Lake Ontario Waterkeeper C/O Mr. Mark Mattson, President

Darlington New Nuclear Power Plant Project Joint Review Panel ______

Projet de nouvelle centrale nucléaire de Darlington Commission d’examen conjoint

PMD 11-P1.164

File / dossier : 8.01.07 Date: 2011-02-21 Edocs:36814445

Written submission from Mémoire de Lake Ontario Waterkeeper Lake Ontario Waterkeeper

In the Matter of À l’égard de

Ontario Power Generation Inc. Ontario Power Generation Inc.

Environmental Assessment pursuant to the L’évaluation environnementale, en vertu de la Canadian Environmental Assessment Act of Loi canadienne sur l’évaluation a proposal by Ontario Power Generation for a environnementale, du projet d’Ontario Power Project that includes site preparation, Generation qui inclut la préparation de construction, operation, decommissioning l’emplacement, la construction, l’exploitation, and abandonment of up to four new nuclear le déclassement et l’abandon de jusqu’à quatre power reactors at its existing Darlington nouveaux réacteurs nucléaires sur le site de la Nuclear Site located near Oshawa, Ontario, centrale nucléaire Darlington près d’Oshawa in the Municipality of Clarington and a (Ontario), dans la municipalité de Clarington, et Licence to Prepare a Site application for the une demande de permis de préparation de Project under the Nuclear Safety and Control l’emplacement, aux termes de la Loi sur la Act. sûreté et la réglementation nucléaires.

Public Hearing Audience publique

March 21, 2011 Le 21 mars 2011

Joint Review Panel Hearing

Darlington New Nuclear Power Plant: Environmental Assessment and Licence to Prepare a Site

Written Submissions of Lake Ontario Waterkeeper

!!!!!

!!!!!!!Lake Ontario Waterkeeper !!!!!!!410 - 600 Bay Street !!!!!!!Toronto, ON M5G 1M6 !!!!!!! !!!!!!!Mark Mattson !!!!!!!Counsel for Lake Ontario Waterkeeper !!!!!!!Tel: 416-861-1237 !!!!!!!Fax: 416-850-4313 CONTENTS

OVERVIEW 1

FACTS 2

Lake Ontario Waterkeeper is a charity participating in this process in the public interest. 2

Darlington New Nuclear Power Plant would be a major development on the shore of a precious, threatened lake. 3

The Proposed New Nuclear Power Plant at Darlington is a major undertaking. 3

In anticipation of this important process, Waterkeeper has been preparing for years. 4

Lake Ontario is an irreplaceable and threatened source of life, beauty, and recreation. 6

The Local and Regional Study Areas are saturated with pollution sources. 7

ISSUES 10

The Environmental Assessment Report 10

The Nuclear Safety and Control Act licencing decision 11

DISCUSSION 12

A. What should the Joint Review Panel recommend to the Minister and the Responsible Authorities with respect to the environmental impacts of the project? 13

A.1 Will the project cause significant adverse environmental effects? 13

Harmful impacts on fish and fish habitat resulting from the project constitute adverse environmental effects. 15

Most of a new plant’s environmental impacts will affect the most productive and valuable habitat type in the lake: nearshore habitat. 15

Once-through cooling is the most destructive option with respect to Lake Ontario. 16

Impacts from once-through cooling will be amplified at the new plant due to dramatically higher flow rates. 17

Impingement will kill from 23 to 46 thousand fish each year. 18

Entrainment rates will be more than 66% higher than at Darlington NGS. 20 Heated water discharge can affect fish health, fish habitat, plankton, and benthic organisms. 22

Fish habitat will be destroyed by the construction of cooling water intake and discharge structures. 25

Boating is restricted in the area around once-through cooling structures. 25

There are alternatives to once-through cooling. 26

Lake Filling will result in the permanent loss of nearshore fish habitat. 28

There are alternatives to filling in the lake. 29

Pollution from the project may cause adverse environmental effects. 31

Preparation, construction and operation of the project may pollute the air and water. 31

The project will contribute significantly to existing pollution sources in the area, increasing the load of cumulative effects. 35

Incompatible land use on the adjacent St. Marys Cement property may cause adverse environmental effects. 37

Uncontained waste may cause adverse environmental effects. 38

The EIS is incomplete and does not represent adequate provision for the environment. 39

The bounding scenario does not provide a basis to conclude that OPG will make adequate provision for the protection of the environment. 41

Potential emissions to air and water have not been identified and addressed. 42

Air dispersion modeling is incomplete and does not reflect potential impacts. 46

Sampling parameters must be established based on provincial and federal law. 48

Effective water quality monitoring plans are missing from the EIS. 50

Effective stormwater quality monitoring is essential, and missing from the EIS. 53

A.2 Are measures available to mitigate or avoid the significant adverse environmental effects of this project? 55

Closed cycle cooling, used in conjunction with the best available fish protection technology, could avoid many of the adverse effects associated with once-through cooling. 56 The existing CN rail line could be relocated to prevent lake filling. 57

The proposed site layout could be reconfigured to prevent lake filling. 57

Fish habitat compensation is not mitigation and should be a last resort. 58

A.3 Can the significant, unmitigated environmental effects resulting from the project be justified in the circumstances? 60

The adverse environmental effects of the project cannot be justified based on failings at other sites. 61

B. Should this project be granted a Nuclear Safety and Control Act licence to prepare the site? 62

B.1 Will OPG, in carrying out the activity, make adequate provision for the protection of the environment? 63

B.2 Are any terms or conditions on the license necessary for the purposes of the NSCA? 64

CONCLUSION 65

APPENDIX A: Expert Reports

______OVERVIEW !

Lake Ontario Waterkeeper makes this submission to share our vision of a swimmable, drinkable, ﬁshable lake with the Joint Review Panel. We offer our knowledge and expertise to help ensure that this Panel’s decision reﬂects and contributes to a healthy, celebrated, and shared Lake Ontario.

The proposed Darlington New Nuclear Power Plant is a major project that will sit on the north shore of Lake Ontario for at least the next 130 years. Lake Ontario’s ecosystem is inundated with historic and ongoing pollution stressors. A source of drinking water, aquatic habitat, and recreation, the importance of the lake necessitates precautionary decision-making.

The Joint Review Panel has two interconnected decisions to make at the end of this hearing, each with serious implications for the health of Lake Ontario. Both decisions hinge on the adverse environmental impacts associated with the project and whether they can, and have, been addressed.

Ontario Power Generation bears the onus of proving that the new nuclear power plant will not adversely impact the environment in any way that cannot be mitigated or justiﬁed. OPG must prove that it has made, and will continue to make, adequate provision for the protection of the environment. OPG has not discharged this burden.

OPG expresses a preference for once-through cooling, the most destructive cooling technology option available from an ecological perspective. OPG commits to ﬁlling in up to 40 hectares of Lake Ontario with excavated soil and rock. OPG fails to provide details on the contaminants that will be emitted from the plant, the regulatory standards that will be applied, or the monitoring plans that will be developed. OPG does not adequately consider the available mitigation measures or alternative means of carrying out the project. OPG does not justify the need for this project.

This project will result in signiﬁcant adverse environmental effects that will not be mitigated and cannot be justiﬁed. The seriousness of the potential impacts, combined with the lack of detailed plans to address those impacts, shows that OPG is not prepared to make adequate provision for the protection of the environment. The project cannot be approved or licenced as planned without causing irreparable harm to Lake Ontario.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 1 ______FACTS

Lake Ontario Waterkeeper is a registered Canadian charity that works to protect and celebrate the Lake Ontario watershed. Waterkeeper is participating in this hearing process in the public interest, to share our expertise and our vision of a swimmable, drinkable, ﬁshable lake with the Joint Review Panel.

Ontario Power Generation’s application to construct and operate a new nuclear facility on Lake Ontario is a major undertaking. Due to the magnitude and longevity of the project’s potential environmental impacts, this review process has continued to be a major priority for Waterkeeper since comments were ﬁrst solicited in 2008.

Lake Ontario is an irreplaceable resource. It is the source of drinking water for millions of people, the site of recreation, transportation, and a diverse aquatic habitat. The lake is inundated with pollution sources, both historic and ongoing. Through decision-making that relies on science and precaution, Waterkeeper believes that Lake Ontario can recover from these threats and become swimmable, drinkable, and ﬁshable again.

Lake Ontario Waterkeeper is a charity participating in this process in the public interest.

Lake Ontario Waterkeeper [Waterkeeper] is a grassroots environmental organization that uses research, education, and legal tools to protect and restore the public’s right to swim, drink, and ﬁsh in Lake Ontario. Founded in 2001, Waterkeeper is a non-political registered charity focusing on research and justice issues in the public interest.

Waterkeeper is a licenced member of the New York based Waterkeeper Alliance, a coalition of close to 200 groups worldwide working for clean and accessible water. Led by Robert F. Kennedy Jr., Waterkeeper Alliance is a global movement of on-the-water advocates who patrol and protect over 160,000 kilometres of rivers, streams, and coastlines in North and South America, Europe, Australia, Asia, and Africa.

Waterkeeper is responsible for protecting and celebrating the Lake Ontario watershed, including the wetlands, streams, rivers, and creeks that flow into the lake. Waterkeeper conducts academic, legal, and field research, and shares the findings with the public. Waterkeeper works with communities to facilitate the use of environmental laws to protect their rights to swim, drink, and fish.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 2 Waterkeeper participates in legal processes to help ensure that environmental decisions are made on the basis of sound and tested scientific evidence by independent decision- makers and in the public interest. We are participating in the review of the Darlington New Nuclear Power Plant in order to share our vision of a swimmable, drinkable, fishable lake with the Panel. We hope to contribute our knowledge and expertise to help ensure that this Panel’s decision reflects and contributes to that vision of a healthy, celebrated, and shared Lake Ontario.

Darlington New Nuclear Power Plant would be a major development on the shore of a precious, threatened lake.

The Proposed New Nuclear Power Plant at Darlington is a major undertaking.

Ontario Power Generation [OPG] has applied for approval to build a new nuclear power plant on the shore of Lake Ontario in the municipality of Clarington. Located immediately adjacent to the existing Darlington Nuclear Generating Station [DNGS], the The project will take a considerable new build would be known as amount of time, money, space, and “Darlington B”. It is referred to in this resources to complete. submission as the Darlington New • The proposal to build, run, and decommission Nuclear Power Plant [NNPP] or New up to four reactors will require between Nuclear Darlington [NND]. 750,000 and 1,000,000 cubic metres of concrete.

In addition to provincial and international • Up to 12,400,000 cubic metres of soil and rock obligations, the project requires a variety will be excavated. Some of that material will be of approvals and licences from the landfilled on site, while some is trucked to federal government, including: offsite disposal sites. • Authorisation from the • Some of the aggregate will be used to fill in up to 40 hectares of Lake Ontario. Forty hectares Department of Fisheries and is equivalent to the footprint of almost eight Oceans to harmfully alter, Rogers Centre (SkyDome) stadiums. disrupt, or destroy fish habitat, • Constructing the coffer dam required to ss.35(2), Fisheries Act; facilitate the lake fill will require up to 200 trucks • Authorisation the Department of full of aggregate each day. Fisheries and Oceans to • OPG anticipates 85 years of operations, destroy fish by means other including one refurbishment, so that the facility than fishing, s.32, Fisheries Act; would operate to the year 2100. Thirty years of decommissioning and abandonment will take • Authorisation from Transport nuclear operations at this site to 2130.1 Canada to construct the project

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 3 in navigable waters pursuant to s.5(1)(a) of the Navigable Waters Protection Act [the NWPA]; • Authorisation from the Canadian Transportation Agency to move the existing CN rail line, create a new rail spur, or create crossings of the existing rail line; • Licences from the Canadian Nuclear Safety Commission pursuant to s.24(2), Nuclear Safety and Control Act: • Licence to prepare site; • Licence to construct; • Licence to operate; • Licence to decommission; and • Licence to abandon.

These include some approvals listed on the Law List Regulations 1 under the Canadian Environmental Assessment Act [the CEAA]2. The construction of a new nuclear plant is also listed on the Comprehensive Study List Regulations, so that a Comprehensive Study EA was triggered. Due to the potential for this project to cause signiﬁcant, post-mitigation adverse environmental effects and the signiﬁcant public concern over this project, the Minister of the Environment referred the environmental assessment to a review panel for a more stringent evaluation.3

In anticipation of this important process, Waterkeeper has been preparing for years.

In September 2008, the draft Environmental Impact Statement (EIS) Guidelines and the draft Joint Review Panel (JRP) Agreement were released for public review. In response, Waterkeeper and Gord Downie initiated public consultation, contacting volunteer organizations and business with operations in the nearby Lake Ontario watershed (e.g., marinas, ﬁshing operations). We received signiﬁcant insight from the community regarding concerns about environmental impacts and the process. Those comments helped inform our submissions on the JRP and EIS Guidelines, which we submitted to the panel on November 19, 2008.

Following the release of the ﬁnal EIS Guidelines and JRP Agreement, Waterkeeper sought and was granted funding from the CEA Agency to continue our participation throughout phase two of the review process, including our review of the EIS and participation in the

1 Law List Regulations, S.O.R./94-636.

2 Canadian Environmental Assessment Act, R.S.C. 1992, c. 37.

3 Ibid., s.28.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 4 hearing. That funding allowed Waterkeeper to hire a team of expert consultants to assist with our review of the EIS.

The expertise of our consultants is reﬂected in the observations and recommendations described below.4 Our consulted experts include:

Wilf Ruland Hydrogeologist Reviewed potential for surface and groundwater pollution; waste management; erosion and dust control plans; and the potential for subsidence or induced seismicity.

Dr. Peter Henderson, Fish biologist and Reviewed proposed cooling water Pisces Conservation cooling water system alternatives and identiﬁed impacts of concern expert speciﬁc to Lake Ontario.

David Dillenbeck Aquatic biologist Reviewed potential surface water impacts, water monitoring programs, and stormwater management programs.

Doug Howell Fish habitat expert Reviewed the impacts on ﬁsh habitat, the applicability of the Fisheries Act, and habitat compensation.

Peter Faye Energy systems Advised Waterkeeper on the application of consultant CEAA, particularly requirement to prove need and identify alternatives to the project.

Dr. Henry Cole Air modeling specialist Reviewed air modeling applied to the site, shoreline fumigation, and potential air pollution impacts on Lake Ontario.

The comment period for the EIS lasted from November 16, 2009 to October 8, 2010. On December 14, 2010, the Panel announced a public hearing commencement date of March 21, 2011. On January 12, 2011, Waterkeeper successfully registered to submit written representations and participate in person in the hearing. Government agency reports to the Panel were submitted January 31, 2011.

Waterkeeper prepared these comments to summarize our main concerns and the attached experts reports for the Panel’s consideration. The reviews undertaken by our consultants led to important ﬁndings that we hope will be of use to this Panel. Waterkeeper will make oral submissions to the Panel and will be happy to respond to any

4 Curriculum Vitae for each of our consultants are included in Appendix A.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 5 inquiries during the upcoming hearing process. Given the limited time allotted for our oral presentation, we rely on these written submissions to cover evidence and argument that we may not have the opportunity to fully discuss during the hearing process.

Lake Ontario is an irreplaceable and threatened source of life, beauty, and recreation.

The Panel must consider the fragile state of Lake Lake Ontario, the 14th largest lake Ontario’s ecosystem in order to make decisions in the world, is the smallest of the that are precautionary and as protective of the Great Lakes in surface area. The ecosystem as possible. A site-specific review lake straddles the border between Canada and the United States, with based on the precautionary principle and over 1000 kilometres of shoreline in accounting for cumulative effects is in keeping with the two countries. Lake Ontario’s this Panel’s mandate. drainage basin covers more than 64,000 km2 in New York State, Pennsylvania, and Ontario. Linked to The degraded state of the environment in Lake the other Great Lakes through the Ontario makes it more important to protect and Niagara River, Lake Ontario drains restore the lake. Greater caution is required when through the St. Lawrence River to the assessing potential additional sources of pollution Atlantic Ocean.5 in stressed ecosystems. The health of Lake Ontario is essential to the ongoing health and prosperity of Ontario and the entire Great Lakes region. The lake provides drinking water for millions of Canadians and Americans. It serves as fish and wildlife habitat. It supports transportation and recreation. The lake is threatened by a number of stressors, most linked to a failure to respect and nurture it as a finite and essential resource.

Lake Ontario constitutes an ecosystem of international importance that provides signiﬁcant ecological services to millions of people. Historic and ongoing abuse and pollution of this ecosystem have drastically altered nutrient dynamics, hydrological rhythms, coastal habitats, water quality, and biological diversity. Many of these changes have occurred rapidly, and the lake continues to respond to these changes in unpredictable ways.

In his report on the Darlington NNPP EIS, Dr. Peter Henderson states, “The Great Lakes are in the midst of a huge ecological upheaval”.5 He points to the increasing populations of invasive species, including zebra mussels, quagga mussels, sea lamprey, and alewife. He notes the contemporaneous decline in native populations of ﬁsh, like the slimy sculpin,

5 P. A. Henderson, “Comments on aquatic issues relating to the proposed New Nuclear Darlington (NND) power plants”, Prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant EA Process, (4 October 2010) [hereinafter “Henderson, 2010”] at 2 .

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 6 and of amphipod crustaceans, like Diporeia. Diporeia once generated more than 80% of total benthic production of Lake Ontario and was a critical component of the diets of most benthic ﬁshes. As the lake’s water clarity changes, there is increased plant growth, including beds of cladophora or green algae along the shore by the Darlington site.

These changes impact the Valued Ecosystem Components (VECs) in the aquatic environment identified in the EIS, including the Lake Ontario nearshore, forage fish species, benthivorous fish, predatory fish, and benthic invertebrates. Dr. Henderson observed that the populations of many of these VECs are far from healthy. The state of these populations and their habitat makes the addition of further mortality from power plant operations more potentially deleterious than it would be for healthy populations.

The Local and Regional Study Areas are saturated with pollution sources.

Both the Regional Study Area [RSA] and the Local Study Area [LSA] for this project are host The Local Study Area and Regional to a number of significant historic and ongoing Study Area are defined in the EIS as pollution sources. areas that could reasonably be affected by the project. The LSA includes the Darlington property, lands in The RSA encapsulates the Pickering Nuclear the Municipality of Clarington closest to it, Generating Station and the Town of Port Hope, and the area of Lake Ontario adjacent to including Cameco’s uranium refinement facility. the facility. It is the area where the The Local Study Area is host to the existing environment is most likely to be negatively affected by the project. The Darlington Nuclear Generating Station and a RSA extends approximately 40 km east St. Marys Cement plant. The recently and west of the site, from the York approved Durham energy-from-waste Region border to the Town of Cobourg.6 incinerator will be built just west of OPG’s property.

OPG’s eastern neighbour is St. Marys Cement, a large industrial limestone quarry and cement processing plant. The maximum point of impingement [POI] for the St. Marys plant during easterly winds is the agricultural area to the west of the Darlington site, where the Durham incinerator will be built.6

The St. Marys Bowmanville plant is regularly rated in the top ten air polluters in Ontario. In 2009, its emissions included 3228 tonnes of SO2, 764 tonnes of CO, 3372 tonnes of NOx,

6 St. Marys, “Alternative Fuel Demonstration Project: Bowmanville Plant, Frequently Asked Questions and Comments”, online: at 5.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 7 177 tonnes of particulate matter, 49 tonnes of volatile organic compounds (VOCs), 15 kg of mercury, 14 kg of arsenic, and 125 kg of lead.7

In the US, where cement kilns are the third largest source of mercury pollution, new rules have been introduced to control emissions from cement plants with technology that is used in coal plants.8 No such rules exist in Canada, and cement kilns remain one of the dirtiest sources of air and water pollution.

The pollution sources concentrated around the Darlington NNPP site have more environmental impact because they sit on the edge of a Great Lake. The location of the proposed project is one of the main determinants of the ecological risk it poses. By locating the plant on the shore of Lake Ontario, site speciﬁc, lake-based impacts arise. Not only do these sources impact the lake directly through proximity, but phenomena known as shoreline fumigation and plume trapping keep pollutants in the area and amplify their effects.

Dr. Henry S. Cole explains “shoreline fumigation”, wherein a temperature inversion in the air over a cold lake causes pollutants emitted near the shoreline to be cycled low over the land a few kilometres from the water. The cycling results in pollutants remaining in the breathing zone for many hours each day instead of dissipating. The process means that the area around a pollution source like a nuclear reactor is essentially fumigated with the emitted contaminants.

Figure 1: Shoreline fumigation schematic.9

7 Environment Canada, “National Pollutant Release Inventory (NPRI)”, online: .

8 US Environmental Protection Agency, News Releases, “EPA Sets First National Limits to Reduce Mercury and Other Toxic Emissions from Cement Plants” (9 August 2010), online: .

9 Dr. H.S. Cole, “Review of Technical Support Documents pertaining to the potential impact of the Darlington Nuclear Facility air emissions on ambient air quality”, Prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant EA Process, (February 2011) [hereinafter “Cole, 2011”] at 5.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 8 Dr. Cole explains that “plume trapping” is a second phenomena that ampliﬁes the effects of pollution emissions near water. Plume trapping occurs in overcast conditions, when heat from the sun is restricted, and there is a stable onshore ﬂow due to the presence of a large body of water like Lake Ontario. The turbulent boundary layer remains shallow, trapping low level plumes near the ground. At the Darlington site, OPG anticipates low vents or stacks on or near the building, which can combine with building downwash to bring pollutants to ground level.10 Dr. Cole explains that this phenomenon would restrict dispersion and could result in high level concentrations of pollutants in the breathing zone. Trapped plumes are slow to diminish downwind of the source.

Figure 2: Plume Trapping schematic. In these conditions, only low elevation emissions are trapped.11

10 Ontario Power Generation, “Technical Support Document 1: Atmospheric Environment Existing Environmental Conditions” at p. 2-8.

11 Cole, 2011 at 8.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 9 ______ISSUES

The Joint Review Panel has two interconnected decisions to make, each within a different statutory context and with a different outcome. The ﬁrst is a report to the Responsible Authorities and the Minister of the Environment with respect to the test set out in the Canadian Environmental Assessment Act. The second is a licencing decision under the Nuclear Safety and Control Act. The tests for each decision hinge on the adverse environmental impacts associated with the project and whether they can, and have, been addressed.

The tests, as set out below, have provided the context and structure for Waterkeeper’s written submissions.

The Environmental Assessment Report

What should the Joint Review Panel recommend to the Minister and the Responsible Authorities with respect to the environmental impacts of the project?

A. Will the project cause significant adverse environmental effects? 1. If yes, can those effects be mitigated through mitigation measures and/or alternative means of carrying out the project? a. Are there alternative means of carrying out the project? If so, what are the environmental effects of those alternative means? 2. If no, can these significant adverse environmental effects be justified in the circumstances? a. Is there a need for the project? b. Are there alternatives to the project?

Under s.16 of the CEAA, every assessment by a review panel must include a consideration of: • The environmental effects of the project, including the effects of malfunctions or accidents, and any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have or will be carried out; • The signiﬁcance of those environmental effects; • Public comments; • Feasible measures to mitigate any adverse environmental effects; • The purpose of the project;

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 10 • Alternative means of carrying out the project and the environmental effects of those alternatives; • The need for and requirements of any follow-up programs; • The capacity of renewable resources that are likely to be signiﬁcantly affected by the project; and • Any other matter that the responsible authority or the Minister requires considered, such as the need for the project.

OPG bears the onus of proving the project will not adversely impact the environment in ways that cannot be mitigated or justiﬁed. The CEAA puts the onus onto the proponent to bring forward evidence to show that the project will not have any unacceptable adverse environmental impacts. That the project will have adverse environmental impacts is clear and accepted by the proponent. OPG must bring evidence before the Panel that establishes how mitigation of these adverse effects will occur. The evidence should allow the Panel to evaluate whether mitigation will be effective, and if not, what remaining adverse effects may occur.

OPG bears the onus of justifying any remaining adverse effects. OPG bears the onus of proving that there is a need for this project and no alternative means of achieving the same ends. If OPG does not provide sufﬁcient evidence to allow the Panel to conclude that the project will cause no unjustiﬁed, unmitigated adverse environmental effects, they have not met the burden of proof and the project should not be approved.

The Nuclear Safety and Control Act licencing decision

Should OPG be granted a licence to prepare the site under subsection 24(2) of the Nuclear Safety and Control Act? A. Will OPG, in carrying out that activity, make adequate protection for the environment? B. Are any terms or conditions on the licence necessary for the purposes of the NSCA?

OPG bears the onus of proving it will adequately protect the environment. As with the environmental assessment report, if the Panel has insufﬁcient information to make this determination, it cannot issue a licence. In order to issue a licence, the Panel must be certain that OPG will adequately protect the environment throughout each stage of the project. If the Panel has insufﬁcient information on which to base this conclusion, it cannot issue a licence. If the Panel decides to issue a licence, it has the authority and responsibility to impose terms and conditions to ensure accepted environmental protection measures are enforceable.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 11 ______DISCUSSION

Waterkeeper submits that this project would result in signiﬁcant adverse environmental effects that will not be mitigated and cannot be justiﬁed. The seriousness of the potential impacts, combined with the lack of detailed plans to address those impacts, indicates that OPG is not prepared to make adequate provision for the protection of the environment.

The proposed Darlington NNPP will cause significant adverse environmental impacts, including the destruction and disruption of fish habitat and fish kills through impingement and entrainment. The project may cause significant adverse effects by creating thermal pollution and pathways for contaminants to enter Lake Ontario, in a Local Study Area already saturated with pollution sources.

OPG has expressed a preference for once-through cooling, the most destructive cooling technology option available from an ecological perspective. OPG has committed to ﬁlling in up to 40 hectares of Lake Ontario with excavated soil and rock. OPG has consistently failed to identify the regulatory requirements that will be used to determine whether emissions from the Darlington NNPP could impact the environment. Effective water quality monitoring plans and stormwater management plans are missing from the EIS.

The EIS does not provide an adequate assessment of potential impacts of the project. Too much information is missing to allow this Panel to conclude that OPG will make adequate provision for protecting the environment. It is impossible to conduct an environmental assessment that considers the project in a “careful and precautionary manner” without knowing what the project will entail or what speciﬁc effects it will have on the environment.

Mitigation measures and alternative means of carrying out the project are available, but have not been adequately considered in the EIS. These include closed cycle cooling to avoid many effects of once-through cooling; moving the CN rail line to avoid lake fill; alternative reactor and cooling tower configuration to avoid lake fill; and recognizing habitat compensation as a last resort.

The onus of establishing that there is a need for this project and that there are no acceptable alternatives to this project rests on the proponent. Waterkeeper submits that OPG has not met this onus and has therefore failed to provide justiﬁcation for the project.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 12 A. What should the Joint Review Panel recommend to the Minister and the Responsible Authorities with respect to the environmental impacts of the project?

This Panel’s recommendations in the Environmental Assessment Report depend on the answers to the questions set out in the CEAA:

Will the project cause signiﬁcant NO: No further adverse environmental effects? examination required.

YES: Can those effects be mitigated through mitigation measures and/or alternative means YES: No further of carrying out the project? examination required.

Consider: Is there a need for the project? NO: Can the signiﬁcant, unmitigated adverse environmental effects be justiﬁed? Are there alternative means of carrying out the project? Are there alternatives to the project?

A.1 Will the project cause signiﬁcant adverse environmental effects?

The proposed Darlington new build will cause adverse environmental effects, including: • Permanent destruction of fish habitat through lake filling; • Destruction of nearshore habitat, including critical habitat for the emerald shiner, alewife, round whitefish, and lake trout; • Mortality of significant numbers of fish through impingement and entrainment; • Negative impacts on fish and fish habitat due to the discharge of heat into the lake; • Emission of biocides and other contaminants to the lake; • Disruption or destruction of fish habitat due to the construction and presence of water intake and discharge structures;

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 13 • Creation of new zones of restricted navigation; • Potential pollution through the deposition of contaminant lake ﬁll; • Addition to cumulative impacts in the Local Study Area; • Discharge of contaminants to air and water from a variety of sources during all stages of the project; • Potential pollution from unmanaged contaminated soils, construction wastes, and low, medium, and high level radioactive waste; and • Potential pollution due to insufﬁcient stormwater management systems.

These effects can be quantifiably identified as significant for three main reasons: First, Lake Ontario is an important source of drinking water, recreation, cultural heritage, and aquatic habitat. Second, Lake Ontario is a threatened resource, such that any additional environmental impacts add to the cumulative pollution loading and must be treated with greater precaution than in pristine environments. Under the CEAA, cumulative effects are one of the additional, site specific considerations in an environmental assessment. Third, the effects trigger a requirement for environmental authorizations. Without special authorisation, the project would not be able to meet the government’s standards set for the protection of the environment. Established environmental laws and standards set the minimum level of acceptable impact. If they are met, site specific considerations must be assessed to determine the acceptability of a project.

As described above, the Local Study Area for this proposal is densely saturated with existing sources of pollution. These emissions have a greater impact on the environment due to their location on Lake Ontario, which causes shoreline fumigation.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 14 Harmful impacts on ﬁsh and ﬁsh habitat resulting from the project constitute adverse environmental effects.

Without special authorisation or Canada’s Fisheries Act establishes standards for regulation, the proposed project the protection of aquatic life. Pursuant to section would result in violation of the 36(3), no one is permitted to deposit a deleterious substance in water frequented by fish without Fisheries Act. Through site authorising regulations made by the Governor in preparation, construction, and normal Council. Section 35(1) prohibits the harmful alteration, operation of the facility, fish habitat will disruption or destruction of fish habitat without be destroyed, altered, and disrupted. regulations made under the Fisheries Act or under conditions authorised by the Minister. Section 32 Fish will be harmed or killed through prohibits the destruction of fish without regulations or the deposition of deleterious Ministerial authorisation. 9 substances. Fish will be killed directly by the cooling water system.

Construction activities required to undertake the project are likely to harmfully alter or disrupt fish habitat as bare soils erode and enter the environment as dust. Disposing of rock and soil in the lake destroys fish habitat directly. The construction of intake and discharge structures, and berms to facilitate construction, further disrupt or destroy fish habitat.

During operations, fish will be killed through entrainment and impingement by cooling water intake. The elevated temperature of discharged cooling water is likely to harmfully alter or disrupt fish habitat. Direct water pollution and air pollution that is deposited into the lake could harmfully alter fish habitat and be deleterious to fish. All of these impacts will occur in the most important habitat type in the lake.

Most of a new plant"s environmental impacts will affect the most productive and valuable habitat type in the lake: nearshore habitat.

Most of the impacts on Lake Ontario associated with this proposal are concentrated in the nearshore environment. This is also the area of the lake that supports most aquatic life. According to Environment Canada and the US EPA:

The nearshore areas of the Great Lakes are diverse physical habitats, exhibiting a range of morphometric features, current velocities, substrates, and aquatic vegetation. These features, combined with seasonal ﬂuctuations in temperature, provide

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 15 conditions optimum to most species of ﬁsh in the Great Lakes for at least a portion of their life cycle.12

The properties of nearshore habitat that many species of fish require in order to carry out some or all of their life processes, such as spawning and/or nursery activity, qualify the nearshore as ‘critical habitat’.13 According to fish habitat expert Doug Howell, any loss of critical habitat is normally considered significant. It cannot be described as negligible, contrary to the conclusions drawn in the EIS and Technical Support Documents.14

Mr. Howell adds, “[n]earshore habitats are generally the most productive areas within aquatic ecosystems. Because of sunlight penetration to the substrate and nutrient inputs from adjacent land areas, primary productivity is usually highest and many ﬁsh species ﬁnd suitable spawning and rearing habitat in these shallower, warmer areas”.

The nearshore area that would be impacted by the project is considered critical habitat for the emerald shiner, alewife, round whitefish, and lake trout. Of these four species, round whitefish is of the greatest concern. The Ontario Ministry of Natural Resources has identified round whitefish as the species most likely to experience significant negative impacts to its distribution and abundance from the project.15 Mr. Howell explains, “This section of the north shore of Lake Ontario is known to provide spawning and nursery habitat for this species and the loss of any portion of this critical habitat must be considered significant”.

Once-through cooling is the most destructive option with respect to Lake Ontario.

OPG has identiﬁed once-through cooling as their preferred option, despite evidence that once-through cooling systems have the greatest negative impact on the environment of any cooling water alternative. This preference is not justiﬁed. Of the four presented

12 Environment Canada and the United States Environmental Protection Agency, “Nearshore Waters of the Great Lakes”, Paper presented at the State of the Lakes Ecosystem Conference, 1996, online: at “Section 7: Status and Trends”.

13 Deﬁnition of critical habitat based on: Department of Fisheries and Oceans Canada, “The Fish Habitat Primer, Ontario Edition”, online: .

14 Ontario Power Generation, “Technical Support Document 6: Aquatic Environment Assessment of Environmental Effects”, (30 September 2009), s. 2.4.1.2, p. ES-2 - ES-3.

15 Ontario Ministry of Natural Resources, Lake Ontario Management Unit, Letter to Mr. Ron DesJardine, District Manager, Department of Fisheries and Oceans (10 April 2010), online as part of the CEAA Registry: .

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 16 cooling options, once-through cooling has the greatest potential to negatively impact ﬁsh and ﬁsh habitat in Lake Ontario.

Once-through cooling would have the greatest negative impact on fish and fish habitat because it will result in: • The mortality of significant numbers of fish through Condenser cooling water is used in nuclear reactors to cool process impingement and entrainment; water. Reactors work by heating water • Negative impacts on fish and to make steam, which then turns turbines to make electricity. In order to convert fish habitat due to the that steam back into process water, cool discharge of a large amount of water is passed through the system. In heat directly into the lake; the proposed plant, that water would come from Lake Ontario. Once the water • The emission of biocides and has been used for cooling, it is other contaminants to the discharged back into the lake at a higher temperature than the ambient lake water. lake; and Depending on the cooling water • The disruption or destruction technology chosen, the amount of lake water used in this process can differ of fish habitat due to the significantly. Once-through or open cycle construction and presence of cooling uses the most water of any of the the intake and discharge options available. structures themselves.

