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1 From: MULLER Andrew -DNNP < address removed> Sent: December 20, :01 PM To: DGR Review / Examen DFGP [CEAA] Cc: 'McGee, Kelly'; Myles,Debra [CEAA]; 'Peter Elder (Peter.Elder@cnsc-ccsn.gc.ca)'; 'King, Frank'; WEBSTER Allan P -DNNP; SULLIVAN Gord -DNNP Subject: Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Package #7 Please find attached a copy of the letter signed by Mr. Albert Sweetnam to Dr. Stella Swanson, Chair of the Joint Review Panel for the Deep Geologic Repository Project, titled Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7. This letter responds to all of the in Package #7 and provides an updated Tracking Table for all OPG submissions to date. The signed original is being sent by courier. Sincerely, Andrew Müller Section Manager Licensing (DGR) Ontario Power Generation

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5 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR OPG Responses to Package #7 IR# EIS Guidelines Section Information Request and Response EIS Section 12, Accidents, Malfunctions and Malevolent Acts Information Request: Provide additional information about fuels and chemicals that would be used and stored on site so that risks posed by spills can be more thoroughly evaluated. Provide information on specific worst-case accident and spill scenarios, and define the bounding scenarios for each case. Context: More information related to conventional accidents and malfunctions is required. Only a generalized list of the chemicals/substances (i.e. fuels, lubricants, glycols) that would be used and stored on site was provided. Information on the chemicals and types of oils and lubricants, and where they will be stored onsite, is required. Similarly, there is no information on the volumes, sizes and types of tanks, locations of these tanks/vessels, and whether any secondary containment/spill protection is associated with them. Such information is needed in order to determine the potential for incidents and their significance. It is mentioned in Table on page 41 of the Malfunctions, Accidents and Malevolent Acts TSD that "the volume of a spill is assumed to be approximately 4500 litres of diesel fuel, 200 litres of a chemical or 100 litres of a lubricant or oil but no explanation is provided to justify the assumed volumes. From a general risk assessment procedural standpoint, the Malfunctions, Accidents and Malevolent Acts TSD does not outline specific accidents or malfunctions and where they would do the most damage (i.e. worst probable case scenarios), but simply mentions general "vehicle accidents" or "operational errors". Specific worst-case scenarios are necessary to define the bounding scenarios. OPG Response: As discussed in the Environmental Impact Statement (EIS) (OPG 2011, Section ), surface diesel and fuel storage for mobile equipment will be limited to the site preparation and construction phase and will be removed prior to operations. The temporary fuel storage consists of 5,000 L above-ground double walled tanks equipped with metered dispensing equipment located within a secured area and protected by concrete bollards. During operations, diesel fuel storage at surface is limited to the emergency power system fuel supply, which is contained in a 5,000 L double walled tank located adjacent to the emergency generators. Section (OPG 2011) incorrectly identified the tank size as 10,600 L; the correct volume of 5,000 L was provided in Section (OPG 2011). Underground fuel storage includes two 2,700 L double walled steel fuel totes in an integrated unit with a built-in leak containment and fire suppression system. Page 1 of 90

6 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Both surface and underground fuel storage areas will be provided with sufficient sump capacity to collect accidental spillage that could occur during fuel transfer or leakage from any tanks or pipes. Berms will be constructed as needed to ensure that any spillage of fuel or lubricant will be retained within the storage and refueling areas. The EIS (OPG 2011, Section ) provides estimates of quantities of oils and grease, and solvents and paints that will be used each year. Hazardous materials to be used at the site are expected to be commonly used and commercially available materials. Annual usage of hazardous materials is relatively small and large volumes of hazardous materials will not be stored at the site. The Malfunctions, Accidents and Malevolent Acts Technical Support (AMEC NSS 2011, Table 5.2-1) considers the quantities likely to be released as a result of a malfunction/accident at a single container for each type of material. The worst case scenario considered, a spill of 4,500 L of diesel, represents 90 per cent of the capacity of the emergency generator diesel fuel storage tank for the operations phase. This is a conservative estimate of the volume of spill as the storage tank will be located on a concrete pad which drains to a sump and all releases will be contained. Had a spill of 5,000 L been assessed, the results of the assessment would be the same. The specific details of chemicals and lubricants will depend on the types of equipment being used on site. This information is not available at this time. Above ground, chemicals will be stored in substance appropriate, secured storage cabinets. The location of the storage units will be as required in close proximity to large equipment and determined in consultation with contractors. Below ground, chemicals will be stored in dedicated areas, in substance appropriate, secured cabinets, for example, in the diesel fuel bay, and maintenance shop. References: AMEC NSS Malfunctions, Accidents and Malevolent Acts Technical Support. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) OPG OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement, Volume 1. Ontario Power Generation report REP R000. Toronto, Canada. (CEAA Doc# 298) EIS Section 12, Accidents, Malfunctions and Malevolent Acts Information Request: Provide additional justification for an explosion to be considered non-credible. Describe the susceptibility of stored fuels and chemicals to an explosion based on the proximity of explosives being used, stored, or transported. Explain how the Project will be designed and operated to minimize explosion risk and the consequences of an accidental explosion Page 2 of 90

7 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Context: Considering that there will be usage, transport and potentially storage of explosives on site, some risk of an accidental explosion does exist. Other substances could cause or contribute to explosions. OPG Response: An explosion scenario capable of damaging the DGR was considered not credible event for the operations phase of the DGR (OPG 2011a, p.423). OPG s response to Information Request (IR) EIS (OPG 2012a) acknowledges that explosions are credible for the site preparation and construction phase as the use of explosives is required to excavate the rock and have been assessed as part of the Environmental Impact Statement (OPG 2011b, Section ). However, an explosion accident is considered low-risk during the construction activities due to design considerations, operational controls and measures to comply with the regulatory requirements that will be implemented for the DGR. OPG s response to IR-EIS (OPG 2012b) also discusses the potential of access tunnel closure walls to resist explosions. The DGR project transportation and storage requirements for blasting explosives and initiating devices are regulated through the Explosives Act of Canada and the Ontario Mines and Mining Plants Regulations (O.Reg. 854/90). Additional guidance is provided by the Explosives Regulatory Division of Natural Resources Canada through Blasting Explosives and Initiation Systems - Storage, Possession, Transportation, Destruction and Sale, March The location of magazines for the storage of explosives and detonators, both on surface and underground, requires that the location isolates the explosives from potential igniting or fire sources (e.g., fuel storage, chemicals, electrical and mechanical installations, mobile equipment) and where workers may congregate. The construction and location of the magazines, with explosives and detonators stored separately, have sufficient separation to minimize the potential for ignition. For surface storage, the positioning of magazines uses Quantity-Distance tables, correlating the quantity of explosive to be stored to the closest receptors with the distance set to the closest receptor hazard classification (e.g., distance to a lightly traveled road is shorter than the distance to an inhabited building). These distances are set to minimize the potential impact of an unplanned explosion. Underground, there is a minimum distance of 60 m from closest receptors as described above. Transportation of explosives requires consideration for the physical equipment handling explosives, as well as, operational control to ensure safe and efficient movement of explosives to transfer or storage locations. Receipt of explosives at the Bruce nuclear site will be coordinated with Bruce Power security and maintain established transportation routes. The equipment used for the delivery of explosives will be licensed for their transport. Post delivery transport and use of explosives will be in accordance with the requirements of the Ontario Mines and Mining Plants Regulations (O.Reg. 854/90). Transport of explosives in the shaft and underground workings must take priority and not be stored or transported with other materials or substances. Explosives use during excavation activities will use best industry practice and is considered to be typical use within the mining industry. Page 3 of 90

8 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response References: OPG. 2011a. OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Preliminary Safety Report. Ontario Power Generation report SR R000. Toronto, Canada. (CEAA Doc# 300) OPG. 2011b. OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement. Ontario Power Generation report REP R000. Toronto, Canada. (CEAA Doc# 298) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to, CD# CORR , March 9, (CEAA Doc# ) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to the Final Sub-set of Package #4, CD# CORR , September 28, (CEAA Doc# 759) EIS Section 12, Accidents, Malfunctions and Malevolent Acts Information Request: Provide an assessment of plume temperatures and the velocity of the plume being emitted to the atmosphere for the scenario of an underground fire, as well as the duration of such a scenario. Context: Considering the heat generated by a fire and the rapid rise of air to surface due to buoyancy, it seems unlikely that this contaminated air would cool by the time it reached surface. The assumption made on page 448, Section Dispersion Modelling for Releases of the Preliminary Safety Report provides no technical discussion to support the assumption that the release would be non-buoyant. Also, considering that the contaminated air would exit through one or both of the headframes, the elevated height of these structures is an important consideration in the dispersion of the contaminated air into the surface atmospheric environment. OPG Response: 1. Atmospheric Dispersion Factor for Underground Fire Scenario The preclosure accident assessment for OPG s Deep Geologic Repository conservatively used an atmospheric dispersion factor (ADF) based on non-fire ground-level release for the underground fire scenario (OPG 2011, Section ). For a thermal (buoyant) plume, the ADF is much lower (i.e., more dispersion) than that for non-fire ground-level release (OPG 2011, Table 7-36). A buoyant ADF would result in proportionally lower air concentrations of Page 4 of 90

9 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response radionuclides and non-radiological species off-site, and therefore lower radiological dose and non-radiological hazard to a member of the public than those given in Table 7-40 of OPG (2011) for underground fire scenarios. Similarly, discharge from an elevated height would also result in more dispersion than the assumed ground-level release, and therefore would also reduce the radiological dose and non-radiological hazard to a member of the public from those calculated in the Table 7-40 of OPG (2011) for underground fire scenarios. Since the use of a non-buoyant ground-level release ADF results in a conservative estimate of impact from underground fires, and since the resulting calculated doses are within criteria, an assessment of plume temperatures and velocity is not provided. 2. Fire Duration The estimated fire duration (T FD ), i.e. the time taken to burn all affected waste in an underground fire, is given as 1/ T FD in Table 7-40 of OPG (2011). For example, the estimated fire duration is about 0.7 hrs for a single non-processible waste package, and about 130 hours for an entire emplacement room containing non-processible wastes. The methodology to estimate T FD is provided in Section of OPG (2011). Reference: OPG OPG s Deep Geologic Repository Project for Low and Intermediate Level Waste - Preliminary Safety Report. Ontario Power Generation report SR R000. Toronto, Canada. (CEAA Doc# 300) EIS Section 11, Effects Prediction Section , Effects of the Environment on the Project Information Request: Provide additional information to support the modelling of the onsite direct precipitation flood risk. Describe the impact that errors/uncertainty in the hydrologic model parameters, inputs, assumptions and procedures chosen have on the critical PMP event and computed PMF discharges. Describe the impact that errors/uncertainty in the hydraulic model parameters, inputs, assumptions and procedures chosen have on the computed PMF water surface elevations. Explain the rationale for the chosen Manning s roughness coefficients, including a sensitivity analysis. Context: The assessment describes soil conditions in the study area required for the hydrologic modelling conducted as well as the sources of this data, but the choice of numerical procedures used to compute runoff, of which there are many, are not described, nor are the choices of parameter values for such model inputs that may have been required, such as initial infiltration rate, time of concentration, percent imperviousness, etc. The Proponent states that the Manning s roughness coefficients were chosen to be conservative estimates. Environment Canada indicated that Manning s roughness coefficients are uncertain, especially in such cases as this Page 5 of 90

10 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response when they are chosen based on theoretical values and without proper model validation. Furthermore, roughness can also vary with time (e.g. vegetation growth in drainage channels, lack of channel maintenance). Environment Canada has suggested that the chosen Manning s roughness coefficients would likely have a significant impact on modelled water surface elevations. The sensitivity analysis of errors/uncertainty would be of even greater importance if the calibration and validation of the models were not performed. Environment Canada noted that sensitivity analyses could also be undertaken inversely, by identifying the values of each input that would cause flooding, and then assessing how probable (or improbable) such values are, both individually and in combination. OPG Response: The detailed flood analysis presented in AMEC NSS (2011) was conducted to support the preliminary design. The results of this analysis show that the primary flooding risk for the repository is due to onsite direct precipitation. Flood analysis was therefore conducted for an on-site Probable Maximum Precipitation (PMP) event. It should first be noted that the reference PMP itself is conservative. The flood analysis assumed a PMP of 0.38 m precipitation in one hour. For comparison, the maximum precipitation from Hurricane Hazel was 0.28 m in Ontario over 48 hrs (peak rate of 0.05 m/hr), and from the Harrow storm was 0.45 m in Ontario over 30 hrs (AMEC NSS 2011, Table 5.9). The maximum precipitation from the recent Hurricane Sandy was 0.18 m (in USA) over its multi-hour duration (NASA 2012). The flood analysis predicted maximum flood levels of to metres above sea level (masl) (AMEC NSS 2011, Section 7) based on the preliminary designs of site grading and the stormwater management system. The height of the shaft collars (and other intake/exhaust structures providing access underground) is required to exceed the maximum flood value, with the height to be finalized as part of the detailed engineering design of site grading and the stormwater management system. This detailed design would also include repeating the flood hazard assessment. The detailed design has not been finalized, but the interim reference design height for the shaft collars is 188 masl. In response to this Information Request, sensitivity calculations were made for a number of hydrologic and hydraulic model parameters for the same conditions considered in the AMEC NSS (2011) flood analysis. The following sensitivity cases were evaluated: Soil Conservation Service Curve Number for each sub-catchment in the hydrologic model - varied ±10% and ±20%. Manning roughness n coefficient - varied ±10% and ±40%. Subcatchment Area - increased 10%. Time to peak parameter - decreased 10%. Peak flow from hydrologic model - varied ±10%. Page 6 of 90

11 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Cross-section interdistance - varied ±10%. It was assumed that the DGR main channel will be earthen, straight and uniform with some short grass, and the bank will have some grasses and scattered brush. For these conditions, relevant roughness coefficients are for a clean earth channel, for a weedy earth channel, and for floodplain with tall grass (pasture). Therefore, the reference values of Manning roughness coefficient in the hydraulic model were conservatively estimated as 0.03 and 0.04 for the main channel and bank, respectively (AMEC NSS 2011, Section 5.3.3). The ranges tested in sensitivity analyses were therefore 0.02 to 0.04 for main channel and 0.03 to 0.05 for the bank. Based on the results from the sensitivity analysis, it is concluded that the computed water surface elevations for the base case at the DGR site are not sensitive to modifications to parameters in either the hydrologic or hydraulic model. None of the simulations showed substantial differences in the maximum water surface elevation. The most sensitive hydrologic parameter was subcatchment area, which increased the maximum water surface elevation by m for the +10% increased area case (+0.04 cm for curve number increased 20%, m for Manning s roughness decreased 40%, and no change for time to peak decreased 10%). The most sensitive hydraulic model parameter was the Manning s roughness coefficient in the channel, which increased the maximum water surface elevation by 0.13 m in the +40% case (+0.05 m for peak flow increased 10%, m for cross-section interdistance increased 10%). The area of potential flood risk was not changed from the base case. References: AMEC NSS Maximum Flood Hazard Assessment. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NASA Hurricane Sandy. Retrieved December 3, 2012, from EIS Section 11, Effects Prediction Section , Effects of the Environment on the Project Information Request: Describe the quality assurance measures used to ensure that the elevation data, including both the 0.5 m LIDAR (light detection and ranging) data and site grading and drainage data, were sufficiently accurate, consistent, and properly georeferenced. Explain whether the LIDAR data is of sufficient accuracy and resolution to use for such a small-scale and presumably detailed catchment. Describe any checks performed to ensure consistency between the two datasets. State whether the vertical and horizontal datums were consistent between the two datasets. Context: No context required. Page 7 of 90

12 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response OPG Response: The LIDAR database that has been used as the basis for definition of topography across the DGR site was collected during leaf-off conditions in the fall of LIDAR and orthophoto surveys were completed to obtain a bare-earth digital elevation model and an ortho-rectified photograph of the land area within a 60 km 2 area encompassing the Bruce nuclear site. The data collection quality control process included calibration flights to confirm georeferencing to Geodetic Survey control monuments including BM# U180, a first-order vertical monument located approximately 9.6 km from the DGR site, and BM# , a first-order horizontal monument located in Port Elgin. The LIDAR data was captured at a 1 m 1 m resolution (i.e., a minimum of one point for every 1 m 1 m grid cell). The following is an excerpt from the ground control report that accompanied the data transmittal (Terrapoint 2007). December 14, Ground Control Report - Bruce Nuclear Synopsis: Average delta z Minimum delta z Maximum delta z Average magnitude Root mean square Standard deviation m m m m m m The accuracy report that also accompanied the data transmittal (Terrapoint 2007) indicates the maximum and minimum deviation from ground truth elevation is about 8 cm and -11 cm, respectively. The overall average deviation of the complete dataset is about -2 cm. The accuracies associated with this dataset demonstrate that its use for this assessment is valid. The cross section data upon which the hydraulic model of the DGR site was founded was abstracted from the available 0.5 m LIDAR contour data (described above) supplemented with site grading and drainage data. The site grading and drainage data was geo-referenced in the form of AutoCAD drawing files. When combined with the LIDAR contour data (using AutoCAD) the two datasets were visually co-ordinated both vertically and horizontally. Page 8 of 90

13 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Further, no scaling was required of one or the other datasets to facilitate compatibility (i.e., both datasets were founded in SI units using one drawing unit to represent 1 m). As well, major existing features such as roadways and drainage ditches that were common (i.e., recognizable) within both datasets were seen (visually) to be aligned. This co-ordination between the two datasets was considered sufficient and consistent with the accuracies associated with the modelling methodology that was adopted for the project. Reference: Terrapoint Bruce nuclear site LIDAR data transmittal, supporting text files Network_Control_Report_Fully_Constrained.txt and GPS_Ground_Control_Accuracy_Assessment.txt. Terrapoint Mapping Systems Inc., Ottawa, Canada. EIS Section 11, Effects Prediction Section , Effects of the Environment on the Project Information Request: Describe the impact of the existing drainage system on the Bruce site. State whether OPG confirmed the revision of the assumptions on the depth of the ditch connecting the perimeter ditch to the settling pond. Confirm whether this revision brings into question any of the other information provided in the site grading and drainage data provided by OPG and used in the analysis. Describe the impact that this would this have on the results. Context: It is suggested (pg. 101, Maximum Flood Hazard Assessment document) that the depth and slope of the ditch connecting the perimeter ditch to the settling pond shown in site design drawings was found to be inaccurate and, as a result, assumptions on the depth of the ditch had to be revised from the depth provided. It is stated that a conservative assumption was made for this analysis that the sub-surface stormwater conveyance system (which is designed for the 10-year storm event) would not be functional during the PMF event, and as a result all precipitation from the PMP event falling on the DGR facility would be conveyed through the surface stormwater management system. Environment Canada has questioned whether this is truly a conservative assumption, or if it is possible that the subsurface stormwater system may actually contribute in some way to increased flooding during the PMF event (e.g., perhaps conveying water from other areas of the Bruce nuclear facility to the DGR site). Additional clarification on this assumption is needed. Page 9 of 90

14 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section OPG Response: Impact of Existing Drainage System Information Request and Response The planned drainage system for the DGR is separate from other existing drainage systems on the Bruce nuclear site. There is no flow from the existing surface drainage systems into the planned DGR site stormwater management system. There is no connection of existing subsurface stormwater systems from outside of the DGR site onto the DGR site. In particular, the WWMF surface and subsurface drainage systems drain into the south railway ditch and subsequently Stream C, and are separate from the DGR site stormwater management system. Impact of Assumptions on Depth of Ditch During the preliminary design stage, it was initially assumed that finished ground surface elevation around the DGR surface facilities would be 186 metres above sea level (masl), which corresponds approximately to the current land surface elevation. The flood hazard assessment was based on this assumption, and included a consistent ditch depth (AMEC NSS 2011, Section 5.3.3). However, the preliminary design work indicated that the stormwater management system required a higher ground elevation at the DGR surface facilities to facilitate site drainage. The interim finished ground surface elevation around the surface facilities has been increased to 188 masl. This will be finalized as part of detailed design. This higher elevation will allow greater ditch depth and ensure better runoff from the surface facilities than that considered in the AMEC NSS (2011) flood analysis. Reference: AMEC NSS Maximum Flood Hazard Assessment. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) EIS Section 11, Effects Prediction Section , Effects of the Environment on the Project Information Request: Provide the margin of safety for the design of mitigation measures for flooding. Context: Environment Canada noted that the assessment was based on preliminary design details of the DGR facility and, in part as a result of the assessment s finding regarding direct precipitation flood risk, the design is likely to be revised. While the finding regarding the possibility of flooding itself is sufficiently well-documented, the actual flood elevation is less certain. Environment Canada has noted that if the preliminary design elevations of the DGR facility are to be modified and collar elevations of surface infrastructure determined based on the modelling results, then its suggestions for further analysis are more critical. Page 10 of 90

15 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Environment Canada stated that significantly more detail would be needed on the data, inputs and assumptions used in the modelling in order to be confident that the flood elevations computed are sufficiently accurate for determining or revising the DGR facility s design elevation. A factor of safety should also be included in any design of mitigation measures. OPG Response: The detailed flood analysis presented in AMEC NSS (2011) was conducted to support the preliminary design. The results of this analysis show that the primary flooding risk for the repository is due to onsite direct precipitation. Flood analyses were therefore conducted for an on-site Probable Maximum Precipitation (PMP) event. It should first be noted that the reference PMP itself is conservative. The flood analysis assumed a PMP of 0.38 m precipitation in one hour. For comparison, the maximum precipitation from Hurricane Hazel was 0.28 m in Ontario over 48 hrs (peak rate of 0.05 m/hr), and from the Harrow storm was 0.45 m in Ontario over 30 hrs (AMEC NSS 2011, Table 5.9). The maximum precipitation from the recent Hurricane Sandy was 0.18 m (in USA) over its multi-hour duration (NASA 2012). The flood analysis provided maximum flood levels of to metres above sea level (masl) (AMEC NSS 2011) based on the preliminary design of the stormwater management system. The height of the shaft collars (and other intake/exhaust structures providing access underground) is required to exceed the maximum flood value, with the height to be finalized as part of the detailed engineering design of site grading and the stormwater management system. This detailed design would also include repeating the flood hazard assessment. The detailed design has not been completed, but the interim reference design elevation for the shaft collars is 188 masl. As an estimate of the margin of safety, the total volume of precipitation in the reference 1-hr PMP event was doubled - that is, 0.76 m of precipitation was assumed to fall on the site in one hour. Repeating the analysis from AMEC NSS (2011), the maximum water surface elevation increased to masl, which is less than the interim shaft collar height. There is a large margin in the current design relative to the risk of flooding. This will be reaffirmed as part of the detailed design process. References: AMEC NSS Maximum Flood Hazard Assessment. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NASA Hurricane Sandy. Retrieved December 3, 2012, from Page 11 of 90

