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HomeMy WebLinkAboutPSD-027-02 , '1' ~ .. . Q!J!-fl1gron REPORT PLANNING SERVICES Meeting: Date: Report #: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE E05 Monday, April 8, 2002 PSD-027 -02 GIY1-16f,-D~ File #: PLN 26,10 By-law #: Subject: DRAFT ENVIRONMENTAL ASSESSMENT GUIDELINES FOR THE USED FUEL DRY STORAGE FACILITY PROPOSED ON THE DARLINGTON NUCLEAR GENERATION STATION LANDS. RECOMMENDATIONS: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1, THAT Report PSD-027 -02 be received; 2, THAT Report PSD-027-02 be approved as the comments of the Municipality of Clarington on the document entitled "Draft Environmental Assessment Guidelines (Scope of Project & Assessment): Environmental Assessment of the Proposed Construction and Operation of the Darlington Used Fuel Dry Storage Facility in Clarington, Ontario," dated February 15, 2002 FORTHWITH; 3, THAT a copy of Report PSD-027-02 and Council's resolution be forwarded to the Canadian Nuclear Safety Commission (CNSC) ; and 4, THAT the interested parties listed in this report be advised of Councils decision, Submitted by: RevieWedbY:cJ ~--~ Franklin Wu, Chief Administrative Officer David rome, MCIP, R.P.P, Director of Planning Services HB*BN*DJC*lw April 3, 2002 CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1C 3A6 T 905-623-3379 F 905-623-0830 669 .. " < REPORT NO.: PSD..o27-o2 PAGE 2 1.0 BACKGROUND 1.1 Ontario Power Generation Inc. (OPG) is proposing to construct a Used Fuel Dry Storage Facility on the Darlington Nuclear Generating site. This proposed facility will accommodate the relocation of used fuel bundles that have been stored in the irradiated fuel bays in the station for a minimum of ten years. The irradiated fuel bays are nearing capacity and movement of fuel bundles to a dry storage facility is required. Following all regulatory approvals, it is OPG's intention to have the dry storage facility in operation by the fall of 2007. 1.2 In accordance with the Canadian Environmental Assessment Act (CEM) the construction of this facility requires the completion of a Federal Environmental assessment. The purpose of this environmental assessment (EA) is to determine if there will be any environmental impacts attributed to the construction and operation of this facility. 1.3 On February 15, 2002, the Canadian Nuclear Safety Commission (CNSC), as the Responsible Authority (RA) for the Project, released a document entitled "Draft Environmental Assessment Guidelines (Scope of the Project & Assessment): Environmental Assessment of the Proposed Construction and Operation of the Darlington Used Fuel Dry storage Facility in Clarington, Ontario" (Draft Scope EA). The CNSC is requesting the public and other stakeholders to provide comments on the Draft Scope EA document. The public consultation period runs from Monday, February 28th, 2002 to Friday, April 5, 2002. Clarington Council requested the extension of the public consultation period and CNSC granted the Municipality one additional week for comments until April 12th, 2002. Comments provided during this consultation process will be considered in the final review of the EA Scope document. 1.4 The purpose of this staff report is to provide Council an overview of the Canadian Environmental Assessment process, a review of the Draft EA Guidelines for this project and the Municipality's comments to the CNSC. 670 ,. , REPORT NO.: PSD..o27-o2 PAGE 3 1.5 Ontario Power Generation Inc. has agreed to provide funding on behalf of the Municipality for consultants to undertake peer reviews of the studies and provide advice to the Municipality throughout the EA process. This funding is provided to the Municipality as the host community; it is not intervener funding as provided for under the CEM. Given the time constraints for preparing the Municipalities comments, the Director of Planning Services retained the services of Acres and Associated to assist in preparing comments on the Draft Environmental Assessment Guidelines onlv. The peer review of the EA will be tendered separately. Acres International was previously retained on three projects by the Municipality, including the Interim Waste Authority site selection process and the Laidlaw Landfill project. Staff and Council were very satisfied with this work. Also, Acres and Associated were retained by the Town of Ajax as the peer review consultant with respect to the start-up of the Pickering 'A' Nuclear Power Plant of OPG. Excellent references were obtained with respect to their services. 