Environmental Assessment Programme Health Canada 180 Queen Street West, 10 th Floor Toronto, ON M5V 3L7. June 26, 2012

Transcription

1 Environmental Assessment Programme Health Canada 180 Queen Street West, 10 th Floor Toronto, ON M5V 3L7 June 26, 2012 Kelly McGee DGR Joint Review Panel Co-Manager C/O Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa, ON K1P 5S9 Debra Myles DGR Joint Review Panel Co-Manager C/O Canadian Environmental Assessment Agency 160 Elgin Street, 22 nd floor Ottawa, ON K1A 0H3 Subject: Health Canada s Information Requests on the Environmental Impact Statement for OPG s Deep Geologic Repository Project (DGR) for Low & Intermediate Level Waste, dated March 2011 Dear Ms. McGee and Ms. Myles, Thank you for the letter provided by the Joint Review Panel (JRP), dated February 3, 2012, requesting Health Canada s (HC) review of the Environmental Impact Statement (EIS) for the aforementioned project. As per the JRP s request, HC s comments are presented according to the Template for Submitting Information Requests; it is available, below, in the attachment: Health Canada Package 1 Information Requests on the DGR Project. Should you have any questions concerning HC s comments or identify any other specific human health concerns with respect to this project, HC would be pleased to provide Sent by to: DGR.Review@ceaa-acee.gc.ca 1

2 expertise upon request as a Federal Authority, pursuant to the Canadian Environmental Assessment Act. Sincerely, Kitty Ma Health Canada - Ontario Region A/Manager, Environmental Health Programs Tel: Fax: cc: Adele Iannantuono, A/Manager of Environmental Health Programs - Ontario Region, Health Canada Luigi Lorusso, A/Manager of Environmental Assessment Division, Health Canada Gregory Kaminski, Senior Environmental Health Assessment Advisor, Health Canada Attachment: Health Canada Package 1 Information Requests on the DGR Project Sent by to: DGR.Review@ceaa-acee.gc.ca 2

3 OPG s Deep Geologic Repository Project (DGR) for Low & Intermediate Level Waste Health Canada Package 1 Information Requests on the Deep Geologic Repository (DGR) Project Prepared for the DGR Joint Review Panel June 21, 2012

4 Abbreviation / Acronym a Bq Derived Release Limit EIS Equivalent dose ILW LLW msv NEWs NORM SI TSD Definition Annum (year) Bequerel: The SI unit of activity equal to one disintegration per second. A measure of radiological emissions from a nuclear facility as specified by the regulator, and is usually based on the average radiation dose to a member of the critical group which should not exceed a dose of 1 msv on annual basis. Environmental Impact Statement Absorbed dose multiplied by a radiation weighting factor which varies from one for beta and gamma radiation to 20 for alpha radiation. The equivalent dose allows for the fact that some types of radiation are more damaging than others at the same level of absorbed dose. The SI unit of equivalent dose is the Sievert (Sv) which has the same dimensions as the Gray (Gy), i.e., joules per kilogram. Intermediate level waste Low level waste Millisievert : The SI unit of equivalent dose with dimensions of joules per kilogram. Subdivided into the millisievert (msv) = 1/1000 Sievert and the microsievert (μsv) = one millionth of a Sievert. Nuclear Energy Workers Naturally Occurring Radioactive Materials Système Internationale: The officially adopted international system of units, based on the metre, kilogram, second, and ampere Technical Supporting Document June 26,

