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From: Glenn Sutton To: Deep Geologic Repository Project/ Projet de stockage de déchets radioactifs[CEAA\ACEE]; Glenn Sutton Subject: Conference Proceedings From 5th ICGR Paris, France Date: March 3, 2017 4:54:55 PM

Deep Geologic Repository Project

Canadian Environmental Assessment Agency Government of Canada 160 Elgin Street, 22nd Floor Ottawa ON

To Whom It May Concern:

Please find below an excerpt from the web page for the Fifth International Conference on Geological Repositories (ICGR) held recently in Paris.

Fifth International Conference on Geological Repositories

Developing and implementing geological repositories for long-lived radioactive waste On 6-9 December 2016, the NEA and the French national radioactive waste management agency Andra held the fifth International Conference on Geological Repositories (ICGR) in Paris, France. The conference, on "Continued Engagement and Safe Implementation of Geological Repositories", convened senior-level decision-makers representing international and national bodies from countries that are in different stages of implementing deep geological repository programmes. Participants underlined the added value of international co-operation for the safe implementation of geological repository projects and concluded that deep geological repositories remain a viable and safe option for the management of radioactive waste. The scientific knowledge and technical bases relating to the disposal of radioactive waste are being enhanced and the technical design of repositories will be further optimised through current and future R&D programmes. Participants also noted that current strategies for repository implementation follow international standards, recommendations and best practices for nuclear safety and security. The important role of continued stakeholder dialogue in advancing a geological repository project was also highlighted. Conference proceedings are in preparation and will be issued online.

It is recommended that the CEAA obtain a set of the conference proceedings that contain the papers or proceedings that resulted in this quote being included in the press release: "Participants underlined the added value of international co-operation for the safe implementation of geological repository projects and concluded that deep geological repositories remain a viable and safe option for the management of radioactive waste."

Further, that this set of information & facts be included in and recognized in any final report.

Respectfully Submitted,

Glenn R. Sutton P. Eng., PMP.

To: Deep Geological Repository Project Canadian Environmental Assessment Agency 160 Elgin St. Ottawa ON K1AOH3

Comments re OPG's Response to Information Request from Minister of Environment & Climate Change Here are my brief comments on the seven reports as follows. I have concentrated on the first report. 1) Main Submission I have read over this report. It is well documented. I support the conclusions in section 10. This report is presented in the manner of previous EA reports. In section 9 of the Main Submission, reference is made to the IEP (International Expert Panel). I would like to reiterate three statement that appears in the IEP report: a) Section 3 last paragraph page 13:

"The IEP is familiar with many of the reference documents cited within the OPG response and the IEP did look at a number of the documents to confirm their relevance and accuracy. Overall, the IEP finds the reference documents have been utilized in an appropriate manner to support conclusions reached by OPG".

b) Main Conclusion1 # 7 page 17 : "The host rock at the planned DGR site at the BNS is a superb environment to secure the L&IL W in a manner that will effectively isolate the radionuclides from the biosphere. The transport time of any radionuclides in porewater through the host rock to the accessible environment is so long that they will decay to insignificant levels before release occurs."

c) Main Conclusion page 17 - second last paragraph:

"In the view of the IEP, the OPG submission illustrates that the solution with the least environmental and economic consequence is the proposed DGR at the BNS. The IEP conclusion is consistent with a similar conclusion reached in 2015 by the Joint Review Panel established by the Minister and the President of the Canadian Nuclear Safety Commission."

2) Description of Alternate Locations

Crystalline rock and Sedimentary rock is compared and contrasted. This report lays the groundwork for the next report.

3) Environmental Effects of Alternative Locations

Seven "Valued Components" were identified and studied.in detail. These seven components have been studied for other projects at the Bruce site (e.g. Douglas Pt., BNGS-A, BHWP-NBICID, BNGS-B and the WWMF. For this report, two locations in Northern Ontario for crystalline rock and in Southern Ontario for sedimentary rock were analyzed.

The report conclusion was: "A DGR at an alternate location could be constructed without any likely significant environmental effects. However, environmental effects of a DGR at an alternate location (both sedimentary and crystalline rock) are likely to be greater as compared to the DGR Project at the Bruce Nuclear site".

4) Cost and Risk Estimates for Packing and Transporting Waste to Alternate Sites

Detailed Analysis of the costs and risks for alternate sites in both crystalline rock in Northern Ontario and sedimentary rock in Southern Ontario were completed. The results are found in Tables 4-1 to 4-5 for a variety of cost estimates. It is noted that there would be additional costs depending on distance. 5) Updated Analysis of Cumulative Environmental Effects

This report analyzes the cumulative effects from the OPG DGR with respect to an APM DGR in either South Bruce, Twp. ofHuron-Kinloss or Central Huron.

Table 7-1 on page 41 summarizes all of the cumulative effects. The conclusion on page 43 is:

"The updated analysis of the cumulative effects of the DGR Project at the Bruce Nuclear site in light of the APM DGR project shows that there is no potential for likely adverse cumulative effects and the conclusions presented in the EIS for the DGR Project at the Bruce Nuclear site [OPG 2011a] regarding cumulative effects remains valid. This report also shows that cumulative effects are unlikely as a result of malfunctions, accidents, and malevolent acts related to both projects."

6) APM DGR Preliminary Description

This report was prepared to support the previous report in section 5. It is basically a design description of a DGR for spent nuclear fuel. Many design features, drawings and building & equipment requirements are presented.

7) Mitigation Measures

This report is the longest of all reports at 192 pages. This report completes the third request of the Minister for "an updated list of mitigation and monitoring commitments for each identified adverse effect for the DGR project at the Bruce Nuclear site."

It is achieved by use of 10 tracking tables, one for each Environment Component with commitments according to Valued Component and topic.

This is to ensure that upon completion the DGR project will not cause any significant adverse environmental effects. Summary & Recommendation

I have reviewed all 7 ofOPG's reports listed above. All 7 reports are very thorough and detailed.

One of the highlights of the suite of reports is the IEP (International Expert Panel). Three independent experts form the USA, Canada and Finland reviewed the previous work of OPG and agreed with OPG' s conclusions.

I, as before, again concur with the conclusion of each of these 7 reports and that the Federal Minister of Climate Change and the Environment should approve the Joint Review Panel's recommendation that:

"The Panel agrees with OPG that the DGR is the preferred solution for the long term management of L& ILW."