2.0 CANADIAN ENVIRONMENTAL ASSESSMENT PROCESS 2.1 CEM provides for both Responsible Authorities (RA) and the proponent for a project, to be identified. The CNSC is the RA for this project and pursuant to the Federal Coordination Regulations of the CEM, Health Canada, Environment Canada, Natural Resources Canada and the Department of Fisheries and Oceans have been identified as expert Federal Authorities (FA) for the purpose of providing expert assistance during the Environmental Assessment. Although Indian and Northern Affairs Canada indicated that they do not have a role in the Assessment, they would like to have the local Aboriginal groups included in the process. The CNSC confirmed with the Ontario Ministry of the Environment that there are no Provincial environmental assessment requirements under the Ontario Environmental Assessment Act that are applicable. 2.2 The RA is responsible for ensuring that the EA is carried out in accordance with CEM. As such, the proponent is required to keep the RA advised of the progress of the EA. The proponent must also consult with the public, the Municipality and other stakeholders during the preparation of the EA. OPG will be conducting the technical support studies, 671 , , REPORT NO.: PSD..o27-o2 PAGE 4 prepare the EA study report, and conduct the public consultation program. The Draft EA Guidelines for the Used Fuel Dry Storage Facility proposed on the Darlington Nuclear Generation Lands has been prepared by the CNSC. 2.3 Once the EA study report is finalized, it will be submitted to the RA. The RA and the Federal Authorities will review the study report to determine, among other matters, if it has been prepared in compliance with CEM and the EA Guidelines. The RA will use the EA study report as the basis for the preparation of a screening report. The screening report takes into consideration all documentation, ensures the legislative requirements are satisfied and is the basis of the decision by the RA to permit the project or to refer the project to a mediator or review panel. 3.0 DRAFT ENVIRONMENTAL ASSESSMENT GUIDELINES 3.1 Purposes and Description of the Project The Draft EA Guidelines states "the purpose of this document is to provide guidance on the scope of the environmental assessment (EA) that will be conducted on the proposed construction and operation of the Darlington Used Fuel Dry Storage facility at the Darlington Nuclear Generating Station (DNGS)." The project shall describe and identify the proposed facility, including the location, construction and operation of such facility. A conceptual decommissioning plan for the facility will also be included in the assessment. In consideration of the above, the project shall identify and characterize those activities or components that have the potential to interact with the environment, resulting in a change or disruption to the surrounding environment. 3.2 Type of Assessment The CEAA provides for either a screening study or a comprehensive study to be undertaken, depending on the specific characteristics of a project. As this project is not identified in the Comprehensive Study List Regulations of the CEM, a screening level assessment is what is required to be prepared. The following factors are those that must be considered: . the environmental effects of the Project, including the environmental effects of malfunctions or accidents, and their significance 672 , REPORT NO.: PSD-027-o2 PAGE 5 . any cumulative environmental effects that are likely to result from the Project in combination with other Projects or activities . comments from the public that are received in accordance with the CEM . measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the Project. A screening level assessment is not required to address as many factors as a comprehensive level assessment. However, the Draft EA Guidelines proposes to require the assessment to also address the following factors that are required for a comprehensive study: . the purpose of the Project . the need for and requirements of any follow-up program in respect of the Project . the capacity of renewable resources that are likely to be significantly affected by the Project to meet the needs of the present and those of the future Additional or more specific factors may be identified following consultation with the Federal Authorities or other stakeholders. 