1. Introduction NORTHWATCH 1

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1 Review of Ontario Power Generation s Additional Information in Support of their Proposed Deep Geologic Repository for Low & Intermediate Level Nuclear Wastes NORTHWATCH MARCH 6, 2017 REFERENCE # 17520

2 1. Introduction In a letter dated 18 February 2016 the federal Minister of the Environment and Climate Change, the Hon. Catherine McKenna, informed Ontario Power Generation that OPG was required to provide "additional information" about their proposal to construct a deep geologic repository for the emplacement of radioactive waste beneath the Bruce Nuclear Generating Station, adjacent to the eastern shore of Lake Huron. Ontario Power Generation replied in April 2016 that they would provide the required information prior to the end of Submitted with a cover letter dated December 28, 2016, Ontario Power Generation s response to the Minister s requirement for additional information was posted in the mid-to-late afternoon of January 3rd, 2017 on the public registry maintained by the Canadian Environmental Assessment Agency for this project s review. The OPG response is comprised of several documents, including a main submission and three supporting documents corresponding to the Minister s direction to provide a study of alternate locations, an updated analysis of cumulative effects with one supporting document, and an updated report on mitigation measures. The Canadian Environmental Assessment Agency announced a public comment period ending February 17 th, 2016 which was later extended to March 6 th, The following analysis and conclusions are submitted by Northwatch as part of this stage of the review process. NORTHWATCH 1

3 2. Key Findings As outlined in the following sections of this report, Northwatch s review has included a general analysis and two reviews by technical experts. Northwatch s review has concluded that Ontario Power Generation has failed to appropriately and adequately respond to the Minister s requirement for additional information. In particular, Ontario Power Generation has failed to adequately reply to the Minister s request for additional information. First and foremost, Ontario Power Generation did not undertake a study of actual locations, and does not provide studies or even basic descriptions - in reference to actual locations. OPG s borrowed description of a representative surface area is not a description of an actual area, but of a hypothetical one, The study of alternate locations took a scatter gun approach to the siting of the alternate locations The seven sedimentary, and 14 crystalline/basement rock locations are given insufficient examination in any of the OPG reports The OPG reports makes numerous unsupported statements and assumptions, for which no supporting evidence of studies are provided. OPG sets out criteria for technically and economically feasible alternate locations which is extremely generic and does not meet the direction of either the Minister s requirement for additional information or CEAA s 2015 Operational Policy Statement. Some of the failings of the OPG reports are circular, i.e. in not following the directions to identify actual locations, OPG has created a circumstance in which it will be extremely difficult to put forward anything more substantive than very generic feasibility criteria and thresholds, but even quite generic feasibility criteria and thresholds will not be met by all locations / areas within the very large regions that OPG has sought to use as substitutes for actual locations. The methods used do not conform to best practices for the transportation risk assessment of radioactive materials. For example, the cost assessment is so narrow that its conclusions may be lead to significant underreporting of actual costs. The report uses a generic methodology to assess risks and costs. Further to the failures outlined above and detailed in later sections of this report, the Minister s decision statement for the federal environmental assessment of Ontario Power Generation s deep geologic repository must clearly set out that Ontario Power Generation has failed to meet the requirements of the Canadian Environmental Assessment Act and that on the basis of that failure Ontario Power Generation s application is denied. NORTHWATCH 2

4 3. Background Ontario Power Generation is proposing to construct a deep geologic repository for low and intermediate level radioactive waste within the site boundaries of the Bruce Nuclear Generating Station in Kincardine, Ontario on the eastern shore of Lake Huron. The repository has a conceptual design which places it within 1,000 metres of Lake Huron and at a reference depth of 680 metres below the surface, in a band of limestone topped by shale. The repository would be comprised of two shafts and a series of caverns into which Ontario Power Generation proposed in their Environmental Impact Statement (EIS) to place 200,000 cubic metres of nuclear waste. Some of these wastes called low level radioactive wastes do not require extra barriers to shield workers from radioactivity, although they are still hazardous. Other wastes - classified as intermediate wastes - are highly radioactive. In fact, some wastes classified as intermediate waste are similar in their level of radioactivity to wastes classified as high level waste, namely used fuel or irradiated nuclear fuel waste. Elements of these wastes will remain dangerously radioactive for hundreds of thousands of years, and some for even far longer than that. While Ontario Power Generation s environmental assessment application (2011) is for a waste volume of 200,000 metres 3, in August 2013 Ontario Power Generation acknowledged on the public record that they intend to double the amount of waste to be placed in the proposed DGR and will seek a licence amendment after they receive a project approval based on the original volume; the final use and size of the proposed DGR remains unknown. The project was the subject of discussions between Ontario Power Generation and the Municipality of Kincardine as early as 2002 and a hosting agreement between Ontario Power Generation and area municipalities which included financial compensation to supporting municipalities in was signed in In 2006 the project was referred for a federal environmental assessment by a Joint Review Panel. A hearing under the Canadian Environmental Assessment Act commenced in September 2013 and extended into October 2013, then adjourned and was reconvened in The extension and recommencement were as a result of the Joint Review Panel requiring additional information from Ontario Power Generation to supplement that provided in OPG s 2011 Environmental Impact Statement and Technical Support Documents and in responses to over 500 information requests posed by the Joint Review Panel to Ontario Power Generation. NORTHWATCH 3

5 4. Northwatch s Interest Northwatch is a public interest organization concerned with environmental protection and social development in northeastern Ontario, founded in Northwatch has a longstanding interest in the management of nuclear waste; this interest was initiated by proposals dating back to the 1970 s to site nuclear waste disposal projects in northern Ontario. The proposal by Ontario Power Generation (OPG) for a deep geological repository (DGR) at the Bruce Nuclear Site is of interest both because of its precedent setting nature and because of its close proximity to Lake Huron, and the potential for adverse effects on the North Channel and North Shore of Lake Huron, Manitoulin Island, and the broader Great Lakes ecosystem. Northwatch has actively participated in the federal review of OPG s proposed DGR since Prior to and since the appointment of the Joint Review Panel (JRP) in 2012 Northwatch has participated through monitoring the public registry, and since the JRP appointment in 2012 Northwatch has participated through continued monitoring of the public registry and reviewing postings on the public registry; reviewing the written evidence, including OPG and CNSC responses to Information Requests (IRs), submitting proposed IRs, making written submissions, presenting expert evidence, participating in JRP hearings through oral presentations and proposing questions, and submitting final comments to the Joint Review Panel. In 2015, Northwatch submitted comments to the Canadian Environmental Assessment Agency, commenting on the draft potential conditions, and noting that in their final report and recommendations the Joint Review Panel (JRP) had erred in several respects, including by failing to appropriately weigh the evidence before them, by basing their decision(s) on impressions they seemingly formed based on information that was not on the public record, and by delegating the actual decision-making role to an unknown future decision-maker. Northwatch had concluded that the potential conditions as drafted by the Canadian Environmental Assessment Agency (CEAA) did not remedy the failings of the JRP report Northwatch s written submissions and participation in the public hearing are part of the public record 1 and forms part of the body evidence that was before the Joint Review Panel and is available to Canadian Environmental Assessment Agency and the federal Minister of the Environment. NORTHWATCH 4

6 5. Requirement for Additional Information In her letter of February 18, 2016 the federal Minister of the Environment and Climate Change directed Ontario Power Generation to collect the following information and undertake the following studies: A study that details the environmental effects of technically and economically feasible alternate locations for the Project, with specific reference to actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility. In conducting this study, Ontario Power Gneration is to detail the thresholds for what is considered to be technically and economically feasible. In addition, Ontario Power Generation is to indicate what the incremental costs and risks would be for additional off-site transportation of the nuclear waste. An updated analysis of the cumulative environmental effects of the Project in light of the results from the Phase I Preliminary Assessmetns undertaken by the Nuclear Waste Management Organization, which identified three potential host communities that fall within the traditional territory of the Saugeen Ojibway Nation. An updated list of mitigation commitmetns for each identified advese effect under CEAA 2012, Ontario Power Generation shall identify out-dated or redundant commitments that were previously brought forward to the Panel. CEAR # 2872 From the Minister of Environment and Climate Change to Ontario Power Generation re: Request to provide additional information The Minister further directed Ontario Power Generation to inform the Canadian Environmental Assessment Agency no later than April 16, 2016 as to when OPG anticipated filing the required studies and additional information. On April 15, 2016 Ontario Power Generation provided a reply to the Canadian Environmental Assessment Agency, advising that they intended to provide the additional information by yearend and setting out OPG's understanding and response plan for each of the three elements of the request. (CEAR 2874) In response, on September 7, 2016 the Agency noted among other things that while Ontario Power Generation has indicated that it intends to provide an assessment of the environmental effects of two technically and economically feasible geologic regions in Ontario, specifically in a sedimentary rock formation in southern Ontario and in a granite rock formation located in central to northern Ontario, without providing specific reference to actual locations. The Agency further clarified that the analysis of the environmental effects of the alternate locations to be provided by Ontario Power Generation provide a narrative assessment that does not assume that alternate sites in the geologic formation would have the same geographical and hydrological characteristics of the preferred site. 2 NORTHWATCH 5

7 6. Review of Additional Information Provided by Ontario Power Generation 6.1 Alternate Locations As noted above, federal Minister of the Environmental and Climate Change required Ontario Power Generation to: Produce a study that details the environmental effects of technically and economically feasible alternate locations for the Project Undertake that study with specific reference to actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility Detail the thresholds for what is considered to be technically and economically feasible, and Indicate what the incremental costs and risks would be for additional off-site transportation of the nuclear waste. Ontario Power Generation produced a general report which they titled Main Submission and three supporting documents relating to each of describing alternate locations, describing environmental effects of alternate locations, and estimating costs and risks or transportation to alternate locations. The main submission summarizes material found in the three supporting reports, while the three supporting reports align with the three of the four topics OPG was directed to address under the broad heading of study of alternate locations ; OPG s address of the fourth topic, the detailing of thresholds for what is considered to be technically and economically feasible, is included in a limited way in the report describing alternate locations. Actual Locations vs. Geologic Regions Ontario Power Generation was required to undertake a study of alternate locations with specific reference to actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility. First and foremost, Ontario Power Generation did not undertake a study of actual locations, and does not provide studies or even basic descriptions - in reference to actual locations. Rather than actual locations, Ontario Power Generation provided very general descriptions of two large geologic regions 3. In the case of the Crystalline Alternate location more commonly referred to as the Canadian Shield the result is a 726,052-square-kilometre land mass covering roughly 73 per cent of the province 4. While OPG persistently uses the word location as if interchangeable with the word region, such wordplay does not transform an area larger than France into an actual location. NORTHWATCH 6

8 In addition to the map of geologic regions titled The Crystalline and Sedimentary Alternate Locations, OPG provided a listing of fourteen GPS coordinates for the Crystalline Alternate Location and seven GPS coordinates in the Sedimentary Alternate Location, presented in Tables 2-1 and 2-2 respectively, as found in the OPG document titled Description of Alternate Locations. The listing for locations in crystalline rock was subsequently amended through an errata filed by OPG on January 13, The Minister of the Environment and Climate Change was quite clear in her request of 18 February 2016 that the study requested was to detail the environmental effects of technically and economically feasible alternate locations for the project, with specific reference to actual locations that would meet Ontario Power Generation s criteria for technically and economically feasible. NORTHWATCH 7

9 In her letter of February 18, 2016 the federal Minister of the Environment and Climate Change directed Ontario Power Generation to conduct A study that details the environmental effects of technically and economically feasible alternate locations for the project, with specific reference to actual locations that would meet Ontario Power Generation s criteria for technically and economically feasible. In September 2016 the Agency responded to Ontario Power Generations proposal of April 2016 that for their response OPG would assess the environmental effects of two technically and economically feasible geologic regions in Ontario (rather than actual locations). The Agency clarified that while Ontario Power Generation has indicated that it intends to provide an assessment of the environmental effects of two technically and economically feasible geologic regions in Ontario, specifically in a sedimentary rock formation in southern Ontario and in a granite rock formation located in central to northern Ontario, without providing specific reference to actual locations, this was not consistent with the Minister s direction. The Agency provided this clarification by: - Indicating that the Agency was already aware of previous assessments that OPG had provided to the Joint Review Panel, and was aware that in previous assessments OPG had taken a regional level or generic approach (rather than using actual locations) - Noting that Ontario Power Generation assumed that the alternate sites would have similar geographical and hydrological characteristics as the preferred site in previous assessments and discouraging a repeat of that approach, including by requesting that the analysis of the environmental effects of the alternate locations to be provided by Ontario Power Generation provide a narrative assessment that does not assume that alternate sites in the geologic formation would have the same geographical and hydrological characteristics of the preferred site. - Reiterating that what was being requested was an analysis of the environmental effects of alternate locations. The Agency was clear in its response: it discouraged a repeat of OPG s early approach, and it described what was required using the terms alternate locations and alternate sites and stated clearly and directly that the Agency requests that the analysis of the environmental effects of the alternate locations to be provided by Ontario Power Generation provide a narrative assessment that does not assume that alternate sites in the geologic formation would have the same geographical and hydrological characteristics of the preferred site. Further, the Agency emphasized in their letter that in responding to all three elements of the Minister's request, Ontario Power Generation must ensure that the information submitted in its response does not replicate what is already on the record of the review. As a final point, the Agency would not simply not have had the authority to substitute the Minister s requirement that OPG provide information on alternate locations with OPG s preference that their reports describe geologic regions, even if that had been the Agency s inclination. Despite the Agency having provided this clarification, Ontario Power claimed in their Main submission that the Agency raised no objection to OPG s approach (i.e. of providing NORTHWATCH 8

10 information on geologic regions versus the actual locations, as the Minister had required) and further argued that the Agency did provide further clarifications regarding the alternate locations study, including a clarification indicating that the study could be based on geologic regions. 6 This is sophistry, at best. That OPG could misread the Minister s direction and the Agency s clarification is difficult to believe. That OPG would then make these bold and unfounded claims that the Agency actually concurred with their wrong interpretation is simply mischief, at best. Frivolous and vexatious are other fitting descriptors of this OPG feint. NORTHWATCH 9

11 Description of Alternate Locations Ontario Power Generation provides their purported description of alternate locations in Section 4 of the Main Submission and in the document titled Description of Alternate Locations. 7 Given that Section 4 of the Main Submission is simply a summary of the latter document, Northwatch s review will focus primarily on the document titled Description of Alternate Locations. 8 Section 2 of that document which presents OPG s proposed criteria for technically and economically feasible alternate locations is discussed under separate heading later in this submission. Ontario Power Generation has in effect proposed to substitute the required description of alternate locations with a generic description of geologic regions, despite the Agency s clarification of the Minister s direction and in disregard for the very different meaning of the term location and region. According to the Oxford dictionary, the word location has its origin in the late 16th century, and is a derivative from Latin verb locare and is defined as A particular place or position. Synonyms include: position, place, situation, site, locality, locale, spot, whereabouts, point, placement. By using the adjective actual the word meaning existing or real - the Minister emphasized that she was requiring OPG to describe a defined and specific potential site for the carrying out of OPG s project. In contrast, using the same dictionary, the term geological is defined as Relating to the study of the earth's physical structure and substance and the term region is defined as An area, especially part of a country or the world having definable characteristics but not always fixed boundaries. 9 Clearly, the terms actual locations and geologic regions have very different meanings. Equally clearly, the descriptions provided by Ontario Power Generation are very generalized descriptions of two very large geologic regions, at best. Ontario Power Generation does not describe actual or specific locations, as they were required to do. Nor do they provide detailed descriptions of the geologic regions. Also excluded from their report are any descriptions of the actual locations found at any of the 21 sets of coordinates provided in Table 2-1 and 2-2 included in Section 2.3 which OPG titled as being a discussion of economic feasibility. General versus hypothetical geological descriptions Section 3 of the Description of Alternate Locations report begins by introducing a representative surface area of approximately 176 square kilometres which it describes as having been developed as a reference area for a Canadian Shield setting for a used fuel DGR [NWMO 2012]. It is important to note that this borrowed description of a representative surface area is not a description of an actual area, but of a hypothetical one, described as being 5734 km2 10 in size and comprised of a composite of potential features of a site located in crystalline rock. A hypothetical geosphere was derived, in part, from historic experience gained in the Canadian Nuclear Fuel Waste Management Program. It was developed for the purpose of this illustrative case study. 11 NORTHWATCH 10

12 As noted in the description of the hypothetical site, a site s potential suitability for a deep geological repository relies on site-specific conditions, i.e. a hypothetical description cannot be used as a stand-in for information about actual locations. The geosphere will provide a geomechanically and geochemically stable environment. The ability of the geosphere to support these attributes will be dependent on site-specific conditions 12 The representative surface area described in OPG s Description of Alternate Locations relies on a hypothetical site description, which the NWMO describes as being of a site that could be encountered during site characterization, rather than a site which is an actual location. The purpose of this chapter is to describe the characteristics of a hypothetical crystalline site that could be encountered during geoscientific site characterization activities on the Canadian Shield. The description is provided in-lieu of geoscientific information that would be derived through site-specific surface and sub-surface investigations. 13 While Ontario Power Generation and the Nuclear Waste Management Organization are forwarding the notion that an actual site like the hypothetical site could have suitable characteristics, operational experience and research are establishing that it is more likely that any particular candidate location would not have suitable characteristics. For example, of the sixteen municipalities in the Canadian Shield region who entered into the Nuclear Waste Management Organization s Adaptive Phased Management process of investigating areas as possible locations for a deep geological repository for nuclear fuel waste, only six now remain in the process, the others having been discontinued for geoscientific reasons in the earliest phase of a preliminary assessment of potential suitability. 14 Section 4 of the OPG report provides a description in a sedimentary alternate location which similarly relies on the hypothetical geosphere developed by the Nuclear Waste Management Organization in their Adaptive Phased Management program to identify a candidate location for a deep geological repository for all of Canada s used nuclear fuel, and on information developed by OPG in support of their proposed deep geological repository for low and intermediate level operating wastes. 15 A hypothetical geosphere was derived, in part, from experience gained in the Canadian Nuclear Fuel Waste Management Program. It was developed for the purpose of this illustrative case study while the NWMO proceeds with the APM siting process and selection of a preferred site in an informed and willing host community. While the hypothetical site represents one example of a possible sedimentary rock setting in southern Ontario, other characteristics are considered in the safety assessment to illustrate an approach to assessing both long-term safety and the functionality of various barrier systems. 16 NORTHWATCH 11

