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CMD 06-H22.1

File/dossier 1-3-1-7 Date 2006-08-24 Oral Presentation Submission from Ontario Power Generation Inc. In the Matter of Ontario Power Generation Inc.

Exposé oral Mémoire de Ontario Power Generation Inc. À l’égard du Ontario Power Generation Inc.

Scoping Document (Environmental Assessment Guidelines) regarding Ontario Power Generation Inc.’s proposal to construct and operate a Deep Geological Repository within the Bruce Nuclear Site in Kincardine, Ontario

Document d’établissement de la portée (lignes directrices pour l’évaluation environnementale) concernant le projet d’Ontario Power Generation Inc. visant à construire et exploiter un dépôt dans des couches géologiques profondes sur le site nucléaire de Bruce, à Kincardine (Ontario)

One-Day Public Hearing October 23, 2006

Audience publique d’une journée Le 23 octobre 2006

DOCUMENTARY INFORMATION SUMMARY

August 2006


A submission to the Canadian Nuclear Safety Commission

in support of

October 23, 2006 Hearing on the Scoping Document (EA Guidelines)

regarding

OPG’S PROPOSAL TO CONSTRUCT AND OPERATE A DEEP GEOLOGIC REPOSITORY AT THE BRUCE NUCLEAR SITE

in the

Municipality of Kincardine


August 2006

PAGE LEFT BLANK


August 2006

TABLE OF CONTENTS

1.0 Introduction ....................................................................................................................... 11.1 Western Waste Management Facility…………………………………………………......... 11.2 Safety and Environment Record………………………………..…………………………… 21.3 Community Acceptance………..……………….…………………………........................... 31.4 Long-term Planning for Nuclear Waste Management………………..………………..….. 4 2.0 Kincardine – OPG Joint Feasibility Study……………………………………………….…. 42.1 Memorandum of Understanding Studies..…………………………….……………….….... 42.1.1 Site Visits to Operating Long-term L&ILW Management Facilities…………………….… 52.1.2 Independent Assessment Study…….……………………………………………………….. 52.1.3 Stakeholder Communication and Consultation………………………………………….... 62.1.3.1 Stakeholder Briefings…………………………………………………………...……..….. 62.1.3.2 Open Houses……………………………………………………………..………………... 72.1.3.3 Independent Assessment Study Web Page………………………………………...….. 72.1.3.4 Newsletters……………………………………………………………………………….… 72.1.4 Results of the Independent Assessment Study…………..…………………..………….… 82.2 Kincardine Council Decides on the DGR………………………………………………...… 82.3 OPG Board Approval to Proceed ……………………………………………..…….………. 92.4 Host Community Agreement………………………………..……………………………...… 92.5 Assessing Residents' Support for the Agreement……………………………………….… 102.5.1 Community Consultation in the Municipality of Kincardine……………………………..… 102.5.1.1 Fact Sheets in the Media ............................................................................................... 112.5.1.2 Distribution of Printed Material…………………………………………………………….. 112.5.1.3 Web Page ……………………………………………………………………………...……. 112.6 The Poll………………………………………………………………………...…..………...… 122.7 Communications and Consultation in Surrounding Communities – Post Poll………….. 122.7.1 Open Houses in Surrounding Communities…………… ………………………………..… 122.7.2 Open Houses in Local Cottage Communities……………………………………………... 132.8 Communications with First Nations................................................................................... 132.8.1 Memorandum of Understanding Between First Nations and OPG………………….…… 132.8.2 Implementation of the MOU with First Nations …………………………………………..... 132.8.3 Open Houses at First Nations ……………………………………………...…………..…… 142.8.4 Site Tours…………………………………………………………………….………………… 14 3.0 DGR Project……………………………………………………………………………………. 153.1 Overview of the DGR……………………………………………….……………………….... 153.2 Wastes to be Placed in the DGR……………………………………………………..……… 153.3 Bruce Site Geology.…………………………………………………………………………… 173.4 Safety of the DGR at the Bruce Site…...…………………………………………...…….… 21 4.0 International Experience……………..……………………………………...……………...... 224.1 Operating Facilities…………………………..……………………………..……………….… 224.2 International Acceptance of Sedimentary Rock Formations………….….………….……. 23 5.0 EA Technical Studies…………………………………………………………………….…… 245.1 Geoscientific Site Characterization Plan…………………………………………………..... 245.2 Safety Studies…………………………………………………………………………….…… 25 6.0 On-Going Community Consultation…………………………………………………..…...... 26


August 2006

7.0 Project Schedule…………………………………………………………………………..…... 26 8.0 Conclusions…………………………………………………………………………..………… 27 9.0 References…………………………………………………………………………..…………. 28


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1.0 Introduction Ontario Power Generation (OPG) has submitted a Project Description (OPG, 2005) to the

Canadian Nuclear Safety Commission (CNSC) to begin the regulatory review process for the

construction and operation of a Deep Geologic Repository (DGR) at the Bruce nuclear site, in

the Municipality of Kincardine. The DGR would provide safe long-term management of low and

intermediate level radioactive waste (L&ILW), in the sedimentary rock approximately 500 to 700

m below the ground surface. OPG currently manages L&ILW at the Western Waste

Management Facility (WWMF) located at the Bruce nuclear site.

The Municipality of Kincardine approached OPG with the proposal to study the feasibility of

long-term management at the Bruce nuclear site. The feasibility studies, conducted by

independent consultants, have concluded that the proposed DGR is technically feasible, is safe,

would not have significant adverse environmental effects, and is supported by the local

community.

1.1 Western Waste Management Facility (WWMF) OPG and its predecessor, Ontario Hydro, have safely managed low and intermediate level

radioactive waste (L&ILW) arising from OPG-owned reactors since 1975.

Low level waste, which typically consists of slightly contaminated rags, mops, clothing, floor

sweepings, etc., is volume reduced where possible, either by compaction or by incineration.

Low level waste makes up about 95 per cent of the non-fuel waste volume received at the

WWMF. Approximately 3000 m3 of low level waste is placed in storage each year. Average

radiation levels at the surface of the low level waste containers are less than 0.01 mSv/h for

about half of the LLW when it is received at the WWMF, and less than 0.25 mSv/h for most of

the remaining half. These radiation levels decrease in time, to approximately 1/10th of the

original amount after 50 years, and about 1/50th of the total amount after 250 years (Golder,

2004).

Intermediate level waste, typically consists primarily of used nuclear reactor components, and

ion-exchange resins and filters used to purify reactor water systems. The dose rates for ILW

are higher than for LLW, with an average dose rate less than 200 mSv/h for more than 80 per

cent of waste containers and more than 47,000 mSv/h for the remaining containers. Ninety nine


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per cent of the ILW has a dose rate of less than 1000 mSv/h. Approximately 290 m3 of ILW is

placed in storage each year.

L&ILW produced at the Bruce, Darlington and Pickering nuclear generating stations are

transported by truck to the WWMF for interim storage. OPG uses several different types of

packaging to transport radioactive materials depending on the contents. All are built to the

stringent packaging requirements specified by the CNSC’s “Packaging and Transportation of

Nuclear Substances Regulation”. OPG also manages used fuel from the Bruce Power

generating stations at the WWMF at the Used Fuel Dry Storage Facility; however, used fuel will

not be placed in the proposed DGR.

Waste types and volumes will not change as a result of the proposed DGR. Much of the waste

to be stored in the DGR is already in interim storage at the WWMF. The remainder will be

transported over the remaining operating lives of OPG-owned nuclear generating stations.

1.2 Safety and Environment Record

Each of Bruce Power, Atomic Energy of Canada, and OPG operates facilities at the Bruce site.

These activities result in the release of some radionuclides, some of which are also naturally

present in the environment. Environmental monitoring programs conducted at the Bruce site

routinely measure radiological emissions and the concentrations of selected radionuclides in the

atmospheric, aquatic, terrestrial and geophysical environments.

The results of these monitoring programs, together with data on water use and food sources,

are used to calculate the radiation dose to members of the public living in the vicinity of the

Bruce site. The highest calculated dose from the entire Bruce site in 2005 was 2.02 µSv. The

data indicate that the WWMF makes a very small contribution to the dose from the Bruce site.

The public dose from the WWMF is <4 per cent of the Ontario background and < 0.01 per cent

of the legal limit (of 1000 µSv/a).

Nuclear Waste Management Division (NWMD) has a systematic approach to safety and

environmental protection, which includes a focus on continuous improvement of its operations.

NWMD’s safety and environmental programs were developed consistent with external

standards and have been audited relative to those standards. NWMD is registered to the ISO

14001 Environmental Management System Standard and has been since 1999. NWMD uses a


_____________________________________________________________________________________________ 3 August 2006

preventive loss control program which documents very low hazardous conditions, such as

housekeeping conditions, so that they can be corrected before an injury occurs or equipment is

damaged. NWMD’s system has been rated by an external auditor at a score of 8 relative to the

International Safety Rating System (ISRS), a result which is considered very good.

