· attachment to opg letter, albert sweetnam to dr. stella swanson, “deep geologic repository...

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ATTACHMENT

Attachment to OPG letter, Albert Sweetnam to Dr. Stella Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to the First Sub-set

of Package #8 Information Requests”

February 14, 2013

CD#: 00216-CORR-00531-00160

OPG Responses to the First Sub-set of IRs From Joint Review Panel IR Package #8

This attachment includes responses to the following IRs:

EIS-08-315 EIS-08-352

EIS-08-317 EIS-08-363

EIS-08-318 EIS-08-364

EIS-08-319 EIS-08-365

EIS-08-324 EIS-08-366

EIS-08-326 EIS-08-372

EIS-08-329 EIS-08-373

EIS-08-332 EIS-08-374

EIS-08-337 EIS-08-375

EIS-08-338 EIS-08-376

EIS-08-339 EIS-08-377

EIS-08-341 EIS-08-378

EIS-08-342 EIS-08-381

EIS-08-343 EIS-08-383

EIS-08-344 EIS-08-389

EIS-08-346 EIS-08-391

EIS-08-347 EIS-08-392

EIS-08-348 EIS-08-393

EIS-08-349 EIS-08-395

EIS-08-350 EIS-08-399

Attachment to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to the First Sub-set of Package #8 Information Requests”, CD# 00216-CORR-00531-00160

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OPG Responses to the First Sub-set of IRs from Joint Review Panel IR Package #8

IR# EIS Guidelines Section

Information Request and Response

EIS-08-315 Section 10.1.1 Geology and Geomorphology

Information Request:

Provide a clear assessment via the 3DGFM of the influence of major basement features on the occurrence of faults and fractures in the megablock encompassing the DGR site.

Provide information on the possible role of the Midcontinent Rift, a significant basement feature shown in the seismic hazard report, on some Paleozoic fracturing in the RSA.

Context:

Basement-seated faults and known tectonic boundaries can be expected to cross cut Paleozoic strata in the vicinity of the proposed DGR site. The block models and contour maps span more than 150km and can reasonably be expected to be affected by basement-seated faults.

Basement-seated faults are important as the main features that are the likely controls on fracturing and faulting in the vicinity of the DGR.

Basement-seated faults and tectonic boundaries have been identified within the RSA in the regional geology report (Figure 3.4) and in the seismic hazard report.

Faults and fractures in limestone within the RSA, which are parallel to basement features, are likely the result of reactivation. Other faults that cross-cut Grenville structures may relate to the Ottawa-Bonnechere graben. This leads to two types of basement-seated faults that occur in the RSA. 1. Steep NNE trending early Paleozoic faults, formed by reactivation of mesoproterozoic faults in the Grenville basement 2. NE trending faults that cut Grenville structures, probably associated with the Ottawa-Bonnechere graben.

The reactivation of basement-seated faults is an important control on sedimentation and fault propagation in intracratonic basins, including the Michigan Basin, which encompasses the proposed DGR site. In southern Ontario, “the reactivation of basement-seated faults is suspected to control the location of Paleozoic faults and fracture systems” (Boyce and Morris, 2002). Therefore, proper documentation of these features at the proposed DGR site and how they impact on the RSA is essential.

Basement-seated faults cutting Cambrian and Mid-Ordovician strata are generally aligned NNE, in parallel with structures in the underlying rocks of the Grenville orogen and may be the result of reactivation of Grenville basement structures.

Faults that cross-cut pre-existing basement structures are:

EW-trending faults in the southwest corner of Ontario;


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the Ottawa-Bonnechere graben and related faults (early Paleozoic) part of the St Lawrence Rift extending from Montreal to the northeast corner of Georgian Bay; and

NE trending faults south and southeast of Bruce

In other parts of southern Ontario, basement-rooted faults that have displaced Cambrian and Ordovician strata are associated with hydrothermal dolomitization (HTD) and with oil and gas pools.

OPG Response:

The primary roles of the 3D Geological Framework Model (3DGFM) (ITASCA CANADA and AECOM 2011) were to define the stratigraphic and spatial continuity of Paleozoic bedrock formations at the regional scale and to provide both context for the site-specific investigations at the Bruce nuclear site, and to provide a rationale for extrapolation of site conditions (stratigraphic continuity) beyond the DGR site. The 3DGFM was created using the same Oil, Gas and Salt Resources Library (OGSR 2004 and 2006) dataset (including key control point boreholes) employed in determining the regional scale stratigraphic architecture, and the history and spatial distribution of basement-seated faults, of southern Ontario (Armstrong and Carter 2010).

It is acknowledged, as discussed in Boyce and Morris (2002), that the reactivation of basement-seated faults is suspected to control the location of Paleozoic faults and fracture systems. The aeromagnetic lineament interpretation of Boyce and Morris (2002) was in good agreement with the Sanford et al. (1985) fracture model for the Niagara megablock region, but showed poor correlation with fracture patterns within the Bruce megablock. This partial correlation is consistent with the understanding that there is a fundamental difference in the fault pattern (and underlying basement structure) between the Appalachian Basin and Michigan Basin sides of the Algonquin Arch, as suggested by Cruden (2011). Differences include a notable decrease in fracture density on the Michigan Basin side of the arch, and recognition that Silurian-aged faults are restricted to the Niagara Megablock, suggesting that the basement structure beneath the Bruce megablock is less pervasive and simpler than that beneath the Niagara Megablock (AECOM and ITASCA CANADA 2011, Section 3.1.3). This simple regional scale basement structure pattern for the Bruce megablock is consistent with the following lines of evidence.

The regional micro-seismic monitoring network confirms the lack of low-level seismicity (> M1.0), implying no seismogenic structures or faults within or in close proximity to the DGR footprint (INTERA 2011, Section 5.3 and Figure 5.2).

An analysis of the seal capability of the Ordovician shale cap-rock, including examination of the degree of hydrocarbon maturation, the longevity of formation underpressures, burial history, and tectonic controls on sedimentation, found that the shales have maintained their integrity for geologically long periods of time and that this would continue to be the case in the future (Engelder 2011).

The simple planar continuation of formation contacts from the DGR boreholes to those within the Texaco #6 well 2.9 km away to the southeast argues strongly against the presence of vertical faults within the Paleozoic bedrock at, or near, the Bruce nuclear site, across distances of several km (INTERA 2011, Figure 3.71).


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The lack of economically viable hydrocarbon pools within the regional study area, as discussed previously in OPG’s response to Information Request EIS-05-162 (OPG 2012).

Calculations of the depth, thickness and strike and dip of the Paleozoic bedrock formations and marker beds at the Bruce nuclear site (INTERA 2011, Tables 3.1 and 3.2) show remarkable uniformity, particularly below the Salina B Unit. This uniformity in depth and orientation of DGR strata below the Salina B Unit argues against significant faulting having disturbed formation contacts. The presence of possible fault structures, identified from seismic lines, was investigated through inclined drilling of boreholes DGR-5 and DGR-6. These boreholes found no evidence of vertical offsets in the targeted horizons (INTERA 2008). Site investigation work (INTERA 2011) from the DGR series boreholes, and additional modelling work, (where referenced) yield the following results.

In situ straddle packer testing yielded average hydraulic conductivities of 10-11 m/s or less throughout the Ordovician interval, as well as anomalously high vertical hydraulic gradients, which could not be sustained in the presence of conductive through-going faults (NWMO 2011, Figure 5.1).

Underpressures in the Ordovician shales and Trenton Group limestones, with maximum underpressures occurring within the Blue Mountain Formation equal to environmental heads of 300 mBGS, as well as the strong overpressures in the Cambrian sediments (NWMO 2011, Section 5.2.2.2), could not be sustained in the presence of vertical/sub-vertical through-going fault-controlled transmissive pathways.

No evidence of shear zones, slickensides, cataclasites, fault gouge, or a fault-related offset in the stratigraphy within the core recovered from the targeted intervals (NWMO 2011, Section 2.3.9.1).

There is no evidence in the borehole drilling and testing program for widespread hydrothermal dolomitization, or an attendant fault (plumbing) system, as indicated by the presence of only minor dolomite occurrences throughout much of the Ordovician strata (NWMO 2011, Section 2.3.9.3).

Upward propagation of faulting from the Precambrian is the most likely mode of paleofault formation for the Ordovician sedimentary sequence in southern Ontario (Carter et al. 1996). No faults younger than the Trenton Group limestones have been mapped in this part of southern Ontario (Armstrong and Carter 2010).

A quantitative assessment was performed on the potential effects of a transmissive sub-vertical fracture or fault located in the vicinity of the DGR (Sykes et al. 2011, Sections 4.5.4 and 7.2.1). The results indicate that a transmissive fault in close proximity to the DGR is inconsistent with the physical and chemical hydrogeological data and observations at the Bruce nuclear site. A further quantitative assessment of safety implications is provided by QUINTESSA et al. (2011, Sections 6.2.5 and 7.2.4) in their vertical fault scenario analysis. These results indicate that an unknown fault in the vicinity of the DGR would lead to hypothetical public doses significantly less than the established dose criterion.

Several regional-scale tectonic structures, including the Ottawa-Bonnechere Graben and the Mid Continent rift and the Grenville Front tectonic zone, are evident in the basement rocks surrounding and beneath the regional study area and the Bruce Megablock. The Mid Continental Rift terminates within the Grenville Front at the border between Michigan and Ontario, with no evidence to suggest that the rift extends into Southwestern Ontario (Hinze et al. 1992). In addition,


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apart from localized periodic reactivation during the Mesozoic Era (after 250 Ma), the Grenville Province in southern Ontario is presently considered to be a tectonically stable part of the North American craton (Percival and Easton 2007).

Within the Bruce megablock, as evidenced by several NWMO studies (INTERA 2011, Cruden 2011, and ITASCA and AECOM 2011), site-scale, local and regional observations do not support the Sanford et al. (1985) conceptual fracture model and, instead, suggest that structures within the Bruce megablock fit a pattern consistent with Paleozoic intraplate deformation associated with the Michigan Basin. The multiple lines of regional and site-scale evidence described above do not suggest any likelihood that the megablock encompassing the DGR site hosts any as-of-yet undetected basement-seated faults that would be detrimental to the safety case for the proposed DGR.

No faults younger than the Trenton Group limestone’s have been mapped within this part of southern Ontario (Armstrong and Carter 2010).

The closest reported Ordovician reservoir is situated some distance away, with none found within a 40 km radius of the proposed site (NWMO 2011, Figure 2.20).

Borehole DGR-6 fully intersected the seismically interpreted fault occurrence window in the Georgian Bay, Blue Mountain, Cobourg, Sherman Fall and Coboconk formations before terminating within the upper part of the Gull River Formation (INTERA 2011, Figure 3.59). The results of core logging, borehole geophysical logging and hydraulic testing of both DGR-5 and DGR-6 show no evidence of fault presence, as characterized by increased fracturing, dolomitization and/or increased formation hydraulic conductivity.

Environmental water heads measured from the DGR boreholes display significant underpressures implying that the (Ordovician) formations in which they are measured must be of extremely low permeability in order for them to persist (INTERA 2011, Section 6.2). This is indicative of a lack of proximal structures (see point above) which would create noticeable perturbations within these horizons and environmental tracers by enhancing transport pathways.

To conclude, multiple lines of evidence at both the regional and site-scale indicate that basement features within the Huron Domain may not exert as strong an influence on geologic structure in the overlying Paleozoic sediments, as occurs in the Niagara megablock. No new evidence has been obtained during the DGR investigations that would provide reason to identify geologic structure within the Paleozoic sequence of the RSA other than that documented in NWMO (2011, Section 2.2). In particular, site-specific investigations at the DGR footprint scale have found no evidence for the occurrence of Ordovician fault structure that would compromise the DGR safety case.

References:

AECOM and ITASCA CANADA. 2011. Regional Geology – Southern Ontario. AECOM Canada Ltd. and Itasca Consulting Canada, Inc. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-15 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

Armstrong, D.K. and T.R. Carter. 2010. The Subsurface Paleozoic Stratigraphy of Southern Ontario. Ontario


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Geological Survey, Special Volume 7.

Boyce, J.J. and W.A. Morris. 2002. Basement-controlled faulting of Paleozoic strata in southern Ontario, Canada. New evidence from geophysical lineament mapping. Tectonophysics 353, pp.151-171.

Carter T.R., R.A. Treveil and R.M. Easton. 1996. Basement controls on some hydrocarbon traps in southern Ontario, Canada. In: B.A. van der Pluijm and P.A. Catacosinos (eds.), Basement and Basins of Eastern North America. Geological Society of America Special Paper 308, 95-107.

Cruden, A. 2011. Outcrop Fracture Mapping. Nuclear Waste Management Organization report NWMO DGR-TR-2011-43 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

Engelder, T. 2011. Analogue Study of Shale Cap Rock Barrier Integrity. Nuclear Waste Management Organization report NWMO DGR-TR-2011-23 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

INTERA. 2008. Phase 2 Geoscientific Site Characterization Plan, OPG’s Deep Geologic Repository for Low and Intermediate Level Waste, Report INTERA 06-219-50-Phase 2 GSCP-R0, OPG 00216-PLAN-03902-00002-R00. Ottawa, Canada.

INTERA. 2011. Descriptive Geosphere Site Model. Intera Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-24 R000. Toronto, Canada. (CEAA Registry Doc# 300)

ITASCA CANADA and AECOM. 2011. Three-Dimensional Geological Framework Model. Itasca Consulting Canada, Inc. and AECOM Canada Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-42 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

Hinze, W.J., D.J. Allen, A.J. Fox, D. Sunwood, T. Woelk and A.G. Green. 1992. Geophysical investigations and crustal structure of the North American Midcontinent Rift system. Tectonophysics, Volume 213, Issues 1–2, 30 October 1992, pp. 17-32.

OGSR. 2004. Cumulative oil and gas production in Ontario to the end of 2004. Excel format data. In. Members Package Dataset. Petroleum Resources Centre, Ministry of Natural Resources Oil, Gas & Salt Resources Library.

OGSR. 2006. Oil and Gas Pools and Pipelines of Southern Ontario, revised October 2006. Petroleum Resources Centre, Ministry of Natural Resources Oil, Gas & Salt Resources Library UTM NAD83. Ontario Digital Base Data.

OPG. 2012. 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 #5 Information Requests”, CD# 00216-CORR-00531-00146, November 7, 2012. (CEAA Registry Doc# 793)

NWMO. 2011. Geosynthesis. Nuclear Waste Management Organization report NWMO DGR TR-2011-11 R000.


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Toronto, Canada. (CEAA Registry Doc# 300)

Percival, J.A. and R.M. Easton. 2007. Geology of the Canadian Shield in Ontario. An Update. OPG Report 06819-REP-01200-10158-R00, OGS Open File Report 6196, GSC Open File Report 5511.

QUINTESSA, GEOFIRMA and SENES. 2011. Postclosure Safety Assessment. Quintessa Ltd., Geofirma Engineering Ltd., and SENES Consultants Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-25 R000. Toronto, Canada. (CEAA Registry Doc# 300)

Sanford, B.V., F.J. Thompson and G.H. McFall. 1985. Plate tectonics – A possible controlling mechanism in the development of hydrocarbon traps in southwestern Ontario. Bulletin of Canadian Petroleum Geology 33, pp.52-71.

Sykes, J.F., S.D. Normani and Y. Yin. 2011. Hydrogeologic Modelling. Nuclear Waste Management Organization report NWMO DGR-TR-2011-16 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

EIS-08-317 Section 10.1.1, Geology and Geomorphology

Section 11.4.1, Geology and Geomorphology


Describe the sampling method used to protect the samples from contamination by drilling fluids.

Context:

Opportunistic water samples were acquired and analysed during the drilling of DGR-1 to DGR-8.

OPG Response:

In order to assess drilling fluid contamination, all drill waters were tagged with a tracer, sodium fluorescein (NaFl), in the field. The methodology to correct for drill fluid contamination in the Opportunistic Groundwater (OGW) samples (DGR-1 through DGR-6) is summarized below and can be found described in the relevant Technical Reports (Jackson and Heagle 2010, Section 3; and Heagle and Pinder 2010) and in the Descriptive Geosphere Site Model (INTERA 2011, Section 4.5.2). Opportunistic groundwater sampling methods are further described and stipulated in Test Plan developed as part of the Project Quality Plan (Jackson and Clark 2007; Jackson et al. 2008 and Heagle 2009).

Once each permeable horizon identified for OGW sampling was reached, drilling was halted, a packer was inflated above the sampling interval, and drilling fluid was circulated in the borehole. The fluid was sampled when it returned to surface, and was identified as the ‘drill water return’, which provided a representative sample of the drilling fluid chemistry for that particular sampling horizon.

Prior to collection of the opportunistic groundwater samples, the waters were purged from the isolated permeable horizon(s) by swabbing the drill rods. Swabbing deploys a rod-like device into the drill rods down to the top of the packer. The rod is pulled to the surface as rapidly as possible, pulling both drilling fluid and groundwater to surface. During the DGR sampling campaign, each swab purged, on average, 70 L from the test interval and the drill tubing.


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Following each purge, the groundwater was analyzed in the field for the NaFl concentration and electrical conductivity (EC). Collection and analysis of the OGW samples only occurred in the field when on-site estimates of drilling fluid contamination (using the measurements of NaFl) were <3% and EC values between sequential purges had stabilized (i.e., similar values obtained between purges).