13 The long-term safety and performance of a used fuel repository will rely in part on the geological setting that surrounds the repository. The geosphere will provide a geomechanically, hydrogeologically and geochemically stable environment. Geomechanical stability enables safe excavation and placement of the containers and engineered barrier system, and also, together with hydrogeological and geochemical stability, isolates the containers from a wide range of future human and natural events. A stable geochemical environment supports the container durability and minimizes contaminant mobility. The ability of the geosphere to support these attributes will be dependent on site-specific conditions. 17 The representative surface area described in OPG s Description of Alternate Locations relies on a hypothetical site description, which the NWMO describes as being of a site that could be encountered during site characterization, rather than a site which is an actual location. The purpose of this chapter is to describe the characteristics of a hypothetical sedimentary rock site that could be encountered during geoscientific site characterization activities on the margin of the Michigan Basin in southern Ontario. The description is provided in-lieu of geoscientific information that would be derived through site-specific surface and sub-surface investigations. 18 Further, Ontario Power Generation states that their description of alternate locations in sedimentary rock rely in part on information developed by OPG in support of their proposed deep geological repository for low and intermediate level operating wastes. 19 On this basis, Northwatch s technical expert Dr. GM Reeves undertook a summary review 20 of the site specific geoscientific information available as a result of OPG s investigations in support of their project to construct and operate a deep geologic repository for low and intermediate level radioactive wastes at the Bruce Nuclear site. Dr. Reeves finding was that the geoscientific investigations were inadequate to support the project as proposed, but also inadequate as an input into the subject report. Dr. Reeves observed that while OPG has published many reports and associated publications over a period of 16 years on the purported suitability of their Bruce Site as a suitable Deep Geologic Repository, the Bruce site has only been characterised in terms of geology, geotechnics and most importantly, hydrogeology, on the basis of investigations in six deep boreholes, drilled, logged and tested between 2006 and He notes that two of these boreholes were inclined and specifically targeted on particular features, and only 4 vertical boreholes (DG-1, DG-2, DG-3 and DG-4) have been drilled to investigate the deep rock, repository zone geological, geotechnical and hydrogeological environments, and Borehole DG-1 did not reach the proposed disposal depth of 680 metres, and only reached the upper section of the Queenston Formation. None of these boreholes are located outside the approximate four square kilometre Study Area site located in the centre of OPGs Bruce PS complex. Dr. Reeves concluded, therefore, that only a very limited (projected to DGR proposed depth) surface area, and very restricted volume of rock at that depth, have been NORTHWATCH 12

14 investigated by OPGs deep drilling program of 6 boreholes, into the Proposed Repository Horizon in the limestones of the Cobourg Formation at 680 metres depth below the Bruce NPP site. 21 Of specific note in considering the suitability of OPG s work in support of their preferred location at the Bruce nuclear site as an input to the required study of alternate locations, Dr. Reeves noted that no far-field (or even outer near field ) boreholes have been specifically drilled for in the course of OPG s investigations. Therefore any large scale groundwater modelling for the Bruce site, which could investigate the potential flow of deep connate groundwater eastwards towards the outcrop of the Cobourg Formation some 86 kilometres to the East on the southern shores of Georgian Bay, cannot have been realistically undertaken by OPG. 22 On this basis, it would be unreasonable to consider that the previous OPG investigations provide a basis from which a description of an alternate site could be extrapolated given that a) the investigations were inadequate and b) the information were it available would be site specific, and so not applicable to an alternate location which was an actual location, as required by the Minister for the purpose of the subject report. Descriptions of Geological Regions The description of alternate locations fail to respond to the requirements issued by the Minister of the Environment and Climate Change in February 2016 in that the OPG report provides a very generalized description of geological regions based on a set of hypothetical sites described for other purposes. In addition, the report fails even as a description of geological regions. The descriptions are completely inadequate for any relative comparisons of suitability, as little or no ground control nor any comparable detailed geological, geotechnical, hydrological or hydrogeological data is presented in OPGs Study of Alternative Locations reports. Northwatch s technical reviewer, Dr. G.M. Reeves, noted that the complete lack of reference to any of AECL (Atomic Energy of Canada) Research Company s 1975 to 1996 Research Area Program (carried out in conjunction with the Geological Survey of Canada, and the Earth Physics Branch of Energy, Mines and Resources, Canada) further undermines both the credibility and thoroughness of OPG s present review, in that it did not make use of the large volumes of information already available. Dr. Reeves noted in his report that a number of crystalline rock locations, (which were investigated and reported in great detail, as part of the 20 plus year program of AECL Research Company in the last three decades of the past Century), could readily have been compared with the Bruce Site investigations carried out from 2006 to 2010 by OPG. Dr. Reeves also challenged the assertion, endorsed by OPGs Panel of Experts in their supporting report, that crystalline rock locations are likely to be more fractured at depth than deep sedimentary environments, and consequently will be more costly locations to develop as a DGR, finding that it was unsupported by any geological, geotechnical or hydrogeological data from any actual investigations at depth at any of the proposed Alternative Locations. NORTHWATCH 13

15 Northwatch notes that there is a large volume of information about Ontario s geology, geophysics and geoscience available even through publicly accessible on-line resources. Such resources are sufficient for even a hobby geologist to develop a more detailed understanding and description of Ontario s geology than OPG has provided, despite OPG taking ten months and having unlimited resources to complete their study. Northwatch has listed a selection of such online resources in Appendix 3. Figure 1: OGS Earth Screen Shot of Data Layer Depicting Bedrock Geology Comparison to Accepted Approaches to DGR Location Characterisation As described in more detail in his full report in Appendix 1, at Northwatch s request Dr. Reeves provided an outline of the international practice in terms of information required in the characterization of a potential location for a deep geological repository for radioactive wastes. The remainder of this subsection summarizes Dr. Reeves response: In comparable studies elsewhere in the world 23 for deep geologic repositories and/or underground research laboratories, extensive targeted surface geophysical surveys, (usually but not exclusively seismic surveys) are normally carried out, tied in by an array of preliminary deep boreholes (typically tens of boreholes through which the geophysical results are refined and controlled, providing accuracy of interpretation). More drilling is then informed by the above First Phase exploration, providing an improved network of characterised ground, to and usually beyond the proposed repository depth. Coverage is often in the tens, sometimes approaching hundreds of square kilometres around the proposed repository site. 24 Information as to the variability of rock type (igneous, metamorphic or sedimentary), material properties, competence, bedding, geological structure and solubility/effects of NORTHWATCH 14

16 past weathering and alteration, are normally all targeted over a substantial area, relative to the DGR footprint and the Potential Repository Zone (PRZ), area by an extensive borehole drilling program and comprehensive geophysical surveying campaign. Penetrative investigations (ie. Borehole drilling) away from the immediate PRZ area also has the benefit of providing geologic, geotechnical and hydrogeologic data from the lithologies at the proposed depths of the DGR/URL, without providing potential for disturbance, unnecessary penetration, leakage pathways, and hence compromising the integrity of the facility unnecessarily by near-field activities. After an understanding of the geologic variability of either crystalline or sedimentary terraines around, under and some distance (tens of kilometres, normally) from any proposed DGR or URL, a program of detailed hydrogeologic testing is normally carried out in each borehole. There are usually tens of such suitable boreholes available for such testing. They are normally located both in the Potential Repository Zone (PRZ), and at distances of kilometres, and commonly tens of kilometres distance from the PRZ. Such testing work shows how, and to what extent hydrogeologic conditions (ie. Permeability, porosity, groundwater chemistry etc.) varies away from the PRZ area. On a wider scale, hydrological and hydrogeologic studies help to identify recharge and (most importantly) discharge areas, on a catchment and sub-catchment scale, whilst also providing real field data for long term hydrogeologic modelling for the near and far-field conditions affecting the DGR/URL and its environments. In both crystalline and sedimentary environments, a good understanding of the geochemistry, development and potential for movement of connate (ie. Deep) groundwater regimes affecting both the near-field and far-field conditions relevant to the PRZ at depth is also required. 25 These data are also invaluable for long-term hydrogeologic modelling for both far- and near-field predictions of disturbed groundwater conditions and flow, as well as in improving the understanding of relevant hydrogeologic conditions affecting the proposed site. Coordinates of Crystalline and Sedimentary Alternate Locations As noted above, as one element of Ontario Power Generation s attempted substitution of geologic regions for actual locations, OPG closes their arguments in the Main Submission over the Minister s requirements by writing that for clarification OPG is providing in this report and in the Description of Alternate Locations [OPG 2016b] technical document, specific references to actual locations 26 and provides a list of coordinates for 14 crystalline locations and seven sedimentary locations in the document titled Description of Alternate Locations. 27 Generic Approach of OPG in identifying Alternate Locations. The Alternate Locations of OPG in their December 2016 reports, in response to the Minister s requirements, covers virtually the whole of Ontario. NORTHWATCH 15

17 Sites seem to have been selected, in both crystalline and sedimentary geologic terrains, based on Maximum distances from Bruce NPP Site (ie. Near to Provincial borders, in one case beyond such a border) rather than on geologic or hydrogeologic suitability or hard data from such sources. Figure 2- Figure from OPG Main Submission depicting Alternate Locations The study carried out by OPG, and its consultants in 2016, at the request of The Minister into alternate sedimentary and crystalline rock locations is highly unusual, in terms of geological study. OPG appears to have used almost a scatter gun approach to the siting of the alternate locations that they were requested to consider by the Federal Minister of Environment and Climate Change, Hon. Catherine McKenna in her letter to the VP of OPG of 18 February Despite identifying 21 locations (14 in crystalline rock terraines, and 7 alternative sedimentary sites), no maps, geological or otherwise are included in this report and supporting documents. It is therefore evident that OPG have not complied with the Minister s request that OPG prepare A study that details the environmental effects of technically and economically feasible locations for the Project, with specific reference to actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility. NORTHWATCH 16

18 The 21 Alternative Locations identified by OPG and labelled, annotated and plotted by Northwatch, are shown in the table and plan, below, and are not investigated further detail herein, due to the total lack of any detailed site-specific geologic information provided by OPG for these sites. Figure 2 - The 21 Alternate Locations of OPG, plotted by Northwatch using Google Map NORTHWATCH 17

19 ID# Geologic region Longitude Latitude Location Name C-1 Crystalline Honey Harbour North C-2 Crystalline Collins Inlet, East Killarnay C-3 Crystalline Sault Ste. Marie C-4 Crystalline Neys C-5 Crystalline Thunder Bay / Pigeon River C-6 Crystalline Shoal Lake C-7 Crystalline Pauingassi C-8 Crystalline Pasquatchai C-9 Crystalline Winisk C-10 Crystalline Jog Lake C-11 Crystalline Kesagami C-12 Crystalline Lorraine Valley C-13 Crystalline Pakenham C-14 Crystalline Frontenac S-1 Sedimentary Collingwood S-2 Sedimentary Midtown Toronto S-3 Sedimentary Burlington Skyway S-4 Sedimentary Niagara S-5 Sedimentary Fort Erie / Stonemill Road S-6 Sedimentary Lake Erie / Grosse Isle S-7 Sedimentary Sauble Beach, offshore Notes: - ID numbers are assigned by Northwatch, based on the order of sites as listed by Ontario Power Generation - Source for Crystalline site locations is CEAR#2902, OPG Errata, Att. 2 - Source for Sedimentary site locations is Table 2-2, OPG Description of Alternate Locations, posted as one of seven documents in CEAR# Location names are assigned by Northwatch, based on proximate location - Map was generated by inputting OPG provided co-ordinates into Google maps Table 1- The Alternate Sites of OPG- December 2016 NORTHWATCH 18

20 Discussion: The 21 Alternate Locations The seven sedimentary, and 14 crystalline/basement rock locations are given scant detailed examination in any of OPGs recent reports on the Alternate Locations. These locations can be examined using the Ontario Geological Survey Geological Database mapping (OGSEarth, based on Google Earth satellite imagery and mapping.) Such geologic information on any of the 21 alternate locations has not been included in OPGs Alternate Locations Reports. Neither has any borehole data been included, nor geotechnical or hydrogeologic information for the 21 sites. It is probable that no such information, either on open file or confidentially classified, exists for these sites. Furthermore, only Sedimentary and Crystalline alternative locations are discussed. Evaporitic deposits in Ontario, such as are located in the Windsor area, have not been considered by OPG or their consultants. Such lithologies have been proposed, investigated and put into commission as DGRs at both the WIPP site in New Mexico, USA, and at the Asse Salt mine in Northern Germany. It is relevant to note that this limitation is not placed upon OPG by The Minister s Requirement letter of February 18 th Geotechnical Characterisation of any of these, often remote, Ontario locations would be expensive and time-consuming, as was demonstrated during AECL s NFWMRP Research Area program from 1975 to No consideration has been given to any specific hydrogeological studies of the 21 locations or their recharge areas and discharge areas. The appearance of Connate waters, ie. Saline water emerging at surface from depth, is a wellknown feature of some locations throughout the Canadian Shield. These sites are colloquially known as natural Moose Licks, and often quite deep in the bush, and are quite different from the highway locations where road salt attracts wild moose. Such features have been reported near Lake Nipigon and Thunder Bay, amongst other locations on the Canadian Shield. (Frappe et al; 1984;1987) In addition, there has been no assessment of geological structure, igneous competence, sedimentary bedding, or tectonic structure for any of the Alternate Locations. NORTHWATCH 19

21 Environmental Effects of Alternate Locations In February 2016, the federal Minister of the Environment and Climate Change directed Ontario Power Generation to produce a study that details the environmental effects of technically and economically feasible alternate locations for the Project The December 28 th 2016 filing by OPG does not conform to this request, for a number of reasons, including but not limited to the following: - The study is not of actual locations, as requested, but of very generalized descriptions of two large areas or regions - The description of environmental effects are, subsequently, also very generalized - In the absence of an actual set of technical and economic criteria, had Ontario Power Generation identified any actual locations the review would have then been limited by the inability to determine the feasibility of the identified location(s) given the absence of any actual criteria for determining its feasibility Ontario Power Generation provided a sixty-two page report which identifies only extremely high level listing of valued components of the environment; in effect, these are components that would be present in every possible assessment of any project. 28 OPG then proceeds to discuss in the most general way possible potential general effects on a generic or hypothetical environment. After a brief introduction, the substance of the report begins by referencing the updated CEAA Operational Policy Addressing Purpose of and Alternative Means under the Canadian Environmental Assessment Act, 2012, indicating that the authors were aware of this guidance. However, the report fails to meet this guidance, on a number of counts. As set out in the policy statement, 29 Alternative means includes the various technically and economically feasible ways under consideration by the proponent the alternative means include options for locations, development and/or implementation methods, routes, designs, technologies, mitigation measures, etc. As per the Minister s direction of February 2016, in this instance the examination of alternatives means was to focus on alternative locations. The policy sets out a number of considerations to be applied and steps to be followed. OPG s failure to follow these steps in most respects traces back to an underlying issue: an analysis of alternate locations cannot be undertaken in the absence of any actual locations. The following points illustrate areas of weaknesses and / or failings of the report: - The identified valued components in Table are overly general - The report appears to be more the product of some brainstorming sessions, stream-ofconsciousness thinking and hearsay reports than to be a product of actual scientific or social research; for example, the set of bullets at the top of page 5 identify potential socio-economic factors that are so general as to be uninformative, and which are unsupported with any research or evidence Table 3-1 Basis for the Effects Assessment of the DGR at alternate locations conveys that the only difference in effects between the preferred site beneath the Bruce nuclear site and any other NORTHWATCH 20

22 location in the two extremely large regions identified by OPG as alternate locations are a) site selection and licensing; duplicating general conditions already present at the Bruce site or any other industrial site including fences, monitoring, and road and power access; security and storage, and transportation and packaging. The only indicator that there are different physical characteristics of particular sites that would be a factor is the bullet at the bottom of Page 9 indicating that backfilling of some rooms with cement if necessary (depends on host rock conditions at alternate locations), and even this bullet messages that any site will do, any rock will do, so any location will do. Reflecting on the large volume of materials OPG prepared, filed and presented in the 2013 and 2014 hearings with respect to specific site conditions and characteristics, this argument that any location will do, coupled with the failure / refusal to identify any locations, is an interesting approach on the part of OPG. The report makes numerous unsupported statements and assumptions, for which no supporting evidence of studies are provided. In just a few pages of the report, this sort of statement included but was not limited to the following: That the sedimentary alternate location is assumed to be in a Class 3 (Rural) area in accordance with MOECC guidelines [MOECC 2016]. The proximity of the closest receptor (e.g., residences) is assumed that the closest receptor would be approximately 1 km from the DGR activities [OPG 2016] Transportation between the WWMF and alternate location would largely be along existing roads with existing truck traffic Localized noise level changes are therefore not likely to be measurable. Overall effects on noise levels are likely to be greater at the DGR at the sedimentary alternate location, predominantly as a result of lower background noise levels For the sedimentary alternate location, the waste rock pile is assumed to be similar in size and composition as the DGR Project at the Bruce Nuclear site The DGR at the sedimentary alternate location is located in southern Ontario. Most of the land is developed for livestock and cash crop farming, The DGR at the sedimentary alternate location is located in southern Ontario. Most of the land is developed for livestock and cash crop farming, with areas not developed for agriculture generally either forested or consisting of small rural communities. For the sedimentary alternate location, the waste rock pile is assumed to be similar in size and composition as the DGR Project at the Bruce Nuclear site and that any runoff would be treated for suspended solids as a minimum. The above noted unsupported statements and assumptions are presented not because of any singular importance of any one of these assumptions although each have the potential to misrepresent reality in a way that could impede a legitimate evaluation being done but because this quality of statement is representative of the document itself. More significant are the unsupported assumptions that the distance from the WWMF to an alternate location in southern Ontario would be 100 to 300 km and in northern Ontario would be 200 to 2000 km. These assumptions are discussed in the next section. NORTHWATCH 21

23 Also significant is that there is no discussion of transportation from Pickering and Darlington nuclear generating stations to the Western Waste Management Facility, or any consideration of wastes being shipped directly from Pickering or Darlington dto an alternate location and how having multiple stations as direct waste sources (rather than the waste from Pickering and Darlington first being diverted to the WWMF). Interestingly, while the document seeks to convince that the entire regions of southern (sedimentary) and northern (crystalline) Ontario are alternate locations, i.e. that any actual location in these large regions are is an alternative location, it simultaneously supposes that location will be likely agricultural 30 in southern Ontario and likely forest 31 and would require construction of up to 20 km of new access road, and up to a 50 km power corridor 32 in northern Ontario, rather than a brownfield site or former industrial or mining lands. Yet the document provides no single reason why a brownfield site would not be appropriate, at minimum, or prioritized. NORTHWATCH 22