Once-through cooling may be preferred by OPG because discharging high quantities of cooling water allows for the dilution of discharged contaminants. As explained by the CNSC, the amount of contamination emitted from nuclear reactors does not change with different cooling technology.16 Instead, the amount of water pulled in and discharged by a once-through cooling water system allows contaminants to be diluted in more water than would be available with a more water-efﬁcient technology like closed cycle cooling. It has long been recognized that dilution is not the solution to pollution. Dilution should not be used in this case to link once-through cooling with lower pollution levels.

Impacts from once-through cooling will be ampliﬁed at the new plant due to dramatically higher ﬂow rates.

If once-through cooling is used at the proposed plant, the volumes of water used would be greater than for the existing DNGS. Aquatic impacts are generally greater the more water

16 CNSC, “Brieﬁng note for the Darlington Joint Review Panel (JRP): Clariﬁcation about Interpretation of IR 169 response from OPG: Estimates of Radiological Emissions for Cooling Towers vs. Once Through Cooling” (October 2010), online: .

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 17 is extracted and discharged. Dr. Henderson explains that the potential for impingement and entrainment is higher for the proposed plant, and the plant would create a greater amount of waste heat than the existing plant.

The intake and diffuser for the Darlington NNPP once-through cooling system was modelled on the system at the existing Darlington plant. However, since the ﬂow rate proposed for the NNPP is considerably greater than at the DNGS, the system would be “scaled-up” in a number of signiﬁcant ways. To maintain the same intake and discharge velocities, the porous area of the intake structure will have to be increased by 67%, and the diameter of the discharge ports will be 41% larger.17

According to OPG, the new plant would intake and discharge up to 250 m!/s of lake water, as opposed to 150 m!/s at the DNGS. Mr. Howell noted that this volume is similar to spring ﬂows in the Trent River at Trenton. To handle the increased ﬂow, the water intake and discharge structures would be scaled up at the new plant, in turn scaling up the environmental impacts of the cooling system.

Impingement will kill from 23 to 46 thousand ﬁsh each year.

OPG is proposing to use intake and discharge Impingement is the technical term structural designs similar to those installed used to describe the capture of when DNGS was built in the 1980’s. Plans for animals, typically fish and the new plant do not reflect any attempt to crustaceans, on filter screens. The organisms come into contact with the upgrade those designs to decrease their impact hard surface of the screen. Delicate- on fish. bodied organisms, such as open water fish, are usually killed, collected in the While fish mortality through impingement at “screen house trash bin”, and disposed of by plant staff. The size range of organisms DNGS is less than at other facilities on the Great impinged is dependent on the size of the Lakes (such as OPG’s Pickering Nuclear Power mesh and the protection installed at the Plant), annual fish kills at DNGS still range from intake. 14,000 to 26,000 fish each year. Where the flow volumes would be greater at the new plant, the estimated fish losses would range from 23,000 to 46,000 fish each year. Mr. Howell advises that this impingement rate is still high and should not be accepted simply because rates are higher at other facilities.

17 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 5-24.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 18 The EIS fails to reflect an attempt to improve on the DNGS design to reduce fish kills to the lowest possible level. For instance, a fish return system, which would return fish that are caught but not killed to the lake, is not considered. Dr. Henderson points to sturgeon as an example of a species that could benefit from a fish return system. While their population numbers are currently low, they could rebound in the next 60 years. If OPG begins to impinge juvenile sturgeon, a fish return system will be required to return those juveniles to the lake. Retrofitting such a system is costly and should be considered now, during the design phase.

Dr. Henderson cautions that the relative success of impingement reduction attempts at the DNGS may not translate into reductions at the new plant. While OPG claims it can replicate that success using the same designs, achieving the same impingement rates would require replicating the intake velocity and positioning of Darlington NGS. OPG has not provided evidence to show that the old design would be effective with the different conditions in front of the new site.

Even if it is scaled up, the impingement rate at DNGS may not provide an accurate basis for predicting impingement in a higher flow system. Impingement often increases at a faster rate than the increase in flow.18 OPG has not considered this potential non-linear relationship between flow rate and impingement. Dr. Henderson points to this flaw in the EIS, noting that it is not clear how the impingement predictions were generated. He cautions that, if the conclusions in the EIS are based on the assumption that catch is directly proportional to volume of water pumped, the calculation needs to be more fully justified.

Different species of fish are impacted differently as flow rate increases. For some, the rate of impingement does increase proportionally with flow rate increases. Others, like Alosa pseudoharengus and Osmerus mordax, are attracted to faster moving water so that impingement increases faster than flow rate. In contrast, species like Micropterus dolomieui are impinged less as flow increases, potentially because they avoid faster moving water. Dr. Henderson explains that these differences mean that impingement cannot be estimated using a simple scaling up. He provides a potential equation that could more accurately predict impingement.19

18 Henderson, 2010 at 5.

19 Henderson, 2010 at 6.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 19 Entrainment rates will be more than 66% higher than at Darlington NGS.

Entrainment rates at the new plant will be higher than at the existing plant due to the increased cooling water flow rate. The increase in flow rate from 150 m!/s to 250 m!/s will result in greater entrainment impacts on fish populations.

In 2004, it was estimated that 15,631,833 eggs and 1,201,943 larvae were entrained at Entrainment describes the fate of organisms that are drawn into the 20 DNGS. If entrainment losses increase in cooling water intake structure and direct proportion to flow, we can expect enter the cooling system. approximately 26,053,055 eggs and The organisms pass through fine filter 2,003,238 larvae to be entrained annually at screens via the plant’s pipe-work, and the Darlington NNPP.21 Dr. Henderson are discharged back to the environment with the heated effluent water. Of explains that unlike impingement losses, particular concern is the entrainment of entrainment losses are usually directly fish eggs and larvae, which may be proportional to the volume of water. This is killed in very large numbers during because most planktonic organisms are more passage through the power plant’s condensers. Recent studies show that or less passive in the water body, whereas fish mortality rates of entrained organisms react differently to varying flow rates. can be as high as 97%, depending on the species and life stage entrained.16 The slimy sculpin, or Cottus cognatus, is a fish native to Lake Ontario that was identified, along with alewife and rainbow smelt, as a species affected by entrainment at the Darlington NGS in 2001. According to the EIS, an “estimated 8,000 equivalent adult slimy sculpin were lost due to entrainment, and this species was noted to have suffered a lake-wide decline, likely as a result of food web changes”.22 Numbers of slimy sculpin in the lake continued to decline, so that the fish was not detected in entrainment studies conducted in 2004 and 2006. Alewife has also been identified as a species in decline in Lake Ontario. As Dr. Henderson observes, additional losses of these species in decline through impingement or entrainment will likely further that decline.

20 Ontario Power Generation, “Technical Support Document 6: Aquatic Environment Assessment of Environmental Effects”, (30 September 2009), at 3-30.

21 Based on 2004 entrainment estimates from DNGS multiplied by a factor of 1.6667.

22 Ontario Power Generation, “Technical Support Document 5: Aquatic Environment: Existing Environmental Conditions”, (30 September 2009), at 3-75.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 20 In the EIS, OPG declares that entrainment losses are relatively small and not meaningful at a population level.23 However, this statement is dependent on a mathematical translation of egg deaths to equivalent adult deaths, leaving room for error and interpretation.

Dr. Henderson questions the calculation of the “Equivalent Adult (Age) Value [EAV]” in the referenced studies. He explains that, “the numbers of eggs and larvae entrained and potentially harmed or killed is often a huge number, frequently lying between 107 and 1011 individuals per year. It is difﬁcult for us to appreciate the signiﬁcance of such numbers for the populations concerned”. That is why the EAV is used to translate the meaning of entrainment losses. It is derived mathematically and is meant to represent the reproductive importance or potential of an individual. Since it is based on reproductive potential, the EAV values a juvenile on the brink of reproduction much more highly than a new egg or larvae.

Dr. Henderson identifies two significant problems with this approach to understanding the effects of entrainment on fish populations:

First, the valuation and assumptions used in calculating the EAV are inadequately explained or justiﬁed in the EIS. Dr. Henderson explains how the conclusions are, “heavily dependent on the values assumed for the survival and possibly fecundity when making the equivalent age calculations”. He points out that, based on the information provided, it is not clear if appropriate values were used for either present or future conditions. It is also not clear how sensitive the equivalent age values are to the values used.

Second, valuing juveniles or adults more highly than eggs or larvae fails to account for the importance of those eggs or small organisms to the ecosystem. Dr. Henderson explains that entrainment losses are important because: 1) it is the small entrained organisms that form the base of the lake’s food web, supporting ﬁsh, birds and other organisms at higher trophic levels; and 2) many ﬁsh have young life stages that are both vulnerable to entrainment and feed upon entrained organisms.

This concern is rooted in fundamental ecology, wherein organisms higher in the food chain rely on the health and abundance of those at lower levels. In the case of Lake Ontario, the juveniles and adults that are valued more highly in the EAV calculation rely on the small organisms that are entrained as food sources. These include primary producers (diatoms, green algae, blue-green algae and dinoﬂagellates), basal decomposers (bacteria and fungi), small zooplankton (copepods, protozoans, cladocerans, amphipods, and rotifers),

23 Ontario Power Generation, “Technical Support Document 5: Aquatic Environment: Existing Environmental Conditions”, (30 September 2009), at 3-75.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 21 and macroinvertebrates (including the amphipod Diporeia spp., mysids, worms, midges, leeches, clams, snails and insect larvae). Entrainment therefore damages the links in the food chain that support larger ﬁsh. This is not accounted for in the EAV calculation.

Commonly, the impacts of entrainment are dismissed because the organisms killed have a high reproduction rate. Dr. Henderson addresses this misconception by pointing to the population decline of Diporeia spp., an amphipod. Its decline has been theoretically attributed to the zebra and quagga mussel invasions. The effect on fish stocks has been significant. Dr. Henderson notes that, if the mussel invasions can affect macroinvertebrates to the extent that fish stocks decline, entrainment at power plants must be considered beyond equivalency calculations. At a minimum, the entrainment figures should be compared to the number of organisms affected by zebra and quagga mussels in order to gain some understanding of the potential impacts on the food chain and population dynamics. To this point, Dr. Henderson concludes that, “no useful quantification of the invertebrate entrainment loss is presented” in the EIS for the Darlington NNPP.

Heated water discharge can affect ﬁsh health, ﬁsh habitat, plankton, and benthic organisms.

Almost all aquatic life is affected by thermal Water that is warmer than ambient discharges, so that the heated water that is temperature can have significant negative effects on local ecology. discharged into a lake is a water quality 24 Thermal plumes, ice cover, and reduced parameter of significant concern. The waste drinking water quality are potential heat output to the lake from a once-through environmental effects from the heated water cooling system is estimated at double the discharged from a once-through cooling water system. Thermal plumes have been electrical generating capacity of the plant. In shown to attract fish that then suffer cold this case, that would make the waste heat water shock when leaving the plume or load 9480 MW, which would correspond to a when the plant is shutdown for outages, temperature increase of approximately 9°C 22 causing harm to fish. They are also 25 associated with increased longevity and over ambient temperatures. productivity of bacteria and Cladophora algae. Phytoplankton productivity declines Mr. Howell notes that the diffuser used at with increasing temperatures above DNGS has been effective at preventing the approximately 20°C.23 Over 30°C, the species diversity of phytoplankton dispersion of water that is more than 2ºC decreases. Phytoplankton blooms have above ambient beyond the mixing zone. also been associated with thermal However, it still generates an area of higher discharge, specifically from nuclear plants. temperature in the immediate vicinity of the

24 Henderson, 2010 at 10.

25 Henderson, 2010 at 4.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 22 discharge. He explains that the resulting area of warmer water, “would result in ﬁsh avoiding this area and therefore reduce the productive capacity of the site”.26

Dr. Henderson explains that thermal effects on fish are significant because they are completely submerged in the water, and because they constantly pass a large amount of water across their gills to obtain oxygen. Fish can acclimate or metabolically adjust to thermal changes, but only to a certain point. After that point, the fish becomes uncoordinated, distressed, and ‘heat death’ can ensue.27

As fish can sense temperature changes of 0.03 to 0.07°C, they will attempt to avoid stress by moving out of less preferred temperatures. However, uncoordinated fish will have a harder time moving out of the warm water, and it will be more difficult the longer they are in the warmer water. While heat can increase swimming speeds, once it exceeds the critical thermal maximum temperature, fish endurance is decreased so that fish have less ability to escape to cooler water. At temperatures over 40°C, heat death ensues.

In addition to heat stress and death, ﬁsh suffer a variety of problems at increased temperatures. Dr. Henderson notes that temperature can affect, “survival, growth and metabolism, activity, swimming performance and behaviour, reproductive timing and rates of gonad development, egg development, hatching success, and morphology”.28 Further, temperature increase can exacerbate the stress level in ﬁsh caused by other factors, like pollution or disease. Thermal impacts from this plant must be considered in the context of the cumulative pollution impacts in the Local Study Area.

Different fish species react differently to heat. Some, like stenothermal salmonids, have a narrow range of temperature tolerance. Dr. Henderson emphasises the distinction between the ability to survive and the ability to propagate, as warmer temperatures can, “advance or delay breeding seasons, encourage breeding in the wrong place or inhibit fish migration”.29 Where larger fish can often swim out of the heated zone, heat pollution tends to affect eggs and weakly-swimming early life stages. These, along with plankton that is also negatively impacted by heat, are the same organisms affected by entrainment. This leads to the same consequences of targeting the foundational levels of the food web, wherein larger organisms cannot survive as their food sources are removed.

26 H. D. Howell, “Review of Fish Habitat Related matters in the Environmental Impact Statement and associated Technical Support Documents”, Prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant EA Process, (25 January 2011) [hereinafter “Howell, 2011”] at 6.

27 Henderson, 2010 at 13.

28 Henderson, 2010 at 14.

29 Henderson, 2010 at 14.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 23 While is it clear that the thermal impact of the Darlington NNPP would not be sufficient to change the mixing structure of a lake the size of Lake Ontario, it could have local impacts that would, in turn, affect plankton populations. Dr. Henderson found that this issue was not addressed sufficiently in the EIS and the document, “gives little information on possible effects on stratification and the far field thermal model did not address this issue”.30

The temperature difference between discharged and ambient lake water can The release of water at a temperature higher than the surrounding lake water also mean that small organisms like eggs, could constitute the deposit of a plankton, and larvae, are entrained in the deleterious substance and the harmful warm discharge stream. While alteration, disruption or destruction of entrainment is commonly used to refer to fish habitat. Section 34(1)(b) of the Fisheries Act defines “deleterious substance” as: “any organisms caught in cooling water intake water that contains a substance in such streams, the term is general enough to quantity or concentration, or that has been so encompass organisms being caught up treated, processed or changed, by heat or and carried along in any flow. The sudden other means, from a natural state that it would, if added to any other water, degrade or alter or temperature change is likely to stress the form part of a process of degradation or organisms, according to Dr. Henderson, alteration of the quality of that water so that it and, “makes it inevitable that the structure is rendered or is likely to be rendered of the lake community in the region of deleterious to fish or fish habitat or to the use by man of fish that frequent that water...” impact will be altered to some extent”.31

The discharge system, modeled on the existing DNGS system, will use a submerged offshore diffuser. It will consist of a single line of 90 ports that emit the efﬂuent rapidly from a lake bottom discharge pipe. The EIS states, “The diffuser ports are angled upward such that contact of heated water with the lake bottom is minimized and rapid mixing with the overlying water column is achieved”.32 The rapid mixing described will cause entrainment of plankton, eggs, larvae, and other small organisms. Entrainment in the streams emitted from the diffuser ports has not been adequately considered in the EIS.

Heated water emissions could have special impact on benthic communities. Dr. Henderson explains that warmer discharges are generally less dense than colder receiving water, so that they do not usually impact benthic organisms and environments. However, this is not the case consistently at the proposed Darlington site. In cold conditions, warm

30 Henderson, 2010 at 10.

31 Henderson, 2010 at 10.

32 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 4-47.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 24 water can be more dense than cold water, so that the warm layer actually lies on the bottom, affecting benthic communities. He notes that there is almost no information on benthic organisms in the EIS, and notes the need for an assessment of the benthic community in the affected area.

Fish habitat will be destroyed by the construction of cooling water intake and discharge structures.

The ﬁsh habitat impacts of constructing the intake and discharge structures, and the lasting impact of their addition to the lake, have not been adequately evaluated in the EIS.

In addition to the impacts on fish during operation, the installation of the large structures required to intake and discharge 250 m!/s of cooling water will directly impact fish habitat. The proposed intake would be a concrete structure at least 85 metres in diameter. Mr. Howell notes that, “its hard, relatively flat surface would replace the natural substrates with an area that has a much lower utility for fish and the organisms they feed upon”.33 OPG has estimated that these structures will occupy about two hectares of lake bottom.

Construction of these structures may also disrupt or destroy a larger area of fish habitat. OPG may use a 4.62 hectare berm to allow the structures to be installed on the lake bottom in dry conditions. That area would not be serving as fish habitat when dry. It is not clear whether it will be more or less suitable as fish habitat when water is returned, if the physical environment has been changed.

Boating is restricted in the area around once-through cooling structures.

The project as proposed would impact Boating near cooling water structures can navigation in Lake Ontario, particularly be dangerous due to the currents created by the intake and discharge ﬂows. OPG when considered in conjunction with the states, “The area immediately offshore of the existing navigational barriers imposed DNGS where its cooling water intake and around the DNGS. The EIS fails to diffuser are located has been marked as a account for small boat and recreational prohibited zone on the navigation charts. This zone is approximately 1,400 m wide (measured boat trafﬁc. It refers only to shipping alongshore) and extends approximately 2,000 m channels in Lake Ontario that are located into the lake”.30 much further offshore than the restricted zone.

33 Howell, 2011 at 6.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 25 The intake structure for the DNGS extends approximately 1 km into the lake; the existing diffusers extend 1.5 km. OPG estimates that, if once-through cooling is implemented at the new plant, the intake and output will extend approximately the same distance into the lake. This will essentially double the prohibited navigation zone around the plant. The impacts on recreational boating in the vicinity of the site could be signiﬁcant, but the issue is not sufﬁciently considered in the EIS.

There are alternatives to once-through cooling.

After a thorough review of the EIS and the four condenser cooling technologies considered by OPG, Dr. Henderson concluded that:

In terms of the impact on Lake Ontario, the The project description submitted preferred option of once-through cooling is the by OPG identifies four potential most damaging, as it will result in: cooling water systems that could be installed at the Darlington 1. The greatest level of entrainment of fish NNPP: and invertebrates; • Once-through lake water 2. The greatest level of impingement of fish cooling; and invertebrates; • Natural draft cooling towers; 3. The largest thermal discharge; and • Fan-assisted natural draft cooling towers; or 4. A larger use and release of biocides such 34 • Mechanical draft cooling as chlorine. towers.

Mr. Howell concurs that once-through cooling would have the greatest negative impact on the lake of all available options. He adds that once through cooling will also result in the disruption or destruction of ﬁsh habitat due to the construction and presence of the intake and discharge structures themselves.

Once-through cooling necessitates impingement, entrainment, thermal impacts, structural impacts, and navigation restrictions. As Dr. Henderson explicitly states, “While the design of the intakes and outfall can reduce these impacts, they cannot be reduced to levels comparable to that which can be achieved using one of the closed-cycle cooling options”.

34 Henderson, 2010 at 21.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 26 In an open system the coolant (water) is in contact with the environment; in a closed system the coolant circulates through the plant without contact with the environment.35 OPG has excluded hybrid (wet/dry) cooling towers, dry cooling towers, and spray/cooling ponds from consideration due to the cost of these alternatives, limiting the options before this Panel to open system cooling.30 Waterkeeper submits that this Panel has the authority to expand the scope of alternatives in consideration to include closed cycle cooling.

If closed cycle cooling were installed at the Darlington NNPP, such that cooling water did not contact the environment, most of Waterkeeper’s concerns about this project’s impacts on ﬁsh and ﬁsh habitat would be addressed. If one of the options that uses considerably less cooling water, such as cooling towers, were installed, the volumes of water being taken in (6 m!/s) and discharged (1.5 m!/s) would be much lower, reducing impingement, entrainment, and heated discharge.

After considering the four options before this Panel, Mr. Howell stated:

“Considering the impact on ﬁsh and ﬁsh habitat in Lake Ontario, the employment of cooling towers, of whatever type, must be considered the preferred option. Because of the dramatically reduced volumes of intake and discharge water, and the reduced size and footprint of the intake and discharge structures themselves, any of the cooling tower options will have greatly reduced impacts, particularly if best available designs are implemented.”

OPG states that it has chosen the technology most damaging to the lake because of the existence of the lake. Stating that hybrid or dry cooling technologies are meant for dry climates, OPG states that because water is plentiful at the Darlington site, it should be used for cooling.36 The fact that water is available does not justify its exploitation, when the effects leave that aquatic resource damaged and depleted.

Once-through cooling is the most damaging option for the lake from an ecological perspective and should not be approved for use at the Darlington NNPP site.

35 R. Seaby & P. Henderson, “Notes on the Guidelines for the EIS for Darlington B nuclear power plant”, Prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant EA Process (14 November 2008) at 2.

36 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), s. 2.4.1.2 at 2-14.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 27 Lake Filling will result in the permanent loss of nearshore ﬁsh habitat.

OPG has requested approval to fill in up to forty hectares of Lake Ontario with excavated soil and rock. Forty hectares is equivalent to the land area of forty international rugby fields, or almost eight SkyDome stadiums. The fill would extend along two kilometres of shoreline and into the lake to a depth of four metres. It would be bordered by an armor stone wall to prevent erosion.

The permanent loss of nearshore fish habitat Lake filling associated with the NND resulting from filling is the most obvious Project will destroy approximately 40 impact on fish associated with the proposal. hectares of nearshore fish habitat. It will extend from the eastern limit of the The destruction is concentrated in the DN site to approximately the DNGS nearshore area and includes critical fish intake channel, and about 100 m into habitat. the lake on its western limit and approximately 450 m on its most eastern dimension. 31 Fill will also be added to the lake in front of the existing Darlington NGS, extending the area that was filled when that plant was built. Mr. Howell observes that, in the decades since that was filled, “it is probable that a robust community of fish and other aquatic organisms have become well established on the armored fill slope”.

In addition to directly destroying fish habitat through deposition in the lake, filling can harmfully alter fish habitat outside the fill zone through contamination. According to the EIS, construction waste and hazardous materials produced or uncovered during site grading will be sent to appropriate offsite management facilities.37 The EIS does not indicate how hazardous or contaminated materials will be identified or separated from excavated fill. Instead, it states that it is assumed that the excavated material will be monitored for contamination and that contaminated soils will be removed prior to lake fill. It is assumed that soil will “meet quality criteria for lakefill”. 38

No procedures for sampling soils prior to, during, or following excavation are described. No specific criteria for contamination are indicated. The criteria for lakefill referred to are not identified. Given the numerous pollution sources surrounding the site, there is potential for some contamination to exist in the 12.4 million cubic meters of soil and rock OPG plans to excavate. Simply assuming that soils will be tested and will meet standards is not adequate provision for protection of the lake.

37 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), s.2.5.2, at 2-30.

38 Ontario Power Generation, “Technical Support Document 10: Geological and Hydrogeological Environmental Assessment of Environmental Effects”, (30 September 2009), s.3.2.1.3, p. 3-9.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 28 There are alternatives to ﬁlling in the lake.

Waterkeeper is very concerned by the proposed lake inﬁll and submits that the issue has not been adequately explored or supported by evidence in the EIS. According to OPG, the decision to ﬁll 40 hectares of Lake Ontario was made prior to the beginning of the EA process.39 This contradicts the proposed bounding scenario approach, and undermines the scope of the decision that has been put before this Panel.

There is insufficient evidence in the EIS to support a conclusion that lake infill is necessary. The EIS does not consider a number of potential alternatives to lake filling, including:

• Using the northwest landﬁll to store excavated ﬁll and for construction lay-down.

• Moving existing features on the site to create more space on the property. Most obvious of these is the existing rail line, which could be moved further north to accommodate lay-down and create room for the construction of reactors or cooling towers.

• Varying the placement of reactors or cooling towers from a linear north-south conﬁguration to an angled or L-shaped arrangement.

• Construction waste and excavated soils could be removed to off-site disposal sites.

• Decreasing the number of reactors to allow the plant to ﬁt on the existing site.

OPG has stated a preference for filling in 40 hectares of the lake, stating that lake fill is required for security, erosion protection, and the creation of extra land for construction lay- down and construction of reactors or cooling towers. Hydrogeologist Wilf Ruland did not find adequate justification for this decision in the EIS. In his professional opinion, lake filling could have a significantly negative effect on the aquatic environment and should have been properly assessed in the EIS through the consideration of alternative designs.

OPG limited their consideration of alternative model plant layouts to three in the EIS.40 All are shown to require 40 ha of lake inﬁlling. At a later date, in response to a request from DFO, twelve additional alternative plant layout options were put forward by OPG. While

39 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-112.

40 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-21 to 2-23.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 29 some of these twelve options show less than 40 ha of inﬁll, all require encroachment into Lake Ontario.

Doug Howell notes that OPG relies on three main arguments to conclude that lake filling will have a “negligible” effect on the environment.41 After considering each of these claims thoroughly, Mr. Howell found that concluding that infilling 40 hectares of nearshore aquatic habitat would be negligible is, “not credible”. It appears that one of the main impetuses for lake fill may be the preference for onsite disposal of excavated materials. OPG should not be authorised to fill in fish habitat in order to save money on proper disposal of excavated materials.

OPG Justiﬁcation for Expert Opinion Lake Fill

There are extensive areas The size of Lake Ontario cannot be used to justify of similar habitat in the destroying ﬁsh habitat. Just like the debunked refrain, lake. “Dilution is the solution to pollution”, an activity that would not be acceptable on a smaller lake cannot be justiﬁed because it is being carried out on a Great Lake.

The infill area does not In the new build area, the fill would extend out from shore consist of a meaningful to a point where the lake is currently approximately five proportion of habitat for metres deep. Mr. Howell notes that this area, “provides any VEC indicator species. habitat for a broad array of fish species characteristic of the Lake Ontario near shore environment”. The nearshore habitat is the most productive area of the lake. The proposed infill area provides critical habitat for four species of fish, and general habitat for many others.

Effects will be negligible A compensation plan is only used where the harmful because a compensation impact on ﬁsh habitat is signiﬁcant and cannot be plan will be undertaken. mitigated. This is the opposite of a negligible effect. Compensation should be a last resort.

41 Ontario Power Generation, “Technical Support Document 6: Aquatic Environment Assessment of Environmental Effects”, (30 September 2009), s. 3.3.1.6, p. 3-21.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 30 Pollution from the project may cause adverse environmental effects.

A number of pathways for pollution to air and water will be created by the proposed Darlington NNPP. The effect of this pollution would be ampliﬁed at the Darlington site due to the cumulative pollution load in the area, the potential for shoreline fumigation, and the disproportionate effect on sensitive nearshore habitat. Despite this ampliﬁcation, the EIS fails to thoroughly consider impacts by identifying potential pollutants, the standards that will be used to evaluate them, and the measures that will be taken to ensure they do not enter or negatively impact the environment.

Preparation, construction and operation of the project may pollute the air and water.

Pollutants are emitted from nuclear plants through a variety of pathways, including through spills, air emissions, storm water runoff, sewage discharges, and in cooling water. The proposed project would create a number of new pathways from site preparation to waste disposal.

Pollutants are routinely discharged with cooling water: An ongoing source of contamination that is deliberately released from nuclear facilities is the discharged cooling water used in once-through cooling water systems. While Waterkeeper is concerned by all contaminant emissions from nuclear facilities, we submit that this Panel has special responsibility to consider the release of contaminants through cooling water discharge that will continue for up to 85 years if once-through cooling is approved for this site.

The most common of the routine emissions in cooling water come from the addition of biocides. To keep plant pipes and equipment free of organisms like mussels, OPG will have to use semi-continuous low-level chlorination. That chlorine will kill most of the entrained organisms, bacteria, and other micro-organisms in the water before it is released to the lake with the discharged cooling water.

CANDU reactors emit air pollution: Air pollution, while a concern unto itself, also contributes to water pollution. When atmospheric emissions are deposited in nearby water bodies, many dissolve and become available for uptake by aquatic organisms.42 Heavy metals, like the chromium, lead, and mercury emitted from Darlington NGS, can cause adverse effects in aquatic organism, or render them unﬁt for consumption by humans or organisms higher in the food chain.

42 See generally: D.S. Jeffries & W.R. Snyder (1981), Atmospheric deposition of heavy metals in central Ontario, 15(2) Water, Air, & Soil Pollution 127; J.N. Galloway & G.E. Likens (1979), Atmospheric enhancement of metal deposition in Adirondack lake sediments, 24(3) Limnology and Oceanography 427.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 31 There is overwhelming evidence that the operation of CANDU reactors results in the emission of pollutants into the environment. On June 30, 2009, OPG sought a renewal of their Basic Comprehensive Certiﬁcate of Approval for the Darlington NGS. In the application, OPG states that the following contaminants are emitted into the atmosphere from, “all sources at the facility, including (4) CANDU generating units…”:

2-propenoic acid, ammonia, aromatic hydrocarbon resin, benzene, carbon dioxide, carbon monoxide, hydrazine, morpholine, nitrogen oxides, phosphoric acid, quarterly ammonium compounds, sulphur dioxide, suspended particulate matter, and total hydrocarbons.43

Tritium is emitted to the air and water: All CANDU reactors release radioactive material, including tritium. Tritium is a radioactive form of hydrogen that is released into the air and water from nuclear plants. Tritium is dangerous when eaten or absorbed into the skin. It is associated with cell damage and has the potential to induce cancer.44

According to the CNSC, 39 tritium emissions to air and water in 2006 from Ontario’s three nuclear generating stations were:

Tritium emissions Tritium emissions Plant to air to water

Darlington NGS 1.3 x 1014 Bq 1.9 x 1014

Pickering NGS 5.7 x 1014 Bq 3.3 x 1014 Bq

Bruce NGS 9.0 x 1014 Bq 7.3 x 1014 Bq

Tritium levels in the air and water surrounding nuclear facilities are greater than background levels. Atmospheric tritium concentrations close to nuclear facilities can reach 10 Bq/m3 (Becquerels per cubic metre) and 100 Bq/L (Becquerels per litre) in water. The

43 Government of Ontario, EBR Registry Number: 010-7054 (Toronto: Ministry of the Environment, 2009), online: Environmental Registry .

44 See Canadian Nuclear Safety Commission, Tritium Releases and Dose Consequences in Canada (Ottawa": Minister of Public Works and Government Services Canada, 2009) at 13; U.S Department of Energy, Human Health Fact Sheet Tritium, (Argonne: Argonne National Laboratory, 2005) online: Environmental Science Division ; J.D. Happell, “A history of atmospheric tritium gas (HT) 1950-2002” (2004) 56:3 Tellus Series B: Chemical and Physical Meteorology 183 at 183.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 32 background level of tritium in water in Ontario is between 2 to 3 Bq/L. The elevated tritium levels around nuclear facilities suggest a connection between the documented tritium releases and accumulation of tritium in the environment.45

Dust and erosion: The potential for air emissions from dust and surface water emissions from erosion are extensive during site preparation and construction. The EIS indicates that, “for assessment purposes it is assumed that the entire site will be prepared for construction at the outset of the project”.46 Up to 12.4 million cubic meters of soil and rock will have been excavated and moved, and a vast area of raw soil will be exposed.47 Hydrogeologist Wilf Ruland notes, “Excavation and grading activities on such a scale bring with them the potential for massive air quality impacts (from dust) and surface water quality impacts (from soil erosion)”.48

The EIS indicates that “dust suppressants” will be used as needed at the site. The nature of those suppressants is not indicated. No criteria for when suppressants will be deemed necessary is described. The nature of dust suppressants and criteria for their application should be before this Panel for consideration.

To mitigate potential surface water impacts, a precondition for any site clearing, preparation, or construction in any new area for the NND project should be the construction of surface water management ponds capable of containing and treating all runoff from the affected area(s).

Sewage creates a pathway to water contamination: One of the potential pathways for liquid efﬂuent to move off the site is by sanitary sewer. Sanitary sewage from the Darlington NGS is treated onsite, but sewage from the planned NNPP would go to the offsite Courtice Water Pollution Control Plant. Hydrogeologist Wilf Ruland notes that,

45 R.V. Osborne, “Tritium in the Canadian Environment: Levels and Health Effects” (Ottawa": Canadian Nuclear Safety Commission, 2002) at i, 1, 6, 7 & 8; Ontario Drinking Water Advisory Council, Report and Advice on the Ontario Drinking Water Quality Standard for Tritium (Toronto: Ontario Minister of Environment, 2009) at 3.

46 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-27.

47 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), s. 2.5 at 2-27.

48 W. Ruland, “Independent Review of Hydrogeological Issues Pertaining to the OPG Environmental Impact Statement for the Proposed Darlington New Nuclear Plant Project”, Prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant EA Process, (16 February 2011) [hereinafter “Ruland, 2011”] at 5.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 33 “Using an off-site wastewater treatment plant to deal with sewage from the site introduces a pathway for contaminants to escape the site and cause off-site water contamination”.

The EIS indicates that, “all domestic sewage will be directed to the wastewater treatment plant” by sanitary sewer, and that the existing DNGS buildings will also be serviced by the sewer system.49 In Interrogatory 197, Mr. Ruland asked OPG to describe, “all measures which will be used to ensure that nothing other than domestic sewage will be ﬂowing into the sewer system”. Such measures should include: • a corporate best practices approach to handling of all liquids, • only discharges of normal domestic sewage from buildings permitted; • proper training of personnel; and • a rigorous program of independent testing of discharges to the sewer system.50

The response provided by OPG fails to indicate that these or any other measures will be used to ensure that nothing other than domestic sewage will enter sewage mains. It is not clear that the Courtice wastewater treatment plant is equipped to handle contaminated sewage streams from a nuclear power plant, nor that workers at the plant are trained to deal with such contamination. This could lead to off-site water contamination that is not addressed in the EIS.