With respect to alternative locations reviewed in Northern Ontario for crystalline rock and in Southern Ontario for sedimentary rock, these two options are more expensive and would be completed much later than the current proposal. Also, both of these options are missing one key factor and that is a "Willing Host Community". The Municipality of Kincardine is a "Willing Host Community" and that fact is the most important factor.

Respectfully Submitted,

Glenn R. Sutton, P. Eng., PMP. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

OVERVIEW AND UPDATE ON “THE KINCARDINE INITIATIVE”: OPG’S DGR FOR THE STORAGE OF LOW AND INTERMEDIATE LEVEL NUCLEAR WASTE (2000 – 2016)

G. R. Sutton Energy Initiatives Ontario, Kincardine, Ontario, Canada

Abstract

The Bruce site (Western Waste Management Facility {WWMF}) has been the host storage site for all Low & Intermediate Level Waste (L/ILW) from Ontario Power Generation (OPG) reactors. This paper will summarize key themes and techniques that resulted in the initial proposal called the “Kincardine Initiative” leading to a Memorandum of Understanding (MOU) being signed between the Municipality of Kincardine (MOK) and OPG. Particular attention will be given to various engagement techniques that assisted council members of the MOK to assure them that there was community support. A summary of best international communications practices will be reviewed and discussed briefly. References to other relevant, international nuclear waste disposal sites will be provided. Challenges of simplifying complex scientific, technical and geological concepts and information for general public understanding will be addressed. Highlights of this plan included commitments to openness and transparency in the options review and a commitment to both public consultation and communications. This commitment also included joint trips to Europe and the USA to aid selection of the best technology and alternatives. This led to signature of a unique Community Hosting Agreement. Major themes to be described for use by other jurisdictions included the use of a Community Consultation Centre staffed by both MOK and OPG, use of University of Western Ontario MBA students to research international industry trends and briefings with key stakeholders including First Nations. Finally, the extensive hearings by the Joint Review Panel (JRP) will be reviewed to emphasize how science based Environmental Assessments are the “wave of the future”.

1. Purpose of paper

The main purpose of this paper is to describe how the MOK Council was assured that there was community support for this project.

2. Prior history of nuclear waste management in Canada

A condensed history of Nuclear Waste Management may be found in “Canada Enters the Nuclear Age” [1], Chapter 19 (Waste Management) and also the NWMO Final Study [2]. A quote from Chapter 19 is prescient: “That the waste management facilities at Chalk River have withstood the test of over forty years of operation without even approaching any releases of concern is testimony to the soundness of the judgment exercised by those early scientists” (as of 1997 - date of book publishing) [1].

3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

3. Brief history of Canadian HLW long-term management

The issues and challenges in Canada, of how to address the issue of disposal and storage of High Level Waste (HLW) was summarized in the NWMO Final Study [2]. In section 1.1: “A paper documenting the legacy of the Seaborn Panel in pointing to the imperative to consider the ethical and social domains as well as the technical questions on one of the approaches under NWMO”s review can be found at www.nwmo.ca (background paper # 2-8).

4. Nuclear Fuel Waste Act (NFWA)

Quoting from the Nuclear Waste Management Organization (NWMO) in Section 1.1, Introduction of the Final Study (Choosing a Way Forward) [2]:

“The Government considered and responded to the Seaborn Panel, and in November 2002 brought into force the Nuclear Fuel Waste Act [3] (an Act respecting the long-term management of nuclear fuel waste) (NFWA) (see Appendix 2). As required by that federal legislation, the Nuclear Waste Management Organization (NWMO) was established.

Thus the stage was now set for a new, fresh approach to the ultimate Canadian solution for long- term storage of HLW; however, there was a problem! The newly approved Nuclear Fuel Waste Act was silent on what approach to use for the storage of L/ILW!

5. MOK committee system

The NWSC (Nuclear Waste Steering Committee) was a special committee of Council struck in about 2001 to start the process of negotiating with OPG on the MOK’s desire to offer itself as a “willing host community”.

6. Initial approach by MOK to OPG

Initial approaches were made by the MOK to OPG about the possible long-term storage of both LLW & ILW at the Bruce site. More detailed discussions were held and coordinated by the NWSC who reported back to the full council as required.

At the end of those discussions, which were accompanied by intense negotiations between both MOK and OPG, Resolution # 2002-202 was introduced at MOK council, discussed and passed on April 15, 2002. It was in the form of a “Memorandum of Understanding” (MOU) [4].

7. Due diligence by MOK

Two separate information gathering trips were undertaken by MOK Council and OPG staff. The purpose of these trips was to determine the “best in class” technology available in the world to recommend to MOK Council, for eventual adoption as the selected method for final long-term storage of L/ILW. In 2002, Switzerland (Zwilag in Wurenlingen, and the NAGRA project in Wettingen), France (ANDRA Centre de l’Aube) and Sweden (SKB – SFR Facility in Forsmark) were toured. In 2003, South Carolina (Barnwell) and New Mexico (Carslbad – WIPP Facility) were toured. Please refer to the Joint Review Panel PowerPoint presentation [5] submitted by the MOK for an overview and summary of both trips. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

8. Determination of public support for the project

The NWSC was assigned, on behalf of MOK Council, the task of developing a process that would measure the degree of support from the residents of MOK, and also owners of property who were in MOK during the summer. The first task at hand was to prepare an Independent Assessment Study (IAS) that basically researched three options and presented a thorough analysis of each one with the preferred option.

Quoting from the Executive Summary [6]: “The study examined the costs, impacts and benefits of constructing and operating each of three long-term management concepts at the WWMF, namely: Enhanced Processing and Storage, Surface Concrete Vaults, and Deep Rock Vaults. The study found that all three long-term management options are technically feasible and may be safely constructed and operated at the WWMF.”

Also quoting from Section 7.2.5 (First Nation Consultation) [6]: “Stakeholder contact with Chippewas of Nawash First Nation and the Saugeen First Nation was conducted as part of the consultation plan. A draft communications protocol was developed and provided to the First Nations to facilitate a productive exchange of information between First Nations, Kincardine and OPG.”

Finally, quoting from Section 7.4 (Overview of Communication and Consultation) [6]: “Based on feedback received from the stakeholders briefings, Open Houses and First Nation briefings, the majority of stakeholders are supportive of the IAS and appreciate the consultation efforts to date. There was little opposition to any of the long-term management facility options.”

The NWSC recommended to Council that Deep Rock Vaults be pursued. The MOK Council adopted this recommendation.