24 Criteria for Technical and Economic Feasibility In her letter of February 2016 the federal Minister of the Environment and Climate Change directed Ontario Power Generation to prepare report on alternative actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility and to detail the thresholds for what is considered to be technically and economically feasible. The December 28 th 2016 filing by OPG does not conform to the requirements of the Minister s letter or of the Canadian Environmental Assessment Agency s Operational Policy Statement: Addressing Purpose of and Alternative Means under the Canadian Environmental Assessment Act, for a number of reasons, including but not limited to the following: - The criteria for technically feasible 34 is so extremely vague and general that it is of no meaning in terms of demonstrating that an alternate location had Ontario Power Generation identified one met a - The criteria for economically feasible 35 is also without basis; in effect, what OPG sets out as economic criteria is the notion that there is no cost threshold for the Project - The application of meaningless criteria to a massive area instead of assessing actual locations using substantive criteria has produced a set of reports which fail to meet the direction of February 2016 While OPG could have put forward an argument that they should be meeting CEAA s 2007 Operational Policy Statement Addressing Need for, Purpose of, Alternatives to and Alternative Means under the Canadian Environmental Assessment Act given that these reports are filling gaps in their 2011 Environmental Impact Statement rather than an EA started under CEAA 2012, OPG makes a clear statement that their approach was as set out in the updated 2015 policy statement. 36 Northwatch s review was undertaken on that basis. The 2015 Operational Policy Statement provides direction for the development and application of criteria for technical and economic feasibility, setting out a number of steps, which OPG has summarized, while omitting even reference to what is to be undertaken within each of these steps. Step 1 relates most closely to the specific direction from the Minister to prepare a report on alternative actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility and to detail the thresholds for what is considered to be technically and economically feasible. In contrast to the specific directions provided, in their December 2016 report OPG sets out their criteria for technically and economically feasible alternate locations which is extremely generic, and through which application it is possible that no location in Ontario with the exception of some portion of the James Bay lowland would not meet the criteria. This does not meet the direction of either the Minister s requirement for additional information or CEAA s 2015 Operational Policy Statement. Similarly, OPG s purported thresholds 37 are extremely broad and would contribute little to the evaluation of any actual location. NORTHWATCH 23

25 Step 1: Identify technically and economically feasible alternative means To identify and describe the technically and economically feasible alternative means to carry out the designated project, the proponent should: Develop criteria to determine the technical and economic feasibility of the alternative means. Examples of technical criteria could include use of energy, mode of operation, performance, supporting infrastructure, schedule and risks. Examples of economic criteria could consist of a comparison of cost estimation and forecasted revenues. Identify and describe the alternative means from the proponent's perspective. The description of the alternative means must be in sufficient detail to establish how to assess them relative to the criteria developed for determining their technical and economic feasibility, as well as to support the analysis described in Steps 2 to 4. Establish which of these alternative means are technically and economically feasible. A qualitative approach may be used to establish how the alternative means relates to the criteria, based on evidence and professional judgment. Thresholds or other quantitative decision-making tools may also be used, when available and relevant for specific criteria. Document the rationale for the alternative means retained for consideration in the project EA. The rationale must provide sufficient detail for an independent reviewer to assess the criteria developed, the nature of the alternative means considered, the approach taken to assess these alternative means against the criteria, and the alternative means retained for further analysis in Step 2. Table 2: Excerpted from CEAA Operational Policy Statement 2015 Technical Feasibility Criteria and Thresholds Ontario Power Generation introduces their presentation of technical feasibility with a broad definition of the objective of the technical feasibility, i.e. that any selected location must support the safe construction, operation and post-closure performance of the DGR without harm to the public, workers or the environment noting that this safety is achieved by a combination of the physical features of the site, the design and the wastes, and by how the facility is constructed, operated and monitored. Northwatch does not dispute this very summary description of the objectives of the technical feasibility criteria. However, the technical feasibility criteria is inadequate to the task of contributing to that objective. OPG s identified the following technical feasibility criteria for a DGR: 1. Is the host rock geologically stable and resistant to expected geological and climate change processes? 2. Is the depth and thickness of competent rock sufficient to host and enclose a DGR? 38 followed by the statement that These criteria reflect the basic requirement of a DGR to provide long-term containment and isolation of the wastes. NORTHWATCH 24

26 OPG S presented technical thresholds are somewhat more detailed than their criteria, but insufficiently so. The thresholds are presented as follows: With respect to geological stability, the requirement should be that the rock has been stable for times that are long compared to the lifetime of the main hazard in the L&ILW, and that have been resilient to past glacial and seismic events. While much of the radioactivity in the L&ILW will decay within about 100,000 years, the OPG DGR safety assessment considered time frames of 1 million years. Therefore for demonstrated geologic stability, the bedrock should be much older than this. For context, in Ontario, the crystalline rock of the Canadian Shield at more than 1 billion years old, and the sedimentary rock formations of southern Ontario at 354 to 543 million years old, readily satisfy this criterion. With respect to depth and volume, the thresholds adopted in the present study are a minimum of 200-m depth and 300-m bedrock thickness. These consider the nature of the hazard of the L&ILW, and in particular that it contains long-lived ILW. Therefore, consistent with international practice, such wastes are planned for disposal in deeper rock formations. The minimum depth of 200-m is consistent with remaining below the extent of shallow groundwater regimes. A minimum rock thickness of 300-m allows for at least a 100-m layer of competent bedrock to lie above and below the repository to ensure that it is fully enclosed. 39 The problems with OPG s offered technical feasibility criteria and threshold are threefold: - They are overly generic, and provide little to no meaningful information about which sites within the large regions identified could be actual candidates for consideration - They are not specific to the challenge of isolating radioactive wastes from the environment in that they do not speak to the properties required of a host geology - In identifying two large regions as substitutes for actual locations, OPG has positioned themselves such that the technical feasibility criteria and threshold must be applicable to the entire region/location, or the region/location is disqualified. With respect to the third point, even the very generic technical feasibility criteria and threshold, when applied to either of the region/locations identified by Ontario Power Generation cannot be met, in that, for example: - There are areas of seismic activity within both the identified region/locations - OPG s equating of geological age with geological stability is unfounded; these two characteristics are not interchangeable - There are numerous areas that do not have a minimum of 200-m depth - There are numerous areas which do not have a 300-m bedrock thickness. - Shallow groundwater regimes are not consistently contained above a 200 meter depth Some of the failings of the OPG reports are circular, i.e. in not following the directions to identify actual locations, OPG has created a circumstance in which it will be extremely difficult to put forward anything more substantive than very generic feasibility criteria and thresholds, but even quite generic feasibility criteria and thresholds will not be met by all locations / areas within the very large regions that OPG has sought to use as substitutes for actual locations. NORTHWATCH 25

27 While Canada does not at present have standards or regulations which set out technical criteria or thresholds for the evaluation of deep geologic repositories 40, the onus was on the OPG to develop and present in their reports criteria to determine the technical and economic feasibility of the alternative that was sufficiently detailed and supported. While it is not Northwatch s responsibility or intention to draft such criteria and thresholds on OPG s behalf, the following elements are examples of what could have been included: - Geomechanical stability - geochemical stabililty - hydraulic conductivity - distance between the repository and an assumed transmissive fracture(s) - geosphere sorption rates - porosity - hydrogeologic conditions 41 - permeability - Intensity and distribution of fracture systems 42 - Position relative to predicted future glacial unloading 43 At minimum, OPG should have fashioned criteria and thresholds releative to the features of their preferred site: - soil quality, which includes the characterization of soil as defined by chemical and - physical analysis; - overburden geology, which includes the unconsolidated materials underlying the study - area; and - bedrock geology, which includes the sedimentary and crystalline bedrock formations - underlying the study area; - hydrogeology, which includes groundwater zones, environmental heads and - conductivity, porosity, fluid density and hydrogeological modelling; - hydrogeochemistry, which includes regional scale characterization, spatial distribution - of water, origin of brines, as well as groundwater and pore water compositions; - geomechanics, which includes geomechanical properties, in-site stress and orientation; and - regional seismicity, which includes earthquake magnitudes and seismic potential. As Dr. Reeves notes in his review undertaken on Northwatch s behalf of OPG s Description of Alternate Sites (see Appendix 1), evaluation of candidate areas for deep geological repositories use as initial criteria information gathered through geophysical surveys, (usually but not exclusively seismic surveys) followed by sub-surface investigations. Information as to the variability of rock type (igneous, metamorphic or sedimentary), material properties, competence, bedding, geological structure and solubility/effects of past weathering and alteration is collected, as is information in the surrounding area providing geologic, geotechnical and hydrogeologic data from the lithologies at the proposed depths of the DGR/URL. This information is all of central importance to determining the feasibility of an actual location and its potential to be investigated further as a site for a deep geological repository. OPG s technical feasibility and thresholds do not incorporate any of these factors. NORTHWATCH 26

28 Ontario Power Generation closes its discussion of technical feasibility and thresholds with a statement that In subsequent sections, two alternate locations in Ontario are identified that satisfy the above technical feasibility thresholds, one in crystalline rock and one in sedimentary rock. In fact, with the exception of making very generalized statements at the regional scale, the technical feasibility and thresholds are not discussed further. Criteria for Economic Feasibility and Thresholds Apparently, cost is simply not a factor for Ontario Power Generation; if they can find the money, they will spend it. In Section 2.2 of their report describing alternate locations, Ontario Power Generation writes that OPG s has therefore identified the following economic feasibility criterion for a DGR as being OPG s ability to finance the cost of a DGR at the alternate location. OPG s offering of an economic threshold travels a very short distance from this uninformative statement to arrive at the following: The threshold for the economic feasibility criterion is whether OPG reasonably expects to be able to finance the cost from internal resources, or through debt financing, or a combination of the two. 44 OPG then proceeds in Sections 2.3 and 2.4 to argue that because OPG reasonably expects to be able to finance the cost of a DGR at each of the crystalline alternate location and the sedimentary alternate locations through one of the mechanisms, if required then the economic feasibility criterion and threshold are satisfied. What OPG provided is an unsupported claim that they have the means to finance including through debt financing a repository at an location, under any conditions, and at any cost. It is difficult to image what portion of this non-response required ten months to prepare. While this notable failure or refusal to respond to the direction from the Minister and the requirements set out in the Operational Policy Statement to describe economic criteria and thresholds and then apply them to an actual alternate location has been the cause of some hilarity among reviewers, it is of limited to no usefulness beyond that. NORTHWATCH 27

29 Incremental Costs and Risks for Off-site Transportation As an addition to the requirement to prepare a study that detailed the environmental effects of technically and economically feasible alternate locations, Ontario Power Generation was also required to indicate what the incremental costs and risks would be for additional off-site transportation of the nuclear waste. OPG s response to this requirement was to hire Energy Solutions to prepare an 84 page report which ES titled Cost and Risk Esimate for Packaging and Transporting Waste to Alternate Locations. 45 As part of Northwatch s general review the OPG response to this requirement was evaluated. In addition to the technical review summarized below and found in full in Appendix 2, Northwatch makes the following more general observations: - The report discloses that EnergySolutions applied their own operatioal experience, and describes that experience in a manner that might leave an impression that this consultants experience is Ontario based, or even Canadian based; as self-described on their web site, EnergySolutions is an international nuclear services company headquartered in Salt Lake City with operations across the United States, Canada, the United Kingdom and other countries around the world ; several large and well known projects are described on this proponent s web site, albeit no Canadian projects; the selection of this proponent as consultant to OPG raises concerns about conflict of interest and bias - the report provides no basis for the selection of 100 and 300 km distances for locations in sedimentary region and 200 and 2000 for crystalline region, other than a very general reference to the 300 km and 2000 km being the farthest distance possible by road in those regions - the report is wholly unclear as to whether it intends or considered direct transfer of wastes from Darlington to an alternate-location repository; all discussion is with respect to retrieving wastes already stored at the WWMF, with no address to wastes generated in the future which are not yet at the WWMF - similar to other reports filed by OPG in December 2016, certain failings of this report may be unavoidable in the absense of OPG having identified actual locations - Energy Solutions assumes a population density of two people per km 46, but provides no reference or supporting evidence, and on its face it does not appear to be credible; Northwatch notes that the population density for Bruce County, where the Bruce Nuclear Site is located, which in 2016 was 16.2 per km2; other counties it would pass through to get to a location in a crystalline rock formation, for example, would be Gray County (20.5) and Simcoe County (59.2) 47 and suggests that population density per km along major roadways would be similar or higher - Northwatch welcomes Ontario Power Generation s recognition of the radiation hazards associated with the transportation of low and intermediate level wastes; in past environmental assessment reviews, such as for Ontario Power Generation s proposal to build up to four new reactors at the Darlington Nuclear Generating Station with an intent to ship all low and intermediate level radioactive wastes to the Western Waste Management Facility at the Bruce nuclear site there was no discussion of radiological hazards or risks of exposure for workers or those along the transportation route 48 NORTHWATCH 28

30 Northwatch retained Dr. Fred Dilger to undertake a technical review of the Energy Solutions document titled Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations and to report to Northwatch on the degree to which he found OPG s consultants work to be based on realistic assumptions as well as commenting on its overall usefulness to the Agency, the Minister, and public review participants. Dr. Dilger s report is found in full in Appendix 2. His key findings are summarized in this section of Northwatch s general submission. Dr. Dilger described the Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations (CREPT) report as a generic risk assessment and a high-level cost assessment of shipments from a waste management facility at the Bruce Nuclear Generating Plant to a hypothetical Deep Geologic Repository (DGR) at an unspecified location. The report provides a generic risk assessment and a high-level cost assessment of the shipping program. His review considered the contents of the CREPT report by comparing it to the information requested by the Minister, it describes the proposed action, and then examines the risk assessment and cost assessment portions of the CREPT report. It critiqued the risk assessment and the cost appraisal portion of the CREPT report. Dr. Dilger s review of the CREPT report concluded that the methods used do not conform to best practices for the transportation risk assessment of radioactive materials. For example, the cost assessment is so narrow that its conclusions may be lead to significant underreporting of actual costs. The report uses a generic methodology to assess risks and costs. He noted that the Report Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations suffers from a problem common to many such estimates. The report assumes that radioactive materials transportation is straightforward and does not deserve a high degree of focused attention. The report does not provide specifics regarding routes, unique local conditions, response preparation, or coordination with local communities. While the report contains detailed information about equipment and personnel costs, it ignores the many other issues that will be associated with the shipment of these materials. Additional key points from this technical review included but are not limited to: - The report emphasizes success of other agencies activities, which is not the subject of evaluation - the report relied on references from Germany; the German program relies heavily on rail, and wastes are shipped short distances, while OPG s program assumes road transport by truck and potentially for long distances - the report focuses on the probability of an accident (low) rather than consequences (high) - the report was overly generic, with insufficient information; this could have been addressed by such measures as determining the maximum number of shipments and a maximum dose, or by assessing the effect to a Maximally Exposed Individual establish an upper boundary of the health effects, or by defining a maximum accident to establish an upper boundary on how severe an accident could be - the report does not provide sufficient detail to assess its validity; one example is that the CREPT report assumes a population density of two people per km but does not support NORTHWATCH 29

31 that assumption, and other publicly available data suggests much higher population densities - The report provides cost estimates only at the very high level, and they are flawed by the imprecision of the waste characterization - based on the information contained in the CREPT, the costs of the program are currently not known The conclusion of Northwatch s technical review was that the CREPT report does not provide a meaningful response to the Ministerial request for additional information, and that the CREPT report was prepared with insufficient methods, data and information. As a result, the CREPT report is of limited value. NORTHWATCH 30

32 6.2 Cumulative Effects As noted in Section 5, federal Minister of the Environmental and Climate Change required Ontario Power Generation to produce an updated analysis of the cumulative environmental effects of the Project in light of the results from the Phase I Preliminary Assessmetns undertaken by the Nuclear Waste Management Organization, which identified three potential host communities that fall within the traditional territory of the Saugeen Ojibway Nation. OPG summarizes the findings of their cumulative effects assessment as follows: The updated cumulative effects assessment of the APM DGR identified no likely adverse cumulative effects given the location of the potential site for the APM DGR and the limited extent of the environmental effects of the DGR Project at the Bruce Nuclear site and the APM DGR. Moreover, the updated assessment concluded that cumulative effects as a result of malfunctions, accidents and malevolent acts from the DGR Project at the Bruce Nuclear site and the APM DGR are unlikely. Since no adverse cumulative effects were identified, an assessment of significance of cumulative effects is not required. The original conclusions presented in the Environmental Impact Statement (EIS) regarding cumulative effects of the DGR Project at the Bruce Nuclear site and other projects and activities remain valid when the APM DGR is considered It appears that OPG is able to arrive at this conclusion by simply combining an unsupported conclusion that there will be no adverse effects from a deep geological repository for high level nuclear fuel waste with their earlier unverified conclusion that there will be no adverse effects from a deep geologic repository for low and intermediate level wastes to arrive at this unsupported and unverified conclusion that there will be no likely adverse cumulative effects. This conclusion is of little to no value. In addition to conveying these general observations Northwatch adopts the findings and conclusions of the evaluation of OPG s cumulative effects study prepared by Mr. John Jackson on behalf of SOS Great Lakes and commends them to the Agency and Minister. NORTHWATCH 31