16 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section EIS Section 9.3, Valued Ecosystem Components Information Request and Response Information Request: Provide further justification for the selection of the burrowing crayfish as the VEC for benthic invertebrate organisms. Provide a list of, and rationale for, other benthic species that can be used as the VEC to represent the benthic invertebrate community. Context: Section of the Radiation and Radioactivity TSD describes the criteria for selecting a species as a VEC for the benthic invertebrate category, and states that benthic invertebrates live in close contact with the sediment and are relatively immobile; therefore they are highly exposed to the contaminants present therein. However, Section of the Aquatic Environment TSD describes the burrowing crayfish as terrestrial organisms that construct burrows through clay or silty clay soils into the groundwater table these burrows extend above the ground surface Based on that description, it is more likely that the burrowing crayfish would be exposed to soils than to sediments, albeit soils that are in close proximity to water bodies. The burrowing crayfish does not appear to be suitable as the VEC for benthic invertebrates since it does not live in sufficiently close/prolonged contact with sediments. Environment Canada has stated that it agrees that the burrowing crayfish species should remain a VEC, considering the unique habitat requirements, but not as the VEC that represents benthic organisms. Environment Canada recommended that true benthic invertebrates should be selected as VEC s consistent with the description provided in section of the Radiation and Radioactivity TSD and to more accurately identify any risks to this component of the environment. Leeches and snails along with aquatic crayfish are mentioned in section of the Aquatic Environment TSD, however, it is apparent that no comprehensive benthic community survey information is provided in the Aquatic Environment TSD (see IR # EIS ). It is not clear whether such surveys were carried out in Stream C, the South/North Railway ditches and other appropriate waterbodies. OPG Response: No individual species were identified as Valued Ecosystem Components (VECs) in the Radiation and Radioactivity Technical Support (AMEC NSS 2011); instead, the guild, benthic invertebrates, was the VEC. The burrowing crayfish was identified as the indicator for the benthic invertebrate VEC for consistency with the non-radiological VECs. However, the assessment of doses to this indicator was calculated in a manner consistent with an aquatic benthic invertebrate (i.e., resident in water and sediments all the time). In calculating the radiological dose to the burrowing crayfish, the conservative assumption was made that the crayfish exposure would be consistent with the behaviour of an aquatic crayfish (i.e., resident in water and sediments all the time). Therefore, the dose to the burrowing crayfish would be the same as the dose calculated for a species that is a true aquatic benthic (e.g., Orconectes spp.). The DGR Project will not discharge to Stream C, nor will it discharge to the South and North Railway Ditches. Further, Page 12 of 90

17 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section EIS Section , Ambient Radioactivity Section , Radiological Conditions Information Request and Response the North Railway Ditch is frequently dry and does not contain water for extended periods of time to support aquatic flora or fauna; therefore, it is not considered to be a waterbody. With respect to other surveys and information related to benthic invertebrates, please refer also to OPG s responses to EIS (OPG 2012), EIS (OPG 2012), EIS and EIS References: AMEC NSS Radiation and Radioactivity Technical Support. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) OPG OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to a Sub-set of Package #5, CD# CORR , October 24, (CEAA Doc# 776) Information Request: Explain the discrepancy between the levels of Iodine-131 and radioactive particulates in air measured in 2001 and those measured between Evaluate whether the Project may cause emissions to again increase above the levels measured from , and evaluate any effects this might have. Context: Table of the Radiation and Radioactivity TSD shows that from years 2002 to 2008, the annual air emissions from the Western Waste Management Facility (WWMF) for Iodine-131 ranged from approximately 1x10 4 Bq to 4x10 5 Bq comprising 1% or less of the total Iodine-131 air emissions from the Bruce site. By comparison, in 2001, the WWMF released 2x10 7 Bq of Iodine-131 to the atmosphere, which was 42% of the total Iodine-131 air emissions from the Bruce site. Likewise, radioactive particulate air emissions from the WWMF ranged from 4x10 4 Bq to 2.5x10 6 Bq between 2002 and When compared to most years in the period, the 2001 air emissions of radioactive particulate (and Iodine-131) were approximately three orders of magnitude greater. Despite the marked difference, no acknowledgment of this is made nor any explanation provided. OPG Response: The primary contributor to the WWMF airborne releases is the radioactive waste incinerator. The "old" incinerator, which operated until 2001, employed a simple one stage off-gas baghouse filtration system designed in the 1970s. The "new" incinerator, which was installed in 2002, employs a more modern three stage off-gas treatment system consisting of a spray cooler, a dry acid gas scrubber (based on lime and carbon addition), followed by a final filtration stage. The primary purpose of the acid gas scrubber is to remove acidic products of combustion, such as chlorine compounds, by chemical reaction. The system is also very efficient at removing other compounds which have similar chemical Page 13 of 90

18 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response properties, including iodine. The dry powder addition to the off-gas also provides a pre-coat layer to the baghouse filter, which improves its efficiency for removing radioactive particulate. This system has, therefore, resulted in the step change reduction in the emission of I-131 and radioactive particulate from 2001 to Table 1 presents data which demonstrate the change from pre-2001 to post The year-to-year fluctuations are primarily due to the differences in quantities and compositions of the waste incinerated, which vary from year to year. Tritium and C-14, on the other hand, are present in the off-gas as tritiated water vapour and carbon dioxide gas, respectively. These are not captured by conventional off-gas treatment methods (nor is it practical to do so due to the overwhelming large amounts of chemically identical normal hydrogen and carbon-12 in the combustion gases), hence their emissions remain unaffected by the new system. Table 1: Annual Releases to Air from the Western Waste Management Facility Year Iodine-131 (Bq) Contaminant Particulate (Bq) x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x 10 5 Sources: 1995 to 2000: OPG Quarterly Technical Reports 2001 to 2009: AMEC NSS to 2011: BRUCE POWER 2011 and 2012 Page 14 of 90

19 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response The DGR Project will not cause iodine-131 and radioactive particulates to increase. References: AMEC NSS Radiation and Radioactivity Technical Support. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) BRUCE POWER Annual Summary & Assessment of Environmental Radiological Data for Bruce Power report B-REP R000. (available at BRUCE POWER Annual Summary and Assessment of Environmental and Radiological Data for Bruce Power Report B-REP R000. (available at EIS Section , Ambient Radioactivity Information Request: Provide additional justification for the explanation offered for the exceedances of the gamma water release action level and the apparent upward trend of the gamma-delta water release data from 2006 to Context: Page 40 of the of the Radiation and Radioactivity TSD states that the action level for gross beta was exceeded in Table does not actually indicate action levels but rather, the Derived Release Limits (DRL) for the parameters monitored. Although the annual water releases of gross betagamma from 2001 to 2005 were below 1% of the DRL, there seems to be an upward trend starting from 2006 where gross beta-gamma increased from about 1% of the DRL to more than 10% of the DRL by The explanation on page 40 suggests that the exceedances of the action level in 2009 were a result of the use of road salts and lab techniques. However, it is not clear whether the use of road salts in the other years had any impact on the data. There is little additional information to support the OPG s conclusion. Furthermore, there is no indication in the Radiation and Radioactivity TSD to acknowledge the upward trend, nor is there any explanation regarding this upward trend. OPG Response: The action level for gross beta in liquid effluent for the Western Waste Management Facility (WWMF) is Bq/month. The value was incorrectly reported in Section of Radiation and Radioactivity Technical Support (AMEC NSS 2011) as Bq/month. In the WWMF, gross beta in liquid discharge was calculated based on radioactivity in samples detected using gross beta Page 15 of 90

20 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response analysis technique and the measured volume of water discharged to the environment. Note that up to 2011, annual emissions of gross beta in liquid discharge from WWMF were reported as gross beta/gamma in the Bruce Power s Radiological Environmental Monitoring Program (REMP) documentation. As described below, there are three reasons for the upward trend in gross beta radioactivity in liquid discharges from 2006 to Use of Road Salt Starting in winter 2007, there was an operational change at the WWMF. Road salt was used to replace urea as a deicing agent for the WWMF s surface de-icing needs. As a result, potassium-40, a naturally-occurring radionuclide, was introduced to WWMF liquid effluent (surface drainage) in the form of impurities in the road salt. It is currently the main constituent of gross beta radioactivity in liquid effluent at the WWMF (OPG 2010). This explains a strong seasonal effect on the gross beta concentration in the surface drainage samples observed from the third quarter of 2007 to the first quarter of 2010 as illustrated in Figure Increase in Minimum Detection Levels When the sensitivity of the gross beta measurement is reduced, it can result in the minimum detection level (MDL) rising above the actual level of gross beta within the sample. Following introduction of salt, the MDLs have increased as a result of beta self-shielding due to higher content of solids in the samples. This leads to overestimation of the actual beta levels because the reported value for measurements below MDL is based on the MDL value. This increase does not reflect an actual increase in radioactivity in effluent but is an artifact of the reporting approach. 3. Expansion of the WWMF The operational conditions at the WWMF have changed with the development of new buildings/facilities. The operating footprint at the WWMF, including the paved area which requires de-icing in the winter, has increased by approximately 50% since This has resulted in a significant increase in the amount of surface water effluent (Figure 2) (OPG 2010). While this did not impact concentrations, the increase in the volume of the run-off has resulted in increased total radioactivity discharged from the WWMF. Page 16 of 90

21 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Figure 1: Gross Beta Concentration in Surface Water (2006 to 2010) Page 17 of 90

22 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Figure 2: Volume of Surface Water Discharged to Environment (2001 to 2009) Summary The changes discussed above are the major contributors to the action level exceedance observed in the past. The levels of radioactivity present in the water samples collected from sample stations are within the normal operating range of the structures and do not indicate a loss of containment. As noted, there was an upward trend in radioactivity in liquid effluent at the WWMF from 2006 to The radioactivity in liquid effluent increased from 0.01% of the WWMF waterborne gross beta Derived Release Limit (DRL) to 0.1% of the DRL as shown in Table of Radiation and Radioactivity TSD (AMEC NSS 2011). However the upward trend has not continued since For example, gross beta-gamma emission was Bq in 2010 and in 2011, which is lower than the activity of Bq in 2009 (BRUCE POWER 2011 and 2012). Page 18 of 90

23 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response References: AMEC NSS Radiation and Radioactivity Technical Support. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) BRUCE POWER Annual Summary & Assessment of Environmental Radiological Data for Bruce Power report B-REP R000. (available at BRUCE POWER Annual Summary & Assessment of Environmental & Radiological Data for Bruce Power report B-REP R000. (available at OPG Western Waste Management Facility Waterborne Gross Beta Action Level Exceedance, W-REP R01. EIS Section , Ambient Radioactivity Information Request: Provide more detailed information regarding the location of the tritium in precipitation monitoring stations located within the Site Study Area. Provide more recent monitoring data for the Site Study Area. Context: Precipitation that is contaminated by tritium falls within the various watersheds of the Site Study Area, and will fall or flow into various habitats (e.g. North and South Railway Ditch, Stream C, Baie du Doré, wetlands adjacent to the Project site). These areas include habitat for a variety of terrestrial and aquatic species (e.g. the endangered spotted turtle, various fish species, burrowing crayfish, etc.). It is therefore important to assess effects within these habitats. However, the tritium precipitation data presented in Table in the Radiation and Radioactivity TSD is mainly for monitoring locations that lie outside, or at the edges of, the Site Study Area, for the period Locations within the Site Study Area have not been sampled since There is no text description of the precipitation monitoring locations associated with the data in Table in the Radiation and Radioactivity TSD. Based on data from Table , there has been an overall increasing trend of tritium in precipitation between 2001 and Specifically, at monitoring locations B2 and B4, which are the locations closest to the Site Study Area, the tritium concentration in precipitation has gradually increased two-fold from 2001 to This suggests that tritium levels in precipitation may also be increasing within the Site Study Area. Recent data for the Site Study Area should be provided to understand if a similar trend is occurring, and what the current tritium concentrations are. OPG Response: The tritium in precipitation data reported in Table of the Radiation and Radioactivity Technical Support (TSD) (AMEC NSS 2011) are based on samples collected at a sampling point on the Amenities Building roof within the Western Waste Management Facility (WWMF) (i.e., the Project Area) using a tipping rain gauge (OPG 2005, Section ). Page 19 of 90

24 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response No additional monitoring data has been published for the concentration of tritium in precipitation for the Site Study Area. Recent tritium in precipitation data for the Local and Regional Study Areas are provided in Table 1. Table 1: Annual Average Tritium Activity in Precipitation Monitoring Location 1 Average Tritium Activity in Precipitation (Bq/L) B B B B B B B B B B Notes: 1 Sampling locations are shown on Figure of AMEC NSS AMEC NSS 2011 (Table ) 3 BRUCE POWER 2011 (Table 4.3.3a) 4 BRUCE POWER 2012 (Table 9) As described in the Radiation and Radioactivity TSD (AMEC NSS 2011, Section 5.5.2), tritium levels in precipitation are related to the concentration of tritium in air. The increasing trend in tritium in precipitation parallels the increase in tritium emissions described in Section of the TSD (AMEC NSS 2011), which appears as tritium in precipitation due to washout (BRUCE POWER 2010, Section 2.3.3). The WWMF is a small contributor of tritium releases to air, amounting to less than 4% of the releases from the Bruce nuclear site in 2009 (AMEC NSS 2011, Table ). The WWMF will continue to contribute a very small fraction of the Bruce nuclear site tritium emissions to air, which are the source of tritium in precipitation. For the same reason, future trends for tritium in air will not be influenced by the operation of the DGR Project. BRUCE POWER (2008, Section 4.2.1) states that a slight increasing trend is noticed in airborne tritium concentrations at most sampling stations since 1997 consistent with the corresponding increases in release rates at Bruce A and Bruce B. Page 20 of 90

25 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response The increases in 2003 and 2004 coincide with the restart of Bruce A Units 3 and 4. Since 2005, increased airborne tritium has been associated with specific processes. Maintenance has been completed, or is planned, to reduce the releases (BRUCE POWER 2008, Section 4.2.1). The data in Table 1 show a reduction in tritium in precipitation in 2011 over This reduction is attributed to reduced emissions from Bruce B (BRUCE POWER 2012, Section ). As described in Section of the Radiation and Radioactivity TSD (AMEC NSS 2011), and as shown by the data reported in Table 1, the concentration of tritium in precipitation generally decreases with distance from the Bruce nuclear site. The assessment of effects of the DGR Project examined potential effects on non-human biota associated with radiation doses from exposure to radioactivity in the air, surface water, and from other media into which the radioactivity may transfer. The existing dose rates, shown in Table of the Radiation and Radioactivity TSD (AMEC NSS 2011), are less than the reference values that are expected to ensure the survival of populations of biota. The potential effect of DGR Project radiological emissions on non-human biota is documented in Section of the Radiation and Radioactivity TSD (AMEC NSS 2011). The assessment determined that releases of radioactivity from the DGR Project are not likely to have an adverse effect on non-human biota. References: AMEC NSS Radiation and Radioactivity Technical Support. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) BRUCE POWER Bruce Power New Nuclear Power Plant Project Environmental Assessment. Radioactivity Technical Support. BRUCE POWER Annual Summary & Assessment of Environmental Radiological Data for Bruce Power report B-REP R000. (available at BRUCE POWER Annual Summary & Assessment of Environmental Radiological Data for Bruce Power report B-REP R000. (available at BRUCE POWER Annual Summary & Assessment of Environmental & Radiological Data for Bruce Power report B-REP R000. (available at OPG Radiation and Radioactivity Technical Support. Western Waste Management Facility Refurbishment Waste Storage Project Environmental Assessment. SENES Consultants Ltd. report for OPG. EIS Section , Ambient Radioactivity Information Request: Provide an explanation for the steady increases of tritium detected in well WSH231 since 2002 and the increases of tritium in well WSH243 since Provide information regarding the radiological groundwater contamination in the existing Western Waste Management Page 21 of 90

26 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Facility (WWMF) area and any influences it may have on the proposed DGR project area. Context: Figure of the in the Radiation and Radioactivity TSD show that from approximately January 2002, there has been a significant increase in tritium at the WSH 231 to about 30,000 Bq/L; then there seems to be an upward trend from approximately 2004 to a maximum of 80,000 Bq/L in The Radiation and Radioactivity TSD explains that the tritium trend in this well is believed to be primarily influenced by the tritium collecting in the foundation drains of Low Level Storage Buildings. However, it is unclear whether there is a hydraulic connection between the foundation drains and the site groundwater (i.e. cracks in the foundation drains). There is no explanation of what was done to verify this explanation, what remedial measures are being undertaken, and what effect these tritium plumes may have in relation to the DGR Project. The Radiation and Radioactivity TSD explains that these tritium levels are far below the generic screening criteria of 3,000,000 Bq/L for non-potable groundwater. It is not clear what this generic screening criterion is based on. Additionally, Figure shows that the tritium levels in WSH243 have been steadily increasing, from approximately 50 Bq/L in 2005 to approximately 300Bq/L in Although these numbers are relatively low in comparison to WSH23, no explanation for this trend is provided. OPG Response: This response is provided in addition to information previously provided in OPG s responses to (IR) EIS (OPG 2012a) and EIS (OPG 2012b) on tritium in groundwater and Canadian Nuclear Safety Commission (CNSC) oversight at the OPG Western Waste Management Facility (WWMF). Information provided in these responses is, in part, reproduced below. A routine groundwater monitoring program is conducted at the WWMF as a condition of an operating licence issued by the CNSC. The purpose of the monitoring program is to observe and detect changes in groundwater quality that may occur as a result of WWMF operation. The current monitoring system is comprised of 20 WSH-series wells, including WSH-231 and WSH-243 that are positioned at or near the facility perimeter. The monitoring well network was specifically designed to detect changes in groundwater quality within the upper most aquifers beneath the site in which lateral contaminant migration could occur beyond the WWMF site boundary. The monitoring well network was initially installed in 1990 and has since been increased to accommodate WWMF site expansion. A description of the hydrogeologic conditions in the vicinity of the WWMF, the WSH-series groundwater quality monitoring well network, the spatial distribution of tritium in groundwater at the WWMF and numerical simulations to illustrate the impact of activities in the DGR project area on groundwater flow and tritium migration in the vicinity of the WWMF is provided by Sykes (2012). The groundwater simulations performed by Sykes (2012) indicate that that tritium levels in groundwater in the vicinity of the WWMF will have no material influence on activities conducted in the DGR project area. Noteworthy is that groundwater tritium concentrations in WSH-series monitoring wells down gradient of WSH-231, in particular, those within Page 22 of 90

27 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response the underlying shallow confined carbonate bedrock aquifer (including WSH-243) in which lateral migration beyond the WWMF boundaries could occur, do not exceed ~500 Bq/L. The results of the groundwater monitoring program are reported quarterly to the CNSC as a condition of the WWMF operating licence. In certain circumstances, such as at WSH-231, sampling is conducted bi-weekly and reported monthly to the CNSC. The CNSC is providing regulatory oversight with respect to the tritium in groundwater observed at the WWMF. It should be recognized that all WSH-series monitoring wells are controlled and inaccessible to the public, and are constructed such that they cannot be used as a source of potable drinking water. References: OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to, CD# CORR , March 9, (CEAA Doc# ) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to a Sub-set of Package #6, CD# CORR , November 29, (CEAA Doc# 823) Sykes, J.F OPG DGR: Analysis of the Impact on the WWMF of Groundwater Withdrawal Associated with the Construction of the DGR Shafts. NWMO Technical Memorandum DGR-TM Toronto, Canada. (CEAA Doc# 365) EIS Section , Aquatic Environment Information Request: Provide the following additional information about the aquatic environment baseline: Detailed description of the fish sampling program conducted at Stream C on July 2007 including a map depicting the location of the sampling stations, sampling methodology and sampling results. (Note that results of the 2007 sampling program for the South Railway Ditch were provided in OPG`s response to IR# EIS (p. 47) but there was limited information on how the sampling program was conducted.) Detailed description of the fish sampling program conducted at MacPherson Bay on July 2007 including a map depicting the location of the sampling stations, sampling methodology and sampling results. Detailed description of the smallmouth bass nest sampling program conducted at the Baie du Doré which is briefly depicted on Figure D-3 including a description of the sampling methodology and sampling results. Also provide a description and summary of results of any other fish and benthic invertebrate surveys conducted at the Baie du Doré in previous years. Detailed description of any benthic invertebrate sampling surveys conducted across the Site Study Area (SSA) Page 23 of 90