Sampling was carried out by collecting fluid in the drill rods by one of three methods, which are detailed in Jackson and Heagle (2010) and Heagle and Pinder (2010). The first method used a submersible Grundfos pump to bring the groundwater to surface (when the water level in the drill rods was 70 m below ground surface or less). The second method used Westbay sampling containers to retrieve the groundwater (when the water level was too deep to pump using the Grundfos). The third method was only used for the Cambrian formation and involved the installation of a valve on the top of the drill rods to control the rate of groundwater flow due to the flowing artesian conditions encountered in the Cambrian aquifer. It should be noted also that OGW samples from the Cambrian (OGW-6, OGW-7, OGW-10 and OGW-13) were not swabbed and purged. Flowing artesian conditions in the Cambrian provided a natural purge of the drill fluid from the borehole. For all three sampling methods, groundwater was discharged directly into two serially-connected flow cells at surface (see Figure 1 below), where electrodes measured pH, dissolved oxygen (DO), temperature, and redox conditions (Eh). Additional groundwater samples were collected for both colourimetric and alkalinity testing in the field as well. Colourimetric tests for DO, iron and sulphide were performed (visual inspection only) in order to validate the DO and redox results from the flow cells.

Aliquots of the samples for laboratory analysis were preserved on-site (by filtration and acidification, where appropriate) and shipped to various laboratories for additional and confirmatory analyses. Additional aliquots exist as archived samples within the Core Storage Facility at the Bruce nuclear site as well.


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Figure 1: Serially-connected Flow Cells, with Electrodes Connected to Digital Voltmeters

Drilling fluid contamination was estimated further in the laboratory using tritium (3H) analysis. Although NaFl and EC were used as the field indicators for drill fluid contamination, tritium is considered to be the key parameter for calculating the percent drill fluid contamination because tritium is assumed to not be present in the formation waters where OGW samples were taken. All final OGW concentrations, corrected for drill water contamination, are based on the results of 3H analyses.

The OGW samples are expected to be representative of groundwater compositions due to the extensive purging activities prior to collection, resulting in minimal drilling fluid contamination.

References:

Heagle, D. 2009. DGR-5 and DGR-6 Opportunistic Groundwater Sampling and Analysis, Intera Engineering Ltd. Test Plan TP-09-03, Rev. 1, Ottawa, Canada.

Heagle, D. and L. Pinder. 2010. Opportunistic Groundwater Sampling in DGR-3 and DGR-4. Intera Engineering Ltd. Report TR-08-18, Rev.1. Ottawa, Canada. (available at http://www.nwmo.ca/dgrsitecharacterizationtechnicalreports)



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Jackson, R. and D. Heagle. 2010. Opportunistic Groundwater Sampling in DGR-1 and DGR-2. Intera Engineering Ltd. Report TR-07-11, Rev.2. Ottawa, Canada. (available at http://www.nwmo.ca/dgrsitecharacterizationtechnicalreports)

Jackson, R. and I. Clark. 2007. DGR-1 and DGR-2 Opportunistic Groundwater Sampling and Analysis. Intera Engineering Ltd. Test Plan TP-06-11, Rev. 5. Ottawa, Canada.

Jackson, R., K. Raven and I. Clark. 2008. DGR-3 and DGR-4 Opportunistic Groundwater Sampling and Analysis. Intera Engineering Ltd. Test Plan TP-08-05, Rev. 3. Ottawa, Canada.




Discuss the long-term plans for the archiving of the drill core acquired by DGR-1 to DGR-8 such that the geological value of the core may be preserved.

Context:

No context required.

OPG Response:

Drill core from boreholes DGR-1 to DGR-8 is currently preserved at the OPG core storage facility on the Bruce nuclear site, with a long-term plan to archive the core at the Oil Gas and Salt Resources (OGSR) Library in London, Ontario.

These eight boreholes were drilled under licence from the Ontario Ministry of Natural Resources (MNR) in accordance with the Oil Gas and Salt Resources Act and Provincial Operating Standards (OGSR 2002). Section 13.7 of the Operating Standards requires the operator to ensure that no core is destroyed, except for the purposes of analysis, and that cores are delivered to the OGSR Library at the operator’s expense within one year after the TD (total depth) date of the well.

In consideration of potential DGR project requirements during licencing, the MNR has approved in writing a departure from Section 13.7 that allows for the core (approximately 4700 m) to be kept at the DGR core storage facility, building OBD (B25, RR#3, Tiverton, Ontario) until 2019 (MNR 2012). At that time the core must be delivered to the OGSR library for permanent archiving, if an extension to the agreement is not sought.

At the time of core collection, prior to any sampling, a series of six overlapping high resolution digital photographs are taken of each 3 m core run, and archived in DGR project records. Core remaining after sampling is stored in 3 m capacity wooden core boxes labeled with the borehole, core run and licence numbers, date retrieved and top and bottom depths. Core orientation is maintained by two different coloured lines drawn along the core axis to indicate the “up borehole” direction. Wooden core blanks replace core selected for preservation and testing in the core boxes and all core blanks are labeled as to core sample number, the length of sample, and the purpose of the sample analysis. The boxes are shelved sequentially and the facility is climate controlled with security controlled access. Remaining vacuum


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sealed archival samples are kept in refrigeration at temperatures between 4 and 10°C and a database of the samples is maintained.

References:

OGSR. 2002. Provincial Operating Standards, Version 2.0. Approved by the Ministry of Natural Resources on March 27, 2002. Produced by the Oil, Gas and Salt Resources Library under licence from Ontario Ministry of Natural Resources. Queens Printer for Ontario, 2002.

MNR. 2012. Letter from MNR to Mark Jensen, “Request for Departure from Provincial Standards under the Oil, Gas and Sail Resources Act – Well Licences 11582,11583,11811,11812,11926, 12102 and 12103. Core Maintenance, S.13.7, Provincial Standards”, April 10, 2012.




Provide a geological explanation for the highly fractured bedrock above and including parts of the Salina Group, and comment on its relevance to the integrity of the proposed repository.

Context:

The Rock Quality descriptions of DGR-3 and DGR-4 document highly fractured bedrock above and including parts of the Salina Group.

OPG Response:

The near-surface bedrock beneath the Bruce nuclear site comprises Devonian carbonate rocks underlain by Silurian carbonates, evaporites and shales (INTERA 2011, Figure 3.2). Rock quality within the DGR boreholes is displayed in Figure 3.4 of INTERA (2011), indicating that the upper 170 m of bedrock to the top of the Salina Group contains a high concentration of fractures, which decrease in frequency as depth increases. Within the Salina formation, good to excellent rock quality is observed, except for minor intervals within the Salina that correspond to salt dissolution horizons within the Salina B and D units (INTERA 2011, Section 6.1). The fractures observed in these Devonian and Silurian formations are attributed principally to the dissolution of the Salina salt units, specifically the B-salt, which coincided with large scale tectonic events at the margins of the North American plate during the Paleozoic (AECOM and ITASCA CANADA 2011, Section 4.2.6).

The observed fracturing in the sediments described above can influence permeability distributions within the near-horizontally layered sedimentary sequence. Contributions to rock mass permeability will be influenced by karst process (WORTHINGTON 2011), lithostatic loading, dolomitization, evaporate and calcite fracture cementation and infilling (AECOM and ITASCA CANADA 2011, Section 7.5; Cruden 2011, Section 5.5). Among other factors, the observed sedimentary sequence stratigraphy, formation permeabilities, and both groundwater and porewater chemistries were


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used to derive a conceptual hydrogeologic model of the site (INTERA 2011, Section 4.13). This conceptual model captures the physical and chemical aspects of the groundwater system within the sedimentary sequence as described by Sykes et al. (2011, Section 2.6) and NWMO (2011, Section 5). Numerical groundwater system analyses, coupled with evidence from site specific analogues of environmental tracer and hydraulic head distributions within the sedimentary sequence, strongly support a conclusion that Ordovician sediments in which the DGR would be positioned is isolated from the systems occurring in the overlying Salina Group, upper Silurian and Devonian sediments. This is reflected within the postclosure safety assessment as described by OPG (2011, Section 8).

In summary, characterization of the groundwater system within the sedimentary sequence beneath the Bruce nuclear site illustrates that the fractured rock above the Salina Group has no influence on the long-term integrity and safety of the proposed DGR. The shallow and intermediate groundwater systems associated with these bedrock formations are isolated from the Ordovician deep-seated diffusion-dominated groundwater system that is proposed to host the DGR. The aforementioned postclosure safety assessment, through analyses of repository normal evolution and extreme or ‘what if’ scenarios, provides further information and assurance that the shallow and intermediate systems are not material to DGR integrity or the safety case.

References:

AECOM and ITASCA CANADA. 2011. Regional Geology – Southern Ontario. AECOM Canada Ltd. and Itasca Consulting Canada Inc. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-15 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

Cruden, A. 2011. Outcrop Fracture Mapping. Nuclear Waste Management Organization report NWMO DGR-TR-2011-43 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)


NWMO. 2011. Geosynthesis. Nuclear Waste Management Organization report NWMO DGR-TR-2011-11 R000. Toronto, Canada. (CEAA Registry Doc# 300)

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste - Preliminary Safety Report. Ontario Power Generation report 00216-SR-01320-0001 R000. Toronto, Canada. (CEAA Registry Doc# 300)

Sykes, J.F., S.D. Normani and Y. Yin. 2011. Hydrogeological Modelling. Nuclear Waste Management Organization report, NWMO DGR-TR-2011-16 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

WORTHINGTON. 2011. Karst Assessment. Worthington Groundwater report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-22 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)


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EIS-08-324 Section 10.1.8, Climate, Weather Conditions and Air Quality

Section 11.4.7, Atmosphere


Explain why MOE standards and AAQC values for emissions from stationary sources were not applied when considering project emissions.

Context:

On page 31 of the Atmospheric Environment TSD, the proponent suggests that there is some latitude when considering emissions from selected stationary sources under Ontario Regulation 419/05.

However, MOE indicated that for this Project, no exemptions apply.

OPG Response:

The air modelling presented in the Atmospheric Environment Technical Support Document (TSD) (GOLDER 2011) was completed using acceptable practice for an environmental assessment under the Canadian Environmental Assessment Act, and used an approach similar to that used in previous assessments completed for projects on the Bruce nuclear site. Consistency with these previous assessments provides a point of reference and context for both stakeholders and regulators when reviewing the DGR Project effects. The predicted air quality included emissions from all sources at the Bruce nuclear site and the DGR Project (i.e., stationary and mobile sources) and existing background.

As stated on page 31 of the Atmospheric Environment TSD “… O. Reg 419/05 considers the emissions from selected stationary sources only. Ontario exempts emission sources associated with construction activities from evaluation (MOE 2007). Similarly, evaluations in accordance with O. Reg. 419/05 do not include considerations of background concentrations.” This statement is not suggesting that the stationary sources are exempt, but rather that emission sources associated with construction activities and vehicular/mobile sources are exempt.

Since the air quality assessment considers all of the sources of the Bruce nuclear site (i.e., stationary and mobile) and evaluates the effects of construction, it is not appropriate to apply O.Reg.419/05 criteria directly.

If all emitted species were to be evaluated against Ministry of the Environment (MOE) standards in accordance with O.Reg. 419/05 guidance, the emissions from construction activities and mobile emissions sources would have been excluded, resulting in virtually no emissions during the bounding scenario (Stage 1) of the site preparation and construction phase, and much lower emissions during the operations phase, which would not have properly represented the possible effects of the Project on the Valued Ecosystem Component (VEC) air quality.

As described in the Atmospheric Environment TSD (GOLDER 2011, Section 13.2), OPG acknowledges that an Environmental Compliance Approval (ECA [formerly Certificate of Approval (Air)]), will be required for the appropriate emission sources from the DGR Project. The ECA application for air emissions from the Project will be completed in accordance with O. Reg. 419/05 and/or regulations relevant at the time of application.


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References:

GOLDER. 2011. 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)

MOE. 2007. Certificate of Approval Exemptions - Air. Ontario Regulation 524/98. Ontario Ministry of Environment.




Confirm that the data used in the Atmospheric Environment TSD was approved by appropriate MOE staff.

Similarly, confirm that the data presented in Figure 5.3.4-1 on page 45 of the Atmospheric Environment TSD was reviewed by appropriate Ministry staff.

Context:

In Section 5.3.1 of the Atmospheric Environment TSD, the proponent speaks to the use of a local meteorological data set. The MOE indicated that while the use of a local data set may be appropriate in certain cases, the MOE requires that all such data be approved by modelling staff at the Ministry’s Environmental Monitoring and Reporting Branch (EMRB).

Furthermore, a comparison was made between the meterological data used in the TSD and slightly more recent data from Environment Canada’s station in Kincardine. The two data sets are slightly different. MOE suggested that while the differences are not profound, they underline the need to have the data be reviewed by MOE staff.

OPG Response:

The air modelling presented in the Atmospheric Environment Technical Support Document (TSD) (GOLDER 2011) was completed using acceptable practice for an environmental assessment under the Canadian Environmental Assessment Act, and used an approach similar to that used in previous assessments completed for projects at the Bruce nuclear site. Consistency with these previous assessments provides a point of reference and context for both stakeholders and regulators when reviewing the DGR Project effects.

As described in the Atmospheric Environment TSD (GOLDER 2011, Section 13.2), OPG acknowledges that an Environmental Compliance Approval (ECA [formerly Certificate of Approval (Air)]), will be required for the relevant emission sources of the DGR Project, and that approval by the Ministry of Environment (MOE) to use local meteorological data is required under section 13 of O. Reg. 419/05. The ECA application for air emissions from the project will be completed in accordance with O. Reg. 419/05 and/or regulations relevant at the time of submission.

A description of the development of and rationale for the meteorological data used in the environmental assessment is provided in the Atmospheric Environment TSD (GOLDER 2011; Appendix C, Section C2.2). The decision process used in selecting the appropriate data to use in the modelling is illustrated in Figure C2.2-1 of the Atmospheric Environment


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TSD (GOLDER 2011). A description of the QA/QC process for the meteorological data was provided in the OPG’s response to Information Request (IR) EIS-01-10 (OPG 2012).

As discussed in the Atmospheric Environment TSD (GOLDER 2011; Appendix C, Section C2.3), prior to developing a dispersion meteorology data set, on-site meteorological observations were compared with selected archived weather maps to identify whether the data recorded at the Bruce nuclear site matched with regional weather patterns. This comparison was done by a Canadian Meteorological and Oceanographic Society certified meteorologist. As noted in the context above, in general the archived weather patterns matched the on-site observations reasonably well.

The regional meteorological modelling data set recommended for use by the MOE at the Bruce nuclear site is based on surface data from Pearson International Airport in Toronto and upper air observations from Buffalo, NY. The regional meteorological data from Pearson International Airport were not considered to be suitable for use in this assessment for evaluating the emissions from the DGR Project since the facility is located 170 km to the west, on the shores of Lake Huron, and will be greatly influenced by winds and weather across the lake (GOLDER 2011, Appendix C).

References:


OPG. 2012. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to Information Requests”, CD# 00216-CORR-00531-00108, March 9, 2012. (CEAA Registry Doc# 363)




Provide more detail in the air quality assessment results in Section 8.2.3.2, including maps outlining off-property concentrations of the various modelled species, tables of maxima and averages, and frequencies of high values.

Context:

Results of the air quality assessment are presented in section 8.2.3.2 in the Atmospheric Environment TSD. The MOE indicated that considerably more detail is required in this section for a full evaluation, including separate tables and maps for different stages of the project.

OPG Response:

The Atmospheric Environment Technical Support Document (TSD) (GOLDER 2011) provides a comprehensive evaluation of the air quality effects associated with the DGR Project, including details regarding emissions, source configurations and modelling options in Appendix F to the TSD. The TSD also lists the maximum off-site concentrations for the indicator compounds predicted during the site preparation and construction phase, as well as during the


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operations phase. Predicted concentrations of all compounds emitted from the DGR Project at identified health receptors, including maximum, averages and percentiles were provided in Appendix J to the TSD.

Tables and figures showing the maximum off-site concentrations for all species emitted during the site preparation and construction phase of the DGR Project are included as part of OPG’s response to Information Request (IR) EIS-04-141 (OPG 2012). The maximum predicted off-site concentrations for each of the emitted compounds and the distance from the maximum concentration to each of the human health receptors are tabulated. Additionally, the locations of the maximum concentrations and the human health receptors were shown on Figure 1 enclosed with the response to IR-EIS-04-141 (OPG 2012).

References:


OPG. 2012. 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)

EIS-08-332 Section 10.2.7 Physical and Cultural Heritage Resources


Identify if there are any existing buildings or structures within the local and site study areas that are 40 or more years old, whether they will be removed or demolished for the project, and whether these actions will require consent from the Ontario Ministry of Tourism, Culture and Sport.

Context:

It is not clear whether there are any existing buildings or structures within the local and site study areas that are 40 or more years old. If the proponent wants to remove or demolish a building or structure of undetermined cultural heritage value, it must have consent from the Ministry of Tourism, Culture and Sport.

The DGR Project is located within the Bruce nuclear site on lands which are currently vacant (OPG 2011, Section 1.1.1).

