editorial Revision *' Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author Filename:PGQCCommentsFINAL.doc Updated on September 10,2004 POK RT HOPE AREA MAM ,AWO LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT OFFICE Page 36 of 36 Document Title: Port Granby Project Environmental Assessment PHAI Report No. Rev/Draft No. Date: Qualified Concepts Report LLRWMO-03710-ENA-13003 Oda I January 2004 Issued by(author): Golder Associates Ltd. Date: Issued to: Contract Supervisor: Low-Level Radioactive Waste Management Office Reviewed by: Paul Bowen, Tyrone Gan, Dave Hardy Phil Organization: Hardy Stevenson and Associates Limited Date: May 6,2004 Rick Rossi Niblett, Mohan Rao, Milo Sturm,Tony van der Vooren, September 10, 2004 Charlotte Young Item No. Section, page No.& Type* G,T, E Reviewer Comments Author's Disposition Status" Para No. A,I, N 140. Appendix B, G To what extent are construction materials required for regrading the Subsequent to waste removal,the existing site would be graded A Section B 6.16, excavated areas of the existing site for Concept ll, after materials (contoured)using imported fill material(as required)from the Lakeshore Page B-50 are excavated and moved? Road site. A preliminary estimate of the volume of material that might be imported from the Lakeshore Road site is 60,000 m3 which corresponds to an average fill thickness of 1 m over the waste excavation area of 6 ha. 141. Appendix B, T Regarding the contingency plan for the failure of the base liner Because re-excavation of the waste and MCS to permit liner replacement N Section B.6.19, system,the potential contingency plans of installing ground water is considered excessively disruptive to the environment, expensive and not Page B-52 purge wells or a reactive barrier wall would appear to be a limited required. solution. Why isn't base liner replacement considered? 142. Appendix B, Automated leachate pumping and on-site treatment is considered a It is agreed that leachate collection and treatment from within the mound is N Section 8.6.19, contingency plan in the event of failure of the cover. However,even a requirement The contingency plan would involve installation of purge Page B-53 with minimal leakage(10 mm per year)there will be production of wells and groundwater pumping from outside of the mound. leachate and the requirement for collection of leachate from the new mound. Therefore, it appears that leachate collection is a requirement rather than a contingency for Concept 2. 143. Appendix B, T We note that the bibliography includes no references to research on References will be added. I Sections B.7.1 HDPE and LLDPE geomembrane liners. Such references are and B.7.2 required. This block should be completed following discussions regarding author's disposition of reviewer's comments. *Note: Signatures are required priorto Reviewer's Signature Date approval of this completed form Author's Signature Date nlactive\2002\1300\021-1384 phai engin.support\engineenng task 10\qualified concepts\june 04,comments\pggc comments_dck2gv1-04 July 09.doc * Comment Type—G: General content comment,T:Technical Revision, E: Editorial Revision ** Disposition Status Code-A:Accepted by Author, I:Incorporated Comment,N:Not accepted by author File name:PGQCCommentsFINAL.doc Updated on September 10,2004 it Appendix E — Minutes from the LLRWMO Roundtables This appendix includes the minutes from two meetings / roundtables that the LLRWMO held at Newtonville Community Hall with members of the Clarington community, specifically those involved with the Southeast Clarington Ratepayers Association (SECRA). The first set of minutes is from a meeting held on March 17,2004. The second set of minutes is from the final roundtable discussion held on June 3,2004. 1 The minutes from the other roundtables are available from the Port Hope Area Initiative's 1 Project Information Exchange. l 1 , Peer Review Report of the Port Granby Project Feasible Concepts and Qualified Concept Reports Hardy Stevenson and Associates Limited September 2004 f ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND SECRA SLIDE TEXT INFORMATION DISCUSSION I VERBAL COMMENTS Session 1 — Presentation by the LLRWMO on their responses to questions raised by residents and SECRA during the consultation process Verbal comments recorded during the presentation are to the right of the slide text of the corresponding slide. The text was pulled out of the slides for ease of reading. I r P0,?THmLAmt We have grouped the questions that I Tkri� rEtir' have been raised into themes in order to answer them. ran b P` ,jec � A8UllriM JQ> s3 II This is just a quick reminder of the I overall purpose of the project. Purpose of Port Granby Project:p Y J It has been suggested here that � 500 years is not appropriate. I The purpose of the Port Granby Project is to provide safe, International convention focusses local, long-term management of historic low-level on 300-400 years. We would radioactive waste now stored at the existing Port Granby like to make the time focus more Waste Management Facility in Clarington. general but still many hundreds of years. Your concerns have been heard.Through I these Roundtable