9. Community Consultation Centre (CCC) & mobile exhibits & open houses

One of the most important and effective methods of public outreach and engagement was the MOK CCC (see Figure 1). This centre was located in downtown Kincardine. Inside there were many large-sized panels illustrating various stages of the L/ILW project. Of most use were the diagrams with details of the proposed deep geological repository. At all times during the various phases of the proposed project, both one member of the MOK council and one employee from OPG staffed the centre. The author remembers and can attest to the fact that some people changed their opinion from that of non-support to support for the MOK Initiative. A guest reception log book was kept.

10. Community consultation

The MOK owns a telecommunications company. A telephone poll was conducted of MOK residents (summer residents were also included). A polling company was retained to conduct this poll and another company performed a third party audit of the process and results. The results were positive for the poll and MOK Council passed By-law # 2004-157 on October 13, 2004 [7].

3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

Figure 1. Opening of the Community Consultation Centre in Kincardine, ON

11. Engagement techniques

Communications: In the area of effective communications, both the MOK and OPG agreed at the outset for the public engagement process to have open and transparent two way communications.

Technical Factors: It was decided to use companies and consultants who were skilled in public dialog with diverse groups and had a previous track record of technical acumen and outstanding communications skills.

Aboriginal Engagement: Saugeen Ojibway Nation (SON) is the collective name for the Chippewas of Nawash Unceded First Nation and the Chippewas of Saugeen First Nation. Outreach to the local First Nations bands was made by the consultant including MOK and OPG representatives.

Continuing on with the earlier quotation from Section 7.2.5 (First Nation Consultation) of the Independent Assessment Final Report [6]: “The goals of this protocol are: - Acknowledging that the Saugeen and Nawash Bands have a demonstrated interest in the operations at the Bruce Power site; 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

- Incorporating issue identification, tracking and management capability in recognition of the reality that issues frequently arise through increased community awareness resulting from the consultation process and the related enhanced profile of the WWMF; and - Maintaining flexibility to respond to newly identified issues as well as Nawash and Saugeen input throughout the study period. The protocol was submitted in June, 2003 to the two First Nation bands and initial briefings were held with both First Nations. A meeting with the Joint Council for both bands is scheduled for early 2004.” In particular, the author took part in one of these Aboriginal consultations. A staff engineer from the consultant, who was of Aboriginal descent, made the initial presentation. His presentation was made in a manner that was appropriate for the Council to understand by using an Aboriginal perspective. After this presentation, the Band Councillors asked questions of both the MOK and OPG representatives.

12. UWO Business School - strategic planning services for MOK

From the Introduction [8]: “A team of four students from the Richard Ivey School of Business were commissioned to consult in a study regarding negotiations on a Radioactive Waste disposal facility. In the original mandate for the report, Kincardine requested a financial analysis, which they can use in negotiations with Ontario Power Generation”. Later it goes on to state: “It is important to note that the content of this report largely focuses on the business opportunity and value-creating mechanisms.” This report was used by both the NWSC and council to assist in its negotiation strategies. Various financial models were analyzed and also the issue of “stigma” was addressed. It was found to be a very useful document for guidance.

13. Canadian Association of Nuclear Host Communities (CANHC)

The CANHC [9] was an association of nuclear host communities across Canada that joined together to compare experiences with the various aspects of the nuclear fuel cycle in Canada. It had an annual meeting each year in Ottawa at the same time as the CNA Winter Symposium. It also made presentations on behalf of its members at regulatory hearings as needed.

Another organization that is somewhat similar to CANHC is the Energy Communities Alliance (ECA) [10].

14. Canadian Nuclear Safety Commission (CNSC) regulatory interface

“The Canadian Nuclear Safety Commission (CNSC) regulates the use of nuclear energy and materials to protect health, safety, security and the environment and to respect Canada’s international commitments on the peaceful use of nuclear energy. Created in 1946 as the Atomic Energy Control Board, the agency changed its name in 2002 with the enactment of the Nuclear Safety and Control Act (NSCA)” [11]. The CNSC is the Canadian regulator for all aspects of the nuclear fuel cycle, but other municipal, county, provincial and federal levels of government have their roles as well.

The CNSC has a Factsheet entitled “Regulating Canada’s Geological Repositories” [12]. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

15. The Environmental Assessment process

The Environmental Assessment (EA) process was started by following the required activities under the Canadian Environmental Assessment Act 2012 (CEAA) [13].

16. OPG’s Deep Geologic Repository Environmental Impact Statement summary

In March of 2011, OPG’s Deep Geologic Repository Project for Low & Intermediate Waste Environmental Impact Statement Summary [14] was issued.

Detailed findings of the EA completed for the DGR are presented in the Environmental Impact Statement (EIS) and Technical Support Documents (these documents can be assessed at www.ceaa-acee.ca).

17. The Joint Review Panel

The Joint Review Panel (JRP) was established to examine this project on January 24, 2012 as per the Executive Summary[15]: “The Panel’s mandate was to: assess the proposed project in accordance with the requirements of the Canadian Environmental Assessment Act, 2012; consider the OPG application for a License to Prepare Site and Construct under the Nuclear Safety and Control Act; and to obtain information about potential adverse effects that the project may have on potential or established Aboriginal rights, title or Treaty rights.”

The JRP issued its final report on May 06, 2015 [15]. The “Overall Conclusion” in the JRP’s Executive Summary was: “The Panel concludes that the project is not likely to cause significant adverse environmental effects, taking into account the implementation of the mitigation measures committed by the Panel”.

18. International co-operation in nuclear waste storage

As a volunteer member of the Township of Huron-Kinloss Nuclear Waste Community Advisory Committee, the author attended the 40th Annual Waste Management Conference 2014 hosted by the WM Symposia [16]. That symposium was very beneficial in providing the most up to date information on all aspects of nuclear waste and is “the premier international conference for the management of radioactive materials and related topics”. The author’s trip report [17] summarized the current status of world experience with DGR’s and also community engagement processes used elsewhere.