28 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response (i.e., MacPherson Bay, Baie du Doré, North and South Railway ditches and Stream C), including a map depicting the location of the sampling stations and sampling methodology. Context: OPG has indicated that various field sampling surveys have been conducted in the Site Study Area in 2007 and However, very little information has been provided for review. A well-established baseline is necessary in order to facilitate temporal comparisons to identify changes in the Site Study Area. The following considerations establish the need for the additional information requested: It is indicated on p. 45 of the Aquatic Environment TSD and in OPG s response to IR# EIS that various species were collected in Stream C on July 2007 however a limited amount of information has been provided about how the sampling program was conducted. Also, there was no data provided for Stream C in Appendix C or in OPG s response to IR# EIS-01-14, just a brief summary on p. 45. The requested information will ensure that the baseline dataset for Stream C is complete in order to determine if future project-related activities have an effect on Stream C. The benthic invertebrate community is an indicator of habitat health. There was no indication in the EIS of any sampling programs or sampling data collected in the Site Study Area for the assessment of the benthic invertebrate community. It is briefly discussed on p. 45 of the Aquatic Environment TSD that cold-water species have been found at MacPherson Bay (i.e. round whitefish, lake whitefish, lake trout, deepwater sculpin) but no detailed information is provided for these species in Table C-2. It is also indicated on p. 45 that studies focusing on lake whitefish and round whitefish have been conducted in the area, therefore the requested information should be available. There is no additional information provided in the of the Aquatic Environment TSD about the smallmouth bass nest sampling program conducted in the Baie du Doré other than the information presented on Figure D-3 of the Aquatic Environment TSD. Additional information on the survey and the rationale behind the survey will be of value to the assessment of potential effects of the Project on the Study Site Area. OPG Response: The aquatic ecology field program for the DGR Project focused on collecting data to fill known data gaps in the existing information for watercourses and waterbodies where potential effects due to the DGR Project were anticipated. The Project will not discharge to Stream C or Baie du Doré. The description of the existing aquatic environment provided in the Aquatic Environment Technical Support (TSD) (GOLDER 2011) is a combination of field data collected for the DGR Project and information from secondary sources. Fish Sampling Program at Stream C and the South Railway Ditch (July 2007) The July 2007 fish sampling in Stream C was completed as part of the Bruce New Nuclear Power Plant Project Page 24 of 90

29 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Environmental Impact Statement (EIS) (BRUCE POWER 2008), not as part of the field data collection for the DGR Project. The sampling stations were depicted on Figure , Stream "C" Assessment 2007 (enclosed), of the Bruce New Nuclear Power Plant Project Aquatic Environment TSD (GOLDER 2008). The field sampling protocol and detailed results of that sampling program are found in the Bruce New Nuclear Power Plant Project Aquatic Environment TSD (GOLDER 2008, Section and Appendix E). The results of the sampling program are provided in OPG s response to Information Request (IR) EIS (OPG 2012a). As stated in the Aquatic Environment TSD (GOLDER 2011, Section 5.1.2), fish sampling was conducted in the South Railway Ditch from the area adjacent to the proposed DGR Project to the confluence with Stream C. Fish sampling locations in the South Railway Ditch are shown on Figure 1, Fish Sampling in the South Railway Ditch (enclosed). The method for the fish sampling in the South Railway Ditch is provided in Section of the Aquatic Environment TSD and restated here. The sampling was conducted using a Smith Root backpack electro-fisher following the Ontario Ministry of Natural Resources (MNR) single pass electro-fishing procedure outlined in the Ontario Stream Assessment Protocol (Stanfield 2005). Captured fish were enumerated, and fork and total length (as applicable) were measured and recorded. All captured fish were released after handling. Observations of fish habitat and aquatic vegetation were recorded. The estimated length of the surveyed reach was 1,100 m with 5,560 seconds of electro-fishing conducted. The fish sampling results for the South Railway Ditch are provided in Table C-3 of the Aquatic Environment TSD (GOLDER 2011). OPG s original response to IR-EIS (OPG 2012a), and supplementary response to IR-EIS (OPG 2012b) provided additional quantitative data from this program. Fish Sampling Program at MacPherson Bay (July 2007) The nearshore fish community in MacPherson Bay was sampled in July 2007 as part of the aquatic field program for the DGR Project. The methods used included seine nets and minnow traps as documented in the Aquatic Environment TSD (GOLDER 2011, Section 5.1.2). A map depicting aquatic sampling locations in MacPherson Bay is provided for this response as Figure 2, Aquatic Sampling (enclosed). The sampling results for this program are provided in Tables C-1 and C-2 of the Aquatic Environment TSD (GOLDER 2011). Page 45 of the Aquatic Environment TSD (GOLDER 2011) referenced coldwater species (e.g., lake whitefish and lake trout) in deep water habitats and offshore open lake habitats. The Aquatic Environment TSD (GOLDER 2011) did not indicate that coldwater species were caught in MacPherson Bay as part of the sampling program. The species caught during the 2007 fish sampling program in MacPherson Bay are generally warmwater species. Table C-2 in the Aquatic Environment TSD (GOLDER 2011) lists those species that were caught during the July 2007 nearshore fish sampling in MacPherson Bay. This list does not contain any of the coldwater species mentioned on page 45 of the Aquatic Environment TSD (GOLDER 2011). The statement referring to studies focusing on lake whitefish and round whitefish spawning in the vicinity of the Bruce nuclear site is in recognition of a number of historical studies such as the Bruce 5-8 Environmental Effects Report (OPG 1999). Page 25 of 90

30 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Smallmouth Bass Nest Sampling Program at Baie du Doré No sampling of smallmouth bass nests was conducted as part of the aquatic field program for the DGR Project. However, the Bruce New Nuclear Power Plant EIS (BRUCE POWER 2008, Section 2.2.3) did include field studies to count active smallmouth bass nests in the Bruce A and Bruce B discharge channels, Baie du Doré and MacPherson Bay in May and June Descriptions of the smallmouth bass nesting program methods and results can be found in the Bruce New Nuclear Power Plant Project Aquatic Environment TSD (GOLDER 2008, Sections and ), which found that there were no smallmouth bass nests observed in MacPherson Bay. It was determined that there was no plausible pathway of effect from the DGR Project to the smallmouth bass nesting habitat in Baie du Doré, thus further analysis of this field data was not required for the DGR Project. Because the DGR Project will not discharge to Stream C, thus will not have any direct effects on aquatic species in Baie du Doré, no specific aquatic field work was completed in Baie du Doré as part of the DGR Project. The Aquatic Environment TSD (GOLDER 2011, Section 5.3.3) provided a summary of existing aquatic conditions in Baie du Doré based on secondary sources. Benthic Invertebrate Sampling Program OPG s responses to IRs EIS and EIS (OPG 2012c) contain detailed information on benthic invertebrate sampling programs across the Site Study Area from secondary sources. These responses indicate that background information and incidental observations of invertebrate use of the aquatic systems were used to characterize the existing conditions in the Project Area for benthic invertebrates. For instance, in 2004 a bioinventory of the South Railway Ditch for the Western Waste Management Facility Integrated EA Follow-Up Program concluded that the benthic invertebrate community consists of few species, including leeches, aquatic snails, aquatic crayfish and larval beetles at stations located in open water areas of the ditch (KINECTRICS 2005, Section 8). Sampling methods and sampling locations can be found in the Western Waste Management Facility Integrated EA Follow-Up Program report (KINECTRICS 2005, Section 3 and Appendix J). These invertebrate observations were supported by DGR field studies in 2007 and reported in the Aquatic Environment TSD (GOLDER 2011, Section 5.3.1). There were no benthic invertebrate community sampling programs in Stream C as part of the DGR field program. It was determined early on that drainage from the DGR site would be conveyed away from Stream C. Since there would be no direct pathway of effect from the DGR Project on Stream C, sampling of benthic invertebrates was not undertaken. The South Railway Ditch was not sampled because it is a constructed, ephemeral and intermittent feature, in which seasonal variability is high and dry conditions preclude sampling. The North Railway Ditch does not contain water for extended periods of time to support aquatic flora or fauna; therefore, it is not considered to be an aquatic habitat as documented during the field studies for the DGR Project and reported in the Aquatic Environment TSD (GOLDER 2011, Section 5.3). In addition, the drainage from the DGR site would be conveyed away from both the North and South Railway Ditches. Page 26 of 90

31 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response A quantitative assessment of benthic invertebrate communities in MacPherson Bay and Baie du Doré was completed in 2007 to support the Bruce New Nuclear Power Plant Project EIS (BRUCE POWER 2008, Section ). The findings were summarized in Section of the Aquatic Environment TSD (GOLDER 2011) and detailed in the responses to information requests EIS and EIS The benthic sampling locations are depicted on Figure 2 to this response. The sampling methods and detailed data on the benthic invertebrate communities can be found in the Bruce New Nuclear Power Plant Aquatic Environment TSD (GOLDER 2008, Section , and Appendix E). References: BRUCE POWER Bruce New Nuclear Power Plant Project Environmental Assessment - Environmental Impact Statement. GOLDER Bruce New Nuclear Power Plant Project Environmental Assessment: EIS Studies Aquatic Environment Technical Support. GOLDER Aquatic Environment Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc # 299) KINECTRICS Western Waste Management Facility Integrated EA Follow-up Program. Phase III - Operational Phase. Report No. K RA-0001-R0. Prepared for Ontario Power Generation. OPG Bruce 5-8 Environmental Effects Report. Ontario Power Generation report No. NK29-REP R00. OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to, CD# CORR , March 9, (CEAA Doc# ) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Supplementary Material to Information Request (IR) Package #1 Responses, CD# CORR , July 10, (CEAA Doc# 606) OPG. 2012c. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of a Sub-set of Package #5, CD# CORR , October 24, (CEAA Doc# 776) Stanfield, L Ontario Stream Assessment Protocol. Fish and Wildlife Branch, Ontario Ministry of Natural Resources. Peterborough, Canada. Page 27 of 90

32 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response EIS Section , Surface Water Information Request: In addition to the information requested in IR# EIS 03-79, data on the following water quality parameters should be provided to establish surface water quality baseline in the Site Study Area (i.e., MacPherson Bay, Baie du Doré, North and South Railway ditches, and Stream C): dissolved oxygen; chlorophyll a; and biological oxygen demand (BOD). Context: Releases from the Project can also contribute to eutrophication in the receiving environment. Monitoring of chlorophyll a and BOD will provide an indication of the eutrophication potential at the sampled water body. Monitoring of dissolved oxygen will be an indicator of habitat quality for the fish communities in the Site Study Area. This establishes important baseline information for temporal comparisons as part of the Follow-Up Monitoring Program. OPG Response: The DGR Project will not discharge to the North and South Railway Ditches, Stream C or Baie du Doré. Therefore, releases from the DGR Project will not affect the trophic conditions in these surface water features. The measures of dissolved oxygen, chlorophyll a and biological oxygen demand (BOD) can be used to characterize trophic status and biological activity. While the effluent from the DGR project (stormwater management pond) is not expected to have any significant concentrations of phosphorous or organic material (e.g., biological oxygen demand), it is expected to contain nitrate and ammonia. However, the effluent is not expected to change the trophic status of MacPherson Bay since the growth of algae and/or macrophytes in MacPherson Bay will be limited by the available phosphorous. Appendix E of the Hydrology and Surface Water Quality Technical Support (GOLDER 2011) shows that the phosphorous concentrations in MacPherson Bay are less than the Provincial Water Quality Objective for phosphorous used in the assessment (0.020 mg/l). As stated in OPG s response to Information Request (IR) EIS (OPG 2012), since the monitoring locations are characterized by shallow water depths, dissolved oxygen is not a concern. Surface re-aeration will maintain dissolved oxygen values at near-saturation levels in shallow water bodies. This is especially true for MacPherson Bay, which is subject to wind/wave action, and Stream C, which is a continually flowing water body. References: GOLDER Hydrology and Surface Water Quality Technical Support. Golder Associates Ltd. report for Page 28 of 90

33 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response the Nuclear Waste Management Organization NWMO DGR-TR R000. (CEAA Doc# 299) OPG OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to the Final Sub-set of Package #5, CD# CORR , November 7, (CEAA Doc #793) EIS Section , Surface Water Information Request: Provide the results of surface water quality monitoring conducted at the control water quality sampling stations in Goderich and the Little Sauble River. Explain the observed elevated levels of total suspended solids, nutrients and metals observed in some of the surface water quality samples collected in the Site Study Area. Context: Sections , , (and in more detail Appendix E) of the Hydrology and Surface Water Quality TSD indicate that some water quality parameters were elevated at some of the surface water quality stations in the Site Study Area. For example, total phosphorus was noted as elevated above the PWQO guideline of 20 μg/l in 2003 and 2004 water quality samples collected at the South Railway Ditch and in the October 27, 2009 water quality sample. These elevated concentrations were noted by the Proponent as being consistent with water quality results at the control stations; however, the results from the control station water quality samples were not provided for comparison. Other examples include the elevated iron concentrations detected on several water quality samples collected in 2007 and 2009 from SW1 (Stream C Upstream) and zinc concentrations measured at SW5 (Drain Under Interconnecting Road) in 2007 and OPG Response: The Hydrology and Surface Water Quality Technical Support (TSD) (GOLDER 2011, Section 5.5.1) provides a characterization of the existing water quality conditions in the Site Study Area. The TSD states: Where appropriate, results from the sampling programs are compared with the Provincial Water Quality Objective (PWQO) [9] and the Canadian Council of Ministers of the Environment (CCME) Guidelines [26]. This comparison is provided solely to reflect water quality relative to existing accepted benchmarks. In general, the PWQOs provided more stringent criteria than the CCME Guidelines and therefore most of the discussions below reference the PWQO criteria instead of the CCME Guidelines. The DGR Project does not discharge to the South Railway Ditch or to Stream C. Therefore the project will not affect metals levels in these surface waters. Page 29 of 90

34 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Explanations of the exceedances are not required to define the baseline conditions; however, the following information is provided. As indicated in the Hydrology and Surface Water Quality TSD (GOLDER 2011, Section ), the elevated levels of Total Suspended Solids (TSS) were measured in samples taken after rainfall events (i.e., rained within the previous 24 hours). Concentrations of TSS are commonly elevated in surface waters following rainfall events. The Hydrology and Surface Water Quality TSD (GOLDER 2011, Section ) identifies elevated total phosphorous levels in the South Railway Ditch in samples collected in 2003 and In water quality sampling completed for the DGR Project, only two samples measured phosphorous levels above the PWQO of 20 µg/l; both only slightly above at 23 and 28 µg/l. It should be noted that for phosphorous, there are three PWQOs of varying levels of protection, and these levels are specific to particular receiving water environments. Although the two samples measured phosphorous levels above the PWQO used in the assessment (20 µg/l of phosphorous to avoid nuisance concentrations of algae in lakes), a PWQO of 30 µg/l exists for phosphorus (to avoid excessive plant growth in rivers and streams). The levels measured in samples for the DGR Project are below this value. Ammonia levels in the DGR samples did not exceed the criterion. The DGR Project sampling sites for which metal concentrations exceeded criteria are listed in the Hydrology and Surface Water Quality TSD (GOLDER 2011, Section ). Samples collected from the South Railway Ditch (sampling locations SW3 and SW4) exceeded the PWQOs for iron and zinc. As discussed in OPG s response to Information Request EIS , the South Railway Ditch received surface runoff from the Spent Solvent Treatment Facility, as well as potential runoff from a Sewage Processing Plant and an abandoned oil unloading facility. Sediments in the South Railway Ditch have also been observed to have elevated concentrations of some metals (EIS ). Samples taken at the Drainage Culvert under Interconnecting Road (SW5) also showed elevated levels of zinc, iron and copper. This ditch is located adjacent to a roadway on the Bruce nuclear site. The water quality sampling results (Goderich and Little Sauble River control sites only) from the Western Waste Management Facility Integrated EA Follow-up Program (KINECTRICS 2005, Appendix E) are provided below for reference (scanned images of printed report). (Note: larger size tables are provided at the end of the responses to EIS IRs). Page 30 of 90

35 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Page 31 of 90

36 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Page 32 of 90

37 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Page 33 of 90

38 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response References: CCME Canadian Environmental Quality Guidelines. Canadian Council of Ministers of the Environment. GOLDER Hydrology and Surface Water Quality Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) KINECTRICS Western Waste Management Facility Integrated EA Follow-up Program. Phase III - Operational Phase. Kinectrics Inc. report K RA-0001-R00. MOE Water Management - Policies, Guidelines, Provincial Water Quality Objectives of the Ministry of Environment and Energy. (issued 1994; reprinted 1999) EIS Section , Surface Water Section , Information Request: Evaluate water quality data against the proper Provincial Water Quality Objectives (PWQO) and Canadian Council of Ministers of the Environment (CCME) s Canadian Environmental Quality Guidelines (CEQG). Provide and evaluate data regarding un-ionized ammonia. Page 34 of 90

39 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Surface Water Information Request and Response Context: Environment Canada noted various issues with some of the proposed water quality criteria in Appendix D of the Hydrology and Surface Water Quality TSD, as follows: Total Ammonia CEQG criteria: mg/l i. The Proponent should note that the CCME water quality guideline for the protection of aquatic life is phand temperature-dependent. The Proponent should indicate what ph and temperature the suggested criteria range was based on. Un-ionized Ammonia CEQG criteria is 19 μg/l. Nitrate CEQG criteria: The Proponent provided a narrative guideline; however, it should be noted that there is a CEQG of 13 mg/l for freshwater environments. Temperature: Environment Canada proposes the use of CCME s Thermal criteria, whereby thermal additions to receiving waters should be such that the maximum weekly average temperatures (MWAT) and short-term daily maximums of the sensitive important species that are normally found at that location and time are not exceeded. Environment Canada also suggests that the Proponent refer to the 1987 Canadian Council of Resource and Environment Ministers thermal guidance factsheet for additional information. Turbidity CCME CEQGs for turbidity are for clear flow and high flow on turbid waters scenarios. The stated guideline for the high flow case is incorrect. The correct guideline is the following: i. maximum increase of 8 NTUs from background levels at any one time when background levels are between 8 and 80 NTUs. Should not increase more than 10% of background levels when background >80 NTUs. Mercury stated CCME CEQGs of mg/l is incorrect. The correct CCME CEQG is: i. Inorganic: μg/l ii. Organic: μg/l Uranium: The Proponent should note that there is a new CCME CEQG for uranium: i. Chronic exposure: 15 μg/l ii. Acute exposure: 33 μg/l Page 35 of 90

40 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response OPG Response: Appendix D of the Hydrology and Surface Water Quality Technical Support (TSD) (GOLDER 2011) provides a list of the criteria used to define an adverse effect resulting from changes in surface water quality associated with the stormwater management pond (SWMP) discharge (GOLDER 2011, Section 8.1.1). These criteria are not proposed discharge criteria for the project, though they may be referenced in the future during the Ontario regulatory permitting process to establish site specific discharge criteria. Appendix E of the Hydrology and Surface Water Quality TSD (GOLDER 2011) presents a summary of the existing surface water quality data for sample locations SW1, SW2, SW3, SW4, SW5 and SW6. As discussed in the document (GOLDER 2011, Section 5.5.2), where appropriate, results from the sampling program were compared with the Provincial Water Quality Objectives (PWQO) and the Canadian Council of Ministers of the Environment (CCME) guidelines. This comparison was provided solely as context for existing surface water quality relative to existing accepted benchmarks. In general, the PWQOs provided more stringent criteria than the CCME Guidelines and therefore most of the discussions in Section (GOLDER 2011) reference the PWQO. OPG acknowledges that the CCME CEQG values for total ammonia rely on both temperature and ph. The following table provides a matrix of total ammonia CEQG values for various temperature and ph ranges. The two values listed in Appendix D (GOLDER 2011) were provided as examples, and fall generally in the middle of the criteria table. The final criteria will be determined through the Ontario permitting process and would be based on Table 1 below. Table 1: Water Quality Guidelines for Total Ammonia for the Protection of Aquatic Life (mg/l NH 3 ) ph Temperature ( o C) Source: CCME Page 36 of 90

41 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response OPG acknowledges that the CEQG for un-ionized ammonia is 19 μg/l. All of the sample results presented in Appendix E (GOLDER 2011) are below the 19 μg/l criterion. In most cases, sample results are below the reported method detection limits, which ranged from 0.3 to 2.0 μg/l. The maximum concentration of un-ionized ammonia was calculated to be 13 μg/l in a sample collected at SW2 (Stream C exiting the Bruce nuclear site). OPG acknowledges that there is a CEQG of 13 mg/l for nitrate in freshwater environments. Nitrate was not analyzed in the samples collected; therefore, a comparison with the criterion is not possible. In Appendix D (GOLDER 2011), the narrative CEQG nitrate guideline was provided. At the time the Hydrology and Surface Water Quality TSD (GOLDER 2011) was prepared, the CEQG value of 13 mg/l for protection against direct toxic effects was listed as an interim guideline. OPG acknowledges that there are CCME criteria for thermal additions. However, there are no anticipated thermal additions associated with discharges from the DGR Project. The only discharge from the DGR Project will be effluent from the SWMP. During the construction phase, the water in the SWMP will include surface runoff and water pumped from the underground construction areas (i.e., groundwater infiltration and process water from drill and blast). During operations, water from the SWMP will include surface runoff and water pumped from the underground repository (i.e., groundwater infiltration). A temperature differential between the water discharged from the SWMP and MacPherson Bay is not expected because the water in the SWMP will be subject to the same environmental influences (e.g., ambient air temperatures) as MacPherson Bay. The temperature of MacPherson Bay was determined to correlate well with the ambient air temperature (GOLDER 2011, Section ). OPG acknowledges that there are two separate CCME CEQG for turbidity. The criterion listed in Appendix D (GOLDER 2011) was for turbidity in situations with high flow or turbid waters. There is a second criterion for clear flow situations. Environmental conditions determine which of these criteria applies. Footnote 24 to the table in Appendix D should read: Clear flows: Maximum increase of 8 NTUs from background levels for a short-term exposure (e.g., 24-h period). Maximum average increase of 2 NTUs from background levels for a longer term exposure (e.g., 30-d period). High flow or turbid waters: Maximum increase of 8 NTUs from background levels at any one time when background levels are between 8 and 80 NTUs. Should not increase more than 10% of background levels when background is >80 NTUs. Appendix E (GOLDER 2011) summarized the results of the sampling program used to characterize existing surface water quality. The criteria for turbidity define allowable changes from existing (baseline) conditions and cannot be used to evaluate the existing turbidity levels. OPG acknowledges that there are currently two CCME CEQGs for mercury: μg/l for inorganic mercury and μg/l for organic mercury. However, only total mercury was analyzed in the samples collected (GOLDER 2011, Appendix E); therefore, comparison of existing mercury levels in surface water to the CCME CEQGs is not possible. The Page 37 of 90

