HomeMy WebLinkAboutPSD-012-03
.~~ 4~
'"
Cl!Jl-!l!glon
REPORT
PLANNING SERVICES
Meeting:
GENERAL PURPOSE AND ADMINISTRATION COMMITTEE
PSD-012-03
7)03
PLN 26,10
6m-{};Z:)-o 3
By-law #:
Date:
Monday, January 20,2003
Report #:
File#:
Subject:
DRAFT ENVIRONMENTAL ASSESSMENT STUDY REPORT FOR THE
USED FUEL DRY STORAGE FACILITY PROPOSED ON THE
DARLINGTON NUCLEAR GENERATION STATION LANDS -
COMMENTS
RECOMMENDATIONS:
It is respectfully recommended that the General Purpose and Administration Committee
recommend to Council the following:
1, THAT Report PSD-012-03 be received;
2. THAT Report PSD-012-03 be approved as the comments of the Municipality of
Clarington on the document entitled "Darlington Used Fuel Dry Storage Project
Draft Environmental Assessment Study Report", dated November 2002;
3, THAT the CNSC extend the comment period for the draft screening report from
30 days to 45 days;
4, THAT a copy of Report PSD-012-03, a copy of IER's "Review of Ontario Power
Generation Draft Environmental Assessment Study Report" dated December
2002, and Council's resolution be forwarded to the Canadian Nuclear Safety
Commission (CNSC) and Ontario Power Generation; and
3, THAT all interested parties listed in this report and any delegations be advised of
Council's decision.
609
"=-
.j'~ ,~
REPORT NO.: PsD-012-03
Submitted by:
D i ,Crome, M,C,I.P"R.P,P,
Director, Planning Services
HB*DC*df
8 January 2003
PAGE 2
Reviewed byQ ~~ ~
Franklin Wu
Chief Administrative Officer
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1C 3A6 T (905)623- 3379 F (905)623-0830
610
, ,~ ., ""4
REPORT NO.: PsD-012-03
PAGE 3
1.0 BACKGROUND
1,1 Staff reported to Council in April 2002 (PsD-027 -02) that Ontario Power
Generation (OPG) is proceeding to gain the necessary approvals to construct and
operate a used fuel dry storage facility at their Darlington site. At that time, the
Municipality provided comments to the Canadian Nuclear Safety Commission
(CNSC) on the draft Environmental Assessment Guidelines. On July 26, 2002,
the CNSC released the final Environmental Assessment Guidelines. In response
to this document, OPG prepared the "Draft Environmental Assessment Study
Report - November 2002" (draft Study Report) which was released by the CNSC
on November 20th, 2002. The CNsC is requesting that all written comments
regarding this document be provided by January 31, 2003.
1,2 At the November 18th, 2002 meeting of Council, IER-Planning, Research and
Management Services (IER) was awarded the contract to peer review the draft
Study Report, related technical documents and the draft Screening Report (COD-
57-02). The scope of IER's work includes; confirmation that the requirements of
the final Environmental Assessment Guidelines have been complied with, peer
review the draft and final Study Reports ensuring that the CNSC's requirements
have been fulfilled, and review the draft Screening Report that will be prepared by
the CNSC. IER have finished their review of the related technical documents
(background documents prepared by OPG in support of the project) and the draft
Study Report. An executive summary of IER's findings is contained in Attachment
1 and the full report has been forwarded to Council under separate cover.
2.0 DESCRIPTION OF THE USED FUEL DRY STORAGE FACILITY AND
CONTAINERS
2.1 OPG selected Site B as the preferred site for location of the facility, This site was
compared to three other sites, all located on the Darlington property (Attachment
2). OPG determined that no other site offers a significant advantage over Site B.
Site B is a relatively flat area located east of the parking lot servicing the
Engineering Support Services Building.