discussions and Hearing all Viewpoints: the Peer Review Team comments • Your concerns have been heard and we are here today to on our recommended qualified respond to the issues you have raised. concept from four perspectives • The recommendation presented by the LLRWMO this - health and safety,environment, spring results from extensive studies and consultation technical and economics, we have with all stakeholders, over the past 2 112 years. seen no reason to reconsider our 1 • The Roundtable Discussions with local residents recommendation. We have also and members of South East Clarington Ratepayers heard a number of community and Association are one more step in on-going consultation social concerns and have taken with all stakeholders in the Port Granby project. them into consideration.We believe that they can be mitigated either directly or through some sort of Designed and Facilitated by the Independent Facilitator- Ogilvie,Ogilvie&Company 3 I , i ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND SECRA SLIDE TEXT INFORMATION DISCUSSION I VERBAL COMMENTS design solution. We will able to bring specific mitigative measures to address these societal issues. Responding to Your Comments on... We fully appreciate that the local p 9 residents have an important interest • Safety of the above ground mound design in this project. • Environmental Assessment and Alternative Means processes • Excavating and moving the waste These are the themes that we have • Social factors—impact on your way of life arranged your comments into in Protecting property values order to respond to them here Social factors&future of the Port Granby area tonight. • Next Steps Design - Long Term Durability of the Mound (Bottom Liner System): 1. Geomembrane Component Conditions known to give premature failure of geomembrane We say that the liners are durable and will be absent(i.e.,high temperature,UV light,concentrated the technology is sufficient but chlorinated organic liquids) perhaps we need to supply more • Standardized durability testing has been carried out by proof. researchers since early 1980s(e.g. immersion testing in With respect to the geomembrane concentrated liquids, accelerated oxidation aging tests). component of the bottom liner Results support that: • Geomembrane is compatible with the kinds of system, the following statements chemicals in Port Granby wastes(e.g.high pH,arsenic, and supporting references demonstrate why we can say that uranium,radium, etc.) [Koerner,1990] the liners are durable and the • Oxidation at base of mound will not compromise technology is sufficient. Let's performance over 500 years design life [US EPA, 2002] review these statements related • Geomembrane is flexibleand can withstand vibrations due to the geomembrane component.(Samples of the material were to earthquakes. They have performed well in areas of high passed around to the residents). f seismicity(e.g. California)[Koerner, 1990] I Design - Long Term Durability of Mound (Bottom Liner System): 2. Compacted Clay Component • Examples of 1000 year old compacted clay dams exist [Schnitter,1967] • Conditions known to give premature failure will not exist (i.e., drying, freeze/thaw cycles, excessive differential settlement of subgrade) Clay particles are at the end point of their natural weathering cycle and will not undergo further natural deterioration • Standardized chemical compatibility testing documented in scientific literature support that performance will not be compromised by the types of chemicals in the Port Granby waste(e.g.,high pH,calcium,uranium,arsenic,radium,etc) • [Rowe et.al., 1995; Mitchell and Madsen, 1987] Compacted clay is moderately flexible and can withstand vibrations due to earthquakes. Examples of performance in areas of high seismicity(e.g.California)exist.[Goldman, et. al., 1990] 4 Designed and Facilitated by the Independent Facilitator-Ogilvie, Ogilvie&Company I I ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND SECRA SLIDE TEXT INFORMATION DISCUSSION I VERBAL COMMENTS Next we have the following comments Design - Monitoring for Mound and references related to the compacted clay component of the Performance: bottom liner. 1. Monitoring The clay liner is at the bottom of the Routine inspection facility and therefore not subject • Conductivity sensors within compacted clay liner to different natural cycles. • Groundwater monitoring wells along perimeter of mound We can have a high degree of confidence and along site boundary in the durability and suitability of • Water quality monitoring of stormwater management the liner technology. pond • Water quality monitoring in Port Granby Creek I Design - Contingency Planning: The following measures and actions • The comprehensive surveillance and monitoring program would be taken to monitor the would provide early detection of need for contingency performance of the mound. measures The surveillance monitoring program • Examples of potential contingency measures would give us early warning of • Collection/treatment of impacted groundwater within any situation that might need to I site boundary (e.g. using groundwater purge wells be addressed. We could install {I and/or