19. The future prognosis for LLW/ILW/HLW storage in DGRs

What is the future prognosis for LLW/ILW/HLW nuclear waste disposal, storage and recycling (both short & long term)? The author has included HLW in this section of the report because all three forms of nuclear waste disposal are intimately linked together. Any development for one type of nuclear waste is a possible solution for the other two. It is important to understand the transition in Canada from previous recommendations to use granite from the Canadian Shield (for HLW) to more recent recommendations to use sedimentary rock as an alternative. The major research effort (s) that lead to that transition may be found in two NWMO position papers [18] [19]. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

To provide an additional level of review for this project the MOK Council had Hardy Stevenson and Associates Limited (HSAL) review, in April 2012, both of the following documents: • Socio-economic Environmental Support Documents, dated March 31,2011, prepared by AECOM Canada Ltd. (NWMO-DGR-TR-2011-08); and • DGR EA Follow-up Monitoring Program March 2011, prepared by the NWMO (NWMO-DGR-TR-2011-10). By November, 2012, after a thorough review of the OPG, AECOM and NWMO documents, HSAL found only six issues that needed to be addressed. All of these issues were resolved by the fall of 2012. HSAL’s conclusions in the Final Peer Report [20] were: • The studies were well done • Overall, the Socio-Economic Environment TSD and Follow-up Monitoring Programs were well done and HSAL supported the conclusions • HSAL reached the same conclusions as AECON/NWMO, that the socio-economic effects will not be significant [5]. HSAL presented their findings to the MOK Council. After the council discussed this report, it was accepted by Resolution #11/07/2012-08 (DGR Peer Review) passed on November 07, 2012 [21].

20. Lessons learned

Communications - At the WM Symposia 2014, the author was impressed with all papers presented in Session # 26. However; one paper captured the essence of how we, as people working in the nuclear fuel cycle, can improve our methods of engaging and reaching out. This includes the general public, including those involved in setting energy and environmental policies etc., at all levels of government and industry [22]. Also, Session # 3 [23] captured local community involvement in both Finland and Sweden. It was very pleasing to see that these two municipalities followed much the same process, as did the MOK; however, there were slight variations due to different rules, regulations, taxation, laws and culture. Session # 24 also covered many aspects of engaging citizens based on lessons learned for around the world, including Canada. Note that a paper was presented by NWMO staff in Session # 26 about the engagement of citizens [24].

Simplification of Nuclear Technology Terms - With respect to nuclear waste disposal, this subject has a separate set of specific terms. Such terms as “permeability”, “hydraulic gradient”, “high sorption capacity”, “repository”, “bentonite clay”, “immobilization”, “gas generation”, “radionuclide migration”, and “buffer” etc. need restating from technical terms into “layman’s language”. This is always on ongoing issue and the industry needs to keep efforts continuing for improvements in this area, such as simplified technical reference words and terms. Please refer to Paper # 14124 from the WM Symposia 2014 that describes a Mini Encyclopedia of Nuclear Energy [25] as an example of this suggestion. It is the author’s opinion that we must improve our communications in this area as nuclear waste disposal/storage is a destiny issue. This means an issue that could affect our industry if it is not addressed in a timely manner, and result in a loss of influence and ability to advance our future growth. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

Concept of Repository Resaturation - One of the main concepts that is challenging to explain about a DGR (to the public at times) is the use of computer simulation for purposes of modelling radioactive isotope transport through rock. This is assumed to start when a DGR is instantaneously resaturated (worst case) after the DGR is sealed off, and then transport occurs after corrosion has taken place and the canister is breached. A book that the author has found most useful for this aspect of DGR radiochemistry is “The Chemistry of Nuclear Fuel Waste Disposal” [26]. It is a concise summary of all the major issues related to nuclear waste disposal and storage.

21. A challenge for the future – ethics in energy?

As an industry we must keep up high safety standards. We must always be fact-based in our approaches and respectful of all points of view. This, for the author, brings up the subject of ethics in energy. When the author met the first Chair of the NWMO at an Impact Advisory in about 2002, the concept of ethics in nuclear waste was first mentioned by the Chair. As a member of the CNS, the author started to receive issues of “Ethics and Energy” [27] in 1980. This series of newsletters ended in 1986. This may be another challenge for our industry to resume in the near future. The author met Tom Isaacs (former Lead Advisor to United States Blue Ribbon Committee on America’s Nuclear Future) recently during his talk with the Twp. of Huron-Kinloss CAC [28]. Quoting from this article, he said “But, as you know, the big issues are often non-technical, they are issues of public acceptance, political issues”. Also, he stated “You need to build a core and earn a core of trust with people”. This also brings up the concept of social license and that is a whole separate but related topic. The author believes that the MOK has received a social license based on the positive poll response and subsequent ongoing updates and communications.

22. Summary and status of the JRP

22.1 Summary

This paper has attempted to summarize a historical overview of the MOK initiative for the OPG L/ILW DGR from 2000 to 2016. The JRP has been completed. The “Kincardine Initiative” being executed by OPG is a very large project. A new book issued this year [29], contains relevant information on how to create a transformational culture.

22.2 Status of the JRP

22.1.1 Request from Minister of Environment and Climate Change.

On February 18, 2016 [30], the Minister of Environment and Climate Change issued a letter to OPG to conduct three further studies into OPG’s low and intermediate level waste (L&ILW) DGR before making a decision on the environmental assessment, and reply back by no later than April 18, 2016.

3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

22.1.2 Reply from OPG

On April 15, 2016, OPG issued a Press Release [31] that stated: “Ontario Power Generation (OPG) has informed the federal government that it will complete further studies on its proposed deep geologic repository (DGR) by Dec. 31, 2016”.

23. Regulatory update 2016

The CNSC issued four documents in 2016 that are germane to this paper: • On February 12, 2016, the CNSC issued REGDOC-3.2.2, Aboriginal Engagement [32]. This document “sets out requirements and guidance for licensees whose proposed projects may raise the Crown’s duty to consult”. The author enrolled in and took a six lesson on-line course [33] “Exploring Ontario First Nation Cultures”. A broader understanding of Aboriginal history and culture was obtained. • On March 14 to 16, 2016, the CNSC hosted a “Multinational Workshop on the Regulation of Deep Geological Repositories” in Ottawa, Canada [34]. • On April 14, 2016, the CNSC [35] issued a “new timeline detailing the CNSC’s extensive independent research on deep geological repositories (DGRs) in Canada –from the first study conducted in 1978 to present. • On June 14, 2016, the CNSC [36] issued a “fact sheet on protecting the Great Lakes from radionuclides”. The fact sheet goes on to state “CNSC licensees are responsible for controlling and monitoring levels of radionuclides around their facilities, including within the Great Lakes.” The Chalk River Laboratories (CNL) submitted an Environmental Assessment for their Near Surface Disposal Facility Project (NSDF), which was assigned CEAR reference number 80122 on May, 05, 2016. Quoting from their project description, section 3.1.1 Project Context [37]: “Canadian Nuclear Laboratories has an immediate requirement for a new facility at its CRL property for the disposal of large quantities of LLW generated from past, present and future activities at CRL and at its other business locations.”