These managed systems contribute to NWMD staff achieving significant milestones in the areas

of safety and the environment. In 2005 NWMD reached a milestone of 11 years without a lost-

time accident. In more than thirty five years of transporting radioactive tools, samples,

equipment, and waste, almost fifty thousand shipments have been made with no serious injuries

and no releases of radioactive material to the environment.

1.3 Community Acceptance

OPG is committed to keeping the public and community stakeholders informed about its nuclear

waste management operations and plans. Stakeholders, especially those in the communities in

which OPG operates nuclear waste management facilities, are routinely provided update

briefings about OPG’s nuclear waste management plans. In the Bruce community these

updates are provided through the distribution of the Neighbours Newsletter to residences,

through notices published in the local newspapers, OPG attendance at community events such

as home shows, Pumpkinfest, the Scottish festival, and participation in the Living Snow Fence,

the Impact Advisory and Liaison Committees, as well as many other programs. OPG also

keeps the public informed about plans for changes to its operations. Prior to construction of a

new facility or other planned project, the public is provided with opportunities to learn about and

comment on the proposed projects.

Public Attitude Research was conducted both in Kincardine and in the communities surrounding

Kincardine. The results of the research indicated that for 91 per cent of the community the

WWMF has no effect on their daily life. Of the nine per cent who said it has an effect, five per

cent said the effect is positive. Approximately two thirds of respondents also indicated that none

of the long-term management options considered for L&ILW, including the DGR, would have an

adverse effect on their feelings of personal security or satisfaction with the community or on the

community as a place to visit, to operate a business or to live. Of those who said it would have

an effect, about a third thought the effect would be positive.


_____________________________________________________________________________________________ 4 August 2006

1.4 Long-term Planning for Nuclear Waste Management

The current WWMF provides interim storage for L&ILW. These facilities can continue to provide

safe storage of the waste for many decades into the future. However OPG is also committed to

ensuring that a long-term management solution is available. OPG’s preliminary long-term

plans, completed in 1998, were for a repository to be available, starting in 2015. Plans at that

time did not identify a specific site for the repository.

An important part of the planning process was making financial provision, so that funding would

be available for the life cycle cost of the L&ILW management and costs would not be passed to

future generations. OPG, assisted by international experts, has conducted extensive studies to

determine the life cycle cost of nuclear waste management. The Segregated Fund, established

to pay for the long-term management of low and intermediate level waste and the

decommissioning of Ontario's nuclear generating stations, currently has funds to the value of

$4.2 billion, which is more than 100 per cent of the estimated requirement. These estimates

were reviewed by the CNSC as part of the Decommissioning Financial Guarantee process.

2.0 Kincardine – OPG Joint Feasibility Study

2.1 Memorandum of Understanding (MOU) Studies In 2001, the Municipality of Kincardine approached OPG seeking to enter into an agreement to

study options for long-term management of L&ILW at the existing WWMF. Those discussions

led to the signing, in April 2002, of a Memorandum of Understanding (MOU) between OPG and

the Municipality of Kincardine. The work plan under the agreement included:

A review of the technical feasibility of the long-term management options for L&ILW at the

WWMF

A socio-economic impact assessment in the Municipality of Kincardine of the existing

operation of the WWMF and of the potential long-term options

A review of European and American models for long-term management of L&ILW, including

site visits to look at issues such as technical infrastructure and community compensation.


_____________________________________________________________________________________________ 5 August 2006

A Steering Committee was established with four representatives from the Municipality of

Kincardine and three from OPG. The Steering Committee met regularly to develop and

advance the work plan.

2.1.1 Site Visits to Operating Long-term L&ILW Management Facilities Representatives of the Municipality of Kincardine visited a number of communities which host

waste facilities, in Europe and the United States. The purpose of the fact finding visits was to

review best practices in low and intermediate level waste management from a technical

perspective and to meet with community officials/representatives and review community

agreements.

The group toured the following facilities:

Zwilag, Switzerland (enhanced processing and storage facility)

Centre de l’Aube, France (covered above-ground concrete vaults for low level

radioactive waste)

SFR Facility, Sweden (in crystalline rock 60 metres below the Baltic Sea for low and

intermediate level waste)

Barnwell, South Carolina, USA (trench disposal of low level waste)

Waste Isolation Pilot Plant (WIPP), Carlsbad, New Mexico, USA [Deep Geologic

Repository for transuranic waste, 2,150 feet (about 650 m) below ground in a salt

formation]

Site visits confirmed that there were several feasible technologies for long-term L&ILW

management and that in some cases host community agreements were in place, and in some

cases they were not.

2.1.2 Independent Assessment Study

The work plan included an Independent Assessment Study (IAS) of options for the long-term

management of Low and Intermediate Level Waste (L&ILW), with the existing operation serving

as the base case for purposes of comparison. The IAS, conducted by Golder Associates,

evaluated the geotechnical feasibility, safety, potential environmental effects and the potential

social and economic effects of several options.


_____________________________________________________________________________________________ 6 August 2006

The Enhanced Processing, Treatment and Long-term Storage option uses both existing

and new equipment and processes to treat waste prior to placing it in long-term above-ground

storage.

The Covered Above-ground Vault involves the construction of large reinforced concrete

enclosures located on the ground surface. The Covered Above-ground Vaults are located and

constructed so that the wastes are maintained in a dry state throughout the vaults’ lifetime. The

vault would be constructed of reinforced concrete and subsequently covered with layers of earth

and synthetic material designed to minimize infiltration of water.

The Deep Geologic Repository involves the construction of rock caverns within the stable, low

permeability bedrock using conventional mining methods. Access to the caverns is either by

ramp or shaft. As each emplacement room is filled it receives a temporary seal with an access

hatch. At the end of the operating life of the facility, the access is sealed with low permeability

material and backfilled to the surface. The repository rooms and tunnels would not be filled with

material.

Golder Associates also developed and implemented a Community Consultation and

Communications program as a part of the Independent Assessment Study. The

communications included one-on-one stakeholder briefings, open houses, newsletters, public

attitude research, web site, advertising in local newspapers, and presentations at regularly

scheduled meetings.

2.1.3 Stakeholder Communication and Consultation The stakeholder consultation and communication program focussed on the local municipalities

since, based on feasibility studies, no effects outside of Bruce County were anticipated. The

Independent Assessment Study web site and the subsequent OPG DGR web site

(www.opg.com/dgr) provided access to information for members of the broader community who

had an interest in the studies.

2.1.3.1 Stakeholder Briefings Key stakeholders, who included government agencies, First Nations, local political

representatives, community leaders and labour unions, were briefed throughout the

Independent Assessment Study at the following key milestones:


_____________________________________________________________________________________________ 7 August 2006

• Initiation of the Independent Assessment Study process

• Completion of the Independent Assessment Study

• Completion of the Community Consultation in Kincardine

2.1.3.2 Open Houses

Golder Associates, on behalf of the Municipality of Kincardine and Ontario Power Generation,

held Open Houses in Kincardine and in the municipalities in the outreach area in June 2003.

The objectives of the Open Houses were to:

• Inform the general public, employees of the Municipalities and OPG, other stakeholders

and the media about the discussions on the various options being considered for long-

term management of low and intermediate level waste at the WWMF

• Provide opportunities for stakeholders to provide data and information as input to the

Independent Assessment Study and to identify and discuss any concerns they had.

Feedback included comments about health, safety and environmental issues, risks to

groundwater, flooding of the repository, location of aquifers relative to the depth of a deep

geologic repository, and questions about the amount of radioactivity associated with low and

intermediate level waste. Questions were raised about the cost of a facility and employment

opportunities that may result from the construction and operation of a facility.

2.1.3.3 Independent Assessment Study Web Page A web site provided information on the existing waste management operations, the objectives of

the Independent Assessment Study, the options being considered in the Independent

Assessment Study, responses to Frequently Asked Questions, and copies of printed materials

such as newsletters, the Geotechnical Feasibility Study Report, the Preliminary Safety

Assessment Report, the independent Social and Economic Analysis study, the results of the

Public Attitude Research and the Independent Assessment Study Report. The Web Site

included a comment form that could be submitted electronically to Golder Associates.

2.1.3.4 Newsletters Two newsletters were produced in association with the Independent Assessment Study. The

newsletters were distributed to residences in the Municipality of Kincardine, Saugeen Shores,

Arran-Elderslie, Brockton and Huron-Kinloss, as well as at the Saugeen and Nawash First


_____________________________________________________________________________________________ 8 August 2006

Nations. It was delivered to approximately 22,000 residences. Copies were also available at

Municipal Offices and libraries in the outreach area.

2.1.4 Results of the Independent Assessment Study

The results of the IAS were documented in a report (Golder, 2004), which concludes that each

of the three options examined:

Is technically feasible. The geology of the Bruce site is ideal for a deep repository;

however it could also support above-ground concrete vaults.

Could provide safe storage for some or all of the L&ILW. Radiation doses would be

much lower than regulatory criteria and would occur far out into the future.

Would have no significant residual adverse environmental effects.