Contaminants are released through spills and fugitive emissions: Unplanned emissions of contaminants from nuclear power stations occur through a variety of pathways, including to air, surface water, and ground water. In December 2009, about 210,000 litres of water containing tritium and hydrazine were spilled into Lake Ontario from the Darlington NGS.51 According to the EIS, tritium emissions from the Darlington NGS have resulted in tritium concentrations on the property as high as 500 Bq/L, more than 150 times background levels. The EIS does not consider tritium spills or fugitive emissions.

49 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 5-38 and 6-17.

50 Ruland, 2011 at 7.

51 Ontario Power Generation, News Release (22 December 2009), online: ; Durhamregion.com, “Tritium spills into Lake Ontario after Darlington accident” (23 December 2009), online: .

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 34 The project will contribute signiﬁcantly to existing pollution sources in the area, increasing the load of cumulative effects.

For the sake of the people, animals, ﬁsh, and aquatic life that rely on it, Lake Ontario requires a high degree of protection and precaution. The CEAA requires the panel to consider cumulative environmental impacts before making a decision with respect to the Darlington NNPP. After a thorough review of the EIS and on the advice of our expert consultants, Waterkeeper has found that the EIS does not adequately consider cumulative impacts.

Dr. Peter Henderson of Pisces Consulting restricted his review to the long-term aquatic impacts of the proposed plant’s cooling water system. Given the potential life span of 85 years, Dr. Henderson focused on, “seemingly small effects that may have cumulative and damaging impacts over the long-term”. These effects arise from the normal operation of the plant and result from design decisions, such that choices made regarding cooling water now will determine this development’s effect on the lake for the next 85 years.

Dr. Henderson explains that, for the aquatic environment, by far the most important long- term impacts relate to the cooling water system. He points to recent major changes in populations of bivalves, ﬁsh, and plants in the lake. Based on the rate of change and past experience, Dr. Henderson predicts that the assemblage of common species in the lake could be different in 20 to 40 years, long before the new plant’s predicted end of life in 85 years.

While a species may be prospering currently, a change wherein the species is barely able to maintain numbers can occur in a matter of years. Dr. Henderson suggests that may be the case currently for the slimy sculpin and Diporeia. When species begin to struggle, additional mortality caused by impingement, entrainment, thermal pollution, or biocides can exacerbate the decline. For both operational and environmental reasons, he suggests a conservative approach should be applied to decisions about cooling water.

Not only do the wider cumulative impacts of another industrial development on Lake Ontario need to be considered, but also the speciﬁc combined effects of this plant with the neighbouring existing plant, which OPG plans to refurbish to facilitate a life extension. As Dr. Henderson explains,

“One of the reasons that the Great Lakes ecosystems have been so disrupted by Man is our inability to take a holistic view of a multitude of local effects. All users claim they will only have a limited local impact. But when these are all combined, how can the ﬁsh and

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 35 invertebrates prosper? The EA did not consider in-combination issues in the depth required”.52

Specifically, Dr. Henderson found that the EIS failed to consider the cumulative effects of the cooling water systems for the Darlington NGS and the proposed NND plant. The combined impact of 250 m3/s at the new plant and 150 m3/s intake from the existing plant could cause, “an appreciable alteration of water flows”. The scale of the new intake structures, in combination with the existing NGS intake structures may create new habitat that attracts fish to the area.

Dr. Henderson also notes that the EIS fails to thoroughly analyse the potential impacts of blow-down from cooling towers as dissolved solids content is increased and pollutants in the water are concentrated.53 As this effect could be compounded due to shoreline fumigation, it must be considered in the cumulative context.

Doug Howell, Waterkeeper’s ﬁsh habitat expert, expressed concern at the failure of the EIS to adequately address the cumulative heat loading to the lake from the combined outputs of the Darlington NGS, the adjacent St. Marys Cement plant, and the proposed NNPP.

The EIS indicates that discharged water will be approximately 9°C above ambient temperature. Mr. Howell explains that fish and other mobile aquatic organisms are likely to avoid a significant portion of the warmer mixing zone around the cooling water discharge structure, resulting in a loss of fish habitat. The thermal loading in Lake Ontario will be augmented by the concurrent operation of the Darlington NNPP, Darlington NGS, and Pickering NGS. Further, St. Marys Cement also discharges untreated once-through cooling water to the lake.54 Despite these sources of heat pollution, an assessment of the cumulative heat loading and its effect on the lake is omitted from the EIS.

Increasing the temperature of water also affects ﬁsh by making the water less soluble to gases, including oxygen which ﬁsh need to live. This problem is exacerbated by other causes that reduce dissolved oxygen, such as sewage discharge.55 Just as Lake Ontario provides drinking water for millions of people living near its shore, the lake is also the repository for the sewage produced by those millions of people. The Darlington NNPP site is located in the midst of a number of large-output sewage plants, including the Port

52 Henderson, 2010 at 21.

53 Henderson, 2010 at 19.

54 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), s.8.2.1, at 8-16.

55 Henderson, 2010 at 21.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 36 Darlington plant in Bowmanville, the Courtice plant, and the Dufﬁn Creek Sewage Treatment Plant in Pickering that is in the process of expanding to accommodate sewage from across York Region. An assessment of the cumulative effects of sewage emissions and thermal discharges should be before this Panel for consideration.

Incompatible land use on the adjacent St. Marys Cement property may cause adverse environmental effects.

The potential for catastrophic pollution exists due to the proximity of the St. Marys Cement Plant. The quarry’s Aggregate Resources Act licence permits it to continue extraction to a depth of 200 metres below ground (190 metres below lake level). This is deep enough to be considered an open pit mine. The new extraction will extend right up to the southeast corner of OPG’s Darlington property, adjacent to the area of the property proposed for the new Darlington plant. The quarry will be 80 metres deep within 100 metres of the Darlington property boundary, and 200 metres deep within 500 metres.

As a hydrogeologist, Wilf Ruland found the proposal to construct a nuclear plant in such close proximity to an active quarry of this depth to be one of his most critical concerns with the EIS. He explains that: • Decades of ongoing blasting in immediate proximity to the Darlington NNPP will be carried out by a third party, outside the control of the proponent or the regulatory control of the CNSC. There is potential for vibration from the blasting to affect the NNPP. • The quarry extension will remove a great mass of bedrock from the immediate area. Significant amounts of groundwater will be removed through quarry dewatering. This removal of groundwater and bedrock can cause ‘induced seismicity’, wherein the removal of millions of tonnes of material combined with ongoing blasting can induce seismic events in the area. • Dewatering at the scale that will occur on St. Marys property can cause subsidence in adjacent land. As groundwater is removed, water from adjacent bedrock flows into the quarry. This water must then be pumped to maintain a dry quarry floor. As the adjacent area loses its groundwater to the quarry, it begins to compact and subside. Any karstification or moderate permeability in the bedrock layers below the new plant could lead to subsidence below the nuclear facility.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 37 The EIS does not address the potential ramiﬁcations for the environment from changes to the plant from blasting vibration, bedrock subsidence, or an induced-seismic event. The possibility of emissions from such an incident has not been considered.

Uncontained waste may cause adverse environmental effects.

The scope and scale of the project mean that this review includes existing waste and contaminated soils, wastes created during site preparation and construction, ongoing wastes produced during operation, and long-term decommissioning waste. Waste is a major focus for many intervenors participating in this review. Waterkeeper’s focus with respect to waste is the potential for emissions to the lake from improperly contained waste.

Wilf Ruland has considerable experience evaluating the effectiveness of waste management sites.56 He found that the stated expectation that all existing waste and legacy contamination on the Darlington site will be dealt with prior to site preparation is unrealistic.57 Instead, it is more likely that contamination will be discovered during construction. This could include inorganic, organic, and radiological contamination.

No details regarding how the waste will be dealt with are provided in the EIS. Mr. Ruland emphasizes the urgency of a plan for dealing with existing waste and contaminated soils that are encountered during construction, including: • a ﬁrm commitment to disposing of any existing wastes and/or contaminated soils at licenced off-site facilities; • comprehensive testing of soil quality across the proposed excavation/construction area, with stepped up testing in areas known to have been disturbed historically; • consideration of the logistics of separating/stockpiling such wastes and/or contaminated soils to ensure that water contamination from the stockpiling/ separation areas is prevented; • the regulatory standards which will be used for determining where to dispose of the contaminated materials off-site.58

56 Curriculum Vitae of Wilf Ruland, attached in Appendex A.

57 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-27.

58 Ruland, 2011 at 6.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 38 Mr. Ruland found that the EIS is similarly lacking a plan to deal with construction waste and soils that may become contaminated during construction. No details are provided beyond an assertion that construction waste will be sent to an off-site waste management facility.59

It is not clear from the EIS whether waste and contaminated soils will be landfilled onsite, or whether the existing Northeast landfill contains waste or contaminated soil. While the EIS states that no waste disposal facilities will be established on the property, it describes expanding the Northwest Landfill and creating a new Northeast Landfill to receive, among other material, excavated soil and rock. Mr. Ruland notes that the term “landfill” generally indicates waste or contaminated material. Areas that receive only clean rock and soil are termed ‘fill areas’.

Mr. Ruland highlights the omission of consideration of the potential environmental impacts of nuclear waste storage in the EIS. While various disposal options are discussed, the impacts of disposing low, intermediate, and high-level radioactive waste are not assessed.

The EIS is incomplete and does not represent adequate provision for the environment.

Each of the experts consulted by Waterkeeper regarding the EIS found the information to be inadequate and incomplete. Mr. Ruland explained that, from a hydrogeological perspective, a complete EIS would include: • a comprehensive assessment of potential water quality impacts at all stages of the project including site preparation, construction, operation, and decommissioning; • detailed proposals for mitigation; and • appropriate monitoring plans and realistic contingency plans.

Each of these components is missing from the EIS in Waterkeeper’s focus areas: hydrogeology, cooling water systems, aquatic biology, and ﬁsh habitat biology. The EIS does not provide an adequate assessment of potential impacts of the project. It does not meet the criteria set out in the EIS Guidelines. Too much information is missing to allow this Panel to conclude that OPG will make adequate provision for protecting the environment. As Mr. Ruland notes, the EIS is merely, “a plan to have a plan”.

59 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-30.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 39 Pursuant to s.34(a) of the CEAA, the review panel is required to, “ensure that the information required for an assessment by a review panel is obtained and made available to the public”. The panel obtains this information through the proponent’s Environmental Impact Statement [EIS], from interested stakeholders and members of the public, and through the hearing process. The EIS, which must be prepared according to guidelines set by the panel, is the major source of project information, and therefore should provide enough detailed and reliable information to allow the panel to fully understand, consider, and render a decision on all the points enumerated in s.16 of the CEAA.

The EIS does not provide an adequate assessment of the potential impacts of the proposed New Nuclear - Darlington (NND) project. Mr. Ruland identiﬁed a number of critical points that should be before this Panel, including: • Reactor technology decision; • Whether to ﬁll any of Lake Ontario, and if so, how much. This should not be predetermined by the proponent; • Plans for erosion control and stormwater management during preparation/ construction are missing; • Plans for dealing with existing wastes or contaminated soils, and construction waste management plans are missing; • An environmental management plan has not been prepared; • No environment protection plan for handling, storage and disposal or fuel oils, solvents and lubricants have been prepared; • No spill response plan is included in the EIS; • Groundwater and surface water quality monitoring plans are not provided; • There are no contingency plans to protect the environment in the case of emergencies; and • The follow-up program is incomplete, constituting a plan to have a plan.

Based on these gaps and issues with the document, Mr. Ruland states that:

In my professional opinion, the EIS Report has been issued prematurely. There is no decision yet on which reactor type is proposed to be used, and critical plans are missing entirely from the EIS and supporting documentation... In essence much of the EIS simply represents a “plan to have a plan”, which is not satisfactory for the environmental impact assessment of a project of this magnitude.

OPG has stated that more information, including detailed emissions rates and streams, will be available when the engineering documents are developed, which will not happen until a design and vendor are selected. Waterkeeper submits that it is impossible to conduct an environmental assessment that considers the project in a “careful and precautionary

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 40 manner” without knowing what the project will entail or what speciﬁc effects it will have on the environment.

The bounding scenario does not provide a basis to conclude that OPG will make adequate provision for the protection of the environment.

OPG relies on the bounding scenario throughout the EIS. It is used to justify the omission of specific information with respect to everything from the amount of lake fill required to the specific contaminants that will be emitted from the plant. The scenario is used to justify conducting an environmental assessment before fundamental decisions about the nature of the project have been made. While this may be appropriate for use in issuing a licence to prepare a site, it is not appropriate for an environmental assessment decision that applies to the life of a major project. The result is an EIS that is cumbersome, missing important information, and fails to provide the basis for an environmental assessment decision.

Instead of describing the details of the project prior to undertaking the EA, OPG has applied a “bounding framework that incorporates the Plant Parameter Envelope” [“bounding scenario”]. The bounding scenario approach requires OPG to identify all potential emissions in order to establish the “worst case scenario” for this Panel to assess.

According to the EIS: “The essential aspect of the method adopted for defining the “Project for EA Purposes” is the use of a bounding framework that brackets the variables to be assessed. This bounding framework is defined within a Plant Parameter Envelope (PPE). The PPE is a set of design parameters that delimit key features of the Project. The bounding nature of the PPE allows for appropriate identification of a range of variables within a project for the purpose of environmental assessment”.60

The EIS declares that the use of a bounding scenario is consistent with CNSC licensing guidance for new nuclear power plants, wherein a licence to prepare a site may be submitted before a technology is chosen. However, this justiﬁcation does not apply to environmental assessments. In the case of a licencing decision, there are further review stage after the licence to prepare a site is issued. Once the site is prepared, the proponent is required to apply for a licence to operate the plant. At those further licencing stages, the CNSC would not issue a licence without a chosen reactor and cooling water technology.

60 SWE-EEC, s. 2.0 Existing Environment Characterization Program, p. 2-1

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 41 In contrast, the environmental assessment decision before this Panel will not be revisited at future stages of the project. It is being completed now and will apply to the project throughout its life. Neither the Panel nor the public will have the opportunity to revisit the environmental assessment decision after the reactor or cooling water technology are selected.

Section 4(1)(a) of the CEAA requires the Joint Review Panel to, “ensure that projects are considered in a careful and precautionary manner before federal authorities take action in connection with them, in order to ensure that such projects do not cause signiﬁcant adverse environmental effects”. In order to achieve this purpose, the actual anticipated impacts must be considered by the Panel. Consideration of a bounding scenario does not permit for a careful or precautionary review of the project due to the heavy reliance on estimation and the lack of concrete information.

In addition to providing insufficient information for environmental assessment purposes, reliance on a bounding scenario eliminates consideration of impacts below the most harmful level. For lake filling, the bounding scenario includes consideration of the impact of filling 40 hectares of Lake Ontario. The EA should instead be considering how much, if any, lake fill is absolutely necessary to conduct the project, accounting for need and alternative means. It should then consider whether that amount can be filled without unmitigated harm to the environment. Instead, we are presented with an “all or nothing” approach that puts only the most harmful possibilities before the public and the Panel.

Each of Waterkeeper’s consultants found that the bounding approach negatively impacted their ability to review the EIS. Dr. Henderson summarised: At the time of writing of the Environmental Statement many aspects of plant design that would directly impact the aquatic environment were still undecided. From the aquatic viewpoint the most important decisions relate to the choice of cooling water conﬁguration. ...The variety of possible cooling water options under consideration makes it difﬁcult to focus on the aquatic implications of the proposal and give a clear summary of the impacts.

Potential emissions to air and water have not been identiﬁed and addressed.

Key information missing from the EIS means that it is not possible to conclude that the project will not pollute the air and water. Mass loading calculations, which would indicate how much of each contaminant is actually discharged prior to dilution, are not provided in the EIS. It is not possible to conclude that pollution effects will not be signiﬁcant because the EIS does not include sufﬁcient data on contaminants or measures that will control pollution.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 42 Despite the foundation of the EIS on a bounding scenario, that scenario has not been applied consistently to all areas of the project. If the bounding approach was applied to pollution, all potential contaminants and the maximum potential emission levels would be identified in the EIS. Measures for preventing and controlling those specific emissions would be described and submitted to the Panel for consideration. This point is reflected in the Panel’s question to OPG in IR 18.61 Despite the Panel’s request for a bounding scenario that includes predicted emissions to air and water, OPG states that liquid effluents emissions from the new plant cannot be determined.62

In his review of the EIS, Mr. Dillenbeck found that the availability of water quality data for the site is, at best, poor to fair.63 He notes that, while some statements in the EIS indicate that water quality monitoring on the site has been extensive, other sections show the inaccuracy of this assertion. Stormwater outfalls have not been adequately characterized. Sampling frequency at some locations is not sufﬁcient to allow OPG to respond in a timely way should a deleterious substance be discharged.

In his review of the 2007 - 2008 surface water sampling program, Mr. Dillenbeck noted that not all the data relevant to a thorough review was provided. He notes that, while data is presented for locations as an aggregate, discrete results for each sample taken at each location is excluded from the report. This precludes “within location” analysis that would provide information on the temporal variations at each sample site, and allow for a thorough discussion and interpretation of the results.

The EIS does not even include a range of potential emissions for each technology option. Mr. Dillenbeck identiﬁes this as a major failing of the EIS, asking why potentially harmful substances that may be emitted from the proposed plant could not be identiﬁed on the basis of the plant parameter envelope. Although they cannot be physically sampled before the technology is chosen, OPG must have some idea of the likely contaminant releases from each technology. On this basis, a bounding scenario setting out the highest potential level of each contaminant should be described.

61 Interrogatory 18.

62 Ontario Power Generation, “Technical Support Document 3: Surface Water Environment, Existing Environmental Conditions”, (30 September 2009), s. 4.3.4, p. 4-25.

63 D. Dillenbeck, “Review of Environmental Impact Statement New Nuclear -- Darlington Environmental Assessment”, Prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant EA Process, (1 February 2011) [hereinafter “Dillenbeck, 2011”] at 4.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 43 Data from Darlington NGS and existing CANDU 6 reactors should be used: While OPG claims that contaminants cannot be identiﬁed because the reactor technology at the new plant will differ from what is installed at the adjacent Darlington NGS. That argument is no longer valid due to the inclusion of the CANDU 6 reactor as a fourth reactor technology option. CANDU 6 reactors are in operation in Canada, Korea, Argentina, Romania, and China.64 Data from operating CANDU 6 reactors should be used to establish a baseline of expected emissions.

In addition to data from operating reactors, OPG has a site speciﬁc case study in the form of Darlington NGS. Hydrogeologist Wilf Ruland notes that the opportunity to evaluation plans for a new plant on the basis of data from a real plant on the same site is uncommon. He questions why the EIS does not include more information on the observed effects on ground and surface water at Darlington NGS. This information could provide a starting point to understanding contaminant pathways on the site, regardless of which reactor technology is chosen.

Detailed information is missing in a number of areas key to impacts on Lake Ontario: Waterkeeper and our consultants found information missing with respect to a number of potential efﬂuent streams that could adversely affect Lake Ontario. Without this information, it is not possible to determine whether pollution from this plant will constitute an adverse environmental effect.

Wilf Ruland documented a number of instances where important information is missing from the materials before this Panel:

• Blasting-related contaminants: The EIS indicates that all water contacted by blasting agents will be collected and appropriately disposed of, but no details regarding how this will be done are provided.65 Mr. Ruland notes that contaminants in blasting agents can have signiﬁcant negative impacts on water quality. Details on the collection and disposal plan for this contaminated water are required. Further, the appropriate standards to apply when testing blasting contaminated water should be the Provincial Water Quality Objectives [PWQO’s]. This standard should be made explicitly applicable before any approval is given for this project.

64 AECL, “CANDU 6 Reactors in Operation”, online: .

65 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 5-38, and Response to JRP IR #198.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 44 • Liquid radioactive waste: The EIS indicates that liquid radioactive waste, mingled with non-radioactive contaminants, will be discharged to Lake Ontario after testing and treatment.66 The treatment and discharge criteria are not speciﬁed in the EIS. In Mr. Ruland’s professional opinion, detailed regulatory criteria for this waste stream must be before this Panel. The PWQO’s should be applied.

• Steam generator blowdown: The EIS notes that “intermittent releases of steam generator blowdown” will be tested and treated appropriately. No description of how blowdown will be collected or treated is given. No standards against which the blowdown will be compared or treated to meet are indicated. In Mr. Ruland’s professional opinion, the PWQO’s should be applied.

• Biocides: Regardless of the technology chosen, biocides will be added to cooling water to kill aquatic life that could interfere with the system’s operations. OPG has not provided details regarding the nature of those chemicals, citing the lack of a chosen technology as the reason for not providing detailed information.67 As with blasting-related chemicals, the potential impacts of biocides cannot be properly assessed by this Panel without being identiﬁed and quantiﬁed.

• Sewage: As described above, sewage from the facility will go to the Courtice Water Pollution Control Plant, creating a pathway for contaminants to leave the facility’s control and enter the environment. Further, liquid collected in the ‘inactive drainage system’ (sumps in various buildings) will be discharged to Lake Ontario or sanitary sewer. No discharge standards are supplied with respect to the inactive drainage system. The EIS does not describe the measures that will be used to ensure that no contaminants that cannot be treated at the Courtice plant enter that sewage stream.

These emissions have the potential to affect the environment throughout each phase of the project, from site preparation to decommissioning and storage. Without knowing what may be emitted and in what quantities, a meaningful discussion of potential impacts and mitigation measures cannot be undertaken. Without specifying which regulatory standards will be applied, stating that emissions will meet all regulatory standards is insufﬁcient.

66 Ontario Power Generation, “Technical Support Document 4: Surface Water Environment, Assessment of Effects”, (30 September 2009), Table 3.1-1, p. 3-6.

67 Response to JRP IR #203.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 45 Air dispersion modeling is incomplete and does not reﬂect potential impacts.

This Panel has not been provided with adequate information regarding the site speciﬁc deposition of airborne emissions from the proposed plant. Shoreline fumigation is relevant to the Darlington NNPP Project because the proposed site is on the shoreline of Lake Ontario. Any air emissions from the plant should be evaluated, and mitigation measures should be designed, using site speciﬁc air emissions dispersion modeling. As Dr. Cole explains, “neither the public nor a regulatory agency should accept an environmental impact statement for a shoreline emission source without requiring the application of available models that simulate shoreline dispersion conditions including fumigation”.

Section 11.4.7 EIS Guidelines explicitly requires OPG to consider and provide evidence regarding shoreline fumigation: Modeling incorporating site-speciﬁc atmospheric characteristics (e.g., shoreline fumigation) is to be completed to assess potential inﬂuences on air quality, and the transport of atmospheric contaminants and any associated exposure of humans and non-human biota [emphasis added].

Despite the evidence provided by Waterkeeper and the explicit requirement to consider it in the Guidelines, there is no consideration of shoreline fumigation in the EIS. Dr. Cole explains that s.11.4.7 equally requires consideration of a phenomenon known as “plume trapping”. He states, “[T]hese omissions represent a major ﬂaw in the applicant’s dispersion modeling and environmental assessment”.68

The EIS does not include the speciﬁc information and data required for a complete air dispersion analysis. Dr. Cole found that the lack of source parameters such as source location, stack height, stack diameter, and exit velocity make the EIS incomplete. Concentration estimates and the resulting impacts of shoreline fumigation are not provided with the AERMOD information. The lack of data means that the EIS Guidelines have not been met with respect to air emissions.

There is no evidence in the EIS or TSDs that the climatological impact of Lake Ontario was considered or included in modeling. The lake has a considerable impact on temperature, winds, and the conﬁguration of the internal boundary layer (mixing zone above the surface). These lake effects change pollutant concentrations. As Dr. Cole explains, onshore winds carry emissions towards residents and have a major effect on pollution dispersion.69

68 Cole, 2011 at 2.

69 Cole, 2011 at 3.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 46 The EIS does not indicate whether or how these effects were incorporated into dispersion modeling for the facility. It fails to account for diurnal and seasonal variations in climate, such as warm season lake breezes. Dr. Cole found this to be a signiﬁcant omission because these variations can cause temperature inversions. When warmer air passes over cooler water, as occurs on Lake Ontario in the summer, the air mass becomes stable. Less turbulent mixing occurs in these conditions, such that plumes of fog, steam, or pollutants hang in the air rather than dispersing. Stable onshore ﬂow results in two phenomena that were not adequately considered in the EIS or TSDs: shoreline fumigation and plume trapping.

The model applied by SENES in preparation of the TSDs is not even capable of simulating the effects of shoreline fumigation. No other model was applied, despite the existence of models that speciﬁcally include lake effects and shoreline fumigation, such as the Ontario Ministry of the Environment’s “Shoreline Dispersion Model”. The EIS does not indicate why models that account for shoreline fumigation were not applied, or assess the consequences of ignoring this phenomenon. As Dr. Cole points out, Canadian ofﬁcials (include the Ontario MOE) have been familiar with shoreline dispersion and how to model it for over three decades.70

The EIS does recognize the importance of considering low level emissions brought to the surface via downwashing. However, Dr. Cole found insufﬁcient information to indicate whether chemical concentrations resulting from plume trapping were included in the model. He explains that, unlike shoreline fumigation, AERMOD can evaluate plume trapping. However, it will only do so if the proper inputs are used by the modeler, including the actual mixing conditions on a hourly basis.

Dr. Cole explains that the EIS and TSDs do not provide sufficient information to indicate whether the proper time-dependent, site-specific inputs were used in the model. The EIS does not indicate how the three essential inputs (surface roughness, albedo, and the Bowen ratio) were obtained or whether they accurately reflect site-specific conditions. He gives the example of surface roughness, which the EIS says was calculated with reference to the US EPA’s AERMOD guidance. The TSD omits significant aspects of the EPA guidance, including how surface roughness calculations should reflect site-specific characteristics like the roughness difference between a lake and land.

Further, there is no evidence that OPG considered the impacts of air emissions on the lake. Section 4.2.4 of the EIS (Air Dispersion Modeling) refers to and provides a map of speciﬁc receptors that were selected to represent potentially sensitive areas for the Air Quality Assessment. None of the receptors represent locations in the lake. Dr. Cole notes that

70 Cole, 2011 at 7.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 47 the reference to the site’s meteorological tower also indicates that air modeling, speciﬁcally surface roughness estimates, may have been limited to the land, which is not likely to provide an accurate representation of conditions at the site.

Dr. Cole also notes that the EIS fails to consider the cumulative air emissions of the Darlington NNPP and the Darlington NGS. Cumulative emissions from these facilities, along with the St. Marys cement plant, should be assessed and subject to proper air modeling for this Panel’s consideration.

Sampling parameters must be established based on provincial and federal law.

OPG has consistently failed to identify the regulatory requirements that will be used to determine whether emissions from the Darlington NNPP could impact the environment. The EIS cannot be considered complete until the regulatory criteria to be used in determining acceptability of all discharges are speciﬁed and determined acceptable by this Panel.

At a site visit arranged for Waterkeeper staff and consultants on June 29, 2010, hydrogeologist Wilf Ruland asked OPG staff why the EIS does not include any discharge standards, and whether they could indicate which discharge standards will be applied to the new build. In response, OPG indicated that they will, “meet all applicable standards”. OPG staff would not conﬁrm what those standards might be, whether provincial or federal, binding or voluntary, designed for drinking water or the protection of aquatic life.

The EIS and OPG’s IR responses have been similarly vague: “An underlying assumption in the effects assessment for the Surface Water Environment and Geology and Hydrogeology Environment is that the NND project will be conducted in full compliance with all applicable environmental regulations and standards”,71 and “[A]ll water impacted by radioactive or conventional contaminants, discharged from any liquid stream... to the environment... will be treated as necessary to meet regulatory requirements”.72

As Wilf Ruland points out, “In the absence of commitments to treatment/discharge criteria these assurances are open to question. Speciﬁc treatment/discharge criteria are required

71 Response to JRP IR #195.

72 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 5-38.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 48 for a variety of inorganic, organic, and radiological parameters before the EIS can be considered complete.73

Mr. Dillenbeck explains, “To effectively ascertain whether or not there has been environmental impact in a given situation, it is necessary to establish two elements. First, one must determine the most appropriate component of the environment in which to monitor for impact. Second, one must recognize a threshold, above which, environmental impact will be deemed to have occurred.” Without an established and recognized threshold, sampling cannot indicate whether environmental impact has occurred.

In order for sampling to be an effective means of preventing water quality impacts, all sampling results must be compared to the appropriate provincial and federal standards for water quality. Based on Waterkeeper’s experience, Mr. Ruland’s expertise, and Mr. Dillenbeck’s expertise, the appropriate standards for water quality assessment at Darlington are set out in the Canadian Water Quality Guidelines [CWQGs] and the Provincial Water Quality Objectives [PWQOs].

Mr. Dillenbeck explains that the provincial and federal guidelines have been established for the protection of aquatic life, and their exceedance may impair water quality and endanger aquatic life. Mr. Ruland explains that the PWQOs reﬂect current water quality in Lake Ontario: “Only where no PWQO exists should criteria from other jurisdictions be used”.74

Identifying and applying sampling criteria would clarify which contaminants the EIS should address. Mr. Ruland and Mr. Dillenbeck each note that many potential contaminants are not considered in the EIS.75

Mr. Ruland found that many potential contaminants are not considered at all in the EIS. If OPG is certain that there is no potential for a substance to be found in any efﬂuent streams, they should commit to this in the EIS rather than avoid discussion that substance. If this were done, these substances could be incorporated into monitoring plans designed to conﬁrm the predicted emission level of zero for those substances.

73 Ruland, 2011 at 13.

74 Ruland, 2011 at 8.

75 Table 5.1-1 lists only 16 of the possible 220 parameters addressed by the PWQO’s. Some conventional parameters are included in Table 3.5-1.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 49 Effective water quality monitoring plans are missing from the EIS.

Clearly identifying discharge criteria is the ﬁrst step towards effective water quality monitoring. Once standards have been set, the next step is developing detailed plans for monitoring water quality. Plans are needed to monitor and respond to water pollution during all phases of the project, from site preparation to abandonment.

David Dillenbeck, aquatic biologist, reviewed the EIS in the context of his experience with water quality monitoring and the application of provincial and federal aquatic protection laws. He explains that thorough and properly conﬁgured water quality monitoring, when used in conjunction with established thresholds or criteria to determine impact, provides: “an ideal early warning system. With appropriate monitoring, water quality degradation can be detected long before aquatic biota start exhibiting evidence of environmental stress. The establishment of guidelines “for the protection of aquatic life” by many governments and environmental groups demonstrates the widespread acceptance of this concept.”

It is much more expedient and environmentally protective to monitor water quality and respond when degradation has been detected, than to monitor aquatic populations and respond when a population impact is detected. Mr. Dillenbeck stresses that, “It is important to identify and quantify substances at the point of discharge to the receiving body of water. Initial dilution can signiﬁcantly reduce or even eliminate the possibility of detecting the substance in the receiving body of water.” This approach is consistent with the Fisheries Act, as the prohibition against discharging deleterious substances into water frequented by ﬁsh applies to substances prior to dilution.76

Despite the value of surface water as a warning system for other environmental effects, water quality is an important environmental component in and of itself. CEAA defines Valued Ecosystem Component [VEC] as, “The environmental element of an ecosystem that is identified as having scientific, social, cultural, economic, historical, archaeological or aesthetic importance”.77 Mr. Dillenbeck notes that OPG has not identified any VECs for surface water. Instead, the EIS states that surface water is a pathway for effects on other VECs, and that changes in surface water quality can be used as an indicator of potential effects on other ecosystem components. While monitoring surface water does provide an essential tool to identify general environmental impacts, surface water should be monitored to ensure its own quality is not degraded.

76 Fisheries Act, R.S.C. 1985, c.F-14, s. 36(3).

77 Canadian Environmental Assessment Agency, “Glossary: Part 2. Explanation of Terms”, online: .

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 50 Water quality monitoring programs: The early detection and identiﬁcation of the source of a potentially deleterious substance(s) is essential to ensure the source is eliminated or reduced, and the impact prevented or minimized. This should be achieved through the implementation of a comprehensive water quality monitoring program.

Mr. Ruland points to an inadequate and incomplete water quality impact assessment in the EIS for a project of this magnitude. He emphasizes that it is inappropriate for the EIS to conclude that treatment and mitigation measures will work perfectly, to the point of negligible impacts. Without indicating any details as to how this will be achieved or the regulatory standards that will be used to determine whether an effect is ‘negligible’, this is an unrealistic conclusion.

The reliance on these assumptions increases the importance of a thorough and effective water quality monitoring regime. Yet, the EIS again provides only a plan to have a plan with respect to monitoring many key elements of the project, including: • groundwater quality and groundwater levels; • stormwater ﬂows and stormwater quality; • water quality of a variety of liquid waste efﬂuent streams; and • the Radiological Environmental Monitoring Program (REMP).

The EIS does not list the conventional or radiological contaminants that will be monitored or the frequency of monitoring. The speciﬁc ﬂows and discharges that will be monitored are not indicated.

Mr. Dillenbeck identiﬁed the elements that must be deﬁned to implement an effective water quality monitoring program:

Sampling Sampling locations should be determined based on the location of locations discharges and potential impacts. Locations should be clearly identiﬁed and accompany all monitoring reports.

Sampling Samples should continue to be collected on at least four occasions annually frequency during the ice-free period. Any exceedance of a water quality objective or threshold should trigger additional sampling at the location of the exceedance and any other locations that may be affected.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 51 Sample size Sample size, meaning the number of observations in a data set, has a direct impact on the precision of the estimates and conclusions drawn from the data. Regardless of the sample size, there will always be some margin of error, but that small sample sizes tend to create a larger margin error than when many samples are taken.