5 General Information and Design Description OPG s EIS Information Request Context EIS Waste to be placed in the DGR HC advises including an explanation for why decommissioning L&ILW was not included in the assessment. Operational Low and Intermediate-Level Waste (L&ILW) and refurbishment L&ILW are included in the assessment; however, decommissioning L&ILW is not included in the assessment. If there is the possibility that decommissioned L&ILW will be stored in the DGR, HC suggests that L&ILW should then be included in the assessment. This will ensure that all potential sources of radiation exposure for workers or members of the public have been accounted for in the EIS General Information and Design Description EIS Waste to be placed in the DGR EIS Total Radionuclide Inventory of Waste HC advises providing the estimated radionuclide inventory for 2020, and that these values be used in the dose assessment for members of the public. The radionuclide inventory in the year 2062, the assumed decommissioning date, is provided. However, figures and show the peak activity of the DGR occurring at approximately HC advises providing the radionuclide inventory for 2020 and use this in the dose assessment in order to ensure that the doses have not been underestimated Ambient Radioactivity EIS Radiation and Radioactivity EIS Radioactivity in Groundwater HC advises confirming whether the groundwater sampled at Well 231 is used as a drinking water source. The maximum tritium concentration at Well 231 is 8 x 10 4 Bq/L. This is less than the screening criteria of 3 x 10 6 Bq/L for non-potable groundwater used by the proponent. However, this tritium concentration is elevated above the drinking water guideline of 7 x 10 3 Bq/L. HC advises clarifying that the water at Well 231 will not be used as a drinking water source at any time Radiological EIS Radiological EIS Humans HC advises providing the radon assessment identified in Section 7.6 for review. The proponent states that Naturally Occurring Radioactive Materials (NORM), in particular radon, may be a cause for concern during the site preparation, construction, and operations phases; however, a recent study indicated that there is no significant radon hazard to the workers or general public. HC advises that this document be reviewed and compared to the Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (Health Canada 2000). June 26,

6 Radiological OPG s EIS Information Request Context EIS Radiological EIS Identification and Assessment of Effects The first bullet of the regulatory limits on the annual dose to members of the public and to workers should read: nuclear energy workers, not including a pregnant nuclear energy worker. The bullet currently reads nuclear energy worker, including a pregnant nuclear energy worker. This is not correct. HC suggests revising the bullet to prevent any misunderstanding Radiological EIS Radiological HC advises providing an estimated dose for members of the public. The proponent has not provided an estimated dose for members of the public. The dose to members of the public must be shown to be below the Radiation Protection Regulations (Government of Canada 2000) dose limit of 1 msv/a. EIS Humans June 26,

7 Accidents, Malfunctions and Malevolent Acts OPG s EIS Information Request Context EIS Radiological Malfunctions and Accidents EIS Potential Effects HC advises providing details of exposure and mitigation measures for members of the public in the accidents and malfunctions section. This information may be in the Preliminary Safety Report. HC suggests this information be provided for review. Currently, it is not clear why the 1 hour exposure period for member of the public is appropriate. The EIS states that it is not likely that a member of the public will be exposed for more than 1 hour in the event of an accident and/or malfunction, however no information and/or discussion was provided to support this exposure level assumption. In addition, no mitigation measures (such as evacuation or longterm relocation) were provided. This comment also applies to Section Identification and Screening of Radiological Accidents, and Section Members of the Public in the Malfunctions, Accidents, & Malevolent Act TSD Long-Term Safety of the DGR EIS 9. Long-Term Safety of the DGR EIS Disruptive Scenario Results HC advises providing dose estimates and mitigation measures for the disruptive scenarios. This information may be in the Postclosure Safety Assessment. HC suggests this information be provided for review. The proponent has not provided exposure details for the disruptive scenarios. In addition, only doses of about 1 msv are provided. Dose estimates are required to ensure that the disruptive scenarios have been thoroughly assessed, and that they are below the regulated dose limit of 1 msv/a for members of the public. June 26,

