andrew müller - impact assessment agency · particulate matter [spm]) due to site preparation and...

From: MULLER Andrew -DNNP <email address removed> Sent: December 20, 2012 11:31 AM To: DGR Review / Examen DFGP [CEAA] Cc: 'McGee, Kelly'; Myles,Debra [CEAA]; 'Peter Elder ([email protected])'; 'King, Frank'; WEBSTER Allan P -DNNP; MITCHELL Leslie -DNNP; SULLIVAN Gord -DNNP Subject: Deep Geologic Repository Project for Low and Intermediate Level Waste - Undertakings from Technical Information Session #2 Please find attached a copy of the letter signed by Mr. Albert Sweetnam to Dr. Stella Swanson, Chair of the Joint Review Panel for the Deep Geologic Repository Project, titled “Deep Geologic Repository Project for Low and Intermediate Level Waste – Undertakings from Technical Information Session #2”. This submission provides OPG’s response to the undertakings assigned to OPG at the Joint Review Panel’s Technical Information Session #2. The signed original is being sent by courier. Sincerely, Andrew Müller Section Manager - Licensing (DGR) Ontario Power Generation

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Attachment to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste –Undertakings from Technical Information Session #2”, CD# 00216-CORR-00531-00154

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OPG Responses to Undertakings from Technical Information Session #2

Undertaking # Undertaking and Response

MTIS 1 Undertaking:

OPG to provide data regarding dose modelling to non-human biota for the construction period, taking into consideration the remobilization of radionuclides in the soil. The modelling should also include the possibility of construction activities disturbing areas of the site, particularly sediments, for which there is currently little or no relevant data, such as ditches and Stream C.

OPG Response:

Change in transfer factors due to construction activities is generally possible, but only if there were changes in the chemical forms of environmental components or significant impacts on environmental interactions. It is not anticipated that site preparation and construction will result in creation of new chemical forms or environmental interactions; therefore there will be no change in exposure of non-human biota due to introduction of these effects.

In addition, activities implemented during site preparation and construction may lead to radiation exposure of non-human biota via the following mechanisms:

Radionuclide mobilization within local sediment or soil for enhanced uptake locally or downstream; Radionuclide mobilization in the form of contamination attached to suspended particles (dust) and subsequent

exposure via inhalation, immersion or external/internal exposure from deposited radioactivity; and Radionuclide mobilization into water from sediment and deposition of resuspended particles, and subsequent exposure

locally or downstream.

Potential for additional exposure due to these three types of remobilization is discussed further below.

1. Exposure due to Mobilization within Local Sediment and Soil

During the site preparation and construction phase, there will be no activity that would disturb Stream C sediments and few activities that would disturb sediments in the existing ditches. The one exception would be the area where the crossing of the abandoned rail bed would require the disturbance of less than 50 m of both the North and South Railway Ditches. However, as described in the Aquatic Environment Technical Support Document (TSD) (GOLDER 2011a, Section 8.2), all sediments disturbed during the excavation would be contained in place and not allowed to affect surface water quality or non-human biota downstream of the construction or subsequently in Stream C. Therefore, no further radiological calculations are required with respect to sediments.

Tritium and carbon-14 are the principal anthropogenic radionuclides from operation of the existing nuclear facilities at the Bruce nuclear site. Current concentrations of other radionuclides in soil within the Local Study Area are at background levels (refer to OPG’s response to Information Request (IR) EIS-06-238 [OPG 2012a]). The effects due to disturbance of background radionuclides in soil would be the same as at any construction site, and would not change the conclusion reached in the EIS.


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2. Exposure due to Resuspension of Radioactivity into Air

During the site preparation and construction phase there is a potential for activities to disturb the overburden, resulting in airborne particulate (i.e., dust). Dust will be minimized by dust suppression measures as described in the Atmospheric Environment TSD as well as OPG’s response to Information Request (IR) EIS-04-137 (OPG 2012b). Dust will dissipate when the source activity stops, effectively at the same time as construction stops. Dust deposition rates are a function of the particle size and concentration. Those dust particles large enough to deposit will deposit quickly, in the order of seconds or minutes. Maximum off-site, 24-hour air concentration of dust (i.e., suspended particulate matter [SPM]) due to site preparation and construction activities was predicted in the Atmospheric Environment TSD as 224.8 μg/m³ (GOLDER 2011b, Section 8.2.3.2). This prediction includes not only particles present in air due to resuspension but also those emitted by construction vehicles and equipment.