The dates and times for all samples taken at the site should be provided to and considered by the Panel in its evaluation of water quality data at the Darlington site. In his review of the “Integrated Lake Ontario Water Quality Sampling Program” undertaken by OPG, Mr. Dillenbeck found that key information about sample size is missing. For instance, It is not clear whether multiple samples in each sampling campaign were collected on the same day or on ﬁve separate dates. If the samples were collected on the same date, they are replicate samples instead of ﬁve separate samples, greatly reducing the actual sample size. The margin of error is higher for a data set with a small sample size.

Analytical The applicable analytical parameters should be determined as part of the parameters design of a water quality monitoring program.

Minimum MDLs represent the minimum level of a substance required for it to be Detection detected. The MDL is not an absolute limit based on technology; it is Limits determined prior to testing and can be set to a more sensitive level (generally for a higher cost). In his experience, Mr. Dillenbeck has encountered [MDLs] instances where the MDL is set higher than the established criteria for a substance. For instance, the MDL is 0.2 ppm, but the establish maximum level for the substance is 0.1 ppm. In such cases, it is not possible to determine whether there has been an exceedance, and the MDL becomes a de facto replacement for the actual environmental standard. Should the project proceed, OPG should be required to test for all substances using an MDL that is equal to or lower than the appropriate environmental standard.

Reporting Water quality should be recorded and reported annually. Each report should frequency pertain to no more than one year of data, and each should be submitted within six months of the end of the sampling period. The program should be conducted for a minimum continuous period of three years. A review of sampling locations and frequency should be undertaken after three years to determine the best way to continue the program, which should not be discontinued for the life of the project.

Data analysis Data analysis methodology should be described as part of the monitoring methodology program to determine how results will be evaluated.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 52 Criteria to CWQO's or PWQO's or most stringent criteria available; When data are assess and presented, whether in a table or a graph, include the criteria, for reference; evaluate the data

Thresholds The monitoring program should clearly describe the threshold(s) for action, who determines when a threshold has been exceeded, what speciﬁc action is to be taken if a threshold is reached, and by whom.

Effective stormwater quality monitoring is essential, and missing from the EIS.

Just as surface water emissions must be monitored and compared to appropriate standards in order to prevent or respond to environmental impacts, a stormwater quality management plan is essential for the Darlington site. According to the EIS, stormwater leaves the Darlington site through a minimum of 22 outfalls, 18 of which empty directly into Lake Ontario as either submerged conduits or direct outfalls.78

The potential for stormwater runoff is particularly high during site preparation and construction, when up to 12.4 million cubic metres of soil and rock will be excavated. Mr. Ruland notes that, for a construction site of this magnitude, it is inappropriate that even basic conceptual stormwater plans and commitments are missing.

Even without a substantive approach to management stormwater, the plans are assumed to be perfectly effective in mitigating stormwater impacts, such that they are screened out of the EIS.79 Mr. Ruland suggests that the track record at Darlington NGS calls this assumption into question.

Stormwater discharge at Darlington NGS has been poorly characterized at a few locations and not characterized at all at most locations. Where the stormwater has been sampled and found to be in excess of the PWQOs or acturely toxic, effective remediation has not been pursued. Mr. Dillenbeck notes that, where sampling of stormwater outfalls was conducted by OPG, data tabulation is not provided and discussion is very limited. Further, even where contaminants of concern were identiﬁed or the stormwater failed daphnia magna acute lethality tests, thorough data was not provided.

78 Ontario Power Generation, “Technical Support Document 4: Surface Water Environment, Assessment of Effects”, (30 September 2009), at 4-18.

79 Ontario Power Generation, “Technical Support Document 4: Surface Water Environment, Assessment of Effects”, (30 September 2009), at C-5 - C-6.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 53 Mr. Dillenbeck emphasizes the importance of monitoring low-volume stormwater emissions, which can have a signiﬁcant impact over time. “It is often the low volume discharges that are overlooked and either not monitored or are inadequately monitored, while the larger volume discharges are more frequently monitored and reported on.”80

Mr. Dillenbeck recommends the establishment of a comprehensive stormwater monitoring program for the Darlington site in order to identify and quantify the potential substances of concern in each discharge. This must be in place prior to the commencement of site preparation and construction, and should be put before this Panel for consideration.

Mr. Ruland identifies five key commitments that should be included in the stormwater plans: 1. Surface water management ponds capable of containing and treating all runoff from the affected area(s) must be constructed prior to site preparation. 2. Best industry management practices should be followed to prevent surface water quality impacts. 3. All surface water management facilities must be able to contain the largest expected regional storm (equivalent to Hurricane Hazel). 4. Stormwater must be retained until confirmed through testing to be of appropriate quality for discharge. 5. Comprehensive surface water quality monitoring (including at least two full seasons of pre-construction baseline data) should be conducted throughout construction to ensure that PWQOs are met for all surface water discharges from the NND property at all times.

Mr. Dillenbeck provides speciﬁc parameters for stormwater management plans for the site: • Samples must be taken at least monthly at each outfall during the ice-free period until a characterization of each discharge has been established. • Where discharge is low or intermittent, sampling should happen as frequently as possible; if necessary, after rainfall. • A review of sampling locations and frequency should occur after year three, at which point sampling could be reduced to bi-monthly or quarterly at a minimum. • As recommended for the surface water quality monitoring program, samples should be tested for routine water chemistry parameters, heavy metals, and organic compounds.

80 Dillenbeck, 2011 at 7.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 54 • For each outfall, a determination should be made of: • total volume discharged monthly and annually, based on measurements taken weekly and during signiﬁcant rainfall events; • loading discharged to Lake Ontario, and an assessment of the impact of the contaminant loads on the water quality in the immediate area of the discharge; and • acute lethality testing (i.e. daphnia and rainbow trout toxicity testing) conducted on at least one occasion for each stormwater outfall and more frequently at any outfalls that may be found to be toxic.

As required for general water emissions, minimum detection limits [MDLs] should be set at equal to or lower than the applicable provincial or federal standard. Data analysis should be conducted in the same way recommended for surface water quality monitoring. Reporting should also follow the recommendations outlined above, including annual reports submitted no longer than six months after the conclusion of testing for that year.

The criteria that should be applied to stormwater discharge are the existing provincial and federal water quality guidelines: the CWQGs and PWQOs, which are set for the protection of aquatic life.

A.2 Are measures available to mitigate or avoid the signiﬁcant adverse environmental effects of this project?

In the section above, Waterkeeper provided details of the signiﬁcant adverse environmental effects anticipated based on the EIS for the Darlington NNPP and potential environmental effects that cannot be ruled out due to missing or insufﬁcient information. In the second part of the test established under the CEAA, this Panel is charged with assessing whether those effects can be mitigated or avoided through the use of alternative means.

Waterkeeper’s expertise, including the expertise of our retained consultants, is weighted towards identifying adverse environmental effects. Based on their experience in their respective ﬁelds, our consultants also have expertise in identifying best practices and alternatives that should be considered when adverse effects are anticipated.

There are mitigation measures and alternative means of carrying out the project that could address most of the environmental effects described above. These alternatives have not been adequately considered in the EIS, but are before this Panel for consideration: • Closed cycle cooling to avoid many effects of once-through cooling; • Moving the CN rail line to avoid lake ﬁll;

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 55 • Alternative reactor and cooling tower conﬁguration to avoid lake ﬁll; and • Recognizing habitat compensation as a last resort.

Closed cycle cooling, used in conjunction with the best available ﬁsh protection technology, could avoid many of the adverse effects associated with once- through cooling.

The ﬁsh habitat and cooling water system experts consulted on this project concluded that once-through cooling is overwhelmingly the most damaging of all the potential cooling options. The volume of ﬁsh that will be impinged, entrained, or impacted by thermal discharges, the effects that radiate through the food web, and the planned continuance of these impacts for up to 85 years make it clear that once-through cooling is not a sustainable option for this site.

Dr. Henderson emphasises, “Given the availability of closed-cycle options using cooling towers which would minimise impacts on Lake Ontario these should be favoured, particularly given the unstable ecological condition of the Lake”. Notwithstanding the potentially signiﬁcant reduction in adverse environmental impacts associated with closed cycle cooling, OPG has scoped it out of the EIS.

Of the options put before this Panel for consideration, cooling towers would have the least impact on Lake Ontario. Doug Howell, fisheries biologist, explains: “because of the dramatically reduced volumes of intake and discharge water and the reduced size and footprint of the structures themselves, any of these [cooling tower] options would have a much lower impact on fish and fish habitat in Lake Ontario”, when compared with once- through cooling.

Despite the lower impact associated with cooling towers, their operation still requires the intake and discharge of lake water to operate. The best technology options for preventing impingement, entrainment, and thermal impacts are still required if cooling towers are selected.

Waterkeeper submits that the alternative cooling technology options have not been given proper weight in the EIS. OPG has expressed a consistent preference for the most destructive option from an aquatic perspective: once-through cooling. It is this Panel’s prerogative to consider all available alternative means of carrying out the project, including closed-cycle cooling and cooling towers with ﬁsh protection technology. The decision with respect to cooling technology should be made on the basis of environmental protection, ruling out the option of once-through cooling.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 56 The existing CN rail line could be relocated to prevent lake ﬁlling.

The rail line that runs through the Darlington property is currently acting as a northern boundary for any new development, despite land north of the rail line that could otherwise be used by OPG. Moving the rail line would allow the proposed location of the reactor buildings to shift further north. This would remove the main impetus for ﬁlling in up to 40 hectares of Lake Ontario.

In response to an inquiry from this Panel regarding moving the rail line, OPG replied that the costs and time delays associated with moving the line were unacceptable.81 OPG states that moving the rail line offsite would require unacceptable amounts of time and money. They cite the additional highway crossings that would be required to move it outside the current property boundary. OPG states that the line could be moved approximately 100 metres north on OPG land, but that the higher elevation of that portion of the site would require more lake ﬁll.

This argument is essentially about cost. OPG has not shown that increased road crossings or excavation would have adverse impacts on the environment, nor that these impacts would be worse than lake filling. The increase excavation that may result does not necessitate lake fill as that material could be moved offsite. Waterkeeper submits that the opportunity to reduce the extent of lake fill by at least 100 metres was not properly weighed in the EIS or OPG’s IR responses.

While the cost and number of administrative requirements associated with moving the line may be greater than with lake ﬁlling, that does not equate with environmental impact. The fact that OPG would save money and avoid inconvenience by disposing of excavated materials in Lake Ontario does not justify that choice in the context of this environmental assessment.

While OPG has declared that moving the rail line would be too expensive and time consuming, the task of determining whether moving the line would have more or less impact on the environment than ﬁlling 40 hectares of Lake Ontario falls to this Panel. The option was not fully canvassed in the EIS, but should be before the Panel for consideration.

The proposed site layout could be reconﬁgured to prevent lake ﬁlling.

There appears to be little consideration in the EIS of any site layout option that does not require the ﬁlling of up to 40 hectares of Lake Ontario. OPG states that they “screened

81 Response to JRP IR #8.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 57 out” any option that does not require lake ﬁll early in the process, instead of putting that decision before this Panel.82

The model plant layout scenarios presented in the EIS show the inﬁll area being used primarily for construction laydown.83 Land area between the lake and the CN rail line is used in part for ofﬁce and support facilities. It is not clear that this function could not be served elsewhere on the property, nor is it apparent that true alternatives were considered in the EIS.

Mr. Howell found that the proposed arrangement of the reactors, regardless of type, has led to a significant impact on the overall site layout and the amount of lake filling. He points out that, in all cases, the reactors have been placed in a linear north-south orientation. If the rail line is not moved from its current location, this linear arrangement results in encroachment on Lake Ontario. Mr. Howell concludes: “Considering that many of the optional conceptual layouts show differing sizes, shapes and configurations for other on-site structures or spaces, it seems that OPG could have considered other configurations for the reactors. If the layout of the reactors could be ‘L’ shaped or oriented in a NE-SW direction, it appears that it should be possible to accommodate all the required development without any, or with only very minimal, lake infilling.”

There is no evidence in the EIS that alternative, non-linear arrangements have been considered by OPG to prevent encroachment on the lake. Nor has any explanation of the need to arrange reactors in a line been offered.

Fish habitat compensation is not mitigation and should be a last resort.

OPG appears to be relying on a fish habitat compensation plan as a key to mitigating the effects of filling in 40 hectares of Lake Ontario. OPG relies on habitat compensation to assert that the infilling will have no residual environmental effects. Mr. Howell cautions that fish habitat compensation plans are created only where the harmful effects on fish habitat cannot be mitigated, and thus should be treated as a last resort.

The development of a ﬁsh habitat compensation plan is not considered a mitigation measure by the Department of Fisheries and Oceans. Their position is that the need for compensation results from the fact that residual negative effects remain after all suitable

82 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-12.

83 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), Figures 2.4-1, 2.4-2, and 2.4-3.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 58 mitigation measures have been incorporated into a project. Implementing a project that has residual negative effects will result in the harmful alteration, disruption, or destruction of ﬁsh habitat [HADD]. The fact that OPG has acknowledged that their proposal will require an authorisation from DFO to create a HADD means that harmful, residual environmental effects will result from lake ﬁlling.

Any lake infilling should be considered a residual environmental effect and the magnitude of that effect should be eliminated or reduced to the extent possible. If any lake filling is deemed necessary and justified by this Panel, it should be limited to areas of low ecological productivity. In such cases, areas of high productivity habitat should be developed to ensure a net improvement in the overall quality or extent of fish habitat.

The full extent of compensation required is not reﬂected in the EIS or Aquatic Environment Compensation Report.

Mr. Howell notes that thermal impacts have not be adequately accounted for in the proposed Aquatic Environment Compensation Report. The discharge of heated water alters or disrupts ﬁsh habitat through both turbidity and temperature change. It constitutes a physical ﬁsh habitat disruption that must be accounted for in any compensation plans required under the Fisheries Act.

It is also not clear that the 40 hectares of lake ﬁll described by OPG includes the 4.62 hectare berm proposed for the construction phase. Nor does it appear to include the two hectare area required for the intake and discharge structures. Mr. Howell stresses that these areas must be accounted for in any compensation plan developed as a result of the project.

Where fish habitat compensation is absolutely necessary, DFO requires compensation in an amount equal to, or often, greater than the area of the loss. As OPG relies on the option to compensate for fish habitat elsewhere, an Aquatic Environment Compensation Report [AECR] was submitted to DFO in August 2010. However, the AECR does not acknowledge the fact that an area larger than what is being lost may be required for compensation. Mr. Howell notes that the AECR should reflect this larger extent of potential compensation area.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 59 A.3 Can the signiﬁcant, unmitigated environmental effects resulting from the project be justiﬁed in the circumstances?

Pursuant to the CEAA, this Panel must consider whether the adverse environmental impacts of this project can be justiﬁed on the basis of need and possible alternatives to the project. Of all the gaps in the EIS, consideration of need and alternatives to the project represents the most glaring omission. The onus of establishing that there is a need for this project and there are no acceptable alternatives to this project rests on the proponent, OPG.

Waterkeeper submits that OPG has not met this onus and has therefore failed to provide justiﬁcation for the adverse environmental impacts of the Darlington NNPP.

OPG limits its submissions on need in the EIS to instructions from the Ontario government to procure two new reactors, using a bounding scenario that extends up to 4800 MW, at the Darlington site.84 This is an insufﬁcient basis for establishing need for the purposes of the CEAA.

The provincial instructions issued to OPG must be considered in the context of the province-wide twenty year energy plan that the Ontario Power Authority is obligated develop. Section 25.30 (1) of the Electricity Act requires the OPA to develop and submit an Integrated Power System Plan [IPSP] to the Board once during each period prescribed by the regulations, or more frequently if required by the Minister or the Board. According to section one of Ontario Regulation 424/04, the OPA shall develop and submit an IPSP and shall submit an update of that plan every three years.

Despite this legal obligation, no IPSP has been approved by the Ontario Energy Board. The initial IPSP prepared by the OPA in 2007 was before the Board in 2008 when the provincial Minister of Energy and Infrastructure, George Smitherman, issued a “Supplemental Directive” requiring the OPA to change aspects of the IPSP. The Board suspended the hearing pending receipt of the updated IPSP. On March 12, 2009, the OPA informed the Board and Intervenors that it would require more time to comply with the Minister’s Directive. No revised version of the IPSP 2007 was submitted, and the hearing was not reconvened.

84 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), s.1.1.3, p.1-3.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 60 In February 2011, the provincial government issued a new Supply Mix Directive to the OPA with instructions to create a new IPSP. That plan will have to go before the Energy Board to be tested and improved before it is approved.

OPA is relying on an untested and unapproved provincial directive to exclude consideration of need or alternatives to the project from this EA process. No deference can be given to a decision of the Ontario Energy Board when no such decision has been rendered. It is possible that, when the most recent IPSP goes before the Board, evidence related to the complete provincial energy system will show that there is no need for this project, or that more appropriate alternatives are available.

It is untenable for this Panel to render a decision without fully considering all the issues set out in the CEAA on the basis of an unapproved and unexamined energy plan.

The adverse environmental effects of the project cannot be justiﬁed based on failings at other sites.

Throughout the EIS, OPG offers justification for the anticipated environmental impacts of this project based on the fact that impacts are higher at other power plants. This is particularly true with respect to fish impacts through impingement, entrainment, and thermal pollution. Waterkeeper submits that a decision under the CEAA cannot be based on comparatively worse impacts at other facilities. Instead, the impacts must be compared to what is achievable using the best available technology. If adverse impacts cannot be mitigated or justified on the basis of need and alternative projects, the project cannot be approved.

Mr. Howell explains that using the track records of older facilities is not a sound basis for determining acceptable impacts from the Darlington NNPP:

“Despite the apparent reduction in ﬁsh mortality (compared to more conventional designs) associated with the intake design employed at DNGS, large numbers of ﬁsh are still being impinged and entrained. Simply changing the scale of the structures to cope with the increased volumes is expected to result in even larger numbers of organisms being impacted. The design of the DNGS structures was developed over 20 years ago. OPG appears to have accepted this design as good enough and it is not evident that they have evaluated any amendments to the DNGS design that may further reduce these losses. They should be required to do so.”

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 61 As Dr. Henderson agrees that fewer aquatic impacts at Darlington NGS is not tenable basis for building a new plant using that thirty year old technology. Not only should OPG strive to improve over past practices as good environmental citizens; this Panel has an obligation under s.4(1) the CEAA to ensure that the project does not cause signiﬁcant adverse environmental effects, and to take actions that promote sustainable development and thereby achieve or maintain a healthy environment and a healthy economy. This obligation cannot be met by ensuring a base level of environmental performance commensurate with existing plants, some of which have been operating for decades.

At a recent hearing regarding the relicensing of Pickering A Nuclear Generating Station, the Commission asked OPG staff why the company had not acted sooner to stem fish kills through entrainment and impingement at that plant, when the problem has been apparent throughout the life of the plant. An OPG representative responded, “There has been changes in expectations over the past number of years with respect to fisheries driven in part by changes in U.S. legislation that’s been proposed”.85 As this panel considers a brand new nuclear installation that could sit on the shore of Lake Ontario for the next 85 years, it must not accept OPG’s assertion that matching the fish impacts of other plants is sufficient.

B. Should this project be granted a Nuclear Safety and Control Act licence to prepare the site?

OPG has applied for a licence to prepare the site pursuant to the Nuclear Safety and Control Act [NSCA]. Preparing the site includes clearing the area, excavating up to 12.4 million cubic metres of soil, installing water monitoring and mitigation measures, clearing vegetation, and grading the site. The licence would include authorisation to ﬁll up to 40 hectares of Lake Ontario, as this is considered part of both the excavation and “ﬂood control and shoreline protection”.86

OPG must return to the CNSC for a licence for the latter stages of this project. However, that does not diminish the importance of this licencing decision. Major impacts on the environment, including water quality and ﬁsh habitat, are covered by the licence to prepare the site. Those making future licencing decisions may not have the beneﬁt of a full public hearing. They will not have the opportunity to consider the licence applications in the

85 Canadian Nuclear Safety Commission, Transcript: “Public Hearing, Ontario Power Generation Inc.: Application for the renewal of the Pickering Nuclear Generating Station Licence”, (21 May 2010) at 120.

86 CNSC, “Brieﬁng Note to Commission Members, Environmental Assessment and Licence to Prepare Site” (24 March 2010), online: .

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 62 context of an environmental assessment. This Panel has the opportunity to reach a licencing decision based on evidence and scientiﬁc expertise that will not be available to future decision-makers.

B.1 Will OPG, in carrying out the activity, make adequate provision for the protection of the environment?

Waterkeeper submits that OPG has not demonstrated adequate provision for the protection of the environment with respect to the Darlington NNPP. As described in section A.1 of this submission, the potential adverse environmental impacts are signiﬁcant and may cause lasting ecological degradation. Those impacts have not been adequately addressed in the EIS, as evidenced by the extensive list of missing information identiﬁed by our consultants. Potential mitigation measures and alternative means of carrying out the project have not been thoroughly assessed. The seriousness of the potential impacts, combined with the lack of detailed plans to address those impacts, indicates that OPG is not prepared to make adequate provision for the protection of the environment.

Instead of providing detailed information on these potential adverse environmental effects to the Panel and addressing how they might be mitigated or avoided, the EIS repeatedly says that standards will be met. This commitment is insufﬁcient evidence to put before a federal Review Panel conducting an environmental assessment for a project of this magnitude.

The lack of speciﬁed regulatory standards is particularly concerning in light of OPG’s application of “Good Industry Management Practices” instead of best practices. The EIS indicates that the precautionary principle, industry standards, and best practices were applied throughout the preparation of the EIS.87 In contrast, the EIS indicates that only Good Industry Management Practices [GIMPs] will be applied during the project.88 Mr. Ruland advises Waterkeeper that GIMPs should not be the standard used at this site; instead, the precautionary principle and best industry management practices should be applied through the life of the project.

The adverse impacts on Lake Ontario from once-through cooling and lake ﬁll are established. Potential impacts from pollution, adjacent land uses, and improperly

87 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 3-20.

88 Ontario Power Generation, Environmental Impact Statement for the New Nuclear at Darlington Project, (30 September 2009), at 2-28, 2-29, 2-32, 2-39, 2-57, 2-64, 2-80, 3-18, 3-23, 4-174, 5-18, 5-20, 5-38, 5-74, 5-87, 5-112, 5-116, 5-191, Table 5.15-1, 8-79, and 12-21.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 63 managed waste have not been addressed in the EIS. Plans to prevent erosion, dust, and stormwater impacts during site preparation and construction have not been prepared. Adequate measures to mitigate or avoid those effects are not evidenced by the material supplied by OPG. OPG has not met the onus of proving that they have, and will continue to make, adequate provision for the protection of the environment.

B.2 Are any terms or conditions on the licence necessary for the purposes of the NSCA?

Waterkeeper submits that OPG has not shown that the environment will be adequately protected, so that a licence to prepare the site should not be issued by this Panel.

If a licence is issued to OPG, terms and conditions must be included to minimize the adverse environmental impacts of the project. This Panel has the opportunity to ensure that recommendations made in the environmental assessment decision are binding on OPG in the form of terms and conditions. Waterkeeper submits that all recommendations made by this Panel related to environmental protection should be reﬂected as terms and conditions if a licence is issued.

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 64 ______CONCLUSION

The project cannot be approved or licenced as planned without causing irreparable harm to Lake Ontario.

This project will result in significant adverse environmental effects that will not be mitigated and cannot be justified. Once-through lake water cooling is the most ecologically destructive cooling option available. Filling in the lake with excavated material will destroy fish habitat and cannot be justified on the basis of economics or disposal convenience. Pollution from cooling water, air emissions, water emissions, and waste pose a threat to the lake that has not been addressed in the EIS.

The seriousness of the potential impacts, combined with the lack of detailed plans to address those impacts, shows that OPG is not prepared to make adequate provision for the protection of the environment.

OPG has not met the onus of proving that the new nuclear power plant will not adversely impact the environment in any way that cannot be mitigated or justiﬁed. OPG has not proven that it has made, and will continue to make, adequate provision for the protection of the environment. OPG has not discharged its burden under the CEAA or the NSCA. The Darlington NNPP should not be licenced or approved by the Panel.

ALL OF WHICH IS RESPECTFULLY SUBMITTED THIS 21st DAY OF FEBRUARY, 2011.

______#######Mark Mattson #######Counsel for Lake Ontario Waterkeeper #######410 - 600 Bay Street #######Toronto, ON M5G 1M6 #######Tel: 416-861-1237 #######Fax: 416-850-4313

600 Bay Street, Suite 410 Toronto, ON M5G 1M6 416-861-1237 [email protected] www.waterkeeper.ca Proud member of Waterkeeper Alliance 65 APPENDIX A

Expert Reports prepared for Lake Ontario Waterkeeper with reference to the Darlington New Nuclear Power Plant Project

A.1: ! P. A. Henderson, “Comments on aquatic issues relating to the proposed New ! Nuclear Darlington (NND) power plants” (October 2010).

! R. Seaby & P. Henderson, “Notes on the Guidelines for the EIS for Darlington B ! nuclear power plant” (November 2008).

" Curriculum Vitae, Dr. P.A. Henderson

A.2: ! Dr. H.S. Cole, “Review of Technical Support Documents pertaining to the potential ! impact of the Darlington Nuclear Facility air emissions on ambient air quality” ! (February 2011).

" Curriculum Vitae, Dr. H.S. Cole.

A.3: ! H. D. Howell, “Review of Fish Habitat Related matters in the Environmental Impact ! Statement and associated Technical Support Documents” (January 2011).

" Curriculum Vitae, H. D. Howell.

A.4: ! W. Ruland, “Independent Review of Hydrogeological Issues Pertaining to the OPG ! Environmental Impact Statement for the Proposed Darlington New Nuclear Plant ! Project” (February 2011).

" Curriculum Vitae, W. Ruland.

A.5: ! D. Dillenbeck, “Review of Environmental Impact Statement New Nuclear -- ! Darlington Environmental Assessment” (February 2011).

" Curriculum Vitae, D. Dillenbeck. " APPENDIX A.1

! P. A. Henderson, “Comments on aquatic issues relating to the proposed New ! Nuclear Darlington (NND) power plants” (October 2010).

! R. Seaby & P. Henderson, “Notes on the Guidelines for the EIS for Darlington B ! nuclear power plant” (November 2008).

" Curriculum Vitae, Dr. P.A. Henderson !

! ! ! ! ! ! !

"#$$%&'(!#&!)*+)',-!,((+%(! .%/)',&0!'#!'1%!2.#2#(%3!4%5! 4+-/%).!6)./,&0'#&!74468!2#5%.! 2/)&'(! 3K!WK!;/$%/05#$!

! ! ! ! ! ! ! ! "#$%&'(!)*!+,-#./0!1)2)! ! 345,/5!6#$5/07&-4#$!8-%! 9:6!;#<5/! =>/!?@<&0/! 3/$$4$A-#$! 8'B4$A-#$! ;&BC5>40/! ?+*2!DEF! GH! ! C45,/5IC45,/5J,#$5/07&-4#$K,#B! ! LLLK40,>#<5/K%/B#$K,#K#$/N! **!O)P!2QR)!ST*)))! U&V! **!O)P!2QR)!STQQRR! !

"#$%&$%'!

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

!"#$%&'%"()*%'+,-.$)*"/.01"2343" $$$" " !

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• O*&'J.6+)7@6">-M'"=-.'+"&))>$*@R"" • <-.7+->"0+-;."&))>$*@".)='+%R"" • N-*J-%%$%.'0"*-.7+->"0+-;."&))>$*@".)='+%R"" •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

2" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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•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b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

5" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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

5" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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

2B" J6'" *'N." 8','8" )<" .6'" &6-$*" $%" >-0'" 79" )<" %>-88" O))98-*?.)*1" =6$&6" $*&870'" &)9'9)0%1"9+).)O)-*%1"&8-0)&'+-*%1"->96$9)0%"-*0"+).$<'+%B""

PB" Q-&+)$*,'+.':+-.'%" <)+>" .6'" .6$+0" 8','8" )<" .6'" &6-$*B" K>9)+.-*." 0''9=-.'+" >-&+)$*,'+.':+-.'%" $*&870'" !"#$%&"'" %99B" F-*" ->96$9)0G1" >;%$0%1" =)+>%" -*0" >$0@'%B"R6-88)="=-.'+"0='88'+%"$*&870'"8''&6'%1"&8->%1"%*-$8%"-*0"$*%'&."8-+,-'B""

SB"I$%6'%"%7&6"-%"-8'=$,'%1",-+$)7%"%6$*'+%"-*0"8-?'"6'++$*@"<''0")*"98-*?.)*B""

TB"U.6'+"<$%6'%1"8$?'"8-?'".+)7.1"<''0")*"98-*?.)*1">-&+)$*,'+.':+-.'%"-*0"<$%6'%B" L'*'+-88;1"V7,'*$8'%")<"8-+@'")+">'0$7>M%$O'0"<$%6'%1"8$?'"%-8>)*"-*0";'88)="9'+&61" <''0">-$*8;")*"98-*?.)*"-*0">-&+)$*,'+.':+-.'%"7*.$8".6';"@+)="8-+@'"'*)7@6".)" '-."%>-88"<$%6'%B"R>-88"<$%6'%"9+),$0'">7&6")<".6'"<))0"<)+"8-+@'+"<$%6'%B""

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

5" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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

" " "#$%&'!(!)*'!+&',-!.,/'0!1223!4'5!6!,77'00'3!8'9-':5'&!;<(>444?%409?'3%>$'2>1,7%@-A>&#--'&>$'2$(<(>-'B-522/>5#2$'2$&,9*A>-&29*#7C@'D '@0C,E3C1223C7*,#E0?*-:@!!