24. Great Lakes issues

The author recently attended the “Is the Coast Clear?” Conference on May 27, 2016 in Port Elgin [38]. The author heard three presentations in concurrent sessions on the Great Lakes Protection Act [39], Extreme Lake Levels Adaption and Plastics Pollution.

It has been questioned about a DGR being located adjacent to large bodies of water. A DGR is very similar in design and operation to a mine. There are several examples of DGR’s located near (or under) large bodies of water. One toured in 2002 by MOK (including the author) & OPG was Forsmark, Sweden, beside and under the Baltic Sea [5]. Several mines are located directly underneath large bodies of water. Locally, in Goderich, Ontario, we have a salt mine that goes under Lake Huron (that the author toured in approximately 2005).

3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

25. Effect of climate change & Ice Ages

These two factors will now be reviewed as they pertain to the Great Lakes basin:

Climate Change - it appears that a greater number of hurricanes & tornadoes are being experienced due to climate change. With respect to tornadoes and other natural disasters, it would be safer to have any DGR located below the surface of the earth, than risk the potential damage to above ground storage facilities. Ice Ages - our most recent ice age was about 10,000 years ago. Current estimates of the next ice age indicate that it will be in less than 20,000 years [26 pg 16]. This time frame of 20,000 years is at the early stage of the design life for a DGR. Prudence would suggest that a DGR located below the surface of the earth would be safer from the effects of a new ice age.

26. Recent OPG update

On June 15, 2016 OPG appeared as a delegation before MOK Council. Please refer to the OPG PowerPoint presentation [40] for the details of their update, especially: # 1: Study of Alternate Locations; #2: Cumulative Effects Update; and #3: Mitigations Update.

27. Summary & conclusion

We all will have to wait for OPGs’ formal reply to the Minister of Climate Change and Environment and then for the Minister’s decision. In the author’s opinion, the Joint Review Panel Environmental Assessment Report has been based on science and thus should meet the “bar” as set by the federal government’s recent election policy statement about environmental assessment decisions being “science-based”.

28. References

[1] Canada Enters the Nuclear Age – A Technical History of Atomic Energy of Canada Limited, McGill-Queen’s Press. ISBN 0-7735-1601-8, 1997. [2] Choosing a Way Forward – The Future Management of Canada’s Used Nuclear Fuel, NWMO Final Study. November, 2005. [3] Nuclear Fuel Waste Act S.C. 2002, c23: An Act Respecting the long-term management of nuclear fuel waste (Assented to 13th June 2003). [4] Resolution # 2002-202 – Authorize the Mayor and CAO to Enter into a Memorandum of Understanding with Ontario Power, April 15, 2002. [5] Joint Review Panel Presentation Powerpoint, MOK. August 23, 2013. [6] 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, Rev. 3 February 2004. [7] Bylaw No. 2004-157: Being A By-law To Authorize The Signing Of An Agreement With Ontario Power Generation Inc. For The Management Of Low And Intermediate Level Nuclear Waste Within The Municipality Of Kincardine, October 13, 2004. [8] Analysis and Recommendations regarding Intermediate Level Waste/ Low Level Waste Management Facilities. – A report prepared by the Ivey Client Field Project Team 54: March 10, 2004 for the Municipality of Kincardine. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

[9] Canadian Association of Nuclear Host Communities: see web site at www.canhc.ca [10] Energy Communities Alliance: see web site at www.energyca.org [11] Nuclear Safety and Control Act (enacted May 31, 2000). [12] CNSC Factsheet “Regulating Canada’s Geological Repositories” February 2011. [13] Canadian Environmental Assessment Act, 2012 S. C. 2012, s.52 (Current to March 16, 2016). [14] OPG’s Deep Geologic Repository Project for Low & Intermediate Waste (Environmental Impact Statement Summary), March, 2011. [15] Joint Review Panel - Environmental Assessment Report - Deep Geological Repository for Low and Intermediate Level Radioactive Waste Project, CEAA Reference No. 17520: May 06, 2015. [16] Waste Management Symposia (wmsym.org). [17] Letter to Township of Huron-Kinloss Nuclear Waste CAC & Council – Trip Report: Waste Management Symposia 2014 by Glenn R. Sutton, Apr. 01, 2014. (www.huronkinloss.com). [18] NWMO Website, Technical Methods: Paper No. 6.12: Long-Term Used Nuclear Fuel Waste Management of Used Nuclear Fuel, July, 2004. [19] NWMO Website, Technical Methods: Paper No. 6.13: Conceptual Designs for Used Nuclear Fuel Management – in Sedimentary Rock, July, 2004. [20] Final Report – Peer Review of a (1) Technical Support Document and (2) Follow up Monitoring Program submitted by Ontario Power Generation in support of the Construction of a Deep Geological Repository for Nuclear Waste – Submitted to the Municipality of Kincardine. Prepared By Hardy Stevenson and Associates Limited – October 24, 2012. [21] Resolution #11/07/2012-08 (DGR Peer Review) passed on November 07, 2012 [22] WM Symposia 2014 – Session # 26, Paper # 14357: A New Mindset in Terms of How the Nuclear Industry Engages the General Public, Laurel Boucher - The Laurel Co., http://www.the-laurel-company.com [23] WM Symposia 2014 – Session # 3: Finland/Sweden Featured Nations: National Programs & Local Views. Paper – Local Community Involvement - The Finnish Example – Mayor Vesa Jalonen- Eurajoki; and Local Community Involvement - The Swedish Example – Mayor Jacob Spangenberg (Mayor of Osthammer). [24] WM Symposia 2014 – Session # 26, Paper # 14602: Site Selection for Canada’s National Repository for Used Nuclear Fuel – Jo-ann Facella – NWMO. [25] WM Symposia 2014 – Session # 26, Paper # 14124: Mini Encyclopedia of Nuclear Energy – an Important Tool for Public Information – Igor Jenic – Jozef Stefan Institute Slovenia. [26] The Chemistry of Nuclear Fuel Waste Disposal, Donald R. Wiles – Polytechnic International Press. ISBN 2-553-01025-7. 2002. [27] Ethics & Energy Newsletter Volume 1 Number 1. August 1980. Editor D. Hardy & Managing Editor M. Stevenson. Second edition December, 1980 (No date for the first edition). [28] “Nuclear waste expert says that trust, transparency necessary for successful used fuel repository project”. Kincardine News, March 31, 2016. 3rd Canadian Conference on Nuclear Waste Management, Decommissioning and Environmental Restoration Ottawa Marriott Hotel, Ottawa, ON, Canada, September 11-14, 2016