42 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response criterion of mg/l for filtered mercury that was listed in Appendix D is incorrect. The new CCME CEQGs for uranium is noted. Measured concentrations of total uranium were well below the new CCME CEQGs (both chronic exposure and acute exposure) in all samples, with a maximum concentration of 1.7 μg/l measured at SW5 (west end of South Railway Ditch) (GOLDER 2011, Appendix E). References: CCME Canadian Environmental Quality Guidelines Summary Table Ammonia (Total). (accessed on November 19, 2012 from GOLDER Hydrology and Water Quality Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) EIS Section , Aquatic Environment Information Request: Provide the rationale for the observed elevated concentrations in Appendix F of the Hydrology and Surface Water Quality TSD of some parameters in sediment samples collected in the Site Study Area. Indicate if sediment samples have been collected in the Local Study Area and if they have, provide the result of the analysis of those samples. Context: Various parameters in Appendix F of the Hydrology and Surface Water Quality TSD were found to be at elevated concentrations in sediment samples collected in the Site Study Area. Also, sediment quality criteria are available for only a limited number of parameters. Sediment quality data should be interpreted in the context of data collected from the Local Study Area. OPG Response: The Hydrology and Surface Water Quality Technical Support (TSD) (GOLDER 2011) documented the results of the sediment sampling program undertaken as part of the characterization of the existing environment, conducted for the Environmental Impact Statement (EIS) (OPG 2011). Sample results were compared with the relevant standards and guidelines at the time: Canadian Council of Ministers of the Environment (CCME) Canadian Sediment Quality Guidelines (CSQG) for the protection of aquatic life (CCME 1999); and/or the Ontario Ministry of the Environment (MOE) Soil, Ground Water and Sediment Standards (SGWS), Table 1 for background conditions (MOE 2009). Exceedances of applicable criteria in sediment samples collected are listed below. Exceedances of the sediment criteria for copper and zinc were reported in samples at SW3, SW4 and SW5. Exceedances of the criteria for arsenic, cadmium and nickel were also reported in the sample at SW3. Page 38 of 90

43 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Petroleum Hydrocarbons (PHC) concentrations were generally below the detection limits with some exceptions. In samples at SW1, SW4 and SW5, the reported concentrations of F3 (C16 to C34 hydrocarbons) PHC ranged from 13 to 41 µg/g, with a maximum measured concentration of 720 μg/g from the sample at SW3. Additionally, an F4 (C34 to C50 hydrocarbons) PHC concentration of 460 μg/g was reported at SW3 (South Railway Ditch west); however there are no CCME CSQG or MOE SGWS for PHC in sediment. The highest concentrations of metals were recorded at sampling location SW3 (shown on Figure of GOLDER 2011) which is located in the South Railway Ditch adjacent to the Western Waste Management Facility (WWMF). Concentrations of copper and zinc were observed to exceed the CCME CSQG and/or the MOE SGWS in the samples collected at SW4 (in the South Railway Ditch downstream of SW3), although concentrations were lower than those measured in the sample collected at SW3 (GOLDER 2011, Appendix F). PHC concentrations were measurable in the samples collected from the South Railway Ditch locations and at the SW1 and SW5 locations, which are adjacent to roadways with frequent traffic. Sediment sampling was also completed in the WWMF Integrated EA Follow-Up Program, conducted between 2000 and Exceedances of CCME and MOE sediment criteria relevant at the time of the studies were reported for a number of metals. In the Phase I sampling program undertaken from spring 2000 spring 2001, exceedences of criteria were measured for cadmium, copper, manganese, nickel and zinc in South Railway Ditch sediment samples (Patrick and Romano 2001, Table 8; Patrick et al. 2001, Table 7). Phase II sampling, conducted from fall 2001 to fall 2002, measured exceedances of sediment quality criteria for arsenic, cadmium, chromium, copper, iron, lead, manganese, nickel, silver and zinc in samples collected from the South Railway Ditch (OPG 2005a, Table 7). A statistical analysis determined that concentrations measured in the samples collected in 2002 were significantly higher than those for samples collected in Phase III sampling was conducted in 2003 and Exceedances of sediment quality criteria were observed for cadmium, chromium, copper, manganese, nickel, and zinc in the samples collected in the South Railway Ditch (KINECTRICS 2005, Table 11). These exceedances recorded over the course of the WWMF Integrated EA Follow-up monitoring program are consistent with the data collected in 2009 and reported in Section of the Hydrology and Surface Water Quality TSD (GOLDER 2011). These data are summarized in Table 1, which shows that no measured concentrations of metals in South Railway Ditch samples exceeded applicable sediment criteria for the first time in Page 39 of 90

44 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Table 1: Maximum Concentrations Measured in South Railway Ditch Sediment Samples for Metals that Exceed Relevant Sediment Quality Criteria Metal Units CCME a MOE b WWMF Integrated EA Follow-up Phase I Sampling Campaign WWMF Integrated EA Follow-up Phase II WWMF Integrated EA Follow-up Phase III DGR Project 2000 c May 2001 d August 2001 e 2002e 2003 f 2004 f 2009 g Arsenic µg/g Cadmium µg/g Chromium µg/g Copper µg/g Iron µg/g - 20,000 h 16,562 13,842 6,750 24,400 15,100 14,500 16,000 Lead µg/g Manganese µg/g h N/A , ,300 Nickel µg/g - 16 N/A Silver µg/g N/A <0.2 Zinc µg/g , ,200 Notes: a CCME (Canadian Council for Ministers of the Environment) Canadian Sediment Quality Guidelines for the Protection of Aquatic Life; exceedances bolded b SGWS (Soil, Ground Water and Sediment Standards) Table 1: Full Depth Background Site Conditions Standards (for Sediment); exceedances shaded c Based on Table 8 in Patrick and Romano (2001); sampling conducted in May 2000 and August 2000 d Based on Table 7 in Patrick et al e Based on Table 7 in OPG 2005a; sampling conducted in August 2001, May 2002 and September 2002 f Based on Table 11 in KINECTRICS 2005; sampling conducted in November 2003 and June 2004 g Based on Appendix F in GOLDER 2011, sampling conducted in September 2009 h MOE Guideline for the Protection and Management of Aquatic Sediment Quality in Ontario, 1993 Metals concentrations measured during the WWMF Integrated EA Follow-up monitoring program sampling campaigns were highly variable as shown in Table 1 and documented in OPG 2005b (Section ). The maximum sediment concentrations generally occurred in the samples collected in May 2002 and/or September 2002 at the WWMF Integrated EA Follow-up program sampling location W3, which approximates sampling location SW3 used for the 2009 Page 40 of 90

45 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response DGR Project sampling program. Many of the sediment metals concentrations measured in 2003 and 2004 sampling were at levels measured during 2000/2001 and at off-site control sampling locations (Little Sauble River, Goderich). It was hypothesized that the variability observed in concentrations of various metals in the South Railway Ditch sediments may be associated with sampling anomalies that introduce cross-contamination with railway bed materials that have elevated metals concentrations (OPG 2005b, Appendix C). The concentration of trace elements on stream bed materials is strongly affected by the particle-size distribution of the sample (USGS 1994). Generally, the concentration of trace elements on stream bed materials increases as particle size decreases (USGS 1994). Fine grained sediments are generally located in zones of deposition, and are usually associated with higher levels of contaminants than other particle size fractions (ENVIRONMENT CANADA 1994). Therefore, variations in the physical characteristics of the sample locations (e.g., bottom topography, water depth, and whether the sample was collected from a depositional or erosional zone), could affect the distribution of particle size and account for the variability in metals and PHC concentrations in the South Railway Ditch samples. The metals for which elevated concentrations were observed in sediment samples collected from the South Railway Ditch in 2009 are those for which elevated concentrations have been observed in sampling programs undertaken over the past decade, as explained above. The South Railway Ditch receives drainage from the former Spent Solvent Treatment Facility (SSTF) as well as potential runoff from the Sewage Processing Plant and the Waste Chemical Transfer Facility (OPG 2005b, Section ), and an abandoned oil unloading facility on the opposite side of the South Railway Ditch. Drainage and runoff from each of these facilities would likely include metals, oil and organics that are sometimes observed in elevated concentrations in the sediments sampled from the South Railway Ditch (OPG 2005b, Section ). Approximately 100 to 200 L of spent boiler cleaning solvent from the SSTF leaked to the South Railway Ditch in February It was hypothesized that this leak, which took place upstream of the South Railway Ditch sampling points, may have contributed to the observed metals contamination (KINECTRICS 2005, Section 3.2.3). Petroleum hydrocarbons and heavy metals (including arsenic, cadmium, copper, nickel and zinc) are common rail way and rail yard contaminants. The railroad ties may have been preserved with creosote, which is a distillate of coal tar. It should be noted that the SW3 and W3 locations correspond roughly with the location of the spur line. Heavy lubricants are used in railway switch plates. It is also possible that additional wear and weathering at the junction could have resulted in higher erosion of rail bed and railway materials into the ditches at those sample locations. Samples from two control locations on the Little Sauble River, located in the Local Study Area south of the Bruce nuclear site, were collected throughout the WWMF Integrated EA Follow-up Program (KINECTRICS 2005; OPG 2005a; Patrick and Romano 2001). The samples were collected approximately 500 m apart on the lower reaches of the river near the eastern boundary of Inverhuron Provincial Park. The sampling sites on the Little Sauble River were selected as controls for the WWMF Integrated EA Follow-up Program since they are located in proximity to the Bruce nuclear site, but are not affected by activities occurring on the site (Wong 2000, Section 4.1). The analyses confirmed that the metal concentrations measured in the South Railway Ditch sediment samples are higher than those measured in the Little Sauble River sediment samples. The results from the control samples collected in November 2003 and June 2004 were Page 41 of 90

46 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response enclosed with OPG s response to Information Request EIS (OPG 2012). In June 2001, sediment samples were collected from five locations at the head of Baie du Doré, which is located in the Local Study Area (BRUCE POWER 2002). Analysis of all samples indicated that there are low concentrations of metals in sediments collected in the nearshore area around the Bruce nuclear site relative to deep basin Lake Huron background concentrations. The results are also consistent with the levels of copper (16 µg/g), lead (1 µg/g), and zinc (14 µg/g) measured in sediments collected from MacPherson Bay (SW6 on Figure of the Hydrology and Surface Water Quality TSD) in 2009 (GOLDER 2011, Appendix F). The results of the sediment quality study conducted in 2001 are shown in Table 2. Table 2: Mean Concentration of Copper, Lead and Zinc in Sediments Sampled in Baie du Doré, June 2001 (BRUCE POWER 2002, Table ) Sampling Location Metal (µg/g dry weight) Copper Lead Zinc Baie du Doré #1 8 <5 18 Baie du Doré #2 13 <5 31 Baie du Doré #3 8 <5 15 Baie du Doré #4 7 <5 18 Baie du Doré #5 5 <5 19 Lake Huron Background Note: 1 Data from deep basin of lake (BRUCE POWER 2002) The 2001 Baie du Doré sediment samples were also analyzed for PCB compounds. The results of the analysis yielded no detectable levels at a detection limit of 0.05 µg/g, indicating there has been no long-term accumulation of PCB compounds in sediments (BRUCE POWER 2002, Section ). These results are consistent with the findings of the 2009 study reported in Section of the Hydrology and Surface Water Quality TSD (GOLDER 2011, Appendix F). In general, the elevated concentrations of heavy metals and PHCs measured at various sample locations correspond with areas of the site that are more developed, with a historical industrial use, and are proximal to higher traffic areas (roadways or railway). It is unlikely that a single point source contributed to these elevated levels, but that they are rather the result of a variety of non-point sources over the 50-year history of the site. The elevated parameters measured in the site study area are not uncommon to sites with a long history of industrial development. Page 42 of 90

47 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response References: BRUCE POWER Bruce A United 3 & 4 Restart Environmental Assessment Study Report. Volume 1: Main Report. CCME Canadian Environmental Quality Guidelines. Canadian Council of Ministers of the Environment. ENVIRONMENT CANADA Guidance on Collection and Preparation of Sediments for Physicochemical Characterization and Biological Testing. Report EPS 1/RM/29. GOLDER Hydrology and Surface Water Quality Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) KINECTRICS Western Waste Management Facility Integrated EA Follow-up Program; Phase III Operational Phase October 2003 May Kinectrics report K RA-0001-R00. MOE Soil, Ground Water and Sediment Standards for Use Under Part XV.1 of the Environmental Protection Act Ministry of the Environment. OPG. 2005a. Western Waste Management Facility Integrated EA Follow-up Program. Phase II Report During Construction Phase Re-issue Ontario Power Generation report REP R01. OPG. 2005b. Western Waste Management Facility Refurbishment Waste Storage Project Environmental Assessment Study Report. Ontario Power Generation report REP R01. OPG OPG s Deep Geologic Repository for Low and Intermediate Level Waste Environmental Impact Statement. Ontario Power Generation report REP R000. Toronto, Canada. (CEAA Doc# 298) OPG OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Information Request (IR) Package #3, CD# CORR , July 9, (CEAA Docs# and 615) Patrick, P.H., H. Kowalyk, and J. Kowalewski Western Waste Management Facility Low and Intermediate Level Waste EA Follow-up Environmental Monitoring Program, Phase I Report The Pre-Construction Phase. Report No REP R00. Patrick, P.H. and C. Romano Bruce Used Fuel Dry Storage Project Environmental Monitoring Program Phase I Report Pre-Construction Phase. Report No REP R00. USGS Guidelines for Collecting and Processing Samples of Stream Bed Sediment for Analysis of Trace Elements and Organic Contaminants for the National Water Quality Assessment Program. U.S. GEOLOGICAL Page 43 of 90

48 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response SURVEY, Open-File Report Wong, T.S Bruce Used Fuel Dry Storage Project, Environmental Assessment Follow-up Program Environmental Monitoring Program Manual. Ontario Power Generation File WF R01, CD #0198-MAN R00. EIS Section 6.1, Aboriginal Peoples Information Request: Provide details on engagement activities conducted by OPG/NWMO with Aboriginal groups since the EIS was completed in March Include information on concerns or issues raised by Aboriginal groups in relation to the project and how OPG has addressed or plans to address these concerns or issues. Context: The EIS Guidelines require the proponent to describe in the EIS how concerns respecting Aboriginal people will be addressed. The description should include a summary of discussions, the issues or concerns raised, and should consider and describe any asserted or established Aboriginal rights, Aboriginal title and treaty rights. OPG Response: Saugeen Ojibway Nation (SON) Representatives of SON and OPG continue to meet regarding OPG s operations within SON Traditional Territory, including concerns respecting OPG s proposed Deep Geologic Repository Project. OPG and SON have met approximately ten times since the Environmental Impact Statement (EIS) submission including meetings of the OPG- SON DGR Joint Liaison Committee. SON seeks to protect the safety of their communities, the integrity of their Traditional Territory, and their Rights and interests within that Territory. OPG and SON continue to implement their DGR Protocol Agreement which provides capacity for, among other things, SON community engagement and communications, technical review of the DGR EIS and related materials, technical studies, and identification of affected rights and interests. In that respect, SON and OPG have met to discuss issues included in the EIS for the proposed DGR project and SON has met in caucus in preparation for meetings with OPG, and the federal regulator, to undertake technical research and capacity building initiatives relating to nuclear waste, and for participation in the JRP regulatory review. SON leadership provides oversight and direction and leads community information sessions on matters related to SONIOPG relations. SON representatives have attended JRP orientation and technical information sessions. Additional technical documents not included in the DGR EIS were provided for review by the NWMO/OPG. SON continues to build community and leadership understanding of the proposed Project, to prepare for SON participation in the JRP process, and to prepare Page 44 of 90

49 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response for continued engagement with OPG on the Project. Historic Saugeen Métis (HSM) Engagement activities with the HSM have been carried out in accordance with a Participation Agreement signed by HSM, OPG and NWMO in HSM engagement activities have focused on community consultation, technical expert peer review, and the collection of traditional knowledge. Since the filing of the EIS submission, there have been five meetings of a tri-partite Working Group to further the HSM engagement in the above areas. Additionally, DGR project staff has attended the Annual HSM Rendezvous in both 2011 and 2012, including an exhibit at the 2012 event to disseminate information and to address community questions about the project. To date, OPG has received no input from HSM that would lead to changes to design, construction and operating plans resulting from the engagement. HSM have expressed an ongoing interest in long-term environmental monitoring programs that are currently the subject of discussion. Métis Nation of Ontario (MNO) Engagement activities with the MNO have been carried out in accordance with a Participation Agreement signed by MNO (including the Georgian Bay, Moon River, and Great Lakes Métis Councils), OPG and NWMO in May MNO engagement activities have focused on community consultation, technical expert peer review, and the collection of traditional knowledge. Since the filing of the EIS submission, there have been five meetings of a tri-partite Liaison Committee to further the MNO engagement in the above areas. Additionally, there have been two tours arranged for MNO community members of the waste management facilities at the Bruce nuclear site, and an article to be published about the project in the Voyageur newsletter. DGR Project staff has attended the MNO s Annual Regional Fish Fry in July 2012 to discuss the project with community members. To date, OPG has received no input from MNO that would lead to changes to design, construction and operating plans resulting from the engagement. MNO collection of traditional knowledge and peer review activities are expected to be completed early United Chiefs and Councils of Mnidoo Mnising (UCCMM) NWMO/OPG presented an overview of the DGR Project to UCCMM staff and elders on May 30, Following the meeting, OPG offered, in correspondence, to arrange further meetings or a tour of the Western Waste Management Facility and the DGR site on request from UCCMM. Wikwemikong Unceded Indian Reserve NWMO/OPG presented an overview of the DGR Project to Wikwemikong staff and elders on May 31, Following the meeting, OPG offered, in correspondence, to arrange further meetings or a tour of the Western Waste Management Facility and the DGR site on request from Wikwemikong. Page 45 of 90

50 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response OPG s response to Information Request EIS (OPG 2012) provides information on concerns raised by First Nations and Métis communities and how they have been incorporated in the assessment. Reference: OPG OPG letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to the Final Sub-set of Package #5, CD# CORR , November 7, (CEAA Doc# 793) EIS Section 4.2, Factors to be considered in the EIS Information Request: Describe the methods/practices that OPG/NWMO has used to attempt to collect Aboriginal Traditional Knowledge in order to ensure it was considered in the EIS. Context: Given that traditional use of lands and resources is identified as a Valued Ecosystem Component (VEC), it is important to understand how the proponent attempted to collect Traditional Knowledge and Traditional Use information from Aboriginal peoples. OPG Response: Aboriginal Traditional Knowledge was considered in the preparation of the Environmental Impact Statement (EIS) (OPG 2011) where such information was available. This information was gathered through the examination of available information pertaining to general ecological, socio-economic and cultural heritage interests for Ojibway and Métis peoples in Ontario (AECOM 2011, Section 4.1). This included the following: Interests raised by Aboriginal communities with regards to previous studies; Interests raised by Aboriginal communities in the context of dialogue on the DGR Project; and Insights into traditional knowledge and interests of general importance to local Aboriginal communities. In addition to the available literature containing information on Aboriginal Traditional Knowledge, engagement activities were undertaken to provide an opportunity for Aboriginal input to the Environmental Assessment (EA). Some key information that is reported in the Aboriginal Interests Technical Support (AECOM 2011, Section 4.2.1) relates to the traditional Ojibway spiritual worldview which constitutes the foundation of the SON knowledge system, and the unique history, culture and language and Way of Life of Métis peoples. OPG s response to Information Request (IR) EIS (OPG 2012a) describes activities undertaken by OPG to obtain Aboriginal input for use in identifying and finalizing the list of Valued Ecosystem Components (VEC) for the DGR Project. Input on VECs was used to optimize the list to include VECs and indicators which are identified by the Aboriginal groups Page 46 of 90

51 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response to be of interest and importance to their communities. OPG s response to IR-EIS (OPG 2012a) describes the method OPG undertook to obtain Aboriginal Traditional Knowledge for use in identifying VECs for Aboriginal interests. OPG s response to IR-EIS (OPG 2012b) describes how OPG used the results of a peer review, conducted by an independent consultant on behalf of the Saugeen Ojibway Nation (SON), of the Independent Assessment Study (GOLDER 2004) in the EA for the proposed DGR Project. The peer review (ECOMETRIX 2005) identified areas of interest to the SON in relation to the DGR Project and included recommendations for topics to be considered in the EA. OPG s response to IR EIS (OPG 2012c) describes the process used to engage Métis communities and obtain Traditional Knowledge. A list of engagement activities with Aboriginal communities is provided in the EIS (OPG 2011, Table ). Engagement activities included meetings, site tours/visits, correspondence, participation in community events, and distribution of DGR Project information. References: AECOM Aboriginal Interests Technical Support. AECOM Canada Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) ECOMETRIX Peer Review of Independent Assessment of Long-term Management Options for Low and Intermediate Level Wastes at OPG s Western Waste Management Facility. Prepared for Chippewas of Saugeen and Nawash. GOLDER Final Report on Independent Assessment of Long-term Management Options for Low and Intermediate Level Wastes at OPG s Western Waste Management Facility. Golder Associates Ltd. report for the Steering Committee Municipality of Kincardine and Ontario Power Generation. Mississauga, Canada. OPG OPG s Deep Geologic Repository for Low and Intermediate Level Waste Environmental Impact Statement. Ontario Power Generation Report REP R000. Toronto, Canada. (CEAA Doc# 298) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Information Request (IR) Package #3, CD# CORR , July 9, (CEAA Doc# ) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to the Final Sub-set of Package #5, CD# CORR , November 7, (CEAA Doc# 793) OPG. 2012c. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Page 47 of 90