611
",",
REPORT NO.: PSO-012-03
PAGE 4
2,2 The detailed design and layout of the facility has not been finalized, but OPG has
prepared a conceptual layout of the facility (Attachment 3), It is proposed that the
completed structure will consist of a processing area and three storage areas
surrounded by security fencing. Each storage building will hold approximately 500
of the used fuel dry storage containers, A processing area and one storage area
will be built immediately after all approvals have been received. The 2 other
storage areas will be added when needed, The buildings shall be designed and
constructed in accordance with the Ontario Building Code and OPG will be
required to enter into a site plan agreement with the Municipality prior to issuance
of any building permits for this facility.
2,3 The used fuel dry storage containers are approximately 3.5 metres in height and
2.5 metres in width and hold 384 used fuel bundles. The container is made of
reinforced high density concrete with a steel inner liner and a steel outer liner.
The cap is welded shut and x-rayed to ensure there are no cracks in the welding,
Each storage unit has a security seal attached to it by an Intemational Atomic
Energy Agency (IAEA) inspector. A total of 1,378 used fuel dry storage
containers will be required to house 529,000 used fuel bundles anticipated to be
generated during the 40 year operating life of the generating plant.
2.4 It is anticipated that the used fuel dry storage facility will continue to be in
operation for 10 years after shut down of the last of the four reactor units.
Decommissioning of the facility will then begin and will be subject to a separate
licence application. Decommissioning can only begin after all the used fuel dry
storage containers are removed. OPG has not addressed decommissioning of
the used fuel dry storage containers as they are awaiting the outcome of the study
addressing the long-term storage of nuclear fuel as required in accordance with
the "Nuclear Fuel Waste Act" passed by federal parliament in 2002.
612
~ .\,.
REPORT NO.: PSO-012-03
PAGE 5
3.0 COMMENTS
3.1 Generally, IER found the work conducted by OPG, including the draft Study
Report and the related technical documents, to have been carried out properly
and to be consistent with good environmental assessment practice. IER did
identify two areas of major non-compliance with the final Environmental
Assessment Guidelines. IER also identified areas that require clarification or
improvement, and some areas where additional information would enhance the
draft Study Report.
3.2 Calculation of Dose of Radiation
One area of non-compliance deals with the significance of the dose of radiation
that may be received by a non-nuclear energy worker if an accident occurred
during transportation of the dry fuel container from the plant. Radiation dose
calculations were prepared only for a nuclear energy worker in this scenario. As
the transportation route for the dry fuel containers passes beyond the protected
area, the probability of an accident involving a non-nuclear energy worker
increases,
IT is recommended that the CNSC request OPG to investigate the
significance of dose to a non-nuclear energy worker during the
transportation of the used fuel dry storage container, identify mitigating
measures, and assess the impact differing results may have on the choice
for the preferred site.
3,3 Lonq-Term Inteqritv of Used Fuel Dry Storaqe Containers
The second area of non-compliance consists of a lack of details regarding the
long-term integrity of the used fuel dry storage containers, The Municipality
commented on the draft Environmental Assessment Guidelines that the integrity
of the used fuel dry storage containers be examined in more detail. Although the
CNSC did not change the final Environmental Assessment Guidelines to include
this requirement, they did request OPG to address these concerns and to provide
613
, 't.' ~_,
REPORT NO.: PsD-012-03
PAGE 6
additional information on the design of the used fuel dry storage containers in the
Study Report.
IT is recommended that the CNsC request OPG to provide additional
details regarding the design and long-term integrity of the used fuel dry
storage containers.
3.4 Preliminary Decommissionina Plan
The final Environmental Assessment Guidelines specified the documentation
regarding the preliminary decommissioning plan. The information provided by
OPG is brief and does not fulfill the requirements as established by the CNSC.
IT is recommended that the CNsC ensure that the level of detail as required
by the final Environmental Assessment Guidelines regarding the
preliminary decommissioning plan be provided.
3.5 Follow-up Monitorina and Mitiaation Proaram
The CNSC, through the licensing and compliance program, will ensure that
appropriate feasible mitigation measures are implemented and that the follow-up
monitoring program is implemented. The purpose of the follow-up monitoring
program is to determine that the environmental effects are as predicted and that
the proposed mitigation measures are effective, If the implemented mitigation
measures are ineffective, new mitigation measures would be justified,
Details of the follow-up monitoring program will be fully developed by the CNSC
in consultation with appropriate stakeholders, including the Municipality of
Clarington. This consultation will take place prior to the construction of the facility.