The Kincardine Heritage Register (enclosed) provides a listing of heritage buildings in the Municipality of Kincardine, the Local Study Area for the Socio-economic assessment. Registered heritage buildings and structures located within approximately a 10 km distance of the Bruce nuclear site are shown on Figure 1 (at the end of this table).

No buildings, in the Site or Local Study Areas, will be removed or demolished for the Project. Therefore no consent will be required from the Ontario Ministry of Tourism, Culture and Sport.


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References:

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement, Volume 1. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298)

Municipality of Kincardine. Heritage Registry. (enclosed)

EIS-08-337 Section 10.2.2, Land Use and Value


Confirm whether OPG owns property adjacent to the Bruce Nuclear Site other than Inverhuron Park.

Describe how OPG’s lease agreement with the Ontario Ministry of Natural Resources for the Inverhuron Park property may be affected by the site preparation, construction and operation activities associated with the proposed DGR.

Context:

In section 6.10.6.1 of the EIS, it states that the Inverhuron Park property is owned by OPG and the Ministry of Natural Resources has a long term lease agreement with the corporation allowing continued operations of the park.

OPG Response:

OPG owns 351 acres of land to the north of the Bruce nuclear site, in the Baie du Doré area, originally acquired in the 1970’s for the exclusion zone related to the operation of the Bruce Heavy Water Plants, and 679 acres adjacent to the eastern boundary of the Bruce nuclear site; from Concession Road 6 in the north to the Hydro One Transmission Corridor south of Concession Road 4.

The Lease Agreement with the Ontario Ministry of Natural Resources (MNR) for the Inverhuron Park property is for a term of 999 years; effective July 31 1973. At any time the MNR can exercise its option to terminate the Lease, cease to operate all or any part of the lands as a provincial park and remove all buildings, chattels and other property brought or erected on the lands.

Under this Lease, the MNR agrees to operate the lands as a provincial park in accordance with normal park policies. The MNR agrees that the Lease is subject to any orders, rules, regulations or constraints imposed by any regulatory authority, governing operations at the Bruce Nuclear Power Development and any regulatory licences that may impact on all or any portion of the Park.

It is not expected that site preparation, construction or operation activities associated with the proposed DGR Project will have any impact on the OPG/MNR Lease Agreement for Inverhuron Park. The Environmental Impact Statement (OPG 2011, Section 7.10.2.12) provides the results of the assessment of potential effects of the DGR Project on Inverhuron Provincial Park. No residual adverse effects are predicted.


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Reference:

OPG. 2011. OPG’s Deep Geologic Repository Project for Low and Intermediate Level Waste – Environmental Impact Statement, Volume 1. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Ontario. (CEAA Registry Doc# 298)

EIS-08-338 Section 14, Cumulative Effects


Provide information concerning the operation of the Volume Reduction Low Level Waste Incinerator, including air emissions and radioactive ash, and explain why the Volume Reduction Low Level Waste Incinerator was not included in the cumulative effects assessment in Section 10 of the EIS.

Context:

Nineteen projects that were considered in the cumulative effects assessment are listed in Table 10.4-1 in the Cumulative Effects section of the EIS. The Volume-Reduction Low Level Waste Incinerator was not included.

OPG Response:

OPG’s response to Information Request (IR) EIS-04-104 (OPG 2012) confirms that incineration of low level waste is taking place at OPG’s Western Waste Management Facility (WWMF) and explains the regulatory framework for the incinerator. The incinerator is operated under the WWMF’s operating licence granted by the Canadian Nuclear Safety Commission. Also, the WWMF incinerator has a Certificate of Approval (C of A) (air) issued by the Ontario Ministry of the Environment and emissions are regulated by the limits set in that C of A. OPG complies with the requirements of its C of A.

Ontario Regulation 127/01 (made under the Environmental Protection Act) (GOVERNMENT OF ONTARIO 2001) requires Ontario-based facilities that emit certain quantities of specific substances to report their emissions to the government. These emissions reports must also be made available to the public. The reporting requirements for Regulation 127/01 have been harmonized with Environment Canada's federal air emissions reporting requirements. All reports (from 2005 onward) are available to the public through the National Pollutant Release Inventory (NPRI) website. Reported data for OPG’s WWMF is available at: http://www.ec.gc.ca/pdb/websol/querysite/facility_substance_summary_e.cfm?opt_npri_id=0000007098&opt_report_year=2011.

Information on ash characteristics is provided in Reference Low and Intermediate Level Waste Inventory for the Deep Geologic Repository (OPG 2010). Table B.1 provides a Summary of Specific Activities of Operational Low-Level Waste (As-Received). Table C.1 provides the Chemical Composition of Low- and Intermediate-Level Waste (non-radionuclide). Separate columns are included in each table for different types of ash.


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The incinerator was included in the cumulative effects assessment presented in Section 10 of the Environmental Impact Statement (OPG 2011). OPG’s response to Information Request (IR) EIS-04-110 (OPG 2012) provided this information.

References:

Government of Ontario. 2001. Airborne Contaminant Discharge, Ontario Regulation 127/01.

OPG. 2010. Reference Low and Intermediate Level Waste Inventory for the Deep Geologic Repository. Ontario Power Generation report 00216-REP-03902-00003-R003. Toronto, Canada. (CEAA Registry Doc# 300)

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement, Volume 1. Ontario Power Generation report 00216-REP-07701-00001-R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2012. 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-00531-00134, August 27, 2012. (CEAA Registry Doc# 704)

EIS-08-339 Section 10.2.3, Aboriginal land, Aquatic Areas and Resource Use


Provide historical information concerning the identification and delineation of the Site Study Area boundary, i.e., the “existing licensed exclusion zone for the site on land and within Lake Huron.”

Include information on any consultation with Aboriginal groups that was conducted to identify the extent of that zone.

Context:

The EIS must describe land use at the site and within the local and regional study areas. The proponent should identify the lands, waters and resources of specific social, economic, archaeological, cultural or spiritual value to Aboriginal people that assert Aboriginal rights or title or treaty rights or in relation to which Aboriginal rights or title or treaty rights have been established and that may be affected by the project.

OPG Response:

The Environmental Impact Statement (EIS) Guidelines (CEAA and CNSC 2009, Section 9.1) state that:

“The following geographic study areas should serve as the basis for developing project-specific and effect-specific study areas:

Site Study Area: The Site Study Area includes the facilities, buildings and infrastructure at the Bruce Nuclear Site, including the existing licensed exclusion zone for the site on land and within Lake Huron, and particularly the property where the DGR is proposed.”


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This guidance provided in the EIS Guidelines (CEAA and CNSC 2009, Section 9.1), along with information from the environmental assessments that have been completed and accepted for projects at the Bruce nuclear site, and the geographic area where effects of the DGR Project were most likely, was considered in identifying the Site Study Area for the DGR Project. The generic Site Study Area identified for the DGR Project is the land portion of the Bruce nuclear site, plus the areas of the exclusion zones for the Bruce reactors that extend into Lake Huron.

The Class I Nuclear Facilities Regulations (SOR/2000-204, Section 1) provide a definition of “exclusion zone”. An exclusion zone is defined as “a parcel of land within or surrounding a nuclear facility on which there is no permanent dwelling and over which a licensee has the legal authority to exercise control”. Historically, the exclusion zone for nuclear power plants in Canada has been defined as 1,000 yards (914 metres) from the containment [reactor] (CNSC 2002, No. 67). The DGR will not have an exclusion zone. It is only reactors on the Bruce nuclear site that have exclusion zones.

OPG’s response to Information Request (IR) EIS-03-45 (OPG 2012a) provides information on efforts to obtain input from Aboriginal groups, and other stakeholders, and how input was used in identifying the study areas for the DGR Project.

The EIS (OPG 2011) provides a description of land use at the site and within the local and regional study areas in Section 6.10.5.3 (Land Use) and Section 6.10.6 (Social Assets). Section 6.10.6.2 describes cultural and heritage resources.

The EIS Guidelines (CEAA and CNSC 2009, Section 2.3) require that the proponent “must incorporate into the EIS the local knowledge to which it has access or that it may reasonably be expected to acquire through appropriate due diligence…”. OPG’s response to IR EIS-07-297 (OPG 2012b) describes the methods/practices that OPG/NWMO used to obtain Aboriginal Traditional Knowledge for inclusion in the assessment. The available information on aboriginal rights and title or treaty rights is presented in the Aboriginal Interests Technical Support Document (AECOM 2011, Sections 4.1 and 4.2).

References:

AECOM. 2011. Aboriginal Interests Technical Support Document. AECOM Canada Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-09 R000. Toronto, Canada. (CEAA Registry Doc# 299)

CEAA and CNSC. 2009. Guidelines for the Preparation of the Environmental Impact Statement for the Deep Geologic Repository for Low- and Intermediate-Level Radioactive Wastes. (CEAA Registry Doc# 150)

Class I Nuclear Facilities Regulations. SOR/2000-204. Canada.

CNSC. 2002. Convention on Nuclear Safety Second Review Meeting – April 2002 Responses to Questions Presented to Canada. (available at http://nuclearsafety.gc.ca/eng/pdfs/i0723res_e.pdf)

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Environmental Impact


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Statement, Volume 1. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to Information Request (IR) Package #3”, CD# 00216-CORR-00531-00117, July 9, 2012. (CEAA Registry Doc# 608)

OPG. 2012b. 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. (CEAA Registry Doc# 843)

EIS-08-341 Section 8.1, General Information and Design Description


Provide the maximum expansion capacity of the proposed DGR.

Discuss any obstacles to expansion and how these could conceivably be overcome.

Context:

Given that the safe storage and decommissioning of reactors such as Bruce (in approximately 2024) and Bruce A (in approximately 2046) overlap the operational phase of the DGR, future EAs (addressing decommissioning) could conceivably propose disposal of low and intermediate level decommissioning waste at the DGR.

OPG Response:

OPG’s application is for a site preparation and construction licence for a repository with a capacity of approximately 200,000 cubic metres for OPG’s operational and refurbishment low and intermediate level waste.

In accordance with the requirements of the Environmental Impact Statement Guidelines (CEAA and CNSC 2009, Section 14), OPG undertook an assessment of the cumulative effects of an expansion of the repository to include OPG’s reactor decommissioning wastes, with results reported in the Environmental Impact Statement (OPG 2011, Section 10).

Furthermore, OPG’s responses to Information Requests EIS-04-120 (OPG 2012a) and EIS-04-145 (OPG 2012b) discuss the maximum expansion potential of the DGR that has been assessed, as well as some of the factors that would be involved in constructing such an expansion.

References:

CEAA and CNSC. 2009. Guidelines for the Preparation of the Environmental Impact Statement for the Deep Geologic Repository of Low- and Intermediate- Level Radioactive Wastes. (CEAA Registry Doc# 150)

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Environmental Impact


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Statement. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2012a. 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)

OPG. 2012b. 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 #4 Information Requests”, CD# 00216-CORR-00531-00143, September 28, 2012. (CEAA Registry Doc# 759)



Specify the criteria for chemical compatibility used in the Waste Acceptance Criteria which will ensure that materials incompatible with packaging materials, shipping and storage container materials, other wastes or facility closure material, are not accepted in the DGR.

Context:

The Summary of Waste Acceptance Criteria (EIS Table 4.5.1-3) does not appear to include the possibility of chemical incompatibility of materials.

OPG Response:

As shown in Appendix E of the DGR reference inventory report (OPG 2010), there is a variety of containers available for the different waste streams. Chemical compatibility is one of the criteria used in selecting an appropriate container type for a given waste stream. The majority of the wastes in storage are “dry”, and “wetter” wastes, such as ion exchange resins, are typically stored in stainless steel or polyethylene containers. Materials which may have a deleterious effect on the repository performance, such as chelating agents, are also restricted, as shown in the Environmental Impact Statement (OPG 2011, Table 4.5.1-3). As such, chemical compatibility is not a significant issue. This is evidenced by more than 35 years of safe operation at OPG’s Western Waste Management Facility where these wastes are currently stored in the container types that will be transferred to the DGR, as well as at many other facilities in the world where similar types of waste are stored in similar containers, e.g. as previously described in OPG’s response to Information Request (IR) EIS-03-51 (OPG 2012a).

For new waste forms, evaluation of the potential for waste-container interaction is included as part of the selection process for an appropriate container.

As discussed previously in OPG’s responses to other IRs (e.g., IR-EIS-04-122 (OPG 2012b)), each package will be visually inspected prior to transfer to the DGR. If any deterioration that compromises package safety is detected, it will be remediated prior to transfer and emplacement in the DGR.


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References:


OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement. Ontario Power Generation report 00216-REP-07701-00001-R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Information Request (IR) Package #3”, CD# 00216-CORR-00531-00117, July 9, 2012. (CEAA Registry Doc# 608)

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-00531-00134, August 27, 2012. (CEAA Registry Doc# 704)



Provide an outline of the requirements for package certification that will be in place to ensure that the manufacturing methods and materials used are in accordance with design specifications.

Provide plans that show how all packages are periodically inspected so that they comply with all the relevant requirements and specifications for waste placement in the DGR.

Context:

EIS Table 4.5.1-3 states that "all DGR waste package designs must be approved".

OPG Response:

As discussed previously in OPG’s response to Information Request (IR) EIS-04-152 (OPG 2012), there are no specific Canadian Nuclear Safety Commission (CNSC) regulatory requirements for radioactive waste containers to be placed in a repository. The context of the “design approval” referred to in Table 4.5.1-3 of the Environmental Impact Statement (OPG 2011) is that all waste package designs require prior approval by the responsible parties in OPG.

Waste containers are designed according to Design Requirements documents and procured under OPG’s nuclear procurement procedures, which include requirements for manufacturing inspection and test plans. This ensures that the products meet OPG’s specified Design Requirements and Technical Specifications. In addition, they are procured from vendors on OPG’s qualified suppliers list. These vendors undergo periodic quality management audits by OPG to ensure that they are maintaining their Quality Management Systems. As discussed previously in the responses to other


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IRs (e.g., EIS-04-122 (OPG 2012)), each package will be visually inspected prior to transfer to the DGR to ensure it meets the DGR waste acceptance criteria. If any deterioration that compromises package safety is detected, it will be remediated prior to transfer and emplacement in the DGR.

Waste packages are also included in the aging management program for the Western Waste Management Facility storage structures. As part of this program, a sample population of these packages is visually inspected. The results of such inspections are used to confirm package performance expectations, plan future changes to container designs, anticipate possible remedial actions, etc.

References:





Provide information on center of gravity or similar requirements to ensure the physical stability of waste packages during transport, especially for travel down the 680 m shaft and movement through the DGR.

Context:

EIS Table 4.5.1-3 specifies a mass limit of 35 Mg per waste package, subject to maximum design limit for each waste package type

OPG Response:

Waste package movement at the DGR, through surface handling, shaft handling, underground transfer and placement in emplacement rooms, will be conducted in a physically stable configuration utilizing practices that meet applicable regulations (refer to OPG 2011, Section 6.5 for methods of package handling).

Waste packages currently at the Western Waste Management Facility (WWMF) are stored in a physically stable configuration. Waste packages will be transferred from the WWMF to the DGR and inspected to ensure that damage has not occurred in transfer and confirm that waste acceptance criteria have been met. Once accepted at the DGR, all waste packages will be transferred into the main shaft cage by means of a rail-based transfer cart. This rail cart will be of a low profile design to maintain a low center of gravity of the loaded cart and its rate of travel will be limited to about 0.5 m/s. Packages will be secured on the cart, as required, to ensure that the load will remain stable while the cart is


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moved into and out of the cage, and while the cage is in motion.

During shaft handling operations, the main shaft cage will be chaired (i.e., secured in position to limit vertical travel) at both the surface and repository levels to ensure a smooth transition of the rail cart during loading and unloading of the main shaft cage. Once the rail cart has been loaded on the main shaft cage it will be mechanically secured for transport from the surface level to the repository level. The main shaft cage will be guided by fixed guides in the shaft to minimize lateral movement of the cage. Guide roller assemblies will dampen any lateral motion of the cage to ensure smooth travel through the shaft. The rate of travel of the main cage will be limited to 5.0 m/s.

At the underground shaft station waste packages will either be unloaded by forklift and transported to emplacement rooms, or the rail cart will proceed via the embedded rail network directly into a gantry crane equipped emplacement room.

All equipment that handles waste packages will be designed to move each package in a way that will optimize positive control of package position. The majority of the waste packages are low profile, would be evenly loaded. Therefore, they would naturally have a low and stable center of gravity.

The exceptions to this are tall packages, carried in the upright position. These include encapsulated tile holes and resin liner shields, which will require additional securing and speed limitations during waste package handling.

The waste inventory is detailed in the Preliminary Safety Report (PSR) (OPG 2011, Chapter 5), as well as the Reference Inventory Report (OPG 2010).

Requirements to ensure the physical stability of waste packages during transport can be found in the PSR (OPG 2011, Section 6.5.1.1).

References:


OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Preliminary Safety Report. Ontario Power Generation report 00216-SR-01320-00001 R000. Toronto, Canada. (CEAA Registry Doc# 300)



Outline any plans for recycling or restricted use of waste materials in cases where it may either be cost effective, or have a cost comparable to, placement into the DGR.

Context:

Table 4.5.3-1 of the EIS provides a Chemical Inventory of low and intermediate level waste including, for example, chemical inventories of 3.4 million kilograms of copper and 1.5 million kilograms of lead.