The release of tritium and carbon-14 by resuspension may lead to exposure of non-human biota (AMEC NSS 2011). Assuming additional dust concentrations in air during site preparation and construction result from resuspension of particles from locations with maximum concentration of radioactivity, and taking the cumulative concentration of dust in air of all particle sizes, the additional radionuclide concentrations in air will be 0.00004 Bq/m³ of tritium and 0.0001 Bq/m³ of carbon-14. Comparison of these values with the assumed bounding concentrations during DGR operations is provided in Table 1 below.

Table 1: Radionuclide Concentrations in Air

Radionuclides Assumed Maximum

Concentrations in Air Resulting from DGR Operations

(Bq/m³)

Maximum Concentrations in Air Due to Remobilization during DGR Construction

(Bq/m³) Ratio

Tritium 3.9 0.00004 100,000 Carbon-14 0.21 0.0001 2,000

Radionuclide concentrations in air during site preparation and construction of DGR Project are negligible compared to the bounding estimate considered in the assessment of doses to non-human biota for the operations phase (AMEC NSS 2011, Appendix C, Section C.1). Estimated radionuclide concentrations due to resuspension are at least three orders of magnitude less than present maximum concentrations due to operation of Western Waste Management Facility (WWMF) and nuclear generating stations at the Bruce nuclear site (which were used to derive bounding concentrations for the operations phase of the DGR Project). While carbon-14 due to resuspension may be emitted in the form of particulate rather than gaseous CO2, any additional dose effect due to a higher inhalation dose coefficient is small compared to the ratio between estimated concentrations for this radionuclide.

Therefore, resuspension of radionuclides during site preparation and construction contributes very little to the dose to non-human biota at the Bruce nuclear site.

3. Radionuclide Mobilization into Water

Construction activities may result in elevated radionuclide concentrations in surface water either due to sediment


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disturbance or due to deposition of resuspended particles. As discussed above, neither of these two pathways is significant for the DGR project. Specifically:

All sediments disturbed during the excavation in the railway ditch would be contained in place and not allowed to affect water quality.

Radionuclide deposition into surface water due to construction dust will be at least three orders of magnitude less than present maximum concentrations which were used to derive bounding concentrations for the operations phase of the DGR project.

In summary, environmental radionuclide concentrations during construction will be bounded by the assumption that environmental concentrations will double during operations of DGR.

With levels of radioactivity in the environment during site preparation and construction being bounded by those assumed for operations in the Radiation and Radioactivity TSD (AMEC NSS 2011, Appendix C1), it can be concluded that the assessment of doses to non-human biota during operations is bounding of exposure during the construction phase.

References:

AMEC NSS. 2011. Radiation and Radioactivity Technical Support Document. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-06 R000. Toronto, Canada. (CEAA Registry Doc# 299)

GOLDER. 2011a. Aquatic Environment Technical Support Document. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-01 R000. Toronto, Canada. (CEAA Registry Doc# 299)

GOLDER. 2011b. Atmospheric Environment Technical Support Document. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-02 R000. Toronto, Canada. (CEAA Registry Doc# 299)

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to the Final Sub-set of Package #6 Information Requests”, CD# 00216-CORR-00531-00153, December 12, 2012. (CEAA Registry Doc# 832)

OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to a Sub-set of Package #4 Information Requests”, CD# 00216-CORR-00531-00138, September 6, 2012. (CEAA Registry Doc# 725)

MTIS 2 Undertaking:

OPG to document its confidence and the level of conservatism regarding the protection of listed species, at an individual level, from radionuclides.

OPG Response:

The Radiation and Radioactivity Technical Support Document (TSD) provides an assessment of radiological exposure and risks to populations of indicator species (AMEC NSS 2011). This approach is consistent with current Canadian and International standards (e.g., CSA 2012 and ICRP 2008) and practice (e.g., ENVIRONMENT CANADA and


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HEALTH CANADA 2003; OPG 2009).

For the DGR Project, calculations conducted for populations of indicator species are also representative of the effects to individuals of listed species. In order to demonstrate this, it is necessary to address the following three issues:

1. Is the assessment of doses to populations of non-human biota described in the Radiation and Radioactivity TSD also valid for individuals?

Spatial and temporal variability relative to the distribution of contamination in the environment can be taken into account when evaluating internal and external doses to populations of non-human biota. Such averaging, over the size of habitat for populations or over time, is reasonable for hundreds of individuals but may not be sufficiently conservative for individuals.