interceptor trench) purge wells around the facility or • Repair/improvement of cover system an interceptor trench around the facility. We could also repair or make improvements to the cover system if required. Environmental Assessment Process: • The proponent (LLRWMO) is required to consider the The Responsible Authorities conducted relocation concept as an alternative means in the Scope public consultation on the draft of the Environmental Assessment which was written by scope of the Environmental the Responsible Authorities(NRCan,CNSC, DFO) Assessment. This is a screening • The ResponsibleAuthorities conducted public consultation assessment, but far more of the draft Scope and decided to require the consideration extensive. of the relocation option as an"alternative means" I • As required by the Scope,this is a screening assessment but conducted in far more depth and with extensive public consultation Alternative Means Process: For both in-situ concepts, the • Both in-situ concept designs were optimized and then engineering team optimized the compared with the relocation option. designs prior to the alternative • means evaluation. • Because of the complex combination of factors such as: I• slope stabilization, • groundwater remediation, • groundwater flow cut-off technology, • on-going leachate treatment, i • shoreline erosion control structures and { • the lack of a liner, • No potential redesign would make the in-situ option as good as encapsulation of the waste away from the lakeshore. 1 Designed and Facilitated by the Independent Facilitator-Ogilvie, Ogilvie&Company 5 ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND SECRA SLIDE TEXT INFORMATION DISCUSSION I VERBAL COMMENTS A Comments: The Responsible Authorities • Natural Resources Canada stated that the 1978 commented on the Feasible Federal Environmental Assessment Review Panel and Qualified concepts brought recommendation on the Eldorado proposal for a refinery forward. and a short-term low-level waste storage facility does not Natural Resources Canada addressed apply to this Project in a letter dated 22 May 2003. the applicability of the 1978 EA • CNSC has stated that all feasible concepts are licenseable, review panel. but that the in-situ option would likely be more difficult to CNSC stated that the in-situ option license due to potentially higher risks and moretechnical may be more difficult to license challenges to ensure public safety.(8 Oct 03 RA/LLRWMO due to higher risks, technical Minutes) challenges etc. • Fisheries and Oceans has stated that because of potential DFO's policy is that if there is an harm to fish habitat the in-situ concepts would not alternative available,do it rather be DFO's preferred option where a viable alternative than disrupt fish habitat. (relocation) exists.(8 Oct 03 RA/LLRWMO Minutes) Waste Handling Issue-Excavating This is at the heart of the difference of the issues. We believe the waste and Moving the Waste: can be excavated and transported • Experience shows that waste containing radioactive safely. There is a lot of US material (including Thorium 230) can be moved safely experience in doing this.,St.Louis, (Stantec 2003). Tonawanda New York, Maywood • In the US, excavating and moving low-level radioactive New Jersey and many others.The waste safely has been done frequently New Jersy example is interesting • Army Corps of Engineers, Department of because it is similar to the Port Energy Hope example. Please see a US • e.g. St. Louis, Missouri, Maywood, New Jersey example on page 14. Essentially, ' and Tonawanda,New York experience shows that the waste • In Canada,the LLRWMO has nation-wide experience and can be removed from the site and has developed procedures for safe handling of waste that transported safely. { are appropriate to each unique project f Methods of Handling Waste: We apply lessons learned from other • Public and worker safety are paramount in all LLRWMO projects. Human health and safety projects are the overriding considerations. • Lessons learned from past projects will be applied The characterization of the waste • Careful consideration will be given in the environmental is well-known to us. The records eff ects assessment to all components of the Port Granby from Eldorado were quite accurate environment, but human health and safety override all in terms of knowing what is in the other considerations site. • Characterization of the waste is well understood,based on scientific investigation techniques and unique historical knowledge available in the community and the project partners We are not sure that the social impacts would be any less, Social Issues - Potential Disruption regardless of which option (in- situ or encapsulation) were to of Port Granby Way of Life: be implemented. We draw on How can we reduce the impact of constructing a facility? previous experience,work with the • Draw upon our previous experience and other Canadian municipality and the residents. projects We have Tom Wlodarczyk here tonight Work with you on social and economic effects assessment who is doing our socio-economic and mitigation measures, such as: work. We plan on doing surveys and 6 Designed and