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OPG Response:

Table 4.5.3-1 of the Environmental Impact Statement (EIS) (OPG 2011) lists an elemental inventory of the bulk waste. This does not mean that the materials are in a pure or accessible form and can be easily separated. For example, most of the copper will be present in the form of corrosion resistant alloys, such as heat exchanger tubes. Most of the lead will be in the form of shielding integral to waste packages.

As discussed in the EIS (OPG 2011, Section 3.4.1) and further in OPG’s response to Information Request EIS-03-50 (OPG 2012), there is the potential to measure the radioactivity (e.g., gamma scanning) of the existing stored wastes (some of which will have decayed for several decades) at the time they are retrieved from storage and remove them from the DGR wastes by applying the clearance criteria contained in the Nuclear Substances and Radiation Devices Regulations (SOR/2000-207). This would be done on a container-by-container or object-by-object basis (rather than targeting specific materials), for example, using methods described in CSA Standard N292.5-11 (CSA 2011).

OPG recognizes the potential for reducing the volume of waste to be placed in the DGR. OPG continuously operates with waste minimization in mind, stations have waste minimization strategies, and this ongoing process will be applied to retrieved wastes prior to emplacement in the DGR.

References:

CSA. 2011. Guideline for the Exemption or Clearance from Regulatory Control of Materials that Contain, or Potentially Contain, Nuclear Substances. Canadian Standards Association, CSA N292.5-11. Toronto, Canada.

Nuclear Substances and Radiation Devices Regulations. SOR/2000-207. Canada.


OPG. 2012. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Information Request (IR) Package #3”, CD# 00216-CORR-00531-00117, July 9, 2012. (CEAA Registry Doc# 608)


Information Request: Provide information on any limits for the presence of a maximum amount of free water (in cubic liters) in a waste package. If no such limits are proposed, explain why.

Context: EIS Table 4.5.1-3: "Summary of Waste Acceptance Criteria" states that residual liquids generally must be less than 1% free liquid by volume, and for bulk IX resins must be less than 5% free water by volume.


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OPG Response:

As reported previously in OPG’s response to Information Request (IR) EIS-03-50 (OPG 2012), most of the waste to be emplaced in the DGR will be essentially “dry”. However, there will be small amounts of incidental moisture. As noted in the Context, the limits on water content are given in the Environmental Impact Statement (OPG 2011, Table 4.5.1-3) as less than 1% free liquid by volume except for bulk IX resins, which must be less than 5% free water by volume. The volume this represents per waste package will depend on the package. Typical waste packages are described in Appendix E of the DGR inventory report (OPG 2010).

One percent free water in most waste packages has been adopted as a practical limit and is consistent with international practice; see for example (USNRC 1992, clause 61.56 (a)(3)). For example, in a low-level waste container with an internal volume of 2.5 m3, this corresponds to a maximum of 25 litres of water. Note that most wastes received are essentially dry, with very low residual free water.

The bulk IX resins represent a special case. They are transferred to containers at the nuclear stations as a slurry, then dewatered to remove most of the free water. This is consistent with international practice, as reported previously in OPG’s response to IR-EIS-03-51 (OPG 2012). A residual amount of 5% free water in a 3 m3 resin container represents a volume of approximately 150 litres (0.15 m3).

These criteria already exist in the Waste Acceptance Criteria for storage at OPG’s Western Waste Management Facility, so any waste received at the WWMF must meet these criteria before it is accepted for interim storage.

References:



OPG. 2012. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Information Request (IR) Package #3”, CD# 00216-CORR-00531-00117, July 9, 2012. (CEAA Registry Doc# 608)

USNRC. 1992. 10 CFR 61-Licensing Requirements for Land Disposal of Radioactive Waste, Subpart D-Technical Requirements for Land Disposal Facilities. United States Nuclear Regulatory Commission. Washington DC, USA (available at http://www.nrc.gov/reading-rm/doc-collections/cfr/part061/full-text.html)


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Explain the apparent inconsistency arising when sludges are characterized as solids.

Provide additional information on the waste packaging of sludges and any measures taken to control condensation and leakage following packaging.

Context:

EIS Table 4.5.1-3 defines "waste form" criteria as "solid only." But it is also stated that "sludges must have slump of less than 150 mm". Wet concrete typically has a slump of 150 mm to 175 mm. Sludges are typically considered to be semi-solid, and it appears that the acceptance criteria for sludge is bordering on what could be considered wet.

OPG Response:

The DGR waste acceptance criteria exclude “liquids”. Liquids are defined in the relevant regulation, R.R.O. 1990, Reg. 347 (Ontario 1990), as “waste that has a slump of more than 150 millimetres using the Test Method for the Determination of Liquid Waste (slump test) set out in Schedule 9.” Schedule 9 defines a specific test protocol. If the sludge does not meet the criteria for a “liquid” it is considered to be a solid and is acceptable for the DGR. This criterion already exists in the waste acceptance criteria for storage at OPG’s Western Waste Management Facility, so any waste received at the WWMF must meet this criterion before it is accepted for interim storage.

As indicated in OPG responses to previous Information Requests (IR) (e.g., EIS-03-50 (OPG 2012a)), the waste category “ALW Sludge” included in the reference inventory report (OPG 2010, Section 2) is in fact a solid. The “sludge” in the title refers to the original source of the waste. It is treated with clay-based or polymer binding agents to produce a solid cake prior to packaging in steel containers and delivery to OPG’s Western Waste Management Facility for interim storage. Since the resulting waste form is a solid, no additional measures are considered necessary to control condensation and leakage following packaging.

In addition, as discussed previously in OPG’s responses to other IRs (e.g., EIS-04-122 (OPG 2012b)), each package will be visually inspected prior to transfer to the DGR to ensure it meets the DGR waste acceptance criteria. If any significant deterioration in the package resulting in leakage is detected, it will be remediated prior to transfer and emplacement in the DGR.

References:

Ontario. 1990. Environmental Protection Act, R.R.O. 1990, Regulation 347, General - Waste Management. (available at www.e-laws.gov.on.ca/html/regs/english/elaws_regs_900347_e.htm)

OPG. 2010. Reference Low and Intermediate Level Waste Inventory for the Deep Geologic Repository. Ontario Power


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Generation report 00216-REP-03902-00003-R003. Toronto, Canada. (CEAA Registry Doc# 300)

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Information Request (IR) Package #3”, CD# 00216-CORR-00531-00117, July 9, 2012. (CEAA Registry Doc# 608)

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-00531-00134, August 27, 2012. (CEAA Registry Doc# 704)



Discuss the current and future chemical mobility of radionuclides and potentially hazardous constituents taking into account the effects of incineration, the solubility in steel, as well as other factors.

Context:

The EIS states that over long time period the waste and containers will degrade. The various metals will degrade into organic salts, oxides, or minerals consistent with the surrounding reducing saline water chemistry. The organic materials will generally degrade into simpler elements, likely under microbial-mediated reactions that will be slow under this expected saline, reducing condition. The chemical mobility of radionuclides and other potentially hazardous constituents may therefore change over time.

OPG Response:

The chemical conditions within the geosphere will remain reducing, saline and wet, with a near-neutral pH due to the massive carbonate content of the rock.

The chemical conditions within the repository and shaft will evolve from aerobic and relatively dry, to anaerobic, reducing and (depending on location and timing) dry or saline wet. Locally there will be more variation in chemical conditions due to the range of materials emplaced, and the local interaction between alkaline materials such as cements or incinerator ash, neutral buffering materials such as the carbonate rock, and acidic materials such as CO2 and organic waste degradation products.

Of all these factors, however, the key chemical assumption used in the postclosure safety assessment was that conditions will relatively quickly become anaerobic and reducing everywhere underground as the repository is closed, which is consistent with practical experience in mines and landfill.

The chemical mobility of radionuclides and non-radioactive contaminants was then assessed using a conservative model for their release and migration within and from the DGR (OPG 2011, Section 8.6.2.1) based on the following assumptions:


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instant release of radionuclides and potentially hazardous constituents from most waste forms and container materials on contact with water (the exception is that release from irradiated core components and retube wastes is by corrosion dissolution);

no credit given to waste packaging as chemical or physical barrier; no sorption of contaminants in repository, or in cement or asphalt seals; no sorption for most contaminants anywhere, with limited sorption for some contaminants (Zr, Nb, Cd, Pb, U, Np,

and Pu) allowed in the shaft bentonite seals and in the geosphere where conditions are expected to be stable; no solubility limitation in the repository, geosphere and shafts except for carbon, the dissolved concentration of

which is assumed to be governed by carbonate equilibria; no credit for incorporation of key radionuclides, in particular C-14 and Cl-36, into minerals within the repository

concrete or the surrounding carbonate rock (some C-14 is incorporated into FeCO3); diffusivity parameters were defined from data for simpler and more mobile species.

More information on these assumptions is included in the Postclosure Safety Assessment: Data report (QUINTESSA and GEOFIRMA 2011) includes Appendices C (potential solubility limitation), D (potential sorption), E (corrosion) and F (degradation).

In summary, the chemical mobility of the various species was assessed with a conservative approach, such that the detailed chemical mobility and potential changes with time were not modeled.

References:

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Preliminary Safety Report. Ontario Power Generation report 00216-SR-01320-00001 R000. Toronto, Canada. (CEAA Registry Doc #300)

QUINTESSA and GEOFIRMA. 2011. Postclosure Safety Assessment: Data. Quintessa Ltd. and Geofirma Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-32 R000. Toronto, Canada. (available at www.nwmo.ca/dgrpostclosuresafetyassessmentreports)



Clarify how PCBs generated in the incinerator and trapped in ash will be excluded from the waste emplaced in the DGR

Context:

The EIS summary, on pages 10 and 11, states that L&ILW may contain varying amounts of chemicals or elements that can be hazardous, including PCBs produced in the incinerator and trapped in the ash. In the EIS, Table 4.5.1-3, Summary of the Waste Acceptance Criteria, states the PCB wastes are excluded.


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OPG Response:

“PCB waste” is defined in the relevant regulation, R.R.O. 1990, Reg 362 (Ontario 1990), as materials containing PCBs at a concentration of more than 50 (fifty) parts per million (PPM) by weight. Although the ash contains trace amounts of PCBs as a result of the combustion process, the ash is well below this limit. As documented in Table C-1 of Appendix C of the DGR reference inventory report (OPG 2010), the measured concentrations of PCBs in ash are in the range of 0.024 to 0.2 µg/g (i.e., 0.024 to 0.2 PPM by weight). Therefore, the ash does not meet the definition of PCB waste and is acceptable for the DGR.

This criterion already exists in the Waste Acceptance Criteria for storage at OPG’s Western Waste Management Facility, so any waste received at the WWMF must meet this criterion before it is accepted for interim storage.

References:

Ontario. 1990. Environmental Protection Act, R.R.O. 1990, Regulation 362, Waste Management - PCBs. (available at http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_900362_e.htm)


EIS-08-352 Section 8.2, Site Preparation and Construction


Clarify that for the new site configuration, 9% of the surface areas will be impervious, while the rest will be dirt, gravel, turf, vegetation, or other porous surface. Also clarify whether these surfaces will be permanent.

Provide details on sustainable design features, which would increase infiltration of stormwater that have been incorporated into construction plans.

Describe temporary actions, such as during construction lay-down, planned to reduce resultant effects of precipitation.

Context:

On page 7-12 of the EIS, it states that new infrastructure will result in 9% of new impervious surface area. There is little discussion of how temporary effects have been reduced. As well, there is no discussion of whether this 9% of surface areas can include elements of sustainable design, such as permeable pavement, which would increase infiltration of stormwater.

OPG Response:

There will be approximately 9% of the DGR project site surface areas that will be permanent, impervious surfaces. This 9% can be further broken down into 1.5% for surface buildings, 2.5% for permanent roads and non-radiological parking


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areas, and 5% representing the Zone 2 radiological areas. The majority of these areas will be constructed at the later stages of the construction phase for use during operations. During construction, the majority of roads and laydown areas will be gravel and graded to discharge surface run-off to the stormwater management system. Silt curtains, berming and vegetation will be used to minimize the amount of suspended solids entering the stormwater ditches and pond.

The stormwater management ditches and pond will be constructed as part of site preparation activities, and the site graded to capture all stormwater collected on the site, and directed it to the stormwater management pond. During operations, the ditch system will be maintained and impervious surfaces will continue to drain to the stormwater system. In the Zone 2 radiological area, the water is collected and directed to an oil-water separator prior to discharge into the stormwater management system. The drainage system is designed to allow isolation of stormwater collected in this area should there be an upset condition (e.g. package drop). For this reason, permeable pavements are not suitable to provide for containment. For the remaining areas of paved surface (1.5% of surfaces), the location of these relative to the stormwater ditching system would not significantly benefit from permeable pavements.

EIS-08-363 Section 5.2, Project Overview and Purpose


Explain the rationale for the 300-year timeframe for passive monitoring, given the long time-frame of the project.

Context:

The L&ILW in the proposed DGR will be radioactive beyond 300 years.

OPG Response:

The 300-year timeframe is the period of institutional control, following DGR closure, assumed for postclosure safety assessment purposes. As is explained in OPG’s response to Information Request EIS-05-181 (OPG 2012), as part of the discussion on institutional controls, an assumed period of institutional control of 300 years is consistent with international practice. Given that institutional controls are assumed not to be in place after 300 years, it is conservatively postulated for safety assessment purposes that there could be inadvertent intrusion into the repository by drilling after 300 years.

The period of monitoring following DGR closure will be determined in consultation with the community and regulatory authorities many decades from now.

References:

OPG. 2012. 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 #5 Information Requests”, CD# 00216-CORR-00531-00145, October 24, 2012. (CEAA Registry Doc# 776)


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EIS-08-364 Section 8.3, Abandonment


Explain how OPG’s plans for operating the DGR anticipate requirements for future passive control. Include reference adaptive management plans and processes.

Describe OPG’s reasonably anticipated range of possible requirements for abandonment.

Context:

In Table 2.6.1-1 of the EIS, OPG mentions “at this time there are no specific plans [for passive control]. Control mechanisms aren’t required for another 50 to 100 years. At that time, it is expected several countries will be in the same position, and that a solution will be developed with international consensus.”

OPG Response:

OPG’s response to Information Request (IR) EIS-05-181 (OPG 2012) provides a conceptual abandonment plan and discusses postclosure institutional control. Anticipated requirements for abandonment and future passive control are included in the response to this IR.

OPG’s plans for the operational phase of the DGR facilitate, and do not preclude, a range of passive controls. For example, documentation of design and operational information useful for the postclosure phase will be maintained in a secure records management system to ensure knowledge preservation. Also, the possible use of location markers is not precluded and can be resolved during the decommissioning phase and as part of the planning for abandonment, as can the details of land use restrictions.

In the Context section of this IR, a quote is provided from Table 2.6.1-1 (Item 16) of the Environmental Impact Statement (OPG 2011). This quote deals with a question related to location markers that came up in a DGR Open House, and does not deal with passive controls in general.

References:

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Environmental Impact Statement. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2012. 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 #5 Information Requests”, CD# 00216-CORR-00531-00145, October 24, 2012. (CEAA Registry Doc# 776)


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EIS-08-365 Section 8.7, Accidents, Malfunctions and Malevolent Acts


Elaborate on the response to EIS 01-03. Provide specific definitions for “possible” events, “unlikely” events, and “non-credible” events for each of the initiating events. Support the definitions with references or detailed justification to supplement the reference supplied in the response to EIS 01-03.

Context:

In Section 8.1 of the EIS, OPG outlines three categories that describe the likelihood of impacts:

possible events: annual frequency greater than 10-2; unlikely events: annual frequency between 10-2 and 10-7; and non-credible events: annual frequency of 10-7.

The above general definitions may not be appropriate for specific initiating events. Labeling certain events as ‘unlikely’ may be misleading, given the long timeframe of the Project and the likelihood of these events over the long term.

It is anticipated that the definitions will vary with each initiating event.

OPG Response:

The definitions are as noted in the Environmental Impact Statement (EIS) (OPG 2011a, Section 8.1) and repeated in the above Context. The categories were based on the likelihood of events occurring that could lead to radiological releases during the planned operational period of about 50 years. They were not used for assessing accidents in the postclosure period. The three categories therefore correspond respectively to events that would have a high probability of occurring during the operational period (“possible events”), a low probability of occurring during the operational period (“unlikely events”), and a very low probability of occurring during the operational period (”non-credible events”).

However, as discussed in the EIS (OPG 2011a, Section 8.1) and the Preliminary Safety Report (OPG 2011b, Section 7.5.1.2), and in OPG’s response to Information Request (IR) EIS-01-03 (OPG 2012a), the precise distinction between “possible” and “unlikely” events is not important to the DGR safety assessment since all such events are considered in the subsequent bounding accident scenarios, and the same dose constraint was applied.

Furthermore, the potential consequences of non-credible accidents such as explosion and tornado are further discussed in the OPG response to IR-EIS-06-270 (OPG 2012b).

References:

OPG. 2011a. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Environmental Impact Statement. Ontario Power Generation report 00216-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2011b. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Preliminary Safety Report.