8 Cumulative Effects OPG s EIS Information Request Context EIS Cumulative Effects EIS Radiation and Radioactivity HC advises providing a detailed description of all projects identified as having a cumulative effect on the radiation and radioactivity environment in the vicinity of the project. There are 16 projects which may act cumulatively in the radiation and radioactivity environment (see Section ). Three of the projects listed in Section do not appear in the discussion in Section including: Douglas Point Nuclear Generating Station Decommissioning, Heavy Water Plant Decommissioning, and RWOS1 safe storage. The effects of the other 13 projects are only vaguely described. More detail on the 16 overlapping projects is suggested to ensure that cumulative radiation effects have been thoroughly assessed Cumulative Effects EIS Cumulative Effects HC advises providing a cumulative dose estimate for members of the public. There are 16 projects which may act cumulatively in the radiation and radioactivity environment. The projects should be described individually, along with expected doses resulting from each project. These doses should be summed to calculate the cumulative dose to a member of the public. EIS Radiation and Radioactivity Radiological Appendix C: Human Health Assessment C Radiation Exposure Levels C Members of the Public HC advises including aboriginal communities and seasonal users in their critical group assessment. Table C1.2-1 identifies four Valuable Ecosystem Components (VECs) for Human Health including: Overall Health of Local Residents, Overall Health of Members of Aboriginal Communities, Overall Health of Seasonal Users, and Health of Workers. In their dose assessment for members of the public, the proponent has considered: A non-farm resident, a farm resident, and a dairy farm resident. These all fall within the Overall Health of Local Residents VEC. HC advises that Aboriginal groups and seasonal users also need to be included in the critical group assessment in order to ensure that all VECs have been considered and that the critical group represents the most exposed of these groups. June 26,

9 Radiological OPG s EIS Information Request Context Appendix C: Human Health Assessment C2.3.3 Radiation Exposure Levels HC advises providing a complete list of all radionuclides considered in the Human Health Risk Assessment (HHRA) for the DGR project. Currently, the EIS lists: Tritiated water, Noble gases, Iodine, Particulates, Carbon-14, and Organically bound tritium in Table C HC advises that a complete listing of the radionuclides considered be provided, rather than simply using broad groupings such as Noble Gases and Particulates. This will ensure that all radionuclides relevant to the DGR project have been included in the HHRA. Table C : Radionuclides and Pathways to Critical Groups Radiological Appendix C: Human Health Assessment C Radiation Exposure Levels HC advises considering the incidental ingestion of contaminated soil and sediment in the dose assessment. Although the current dose assessment includes external exposure from contaminated soil and sediment, it does not include incidental ingestion of soil or sediment. HC advises that these pathways be considered in a complete pathways analysis such as that seen in Canadian Standards Association (CSA) document N288.1 (CSA 2008). Although this pathway may not be expected to be a large contributor to overall dose, it can be substantial, particularly for children. Table C : Radionuclides and Pathways to Critical Groups June 26,

10 Follow-Up Program Follow-Up Program OPG s EIS Information Request Context DGR EA Follow-up and Monitoring Program 8. Radiological Monitoring DGR EA Follow-up and Monitoring Program 8. Radiological Monitoring 8.1 Radiological Analysis of Air HC advises describing the follow-up and monitoring programs for the decommissioning and abandonment stages of the DGR project. HC advises adding noble gases to the air monitoring program. Additionally, HC advises providing a list of all radionuclides to be monitored in air during operations of the DGR. The air, groundwater, and surface water follow-up and monitoring programs are described in this section for the preparation, construction, and operation phases of the project. Follow-up and monitoring will also be required for the decommissioning and abandonment phases. HC suggests describing programs for these phases to ensure the radiological environment is characterised and the doses predicted in the assessment for these phases are verified. Currently, the proponent states that during operations, radioactivity (tritium, particulate and carbon-14) will be monitored in the vent exhaust air. HC advises that noble gases are added to the monitoring program as noble gases are included in the Human Health Risk Assessment. As discussed in the proposed information request #12 above, HC advises providing that a complete listing of the radionuclides included in the air monitoring program rather than the broad groupings such as particulates and noble gases. This will ensure that all radionuclides relevant to the DGR project have been included in the monitoring program Follow-Up Program DGR EA Follow-up and Monitoring Program 8. Radiological Monitoring HC advises including gross alpha in the groundwater and surface water monitoring program. The EIS states that only tritium and gross beta levels will be routinely measure in groundwater; and tritium, gross beta, and in one case carbon-14 levels only will be routinely monitored in surface water. HC advises that gross alpha also be monitored to ensure it does not exceed the screening level in the Canadian Drinking Water Guidelines of 0.5 Bq/L. 8.2 Radiological Analysis of Groundwater 8.3 Radiological Analysis of Surface Water June 26,