[29] The Art And Science Of Transformation, Harold M. Schroeder – CreatSpace Independent Publishing Platform, North Charleston, SC Library of Congress Control No. 2016905143. 2016. [30] Letter to Ms. Laurie Swami (OPG) from the Federal Minister of Environment & Climate Change (requiring further information and/or studies). February 18, 2016. [31] Press Release: OPG Commits to Completing Further DGR Studies by Year-End, April 15, 2016. [32] E-mail: “CNSC publishes regulatory document on Aboriginal Engagement”, February 12, 2016. [33] www.goodlearninganywhere.com (Exploring Ontario First Nation Cultures course: Sioux Hudson Literacy Council), March 08 to 31, 2016. [34] E-mail: “CNSC hosts Multinational Workshop on the Regulation of Deep Geological Repositories “, March 14 to 16, 2016. [35] E-mail: “New CNSC timeline: The science behind safe nuclear waste disposal: decades of research”, April 14, 2016. [36] E-mail: “CNSC factsheet on protecting the Great Lakes from radionuclides”, June 14, 2016. [37] Project Description: Near Surface Disposal Facility At Chalk River Laboratories, 232- 50922-ENA-001 Rev 0. [38] www.lakehuron.on.ca – The Lake Huron Center for Coastal Conservation. Goderich, Ontario. [39] Great Lakes Protection Act, 2015 S.O. 2015, CHAPTER 24. [40] OPG’s Low and Intermediate Level Waste Deep Geological Repository (DGR) – Update to Municipal Councils June 2016 OPG's Low and Intermediate Level Waste Deep Geological Repository (DGR) - Update to Municipal Councils June 2016

Note: supporting documents are available at www.kincardine.net/DGR and www.opg.com WMDER 2016

OVERVIEW AND UPDATE ON “THE KINCARDINE INITIATIVE”: OPG’S DGR FOR THE STORAGE OF LOW AND INTERMEDIATE LEVEL NUCLEAR WASTE (2000-2016)

Presented by Glenn R. Sutton President Energy Initiatives Ontario

NOTES  Municipality of Kincardine (MOK): in 2000 , provincial government restructured Ontario municipalities. MOK now consists of the former Town of Kincardine, Kincardine Township & Bruce Township. It has a population of approximately 11,500.  Bruce NGSA & Bruce NGS-B (both operated by Bruce Power), OPG’s WWMF, the former BHWP plants (4) and the Bruce Energy Centre are all located in Bruce Township.  MOK owns Bruce Telecom. - Founded in 1910 - Fibre Optic link was in place by 1989 - Offers high speed internet - Provides services in 5 counties  MOK is the “Powerhouse of Ontario”.

Purpose of Presentation: How the MOK Council engaged the community to assure that there was community support for the LLL/ILW DGR Nuclear Waste Storage.

History of LLW/ILW/HLW in Canada

• Used Nuclear Fuel, NWMO Final Study: Chapter # 1 & #2. • HLW requirements may be found in Nuclear Fuel Act S.C.: An Act Respecting the long-term management of nuclear fuel waste (assented to 13th June 2003 • However; there was a problem: The new NFA was silent on what approach to use for LLW/ILW ! • Approach by MOK Council to OPG - wanted to take responsibility for this waste now and not leave the legacy issue to future generations (to meet intent of Bruntland Commission’s definition of ‘sustainable development) &. offered itself to be considered as a “willing host community” for LLW & ILW. • Detailed discussions & negotiations were carried out by the NWSC on behalf of Council. • Resolution # 2002-202 on April 15, 2002 was discussed & passed in the form of a “Memorandum of Understanding” to guide the process.

Due Diligence by MOK: European & USA Trips 2002/2003

Sites visited were:  France – Centre de l’Aube.  Switzerland – Zwilag in Wurenlingren.  - NAGRA project in Wettingen.  Sweden – SFR Facility in Forsmark.  South Carolina – Barnwell  Carlsbad, New Mexico – WIPP  Trip Project Goals (for both trips): - to review best practices in LLW & ILW waste management practices. - to discuss governmental approval processes & talk with local officials. - to ascertain public consultation methodologies

Zwilag Facility Switzerland Switzerland LLW Final Disposal Facility

 NAGRA (utility owned consortium for studying & selecting the long term facility for low & medium nuclear waste)  Proposed sites based upon the geological suitability (Wellenberg was selected site )  Waste to originate from operating ,medical and decommissioned plants.  Retrievability of waste is possible in principle , however not financially viable.  Safety & Geological reports sent to public.  10 % of electorate toured model facility.  Area plebiscite defeated proposal , 70 % voter turnout ( Green party funded opposition & conducted an anti nuclear campaign)  Core area approval high , but concerns from outlying area.

Centre de l’Aube France

 Second generation long term low & short term intermediate nuclear waste facility.  70 % of Hydro in France is nuclear generated .  58 nuclear reactors in France generate 70,000 mega watts of power.  Three barrier facility , containers in concrete containers in vault packed in concrete , with a water proof liner , with final cover of clay berm.  Facility designed for 300 years to match the radioactive decay life of LLW.  Approval to store 1,000,000m3 of LLW.  Super compactor on site to process LLW drums and some waste conditioning on site.  The site accepts 12,000 cubic meters per year, with a 50 year design life.  Again this facility is an above ground concept located in rural France.  All nuclear waste material is in a national data base and bar codes are used when material is received at the facility.

SKB Facility Sweden

 Underground LLW & ILW long term facility.  SKB is owned 51 % by the Swedish power authority & 49 % by other generators.  Sweden's Nuclear program has 11 Nuclear Power units with output similar to Canada.  Facility is mined 50 meters under the Baltic.  Material transportation is by sea and unloaded by special lift vehicle and driven into the mined facility  The facility capacity is 60,000 cubic meters ( 20,000 used to date – as of 2002) & the site receives 500 cubic meters per year .  Site development cost is 100 million dollars. ( note rural setting for the waste facility & reactors)  All nuclear waste in Sweden is in a regulated data base and is checked by bar code & radiation level at site when received.  All material is compacted & solidified at the generating stations prior to transport to SKB.