Would have no adverse social effects. The majority of respondents also indicated that

none of the long-term management options considered, including the DGR, for L&ILW

would have an adverse effect on their feelings of personal security or satisfaction with the

community or on the community as a place to visit, to operate a business or to live.

Would have a positive effect on the local economy.

2.2 Kincardine Council Decides on the DGR

Following a review of the Independent Assessment Study Report, municipal support was

indicated at the April 21, 2004 Council Meeting at which the following resolution was carried:

Resolution #2002 – 232

“that Council endorse the opinion of the [Kincardine] Nuclear Waste Steering Committee and

select the “Deep Rock Vault” option as the preferred course of study in regards to the

management of low and intermediate level radioactive waste”.

The Council’s decision to support the DGR as its preferred option was based on the following

key points:

• It is consistent with best international practice

• It provides the highest level of safety of any option, including the existing interim facilities


_____________________________________________________________________________________________ 9 August 2006

• It provides a permanent storage method for L&ILW, much of which is already at the

Bruce site, and if necessary will do so in the absence of institutional controls

• An environmental assessment will be conducted prior to OPG proceeding with the DGR

• It provides significant economic benefit to the residents of our municipality

• No high level waste or used nuclear fuel would be allowed in the facility.

2.3 OPG Board Approval to Proceed

At its June, 2005 meeting, OPG’s Board of Directors approved moving forward with the

proposed DGR. Their acceptance of the proposal was based on:

The DGR would provide a high level of safety in the long term

The proposed project provides for management of L&ILW and is consistent with OPG’s

long-term plans for this waste

An independent consultant has determined that the Bruce site geology is ideal for safe

containment of the waste

The Segregated Fund for low level waste and decommissioning is fully funded, therefore

funding is in place for the full costs of developing, constructing and operating the proposed

DGR

The Kincardine community has expressed support for the proposed DGR.

2.4 Host Community Agreement During their visits to host communities in Europe and United States, Kincardine officials

confirmed that there was international precedent for Agreements for hosting long-term

radioactive waste facilities. The Port Hope Agreement, signed between the Town of Port Hope,

Township of Hope, Municipality of Clarington and the Government of Canada in 2001, for the

long-term management of historic wastes provides a recent Ontario example of a hosting

agreement.

The 2005 Kincardine Host Community Agreement includes the following provisions:

OPG will design, license, construct and operate a deep geologic repository for L&ILW

streams currently stored at the WWMF, with the support of the community


_____________________________________________________________________________________________ 10 August 2006

Kincardine, Saugeen Shores, Huron-Kinloss, Arran-Elderslie and Brockton receive

35M$ (2004$, inflation protected) paid over thirty years subject to achieving key

project milestones

No used fuel would be stored in the DGR

Property value protection plan is provided

Kincardine Council obtains endorsement from Kincardine residents

Although the agreement is formally between OPG and the Municipality of Kincardine, OPG

received letters of support for the DGR from each of the four other municipalities which would

financially benefit from it.

2.5 Assessing Residents’ Support for the Agreement

2.5.1 Community Consultation in the Municipality of Kincardine Kincardine Council determined that they would seek formal endorsement of the hosting

agreement from Kincardine residents through a telephone poll. Leading up to the poll, a

community education/information plan was put in place to provide all residents an opportunity to

obtain information about the DGR concept and the hosting agreement. During this stage of the

process public consultation and communications efforts focused primarily on the residents of the

Municipality of Kincardine.

The Municipality of Kincardine and OPG jointly operated a Community Consultation Centre

located on the main street of Kincardine from October 2004 to the end of the telephone poll.

The Consultation Centre provided the opportunity for many discussions about the existing waste

management operations, the technology used in other countries to manage low and

intermediate level wastes, whether the repository would be used to store used nuclear fuel,

potential environmental effects from a DGR including effects on groundwater and Lake Huron,

what the effects of an earthquake would be on the repository and the waste stored in it, the

Hosting Agreement, the consultation process, and the regulatory approvals process associated

with the proposed DGR. In total, 312 individuals took the opportunity to attend the Consultation

Centre and discuss the proposal with representatives of OPG and the Municipality.


_____________________________________________________________________________________________ 11 August 2006

Leading up to the telephone poll, the Municipality of Kincardine and OPG also made

presentations on the Deep Geologic Repository Proposal, on a request basis, to community

groups.

2.5.1.1 Fact Sheets in the Media

OPG and Kincardine placed a total of eight fact sheets in the local newspapers, providing

experts’ views of their particular speciality, as well as invitations to attend the Consultation

Centre to obtain information about the DGR proposal. Fact sheets addressed a number of

questions and comments which had been raised during the public communications program.

The fact sheets covered topics such as geoscience, safety assessment, the process for

residents expressing their views, health perspectives, and were provided by a number of

sources including Golder Associates, Quintessa, the Mayor of Kincardine and the Medical

Officer of Health for Grey-Bruce.

2.5.1.2 Distribution of Printed Material Kincardine residents were provided with two mail-outs, jointly issued by OPG and the

Municipality of Kincardine Council. The first was a newsletter and the second a pamphlet which

included background information on radioactive waste, the existing Waste Management Facility,

the Memorandum of Understanding, the Independent Assessment Study, the proposed DGR,

the Hosting Agreement, and the regulatory approvals process.

2.5.1.3 Web Page During the community consultation OPG launched a web page, which posted the Independent

Assessment Study report, as well as more detailed background information such as the

Preliminary Safety Assessment, the Geotechnical Feasibility Study, newsletters, panels

displayed at the Community Consultation Centre, and hours of the Community Consultation

Centre. It also included an electronic comment form which could be used to request specific

information about the DGR Proposal. During the time period that the Community Consultation

was underway, OPG responded individually to each comments/questions received.


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2.6 The Poll

An independent company, Strategic Counsel, conducted the telephone survey in January and

February 2005. Diligent efforts were made to contact each household, and each eligible

resident, either by telephone, through a 1-866 number, or by mail if no telephone contact could

be made. Seasonal residents were mailed a copy of the question and asked to respond by

mail.

Of the 5257 eligible households indicated in the 2001 Statistics Canada Census, 3763

participated in the poll. This represented 6778 individual votes. The results of the vote were:

Yes 60% No 22% Neutral 13% Don’t Know/Refused 5%

The Kincardine Municipal Council accepted the poll results as an indication of sufficient support

to move forward with the Hosting Agreement.

2.7 Communications and Consultation in Surrounding Communities – Post Poll 2.7.1 Open Houses in Surrounding Communities Throughout the Community Consultation process, communications efforts were focussed on the

residents of the Municipality of Kincardine. Following the completion of that process, and the

results which indicated residents supported proceeding with the regulatory process for a DGR,

OPG broadened its communications efforts.

Open Houses were held in each of the four surrounding municipalities including Port Elgin,

Walkerton, Chesley and Ripley. During the course of the four Open Houses, most attendees

took the time to have a lengthy conversation with one of the OPG representatives, to express

their views, ask questions and obtain information. The majority of visitors left the Open Houses

with more information and a greater level of comfort about the proposed DGR.

After each of these Open Houses a copy of the panels, in booklet format, was delivered by

Canada Post to each residence, year-round and seasonal, in the municipality.


_____________________________________________________________________________________________ 13 August 2006

2.7.2 Open Houses in Local Cottage Communities

A number of property owners in the Municipality of Kincardine and adjacent municipalities are

seasonal residents, who use their properties primarily during the summer months. OPG held

Open Houses in three cottage communities (Point Clark, Southampton and Inverhuron) in the

summer of 2005 to provide opportunities for these people to provide comments and obtain

additional information about the DGR proposal. Visitors to the Open Houses expressed an

interest in potential effects of the proposed DGR on water quality in Lake Huron.

Overall, visitors to the Open Houses found the display informative and were appreciative of the

opportunity to discuss the proposal. Not all visitors supported the proposal; however the

majority are better informed and have a greater level of comfort with the proposal after attending

the Open Houses.

2.8 Communications with First Nations The Independent Assessment Study included a Communications Program with First Nations.

2.8.1 Memorandum of Understanding between First Nations and OPG

OPG and the Saugeen First Nation and the Chippewas of Nawash, signed an MOU. The MOU

outlined terms and a process for OPG and First Nations to communicate on the proposed DGR.

It included funding support for First Nations to have a legal review of the draft MOU between

First Nations and OPG, an Administrative Co-ordinator to facilitate communications, and a

technical advisor to peer review the Independent Assessment Study Report and provide

technical advice. Discussions are underway towards reaching agreement on a longer term

MOU.

2.8.2 Implementation of the MOU with First Nations OPG provided funding for a Communications Advisor, and for a technical review of the

Independent Assessment Study. OPG has also made technical support and advice available to

First Nations to assist them in developing applications for federal government funding for

feasibility studies for wind energy at the Chippewas of Nawash and Saugeen First Nation, and


_____________________________________________________________________________________________ 14 August 2006

has also provided a preliminary assessment of potential sites suitable for wind energy on each

of Nawash and Saugeen lands.