Facilitated by the Independent Facilitator-Ogilvie, Ogilvie&Company ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND$ECRA Comments prompted by the concept of the site(note and mentioned some community committees,would that this was slide 21 during the presentation): water monitoring be part of that? Response: Yes, that is possible. i Question: If this is the new mound. What are the Question: There was some information about a LLR- blue rectangles on the drawing? WMO telephone survey for the residents of East Response: They are new water treatment ponds. Clarington. Were the residents of western Port The wastes are going to take a number of years Hope who live near the Port Granby site included? to be moved, so the water that accumulates Response: The survey included residents of both within the new site, until such time as the cap clarington and port hope selected on a random and cover is installed, needs to be treated. basis but we will confirm wheteher the people Question: Do you have a mound like this in exis- of western Port Hope were included in the Port tence? Granby survey. Response: Yes, there are a number of precedents, Sue investigated and found that the Port Granby both built and under construction. area calls were made by postal code district and all of rr 8 newcastle(11b 119 was included). Weldon Springs, Missouri, constructed from That means that Lakeshore Road and East 1997 to 2001, the aboveground mound has Townline Road residents of Port Hope were an 18 hectare footprint and accommodates included in the survey. 1,130,000 cubic metres of low-level radioac- tive waste and marginally contaminated soil. Question: What happpens when you have 15-30 rum- Note - A High School with 2,000 students has bling trains passing by the site everyday? been located 1/2 mile away from the site for Response: The mound is a couple of hundred over 30 years. metres away from the tracks and the liner is At Edgemount Mill in South Dakota, over 2 million flexible so that it would withstand that type cubic metres of uranium mill tailings are man- of vibration. In california there are cases aged in an engineered disposal facility closed where there have been earthquakes up to a since 1989. 6 and there has been no damage done to the The Connonsburg Pensylvania site accomodates facility. 145 000 cubic metres of low-level radioactive We (LLRWMO) have looked into it. Whether it waste and contaminated materials in an above- is from an earthquake or trains, we have the ground mound facility completed in 1985 and now evidence to show that the facility can withstand located in a residential area of the city. either type of vibration. Canadian examples are the low-level waste man- Follow-up Question: Do you(LLRWMO)have specific agement projects at Passmore Avenue in Scar- proof of how the liner will withstand the CON- borough, and at Fort McMurray in Alberta. STANT vibration from 15-30 trains every day? Question: Are they subject to the same weather Response: A specific example of this might be the swings? Keele Valley Landfill Site that has a rail line on the western perimeter of the site. from Response: In South Dakota yes. an engineer's perspective, the clay has the Question: Are they near residential areas? effect of dampening vibration. Then consider Response: Yes, please see the picture on the the fact that the liner is flexible. We can in next page. the detailed design stage, do computer model- ling to investigate this issue in greater detail, if required. Question: Will the property be owned by the Federal I Government? Robb: Are you prepared to provide the group the Response: Yes, it is in the legal agreement. literature and evidence of vibrations? Your pro- fessional opinion is that it wont have an effect. Question: Will other streams other than Port Granby It is also possible to investigate this through dif- Creek be monitored? ferent modelling techniques during the detailed Response: Yes, that will be investigated. design stage. Follow-up Comment: There is running water in the valley system located some 400 to 500 metres east of the current site. Robb: Slide 14,you had some examples of concerns Designed and Facilitated by the Independent Facilitator- Ogilvie,Ogilvie&Company 9 f ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND$ECRA f f ,Y r Cannonsburg Pennsylvania fReports on the Clary Liner (for thickness itself is about 12 or 13 m of waste provided on top of the liner for protection. The cap is further information), p not susceptible to damage from freezing. It by Dr. Frank Barone from &older will be covered by 2m of material. They use geomembrane material to line facilities in the Associates: Arctic, so it can withstand cold. Bonaparte, Rudolph Ph.D., P.E., David E. Danniel, Ph.D., P.E. and Robert M. Koerner, Ph.D., P.E.. Question: With regards to the liner, how are you "Assessment and Recommendations for Improving going to get the waste in the hole? Drive over it? the Performance of Waste Containment Response: You don't drive directly on the liner. Systems".EPA Cooperative Agreement Number Any road has between a metre to a metre JCR-821448-01-0. December, 2002. (Project and a half cover, so the liner won't