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Ontario Power Generation report 00216-SR-01320-00001 R000. Toronto, Canada. (CEAA Registry Doc# 300)

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to Information Requests”, CD# 00216-CORR-00531-00108, March 9, 2012. (CEAA Registry Doc# 363)

OPG. 2012b. 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)

EIS-08-366 Section 13, Long-Term Safety of the DGR


Describe the ‘considerable international experience’ of other DGR projects sufficiently to establish how the success and failure of other DGR-type projects can inform the proposed DGR.

Provide any detail of the facilities in Forsmark, Sweden (commissioned in 1988) and Loviisa, Finland (operating since 1997) to indicate what insights have been gained, what uncertainties remain, and how the operating experience should be applied for the proposed DGR.

Context:

In Section 7.10.2.11 of the EIS, OPG notes that the proposed DGR project introduces a new type of facility that is unique to North America. However, to counter the concerns of related to the uniqueness of the undertaking, Section 3.3.7 of the EIS and the Executive Summary of the IAS both mention considerable international experience with all three options (enhanced processing and storage, surface concrete vaults, and deep rock vaults) for the long-term storage of LILW.

The two deep rock vaults noted in the IAS relate to one in Forsmark, Sweden (commissioned in 1988) and Loviisa, Finland (operating since 1997).

OPG Response:

Utilization of international experience has been, and will continue to be, an important aspect in the development and future operation and decommissioning of the DGR. DGR project staff have visited repository sites in Finland, Germany, Sweden and the USA to gain and exchange experience in the areas of site characterization, design, operation, safety assessment, regulatory practices and public engagement.

Information already on the DGR public registry (CEAA Registry Doc# 521) submitted by the Canadian Nuclear Safety Commission (CNSC 2012) provides technical details of the Forsmark and Loviisa repositories.

Insights gained from international repository projects include:

comprehensive public engagement programs are an important part of attaining public acceptance of repository


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projects; geological conditions as well as the roles of various natural and engineered barriers are unique at each

repository site and strongly influence the safety case at each site; the efficacy of specific site characterization methods; the importance of ensuring no significant groundwater flow paths into a repository; concurrent room excavation and waste emplacement, versus having these activities sequential is an important

design and operational consideration; the importance of maintaining the safety case consistent with actual waste inventories; approaches to preclosure and postclosure safety assessments; issues with certain waste conveyance methods, in shaft and underground; and plans for shaft seal design.

Uncertainties are generally very repository-design specific; hence any uncertainties remaining relative to the operational Forsmark and Loviisa repositories are not necessarily pertinent to OPG’s DGR.

Reference:

CNSC. 2012. Overview of the Relevance of Existing Waste Repositories to OPG’s Proposed Deep Geologic Repository (DGR) for Low and Intermediate Level radioactive Waste (L&ILW). CNSC Memorandum 2.05/37-2-6-0. (CEAA Registry Doc# 521)

EIS-08-372 Section 10, Existing Environment



Explain the absence from the core log record for borehole DGR-8 of any information relating to significant geomechanical parameters such as core recovery and Rock Quality Designation (RQD) percentages.

Context:

In the Golder Associates Factual Report, submitted February, 2012 to OPG, geotechnical logging parameters of rock at the main and ventilation shaft sites are presented for boreholes DGR-7 and DGR-8.

Over large sections of tabulated data for Borehole DGR-8 that penetrated through the Cobourg Formation, there is no indication of Total or Solid Core recovery percentages, or RQD percentages (for example, for the Blue Mountain Formation from 643.9 m, through the entire Cobourg Formation and into the Sherman Fall Formation to a depth of 718 m). Data from this section of the core logs, within which the DGR is to be constructed, is most important for geomechanical design purposes and for assessing the stability of repository excavations.


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OPG Response:

The Factual Report (GOLDER 2012) presents all data for Total and Solid Core recoveries, and Rock Quality Designation (RQD). The logs appear blank in the columns containing these data because 100% core recoveries and 100% RQD were observed in large sections at depth in DGR-8.

Golder Associates colour scheme for the logs is to show ‘bad’ rock in black shade. Therefore, 100% Total and Solid Core recoveries, and RQD are represented by white shade in logs.

Reference:

GOLDER. 2012. Factual Report. OPG’s Deep Geological Repository for Low and Intermediate Level Waste, Boreholes DGR-7 and DGR-8 Geotechnical Logging. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0004-00. (CEAA Registry Doc# 700)




Justify whether field estimated unconfined strength values for rock, as assessed using the ISRM (1981) Rock Hardness Technique, are suitable for assessing numerical modelling and engineering design factors in geomechanical analysis of the DGR.

Explain why differences exist between rock unconfined compressive strengths that have been determined using laboratory measurement and field estimation techniques, and in which field estimated strengths all exceed laboratory-derived strengths for similar formations at depths below approximately 525 m and through the proposed repository formation.

Explain why borehole logging data plots for hole DGR-7, contained within Golder Factual Reports 1011170042-REP-G2040-0004-00 and 1011170042-REP-G2040-0005-00, do not show similar unconfined compressive strength data.

Context:

In the Golder Asociates Factual Report, submitted April, 2012 to OPG, rock mass characterization parameters of rock at the main and ventilation shaft sites are presented for boreholes DGR-7 and DGR-8.

In Section 2.2 (p.3) of this report, it is stated that “The strength factor in this (RMR) system was taken from the field estimation of the strength index …” and that this field index value is derived from guidelines established by the International Society of Rock Mechanics that provide qualitative estimates of rock unconfined compressive strength over various strength ranges. Ranges in strength for “Weak rock” are stated to range from “5-25 MPa” and for “Very strong rock” range from “100-250 MPa”. Such strength estimations, in addition to being only qualitative assessments, are also subject to wide ranges in parameter values within each range.


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Data shown in EIS Figure 6.2.9-1 (p. 6-53) summarizes laboratory-measured unconfined rock strength for boreholes DGR-1 through DGR-6. Field estimates of core unconfined strength for borehole DGR-7 and DGR-8 are similarly tabled in Appendix B of Golder Factual Report 1011170042-REP-G2040-0004-00. A summary of average strength data as derived using both methods (laboratory-measured and field estimated) is provided in Table 3.3 (Golder Factual Report 1011170042-REP-G2040-0005-00). Strength data in Table 3.3 indicates that field estimated values for rock strength for the Georgian Bay Formation and all deeper ones, including the Cobourg Formation, are higher than rock strengths derived from laboratory measurements.

In Golder Associates Factual Report 1011170042-REP-G2040-0004-00, no strength data is indicated in the drillhole log, whereas in Golder Associates Factual Report 1011170042-REP-G2040-0005-00, the full borehole length of the record shows complete strength parameter data.

OPG Response:

Please note that 1011170042-REP-G2040-0005-00 is the Rock Mass Characterization Report, not the Factual Report.

In the Golder Associates report on rock mass characterization of DGR-7 and DGR-8 (GOLDER 2012a), the rock strength index (field estimate) was used to determine the strength parameter rating for estimation of rock mass rating (RMR) for rock mass characterization purposes only. Rock mass strength parameters, for the purpose of numerical modeling, were based on intact strengths measured in the laboratory, not on field estimates.

Table 3.3 of Golder’s Rock Mass Characterization Report (GOLDER 2012a) does not compare field results to laboratory results. It compares two separate campaigns of laboratory testing. Table 3.3 presents a comparison of laboratory uniaxial compressive strengths (UCS) based on the specimens retrieved from DGR-1 to DGR-6 and specimens retrieved from DGR-8.

No strength data was included in Golder’s Factual Report (GOLDER 2012b) because of unavailability of the final laboratory tests results. This report is being updated with final laboratory results and will be provided upon completion.

References:

GOLDER. 2012a. Boreholes DGR-7 and DGR-8 Rock Mass Characterization. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0005-00. (CEAA Registry Doc# 699)

GOLDER. 2012b. Factual Report. OPG’s Deep Geological Repository for Low and Intermediate Level Waste, Boreholes DGR-7 and DGR-8 Geotechnical Logging. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0004-00. (CEAA Registry Doc# 700)


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Justify why no comparison, correlation or utilization was made between laboratory-derived and field estimated unconfined compressive strength data for rock recovered from within similar formations and depths, though for different boreholes, at the DGR site.

Explain whether numerical modelling and engineering design procedures for the DGR excavations and shafts (that utilize rock mass characterization parameters) will be conducted using only inferred strength data from the DGR-8 borehole, or whether combined strength data from all previous lab testing and field estimated values from boreholes DGR-7 and DGR-8 will be used for this purpose.

Provide any additional unconfined compressive strength data that may have been determined on the basis of laboratory strength testing of rock cores recovered from boreholes DGR-7 and DGR-8.

Context:

Golder Associates Factual Report 1011170042-REP-G2040-0005-00 states that this report was used “to estimate the rock mass quality at OPG’s DGR … along the shaft pilot borehole (DGR-8) and the ventilation shaft (DGR-7) … for the purpose of estimating the parameters for numerical modelling and for engineering purposes.” In Section 2.2 (p. 1) of this Report, the “strength factor in this system was taken from the field estimation of the strength index …” and was used to assess coefficients that would be applied for strength modelling purposes. This statement indicates that only field estimated strength data would be applied for numerical modelling purposes and subsequent engineering design, without any consideration being given to utilizing a substantial database of additional rock strength data derived from laboratory testing of cores from other boreholes.

OPG Response:

Please note that 1011170042-REP-G2040-0005-00 is the Rock Mass Characterization Report (GOLDER 2012), not the Factual Report.

As stated in OPG’s response to Information Request EIS-08-373, the DGR design is based on laboratory testing data. Field strength estimates were only used to determine Rock Mass Ratings (RMRs). The rock strength rating for RMR estimation is based on wide intervals of uniaxial compressive strength (UCS) values that correspond to the R0 to R6 ISRM (International Society for Rock Mechanics) scale; the field estimates of strength are accurate enough to enable selection of the correct rating for the Geomechanics Classification System.

Prior to the drilling of the shaft pilot holes, DGR-7 and DGR-8, the information for the DGR design was based on the data from DGR-1 to DGR-6. As the DGR-8 data became available, the designs of the shaft and repository were updated using laboratory test data from DGR-8. The strength parameters in the early repository-wide and emplacement room modeling work used DGR-1 to DGR-6 strength data. The detailed modeling performed later used DGR-1 to DGR-6 and DGR-8 strength data. Because the rock strength determined from the testing of DGR-8 specimens is generally higher


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than that of DGR-1 to DGR-6 strength data, results from early modeling work are conservative (OPG 2012).

There was no geomechanical testing on rock samples retrieved from DGR-7. The figure below shows a stratigraphic column with uniaxial compression test results of DGR-1 to DGR-6 and DGR-8.


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References:

GOLDER. 2012. Boreholes DGR-7 and DGR-8 Rock Mass Characterization. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0005-00. (CEAA Registry Doc# 699)

OPG. 2012. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Responses to Undertakings from Technical Information Session #1”, CD# 00216-CORR-00531-00132, August 15, 2012. (CEAA Registry Doc# 692)




Justify the decision to utilize the modified Tunnelling Quality Index (Q’) determination over the entire proposed shaft lengths, including the upper elevation sections where high inflow water conditions exist.

Justify also the decision to use the dry rock condition in estimating RMR values over the entire proposed shaft length, rather than using wet rock conditions in upper shaft sections where factor assessment could be appropriately applied.

Context:

In Golder Associates Factual Report 1011170042-REP-G2040-0005-00 it is stated that “parameters for water and stress (Jw and SRF) were not considered in this classification stage …”. In the upper elevations of the proposed shafts, high inflow water conditions are known to exist that could provide more conservative Tunnel Index characterization factoring if (Jw) and (SRF) factors were to be considered.

In Section 2.2 (p. 2) of this report, the RMR characterization study was also compiled by assuming that fully dry conditions exist throughout the length of the shafts. The difference in RMR factor values between fully dry and very wet rock conditions can be as much as 10, or 10% of the maximum possible RMR value.

OPG Response:


The modified Tunnelling Quality Index (Q’) was selected for the characterization of the rock mass of the sedimentary sequence for DGR-8 because the approach is suitable to the DGR application and is one of the most widely used engineering rock mass classification system in the field.

It was described in the report (GOLDER 2012, Section 2.1) that the parameters for water and stress (Jw and SRF) were not considered when classifying the DGR rock mass using the modified Q system in order to avoid double counting in the design process. These two factors are generally incorporated in the numerical modeling. For the same reason, the rock mass condition was assumed dry in the RMR76 classification (GOLDER 2012, Section 2.3). As per OPG’s response to Information Request EIS-08-373, numerical modeling used in the DGR design is based on laboratory test


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results and the hydrostatic pressure profile as part of input data. The Rock Mass Rating was not used in rock mass strength estimation for modelling.

Refer to the following excerpt from Support of Underground Excavations in Hard Rock (Hoek, Kaiser and Bawden 1995):

“… The rock mass classifications by Bieniawski (1974) and Barton et al. (1974) were developed for the estimation of tunnel support. They were adopted by Hoek and Brown (1980) for estimating m and s values because they were already available and well established in 1980, and because there appear to be no justification for proposing yet another classification system. However, there is a potential problem in using these existing rock mass classification systems as a basis for estimating the strength of a rock mass.

Consider a tunnel in a highly jointed rock mass subjected to an in situ stress field such that failure can occur in the rock surrounding the tunnel. When using the Tunnelling Quality Index Q proposed by Barton et al. (1974) for estimating the support required for the tunnel, the in situ stress field is allowed for by means of a Stress Reduction Factor. This factor can have a significant influence upon the level of support recommended on the basis of the calculated value of Q. An alternative approach to support design is to estimate the strength of the rock mass by means of the Hoek-Brown failure criterion. This strength is then applied to the results of an analysis of the stress distribution around the tunnel, in order to estimate the extent of zones of overstressed rock requiring support. If the Barton et al. classification has been used to estimate the values of m and s, and if the Stress Reduction Factor has been used in calculating the value of Q, is is clear that the influence of the in situ stress level will be accounted for twice in the analysis.

Similar considerations apply to the Joint Water Reduction Factor in Barton et al.’s classification and to the Ground Water term and the Rating Adjustment for Joint Orientations in Bieniawski’s RMR classification. In all cases there is a potential for double counting, if these factors are not treated with care when using these classifications as a basis for estimating the strength of rock masses. …”

References:

GOLDER. 2012. Boreholes DGR-7 and DGR-8 Rock Mass Characterization. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0005-00. (CEAA Registry Doc# 699)

Hoek, E., P.K. Kaiser and W.F. Bawden. 1995. Support of Underground Excavations in Hard Rock, A.A. Balkema, Rotterdam, pp 215.




Explain the sources of unconfined compressive strength data that are listed in Table 3.3 (p.9) of the Golder Associates Factual Report 1011170042-REP-G2040-0005-00. Provide an assessment of the accuracy and extent (in frequency of tests per formation) of the strength estimates shown for characterizing the various rock formations sampled, and the suitability of current core strength testing for providing accurate and repeatable data for rock mass characterization and engineering design purposes.

Explain what variation in (RMR’76) values would develop if “Previous UCS results” data were to be applied in the


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characterization assessment in place of the “New” strength data, and how this would affect the comparison of rating values between the RMR and Q’ techniques.

Context:

In Golder Associates Factual Report 1011170042-REP-G2040-0004-00, no strength data is indicated in the drillhole log, whereas in Golder Associates Factual Report 1011170042-REP-G2040-0005-00, the full borehole length of the record shows complete strength parameter data.

A summary table of geomechanical parameters used in the derivation of RMR and Q’ values is illustrated. Two different columns of unconfined compressive strength data are herein indicated to show average UCS values versus depth conditions in borehole DGR-8, with only several indicating standard deviation values for the published data. One is labeled for “UCS Previous Results” and the other for “UCS New test Results”.

For the borehole depth range between 11.9-47.1 meters (Lucas Formation), only three measured field strength values (“New test Results”?) are indicated in Table 3.3. Based on information shown in the EIS, Table 6.2.9-1 (p.6-53), and for this same formation, only two lab-measured (“Previous Results”?) are indicated.

In the caprock and Cobourg formations, the “Previous” UCS results are indicated to be significantly less than values inferred by “New” UCS field-estimated results. However, the RMR’76 parameter evaluation process was completed using the “New” UCS values only (“the parameters used were measured directly in the field.”)

OPG Response:


The two sets of uniaxial compressive strength (UCS) data are presented in Table 3.3 of the Rock Mass Characterization Rock report (GOLDER 2012a) and both are based on the results of laboratory testing conducted by CANMET-Mining and Mineral Sciences Laboratories (MMSL), Ottawa, Ontario. The “Previous Results” represent test results of core samples retrieved from DGR-1 to DGR-6 and the “New Test Results” of samples from DGR-8.

Except for the testing of rock swelling behaviour, core samples from DGR-8 were collected for laboratory strength testing by CANMET. Sampling and laboratory testing programs were designed to fill in the data gaps in the geomechanical data for the rock units. The sampling distribution was aimed to address the spatial variability of the strength properties of the sedimentary sequence with the following guidelines:

A minimum of 5 UCS tests (including previous testing of DGR-1 to DGR-6) from each formation thicker than 10 m.

A minimum of 3 UCS tests (including previous testing of DGR-1 to DGR-6) from each formation less than 10 m thickness.