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°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

43" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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

"#$#$ %&'()*+!,)-*./0!12!-+*2/0! J','+-6"%.A0$'%":-,'"%:)D*".:-."%5'&$'%"0$,'+%$.C")>"5:C.)56-*7.)*"0'&+'-%'%"$*" -+'-%"&)*%$%.'*.6C":'-.'0".)"),'+"K3"L("M?$0"N3%"OP8"" " 9:'"-,-$6-@6'"0-.-"D)A60"%A=='%.".:-."5:C.)56-*7.)*"5+)0A&.$,$.C"-%"?'-%A+'0"@C" (-+@)*"-%%$?$6-.$)*"+-.'%"0'&6$*'%"D$.:"$*&+'-%$*=".'?5'+-.A+'%"-@),'"-@)A."23" L(8" 9:'" >)66)D$*=" =+-5:" >+)?" /-*=>)+0" M4QQ3P" %:)D%" .:'" +-5$0" 0'&6$*'" >)+" 5:C.)56-*7.)*"$*"6-7'%8" "

!"#$%&'%"()*%'+,-.$)*"/.01"2343" 44" " "" "

5*"-00$.$)*".)"0-6-7'".)"89-*.%"':8)%'0".)";$7;".'68'+-.<+'%"=<+.;'+"->-?"=+)6" .;'"0$%&;-+7'".;'+'"$%".;'"8)%%$@$9$.?".;-."8;?.)89-*A.)*"@9))6%">$99"0','9)8B"C)+" ':-689'" $*" .;'" ()**'&.$&<." D$,'+" *'-+" .;'" E-00-6" F'&A" *<&9'-+" 8)>'+" 89-*." 8;?.)89-*A.)*" 7+)>.;" $*&+'-%'0" 0)>*%.+'-6" )=" .;'" 89-*.B" G9))6%" )=" !"#$#%#&'(&" -*0" )*"+,"-&.*&" >'+'" -%%)&$-.'0" >$.;" .;'" 0$%&;-+7'" -*0" >'+'" $*&+'-%'%">'+'"0'.'&.-@9'"2"A6"0)>*%.+'-6B" "

!"#"$ %&'&()*+,&)-.(&/+0,+-1&+(&/20'/&+0,+,3/1+-0+-&42&()-.(&+ H"=$%;"9$,'%"$66'+%'0"$*"-"9$I<$0"J>-.'+K")="+'9-.$,'9?";$7;".;'+6-9"&-8-&$.?1"-*0">$99" 7-$*";'-."I<$.'"+-8$09?"@?"&)*0<&.$)*"-&+)%%"$.%"'*.$+'"@)0?"%<+=-&'B"L)+'),'+1"$." 6<%." 8-%%" .;$%" =9<$0" ),'+" $.%" 7$99%1" -*0" $*" &)*%$0'+-@9'" ,)9<6'%" %$*&'" .;'" &)*&'*.+-.$)*")="):?7'*"$%"&)68-+-.$,'9?"9)>B"M$99%"-+'"+$&;9?"%<889$'0">$.;"@9))0" -*0";-,'"-"%<@%.-*.$-9"%<+=-&'"-+'-".)")8.$6$N'"7-%"':&;-*7'B"O;'%'"='-.<+'%"-9%)" 6-A'" =)+" '==$&$'*." ;'-." ':&;-*7'" -*0" .;'" @9))0" +-8$09?" 0$%.+$@<.'%" ;'-." .;+)<7;)<.".;'"@)0?"J(+->%;->1"4PQPKB"" "

42" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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°(;"Q$%C"B$99".C'+'I)+'"-..'8A." .)" -,)$0" %.+'%%I?9" .'8A'+-.?+'%" <=" -&.$,'9=" %''F$*7" B-.'+" -." .C'" A+'I'++'0" .'8A'+-.?+'1"'&.1"I+)8".C'"8)9'&?9-+".)"BC)9'")+7-*$%8"9','91"B-%".C-.")I"^)%'":4GUH@;" VC'"+'%A)*%'")I"I$%C".)".'8A'+-.?+'"$%"&)8A9'O;"Q$%C"C-,'"*-.?+-9".C'+8-9"*$&C'%" :A+'I'+'*0-@"-*0"$*".C'".'8A'+-.'"K)*'"I+'%CB-.'+"%A'&$'%"-+'"'$.C'+Z" cold water species, such as salmon, trout, tomcod & smelt; cool water species; warm water species, such as carp; VC$%"&-.'7)+$K-.$)*".'*0%".)"I-99"-9)*7".-O)*)8$&"9$*'%"$*".C-."+'9-.'0"%A'&$'%"-*0" 7'*'+-"C-,'"%$8$9-+".C'+8-9"*$&C'%":E)F-*%)*1"4GHH@;"(C'++="$!"%&'":4GHR@"I)?*0" .C-.".C'"%.'*).C'+8-9"%-98)*$0%"C-0".C'"*-++)B'%.".'8A'+-.?+'".)9'+-*&'"+-*7'%" )I"-99".C'".'9')%.%"BC$&C".C'="%.?0$'0;" "

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survival, growth and metabolismA"

!"#"$ %&'(&)*+,)&-*./-/011234&/-5*1&1- L*0$+'&." '=='&.%" )=" .'98'+-.7+'" )*" =$%:" $*&;70'" +'07&'0" %);7>$;$.<" )=" @-%'%1" 8-+.$&7;-+;<" )=" )E<@'*1" -*" '=='&." ?:$&:" &-*" >'" 'E-&'+>-.'0" ><" .:'" ';',-.'0" .'98'+-.7+'"%$97;.-*')7%;<"$*&+'-%$*@".:'"+-.'")=")E<@'*"+'9),-;"><"8);;7.-*.%" %7&:"-%"%'?-@'A"M:'"%)+.")=".'98'+-.7+'"';',-.$)*%".:-."-+'"'*&)7*.'+'0")7.%$0'" .:'"$99'0$-.'",$&$*$.<")="-"8)?'+"%.-.$)*"0$%&:-+@'"-+'")=">'.?''*"4°"-*0"N°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°(" D6*<0'+1" 4U[UFA" \" %$9$;-+" '=='&." ?-%" =)7*0" ><" ()7@:;-*" D4UZ3F" $*"*+,-$.)+,+%"I';.%"?:'*" 9-$*.-$*'0"$*"%78'+%-.7+-.'01":'-.'0"%'-X?-.'+"D#+"4N°(F"=)+".?)"9)*.:%A"

!"#"6 %7&)'*3-+23&)*.8&-29-9017-1(&80&1-- M:'"'=='&.%")=".'98'+-.7+'")*".:'">$);)@<"-*0"'&);)@$&-;"+']7$+'9'*.%")="=$%:":-,'" >''*" 'E.'*%$,';<" %.70$'0" -*0" +',$'?'0A" M'98'+-.7+'" &-*" -=='&." %7+,$,-;1" @+)?.:" -*0" 9'.->);$%91" -&.$,$.<1" %?$99$*@" 8'+=)+9-*&'" -*0" >':-,$)7+1" +'8+)07&.$,'" .$9$*@"-*0"+-.'%")="@)*-0"0',';)89'*.1"'@@"0',';)89'*.1":-.&:$*@"%7&&'%%1"-*0"

45" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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`'"$%":$,'*".8'",-9>'%"-+'"?)+"-0>9.%<"\'*'+-99;";)>*:"-*0"%6-99"?$%8" -+'"6)+'",>9*'+-@9'".)"'9',-.'0"C-.'+".'67'+-.>+'%".8-*"-0>9.%<""

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

78987 ,12*:' .-#2%$)+' !*3;%#&' 1+' *:#' *#-"#2)*32#' &#+&%*%<%*=' 1>' &)/-1+%;&' B'&-8%'")I".>'$+"<'*'+-C"%'*%$.$,$.7".)".'=6'+-.8+'"-*0".>'$+"'&)*)=$&"$=6)+.-*&'" %-C=)*$0%"-+'")*'")I".>'"I'G"I$%>"<+)86%"-?)8."G>$&>"G'">-,'"<))0"$*I)+=-.$)*" )*".>'$+"+'%6)*%'".)".'=6'+-.8+'@"O."$%"C$E'C7".>-.".>'"+'%6)*%'")I"%-C=)*"G$CC"?'" $*0$&-.$,'")I"&)C0"G-.'+"I)+=%"I)8*0"$*".>'"S+'-."/-E'%@"" " HC.=-**" T" U$..='+" V4W55X" C$%.1" I+)=" .>'$+" +',$'G1" 866'+" .'=6'+-.8+'" .)C'+-*&'%" I)+"%-C=)*$0%")I"2L°("V@A+*,-,$"-*0"@A+'$)'',"6+)C-+,-'"T"6)%.C-+,-'X"-*0"25°("I)+"@A+ '$)''," -C',$*%" V-&&C$=-.$Y'0" -." 23°(XZ" 866'+" .'=6'+-.8+'" .)C'+-*&'%" I)+" 96#%$1;6#1)*"%6'&$'%"G'+'"2;:2A°("I)+"?).>"[8,'*$C'%"-*0"-08C.%"V-&&C$=-.$Y'0"-." 23°(X@"S'*'+-CC71".>'$+"0-.-"$*0$&-.'".>-."\)+.>"H='+$&-*"%-C=)*$0"-08C.%".)C'+-.'" %C$<>.C7" >$<>'+" .'=6'+-.8+'%" .>-*" 0)" .>'$+" [8,'*$C'%" V&)*.+-+7" .)" .>'" I$*0$*<%" )I" HC-?-%.'+"V4W59Z"4W5;X"-*0"HC-?-%.'+"T"U)G*$*<"V4W55X"G>)"I)8*0"7)8*<"%.-<'%"

45" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

&)670" 89$.:%.-*0" %);'9:-." :$<:'+" .';='+-.6+'%" .:-*" -067.%8>" ?:'" ;-@$;6;" .';='+-.6+'"-."9:$&:"!"#$%&%'"'<<%"9$77":-.&:"A$*"'@='+$;'*.-7"&)*0$.$)*%B"$%"43°(>" C+'.."()#%&""A4DEFB"%:)9'0".:-."%6%.-$*'0"%9$;;$*<"%=''0")G".:'"%)&H'I'"%-7;)*" A*+,-'./+,.0$# +('1%B" 9-%" )=.$;6;" -." 4E°1" 0'&+'-%'0" =-%." 23°-*0" +-=$07I" -==+)-&:'0" .:'" 7'.:-7" 7$;$." -." 2E°(>" J'" KI7,-" A4DLDB" &)*&760'0" -*" 6=='+" 7'.:-7" 7$;$."G)+"8;)%."G$%:'%8")G"MM°(1"N6."+'&);;'*0'0".:-."-"+'-7$%.$&"&)*%.+-$*."7','7" %:)670" N'" ='+:-=%" 2°(" N'7)9" .:$%>" K=--%" A4DL3B" G)6*0" .:'" .';='+-.6+'" 7','7%" 867.$;-.'7I"7'.:-7"8".)"%-7;)*$0%"9'+'"&7)%'".)"M3°(>" " C)6&H"A4D55B"%.-.'0"8#'+:-=%"*)").:'+"%$*<7'"=-+-;'.'+":-%"%6&:"-"0'.'+;$*$*<" 'GG'&." )*" -" G$%:'+I" -%" 0)'%" $.%" 9-.'+" .';='+-.6+'8>" O*-0+);)6%" %-7;)*$0%" G''0" ,'+I" 7$..7'" 06+$*<" .:'$+" %=-9*$*<" +6*1" %)" $*&+'-%'0" .';='+-.6+'" 7'-0$*<" .)" $*&+'-%'0";'.-N)7$&"+-.'"+'%67.%"$*"$*&+'-%'0"9'$<:."7)%%"06+$*<";$<+-.$)*"P")*&'" G-."+'%'+,'%"-+'"6%'0"6=1";6%&7'"$%"&)*,'+.'0"G)+"'*'+"C)6&H"()#%&""A4D5LB"H'=." -067." %)&H'I'" %-7;)*" A*+,-'./+,.0$# +('1%B" -." 43°(" -*0" 4L>E°(Q" 8R,'+" .:'" .'%." ='+$)08"A6*%='&$G$'0B".:'"G)+;'+"7)%."-*"-,'+-<'")G"5>ES")G"N)0I"9'$<:."-*0"%.$77" :-0" %);'" G-." +'%'+,'%" 7'G.T" .:'" G$%:" -." .:'" :$<:'+" .';='+-.6+'" 7)%." 42S" )G" N)0I" 9'$<:.1"9$.:"8,$%$N7'"G-."+'%'+,'%"'%%'*.$-77I"0'=7'.'08>"?:'".'%.'%"9'+'";)+'".:-*" 2ES" %;-77'+" -." 4L>E°".:-*"-."43°1" -*0" '<<%" 9'+'" %;-77'+" -*0" 7$<:.'+1" %:)9$*<" -" &)++'7-.$)*"9$.:"N)0I"9'$<:.>" " U-6<<" ()# %&"" A4D52B" G)6*0" .:-." -." .';='+-.6+'%" !4M°(" V6,'*$7'" %-7;)*" -*0" %.''7:'-0"8:-,'"0$GG$&67.I";-H$*<".:'"=-++P%;)7.".+-*%G)+;-.$)*8>"W'0'+;'I'+"()# %&"" A4DF3B" &)*&760'" .:-." .';='+-.6+'%" !4M°(" $*:$N$." %;)7.$G$&-.$)*" $*" N).:" *"2/13$$" -*0" !"$%&%'Q" !"$%&%'" %:)9" <+'-.'%." 0)9*%.+'-;" ;$<+-.$)*" +6*%" -%" .:'" .';='+-.6+'"+$%'%".)"43°(1"-*0"%;)7."+6*%"-+'"),'+"N'G)+'".:'"9-.'+"9-+;%".)" 4E°(" )+" ;)+'>" X6+.:'+1" -." '7',-.'0" .';='+-.6+'%" A-%" ;-I" N'" '@='+$'*&'01" G)+" '@-;=7'1"$*":-.&:'+$'%"-..';=.$*<".)"-&&'7'+-.'"<+)9.:B1"N).:"&):)"-*0"&:$*))H" %-7;)*"6*0'+<)"-"+','+%$)*".)"=-++"&)*0$.$)*"A0'%;)7.$G$&-.$)*B"AW'0'+;'I'+"()# %&"1"4DF3"-*0"+'G'+'*&'%".:'+'$*B>"

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°QP" R3CL°(ST1" 8$9+-.$*9" %->8)*" -%&'*0$*9" +$,'+%" P%'>'&.'0P" .<'" %.+'-8" B$.<" .<'" >)B'+" .'8A'+-.7+'U" .<$%" &)*&>7%$)*" B-%" 8-0'" B<$>'"7*-B-+'")=".<'"$8A)+.-*&'")=").<'+"=-&.)+%"%7&<"-%"=>)B"$*"%.+'-8"%'>'&.$)*C" 6)+'"+'&'*.>:1"6-V)+"W"6$9*'>>"?4ELL@");%'+,'0".<-."-07>."+"#,*'-%"8$9+-.$*9"7A" .<'"()>78;$-"X$,'+"B)7>0"*)."'*.'+".<'"YJ-9)*"X$,'+"B<'*".<'".'8A'+-.7+'")=" .<'">-..'+"'Z&''0'0"24°(C" " [)*%%)*"?4EE4@"%<)B'0".<-.".<'"$*$.$-.$)*")="0)B*%.+'-8"8$9+-.$)*"$*"%->8)*$0%" ?$*&>70$*9"\.>-*.$&"%->8)*"-*0".+)7.@"B-%"0'A'*0'*.")*"B-.'+".'8A'+-.7+']"-%".<'" .'8A'+-.7+'" +)%'" .<+)79<" 43°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`)+B-:1" $=" B-.'+" .'8A'+-.7+'%" B'+'" ;'>)B" 5°(U" N>%)*"?4ELE@"=)7*0".<-."+$,'+"-%&'*.";:"!"#$%&%'"$*".<'"`)+.'.<->".'8A'+-.7+'1"%''"-;),'@C"D-BJ$*%"?4E5E@"=)7*0".<-." A).'*.$->>:"7A8$9+-.$*9"!"#$%&%'"+'8-$*'0"$*".<'"%'-")==".<'"XC"c''1"^&).>-*01"B<'*" +$,'+"B-.'+".'8A'+-.7+'"'Z&''0'0"23°(C" " ^7&<" .'8A'+-.7+'" >$8$.-.$)*%" <-,'" d))9')9+-A<$&" $8A>$&-.$)*%C" #)B'+" ?4E54@" %<)B'0"<)B"&>$8-.$&"&)*0$.$)*%"0)B*".<'"'-%.'+*"&)-%.")="`)+.<"\8'+$&-"+'%7>."$*" .'8A'+-.7+'" &)*%.+-$*.%" )*" 8$9+-.$)*" +7*%U" .<'" *)+.<'+*8)%." A)A7>-.$)*%1" $*" e7';'&1" <-0" -" %8->>" ?4M2" 8)*.<%@" 8$0%788'+" B$*0)B" )=" )AA)+.7*$.:" =)+" 8$9+-.$)*"$*">-.'"%788'+1").<'+".$8'%")=":'-+";'$*9".))"&)>0U".<$%"P.'8A'+-.7+'" B$*0)BP" B$0'*%" =7+.<'+" %)7.<1" .)" %)8'" L" 8)*.<%" $*" `),-" ^&).$-1" 7*.$>" $*" ()**'&.$&7." 8$0M%788'+" .'8A'+-.7+'%" $*" .<'" +$,'+" ?-*0" %'-@" -+'" .))" <$9<1" +'%7>.$*9"$*".B)"+7*%")="%.)&J1")*'"'-+>:"%A+$*91")*'">-.'"-7.78*C"

45" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

" ()*,'+%'67".)".8'"9'*'+-6"$:;+'%%$)*".8-."%-6:)*$0%"-,)$0"8'-.'0"<-.'+1"=;$9-+'66$" >" ?8)::'%" @45A5B" &)*&6C0'0" %.+)*9" @-6D'$." &$+&C:%.-*.$-6B" ',$0'*&'" E)+" .8'" -..+-&.$)*")E"!"#$%&''".)"-".8'+:-6";6C:'"$*"/-F'"G$&8$9-*H"IJC-6671"-"*C:D'+")E" %.C0$'%" 8-,'" D''*" +';)+.'0" <8'+'" -" 0$EE'+'*&'" $*" .':;'+-.C+'" D'.<''*" .<)" <-.'+"D)0$'%"8-%"8-0"*)"'EE'&.")*".8'":$9+-.$)*")E"%-6:)*$0%"D'.<''*".8'".<)" @%''"K-*F%1"45L51"E)+"6$%.BH"

"#$#% &'()*+',-!*-.!/0*+0.!.'12/*)(01! ()C.-*." @45LMB" E)66)<'0" %):'" A3" +-0$)N.-99'0" !()*+,$(),-'" %;'&$'%" $*" .8'" O-*E)+0" P'-&8" )E" .8'" ()6C:D$-" P$,'+1" <8'+'" .8'" O-*E)+0" QC&6'-+" P'-&.)+" 0$%&8-+9'%" -" 8'-.'0" ;6C:'1" -*0" E)C*0" .8-." .8'" -0C6." E$%8" :)%.67" :$9+-.'0" C;%.+'-:"$*"%8-66)<"<-.'+")*".8'");;)%$.'"%$0'")E".8'"+$,'+1"-,)$0$*9"-*7".8'+:-6" D-++$'+H"O)<','+1"Q-F-.-*$"@45L5B"E)C*0"-0C6."+-$*D)<".+)C."-*0"&8$*))F"%-6:)*" C;N:$9+-.$*91"-*0".8'"6-..'+"%;-<*$*91".)<-+0%".8'"+'-&.)+"%$0'")E".8'"+$,'+H" " O'"0$0"E$*01"E+):"6-D)+-.)+7ND-%'0"'R;'+$:'*.%1".8-.".8'";'+&'*.-9'":)+.-6$.7")E" &8$*))F" 7)C*9" $*&+'-%'0" <$.8" $*&+'-%'0" S?1" -%" 0$0" .8'$+" +-.'" )E" 9+)<.8T" .8'" .':;'+-.C+'" +'%;)*%'" -;;'-+'0" :)+'" +'6-.'0" .)" -D%)6C.'" .':;'+-.C+'" .8-*" .)" .8'" S?1" U%$9*$E$&-*.U" @V23WB" :)+.-6$.$'%" )&&C++$*9" -." .':;'+-.C+'%" 9+'-.'+" .8-*" 4A°(H" X)<*N:$9+-.$)*" )E" 7)C*9" )&&C++'0" E+):" G-+&8" @E+7" -*0" 3N9+)C;B" .)" YC67" @%:)6.%BT"-"6)<'+"S?")*"<-.'+".':;'+-.C+'%"-.".8$%".$:'")E"7'-+"@)E"L".)"4ZHZ°(B" .)9'.8'+"<$.8".8'"$*&$0'*&'")E"-"7'-+67"E+'%8'."@6-.'"G-7N'-+67"YC*'B"-;;'-+'0".)" :$*$:$['"-*7"'EE'&.%"-.".8-.".$:'H"?8'"S?"E+):".8'"+'-&.)+%"<-%"U&6-%%$E$'0U1"DC." -;;'-+%".)"8-,'"D''*"C;".)"4A°(H" " ?8'"+$,'+"$%"<$0'"@).""Z33":B"-*0"&):;-+-.$,'67"0'';"@-D)C."42":BT".8'"<-+:'+1" -*0".8'+'E)+'"6'%%"0'*%'1"<-.'+"<)C60"8-,'"D''*"-.".8'"%C+E-&'"N").8'+";6-*.%")*" 6-+9'"Q)+.8"\:'+$&-*"+$,'+%"%8)<"-"0+);")E"M".)"43°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

!"#$%&'%"()*%'+,-.$)*"/.01"2343" 45" " 5)6*%'*" 74893:" %.;0$'0" .6'" <),'<'*." )=" '$>6." $*0$,$0;-?" .->>'0" <$>+-.$*>" %-?<)*$0%" 7!"# $%&$$'(# )*+,%-.*+-&/# 0.12//(# )"# $/-'3.$/+-'" @" )"# 12/&$+-:" $*" -" 6'-.'0" 0$%&6-+>'" A?;<'" 7BC" 43°(:" $*" /-D'" E$&6$>-*F" G*" +'?'-%'1" =$%6" $*" .6'" 0$%&6-+>'"H-.'+"<),'0"-."3F2"<"%I4"&)".6'",$&$*$.J" )=".6'"0$%&6-+>'")="4"<"%I4"70'%A$.'"$*&+'-%'0"%H$<<$*>"%A''0"H$.6".'" -&+)%%" .6'" A?;<'I-+-.$)*" %A''0" 7.6'" <-Q$<;<"H-%"22"6"=)+"-"!"$%&$$'1"'N;$,-?'*.".)"-"?)%%")="RM"D<")+"49"6:F"S%".6'"=$%6" H'+'"&-;>6."H$.6$*".6'"A?;<'1".6'%'"0-.-"-+'"<$*$<-T"6)H','+1".6'"+'%;?.%"<-J" H'??"6-,'"K''*"$*=?;'*&'0"KJ".6'"6-*0?$*>"%.+'%%")=".6'".->>$*>"A+)&'0;+'1"H6$&6" $%"D*)H*".)"+'0;&'"%H$<<$*>"A'+=)+<-*&'"$*"=$%6"7'F>F"C;+*A'**J1"489M:1"-%"H'??" -%"KJ".6'"$*=?;'*&'")=".6'"+'?-.$,'?J"?-+>'"-&);%.$&")+"+-0$)".->%"-,-$?-K?'"-.".6-." .$<'F" " L$*&'" 5)6*%'*" 74,+"# +2$":" =);*0" -" <'-*" <$*$<;<" +'%$0'*&'" .$<'" =)+" .+);." $*" 6$%" '==?;'*.")="49F8O"61"$F'F"44MP"<$*;.'%"7+-*>'"8OU".)"4M23:1".6'"V&)*&'+*"?','?V")=" S?-K-%.'+"748RP:")="4333"<$*;.'%"<'0$-*"?'.6-?".'6." -?%)" K'" -" ,-?$0" &-;%'" =)+" &)*&'+*F" " X+-J"5$#'4""748PP:"0;+$*>"'QA'+$<'*.-?"%.;0$'%"=);*0".6-."Y;,'*$?'"&6$*))D"%-?<)*" -,)$0'0"-"%$<;?-.'0".6'+<-?"'==?;'*."H6'*".6'"BC"H-%")="8I44°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

23" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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

!"#$%&'%"()*%'+,-.$)*"/.01"2343" 24" " .5'"6)678-.$)*"$%"9-+'8:"-98'".)";-$*.-$*" *7;9'+%1".5'"-00$.$)*-8";)+.-8$.:";-:" &)*.+$97.'".)"-"0'&8$*'<"=7%."%7&5"-"&5-*>'";-:"+'&'*.8:"5-,'")&&7++'0"?)+"%8$;:" %&786$*"-*0"!"#$%&"'<"@5$%"6)%%$9$8$.:"-8)*'"-+>7'%"%.+)*>8:"$*"?-,)7+")?".5'"7%'")?"-" &8)%'0A&:&8'"%:%.';<"@5'"-+>7;'*."$*"?-,)7+")?"&8)%'0A&:&8'"&))8$*>"$%";-0'";)+'" .'88$*>"B5'*"5'-."-*0"9$)&$0'"+'8'-%'"-+'"-8%)".-C'*"$*.)"-&&)7*.<"@5'"-;)7*.")?" 5'-.".5-."B)780"9'"$*D'&.'0"$*.)".5'"8-C'"B$.5".5'")*&'A.5+)7>5"&))8$*>")6.$)*"$%" &)*%$0'+-98'"-*0";-:"5-,'"7*0'%$+-98'"8)&-8"'??'&.%<"E."$%"6+)6)%'0".)"7%'"0$??7%'+%" .)" &+'-.'" +-6$0" 8)&-8" ;$F$*><" @5$%" %'+,'%" .)" +-6$08:" 0$%%$6-.'" .5'" 5'-.1" 97." $." B$88" &-7%'"68-*C.)*".)"9'"'*.+-$*'0"$*.)".5'%'"D'.%")?"B-.'+"-*0"6)%%$98:"5-+;'0<"" " @5'" &)+'" -+>7;'*." 7%'0" $*" .5'" GH" $%" .5-." .5'" IJKL" -M7-.$&" $;6-&.%" -+'" %;-88" &);6-+'0"B$.5";-*:"6)B'+"68-*.%1"-*0".5'+'?)+'".5':"&-*"9'"%&-8'0"76"?)+".5'" JJI" -*0" +'A-668$'0<" N)B','+1" .5'+'" $%" -" 6+'%%$*>" *''0" .)" &)*.$*7'" .)" $;6+),'" 76)*" 6-%." 6+-&.$%'%1" 6-+.$&78-+8:" B5'*" .5'" .$;'" %&-8'" ),'+" B5$&5" .5'" JJI" ;-:" )6'+-.'"$%"&)*%$0'+'0<"K$,'*".5'"-,-$8-9$8$.:")?"&8)%'0A&:&8'")6.$)*%"7%$*>"&))8$*>" .)B'+%"B5$&5"B)780";$*$;$%'"$;6-&.%")*"/-C'"O*.-+$)".5'%'"%5)780"9'"?-,)7+'01" 6-+.$&78-+8:">$,'*".5'"7*%.-98'"'&)8)>$&-8"&)*0$.$)*")?".5'"/-C'<"" " H" ?$*-8" 6)$*." +'8-.'%" .)" $*A&);9$*-.$)*" '??'&.%<" E" B-%" 7*&8'-+" ?+);" .5'" GH" 0)&7;'*.-.$)*" .)" B5-." 'F.'*." .5'" 'F$%.$*>" 68-*." -*0" .5'" 6+)6)%'0" *'BA97$80" B)780"9'"B)+C$*>"&)*.';6)+-*')7%8:<"@5'+'"5-%"9''*"-">'*'+-8".'*0'*&:"?)+".5'" 8$?'" )?" 'F$%.$*>" 68-*." .)" 9'" 'F.'*0'0" B'88" 9':)*0" .5'" )+$>$*-8" 0'%$>*" 8$?'<" E%" $." 6)%%$98'".5-.".5'+'"B)780"9'"-".).-8"&))8$*>"B-.'+"'F.+-&.$)*"-*0"0$%&5-+>'")?"4P3" Q2P3"R"S33";T%A4"?)+"-*"'F.'*0'0"6'+$)0U"V7+.5'+1".5'"'??'&.%")?"B-.'+"'F.+-&.$)*" *''0".)"9'",$'B'0"$*".5'"B$0'+"&)*.'F.")?".5'"'*.$+'"8-C'<"W-*:")?".5'")+>-*$%;%" .5-." B)780" 9'" $;6-&.'0" 9:" .5'" JJI" .5-." B)780" -8%)" 9'" $;6-&.'0" ?+);" ).5'+" B-.'+"7%'+%"-*0"0$%&5-+>'+%<"O*'")?".5'"+'-%)*%".5-.".5'"K+'-."/-C'%"'&)%:%.';%" 5-,'" 9''*" %)" 0$%+76.'0" 9:" W-*" $%" )7+" $*-9$8$.:" .)" .-C'" -" 5)8$%.$&" ,$'B" )?" -" ;78.$.70'")?"8)&-8"'??'&.%<"H88"7%'+%"&8-$;".5':"B$88")*8:"5-,'"-"8$;$.'0"8)&-8"$;6-&.<" X7."B5'*".5'%'"-+'"-88"&);9$*'01"5)B"&-*".5'"?$%5"-*0"$*,'+.'9+-.'%"6+)%6'+U"@5'" GH"0$0"*)."&)*%$0'+"$*A&);9$*-.$)*"$%%7'%"$*".5'"0'6.5"+'M7$+'0<" ! "#$#%#&'#() H8-9-%.'+"=5".';6'+-.7+'%<"/'*&%,5&6&'%9:1"+["\4\A \T3<" H8-9-%.'+"='%")*"?+'%5B-.'+"?$%5"$*"X+$.-$*<"();" _+'*C'8"`"#-+C'+1"4YZY<"(5-6.'+"44["TPSAT\3<"

22" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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`)+H1"V)7L'%" I"G'$'+"#B87$%A'+%1"U*&:"4342FF:" J-70T$*" 9:" I" V)&A-&AH-" @:S:1" 4<[3:" @B*&.$)*-7" %$E*$N$&-*&'" )N" $%)'*aCL'%" $*" .A'+L-7"-&&7$L-.$)*:"8$&27('$2*+,5&E%"*+1",,-P"==5D==[:" J-*H%"9:S:1"4:" ;:1" G:" 9)A*1" '." -7:" \4<[R]:" b()LF-+$%)*" )N" N$%A" $LF$*E'L'*." -." .A'" #-7$%-0'%"*B&7'-+"F)T'+"F7-*."N)+")*&'D.A+)BEA"-*0"&7)%'0"&C&7'"&))7$*E:c" U*0$-*-"6&-0'LC")N";&$'*&'d"4RRD4Q3:" " J$%A-$" V:G:1" 4:1"V)77-*0%"G:"I"670'+0$&'"O:@:1"4:1"4<[[:"KA'"$LF)+.-*&'")N"T-.'+"MB-7$.C".)"()7BL8$-">$,'+"%-7L)*"-*0" %.''7A'-0:"-'(%3,6$.73,4&23,4F(2$*+,JE1+$2*)$&"."./0,2P"4X:1" (A-FL-*" #:S:1" ;&A*'$0'+" #:S:" 9+" I" ;.','*%" O:1" 4<[Q:" ZNN'&.%" )N" A)70$*E".'LF'+-.B+'%")*"+'F+)0B&.$,'"0','7)FL'*."$*"-0B7."%)&H'C'"%-7L)*"

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`#^?`DNV1"K*.'+*-.$)*-A"_.)M$&"[*'++%6#-"*R$$2$;6)01"",="22T>2DN8" [A%)*"#8a81"4CEC8"B$C8" a'+<@%)*" :8\81" 4CTV8" LI'" G+'H'++'0" .'MG'+-.@+'" )H" H$%I" -*0" .I'$+" M$0%@MM'+" 0$%.+$U@.$)*" $*" .'MG'+-.'" A-;'%" -*0" %.+'-M%8" <=* 56)&=* B+)=* C:* 7-"=1" ")=" E3N>E458" a$%I'+"Q8(81"4CTV8"_*"-GG+)-&I".)".I'")+<-*"-*0"&'AA@A-+"GIO%$)A)>600++*$"*56)&*7(20(%+8" a$%I8":'%8"?0"(-*-0-"-*0"Y-.8":'%8"()@*&$A1"9..-X-8" \-+%$0'" [8L" R" L-$." S8F81" 4CTV8" #+'H'++'0" .'MG'+-.@+'" )H" +-$*U)X" .+)@." 6D-2>$* ;-6%:"+%66" :$&I-+0%)*7" -*0" $.%" @*@%@-A" +'A-.$)*%I$G" .)" -&&A$M-.$Z-.$)*" .'MG'+-.@+'8"7-"-:6-"*<=*R$$2=1"#-="TE5>TEN8" \+-O":8B81"4CC38"a$%I"U'I-,$)@+"-*0"'*,$+)*M'*.-A"-%%'%%M'*.8"E"O6%$"=*U$S6#$2=* 7&+>=1",="TD>EE8" \+-O":8B81"\'*)X-O":8\8"R"?-++-&A)@=*56)&=*D$#=1""*-="DEE>DN38"

25" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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`C@'*" &)*&'*.+-.$)*%" $*" +'F-.$)*" .)" .A'" E-%%-@'" )?" B$@+-.)+C" %-FB)*$0%:" ?%/;.+ <;1;%.=9+>;"/.;+<;5(./"VW5BQ"4Ra=:" K'*%'*" 9:K:1" K)A*%'*" H:^:" J" 6-*%'*" /:#:1" 4<=<:" I??'&." )?" +$,'+" ?F)7" -*0" 7-.'+" .'BE'+-.D+'")*".A'"DE%.+'-B"B$@+-.$)*")?"-0DF."9.F-*.$&"%-FB)*"$%&'(+1%&%." /:"$*".A'"Y$,'+"b'?%*-1"*)+.A'+*"\)+7-C:"!"#"H+-**)*"I:"J"K)*%%)*"H:"LI0%M1" $%&'(")*+ ,)-.%/)("+ %"*+ 0)1/.)23/)("+ $4'5(1)3':" N'-..F'1" O*$,'+%$.C" )?" P-%A$*@.)*Q"EE:4W3R4W]:" K)A*%'*" #:H:1" 4<=3:" XA'" B),'B'*.%" )?" B$@+-.$*@" %-FB)*$0%" $*" .A'" ,$&$*$.C" )?" -" A'-.'0" '??FD'*." 0'.'+B$*'0" GC" -" .'BE'+-.D+'" -*0" E+'%%D+'" %'*%$*@" +-0$)" .'F'B'.+C"%C%.'B:"!"c"9BF-*'+"(:K:"J"S-&;)*-F0";:P:"LI0%M1"@+A%"*2((B+("+ :)(/;&;';/.4+%"*+<%*)(+C.%=B)"-:"^`?)+01"#'+@-B)*"#+'%%Q"EE:"V=4RV=a:" K)*%%)*" \:1" 4<<4:" U*?FD'*&'" )?" 7-.'+" ?F)71" 7-.'+" .'BE'+-.D+'" -*0"F$@A." )*" ?$%A" B$@+-.$)*"$*"+$,'+%:"D(.*)=+6E+8.;19F%/;.+<;1E1"""Q"23Ra5:" Z'F%)1"K:"Y:"S:"-*0"T:"N:"S$FGD+*"L4:/:1" 4<]<:" :)(&(-)=%&+ @15;=/1+ (7+ C9;.'%&+ G(&&3/)(":" G.(=;;*)"-1+ (7+ /9;+ D%/)("%&+ $4'5(1)3'+ ("+ C9;.'%&+ G(&&3/)("H+ 63";+ IJKJ:" b-*0'+G$F."O*$,'+%$.C"#+'%%1"^+'@)*1"ON9:" /-*@?)+0" X:I:1" 4<=a:" IF'&.+$&$.C" @'*'+-.$)*" -*0" .A'" '&)F)@C" )?" *-.D+-F" 7-.'+%:" /$,'+E))F"O*$,'+%$.C"#+'%%1"/$,'+E))F:"aW2EE:" /-*@?)+01"X:"I:"/:"L4<<3M"I&)F)@$&-F"I??'&.%")?"XA'+B-F";$%&A-+@'%:"IF%',$'+"9EEF$'0" N&$'*&'"/.0:1"I*@F-*0:"W]="EE:" S-f)+" Y:/:" J" S$@*'FF" K:/:1" 4<]]:" U*?FD'*&'" )?" Y)&8C" H'-&A" ;-B" -*0" .A'" .'BE'+-.D+'" )?" .A'" ^8-@)*" Y$,'+" )*" .A'" DE%.+'-B" B$@+-.$)*" )?" %)&8'C'" %-FB)*:">$%A'+C"HDFF'.$*1"]]"L4MQ"4a4R4WV:"

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`9R9Y91":0$*L@+>=9"I3DD9" 8)%'"M9\91"S:09T1"4;5I9"45).80C,010239"M&-0'?$&"#+'%%1"/)*0)*9"5KHDD9"aR"/$L+-+J" )<"()*>+'%%"5IG4N45H9" R=-D$+)1" `9" M9" '." -B" S4;N3T" [='" +)B'" )<" <+''GB$,$*>" -?)'L-'" )&&@++$*>" $*" ='-.'0" '<'*.%" )<" =@?-*" 0$%'-%'1" DD" 4HKG4F;" V*b" X'*7$*%" C" R&=)0.c=-*%'*"S:0%T"())B$*>"P-.'+"0$%&=-+>'%"<+)?"&)-BG<$+'0"D)P'+"DB-*.%E" d-.'+"#)BB@.$)*"#+)LB'?%9"#'+>-?)*"#+'%%1"Y_<)+09" R*J0'+"Q9891"4;5;9"\'-."-*0"-*-0+)?)@%"<$%='%"G"]$%&@%%$)*9"V*b"A+'*7'B"C"#-+7'+1" 4;5;9"DD9H4NGHHI9" R)B)?)*"]9X91"4;IN9"`$>+-.$)*")<"%?)B.%")<"M.B-*.$&"%-B?)*"S7'180+*'1'."/9T"-*0"%'-" .+)@."S7'180+6.A66'"/9T"$*"-"&=-B7"%.+'-?9"F"&,.=+/,01=+?,*5=1"!E"22HG22;9" RD--%"X9[91"4;539"()*.+$L@.$)*".)".='"&)?D-+-.$,'"D=J%$)B)>J"-*0">'*'.$&%")<".='" :@+)D'-*" %-B?)*$0-'9" VVV9" ['?D'+-.@+'" +'%$%.-*&'" -." 0$<<'+'*." ->'%9" G3%.0C,0102,'1"#$E"INGNN9" RD$>-+'BB$"R9M91" 4;IK9"^'=-,$)@+-B"+'%D)*%'%")<"/-7'"`$&=$>-*" <$%='%".)"-"*@&B'-+" D)P'+" DB-*." 0$%&=-+>'9" DD" FI;GF;;9" !"#+ F"&,.0"8)"6'1+ )BB)(6*+ 0B+ (001,"2+ *3*6)8*+'6+"A(1)'.+:0D).+:1'"6*9" #+)&''0$*>%" )<" RJ?D)%$@?1" Y%B)1" M@>@%." 4;IF9"NH3DD9"R[Ve#a^eHIN1"V*.'+*-.$)*-B"M.)?$&":*'+>J"M>'*&J9"f$'**-9" RD$>-+'BB$" R9M9" C" [=)??'%" `9`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

25" !"#$%&'%"()*%'+,-.$)*"/.01"2343" " !

