Ontario Ministry of Northern Development and Mines Submission to the Joint Review Panel Public Hearing Proposed Bruce Deep Geological Repository August 27, 2013
Background and Scope June 18, 2013, the Joint Review Panel invited the Ontario Ministry of Northern Development and Mines to provide a submission on: While the letter advised that the Ontario Mining Act would only apply should access to Crown land be required, the Panel invites the Ministry of Northern Development and Mines to provide a written submission and make an oral presentation for the upcoming public. In particular, the Panel is interested to know if the Ministry has any expertise to offer in relation to waste rock management and minewater management. MNDM has regulatory authority for administration of the Ontario Mining Act and is mandated to document the geology of Ontario and it s Earth resources, including regional aspect of the hydrocarbon resources (co-ordinated with Ministry of Natural Resources), mineral resources, groundwater resources. MNDM will not comment on waste rock management and minewater management because the proposed DGR is not a mining project. MNDM will comment on several geoscience topics: Bedrock and surficial geology; Groundwater; Overburden groundwater quality; Overburden groundwater transport; Shallow bedrock groundwater quality; Shallow bedrock groundwater and solute transport; Mineral potential; Metallic; Aggregate; Energy potential (in conjunction with MNR). 23/08/2013 MNDM Comments - Proposed Bruce DGR 2
Scope and Staff Technical Experts Regulatory: Mining Act: Leslie Cooper (not in attendance) Geology, groundwater, mineral resources, hydrocarbon resources (collaborative with MNR): Bedrock geology: Derek Armstrong + Frank Brunton; Surficial geology: Andy Bajc + Peter Barnett; Shallow groundwater geochemistry: Stewart Hamilton; Mineral potential: Frank Brunton + Derek Armstrong; Hydrocarbon: Derek Armstrong; Karst: Frank Brunton (geology) + Stewart Hamilton (groundwater geochemistry relevant to karst systems). Co-ordination: Jennifer Paetz; Andy Fyon. 23/08/2013 MNDM Comments - Proposed Bruce DGR 3
Context for MNDM Comments MNDM does not have expertise or mandate to comment on cumulative holistic environmental impact of the proposed DGR. MNDM has technical geoscience comments of a scientific nature. MNDM identifies some conditional geological topics for further study. Technical Support Document geoscience studies and scientific methods were appropriately conducted, there are no substantive science topic gaps. Technical Support Document geological conclusions are consistent with the geoscience data. 23/08/2013 MNDM Comments - Proposed Bruce DGR 4
Scope of MNDM Comments Proposed DGR Is Not a Mining Project MNDM administers the Ontario Mining Act. From the Ontario Mining Act; The purpose of this Act is to encourage prospecting, staking and exploration for the development of mineral resources, in a manner consistent with the recognition and affirmation of existing Aboriginal and treaty rights in section 35 of the Constitution Act, 1982, including the duty to consult, and to minimize the impact of these activities on public health and safety and the environment. 2009, c. 21, s. 2. The DGR as currently proposed is not a mining project under the Mining Act and would not require a closure plan or any approval under the Act. Therefore, MNDM has no comments on: waste rock management; or mine water management. 23/08/2013 MNDM Comments - Proposed Bruce DGR 5
Paleozoic Bedrock Context for MNDM comments: reviewed the Bedrock Geology section (5.5), of the Geology Technical Support Document (TSD) (NWMO DGR-TR-2011-03) with a focus on the Paleozoic stratigraphy; reviewed parts of other supporting documents [Geosynthesis Report (NWMO DGR-TR-2011-11) and the Descriptive Geosphere Site Model (DGSM) (NWMO DGR-TR-2011-24)]; Participant in DGR geological workshops, as part of team that reviewed and confirmed stratigraphic contacts in most of the vertically drilled wells; NWMO adopted most recent terminology and standards for regional Paleozoic geology [2006 The Subsurface Paleozoic Stratigraphy of Southern Ontario (Derek Armstrong (MNDM) and Terry Carter (MNR) )and the 2010 updated version OGS Special Volume 7, and other OGS publications, which guided DGR geological assessments]; DGR-related stratigraphic model follows closely the OGS standard; Recently published and on-going regional studies of Karst and associated groundwater chemistry in the Devonian bedrock strata in and around the DGR site are not discussed. Comments: There is a scientific divergence between inferred ages of rocks cited in the TSD technical reports, which were based on early OGS publications that were subsequently revised in more recent OGS publications. Implication: divergences may warrant further consideration because those rocks are relevant to groundwater flow and hydrocarbon potential in the Silurian rocks; Examples include: high groundwater flow zones in Guelph Formation, recently published changes to Early Silurian nomenclature, and petroleum potential of Salina A1 and A2 carbonates in vicinity of site. 23/08/2013 MNDM Comments - Proposed Bruce DGR 6
Paleozoic Bedrock Faults Potential for bedrock geological faults: TSD data identified potential faults in proposed DGR site; Not all faults were tested; Seismic features that were tested proved not to be faults; Potential remains for untested features to be faults in Ordovician carbonate rocks. Implication: Faults can channel past and future fluid flow and influence ground stability. 23/08/2013 MNDM Comments - Proposed Bruce DGR 7
Surficial Geology Correction to Written Submission Correction to the July 24, 2013 written submission provided by MNDM. Last paragraph, last sentence, under Regional Surficial Geology states: This possible surface bedrock groundwater connection should be re-assessed by the DGR project should the proposed development disrupt the unit of middle sands and layered till. Statement should not be attributed to Peter Barnett. Statement was an interpretation of verbal discussion with Dr. Barnett. MNDM position on Surficial geology in this presentation. 23/08/2013 MNDM Comments - Proposed Bruce DGR 8