52 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Level Waste Submission of Responses to a Sub-set of Package #5, CD# CORR , October 24, (CEAA Doc# 776) EIS Section 10, Aquatic Environment Information Request: Provide the following additional information: information regarding groundwater recharge to Stream C, including a quantitative assessment of potential impacts from the excavation, construction and operation of the underground facility to the groundwater recharge to stream C; the hydrological properties of Stream C, including the baseline flow rate, depth profile, and seasonal fluctuation data, and a quantitative assessment of the potential impact of the project to the hydrological properties; and the baseline surface water, water column, and substrate temperature of Stream C and an assessment of potential project impact to water temperature due to the change of groundwater recharge to Stream C and Baie du Doré. Context: The information is required to meet the EIS Guidelines Section 10 Existing Environment: The EIS must describe surface water quality, hydrology and sediment quality at the site, local and regional study areas. The proponent must describe hydrological regimes, including seasonal fluctuations and year-to-year variability of all surface waters and assess normal flow, flooding, and drought properties of water bodies as well as the interactions between surface water and groundwater flow systems. As indicated in the Aquatic Environment TSD, Stream C is a DFO-designated coldwater fish habitat including temperature sensitive fish species such as brook trout, rainbow trout, brown trout and Chinook salmon and other forage fish species. More importantly, Stream C is a spawning habitat for the native brook trout. Water temperature in surface water and stream substrates is a key factor in determining brook trout habitat. They need a year-round supply of cold, clear water. The Canadian Nuclear Safety Commission (CNSC) suggested that the change of groundwater recharge to Stream C may change the water temperature enough to lead to changed fish habitat use and changed populations of brook trout and other salmonines in stream C. The CNSC noted that this potential adverse effect could be worsened in the longer term by anticipated increased ambient air and stream water temperature warming due to climate change. As a receiving body for groundwater, the relative importance of groundwater as baseflow into Stream C should be provided as this may inform what additional measures are required to protect the ecological function and quality of Stream C. This information is critical because the evacuation and construction of the underground facility could directly or indirectly affect stream flow and temperature by changing the groundwater level and discharge rate to the stream. No information has been provided regarding the relative importance of groundwater in maintaining the ecological function of Page 48 of 90

53 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Stream C and the area where it empties into the Baie du Doré Provincially Significant Wetland. As such, there is no way to evaluate the risks to ecological function that the DGR Project may pose to the groundwater recharge. OPG Response: The northern portion of the DGR Project Area is underlain by between 0.7 to 1.5 m of surficial sand and gravel to clayey silt (fill materials) overlying at least 10 m of hard low-permeability glacial till. The hydraulic conductivity of the glacial till is three orders of magnitude less than the hydraulic conductivity of the underlying shallow bedrock Lucas Formation. Further information on the near surface hydrostratigraphy of the Project Area is provided in OPG s response to Information Request (IR) EIS (OPG 2012). The native glacial till soil has a very low potential for infiltration. This was conservatively estimated at 5 to 10 cm/yr of surficial infiltration into the till (GOLDER 2011a). Subsequent modelling of the infiltration into the till has been prepared by Sykes (2012), using hydraulic conductivities in the till layer in the range of to 10-9 m/s (K-horizontal, or K h ), with K-vertical (K v ) assigned as one-half of the K h. These estimates were used for modelling the recharge of the Lucas Formation limestone due to leakage through the till. The estimates ranged from 3.3 mm/yr (undisturbed till) to 0.36 mm/yr (waste rock management area reference case scenario). Recharge to the Lucas Formation from the till is a negligible component (approximately 0.03%) of the average annual precipitation (Sykes 2012). During construction, it will be necessary in certain periods to dewater in order to advance the shafts. Given the shaft locations are more than 400 m from Stream C, it is unlikely that dewatering within the bedrock and the resulting zone of influence (ZOI) will have any effect. The Environmental Impact Statement (OPG 2011, Section 7.2.2) and OPG s response to IR-EIS (OPG 2012) describe the estimated ZOI for pumping during construction of the shafts. The estimated ZOI determined during the dewatering design was far less than the distance from the shafts to Stream C. The follow-up monitoring program will include monitoring to ensure that the drawdown during construction, and the resulting ZOI, will have no effect on surface water courses or wetland features. During operations of the DGR, the estimated inflow of groundwater from the overburden into the shafts is expected to be very low, in the range of 1.3 to 1.6 L/day. The ZOI of groundwater inflow into the shafts from the overburden during operations will be much less than the radius during construction of the shafts. Therefore, there will be no influence on surface water courses or wetland features. The DGR Project has been designed such that there are no discharges to Stream C or its tributaries. The only direct interaction of the project with water quantity in Stream C is a reduction in the drainage area due to the proposed diversion of flow from the North Railway Ditch. This reduction in drainage area is predicted to reduce the average annual flow in Stream C by 0.8% (GOLDER 2011b, Section ). A change of 0.8% reduction in flow is not expected to result in an adverse effect on surface water quality or surface water quantity and flow. Since adverse effects to surface water quality and surface water quantity and flow are not expected in Stream C as a result of a reduction of the drainage area, no effects in Baie du Doré, which has an overall drainage area bigger than Page 49 of 90

54 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Stream C, are expected. Because the groundwater infiltrating into the overburden soils within the Project Area does not contribute to baseflows in Stream C, and drawdowns of the groundwater table during construction and operations do not extend to Stream C or surface wetlands, there would be no effect on the temperature regime due to changes in groundwater. As there will be no surface water discharges from the project to Stream C, and only a slight decrease (0.8%) in runoff, changes in surface water should have no measurable effect in temperature. Further, it is predicted that the diverted flow from the North Railway Ditch (0.8%) would have to be more than 12 C cooler than the remaining flow (99.2%) in Stream C to cause a temperature increase of just 0.1 C in Stream C. The temperature data collected during the surface water quality baseline sampling program (Appendix E of the Hydrology and Surface Water Quality TSD [GOLDER 2011b]) shows no such difference exists. Given that groundwater beneath the DGR Project Area does not contribute baseflow to Stream C, and the change in the surface water flow to Stream C is not expected to cause an increase in stream temperatures, there are no anticipated changes to the thermal regime of Stream C as a result of the DGR Project. Therefore, the DGR Project will have no effect on brook trout or any other cold water species that inhabit Stream C. The DGR Project will not have an effect on the ecological functions of Stream C or Baie du Doré. In addition, no changes to the conclusions as a result of climate change (Section 10 of the Hydrology and Surface Water Quality TSD [GOLDER 2011b]) are therefore anticipated. References: GOLDER. 2011a. Geology Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) GOLDER. 2011b. Hydrology and Surface Water Quality Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) OPG OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement. Ontario Power Generation report REP R000. Toronto, Canada. (CEAA Doc# 298) OPG OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Information Request (IR) Package #3, CD# CORR , July 9, (CEAA Doc# ) Sykes, J.F OPG DGR Project: Analysis of Shallow Groundwater Impacts. Nuclear Waste Management Organization Technical Memorandum DGR-TM (P) R0. Toronto, Canada. (CEAA Doc# 682) Page 50 of 90

55 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response EIS Section 10, Aquatic Environment Section 11, Effects Prediction, Mitigation Measures and Significance of Residual Effects Information Request: Provide additional information describing: the baseline information of water quantity and flow rates South and North Railway Ditches, and the drainage ditch (under Interconnecting Road); the baseline information of the quantity and quality of effluents that discharge to South/ North Railway Ditches, Stream C, and MacPherson Bay, discharge criteria and loadings of contaminants, from any projects and/or activities within the study area; and the quantitative assessment of effluent and stormwater discharge to the surface drainage in study area on surface water quantity and quality, sediment quality of Stream C, South and North Railway Ditch, Baie du Doré and MacPherson Bay from the site preparation, construction and operation of the DGR project. Context: This information is required to meet the EIS Guidelines - Section 10 Existing Environments: The EIS must describe surface water quality, hydrology and sediment quality at the site, local and regional study areas. The proponent must describe hydrological regimes, including seasonal fluctuations and year-to-year variability of all surface waters and assess normal flow, flooding, and drought properties of water bodies as well as the interactions between surface water and groundwater flow systems. Furthermore, the baseline description must include characterization of environmental conditions resulting from historical and present activities in the local and regional study area. Only limited baseline information was provided on water quality parameters from the 2007 and 2009 surface water sampling results in the Hydrology and Surface Water Quality TSD. This information is needed to support the EIS prediction statements and as a baseline against which to verify these predictions statements with the EIS follow-up monitoring program. OPG Response: The DGR Project does not discharge to the North or South Railway Ditches or to Stream C. As a result, field studies for the DGR Project did not collect flow measurement data for these streams. However, calculated flow rates for the South and North Railway Ditches and the drainage ditch under Interconnecting Road, the latter which will receive flow from the DGR stormwater management pond, are presented in Table of the Hydrology and Surface Water Quality Technical Support (TSD) (GOLDER 2011). Currently the North Railway Ditch and the drainage ditch under Interconnecting Road are frequently dry, with flow during and following rain events. The EA Follow-up Monitoring Program (NWMO 2011, Table 2) includes collection of flow data for the North Railway Page 51 of 90

56 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Ditch and the drainage ditch near the stormwater management pond outlet as part of baseline monitoring. The data will be measured on a quarterly basis and after each of two storm events, and can be used to calculate an annual discharge volume. Flow rates will also be monitored during the site preparation and construction and operations phases to confirm the effects predicted in the assessment (NWMO 2011, Tables 3a and 3b). Surface runoff from the Bruce nuclear site drains through on-site ditches and ultimately to Lake Huron. Currently there are no direct effluent discharges from the Bruce nuclear site projects and/or activities into Stream C, MacPherson Bay, Baie du Doré, or the North Railway Ditch. The majority of effluents associated with the operation of the Bruce A and B generating stations are directed to the respective condenser cooling water intakes or discharge channels (e.g., see Figure of BRUCE POWER 2005). Domestic sewage from the generating stations is treated at the on-site sewage processing plant that discharges clean effluent to Lake Huron via the Douglas Point outfall (BRUCE POWER 2008, Section ). Surface run-off is collected in the drainage system described in the Hydrology and Surface Water Quality TSD (GOLDER 2011, Section 5.4.3). Surface and sub-surface drainage from the Western Waste Management Facility (WWMF) and Spent Solvent Treatment Facility (SSTF) discharge into the South Railway Ditch. Neither the WWMF nor the SSTF discharges process water, and all effluent from these facilities originates as precipitation. The discharge locations, from west to east, are listed below, and illustrated on the enclosed figure, Western Waste Management Facility General Arrangement 0125-WS FS4: 1. SSTF surface drainage collected in the tank farm dyked area 2. Low Level Storage Buildings (LLSBs) sub-surface drainage 3. LLSBs surface drainage 4. Yard surface drainage (downstream of filter bed) 5. Western Used Fuel Dry Storage Facility (WUFDSF) and East Storage Area surface drainage (via grassed swale) Discharge from the SSTF must meet criteria described in the Operating Procedure for the facility (OPG 2010a). Note that the SSTF is currently in a non-operational state. Section 3.7 of the Operating Procedure (OPG 2010a) specifies the following criteria. ph: 6.5 to 9.5 COD: <20 ppm; in the event COD measures between 20 and <300 ppm, disposal options are considered NH 3 : <300 ppm Copper (Cu): <3 ppm Iron (Fe): <15 ppm Nickel (Ni): <3 ppm Zinc (Zn): <3 ppm In the event that the effluent did not meet one or more of these criteria, it would not be discharged to the South Railway Page 52 of 90

57 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Ditch; however, effluent quality has always been in compliance. Total suspended solids (TSS) are monitored at the outlet of the grassed swale associated with the WUFDSF and East Storage Area as required by OPG s Ontario Ministry of Environment Certificate of Approval (C of A); however, the C of A does not specify a discharge criterion for TSS (MOE 2007). No other discharge criteria are specified in the C of A. Monitoring commenced in 2007, and the results are summarized in Table 1. Table 1: Summary of Grassed Swale Effluent Total Suspended Solids Results for 2007 and 2011 Year Sample Collection Quarter Total Suspended Solids (ppm) October a December b Sampled quarterly 4.27 to c Sampled quarterly 2.14 to d 2011 e Notes: a OPG 2008, Section 4.0 b OPG 2009, Section 4.0 c OPG 2010b, Section 4.0 d OPG 2011, Section 4.0 e OPG 2012a, Section 4.0 Q1 104 Q1 177 Q2 <2 Q Q4 <2 Q Q Q Q The LLSBs surface and subsurface drainage, yard surface drainage, and the WUFDSF and East Storage Area surface drainage are monitored for tritium and gross beta. The effluents are sampled at a series of sampling stations, shown on Page 53 of 90

58 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response the enclosed figure, prior to discharge into the South Railway Ditch. The discharge is monitored by taking flow proportional grab samples that are composited on a weekly basis. The annual activity for 2002 through 2011 is summarized in Table 2, along with the quantity of effluent released to the South Railway Ditch on an annual basis. Table 2: WWMF Flow and Tritium and Gross Beta Loadings to South Railway Ditch 2002 to 2011 (Source: OPG Quarterly Technical Reports, W-REP through [OPG 2002 to 2011]) Year Total Tritium in Waterborne Effluent (Bq) Total Gross Beta in Waterborne Effluent (Bq) Total Flow 3 of Waterborne Effluent (L) E E E E E E E E E E E E E E E E E E E E E E E E E E E E E E+08 Notes: 1. In 2003 the WUFDSF was built, adding area to the site. 2. In 2007, the East Storage Area was developed, adding additional area to the site. 3. The WWMF is not a consumer of water. Water effluent from the site originates from nature (rainfall & snow). As noted, the DGR Project will not discharge any effluent or runoff to the North or South Railway Ditches, to Stream C, or ultimately to Baie du Doré. Surface water quality and sediment quality will not be affected in these water bodies by the DGR Project. As described in the Hydrology and Surface Water Quality TSD (GOLDER 2011, Section 8.2.3) a decrease in flow to the North Railway Ditch is anticipated but it will not result in a significant adverse effect. As described in OPG s response to Information Request EIS (OPG 2012b), underground water and surface runoff will be routed to the stormwater management pond, and subsequently to the drainage ditch for discharge to MacPherson Bay. Discharges from the stormwater management pond will meet all applicable discharge criteria. These criteria will be developed in conjunction with the Ministry of the Environment (MOE) as part of the Ontario Environmental Page 54 of 90

59 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Compliance Approval (ECA) and other regulatory processes (e.g., Canadian Nuclear Safety Commission licensing), and will be protective of the environment. The limits will be established taking into consideration the Provincial Water Quality Objectives, the acute toxicity thresholds for sensitive species that are present in the receiving environment, and the existing water quality in the receiving water at MacPherson Bay. Provided the discharge from the stormwater management pond meets the ECA discharge criteria, no residual adverse effects are anticipated during site preparation and construction, and operations of the DGR Project. The stormwater management system will be decommissioned at the end of operations, and will not be operational during the postclosure phase. References: BRUCE POWER Bruce A Refurbishment for Life Extension and Continued Operations Project Environmental Assessment Study Report. Volume 1: Main Report. BRUCE POWER Bruce New Nuclear Power Plant Project Environmental Assessment. EIS Studies: Socio- Economic Conditions Technical Support. GOLDER Hydrology and Surface Water Quality Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) MOE Ontario Ministry of Environment. Amended Certification of Approval, Industrial Sewage Works Number FRJ4Q, January 10, NWMO DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc #299) OPG to Nuclear Waste Management Division, Western Waste Management Facility and Radioactive Waste Operations Site 1, Quarterly Technical Report, Quarter, Year. W-REP to W-REP OPG Stormwater Management Western Waste Management Facility (WWMF) 2007 Annual Report (9559-6VSQRM). Ontario Power Generation report W-REP R000. OPG Stormwater Management Western Waste Management Facility (WWMF) 2008 Annual Report FRJ4Q. Ontario Power Generation report W-REP R000. OPG. 2010a. Nuclear Waste Management Division Operating Procedure: Spent Solvent Transfer and Holding Facility, OP R011. OPG. 2010b. Stormwater Management Western Waste Management Facility (WWMF) 2009 Annual Report FRJ4Q. Ontario Power Generation report W-REP R000. OPG Stormwater Management Western Waste Management Facility 2010 Annual Report #9205-7FRJ4Q. Page 55 of 90

60 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Ontario Power Generation report W-REP R000. OPG. 2012a. Stormwater Management Western Waste Management Facility 2011 Annual Report #9205-7FRJ4Q. Ontario Power Generation Report W-REP R000. OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Final Sub-set of Package #4, CD# CORR , September 28, (CEAA Doc# 759) EIS Section 10, Aquatic Environment Section 11, Effects Prediction, Mitigation Measures and Significance of Residual Effects Information Request: Provide the following additional information: baseline information of benthic invertebrates and aquatic macrophytes, including but not limited to density and diversity benthic invertebrates and aquatic macrophytes in Stream C, South/North Railway Ditches, Baie du Doré, and MacPherson Bay from available studies and investigations; and an assessment of potential impacts from the site preparation, construction and operation of the DGR project to benthic invertebrates and aquatic macrophytes. Context: This information is required to meet the EIS Guidelines - Section 10 Existing Environments: The EIS must provide a baseline description of the environment, including the components of the existing environment and environmental processes, their interrelations and interactions as well as the variability in these components, processes and interactions over time scales appropriate to this EIS. Benthic invertebrates and aquatic macrophytes are identified VECs for the aquatic environment, and are valuable food sources for other VECs such as fish and terrestrial species. The EIS guidelines direct the proponent provide a description of the aquatic and wetland species at the site and within the local and regional study areas including a description of the flora, fauna and their habitat. The information is important to evaluate the potential impact of the DGR Project on the critical fish habitat. OPG Response: A description of the fish, benthic invertebrates and aquatic macrophytes and their habitat on the DGR site is discussed in Sections (South Railway Ditch) and (wetlands) of the Aquatic Environment Technical Support (TSD) (GOLDER 2011). A description of the fish, benthic invertebrates and aquatic macrophytes and their habitat in the Site Study Area is provided in Sections (Stream C) and (MacPherson Bay and Baie du Doré). The North Railway Ditch does not contain water for extended periods of time to support aquatic flora or fauna; therefore, it is not considered to be an aquatic habitat as documented during the field investigations for the DGR Project and reported in Page 56 of 90

61 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response the Aquatic Environment TSD (GOLDER 2011). Therefore, the North Railway Ditch was not sampled for benthic invertebrates and aquatic macrophytes as part of the baseline sampling program for the DGR Project. Additional information on benthic invertebrates has been provided in OPG s responses to (IR) EIS and EIS (OPG 2012), as identified in the response to IR-EIS An assessment of potential effects of the DGR Project during site preparation, construction and operations on the benthic invertebrates and aquatic macrophytes is provided in the Aquatic Environment TSD (GOLDER 2011, Sections and 8.2). The DGR Project will not discharge to the North or South Railway Ditches, Stream C or Baie du Doré; therefore, will not have any direct effects on the benthic invertebrates in these areas. Potential indirect effects of the DGR Project on the aquatic valued ecosystem components (VECs) variable leaf pondweed and benthic invertebrates through changes in surface water quality, surface water quantity and flow were identified and assessed in Section (South Railway Ditch), Section (Stream C), and Section (Lake Huron, MacPherson Bay and Baie du Doré) of the Aquatic Environment TSD (GOLDER 2011). No measureable changes to these VECs were identified and thus no adverse effects are expected. Section of the Aquatic Environment TSD (GOLDER 2011) demonstrates that the DGR Project activities (e.g., clearing and grubbing of vegetation in the Project Area and construction of the surface buildings and infrastructure) are not expected to have direct interactions with the aquatic environment VECs in Lake Huron, MacPherson Bay, Baie du Doré and Stream C as these habitats are located at least 500 m from all disturbances associated with the DGR Project. It was concluded that, because no potential direct interactions with the aquatic VECs in these habitats are possible, these pathways were not considered further in the assessment of direct effects. References: GOLDER Aquatic Environment Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) OPG OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to a Sub-set of Package #5, CD# CORR , October 24, (CEAA Doc# 776) EIS Section 16, Follow-Up Program Information Request: Provide the following additional information: further reasoning for the lack of the monitoring of water quantity and quality such as the flow rate, contaminant level in surface water and sediment, and temperature of surface water and substrate in Stream C, North and South Railway Ditch; surface water and sediment quality in Baie du Doré and MacPherson Bay; and Page 57 of 90

62 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response further reasoning for the lack of the monitoring of brook trout in Stream C. Context: This information is required to meet the EIS Guidelines - Section 16 Follow-up Program: A follow-up program must be designed to verify the accuracy of the environmental assessment and to determine the effectiveness of the measures implemented to mitigate the adverse environmental effects of the project. As the Hydrology and Surface Water Quality TSD stated, maintaining natural flows and water quality in local stream is critical to various life stages of sensitive species, such as the VEC species brook trout in Stream C. Groundwater recharge to Stream C is very important in maintaining the ecological function of Stream C as important brook trout spawning, feeding, nursery, and rearing habitat. The potential DGR project impacts, including groundwater recharge, water quantity and water quality, should be verified by monitoring the flow rate, temperature and water quality in stream C, North/South Railway Ditch, surface water and sediment quality in Baie du Doré and MacPherson Bay. OPG Response: The DGR site and the surface water management system were designed to avoid discharges to Stream C, and ultimately Baie du Dore, in part, because maintaining natural flows and water quality in Stream C is critical to various life stages of sensitive species, such as the VEC species brook trout in Stream C. As described in Technical Information Session #1 (OPG 2012a), all underground water and all surface runoff from the DGR Project site will be routed to the stormwater management pond (SWMP) via the perimeter ditch system thus preventing a contaminant pathway to Stream C, Baie du Dore, the North Railway Ditch and the South Railway Ditch via surface runoff. SWMP discharge is conveyed through approximately 1 km of vegetated drainage ditch leading to the outlet at MacPherson Bay. The discharge from the SWMP is expected to meet the criteria that will be set as part of the permitting process and to prevent adverse effects to the surface water quality of MacPherson Bay. This prediction will be verified by the surface water quality sampling program (including temperature) described in the DGR EA Follow-up Monitoring Program (NWMO 2011, Tables 3a and 6). Since the SWMP is the only pathway for effects on surface water from the DGR Project to MacPherson Bay, this program will meet the requirement to verify the accuracy of the environmental assessment and to determine the effectiveness of the mitigation measures, as outlined in the EIS Guidelines. OPG s response to Information Request (IR) EIS (OPG 2012b) provides additional rationale on the design of the surface water management system monitoring program. The deposition of sediments in natural water bodies occurs at a slow rate (e.g., typically less than a few millimetres per year). A sample that includes the top few centimetres of sediment can be representative of the environmental conditions of the last decade or more. Therefore, detecting changes in sediment quality trends that would be attributable to the Page 58 of 90