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`$%@'%a"O"_-.-"()78$9-.$)*;"\+'-."/-N'%"`$%@;"()77;"?8'&;"#=A;"W5G[;"4HF"8;" :))0" D;" <" 6=+*8'**J" O;:;E;1" 4>>I;" /-A)+-.)+J" +'-&.$)*%" )C" %-97)*$0" ^=,'*$9'%" -*0"%7)9.%".)"-".@'+7-9"$*.'+C-&';"`O:/TM"-+9"D'8)+.".)"]TVO"K);"444Q>I;" b-=BB" :;?;1" O0-7%" S;/;" <" V&/'-*" /;D;1" 4>52;" ?.''9@'-0" 7$B+-.$)*a" 8).'*.$-9" .'78'+-.=+'"'CC'&.%"-%"$*0$&-.'0"AJ"B$99"-0'*)%$*'".+$8@)%[email protected]%'"-&.$,$.$'%;" A1'+"1+1"&$(Z"I4FGI4H;" b@)="M;1"4>W2;"6@'"%L$77$*B"A'@-,$)=+")C"C$%@"$*".)L'0"B'-+%Z"-"+''c-7$*-.$)*")C" .@'"8+$*&$89'%;"A1),,8$9'/:8$?)(H8$C-08I$J+0,8$56('18$9'/:8$A1),.-"E1"'Z"4GFF;" "

!"#$%&'%"()*%'+,-.$)*"/.01"2343" 25" " Memo: Pisces Conservation Ltd

To: Krystyn Tully, Lake Ontario Waterkeeper From: Dr R Seaby and P Henderson CC: Date: November 14, 2008 Re: Guidelines for the preparation of the Environmental Impact Statement for Ontario Power Generation’s Darlington ‘B’ new nuclear power plant project

Notes on the guidelines for the EIS for Darlington ‘B’ nuclear power plant

Lake Ontario Waterkeeper has asked Pisces Conservation to comment on the document;

Guidelines for the Preparation of the Environmental Impact Statement for Ontario Power Generation’s Darlington ‘B’ New Nuclear Power Plant Project.

This document is to ensure that the environmental impact statement to be prepared by Ontario Power Generation (OPG) addresses all the issues raised by this project, for all the stages of the development.

This memo addresses a series of questions presented in a letter from Krystyn Tully at Lake Ontario Waterkeeper, dated 3 November 2008.

• In your opinion, is the scope of the project sufficiently broad to capture all environmental effects relating to your area of expertise? (Section 4.1)?

In Section 4.1 OPG describes the major operations that will occur during the preparation, construction, operation and decommissioning phases of the development of the Darlington ‘B’ site. They propose to cover all the likely operations that will have an effect on aquatic life.

The scope is sufficiently broad to cover all the main impacts of a power plant on the aquatic environment. During the preparation phase, the main aquatic issues are likely to be building a wharf, stabilising the shore, land reclamation and stream realignment.

During construction the building of new intakes and outfalls and the use of the wharf are potentially the most significant.

Operational impacts are mainly related to the use of cooling water and comprise entrainment, impingement, thermal plume and any biocide system used.

Decommissioning is unlikely to raise any important new aquatic issues provided that decontamination and demolition do not pollute surface waters. At some old nuclear Pisces Conservation Ltd IRC House, The Square [email protected] Phone: 44 (0) 1590 674000 Pennington, Lymington www.irchouse.demon.co.uk Fax 44 (0) 1590 675599 Hampshire, SO41 8GN, UK www.pisces-conservation.com Page 1 of 10 Memo: Pisces Conservation Ltd

facilities now decommissioned, it has been found essential to consider the impacts of the loss of the heated water discharge plume on the local flora and fauna which had become adapted to the warm water over the 30 - 40 year existence of the plant.

During the construction phase, no explicit mention is made of good environmental site practices that need to be followed with regard to stopping the release of silt into surface waters, fuelling of vehicles etc, wheel washing and other construction activities.

• Looking at the list of alternative means in Section 7.3, are there any alternatives that should be added to this list or modified on this list, relating to cooling water?

In Section 7.3 the document describes the alternative means to carry out the project that are considered technically and economically feasible. Aquatic impacts mainly relate to cooling water design. OPG intends to assess alternative condenser cooling water systems, although the types of cooling system that will be considered are far from clear. The reference to discharge through underground tunnels to the lake suggests the possibility of a once-through system, and cooling towers are also mentioned. The closed-cycle cooling water option must also be considered. However, we were unclear exactly what systems would be assessed. In particular, did closed- cycle include a dry-cooling option? We assume so, but this needs to be checked.

To aid in the discussion of the various cooling water system options and their environmental impacts and advantages, we summarise below the various options that are commonly used. We consider this topic in detail because it is the key issue in terms of aquatic environmental impacts.

At present no information has been supplied on the design of cooling water systems proposed for the power stations. Cooling water systems vary greatly in their impacts upon the aquatic environment, and the choice of system will define to a great extent the level of environmental impact. The present nuclear power stations use once- through cooling, which is the most environmentally damaging option.

A Review of Cooling Methods

The classification of cooling systems can be confusing. The following binary distinctions are in general use: • Dry air-cooled compared with evaporative wet-cooled. In evaporative cooling, water is lost to the atmosphere and heat is removed by latent and sensible heat transfer. With dry cooling, water is not lost to the atmosphere and only sensible heat is transferred. • Open compared with closed systems. In an open system the coolant (water) is in contact with the environment; in a closed system the coolant circulates through the plant without contact with the environment.

Pisces Conservation Ltd IRC House, The Square [email protected] Phone: 44 (0) 1590 674000 Pennington, Lymington www.irchouse.demon.co.uk Fax 44 (0) 1590 675599 Hampshire, SO41 8GN, UK www.pisces-conservation.com Page 2 of 10 Memo: Pisces Conservation Ltd

• Direct compared with indirect systems. In a direct system, there is one heat exchanger where the coolant and the medium to be cooled exchange heat. In an indirect system, there are at least two heat exchangers and a closed secondary cooling circle between the process or product to be cooled, and the primary coolant. Once-through cooling systems

Direct once-through cooling systems

In direct once-through systems, water is pumped from a source (e.g. a river, lake, sea or estuary) via large water inlet channels directly to the plant. After passing via heat exchangers or condensers, the heated water is discharged directly back into the surface water. The heat is transferred from the turbine steam water to the coolant through the wall of the condenser tubes. Figure 1: Schematic representation of a direct once-through cooling system

Potential environmental issues For once-through systems, the major environmental issues are as follows: 1. Those associated with the use of large amounts of water. These include impingement and entrainment of fish and other aquatic life. 2. The discharge of heated water 3. Sensitivity to biofouling and the need to add antifouling agents 4. Corrosion and scaling problems. 5. The release of heavy metals. 6. The use of additives and the resulting emissions to water. 7. Construction of intake structures, intake canals etc. 8. Changes in water flow and bed scour

Once-through cooling systems with cooling tower At some localities once-through systems are combined with a cooling tower to cool the discharge before it is released to the receiving surface water. This is done in situations where cooling water may recirculate and raise the temperature of the cooling water intake of the same plant, or where there is a serious risk of the heated effluent, damaging sensitive environments. This configuration has been used at both coastal and inland power stations.

Potential environmental issues For once-through systems with cooling towers the major environmental issues are as follows: 1. Those associated with the use of large amounts of water. These include impingement and entrainment of fish and other aquatic life. This is lower than for a simple once-through system. 2. The discharge of heated water 3. Sensitivity to biofouling and the need to add antifouling agents 4. Corrosion and scaling problems. 5. The release of heavy metals. 6. The use of additives and the resulting emissions to water. 7. Construction of intake structures, intake canals etc. 8. Changes in water flow and bed scour. 9. Cooling towers in saline water systems can cause salt spray drift. 10. Possible build-up of pathogens in the cooling towers. Controlled by the use of biocides. Figure 2: Schematic representation of a direct once-through cooling system with a cooling tower as applied in the power industry.

Cooling tower

Condenser

Water source / discharge Power station

Open recirculating cooling systems Open recirculating cooling systems are also referred to as open evaporative cooling systems. In these systems, cooling water that is led through the heat exchanger(s) system is cooled down in a cooling tower, where the majority of the heat is discharged to the environment. In the cooling tower the heated water is distributed over the cooling tower fill, and is cooled by contact with air and collected in a reservoir, after which it is pumped back to the reservoir to be reused as a coolant. The air movement is created naturally or by means of fans that push or pull the air through the tower. Cooling of the water is a result of evaporation of a small part of the cooling water and of sensible heat loss by the direct cooling of water by air, also called convection. The main causes of water loss are evaporation, blowdown (windage, drift, purge (intentional blowdown) and leaks). Intentional blowdown is the draining of water from the circuit necessary to avoid concentration of dissolved solids. To compensate for the blowdown and evaporation, make-up water is added. Generally, the make-up water flow used by an open recirculating system is about 1-10% of the flow of a once-through system with the same cooling capacity. Blowdown generally ranges from 0.15-0.80 m3/s per 1000 MWth cooled.

Figure 3: Schematic representation of an open recirculating system. (Jenner et al 1998)

Potential environmental issues Recirculating system impacts depend on the type of cooling tower and the way it is operated. Impingement and entrainment deaths are reduced to only about 20% or less of that caused by a once-through system. The main impacts are:

1. Cooling water additives and their emission through the blowdown to surface water 2. Emissions into air 3. Plume formation, condensation and ice formation 4. Noise 5. Waste due to replacement of cooling tower fill 6. Human health aspects 7. Effects related to the extraction of water including impingement and entrainment Closed (dry) circuit cooling systems In air-cooled cooling systems (normally termed dry cooling systems) the turbine water is circulated through coils, tubes or conduits, which are cooled by a passing air stream.

Closed circuit dry air-cooled systems consist of finned tube elements, coils or conduits of a condenser, fans with drives and a carrying steel construction or a tower. The process medium itself or a coolant (indirect system) is circulated through the tubes. An air stream is created, naturally or by fans, that flows past the tubes thus cooling the medium by conduction and convection. If the process medium is a fluid, the cooling system is called an air-cooled fluid cooler. If it is a vapour that is condensed to liquid, the cooling system is called an air-cooled condenser.

Potential environmental issues Impingement and entrainment deaths are reduced to negligible levels. The main impacts are:

1. Noise 2. Impingement of aerial plankton – health issues

Figure 4: Example of natural draught dry cooling tower for a power plant application

Combined wet/dry cooling systems The open wet/dry cooling tower or hybrid cooling tower is a special design that has been developed as a solution to the problem of cooling water use and of plume formation.

It combines both 'wet' and 'dry' cooling tower features: evaporative and non-evaporative cooling. A hybrid cooling tower can be operated either as a pure wet cooling tower or as a combined wet/dry cooling tower, depending on the ambient temperature. The heated cooling water first passes through a dry section of the cooling tower, where part of the heat load is removed by an air current, which is often induced by a fan. After passing the dry section, water is further cooled in the wet section of the tower, which functions similarly to an open recirculating tower. The heated air from the dry section is mixed with the vapour from the wet section in the upper part of the tower, thus lowering the relative humidity before the air current leaves the cooling tower, which reduces plume formation above the tower.

Potential environmental issues The major difference between a hybrid cooling tower and a conventional cooling tower is the comparatively lower water use of 20% less than that of a wet cooling tower. There is therefore a proportional reduction in entrainment and impingement.

• Section 9.3 lists the VECs (Valued Ecosystem Components). Is this list complete, or are there other components that should be added? Are there any VECs currently on this list that should be removed?

Section 9.3 describes the general criteria used to identify VECs that may be affected by the project. OPG lists several species and habitats.

Two ecological components that are not included within the VECs that merit inclusion are submerged aquatic vegetation and planktonic crustaceans. We do not know if there are any important submerged aquatic vegetation species in this region.

• In your opinion, should anything be added to Section 10.1?

Section 10.1 ensures that the baseline bio-physical environment is described. Section 10.1.2 describes the existing surface water environment and what needs to be described for the characterisation of the baseline. Section 10.1.5 addresses the aquatic environment; we consider OPG has listed all the important habitats, flora and fauna.

• In your opinion, should anything be added to Section 11.4?

Section 11 describes changes in the environment caused by the project, including the effects on the aquatic environment. In Section 11.4 OPG describes the changes and effects that will be investigated in the bio-physical environment.

In section 11.4.2 surface water, OPG does not mention the possible use and release of any biocide. It is possible that the plant does not use a chemical biocide such as chlorine to control fouling. However, it is equally possible that in the future a once- through or open cooling tower system would find the use of biocides essential. Changes in the biology of the lake, caused by anthropomorphic and biological factors over the possible 60-year life of the plant, may require their use. The dramatic increase in zebra mussel and other related species in recent years demonstrates the potential for great changes and increased fouling.

Section 11.4.5 (Aquatic environment) lists a range of effects caused by the operation of the power plant. We feel that the assessment of future impacts would be more robust if some account were taken of the potential changes in climate over the next 60 years. These changes could, for example, affect the temperature of lake, the species present, the water height and the sensitivity of the habitat to thermal plumes.

• In your opinion, should anything be added to the list of follow-up programs on Page 50?

In Section 15, follow-up programs that will monitor the effects of the project are outlined in general terms. It is general and does not suggest what data are to be gathered. If once-through cooling were used, we believe that long-term monitoring of Pisces Conservation Ltd IRC House, The Square [email protected] Phone: 44 (0) 1590 674000 Pennington, Lymington www.irchouse.demon.co.uk Fax 44 (0) 1590 675599 Hampshire, SO41 8GN, UK www.pisces-conservation.com Page 9 of 10 Memo: Pisces Conservation Ltd

entrainment and impingent of fish and other species at the station would be appropriate. Further, monitoring of the benthic species and plankton of the lake would also be appropriate.

• In your opinion, do you have any concerns or advice regarding the instruction that certain financial, commercial, scientific, technical information cooling water should remain confidential? (p. 3)

Scientific debate and analysis cannot be undertaken if information is withheld as confidential. In general therefore we would argue strongly that as far as possible a full disclosure of the relevant ecological data should always be sought.

With nuclear plant there are always areas of concern regarding safety, terrorist threat etc., that must remain confidential, but in our experience these almost never impinge upon the debate of ecological issues.

Unfortunately we have no knowledge of the Canadian law on confidentiality so do not feel we can comment further.

• Do you have any suggestions regarding the “description of the relevant organizational and management structure, and staff qualification requirements with emphasis on safety and environmental management programs” as those requirements relate to cooling water? (p. 18)

Other than the essential requirement that all senior staff should have relevant professional qualifications and training, we have nothing to add.

Conclusion

In general, this is a well thought-out scoping document for the environmental impacts of the proposed projects. The document includes all the major areas that need to be considered. Three points that may be worth raising are • More clarity in the cooling water options to be assessed. • Little regard is given to the potential effects of global warming and ecological change on the impact of the station over the life of the plant. • We found no mention of biofouling control methods and biocides in particular.

Richard Seaby and Peter Henderson

14 November 2008.

!"#$%&%"#'(')#*%)!%"+,)#

+,-.'%/0123'+425./6'75,6123'+425./63'%89:61./63';<=>'?@7'

-./012#3-4-563178-7.89:7-5;0419:<89/#

'='!%>?=#@A'(?B?='&?,)+#')!#$,+?&?,)+#

C+8#D74#=2077#*9:9E57#F9929GH#0:I#'3321-I#%:49/929GHA'$9B25:,C'!/CC2123'%/60/6D'

$J!K#!?=K#A:1;-5714H#9L#(9:I9:K#&J-717#M.'E/BFC,.:/6';.F0:2-',60'G2H,4:/F5'/I'!"#$%&'#(%()*%&+,'J&FCC25K3' J!5F-.,L2,3'<-.5,L/0,K'

+-:195#"-7-058J#'7798104-K#!-34

%O$%"&?+%#')!#%O$%"?%)=%#

*6'2L/C/1:L,C'L/6-FC.,6.',60'52-2,5LH'-L:26.:-.'M:.H'NO'82,5-'2PB25:26L2'L/9Q:6:61'.H2/52.:L,C3',BBC:20',60'I:2C0' 52-2,5LHD'+P.26-:42'2PB25:26L2'/I'.H2'9,6,12926.'/I'9,R/5'2L/C/1:L,C',--2--926.'B5/R2L.-':6LCF0:61'B52B,5,.:/6' ,60'B52-26.,.:/6'/I'9,.25:,C'I/5'BFQC:L'26SF:52-',60'C:,:-:61'M:.H'L/6-254,.:/6'Q/0:2-',60'261:6225-D'E5/R2L.-' F6025.,T26':6LCF02'L/6-254,.:/6'BC,66:61'I/5'C,512'.5/B:L,C'6,.F52'52-2542-3'2L/C/1:L,C'2II2L.-'-.F0:2-'/I'6FLC2,5' B/M25'-.,.:/6':6.,T2-3'L/6-254,.:/6'-.F0:2-'/I'5,52'I52-HM,.25'C:I2',60'2II2L.-'/I'LC:9,.2'LH,612',60'05/F1H.D'$' C2L.F52',60'H/C0','B/-:.:/6',-','-26:/5'52-2,5LH',--/L:,.2':6'.H2'02B,5.926.'/I'U//C/183'"6:425-:.8'/I'

$",P%=&#?)Q,(Q%>%)&##

?)!A+&"?'(#%=,(,RS#

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

J(3*"'1&52*"(*"%*(#-(%F3%"'14%(14(#+('A%(1)31+,%)%+'(*+6(%+'"*1+)%+'(#-(-14A(*+6(&"54'*&%*+4(*'(&#*4'*2(*+6( %4'5*"1+%(1+'*=%4(1+('A%(:"1'14A(E42%4C(E(A*0%(9#"=%6(#+('A14(-1%26(-#"()#"%('A*+(KL(>%*"4(*+6(A#26('A%(2*",%4'(6*'*( 4%'(#+(1)31+,%)%+'(#-(-14A(1+(%F14'%+&%C(

!"#$%&'()*&#(#+,)

@14A%"1%4("%4%*"&A()*+*,%"(*+6(DMJ(&#+452'*+'(#+(-14A%"1%4(*+6(*N5*'1&(%>4'%)4(-#"(!"#$%&'(O*)1"*5*(1+('A%( 533%"(J)*8#+C(P"#31&*2("%4%*"&A(A*4(B%%+(0*"1%6(*+6(1+&256%4(9#"=(#+('A%('*F#+#)>(#-(J)*8#+1*+(-14A;( B%A*01#5"(#-(%2%&'"1&(%%24(*+6('A%(&#))5+1'>(4'"5&'5"%(-#5+6(*"#5+6(2%*-(21''%"(*+6(-2#*'1+,()%*6#9(A*B1'*'4C(

*&#(#+%&'()-!./%*-)

:QEPE7<(R7P.JQESR(JSM(QETRQESR(?DOO.SEPER7(

O#"%('A*+(KL(>%*"4(#-(4'56>(#-(:"1'14A(%4'5*"1+%(-14A(*+6(&"54'*&%*+(3#352*'1#+(6>+*)1&4C(7'561%4(5+6%"'*=%+(#-( &#))5+1'>(6>+*)1&4;(9##6(9%B4;(&21)*'1&(%--%&'4(*+6(3"%6*'#"U3"%>(1+'%"*&'1#+4C(Q%&%+'(9#"=(A*4(&#+&%+'"*'%6( #+('A%(%--%&'4(#-(&21)*'%(&A*+,%(#+(-14AC(E(A*0%(3*"'1&52*"(%F3%"'14%(1+('A%(:"14'#2(?A*++%2V(7%0%"+(R4'5*">(*+6('A%( PA*)%4(R4'5*">C(

?DS7RQTJPEDS(OJSJHRORSP(!GJSSESH(

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

ESTRQPR:QJPR(PJ]DSDO^(

J5'A#"(#-('A%(@"%4A9*'%"(D4'"*@(B##=(1+('A%(4%"1%4(7>+#3414(#-('A%(:"1'14A(@*5+*(4%"1%4C(P*F#+#)1&(4'561%4(*24#( 5+6%"'*=%+(#+()>4164;(4A"1)34(*+6(-14AC(

( !"#$#%"&'$(')*(+,',"+,"&'$(+#-,.'/0(

,12(32456728(973(32:2;<=28(<>(?<@=AB28(C9423(2D=28B(4E4B2@4F(57?;A3576(B12(?<@@28?59;(4<>BG982(=9?H9624(0I( J><8(27:58<7@27B9;(2>>2?B4(2:9;A9B5<7(G15?1(54(9:95;9C;2(>8<@(,12(+B9B5<798E(#>>5?2KF(+=2?524(/5?17244(973(*5:2845BE( J9:95;9C;2(>8<@(L"+&0+KF(&<@@A75BE('79;E454(L9?H962(J9:95;9C;2(>8<@(L"+&0+K(973(*E79@5?9(J9:95;9C;2(>8<@( &19=@97(M(N9;;KO("(32456723(973(32:2;<=23(L"+&0+F(97(2D=28B(4E4B2@(A423(B<(=8235?B(>541(973(?8A4B9?297( 5@=5762@27B(973(27B8957@72B(9B(=

L#LR$',"#)(!"#$#%S(

"7?;A3576(B12(4BA3E(<>(>541F(<4B89?<3F(?8A4B9?297(973(5742?B(=<=A;9B5<74(57(@97E(35:2842(19C5B9B4O("(;2?BA82(57( =<=A;9B5<7(3E79@5?4(9B(B12(R75:2845BE(<>(#D><83O("(=AC;54123(G5B1(+58(/5?1983(+

!"#$%&'()*+(,*-&'$'()**

$0&,R/0/(')*(+RL0/U"+#/((

'7(2D=28527?23(4A=28:54<8(<>(=<4BT6893A9B2(4BA327B4O($2?BA828(973(BAB<8(<7(B12(?;5@9B5?(?19762(@94B284(?<9842(9B( B12(R75:2845BE(<>(#D><83O((

./",")%(')*(!/#'*&'+,")%(

-822;97?2(G85B28(><8(!85B541(.5;3;5>2(973(5?(93:54<8(><8(B12(!!&( 973(<824B4F(B8<=5?9;(>541(973( !85B541(G5;3;5>2O(

.&/0"11'/(+!*2'1$/&3*

.456578*9:6;8;:76<*,;45=8:4*.'1#"1*#:7654>?8;:7*!8@A*B*157;:4*&565?4=C*+66:=;?85D*,598A*:E*F::G:HID*%7;>546;8I*:E* /JE:4@*

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

!"#$%&'(!E!-)F5&7!23,)'+4!?&.&)#4/!G)A$#)'$#+&.!G'1D! )%*+,+%-./!H+#&4'$#!89::9<9::I>! ?&.@$0.+A5&!B$#!.$B'F)#&!1&C&5$@*&0'J!*)'/&*)'+4)5!*$1&55+06J!.')'+.'+4.!)01!*)#+0&!)01!&.',)#+0&!+*@)4'! )..&..*&0'.!$B!@$F&#!.')'+$0.D!

!"#$%&'(!E!K&0'#)5!L5&4'#+4+'7!?&.&)#4/!G)A$#)'$#7!)01!M)'+$0)5!"$F&#!"GK! )%*+,+%-./!?&.&)#4/!N4+&0'+.'!89:=;<9::9>D!! O$#P+06!$0!'/&!1&C&5$@*&0'!$B!*)'/&*)'+4)5!*$1&5.!$B!0)',#)5!.7.'&*.D!()%$#!#&.&)#4/!)#&).!F&#&!8+>! @$@,5)'+$0!A+$5$67!$B!*)#+0&!B+./!)01!4#,.')4&)0.E!8++>!'/&!*$1&55+06!$B!F)'&#!*$C&*&0'!)01!4$$5+06!F)'&#! 1+.4/)#6&.E!8+++>!'/&!4),.&.!$B!#&1!'+1&.E!8+C>!B#&./F)'&#!4$**,0+'7!.'#,4',#&!+0!#&5)'+$0!'$!F)'&#!4/&*+.'#7!4/)06&.! 4),.&1!A7!)4+1!#)+0D!!

012!3.)04515064.2!78.. QRR;

!91!36:7.);<75=:15064.

<00>4. 2'-?'(*%-!^!()#6&''.!8L1.>J!9:;:D!-+./!+0!L.',)#+&.D!-+./&#+&.!N$4+&'7!$B!'/&!T#+'+./!W.5&.D! 2'-?'(*%-!89::R>D!!"#$%&'(#")*$("'+*,$D!N70$@.+.!$B!'/&!T#+'+./!-),0)!8M&F!N&#+&.>!M$D!IQD!U0+C&#.)5!A$$P! .&#C+4&.J!_&6.'6&&.'J!M&'/)01.D! 2'-?'(*%-@.)A.:A.^!N$,'/F$$1J!`D!?D!LD!8QRRR>!-+*.*/0+'.)1#(%*,$D!\#1!L1+'+$0!T5)4PF&55!N4+&0'+B+4D!Z:R!@@! 2'-?'(*%-@.)A.:A.8QRRQ>)2"'+(0+'.)1#(%*,$)03)-+*.*/4D!T5)4PF&55!N4+&0'+B+4D! 2'-?'(*%-@.)A!:D!)01!N&)A7!?D!(D!8QRR;>!5)2"'+(0+'.)6'3,7**8)9*")1:.(0;'"0'(#)1#(%*,$D!"+.4&.!K$0.&#C)'+$0!G'1DJ! QQ\@@D! N@&+6/'J!(.B.2'-?'(*%-.@.)A2D!8QR9R>!1'"03#)<0*.*/4=)>*3+#?($)'3,)5??.0+'(0*3$D!O+5&7

):)!34. b)*+5'$0J!2'-?'(*%-!^!($#)0!89:;9>D!-5,4',)'+$0!$B!&0C+#$0*&0'!)01!4$0C$5C&1!)0')6$0+.'!@$57*$#@/+.*!).! B)4'$#.!+0!'/&!*)+0'&0)04&!$B!.&cD!M)',#)5!.&5&4'+$0!)01!.$4+)5!A&/)C+$,#E!#&4&0'!#&.&)#4/!)01!0&F! '/&$#7D!K/+#$0!@#&..D!M&F!d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`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`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`48%6.#%'1#:5'1.&0':K46J:63%'.6'50%'#"=%2' 7%8%26'9&54:2;@'V%50@'?@'7%:'W%&@(CCa'CT*FCC,@' !"#$"%&'#'P@L@'('!:$.#5"6'P@L@')*++Q-@'75:6J.6/'32"I':6J'J.&52.K45."6'"1'1.&0'.6'J2.15.6/':6J':55:30%J'1#":5.6/' $%:J"='=.50.6':6'\II%2'L$:M"6.:6'8:2M%:'#:H%@'?@'A.&0'B."#@'ONE'TDDFTND@' [:/422:6E'L@'9@E'R28.6/E'P@'G@'('!"#$"%&'#)(*+(,+()*++D-'R&'50%2%':'1.&0':#:2$'I0%2"$"6%>'L'=.#J'&54J;':6J' 32.5.b4%@'P2"3@'W@'7"3@'^"6J@'B@E'TDCE'*QQ*F*QQD@' !"#$"%&'#)(*+(,+(R28.6/E'P@'G@'('[:/422:6E'L@'9@')*++N-'A.&0'I0%2"$"6%&':6J'%8"#45."6:2;'%6./$:&<':'2%I#;'5"' 7$.50@'P2"3@'W@'7"3@'^"6J@'B@E'TDOEOQ*FOQC@' !"#$"%&'#)(*+',@'('Z"2I&E'[@')*++N-@'Y0%'2"#%'"1'5%$I%2:542%':6J'3:66.K:#.&$'.6'.65%2:664:#'2%324.5$%65'8:2.:5."6' "1'K:&&'.6'B2.5.&0'=:5%2&@'?@'A.&0'B."#@E'Q,E'T_,FT+Q@' !"#$"%&'#)(*+(,+()(!:$.#5"6E'G@'c@'('Z2:$I5"6E'G@'d@'W@')*++_-'98"#45."6':6J'J.8%2&.5;'.6'50%'L$:M"6.:6' 1#""JI#:.6'3"$$46.5.%&@'c;6:$.3&'"1'52"I.3:#'3"$$46.5.%&E'V%=K42;E'c@'[@E'P2.6&E'!@'!@'Y@'('B2"=6E'V@'c@' )%J&-'Y0%'CN50'B2.5.&0'93"#"/.3:#'7"3.%5;@'C_QFO*+@' !"#$"%&'#)(*+(,+()*++_-'S6'50%'8:2.:5."6'.6'J:K'!")$*+$'(")$*+$'2%324.5$%65<':'M""/%"/2:I0.3'&54J;@'?@'7%:' W%&%:230E'O,E'*C*F*OT@' !"#$"%&'#)(*+(,+')*+++-'Y0%'6:542:#'0.&5"2;'"1'B2.5.&0'%&54:2.%&@'B2.5.&0'G.#J#.1%'*,E'O,CFO**@' !"#$"%&'#E'P@'L@'('7%:K;E'W@'[@'!@')*+++-@'P"I4#:5."6'&5:K.#.5;'"1'50%'&%:'&6:.#':5'50%'&"450%26'%J/%'"1'.5&'2:6/%@'?@' A.&0'B."#@'QOE'**D*F**ND@' !"#$"%&'#)(*+(,+')*+++-'S'L$K.%65%'Lb4:5.3"'J:'2%&%28:'[:$.2:4:@'R6<'9&5:5%/.:&'I:2:'$:6%`"'J%'2%342&"&' I%&b4%.2"&'%$'[:$.2:4:@'9J@'!@'e4%.2"M'('G@'Z2:$I5"6E'ZVPbE'B2:M.#@'*F+@' !"#$"%&'#)(*+(,+')*+++-'75%II.6/'K:3H'12"$'50%'K2.6H<'%&54:2.6%'3"$$46.5.%&':6J'50%.2'I2"&I%35&@'B2.5.&0'G.#J#.1%' **E'_QF+,@' !"#$"%&'#)(*+(,@''('W"K%25&"6E'B')*+++-'S6'&5243542:#'3"$I#%U.5;':6J'1.&0'J.8%2&.5;'.6':6'L$:M"6.:6'1#""JI#:.6@' PI@'OQFQ_@'R6<'Z@'P:J"30E'?@[@'L;2%&E'[@'P.6%J"Ff:&b4%ME':6J'L@'!%6J%2&"6')9J&-@'fg2M%:<'c.8%2&.5;E' c%8%#"I$%65':6J'Z"6&%28:5."6'"1'L$:M"6.:h&'G0.5%=:5%2'A#""JI#:.6&@'V%='i"2HE'V%='i"2H'B"5:6.3:#' d:2J%6'P2%&&@' Y@'W@'9@'7"450=""JE'*+(,+(!"#$"%&'#'('R@'P@'G".="J')T,,C-'75:K.#.5;':6J'30:6/%'"8%2'DN';%:2&'j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`aH2(:"# %&'(&)*+',#!"#$"#S#!1C3((1')#8")#>?M?"#K-'<-'C#/[&D-&/#1R3':1'D&#:-/4(-R34-2'/#-'#'3.&(-D17#1R3':1'D':# R-2.1//#45(23C5#/-.[7//3.[4-2'/#1R234#D2..3'-4G#/4(3D43(&"#8/"0$$;,:-'&".&<)$&="+%#&!"0,$<+&>2& >,"#"-,0%#&!0,$:0$')#`'7-'&#[3R7-D14-2'#:14&b#MZF$1'F>?M?"# %&'(&)*+',#!"#$"#S#I-(:#*"#$")#>?M?"#_-/5#1':#.1D(2FD(3/41D&1'#D2..3'-4-&/#1':#45&-(#:G'1.-D/#-'#45&#,&E&('# 6/431(G"#!1(-'&#J27734-2'#I377&4-')#NM)#M??FMM@"# %&'(&)*+',#!"#$",#>?M?"#1"4#,:-&%:;&?:<,."4#,:-&,:&@<)$/&A:;4',"."4#,:-"#+-7&G#I71D<9&77#@>\[["#6:"#,"#*3((#1':#$"#X"#T52.1/2'"# APPENDIX A.2

! Dr. H.S. Cole, “Review of Technical Support Documents pertaining to the potential ! impact of the Darlington Nuclear Facility air emissions on ambient air quality” ! (February 2011).

" Curriculum Vitae, Dr. H.S. Cole.