2. Are the dose criteria applied to populations also protective of individuals?

For individual plants and animals, especially listed species, the health effects of concern (endpoints) could be different from the effects of concern in protection of populations. Furthermore, it is necessary to demonstrate that Estimated No Effect dose rate Values (ENEVs) applied in the assessment of population effects (AMEC NSS 2011, Section 8.1.1.2) are also valid for individuals of listed species.

3. Will the listed species be protected given that the assessment was carried out for indicator species?

Indicator species considered in the Radiation and Radioactivity TSD (AMEC NSS 2011, Table 4-1) are not identical to the listed species as described in the Terrestrial Environment TSD (GOLDER 2011).

These three issues are addressed below.

1. Validity of Dose Assessment

Non-human biota could be exposed to radiation and radioactivity via direct exposure (gamma exposure) from waste packages or through indirect exposure to radioactivity in environmental media (various pathways) as follows:

Indirect Exposure to Emissions:

Releases of radionuclides from the DGR Project during the operation and decommissioning phases could lead to exposure of non-human biota via different pathways such as ingestion, inhalation or immersion in contaminated surface water.

Direct Exposure to External Radiation:

During operation of the DGR Project, waste packages will be transferred from the Western Waste Management Facility (WWMF) to the DGR via a crossing of the railway ditches. The packages may then remain in the above-ground Waste Package Receiving Building for a few days prior to transfer to the underground emplacement rooms. During this process, non-human biota along the transfer route and in the vicinity of the Waste Package Receiving Building may be exposed to gamma radiation from radioactive waste packages.

The indirect exposure scenario was assessed using maximum site concentrations (AMEC NSS 2011, Appendix C.1).


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There was no spatial or temporal averaging of environmental concentration of radionuclides. Therefore, assessment results for this exposure scenario are also conservative for individual organisms.

The direct exposure scenario considered external exposure to waste packages being transferred from the WWMF, or stored at the Waste Package Receiving Building (AMEC NSS 2011, Section 7). The assessment (for populations) accounted for some spatial and temporal averaging to account for the distribution of a large number of individuals within the population of a given species. It was conservatively assumed that indicator species would be exposed at a distance of 10 m, for a period of 1 hour per day, taking account of dimensions of habitats for indicator species, population size and indicator species’ habits.

The assumptions used in determining doses to non-human biota are considered to be conservative for populations as well as most individuals of a population because most individuals within the population would be located further from the waste packages than 10 m. Only in situations where an individual is exposed at a distance closer than 10 m, or for a period of time longer than 1 hour would the approach used for assessing doses to non-human biota not be conservative from an individual perspective.

The Terrestrial Environment TSD (GOLDER 2011, Section 5.8) identified listed species under the Ontario Endangered Species Act (Government of Ontario 2007) and the Canadian Species at Risk Act (Statutes of Canada 2002). No listed species were identified as using habitat within the Project Area. Within the Local Study Area listed species of flora and fauna were identified, with fauna including birds and herpetofauna. In the wider Regional Study Area, listed species of flora and fauna were identified, with fauna including birds, herpetofauna, mammals and insects. However, as discussed in OPG’s response to Information Request EIS-07-305 (OPG 2012), eastern meadowlark (Sturnella magna) and Canada warbler (Wilsonia Canadensis) have been reclassified since the submission of the Terrestrial Environment TSD (GOLDER 2011) and would now be considered listed species. These newly-listed species were present in the Site Study Area during the field programs for the DGR Project.

Because no listed species were identified as using habitat within the Project Area, individuals of listed species of flora are only predicted to grow at a distance well beyond 10 m from any waste package. In addition, individuals of listed species of fauna are predicted to use preferred habitat located well beyond 10 m from any waste packages. In the event that an individual of a listed species of fauna traversed into the Project Area, it is likely the period of exposure would be relatively short.

The category of fauna most likely to traverse into the Project Area is birds, as they are highly mobile and can cover large areas while foraging. However, vegetation within the DGR Project site will be cleared during the site preparation and construction phase. Thus, there will be limited suitable habitat for individuals of listed bird species in close proximity (i.e., within 10 m) of the waste packages or the Waste Package Receiving Building.