Details provided by OPG in the draft Study Report regarding the follow-up
monitoring program is a good starting point, but should be developed further.
614
, ,~ , ,';.
REPORT NO.: PsD-012-03
PAGE 7
IT is recommended to the CNsC that more details be provided regarding
the follow-up monitoring program and mitigation measures at this time.
3,6 Water Resources
As part of the environmental assessment, existing surface water and
groundwater conditions must be identified and potential impacts to these
resources acknowledged, The draft Study Report identifies that on the preferred
site (Site B), the water table can be found approximately 1 metre below the
ground surface. It is not clear how OPG has addressed the location of the water
table in it's consideration of Site B as the preferred site nor has the potential for
contamination of the water table been adequately dealt with in the "Assessment
and Mitigation of Likely Effects of the Project".
Two existing drainage ditches will require relocation on Site B. The impact of
moving or elimination of these drainage ditches. is an important environmental
effect and should be given due consideration.
IT is recommended to the CNsC that OPG clarify how the impact of a high
ground water table was assessed at Site B and what impacts will result
from the relocation or elimination of 2 existing drainage ditches on Site B.
3,7 Other Areas
A number of areas that would benefit from clarification or the provision of more
detailed information include, in part:
)- A traceable process for the evaluation of alternative locations for the
facility;
)- Provision of consistent criteria for the development of accident scenarios
considering integrated conventional and nuclear consequences;
615
,
, "
REPORT NO.: PSO-012-03
PAGE 8
>- Additional information on the extent of public input into the selection of
Valued Ecosystem Components (VECs);
>- Whether the cumulative effects of this project, in combination with other
projects and activities, result in a significant cumulative environmental
effect;
>- The Aboriginal Interests component of the study requires identification as
to whether the criteria established for spiritual and cultural meaning was
appropriate and whether Traditional Knowledge was considered as a
source of information.
The executive summary contained in Attachment 1 provides additional
suggestions of areas for improvement.
3,8 Consideration of the Municipality's comments on the draft Study Report, as well
as those received from other agencies and interested parties, will be undertaken
by the CNSC. If necessary, the CNSC may request OPG to make appropriate
changes, Upon completion of these changes, OPG will resubmit the final Study
Report to the CNSC where it will be reviewed and attached to the CNSC's draft
Screening Report, The draft Screening Report will be circulated for a 30 day
comment period. After which the CNSC will review the comments and
incorporate if necessary. Following this, a public hearing will be held and a final
decision on the environmental assessment and the project will be made.
3,9 IER will be working in consultation with staff on the review of the draft Screening
Report, In order for the Municipality and IER to have sufficient time to review this
document, prepare comments and report to Council, it is requested that the CNsC
extend the commenting period from 30 days to a minimum of 45 days.
616
,
_ ",
REPORT NO.: PSO-012-03
PAGE 9
4.0 CONCLUSION
4.1 Currently, OPG's policy is to store the used fuel bundles on the site where they
have been consumed until a long-term solution for the storage of this waste has
been approved, This is an important project for OPG as they will need a location
for the storage of the used fuel by 2007, This same type of technology proposed
for the dry storage of the used fuel bundles at Darlington including the facility,
transportation and storage containers has been utilized at the Pickering
Generating Station since the mid 1990's and was recently approved for the
Western Nuclear Facility (Bruce Nuclear Plant).
4,2 IER has conducted a comprehensive review of the final Environmental
Assessment Guidelines, the draft Study Report, and the related technical
documents and staff concur with their findings, The "bolded" recommendations
contained in Section 3 of this report have been taken from the IER report and are
identified as areas of particular importance to the Municipality, It is recommended
that Council adopt this report and the comments of IER and submit them to the
CNSC before January 31st, 2003 as the Municipality's comments on the draft
Study Report,
4,3 It is recommended that the public commenting period of the review of the draft
Screening Report be extended beyond the 30 day commenting period to a
minimum of 45 days.