If the minimum number of tests had already been performed previously for a formation at other boreholes, an


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additional 3 tests at the shaft pilot hole location were conducted. A minimum of 5 UCS tests within the formations intersected by repository lateral excavations (Cobourg,

Sherman Fall, Kirkfield). Triaxial compression and tension tests at selected locations in formations at the level of the repository

excavations (Cobourg, Sherman Fall, Kirkfield). Representative samples were collected under the direction of a field engineer.

As mentioned above, all geomechnical strength testing was conducted by CANMET which is an accredited testing laboratory operating under an ISO 9001 (2000) certified quality management system and ISO/IEC 17025.

No strength data were provided for the drill logs in the Factual Report (GOLDER 2012b) because the interpretation of laboratory testing results was not complete. This report is being updated with final laboratory results and will be provided upon completion.

In the Lucas Formation, the two UCS listed in the Environmental Impact Statement (OPG 2011, Table 6.2.9-1) were from the testing of DGR-1cores and the remaining three UCS were from recent testing of DGR-8 (GOLDER 2012b).

The difference in the strength test results is not sufficiently large to have resulted in a change in strength rating affecting RMR, because of the wide range in the rating categories.

R0 – 0 (1 – 3 MPa)

R1 – 1 (3 – 10 MPa)

R2 – 2 (10 – 25 MPa)

R3 – 4 (25 – 50 MPa)

R4 – 7 (50 – 100 MPa)

R5 – 12 (100 – 200 MPa)

R6 – 15 (> 200 MPa)

References:

OPG. 2011. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Environmental Impact Statement. Ontario Power Generation report 00216-REP-07701-00001-R000. Toronto, Canada. (CEAA Registry Doc# 298)

GOLDER. 2012a. Boreholes DGR-7 and DGR-8 Rock Mass Characterization. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0005-00. (CEAA Registry Doc# 699)

GOLDER. 2012b. Factual Report. OPG’s Deep Geological Repository for Low and Intermediate Level Waste,


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Boreholes DGR-7 and DGR-8 Geotechnical Logging. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0004-00. (CEAA Registry Doc# 700)




Define the meaning of the term “strength index” that is listed in Figures 5 through 28 in the Rock Mass Characterization Factual Report (1011170042-REP-G2040-0005-00)

Explain why no input parameter information plots exist for rock formations lying below the bottom of the Blue Mountain Formation at approximately 657.9 m depth, and notably for the Cobourg Formation within which the DGR is proposed to be developed.

Context:

In Golder Associates Factual Report 1011170042-REP-G2040-0005-00, the input parameter information that is used in estimating RMR conditions for each formation is based on the System defined in Table 3.2 (p. 8) and field measurements of various geomechanical parameters that are plotted in Figures 5 through 28.

In each figure, a “strength index” is identified and shows a range of values over all formations that range between 2.0 and 5.5. The meaning of the term “strength index” is undefined, and is neither the Unconfined Compressive Strength (UCS) value nor the RMR strength rating value that is predicted from Table 3.2. Inasmuch as the field-estimated strength of the rock derives from the (ISRM 1981) Field Estimation of Rock Hardness table (Table 3.1, Golder Associates Factual Report 1011170042-REP-G2040-0004-00), there may be correlation between the “strength index” and the hardness “grade” that is assessed using this table.

OPG Response:

Please note that 1011170042-REP-G2040-0005-00 is the report number of the Rock Mass Characterization Report, not the Factual Report.

The Strength Index is defined in Table 3.1 (Field Estimation of Rock Hardness (after ISRM 1981)) in the Factual Report for boreholes DGR-7 and DGR-8 (GOLDER 2012). The Strength Index ratings in Table 3.1 (R0 to R6) correspond to the strength ranges (UCS) of the Geomechanical Classification System (RMR). There is a one-to-one correlation between the Strength Index and the RMR strength rating value:

R0 – 0 (1 – 3 MPa)

R1 – 1 (3 – 10 MPa)

R2 – 2 (10 – 25 MPa)

R3 – 4 (25 – 50 MPa)


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R4 – 7 (50 – 100 MPa)

R5 – 12 (100 – 200 MPa)

R6 – 15 (> 200 MPa)

There are no parameter distributions in the rock formations lying below the bottom of the Blue Mountain Formation because there were no discontinuities observed in the core, and an RQD of 100% was measured; thus, there were no statistical variations measured for joint spacing, condition and RQD, resulting in only a deterministic value of Q and RMR for those formations.

Reference:

GOLDER. 2012. Factual Report. OPG’s Deep Geological Repository for Low and Intermediate Level Waste, Boreholes DGR-7 and DGR-8 Geotechnical Logging. Golder Associates Ltd. report to NWMO 1011170042-REP-G2040-0004-00. (CEAA Registry Doc# 700)

EIS-08-378 Section 7.1, Purpose and Need for the Project


Provide a specific break down of waste volumes per reactor and per activity, in the form of a pie chart. Identify whether any decommissioning waste is in the current proposed project description.

Context:

On page 3-2, in section 3.1 'Purpose of the Project' it states if the fleet of 20 reactors each operate to the end of life (a nominal 50 years), which assumes refurbishment of each of the generating stations, approximately 200.000 m3 (emplaced volume) of operational and refurbishment L&ILW would be produced".

On page 3-4 of the EIS, it states “...as a result of the refurbishment and improvements activities it is expected the life of each reactor unit will be extended for up to 25 to 30 years." "About 21,000 m3 of radioactive waste will be generated from the planned refurbishment activities".

It is not evident if the amount of 21,000 m3 is the waste generated from each of the 16 reactors ( 20 minus 4 at Pickering B) or a combined amount for all ongoing and possibly planned refurbishments.

Also, on the page 3-4, OPG states that, “in the future, an additional approximately 135,000 m3 of L&ILW is expected to be produced during the decommissioning of the [20] reactors and the associated nuclear waste storage facilities." The next sentence reads: "The currently proposed DGR Project does not include management of decommissioning waste".


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OPG Response:

As documented in the DGR reference inventory report (OPG 2010, Tables 2.1 and 3.1), the amount of waste to be placed in the DGR within the scope of the application is approximately 182,300 m3 of “operational” low and intermediate level waste plus 21,700 m3 of “refurbishment” low and intermediate level waste, for a total of 204,000 m3. This represents the total of all as-packaged waste from OPG owned or operated reactors for emplacement in the DGR, and uses the radiologically-conservative assumption that all reactors except for Pickering A are refurbished for continued operation. (In this context, “radiologically-conservative” means maximizing the radionuclide inventory of the waste for postclosure safety assessment purposes.)

The breakdown of the 204,000 m3 by station and activity is given in Figure 1 below. The “operational” waste includes both the pre- and post-refurbishment periods. The OPG owned or operated support facilities include the waste management facilities at the Pickering, Darlington, and Bruce sites; and the Darlington Tritium Removal Facility, health physics labs, the Central Maintenance and Laundry Facility at the Bruce nuclear site, and other similar facilities required to directly support the operation of the nuclear generating stations.

In addition to this, approximately 135,000 m3 of decommissioning low and intermediate level waste is expected to be generated in the future. As reported previously in OPG’s response to Information Request EIS-04-102 (OPG 2012), this is not included in the current DGR project scope inventory. However, it is identified in the Cumulative Effects Assessment in the Environmental Impact Statement (OPG 2011, Section 10.4.1) as a “reasonably foreseeable” future project. As shown below in Figure 2, the 135,000 m3 of decommissioning waste can be allocated as approximately 17% Bruce A, 18% Bruce B, 33% Pickering A + B, 29% Darlington, and the remaining 3% for the miscellaneous support facilities.


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Bruce A Operations23%

Bruce A Refurb3%

Bruce B Operations14%

Bruce B Refurb4%

Pickering A+B Operations

34%

Pickering B Refurb2%

Darlington Operations

13%

Darlington Refurb2%

Support facility Operations

5%

Figure 1: Breakdown of 204,000 m3 Total DGR Waste Volume by Origin


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References:




Bruce A Decommissioning

17%

Bruce B Decommissioning

18%

Pickering A+B Decommissioning

33%

Darlington Decommissioning

29%

Support facility Decommissioning

3%

Figure 2: Breakdown of 135,000 m3 Decommissioning Waste Volume


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EIS-08-381 Section 8, Description of the Project

C1NFR 5(a), (d), (f) and (i)


Provide a plan for the geomechanical modeling of the large openings at the shaft station and service area.

Provide a risk/safety assessment for the excavation of these large openings.

Context:

This IR was generated based on the information provided at the October 11, 2012 Technical Information Session on numerical modeling and the July 18, 2012 Technical Information Session.

The design and stability analysis of the large underground openings at the shaft station and service area greatly rely on state-of-the-art two and three dimensional geomechanical modeling of the excavation to gauge the level of risk associated with high horizontal stresses. In particular, when the emplacement rooms are aligned with the maximum horizontal stress, this maximum horizontal stress will be perpendicular or close to perpendicular to the large openings at the shaft and service area that will exacerbate the stability of the large openings. This will pose potential risks to the workers’ safety during the construction of the facility.

The findings of the geomechanical modeling/analysis will form the basis for geotechnical design of the large underground openings and are important to ensure the underground stability and the worker’s safety during the construction and future operation of the DGR facility.

OPG Response:

The design of the repository is informed through the 2D and 3D geomechanical modeling as described in the July 18, 2012 Technical Information Session #1 (TIS#1) (OPG 2012a). Repository-wide three-dimensional (3D) numerical modeling and some detailed 3D modeling of intersections between emplacement rooms and access tunnels were described in the TIS#1 presentation and submission materials.

The results of repository-wide modeling were used to identify areas in the underground repository that had to be modeled in more detail to assess geomechanical stability. Detailed 3D modeling has been performed for the following areas of the underground repository: the maintenance shop area, main shaft station, ventilation shaft station and loading pocket, and intersections between emplacement rooms and access tunnels. A detailed 3D analysis of selected areas (GOLDER 2012, enclosed) provides a summary of this detailed modeling identifying potentially overstressed sections of the underground repository and provides ground support recommendations for these areas.

Results and recommendations from the 2D and 3D modeling will be incorporated into the design basis and will support the design of the rock support system for various underground openings. The modeling will also support the development of the geotechnical investigation and monitoring plan as described in OPG’s response to Information Request EIS-07-302 (OPG 2012b).


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The on-going risk/safety assessment is a key aspect of the design of all underground openings. To mitigate the risk of major falls of ground, the following major activities have been or will be undertaken:

1. Geomechanical modeling based on conservative assumptions of rock mass properties; 2. Testing and monitoring of the rock response both during shaft sinking and lateral development to confirm rock

mass behaviour as predicted by modeling; 3. Adjustment of rock support design based on observation of rock mass behavior during excavation; 4. Implementation of a rigorous quality control program during procurement and installation of the rock support

system; and 5. Long-term monitoring of cavern response and periodic testing of the rock support system during DGR operations

to ensure safe operating conditions in the underground repository.

References:

GOLDER. 2012. OPG’s Deep Geologic Repository for Low & Intermediate Level Waste - 3D Detailed Analysis of Selected Areas. Golder Associates Ltd. Technical Memorandum No. 1011170042-TM-G2070-0007-00 Rev.00. (enclosed)

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission for the July 18, 2012 JRP Technical Information Session”, CD# 00216-CORR-00531-00123, July 12, 2012. (CEAA Registry Doc# 636)

OPG. 2012b. 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. (CEAA Registry Doc# 843)

EIS-08-383 EIS Guidelines: Section 8.2, Site Preparation and Construction


Section 11.1, Effects Prediction


Provide measurement data sufficient for the characterization of near-surface groundwater in the areas of the stormwater retention pond, the waste rock management area and the general site study area to the property boundary.

There must be sufficient data to allow confident interpretation of the existence of any contaminant plumes and the direction of movement of these plumes. The data are to include but not be limited to tritium, metals and metalloids, PAH, BTEX, and supporting information, such as pH, total dissolved solids and temperature. These data are to be provided by the end of the EIS Review and Comment period.

Context:

This information is required to ensure that the site is adequately characterized for groundwater contamination. The approach is expected to be similar to that used routinely for characterization of brownfield sites. The information will


Page 51 of 62



inform the Panel regarding the possible future requirement for mitigation prior to the initiation of site preparation activities.

The modelling conducted to describe and characterize the near surface groundwater regime is not adequate for the above purpose.

The Panel is aware that there are limited groundwater data available but these are not sufficient for the purpose of its review.

OPG Response:

A shallow groundwater monitoring program was established for the proposed DGR project area in 2012. As described in the DGR EA Follow-up Monitoring Program report (NWMO 2011a, Section 3), the purpose of the monitoring program is to confirm that there are no adverse effects on the shallow groundwater system arising from DGR construction and operation. The design of the groundwater monitoring program and commissioning are described in NWMO (2011b), GEOFIRMA (2011, Section 6), GEOFIRMA (2012a, Section 6.4) and GEOFIRMA (2012b). The monitoring wells (10) are situated in the uppermost aquifer beneath the DGR site area, in which any lateral off-site contaminant migration would first occur. In particular, the monitoring well network was designed to include wells situated down-gradient of the proposed Rock Waste Management Area (RWMA) and Stormwater Management Pond (SWMP). The DGR monitoring well network was installed in the summer of 2012. Routine monitoring activities, which will include hydraulic head and groundwater quality sampling, will be conducted on a quarterly basis. The first round of baseline monitoring was completed in November 2012. A list of groundwater quality parameters is shown in Table 1.

Interim results from the DGR baseline monitoring program indicate that groundwater conditions are consistent with historical investigations, numerical analyses and groundwater monitoring. Water level measurements within the WSH-300 series wells established for OPG’s Western Waste Management Facility indicate that hydraulic head distributions in the confined carbonate bedrock aquifer, directly beneath the dense glacial till, are materially consistent with historical observations and analyses previously submitted to the Canadian Nuclear Safety Commission (Jensen 1995, Sykes 1999). There is no indication of groundwater conditions that would require mitigation prior to site preparation. The results from the groundwater monitoring to the end of March 2013 will be submitted to the Joint Review Panel in early May 2013.


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Table 1: Monitoring of Shallow Groundwater Quality at DGR Project Site

Analytes Included in Baseline Monitoring Program

Additional Analytes for Collection in Q1 2013

Electrical Conductivity (EC) pH Dissolved Oxygen (DO) Redox Potential (Eh) Temperature Alkalinity Total Iron Total Sulphide Tritium 18O and 2H in water Gross Alpha Gross Beta Dissolved Inorganic Carbon Dissolved Organic Carbon Petroleum Hydrocarbons (F1-F4 fractions) Major Cations: Na, NH3+, NH4, NO2, NO3, Ca,

Mg, K, Sr, Fe, Mn Major Anions: Cl, Br, F, I, Si, SO4 Trace Elements: Al, As, Ba, B, Co, Cr, Cs, Cu,

Gd, Th, Ni, Rb, Se, Si, U, Zn

Polycyclic Aromatic Hydrocarbons (PAH) Volatile Organic Carbons (VOCs) including

Benzene, Toluene, Ethylbenzene, Xylenes (BTEX)

Additional metals: Sb, Cd, Pb, Hg, Mo, Ag, Tl, V

References:

GEOFIRMA. 2011. Environmental Monitoring Program DGR- and US-Series Boreholes 2010 Annual Report. Geofirma Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-REP-03420-0001-R000. Toronto, Canada.

GEOFIRMA. 2012a. Environmental Monitoring Program DGR- and US-Series Boreholes 2011 Annual Report. Geofirma Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-REP-03420-0002-R000. Toronto, Canada.

GEOFIRMA. 2012b. Shallow Groundwater Monitoring Well Network Installation (WSH-301 to WSH-310). Geofirma


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Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-REP-04780-0001-R000. Toronto, Canada.

Jensen, M.R. 1995. BNPD RWO Site 2: Numerical Groundwater Flow System Analysis. Ontario Power Generation report NK37-03480-94012 (UFMED) R01. Toronto, Canada.

NWMO. 2011a. DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR-TR-2011-10 R000. Toronto, Canada. (CEAA Registry Doc# 299)

NWMO. 2011b. Shallow Groundwater Quality Monitoring. Nuclear Waste Management Organization report NWMO DGR-REP-03440-0001 R000. Toronto, Canada.

Sykes. 1999. BNPD RWO Site 2: An Analysis of a Proposed Action Level for Tritium. Sykes and Associates report for Ontario Power Generation 0125-REP-79811-0020353. Toronto, Canada.

EIS-08-389 Section 10.1.5, Aquatic Environment


Submit Phase 1 baseline sediment monitoring data.

Context:

Additional Phase II and Phase III sediment data were provided in OPG’s response to EIS-03-86. OPG’s response also stated that Phase I baseline monitoring data exists; however, the data were not provided as part of OPG’s response.

Context from EIS-03-86:

The Hydrology and Surface Water Quality TSD, states on page 62 that: “Unless major changes occur within a stream, changes in sediment quality (if any) are expected to occur slowly over time. It is therefore considered appropriate to use one sampling event to define the existing conditions.” This statement is not supported by adequate data. Provision of additional sediment data is required to establish a basis for evaluation of the defensibility and appropriateness of the assessment.

OPG Response:

OPG, in its response to Information Requests (IR) EIS-06-238 (OPG 2012a) and EIS-07-295 (OPG 2012b), provided Phase 1 baseline sediment monitoring data for radionuclides and conventional parameters respectively. The response to IR-EIS-07-295 also discusses the reasons for variability in sediment monitoring results.