Although the rooftops of structures associated with the DGR Project have the potential to provide suitable nesting or loafing habitat for common species of birds that are habituated to anthropogenic land use, these structures are not likely to provide suitable nesting or loafing habitat for individuals of the listed bird species. Although not currently present in the Project Area, the on-going human disturbance associated with the daily operations of the DGR Project is likely to preclude the use of these structures by individuals of listed bird species.

Although no individuals of listed herpetofauna species were identified within the Project Area, there is a limited amount of


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potential habitat available. While much of this (e.g., south-east swamp) is located hundreds of metres from waste packages, either in transit from the WWMF or staged at the Waste Package Receiving Building, both the North and South Railway Ditches are relatively close as they pass through the culvert under the rail bed crossing. However, the planned layout of the DGR Project shows that the closest point of unshielded exposure within the North and South Railway Ditches would be at least 16 m from the waste packages, which is beyond the distance of 10 m considered in the Radiation and Radioactivity TSD (AMEC NSS 2011, Section 7). Individuals of listed herpetofauna species using the culvert have the potential to be exposed to considerably lower doses because of the shielding provided by the 3 m of granular fill between the road surface and the concrete culvert. Given this potential exposure would occur as the packages cross the culvert under the rail bed crossing, the period of exposure would not exceed 1 hour per day. Furthermore, no individuals of listed herpetofauna species were identified in the Project Area and exposures as described above are unlikely to occur.

In summary, there were no individuals of listed species identified within the Project Area. Furthermore, individuals of listed fauna species within the Local Study Area (i.e., birds and herpetofauna) would be exposed for relatively short periods of time, and at distances greater than 10 m if exposed at all. Therefore, any individual of a listed species would experience a lower exposure than used in evaluating the exposure to populations of non-human biota.

2. Applicability of Dose Criteria to Individual Organisms

There is no equivalency between dose response in representative individual organisms and populations of non-human biota. The reasons are twofold:

a. Potential difference in endpoints of concern between individual organism and population of the same species.

b. Even for the same endpoint, radiation effect in an individual organism may not result in discernible effect on the growth rate of the population.

However, in practice, criteria established for populations of non-human biota are generally protective of individual representatives for the following reasons (DOE 2002):

The vast majority of the available information on effects in populations is derived from experiments conducted in laboratory conditions at the individual level, which is where most of the available information on dose–effect relationship originates (ENVIRONMENT CANADA and HEALTH CANADA 2003). The extrapolation from individuals to populations is associated with uncertainty, usually resulting in the application of safety factors and in dose criteria that are set at levels significantly below effects observed at the individual level.

Estimated No Effect Values (ENEVs) for exposure to radioactivity are often used as population level criteria and are based on the lowest dose at which any effects are observed in any species of a given Valued Ecosystem Component (VEC) (e.g., Pelagic and Benthic Fish, Aquatic and Terrestrial Bird, Aquatic and Terrestrial Mammal, Benthic and Terrestrial Invertebrates, Amphibians and Reptiles and Aquatic and Terrestrial Vegetation). Thus, if it is assumed that the species studied include those which are among the more radiosensitive, the dose criteria intended to ensure that there would be no significant effects at a population level should ensure that there would be no observable effects on individual members of a species (DOE 2002).

Therefore, the ENEVs applied for the assessment of radiation doses to indicator species (AMEC NSS 2011,


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Section 8.1.1.2) can be used as a benchmark for assessing doses to individual representatives of non-human biota.

3. Protection of Listed Species

Although indicator species selected in the assessment were not always identical to listed species, protection of populations of indicator species will also protect individuals of listed species. Characterization of all listed species is not always feasible due to the number of listed species in the Local Study Area and limitations in the available data. For this reason it is a common practice in ecological management that, in order to assess the status of a particular area, or ecosystem type, studies are made for those species that are regarded as ‘typical’ or ‘representative’ (ICRP 2008; EC 2005; OPG 2009). Nevertheless, protection of indicator species provides a reasonable degree of confidence for protection of other species with similar characteristics and behavioural patterns.

Population-level criteria are usually based on observed dose-response relationships of a limited number of species, as more data are often not available. In order to account for uncertainties, including the extrapolation to other species of a certain type (e.g., birds and herpetofauna), multiple safety factors are normally used in setting the criterion to ensure that it will be protective of any species within the type under consideration, including listed species. The ENEVs for a particular category of non-human biota are generally based on the most radiosensitive species within the category (ENVIRONMENT CANADA and HEALTH CANADA 2003), thus providing protection to listed species.