3.3 Specific Information Requirements to be Detailed in Screening Report This component of the Draft EA Guidelines identifies various information requirements that must be detailed, examined or assessed. This includes providing the purpose and description of the project. The description includes providing general information on design characteristics, normal operations, malfunctions and accidents, assessment of site altematives and conceptual decommissioning plan. This exercise is predominantly a fact finding and documentation exercise. However, it is important to ensure that this exercise is complete as it may have a bearing on the outcome of the assessment of the effects or cumulative effects of the project. 3.4 Facility Location and Study Boundaries This Draft EA Guidelines indicates that the EA will focus on the preferred site for the location of the facility (Site B). Only after the assessment of the preferred site is completed will the different effects of locating the facility in one of the other 3 alternative sites be addressed (Attachment 1). Two of the alternative sites are on the lands identified for the Iter Project and will be eliminated if that project is awarded to Canada 673 , ., REPORT NO.: PSD-027-o2 PAGE 6 The Draft EA Guidelines identifies the spatial boundaries of the EA as those areas that can be reasonably expected to be impacted upon by this project. A Site Study Area, Local Study Area and Regional Study Area have been identified (Attachment 2). The temporal boundaries establish over what period of time the effects of the project will be considered and include the construction and planned operational life of the facility. A timeframe describing the longer-term residual affects are to be defined. 3.5 Description of the Existing Environment The environment includes the biophysical and socio-economic environment. This component of the Draft EA Guidelines identifies and discusses the likely elements of the environment that may be impacted upon. 3.6 Assessment and Mitigation of Potential Environmental Effects The EA Study report shall identify and describe the potential interactions between the project and the environment, during construction and normal operations and during malfunctions or accidents. Those mitigation measures that may be applied and are technically and economically feasible shall be identified and described. Lastly, the significance of any environmental effects that will occur after the implementation of proposed mitigation methods shall be described. The consideration of environmental effects is to be undertaken by project phase, completed in a systematic and traceable manner, and clearly documented in the EA study report. An "environmental effecf' is defined to include any changes the project may cause in the environment, including any effects or changes in health and socio-economic conditions, physical and cultural heritage, use of lands and resources for traditional purposes by aboriginal persons, or on any structure, site or thing that is of historical or archaeological value. It shall also include any changes to the project that may be caused by the environmental regardless of whether the changes occur within or outside Canada. 674 REPORT NO.: PSD..o27-o2 PAGE 7 3.7 Assessment of Cumulative Effects and Significance of Residual Effects The assessment will consider the combined effects of this project with the effects of other projects or activities such as future industrial or development on adjacent lands. If potentially significant adverse cumulative effects are identified, other mitigation measures may be considered. The EA will consider the significance of the environmental effects and will determine, taking into account mitigation measures, whether the project will have any significant adverse environmental effects. The CNSC will document the conclusion of these effects in the screening report. 3.8 Public and Stakeholder Consultation Program The Draft EA Guidelines requires the notification of and consultation with potentially affected stakeholders, including the local public. Various forms of media have and will be used to inform and gather comments from individuals, interest groups, and other stakeholders. OPG will be conducting the consultation program under the scrutiny of the CNSC. The screening report will summarize comments received during the EA process, and will indicate how issues raised have been considered. Lastly, the CNSC will hold a public consultation process in the review of the screening report, allowing people to comment of both the draft and final screening report. 