63 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response DGR project is not deemed to be an effective means of confirming predictions made in the EIS in a timely manner. As stated in the Geology Technical Support (TSD) (GOLDER 2011a, Section ), the direction of shallow groundwater flow beneath the DGR site is to the north and west, away from Stream C. An assessment of the impact of the DGR main and vent shaft construction on the shallow groundwater system beneath the Bruce nuclear site is provided in Sykes (2012) which was provided as an attachment to OPG s response to IR EIS (OPG 2012c). As discussed in OPG s response to IR EIS (OPG 2012c), the temporary drawdown created by shaft construction is not expected to influence areal recharge or surface water recharge. Once the hydrostatic shaft liners are installed and sealed (nominal depth 230 m below ground surface), the shafts will be hydraulically isolated and no longer influence the groundwater system. Verification of assessment results will be achieved through proposed routine groundwater and shaft discharge monitoring programs, as discussed in the DGR EA Follow-up Monitoring Program (NWMO 2011, Section 3). The shallow groundwater monitoring program in particular, described in the EA Follow-up Monitoring Program (NWMO 2011, Table 3a, with additional detail provided in OPG s response to IR EIS (OPG 2012b)), will be capable of identifying any changes to the local water table and shallow hydraulic gradients that may have an impact on base flow and recharge in the site study area. It is by these means that the accuracy of the predictions and effectiveness of the mitigation measures presented in the EIS will be verified. There will be no surface water discharges from the DGR site to the North Railway Ditch, therefore water quality monitoring is not required. A change in flow to the North Railway Ditch, estimated to be a decrease of 31% (GOLDER 2011b, Section 8.2.3), was assessed as not significant in part because of the low magnitude. This change in flow will be verified through the flow monitoring described in the EA Follow-up Monitoring Program (NWMO 2011, Table 3a). This predicted decrease in flow in the North Railway Ditch corresponds to a decrease in flow to Stream C of 0.8% (GOLDER 2011b, Section 8.2.3). Given the very low magnitude (i.e., it is not measurable) of this decrease and because flow monitoring in the North Railway Ditch will capture this change, no additional monitoring is proposed at Stream C. Since there will be no surface water discharges to the South Railway Ditch from the DGR project, nor will there be any changes to the current surface water drainage to the South Railway Ditch, no effects are predicted. Therefore, flow monitoring and water quality and sediment sampling are not proposed in the South Railway Ditch. Provided the above stated predictions are verified through their respective monitoring programs, there are no anticipated pathways for effects to Stream C; therefore there is no rationale to monitor brook trout in Stream C. The annual assessment of the effectiveness of the EA Follow-up Monitoring Program (NWMO 2011, Section 16) will provide an opportunity to revise the program should any problems or gaps be identified. References: GOLDER. 2011a. Geology Technical Support. Golder Associates Ltd. report to Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) Page 59 of 90

64 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response GOLDER. 2011b. Hydrology and Surface Water Quality Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) NWMO DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission for the July 18, 2012 JRP Technical Information Session, CD# CORR , July 12, (CEAA Doc# 636) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to the Final Sub-set of Package #5, CD# CORR , November 7, (CEAA Doc# 793) OPG. 2012c. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to, CD# CORR , March 9, (CEAA Doc #) Sykes, J.F Analysis of the Impact on the WWMF of Groundwater Withdrawal Associated with the Construction of the DGR Shafts. NWMO Technical Memorandum DGR-TM Toronto, Canada. (CEAA Doc #365) EIS Section 16, Follow-Up Program Class1 Nuclear Facilities Regulation, 5(i) Information Request: Explain if deformation/displacement measurement/monitoring have been considered for the large underground shaft station and surface area openings. Context: There are large underground openings at the shaft station and service area. Measurement/monitoring of their displacement/deformation is important to confirm the performance of facility, and to ensure the underground stability and the worker s safety during the construction and future operation. OPG Response: A detailed geotechnical investigation and monitoring plan will be developed for the shaft and repository excavations in advance of development activities. This plan will include geotechnical monitoring and related instrumentation/equipment, geological and geomechanical investigations during construction, as well as, long-term monitoring requirements during the operation phase. Specific to deformation/displacement monitoring, vertical displacement (single and multiple point borehole extensometers) and stress measurements (strain cells) are planned in multiple locations for the large span areas of the Page 60 of 90

65 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS EIS Guidelines Section EIS Guidelines, Section 12 Class1 Nuclear Facilities Regulation, 5(i) Information Request and Response repository (e.g., main access tunnel, maintenance shop, large tunnel intersections), as well as, within the panel access tunnels and the emplacement rooms. In many locations, monitoring equipment will be installed in both the back (roof of the tunnel) and the floor. Information Request: Explain if the Peak Particle Velocity (PPV) criteria for blasting operations consider appropriate PPV criteria for the Bruce nuclear generating stations. Provide a monitoring plan, including the monitoring locations, to ensure that the PPV from the blasting is below the proposed criteria. Context: Blasting from the shaft and underground facility excavation will cause ground vibration which might have an impact on different receptors. The PPV criteria (values) were proposed for different receptors by considering the requirements from different guidelines. However, it is not clear if the PPV criteria considered the safe operation requirement for the Seismic Source Characterizations of the Bruce nuclear generating stations. The CNSC noted that the Darlington New Build set the PPV criteria of 3 mm/s by considering the Turbine operation requirement of the Darlington DGS [Site Evaluation of the OPG New Nuclear at Darlington]). The CNSC suggested that it seems no monitoring programs, in particular, the monitoring locations, are proposed to ensure that the PPV is below the criteria. OPG Response: The Atmospheric Environment Technical Support (TSD) (GOLDER 2011, Section I5) predicted ground vibration resulting from blasting activities for the DGR Project on a number of potential sensitive receptors. The nearest portion of the Bruce A and B stations, the transformers and switchyards, are located at approximately 700 m and 1200 m, respectively, from the DGR Project site. The peak particle velocities (PPV) estimated (95% confidence limit) to occur at the Bruce A and Bruce B transformers and switchyards, as a result of DGR blasting, based on the scale distance curve established from Bruce B intake tunnel blasting (GOLDER 2011, Table I6-1), are 0.5 mm/s and 0.3 mm/s, respectively. These estimates are based on maximum explosive weights of 112 and 150 kg per delay during shaft sinking and underground development, respectively. Bruce A and Bruce B generating stations, at distances of approximately 1400 m and 1470 m respectively, are further from the DGR Project site than the transformers and switchyards. High ground vibration attenuation was demonstrated to be characteristic of the Bruce site during the demolitions of the Bruce Heavy Water Plant towers which generated ground motion with low dominant frequencies similar to those from underground blasts. For example, the PPVs measured during the 2685 ton DA103 tower demolition reduced from 134 mm/s at 30 m from the source to 3.4 mm/s at Page 61 of 90

66 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response 130 m and 0.9 mm/s at 435 m. Based on the high ground vibration attenuation, ground vibrations (95% confidence limit) at each station during DGR blasting would be less than the estimated values at the switchyards and are estimated to be approximately 0.25 mm/s and 0.2 mm/s, respectively. Based on these predictions, blasting at the DGR project site is not anticipated to affect the operation of the Bruce nuclear generating stations. It is noted that the PPVs predicted to be felt at the Bruce A/B nuclear generating stations are substantially below the 3 mm/s criterion used for Darlington reactors as noted in the Context section above. A preliminary monitoring program is proposed in the DGR EA Follow-up Monitoring Program (NWMO 2011, Section 7.1). A detailed monitoring program will be developed with the shaft sinking contractor, and in consultation with Bruce Power, after the contract has been awarded and the blasting design finalized. References: GOLDER Atmospheric Environment Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) NWMO DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) EIS Section 8.7, Malfunctions, Accidents and Malevolent Acts Class1 Nuclear Facilities Regulation, 5(i) Information Request: Clarify if local rock falls in the shaft station and service area are considered in the Malfunctions, Accidents and Malevolent Acts TSD, and justify the annual frequency of occurrence applied for rock falls and rockbursts (i.e., 10-2 and 10-7 ). Context: In both EIS (section 8.1) and Malfunctions, Accidents and Malevolent Acts TSD (section 3.2), OPG indicated that local falls within emplacement rooms were considered as a geotechnical malfunction and the accident initiating event with a potential annual frequency of occurrence between 10-2 and It is not clear if local rock falls in the shaft station and service area were considered. OPG Response: Rock fall/rock burst was identified as one of the initiating events for preclosure accidents in the Environmental Impact Statement (EIS) (OPG 2011a, Section 8.1), the Malfunctions, Accidents and Malevolent Acts Technical Support (MAMA TSD) (AMEC NSS 2011, Section 3.2), and the Preliminary Safety Report (OPG 2011b, Section 7.5.1). The annual frequency scale is presented as a simple scale - possible, unlikely or non-credible. To assign events to this scale, a range of frequencies is considered - possible (>10-2 ), unlikely (between10-2 and 10-7 ) or non-credible ( 10-7 ). An explanation of the initiating event frequency estimate is also given in OPG s response to Information Request Page 62 of 90

67 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response (IR) EIS (OPG 2012). With respect to radiological accidents, as noted in the EIS (OPG 2011a, Section ) and in the MAMA TSD (AMEC NSS, Section ), the justification for the frequency is provided in the Preliminary Safety Report (OPG 2011b, Section ). It is important to note that the initiating event frequency is only used to identify non-credible accidents, as both possible and unlikely events are evaluated. Rock fall and rockburst are defined here to mean rock failure sufficient to cause crushing or breaching of a container - otherwise there would be no radiological release. Such rock fall and rockburst events are identified as unlikely within the DGR operations phase for the following reasons: Use of ground and roof support for all underground areas; Defined minimum floor and ceiling thicknesses within the Cobourg Formation for mechanical stability; Alignment of the emplacement rooms (where packages are stored) with principle stress direction; High strength of the host rock relative to the expected in-situ stresses; and Completion of excavation before operation begins. The latter is an important point because it allows time to observe the rock mass behavior to confirm stable rock conditions before waste packages are emplaced. Assuming rockfall occurs, then it could occur in any area of the DGR. However, with respect to radiological accidents, rockfall in the service area is not relevant as waste packages are not brought into the service area. Rockfall within the shaft station would only have a radiological consequence if packages were present at the time; however, packages are not normally stored in the shaft station area. Therefore, the most likely location for rock fall leading to a radiological accident would be within an emplacement room. Note that the non-radiological implications of rockfall and rockburst, including areas such as the service area or shaft station, are considered qualitatively within the MAMA TSD (AMEC NSS 2011), see Table 5.2-1, Credible Nonradiological Accidents Related to the DGR Project, and control measures are noted in Table , Summary of Screening of Hazards to Workers, as well as in OPG (2011b), Section , Excavation Methods and Installing Rock Support. References: AMEC NSS Malfunctions, Accidents and Malevolent Acts Technical Support. AMEC NSS Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) OPG. 2011a. OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement. Ontario Power Generation report REP R000. Toronto, Canada. (CEAA Doc# 298) Page 63 of 90

68 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response OPG. 2011b. OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Preliminary Safety Report. Ontario Power Generation report SR R000. Toronto, Canada. (CEAA Doc# 300) OPG OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to, CD# CORR , March 9, (CEAA Doc# ) EIS Section , Terrestrial Environment Information Request: Assess the potential effects of the project on the Canada Warbler and Eastern Meadowlark. Provide additional baseline information on habitat use by these two species in the Project and Site Study Areas. Confirm that the presence of these species in the Site Study Area has been brought to the attention of the Ontario Ministry of Natural Resources. Context: Section of the Terrestrial Environment TSD states that Neither historical studies nor current database searches identified habitat use by species listed under Schedule 1 of the Species At Risk Act (SARA) or threatened or endangered species as identified by the province under the Endangered Species Act in the Project Area. Table of the Terrestrial Environment TSD, which lists bird species identified during the 2009 breeding bird surveys, indicates that the Canada Warbler and Eastern Meadowlark were identified in the Site Study Area. The Canada Warbler is designated special concern provincially, and is listed as threatened under schedule 1 of SARA. The Eastern Meadowlark recently became designated as threatened provincially (as of January 2012) and by COSEWIC, but currently has no SARA status. As indicated by the EIS guidelines (Section ), it is expected that potential Project effects to all species at risk and their habitats be fully assessed. This expectation is in line with the NSCA requirement to provide adequate protection for the environment. In addition to the NSCA, the DGR Project must also adhere to other legislation, including the federal Species at Risk Act, and the Ontario Endangered Species Act. The designation of Threatened under both of these Acts results in a requirement for additional habitat protection measures. These two species were not assessed as species at risk in the EIS, therefore this information is needed to better understand the potential impacts and ensure consistency with the applicable legislation. OPG Response: The Terrestrial Environment Technical Support (TSD) (GOLDER 2011, Table ) identified that eastern meadowlark (Sturnella magna) and Canada warbler (Wilsonia canadensis) were present in the Site Study Area during the field programs for the DGR Project. At the time of the DGR Project field program (2007 to 2009), eastern meadowlark had no designation either federally or provincially. Eastern meadowlark has since been designated Page 64 of 90

69 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response (May 2011) as threatened in the provincial Endangered Species Act (Government of Ontario 2007). Canada warbler was designated as special concern in Ontario at the time of the field data program (Government of Ontario 2007). In a February 2011 amendment, Canada warbler was listed as Threatened in Canada under the Species at Risk Act (Statutes of Canada 2002). Previous to this, Canada warbler was not ranked federally. Effects of the DGR Project on Eastern Meadowlark and Canada Warbler While eastern meadowlark and Canada warbler have been identified in a number of locations within the Site Study Area, most of these locations fall outside of the Project Area and DGR Project site (OPG 2011, Figure ). The one station where eastern meadowlark was identified within the DGR Project site does not provide suitable breeding habitat and would not be considered preferred habitat. The habitat cleared as part of the DGR Project will not result in the loss of any breeding habitat, or preferred habitat for eastern meadowlark. Therefore, the DGR Project is expected to have no residual adverse effect on eastern meadowlark. The DGR Project will result in the removal of 8.9 ha of forest, mixed woods (GOLDER 2011, Table ). However, Canada warbler was not identified as using this habitat during the field programs. Therefore, the loss of 8.9 ha of forest, mixed woods, should not have any adverse effect on Canada warbler. Habitat Use in Project and Site Study Areas Both species were identified within the Site Study Area during the breeding bird point count surveys conducted during both the 2007 and 2009 field seasons. Surveys were conducted at the same breeding bird plots that were established in both survey years using the same methods. The point count surveys followed the standard five minute point count protocols with the exception of areas that contained wetland vegetation species. At these wetland sites, surveys were conducted for 20 minutes to account for more secretive species such as rails and bitterns. All species recorded were mapped to whether they were heard and/or seen within a 50 m radius or outside the 50 m radius. Species that may have flown through or over the plot location were also recorded as such. Eastern meadowlark was identified at 13 of the breeding bird survey locations, with multiple date records at three of the stations. Canada warbler was documented at five of the breeding bird survey locations with no multiple date records. Eastern Meadowlark Eastern meadowlark was identified in the following Ecological Land Classification (Lee et al. 1998) plant species communities during the breeding bird point count surveys. Station numbers refer to breeding bird survey locations shown on Figure of the Terrestrial Environment TSD (GOLDER 2011). CUM 1 Mineral Cultural Meadow (Station 18); CUM 1-1 Dry-Moist Old Field Meadow (Stations 3, 4, 6, 7, 11); FOC 2-2 Dry-Fresh Eastern white Cedar Coniferous Forest (Station 5); FOC 4-3 Fresh-Moist White Cedar-Balsam Fir Coniferous Forest (Station 20); FOD 5-10 Dry-Fresh Sugar Maple-White Birch-Poplar Deciduous Forest (Station 26); Page 65 of 90

70 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response FOD 5-1 Dry-Fresh Sugar Maple Deciduous Forest (Station 30); CUW1 Cultural Woodland (Stations 8, 9); and IB - Industrial Barren (Station 31). The eastern meadowlark prefers grassy habitats and is not likely to find a number of the vegetation communities listed above as preferred habitat. While identification of a bird species during a breeding bird survey is evidence of some level of habitat use, it cannot be considered confirmation of breeding status. It is likely that Stations 3, 4, 6, 7, 11 and 18 have the potential to provide suitable conditions for breeding for these species. None of these stations are located within the DGR Project Area. The stations located within forested habitats (Stations 5, 8, 9, 20, 26, 30) are not likely to support breeding habitat for this species. Station 31, an industrial barren, is one of the locations with potentially suitable habitat where eastern meadowlark was identified within the DGR Project site (footprint). This is the only location that will be disturbed as a result of activities associated with site preparation for the DGR Project. Station 8 is located within the Project Area but outside of the Project Site. This station is described as a cultural woodland and would not be considered to provide preferred habitat for this species. Station 30 is also located within the Project Area but outside of the DGR Project site. This location is classified as a deciduous forest, which is not considered to be preferred habitat for eastern meadowlark. The Terrestrial Environment TSD (GOLDER 2011, Section 8.3.3) includes a mitigation measure (a nest-survey search conducted within the construction footprint area) if site clearing is undertaken when migratory birds may be nesting. Canada Warbler Canada warbler was identified in the following Ecological Land Classification (Lee et al. 1998) plant species communities during the breeding bird point count surveys. Station numbers refer to breeding bird survey locations shown on Figure of the Terrestrial Environment TSD (GOLDER 2011). FOC 4-1 Fresh-Moist Cedar Coniferous Forest (Station 21, 25); FOD 5-10 Dry-Fresh Sugar Maple-White Birch-Poplar Deciduous Forest (Station 26); and FOM 7-2 Fresh-Moist White Cedar-Hardwood Mixed Forest (Station 13, 27). The Canada warbler prefers forested habitats, often with moist-wet soils with well developed shrub layers. All of the locations where this species was identified during the breeding bird surveys have the potential to provide preferred habitat for this species. However, none of these stations are located immediately within the DGR Project site. Station 27 is located within very close proximity to the proposed footprint; however, this feature will not be disturbed as part of the DGR site preparation and construction activities. As stated above, the Terrestrial TSD includes a mitigation measure (a nest-survey search conducted within the construction footprint area) if site clearing is undertaken when migratory birds may be nesting. A description of the habitats at each of the survey location in provided in the Terrestrial Environment TSD Page 66 of 90

71 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response (GOLDER 2011, Section 5.4). Communication with MNR Regarding Eastern Meadowlark and Canada Warbler No specific communication relating to the observed presence of eastern meadowlark and Canada warbler within the Site Study Area have been held with the MNR. However, OPG is aware that the MNR are reviewing the EIS (OPG 2011) and Terrestrial Environment TSD (GOLDER 2011). During discussions regarding certain species at risk held with MNR staff, the eastern meadowlark and Canada warbler were not mentioned. References: GOLDER Terrestrial Environment Technical Support. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 299) Government of Ontario Endangered Species Act S.O. 2007, Chapter 6. Lee, H. et al Ecological Land Classification for Southern Ontario, First Approximation and its Application. Ontario Ministry of Natural Resources. OPG OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Environmental Impact Statement, Volume 1. Ontario Power Generation report REP R000. Toronto, Canada. (CEAA Doc# 298) Statutes of Canada Species at Risk Act. Chapter 29. Canada Gazette Part III, Ottawa, January 31, EIS Section 13.2, Selection of Assessment Scenarios Information Request: Assess the influence of creep on the long term geomechanical stability of the underground facility and commit to a follow-up program, consisting of both laboratory and field tests to verify that assessment. Context: According to the CNSC, the long term strength test data (Gorski et al.2009) on the Cobourg limestone indicate that creep could be a factor in the long term geomechanical stability. Uniaxial compressive tests were performed at a constant low stress level (at around the crack initiation stress), however, deformation, especially in the diametric direction, showed an increasing trend as a function of time and did not stabilize after 100 days. OPG Response: Creep tests are carried out to assess time-dependent deformation of unconfined intact rock occurring under a constant stress that is less than the short-term strength. Time-dependent deformation is a well-known phenomenon in weak clayrich rocks and rocks such as potash that display viscous plastic behaviour, and in such rock masses laboratory creep tests are in general agreement with mining field observations. In brittle rocks, creep processes are generally attributed to Page 67 of 90

72 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response microcrack growth. Mining experience in brittle rocks, such as the Cobourg limestone formation, have not demonstrated that creep process are significant from the perspective of rock mass stability and hence creep test results seldom factor into the design of underground openings in brittle rocks. Creep tests in brittle rocks are not without challenges. A characteristic of brittle rock creep is that the deformation response is typically only recorded in the lateral strain gauge, unlike creep in visco-plastic material where deformations are measured by the axial strain gauge. In an extensive and unique series of creep tests on Lac du Bonnet granite over a period of 10-years, Lajtai et al. (1987) concluded the following: time-dependent tests for creep strain, static fatigue and slow crack velocity, the effect of water is substantial. The creep strain and slow crack velocity increase and the long-term strength decreases when water is introduced into the previously dry testing environment. The size of the change, however, depends on the stress level (applied stress relative to the instantaneous strength). It is small at high stress levels becoming more substantial as the stress level is decreased. For example, at a stress level of 65%, the steady state creep rate of the lateral strain increased by 300% when water was allowed to flood the previously dry environmental chamber. The laboratory creep tests results on Lac du Bonnet Granite suggested potential creep issues. However, those results are not compatible with the observations from the excavations at the 420 m level of Atomic Energy Canada Limited s (AECL) Underground Research Laboratory that were subjected to stress levels similar to those used in the laboratory creep experiments. The underground excavations showed no evidence of stability issues over a period of 20 years that could be attributed to creep. One of the reasons that creep in brittle rocks does not manifest into large-scale stability issues is that the stress concentrations are localized spatially around the underground excavations. Hence, if creep were to occur it would be concentrated to those minor localized overstressed areas. Given the experience of Lajtai, the lateral creep observed in CANMET testing (Gorski et al. 2009) may be a secondary effect resulting from environmental (moisture) or poroelastic influence (through minor damage from sample disturbance) on the Cobourg limestone. To this end it is noteworthy that acoustic emission readings within the Cobourg samples indicate that the creation of new damage significantly reduces and in many cases ceases after 50 days on average. In most cases the axial deformation shows no signs of long-term deformation and if non-linear trends are examined, most creep tests showed a reduction in creep rate with time. In situ a minor softened/disturbed zone will be created around all the underground excavations. Creep is not expected to materially change the rock mass conditions within this zone. Outside this zone, the confining stresses are higher and it is well understood that creep processes are significantly abated at higher confinement levels (less differential stress). The creep tests carried out at CANMET (Gorski et al and 2010) were performed at the most extreme case of uniaxial loading. It is recognized that stress levels at or above crack initiation in an unconfined state, such as at the periphery of an unsupported excavation may be susceptible to localized yielding. To minimize the potential for this behaviour, the repository layout design: Page 68 of 90