Attachments:
Attachment 1 - Key Map
Attachment 2 - Alternative Sites
Attachment 3 - Conceptual Layout
617
~ t ,..1"
REPORT NO.: PsD-012-03
PAGE 10
Interested parties to be notified of Council's decision:
Mr. Kurt Johansen, M, Eng., p, Eng,
Project Manager - Environmental Assessment
Nuclear Waste Management Division
Ontario Power Generation
700 University Avenue
Office H 16-E 14
Toronto, ON M5G 1X6
Mr. Don Howard
Licensing Project Officer
Waste and Decommissioning Division
Canadian Nuclear Safety Commission
280 Slater Street
P,O. Box 1046, Station B
Ottawa, ON K1P 5S9
Mr, Guy Riverin
EA Specialist
Processing Facilities and Technical Support Division
Canadian Nuclear Safety Commission
P.O. Box 1046, Station B
Ottawa, ON K1P 5S9
Mr. Jim Micak
IER - Planning, Research and Management Services
7501 Keele Street
Suite 300
Concord, ON L4K 1Y2
Sierra Club of Canada
Suite 412
1 Nicolas Street
Ottawa, ON K1 N 7B7
618
.
ATTACHMENT NO.. 1
",
Review By fER of Ontario Power Generation
Draft Environmenllll Assessment Study Report
Dariington Used Fuel Dry Storage Project
December 1001
EXECUTIVE SUMMARY
IER and SCIMUS Inc. were retained by the Municipality of Clarington to undertake a third-party
review of the documentation supporting a federal Environmental Assessment (EA) of Ontario
Power Generation (OPG) Darlington Used Fuel Dry Storage (DUFDS) project.
The mandate of this review was to:
. Confirm compliance with the requirements of the final Environmental Assessment
Guidelines prepared by the Canadian Nuclear Safety Commission (CNSC);
. Conduct a Peer review of Draft Environmental Assessment Study Report, Appendices
and Technical Support Documents prepared and submitted by OPG to the CNSC in
fulfilling the requirements of the final Environmental Assessment Guidelines; and
. Provide advice to municipal staff and Council to assist in understanding the content
of technical reports.
Generally, the Review Team found the work undertaken by OPG to be consistent with good
environmental assessment practice and to have been carried out properly. With respect to
compliance with the requirements of the final Environmental Assessment Guidelines prepared by
the Canadian Nuclear Safety Commission, two areas of non-compliance and several areas for
improvement were identified, which, if addressed, will enhance compliance with the Guidelines.
The Review Team also identified "Other Considerations" which, if addressed, will provide
assistance to municipal staff and Council in understanding the content of the EA Report and the
technical supporting documents.
Compliance with the Requirements of the Final EA Guidelines prepared by CNSC
Areas of Non-Compliance
. OPG should investigate the significance of dose to a non-NEW during the bounding accident
scenario involving the DSC transporter, identify mitigating measures and determine its
impact on the choice of preferred site. This is considered a major non-compliance.
. OPG should provide detalls on DSC design to allow assessment oflong-term integrity.
Areas For Improvement/Clarification
. "Scope of Assessment" provided in Section 1.3.3 does not include consideration of siting
alternatives, therefore, OPG should provide the rationale for considering alternative sites.
Since alternative sites were addressed, OPG should provide a more traceable process for
evaluating alternative sites. OPG should provide evaluation criteria, significance of each
fER .PiIlnning Research & Management Services
619
u
,J"
Review By IER ofOntariD Power Generation
Draft Environmental Assessment Study Report
Darlington Used Fuel Dry Storage Project
De<:ember 2002
criterion, and relative advantages and disadvantages for each site. The rationale for not
considering non-DNGS sites should also be provided,
. Section 1.1.1 "Purpose of the Project" on page 1-2 is somewhat more specific than the
"Purpose of the Project" provided on Section 9.2.1 on page 5 of the EA Guidelines. The
purpose in the EA Guidelines is more generic and states.... ..store used fuel bundles from the
Darlington Nuclear Generating Station,..." Whereas the purpose in the EA Report states
...... to modify existing in-station property for dry storage of used nuclear fueL..". The
proponent should clarify the purpose of the project.