References:

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-


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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 Package # 7 Information Requests”, CD# 00216-CORR-00531-00151, December 20, 2012. (CEAA Registry Doc# 843)


Section 11.2, Mitigation Measures

Section 11.4.2, Surface Water

Section 11.4.3, Groundwater


Discuss the presence of tritium in the stormwater management pond and describe options for its treatment and discharge.

Context:

A tritium plume was predicted to reach the DGR shaft, but OPG didn't discuss or mention tritium in the response to EIS 04-130 in relation to discharge and treatment criterion

OPG Response:

As stated in OPG’s response to Information Request (IR) EIS-01-01 (OPG 2012a), the temporary drawdown created by shaft construction is not expected to influence hydraulic head distributions within the bedrock beneath the Western Waste Management Facility (WWMF), areal recharge or surface water recharge. Tritium concentration within the uppermost bedrock surface in the vicinity of the WWMF is on the order of 500 Bq/L, if captured by the temporary shaft drawdown, is estimated to be diluted by a factor of 2 conservatively, to more than 10. Once the hydrostatic shaft liners are installed and sealed (nominal depth 230 m below ground surface), the shafts will be hydraulically isolated and no longer influence the groundwater system.

In the event that tritiated groundwater originating beneath WWMF is captured by temporary shaft drawdown, the concentrations in groundwater would be relatively low at 50 to 250 Bq/L. These concentration levels are low and well below the Provincial water quality objective (PWQO) for tritium of 7,000 Bq/L and do not require treatment. Verification of assessment results will be achieved through proposed routine groundwater and shaft discharge monitoring programs, as discussed in OPG’s supplementary response to IR-EIS-01-01 (OPG 2012b).

References:

OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to Information Requests”, CD# 00216-CORR-00531-00108, March 9, 2012. (CEAA Registry Doc# 363)

OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Supplementary Material to Information Request (IR) Package #1 Responses”, CD# 00216-CORR-00531-00118, July 10, 2012. (CEAA Registry Doc# 606)


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EIS-08-392 Section 8, Description of the Project


Provide the statistical confidence intervals for all inflow rate estimates.

Explain the reliability of the inflow rate estimates with respect to the natural variability of the local and regional hydrology.

Context:

Although OPG explained various flow rates in its response to EIS 04-151, it did not address the question on the confidence level of the inflow rate estimates.

OPG Response:

OPG responses to Information Requests EIS-04-101 and EIS-04-151 (OPG 2012) provide conservative estimates of groundwater and process water inflow during shaft sinking and lateral development. These estimates are considered to be at the upper end of the full range of possible groundwater and process water inflow estimates and there is a very low probability that actual inflows will be greater than these estimates. There is no practical basis to develop a probabilistic distribution of inflow rate estimates, which would be required to determine statistical confidence intervals. The approach taken was to develop a conservative upper bound.

The design of pumping systems for construction and operations are based on the upper limit of inflow estimates only. In addition, contingency measures are being planned for both construction and operations to handle inflows that may be greater than the upper limit inflow estimates used for design (e.g., additional standby pumping capacity).

Reference:

OPG. 2012. 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 #4 Information Requests”, CD# 00216-CORR-00531-00143, September 28, 2012. (CEAA Registry Doc# 759)

EIS-08-393 Section 13.1, Demonstrating the Long term Safety of the DGR


Provide further explanation for defining the horizontal stress magnitude and influence on repository design due to crustal flexure to justify the assumption that the horizontal stresses are 2 MPa. Explain why this is a conservative assumption.

Context:

OPG did not provide justification for the value of horizontal stress due to crustal flexure in its response to EIS 04-156, including the reference document (ITASCA 2011). More explanation is needed.


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OPG Response:

Further to Ontario Power Generation’s (OPG) response to Information Request (IR) EIS-04-156 (OPG 2012), the long-term geomechanical stability analyses for the DGR shaft and lateral development assumed a scenario involving a maximum glacial loading history as predicted by the University of Toronto Glacial System Model (Peltier 2011). This scenario (nn9904) conservatively considered a maximum vertical ice load of approximately 30 MPa (Peltier 2011, Figure 4.2). The mechanical loading associated with the ice sheet history includes an increase in horizontal stress due to both Poisson’s effect and the bending of the earth’s crust (ITASCA 2011, Section 4.4). In the long-term analysis, the Poisson’s effect resulted in a horizontal stress increase of approximate 13 MPa at repository horizon and the crustal bending was assumed to be 2 MPa. The sum of the horizontal stress increase accounts for close to a 50% increase in the minimum horizontal stress (under contemporary stress regime) or the initial ground stress imposed on the emplacement cavern. As an additional conservatism the initial stress state was assumed to be equal to the maximum horizontal stress of 36.7 MPa despite the emplacement rooms being aligned with the major horizontal principal stress. In summary, the horizontal ground stress used in the analysis as a whole is conservative (NWMO 2011, Section 6).

Regardless of the load magnitude assigned to account for crustal bending, the predicted outcome of the long-term stability analyses is that rock mass responses do not influence the DGR safety case as cavern collapse in all eventualities is self-stabilizing. As described by ITASCA (2011, Section 8) key findings for analyses of glacial loading on the DGR lateral development and shafts are:

Multiple glacial events and associated ice-sheet loading/unloading cycles are expected to cause gradual progressive yielding of the pillars between the caverns and eventual cavern collapse. The number of glacial cycles that will cause this pillar yielding and the timing of it depend on the long-term strength of the Cobourg limestone. A conservative estimate for the Cobourg Formation (limestone) long-term strength of 45 MPa (40% of the measured Uniaxial Confined Strength (UCS)) based on laboratory crack initiation predicts the caverns will stay open for 100,000 years. A strength of 72 MPa (64% UCS), which is still below the traditionally defined long-term strength definition (70% UCS), predicts caverns would remain stable beyond 1,000,000 years.

Under the assumption of the lower-bound long-term strength (45 MPa), the volume increase of the rubble accumulating inside the caverns from progressive yielding of the rock mass during multiple ice-sheet loading/unloading cycles will eventually arrest further propagation of the caved region. A steady state is reached when glacial cycles cause no further expansion of the yielded or caved regions. All rock yielding remains contained within the Cobourg Formation.

The 3D panel-scale analysis also confirmed that deformation of the cap rock due to potential complete pillar collapse, when assuming a lower-bound long-term strength of 45 MPa (40% UCS) for the Cobourg Formation, will cause no or insignificant damage in the cap shales and thus, the repository-induced damage remains contained within the Cobourg Formation.


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With respect to the DGR shafts, multiple glacial loading cycles and long-term strength degradation are predicted to have a negligible effect on Excavation Damage Zone development due to the confinement provided by the backfilled seal materials (NWMO 2011, Section 6.4.3.4).

References:

ITASCA. 2011. Long-Term Geomechanical Stability Analysis. Itasca Consulting Group, Inc. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-17 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

NWMO. 2011. Geosynthesis. Nuclear Waste Management Organization report NWMO DGR-TR-2011-11 R000. Toronto, Canada. (CEAA Registry Doc# 300)

OPG. 2012. 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)

Peltier, W.R. 2011. Long-Term Climate Change. Nuclear Waste Management Organization report NWMO DGR-TR-2011-14 R000. Toronto, Canada. (available at www.nwmo.ca/dgrgeoscientificsitecharacterization)

EIS-08-395 Section 8.3, Operation



Provide plans for a higher initial frequency of surface water sample collection as the hydrology and drainage chemistry of the rock pile(s) will be uncertain.

Context:

OPG indicates that at least one surface water monitoring location will be sited immediately downstream of the WRMA in order to characterize the runoff prior to discharge to the stormwater management pond. Samples will be collected quarterly at a minimum throughout the site preparation and construction phase as described in the EA Follow-up Monitoring Program. Depending on the results of the rock monitoring program described above, additional surface water samples may be collected in order to further characterize “first flush” events (spring runoff and the first rainfall after a prolonged dry period). Because of the variability of site conditions (waste rock characteristics and seasonal variations in precipitation and runoff events), the timing and frequency of the sampling will be determined in the field to best observe and understand the characteristics of the WRMA runoff.

CNSC staff indicated that it expects OPG to collect more samples initially as the hydrology and drainage chemistry of the rock pile(s) will be uncertain. For instance, OPG should collect composite water samples during first flush events until contaminant levels in runoff appear stable. Once the drainage chemistry is stable, OPG could decrease monitoring.


Page 58 of 62



OPG Response:

OPG will collect and analyze composite water samples from the rock pile(s) during first flush events until contaminant levels in runoff appear stable or show a decreasing trend below acceptable benchmarks. As described in the DGR EA Follow-up Monitoring Program (NWMO 2011, Section 12), a detailed sampling plan will be developed in accordance with CSA N288.4-10 (CSA 2010). The frequency and the timing of the sampling program will be dependent on weather conditions (timing of spring runoff, rainfall events, etc.), and on the statistical analysis of the results. Once the drainage chemistry analysis meets either of those conditions (contaminant levels stable or trending lower), OPG will decrease the monitoring frequency.

References:

CSA. 2010. Environmental Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills. Canadian Standards Association N288.4-10.

NWMO. 2011. DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR–TR-2011-10 R000. Toronto, Canada. (CEAA Registry Doc# 299)



Explain the rationale for selecting just five samples for static leachate testing over an approximately 200 m stratigraphic interval (Unit 2) that shows the highest concentrations of trace metals in whole-rock analyses.

Explain the rationale for the selection of the test samples in Unit 2 and how the selection of low sulphur (i.e., sulphide) samples constitutes a conservative (precautionary) approach.

Provide leachate test for Unit 2 that are representative of the sampling interval.

Context:

Whole rock analyses of samples from the shale-dominated Unit 2 (Queenston, Georgian Bay, Blue Mountain) in DGR-3 and DGR-4 have the highest concentrations of trace metals (ex. Pb, Cd, Cr) in the stratigraphic sequence traversed by the DGR shafts. The lithogeochemistry of Unit 2 shows considerable variability.(ex. SiO2 29.4% - 58.1%, CaO 2.1%-34.4%).

A total of only 5 samples from Unit 2 in DGR-3 and DGR-4 were used for static leaching tests. Two of these samples have sulphur contents below the detection limit, while the others contain 0.26, 0.6 and 0.29 % sulphur respectively (average of all samples 0.23%). These values reflect the sulphide mineral content (mainly pyrite) of the samples. Sulphides readily undergo oxidation during weathering and release sulphuric acid and trace metals. In Table 5 (Short-Term Leach Test Results) the three sulphur-bearing samples show the highest concentrations of cobalt & thallium


Page 59 of 62



(marginally greater than the PWQO criteria) of all tested samples.

Semi-quantitative XRD mineral analyses from Unit 2 in DGR-3 and DGR-4 average 2.3% and 2.4% of pyrite respectively. Since pyrite consists of ~53% sulphur by weight, this suggests that the samples selected for the static leaching tests under-represent the suphide content of Unit 2 by a factor of five.

OPG Response:

In addition to professional judgment, several documents provide guidance with respect to the number of samples to be collected to provide representative characterization of waste rock (Price 1997, MEND 2009, INAP 2013). It is expected that 57,500 tonnes of rock (GOLDER 2012a) from Unit 2 will be removed and placed on surface. Based on these guidance documents, it is suggested that less than eight samples need to be collected. Hence the five samples collected and tested are within the number suggested and are considered representative of the sampling interval.

Further, the lithogeochemistry information described in the Context to this Information Request represents mineralogy data for DGR-4 derived from INTERA (2010). Intera analyzed 11 samples from Unit 2. The range of results from Intera’s work is consistent to the whole rock analysis results (SiO2 28.7% - 53.9%, CaO 2.93%-27.5%), (GOLDER 2011, Table 2) used for static leaching tests.

Leach-testing was performed to understand the leachate characteristics of the rock and to identify contaminants of potential concern (COPC). It should be noted that leach testing is used as a screening tool and is not necessarily representative of the concentrations that could be observed at the DGR Project Site, which is also dependent on precipitation and infiltration rates. The leach results identified several COPCs. Since filing the Environmental Impact Statement (OPG 2011), this information was used to predict water quality (GOLDER 2012b) not only from Unit 2 rock, but all rock that will be brought to surface and stored in the waste rock management area (WRMA). The laboratory leachate results, the tonnage of rock, expected precipitation (for various climatic scenarios) and infiltration rates were used to predict the quality of water released from material in the WRMA. The modelling determined that the metal leachate concentrations from Unit 2 and all rock in the WRMA are low and are not an environmental concern.

The potential for acid rock drainage is not solely based on the amount of pyrite present, or by extension, the sulphide content of the rock. Other minerals within the rock, such as carbonates, can neutralize the acidity generated by sulphide minerals. It is the balance of the acid produced by sulphides and neutralization generated from other minerals that must be considered as a whole. This is determined by the net potential ratio, or NPR (MEND 2009). Generally, acidity is not generated for NPRs greater than 2. As described in GOLDER (2012b) the NPRs for the material from Unit 2, and all rock to be placed in the WRMA is greater than 2 and in most instance, greater by a large margin. Additional testing called net-acid generation (NAG) was also performed as an alternative assessment of potential acid generation. The pH value of the water used in the NAG testing is measured and if it is above a value of 4.5, acid generation is not expected (AMIRA 2002). The measured pH values from the NAG for Unit 2 samples, and all samples of rock tested, were greater than 4.5 and in all cases, greatly so. Hence, based on the NPR and NAG pH values, acid generation is not expected


Page 60 of 62



from the rock that is to be placed in the WRMA.

The rock will be monitored throughout the construction phase, as noted in OPG’s response to Information Request EIS-04-160 (OPG 2012), and the quality of water that comes into contact with the rock in the WRMA will be monitored in the construction phase as well and in the operations phase (GOLDER 2012b, NWMO 2011). In addition, several mitigative options (GOLDER 2012b, OPG 2012) have been identified (covering of the waste piles and treatment, if necessary) as a contingency should the behavior of the waste rock be different than that predicted by the standard laboratory testing.

References:

AMIRA. 2002. ARD Test Handbook – Prediction and Kinetic Control of Acid Mine Drainage. AMIRA International Ltd. Environmental Geochemistry International Pty. Ltd. and Ian Wark Institute, University of South Australia.

GOLDER. 2011. Results of Geochemical Testing of Rock Samples from the Deep Geologic Repository (DGR). Golder Associates Ltd. Technical Memorandum from C. McRae to D. Barker. (CEAA Registry Doc# 523)

GOLDER. 2012a. Geotechnical Design Criteria for the Permanent Waste Rock Pile, Technical Memorandum 1011170042-TM-G2120-0002-01.

GOLDER. 2012b. OPG’S Deep Geologic Repository for Low and Intermediate Level Waste, Work Package 2-12: Water Quality Modelling Results for the Stormwater Management Pond (SWMP). Golder Associates Ltd. Technical Memorandum 1011170042-TM-G2120-0014-01.

INAP. 2013. Global Acid Rock Drainage (GARD) Guide. International Network for Acid Prevention. (available at www.gardguide.com)

INTERA. 2010. Mineralogy and Geochemistry of DGR-4 Core. Intera Engineering Ltd. report TR-08-23 Rev.0. Ottawa, Canada. (available at http://www.nwmo.ca/dgrsitecharacterizationtechnicalreports)

MEND. 2009. Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials. MEND report 1.20.1. Mining Environment Neutral Drainage Program, Natural Resources Canada.

NWMO. 2011. DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR-TR-2011-10 R000. Toronto, Canada. (CEAA Registry Doc# 299)

OPG. 2011. OPG’s Deep Geologic Repository Project for Low and Intermediate Level Waste – Environmental Impact Statement. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298)

OPG. 2012. 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 #4 Information Requests”, CD# 00216-CORR-00531-00143, September 28, 2012. (CEAA Registry Doc# 759)


Page 61 of 62



Price, W.A. 1997. Draft Guidelines and Recommended Methods for the Prediction of Metal Leaching and Acid Rock Drainage at Minesites in British Columbia, Ministry of Energy and Mines.