be com- Officer - Mr. David A. Carson, United States promised. Environmental Protection Agency, Office of Research and Development, National Risk Question: There will be no other waste coming to f Management Research Laboratory, Cincinnati, the site? OH 45268) Response: The high level waste will not be coming Goldman, L.J. and L.I. Greenfield. "Clay'Liners to the site, say from Darlington or Pickering f for Waste Management Facilities, Design, generating stations. It is not suitable. We Construction and Evaluation". Noyes Data (Municipality of clarington) can ensure this in Corporation,New jersey,1990. ISBN:0-8155- writing to note that wastes not associated with 1227-9 the port granby facility will not be accepted. f Rowe,R.Kerry, Robert M.Quigley,John R.Booker. "Clayey Barrier Systems for Waste Disposal Question: Our(resident)land is beside Elliot Road,do Facilities". E A FN Spon,an imprint of Chapmand you know how you are going to get over that track? &Hall, England, 1995.ISBN: Have you met with CN about your transportation? f 0-419-19320-0 Response: Our(LLRWMO)transportation consul- tants have looked at this. They have inves- Question: Doesn't the liner get brittle as it gets tigated the site. As part of the conceptual colder? design work, our transportation people have Response: Yes, but what we(LLRWMO) have done said that we can change the approach grade to is make sure that there is enough cover over the the site. There is currently an existing grade liner to prevent it from freezing. The liner will to railway crossing, and Transport Canada f stay well above the freezing point. The waste says that is an acceptable crossing. Their only concern is that signals and a gate may 10 Designed and Facilitated by the Independent Facilitator-Ogilvie, Ogilvie&Company I i ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND SECRA be required. It is anticipated that there will that is not acceptable to the community. be short periods of time during which the raw If the waste has to be moved,it should be materials will be deliverd to the site. The first a minimum distance (just across the road). + year and the last year are expected to be busy They don't talk to us. They need to start times for transportation. consulting the public. 3)The method of storage is not a scientifically Question: Are you (LLRWMO) examining the spur proven method. It is inadequate and line idea? unproven. Liners are prone to rupture. Response: Yes. If it does, there will be an environmental disaster. Question: I (resident) can't see how you can get 4)The future of the Cameco lands. We want trucks over the level crossing on Elliott Road. Are to see an Act of Parliament to protect the you considering all of the trucks going through there site from accepting more waste. on a level crossing? CN approves of that? Did* We want them(LLRWMO)to look at other systems CN try to close this crossing at one time? -other than a single mound system. Response: Yes, it is currently a level crossing. I Question: To move the waste,it will take a couple of (LLRWMO) have to trust our engineers who are years? What happens at the time,when there is no looking at that to determine if it is feasible, cap on the waste- it could blow around? We have spoken to experienced transportation Response: While the material is being placed, engineers and they said it was feasible. The there are various methods of making sure it next step is the detailed design. I understand doesn't become airborn. For example, it can't that CN was trying right across Ontario to blow around following placement of daily cover. close many underutilized crossings to reduce We will use thoushands of cubic metres of maintenance and other costs. This crossing, clean soil to provide daily cover over the placed as I understand it, was one of those. waste. My (LLRWMO) concern is that it will result in several tens of thousands metres of cover soil in the mound. I (LLRWMO) have Robb: We will note Jean, that you are not satisfied asked that other technologies be looked at to with the answer you got. keep a cover on it. One idea that was sug- gested by the Community Advisory Committee Comment: is a foam cover. We(SECRA)have not heard any serious reason Comment: A thousand year old clay dam vs. a com- given today, that the waste should be pacted clay liner - a clay dam can in no way be moved. It is just that the in-situ option is compared to a thin layered clay liner. A friend of more complex. If you stop the water and mine, has found that a compacted layer of clay in f put the same cover on it,it won't make any his fish pond is simply not watertight. 