2.8.3 Open Houses at First Nations

First Nations, under the MOU, arranged for several opportunities at each of Saugeen First

Nation and Chippewas of Nawash for Band members to obtain information about the proposed

DGR and provide feedback on the proposal. First Nations hosted “Peer Review Public

Meetings”, with presentations from technical experts, to provide band members an opportunity

to find out more about nuclear waste management plans and specifically, the DGR proposal.

The technical advisor summarized the Independent Assessment Study Report at the meetings

and presented the conclusion that it appeared to be correct.

Following the Peer Review Meetings, OPG arranged Open Houses at each of Nawash and

Saugeen First Nation to present information on the proposed DGR, respond to questions and

obtain feedback on the proposal. At Nawash, discussion was about the long-term effects on

traditional lands and the scientific information indicating that the environmental effects were

insignificant. At Saugeen, questions focused on the technical details of the proposal and about

potential environmental effects on their traditional lands. They expressed interest in continuing

a dialogue about the proposal and invited OPG to return to provide future updates on the

proposal.

2.8.4 Site Tours

To assist First Nations in familiarizing themselves with OPG’s operations at the Western Waste

Management Facility, OPG provided tours of the existing operation to members of Joint Council

and elders. The tours provided a good opportunity for visitors to see the existing low and

intermediate level waste operation and to have their questions about the waste and the facility

answered.


_____________________________________________________________________________________________ 15 August 2006

3.0 DGR Concept

3.1 Overview of the DGR

OPG proposes to locate the DGR in the Municipality of Kincardine on OPG-owned land at the

Bruce site near to the existing WWMF. The underground repository would be entirely within the

boundaries of the OPG-owned land at the Bruce site. The proposed DGR would be located

approximately 1.5 km east of the Lake Huron shoreline. The DGR would consist of access

(either ramp or shaft), surface facilities, ventilation shaft(s), as well as underground

emplacement rooms. The surface facilities consist of the underground access and ventilation

buildings, associated temporary or permanent buildings, and related infrastructure. The

underground facilities would be comprised of access-ways (shafts, ramps and/or tunnels),

emplacement rooms, and various underground service areas and installations. In this concept,

shown in the figure on the following page, the underground repository would consist of a series

of horizontal emplacement rooms, excavated at a nominal depth of 500 to 700 m below surface

in the shale or limestone. A reference depth of approximately 660 m is used in the conceptual

design. Construction of the DGR may take place in phases, with a number of emplacement

rooms being developed during the construction phase, and waste emplaced in them, followed

by a subsequent campaign developing additional emplacement rooms.

3.2 Wastes to be Placed in the DGR

The DGR would be designed to receive L&ILW produced by OPG-owned nuclear generating

stations through the remainder of their operating lifetimes, as well as L&ILW currently in interim

storage at the Bruce site. The estimated volume of low and intermediate level waste to be

placed in the DGR, excluding decommissioning waste, is 160,000 cubic metres (m3). This

volume estimate is based on a number of assumptions about reactor life, refurbishment and

effectiveness of volume reduction.


_____________________________________________________________________________________________ 16 August 2006

Artist’s Concept of a DGR


_____________________________________________________________________________________________ 17 August 2006

3.3 Bruce Site Geology

The Bruce site has many attributes that contribute to the assessment that it is ideal for the safe

management of L&ILW in the long-term.

OPG contracted with internationally recognized consultants in recent years to complete studies

on the technical feasibility of siting a long-term management facility at the Bruce nuclear site.

Studies conducted included a geotechnical feasibility study (Golder, 2003), and a preliminary

safety assessment (Quintessa, 2003). The understanding of the potential environmental effects

of the proposed DGR in the long-term, and the prediction that there will be no significant

adverse effects on the environment resulting from the DGR during or following

decommissioning, are based on the results of these studies.

As concluded in Golder (2003), the Bruce site has a number of favourable properties that would

serve to limit any adverse effects of the DGR project on the surrounding environment in the long

term. These include the following factors:

Predictability of Rock Strata: The sedimentary rock layers beneath the Bruce site occur in

predictable near-horizontal, laterally continuous layers that extend for many 100s of kilometres.

The figure on the following page shows the rock layering. Note that the vertical scale in the

figure is exaggerated; the rock layering is actually essentially flat. It is expected that large

domains of rock mass unaffected by regional fracturing with near homogeneous rock properties

exist beneath the Bruce site. This geologic setting and predictability will allow a more straight-

forward understanding of the site and explanation of DGR performance.

Geologic Stability: The bedrock that will host the DGR is 450 million years old. These

bedrock formations have endured mountain building events at their margins, deep sedimentary

burial, uplift and erosion, earthquakes and multiple glaciations, and yet have maintained a

simple and relatively undeformed stratigraphy that would be expected to remain in the future.

Further, the site is located in an area of the stable cratonic core that is known to be seismically

quiet.


_____________________________________________________________________________________________ 18 August 2006

Regional Descriptive Geosphere Model


_____________________________________________________________________________________________ 19 August 2006

Permeability of Host Rock: The Ordovician shales and underlying limestone that will enclose

the repository possess extremely low permeabilities. These low permeabilities are expected to

create a diffusion dominated transport regime in which contaminant migration via groundwater is

extremely slow, approximately 1 mm each year. Most of the radionuclides in the L&ILW will

decay to insignificant levels long before they would move any distance from the repository.

Protection of Near-surface Freshwater Aquifer: Near-surface fresh groundwater resources

are drawn from overburden or shallow bedrock wells that extend to depths of approximately

100 m. These groundwater resources, shown in the figure on the following page, are isolated

from the DGR by approximately 550 m of sedimentary bedrock. Within this horizontally layered

sedimentary sequence, a 200 m thick low permeability “blanketing” shale horizon immediately

above the proposed repository prevents vertical groundwater migration. These same

sedimentary bedrock formations isolate the DGR from Lake Huron, as the location of the DGR

is approximately 400 m below the elevation of the bottom of Lake Huron.

Stagnant Deep Groundwater Flow System: Within the Ordovician bedrock, high pore water

concentrations (i.e., >100 g/L total dissolved solids), formation-distinct hydrogeochemical

signatures suggesting an absence of cross-formational groundwater flow, a laterally continuous

and horizontally layered regional scale bedrock hydrostratigraphy, and extremely low rock mass

permeabilities all provide evidence of a sluggish or stagnant groundwater flow system in which

groundwater ages are expected to be older than 1 million years.

Good Constructability and Flexibility of Host Rock: Rock strength is expected to be similar

to the same rock layers at Niagara (Queenston Shale) and at Darlington (Lindsay limestone)

that have been shown to be suitable for standard mining technologies, requiring only ground

and roof support. The lateral extent of the limestone and shale is sufficient without the need to

build or grout around major fractures. In addition, water inflow through the shafts can be

managed using standard mining techniques, as has been demonstrated in other excavations

within this sedimentary layer.

Low Resources for Oil, Gas, Minerals, and Drinkable Water: There are no indications of

commercially viable oil, gas or rock salt resources in the vicinity of the Bruce site. The rock

under the Bruce site does not contain useful metal ores or other mineral resources. The.


_____________________________________________________________________________________________ 20 August 2006

Geoscience: Site Descriptive Geosphere Model


AUGUST 2006

21

groundwaters in the vicinity of the DGR are too salty to be drinkable and the extremely

low rock mass permeabilities makes them unrecoverable.

3.4 Safety of the DGR at the Bruce Site

The site understanding developed to date, together with the results of preliminary safety

assessments, gives confidence that the site possesses favourable characteristics for

isolation of the waste from the biosphere. Key reasons why the DGR is expected to be

safe include:

• The deep groundwaters at the site are very old and do not mix with surface waters

• The rock is very old and stable

• The geology and hydrology are predictable at repository depth

• Postclosure dose estimates are very small because mass transport is diffusion

limited

• Earthquakes, glaciation or other natural events will not disrupt the repository

• The repository is safe from inadvertent human intrusion

• The repository can be built and operated safely using proven technologies

Safety of the DGR is assured throughout its life cycle. During the operational period,

packages of low and intermediate-level waste are placed in the underground vaults.

During this period, the safety of the facility will be governed by conventional mine safety,

and by handling of the packages of low and intermediate level waste consistent with

radiation protection regulations. These are well-established technologies. For example,

the excellent safety record at the WWMF demonstrates our ability to safely handle waste

packages.

In due course, the access shafts are sealed and the underground facility is closed. After

closure, the primary safety case is based on the intrinsic quality of the deep geosphere

at the site – its low permeability, its long-term stability, and its predictability. These

ensure that radionuclide transport from the repository would be very slow, and as a

result virtually all the radioactivity decays within or near the repository.


AUGUST 2006

22

The potential dose consequences of the DGR were estimated in preliminary safety

assessments. Bounding analysis shows that the gradual release of radionuclides from

the repository due to dissolution and diffusion through the rock will result in a very low

dose (<< 10-4 mSv/a). This is much less than natural background (about 2 mSv/a), the

CNSC dose limits for nuclear facilities, and internationally recommended dose

constraints (0.3 mSv/a), and the peak dose would occur tens of thousands of years in

the future.