Enclosures:

Enclosure 1: Kincardine Heritage Register – associated with IR EIS-08-332 response

Enclosure 2: Golder Associates Ltd., OPG’s Deep Geologic Repository for Low & Intermediate Level Waste - 3D Detailed Analysis of Selected Areas, Technical Memorandum No. 1011170042-TM-G2070-0007-00 Rev.00 – associated with IR EIS-08-381 response

Attachment to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to the First Sub-set of Package #8

Information Requests”, CD# 00216-CORR-00531-00160

Page 62 of 62

Figure 1 (associated with IR EIS-08-332 response): Heritage Sites in the Vicinity of the Bruce Nuclear Site

4/5/2011 Municipality of KincardineHeritage Registry

Location Number Street Known As Architectural Style

Architect Builder Designation Date

Photo Investigate

Bruce Township

134 Concession 10 N/A Unique Octagon with second floor sunroom over porch

Alexander Thornburn

Alexander Thornburn 1937

Bruce Township

173 Concession 10 The Octagonal House

Unique Octagon with jutting bays, built of concrete poured on site

Alexander Thornburn


Bruce Township

213 Concession 10 N/A Vernacular Farm House

Alexander Thornburn


Bruce Township

216 Concession 10 N/A Rural Vernacular with hooded eaves, wood construction

Alexander Thornburn





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Bruce Township

1183 Concession 10 N/A Yellow brick with Georgian Revival, stone

Unknown Unknown

Bruce Township

1605 Concession 10 Stone View Vernacular Farm House, stone

Alexander (Sandy) Brunton

Alexander Brunton and Thomas Mather Built for Blakely family 1884

Bruce 192 Concession 12 N/A Edwardian Unknown UnknownTownship

Bruce Township

240 Concession 12 N/A Beaux Arts School House

Unknown Unknown 1920-1930

Bruce Township

1046 Concession 12 N/A Classical Revival School House

Unknown Unknown 1920's




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Bruce Township

1558 Concession 12 Job Carr House

Ontario Vernacular Farm House Twin of Stone View (Con. 10)

Alexander Brunton

Alexander Brunton 1885

October 15, 2008 By-law 2008-174

Bruce Township

362 Concession 8 Crawford House & Farm

Ontario Farm House built with stone

John MacDougal 1874

Bruce Township

398 Concession 8 Foster Farm Ontario Farm House with Gothic Revival built with stone

Alexander (Sandy) Brunton 1884

Bruce Township

4253 Hwy 21 Wesley United Church

Rural Gothic Revival

Unknown Unknown




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Inverhuron 1 Alma Street N/A Rural Vernacular Unknown Unknown

Inverhuron 2 Alma Street Philosopher’s Stone

20th Century Ontario Vernacular Farm House

Eugene Bourgeois

Eugene Bourgeois

Inverhuron 96 Victoria Street Lime Kiln Resorts

Resort Unknown Kilns: John Holms/John Smith (1901-1925) Resort - 1930's

Inverhuron Wellington Street

The Secret Garden

A garden, Italianate-romantic style

David Cunnings

David Cunnings 1956 - Present




Photo Investigate

Kincardine 490 Broadway St. Maple Leaf Cottage

Gothic Revival Unknown Unknown Aug. 18 1988 By-law 1988-56

Kincardine 315 Durham Market North

The Bank House

House: Classical Revival. Bank: Italianate

Unknown Unknown Built for Merchant's Bank

Nov. 20 1980 By-law 4322


N/A Ontario Cottage Unknown Unknown Built for: Gentles

July 17, 1986 By-law 4748


Thomas Canada Rooklidge House

Second Empire AJ Evans AJ Evans January 3, 1985 By-law 4641




Photo Investigate

Kincardine 338 Durham Market South

N/A Vernacular Unknown Unknown June 1, 2004 By-law 2004-009

Kincardine 345 Durham St. Knox Presbyterian Church

“Presbyterian” Gothic Revival

Unknown Robert Donald David Donald 1875 1889 - Tower

Sept. 17 1992 By-law 1992-73

Kincardine 415 Durham St. N/A Gothic Revival Unknown Unknown Est 1880-90

May 19, 1983 By-law 4525

Kincardine 423 Durham St. N/A Gothic Revival Unknown Unknown Est 1880-1890

Sept. 19 1991 By-Law 1991-070




Photo Investigate

Kincardine 224 Durham Street N/A Second Empire Unknown Unknown

Kincardine 250 Durham Street The Bruce House or The Manse

Edwardian Queen Anne "Catalogue house"

Unknown Builder Unknown Built For: Dr.R. Bruce 1911

Jan. 7 1988 By-law 1987-103

Kincardine 255 Durham Street Roseneath/ Malcolm House

Italianate Unknown Builder Unknown Built For: Levi Rightmeyer 1875

March 1, 1979 By-law 4215

Kincardine 268 Durham Street The Terraces Second Empire AJ Evans Probably AJ Evans




Photo Investigate

Kincardine 276 Durham Street Secord House Gothic Revival Unknown Unknown Feb. 6 2008 By-law 2008-019

Kincardine 156 Foot of Durham Street

The Dance Pavilion

Pavilion George Conley

George Conley 1923

Kincardine 283 Gordon Street No Details

Kincardine 288 Gordon Street Arts And Crafts Is this picture correct

Is this picture correct?




Photo Investigate

Kincardine 177 Harbour Street Old Custom Building

Unknown Unknown

Kincardine 217 Harbour Street Robert Walker House

Regency Cottage Unknown 1854-56 Jan. 21 1982 By-law 4428

Kincardine 235 Harbour Street Walker House Georgian Revival Built For: Paddy Walker 1850

Nov. 24 1999 By-law 1999-149

Kincardine 236 Harbour Street The Kincardine Lighthouse

Lightstation (Lighthouse and House)

Unknown Federal Government William Kay 1880

January 28, 2009 By-law 2009-008




Photo Investigate

Kincardine 286-290 Harbour Street N/A Renaissance Revival

Unknown Built for Loscombe (lawyer) 1880's

Sep. 15 1994 By-law 1994-57

Kincardine 457 Huron Terrace Details






Photo Investigate



Kincardine 549 Huron Terrace No Details

Kincardine 567 Huron Terrace Alexander Gordon House

Gothic Revival Unknown Built for Alexander Gordon pre 1867

Nov. 24 1999 By-law 1999-148




Photo Investigate


Kincardine 618 Huron Terrace N/A Italianate Georgian Unknown Unknown Est. 1880’s

Kincardine 806 Huron Terrace N/A Edwardian Unknown Built 1900-10 Jan. 18 1990 By-law 1990-02

Kincardine 814 Huron Terrace N/A Regency (front only) Frame





Photo Investigate

Kincardine 830 Huron Terrace N/A Edwardian Unknown post 1900

Kincardine 849 Huron Terrace N/A Edwardian Unknown Unknown 1990 +

Kincardine 860 Huron Terrace The Doll House

Georgian Revival/ Carpenter Gothic/ Edwardian & Queen Anne

Unknown George Campbell or Rev. Inglis Original House – 1859 Tower -1919

Jan 2 1984 By-law 4577

Kincardine 866 Huron Terrace N/A Edwardian Rumored to have the other half of the ‘Doll House’ inside





Photo Investigate

Kincardine 880 Huron Terrace George Conley House

Arts and Crafts George Conley

George Conley 1924-25

Kincardine 1046 Huron Terrace Old barn at rear of property

Barn, port and beam Post Construction

Unknown Unknown

Kincardine 1058 Huron Terrace N/A Gothic Revival Unknown Unknown 1870’s

Kincardine 888 Huron Terrace N/A Arts and Crafts George Conley

Probably George Conley Late 1920’s




Photo Investigate

Kincardine 378 Kincardine Ave N/A Rural Vernacular Unknown Unknown

Kincardine 513 Kincardine Ave.

Lyndon Hall Italianate Unknown Unknown Est. 1880

Kincardine 603 Kincardine Ave.

N/A Rural Vernacular Unknown Unknown Est. 1880

Kincardine 63 Kingsway St. Penetangore Mid-century Modern

Unknown Unknown Built: 1978




Photo Investigate

Kincardine 219 Lambton Street Ardloch Lodge

Italianate Unknown Built for: Wintringham Clifton Loscombe 1890

Sep. 15 1977 By-law 4086

Kincardine 257 Lambton Street N/A Arts & Crafts Cottage


Kincardine 267 Lambton Street N/A Gothic Revival Unknown Unknown Est. 1875-80

March 5 1987 By-law 1987-19

Kincardine 273 Lambton Street The Old Armory

Italianate Unknown Unknown 1880’s




Photo Investigate

Kincardine 216 Nelson Street “English Style” Details

Kincardine 790 Olde Victoria St.

N/A Rural Vernacular Unknown Unknown Est. 1880’s

Kincardine 796 Olde Victoria St.

N/A Renaissance Revival

Vanstone 1880’s

Kincardine 413 Penetangore Row

Details




Photo Investigate

Kincardine 448 Penetangore Row

Details

Kincardine 689 Princes St. A.J Evans House

Second Empire Abraham Joseph Evans

A.J Evans * Built for himself

Dec. 7, 1978 By-law 4197

Kincardine 731 Princes St. Princess Court Queen Anne Revival

Unknown Unknown 1896 May 6, 2009 By-law 2009-062

Kincardine 737 Princes St. Swan Manor Proto Queen Anne Unknown Built for: George Swan 1892




Photo Investigate

Kincardine 743 Princes St. The Coach House

Barn/Coach House Unknown Unknown Probably NOT the Coach House for Swan Manor

Kincardine 744 Princes St. N/A Vernacular Unknown Unknown

Kincardine 749 Princes St. N/A Vernacular Unknown Unknown 1880’s

Kincardine 750 Princes St. Scougall House

Regency Style Cottage

Unknown Unknown Est. 1875-80

May 19 1983 By-law 4524




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Kincardine 756 Princes St. N/A Board and Batten Cottage

Unknown Unknown

Kincardine 766 Princes St. N/A Red brick house Unknown Unknown 1930-40

Kincardine 769 Princes St. N/A Italianate Unknown Unknown Est. 1875

Kincardine 776 Princes St. Richard Keyworth House

Italianate A.J Evans A.J. Evans 1875 Jan. 17 1980 By-law 4263




Photo Investigate

Kincardine 779 Princes St. Coombe House

Arts and Crafts Unknown Builder: Elmore Mahood Built for Frank E. Coombe 1919

Nov. 15 1984 By-law 4634

Kincardine 786 Princes St. N/A Edwardian Unknown Unknown Feb. 5 1987 By-law 1987-5

Kincardine 791 Princes St. McKendrick House

Queen Anne Revival

Unknown Unknown - Built for Mr. McKendrick, druggist 1897

Dec. 20 1984 By-law 4636

Kincardine 795 Princes St. N/A Georgian Revival Unknown Unknown 1870's




Photo Investigate

Kincardine 796 Princes St. Malcolm House

Edwardian/Queen Anne

Unknown Unknown Built for Malcolm 1897

Aug. 15 1996 By-law 1996-61

Kincardine 803 Princes St. N/A Gothic Revival Vernacular

Unknown Unknown 1880's Feb 6 1992 By-law 1992-10

Kincardine 804 Princes St. N/A Vernacular Italianate

Unknown Unknown 1880’s Jun 17 1982 By-law 4453

Kincardine 809 Princes St. N/A Gothic Revival Vernacular

Unknown Unknown 1880's Apr. 20 1989 By-law 1989-41




Photo Investigate

Kincardine 810 Princes St. N/A Italianate Unknown Unknown 1880’s

Kincardine 813 Princes St. N/A Vernacular Unknown Unknown 1880’s

Kincardine 816 Princes St. N/A Vernacular Italianate

Unknown Unknown 1880's Dec. 20 1984 By-law 4640

Kincardine 844 Princes St. N/A Vernacular farmhouse

Unknown Unknown 1880’s




Photo Investigate

Kincardine 854 Princes St. Bell House Gothic Revival Unknown Unknown 1858 Apr. 20, 1989 By-law 1989-42

Kincardine 862 Princes St. N/A Cottage Unknown Unknown 1920’s

Kincardine 895 Princes St. N/A Arts and Crafts Probably George Conley

Mid 1920’s

Kincardine 929 Princes St. N/A Arts and Crafts Unknown Unknown




Photo Investigate

Kincardine 938 Princes St. N/A Vernacular farmhouse


Kincardine 394 Princes St. S. Details






Photo Investigate

Kincardine 346 Queen St. Details

Kincardine 461 Queen St. The Mirror House

Vernacular Cottage 1860

Kincardine 495 Queen St. N/A Second Empire Unknown Unknown 1880’s

Kincardine 525 Queen St. N/A Gothic Revival Unknown Unknown 1880’s




Photo Investigate

Kincardine 551 Queen St. N/A Vernacular Unknown Unknown 1880’s

Kincardine 559 Queen St. Baptist Church

1960’s

Kincardine 562 Queen St. N/A Arts and Crafts Unknown Unknown 1920-30

Kincardine 570 Queen St. N/A Ontario Cottage Style





Photo Investigate

Kincardine 575 Queen St. N/A Georgian Revival with Second Storey Addition


Kincardine 578 Queen St. N/A Farmhouse Unknown Unknown 1880’s

Kincardine 581 Queen St. N/A Edwardian Unknown Unknown 1900’s

Kincardine 589 Queen St. N/A Edwardian Unknown Unknown 1900’s




Photo Investigate

Kincardine 592 Queen St. N/A Queen Anne/ Edwardian


Kincardine 707 Queen St. Old Town Hall

Classical Revival with Italianate features

Unknown Unknown 1872 Apr. 20 1978 By-law 4144 (Part of Durham Market Square Designation)

Kincardine 727 Queen St. Bruce County Library, Kincardine Branch

Aesthetic Attributed to : W.Fry Colwill

Mackenzie Contractors (Kincardine) Nicholson & Elmore Mahood (Wingham) 1908 – Funded by Carnegie Grant of $4000.00 Modern Addition - 1994

Sept. 3, 1981 By-law 4381

Kincardine 780 Queen St. N/A Victorian Commercial

Unknown Unknown 1880's Apr. 17 1980 By-law 4279




Photo Investigate

Kincardine 789 Queen St. N/A Scottish Renaissance Revival

Unknown Unknown 1880's May 16 1985 By-law 4667

Kincardine 595-59 Queen St. N/A Edwardian Unknown Unknown 1900’s

Kincardine 719-723 Queen St. Old Post Office

Renaissance Revival

Unknown Federal Government 1908

Sept. 3 1981 By-law 4381

Kincardine 786 & 788 (same building)

Queen St. Pemberton Block

Renaissance Revival

A.J Evans A.J Evans Built for: Frances Mary Pemberton 1881

Apr. 17 1980 By-law 4280 & 4278




Photo Investigate

Kincardine 484 Queen St. N/A Vernacular Unknown Unknown

Kincardine 1083 Queen Street Vanstone House

Italianate Richard Vanstone

Richard Vanstone Est. 1875

Aug. 4 1978 By-law 4166

Kincardine 993 Saugeen St. Dew Drop Inn Old Family Cottage

Kincardine 1083 Saugeen St. N/A Log House Unknown Unknown




Photo Investigate

Kincardine Saugeen Street MacPherson Park

Was Levi Rightmeyer’s salt block. Purchased by Sir Alexander Mackenzie and donated to the town as a park in memory of his friend James MacPherson

Kincardine Saugeen Street Rock Garden on waterfront

Romantic Revival Sandy Cameron, Charles Hewitt, Mac M D ld D bMacDonald, Deb Shewfelt Late 1930’s

Kincardine 250 St. Albert Street

Albert Hall Farm House Unknown Unknown




Photo Investigate


Bennie Ruttle House

Carpenter Cottage Unknown Bennie Ruttle 1920


N/A Vernacular Unknown Unknown

Kincardine 141 Kingsway St R. Bruce House

Mid-century Modern

Unknown Unknown Built: 1975

Kincardine Township

607 Bruce Road #23

Lorne Schoolhouse

Italianate John Vanstone

John Vanstone 1876




Photo Investigate

Kincardine Township

755 Bruce Road #23

The Ark Ontario Vernacular Farm House

Unknown John McIntyre 1858

Kincardine Township

5951 Highway #9 N/A Ontario Farm House

Unknown Unknown

Kincardine Township

5883 Highway #9 Hurdon/MacKenzie House

Italianate Possibly AJ Evans

Built for Hurdon 1875

Kincardine Township

2354 Hwy 21 N/A School House Unknown Unknown




Photo Investigate

Kincardine Township

2517 Hwy 21 N/A Second Empire Unknown Unknown

Bruce Township, Lovat

Concession 10 The Pace Place

Log Unknown James McGilvary 1860

Lovat, Bruce Township

Lovet Cemetery

Picture Required Picture & Details

Millarton 1694 Highway #9 N/A Italianate School House





Photo Investigate

Millarton Hwy 9 The Fort, Major Daniel House

Georgian Revival, Stone

Unknown Major Daniel brought a sone mason from Scotland to build the house in 1867

Millarton Hwy 9 The Armoury, The Kincardine Militia Building

Board & Batten Shack

Unknown Major Daniel 1863-4 Paid for by County

Tiverton 94 King St. Bruce Lodge No. 341

Italianate George Clelland

George Clelland Built to be a Lodge Building 1897

Tiverton 100 King St. Campbell/ Scott House

Log with late 20th Century additions

Unknown Unknown 1858 Jan. 18 2006 By-law 2006-007




Photo Investigate

Tiverton 116 King St. N/A Board and Batten Vernacular and Farmhouse Style

Unknown Unknown

Tiverton 140 King St. N/A Italianate Unknown Unknown

Tiverton 7 MacKay St. The Old School House

Italianate George Clelland

George Clelland 1875

Sept. 2, 2009 By-law 2009-126

Tiverton 73 Main St. MacKenzie House

Edwardian Built for Captain Kenneth McKenzie 1908




Photo Investigate

Tiverton 75 Main St. Knox Presbyterian Church

Edwardian Gothic Revival


Tiverton Main St. Baptist Church

Unknown Unknown

Tiverton Main St. Eldon Roppel House

Vernacular Gothic Revival

Unknown Unknown




Photo Investigate

Tiverton Main St. Innes Block Italianate Unknown Unknown

Tiverton Main St. McKellar Block

Renaissance Revival


Tiverton 20 Wickham St. N/A Shingle Style Warehouse

Unknown Unknown

Underwood Highway #21 Bruce Township Hall

Vernacular Gothic Revival

Unknown D.H Bender 1871

· attachment to opg letter, albert sweetnam to dr. stella swanson, “deep geologic repository...

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