11 Ambient Radioactivity OPG s EIS Information Request Context Radiation and Radioactivity TSD 5. Description of the Existing Environment HC advises providing more details of the radiation monitoring in the existing environment. HC advises providing information on which radionuclides are monitored (including within the radioactive particulates) in their existing condition, and their (known or estimated) concentrations. This information is needed to accurately complete the existing environment dose assessment. Table Annual Releases to Air in Gaseous Effluent from Bruce Nuclear Site Ambient Radioactivity Radiation and Radioactivity TSD 5. Description of the Existing Environment HC advises describing mitigation measures to reduce the amount of tritium in precipitation in the Site Study Area. In 2002, the maximum concentration of tritium in precipitation in the Site Study Area was 6,620 Bq/L. This is approaching the Canadian Drinking Water Guideline of 7,000 Bq/L. The assessment states that, precipitation can be a significant component to the recharge of shallow groundwater aquifers, which may be used as a source of drinking water in the region. Therefore, HC advises describing any mitigation measures to reduce the tritium concentration releases. Table Tritium in Precipitation in the Site Study Area June 26,

12 Ambient Radioactivity OPG s EIS Information Request Context Radiation and Radioactivity TSD 5. Description of the Existing Environment HC advises clarifying Table 5.9-2: Tritium Level in Bruce A and B Groundwater Monitoring Wells (Bq/L). Currently under the column Monitoring Location the table has a range of dates. In addition, the second row sampling months are also provided. It appears that there is no information on the actual locations. The temporal meaning of this table is confusing. This may be a typographical error. Please clarify to prevent any misunderstanding. Table 5.9-2: Tritium Level in Bruce A and B Groundwater Monitoring Wells (Bq/L) Ambient Radioactivity Radiation and Radioactivity TSD 5. Description of the Existing Environment HC advises clarifying which guideline value is appropriate for tritium levels in Well 231 to determine if mitigation is necessary. This comment is related to Comment #3 above. Additionally, the figure shows the level of tritium to be above the Operating Limit for tritium of 4 x 10 4 Bq/L. The source of this Operating Limit is not clear. The tritium concentration in Well 231 exceeds the Canadian Drinking Water Guideline for Tritium (Health Canada 2010) and the Operating Limit for Tritium as discussed in Section 5.9 of the Radiation & Radioactivity TSD, therefore, HC advises the proponent to consider and describe mitigation measures for Well 231. Figure Tritium and Gross Beta Concentrations Measured at WWMF Groundwater Monitoring Well Ambient Radioactivity Radiation and Radioactivity TSD The inhalation rates used in the EIS are lower than those recommended in more recent guidance documents. HC advises updating the inhalation rates to the more conservative values. The TSD cited a 2002 OPG Report for the inhalation rates used. However the COG Derived Release Limits Guidance (Hart 2008) and CSA Standard N288.1 (CSA 2008) were both updated in HC advises the proponent to use the more updated inhalation rates from these documents in order to ensure that doses from inhalation have not been miscalculated. June 26,