. OPG should include a summary of the evaluation oftechnologies included in other UFDSF
projects as well as a summary of the performance of the selected technology at the PUFDSF.
. OPG should provide the level of detail required by the EA guidelines for the Preliminary
Decommissioning Plan,
. OPG should provide consistent criteria for the development of accident scenarios considering
integrated conventional and nuclear consequences. The effect of the conventional
consequences of each accident on the assumptions used in the evaluation of nuclear
consequences should be clearly identified.
. OPG needs to provide more information on how public input was incorporated into the
selection of VECs. OPG did convene a workshop to obtain public input on the VECs which
were determined by the consulting team but the report does not describe how VECs were
confirmed or modified based on public comment.
. The conclusions that the predicted effects on Valued Ecosystem Components do not possess
a cumulative effects trigger are reasonable. To demonstrate this OPG must ensure that all
commitments to mitigation and monitoring are implemented as identified in the Follow-up
and Monitoring Plan presented in Section 9.
. While the Review Team agrees with the statements as to the project's specific contribution to
cumulative effects, the real test is whether the cumulative effects of this project in
combination with other projects and activities result in a significant cumulative
enviromnental effect. The EA Study Report does not address this in a comprehensive way.
. The main EA document, "a complete and self-standing document" had several significant
information gaps. In some cases, the required information, e.g. human dose assessment
methodology, was not available even in the TSDs.
IER.Planning Research & Management Servica
620
u
"
Review By fER of Ontario Power Generation
Draft Environmental Assessment Study Report
Darlington US" Fuel Dry Storage Project
December 2002
Other Considerations
. Section 2.3.3,1 on page 2-3 reveals that two drainage ditches running north-south on the site
(Site B) would require relocation. No further reference to this relocation could be found in
the Main EA or the TSDs. This would appear to be an important environmental effect that
requires some discussion regarding significance and mitigation.
. In Section 11, the ''Plan for the Required Follow-up and Monitoring Program" should be
more extensive. Several recommendations from the Review Team, in this regard, are
provided in the Appendix.
. Public attitude research and field surveys should be taken more in line with key decision
points, The proposals provided a good start but the work should be replicated when the 2nd
and 3rd buildings within the DUFDS are commissioned,
. The survey research should be carried out to be statistically significant at least at the 95%
level.
. Section 5.6.3.2 on page 5-46 describes the existing environment and states that the water
table below Site B is 1m below the ground surface. The proponent should explain whether
such a shallow water table represents a disadvantage at Site B versus the other sites. If so,
this should be reflected in Table 5.6.4-1 on page 5-49. Similarly, the apparent disadvantage
of such a hydrogeological condition should be discussed in Section 6 of the EA Study Report
which deals with "Assessment and Mitigation of Likely Effects of the Project".
. OPG should incorporate any other missing information as identified in Section 3.0 and the
Appendix of this Review. In addition, the Review Team felt that, in several areas indicated
in the comments following theEA Study Report could have been written more clearly and
comprehensively.
. The Review Team found that the EA Study Report did not properly recognize First Nations
as being parties with interests that are different, or may be different, than other interests due
to legislation on aboriginal rights. Such recognition could lead to alternate consultation
opportunities. Other deficiencies which were recognized with respect to First Nations are as
follows:
- There is no indication in Table 4.8-1 of the Physical and Cultural Heritage TSD and
hence the EA Study Report that First Nations commented on the criterion of spiritual
and cultural meaning;
- It appears that one Metis organization (The Ontario Metis Aboriginal Associations)
was not consulted;
- There is no reference to, or use of, Traditional Knowledge in the EA Study Report.
IERePlanning Research & Management Services
621
Ii
. <
.<
N
~
"
.