33 6.3 Mitigation Commitments As noted earlier, in her direction of February 2016 the federal Minister of the Environmental and Climate Change also required Ontario Power Generation to produce an updated list of mitigation commitments for each identified advese effect under CEAA 2012, and directed Ontario Power Generation to identify out-dated or redundant commitments that were previously brought forward to the Panel. As expressed in earlier submissions, it is Northwatch s assessment that the proposed mitigation measures and potential conditions are insufficient in terms of remedying the larger uncertainties with respect to OPG s proposed DGR. Limited capacity, the level of detail demanded by the other reports in the OPG filing, and the short time allowed for public comment have restricted Northwatch s ability to do a comprehensive review of the Mitigation Measures Report We make the following comments as examples and for illustrative purposes: OPG s manner of grouping the updated mitigation measures is not helpful. For example, key concerns for Northwatch relate to the unfinished design of the DGR, including that design decisions have not yet been made with respect to the shaft, shaft lining and shaft collar; OPG placed MIT-H-08 which deals with the shaft liner and MIT- G-06 which deals with the shaft collar in the section on Groundwater; while the repository s failure will certainly impact groundwater so the grouping is understandable, it is not helpful, in that all the outstanding design issues should be grouped as such and clearly identified in that manner An additional example of the inappropriateness of the groupings by OPG is the placement the commitment that a waste characterization program will be implemented (MIT-R-19) under the Valued Component of Humans Similarly, the placing of MIT-R-21, committing that before an operating licence is issued OPG will develop and implement a detailed plan on how it would mitigate a scenario where intermediate-level waste containers fail in filled chambers while the DGR is still in operation; while this failure would certainly have a human impact, the commitment should be met as input to the EA review, and should be placed with other commitments related to waste, waste characterization, waste containers and waste packaging Having the same commitment appear repeatedly is confusing and unhelpful (e.g. MIT-H- 08 and MIT-G-06 repeating on Pages 11 and 12 and others) the proposed mitigation measures repeatedly hand EA decisions to the CNSC, rather than to a rightful decision-maker; should the Expert Panel reviewing environmental assessment processes make recommendations as anticipated to remove environmental assessments from the purview of the CNSC, the response of the Agency and the Minister to this document must be such that there is no grandfathering of the CNSC s role in EA; MIT-G-09 is one example NORTHWATCH 32

34 the commitment set out in MON-R-04, i.e. to enhance OPGs capability to detect and monitor the movement of the tritium plume originating from the Western Waste Management Facility should not be deferred until some time prior to shaft sinking as currently proposed; rather the comprehensive assessment of the migration of the tritium plume originating from the Western Waste Management Facility site referred to in MON- R-05 should have already commenced and reporting on its findings should be a precursor to any EA approval, should at some point in the future OPG ever satisfy the requirements of CEAA (noting that they have not to date) Commitments such as that in MON-R-05 to undertake basic research related to the design and the post-closure safety assessment for the proposed DGR, such as the commitment to augment the Geoscientific Verification Plan to provide additional gas generation modelling for the decommissioned DGR and to include modelling of gas generation from decommissioning waste (MON-R-05) is a commitment that should have been fulfilled during the EA development, with the information available to the EA decision-maker; the placement of it in a future time frame reporting to the CNSC is unacceptable In addition to conveying these general observations and providing specific examples, Northwatch adopts the findings and conclusions of the evaluation of OPG s update on mitigation measures as submitted by Anna Tilman and Eugene Bourgeois and commends them to the Agency and Minister. NORTHWATCH 33

35 7. Additional Issues 7.1 Conformity Review Further to the 3 January 2017 posting 49 on the Canadian Environmental Assessment Agency s public registry of the December 2016 reports by Ontario Power Generation, prepared in response to the Minister s February 2016 request for additional information, Northwatch wrote to the Minister of the Environment and Climate Change, the Honourable Catherine McKenna and to the president of the Canadian Environmental Assessment Agency, Mr. Ron Hallman, to provide input into the review process and the Agency s "Estimated Timeline for the Review " 50. In that letter we made submissions that the Conformity Review of OPG s response should include input from the public and Indigenous communities, among other matters. In the absence of a reply to those submissions Northwatch adhered to the deadline set for the federal departments to provide their comments on the conformity of the information filed by OPG and provided comments on the conformity of the OPG filing with the Minister s requirements on January 16, In summary, Northwatch commented that Ontario Power Generation has not provided the requested information. First and foremost, Northwatch noted that Ontario Power Generation does not provide studies of actual locations, or studies which are in reference to actual locations. Rather than actual locations, Ontario Power Generation provided very general descriptions of two large regions. Northwatch commented that the December 28 th 2016 filing by OPG does not conform to this request, for a number of reasons, including but not limited to the following: - The study is not of actual locations, as requested, but of very generalized descriptions of two large areas or regions - The description of environmental effects are, subsequently, also very generalized - The criteria for technically feasible 52 is so extremely vague and general that it is of no meaning in terms of demonstrating that an alternate location had Ontario Power Generation identified one met a - The criteria for economically feasible 53 is also without basis; in effect, what OPG sets out as economic criteria is the notion that there is no cost threshold for the Project - The application of meaningless criteria to a massive area instead of assessing actual locations using substantive criteria has produced a set of reports which fail to meet the direction of February 2016 Northwatch closed by commenting that, as expressed in an earlier letters from Nuclear Waste Watch and from Northwatch, it is imperative that the review pay careful attention to the details of Ontario Power Generation s response and place it within the context of OPG s pattern of nonconformance with both the requirements of the Canadian Environmental Assessment Act and the directions of the previous Joint Review Panel, and observed that the December 28 th filing by Ontario Power Generation very much follows this pattern on non-conformance. Northwatch was disappointed that the conformity review was conducted in a manner that NORTHWATCH 34

36 excluded public participation, both by failing to invite public comment and by setting an extremely short comment period. Northwatch was also disappointed in the very limited response from the federal departments during the conformity review, which ranged from no or nil comment to commenting that particular areas were beyond the expertise of the department. Several departments repeated the statement that OPG's response contains sufficient information to proceed to technical review. 7.2 Information Requests Northwatch and other public interest intervenors submitted information requests after an initial review of Ontario Power Generation s December 28 th 2016 filing of additional information. On January 17 th, Northwatch forwarded a table with ten information requests related to Ontario Power Generation s additional inforamtion to the Canadian Environmental Assessment Agency, and resubmitted them on February 18 th after a template for Information Requests was posted on the public registry, and Northwatch s table was reformatted to replicate the suggested template by adding a column to provide a rationale for each request. The information requested was necessary to Northwatch s review of the OPG filing, and to developing our analysis for submission during the public comment period. In response, on January 19 th, Northwatch received a template letter from the Canadian Environmental Assessment Agency, announcing the public comment period. No actual response was ever received. 54 On January 25, 2017 an informal response from Ontario Power Generation was posted on the public registry, indicating that OPG would not be responding to inquiries that are sent to it, except to those from the Agency CNSC Communications Northwatch noted with concern, as did other public interest intervenors, the letter from Canadian Nuclear Safety Commission President Michael Binder 56 dated December 21, 2016 in which Mr. Binder expresses his opinion about deep geological repositories at length including errors in fact and includes a graphic depiction of a deep geologic repository with the CNSC insignia imprinted on it. Mr. Binder writes that The figure below depicts a non-scientifically or geologically credible direct interaction between the proposed DGR and Lake Huron but provides no source for the graphic or rationale for its inclusion. This correspondence raises concerns about the relationship between the CNSC and the Agency, particularly given the first name basis and references to earlier conversations on the same topic between Mr. Binder and Agency president Ron Hallman. It also raises concerns about the professionalism and the professional judgement of CNSC staff and President, but that is of course beyond the capacity of the Agency to correct. We noted with appreciation that the Agency included this correspondence in the public registry, and that the response from Mr. Ron Hallman was neutral in its tone and content. 57 NORTHWATCH 35

37 7.4 Ontario Power Generation s Consultation In Section 8.1 of their Main Submission Ontario Power Generation describes a meeting on November 11, 2016 OPG as a :full day Stakeholder Information Session, provides a short description, and indicates that a report from this meeting and the associated PowerPoint presentation are posted on OPG s web site. It is interesting to note that of the 20 information sessions listed by OPG, on the November 11 th Stakeholder session has a report posted on the OPG web site. Northwatch was a participant in that session and following review of the draft meeting report advised the OPG consultant from Hardy Stevenson and Associates that Northwatch did not accept the session notes as a full and fair representation of the meeting or the discussions that took place, and requested that the extensive notes which were taken be shared in unedited form as reference and a basis for providing additional comments. Northwatch offered several examples of where the meeting report was inaccurate, and unless alterations were made the final version of the meeting report should indicate that the meeting report has not been endorsed by all meeting participants, and should specifically state that Northwatch has informed Hardy Stevenson and Associates Limited and Ontario Power Generation that Northwatch does not accept the meeting report as provided by Hardy Stevenson and Associates Limited to be a fair and full representation of the discussions and reviewed the meeting report in its draft form. No response was received and no action was taken to remedy all of the errors in the meeting report, although a note was added - as specifically requested by Northwatch - to indicate that Northwatch did not accept the meeting report as provided by Hardy Stevenson and Associates Limited to be a fair and full representation of the discussions. NORTHWATCH 36

38 8. Conclusion and Requested Action As expressed in earlier letters from Nuclear Waste Watch (to which Northwatch was a signator) and from Northwatch it is imperative that the current review of Ontario Power Generation s additional information pays careful attention to the details of Ontario Power Generation s response and place it within the context of OPG s pattern of non-conformance with both the requirements of the Canadian Environmental Assessment Act and the directions of the previous Joint Review Panel. The December 28 th filing by Ontario Power Generation very much follows this pattern on non-conformance. Ontario Power Generation has not provided the requested information In conclusion, Ontario Power Generation has failed to provide the Minister with the additional information she required. Despite the additional clarification by the Agency of September 2016, Ontario Power Generation did not provide responses that met the Minister s requirements. Northwatch provided comments to the Agency on January 16, 2017 as part of the Agency s conformity review. At that time, we identified that there were two options available to the Agency: to reply to Ontario Power Generation that they have failed to conform to the directions provided, and require that they comply within a limited period of time, or to report to the Minister that OPG has failed to conform to the direction provided and recommend that the Minister issue a Decision Statement rejection Ontario Power Generations Environmental Assessment application of 2011 without further delay. Given the Agency s decision to not provide Ontario Power Generation with an additional opportunity to provide the required information and given that Ontario Power Generation has not provided the additional information as per the Minister s direction, the only option still available to the Agency is to report to the Minister that OPG has failed to conform to the direction provided and recommend that the Minister issue a Decision Statement rejecting Ontario Power Generations Environmental Assessment application of 2011 without further delay. NORTHWATCH 37

39 Appendices Appendix 1 Appendix 2 Appendix 3 Review by Dr. George Reeves Review by Dr. Fred Dilbert OGSEarth Geoscience Data NORTHWATCH i

40 ENDNOTES 1 The public registry is online at 2 CEAR # Study of Alternate Locations Main Submission, Section CEAR # Main Submission, Page 16 7 Description of Alternate Locations, December 2016, OPG CD# REP R000 8 Description of Alternate Locations, December 2016, OPG CD# REP R NWMO Used Fuel Repository Conceptual Design and Postclosure Safety Assessment in Crystalline Rock, Pre-Project Report. Nuclear Waste Management Organization Report NWMO TR Page NWMO Used Fuel Repository Conceptual Design and Postclosure Safety Assessment in Crystalline Rock, Pre-Project Report. Nuclear Waste Management Organization Report NWMO TR Page i 12 NWMO Used Fuel Repository Conceptual Design and Postclosure Safety Assessment in Crystalline Rock, Pre-Project Report. Nuclear Waste Management Organization Report NWMO TR Page iii 13 NWMO Used Fuel Repository Conceptual Design and Postclosure Safety Assessment in Crystalline Rock, Pre-Project Report. Nuclear Waste Management Organization Report NWMO TR Page See reports under category Site Selection at 15 Page 17, Description of Alternate Locations 16 Postclosure Safety Assessment of a Used Fuel Repository in Sedimentary Rock, Pre-Project Report. Nuclear Waste Management Organization Report, NWMO TR Page ii 17 Postclosure Safety Assessment of a Used Fuel Repository in Sedimentary Rock, Pre-Project Report. Nuclear Waste Management Organization Report, NWMO TR Page ii 18 Postclosure Safety Assessment of a Used Fuel Repository in Sedimentary Rock, Pre-Project Report. Nuclear Waste Management Organization Report, NWMO TR Page Page 17, Description of Alternate Locations 20 Study of Alternate Locations for the Ontario Power Generation proposals for a Deep Geological Repository for Low- and Intermediate-Level Radioactive Wastes located at the Bruce Nuclear Generating Station site in the Municipality of Kincardine, Ontario, Canada: Report on Geological, Geotechnical and Hydrogeological Considerations. Prepared for Northwatch by Dr. GM Reeves, HydroGEOtecH Consultants, Caithness, Scotland, UK, March 2017, See Appendix 1 21 Study of Alternate Locations for the Ontario Power Generation proposals for a Deep Geological Repository for Low- and Intermediate-Level Radioactive Wastes located at the Bruce Nuclear Generating Station site in the Municipality of Kincardine, Ontario, Canada: Report on Geological, Geotechnical and Hydrogeological Considerations. Prepared for Northwatch by Dr. GM Reeves, HydroGEOtecH Consultants, Caithness, Scotland, UK, March 2017, Section 3 22 Study of Alternate Locations for the Ontario Power Generation proposals for a Deep Geological Repository for Low- and Intermediate-Level Radioactive Wastes located at the Bruce Nuclear Generating Station site in the Municipality of Kincardine, Ontario, Canada: Report on Geological, Geotechnical and Hydrogeological Considerations. Prepared for Northwatch by Dr. GM Reeves, HydroGEOtecH Consultants, Caithness, Scotland, UK, March 2017, Section 4 23 see a UK example in Appendix C 24 Examples of such approaches can be seen in the work of UK Nirex in the Rock Characterisation Facility (RCF) investigations at Longlands Farm/Sellafield in the 1980s and 1990s in Cumbria in the UK (Appendix C), as well as in the AECL Research Company activities at Whiteshell and Lac du Bonnet, Manitoba (where AECLs Underground Research Laboratory-URL was established from 1979 to its closure in 2004), as well as at AECLs Research Areas such as at Atikokan and East Bull Lake, Ontario in the 1980s and 1990s (See Appendix B). NORTHWATCH ii

41 25 At a number of locations on the Canadian Shield occurrences of these mineralised deep connate waters emerging at the surface have been investigated. (Frape et al, 1984) (See also Section 4, Discussion, with relevance to the Bruce Site and Figures 3 and 5, this report, from OPG TSD) 26 Main Submission, Page Pages 5 and 8, Descriptions of Alternate Locations 28 Environmental Effects of Alternate Locations, Table /addressing-purpose-alternative-means-under-canadian-environmental-assessment-act-2012.html 30 Page Page Page See the Operational Policy Statement at 34 Section 2.1, Description of Alternate Locations 35 Section 2.2, Description of Alternate Locations 36 Environmental Effects of Alternate Locations, Page 3 37 Description of Alternate Locations, December 2016, OPG CD# REP R000. Page 3, last two paragraphs 38 Description of Alternate Locations, December 2016, OPG CD# REP R000. Page 3 39 Description of Alternate Locations, December 2016, OPG CD# REP R000. Page 3 40 CEAR #1439, August 20, 2013, PMD 13-P1.171 Oral Intervention by Laura Bowman 41 NWMO Used Fuel Repository Conceptual Design and Postclosure Safety Assessment in Crystalline Rock, Pre-Project Report. Nuclear Waste Management Organization Report NWMO TR Singer, S.N. et al, The Geology of Southern Ontario, Environmental Monitoring and Reporting Branch, Ontario Ministry of the Environment, Second Edition, Talbot, C.J Ice ages and nuclear waste isolation. Engineering Geology 52: Description of Alternate Locations, December 2016, OPG CD# REP R000. Page 4 45 Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations. December Prepared by: Energy Solutions Canada. OPG CD# REP R Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations. December 2016, page As found at and 48 Northwatch s Review of Ontario Power Generation s Darlington New Nuclear Power Plant Project with a Focus on Project-Generated Radioactive Wastes and OPG s Waste Management Approach, Submitted to the Joint Panel Review on February 21, CEAR # CEAR # CEAR# Section 2.1, Description of Alternate Locations 53 Section 2.2, Description of Alternate Locations 54 CEAR # CEAR # CEAR # CEAR #2946 NORTHWATCH iii

42 Appendix 1

43 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Report on:- Study of Alternate Locations for the Ontario Power Generation proposals for a Deep Geological Repository for Low- and Intermediate-Level Radioactive Wastes located at the Bruce Nuclear Generating Station site in the Municipality of Kincardine, Ontario, Canada. :- Geotechnical and Hydrogeological Considerations. By Dr. GM Reeves, HydroGEOtecH Consultants, Caithness, Scotland, UK Study of Proposals for Alternate Locations: OPG-DGR :- Geological, Geotechnical and Hydrogeological Considerations. HydroGEOtecH Consultants. Lybster House, Lybster, CAITHNESS SCOTLAND, UK KW3 6AS 0

44 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Contents Page No. Executive Summary 2 1. Introduction 3 2. Terms of Reference 5 Authorship Instructions from Minister and reporting to CEAA 3. The Bruce Site- Requirements of DGR and Comparative Locations- 6 OPG programs- Common Factors & Generic Approach Geological Characterisation. 7 Hydrogeologic Characterisation 7 Recharge areas, Discharge areas 7 Connate (Deep) Groundwaters 8 4. Discussion- The 21 Alternate Locations and the Bruce Site. 12 Generic Approach & Alternate locations. Adequacy of comparisons by OPG & Discussion of Inappropriate locations Conclusions and Suggestions for Future Work. 17 References 18 Appendices:- (A). GMR- CV and biographic notes. 19 (B). Comparable Studies and Previous Work 23 The Bruce Site 23 The NFWRP of AECL Research Company URL Manitoba 26 CRNL, White Lake and Whiteshell 28 The Ontario Research Areas;Atikokan;East Bull Lake 30 (C). A Comparable DGR Investigation Program to OPGs Bruce Site: 32 The RCF of UK Nirex (1986 to 1996): Longlands Farm, Cumbria UK. 1

45 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Executive Summary:- In response to a Ministerial request in February 2016, Ontario Power Generation (OPG) presented 4 reports (in December 2016) on 21 Alternate Locations (14 in crystalline geologic terrains, and 7 in sedimentary rock environments) positioned throughout Ontario. The Federal Minister of Environment and Climate Change requested that OPG provide additional information prior to making a decision on the Environmental Assessment (EA) of the Deep Geologic Repository (DGR) Project at the Bruce Nuclear site. This review report considers the information that OPG have provided in that exercise, in particular with reference to the extent and adequacy (or not) of compliance with the Minister s request, especially in the areas of geology, geotechnical and hydrogeological data. It is therefore the conclusion of this review, supported by comparable research elsewhere in the world (which is described and referenced), that the investigations into Alternate Locations as well as the geological, geotechnical and hydrogeological work carried out to date on the Bruce Site, and elsewhere in Ontario, are totally insufficient and inadequate to properly characterise safely the location for a DGR below the Bruce PS site, or at any of OPGs Alternate Locations. The Alternate Locations proposals, carried out by OPG at the request of the Federal Minister of Environment and Climate Change, are completely inadequate for any relative comparisons of suitability, as little or no ground control nor any comparable detailed geological, geotechnical, hydrological or hydrogeological data is presented in OPGs Study of Alternate Locations reports. 2