4.0 COMMENTS 4.1 Municipal staff worked with Acres and Associated in reviewing the Draft Environmental Assessment Guidelines for the Darlington Used Fuel Dry Storage Facility. The comments contained in Attachment 3 to this report reflect this review and are endorsed by the Planning Services Department. The peer review report identifies the following areas as requiring more emphasis and/or detail: . That the project is for a temoorarv used fuel dry storage facility only; . The long term integrity of the dry fuel storage containers over time; 675 REPORT NO.: PSD-027-o2 PAGE 8 . Information on the required modifications to the irradiated fuel bays and mitigation measures for any incidents; . The need for an altemative plan for fuel storage if the dry fuel storage facility becomes unavailable/inaccessible for any reason; . Assessment of siting altematives should start with all four sites ("A", "B", "C", and "D"), and then an explanation of how Site "B" was selected; and . Assessment of cumulative effects should include cumulative impacts with the Iter Project. Review and the preparation of this EA is very important to the Municipality. There is a real risk that this project could be a step in transfonning the nuclear generating station to a long-tenn nuclear waste facility. In no means should this EA be utilized to support a long tenn nuclear waste facility in this location. 5.0 CONCLUSION 5.1 The Draft EA Guidelines sets out a broad framework for the preparation of the EA study report for this project. The proponent is responsible for interpreting how the requirements of the EA Guidelines are to be specifically addressed through the various studies that will be undertaken through the EA. The primary responsibility for undertaking and reviewing the environmental assessment for this project lies with the proponent and the RA respectively. However, as the host municipality, Clarington is a key stakeholder in the process. In order to safeguard all current and future residents of Clarington, the Municipality must be completely confident that the findings of the EA fulfill this responsibility. As such, it is critical that the Municipality be consulted frequently as the environmental assessment progresses. It is recommended that the General Purpose and Administration Committee adopt this report and the comments of Acres and Associated and submit them to the CNSC before April 12th, 2002, as the Municipality's comments on the Draft EA Guidelines. 676 -' < REPORT NO.: PSD..o27-o2 PAGE 9 Attachments: Attachment No.1 - Site Study Area Attachment No.2 - Local Study Area Attachment No.3 - Acres & Associated Report Interested parties to be notified of Council and Committee's decision: Kurt Johansen, M. Eng., P. Eng. Project Manager - Environmental Assessment Nuclear Waste Management Division 700 University Avenue TORONTO, Ontario M5G 1X6 Ms. Mary A. Mullan EA Project Manager Radiation and Environmental Protection Division Canadian Nuclear Safety Commission 280 Slater Street P.O. Sox 1046 OTTAWA, Ontario KiP 5S9 Mr. Don Howard Licensing Project Officer Waste and Decommissioning Division Canadian Nuclear Safety Commission 280 Slater Street P.O. Box 1046 OTTAWA, Ontario KiP 5S9 Sierra Club of Canada Suite 412 1 Nicolas Street OTTAWA, Ontario KiN 7B7 677 a-- "'...j = " ~ , f, .1 II 5. " I I I ( t C:.-.::,., i I SITE STUDY AREA DARLINGTON USED FUEL DRY STORAGE ENVIRONMENTAL ASSESSMENT . . ~::~..'" .~ . __,...,.(,:r:." . ........:. II II 'I II II II 'I 'I II II II II I-J l " I I LAKE ONTARIO I.I~lT OF EX~~S~~~~i BUII.D1NG) (914 ME'TRES FROM Cot. .,~~P.~Il4Jlf;IL.NQ.!......,,, PrOJ.d ..Q,\.t.7.!.~.1,{~.lQ!n,,,. LEGEND ----'" , Figure 1 ONGS PROPERTY BOUNDA POSSIBLE SITE BOUNOARtE REFERENCE BASE MAPPING PRC1VlDEO BY ONOS, ~ lO'lIIl NIl _ .11II HII~ 8CAt.E1:10,COO ONTARlOPO'"u IiBlBlAIIlIJ ~ -I f) J: s:: m z -I ~ " ~ ----.J -..c ONTARlOPOwii! GIIIERAroN LOCAL STUDY AREA DARLINGTON USED FUEL DRY STORAGE ENVIRONMENTAL ASSESSMENT Figure 2 tFClFNrl LOCAL &TUOY AR!A (101m eVAClM.TIOH ZONE) j , ~Jni'lll 211M 3Ilr!ll 4I'lM ~ lJCAI.E1:~ )> -I ;; (') :r 3: m z -I '" lr J !! ~. 04/03/02 12:34 FAX 905 374 8365 ACRES & ASSOCIATED 141002 ATTACHMENT 3 Acres & ...