5
~ "
> . z
~ ~ ~
z 0 ~
5 ~ ~ ~
co III Z 5
~ w ~ II:
cr:: I- I- cr::
~ ~ i=: ~
o I- U z
it ~ a: C2
00 is \j I-
~ ~ ~ ~
Cl
Z
W
'"
W
~
W
0:
:J
'"
u:
w
~~
g",
Ow
Za.
<(0
0",
",a.
=>en
Oc>
"-z
"-0
Oz
zo
gen
>-w
<(>-
u-
oen
--'
I
\
\
(
\
\
\
\
\
\
~
I
~
z 9
o 3
~ :
. w
~~ ~z~
w c:: it Q 0 w
~~g ~ >=~
Ow z :.; ;!: a:
iSdg 5~ ~2
~~<i<ll~ffi ~.~
B>~91-,< ffi~
~c~~ll!~~~~
5~~5a:J:~ e~
I- I- a: Cl: ~ ~ w ~;;:
~~~~~~~ ~ffi
\
" 0
~ w ~ ~~
~ o..~ ~ I-~;;:
J: I- }! if...J ~ 8 ~ !z
0;;; en a: is ..J ::> :S
~~~~ ir~ w~l!:::::o..
_ll.<;:Q 1-;5 ~Z,1jt20W
~~~~ ~o [lj~~s!~~
';(i!~~ ~~ \ii~0~12~
~~I-<(~C:W~wa:~UCllO
~~5~~l!!~~;j(:~o..~u
~li~~~g~~~i~~ffi
H~"'oh~~"B~
-"'_' _ '_ ~ ~ .~ ,!<.;;; ~.!1 ;Ii
\
\
n
"
"
'.~\
"
"
II,
,~
62!-
~
~
z
o
~
o
w
o
5
o
"
"
w~
r...l~
z"
w"
o:~
ww
"-",
w<
o:m
,
,
W
L
~
" "
w
"
C
,
o ~
~
"
ATTACHMENT 2
n::'"
U..l2
:!:~
c=~
u....tB
=
22
;:=;
=
=
~
i
~~
~~
01'
~~
~[
e"
3~
.
~
L ,...' "
II.:"
".
~"--,.
,~-,-~~
'{:"~i#
)
,
~
~
N
o
on
o
---
N
o
o
N
i'5
z
or
---
<<
W
---
o
o
on
on
---
.
"
o
~
.
;:-
o
on
~t
O-
Ne;
---
..:;;
/;_::c.:::~
I"'<~.'r.,
_-=:,U
~ .~
o c
Z~
---
"
W
~~
<<
~Z
g~
....
"
CONCEPTUAL LAYOUT OF DUFDS FACILITY AT SITE B
i"
I!
/
~
-
'!,
"
"
;<
o
';,/\"
, /
-..-/ \'.
/ /' '\,
~/~..; \,
_/' ~ ~ PARKlN~'
\ 1 './ \
\ ~9"G \~
\\' 'i!(l.~~G \ _ ,
\. ..
- \ \, %
-1 \\ \
I' ONGS '\ ", \ '\
PARKING LOT _
J!. \\ \
i "\ \\
i \ \, \
'u' . . ~~~rk~~\ \
\ - ------ -------- " \
" ..----/ ------- '
_/-~J;=J '. /
J/
F1..AMI.4A8LE NEW ROAD
MATERiAlS
ST~AGE
ATTACHMENT 3
FIGURE 2.4.4-1
LEGEND
)( )( SECURITY FENCE
- - - - EXTENT OF SIlE B
REFERENCE
BASE MAPPING WAS PROVIDED BY OPG
o 1DO
~o...:
-
.....-
/' ~t.:v
~..
~
_ _ _::-~-:-7i~ _.' / '
-~
UA'E ONTARIO
Date .i'J.o.v.E.M.~E;fl)()()?H
Project H()1.1::J,~(lJ.(??QQLH
623
200
300m
SCALE 1 :4000
ONTARIOPOiiER
GENERATION