46 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Introduction: In response to a Ministerial request in February 2016, Ontario Power Generation (OPG) presented 4 reports (in December 2016) on 21 Alternate Locations (14 in crystalline geologic terrains, and 7 in sedimentary rock environments) positioned throughout Ontario. The Federal Minister of Environment and Climate Change requested that OPG provide additional information prior to making a decision on the Environmental Assessment (EA) of the Deep Geologic Repository (DGR) Project at the Bruce Nuclear site. The Minister of Environment and Climate Change, the Honourable Catherine McKenna, PC, MP, in her letter of February 18 th 2016, specifically requested:- A study that details the environmental effects of technically and economically feasible alternate locations for the Project, with specific reference to actual locations that would meet OPG s criteria for technical and economic feasibility. In conducting this study, OPG is to detail the thresholds for what is considered to be technically and economically feasible. In addition, OPG is to indicate what the incremental costs and risks would be for additional off-site transportation of the nuclear waste. This review report considers the information that OPG have provided in that exercise, in particular with reference to the extent and adequacy (or not) of compliance with the Minister s request, especially in the areas of geology, geotechnical and hydrogeological data. OPG have published many reports and associated publications over a period of 16 years (starting in 2001) on the suitability of their Bruce Site as a suitable Deep Geological Repository (DGR). Despite such large volumes of reporting, the Bruce site has only been characterised in terms of geology, geotechnics and most importantly, hydrogeology, on the basis of investigations in six deep boreholes, drilled, logged and tested between 2006 and Two of these boreholes were inclined and specifically targeted on particular features. None of these boreholes are located outside the approximate four square kilometre Study Area site located in the centre of OPGs Bruce PS complex. (Figure 1 of this report) A projected surface area of less than four square kilometres of the Bruce site was therefore investigated and geologically characterised, at the proposed DGR depth of 680 metres below surface. This site investigation work was reported upon by Golder Associates for OPG in March 2011 and is detailed in their Geology-Technical Support Document (Report No. NWMO DGR-TR ). This Potential Repository Zone (PRZ) footprint contrasts dramatically with other similar previous Canadian investigations, and with those from elsewhere in the world, with which the Bruce Site Investigations are compared in this review-report. These comparable investigations often involve very detailed geological, geotechnical and hydrogeological characterisation of up to 100 square kilometres, using tens, sometimes hundreds of deep boreholes. Furthermore, from specific investigations into potential crystalline rock locations for DGR sites elsewhere in Canada and internationally (eg. in Sweden, Finland, the USA and Switzerland), it is not correct to ascertain unequivocally (as has OPG in their Alternate 3

47 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Locations reports), that crystalline rock locations have a considerably higher degree of fracturing at depth than sedimentary terrains. They then argue that consequently crystalline rock repositories will always be more expensive to develop and construct as a DGR than sedimentary sequences, as well as being highly dependent on engineered barriers. This argument has no basis in fact or experience elsewhere in the world. Sediments always have a set of specific unique features which differentiate them, fundamentally from crystalline intrusive rock masses, ie. Bedding planes and lateral (especially basal) unconformities. These planar features always have differentially enhanced permeabilities and thus potential lateral, and extensively continuous, groundwater flow pathways. It is therefore the conclusion of this review, supported by comparable research elsewhere in the world (which is described and referenced), that the investigations into Alternate Locations as well as the geological, geotechnical and hydrogeological work carried out to date on the Bruce Site, and elsewhere in Ontario, are totally insufficient and inadequate to properly characterise safely the location for a DGR below the Bruce PS site, or at any of OPGs Alternate Locations. The Alternate Locations proposals, carried out by OPG at the request of the Federal Minister of Environment and Climate Change, are completely inadequate for any relative comparisons of suitability, as little or no ground control nor any comparable detailed geological, geotechnical, hydrological or hydrogeological data is presented in OPGs Study of Alternate Locations reports. Furthermore, in the present writer s professional opinion, the complete lack of reference to any of AECL (Atomic Energy of Canada) Research Company s 1975 to 1996 Research Area Program (carried out in conjunction with the Geological Survey of Canada, and the Earth Physics Branch of Energy, Mines and Resources, Canada) further undermines both the credibility and thoroughness of OPGs program of work towards a DPG in Ontario. 4

48 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. 2. Terms of Reference This review has been commissioned by Northwatch, of North Bay, Ontario, Canada, and is supported from Federal funding granted to the Canadian Environmental Assessment Agency. The requirement is for Dr. GM Reeves, Principal Consultant Hydrogeologist of HydroGEOtecH Consultants, of Lybster, Caithness, in the North of Scotland, UK, to produce a review on the reports from Ontario Power Generation Study of Alternate Locations- Main Submission, prepared as part of OPG s Deep Geologic Repository Project for Low and Intermediate Level Radioactive Wastes. In carrying out this task, it is implicit that OPGs DGR program at the Bruce site should be assessed, especially in comparison with the long-term investigations carried out by Atomic Energy of Canada, Research Company, from 1975 to 1996 in crystalline rocks of the Canadian Shield for deep geological disposal of spent fuel, as well as intermediate and low level wastes from throughout Canada. Instructions from Minister and reporting to CEAA This document (with three supporting reports) were prepared by OPG in response to a request by the Federal Minister of Environment and Climate Change that Ontario Power Generation (OPG) provides additional information prior to making a decision on the Environmental Assessment (EA) regarding OPG s Low and Intermediate Level Waste (L&ILW) Deep Geologic Repository (DGR) Project. In particular the Minister requested: Authorship a) A study that details the environmental effects of technically and economically feasible alternate locations for the Project, with specific reference to actual locations that would meet OPG s criteria for technical and economic feasibility. In conducting this study, OPG is to detail the thresholds for what is considered to be technically and economically feasible. In addition, OPG is to indicate what the incremental costs and risks would be for additional offsite transportation of the nuclear waste. b) An updated analysis of the cumulative environmental effects of the Project in light of the results of the Phase 1 Preliminary Assessments undertaken by the Nuclear Waste Management Organization, which identified three potential host communities that fall within the traditional territory of the Saugeen Ojibway Nations (SON). c) An updated list of mitigation commitments for each identified adverse effect under CEAA [Canadian Environmental Assessment Act] OPG shall identify out-dated or redundant commitments that were previously brought forward to the Panel. The four reports prepared by OPG in response to The Minister s request in February 2016 are:- (i). Study of Alternate Locations- Main Submission- Report REP (ii). Description of Alternate Locations-Report REP R000 (iii). Environmental Effects of Alternate Locations REP R000 (iv). Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations This present critical review has been prepared under the sole authorship of Dr. G M Reeves of HydroGEOtecH Consultants. Dr. Reeves has over 45 years of professional experience as an Engineering Geologist and Hydrogeologist. He has been involved in Radioactive Waste Disposal Investigations and Research for over 35 of those years. Relevant professional details and a Biographic note giving Dr. Reeves background and experience are included in Appendix A. This report concentrates solely on geological, hydrogeological and geotechnical aspects of the OPG submission. 5

49 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. 3. The Bruce Site Site investigation work for OPGs DGR at the Bruce Site near Kincardine in Ontario commenced in 2006 and was completed by (Figures 1 and 2 from Geology TSD Report, Golder Associates March 2011) From the start of geological investigation of the DGR repository zone (the Study Area- Figure 1, Geology TSD Report), only 4 vertical boreholes (DG-1, DG-2, DG-3 and DG-4) have been drilled to investigate the deep rock, repository zone geological, geotechnical and hydrogeological environments. The investigated area lies at the centre of OPGs Bruce NPP site (Figure 2) Borehole DG-1 did not reach the proposed disposal depth of 680 metres. (ie. DG-1 :Total Depth- TD at 462m., only reached the upper section of the Upper Ordovician Queenston Formation -see Figures 3 and 4; From Geology TSD Report, Golder Associates March Therefore only a very limited (projected to DGR proposed depth) surface area, and very restricted volume of rock at that depth, have been investigated by OPGs deep drilling program of 6 boreholes, into the Proposed Repository Horizon in the limestones of the Cobourg Formation at 680 metres depth below the Bruce NPP site. Figure 1; From Geology TSD Report, Golder Associates March

50 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Common Factors in Generic Approaches to DGR Location Characterisation Geological Characterisation In comparable studies elsewhere in the world (see a UK example in Appendix C) for deep geologic repositories and/or underground research laboratories, extensive targeted surface geophysical surveys, (usually but not exclusively seismic surveys) are normally carried out, tied in by an array of preliminary deep boreholes (typically tens of boreholes through which the geophysical results are refined and controlled, providing accuracy of interpretation). More drilling is then informed by the above First Phase exploration, providing an improved network of characterised ground, to and usually beyond the proposed repository depth. Coverage is often in the tens, sometimes approaching hundreds of square kilometres around the proposed repository site. Examples of such approaches can be seen in the work of UK Nirex in the Rock Characterisation Facility (RCF) investigations at Longlands Farm/Sellafield in the 1980s and 1990s in Cumbria in the UK (Appendix C), as well as in the AECL Research Company activities at Whiteshell and Lac du Bonnet, Manitoba (where AECLs Underground Research Laboratory-URL was established from 1979 to its closure in 2004), as well as at AECLs Research Areas such as at Atikokan and East Bull Lake, Ontario in the 1980s and 1990s (See Appendix B). Information as to the variability of rock type (igneous, metamorphic or sedimentary), material properties, competence, bedding, geological structure and solubility/effects of past weathering and alteration, are normally all targeted over a substantial area, relative to the DGR footprint and the PRZ area by an extensive borehole drilling program and comprehensive geophysical surveying campaign. Penetrative investigations (ie. Borehole drilling) away from the immediate PRZ area also has the benefit of providing geologic, geotechnical and hydrogeologic data from the lithologies at the proposed depths of the DGR/URL, without providing potential for disturbance, unnecessary penetration, leakage pathways, and hence compromising the integrity of the facility unnecessarily by near-field activities. Hydrogeologic Characterisation- Recharge and Discharge Areas. After an understanding of the geologic variability of either crystalline or sedimentary terraines around, under and some distance (tens of kilometres, normally) from any proposed DGR or URL, a program of detailed hydrogeologic testing is normally carried out in each borehole. There are usually tens of such suitable boreholes available for such testing. They are normally located both in the Potential Repository Zone (PRZ), and at distances of kilometres, and commonly tens of kilometres distance from the PRZ. Such testing work shows how, and to what extent hydrogeologic conditions (ie. Permeability, porosity, groundwater chemistry etc.) varies away from the PRZ area. On a wider scale, hydrological and hydrogeologic studies help to identify recharge and (most importantly) discharge areas, on a catchment and sub-catchment scale, whilst also providing real field data for long term hydrogeologic modelling for the near and far-field conditions affecting the DGR/URL and its environments. 7

51 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Connate (Deep) Groundwaters In both crystalline and sedimentary environments, a good understanding of the geochemistry, development and potential for movement of connate (ie. Deep) groundwater regimes affecting both the near-field and far-field conditions relevant to the PRZ at depth is also required. This can be done after a shaft has been excavated and by way of underground investigations and experimentation (as by the Swiss at their Grimsel Laboratory, and by AECL at the Manitoban URL). However this is best carried out for a proposed operational underground facility before construction, to have as much as possible deep groundwater information (both physical and geochemical data) of the undisturbed pre-construction conditions. These data are also invaluable for long-term hydrogeologic modelling for both farand near-field predictions of disturbed groundwater conditions and flow, as well as in improving the understanding of relevant hydrogeologic conditions affecting the proposed site. At a number of locations on the Canadian Shield occurrences of these mineralised deep connate waters emerging at the surface have been investigated. (Frape et al, 1984) (See also Section 4, Discussion, with relevance to the Bruce Site and Figures 3 and 5, this report, from OPG TSD) 8

52 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 2; From Geology TSD Report, Golder Associates March 2011 Figure 3; From Geology TSD Report, Golder Associates March 2011(Not to Scale) 9

53 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 4; From Geology TSD Report, Golder Associates March

54 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 5; From Geology TSD Report, Golder Associates March 2011 [NB. Horizontal Scale INCORRECT- Should be 20km NOT 50km] 11

55 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. 4. Discussion: The 21 Alternate Locations and The Bruce Site Characterisation. Adequate Data Requirements for Comparative Locations- OPGs program. The restricted investigatory footprint of the OPG DGR site at the Bruce location is discussed in Section 2. No far-field (or even outer near field ) boreholes have been specifically drilled for this investigation. Other deep well data (eg. From oil, gas or deep water well drilling) is not generally suitable for such characterisation studies, apart from providing general regional stratigraphic control (from deeper water wells or hydrocarbon exploration geophysics and drilling data). Therefore any large scale groundwater modelling for the Bruce site, which could investigate the potential flow of deep connate groundwater eastwards towards the outcrop of the Cobourg Formation some 86 kilometres to the East on the southern shores of Georgian Bay, cannot have been realistically undertaken by OPG. Generic Approach of OPG in identifying Alternate Locations. The Alternate Locations of OPG in their December 2016 reports,in response to the Minister s requirements, covers virtually the whole of Ontario. (See Figure 6 - Fig. 2-1 and introduction, from OPG report December 2016). Sites seem to have been selected, in both crystalline and sedimentary geologic terrains, based on Maximum distances from Bruce NPP Site (ie. Near to Provincial borders, in one case beyond such a border) rather than on geologic or hydrogeologic suitability or hard data from such sources. Figure 6- Fig. 2-1 and introduction (from OPG report December 2016) 12

56 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. As can be seen from Appendix B of this report, a number of crystalline rock locations, (which were investigated and reported in great detail, as part of the 20 plus year program of AECL Research Company in the last three decades of the past Century), could readily have been compared with the Bruce Site investigations carried out from 2006 to 2010 by OPG. It is of considerable surprise to this reviewer to report that no reference has been made by OPG, in considering any alternate locations, of AECL Research Company 12 Research Areas in crystalline rocks of the Canadian Shield, carried out from 1975 to 1996, apart from one passing reference to the URL site in Manitoba (see below, this section). The study carried out by OPG, and its consultants in 2016, at the request of The Minister into alternate sedimentary and crystalline rock locations is highly unusual, in terms of geological study. OPG appears to have used almost a scatter gun approach to the siting of the alternate locations that they were requested to consider by the Canadian Minister of Environment and Climate Change, Hon. Catherine McKenna in her letter to the VP of OPG of 18 February Despite identifying 21 locations (14 in crystalline rock terraines, and 7 alternative sedimentary sites), no maps, geological or otherwise are included in this report and supporting documents. It is therefore evident that OPG have not complied with the Minister s request that OPG prepare A study that details the environmental effects of technically and economically feasible locations for the Project, with specific reference to actual locations that would meet Ontario Power Generation s criteria for technical and economic feasibility. In addition, the assertion, endorsed by OPGs Panel of Experts in their supporting report, that crystalline rock locations are likely to be more fractured at depth than deep sedimentary environments, and consequently will be more costly locations to develop as a DGR, is invalid. This assertion, in the light of evidence from other locations elsewhere in the world (such as in Finland, Sweden and AECLs own site at the URL in Manitoba) is wrong. It is also unsupported by any geological, geotechnical or hydrogeological data from any actual investigations at depth at any of the proposed Alternate Locations The 21 Alternate Locations identified by OPG and labelled, annotated and plotted by Northwatch, are shown in the table and plan, below, and are not investigated further detail herein, due to the total lack of any detailed site-specific geologic information provided by OPG for these sites 13

57 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. ID# Geologic region Longitude Latitude Location Name C-1 Crystalline Honey Harbour North C-2 Crystalline Collins Inlet, East Killarnay C-3 Crystalline Sault Ste. Marie C-4 Crystalline Neys Thunder Bay / Pigeon C-5 Crystalline River C-6 Crystalline Shoal Lake C-7 Crystalline Pauingassi C-8 Crystalline Pasquatchai C-9 Crystalline Winisk C-10 Crystalline Jog Lake C-11 Crystalline Kesagami C-12 Crystalline Lorraine Valley C-13 Crystalline Pakenham C-14 Crystalline Frontenac S-1 Sedimentary Collingwood S-2 Sedimentary Midtown Toronto S-3 Sedimentary Burlington Skyway S-4 Sedimentary Niagara S-5 Sedimentary Fort Erie / Stonemill Road S-6 Sedimentary Lake Erie / Grosse Isle S-7 Sedimentary Sauble Beach, offshore Notes: - ID numbers are assigned by Northwatch, based on the order of sites as listed by Ontario Power Generation - Source for Crystalline site locations is CEAR#2902, OPG Errata, Att. 2 - Source for Sedimentary site locations is Table 2-2, OPG Description of Alternate Locations, posted as one of seven documents in CEAR# Location names are assigned by Northwatch, based on proximate location - Map was generated by inputting OPG provided co-ordinates into Google maps Table 1- The Alternate Sites of OPG- December

58 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 7- The 21 Alternate Locations of OPG, plotted by Northwatch using Google Earth 15