13 Ambient Radioactivity OPG s EIS Information Request Context 5. Description of the Existing Environment Table : Summary of Existing Radiation and Radioactivity The dose for non-nuclear Energy Workers (NEWs) provided is incorrect. HC suggests revising the dose to the recalculated correct value. The TSD states that for non-news the current doses do not exceed 100 µsv/a. However, the highest dose rate measured at the perimeter fences was 0.16 µsv/h. Using the proponents assumed exposure time for non-news of 2,000 hours per year, this works out to a dose of 320 µsv/a. Although still less than the dose limit for non-news of 1 msv/a (1,000 µsv/a), it is not less than 100 µsv/a as stated by the proponent. HC suggests the correct dose be presented in the TSD Radiological Radiation and Radioactivity TSD 8. Identification and Assessment of Environmental Effects HC advises providing an estimated dose for each of the critical groups considered, as well as for each age class considered. Estimated doses for each of the critical groups considered, or for each of the age categories have not been identified. HC advises providing this information to ensure that the dose to members of the public presented represents the most highly exposed group Potential Doses to Members of the Public June 26,

14 Radiological OPG s EIS Information Request Context Radiation and Radioactivity TSD Appendix D: Detailed Radiation Dose Calculations (Humans) The maximum airborne release rate for C-14 from all ILW packages is not provided as a rate. HC suggests providing the release rate with the units of activity per time, such as Bq/s. The release rate of C-14 from LLW and ILW packages is 1 stated as.8 x Bq. A release rate requires a unit of time Radiological D2. Estimated Dose to the Public Sample Calculation for Dose from C-14 through the Air Pathway Radiation and Radioactivity TSD Appendix D: Detailed Radiation Dose Calculations (Humans) D2. Estimated Dose to the Public Sample Calculation for Dose from C-14 through the Air Pathway HC advises including an estimate of doses to members of the public by using a detailed pathways analysis specific to the DGR project, rather than the scaled estimate they have used in this example. A scaling method has been used for the dose estimate creating a factor from the expected releases of the DGR and the known releases of the current Bruce Site. This factor was used to scale the calculated dose to members of the public from the Bruce site, to estimate for dose to members of the public from the DGR. This approach is not as precise as completing an independent detailed pathways analysis for the DGR site. An example of such a pathways analysis can be found in CSA document N288.1 (CSA 2008). This would ensure that any differences between the DGR site and the Bruce site are accounted for and the dose to members of the public has been adequately modelled. June 26,

15 Radiological OPG s EIS Information Request Context Radiation and HC advises providing a sample dose As each pathway is treated differently, a sample calculation for C-14 through the air pathway does not Radioactivity TSD calculation for each pathway. provide any information on how the remainder of the pathway analysis was completed. Therefore, HC suggests providing a sample calculation for each pathway. Appendix D: Detailed Radiation Dose Calculations (Humans) Radiological D2. Estimated Dose to the Public Sample Calculation for Dose from C-14 through the Air Pathway Radiation and Radioactivity TSD Appendix D: Detailed Radiation Dose Calculations (Humans) D2. Estimated Dose to the Public Sample Calculation for Dose from C-14 Through the Air Pathway HC advises providing the estimated doses from all pathways, as well as a total estimated dose to the public. The TSD describes how the dose from C-14 is estimated. The TSD states that the sum of the results of similar calculations for all the other radionuclides and pathways would provide the total estimated maximum dose to the public, however these results were not provided. HC advises that the results of these other calculations and the total estimated maximum dose to the public be provided. This will ensure that all radiation exposures to the public have been properly characterised, and the total dose remains below the Radiation Protection Regulations (Government of Canada 2000) dose limit of 1 msv/a. June 26,