4.0 International Experience OPG’s proposal to store low and intermediate level waste in an underground repository

is consistent with practice in other countries in Europe and in the United States. Early

repositories favoured crystalline rock; however sedimentary rock is internationally

accepted as shown by recent initiatives in France, in Switzerland and Belgium.

4.1 Operating Facilities

The Forsmark facility in Sweden, shown in the figure on the following page, has been

storing operational waste in crystalline metamorphic rock 60 metres below the Baltic Sea

since 1988.

In Finland, at the Olkiluoto nuclear plant, an underground repository for low and

intermediate level waste has been operating since 1992 in crystalline bedrock at depths

of 70 to 100 m below ground surface.

Also in Finland, near the Loviisa nuclear plant, a comparable facility was opened in

1998. The repository was built in granite rock at a depth of 110 m.

The Waste Isolation Pilot Plant (WIPP) was the United States’ first operating

underground repository for defense-generated transuranic radioactive waste1. It began

1 Transuranic waste consists of clothing, tools, rags, residues, debris and other such items contaminated with small amounts of radioactive elements – mostly plutonium. These elements are radioactive, man-made, and have an atomic number greater than uranium.


AUGUST 2006

23

operation in 1999. Located in southeastern New Mexico, the facilities include excavated

rooms 2,150 feet (approximately 655 m) underground in an ancient, stable salt

formation.

SKB’s Forsmark Repository for Management of Low and Intermediate Level Waste

4.2 International Acceptance of Sedimentary Rock Formations A number of countries are pursuing radioactive waste repositories in sedimentary rock.

In Germany a deep repository (Konrad) to be sited in a limestone rock formation has

been approved. In France a deep repository for high-level waste in shale (the Bure site)

is being investigated. In Switzerland the federal government recently approved the

conclusions of a feasibility study for a high-level waste repository sited in clay. In

Belgium and Japan sedimentary rock formations are also being investigated for high-

level waste repositories.


AUGUST 2006

24

5.0 EA Technical Studies OPG will undertake technical studies which will include geoscience and safety

assessment studies, and will be consistent with the EA scoping document (EA

guidelines) issued by the regulator for the proposed DGR.

5.1 Geoscientific Site Characterization Plan (GSCP)

OPG has proposed a specific Geoscientific Site Characterization Plan, developed by an

independent consultant, to provide information necessary to develop a comprehensive

site geosphere model that:

Confirms the geoscientific understanding of the current condition of the site, and its

past evolution and provides information to develop an understanding of likely future

natural evolution over the period of interest for safety

Establishes a baseline for detecting potential short-term and long-term environmental

impacts caused by construction, operation and closure of the facility, and

Provides the necessary geoscience information and data to design the facility and

perform safety assessments and design optimizations.

The activities to be completed in the first phase of site characterization, and which

comprise the geoscientific technical studies in support of the environmental assessment,

include:

Re-establish shallow bedrock wells

Expand the seismograph monitoring network

Conduct 2-dimensional seismic studies

Drill boreholes DGR-1 and DGR-2 located on the Bruce site to depths of 400 m and

800 m, respectively

Log borehole geophysical data

Hydraulic testing of boreholes

Install long-term multi-level groundwater monitoring wells

Laboratory core testing

Deep bedrock hydrogeologic monitoring


AUGUST 2006

25

Information gathered in these studies will be integrated to develop a descriptive geologic

model of the DGR site and surrounding area. The geologic site model will describe the

three dimensional spatial distribution of all important geologic formations and the

occurrence of all important geologic structural features within the bedrock units. The

descriptive model will provide a basis for geoscientific understanding of the current

condition of the Bruce site, its past evolution and likely future natural evolution over the

period of interest. The descriptive geologic site model will also provide the basic

framework for the development of descriptive hydrogeologic and geomechanical site

models.

Independent oversight and peer review of the GSCP is provided by the Geoscience

Review Group, comprised of internationally renowned scientists and engineers from

Canada, France, Switzerland and the United States who, among other roles, ensure that

information and lessons learned in similar international DGR work are reflected in the

GSCP.

Phases 2 and 3 of the Geoscientific Site Characterization Plan will provide further

information to support the Construction Licence application for the DGR.

5.2 Safety Studies

The planned site characterization will provide more detailed information on which to

verify the assumptions made in the preliminary safety assessment studies, and to

conduct more detailed modelling of the preclosure and postclosure safety of the

proposed DGR. These assessments will follow international best practice.

The preclosure safety assessment will cover normal operations and accident conditions.

Impacts to workers, public and biota will be considered. The postclosure safety

assessment will cover potential future impacts to people and to biota after the repository

is closed. Detailed analyses will include the best available site, design and waste

inventory information.

The safety of the DGR will be assessed in accordance with the CNSC regulatory guide

G-320. The safety case will include both quantitative safety assessments as well as


AUGUST 2006

26

complementary evidence for long-term safety, including in particular evidence from the

site geology. Scenarios will be developed that account for normal (or expected)

evolution of the site and facility with time, disruptive events such as human intrusion, as

well as hypothetical “what if” scenarios to test the robustness of the repository system.

6.0 On-Going Community Consultation OPG is committed to continuing to reach out to the community to provide current

information on the proposed DGR project and to obtain comments from the community

which will be considered through the environmental assessment process. OPG’s

environmental assessment consultant will be providing guidance in developing and

implementing a stakeholder communications program. This program will include

continued participation of OPG’s van and trailer display at community events such as

home shows and local fairs, presentations at community group meetings, regular

distribution of newsletters, a column in a local newspaper, and regular updates to the

DGR page on the OPG web site. Other opportunities will be identified and pursued

throughout the life of the DGR project.

7.0 Project Schedule The Municipality of Kincardine approached OPG about the feasibility of a long-term

L&ILW management facility at the WWMF in 2001. Initiation of the DGR project, in

2005, has occurred following four years of concept development and feasibility studies,

including extensive community consultation. This process included completion of a

Geotechnical Feasibility Study and a Preliminary Safety Assessment in 2003, an

Independent Assessment Study in 2004, and the signing of a Host Community

Agreement in 2004.

The next steps in the development of the DGR involve the environmental assessment

and licensing processes which are expected to occur over a period of about six years,

from 2006 to approximately 2011. Construction of the DGR, which is expected to start in


AUGUST 2006

27

2012, would take approximately five years. Emplacement of waste into the DGR would

commence in or about 2017.

8.0 Conclusions Deep geologic repositories have been operating safely internationally for many years.

OPG’s proposed DGR, which is consistent with this international practice, would be

located in a willing host community, where the waste has been safely managed for more

than thirty five years. The elected representatives of the municipality have demonstrated

their support for the proposed DGR through a Council Resolution. Support of

constituents was demonstrated through the results of a telephone poll.

In addition to a supportive community, the site is ideal from a geologic perspective.

Feasibility studies, conducted by independent consultants, demonstrated that the

geologic media beneath the Bruce nuclear site could safely isolate the L&ILW from the

environment and from the public, that the predicted releases of radioactivity from the

facility would be many orders of magnitude less than internationally accepted standards,

and that there would be no significant environmental effects resulting from the DGR.

Technical studies, including Geoscience Site Characterization and pre-closure and post-

closure safety assessments, will be done over the next several years to confirm the

results of the preliminary studies.


AUGUST 2006

28

9.0 References Golder Associates, Ltd., 2003. LLW Geotechnical Feasibility Study Western Waste Management Facility, Bruce Site, Tiverton, Ontario, Rpt. No. 021-1570. Golder Associates Ltd., 2004. Final Report on the Independent Assessment of Long-term Management Options for Low and Intermediate Level Wastes at OPG’s Western Waste Management Facility. February 2004. Municipality of Kincardine and OPG. 2004. An Agreement Regarding a Deep Geologic Repository for Low and Intermediate Level Nuclear Waste. Ontario Power Generation, 2005. Deep Geologic Repository for Low and Intermediate Level Radioactive Wastes. Project Description. Report No. 00216-REP-03902-00001-R01. Quintessa, 2003. Preliminary Safety Assessment of Concepts for a Permanent Waste Repository at the Western Waste Management Facility Bruce Site. Report No. QRS-1127B-1 v1.0, March 2003.

CMD 06-H22.1A

File/dossier 1-3-1-7 Date 2006-09-06 Oral Presentation Supplementary Information Submission from Ontario Power Generation Inc. In the Matter of Ontario Power Generation Inc.

Exposé oral Renseignements supplémentaires Mémoire de Ontario Power Generation Inc. À l’égard du Ontario Power Generation Inc.





DOCUMENTARY INFORMATION SUMMARY REV 01

August 2006


A submission to the Canadian Nuclear Safety Commission

in support of

October 23, 2006 Hearing on the Scoping Document (EA Guidelines)

regarding

OPG’S PROPOSAL TO CONSTRUCT AND OPERATE A DEEP GEOLOGIC REPOSITORY AT THE BRUCE NUCLEAR SITE

in the

Municipality of Kincardine


August 2006

Revision Summary

Revision Number Date Comments

R00 2006-08-22 Initial issue. s. 2.1.3.1, removed First Nations from list of stakeholders. Added sentence at the end of the section indicating that First Nations were briefed. s. 2.8.1 Deleted discussion of funding for legal review of MOU. s. 2.8.2 Deleted discussion of wind energy.