59 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Discussion: The 21 Alternate Locations. The seven sedimentary, and 14 crystalline/basement rock locations are given scant detailed examination in any of OPGs recent reports on the Alternate Locations. These locations can be examined using the Ontario Geological Survey Geological Database mapping (OGSEarth, based on Google Earth satellite imagery and mapping.) Such geologic information on any of the 21 alternate locations has not been included in OPGs Alternate Locations Reports. Neither has any borehole data been included, nor geotechnical or hydrogeologic information for the 21 sites. It is probable that no such information, either on open file or confidentially classified, exists for these sites. Furthermore, only Sedimentary and Crystalline alternate locations are discussed. Evaporitic deposits in Ontario, such as are located in the Windsor area, have not been considered by OPG or their consultants. Such lithologies have been proposed, investigated and put into commission as DGRs at both the WIPP site in New Mexico, USA, and at the Asse Salt mine in Northern Germany. It is relevant to note that this limitation is not placed upon OPG by The Minister s Requirement letter of February 18 th 2016.Geotechnical Characterisation of any of these, often remote, Ontario locations would be expensive and time-consuming, as was demonstrated during AECL s NFWMRP Research Area program from 1975 to No consideration has been given to any specific hydrogeological studies of the 21 locations or their recharge areas and discharge areas. The appearance of Connate waters, ie. Saline water emerging at surface from depth, is a well-known feature of some locations throughout the Canadian Shield. These sites are colloquially known as natural Moose Licks, and often quite deep in the bush, and are quite different from the highway locations where road salt attracts wild moose. Such features have been reported near Lake Nipigon and Thunder Bay, amongst other locations on the Canadian Shield. (Frappe et al; 1984;1987) In addition, there has been no assessment of geological structure, igneous competence, sedimentary bedding, or tectonic structure for any of the Alternate Locations. Perhaps the most telling indictment on the coverage of OPGs Alternate Sites reports is the total lack of reference to any of AECL Research Company work at Ontario Research Areas (RAs- See Section 2) in the 1970s, 1980s and 1990s. As previously stated, the only reference to AECL s NFWMR Program concerns the URL investigations in Manitoba. In the report Environmental Effects at Alternate Locations, prepared by Golder Associates for OPG in December 2016, it is stated that. Experience in the crystalline alternate location of the Canadian Shield has shown that active groundwater flow in bedrock is generally confined to shallow localized fractured systems, and at depths is dependent on the secondary permeability associated with the fracture networks [Singer and Cheng 2002]. For example, in Manitoba s Lac du Bonnet batholith, groundwater movement is largely controlled by a fractured zone down to about 200 m depth [Everitt et al. 1996]. The extensive URL research program by AECL therefore hardly supports OPGs assertions that:- Additional engineered barrier(s) would likely be required because of the fractured, more permeable nature typical of crystalline rock. This could include additional grouting to control water inflow from fractures, and backfilling of some emplacement rooms to limit the free water movement in the vicinity of the waste packages...and also. Mitigations for the crystalline alternate location are likely to be more extensive than for the sedimentary alternate location based on the different geologic settings (OPG Report- Environmental Effects at Alternate Locations, Golder Associates December 2016). 16

60 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. 5. Conclusions and Suggestions for Future Work. Ontario Power Generation (OPG) have failed, in both their Bruce site and Alternate Locations considerations, to take into account the extensive experience gained by Atomic Energy of Canada, Research Company in its 20 plus years of investigation in the Canadian Shield in crystalline rock lithologies. In addition, the over dependence, in the long term, of the hydrogeological integrity of sedimentary formations, is not born out by the considerable international practice and experience with the 3- dimensional lateral inhomogeneity of rock properties, (especially permeability), in such sequences. This is especially true in the basal, often conglomeratic, sections of such strata. (for example, as experienced in the UK Nirex, Sellafield-Longlands Farm Public Inquiry- Reeves 1996) Assessment of potential long term discharges (over the required 10s of thousands of years) of connate groundwaters, to outcrop, from the proposed repository depths in such sedimentary formations, has not been adequately carried out by OPG, at the Bruce site or in the medium to far-field areas, notwithstanding the difficulties of such long-term modelling. Until OPG carry out a more thorough investigation of the Bruce site and it s environs, comparable with those investigated elsewhere in crystalline rock (notably by AECL at Atikokan, East Bull Lake, as well as lessons learned from the Manitoba URL site), it is the advice of this review, that the Minister does not approve OPG s plans for the development of the Deep Geological Repository (DGR) at Kincardine. It is necessary for OPG to address the above and other important issues, to adequately assess the deficiencies of sedimentary strata in comparison with crystalline basement rocks, on geological, geotechnical and especially hydrogeological criteria, before the Canadian Federal Government and the Province of Ontario can be fully reassured that the Bruce site is the best location for a Canadian DGR. Dr. GM Reeves

61 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. REFERENCES:- AECB (Atomic Energy Control Board) Regulatory Guide. Geological Considerations in Siting a Repository for Underground Disposal of High-Level Radioactive Waste. AECB Regulatory Document R-72. September 21, AECL (Atomic Energy Canada Limited) Environmental Impact Statement on the Concept for Disposal of Canada s Nuclear Waste Fuel. AECL-10711, COG Brown, P.A., and R. Thivierge Pluton categorization. Atomic Energy of Canada Limited Technical Record, TR-36. Daymond D (& ReevesGM )TR- 248 URL Groundwater Monitoring Program Gandalf (Group) Ontario Power Generation, Deep Geologic Repository Study. Everitt, R., J. McMurray, A. Brown and C. Davison Geology of the Lac du Bonnet Batholith, Inside and Out: AECL's Underground Research Laboratory, Southeastern Manitoba (Field B5). Geological Association of Canada Mineralogical Association of Canada, Joint Annual Meeting, May 1996 GOLDER Environmental Effects of Alternate Locations. Prepared by Golder Associates Ltd. Ontario Power Generation Report REP R000. Frape, S.K. and P. Fritz Geochemical trends for groundwaters from the Canadian Shield. Saline Water and Gases in Crystalline Rocks, P. Fritz and S.K. Frape (Editors). Geological Association of Canada Special Paper 33, pp Frape, S.K., P. Fritz and A.J. Blackmer Saline groundwater discharges from crystalline rocks near Thunder Bay, Ontario, Canada. International Symposium on Hydrochemical Balances of Freshwater Systems, Uppsala, Sweden. IAEA Geological Disposal Facilities for Radioactive Waste. International Atomic Energy Agency, Specific Safety Guide SSG-14. IAEA Geological Disposal Facilities for Radioactive Waste. International Atomic Energy Agency, Specific Safety Guide SSG-14. IEP International Expert Panel Views on the Ontario Power Generation Response to the Request of the Canadian Minister of Environment and Climate Change for Assessment of Alternate Locations for the Deep Geologic Repository JRP Joint Review Panel Environmental Assessment Report, Deep Geologic Repository for Low and Intermediate Level Radioactive Waste Project. Canadian Environmental Assessment Agency (CEAA) Reference OPG. 2011a. Environmental Impact Statement, Volume 1: Main Report. Prepared by Golder Associates Ltd. Ontario Power Generation Report REP R000. (CEAA Registry Doc# 298) OPG. 2011b. Preliminary Safety Report. Ontario Power Generation Report SR R000. (CEAA Registry Doc# 300) OPG. 2016b. Description of Alternate Locations. Prepared by Nuclear Waste Management Organization and Ontario Power Generation. Ontario Power Generation Report REP R000. Reeves GM 1996 Proof of Evidence: Sellafield RCF Public Inquiry for Friends of the Earth. 18

62 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Appendix A. Dr. George M Reeves: Relevant Experience & Biographic Note:- Dr. GEORGE M. REEVES CGeol, CEnv, MSc, PhD, FGS, FIMMM HydoGEOtecH Consultants. Personal Details Nationality Profession Specialisation Position in Company British/Canadian Independent Consultant Hydrogeology and Geotechnics Principal Consultant Years with Company 30 years (Established 1986) Availability per annum (%) 80% Personal Capability Statement George Reeves is an independent consultant with more than 45 years post-graduate experience in industry and academia. His research and consultancy interests cover wide areas of geotechnical engineering, including hydrogeology, coastal engineering, tunnelling and minegas/subsidence. Prior to returning to the UK in 1986, he worked for AECL Research Company in Manitoba, Ontario and Ottawa, Canada, as a member of their Deep Geological Disposal Research Area Characterisation team, on AECLs Underground Research Laboratory near Lac du Bonnet, Manitoba; for AECLs Low Level Waste office, based at AECL Head Office, in Ottawa, and for the Geological Survey/AECL group, also based in Ottawa.. Having over 35 years involvement in radioactive waste disposal investigations and research. He has worked as a consultant and advisor to BNFL, UKEA, MoD, UK Nirex, CoRWM, DTI and DoE/DEFRA and has also supervised a number of postgraduate research projects with some of these organizations George was a member of the DoE/DEFRA Radioactive Waste Advisory Committee (RWMAC) from 1986 to He has been both an active Council and committee member of The Geological Society. He has held a number of posts, within the Geological Society, including Editorial Board Member, Quarterly Journal of Engineering Geology and Hydrogeology, and was Chairman and Proceedings Editor of the International Conference on Geo-Engineering of Hazardous and Radioactive Wastes in He is coauthor/editor of a number of Specialist Engineering Geology Publications of the Geological Society. His research area specialisations include a 20 plus year study of the use of down-hole geophysics in hydrogeological characterization of deep rock excavations for which he was awarded a PhD in 2004 by Newcastle University. He continues research and publications, some of which (particularly relevant to radioactive waste disposal) are listed on pages 21 & 22. -contd.- 19

63 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Career Summary 2007 date HydroGEOtecH Consultants, Caithness, Scotland- Principal Consultant And Geological Advisor to Nuclear Waste Advisory Associates (NWAA) LLWR Ltd. Technical Advisor Environmental Safety Case. Cumbria North Highland College, UHI Millennium Institute, Caithness, Scotland Director, Decommissioning and Environmental Remediation Centre (DERC) University of Newcastle - Upon Tyne, UK Lecturer & MSc Course Director, Engineering Geology/Geotech. Engineering Geological Survey, Energy, Mines and Resources, Ottawa, Canada Hydrogeologist and Hydrogeophysical Research Applied Geoscience Branch, Atomic Energy of Canada, Research Company, Manitoba, Canada, AECL/GSC Ottawa & AECL LLW office. Exploration and site characterisation, Hydrogeology, Geophysics and Drilling Technology as part of Canada s Nuclear Fuel Waste Research Program Robertson Research plc, N Wales Manager, Geotechnics/Geophysical Logging Strata Surveys Ltd, Cheshire Chief Geologist/Hydrogeologist Severn Trent Water Authority, Nottinghamshire Area Hydrogeologist LRA/North West Water Authority- Assistant Engineer, Water Resources Relevant Key Experience AECL Nuclear Fuel Waste Disposal Research Programme Canada Specialising in hydrogeophysical logging, undertook research work in connection with Canada s safe geological disposal of nuclear fuel waste programme. Extensive experience in fracture flow hydrogeology, geophysics and drilling technology. Project Leader- Borehole Geophysics Group- GSC/AECL Ottawa Project Manager- AECL Res Co. URL and Research Area Drilling Contracts AECL Low Level Waste Programme Canada Characterisation of Port Hope township and program for Canadian LLW disposal at Chalk River Nuclear Research Establishment, near Deep River, Ontario..-contd- 20

64 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. HMG/DTI Safety Review Panel ( Project Z ) UK Panel member advising on the hydrogeology of the Sellafield site UK NIREX Public Inquiry:- Expert Witness and Advisor to Friends of the Earth UK RWMAC DETR/DEFRA Committee UK Committee member advising on hydrogeological and geotechnical matters. Member DEFRA (DoE) Radioactive Waste Management Advisory Committee to 2004: Dealing with the Public, Industry, MoD & on International visits/study tours Postgraduate Training & Research, Nuclear Decommissioning and Radwaste Disposal UK As Director, Decommissioning and Environmental Remediation Centre, (DERC-UHI) carried out consultancy, taught and supervised MSc and PhD students and continues part-time supervision of research projects. Development of contaminated land consultancy at UKAEA Dounreay and Sellafield, Cumbria. DERC revised Business Plan with Plumbland Consultants (June 2007) Selected Publications (A full publications list is available on request.) Relevant publications include: Reeves, G M 1983: Hydrogeological Investigation Drilling Techniques in the Canadian Nuclear Fuel Waste Management Program: Geological Association of Canada, Victoria, B.C. May Reeves, G M 1983: Report on: Port Hope Area - Radioactive Waste Management, Remedial Works Leading to Designs for Engineered in-situ Containment.for: AECL Research Co., Ottawa Reeves, G M 1984 The Geology and Hydrogeology of the Surficial Deposits and Shallow Bedrock at the Underground Research Laboratory Lease Area, near Lac du Bonnet, Manitoba: AECL Technical Records TR to 5 and main TR-220. Reeves, G M 1986The Use of Commercial Slimline Logging Equipment in Canada's Nuclear Waste Research Program. Geological Association of Canada, AGM. Special Session: Hydrogeology/Geophysics, Ottawa,May Reeves, G.M The Geology of the Sellafield Area - Deep Drilling and Outcrops - Study Tour Guide and Field Class - Field Guide & Notes. Geological Society Eng. Group May 1993 Reeves, G.M The Sellafield Radioactive Waste Repository - Preliminary Report on Hydrogeological Characterisation of Rock Characterisation Facility (RCF) & area. Project Z Report for Intera Ltd. & DTI /HMIP July Reeves GM. 1993;'The Sellafield Rock Characterisation Project - Drilling and Borehole Geophysical Techniques'.in 10th International Symposium on borehole geophysics - Proceedings: Society of Professional Well Log Analysts, SPWLA-MGLS Symposium, Tulsa, Oklahoma, USA, October Reeves GM. 1993: Preliminary Hydrogeological Report- Aldermaston AWRE. December 1993 for Greenpeace, UK.and Expert Witness- Community Enquiry, Reading Council, March 1994 Reeves GM 1996 Proof of Evidence: Sellafield RCF Public Inquiry for Friends of the Earth. September HydrogeologicaL Investigation Programmes- Best Practice. Reeves GM in RWMAC- Report on Study Tour to Switzerland, October Wellenberg ILW Site and Geoscience aspects of NAGRA programme- Contributing Author 21

65 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Farmer IW and Reeves GM- Site Investigation Requirements for a Deep Repository: In Geo-Engineering of Hazardous and Radioactive Wastes. - EEG-97 3rd European Engineering Geology Conference, Newcastle. Reeves GM in Report:- Radioactive Waste- The Way Forward. July Contrib. Author. Reeves GM in Report RWMAC- Spanish Radwaste Programme; Study Tour, October Contributing Author. July 1998.DETR, London HMSO ISBN ;53pp Reeves GM in Report RWMAC- Joint Author:- RWMAC Advice to the Minister (Rt Hon. Michael Meacher) on:- Scope & Content of the Core Scientific Research programme on Intermediate Level Waste Disposal. October HMSO, London Reeves GM in Report RWMAC- Review of Radioactive Waste Practices at Dounreay NRE, UKAEA Hydrogeology and Geotechnics- GM Reeves, Lead Author. (September 1998) RWMAC- Review of Radioactive Waste Practices at Dounreay NRE, UKAEA. ISBN/ISSN X Reeves GM. A review of borehole geophysical methods for engineering applications, geotechnics and hydrogeology at UKAEA sites:- Down-hole Identification of Remediation Targets.Research Reports for UKAEA Gautschi A, Gustafson G, Lloyd J. & Reeves GM:- Hydrogeology of Sellafield RCF Site- UK Nirex Research Programme, Report of Independent International Review Panel. January 1999 Baseline Groundwater Pressures & Hydrochemistry-Hydrogeology of Sellafield RCF Site - UK Nirex - Research Programme ISBN/ISSN Reeves GM, contributing author. RWMAC Review of Radioactive Waste Practices at Dounreay NRE, UKAEA. Hydrogeology and Geotechnics Reeves GM joint author. RWMAC Advice to Ministers on The Ministry of Defence s Arrangements for Dealing with Radioactively Contaminated land. ISBN ; 56pp Reeves GM, and Reeves HJ Cross-over Technologies from Hydrocarbon exploration to Geotechnics and Hydrogeology in Crystalline rock- Geological Society Petroleum/Tectonics Gp. Special Publications of the Geological Society Reeves GM, Reeves HJ & Cocco P, On The Identification and Characterisation of Discontinuities in Igneous and Sedimentary Rocks. Invited International Refereed Conference Paper. Seventh International Symposium on Minerals and Geotechnical Logging (SPWLA/MGLS), Reeves GM :Application of Geophysical Logging Techniques to Geotechnical and Hydrogeological Investigations, University of Newcastle upon Tyne, UK Thesis submitted 2004 covering over 25 years of research into the application of geophysical logging techniques in hydrogeological and geotechnical applications, leading to PhD award. Reeves GM. Applied Geophysics: Special Publication on Geophysical Logging for Minerals and Hydrogeology; Geophysical Logging Handbook. Geological Society. 2008, in preparation. Catlow FC & Reeves GM: Education in Nuclear Decommissioning in the North of Scotland. Paper ICEM : Proceedings 11 th International Conference on Environmental Remediation and Radioactive Waste Management. Bruges, Belgium Sept Reeves, GM On the legacy of the Hester Pit Disaster (16 January 1862)- in the context of Deep Geological Disposal Research in the UK. : Materials Research Society- Symposium on the Scientific Basis for Nuclear Waste Management. Sheffield, Sept 2007 Matheson, GD and Reeves GM; The Identification, Appraisal and Assessment of Hazards on Quarry Rock Faces in terms of the UK Quarries Regulations: Quarterly Journal of Engineering Geology and Hydrogeology (Geological Society London) Quarterly Journal of Engineering Geology and Hydrogeology 2011; v. 44; p gmr January

66 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Appendix B. Comparable Studies 1. Previous Work in Canada The Bruce Site Site investigation work for OPGs DGR at the Bruce Site near Kincardine in Ontario commenced in 2006 and was completed by (Figures 1 and 2 from Geology TSD Report, Golder Associates March 2011) From the start of geological investigation of the DGR repository zone (the Study Area- Figure 1, Geology TSD Report), only 4 vertical boreholes (DG-1, DG-2, DG-3 and DG-4) have been drilled to investigate the deep rock, repository zone geological, geotechnical and hydrogeological environments. The investigated area lies at the centre of OPGs Bruce NPP site (Figure 2) Borehole DG-1 did not reach the proposed disposal depth of 680 metres. (ie. DG-1 :Total Depth- TD at 462m., only reached the upper section of the Upper Ordovician Queenston Formation (see Figures 3 and 4; From Geology TSD Report, Golder Associates March 2011). Therefore only a very limited (projected to DGR proposed depth) surface area, and very restricted volume of rock at that depth, have been investigated by OPGs deep drilling program of 6 boreholes, into the Proposed Repository Horizon in the limestones of the Cobourg Formation at 680 metres depth. Vertical Boreholes DGR-2 (TD. 862m), DGR-3 (TD. 869m) and DGR-4 (td. 857m) were all drilled to the base of the Mid-Ordovician strata and into the underlying Cambrian fine- to medium-grained, silty sandstone and sandy dolostone. Only borehole (DGR-2) was drilled 1.55 metres into the Pre- Cambrian granitic gneiss. No testing or investigations into the suitability of the crystalline Pre- Cambrian Basement were apparently planned or intended at the Bruce site by OPG, despite this additional Potential Repository Zone (PRZ) being only 200 metres or so deeper than the planned (and still inadequately characterised) Proposed PRZ in the Cobourg Limestones at 680 metres depth Below Ground Level (BGL) at the Bruce PS site. (Figure 4: From Geology TSD Report, Golder Associates March 2011) In the course of the Bruce Site characterisation, carried out by Golder Associates for OPG between 2006 and 2010, no off-site ( far-field or even outer near field ) boreholes were drilled, logged or tested. Therefore no large scale long-term groundwater modelling for the Bruce location and surrounding region, can been realistically have been undertaken by OPG. If this had been attempted, the potential for flow of deep connate groundwater eastwards towards the outcrop of the Cobourg Formation some 86 kilometres to the East on the southern shores of Georgian Bay could have been assessed and investigated more thoroughly and with greater accuracy and reliability. (It should be noted that in Figure from the Geology TSD report, the horizontal scale is incorrect. The 50 kms stated should be 20 kms, giving the approximate 86kms. distance to outcrop of the Cobourg Formation in the South of Georgian Bay. (See Figure 5, below). 23