4 difference. The thing that you have to do Response: This is much more than a fish pond is stabilize the bluffs. This is the problem that is being built. There are several impor- - engineers mindset is not to listen to the tant steps to follow during the installation of a I citizens. I distributed a brief on March 17 clay liner. The main thing is to keep the liner detailing why the mound is a bad concept. The community has always objected to covered and compressed. moving the waste. They are going to do Question: The alternative means assessment, I a snow job. They haven't really answered (SECRA) have a letter from the Minister David our questions. We want certain issues Anderson. He did not answer my question.I asked addressed. One was transportation , two him to make a ruling that this is an alternative to, was Bringing material in, and the third not an alternative means. is Digging the waste up. Your method of These engineers have a thing for mounds. digging the waste is irresponsible. You I talked to one of the project staff in the are not prepared to talk to us about your US and it takes three weeks to get an air i thinking. I want them to answer all of these emissions sample back.That does not instill questions. If they want to answer these confidence. questions, they should have responded to Your maintenence requirements are not the written brief I gave them. possible for 500 years. This is going to be 1) If the waste has to be moved, we want a an on-going probem from year to year to satisfactory way of moving it. They need year. If you go down several metres you to sit down with us. will be in the middle till that is impermeable. 2)Location of the waste. They picked a place If no water can get in, then none can get Designed and Facilitated by the Independent Facilitator- Ogilvie,Ogilvie& Company 11 i ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND$ECRA out. My opinion is that you are biased about Response: The qualified concept report explains the relocation option because you are too the advantage of the new encapsulated mound scared to stand on your own two feet and vs, the in-situ option. From and engineering think for yourselves. technical standpoint, I (LLRWMO - engineer) can build-in redundancy into the mound. For Comment: Engineering phsycology says that they (en- the in-situ, I can't. The in-situ concept relies gineers)tend to get stuck on familiar ideas. on three technical engineered systems working together, and if any one of them fails, there Robb: Because people don't agree with you, doesn't is the potential for leakage. I can't build any mean that they are not listening. Do you agree contigencies into that plan - I can throw a lot with that? of engineering at it, but I cant guarantee it. With the encapsulating mound, I can design the Response: NO. contingencies. If the cap fails, the liner will catch it. If the liner fails, the cap is keep- II Comment: There is a letter here that says that there ing the rain off of it and if everything fails, has been a lot of consultation regarding the project. then there is natural protection provided by I(resident)would say though,that there has been the upper till layer on which the facility would no participation. be constructed and by being away from the lake. Comment: The property value program- the system you (LLRWMO)have designed is relating to the life of the project. We are talking about the impact of Note:Members of the group stated that they do not radioactive waste being dumped in our backyards for accept those arguments. the next 500 years. They are not listening. That problem is not going to go away. Question: Are the treatment ponds just tempo- Question: Is the resolution that we are definitely rary? moving the waste?(resident) Response: Yes, while the waste is being moved, Response: We (LLRWMO) are going through the and for a few years afterwards. process of the alternative means evaluation and finalizing the report. We are looking to the Question: Where will the treated water go? municipality to concur with the recommendation. Response: The treated water would go to Lake If they do, then it will go on to the next step, Ontario, after treatment. The design of the which is licensing. The Municipality is reviewing ponds would be such that they would be disigned the information right now. to take flooding into consideration. Question: What the residents are saying has no im- pact? Is that their (LLRWMO)position? i i i I ROUNDTABLE DISCUSSIONS WITH PORT GRANBY RESIDENTS AND SECRA engineers have recommended in their professional opinion to move the waste. They have chosen to agree to disagree. Comment: If they(LLRWMO)would give the in-situ as much consideration and work as the relocation option, we (residents)might be more satisfied. Question: What are we(residents/SECRA)supposed to do next? I Robb: I can't advise you on that. You have been involved and courtious by coming out to these ses- sions. Comment: We(residents)recieved the survey. Are you(Tom Wlodarczyk from Gartner Lee Limited)prepared to accept the survey directly from us? Response: Yes. Comment: In response to Jean's comments about not speaking to council. Councillor Trim has put a motion forward for a half day workshop with an independent facilitator,the residents,council and SECRA to discuss issues in September. How do you want us(Municipality of Clariington)to proceed? Who do you want to be the facilitator? Where would you like to hold the workshop? How would you like it structured (e.g.do you want to present to Council)? Response: We (SECRA) are going to have a meeting of our own, and we will consider this then. I thought we were going to have a dialogue. That is not what we get. We are looking for a change in attitude. I f I I