Surficial Geology Additional characterization of the subsurface geological stratigraphy and surficial groundwater systems at a local and regional scale may be necessary if it is important to understand: Extent, thickness, connectivity between, and groundwater flow rate in near surface and deeper aquifer systems; Groundwater dewatering potential related to engineering design and excavations (e.g., shaft sinking and other physical site infrastructure); Groundwater interaction with the near-surface environment and bedrock. Implications: Engineering; Potential exposure of subsurface aquifers to surface influences. 23/08/2013 MNDM Comments - Proposed Bruce DGR 9
Types of Additional Surficial Geological Studies For Consideration Detailed stratigraphic succession analysis to assess local and regional significance; Comprehensive bedrock topography and drift thickness; Analysis of drift stratigraphic and physical properties (e.g., permeability, grain size, hydraulic conductivity); Analysis of interaction between site area aquifers (Middle sands and layered till) with potential uplands aquifers; Illustration of point data locations to assess data coverage confidence; Creation of detailed local and regional representative crosssections. 23/08/2013 MNDM Comments - Proposed Bruce DGR 10
Energy Comments Comments: TSD report suggests low probability for economic hydrocarbon resources in the Regional Study Area (RSA); TSD suggests low potential for economic quantities of shale gas from Upper Ordovician shale; However, there is a lack of regional subsurface data in regional study area relative to elsewhere in south western Ontario; Also, Collingwood Member (Cobourg Formation) and lower Blue Mountain Formation have Total Organic Carbon (TOCs) ranging from 1 to 2.5%; There are reported oil occurrences in the Collingwood Member; its thermal maturity suggests that it is a potential host of shale oil, not shale gas. Implication: May be more subsurface faults and related hydrocarbon reservoirs than have been mapped; If understanding hydrocarbon potential is considered significant from a resource perspective, then further analysis may be required to determine the hydrocarbon potential (e.g., oil) of the Ordovician carbonates in the vicinity of the proposed DGR and the likelihood of future hydrocarbon exploration. 23/08/2013 MNDM Comments - Proposed Bruce DGR 11
Aggregate / Industrial Mineral Potential Comments Some sedimentary strata in the proposed DGR area may be of economic value from an industrial minerals and aggregates perspective; The lower member of the Ordovician Cobourg Formation, which is to be excavated to create the proposed DGR site, is chemically analogous to rock along the shore of Lake Ontario that is a source of cement stone; Suggests the Cobourg Formation at the DGR site may have potential as a source of limestone for the cement industry; In the DGR region, whole rock geochemical analyses of the Devonian Dundee Formation (not observed in DGR cores) and Lucas Formation reveal that the Lucas ranges from a high-purity dolostone rock to a high-purity limestone resource that is mined in the Ingersoll-Woodstock area. Implications: Geochemical analyses of the Lucas Formation would assist in the assessment as a chemical stone and/or aggregate resource; Waste rock consisting of the Lower member of the Cobourg at the DGR site may have potential as a cement stone resource; If so, there is potential to convert waste rock to a valuable industrial mineral at the DGR site; This may be a means to deal with excavated rock created by any potential underground project. Should the DGR wish to consider the sale of waste rock for aggregates or its mineral potential, this activity may be subject to Part VII of the Mining Act. 23/08/2013 MNDM Comments - Proposed Bruce DGR 12
Metallic Mineral Potential Lead (Pb) and zinc (Zn) minerals are relatively common in carbonate rocks around the world; Occurrences of Pb and Zn are known in many carbonate rocks in southwestern Ontario; No economic quantities have been discovered to date in Ontario. Implication: Based on current understandings, models and data, MNDM suggests there is limited potential for sediment-hosted metallic mineralization in the area of the proposed DGR site. 23/08/2013 MNDM Comments - Proposed Bruce DGR 13
Shallow and Intermediate Groundwater Flow Systems and Hydrogeochemistry Context for MNDM Groundwater Comments: OGS hydrochemistry studies in the freshwater overburden and shallow bedrock groundwater systems, covering the regional study area of the DGR (published 2011, OGS Miscellaneous Release Data 283); OGS sampling sources differ from those reported on by NWMO (domestic wells for the OGS versus discrete sampling for NWMO). OGS scale is also different providing pan-provincial context. Comment: The Phase 1 Regional hydrochemistry report is comprehensive and well written, however, OGS Ambient Groundwater Geochemical database is newer and contains important new information; In particular it provides geochemical evidence for widespread karst (cavern formation) in the Lucas Formation extending from the proposed DGR site more than 100 km southward. Implications: It is important to address the presence of karst in the Lucas formation in later phases of study as it influences regional groundwater transport and may present geotechnical challenges during future construction phases; TSD and OGS groundwater quality data serve as robust groundwater quality baseline suitable for long-term monitoring of the proposed DGR influence on local and regional environment; Science collaboration would enable both organizations to characterize, model, and understand groundwater flow systems at different scales; we would welcome further science collaboration on groundwater studies. 23/08/2013 MNDM Comments - Proposed Bruce DGR 14
MNDM Concluding Remarks MNDM cannot comment on the cumulative holistic environmental impact of the DGR project. MNDM opinion: geoscience studies and scientific methods for proposed DGR were appropriately conducted, there are no substantive gaps in key science data, and DGR conclusions are consistent with the geoscience data. MNDM s geoscience opinion is that the DGR scientific items of divergence do not likely undermine confidence in the future geological suitability of the DGR. MNDM thanks the Joint Panel Review Board for the opportunity to participate in the public hearing related to the Deep Geologic Repository Joint Review Panel. Thank you. 23/08/2013 MNDM Comments - Proposed Bruce DGR 15