67 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. AECL s NFWMRP to Fieldwork Programs and Research Areas The Research Program of Atomic Energy Research Company into Deep Geological Disposal, Part of the Canadian Nuclear Fuel Waste Management Research Program (NFWMRP), 1979 to In this section, the Canadian research programme (from 1975 to 1996) into research area studies and site investigation methodologies for underground nuclear waste disposal investigations, are considered and summarised, as previous Canadian work which should be considered in view of OPGs DGR proposals at Bruce PS, and especially with respect to the Alternate Locations Reports. In particular, the Underground Research Laboratory (URL) in Manitoba and the hydrogeological monitoring work that was undertaken to establish equilibrium conditions prior to shaft construction, are discussed. This work is of particular relevance to the proposed OPG DGR, due to the necessary investigations and experimental work which was undertaken to validate models of the impact of shaft disruption on groundwater conditions, with the creation of a long-term database of baseline undisturbed groundwater conditions prior to construction of the URL and its shafts, galleries and rooms. Of particular relevance are the problems associated with establishing baseline conditions that arose due to seasonal climatic fluctuations. Background In 1976 the Geological Survey of Canada, working for Atomic Energy of Canada, Research Company, produced a report which identified 52 igneous intrusions (plutons) in the Canadian Shield which it recommended were worthy of further investigation as Research Areas (RAs) as potential locations for the deep geological disposal of Canada s radioactive wastes, including unprocessed used fuel assemblies. (Brown, 1976.GSC) Detailed, sometimes updated, surface geological mapping was carried out on many of these locations, where existing maps were poor or absent. From this work 12 locations were identified for further work involving geophysical surveys, detailed ground truthing and borehole drilling, logging and testing. One of the major objectives of the research programme was to develop characterisation techniques for large volumes of crystalline rock dominated by fracture flow groundwater regimes. This work was undertaken in order to assess the suitability of rock masses to act as barriers to radionuclide migration. Atomic Energy of Canada Limited (AECL), in cooperation with the Geological Survey of Canada, and geophysicists from Energy Mines and Resources, Canada, developed a wide variety of airborne, surface and borehole techniques and targeted methods in the late 1970s and early 1980s to investigate geotechnical and hydrogeologic properties, especially in crystalline rocks of the Canadian Shield. They then applied many of these methods at a number of the RAs (research sites) at a variety of different locations throughout the Canadian Shield. (Davison 1994). Locations where work has been carried out are shown in Fig. 6 (below) The Ontario Research Areas. Between 1975 and 1996, AECL Research Company, with the support and assistance of the GSC, and the EMR Earth Physics Laboratory, drilled, logged and tested over 90 boreholes at 12 Research Area (RAs, See Figure 7) locations in plutonic crystalline rocks throughout the Canadian Shield. Most of these boreholes were instrumented (mostly using the Canadian Westbay Multilevel completion systems) and some were monitored over time periods of up to 20 years. None of this information has apparently been assessed as any part of OPGs DGR investigation programs from

68 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 7: AECLs Research Areas: 1975 to 1996 AECL's field research on site evaluation methods for plutonic (ie. Crystalline rock masses) in the Canadian Shield) began in 1975 with investigations at White Lake, SW of Arnprior near the Ottawa Valley. The work at White Lake finished in 1976 and simultaneous investigations began at Chalk River Nuclear Laboratories (CRNL) and at Whiteshell Nuclear Research Establishment (WNRE) in Investigations at the Atikokan and East Bull Lake sites were initiated in 1979 and 1981 respectively. Routine long term monitoring of hydrogeologic conditions was maintained at the Atikokan and East Bull Lake sites since investigations began up to the termination of AECLs program in Work continues at the Whiteshell site under the current decommissioning program for the site with monitoring of the original multi-level Westbay systems in boreholes WN-1 to WN-5. This work is distinct from that carried out at the now-decommissioned Underground Research Laboratory (URL) site, which was 20 kms to the north of WNRE, near Lac du Bonnet, also in Manitoba. The early site evaluation research work at White Lake, Chalk River and Whiteshell was aimed at developing and testing equipment and methods to measure the physical and chemical characteristics of crystalline rocks at a relatively small scale of investigation i.e. within individual boreholes. Following this initiative, research took two directions. One direction was in developing methods for characterising crystalline rocks and their surroundings at the larger regional scale (500 to 1000km2; and up to 1.0 km in depth. The other direction was to characterise near-field conditions in rock and to determine changes caused by excavation within the rock. 25

69 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. This work was focussed by the construction of AECLs s Underground Research Laboratory (URL) near Lac du Bonnet in Manitoba. The initial agreement for this research program with the Manitoba Provincial Government required that no radioactive wastes would be taken underground during the research program, as Manitoba had no nuclear power stations and hence no requirement for nuclear fuel waste disposal. Sub-surface conditions within the rock mass at the URL site were investigated by an extensive drilling programme prior to the construction of the shaft at the URL site. Since 1980, a comprehensive program of cored, inclined borehole drilling investigations was carried out at the URL site. The initial objective of the site evaluation program was to select a site for the shaft and underground facilities of the URL that would maximise the options for future experiments. In addition, preconstruction hydrogeologic conditions were defined at the site in order to predict the perturbation that would be created as the URL shaft was constructed. A detailed network of instrumentation was installed in the extensive borehole network in and around the URL site to monitor the response of groundwater and rock condition responses during construction and operation of the facility. Hydrogeologic Site Investigations at the URL Site (Figures 8a and b). Drilling and shallow water table monitoring began in 1980 with the construction of 59 shallow "overburden" (O-Series; Nos 1 to 59) boreholes with depths of up to metres. Work continued from May 1981 to August 1982 with the drilling of a further series of shallow "bedrock" (B-series Nos. 1 to 44) boreholes. As these were completed, daily and weekly groundwater level measurements were taken and the boreholes were systematically included into the growing groundwater monitoring network. The data base, software development and scope of this network was operated continuously from 1981 is described in AECL TR-248 (Daymond 1985). The TR-248 series of reports were published from 1981 to the closure of the URL site in TR (Daymond 1995), reported 177 monitoring points in over 120 surface boreholes at the URL site, in an area of 3.8 square kilometres. A series of nineteen large-diameter (156 mm) air-percussion boreholes (Nos. M-1 to M14) were drilled during 1982 (Reeves 1983 and 2004) at the URL site to complete the monitoring network. The locations of these boreholes are as shown in Figures 8 a and b. Groundwater testing and monitoring at the URL site presented a unique opportunity to monitor the perturbation created in the groundwater regime by the construction of the shaft. Based on the measurements made during the hydrogeological site investigation predictions were made of the hydrogeologic disturbance that would be created in the area due to construction of the URL shaft. Actual conditions in the rock mass were monitored during the construction and development of the shaft which commenced on Saturday 12th May 1984 and reached the shaft bottom (240 metre level) on Saturday March 2 nd A report of the Excavation Drawdown Experiment with a comparison of Predicted Seepage and Drawdown against Field Measurements is given in Davison (1995). Difficulties were found in comparing the actual data measured following shaft construction with the predicted measurements as there was insufficient record of the fluctuations in baseline that arise due to climatic fluctuations. Although there was some pre-construction record of the fluctuations caused by seasonal climatic variations these were inadequate for modelling purposes. (Davison 1995). It was noted that; "One difficulty in comparing the actual hydraulic head changes to those predicted by the flow models was associated with establishing baseline values."(davison 1995) It was a fundamental conclusion of this work that a sufficient period of time should be allowed such that the pattern of seasonal climate variation in groundwater baseline values could be established. The Underground Research Laboratory (URL) Site and Boreholes. 26

70 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 8a- The URL Site and Boreholes, Lac du Bonnet, Manitoba.(From AECL-10711) Figure 8b- The URL Site and Boreholes, Lac du Bonnet, Manitoba. The Atikokan Research Area (RA 3- Eye-Dashwa Lakes Area, W. Ontario) (Figures 9 & 10) 27

71 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Extensive drilling and core logging was carried out at the Atikokan site in Western Ontario to characterise this pluton- a granodioritic rock mass- in the greenstones of the Canadian Shield. Early exploration, including the drilling of five NQ-3 wireline core-drilled boreholes (ATK 1 to ATK-5), was carried out in the 1982 and 1983 field seasons. Boreholes ATK-6, 7 and 8 were geophysically logged in the autumn and winter of 1985/6 by the AECL-GSC hydrogeophysics group. Routine long term monitoring of hydrogeologic conditions continued at Atikokan with multiple completion systems installed in most of the 8 deep boreholes on the site. Groundwater records were thus available for over 16 years of research activity at this site. Figure 9 :The Atikokan Research Area (RA 3- Eye-Dashwa Lakes Area, W. Ontario) 28

72 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 10- East Bull Lake- RA7; W of Sudbury, Ontario. East Bull Lake- RA7; W of Sudbury, Ontario. (Figure 10) In the autumn of 1983 investigations were begun at the East Bull Lake site, West of Sudbury, Ontario. Hydrogeological testing was carried out in four deep boreholes and fourteen shallow boreholes. Investigations included drill water tagging, single and straddle packer testing, open hole pump testing and production injection packer installation in the deep diamond cored boreholes and open hole pump testing and groundwater sampling in the shallow boreholes. Diamond core logging, geophysical logging, acoustic televiewer fracture logging and borehole thermal logging data were included in the site assessment. All 18 boreholes were drilled in a 4 km2 area selected for detailed hydrogeological study. Since major structural discontinuities and lineaments are important in groundwater flow system investigations, terrain analysis based on extensive air photo mapping was carried out over the research area. Major lineaments (those greater than 1 km long) and minor lineaments were identified. These major features were intersected by both the deep boreholes and the shallow boreholes. Further hydrogeological testing was carried out between 1986 and 1988 and routine long term monitoring was continued at the site until the end of AECL s Research Program. 29

73 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 6: (Fig2,from AECL-10711)]. Full details of the Canadian approach are given in the Environmental Impact Statement on the Concept for Disposal of Canada s Nuclear Fuel Waste (AECL-10711) and associated supporting references and documentation, published by AECL in Chalk River This location has been the site of AECL s main research laboratories since the end of the Second World War. In 1986 over 100 boreholes were in existence on the site. Some of the early development work into the Canadian slim-hole (NQ-3 size; 76 mm dia.) wireline cored borehole drilling techniques and associated multiple completion monitoring systems (manufactured by Westbay of Vancouver, now owned by Schlumberger) was carried out in the deep boreholes, CN1 to 5. This work was largely carried out from 1979 to Work on the deep boreholes at this site was discontinued in White Lake This site was the first location away from Chalk River investigated for AECL by the Geological Survey of Canada (GCS) and Environment Canada. Work commenced in 1975 and, with only limited drilling and field mapping completed, was discontinued in 1976 as AECL Research Company was building up it s own in-house research team. 30

74 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Appendix C : A Comparable DGR Investigation Program to OPGs Bruce Site: An example of Another DGR Characterisation Program; The Rock Characterisation Facility of UK Nirex (1986 to 1996): Longlands Farm, Cumbria UK. Between 1986 and 1996, UK Nirex spent an estimated 526M characterising a large area of the West Cumbrian coast adjacent to the Sellafield site (Figures 1-1,1-2 and 1-3) in North West England. This was to investigate the Longlands Farm site, adjacent to Sellafield as a potential Rock Characterisation Facility (RCF) which would eventually become the UK Deep Geological Repository for ILW and Long Life LL radioactive wastes. Figure 1. The UK Nirex RCF investigation area, Borehole Locations and seismic survey coverage. 31

75 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Overall an area covering approximately 800 square kilometres was investigated with 28 boreholes drilled (plus one old coal exploration borehole, refurbished- See Figure1-3) and many hundreds of kilometres of seismic survey lines obtained. (Figure 1-2). The UK Nirex Hydrogeological Site Investigation Programme. The Nirex site investigation programme included over 25 kilometres (nearly 16 miles) of drilling. (Chaplow, 1995). However, uncertainties associated with the underlying hydrogeological parameters of the baseline groundwater modelling remained after considerable testing, logging and monitoring in many zones in all 29 boreholes. Thus statistical methods were used by Nirex to generate a significant amount of the hydrogeological data used in their groundwater modelling. Criticism by the Royal Society in November 1994 of UK Nirex s programme stated that."the Nirex timetable for characterisation of the Sellafield site and assessment of its suitability for construction of a deep repository for long-lived wastes is tight by international standards. Their target date of 1998/9 for decision on whether to apply for planning permission for repository construction is, in our view, optimistic. We doubt whether they will be able to produce by then an assessment of post closure repository performance of the high scientific quality that will be needed." (Royal Society 1994). One main lesson learnt from the UK Nirex investigations was in respect of the required length of groundwater monitoring records. To ensure accuracy in groundwater modelling, statistically derived data should be supported by an extensive set of real measurements for all hydrogeological zones incorporated in the groundwater modelling work, especially for performance safety case assessments. In order to obtain an adequate set of groundwater data an adequate period of time must be allowed such that a sufficient number of boreholes may be drilled, and that they may be monitored for a sufficient period of time. The first set of groundwater testing data was obtained during the drilling programme. The main set of measurements of environmental pressure head at Sellafield dated back to the period of drilling which commenced with Borehole No 2 and continued with major drilling contracts from August 1990 to December This work was carried out with a high degree of professional competence by KSW Ltd. (the Kenting-Soil Mechanics - Gewerkshaft Walther consortium). However, measurements of environmental pressure heads and permeability taken during and shortly after drilling are only exploratory measurements of these parameters. To address this problem more detailed testing of specific zones was carried out by Golder Associates. The data acquisition and analysis was to a high standard, and the techniques and equipment used were State of the Art. The longest record of continuous hydrological monitoring of groundwater from any of the deep Nirex boreholes extended to two years eight months for one borehole (Borehole 7A- Multiple completion system installed in January 1993 ). Although some manual records went back to December 1992, other records (Nirex Reports Nos. SA/95/002, 263 and 524) were of a very short duration (2.5 years maximum for the longest manual record, BH 7A). Moreover, many of these records are apparently incomplete, due to system malfunctions and interference from pumping tests. Complete monitoring in the PRZ, RCF and RCM boreholes commenced in January 1995 when the Canadian Westbay MOSDAX- Multiple Observation Data Acquisition'- systems became operational in boreholes PRZ2 and PRZ3. Only boreholes RCM1, RCM2 and RCF2 provide 12 months of records (from August 1994). 32

76 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. UK Nirex s Geological Programme Coverage In-hole investigations within the deeper formations, and particular in the Borrowdale Volcanic Group of rocks (BVG) were considered to be reasonably complete and thorough. Techniques were developed and adapted from oilfield, mineral exploration and specialised geotechnical work for Nirex by their drilling, logging and testing contractors. They have since been recognised, internationally, as highly advanced and innovative, and at the leading edge of these methods for deep geologic investigations. However, detailed geological and groundwater data was considered sparse for the shallow superficial horizons and shallow bedrock to 150 or so metres. This was especially the case in the intermediate field area of the proposed RCF shaft site (from 0.5 to 5kms). The data was sparse, both in density of coverage and also in period of record from these areas. Over a period of 66 days from September 1995 and February 1996 there was a public inquiry at Cleator Moor, Cumbria into an appeal by United Kingdom Nirex Limited, Britains nuclear waste disposal body, against the refusal of Cumbria County Council to grant planning permission for a 'Rock Characterisation Facility' on land at Longlands Farm, Gosforth, Cumbria. After the Public Inquiry, the Planning Application and proposal by UK Nirex to develop the Longlands Farm site as the UKs RCF was turned down. The RCF was intended to demonstrate the practicability of a deep underground radioactive waste repository, which UK Nirex hoped could eventually be located alongside. The site is close to the Atomic Energy Authority's Sellafield works and just outside the Lake District National Park boundary. The scheme would have involved sinking two 5m diameter shafts to depths of up to 1020m and opening out galleries in the Borrowdale Volcanic Group of rocks from and in which extensive scientific and engineering investigations and experiments would be conducted. The inquiry heard detailed evidence from Nirex, and from objectors including Friends of the Earth, Greenpeace and the Irish government. Early in 1997 the Rt. Hon. John Gummer, Secretary of State for the Environment, formally rejected the Appeal. More than 10 years of work and over 500 hundred million pounds of research, investigations and planning by UK Nirex were ended and no Deep Disposal Facility exists to this day for UK radioactive wastes. 33

77 Study of Alternate Locations: OPG-DGR- Geotechnical and Hydrogeological Considerations. Figure 2: The NRA monitoring network for the Sherwood Sandstone aquifer. 34

78 Appendix 2

79 ABSTRACT This document examines the Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations for realistic assumptions and usefulness Review of Ontario Power Generation s Report: Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations Fred Dilger Ph.D. Black Mountain Research

80 Executive Summary The Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations (CREPT) report is a generic risk assessment and a high-level cost assessment of shipments from a waste management facility at the Bruce Nuclear Generating Plant to a hypothetical Deep Geologic Repository (DGR) at an unspecified location. The report provides a generic risk assessment and a high-level cost assessment of the shipping program. This review of the CREPT report concludes that the methods used do not conform to best practices for the transportation risk assessment of radioactive materials. For example, the cost assessment is so narrow that its conclusions may be lead to significant underreporting of actual costs. The report uses a generic methodology to assess risks and costs. The Report Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations suffers from a problem common to many such estimates. The report assumes that radioactive materials transportation is straightforward and does not deserve a high degree of focused attention. The report does not provide specifics regarding routes, unique local conditions, response preparation, or coordination with local communities. While the report contains detailed information about equipment and personnel costs, it ignores the many other issues that will be associated with the shipment of these materials. The report does not provide a meaningful response to the Ministerial request for additional information Introduction This report contains a review of the Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations (CREPT) report published by Ontario Power Generation in December of It begins by describing the request for additional information, including about alternate locations to a proposed deep geological repository for low and intermediate level radioactive wastes. The request was made by Federal Minister of the Environment and Climate Change, the Hon. Catherine McKenna, in February This review considers the contents of the CREPT report by comparing it to the information requested by the Minister, it describes the proposed action, and then examines the risk assessment and cost assessment portions of the CREPT report. It critiques the risk assessment and the cost appraisal portion of the CREPT report. This review concludes that the CREPT report was prepared with insufficient P a g e 1 12