\ Associateo ., Environmental Sdentists and Consulting Engineers Apri12,2002 File: 2002-5856 - 5.0 Municipality of Clarington 40 Temperance Street BOWJnanville, Ontario LIC 3A6 Attention: Mr. David Crome, M.C.J.P., RP.P. Director - Planning and Development Re: PEER REVIEW DRAFT ENVIRONMENTAL ASSESSMENT GUIDELINES FOR DUFDSF Dear Mr. Crome: Please find attached our comments on the ''Draft Environmental Assessment Guidelines" document (February 15, 2002) that the Canadian Nuclear Safety Commission (CNSC) prepared for Ontario Power Generation (OPG) in connection with the Darlington Used Fuel Dry Storage Facility (DUFDSF). We have provided our comments from the viewpoint that they could be considered as the Municipality ofClarington's (the Municipality) comments. In this manner, you are free to adopt any, or all of, our comments as your OWll_ An e-copy of our corrnnents will also be forwarded to you to expedite the incorporation of our comments into your Staff Report. We hope our comments will be of assistance in addressing the concerns of the Municipality, and in formulating your Staff Report and reply to the CNSC - Please do not hesitate to contact me at (905) 374-4470, or (416) 622-9502, should you have any questions concerning the above. Yours truly, ACRES & ASSOCIATED ENVIRONMENTAL LIMITED ~~~ Bruce G. Bennett, M.Sc. Project Manager M;\AandA\F'roJecrs\2002\025856\cover1tr^report.wpd 6fJO Acres & Associa.teil Envirol1mel1tal L imiteil S25-21 Four Seasons Place, Toronto, Ontario M9B 6)8 ... 4342 Queen strc...,~ P,O. Box 1001, Nisgar.tillls, OntlUio L2H 6wI Telephone (416) 6lJ.9S0J h<simile (416) 622-6249 Telephone (905) 374.4470 Faeshnll. (90S) 374.8365 ,. " . ATTACHMENT 3 COMMENTS ON "DRAFT ENVIRONMENTAL ASSESSMENT GUIDELINES" FOR DARLINGTON USED FUEL DRY STORAGE FACILITY (DUFDSF) 1 GENERAL COMMENTS We note throughout the document that the terms "environmental assessment", "assessment", "screening", and "screening assessment" appear to be used interchangeably. It would reduce the confusion to municipal staff, councilors and the public at large if the term "environmental screening" could be used throughout to make it very clear to all concerned that the CNSC has determined that this is an "environmental screening" (rather than "a comprehensive study") in accordance with the requirements of the Canadian Environmental Assessment Act (CEAA). 2 COMMENTS ON "2.0 BACKGROUND" We recommend that the first sentence of this Section be modified to read". . . to apply for authorization to construct and operate a temporary used fuel dry storage facility at the DNGS site until a permanent disposal facility becomes available sometime after 2025. " The Municipality of Clarington (the Municipality) is very sensitive to the fact that this facility is being proposed as a temporary facility by OPG until a long-term management facility becomes available. Emphasizing the word temporary is consistent with: . the statements made under Section 7.0 of the Draft EA Guidelines whereby, on page 4, it is stated that "The long-term management of radioactive waste, including irradiated nuclear fuel, is being developed through separate federal legislation" and "Consequently, it is premature to examine long-term waste management alternatives as part of the scope of this project", and . the statements made under Section 9.0 of the Draft EA Guidelines whereby, on page 7, it is stated that long-term waste management options will not be considered as part of the Conceptual Decommissioning Plan for the reasons stated above. 3 COMMENTS ON "3.0 APPLICATION OF THE CANADIAN ENVIRONMENTAL ASSESSMENT ACT" We were unable to relate the capacity of the facilities (1500 dry storage containers) as noted in the project description, to the capacity (100 t1a) noted in Part VI (f) (Nuclear and Related Facilities) of CEAA to confirm whether this is an environmental screening or comprehensive study under CEAA. Both the project description and Section 3.0 of the Draft EA Guidelines require this clarification. 681 .' , We suggest the following modification to the third sentence of the last paragraph of Section 3.0 of the Draft EA Guidelines: "At this time, CNSC staff is not aware of any potentially significant adverse environmental effects or public concerns. . . " This clarifies for municipal staff, councilors and the public at large more precisely what would warrant a referral to a mediator or review panel as per CEAA Section 25. 4 . COMMENTS ON "4.0 IDENTIFICATION OF OTHER FEDERAL AND PROVINCIAL EXPERT DEPARTMENTS" No comments. 5 COMMENTS ON "5.0 DELEGATION OF ASSESSMENT STUDIES TO ONTARIO POWER GENERATION" As CNSC points out, Section 17(1) of CEAA allows the Responsible Authority (CNSC) to delegate the environmental screening to OPG. In our view, the product of OPG's environmental screening should be an environmental screening report. It then follows that CNSC' s review of OPG's environmental screening report should be an "environmental screening review report". We note from Section 18(1) of CEAA that CNSC must only "ensure" that a screening is done and that a screening report is prepared. The fact that Section 17 (I) allows delegation of the screening to OPG surely allows them to produce the screening report. 6 COMMENTS ON "6.0 PUBLIC REGISTRY" No comments. 