73 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response 1) Aligned the emplacement rooms parallel to the maximum horizontal stress to minimize the stress on the periphery of the excavated openings. 2) Shaped the excavation to place the stress concentrations in the corners of the openings where the geometry of the corner, creates a confining condition. The corner geometry actually changes the loading from stress control to stiffness control, which is equivalent to increasing the confining stress. 3) Supported the small Excavation Damaged Zone (EDZ) on the pillar walls. This zone will create a de-stressed zone that provides confinement to the pillar wall in addition to the proposed ground support. It is well known that confining stress reduces the potential for creep processes. Despite the above, scenarios were considered where the assumption of creep processes is incorrect and their influence has been underestimated. In the long-term geomechanical analysis (NWMO 2011a, Section ), a parametric analysis was carried out for the following six values of the Cobourg limestone long-term strength to investigate the sensitivity of the predictions of cavern and pillar degradation: 45 MPa (40% uniaxial compressive strength (UCS)); 54 MPa (49% UCS); 63 MPa (57% UCS); 72 MPa (65% UCS); 81 MPa (73% UCS); and 90 MPa (81% UCS). The consequence of all the pillars collapsing due to long-term strength degradation is demonstrated. It is evident that as the long-term strength increases, the damage to the emplacement rooms and pillar decreases (NWMO 2011a, Section 6.1). To evaluate the creep process during shaft sinking and lateral development, the project has plans to incorporate deformation monitoring by installing extensometers in the pillar wall and roof to establish if creep is observed in-situ as part of the Geoscientific Verification Plan (NWMO 2011b, Sections and 2.2.6). In addition, other geoscientific activities as described in NWMO (2011b, Sections and ) that involve laboratory testing of large diameter core (>75 mm) or block samples will also be used to investigate time-dependent rock behaviour. References: Gorski, B., T. Anderson and B. Conlon Long-Term Strength Degradation Testing of DGR-2 Core. Intera Engineering Ltd. report TR Rev.0. CANMET Mining and Mineral Sciences Laboratories, Natural Resources Canada. Ottawa, Canada. (available at Gorski, B., T. Anderson and B. Conlon Long-Term Strength Degradation Testing of DGR-3 and DGR-4 Core. Page 69 of 90

74 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Intera Engineering Ltd. report TR Rev.1. CANMET Mining and Mineral Sciences Laboratories. Ottawa, Canada. (available at Lajtai, E.Z., R.H. Schmidtke and L.P. Bielus The Effect of Water on the Time-Dependent Deformation and Fracture of a Granite. International Journal of Rock Mechanics and Mining Sciences and Geomechanics Abstracts 24 (4), NWMO. 2011a. Geosynthesis. Nuclear Waste Management Organization report NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NWMO. 2011b. Geoscientific Verification Plan. Nuclear Waste Management Organization document NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) EIS Section , Geology and Geomorphology Information Request: Discuss whether the increased fracture frequency in the Ordovician may be the result of the proximity to a vertical fault or fracture zone. Discuss the implications of the high fracture frequency in the overpressured Cambrian unit, in light of the relatively high fracture frequency in the Middle Ordovician rocks in DGR-4, the possibility of a vertical fault or fracture zone, and fluid infiltration along such a feature. Context: An explanation and discussion of the anomalous higher fracture frequency and the implications this might have at the Bruce site is required. The CNSC stated that the possible reasons for the relatively higher fracture frequency in the Ordovician in DGR-4 should be provided and require discussion. The natural fracture frequencies presented in the DGSM report (on Figure 3-4 and Table 3.5) show that in DGR-4, the natural fracture frequency is higher in Middle Ordovician units than in other boreholes, with up to ~5 / m. Additionally, the fracture frequency in the (underlying, overpressured) Cambrian unit is shown to be high, with a natural fracture frequency of up to 12 / m. OPG Response: This response is provided in addition to information previously provided in OPG s responses to (IRs) EIS (OPG 2012a) and EIS (OPG 2012b) on evidence regarding the occurrence of sub-vertical faults or fracture zones in proximity to the proposed DGR. a) Evidence gathered during site-specific investigations indicates that the increased fracture frequency reported within the Ordovician limestones at borehole DGR-4 (INTERA 2011, Figure 3.4) is principally the result of Page 70 of 90

75 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response mechanical breakage occurring during drilling and extraction of the borehole cores (INTERA 2011, Section 3.12). This evidence includes detailed core and fracture logs as documented by Briscoe et al. (2010) and colour core photographs taken at the time of core retrieval. It is evident that of the fractures logged the vast majority (i.e., > 90%) occur at a high angle to the core axis. As the logs and core photographs (see Figures 1 to 3 below) illustrate, such features are associated with visible evidence of core damage (e.g., scraping and grinding marks, extreme variation in core diameter along the axis), indicative of mechanical breaks. These high angle features tend to occur within shale-rich horizons or with a change in lithology between carbonate and shale where core diameter variations due to coring are particularly evident. There is no indication that any of these fractures have a mineral infilling, which would preclude the interpretation that they are mechanical in nature. Assuming that the sub-vertical and moderate angle discontinuities are natural fractures leads to a conservative estimate for the fracture frequency in the Ordovician limestones of less than 1 / m. Figure 1: Photograph of Ordovician (Kirkfield Fm) Limestone - Mechanical breaks in core at lithological contacts and associated with core diameter variation due to drilling damage Page 71 of 90

76 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Figure 2: Photograph of Ordovician (Kirkfield Fm) Limestone (DGR-4) - Extreme core diameter thinning at location of mechanical break b) A high fracture frequency is also noted for the Cambrian unit and it has been suggested, based on the results of hydraulic testing, that many of these fractures are open (INTERA 2011, Section 3.6). The core logs for the highly-fractured Cambrian interval in DGR-3 (core runs 288 to 292 described in Briscoe et al. (2010)) describe that some of these fractures are filled by either a white mineral or calcite +/- pyrite. Therefore, some of these fractures are natural and were formed prior to mechanical disturbance by drilling and coring. However, some of these fractures appear due to the same phenomenon of mechanical damage described above. The photograph below (see Figure 3) shows an example of high fracture frequency from a section of the Cambrian unit encountered in borehole DGR-3, in an area where the core diameter is highly variable due to drilling damage, and where a high fracture frequency has been noted. The primary sources for the information were Sterling (2010) and Briscoe et al. (2010), which provide information related to fracture orientation with respect to the borehole axis. As the core logs and the illustrative photograph below show (see Figure 3), the fractures are primarily oriented sub-horizontally (high angle to borehole axis in vertical boreholes), and none of the fractures were described as having a mineral infilling. Page 72 of 90

77 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Figure 3: Photograph of Cambrian - Core diameter thinning at mechanical breaks along core axis Regardless of the fact that some of the Cambrian fractures are associated with increased permeability, information has previously been provided (OPG responses to IR-EIS (OPG 2012a) and IR-EIS (OPG 2012b)) to support the interpretation that there are no unidentified faults in proximity to the proposed DGR footprint. This includes geochemical, hydrogeological and stratigraphic lines of evidence that do not reveal the existence of a sub-vertical transmissive structural feature within the Ordovician sediments. In particular, key points are as follows: In situ straddle packer testing within the DGR-series boreholes yielded rock mass hydraulic conductivities of to m/s within the Ordovician sediments (NWMO 2011, Figure 5.1); Hydraulic underpressures in the Ordovician shales and Trenton Group limestones, with maximum underpressures occurring within the Blue Mountain Formation equal to approximately 300 mbgs, as Page 73 of 90

78 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response well as the strong overpressures in the Cambrian aquifer (NWMO 2011, Section ), generate high vertical hydraulic gradients that could not be preserved in the presence of through-going sub-vertical fault-controlled transmissive pathways; and There is no evidence from drilling or in-situ borehole testing within the DGR-series boreholes of pervasive hydrothermal dolomitization typical of type Ordovician fault centric carbonate reservoirs described elsewhere in southern Ontario (NWMO 2011, Section ). Only minor dolomite occurrences within the Ordovician carbonate strata beneath the site are observed. Based on the information above, the increased fracture frequency in the Ordovician formations observed at borehole DGR-4 principally appears to be the result of mechanical damage. Although some of the fractures in the Cambrian unit appear natural, visual evidence indicates that some are also due to mechanical damage. Regardless, the geochemical, hydrogeological and stratigraphic arguments provide additional evidence that the occurrence of interconnected fault pathways between the overpressured Cambrian and overlying underpressured Ordovician formations in the vicinity of the DGR footprint is remote. References: Briscoe, G., A. Wigston and M. Melaney Drilling, Logging and Sampling of DGR-3 and DGR-4. Intera Engineering Ltd. report TR Rev.0. Ottawa, Canada. (available at INTERA Descriptive Geosphere Site Model. Intera Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NWMO Geosynthesis. Nuclear Waste Management Organization report NWMO DGR TR R000. Toronto, Canada. (CEAA Doc# 300) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Information Request Package #2, CD# CORR , June 1, (CEAA Doc# 523) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to the Final Sub-set of Package #5, CD #00216-CORR , November 7, (CEAA Doc# 793) Sterling, S Drilling, Logging and Sampling of DGR-1 and DGR-2. Intera Engineering Ltd. report TR Rev.1. Ottawa, Canada. (available at Page 74 of 90

79 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response EIS Section Geology and Geomorphology Information Request: Explain the anomalous higher elevation in the 2D seismic survey shown in Figures of the 2D seismic survey report (Intera 2009). Explain if this is a precambrian paleohill, an uplifted basement block, or an artifact. Describe the uncertainties (accuracy and precision) associated with the estimate of 10m of local structural relief along the basement surface and overlying stratigraphic reflectors for individual seismic lines. Describe the accuracy and precision of the depth and configuration of the apparently continuous reflectors evident in some of the seismic profiles. Context: The possible basement-related feature identified in the seismic survey (based on 2-way travel time) north of DGR-1 and DGR-2 is a structure that requires explanation. OPG Response: a) Results from the 2D seismic survey (Watts et al. 2009) indicated anomalous higher basement contact elevations within the project area where DGR-1 and DGR-2 were drilled. The information presented below is consistent with the understanding that this feature, with topographic variation of ~ 10 m, is not a fault-bounded and uplifted basement block, and that it therefore either represents a Precambrian paleohill or an artifact of the seismic data processing. Evidence supporting this conclusion includes the following points. Watts et al. (2009) concluded that triangulation of key marker bed elevations in DGR-1/2, DGR-3 and DGR-4 (that enclose the proposed repository footprint) does not support the interpretation of the presence of local bedrock high or associated faulting near DGR-2. The continuous core retrieved from both inclined boreholes DGR-5 and DGR-6, with the latter specifically targeted to intersect interpreted fault structure to the north-east of the interpreted basement high, showed no indication of the existence of potential faults. There was no evidence of shear zones, cataclasites, fault gouge or a fault-related offset in the stratigraphy within the core recovered from the targeted intervals (INTERA 2011, Section 3.12; NWMO 2011, Section ). Formation contacts predicted at the three-dimensional intersection of the equation of the formation plane (from boreholes DGR-1, 2, 3, 4) with the known DGR-5 and DGR-6 borehole positions, based on Acoustic Televiewer (ATV) and gyroscopic logging, do not indicate significant offsets in the vicinity of DGR-5 or DGR-6 (Sterling and Melaney 2011; INTERA 2011, Table 3.16). Only borehole DGR-2 penetrated into the crystalline Precambrian basement and, therefore, the extent of Precambrian surface paleo-erosional relief was not assessed with drilling. However, the consistent strikes, dips, and thicknesses of the overlying Paleozoic formations negated faulting in the area enclosed by the Page 75 of 90

80 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response DGR boreholes and suggest Precambrian relief is less than the 10 m extent interpretable from the seismic survey. Further support for the interpretation that the seismic feature is not a fault has previously been presented in OPG s responses to (IR) EIS (OPG 2012a) and EIS (OPG 2012b). b) Watts et al. (2009) described the uncertainties and resolution constraints for the 2D seismic survey completed at the Bruce nuclear site. They indicate that factors influencing the data quality include: noise, line orientation (bending), and the high contrast between overburden and bedrock velocities. Further, the seismic survey report states that data resolution within the seismic sections cannot resolve features less than 10 m in vertical extent or 3 seismic traces horizontally (representing 18 and 9 m, for the Key Seismic and Seiscraft processed sections, respectively). Data quality is assigned along all lines, as described in Table 1 and illustrated in Figure 6 of the seismic survey report (Watts et al. 2009). Several key points related to data uncertainty are below. The area interpreted as north-east and east of the bedrock high, along line 4, and at the ends of lines 5, 6, and 9, is of poor data quality, with limited fair quality, and, therefore, either not interpretable on its own or is only interpretable with low confidence (Watts et al. 2009). The interpretation of anomalously high Queenston, Cobourg and Precambrian formation elevations, as indicated by the ribbon plots (Watts et al. 2009, Figures 13, 14, and 15), is partially based on the area to the east having lower formation elevations but should be tempered considering the low degree of confidence and the drilling results which, as discussed above, do not suggest the presence of faults. Confidence in the accuracy and precision of the depth and configuration of the apparently continuous reflectors evident in some of the seismic profiles is increased when the seismic survey results are accompanied by borehole geophysical natural gamma log profiles (e.g., Watts et al. 2009, Figures 16a and 16b). The gamma logs provide a baseline from which to interpret the individual stratigraphic horizons and determine their continuity. In addition, an entire section of the Geosynthesis is devoted to a detailed analysis of the stratigraphic continuity of individual Ordovician formations (NWMO 2011, Section 2.3.4). The discussion highlights the uniformity of geometry and structure, and the traceable nature, of the entire Ordovician stratigraphic interval, which was also determined independently from the seismic dataset. References: INTERA Descriptive Geosphere Site Model. Intera Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NWMO Geosynthesis. Nuclear Waste Management Organization report NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Page 76 of 90

81 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Level Waste Submission of Responses to Information Request Package #2, CD# CORR , June 1, (CEAA Doc# 523) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to the Final Sub-set of Package #5, CD #00216-CORR , November 7, (CEAA Doc# 793) Sterling, S. and M. Melaney Bedrock Formations in DGR-1 to DGR-6. Geofirma Engineering Ltd. report TR Rev.0. Ottawa, Canada. (available at Watts, M., D. Schieck and M. Coniglio D Seismic Survey of the Bruce Site. Intera Engineering Ltd. report TR Rev.0, NWMO DGR-REP R000. Ottawa, Canada. (available at EIS Section Geology and Geomorphology Information Request: Explain or address the inconsistencies identified in the description of the geological framework for the following: Michigan Basin subsidence; Thermal maturity; and Bruce megablock fractures. Context: Numerous inconsistencies identified by the CNSC reduce confidence in the proposed DGR framework with respect to the geometric predictability, tectonic stability, and resource potential in the RSA. The CNSC identified the following inconsistencies: Michigan basin subsidence On page 14 of the Descriptive Geosphere Site Model (DGSM): the statement that the Taconic Orogeny in the Early to Middle Ordovician resulted in the collapse of platform carbonates of the Trenton Group is not supported by literature. For example see Quinlan and Beaumont (1984) and Quinlan (1987) for an overview of basin formation and Paleozoic stratigraphy of the eastern interior of North America, and tilting related to subduction of cratonic interiors. The change from Guelph Formation to the Salina Group is the result of basin subsidence, not arch uplift. Michigan basin subsidence was not caused by the Acadian Orogeny. The interpretation that Cambrian strata were deposited over the Algonquin Arch and then subsequently eroded Page 77 of 90

82 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response prior to the deposition of Ordovician strata (found in some reports e.g. the DGSM, Geosynthesis tectonic evolution of southern Ontario) is problematic. Figure 2.4 in the Regional Geology report and discussed in Hamblin (2011) indicates that the Algonquin Arch was a peninsula while the Cambrian formations were being deposited. This impacts on the conceptual model for the tectonic evolution of the Michigan Basin as presented in the DGSM. Thermal maturity Thermal maturity of rocks in the study area, as mentioned in several reports (including Regional Geology, Analogue Study of Shale Cap Rock Barrier Integrity) should be consistent with observations of hydrocarbon seeps in drill core. In the vicinity of the Bruce site, Middle Ordivician limestone and the overlying Collingwood, Blue Mountain, and part of the Georgian Bay Formations are thermally mature. The pyrolysis data on page 46 of the DGSM report shows that mid Ordovician strata are thermally mature and the top of the oil window is within the Georgian Bay Formation. Although the Cobourg Formation, the proposed host for the DGR, is omitted from the oil window, it should be included because of the hydrocarbon seeps observed in drill core. Bruce megablock fractures The apparently simple fracture pattern in the Bruce megablock relative to the Niagaran may simply reflect borehole coverage, which is much more extensive in southern Ontario. This likely explanation is ignored in reports. The reliance on the Bruce/Niagara megablock concept to explain the lack of discovered oil and gas in the RSA is problematic, owing to ambiguity about the origin and importance of megablock features. OPG Response: The geological framework of southern Ontario, as presented in the Descriptive Geosphere Site Model (DGSM) report (INTERA 2011), the Regional Geology Southern Ontario report (AECOM and ITASCA CANADA 2011) and the Geosynthesis report (NWMO 2011), is considered to be consistent with the current scientific understanding of the tectonic history of southern Ontario and the Michigan Basin. The following sections discuss the points listed in the Information Request in relation to this understanding. 1. Michigan Basin Subsidence a) Recent studies by Howell and van der Pluijm (1990, 1999), that post-date the work by Quinlan and Beaumont (1984), conclude that Interpretation problems of several previous studies of the Michigan basin are largely resolved when the stratigraphy is examined in light of structural sequences, rather than using a predetermined stratigraphic grouping (Fisher et al. 1988) or if paleobathymetry had been explicitly Page 78 of 90

83 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response considered (Coakley et al. 1994). The term collapse, as used in the DGSM, is meant to represent deepening of the depositional basin due to loading of the continental margin during the evolving Taconic Orogen. The description in the DGSM was a much shortened version of what is included in the Geosynthesis (NWMO 2011, Section ) which describes the large-scale eastward-tilting of the Laurentian margin as characterizing the nature of the Taconic Orogeny, citing Coakley et al. (1994), Coakley and Gurnis (1995) and Howell and van der Pluijm (1999). b) The long-term history of continental arches, including their relative vertical motion, is a controversial aspect of global tectonics. Regardless of the mechanism involved, during the Paleozoic Era the Algonquin Arch existed as either a topographically positive or negative feature with respect to the depositional environments of the adjacent Michigan and Appalachian basins. During the transition from the Guelph Formation depositional environment to that of the Salina, the arch was a topographically positive feature that induced the development of a restricted basin environment. During the Silurian, the Algonquin arch subsided at a much slower rate than the adjacent regions, periodically creating a positive topographic feature. The lagoonal setting of the Salina group was therefore at times sub-aerially exposed and eroded (Haynes et al. 1989). c) As discussed in Sections 2.1 and 2.2 of the Regional Geology Southern Ontario report (AECOM and ITASCA CANADA 2011), Howell and van der Pluijm (1990, 1999) determined that the Michigan Basin developed as a result of a series of tectonic events that occurred throughout the Paleozoic (see also Figure 2.4 in AECOM and ITASCA CANADA 2011), including, but not limited to, an Acadian event of basin-centred subsidence. The Middle Devonian Dundee and Traverse formations show eastward facies changes, consistent with an increase in water depth, departing from the typical circular subsidence patterns in the basin (Gardner 1974). This variation occurred as a result of eastward tilting of the formations during the post-acadian Alleghanian event (Howell and van der Pluijm 1999). d) The following passage from Hamblin (2011, p.2) describes the early Paleozoic nature of the Algonquin Arch in a manner similar to what is found in the Regional Geology Report (AECOM and ITASCA 2011). As the Upper Cambrian sea transgressed from the Appalachian Geosyncline through southern Ontario up the flanks of the subdued Algonquin Arch, the depositional units thinned, but likely covered the structure, resulting in an overall transgressive succession of marine sandstone and dolomite resting unconformably on basement (Roliff 1954; Poole et al., 1968). However, these strata, the Sauk Sequence of Sloss (1963), were eroded from the Arch crest during a phase of Early Ordovician uplift, marine regression and subaerial erosion, resulting in the development of the sub-tippecanoe Sequence (of Sloss, 1963). 2. Thermal Maturity a) The visual evidence for oil hydrocarbon seeps within the DGR cores is acknowledged in several places, for example in Section and Figure 2.32 of the Geosynthesis (NWMO 2011), and Section of the Page 79 of 90

