July 31, Comments re Environmental Impact Statement & License Application For Deep Geologic Repository Project

Transcription

1 July 31, 2012 Attention: Debra Myles, Panel Co-Manager c/o Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Ottawa ON K1A 0H3 Kelly McGee, Panel Co-Manager c/o Canadian Nuclear Safety Commission PO Box 1046, Station B 280 Slater Street Ottawa ON K1P 5S9 Dear Ms. Debra Myles & Ms. Kelly Mc Gee Comments re Environmental Impact Statement & License Application For Deep Geologic Repository Project Please find below my comments on the Environmental Impact Statement & Licence Application for the Deep Geologic Repository (DGR) Project of Ontario Power Generation (OPG). This concerns the proposed long term underground storage of Low Level (LLW) & Intermediate Level (ILW) nuclear waste at OPG s Western Waste Management Facility (WWMF) at the Bruce nuclear site in the Municipality of Kincardine (MOK). My Involvement in The DGR Project As a Councillor and Mayor of both the former Town of Kincardine and then the Municipality of Kincardine, I have gained a unique insight into the DGR project. I was a member (as a Councillor and Mayor) of the Nuclear Waste Steering Committee for the Municipality of Kincardine (that consisted of the Mayor, Deputy-Mayor, two Councillors and the CAO) during the years leading up to, during the first proposals and finally the signing of the final Memorandum of Agreement. I was also a member of the South Bruce Impact Advisory Committee for many years as well where we updated other local municipalities. An Overview of The DGR Project In 2002, the MOK approached OPG to consider options for the long term management of OPG s LLW and ILW. On April 16, 2002 the council for the Municipality of Kincardine entered into a Memorandum of Understanding with Ontario Power Generation to set out

2 the terms under which both parties would develop a long term plan to deal with LLW and ILW at the WWMF. Highlights of this plan included : a) a commitment to openness and transparency in the review of the options. b) an Independent Assessment Study (IAS) was commissioned to examine the technical feasibility, safety and licensability, environmental protection feasibility, and socio-economic costs and benefits of each of the long-term management options. c) a commitment to public consultation and community communications. d) use of newsletters, open houses, a web page and advertisements. e) interviews with the media (newspapers, radio and television). f) joint trips to Europe and the USA to visit other countries and tour their low level waste storage sites to assist in the selection of the best alternatives. g) community host fees shared by the Municipality of Kincardine and the surrounding four municipalities. The entire project was managed for Council via our NWSC (Nuclear Waste Steering Committee). Our council had two trips in 2002 and 2003 respectively (two separate groups of different members of council took part with our CAO and several OPG personnel). The objective was to tour nuclear waste long term storage facilities in other countries to obtain information on their design, operation, community consultation & determine the best technology available. In 2002, the first group (that I was a part of) visited: a) the Zwilag facility in Wurenlingen, Switzerland. b) the NAGRA (National Cooperative for the Disposal of Radioactive Waste) in Wettingen, Switzerland. c) the ANDRA National Radioactive Waste Management Agency the Centre de L Aube Disposal Facility in Soulaines, France. d) the SKB: Swedish Nuclear Fuel and Waste Management Company in Forsmark, Sweden. In 2003, the second group visited: a) the Chem-Nuclear Systems LLC LLRW (Low-Level Radioactive Waste Management Facility) in Barnswell, South Carolina. b) the DOE (Dept. of Energy) WIPP (Waste Isolation Pilot Plant) in Carlsbad, New Mexico. In February of 2004, an Independent Assessment Study (IAS) was completed by Golder Associates. The IAS considered three options that were technically feasible and safe. These three options were then analyzed for their the potential environmental, social and economic impacts and benefits:

3 Enhanced Processing, Treatment and Long-Term Storage Covered Above-Ground Concrete Vault Deep Geologic Repository The MOK council then requested OPG to proceed with the DGR as Kincardine s preferred option. A DGR Hosting Agreement was signed by the MOK and OPG in October, This agreement was based on a positive poll being received from the ratepayers of the MOK. As they say in the real estate business, everything boils down to location, location, location. In my personal opinion, the success of our positive public consultation was due to the ongoing commitment of both the Municipality of Kincardine and Ontario Power Generation to communications and keeping our public informed. This was evidenced by the use of a Community Consultation Centre at 759 Queen Street in Kincardine. This office was staffed by a member of Kincardine Council and an OPG person from October 15, 2004 until the end of January, 2005 where the public was welcomed into the office to have their questions and concerns answered. Please refer to Appendix A for a copy of the text used for the actual Community Consultation question. The outcome of the community consultation process was a positive poll result by a majority of our ratepayers. Our council then formally accepted, with a bylaw, an agreement with Ontario Power Generation to proceed onto the Environmental Assessment and CNSC licensing processes. Please note that the MOK council passed a motion right after this bylaw was accepted to inform the Nuclear Waste Management Organization (NWMO) that the MOK did not want to be considered as a willing host community for the long term storage of high level nuclear waste. OPG then proceeded with the Environmental Assessment process. Several test boreholes were drilled at the WWMF and the rock samples tested for geological properties. OPG has collaborated with international experts in the field of geoscience and the DGR project has undergone peer review. This effort has ensured that the DGR project has been developed in alignment with international best practices. Observations re DGR Project OPG has always attended the monthly meetings of both the South Bruce Impact Advisory Committee and the Joint Liaison Committee and reported on operational issues, safety programs, new proposed programs and new buildings. At these meetings that I attended, details were presented of ongoing programs.

4 Worker safety and public safety was always first and foremost in the approach of OPG. The most recent safety statistics were routinely reported. Compliance with regulatory authorities (e.g. CNSC, MOE etc.) was reported on a regular basis. The Quality Assurance program has been in place for many years now and examples given as appropriate. Environmental impacts were minimal and emissions monitoring always in place. Their ISO program supports this objective. There is a management commitment to continuous improvement in operational performance. Loss Control Programs have been maintained at the WWMF with audits completed on a routine basis. In the area of community consultation, OPG has maintained a detailed web site and routinely mails out a document entitled DGR Newsletter to the area. Open Houses are always held for new initiatives at the WWMF. A DGR mobile exhibit has been used for several years now to attend local events and fall fairs etc. to communicate with the public. Summary & Recommendations I have reviewed the documents that OPG has submitted for the DGR Environmental Impact Statement (EIS) and the Preliminary Safety Report (PSR). The major areas of review included geoscience, design engineering, safety assessment, environmental fieldwork and a public engagement program. I concur with the conclusion that the DGR is not likely to result in any significant adverse residual effects to human health or the environment. In summary, for the reasons above, I would urge the Joint Review Panel (JRP) to accept and approve OPG s Environmental Impact Statement (EIS) and the Preliminary Safety Report (PSR). Future Hearing (s) re The DGR I would appreciate an opportunity to appear before any future hearing (s) that the Joint Review Panel (JRP) may have re the DGR. Respectfully Submitted Glenn R. Sutton P. Eng., PMP

5 APPENDIX A Question Used in Community Consultation Question Preamble The Kincardine Council has expressed its support for the long-term management of low and intermediate nuclear waste in a deep geologic repository to be owned and operated by Ontario Power Generation at the Western Waste Management Facility located at the Bruce site. Council s decision was based on the following key points: It provides the highest level of safety of any option. There will be a rigorous environmental assessment and Canadian Nuclear Safety Commission regulatory process that includes opportunities for public input before construction is approved. The deep geologic repository will permanently isolate the low and intermediate level waste stream, much of which is already stored on site. It provides significant economic benefit to the residents of our municipality. No high level waste or used nuclear fuel would be allowed in the facility. In summary, Council believes it is important to solicit the views of residents. Do you support the establishment of a facility for the long-term management of low and intermediate level waste at the Western Waste Management Facility? Yes No Neutral