Chem-Nuclear Systems LL Radioactive Waste Management Facility Barnwell, SC

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Due Diligence by MOK: Common Findings

 European trip: 3 technologies were visited – enhanced storage & processing surface concrete vaults & shallow rock vaults (or DGR).

 USA trip: surface concrete vaults & deep rock vaults (or DGR).

 Both trip reports to Council ranked Deep Rock Vault (DGR) option was best suited for MOK.

 MOK has geology (at depth) supportive of and ideal for DGR construction.

Independent Assessment Report

 Quoting from the IAS Executive Summary : “The study examined the costs, impacts and benefits of constructing and operating each of three long-term management concepts at the WWMF, namely: Enhanced Processing and Storage, Surface Concrete Vaults, and Deep Rock Vaults. The study found that all three long-term management options are technically feasible and may be safely constructed and operated at the WWMF.”  After a thorough examination of these 3 options, the NWSC submitted their recommendation to Council for discussion & adoption of “Deep Rock Vaults” or ‘Deep Geological Repositories’ as the preferred option. This option offered the highest degree of safety margin.  In the actual resolution adopted by MOK Council (Resolution 2004-232), Council publicly accepted the ‘Deep Geological Repositories’ as the preferred option.

Negotiating Strategies

 NWSC developed negotiating strategies for Council endorsement & approval.  Regular negotiating meetings held between MOK & OPG.  Council updated & monitored progress & provided feedback.  Similar international jurisdictions contacted for their experiences.  MOK took part in the formation of the CANHC (see later).  MOK commissioned the Richard Ivey School of Business (UWO) to prepare a report to support these negotiations. A financial analysis was requested. Report stated that “It is important to note that the content of this report largely focuses on the business opportunity and value-creating mechanisms.” Issues also addressed were stigma, compensation, effect on future economic development, possible strategies & course of action.  Contact made with Town of Deep River officials on their previous experience with nuclear waste negotiations with Ontario Hydro.  Contact also made with Town of Port Hope & Municipality of Clarington (re Port Hope, Welcome & Port Granby sites, including operation of the LLWWMO). Engagement Techniques

 NWSC co-ordinated the following outreach activities & engagement techniques:  Communications – of all forms were carried out in an open & transparent manner by MOK & OPG.  Technical Factors – use of companies & consultants skilled in public dialog with a previous track record of technical acumen & outstanding communications skills.  Aboriginal Engagement – outreach made to local Saugeen Ojibway Nation by consultant including MOK & OPG. A protocol was established with each of the Chippewa of First Nation and the Saugeen First Nation to facilitate a productive exchange of information between First Nations, Kincardine and OPG.

Elements of Community Consultation

 The major effort was staffing of a Community Consultation Centre in downtown Kincardine, with a member of Council & an OPG representative on hand at all times.  CCC had many large-sized coloured panels illustrating various stages of the L/ILW project. A guest reception log book was kept.  Of most use were the diagrams with details of the actual proposed DGR (especially 3-D views underground).  Many open houses were held around the MOK and in adjacent impact municipalities.  OPG also had a mobile exhibit to display at local fall fairs, events etc.  Extensive use of newspaper articles (local, regional and international), ads & mail-outs etc. as well as radio & TV coverage.  Provision of speakers to local service clubs etc.  Interviews by all forms of media (newspaper, radio, TV etc.)  Use of MOK & OPG web sites to post all related documents.  Related documents from OPG, the CNSC & the JRP were available at the local branches of the Bruce County Library System.

Opening of Community Consultation Centre (opened on October 13, 2005) Strategic Counsel- Selected From 3 RFP’s

 Poll Methodology Consultation Question

 Another company performed an independent third party audit of the consultation process & results.  Poll results were positive (see paper for a link to all documents).

LLW & ILW Agreement

 Kincardine, Saugeen Shores, Huron-Kinloss, Arran-Elderslie and Brockton to receive 35 M$ (2004 $, inflation protected) paid over 30 years subject to achieving milestones:  EA Guidelines  EA Approval  Construction License  Operating License  The Municipalities will choose how to use the funds, for the benefit of their communities  Provision for all low and intermediate level waste produced during reactor operations until 2035 and for waste from decommissioning all 20 OPG reactors; approximately 200,000m3  Provision to negotiate for additional low and intermediate level waste i.e. repository expansion for new build reactors  No used nuclear fuel will be placed in the deep geological repository  Property value protection  By-Law 2004-157 passed by MOK Council contained all clauses above.

CANHC Canadian Association of Nuclear Host Communities

 Goals  The association’s mandate is to be supportive of the nuclear industry through ongoing dialogue, mutual cooperation and education.

 To strengthen community representation with the nuclear industry and politically through networking with other nuclear host communities.

Pickering’s 8 Reactors Chalk River Nuclear Laboratories

Becancour’s 1 Reactor

Kincardine’s 9 Reactors Darlington’s 4 Reactors

Note: a similar organization that the author discovered on a trip to Pahrump, Nevada at the Nye County Nuclear Waste Repository Project Office is:“The Energy Communities Alliance” (www.energyca.org). Also, the author visited the Pahrump Museum and viewed all of the Yucca Mountain Exhibits. Regulatory Interface & EA Process

 Refer to CNSC Factsheet “ Regulating Canada’s Geological Respositories” & CNSC document “The science behind safe nuclear waste disposal: decades of research”) for a summary of regulatory processes.

- March 2011: OPG issued their Environmental Impact Statement - Summary for the DGR Repository Project for LLW/ILW. - JRP established on January 24, 2012 - The JRP issued its final report on May 06, 2015 . The “Overall Conclusion” in the JRP’s Executive Summary was:

- “The Panel concludes that the project is not likely to cause significant adverse environmental effects, taking into account the implementation of the mitigation measures committed to by OPG together with the mitigation measures recommended by the Panel.”

- The hearings were held in both the Kincardine Legion & the Port Elgin Sportsplex. An additional set of hearings were held to obtain more information and to clarify questions and concerns. - The author attended many of the hearing days (& made several presentations). The press were also present and reported on the JRP.

- The JRP kept order & proper decorum at all times. All presenters, intervenors, Aboriginal & First Nations and members of the public were allowed to speak and present as per the proper process. All points of view were listened to and intervenors were also allowed to ask questions of other intervenors, CNSC staff etc.