16 Accidents, Malfunctions and Malevolent Acts OPG s EIS Information Request Context Malfunctions, Accidents, and Malevolent Acts TSD 4. Radiological Malfunctions and Accidents HC advises providing the estimated doses to the drill crew and to a future person living and farming on the contaminated site for the Human Intrusion Scenario. The TSD states that the calculated doses could be about 1 msv/a for the drill crew or a future person living and farming on the contaminated site for the Human Intrusion Scenario. Estimated doses to members of the public must be calculated to demonstrate that they are below the Radiation Protection Regulations (Government of Canada 2000) dose limit of 1 msv/a Accidents, Malfunctions and Malevolent Acts Humans Malfunctions, Accidents, and Malevolent Acts TSD 4. Radiological Malfunctions and Accidents HC advises providing an estimated dose to members of the public for the Severe Shaft Failure Scenario. The TSD states that the maximum calculated doses are about 1 msv/a for members of the public for the Severe Shaft Failure Scenario. Estimated doses to members of the public must be calculated to demonstrate that they are below the Radiation Protection Regulations (Government of Canada 2000) dose limit of 1 msv/a Humans Accidents, Malfunctions and Malevolent Acts Malfunctions, Accidents, and Malevolent Acts TSD 4. Radiological Malfunctions and Accidents HC advises providing estimated doses to members of the public for the Poorly Sealed Borehole Scenario and the Vertical Fault Scenario. The TSD states that peak annual doses to members of the public for the Poorly Sealed Borehole Scenario and the Vertical Fault Scenario are several orders of magnitude less than the dose criterion. HC suggest providing these estimated doses (and associated calculations) to support this conclusion Humans June 26,

17 Accidents, Malfunctions and Malevolent Acts OPG s EIS Information Request Context Malfunctions, Accidents, HC advises providing dose estimates Malevolent Acts Scenarios described by the proponent include: deliberately driving a forklift into a and Malevolent Acts for the Malevolent Acts Scenarios package or dropping a package during handling; pushing a package or vehicle into the shaft; setting TSD described. waste packages on fire; a person using an explosive or incendiary device; remote military-style attack from the site boundary; and an aircraft crash. HC advises providing dose estimates for members of the 6. Malevolent Acts public and mitigation measures related to these scenarios Radiological Effects Atmosphere Atmospheric TSD Section 2.2 of the Atmospheric TSD HC advises clarifying how nonregulatory approaches (in addition to regulatory frameworks) are used to adequately characterize potential impacts to human health. The TSD states that the air quality assessment is based on changes to the existing environment, and not solely on comparison against regulatory frameworks and that a precautionary approach is employed. In the EIS itself, the precautionary approach is described (for air) as involving the use of conservative emissions scenarios, the results of which however, are compared against regulatory frameworks (Air Quality Standards). While the emissions modeling may (or may not) be conservative, the evaluation of the resulting air quality appears to be solely based on regulatory frameworks. In some cases (especially short-term nitrogen dioxide) the modelled siting/construction and operations phases result in air quality levels several hundred times higher than existing (which itself is a function of emissions from existing facilities) levels. As there are increases in the predicted Criteria Air Contaminants levels associated with project activities, please provide an explanation of how evaluations against non-regulatory frameworks are performed to adequately characterize the impacts to human health. June 26,

18 Information Request # Section # in EIS Guidelines Atmosphere EIS - Section HC advises providing a discussion of the NOx/VOC balance in the area, the atmospheric conditions (such as longrange flows) under which the regular exceedances of ozone standards occur, and a more substantial qualitative discussion of the impact of the project s NOx emissions on ozone formation under the regional conditions which lead to exceedances of ozone standards. OPG s EIS Information Request Context The EIS and TSD argue that the project will have no effect on ozone levels given the regional nature of ozone in the area. Ozone levels in the area routinely exceed the applicable air quality standards (Ministry of Environment 2012, pp. 2-3). Given the high emissions of NOx associated with project activities, HC advises a discussion to explain the above conclusion that is incorporated in the EIS to ensure potential effects on levels of ozone and resulting potential health effects are not underestimated Atmosphere EIS - Section HC advises clarifying the reasons that the 1 hr. CO level is less than 8 hour level Mitigation Measures, Atmosphere EIS - Table HC advises providing a rationale for requiring emissions at only a Tier 2 level for diesel engines and a discussion as to why no Tier 3 would be available / required. In Table of the EIS, 1 hour CO levels are less than 8 hour levels. 1 hour CO levels are less than the 8 hour levels. Please review calculations as 8 hour levels should not exceed 1 hour levels. Tier 3 emissions standards became a requirement in (and Tier 4 in 2012) (Government of Canada 2005) and provide substantial reductions in NOx emissions, and as NOx emissions appear to be one of the most important air quality issues related to the project, it is unclear why the mitigation plan does not include Tier 3 standards. June 26,