7 COMMENTS ON "7.0 SCOPE OF THE PROJECT" Reference should also be made to the project description in this section to ensure a full understanding of all project activities. 8 COMMENTS ON "8.0 FACTORS TO BE CONSIDERED IN THE SCREENING" The paragraph commencing "In accordance with subsection 16 (I) (e) of the CEAA . , . " quotes the incorrect subsection. It should be subsection 16(2). The Municipality of Clarington would, however, also like to see the requirements of subsection 16(1)(e) included in the screening, i.e. the Need for the Project and the Alternatives to the Project. 9 COMMENTS ON "9.0 ASSESSMENT METHODOLOGY" Under Subsection 9, I "Structure of the Screening Report" of the Draft EA Guidelines, we would like to see two additional sections in the screening report as per our comments on Section 8.0 noted above, i.e., the Need for the Project, and the Alternatives to the Project. 2 682 r .. . As noted in our comments on Section 5.0 above, it is confusing to municipal staff, councilors and the general public to call the product of OPG' s environmental screening by another name (i.e. EA study report), and the product of CNSC' s review of the screening, a "screening report". On page 5 of the Draft EA Guidelines under the "General Information, Design Characteristics and Normal Operations" part of Subsection 9.2.2, we would like to see a projection, by year, of the used fuel volumes which are expected to arise from the operation of the DNGS, as well as information on the storage capacity of the irradiated fuel bays. We are very concerned about the long-term integrity of the dry storage containers (DSCs) over time since there is no guarantee that a permanent used fuel disposal facility will be available even at the end of the 50-year design life of the DSCs. Therefore, on page 6 of the Draft EA Guidelines under the "General Information, Design Characteristics and Normal Operations" of Subsection 9.2.2, we would like to see reference made to the provision of more detailed information concerning the factors that affect long-term integrity. These include: · Thermal stress induced concrete cracking (heat from the decay ofradioactivity in the used fuel) · Radiation induced concrete deterioration such as radiolysis of moisture in concrete . Concrete aging · Corrosion and hydriding of metal components in the DSC We would also like to see reference made to the provision of more detailed information concerning (i) the proposed modifications to the irradiated fuel bays and (ii) mitigation measures in the event of an incident as this information is essential in the assessment of worker protection. In our opinion, inclusion of "Malfunctions and Accidents" as part of the project description in Subsection 9.2.2 of the Draft EA Guidelines is inappropriate and is more correctly placed (as it already is) in Section 9.2.5 (Assessment and Mitigation of Environmental Effects). Under this "Malfunctions and Accidents " heading, we also feel that a clear statement is needed which indicates that these events include "operations during fuel loading and transfer at the irradiated bays, transportation from the irradiated fuel bays to the dry storage facility and storage operations at the dry storage facility". On page 7 of the Draft EA Guidelines under the "Assessment of Siting Alternative" part of Subsection 9.2.2, we feel that the assessment of the siting alternatives should start with all four sites (i.e., Sites "A", "B", "C" and "D"). An explanation should then be provided, in a logical manner, as to how Site "B" was selected as the preferred site, taking into account environmental and other considerations. In the last sentence of this part of Subsection 9.2.2, it is suggested that this sentence be modified to read "The 3 683 , - . assessment of the differential effects will involve a detailed and quantitative, as well as qualitative, analysis". We are assuming that the air quality description of the existing environment, as noted on page 8 of the Draft EA Guidelines under Subsection 9.2.4, will include existing background radiation levels for a specified study area. However, we would also like to see this specified in the EA Guidelines for this project. There is considerable duplication regarding the significance of effects as noted in Subsections 9.2.5 (2), (4) and 9.2.7. It is recommended that the discussion regarding significance of effects should be removed from Subsections 9.2.5 (2) and (4) and incorporated into Subsection 9.2.7 since this is the appropriate sequence of events, i.e. significance is only determined on residual effects after