JRP Status & Request From Minister of Climate Change & Env’t

 On February 18, 2016 , the Minister of Environment and Climate Change issued a letter to OPG to conduct three further studies before making a decision on the environmental assessment and reply back by no later than April 18, 2016:

- A study that details the environmental effects etc. of two alternate locations for the Project (sedimentary and granite rock). - An updated analysis of the cumulative environmental effects results from the Phase 1 Preliminary Assessments undertaken by the NWMO, which identified 3 potential host communities falling within the traditional territory of the Saugeen Ojibway Nation. - An updated list of mitigation commitments for each identified adverse effects.

OPG’s Reply

 On April 15, 2016, OPG issued a Press Release that stated: “Ontario Power Generation (OPG) has informed the federal government that it will complete further studies on its proposed deep geologic repository (DGR) by Dec. 31, 2016.”

 The three studies would address the Minister’s three requests.

 OPG also made a report to MOK Council to update them on their plans.

Future Prognosis for LLW/ILW/HLW Storage in DGRs

 The author has included HLW in this section of the report because all three forms of nuclear waste disposal are intimately linked together. Any development for one type of nuclear waste is a possible solution for the other two.

 It is important to understand the transition in Canada from previous recommendations to use granite from the Canadian Shield (for HLW) to more recent recommendations to use sedimentary rock as an alternative. The major research effort(s) that lead to that transition may be found in two NWMO position papers (Technical Methods: Papers # 6.12 – Long-Term Used Nuclear Fuel Waste Management of Used Nuclear Fuel & 6.13 – Conceptual Designs for Used Nuclear Fuel Management –in Sedimentary Rock). Both types of rack are acceptable.

Peer Review by Hardy Stevenson & Associates Ltd.

 To provide an additional level of review for this project the MOK Council had HSAL review, in April 2012, relevant documents.

 By November, 2012, after a thorough review of all relevant documents, HSAL found only 6 issues be addressed & were all issues were resolved. 2012

 HSAL presented their findings to the MOK Council. After the council discussed this report, it was accepted by Resolution #11/07/2012-08 (DGR Peer Review) passed on November 07, 2012.

 All documents on MOK website. Lessons Learned

 1) Communications - At the WM Symposia 2014, the author was impressed with all papers presented in Session # 26.

 2) Simplification of Nuclear Technology Terms - With respect to nuclear waste disposal, this subject has a separate set of specific terms that need restating from technical terms into “layman’s language”. It is the author’s opinion that we must improve our communications in this area as nuclear waste disposal/storage is a destiny issue.

 Concept of Repository Resaturation –the use of computer simulation for purposes of modelling radioactive isotope transport through rock needs better explanation. A book that the author has found most useful for this aspect of DGR radiochemistry is “The Chemistry of Nuclear Fuel Waste Disposal”.

Challenge For The Future: Ethics in Energy

 When the author met the first Chair of the NWMO at an Impact Advisory in about 2002, the concept of ethics in nuclear waste was first mentioned by the Chair. As a member of the CNS, the author started to receive issues of “Ethics and Energy” in 1980. This series of newsletters ended in 1986. This may be another challenge for our industry to resume in the near future to restart that initiative.

 The author met Tom Isaacs (former Lead Advisor to United States Blue Ribbon Committee on America’s Nuclear Future) recently during his talk with the Twp. of Huron-Kinloss CAC. Quoting from a local newspaper article when he met with the press, he said “But, as you know, the big issues are often non-technical, they are issues of public acceptance, political issues”. Also, he stated “You need to build a core and earn a core of trust with people”. Great Lake Issues

 It has been questioned about a DGR being located adjacent to large bodies of water. A DGR is very similar in design and operation to a mine. There are several examples of DGR’s located near (or under) large bodies of water. One toured in 2002 by MOK (including the author) & OPG was Forsmark, Sweden, beside and under the Baltic Sea Several mines are located directly underneath large bodies of water. Locally, in Goderich, Ontario, we have a salt mine that goes under Lake Huron (that the author toured in approximately 2005).

 The JRP had extensive comments about the Great Lakes (all summarized in the Executive Summary):

“The Panel concludes that the project is not likely to cause significant adverse effects on the water quality or aquatic ecosystems of Lake Huron or the other Great Lakes, provided that mitigation measures, including the Panel’s recommendations, are implemented.”

Great Lake Issues (2) Environment Canada informed the Panel that Canada had met its obligations under the Great Lakes Water Quality Agreement with respect to the project. Canada, through the Great Lakes Executive Committee Co-chair, notified the U.S. and the Great Lakes Executive Committee of the DGR public hearing and the process for participating in the hearing on June 21, 2013. The Panel notes that some people, particularly Aboriginal people, may have concerns about effects on Lake Huron that are based upon their worldview and accompanying spiritual requirements regarding showing respect for the earth. This would include asking permission of the earth to construct the DGR. The Panel expects that such concerns will be part of the ongoing dialogue between OPG and Aboriginal peoples under the terms of various agreements. The Panel fully agrees that Lake Huron and the other Great Lakes are precious resources that demand society’s highest level of protection and regard. To that end, the Panel applauds the efforts of Canadian and American federal, state, provincial, and municipal agencies as well as First Nation, tribal, Métis, and private groups, as they address the primary risks to the lakes. The Panel notes that the future sustainability of the Great Lakes depends upon society’s collective ability to reduce the significant stressors on the lake, notably invasive species, habitat disruption or destruction, non-point source pollution, and climate change. The Panel is of the view that the relative position of the proposed project within the spectrum of risks to the Great Lakes is a minor one, albeit one that demands strict attention and regulation. Effect of Climate Change & Ice Ages  Climate Change - with respect to tornadoes and other natural disasters, it would be safer to have any DGR located below the surface of the earth, than risk the potential damage to above ground storage facilities.  Ice Ages - our most recent ice age was about 10,000 years ago. Current estimates of the next ice age indicate that it will be in less than 20,000 years. This time frame of 20,000 years is at the early stage of the design life for a DGR. Prudence would suggest that a DGR located below the surface of the earth would be safer from the effects of a new ice age.

Summary & Conclusion  We will have to wait for OPGs’ formal reply to the Minister of Climate Change and Environment and then for the Minister’s decision. In the author’s opinion, the JRP EA Report has been based on science and thus should meet the “bar” as set by the federal government’s recent policy statements about environmental assessment decisions being “science & evidence based”.  “Science & evidence based” Environmental Hearings will be the “wave of the future” for regulatory hearings.

 THE END – QUESTIONS ?