84 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response DGSM (INTERA 2011). These visual observations, along with the results of pyrolysis analysis (Figure 3.17 of the DGSM in INTERA 2011) indicate that the rocks located beneath the Queenston Formation have reached the oil window in terms of thermal maturity. However, the rocks do not appear to have reached the degree of thermal maturation necessary to develop gas hydrocarbon (Engelder 2011). The lack of natural hydraulic fractures near the base of the Blue Mountain Formation where they would be expected to form if sufficient gas were to have been generated, supports this interpretation. This observation is also consistent with recorded Ordovician Conodont Alteration Index (CAI) values of 1.5 (~80 C) within the northern Huron region (Legall et al. 1981). It is also consistent with the statement in Engelder (2011, Section 3.3) that suggests that the Lower Paleozoic sediments in southern Ontario have attained only an immature to barely mature thermal maturation. Engelder (2011) further states, in Section 4.5, that the organic rich portion of the Blue Mountain shale may be marginally mature, backed up with the observation of minor oil seeps observed in logged core. b) The Cobourg Formation was not omitted from the discussion of the distribution of formations within the oil window because the Collingwood Member is a subunit of the Cobourg Formation. As discussed in Section of the DGSM (INTERA 2011), only 19 samples were chosen for the pyrolysis investigation. The rationale for picking these samples was, in part, to analyze samples with the highest potential percentage of organic content (i.e. dark shale-rich samples). It is understood that stratigraphic units located deeper than those studied, including the Cobourg Formation beneath the Collingwood Member, would have attained the same (or greater) thermal maturity. 3. Bruce Megablock Fractures a) Section of the Geosynthesis (NWMO 2011) discusses the sparse nature of the dataset and its limited usefulness for interpreting the existence of faults throughout the Huron Domain. However no data exists to suggest that the current pattern of mapped faults throughout the Huron Domain, as shown in Armstrong and Carter (2010, Figure 25), is an incorrect or poor representation of the subsurface structure. The results from the site-scale hydrogeological testing program (INTERA 2011) and the detailed fracture mapping of Cruden (2011), in addition to OPG s responses to (IR) EIS (OPG 2012a) and EIS (OPG 2012b), suggest that there is a low likelihood that a major undiscovered fault or complex network of faults exists proximal to the DGR footprint. A lack of recorded micro seismicity within the Huron domain further increases confidence in this interpretation (Hayek et al. 2010). b) A discussion of hydrocarbon potential within the Huron Domain has been previously provided in the OPG s response to IR-EIS (OPG 2012b). In addition, Section of the Geosynthesis (NWMO 2011) discusses that the conceptual model of Sanford et al. (1985) is not a likely interpretation for the structural geometry of the Huron Domain. However, it does appear that the Michigan and Appalachian basins have experienced somewhat different tectonic histories on either side of the Algonquin Arch, which have influenced their hydrocarbon potential. For example, west of the Algonquin Arch, the DGR site stratigraphy Page 80 of 90

85 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response shares a common history with the Michigan Basin. Here typical hydrocarbon pools are located towards the basins depocentre in central Michigan where the increased thickness of sediment corresponds to increased thermal maturity. Therefore on the flanks of the basin, such as in the case of the Huron Domain, the thermal maturity is greatly reduced resulting in a lack of hydrocarbons. East of the Algonquin Arch, the stratigraphy was controlled by the Appalachian foreland basin and a different burial history exists. Here, Ordovician formations, due to the eastwards tilting during the Taconic Orogeny are thicker and contain a higher volume of organic material, resulting in greater hydrocarbon potential. References: AECOM and ITASCA CANADA Regional Geology Southern Ontario. AECOM Canada Ltd. and Itasca Consulting Canada Inc. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (available at Armstrong D.K. and T.R. Carter The Subsurface Paleozoic Stratigraphy of Southern Ontario, Ontario Geological Survey, Special Volume 7, p.301. Coakley, B.J., G. Nadon, and W.F. Wang Spatial variations in tectonics subsidence during Tippecanoe I in the Michigan basin. Basin Research, 6, pp Coakley, B. and M. Gurnis Far-field tilting of Laurentia during the Ordovician and constraints on the evolution of a slab under an ancient continent. Journal of Geophysical Research, 100, pp Cruden, A Outcrop Fracture Mapping. Nuclear Waste Management Organization report NWMO DGR-TR R000. Toronto, Canada. (available at Engelder, T Analogue Study of Shale Cap Rock Barrier Integrity. Nuclear Waste Management Organization report NWMO DGR-TR R000. Toronto, Canada. (available at Fisher, J.H., M.W. Barratt, J.B. Droste and R.H. Shaver Michigan basin, in Sloss, L.L., ed., Sedimentary cover North American craton: U.S.: Boulder, Colorado, Geological Society of America, Geology of North America, D-2, pp Gardner, W.C Middle Devonian stratigraphy and depositional environment in the Michigan basin, Spec. Pap. Michigan Basin geol. SOC., 1. Hamblin, A.P Detailed outcrop and core measured sections of Upper Cambrian and Middle Ordovician sandstones (and associated facies), southwestern Ontario, Geological Survey of Canada, Open File Hayek, S.J., J.A. Drysdale, J. Adams, V. Peci, S. Halchuk and P. Street Seismic Monitoring near the DGR - Annual Report Nuclear Waste Management Organization report DGR-TR Toronto, Canada. Page 81 of 90

86 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Haynes S.J., R. Boland and J. Hughes-Pearl Depositional setting of gypsum deposits, southwestern Ontario; the Domtar Mine Economic Geology and the Bulletin of the Society of Economic Geologists, 4, pp Howell, P.D. and B.A. van der Pluijm Early history of the Michigan basin: Subsidence and Appalachian tectonics. Geology, 18, pp Howell, P.D. and B.A. van der Pluijm Structural sequences and styles of subsidence in the Michigan basin. Geol. Soc. Am. Bull., 111, pp INTERA Descriptive Geosphere Site Model. Intera Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) Legall, F.D., C.R. Barnes and R.W. Macqueen Thermal maturation, burial history and hotspot development, Paleozoic strata of southern Ontario-Quebec, from conodont acritarch colour alteration studies. Bulletin of Canadian Petroleum Geology, 29, pp NWMO Geosynthesis. Nuclear Waste Management Organization report NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Information Request Package #2, CD# CORR , June 1, (CEAA Doc# 523) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to the Final Sub-set of Package #5, CD #00216-CORR , November 7, (CEAA Doc# 793) Poole, W.H., B.V. Sanford, H. Williams, and D.G. Kelley Geology of Southeastern Canada, In Geological Survey of Canada, Economic Geology Report, Number 1, Geology and Economic Minerals of Canada, R.J.W. Douglas (ed.), pp Quinlan, G.M Models of subsidence mechanisms in intracratonic basins, and their applicability to North American examples, in Beaumont, C., and Tankard, A.J., eds., Sedimentary basins and basin-forming mechanisms. Canadian Society of Petroleum Geologists Memoir 12, pp Quinlan, G.M. and C. Beaumont Appalachian thrusting, lithospheric flexure, and the Paleozoic stratigraphy of the eastern interior of North America: Canadian Journal of Earth Sciences, 21, pp Roliff, W.A The pre-middle Ordovician rocks of southwestern Ontario. Proceedings of the Geological Association of Canada, 6, pt. II, pp Sanford, B.V., F.J. Thompson and G.H. McFall Plate tectonics A possible controlling mechanism in the Page 82 of 90

87 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response development of hydrocarbon traps in southwestern Ontario. Bulletin of Canadian Petroleum Geology, 33, pp Sloss, L.L Sequences in the cratonic interior of North America. Geological Society of America Bulletin, 75, pp EIS Section 12, Accidents, Malfunctions and Malevolent Acts Section 13.2, Selection of Assessment Scenarios Information Request: Clarify an apparent discrepancy between the statement that the C-14 inventory in the DGR is about equal to the Western Waste Management Facility (WWMF) DRL (annual release limit that would give a 1 msv/a dose to a person at the site boundary) and the results of the SF-ED disruptive scenario that predicts an 80 msv/a exposure from C-14 (Section and Table 14-3, Argument 3-2). Context: The Severe Shaft Seal Failure Scenario assesses a hypothetical situation in which there is a breakdown in the performance of these barriers. Two situations were considered: A base case for which the hydraulic conductivity of all shaft seals are set at 10-9 m/s (SF-BC) and an extra conservative case for which the hydraulic conductivity of all shaft seals is set at 10-7 m/s with a porosity of 30%, which is equivalent to fine silt and sand (SF-ED). The PSR states (page 551) that the SF-ED case results in a calculated dose to the adult site resident living above the repository that reaches about 80 msv/year after around 3800 years. However, the PSR also notes that (page 551) the estimated total amount of C-14 in the DGR is 6x10 15 Bq (Table 5-8). Even if this entire DGR inventory of C-14 were to be released as gas within one year, it would be roughly equivalent to the current allowed WWMF Derived Release Limit (DRL) for C-14 of 4.6x10 15 Bq/year (Table 7-3) and the peak dose to anyone living around the Bruce nuclear site would be about 1 msv or less. The CNSC questioned why the C-14 released over time through a severely degraded sealed shaft would result in a dose of 80 msv/a if there is insufficient inventory to significantly exceed a 1 msv/a dose if it were released on the surface today. OPG Response: There is no discrepancy. The context given for the WWMF DRL dose information in the Preliminary Safety Report states it is noted that the consequences decrease with distance from the site (OPG 2011, p.551). The difference in the estimated dose from the Severe Shaft Failure Scenario and from WWMF airborne DRL for C-14 is due to the different locations of the receptors as well as other factors. Severe Shaft Failure Scenario - Hypothetical self-sufficient family living in a house over the main shaft and farming on land over the repository site, and in particular over the ventilation shaft. All food is locally grown. The initial release to the biosphere is as CH 4 gas. Page 83 of 90

88 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response WWMF C-14 Airborne DRL - F14 group living in a non-dairy farm located at about 2.8 km from the WWMF. About half of the food is locally grown. The release to the biosphere is CO 2 gas. For a given C-14 release rate, the airborne C-14 concentration at the WWMF DRL critical group location (F14) would be much lower due to much higher atmospheric dispersion compared to that at the house over the main shaft for the Severe Shaft Failure Scenario. Other factors relevant to the comparison are the release rates, the nature of the gas (i.e., CH 4 and CO 2 ) in release, and the local food consumption rates. The purpose of the WWMF DRL example was to bound the potential hazard from the DGR for the more general case of people that live in the vicinity of the site, rather than the hypothetical family living directly on the repository shafts. Reference: OPG OPG s Deep Geologic Repository for Low and Intermediate Level Waste - Preliminary Safety Report. Ontario Power Generation report SR R000. Toronto, Canada. (CEAA Doc# 300) EIS Section , Groundwater Information Request: Provide measured hydraulic gradients in all formations present in the site area. Context: The proponent provided measured hydraulic gradients in the Salina A1 Upper Carbonate, Guelph, and Cambrian, but not in other rock units. The CNSC indicated that the measured hydraulic gradients play an important role in the conceptualization of the local scale groundwater model and the Postclosure Safety Assessment. The CNSC noted that, considering the relative large uncertainty involved with hydraulic conductivity of tight rocks, the measurements of hydraulic gradients are especially important to understand the hydrogeological nature, and possibly improve the conceptualization and modeling, of the groundwater flow and contaminant transport, and thus the Post-closure Safety Assessment. OPG Response: The Descriptive Geosphere Site Model (DGSM) describes activities conducted as part of Deep Geologic Repository (DGR) geoscientific investigations to characterize hydraulic formation pressures within the Paleozoic sediments underlying the Bruce nuclear site (INTERA 2011, Sections 4.12). Information regarding hydraulic formation pressures has been obtained by two means: i) estimates obtained during the in-situ borehole hydraulic conductivity testing program; and ii) fluid pressure measurements within the multi-level Westbay MP-55 and MP-38 systems installed in the DGR and US-series boreholes. As part of an on-going environmental baseline monitoring program, the routine monitoring of formation hydraulic heads within these Westbay-instrumented boreholes has continued on a quarterly basis through 2011 and Page 84 of 90

89 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response As described by INTERA (2011, Section ) horizontal hydraulic gradients were estimated only for the permeable Salina A1, Guelph and Cambrian aquifers (INTERA 2011, see Hydrostratigraphic Units Figure 4.106). Within these confined aquifers the measured hydraulic heads observed in the triangularly-arranged Westbay installations at DGR-1/2, DGR-3 and DGR-4 had equilibrated rendering horizontal gradient estimates reliable. Within the aquitard and aquiclude hydrostratigraphic units shown in INTERA 2011 (Figure 4.106; Hydrostratigraphic Units 3, 5, 6 and 7) similar equilibrated formation pressure conditions do not exist, in part, a consequence of low formation rock mass hydraulic conductivities. This issue coupled with multiple sources of evidence pointing to the existence of low formation hydraulic properties (i.e., to m/s) suggests that groundwater flow and contaminant migration in these units is minimal (i.e., groundwater system diffusion dominant) (NWMO 2011, Section 8). This is particularly the case in the Ordovician sediments proposed to host and enclose the DGR. A discussion of confidence in observed formation pressures and hydraulic properties within these units is provided by INTERA (2011, Sections and ). Given the information above, the estimation of horizontal gradients in aquitard or aquiclude hydrostratigraphic units would not materially change the interpretation of groundwater flow or mass transport described in the Geosynthesis report (NWMO 2011, Section 5.5) or the Postclosure Safety Assessment (QUINTESSA et al. 2011). References: INTERA Descriptive Geosphere Site Model. Intera Engineering Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NWMO Geosynthesis. Nuclear Waste Management Organization Report NWMO DGR TR R000. Toronto, Canada. (CEAA Doc# 300) QUINTESSA, GEOFIRMA and SENES Postclosure Safety Assessment. Quintessa Ltd, Geofirma Engineering Ltd. and SENES Consultants Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) EIS Section 13.5, Interpretation of Assessment Results and Comparison with Acceptance Criteria Class1 Nuclear Facilities Regulation, 5(g) Information Request: Describe what in situ geomechanical testing and what up-scaling conditions are planned to obtain the geomechanical properties of rock masses at the upscaling field testing during the shaft sinking and during the lateral development of the underground facility. Clarify why no in situ geomechanical testing for the Cobourg Formation is planned during shaft sinking, but is planned during the lateral development. Clarify if there is any plan to verify the bottom extent (boundary) of the Cobourg Formation beneath the repository room floor as designed. Provide more information on the specific timing of the various planned verification activities. Page 85 of 90

90 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Context: The intent of the Geoscientific Verification Plan (GVP) is to gather additional geoscientific information to reduce the uncertainties of the sub-surface geologic and geotechnical conditions, and to support engineering decisions and the DGR safety case and any future license applications. The up-scaling in situ geomechanical testing will provide additional site-specific geomechanical data to support the design of the underground facility and to contribute to the safety case. However it is not clear what in situ geomechanical testing is planned under what up-scaling conditions. In situ geomechanical properties of the Cobourg Formation are needed for the design of the lateral underground facility including the shaft station and service area. However, no in situ geomechanical testing of the Cobourg Formation is planned before the development of the lateral facility (i.e. excavation of the shaft station and service area). The underground facility of the DGR is expected to be designed to be fully contained within the Cobourg Formation. This is important for both the construction of the DGR and the long term safety of the facility. However, the GVP does not include the verification of the bottom extent (boundary) of the Cobourg Formation beneath the repository room floor that could be impacted by the inclination of the formation. OPG Response: The Geoscientific Verification Plan lists proposed activities to investigate and confirm up-scaled rock mass properties within the Cobourg Formation (NWMO 2011a, Sections , , and ). These activities principally involve acquiring large diameter core (>75 mm) or intact block (~0.6 m cube) laboratory rock samples to characterize scale and anisotropic influences on estimates of rock mass strength and stiffness necessary for design verification. The proposed geotechnical testing will be similar to that performed during the DGR Site Characterization studies, including uniaxial compression and direct shear tests (NWMO 2011b, Chapter 3). In-situ deformation modulus measurements to determine the variations in rock stiffness at various distances from the shaft wall will also be performed (NWMO 2011a, Section ). A detailed testing plan, beyond that described in the Geoscience Verification Plan, will be developed prior to DGR shaft construction. In-situ geomechanical testing within Cobourg Formation will be performed at first opportunity during shaft sinking once the formation is exposed. Based on the Geoscientific Verification Plan, an under-excavation test is planned within the Cobourg Formation (including Collingwood Member) to verify the up-scaled rock mass parameters and the in-situ stresses used in the DGR engineering design (NWMO 2011a, Section ). This comprehensive test includes drilling a number of instrumented pilot holes with deformation strain gauge type inclinometers installed in advance of shaft excavation in the formation (NWMO 2011a, Section ; Figure 2.4). Stress change cells will also be installed at the end of selected pilot holes to capture the response of the rock mass. These measurements will be back-analyzed to confirm the rock mass modulus and the in-situ stresses. This work will be performed in conjunction with horizontally oriented over-coring stress measurements at selected horizons within the shaft as described by the NWMO (2011a, Page 86 of 90

91 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR IR# EIS Guidelines Section Information Request and Response Section ). As described in the Geoscientific Verification Plan, a geophysical survey will be carried out along all emplacement rooms for their entire length to detect possible geologic structure between room pillars and below the repository to the Precambrian basement (NWMO 2011a, Section ). This geophysical survey will also provide information necessary to confirm, if required given the demonstrated lithostratigraphic continuity, the lower Cobourg Formation contact. In terms of timing, all geoscientific verification activities will be coordinated with the construction schedule for vertical and lateral DGR development. This will need to consider: i) construction progress in gaining shaft access to the nine proposed horizons (i.e., Salina (F, C, A2 and A1 Units), Cabot Head, Queenston, Georgian Bay, Blue Mountain and Cobourg formations (NWMO 2011a, Table 2.2)); and ii) the necessity to obtain verification results as early as achievable to support design verification and preparation of an operating licence application. Based on a preliminary construction schedule, verification activities in the main shaft would occur 15 months following initiation of shaft sinking. Within the DGR lateral development, activities would be conducted as excavation on multiple working fronts permitted during a 36-month construction period. References: NWMO. 2011a. Geoscientific Verification Plan. Nuclear Waste Management Organization document NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) NWMO. 2011b. Geosynthesis. Nuclear Waste Management Organization report NWMO DGR-TR R000. Toronto, Canada. (CEAA Doc# 300) List of Enclosures: 1. Figure , Stream "C" Assessment 2007 associated with IR EIS response 2. Figure 1, Fish Sampling in the South Railway Ditch associated with IR EIS response 3. Figure 2, Aquatic Sampling associated with IR EIS response 4. Western Waste Management Facility General Arrangement 0125-WS FS4 associated with IR EIS response Page 87 of 90

92 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR TABLES ASSOCIATED WITH RESPONSE TO IR-EIS Page 88 of 90

93 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR Page 89 of 90

94 Attachment 1 to OPG Letter, Albert Sweetnam to Dr. Stella Swanson, Deep Geologic Repository Project for Low and Intermediate Level Waste Submission of Responses to Package #7, CD# CORR Page 90 of 90

95 Baie du Doré ³ Bruce A!(!(!(!!(!(!(!(!(!(!(!(!( B Tie Rd. G:\Projects\2006\ _BruceEA\GIS\MXDs\Draft\Report1\Aquatic\Stream_C_Assessment.mxd WWMF Main Entrance LEGEND Stream "C"!( Crayfish Chimney Locations (2007)! Electrofishing Locations Stream Reach Stream 'C' Property Boundary 'A' Reach Designation A REFERENCE Site Layout and Base Data - Provided by Bruce Power. Airphotos - Terra Remote Sensing, 2006, 25cm resolution. Datum: NAD 83 Projection: UTM Zone 17N PROJECT TITLE Concession Rd Kilometres Extent of Map COUNTY RD BRUCE NEW NUCLEAR POWER PLANT PROJECT ENVIRONMENTAL ASSESSMENT STREAM "C" ASSESSMENT 2007 PROJECT No SCALE: AS SHOWN DESIGN SC 22 Jan GIS BC 18 Apr CHECK TdH 18 Apr Mississauga, Ontario REVIEW 18 Apr COUNTY RD 15 REV. 0 FIGURE

96 MacPherson Bay ³ Drainage Ditch Interconnecting Road!(Ï!(Ï!(Ï Spent Solvent Treatment Facility!(Ï!(Ï!(Ï!(Ï Waste Chemical Transfer Facility DGR North Railway Ditch!(Ï!(Ï South Railway Ditch Small Pond Stream 'C' Downstream of Rail Bed Abandoned Rail Bed Upstream of Rail Bed Abandoned Oil Unloading WWMF Former Construction Landfill #1 Central Maintenance & Laundry Facility Fire Training Facility Former Construction Landfill #4 Bruce Learning Centre Tie Rd. Michigan Indiana Index Map Michigan Lake Huron Ohio Lake Erie DGR PROJECT Ontario West Virginia Toronto!. Lake Ontario Pennsylvania Québec New York USA New Jersey LEGEND!(Ï Electrofishing Locations Stream Project Area (OPG-retained lands that encompass the DGR Project) Site Study Area 1 NOTES 1. Site Study Area is defined by EIS Guidelines as: "includes the facilities, buildings and infrastructure at the Bruce nuclear site, including the existing licensed exclusion zone for the site on land and within Lake Huron, and particularly the property where the Deep Geologic Repository is proposed. REFERENCE Base Data Provided by 4DM, November Imagery and Topo Collected and Processed by Terrapoint Canada Inc., Acquisition Date: Nov. 12, 14, and 15, 2006, Ground Resolution: 0.25m, Datum: NAD 83 Projection: UTM Zone 17N PROJECT TITLE Metres AQUATIC ENVIRONMENT FISH SAMPLING IN THE SOUTH RAILWAY DITCH DESIGN GIS CHECK Mississauga, Ontario REVIEW PROJECT NO ASB 17 Oct BC JO 23 Nov Nov SCALE: AS SHOWN FIGURE 1 R000

97 ³ Lake Huron Baie du Doré Douglas Point! MacPherson Bay #I ") ") ") #I #0#0#0#0#0 ") #0#0#0#0 #I ") Bruce A Douglas Point Nuclear Reactor Former BHWP! WWMF Stream "C"! Tie Rd. Bruce B Main Entrance County Rd. 20 Michigan Indiana Index Map Michigan Lake Huron Ohio Lake Erie DGR PROJECT Ontario West Virginia Toronto!. Lake Ontario Pennsylvania Québec New York USA New Jersey LEGEND! Index Netting Location a Smallmouth Bass Nesting Location a! Electrofishing Locations a Benthic Invertebrate Samples a ") Minnow Trap Location b #0 Seining Netting Location b Stream C Bruce nuclear site NOTE a-denotes sampling undertaken for the Bruce New Build EA b-denotes sampling undertaken for the DGR EA REFERENCE Base Data Provided by 4DM, Nov Imagery and Topo Collected and Processed by Terrapoint Canada Inc., Acquisition Date: Nov. 12, 14, and 15, 2006, Ground Resolution: 0.25m, GOLDER Bruce New Nuclear Power Plant Project Environmental Assessment: EIS Studies Aquatic Environment Technical Support. Datum: NAD 83 Projection: UTM Zone 17N PROJECT TITLE ,000 2,000 AQUATIC ENVIRONMENT AQUATIC SAMPLING DESIGN GIS CHECK Mississauga, Ontario REVIEW Metres PROJECT NO ASB 17 Oct BC JW 15 Nov Nov SCALE: AS SHOWN FIGURE 2 R000