19 Significance of Residual Effects, Atmosphere OPG s EIS Information Request Context EIS - Figure HC advises including a discussion on how the decision tree used to determine significance of residual adverse effects for air quality (Figure of the EIS) provides a level of protection for the local population. In addition, HC suggests providing a more extensive discussion of the irreversibility criteria as it applies to specific endpoints related to PM and other pollutants. Please provide a more detailed explanation about the decision tree (Figure of the EIS) used to assign significance to the effects of air quality on health. Aside from the reliance on regulatory frameworks (i.e., Air Quality Standards) the tree itself is not clearly explained, nor is it clear how decisions were made in each step. For the site preparation and construction phase, use of the decision tree results in degree of irreversibility (immediately reversible). The definition behind immediately reversible is particularly unclear. For example, if one stops the emission source, then the air quality will improve quite quickly. However, the health effects will not, given that PM is associated with a wide range of health effects (e.g. asthma attacks, worsening of respiratory symptoms, etc.) Noise Atmospheric Environment TSD Section 5.5 Noise Levels (pp ) HC suggests assessing whether or not excluding sounds of nature would appreciably lower the ambient noise levels in such a way that the potential project noise impacts could be more severe than reported. An alternate approach would be to present the minimum 1hr Leq levels without sounds of nature in the noise assessment. The noise assessment indicates that the sounds of nature were included in monitoring of the baseline noise levels. Typically, HC would not recommend including sounds of nature in determining the ambient sound levels. June 26,

20 Noise and Vibration OPG s EIS Information Request Context Atmospheric Environment TSD Appendix J, page J-10 HC suggests discussing whether or not adjusting the measured/predicted sound levels to account for impulsive, highly impulsive, high energy impulsive (blasting), tonal and/or quiet rural area adjustments would change their calculated change in %HA during construction, operation and decommissioning stages of the Project. Research indicates that certain sound characteristics can increase community annoyance (CSA 2005). Appendix J, page J-10 of the Atmospheric TSD provides the equation used for deriving %HA. However, it does not appear as the %HA was calculated using a rating level. Note that a rating level is an adjustment applied to a measured or calculated sound level. Procedures on how to calculated %HA using a rating level with the applicable adjustments can be found in ISO (2003) (CSA 2005) Noise and Vibration Atmospheric TSD and Socio-economic Environment TSD The assessment of noise impacts on receptors is based on premise that sound level increases of 3dB are not noticeable. For example, Section (pp. 268) of the Socio-economic Environment TSD indicates that increases over an existing noise level up to 3 dba are hardly perceptible. HC advises avoiding statements relating to perceptibility or whether changes in noise are noticeable based solely on decibel levels as they may be misleading to readers. The perception of sound is not related to sound level in decibels in a linear manner. For example, a 10- db increase is the median change in sound level at 1 khz, which is perceived as being twice as loud. A typically cited threshold for an increase in sound level that is often stated as being barely perceptible by the human ear varies from 3 to 5 db. This threshold is often used in environmental assessments, which may state that residual sound increases lower than this threshold will not be perceptible; however, a difficulty with this approach is that humans also perceive and respond to changes in sound characteristics other than loudness. Changes to the characteristics of the sound from baseline, such as a change in frequency, changes in sound modulation, and increased impulsiveness, may be perceived and may cause noise to be more noticeable, even if the absolute sound level (in dba) is not substantially increased. It is important to consider that people respond to sound characteristics that do not necessarily increase the sound level appreciably (ANSI S /Part 4, clause A.1.3). June 26,