In addition, estimated doses for the indicator species considered in this assessment are several orders of magnitude below the respective ENEVs (criteria) for their groups. It is unlikely in this assessment that the listed species would have significantly different doses than those of the indicator species of the corresponding type. Generally, the method used to assess doses to non-human biota is not sensitive to variations in habits between indicator species and listed species within the same group. Thus there is good confidence that the listed species also have doses well below the criteria.

On this basis it can be concluded with a high level of confidence that the use of conservative criteria, bounding source terms and conservative assumptions in the evaluated exposure of indicator species protects listed species present in the Local Study Area at the individual level for the DGR Project.

References:

AMEC NSS. 2011. Radiation and Radioactivity Technical Support Document. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-06 R000. Toronto, Canada. (CEAA Registry Doc# 299)

CSA. 2012. Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills. CSA N288.6-12.

DOE. 2002. A Graded Approach for Evaluating Radiation Doses to Aquatic and Terrestrial Biota. Module 2 Detailed Guidance. U.S. Department of Energy DOE-STD-1153-2002.

EC. 2005. Assessment, monitoring and reporting of conservation status – preparing 2084 the 2001-2007 report under Article 17 of the Habitats Directive. EC DG Env. 2085 B2/AR D (2004).

ENVIRONMENT CANADA and HEALTH CANADA. 2003. Priority Substance List Assessment Report – Releases of Radionuclides from Nuclear Facilities (Impact on Non-Human Biota). Canadian Environmental Protection Act.

GOLDER. 2011. Terrestrial Environment Technical Support Document. Golder Associates report for the Nuclear Waste


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Management Organization NWMO DGR-TR-2011-05 R000. Toronto, Canada. (CEAA Registry Doc# 299)

Government of Ontario. 2007. Endangered Species Act S.O. 2007, Chapter 6.

ICRP. 2008. Environmental Protection - the Concept and Use of Reference Animals and Plants. ICRP Publication 108.

OPG. 2009. Ecological Risk Assessment and Assessment of Effects on Nonhuman Biota: Technical Support Document New Nuclear – Darlington.

OPG. 2012. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to Package # 7 Information Requests”, CD# 00216-CORR-00531-00151, December 20, 2012.

Statutes of Canada. 2002. Species at Risk Act. Chapter 29. Canada Gazette Part III, Ottawa, January 31, 2003.

MTIS 3 Undertaking:

OPG to provide a clearer version of the graphic on slide 196, including the locations of the receptors and wildlife receptors, the dBA level at each receptor, and a legend.

OPG Response:

Two figures with the predicted noise levels for the DGR project are attached:

Figure 1, Predicted Noise Levels (dBA), Site Preparation and Construction Figure 2, Predicted Noise Levels (dBlin), Site Preparation and Construction.

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REV. 0.0

Mississauga, Ontario

DESIGN

PREDICTED NOISE LEVELS (dBA)SITE PREPARATION AND CONSTRUCTION

FIGURE: 1PROJECT NO. 10-1151-0440 SCALE AS SHOWN

PROJECT

TITLE

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REVIEW

ME 23 Oct. 2012

CHECK

DGR PROJECTTECHNICAL INFORMATION SESSIONS

ME 23 Oct. 2012KLC

23 Oct. 2012

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REFERENCE

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Site Location

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Base Data - MNR LIO, obtained 2009Produced by Golder Associates Ltd under licence from Ontario Ministry of Natural Resources, © Queens Printer 2012Projection: Transverse Mercator Datum: NAD 83 Coordinate System: UTM Zone 17

REV. 0.0

Mississauga, Ontario

DESIGN

PREDICTED NOISE LEVELS (dBlin)SITE PREPARATION AND CONSTRUCTION

FIGURE: 2PROJECT NO. 10-1151-0440 SCALE AS SHOWN

PROJECT

TITLE

GIS

REVIEW

ME 23 Oct. 2012

CHECK

DGR PROJECTTECHNICAL INFORMATION SESSIONS

ME 23 Oct. 2012KLC

23 Oct. 2012

!

!

!

!

!

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Sarnia

Toronto

Barrie

Goderich

Kincardine

Kitchener

REFERENCE

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INDEX MAP

SCALE

Site Location

Lake Huron

1:25,000

500 0 500 1,000 1,500250METRES

Lake Ontario

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andrew müller - impact assessment agency · particulate matter [spm]) due to site preparation and...

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