Henry S. Cole & Associates, Inc. http://hcole-environmental.com/wordpress/

REVIEW OF TECHNICAL SUPPORT DOCUMENTS PERTAINING TO THE POTENTIAL IMPACT OF THE DARLINGTON NUCLEAR FACILITY AIR EMISSIONS ON AMBIENT AIR QUALITY

Henry S. Cole, Ph.D. February 2011 ______

1.0 Introduction: At the request of Lake Ontario Waterkeeper, I have reviewed the following technical support documents pertaining to Darlington prepared as part of the Environmental Assessment (EA) Technical Studies for the New Nuclear - Darlington (NND). These, documents, listed in Table 1, were prepared by SENES Consultants Limited for Ontario Power Generation (OPG). Waterkeeper requested this review in order to determine whether the atmospheric dispersion modeling used for the Environmental Assessment / Impact Statement for the new reactor plants meets the requirements of the Canadian Environmental Assessment Agency’s Guidelines for the Preparation of the Environmental Impact Statement (Final Version March 12, 2009).

Table 1: List of Documents Reviewed

Atmospheric Environment, Existing Environmental Conditions Technical Support Document, New Nuclear - Darlington Environmental Assessment, Nk054-Rep-07730-00001 Rev 000

Atmospheric Environment, Assessment of Environmental Effects Technical Support Document, New Nuclear - Darlington Environmental Assessment, Nk054-Rep-07730-00011 Rev 000

Radiation & Radioactivity Environment Existing Environmental Conditions, Technical Support Document New Nuclear – Darlington Environmental Assessment Nk054-Rep-07730-00008 Rev 000

Radiation and Radioactivity Environment Assessment of Environmental Effects Technical Support Document, New Nuclear - Darlington Environmental Assessment, Nk054-Rep-07730-00018 Rev 000

1.1 EIS Guidance requirements for air modeling: Specifically, Waterkeeper asked that I determine whether the atmospheric modeling used to generate the results described in the Technical Support Documents (TSDs) for the Darlington EIS meet the modeling requirements mandated by Section 11.4.7 of the EIS Guidelines for the Darlington expansion.1 The pertinent language is underlined in the following excerpt from this section.

“The EIS must identify and characterize all atmospheric emissions, including but not limited to average and maximum emissions from point sources, planned discharges, and fugitive emissions, including greenhouse gases, expected to be generated during any phase of the project. Modeling incorporating site- specific atmospheric characteristics (e.g., shoreline fumigation) is to be completed to assess potential influences on air quality, and the transport of atmospheric contaminants and any associated exposure of humans and non-human biota. (Underline added for emphasis).

The guideline is specific to the Darlington expansion project. This specific mention of shoreline fumigation strongly suggests that the authors of the guideline were aware that this phenomenon is an important factor to consider.

The attached CV includes my qualifications for making this determination.

2.0 Applicants neglect shoreline fumigation and plume trapping: The above excerpt from the proposal-specific assessment guidance requires that the proponent must incorporate site specific characteristics of the atmosphere that impact air quality and the transport of atmospheric contaminants. The language specifically sites shoreline fumigation as a potentially applicable factor. However, the language applies equally to a second adverse dispersion phenomenon known to occur in shoreline environments known as plume trapping. Neither phenomenon is specifically addressed nor even mentioned in the TDS documents listed in Table 1. As explained below, these omissions represent a major flaw in the applicant’s dispersion modeling and environmental assessment.

3.0 The importance of stable, onshore flow: Given this language the reviewing agencies should reject any assessment that fails to incorporate the applicable phenomena that affect dispersion and contaminant concentrations resulting from the existing and proposed OPG nuclear facilities.

In fact the term shoreline fumigation is not mentioned in any of the TDS assessments dealing with dispersion. Similarly, the TDS reports on atmosphere and radiation also fail to discuss additional lake effects on dispersion including plume trapping. See further discussion below.

1 Canadian Environmental Assessment Agency (January 2009).

2 Onshore winds are critically important because they carry emissions toward residents and onshore flow has an important effect on pollutant dispersion. Thus, it is astonishing that the climatological description in Section 3.0 of the Atmospheric Environment Existing Conditions TDS neglects to describe the major impact that Lake Ontario has on temperature, winds, the configuration of the internal boundary layer (mixing zone above the surface) and the importance of lake effects on pollutant concentrations. Nor do the TDS reports describe whether or how such effects are incorporated into the air quality modeling for the Darlington facility.2

The section should also have described the seasonal and diurnal variation of Lake Ontario’s climatological effects. For example, report’s wind rose diagrams show only annual averages, but fail to provide wind distribution data by season or time of day and therefore likely to miss the contribution of warm season, daytime lake breezes to the frequency of onshore flow. The frequent occurrence of lake breezes north of Lake Ontario (i.e. in Southern Ontario) has been described in the literature.3

This omission is significant. During spring and summer days, the temperature of water in Lake Ontario is typically much colder than the air flowing over the lake. See Figure 1. Flow over the cold lake means that the temperature of the air increases with height (temperature inversion), which causes the air to be stable. Under such conditions turbulence is suppressed and the ability of the air to disperse pollutants is limited. As shown in Figure 3, plumes caught in stable air remain intact with little dilution over large distances. In this case, the satellite photo shows a fog plume; however, the same applies pollutant plumes. The pertinent issue is how stable marine air, frequent on the north shore of L. Ontario, affects the emissions from sources on or near the shoreline.

2 Modeling includes two major components: (a) the particular model used, in this case AERMOD and (b) modeling inputs including data sets and the particular choices that the modeler makes given the options available in the model.

3 King, P, “Lake Breezes in Southern Ontario and Their Relation to Tornado Climatology:” Weather and Forecasting, October 2003. http://journals.ametsoc.org/doi/pdf/10.1175/1520-0434(2003)018%3C0795:LBISOA%3E2.0.CO;2 3

Figure 1: Differential in temperature between air and L. Ontario water as a function of month.

In order to project the full impacts of the project, proponents should have specifically evaluated the potential of two adverse phenomena associated with stable, onshore flow including “plume trapping” and “shoreline fumigation” (See Attachments 1 and 2 for diagrams and detailed explanations).

Adverse dispersion regimes associated with stable, onshore flow, including shoreline fumigation and plume trapping, can last for many hours on spring and summer days with shoreward winds. Onshore winds may result from gradient (synoptic scale) flows or from lake breezes.

The impacts of these regimes have been extensively reported for decades in the scientific literature. Often cited journal articles on the effects of the Great Lakes on shoreline sources include several that I have co-authored with Walter A. Lyons. 4

4 Lyons and Cole, Fumigation and Plume Trapping

4 !igure 2:

“A southerly flow of unseasonably warm, moist air (temperatures of +20° to +26° C, dew points of +14° to +16° C) over the relatively cool Fog plume (generally +2° to +5° C ) water of Lake Michigan and Lake Huron contributed to the development of large advection fog plumes (caused by the horizontal motion of air) during the day on April 16, 2002.” Southerly wind flow NASA, Earth Observatory. http://earthobservatory.nasa.go v/IOTD/view.php?id=2381

4.0 Shoreline fumigation: The diagram in Figure 3 demonstrates the shoreline fumigation dispersion regime including (a) highly stable lake air flowing across the shoreline; (b) the growth of the mixing (internal boundary) layer with increasing distance inland; (c) fumigation occurs inland where the top of the mixing layer intercepts the plume; and (d) the overlying stable air serves as a lid preventing upward dispersion, an effect which explains why fumigation causes higher concentrations than cases where upward mixing is unrestricted. Note also that for the lower source fumigation, the highest ground level concentrations occur nearer to the source. Emissions from very low sources or at the surface disperse within the mixed layer. Highest concentrations will occur when the mixing layer is shallow (see discussion of plume trapping).

Figure 3: Schematic diagram showing shoreline fumigation. Emissions from the lower source fumigates closer to the shoreline.

The TDS documents fail to discuss the significance of shoreline fumigation with regard to chemical concentrations resulting from the combined emissions of the existing and 5 proposed facilities. Although most study of shoreline fumigation has involved the elevated plumes of coal fired power plants, fumigation can also impact contaminants emitted at lower elevations especially when such emissions occur just above or rise into and penetrate the stable marine layer where the boundary layer is shallow near the shoreline.

TDS (existing conditions, p. 4-20)) states, “Detailed source parameters (e.g., source locations, stack height, stack diameter, exit velocity, exit temperature etc.) can be made available upon request.” However, this is a far cry from providing the analysis and discussion that is needed for a public reviewer to determine the potential impact of fumigation on various stack and vent emissions. Nor does this statement meet the requirements of the site specific EIS guideline for the Darlington facility, i.e. “While the EIS guidelines provide a framework for preparing a complete and accessible EIS, it is the responsibility of the proponent to provide sufficient data and analysis on any potential environmental effects to permit proper evaluation by a joint review panel, the public, and technical and regulatory agencies.”

Moreover as discussed in Section 4.1 below, the AERMOD model does not provide concentration estimates resulting from shoreline fumigation and the TDS reports fail to discuss the potential implications of this problem on the impacts of the facility and its proposed expansion.

4.1 AERMOD and Shoreline fumigation: The AERMOD model used by SENES is neither designed nor capable of simulating the shoreline fumigation process or of estimating concentrations resulting from coastal fumigation.5 Nor did the applicant use an additional model capable of incorporating shoreline fumigation. For example, Section 2.4 of the Ontario Ministry of Environment’s (MOE) modeling guideline6 includes the Shoreline Dispersion Model (SDM) as a an acceptable alternative model for shoreline areas. This incorporates an algorithm for shoreline fumigation. Appendix A of the modeling guideline states:

“SDM (Shoreline Dispersion Model)7 can calculate a year or more of hourly concentrations calculating the effect of shoreline fumigation on plumes from stack sources at a shoreline due to shoreline fumigation when that event is likely to occur. At other times, it calculates concentrations based on a standard Gaussian plume model. SDM is relatively easy to

5 To model shoreline fumigation requires a configuration that allows the internal boundary layer (mixing height) to grow with increasing distance inland from the shoreline. AERMOD simulates mixing height growth as a function of hour (grows with solar heating of the surface) but does not allow for variation of mixing height downwind from shoreline or the source.

6 Ontario Ministry of Environment, Air Dispersion Modeling Guideline for Ontario (March 2009). http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/@resources/documents/resource/std01_079138 .pdf

7 U.S. Environmental Protection Agency (1988): User's Guide to SDM: A Shoreline Dispersion Model, EPA-450/4-88- 017. U.S. Environmental Protection Agency, Research Triangle Park, NC 27711

6 use, and is appropriate for sources located at a shoreline. The data requirements and ease of use are typical of Gaussian plume models.” (Emphasis added).

Despite the shoreline environment, the availability of the SDM, the applicant failed to use a model capable of estimating the impact of shoreline fumigation. Moreover, the TDS reports fail to discuss the availability or applicability of SDM or another model capable of simulating shoreline fumigation. Nor do the TDS reports explain the potential consequences of ignoring the phenomena.

These are serious oversights given the EIS guidance requirement that the proponent conduct its assessment “in a careful and precautionary manner in order to avoid or mitigate the possible adverse effects of development on the environment and to encourage decision-makers to take actions that promote sustainable development and thereby achieve or maintain a healthy environment and a healthy economy.” (Section 2.1)

There is ample evidence that regulatory authorities in Canada and Ontario have been aware of the adverse impacts of shoreline dispersion regimes for three decades or more. For example, MOE supported and participated in a major study of the Nanticoke Power Plant plume located on the shoreline of Lake Erie. This study, conducted in the late 1970’s, documented in detail the atmospheric conditions and dispersion impacts of shoreline fumigation. The study resulted in several peer-reviewed articles, including several by P. K. Misra, then an official with the Technology Development and Appraisal Section, Air Resources Branch, of MOE.8 The work on shoreline sources led Misra and others to develop and evaluate the Shoreline Dispersion Model (SDM) discussed above.

5.0 Plume trapping. Figure 4 includes a photograph and schematic illustrating plume trapping. This condition occurs with stable, onshore flow at times when solar heating is restricted (e.g. overcast conditions) and as a result the turbulent boundary layer remains shallow. This has the effect of “trapping” low level plumes and severely limiting vertical dispersion. In the case of the Darlington facility, this condition would restrict dispersion and potentially result in high level concentrations from what the applicant describes as emissions from “vents or stacks on or near the building”9 and emissions brought toward the surface via building downwash. Such downwash (building wake effect) causes emissions to be mixed rapidly downward with maximum concentrations located near the source. High concentrations in this case would expose workers on site and close residents.

Under the conditions occurring on such days the mixed layer typically remains shallow for many km downwind of the source. Thus vertical dispersion is restricted and concentrations are slow to diminish downwind of the source.

8 Ontario Ministry of the Environment (1979), “The Nanticoke May/June 1979 field study; dispersion and oxidation of SO2 in the generating station plume and ambient non-methane hydrocarbon concentrations in the Nanticoke area.” ARB-TDA Report No. 61-80. 9 TDS: Atmospheric Environment Existing Conditions, p. 2-8.

Figure 4: Photograph (a) and schematic (b) showing an example of stable under overcast conditions; source: Lyons & Cole, (1973). Only the low level source affects ground level concentrations in this case since the elevated plume remains aloft with little vertical mixing, plume trapping, but not fumigation occurs.

The Darlington TSD, Atmospheric Environment Existing Conditions (p. 2-8) acknowledges the importance of a) low level emissions vented from buildings and/or brought downward to the surface via downwash due to turbulent wake effects that occur downwind of the plant’s buildings and emission sources. As discussed below, the TDS provides insufficient information to indicate whether the modeling conducted accurately estimates chemical concentrations resulting from plume trapping.

6.0 The importance of model inputs: Although AERMOD is not designed to model shoreline fumigation, it is designed to address plume trapping provided that the modeler uses inputs that allow the model to calculate the actual mixing conditions on an hourly basis. The accuracy of these estimates will depend on the particular inputs and choices made by the modeler.

8 The modeler’s objective should be to use those database treatments / inputs that best replicate site-specific conditions.10 Along these lines the TDS on existing conditions states “[B]y using this extensive data set, all meteorological conditions that can occur have been considered in the modelling, including lake breezes and the effects of temperature inversions on mixing height.” There are several problems with this statement. First as stated previously, AERMOD is not capable of simulating shoreline fumigation.

Secondly, in order for AERMOD to provide accurate predictions of pollutant concentrations, the modeler must input parameters that accurately represent time- dependent, site-specific conditions. As the TSD document (Section ) acknowledges, accurate inputs on upwind surface characteristics is essential to ensure that the model accurately simulates the vertical structure of the atmosphere and its impact on dispersion. The AERMET meteorological processor (EPA, 2004a) requires three surface characteristics including surface roughness length, albedo, and Bowen ratio:

• Surface roughness is a measure of the height to which surface elements, e.g. trees, grass, buildings, and other obstacles to the wind induce turbulence. Smooth surfaces have lesser effects than rough surfaces.

• Albedo is the reflectivity of the surface. A non-reflective surface absorbs more heat contributing to thermally induced instability and turbulence.

• The Bowen ratio is the ratio of energy used to heat the air compared to that used to evaporate water. The lower the ratio the less heating and thermally induced turbulence.

Unfortunately, the TDS provides little detailed information that would allow a reviewer to determine how these critical inputs were obtained and whether they accurately represent site conditions. This problem is discussed below with regard to surface roughness, a critically important parameter.

The TDS (p. 4-18) cites U.S. EPA’s AERMOD guidance (2009) on surface roughness as follows. “Surface roughness length should be based on an upwind distance that captures the net influence of surface roughness elements on the measured wind speeds and allows the determination of the amount of mechanical turbulence in the approaching airstream.” TDS (p. 4-18) adds, “The U.S. EPA’s current practice to determine the effective surface roughness for input to AERMET pre-processor is 1 kilometre relative to the meteorological tower location (EPA, 2009). This recommended distance is considered a reasonable balance of the complex factors noted above and was used in this assessment.” However, the statement does not include the important caveats included in EPA’s (2009) guidance. For example:

• EPA’s guidance (p. 4) stresses the importance of considering discontinuities in surface roughness – and there is a major discontinuity between the lake (roughness on

10 As Section 11.4.7 of the EIS guidance states, “Modeling incorporating site-specific atmospheric characteristics (e.g., shoreline fumigation) is to be completed to assess potential influences on air quality, and the transport of atmospheric contaminants and any associated exposure of humans and non-human biota.” 9 the order of 0.001 m) and the land (with typical roughness scales of 1-3 m). The TDS makes no mention of the lake-land discontinuity and its potential effect on dispersion.

• Moreover, the EPA guidance (2009, p. 5) states that modelers should determine separate surface roughness values for different wind sectors if surface roughness varies significantly by direction. As stated above, there are differences of orders of magnitude in the surface roughness characteristics that affect winds from onshore versus offshore directions. Despite this fact, the TSD gives no information on how its modeling addressed the variation of surface roughness as a function of wind direction or whether it even uses roughness inputs that vary by wind direction.

The location of the Darlington site’s meteorological tower is another factor to consider. As the map in Figure 2.3-1 shows, tower is located close to Highway 41 approximately 1.5 to 2 km downwind from the shoreline depending on wind direction. Given the AERMOD guidance (using an upwind distance relative to the meteorological tower) may indicate that the proponent’s roughness elements were solely land based regardless of wind direction – an input choice which is not likely to accurately represent conditions at the site.

7.0 Conclusion: This review raises serious questions regarding the applicant’s assessment of the impact of an expanded nuclear facility at its Darlington location. In particular, the technical support documents reviewed fail to provide adequate focus on the unique characteristics of the shoreline environment that impact dispersion and ground level concentrations. Moreover, the TSD fails to provide sufficient information for reviewers to evaluate the reliability of the assessment.

Henry S. Cole & Associates, Incorporated Science and Solutions for the Environment & Sustainable Communities

www.hcole-environmental.com

Henry S. Cole, Ph.D.

Summary of Professional Experience Pertaining to Air Pollution Meteorology and Air Quality Modeling

• President of Henry S. Cole & Associates (1993-present): Henry S. Cole & Associates, Inc. is an environmental consulting firm that provides scientific support for a diverse clientele including environmental organizations, corporations and government agencies. The firm provides research and scientific support (e.g. environmental assessments and expert testimony) on a variety environmental issues, including air pollution meteorology, air quality modeling, hazardous waste sites, and municipal landfills.

• Examples of client-based projects: Modeling assessment of air quality impacts of the Kodak’s Rochester facility for NY State Attorney General. Retained by the Franklin County Ohio Court of Common Pleas to oversee air pollution and plant safety compliance at Georgia-Pacific’s resin plant in Columbus, OH.

• Science Director of Clean Water Action (1983-1992): His reports on mercury contamination from municipal incinerators and power plants received widespread media coverage and spurred successful campaigns to reduce mercury emissions.

• Senior scientist/section chief U.S. EPA's Office of Air Quality Planning & Standards (1977-83): Directed several programs using air quality models to develop point, urban and regional scale air pollution control strategies. Chief Model Application Section. Authored numerous reports and articles on modeling issues and developed a version of the single-source CRISTER model incorporating shoreline fumigation.

• Associate Professor Environmental Earth Science, University of Wisconsin-Parkside (1969-77). Conducted research programs involving air pollution meteorology and photochemical oxidants, led several environmental organizations and served as a member of the Wisconsin State Air Pollution Control Council and as an environmental advisor to former Congressman Les Aspin.

• Co-recipient of the EPA’s Presidential Green Chemistry Challenge Award (2002, with Chemical Specialties, Inc) for research on the environmental advantages of ACQ, an arsenic-free and chromium- free alternative wood preservative.

• Education: Dr. Cole received a Ph.D. in meteorology from the University of Wisconsin in 1969 with a minor in geology. His dissertation involved the reconstruction of past climates. He obtained his B.S. with High Honors from Rutgers University - College of Agriculture. He attained membership in Phi Beta Kappa and Sigma Xi (Honorary Research Society). His undergraduate majors included soil science and meteorology.

• Professional associations: American Chemical Society, American Meteorological Society

Attachment 1

PUBLICATIONS, REPORTS, and TESTIMONY OF HENRY S. COLE, PH.D.

Atmospheric Sciences / Air Pollution

A Description of the Effects of Great Lakes on Ontario Shoreline Emission Sources, prepared for Lake Ontario Waterkeeper, November 2009

Expert report on Lafarge application to burn alternative fuels issues pertaining to air pollution meteorology and modeling. Submitted to Ontario Waterkeeper, July 2008.

Expert affidavit demonstrating sources and operational factors causing malodorous emissions from a Detroit-area landfill. (Client confidential). September 2008

Final Report Of Environmental Liaisons’ Investigation: Georgia-Pacific Resins Inc., Columbus, Ohio: Plant Safety And Environmental Issues, Submitted to Franklin County Court of Common Pleas, October 2005. .

Comments on the NJ Master Plan Phase II Submitted to NJ Public Utility Commission on behalf of confidential client. Testimony focuses on air pollution impact of coal burning power plants and the need for incorporate limits on air emissions in NJ’s deregulation plan. 1997.

Mercury Warning: A Study of Mercury Contamination in the United States, Published by Clean Water Fund and Clean Water Action, Washington, DC, August, 1992. (Report focuses on atmospheric sources of mercury, and its fate, transport and biomagnification in the aquatic food chain.)

Testimony before the Environment and Public Works Committee, US Senate, on the "Mercury and the Resource Conservation and Recovery Act Amendments of 1991, September 12, 1991. (Report focuses on incineration and air emissions.)

Testimony before the US Environmental Protection Agency, October 19, 1990, on proposed NSPS and Emissions Guidelines for MSW Incinerators, "Strict Numerical Emission Limits are Needed for Mercury from Municipal Waste Combustors."

Testimony before the Subcommittee on Transportation and Hazardous Materials, Committee on Energy and Commerce, U. S. House of Representatives, May 11, l989, on the Municipal Solid Waste Incinerator Act of 1989.

U.S. EPA, A Review of Recent Applications of the SAI Urban Airshed Model (Ozone/photochemical modeling), EPA-450/4-84-004, December 1983. "Needs and Application of Regional Air Quality Simulation Models for Oxidants in North America", International Conference on Long Range Transport Models, Research Triangle Park, North Carolina, April, 1983.

"Coastal (Air Pollutant) Transport and Diffusion: EPA Research and Development Needs," Workshop on Coastal Transport Processes, Brookhaven National Laboratories, Long Island, New York, July 1982.

"Application of the Airshed Model for Ozone Control in St. Louis", 75th Annual Meeting of the Air Pollution Control Assoc., New Orleans, June 1982.

Cole, H. and Fowler, H.: Draft User’s Manual for the Shoreline CRSTER Models, US. EPA. The authors developed a new model capable of simulating shoreline fumigation. 1982

"Evaluation of the Airshed Model Performance for St. Louis", Third Joint Conference on Applications of Air Pollution Meteorology, American Meteorological Society/Air Pollution Control Association, San Antonio, Texas, January, 1981.

"Basis for Simplified Modeling Approaches for Short Term NO2 Concentrations" 75th Annual Meeting, Air Pollution Control Association, June 1981, Philadelphia (with E. Meyer and R. Kelly).

"Status of the Short-Term NO2 Standard and Microscale NO2 Modeling", Transportation Research Board (National Academy of Sciences), January, 1981, Washington, DC

U. S. EPA, "Summary Report on Modeling for the Avon and East Lake Power Plants", June, 1980.

"The Use of Atmospheric Dispersion Modeling for Incinerators Emitting Hazardous Wastes", Chapter for US EPA Background Document, Section 264.34 Standards for Hazardous Waste Incineration, Resource Conservation and Recovery Act, Oct. 1980 (with John Summerhays).

"Technical Basis for Developing Control Strategies for High Ambient Concentration of NO2 ”US EPA, OAQPS Guidance Document", September, 1980, (with Don Sennett and Ned Meyer), EPA 450/4-80-017.

"A Review of Techniques Available for Estimating Short-Term NO2 Concentrations" Journal of Air Pollution Control Association, August, 1979 (with John Summerhays).

U. S. EPA, "The Impact of NOx Diesel Waiver on NO2 Concentrations Downwind of a Major Line Source", A Report to the Office of Mobile Source Air Pollution Control, May 1979.

U. S. EPA, "Pittston Oil Refinery, Eastport, Maine: Potential for Violation of the PSD Increment", Report to Region I, EPA. June 1978.

"Photochemical Air Pollution Transport in the Chicago-Milwaukee Corridor, a Case Study", Annual Meeting American Association for the Advancement of Science, Washington, DC, February 1978.

"Photochemical Oxidant Transport: Mesoscale Lake Breeze and Synoptic Scale Aspects." Journal of Applied Meteorology, July 1976, (with Walter A. Lyons).

"Fumigation and Plume Trapping: Aspects of Mesoscale Dispersion on the Shores of Lake Michigan during Periods of Stable, Onshore Flow", Journal of Applied Meteorology, April 1973 (with W. Lyons).

"Air Pollution and Weather", The Science Teacher, December 1973.

"The Impact of the Great Lakes on the Air Quality of Urban Shoreline Areas: some practical applications with regard to air pollution control policy and environmental decision-making", 15th Conference on Great Lakes Research, Madison, Wisconsin, April, 1972.

APPENDIX A.3

! H. D. Howell, “Review of Fish Habitat Related matters in the Environmental Impact ! Statement and associated Technical Support Documents” (January 2011).

" Curriculum Vitae, H. D. Howell. Review of Fish Habitat Related Matters in the Environmental Impact Statement and associated Technical Support Documents

New Nuclear - Darlington Environmental Assessment NK054-REP-07730-00029

Prepared for Lake Ontario Waterkeeper 600 Bay Street, Suite 410 Toronto, Ontario

Stringer’s Environmental Services

H. D. Howell, B.Sc. Jan. 25, 2011

1 Review of Fish Habitat Related matters in the Environmental Impact Statement and associated Technical Support Documents New Nuclear - Darlington Environmental Assessment

1.0 Introduction

In early 2009, the writer agreed to become part of a specialist team contracted by Lake Ontario Waterkeeper (LOW) to review the Environmental Impact Statement (EIS) and selected Technical Support Documents (TSDs) prepared by Ontario Power Generation (OPG) concerning the proposed development of New Nuclear – Darlington (NND). The EIS and the TSDs (28 in total) were released by OPG in late Sept. 2009.

The NND Project will involve the construction and operation of up to four nuclear reactor units supplying up to 4,800 MW of electrical capacity to meet the baseload electrical requirements of Ontario. The proposed site is immediately east the existing Darlington Nuclear Generating Station (DNGS) located on the shore of Lake Ontario in the Municipality of Clarington, within the Regional Municipality of Durham, about 70 km east of Toronto.

OPG began the formal process of seeking approval of the project in 2006 with the submission to the Canadian Nuclear Safety Commission (CNSC) of an “Application for Approval to Prepare a Site” for the Project. The application to the CNSC triggered the Canadian Environmental Assessment Act (CEAA) and in 2008, the federal Minister of Environment announced referral of the NND Project to a review panel pursuant to the CEAA. Because both CNSC and the Canadian Environmental Assessment Agency (CEA Agency) have responsibilities for the approval process, a Joint Review Panel (JRP) was established to undertake regulatory and EA review of the process. This review will include a public hearing conducted by the JRP.

As part of the EA process, both Federal and Provincial Agencies have been requested by the JRP to assist in the review of the EIS and provide input and comment to the JRP. In addition to the agency reviews, CEA Agency has provided Participant Funding to a number of NGOs, including LOW. This funding has enabled LOW to engage technical experts to assist LOW to: -Review the EIS prepared by OPG; and -Prepare for and participate in the public hearing.

1.1 Review Responsibilities and Process

The focus of my involvement has been the anticipated fish habitat related impacts of the project with particular reference to Lake Ontario. This has included:

1) review of relevant sections of the EIS;

2 2) review of numerous TSDs with particular reference to the Aquatic Environment Existing Environmental Conditions TSD and the Aquatic Environment Assessment of Environmental Effects TSD (AEAEE TSD); 3) review of all Information Requests (IRs) submitted by the Department of Fisheries and Oceans (DFO), and the Ontario Ministry of Natural Resources (OMNR); 4) review of the responses from OPG to those requests; 5) review of other correspondence and the minutes of meetings involving DFO, OMNR and OPG: 6) review of Aquatic Environment Compensation Report and associated information tabled by OPG on Aug. 30, 2010.

The extent of this review was facilitated by the availability of the documents on the CEAA website (http://www.ceaa.gc.ca/050/details-eng.cfm?cear_id=29525). Without this source, undertaking this review would have required substantially more time and effort.

In addition to reviewing the relevant sections of the EIS and TSDs, much of my effort has focused on reviewing the interchange of information between DFO and OPG. DFO has the legislated responsibility for protecting fish habitat and has substantial staff and financial resources dedicated to fulfilling this responsibility. Regarding this EIS, they are a Responsible Authority pursuant to section 12(3) the CEA Act and have a major role in the review of the EIS. It quickly became apparent that DFO had substantial concerns with the content of the EIS and that my concerns were generally consistent with those of DFO.

1.2 Expertise

My expertise in conducting this review stems from my training and experience as a fisheries biologist with nearly 30 years of experience working for the OMNR. During this period, I was involved in many fisheries related planning and development initiatives and developed comprehensive knowledge of the Fisheries Act and its application in Ontario. Since retiring in 1998, I have been an independent consultant focusing on the impact of construction activities (mainly highways and bridges) on fish habitat.

I have been involved in numerous pre-construction impact assessments including preparing fish habitat impact assessment reports to meet standards outlined in a joint DFO/OMNR/Ontario Ministry of Transportation protocol. I have developed fish habitat compensation strategies to meet DFO requirements for authorizing the harmful alteration, disruption or destruction of fish habitat. I have also conducted hundreds of ‘during construction’ inspections to assess the efficacy of and compliance with mitigation and compensation measures defined for the construction projects. As a result of these activities, I am very familiar with the current legal and technical framework protecting fish habitat in Ontario.

3 2.0 Key Issues Impacting Fish Habitat

In the Executive Summary for the EIS, OPG has identified 5 major ‘alternative means’ for carrying out the project (EIS – pgs. ES-2, ES-3). My review of the documents indicated that the alternatives for condenser cooling and for the management of excavated materials were those with the most potential impact on fish and fish habitat in Lake Ontario. These issues have also been the focus of most of the interchange between the fisheries resource agencies (DFO, OMNR) and OPG.

2.1 Condenser Cooling

Regarding condenser cooling, the alternatives identified by OPG include one that involves once through lake water cooling and 3 similar options involving cooling towers.

OPG’s stated preference is to employ once through lake water cooling. This option involves the intake and discharge of up to 250 m!/s of lake water through intake and discharge structures placed in Lake Ontario. This volume is similar to spring flows in the Trent River at Trenton (Water Survey of Canada data).

OPG is proposing to use designs for these structures that are similar to those installed when DNGS was built. Rather than the more conventional design involving large intake and discharge channels which function as watercourses, the DNGS intake is a large circular, 85 m diameter, porous bottom, submerged intake located 700 m from the shore at a depth of 10 m. It was designed to minimize the impingement and entrainment of fish.

The DNGS discharge structure is essentially a large pipe extending 1,600 m into Lake Ontario with a diffuser length of 900 m. The first pipe segment from shore to about 700 m offshore is a tunnel beneath the lake bottom. The second, diffuser segment, extending from about 700 m to 1,600 m, has 1 m diameter exit ports that sit on the lake bottom at depth contours of 10 to 12 m. There are 90 ports over the entire length of the diffuser.

Because the volumes of water for NND would be greater than for DGNS (250 m!/s vs 150 m!/s for DNGS), both structures would have to be scaled up at NND.

Regarding the cooling tower options for condenser water cooling, the volumes of water being taken in (6 m!/s) and discharged (1.5 m!/s – lower due to evaporative losses) would be much lower than for once through cooling. OPG has indicated the intake would be at a similar location to that used for the once-through cooling intake but has not indicated a specific design. The discharge would be a single port outfall placed at a water depth of 12 m at a location to minimize interaction with the intake and oriented such that the flow is directed offshore.

4 2.1.1 Effects on Fish and Fish Habitat - Once Through Option

The ‘once through’ option will involve the intake and discharge of large volumes of water from Lake Ontario through very large structures. The result will be: a) the mortality of significant numbers of fish through impingement and entrainment; b) negative impacts on fish and fish habitat due to the discharge of a large amount of heat directly into the lake; and c) the disruption or destruction of fish habitat due to the construction and presence of the intake and discharge structures themselves.

The much smaller volumes of water and smaller structures associated with any of the cooling tower options should have significantly reduced impacts.

2.1.1.1 Impingement and Entrainment

Fish mortality resulting from impingement at the DNGS intake structure has been assessed by OPG and, while it is significantly reduced from that experienced at other generating stations on the Great Lakes employing more conventional designs, the annual losses were estimated to range from approx. 14K to 26K fish. OPG’s estimates for losses that would occur at NND, where flow volumes would be greater, are approx. 23K-46K. At other sites on the Great Lakes in both the U.S. and Canada, where different structures are used, losses are 10 to 2000 times greater (Table 3.3.3.2-2 AEAEE TSD. Pg 3-27).

Entrainment normally involves eggs and larval fish which can exist in the natural environment in much larger numbers than the older age classes susceptible to impingement. They are carried through the cooling water system and mortality is a result of thermal shock. The numbers entrained at DNGS have been estimated to be 7.6M in 2006 and 16.8M in 2004. Estimated losses at other sites have been substantially higher. For NND, the 250 m!/s once-through flow is expected to entrain more organisms than DNGS.

Despite the apparent reduction in fish mortality (compared to more conventional designs) associated with the intake design employed at DNGS, large numbers of fish are still being impinged and entrained. Simply changing the scale of the structures to cope with the increased volumes is expected to result in even larger numbers of organisms being impacted.

The design of the DNGS structures was developed over 20 years ago. OPG appears to have accepted this design as good enough and it is not evident that they have evaluated any amendments to the DNGS design that may further reduce these losses. They should be required to do so.

5 2.1.1.2 Thermal Discharge

The negative effects of heated discharge water on fish are mostly a result of the temperature differential that exists between the receiving water and the discharge water. Fish that become acclimated to the ambient temperature in the lake will tend to avoid areas where there is a rapid temperature change.