application of mitigation, where feasible. Therefore: . On page 10 of the Draft EA Guidelines under Subsection 9.2.5 (2), the paragraph commencing "For each identified effect, the predicted magnitude, duration, frequency, timing, . . . " should be removed because this is the procedure for identifying the significance of effects. . Subsection 9.2.5 (4) should be removed in its entirety and the three paragraphs comprising this subsection should be incorporated into Subsection 9.2.7 "Significance of the Residual Effects". We are concerned that there may not be an alternative plan for fuel storage if the dry fuel storage facility is unavailable for any reason - even temporarily. In this event, what are the viable storage options if the irradiated fuel bays run out of storage capacity for fresh used fuel discharged from the reactors - short of temporarily shutting down the nuclear station ? We feel this issue needs to be identified and addressed as part of the contingency response/emergency response plan identified in Subsection 9.2.5 (3). Recent events have also highlighted the issue of preparedness/response to unforeseen events (i.e., safeguards against nuclear material diversion or terrorist attacks). It is recognized that this issue is of utmost concern to both OPG and the CNSC and that the preparedness/response to these events is a high security matter and not for the public record. Nevertheless, we feel that a statement is needed in the Draft EA Guidelines that confirms that this very sensitive issue has/is being addressed by OPG and the CNSC. On page 11 ofthe Draft EA Guidelines under Subsection 9.2.6 "Assessment of Cumulative Effects", no specific mention was made of the ITER project and the manner in which the planned siting for, and expected effects from, the ITER project will have on the DUFDSF project. Therefore, this section should be revised to include reference to the ITER project. 4 684 ,. With regard to the second paragraph on page 12 of the Draft EA Guidelines under Subsection 9.2.8 "Stakeholder Consultation", we would like to see it reworded as "The stakeholder consultation program of Ontario Power Generation will be submitted to CNSC for approval prior to implementation. It will also be available for review and comment by other relevant agencies (federal, provincial and municipal) prior to implementation. Once CNSC approved, the stakeholder consultation program will be continuously monitored by CNSC staff throughout the environmental screening process." 10 COMMENTS ON "10.0 ENVIRONMENTAL ASSESSMENT PROCESS" We recommend a change in the title of this section to "Environmental Screening Process" . We also recommend the following changes to the steps that are listed in this section. . EA Project determination under CEAA (i.e. environmental screening or comprehensive study) (complete) . Establishment of Public Registry (complete) . Stakeholder notification of Public Registry? (complete) . Preparation of working draft ofEA (or Environmental Screening?) Guidelines (complete) · Distribution of draft EA guidelines to proponent and federal and provincial authorities (complete) · Receive comments from federal and provincial authorities and prepare draft for public comment (complete) · Distribute draft EA Guidelines for municipal and public comment (in progress) · CNSC staff dispo:;ition review of municipal and public comments · Preparation Finalization of proposed EA Guidelines . CNSC approval of EA Guidelines · CNSC staff delegation of consultative and technical studies to the proponent · Distribution of draft technical E,^. stud) screening report to review team (CNSC staff, federal and provincial authorities) and the Municipality of Clarington · Revision, as appropriate, of techllical E,^. study screening report and issue to relevant federal, provincial and municipal agencies, and public notification . CNSC staff preparation of draft screening review report · Municipal and public review and comment on draft screening review report · CNSC staff dispositiofl review of municipal and public comments · CNSC completion of screening review report · CNSC issue of screening review report CMD for Commission consideration . Public notification of Commission Hearing · CMD presentation of screening report and screening review report to Commission Hearing (Day 1) · Commission Hearing (Day 2) · Commission Hearing Record of Decision 5 685 r . ,.~ 11 COMMENTS ON "11.0 CONCLUSIONS AND RECOMMENDATIONS FOR DECISION" We recommend that the first sentence read "screening review report" to avoid confusion with the OPG screening under CEAA. 6 686