R01 2006-08-30

Various sections, included “Unceded” in naming the Chippewas of Nawash “Unceded” First Nation.


August 2006

TABLE OF CONTENTS

1.0 Introduction ....................................................................................................................... 11.1 Western Waste Management Facility…………………………………………………......... 11.2 Safety and Environment Record………………………………..…………………………… 21.3 Community Acceptance………..……………….…………………………........................... 31.4 Long-term Planning for Nuclear Waste Management………………..………………..….. 4 2.0 Kincardine – OPG Joint Feasibility Study……………………………………………….…. 42.1 Memorandum of Understanding Studies..…………………………….……………….….... 42.1.1 Site Visits to Operating Long-term L&ILW Management Facilities…………………….… 52.1.2 Independent Assessment Study…….……………………………………………………….. 52.1.3 Stakeholder Communication and Consultation………………………………………….... 62.1.3.1 Stakeholder Briefings…………………………………………………………...……..….. 62.1.3.2 Open Houses……………………………………………………………..………………... 72.1.3.3 Independent Assessment Study Web Page………………………………………...….. 72.1.3.4 Newsletters……………………………………………………………………………….… 72.1.4 Results of the Independent Assessment Study…………..…………………..………….… 82.2 Kincardine Council Decides on the DGR………………………………………………...… 82.3 OPG Board Approval to Proceed ……………………………………………..…….………. 92.4 Host Community Agreement………………………………..……………………………...… 92.5 Assessing Residents' Support for the Agreement……………………………………….… 102.5.1 Community Consultation in the Municipality of Kincardine……………………………..… 102.5.1.1 Fact Sheets in the Media ............................................................................................... 112.5.1.2 Distribution of Printed Material…………………………………………………………….. 112.5.1.3 Web Page ……………………………………………………………………………...……. 112.6 The Poll………………………………………………………………………...…..………...… 122.7 Communications and Consultation in Surrounding Communities – Post Poll………….. 122.7.1 Open Houses in Surrounding Communities…………… ………………………………..… 122.7.2 Open Houses in Local Cottage Communities……………………………………………... 132.8 Communications with First Nations................................................................................... 132.8.1 Memorandum of Understanding Between First Nations and OPG………………….…… 132.8.2 Implementation of the MOU with First Nations …………………………………………..... 132.8.3 Open Houses at First Nations ……………………………………………...…………..…… 142.8.4 Site Tours…………………………………………………………………….………………… 14 3.0 DGR Project……………………………………………………………………………………. 153.1 Overview of the DGR……………………………………………….……………………….... 153.2 Wastes to be Placed in the DGR……………………………………………………..……… 153.3 Bruce Site Geology.…………………………………………………………………………… 173.4 Safety of the DGR at the Bruce Site…...…………………………………………...…….… 21 4.0 International Experience……………..……………………………………...……………...... 224.1 Operating Facilities…………………………..……………………………..……………….… 224.2 International Acceptance of Sedimentary Rock Formations………….….………….……. 23 5.0 EA Technical Studies…………………………………………………………………….…… 245.1 Geoscientific Site Characterization Plan…………………………………………………..... 245.2 Safety Studies…………………………………………………………………………….…… 25 6.0 On-Going Community Consultation…………………………………………………..…...... 26


August 2006

7.0 Project Schedule…………………………………………………………………………..…... 26 8.0 Conclusions…………………………………………………………………………..………… 27 9.0 References…………………………………………………………………………..…………. 28


_____________________________________________________________________________________________ 1 August 2006

1.0 Introduction Ontario Power Generation (OPG) has submitted a Project Description (OPG, 2005) to the

Canadian Nuclear Safety Commission (CNSC) to begin the regulatory review process for the

construction and operation of a Deep Geologic Repository (DGR) at the Bruce nuclear site, in

the Municipality of Kincardine. The DGR would provide safe long-term management of low and

intermediate level radioactive waste (L&ILW), in the sedimentary rock approximately 500 to 700

m below the ground surface. OPG currently manages L&ILW at the Western Waste

Management Facility (WWMF) located at the Bruce nuclear site.

The Municipality of Kincardine approached OPG with the proposal to study the feasibility of

long-term management at the Bruce nuclear site. The feasibility studies, conducted by

independent consultants, have concluded that the proposed DGR is technically feasible, is safe,

would not have significant adverse environmental effects, and is supported by the local

community.

1.1 Western Waste Management Facility (WWMF) OPG and its predecessor, Ontario Hydro, have safely managed low and intermediate level

radioactive waste (L&ILW) arising from OPG-owned reactors since 1975.

Low level waste, which typically consists of slightly contaminated rags, mops, clothing, floor

sweepings, etc., is volume reduced where possible, either by compaction or by incineration.

Low level waste makes up about 95 per cent of the non-fuel waste volume received at the

WWMF. Approximately 3000 m3 of low level waste is placed in storage each year. Average

radiation levels at the surface of the low level waste containers are less than 0.01 mSv/h for

about half of the LLW when it is received at the WWMF, and less than 0.25 mSv/h for most of

the remaining half. These radiation levels decrease in time, to approximately 1/10th of the

original amount after 50 years, and about 1/50th of the total amount after 250 years (Golder,

2004).

Intermediate level waste, typically consists primarily of used nuclear reactor components, and

ion-exchange resins and filters used to purify reactor water systems. The dose rates for ILW

are higher than for LLW, with an average dose rate less than 200 mSv/h for more than 80 per

cent of waste containers and more than 47,000 mSv/h for the remaining containers. Ninety nine


_____________________________________________________________________________________________ 2 August 2006

per cent of the ILW has a dose rate of less than 1000 mSv/h. Approximately 290 m3 of ILW is

placed in storage each year.

L&ILW produced at the Bruce, Darlington and Pickering nuclear generating stations are

transported by truck to the WWMF for interim storage. OPG uses several different types of

packaging to transport radioactive materials depending on the contents. All are built to the

stringent packaging requirements specified by the CNSC’s “Packaging and Transportation of

Nuclear Substances Regulation”. OPG also manages used fuel from the Bruce Power

generating stations at the WWMF at the Used Fuel Dry Storage Facility; however, used fuel will

not be placed in the proposed DGR.

Waste types and volumes will not change as a result of the proposed DGR. Much of the waste

to be stored in the DGR is already in interim storage at the WWMF. The remainder will be

transported over the remaining operating lives of OPG-owned nuclear generating stations.

1.2 Safety and Environment Record

Each of Bruce Power, Atomic Energy of Canada, and OPG operates facilities at the Bruce site.

These activities result in the release of some radionuclides, some of which are also naturally

present in the environment. Environmental monitoring programs conducted at the Bruce site

routinely measure radiological emissions and the concentrations of selected radionuclides in the

atmospheric, aquatic, terrestrial and geophysical environments.

The results of these monitoring programs, together with data on water use and food sources,

are used to calculate the radiation dose to members of the public living in the vicinity of the

Bruce site. The highest calculated dose from the entire Bruce site in 2005 was 2.02 µSv. The

data indicate that the WWMF makes a very small contribution to the dose from the Bruce site.

The public dose from the WWMF is <4 per cent of the Ontario background and < 0.01 per cent

of the legal limit (of 1000 µSv/a).

Nuclear Waste Management Division (NWMD) has a systematic approach to safety and

environmental protection, which includes a focus on continuous improvement of its operations.

NWMD’s safety and environmental programs were developed consistent with external

standards and have been audited relative to those standards. NWMD is registered to the ISO

14001 Environmental Management System Standard and has been since 1999. NWMD uses a


_____________________________________________________________________________________________ 3 August 2006

preventive loss control program which documents very low hazardous conditions, such as

housekeeping conditions, so that they can be corrected before an injury occurs or equipment is

damaged. NWMD’s system has been rated by an external auditor at a score of 8 relative to the

International Safety Rating System (ISRS), a result which is considered very good.

These managed systems contribute to NWMD staff achieving significant milestones in the areas

of safety and the environment. In 2005 NWMD reached a milestone of 11 years without a lost-

time accident. In more than thirty five years of transporting radioactive tools, samples,

equipment, and waste, almost fifty thousand shipments have been made with no serious injuries

and no releases of radioactive material to the environment.

1.3 Community Acceptance

OPG is committed to keeping the public and community stakeholders informed about its nuclear

waste management operations and plans. Stakeholders, especially those in the communities in

which OPG operates nuclear waste management facilities, are routinely provided update

briefings about OPG’s nuclear waste management plans. In the Bruce community these

updates are provided through the distribution of the Neighbours Newsletter to residences,

through notices published in the local newspapers, OPG attendance at community events such

as home shows, Pumpkinfest, the Scottish festival, and participation in the Living Snow Fence,

the Impact Advisory and Liaison Committees, as well as many other programs. OPG also

keeps the public informed about plans for changes to its operations. Prior to construction of a

new facility or other planned project, the public is provided with opportunities to learn about and

comment on the proposed projects.