81 methods, data and information. As a result, the CREPT report is of limited value. This report concludes with suggestions for improving future efforts of this type. The Requested Action In February 2016, the federal Minister of Environment and Climate Change requested additional information before a final decision was made on the Environmental Assessment of Ontario Power Generation s proposed Deep Geologic Repository (DGR) at the Bruce nuclear site in Kincardine, Ontario. In particular the Minister requested: A study that details the environmental effects of technically and economically feasible alternate locations for the Project, with specific reference to actual locations that would meet OPG s criteria for technical and economic feasibility. In conducting this study, OPG is to detail the thresholds for what is considered to be technically and economically feasible. In addition, OPG is to indicate what the incremental costs and risks would be for additional off-site transportation of the nuclear waste. In response to OPG s letter dated April 15, 2016 describing OPG s proposed approach to responding to the Minister request, the Canadian Environmental Assessment Agency (Agency) provided clarification as follows: [OPG] has indicated that it intends to provide an assessment of the environmental effects of two technically and economically feasible geologic regions in Ontario, specifically in a sedimentary rock formation in southern Ontario and in a granite rock formation located in central to northern Ontario, without providing specific reference to actual locations.... the Agency requests that the analysis of the environmental effects of the alternate locations to be provided by OPG provide a narrative assessment that does not assume that alternate sites in the geologic formation would have the same geographical and hydrological characteristics of the preferred site. On behalf of Ontario Power Generation, Energy Solutions Canada produced a report titled Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations, 1 which is the subject of this review and will be hereinafter referred to by its abbreviated title of the CREPT report. 1 Cost and Risk Estimate for Packaging and Transporting Waste to Alternate Locations, December 2016, Prepared by: Energy Solutions Canada, OPG CD# REP R000 P a g e 2 12

82 The CREPT report describes the costs and risks associated with packaging and transporting approximately 150,000 cubic meters of radioactive waste from the Western Waste Management Facility (WWMF) to an alternate location that is not located on the Bruce Nuclear site 2. The CREPT report estimates the costs needed to transport the wastes on public roads to a low level and Intermediate Level Waste (L&ILW) at a distance from the Western Waste Management Facility which is located at the Bruce nuclear site. Consistent with other reports filed by OPG in response to the Minister s February 2016 request for additional information 3 the CREPT report identifies two geological regions as alternate locations. To perform the risk and cost estimates the report used two scenarios with different DGE opening years and different distances. It estimates distances of 100 km and 300 km for the 2045 scenario in the sedimentary region and 200 km and 2000 km for the 2055 scenario in the crystalline region. The CREPT report acknowledges it does not provide specific transportation information. The description of what OPG proposes to do contains a number of substantial uncertainties. These are acknowledged in this report: Specific transport planning, including route selection, and logistical planning and scheduling have not been developed for purposes this study. Numerous assumptions and judgments are made throughout this study based on available inputs and industry OPEX to accomplish the objectives of this study to develop the respective indicative cost estimate and to assess risks. These assumptions and judgments likely introduce uncertainties into the cost estimate results, e.g., variability in the type and quantity of transport packagings needed and truck transport cycle times. For purposes of this estimate, cost adjustment factors are used for each waste category to account for such uncertainties. (Page 7) This is unfortunate because risk and cost information are highly sensitive to the quality of information included. The conclusions reached by the CREPT report may not be valid and the OPG may not know why based on the contents of the report. While the ultimate site of the DGR is unknown, the Bruce site is known. The possible alternative routes are few and easily identified and measured. The CREPT report should have provided an estimate of the number of shipments to each site. The report does not provide 2 Page 1, CREPT Report 3 See, for example, Ontario Power Generation s Study of Alternate Locations, Main Submission 0216-REP , December 2016 P a g e 3 12

83 a map displaying where the waste is or to where it will be transported. It is readily possible to identify locations and measure distances required to transport the waste. Waste Waste Container 2045 Containers 2055 Containers Description Low Level Waste Low Level Waste 90% packaged in NPB-47 6,150 6,508 Containers (P 17) 10% in IP-2 Transport Packaging Low Level Storage NPB-4 Non-Pro Bins 2,446 2,446 Containers (P 18) Bruce Steam Type IP-2 or Type A Generators (P19) packaging Trench Waste (P20) NPB47 no-pro boxes Model DBINI drums bins Heat Exchangers Type IP-2 Freight containers (P21) Unshielded Type IP-2 version Intermediate Low Level Waste IC-2 Tile holes with Fixed Waste Liners Waste (P 22) New shielded containers MSC (Type A/B) 17 Approx 5 type A Approx 12 Type B 17 Approx 5 type A Approx 12 Type B IC Tile holes with removable liner waste (P24) New shielded containers MSC (Type A/B) 66 Approx 20 type A Approx 46 Type B 66 Approx 20 type A Approx 46 Type B Quadricell resin liners (P25) Trillium flask Type B shielded cask 98 Approx 29 type A Approx 69 Type B 98 Approx 29 type A Approx 69 Type B IC-18 Tile Hole Equivalent Liner Waste (P26) New shielded containers MSC (Type B) 616 Approx 184 type A Approx 431 Type B 698 Approx 209 type A Approx 488 Type B Resin Liners (P27) Type B packages 1,771 Approx 184 type A Approx 431 Type B 1,946 Approx 184 type A Approx 431 Type B P a g e 4 12

84 Grouted Tile Hole (P 28) Type A Intermodal Freight Container Type B Conceptual model 43 Approx 184 type A Approx 431 Type B 43 Approx 184 type A Approx 431 Type B Bruce Retube Waste Containers (P29) Bruce Retube Waste Containers 306 Type B EF waste 102 Type A EF waste 26 Type B with PT/CT/CTI waste 38 Type A with PT/CT/CTI waste 306 Type B EF waste 102 Type A EF waste 26 Type B with PT/CT/CTI waste 38 Type A with PT/CT/CTI waste Darlington Retube Waste Containers (P 31) Retube Waste Containers/ End fittings/ Pressure Tubes 474 Type B 474 Type B Table 1 Summary of the waste types evaluated by the report The report provides a separate description of the waste types used for report estimates. It provides estimates of the shipment numbers and activity. It is unclear how the different waste types were classified. For example, is CANDU reactor fuel channel waste appropriately classified as ILW? It also reveals that there are unknown waste types that must be classified and shipped. How many casks will need to be procured and when will they be available. The implications of this waste type is uncertain. The CREPT should have provided a specific description of the radiological hazards. This is common practice widely used. Failure to do so suggests that the waste forms have not been characterized well. P a g e 5 12

85 The Risk Assessment The risk assessment contained in the report suffers from a lack of detail that makes it a poor guide to understanding the hazards of transporting the materials. There are three categories of shortcoming with the risk assessment in the report: The first is the absence of method. The second is the generic nature of the assessment. The third is the uncertainty related to risk assessment. It is important to point out that radiation decays over time and that Canadian reactors do not rely on enriched fuel. The very substantial amount of time before the waste is shipped (30 to 60 years) and the relatively low radiological activity means that the hazard being examined by the report may be small. If so, the CREPT report should make that clear. However, some of the wastes in particular the intermediate level wastes are very active. This should also be more clearly presented. Method The first official probabilistic risk assessment for nuclear materials was completed in 1975 (Nuclear Regulatory Commission, 1975). Since that time, there have been numerous official risk assessments prepared for radioactive materials. Widely accepted methods and extensive data have been developed to prepare these reports (Department of Energy, 2002) (Rhyne, 1994). When evaluated in this context, a notable failure of the CREPT report is that it does not define what risk means in this context. It is unclear whether what the CREPT report means by risk can be can be inferred by its referencing of the US Department of Energy s (DOE) Resource handbook on DOE transportation risk assessment as a reference. The formula for risk used by the DOE is that the risk is equal to the probability of harm multiplied by the consequences of an accident. If that is the case, then the method used in the report may follow accepted practice. However, it is not possible to confirm this based on the CREPT report. It is also not possible to conclude that the report provided a realistic appraisal of the consequences of a release for the various types of materials. Instead the report seems to combine all of the radiological consequences and place them into a single summary table (P 40). This is not consistent with accepted methods. It is important to recognize that millions of shipments of radioactive materials are shipped around the world. These shipments are made in robust containers that prevent release of the materials. It is equally P a g e 6 12

86 important to recognize that each shipping program, each shipment is unique. The record of successful shipment is only possible due to extensive, sustained effort. Only constant vigilance enables radioactive materials shipments to be successful and there is no guarantee for future performance. Industry data shows that about 20 million packages of all sizes containing nuclear materials, which includes radioactive waste similar to that residing at the WWMF, are transported around the world on a regular basis via public roads, railways, waterways and even by air (P 36). The CREPT report is characteristic of reports of this type in its tendency to emphasize success of other agencies activities. While there is a successful international record, that record is not what is being evaluated here. One issue with the report is that it relied on references from Germany. The German program relies heavily on rail, while OPG s program specifically highlights truck as the mode used for shipment (P 6). This is also true of the distances shipped. The German program shipped waste very short distances. This is not the case for the proposed OPG program. Another shortcoming of reports of this type is that they focus on the probability of an accident instead of its consequences. The tendency is for industry and regulators to focus on the probabilities, while stakeholders focus on the consequences. This difference explains a great deal of the divisions that exist over the transportation of these wastes. The CREPT is emblematic of this approach. The only stated consequences in this report appear to be a summary of the increased dose. A better approach would be to acknowledge the hazard, the complexity of addressing it and describe the ways in which risks can be mitigated, minimized or avoided. The CREPT could easily have estimated the total loaded kilometers shipped and using Ontario heavy truck accident characteristics, provided a credible estimate of the numbers, types, and severity of the accidents that would occur over the course of the shipping campaign. Generic Method There have been a variety of different generic transportation risk assessments for radiological materials (NRC). The preliminary approach taken by the report is similar to the generic type of risk assessment prepared by US agencies. However, even the generic approach employed by US agencies included substantially more detail than this report. These risk assessments have adopted a variety of techniques. One of the most useful generic methods has been to establish upper and lower boundaries of the impact. For example, by determining the maximum number of shipments and a maximum dose, it is P a g e 7 12

87 possible to evaluate the maximum possible effect of the proposed shipping program while relying on very general data. The CREPT report could also have assessed the effect to a Maximally Exposed Individual establish an upper boundary of the health effects. The CREPT report could also have defined a maximum accident to establish an upper boundary on how severe an accident could be. These techniques are not new, they are not poorly understood, and they do not require large expenditure of time and effort. However, the CREPT report did not include either of these assessments. The generic method adopted fails to support the conclusions of the report. The broad assumptions made in the report about the waste types, hazard, and transportation plan make the quality of the risk assessment suspect. Reliability of Data The problem of detail in risk assessments is not new. The more specific information in a risk assessment, the better the quality of the assessment. A review of Probabilistic Risk Assessments of nuclear power plants found that the risk number varied substantially from plant to plant (Garrick, 1985). Risk assessments prepared using the specific information (e.g. specific wastes being transported, the casks used, the routes and modes) would have more validity than the generic approach taken by CREPT report. The conclusions reached are not valid and not reliable. A problem with assigning a numerical value in a case like this is that the number is so unreliable it cannot be used for decision making. The risk numbers presented in Table 2-1 are merely multiplication. The CREPT report creates a greater problem in that does not address the uncertainty in such estimates and creates a false sense of security that is harmful. The CREPT report acknowledges the there is uncertainty in its estimates, for example: Given this and engineering judgment, the following general transport packaging assumptions are made: For all LLW, 90% qualifies for Type IP-2 packaging, with the remaining 10% requiring Type A packaging. Except for fuel channel waste, 70% of all ILW requires Type B packaging, with the remaining 30% qualifying for Type A packaging. For existing fuel channel ILW, 50% requires Type B packaging, with the remaining 50% qualifying for Type A packaging. For fuel channel ILW generated by future reactor refurbishments, 100% requires Type B packaging P a g e 8 12

88 The need for these assumptions suggests that more waste characterization is necessary. The portion of the report that deals with the risks of transporting the waste does not provide sufficient detail to assess its validity. One example is that the CREPT report assumes a population density of two people per km (P 40). Using publicly available data from Census Canada it is possible to show that the population densities of the areas surrounding the nuclear power plants and along likely routes are greater than 2 persons per km. Uncertainty Another major problem with the CREPT report, and transportation risk assessment in general, is the problem of calculating probabilities and uncertainty with very limited data (Golding). The problem of uncertainty regarding the estimation of the final risk number is not considered by CREPT report. Instead, the report promotes its numerical calculation as if they are absolute values, and that the calculations contain no uncertainty. The risk numbers in table 2-3 of the CREPT report presents a simple multiplication that reveals nothing. A major part of the problem is the uncertainty surrounding these events, a review of PRA s found that initiating events are poorly understood and likely to remain inscrutable partly because of the initiating events ( ). For example, the earthquake that caused the tidal wave that triggered the Fukushima crisis is one example. The same problem is present in the discussion of transportation risk; if the initiating P a g e 9 12

89 events are not understood, and the extent of release and exposure are not understand, no reliable estimate can be made with respect to risk or consequence. This is why PRA is most effectively used ex post facto. A critical misunderstanding about probability lies in its application. Probability is different from statistics. Probability makes statements about the likelihood of an occurrence when a sample is DRAWN FROM A KNOWN POPULATION. Statistics refers the process of drawing samples and making inferences when the samples are DRAWN FROM AN UNKNOWN POPULATION. The CREPT report argues that its calculations include all of the possible probabilities of an accident and therefore it properly assesses the consequences of accidents as well. For example, they would say that the problem is defined as to whether or not a cask will fail. The deficiency of this point of view is seen in the aftermath of Fukushima. The CREPT report fails to answer basic questions. Among the questions a more exhaustive report (the CREPT report does not claim to be exhaustive) would provide answers to the following questions are: What are the specific radiological characteristics of all of the waste forms proposed for transportation? What will be the effects along the routes? What are the potential routes, including potential congestion route to a DRG? What are the routine doses from on-link, off-link, and occupational doses? What are the consequences of the worst foreseeable accident? Given current heavy truck accident rates, how many OPG shipments will be in accidents? Who is affected by the shipments? What will it cost to prepare for shipments? What will it cost to recover from a severe accident or sabotage? What unique local conditions effect risk? Issues with the cost estimate The CREPT report provides cost estimates only at the very high level. The estimates, however, are flawed by the imprecision of the waste characterization. It is clear from the text that the proportion of Type and A and Type B containers used by OPG s program is based on engineering judgement rather than careful waste characterization. This lack of precision in the estimates makes the value of this portion of the report of limited value. Some unanswered questions are: P a g e 10 12

90 What are the costs of producing licensing and testing the MSC What is the cost to recover from the most severe accident involving these shipments? What is the cost to design license and test the MSC or other waste packages used for these shipments? What is the cost for localities to prepare for these shipments? What is the liability of local communities through which these shipments will pass? How great in percentage terms are the uncertainties in the cost estimates? What Aare the upper and lower bounds of the estimates? Preparation costs Package and handling costs Based on the information contained in the CREPT, the costs of the program are currently not known. Among the issues are: uncertainty about the waste characteristics, the numbers of containers of each type required, handling and repackaging equipment required, the manufacture and testing of the MSC. Conclusion The CREPT report did not provide an answer to questions asked. The generic nature of the assessment limits its usefulness. The lack of precision in the risk assessment limits the value of the report. The report does not provide an appraisal of the risks that is sufficiently detailed to use as the basis for decisions. In order for risk assessments to accurately represent reality they must be precise as possible. In this case, the generic approach could have been substantially improved by analyzing the maximally effected individual and the maxim accident. The result is that the report does not provide a comprehensive view of the risks and challenges related to the transportation of radioactive wastes. P a g e 11 12

91 Sources Consulted Department of Energy. (2002). A Resource Handbook on DOE Transportation Risk Assessment. Retrieved from Albuquerque, NM: Garrick, J. B. (1985). Garrick, J.B "Recent Case Studies and Advancements in Probabilistic Risk Assessment.. Risk Analysis, 4(4): Nuclear Regulatory Commission. (1975). NUREG Reactor Safety Study. Washington D.C.: Nuclear Regulatory Commission. Rhyne, W. (1994). Hazardous Materials Transportation Risk Analysis: Quantiative Approaches for Truck and Train. New York: Van Nostrand Reinhold (March 1994). P a g e 12 12

92 Appendix 3

93 Ontario.ca Français MINISTRY OF NORTHERN DEVELOPMENT AND MINES HOME ABOUT NEWS FAQ SITE MAP CONTACT Home» Mines and Minerals» Applications Contacts Follow Us Facebook OGSEarth PRINT Twitter OGSEarth provides geoscience data, collected by the Mines and Minerals division, which can be viewed using userfriendly geographic information programs such as Google Earth. Available Data OGSEarth provides data on the following topics: Mining claims Geology Index maps Administrative boundaries Abandoned mines Data Formats Table of Contents 1. Available Data 2. Data Formats 3. Viewing Data 3.1. Google Earth 4. Source Data The data provided by OGSEarth is available in Keyhole Markup Language (KML) format. Viewing Data OGSEarth data can be viewed using Google Earth or other applications compatible with Keyhole Markup Language. To ensure that you get the current KML file, delete the Google Earth cache file before opening the KML. How to: 1. Open Google Earth 2. select File>Server Sign Out 3. Go to Tools>Options 4. Select the Cache tab 5. Click Delete cache file and then OK. 6. Exit Google Earth and download the KML. Google Earth Google Earth is a 3D geographic mapping and viewing tool. For instructions on how to use Google Earth, read the Google Earth tutorial. Source Data OGSEarth data is created from a variety of sources. A link to the original source data is provided with each layer when available. We are committed to providing accessible customer service. If you need accessible formats or communications supports, please contact us.