21 Noise and Vibration OPG s EIS Information Request Context Atmospheric Environment TSD Section There appears to be no specific methodology used for assessing blasting noise, other than the discussion of perceptibility and the associated problems with this approach as noted above in comment (see IR# 39 above). HC suggests using an approach that will adequately characterize potential human health effects due to blasting and suggest mitigation activities as appropriate. Blasting is identified as project activity in the EIS, but the specific discussion mainly limited to its impacts on air and vibration (Section Noise Levels (p. 90) of the Atmospheric Environment TSD). As noted in Section , noise from blasting would not likely measurably change the 1 hour Leq (the indicator for noise levels) used in this assessment. Therefore it is important to use an approach that will adequately characterize potential human health effects and suggest when mitigation activities should occur. Noise effects due to blasting can be assessed in several ways, depending on how long the blasting will continue. If blasting is anticipated to last less than one year, HC suggests using EPA (1974) approach, where little or no public annoyance is expected to result from any number of daytime sonic booms per day if their measured or predicted peak value is below ( log N) db. In this case, db is now interpreted as meaning Z or Zero weighting (dbz). For blasting of duration of more than one year; HC suggests following the recommendations in CSA (2005) Noise and Vibration Suggested to add to the discussion of noise impacts in the Atmospheric Environment TSD and the appropriate sections of the EIS d HC suggests describing potential project noise impacts on sleep and determining whether or not the World Health Organization s (WHO) threshold for sleep disturbance will be exceeded. Volume 1 of the EIS Section 4.7, page 4-39, Site Preparation and Construction, suggests that some night time activities may be required. See also section , Construction Labour, page However, the EIS does not describe any potential project noise impacts on sleep. Due to the methodology currently used in this noise assessment, it is not possible to assess whether or not the World Health Organization s (WHO) threshold for sleep disturbance will be exceeded. The proponent may wish to consider the potential impact on sleep using the WHO s (Berglund et al, 1999) recommended thresholds for sleep disturbance. These thresholds are: for steady state (continuous) noise inside the bedroom is 30dBA (i.e. 45 dba outdoors with an assumed 15dBA transmission loss with windows partially opened) and 45dBA for discrete noise events (i.e. 60 dba outdoors with an assumed 15dBA transmission loss with windows partially opened). June 26,

22 References: ANSI. (2005). Quantities and Procedures for Description and Measurement of Environmental Sound Part 4: Noise Assessment and Prediction of Long-Term Community Response (ANSI S /Part 4) Standards Secretariat Acoustical Society of America. Berglund, B., Lindvall, T. & Schwela, D.H (Eds.). (1999). Guidelines for Community Noise. World Health Organization (WHO). Available at: Canadian Standards Association (CSA). (2008). N288.1: Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities. Canadian Standards Association (CSA). (2005). CAN/CSA-ISO :05 (ISO :2003) Acoustics Description, measurement and assessment of environmental noise Part 1: Basic quantities and assessment procedures. Government of Canada. (2005). SOR/ Off-Road Compression- Ignition Engine Emission Regulations. Available online at: Government of Canada. (2000). SOR/ Radiation Protection Regulations. Available online at: Hart, D. (2008). COG R2-I Derived Release Limits Guidance. Candu Owners Group (COG). Available online at: FINAL.pdf Health Canada. (2010). Guidelines for Canadian Drinking Water Quality Guideline Technical Document: Radiological Parameters. Available online at: Health Canada. (2000). Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM). Available online at: International Commission on Radiological Protection (ICRP). (2006). 101: Assessing Dose of the Representative Person for the Purpose of Radiation Protection of the Public and The Optimisation of Radiological Protection: Broadening the Process. Ontario Ministry of Environment. (2012). Air Quality in Ontario Report for Queen s Printer for Ontario. June 26,

23 United States Environmental Protection Agency (EPA). (1974). Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety (Report No. 550/ ). June 26,