Public Attitude Research was conducted both in Kincardine and in the communities surrounding

Kincardine. The results of the research indicated that for 91 per cent of the community the

WWMF has no effect on their daily life. Of the nine per cent who said it has an effect, five per

cent said the effect is positive. Approximately two thirds of respondents also indicated that none

of the long-term management options considered for L&ILW, including the DGR, would have an

adverse effect on their feelings of personal security or satisfaction with the community or on the

community as a place to visit, to operate a business or to live. Of those who said it would have

an effect, about a third thought the effect would be positive.


_____________________________________________________________________________________________ 4 August 2006

1.4 Long-term Planning for Nuclear Waste Management

The current WWMF provides interim storage for L&ILW. These facilities can continue to provide

safe storage of the waste for many decades into the future. However OPG is also committed to

ensuring that a long-term management solution is available. OPG’s preliminary long-term

plans, completed in 1998, were for a repository to be available, starting in 2015. Plans at that

time did not identify a specific site for the repository.

An important part of the planning process was making financial provision, so that funding would

be available for the life cycle cost of the L&ILW management and costs would not be passed to

future generations. OPG, assisted by international experts, has conducted extensive studies to

determine the life cycle cost of nuclear waste management. The Segregated Fund, established

to pay for the long-term management of low and intermediate level waste and the

decommissioning of Ontario's nuclear generating stations, currently has funds to the value of

$4.2 billion, which is more than 100 per cent of the estimated requirement. These estimates

were reviewed by the CNSC as part of the Decommissioning Financial Guarantee process.

2.0 Kincardine – OPG Joint Feasibility Study

2.1 Memorandum of Understanding (MOU) Studies In 2001, the Municipality of Kincardine approached OPG seeking to enter into an agreement to

study options for long-term management of L&ILW at the existing WWMF. Those discussions

led to the signing, in April 2002, of a Memorandum of Understanding (MOU) between OPG and

the Municipality of Kincardine. The work plan under the agreement included:

A review of the technical feasibility of the long-term management options for L&ILW at the

WWMF

A socio-economic impact assessment in the Municipality of Kincardine of the existing

operation of the WWMF and of the potential long-term options

A review of European and American models for long-term management of L&ILW, including

site visits to look at issues such as technical infrastructure and community compensation.


_____________________________________________________________________________________________ 5 August 2006

A Steering Committee was established with four representatives from the Municipality of

Kincardine and three from OPG. The Steering Committee met regularly to develop and

advance the work plan.

2.1.1 Site Visits to Operating Long-term L&ILW Management Facilities Representatives of the Municipality of Kincardine visited a number of communities which host

waste facilities, in Europe and the United States. The purpose of the fact finding visits was to

review best practices in low and intermediate level waste management from a technical

perspective and to meet with community officials/representatives and review community

agreements.

The group toured the following facilities:

Zwilag, Switzerland (enhanced processing and storage facility)

Centre de l’Aube, France (covered above-ground concrete vaults for low level

radioactive waste)

SFR Facility, Sweden (in crystalline rock 60 metres below the Baltic Sea for low and

intermediate level waste)

Barnwell, South Carolina, USA (trench disposal of low level waste)

Waste Isolation Pilot Plant (WIPP), Carlsbad, New Mexico, USA [Deep Geologic

Repository for transuranic waste, 2,150 feet (about 650 m) below ground in a salt

formation]

Site visits confirmed that there were several feasible technologies for long-term L&ILW

management and that in some cases host community agreements were in place, and in some

cases they were not.

2.1.2 Independent Assessment Study

The work plan included an Independent Assessment Study (IAS) of options for the long-term

management of Low and Intermediate Level Waste (L&ILW), with the existing operation serving

as the base case for purposes of comparison. The IAS, conducted by Golder Associates,

evaluated the geotechnical feasibility, safety, potential environmental effects and the potential

social and economic effects of several options.


_____________________________________________________________________________________________ 6 August 2006

The Enhanced Processing, Treatment and Long-term Storage option uses both existing

and new equipment and processes to treat waste prior to placing it in long-term above-ground

storage.

The Covered Above-ground Vault involves the construction of large reinforced concrete

enclosures located on the ground surface. The Covered Above-ground Vaults are located and

constructed so that the wastes are maintained in a dry state throughout the vaults’ lifetime. The

vault would be constructed of reinforced concrete and subsequently covered with layers of earth

and synthetic material designed to minimize infiltration of water.

The Deep Geologic Repository involves the construction of rock caverns within the stable, low

permeability bedrock using conventional mining methods. Access to the caverns is either by

ramp or shaft. As each emplacement room is filled it receives a temporary seal with an access

hatch. At the end of the operating life of the facility, the access is sealed with low permeability

material and backfilled to the surface. The repository rooms and tunnels would not be filled with

material.

Golder Associates also developed and implemented a Community Consultation and

Communications program as a part of the Independent Assessment Study. The

communications included one-on-one stakeholder briefings, open houses, newsletters, public

attitude research, web site, advertising in local newspapers, and presentations at regularly

scheduled meetings.

2.1.3 Stakeholder Communication and Consultation The stakeholder consultation and communication program focussed on the local municipalities

since, based on feasibility studies, no effects outside of Bruce County were anticipated. The

Independent Assessment Study web site and the subsequent OPG DGR web site

(www.opg.com/dgr) provided access to information for members of the broader community who

had an interest in the studies.

2.1.3.1 Stakeholder Briefings Key stakeholders, who included government agencies, local political representatives,

community leaders and labour unions, were briefed throughout the Independent Assessment

Study (IAS) at the following key milestones:


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• Initiation of the Independent Assessment Study process

• Completion of the Independent Assessment Study

• Completion of the Community Consultation in Kincardine

Councils of Saugeen First Nation and Nawash Unceded First Nation were also briefed on the

IAS.

2.1.3.2 Open Houses

Golder Associates, on behalf of the Municipality of Kincardine and Ontario Power Generation,

held Open Houses in Kincardine and in the municipalities in the outreach area in June 2003.

The objectives of the Open Houses were to:

• Inform the general public, employees of the Municipalities and OPG, other stakeholders

and the media about the discussions on the various options being considered for long-

term management of low and intermediate level waste at the WWMF

• Provide opportunities for stakeholders to provide data and information as input to the

Independent Assessment Study and to identify and discuss any concerns they had.

Feedback included comments about health, safety and environmental issues, risks to

groundwater, flooding of the repository, location of aquifers relative to the depth of a deep

geologic repository, and questions about the amount of radioactivity associated with low and

intermediate level waste. Questions were raised about the cost of a facility and employment

opportunities that may result from the construction and operation of a facility.

2.1.3.3 Independent Assessment Study Web Page A web site provided information on the existing waste management operations, the objectives of

the Independent Assessment Study, the options being considered in the Independent

Assessment Study, responses to Frequently Asked Questions, and copies of printed materials

such as newsletters, the Geotechnical Feasibility Study Report, the Preliminary Safety

Assessment Report, the independent Social and Economic Analysis study, the results of the

Public Attitude Research and the Independent Assessment Study Report. The Web Site

included a comment form that could be submitted electronically to Golder Associates.

2.1.3.4 Newsletters Two newsletters were produced in association with the Independent Assessment Study. The

newsletters were distributed to residences in the Municipality of Kincardine, Saugeen Shores,


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Arran-Elderslie, Brockton and Huron-Kinloss, as well as at the Saugeen and Nawash First

Nations. It was delivered to approximately 22,000 residences. Copies were also available at

Municipal Offices and libraries in the outreach area.

2.1.4 Results of the Independent Assessment Study

The results of the IAS were documented in a report (Golder, 2004), which concludes that each

of the three options examined:

Is technically feasible. The geology of the Bruce site is ideal for a deep repository

however it could also support above-ground concrete vaults.

Could provide safe storage for some or all of the L&ILW. Radiation doses would be

much lower than regulatory criteria and would occur far out into the future.

Would have no significant residual adverse environmental effects.

Would have no adverse social effects. The majority of respondents also indicated that

none of the long-term management options considered, including the DGR, for L&ILW

would have an adverse effect on their feelings of personal security or satisfaction with the

community or on the community as a place to visit, to operate a business or to live.

Would have a positive effect on the local economy.

2.2 Kincardine Council Decides on the DGR

Following a review of the Independent Assessment Study Report, municipal support was

indicated at the April 21, 2004 Council Meeting at which the following resolution was carried:

Resolution #2002 – 232

“that Council endorse the opinion of the [Kincardine] Nuclear Waste Steering Committee and

select the “Deep Rock Vault” option as the preferred course of study in regards to the

management of low and intermediate level radioactive waste”.

The Council’s decision to support the DGR as its preferred option was based on the following

key points:

• It is consistent with best international practice

• It provides the highest level of safety of any option, including the existing interim facilities


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• It provides a permanent storage method for L&ILW, much of which is already at the

Bruce site, and if necessary will do so in the absence of institutional controls

• An environmental assessment will be conducted prior to OPG proceeding with the DGR

• It provides significant economic benefit to the residents of our municipality

• No high level waste or used nuclear fuel would be allowed in the facility.

2.3 OPG Board Approval to Proceed

At its June, 2005 meeting, OPG’s Board of Directors approved moving forward with the

proposed DGR. Their acceptance of the proposal was based on:

The DGR would provide a high level of safety in the long term

The proposed project provides for management of L&ILW and is consistent with OPG’s

long-term plans for this waste

An independent consultant has determined that the Bruce site geology is ideal for safe

containment of the waste

The Segregated Fund for low level waste and decommissioning is fully funded, therefore

funding is in place for the full costs of developing, constructing and operating the proposed

DGR

The Kincardine community has expressed support for the proposed DGR.

2.4 Host Community Agreement During their visits to host communities in Europe and United States, Kincardine officials

confirmed that there was international precedent for Agreements for hosting long-term

radioactive waste facilities. The Port Hope Agreement, signed between the Town of Port Hope,

Township of Hope, Municipality of Clarington and the Government of Canada in 2001, for the

long-term management of historic wastes provides a recent Ontario example of a hosting

agreement.

The 2005 Kincardine Host Community Agreement includes the following provisions:

OPG will design, license, construct and operate a deep geologic repository for L&ILW

streams currently stored at the WWMF, with the support of the community


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Kincardine, Saugeen Shores, Huron-Kinloss, Arran-Elderslie and Brockton receive

35M$ (2004$, inflation protected) paid over thirty years subject to achieving key

project milestones

No used fuel would be stored in the DGR

Property value protection plan is provided

Kincardine Council obtains endorsement from Kincardine residents

Although the agreement is formally between OPG and the Municipality of Kincardine, OPG

received letters of support for the DGR from each of the four other municipalities which would

financially benefit from it.

2.5 Assessing Residents’ Support for the Agreement

2.5.1 Community Consultation in the Municipality of Kincardine Kincardine Council determined that they would seek formal endorsement of the hosting

agreement from Kincardine residents through a telephone poll. Leading up to the poll, a

community education/information plan was put in place to provide all residents an opportunity to

obtain information about the DGR concept and the hosting agreement. During this stage of the

process public consultation and communications efforts focused primarily on the residents of the

Municipality of Kincardine.

The Municipality of Kincardine and OPG jointly operated a Community Consultation Centre

located on the main street of Kincardine from October 2004 to the end of the telephone poll.

The Consultation Centre provided the opportunity for many discussions about the existing waste

management operations, the technology used in other countries to manage low and

intermediate level wastes, whether the repository would be used to store used nuclear fuel,

potential environmental effects from a DGR including effects on groundwater and Lake Huron,

what the effects of an earthquake would be on the repository and the waste stored in it, the

Hosting Agreement, the consultation process, and the regulatory approvals process associated

with the proposed DGR. In total, 312 individuals took the opportunity to attend the Consultation

Centre and discuss the proposal with representatives of OPG and the Municipality.


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Leading up to the telephone poll, the Municipality of Kincardine and OPG also made

presentations on the Deep Geologic Repository Proposal, on a request basis, to community

groups.

2.5.1.1 Fact Sheets in the Media

OPG and Kincardine placed a total of eight fact sheets in the local newspapers, providing

experts’ views of their particular speciality, as well as invitations to attend the Consultation

Centre to obtain information about the DGR proposal. Fact sheets addressed a number of

questions and comments which had been raised during the public communications program.

The fact sheets covered topics such as geoscience, safety assessment, the process for

residents expressing their views, health perspectives, and were provided by a number of

sources including Golder Associates, Quintessa, the Mayor of Kincardine and the Medical

Officer of Health for Grey-Bruce.

2.5.1.2 Distribution of Printed Material Kincardine residents were provided with two mail-outs, jointly issued by OPG and the

Municipality of Kincardine Council. The first was a newsletter and the second a pamphlet which

included background information on radioactive waste, the existing Waste Management Facility,

the Memorandum of Understanding, the Independent Assessment Study, the proposed DGR,

the Hosting Agreement, and the regulatory approvals process.

2.5.1.3 Web Page During the community consultation OPG launched a web page, which posted the Independent

Assessment Study report, as well as more detailed background information such as the

Preliminary Safety Assessment, the Geotechnical Feasibility Study, newsletters, panels

displayed at the Community Consultation Centre, and hours of the Community Consultation

Centre. It also included an electronic comment form which could be used to request specific

information about the DGR Proposal. During the time period that the Community Consultation

was underway, OPG responded individually to each comments/questions received.


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2.6 The Poll

An independent company, Strategic Counsel, conducted the telephone survey in January and

February 2005. Diligent efforts were made to contact each household, and each eligible

resident, either by telephone, through a 1-866 number, or by mail if no telephone contact could

be made. Seasonal residents were mailed a copy of the question and asked to respond by

mail.

Of the 5257 eligible households indicated in the 2001 Statistics Canada Census, 3763

participated in the poll. This represented 6778 individual votes. The results of the vote were:

Yes 60% No 22% Neutral 13% Don’t Know/Refused 5%

The Kincardine Municipal Council accepted the poll results as an indication of sufficient support

to move forward with the Hosting Agreement.

2.7 Communications and Consultation in Surrounding Communities – Post Poll 2.7.1 Open Houses in Surrounding Communities Throughout the Community Consultation process, communications efforts were focussed on the

residents of the Municipality of Kincardine. Following the completion of that process, and the

results which indicated residents supported proceeding with the regulatory process for a DGR,

OPG broadened its communications efforts.

Open Houses were held in each of the four surrounding municipalities including Port Elgin,

Walkerton, Chesley and Ripley. During the course of the four Open Houses, most attendees

took the time to have a lengthy conversation with one of the OPG representatives, to express

their views, ask questions and obtain information. The majority of visitors left the Open Houses

with more information and a greater level of comfort about the proposed DGR.

After each of these Open Houses a copy of the panels, in booklet format, was delivered by

Canada Post to each residence, year-round and seasonal, in the municipality.


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2.7.2 Open Houses in Local Cottage Communities

A number of property owners in the Municipality of Kincardine and adjacent municipalities are

seasonal residents, who use their properties primarily during the summer months. OPG held

Open Houses in three cottage communities (Point Clark, Southampton and Inverhuron) in the

summer of 2005 to provide opportunities for these people to provide comments and obtain

additional information about the DGR proposal. Visitors to the Open Houses expressed an

interest in potential effects of the proposed DGR on water quality in Lake Huron.

Overall, visitors to the Open Houses found the display informative and were appreciative of the

opportunity to discuss the proposal. Not all visitors supported the proposal; however the

majority are better informed and have a greater level of comfort with the proposal after attending

the Open Houses.

2.8 Communications with First Nations The Independent Assessment Study included a Communications Program with First Nations.

2.8.1 Memorandum of Understanding between First Nations and OPG

OPG and the Saugeen First Nation and the Chippewas of Nawash Unceded First Nation, signed

an MOU. The MOU outlined terms and a process for OPG and First Nations to communicate on

the proposed DGR. It included funding support for First Nations to have an Administrative Co-

ordinator to facilitate communications, and a technical advisor to peer review the Independent

Assessment Study Report and provide technical advice. Discussions are underway towards

reaching agreement on a longer term MOU.

2.8.2 Implementation of the MOU with First Nations OPG provided funding for a Communications Advisor, and for a technical review of the

Independent Assessment Study. OPG has also made technical support and advice available to

First Nations to assist them in developing applications for federal government funding for

feasibility studies for wind energy at the Chippewas of Nawash Unceded First Nation and

Saugeen First Nation.


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2.8.3 Open Houses at First Nations

First Nations, under the MOU, arranged for several opportunities at each of Saugeen and

Chippewas of Nawash Unceded First Nations for Band members to obtain information about the

proposed DGR and provide feedback on the proposal. First Nations hosted “Peer Review

Public Meetings”, with presentations from technical experts, to provide band members an

opportunity to find out more about nuclear waste management plans and specifically, the DGR

proposal. The technical advisor summarized the Independent Assessment Study Report at the

meetings and presented the conclusion that it appeared to be correct.

Following the Peer Review Meetings, OPG arranged Open Houses at each of Nawash and

Saugeen First Nations to present information on the proposed DGR, respond to questions and

obtain feedback on the proposal. At Nawash, discussion was about the long-term effects on

traditional lands and the interpretation of scientific information indicating that the environmental

effects were insignificant. At Saugeen, questions focused on the technical details of the

proposal and about potential environmental effects on their traditional lands. They expressed

interest in continuing a dialogue about the proposal and invited OPG to return to provide future

updates on the proposal.

2.8.4 Site Tours

To assist First Nations in familiarizing themselves with OPG’s operations at the Western Waste

Management Facility, OPG provided tours of the existing operation to members of Joint Council

and elders. The tours provided a good opportunity for visitors to see the existing low and

intermediate level waste operation and to have their questions about the waste and the facility

answered.