The diffuser design used at DNGS has achieved the objective of preventing the dispersion of heated water, that is more than 2ºC above ambient, beyond a mixing zone along the diffuser alignment. There is minimal contact of heated water with lake bed substrates and no propagation of an extensive thermal plume as occurs with stations that employ surface discharge channels.

Although the diffuser design employed at DNGS does result in rapid mixing of discharged water with lake water, it does generate an area of higher temperature water in the immediate vicinity of the discharge. This warmer water would result in fish avoiding this area and therefore reduce the productive capacity of the site.

Despite the increased volumes associated with NND, it is not apparent that OPG has considered design changes that may further reduce the extent of the impacted area. Again, they should be required to so.

2.1.1.3 Intake and Discharge Structures

The installation of the large structures required to intake and discharge the volumes of water needed for once through cooling will directly impact fish habitat.

The proposed intake would be a concrete structure at least 85m in diameter. Its hard, relatively flat surface would replace the natural substrates with an area that has a much lower utility for fish and the organisms they feed upon.

The construction activities associated with the installation of such a large structure will result in further impacts on fish habitat. The reviewed documents indicate that one possible construction method is to utilize a berm that would occupy 4.62 ha of the bottom of Lake Ontario to facilitate installation of the structure ‘in the dry’. This would preclude any use of the area by fish while the berm is in place.

Very scant information is provided about how the discharge structure may be installed but it is likely that the construction process required would result in further habitat impacts.

The EIS should provide a much better evaluation of the direct impacts of the structures, and the construction processes required for their installation.

6 2.1.2 Effects on Fish and Fish Habitat – Cooling Towers Options

Regarding the impacts on fish and fish habitat associated with any of the cooling tower options, because of the dramatically reduced volumes of intake and discharge water and the reduced size and footprint of the structures themselves, any of these options would have a much lower impact on fish and fish habitat in Lake Ontario.

Despite this lower impact due to their reduced size, the most effective designs should be incorporated into these much smaller structures to reduce their impacts to the greatest extent possible.

2.2 Excavated Materials Management

Excavated materials management involves the excavation, relocation and long term disposition of a large volume of earth and rock overburden needed to prepare the site for the installation of the reactors and associated structures. OPG’s stated preference is that the quantity of excavation be minimized and that this material be managed, to the extent possible, on the DN site, including an amount placed as lake infill to benefit both the NND Project and the ongoing physical security of DNGS.

Because the number and type of reactor are unknown, OPG examined 3 alternative layout concepts and proceeded to evaluate what is expected to be a ‘worst case’ or ‘bounding’ scenario.

‘Lake infilling and shoreline protection associated with the NND Project will extend from the eastern limit of the DN site to approximately the DNGS intake channel, and about 100 m into the lake on its western limit and approximately 450 m on its most eastern dimension. This will result in the loss of approximately 40 ha of nearshore habitat. (EIS – pg. 5-48)

Fronting the existing DNGS site, the area filled will extend the previously filled area further out into the lake so that its outer edge will occur in deeper water (4-5 m). In the decades since this previous filling occurred, it is probable that a robust community of fish and other aquatic organisms have become well established on the armored fill slope.

From the east limit of the DNGS site to the east end of the property, the shoreline is natural with a high steep embankment extending back from the water’s edge and gradually increasing depths extending out from shore. The outer limit of the proposed fill area would be in the approx. 5 m depth range. This area provides habitat for a broad array of fish species characteristic of the Lake Ontario near shore environment.

7 2.2.1 Effects on Fish and Fish Habitat

The infilling of up to 40 ha. of near shore habitat is the most obvious immediate negative impact on fish and fish habitat resulting from this project. Its loss would be permanent.

My concerns regarding the proposed infilling are: 1) there appears to be little consideration of any site layout option that does not require the infilling of up to 40 ha. 2) OPG has concluded that because the infill affects only a small portion of the habitat of species found along this section of the shoreline and there are extensive areas of similar habitat elsewhere, the effects of the infilling should be considered negligible. 3) a fish habitat compensation plan is being relied upon by OPG as a key to mitigating the effects of the infill and facilitating their conclusion that the infilling will have no residual environmental effects.

2.2.2.1 Site Layout Options

In the EIS, OPG presents 3 alternative model plant layouts (EIS – pgs 2-21 to 2-23) showing options for the number and type of reactors and for the type of cooling water system. All are shown to require 40 ha of lake infilling.

At a later date, in response to Information Requests from DFO, 12 additional alternative plant layout options were tabled by OPG for discussion purposes. These do include options which would reduce the area of the required infilling but in all cases, some encroachment into Lake Ontario would be required.

In examining the options, it appears to this writer that the proposed arrangement of the reactors, whether 3 EPRs or 4 of the other 2 types, is having a significant impact on the overall site layout and the amount of lake infilling that OPG wishes to undertake. In all options, the arrangement of the reactors has been linear with a N-S orientation. This results in a need for the south end of the reactor array to encroach on Lake Ontario. It is not evident in the reviewed material that other optional arrangements and/or orientations, which could reduce or eliminate this encroachment, have been considered by OPG. I have seen no explanation as to why the reactors could not be in an ‘L’ shaped array or oriented NE/SW so their southern extremity would be further north and not require lake infilling.

Regarding the proposed increase in the fill area fronting the existing DNGS site, the rationale for filling in this area is difficult to ascertain. There is a comment about security and the plant layout alternatives make reference to the area being utilized for building relocation. I am of the view that this proposed fill area is simply a means to dispose of additional excavated material.

8 2.2.2.2 Significance of Infill Area

At the conclusion of Section 3.3.1.6 of the Aquatic Environment Assessment of Environmental Effects TSD (pg 3.21), it is stated that, because the infill does not affect a meaningful proportion of habitat for any of the VEC indicator species, there are extensive areas of similar habitat all along the north shore of Lake Ontario, and compensation for habitat loss will be undertaken, the effects of the infilling of 40 ha. on the aquatic habitat of Lake Ontario should be considered to be of negligible overall environmental impact. This is not credible.

Nearshore habitats are generally the most productive areas within aquatic ecosystems. Because of sunlight penetration to the substrate and nutrient inputs from adjacent land areas, primary productivity is usually highest and many fish species find suitable spawning and rearing habitat in these shallower, warmer areas.

The above mentioned section of the AEAEE TSD outlines the effects that the infill will have on numerous fish species known to be present in the nearshore waters along this section of Lake Ontario. Although for many of the species, the proposed infill area is not considered critical habitat (i.e. spawning and/or nursery area), the area does provide critical habitat for emerald shiner, alewife, round whitefish and lake trout. The loss of even small areas of critical habitat is normally considered significant.

Of the 4 species listed, round whitefish is the species of greatest concern. It has been identified by OMNR as likely to experience significant impacts as a result of this project. This section of the north shore of Lake Ontario is known to provide spawning and nursery habitat for this species and the loss of any portion of this critical habitat must be considered significant.

2.2.2.3 Fish Habitat Compensation Plan

As outlined in more detail in the following section, DFO takes the stance that development of a fish habitat compensation plan can not be considered a mitigation measure. Their position is that the need for compensation results from the fact that residual negative effects remain after all suitable mitigation measures have been incorporated into a project. Implementing a project that has residual negative effects will result in harmful alteration, disruption or destruction of fish habitat.

Where a project is likely to result in any of these harmful impacts, the proponent must apply for an authorization to undertake the project and provide a plan prescribing works that will compensate for these harmful effects.

OPG clearly acknowledges that they will require an authorization from DFO to undertake lake infilling, having submitted an application and a preliminary compensation strategy in Sept. 2009.

9 It is, therefore, difficult to rationalize the conclusion in the EIS that no residual environmental effects will result from lake infilling.

For reasons outlined in the sections above, I am of the view that any lake infilling should be considered a residual environmental effect and the magnitude of that effect should be reduced to the extent possible, or even eliminated.

3.0 DFO’s Approach to Protecting Fish and Fish Habitat

DFO is the designated federal agency with responsibilities to administer most of the provisions of the Fisheries Act. The most important provisions concerning this project are Section 32 and Section 35.

3.1 Fisheries Act Section 32

Section 32 provides that ‘No person shall destroy fish by any means other than fishing except as authorized by the Minister or under regulations made by the Governor in Council under this Act’.

This section has application to this project because, irrespective of the cooling water option finally approved for implementation by OPG, fish will be killed by impingement or entrainment and OPG will need an approving ‘authorization’ or a regulation to comply with the Act.

3.2 Fisheries Act Section 35

Section 35 of the Act is the principal fish habitat protection section. It reads: 35 (1) No person shall carry on any work or undertaking that results in the harmful alteration, disruption or destruction of fish habitat. (2) No person contravenes subsection (1) by causing the alteration, disruption or destruction of fish habitat by any means or under any conditions authorized by the Minister or under regulations made by the Governor in Council under this Act.

In the day to day application of this section, the harmful alteration, disruption or destruction of fish habitat is referred to as a ‘HADD’.

The section has application in a number of ways: -the proposed infilling of a portion of Lake Ontario will constitute the destruction of fish habitat, -construction activities require to undertake the project are likely to harmfully alter or disrupt fish habitat, -the cooling water intake and discharge devices will harmfully alter fish habitat, and

10 -the elevated temperature of discharged cooling water is likely to harmfully alter or disrupt fish habitat.

3.3 Habitat Protection Policy

DFO’s policy objective regarding fish habitat is to ‘Increase the natural productive capacity of habitats for the nation's fisheries resources, to benefit present and future generations of Canadians.’ To implement this objective, they have developed a comprehensive process guided by the principle of ‘no net loss’.

3.4 Habitat Protection Process

The process managed by DFO regarding Section 35 requires proponents of works that may harmfully alter, disrupt or destroy fish habitat to provide detailed information about the project and apply for an ‘authorization’ to undertake the works. DFO’s preference is that any anticipated harmful effects be mitigated through amendments to the design or location of the project and/or the implementation of habitat protection measures.

If it is determined that there are residual harmful effects once all technically and financially viable mitigation measures have been incorporated, DFO will consider whether these residual effects are acceptable and can be compensated for by the proponent through habitat improvement or habitat creation. Only if DFO is satisfied that the residual harmful effects are acceptable and are adequately compensated will they proceed to issue the ‘authorization’.

3.5 DFO’s Review of this EIS

As stated in Section 1.1, this writer has accessed and reviewed all the available documents concerning DFO’s review of the EIS. There has been considerable interchange between DFO and OPG, including 21 proposed information requests that were included in requests from the JRP to OPG. The review of the OPG responses, and DFO’s reaction to those responses, indicates that not all of DFO’s concerns have been fully resolved, although both DFO and OPG have continued to work co-operatively on these issues.

In an effort to satisfy DFO’s ongoing concerns, on Aug. 5, 2010, OPG convened a day long workshop involving CNSC, DFO, OMNR, EC and the Central Lake Ontario Conservation Authority (CLOCA). OPG tabled their planned responses to a number of IRs which addressed the main concerns expressed by DFO. The information covered in those IRs was addressed under 4 subject areas: 1) Lake Infill and Intake/Diffuser Options 2) Round Whitefish Action Plan 3) Shoreline Processes 4) Habitat Compensation Plan

11 Subsequent to the workshop, OPG submitted the Aquatic Environment Compensation Report(AECR) on Aug. 30, 2010. It is considered a key document outlining how OPG anticipates providing compensation for any residual harmful effects resulting from the project. It is anticipated that DFO will need to be very satisfied with its content before serious consideration will be given to granting an authorization.

4.0 Remaining Issues Despite the number and scope of the issues covered in DFO’s numerous IRs and the significant information tabled by OPG in response to these IRs, this reviewer has some additional concerns that were not part of the DFO/OPG interchange or seem to be inadequately addressed to date.

4.1 Plant Layout Options As mentioned previously, OPG has tabled numerous optional conceptual plant layouts, the most recent of these being included in the material presented during the Aug. 5 workshop. In all cases, the reactor buildings have been shown arrayed in a line oriented N-S on the property. The area to be occupied by these structures is restricted to the north by the presence of the railway line through the middle of the property and its southern boundary extends slightly or significantly into Lake Ontario (depending on the reactor type), thus requiring lake infilling.

One of the IRs submitted by DFO addressed the issue of moving the rail line to facilitate shifting the proposed location of the reactor buildings further north and avoiding any lake infilling. OPG provided a response indicating that the costs, time delays and additional environmental impacts associated with moving the line were unacceptable.

In no case that this reviewer has seen, does OPG consider re-orienting the reactor buildings to a configuration other than a straight line oriented N-S. Considering that many of the optional conceptual layouts show differing sizes, shapes and configurations for other on-site structures or spaces, it seems that OPG could have considered other configurations for the reactors. If the layout of the reactors could be ‘L’ shaped or oriented in a NE-SW direction, it appears that it should be possible to accommodate all the required development without any, or with only very minimal, lake infilling.

4.2 Habitat Impacts of Once Through Cooling Structures

The content of the AECR regarding the area of fish habitat in Lake Ontario that may be lost due to this project has been confined to the proposed 40 ha. infill. Not included is the area that will be occupied by the CCW intake and discharge structures associated with the once-through cooling option – OPG has estimated these would occupy approx. 2.0 ha. Since OPG has indicated that the EIS has been prepared using a ‘bounding’ approach which assesses the worst case scenario, the area occupied by these structures should be added to the 40 ha. to ensure that the required habitat compensation works are sufficiently extensive.

12 4.3 ‘During Construction’ Habitat Impacts

Although the fish and fish habitat impacts of the ‘as built’ facility have received considerable attention in the EIS and in DFO’s review, the impacts of the construction activities have not been extensively addressed. As an example, the documents indicate that one possible construction method for installing the once through CCW intake structure is to utilize a berm that would occupy 4.62 ha of the bottom of Lake Ontario to facilitate installation of the structure ‘in the dry’. This would constitute a harmful disruption to fish habitat and should be accounted for in the proposed compensation plan.

Accepting that determining all ‘during construction’ impacts would be very difficult to do until more detail is available regarding the actual works to be undertaken, recognition of the need to compensate for these impacts should be more strongly stated in both the EIS and the AECR.

4.4 On-going Habitat Disruption Associated with Thermal Discharge

In Table 3.4 -1 of the Aquatic Environment Assessment of Environmental Effects TSD, is a section that reads as follows:

“The area of the thermal discharge mixing zone must also be taken into account as a physical habitat disruption (primarily turbulence, but also temperature to some extent) and be included in the fish habitat offsets or compensation associated with section 35(2) of the FA authorization”

The area of Lake Ontario impacted by the thermal discharge, and therefore harmfully altered, has not been adequately taken into account in the AECR. The area of this impact should be included in the total area that requires compensation.

4.5 Extent of Required Fish Habitat Compensation

When DFO determines that there are residual harmful affects (i.e. a HADD) associated with a project, they may require the proponent to provide compensation works that are equivalent in area to the area of the HADD or they may seek a larger area of compensation. While the AECR includes a number of different compensation options, it makes no commitment regarding the area of the compensation works. It can be implied that OPG is prepared to provide compensation to whatever extent DFO may require, but this is not evident in the content of the AECR.

13 5.0 Concluding Remarks

5.1 Condenser Cooling

Considering the impact on fish and fish habitat in Lake Ontario, the employment of cooling towers, of whatever type, must be considered the preferred option.

Once through cooling will result in: a) the mortality of significant numbers of fish through impingement and entrainment; b) negative impacts on fish and fish habitat due to the discharge of a large amount of heat directly into the lake; and c) the disruption or destruction of fish habitat due to the construction and presence of the intake and discharge structures themselves.

Because of the dramatically reduced volumes of intake and discharge water, and the reduced size and footprint of the intake and discharge structures themselves, any of the cooling tower options will have greatly reduced impacts, particularly if best available designs are implemented.

5.2 Excavated Materials Management

Regarding OPG’s preferred plant layout and the resulting extent of lake infilling, the conclusion I have reached is that they are committed to undertaking some degree of infilling (to the max they can get approval for) as a lower cost means of disposing of a large volume of fill from the site. Their apparent unwillingness to propose optional layouts that would avoid lake infilling is a compelling indicator of their wishes. I do not feel that OPG should be allowed to infill the lake simply as a means of disposing of excavated material.

As stated in an earlier section, I feel infilling should be avoided since it generally impacts the most productive, nearshore areas of a waterbody.

Notwithstanding this clear preference, some degree of infilling could be acceptable if the infill area is relatively low in productivity and the required compensation works will result in the establishment of additional, high productivity areas, thus yielding a net improvement in the overall quality or extent of fish habitat.

If it is concluded that some lake infilling is necessary, the extent of the proposed compensation works should be maximized to produce the greatest improvement in the overall productivity of areas where those compensation works are undertaken. This would yield the greatest probability that there will be no overall productivity losses – ergo the reason for my interest in ensuring that all residual impacts, including those associated with the construction activity itself, are accounted for.

14 Regarding the draft AECR, I am of the opinion that OPG has produced a good basis for completing an appropriate fish habitat compensation plan, once the actual extent of fish habitat impacts on Lake Ontario is known. This determination can only be made after decisions are in place concerning the actual size of the infill area needed to accommodate the reactors and the approved condenser cooling water option.

H.D. Howell Jan. 25, 2011

15 H. Douglas Howell, B.Sc., Principal – Stringer’s Environmental Services

Education/Training Honours Bachelor of Science - Marine Biology - University of Guelph – 1969 -numerous related courses while employed with OMNR -completed training in MTO/DFO/OMNR Protocol for Protecting Fish and Fish Habitat on Provincial Transportation Undertakings – June, 2006

Professional Experience Biologist in Training – Commercial Fisheries Section, Ministry of Natural Resources – 1969/70 Extension Biologist – Lake Huron District, OMNR – 1970/73 Fish and Wildlife Program Supervisor – Cambridge, Niagara & Thunder Bay Districts, OMNR – 1973/86 District Manager – Chapleau and Peterborough Districts, OMNR – 1986/97 Manager, Wildlife Section – Fish and Wildlife Branch, OMNR – 1997/98 Regional Director, Ontario – Rocky Mountain Elk Foundation Canada – 1999/2002 Environmental Consultant – Stringer’s Environmental Services(SES)– 1998-present

Professional Affiliations Member of American Fisheries Society – 1969/1993 and present Member of Canadian Society of Environmental Biologists – 1972/1986 MTO RAQS qualified Fisheries Assessment Specialist and Fisheries Contract Specialist

Recent Reports/Publications 2007. Preliminary Fisheries and Aquatic Ecosystems Technical Report. Highway 41, Madawaska River Bridge southerly for 9.1 km. Preliminary Design/Environmental Assessment MTO W.P. 197-99-00 2008. Fish and Fish Habitat Impact Assessment Report Highway 7 and County Rd 41/Hwy 41, Intersection Improvements Preliminary Design/Environmental Assessment MTO W.P. 4173-05-00 2008. Fish and Fish Habitat Impact Assessment, Bridge # 57044 Replacement, East Cross Creek, Golf Course Rd, City of Kawartha Lakes 2009. Fish and Fish Habitat Impact Assessment, Siberia Rd Bridge Replacement, Madawaska River, Municipality of Hastings Highlands. 16pp 2010. Fish and Fish Habitat Impact Assessment, Sideroad 22 Bridge, Town of Halton Hills, Region of Halton. 17pp 2010. Fish and Fish Habitat Impact Assessment, MTO WP 67-99-00 Hwy 7 from the east limit of Norwood to the west limit of Havelock, 55pp 2010. Fish and Fish Habitat Existing Conditions, MTO WP 4051-08-01 Hwy 132 from 1.6km east of Constant Creek Bridge to 0.7km east of Stone Rd., 57pp.

Areas of Expertise/Experience 35+ years of progressively more challenging professional and managerial experiences with emphasis on fish and wildlife management

Fisheries Resource Management and Planning - Great Lakes management teams, focus on lake wide fisheries management planning and administration, district fisheries management and habitat protection, review and input to numerous highway, pipeline and forest access road development projects to ensure inclusion of appropriate measures to protect fish habitat

Fisheries Contract Specialist -inspections and daily reports regarding compliance with the conditions of the ‘authorization for works or undertakings affecting fish habitat’ regarding: MTO Contract 2004-4004 Highway 401-Salmon River Bridge Rehabilitation - April, 2005 to Nov., 2006, included participation in the redesign of fish compensation works. MTO Contract 2007-4027 - 2.6 km west of Marmora to the west limits of Marmora, and from the east limits of Marmora east to 6.6 km west of Hwy 62. April 2007 to Nov. 2008. MTO Contract 2008-4006 Highway 401 Trent River Bridge Rehabilitation and Improvements to Highway 401, Feb 2009 to present; MTO Contract 2008-4030 Hwy 7 from 0.6 km east of Highway 37, easterly for 8.0km, Municipality of Tweed, County of Hastings, Feb., to Dec, 2009; MTO Contract 2009-4011 – Hwy 7 Improvements from 0.1 km east of Drummond Line to 0.3 km east of Highway 28. Peterborough County. July 2009 to Dec. 2010 -have produced 250+ daily inspection reports plus the construction phase summary reports for the above projects -projects involved daily inspections of numerous sediment and erosion control measures for compliance with the fish and fish habitat mitigation measures identified as conditions in the ‘authorization’ for these projects -inspection and assessment of the installation of fish habitat compensation works on 4 of these Contracts – two of the 4 included stream re-alignments requiring the installation of new channels -also assisted in the installation of fish habitat compensation works at Highway 60 Brewers Lake Culvert, Algonquin Park, Contract 2007-4200 – involved modifications to existing riffles and pools and installation of rock baffles inside the culvert

Fisheries Assessment Specialist - review and assessment of potential impacts on fish and fish habitat associated with municipal bridge and culvert replacement – 11 sites in 2005, 7 sites in 2006, 13 sites in 2007, 6 sites in 2008, 8 sites in 2009, 7 sites in 2010 - prepared reports concerning fish and fish habitat existing conditions and impact assessment for inclusion in applications for review by local Conservation Authorities and/or DFO -site review and fish and fish habitat impact assessment for 9 provincial highway reconstruction projects in MTO’s Eastern Region in association with Warme Engineering and Biological Services

Fisheries Compensation Plans - preparation of fish habitat compensation plan associated with impacts resulting from the construction of a new bridge over Gull Creek, County of Lennox and Addington. -preparation of compensation strategy for MTO WP 67-99-00, Hwy 7 from the east limit of Norwood to the west limit of Havelock. APPENDIX A.4

! W. Ruland, “Independent Review of Hydrogeological Issues Pertaining to the OPG ! Environmental Impact Statement for the Proposed Darlington New Nuclear Plant ! Project” (February 2011).

" Curriculum Vitae, W. Ruland. Independent Review of Hydrogeological Issues Pertaining to the OPG Environmental Impact Statement for the Proposed Darlington New Nuclear Plant Project

Prepared for: Lake Ontario Waterkeeper c/o Mr. Mark Mattson, President

Prepared by Wilf Ruland (P. Geo.)

February 16th, 2011

page 1 Table of Contents

1) Introduction...... 3

2) The Overall Inadequacy of the EIS...... 3

3) Overview of Key Information Missing from the EIS...... 4 a) No Decision on Which Reactor Type is to be Used...... 4 b) Insufficient Information and Predetermination on Lake Infill Issue ...... 4 c) Lack of Plans for Water Quality Protection During Site Preparation/Construction . 5 d) EIS Lacks Plans for Dealing with Wastes or Contaminated Soils...... 5 e) EIS is Missing Clear Plans/Criteria for Contaminated Water Discharges...... 6 f) Impacts of Nuclear Waste Disposal Not Considered...... 10

4) Lack of Commitment to Best Industry Management Practices...... 10

5) Case History of Existing Darlington Nuclear Facility not Utilized in EIS...... 11

6) Inadequate/Incomplete Water Quality Impact Assessment...... 12 a) Introduction...... 12 b) Impact Assessment does not Consider A Variety of screened-out Potential Impacts12 c) Regulatory Criteria for Surface Water Treatment/Discharges not Specified...... 13 d) Lack of Details about Required Monitoring Plans ...... 13 e) Lack of Details about Required Contingency Plans ...... 13 f) Summary ...... 14

7) Potential Effects of the Nearby St. Mary’s Quarry on the Proposed NND Facility...... 14

8) Discussion...... 15

9) Conclusions...... 16

10) Recommendations...... 17

_____

Appendix 1) Curriculum Vitae of Wilf Ruland...... 18

Appendix 2) List of Documentation Reviewed or Referenced...... 28

page 2 1) Introduction

I am a hydrogeologist, and I have worked as an environmental consultant for over 20 years (2 years in Germany and 22 years in Canada). I am a specialist in groundwater and surface water contamination issues, and have investigated many such issues over the course of my consulting career. I have given testimony as an expert witness on hydrogeological issues before various boards, including the Environmental Assessment Board, the Joint Board, the Ontario Municipal Board and the Niagara Escarpment Commission. A copy of my Curriculum Vitae is included in Appendix 1 of this review. I have been retained as an expert (by Lake Ontario Waterkeeper) to provide an independent review of the Environmental Impact Statement (EIS) of the proposed Darlington New Nuclear Power Plant Project which has been proposed by Ontario Power Generation (OPG). The focus of my review are the potential groundwater and surface water quality impacts related to inorganic, organic, and radiological contaminants which may be associated with any aspect of the proposal. The adequacy of the EIS (from a hydrogeology perspective) can be measured by the degree to which the EIS provides: - a comprehensive assessment of potential water quality impacts at all stages of the project including site preparation and construction, nuclear plant operation, and site decommissioning; - detailed proposals for mitigation, - appropriate monitoring plans and realistic contingency plans. In order to carry out this work, I have reviewed a series of documents and the most important of these are listed as references in Appendix 2 of this review. I have toured the area of the proposed New Nuclear Darlington Project (on June 29, 2010), and discussed various aspects of the proposal with the OPG representatives who were present on the day of the tour. I have also submitted (through Lake Ontario Waterkeeper) a series of Information Requests (number 195 through 200) which were forwarded to OPG, and have been responded to by OPG subsequently in Document #288.

This review outlines my findings, conclusions and recommendations regarding the EIS of the potential impacts of the proposed Darlington New Nuclear Power Plant Project.

2) The Overall Inadequacy of the EIS

Following careful review, it is my professional opinion that the EIS Report has been issued prematurely. The EIS does not provide an adequate assessment of the potential impacts of the proposed New Nuclear - Darlington (NND) project. Critical environmental protection plans (even at a conceptual level) are missing entirely from the EIS and supporting documentation. The list of omissions and shortcomings of the EIS includes the following: • there is no decision yet on which reactor type is proposed to be used; • there is a predetermined decision to infill up to 40 hectares of Lake Ontario shoreline; • no plans for erosion control and stormwater management during preparation/construction; • there are no plans for dealing with existing wastes or contaminated soils, and there are no construction waste management plans; • there is no environmental management plan; • there is no environment protection plan for handling, storage and disposal or fuel oils, solvents and lubricants; and there are no spills response plans; • there are no groundwater or surface water quality monitoring plans; • there are no contingency plans to cover the response to any emergencies which may arise.

page 3 In essence much of the EIS simply represents an assessment of a “plan to have a plan” and does not include even the most fundamental details of critical aspects regarding water quality protection, which is not satisfactory for the environmental impact assessment of a project of this magnitude. The EIS puts off many major decisions pertaining to the proposed undertaking and simply offers blanket assurances that environmental impacts on groundwater and surface water quality will be taken care of without specifying how this is to occur. If the EIS is approved in its current form, it would allow many of the plans required to mitigate the impacts of this project on water quality to evade public scrutiny. At the same time, for many of these same plans (which have yet to be developed) there is an assumption that they will be totally successful in mitigating all impacts thus scoping numerous potential impacts out of the EIS. In my professional opinion, this is an unacceptable approach to be taking for an EIS of this importance and magnitude.

3) Overview of Information Missing from the EIS

As discussed in Section 2 above, the EIS is missing even the most fundamental details of many aspects of the plans which will be required to build a new nuclear plant on the NND site. In my professional opinion, the result is an incomplete assessment of impacts in an EIS document which has been issued prematurely. The following sections of this review provide a brief summary of the missing information:

a) No Decision on Which Reactor Type is to be Used

The most fundamental decision of all - which type of reactor to build - has not yet been made. This makes a realistic assessment of potential impacts of the undertaking all but impossible, because each different reactor type will bring with it different characteristics and challenges over the life of the project. The EIS describes the lack of a decision about the reactor type on page ES-3 of the EIS, and proposes an approach of using an encompassing framework that “incorporates the Plant Parameter Envelope (PPE)” which is supposed to consider the “envelope” of possible impacts resulting from the different possible reactor designs at every stage of the project proposal. In practice, the lack of a decision on reactor type means that the EIS is much more cumbersome than it needs to be.

b) Insufficient Information and Predetermination on Lake Infill Issue

Although there is no decision on the reactor design in the EIS, an inappropriately predetermined decision is also presented in the form of a fait accompli which the EIS is then built around - namely the decision to infill up to 40 hectares of the Lake Ontario shore and near-shore area. This is described on page 2-12 of the EIS which states that: “Early in the planning stages of the project, it was determined that physical protection of the DN site would require some lake infill and a variation that did not involve lakefilling was screened out as not technically feasible given the space requirements of the Project and existing physical constraints on the site, including the CN railway tracks.” What is being described here is an inappropriate predetermination of a key aspect of the proposed project - one which will result in infilling of up to 40 hectares of the Lake Ontario shoreline. A decision of this magnitude should not have been predetermined in the EIS.

page 4 Adequate justification for this decision is not provided - it is quite possible that one of the main reasons for this proposal is to save money by disposing of surplus rock and soil on the lakefront at the expense of the Lake Ontario marine environment. In my professional opinion, this question should have been properly assessed through alternative designs in the EIS.

c) Lack of Plans for Surface Water Quality Protection During Site Preparation and Construction

Section 2.5 of the EIS provides a detailed conceptual description of the various site preparation and construction activities which will be required for the proposed NND project. Missing entirely from Section 2.5 is any discussion of what measures will be taken to prevent surface water quality impacts from soil erosion. Page 2-27 of the EIS Report indicates that “for assessment purposes it is assumed that the entire site will be prepared for construction at the outset of the project”. This means that raw soil could be exposed across a huge area, with (as indicated on page 2-27 of the EIS) up to 12.4 million cubic meters of soil and rock to be excavated and moved. Excavation and grading activities on such a scale bring with them the potential for massive air quality impacts (from dust) and surface water quality impacts (from soil erosion). The conceptual details of stormwater management plans (which page 2-29 of the EIS indicates have yet to be developed) are urgently needed. These plans should provide details of core commitments including the following: • to mitigate potential surface water impacts, a precondition for any site clearing, preparation, or construction in any new area for the NND project should be the construction of surface water management ponds capable of containing and treating all runoff from the affected area(s); • best industry management practices should be followed in preventing surface water quality impacts; • all surface water management facilities should be sized so that they can contain the largest expected “regional storm” (ie. the equivalent of Hurricane Hazel), with waters retained until they are confirmed through testing to be of appropriate quality for discharge; • comprehensive surface water quality monitoring (including at least 2 full seasons of pre- construction baseline data) should be conducted throughout the construction period, with the goal of ensuring that the Provincial Water Quality Objectives (PWQO) are met for all surface water discharges from the NND property at all times.

d) EIS Does Not Include Plans for Dealing with Wastes and/or Contaminated Soils

While a detailed plan is needed for dealing with existing wastes and/or contaminated soils, there is currently no such plan in the EIS. Page 2-27 of the EIS states the following: “For the purposes of the EA, it is also assumed that all existing features, structures, and residual conditions (eg. legacy contaminated soil) within the area proposed for the Project, that are associated with, or resulting from DNGS activities will be addressed in advance of this Project.” This is an unrealistic assumption. In practice, it is much more likely that significant areas of existing contaminated soil will not be encountered/discovered until construction of the proposed NND facility is underway. These contaminated soils could include various combinations of inorganic, organic, and radiological contaminants.

page 5 Moreover, the above statement does not indicate how existing wastes and/or contaminated soils will be “addressed”. There is likely to be an impetus to simply dump any wastes and/or contaminated soils which are found into the existing Northwest Landfill area. This would not be an appropriate method of disposal for such wastes, and the EIS needs to clarify precisely what will happen with any existing wastes and/or contaminated soils on the NND site.

A comprehensive plan for dealing with existing wastes and/or contaminated soils which are encountered during construction is urgently required for the EIS, to ensure that these are not simply landfilled elsewhere on the property. This plan should include the following: • a firm commitment to disposing of any existing wastes and/or contaminated soils at licensed off-site facilities; • comprehensive testing of soil quality across the proposed excavation/construction area, with stepped up testing in areas known to have been disturbed historically; • consideration of the logistics of separating/stockpiling such wastes and/or contaminated soils to ensure that water contamination from the stockpiling/separation areas is prevented; • the regulatory standards which will be used for determining where to dispose of the contaminated materials off-site.

Similarly, although a comprehensive plan is needed for dealing with future construction wastes and/or soils which become contaminated during construction, there is likewise currently no such plan in the EIS. The only reference I could find to this issue was on page 2-30 of the EIS which indicates that “Construction wastes and hazardous materials will be sent to appropriate off-site waste management facilities for disposal.” Page 2-59 of the EIS Report indicates that “no waste disposal facilities will be established on the DN site”, suggesting that all wastes and contaminated soils (existing and/or newly generated through the NND project) will be disposed of off-site. The above statements appear to contradict what is depicted in Figures 2.4-1, 2.4-2, and 2.4-3 of the EIS - each of which shows an expanded Northwest Landfill area as well as a new Northeast Landfill area. The term “landfill” is very clearly linked with the disposal of waste materials and/or contaminated soils in most definitions which can be found for the term. If all that is meant to go into these facilities is clean soil and rock fill, then I would recommend that they be referred to as the Northwest Fill Area and the proposed Northeast Fill area.

Finally, the EIS report does not clearly indicate whether waste materials (beside soil and rock) are buried in the Northwest Landfill. If there are wastes in the Northwest Landfill then this should be disclosed, because then there will be a contaminant plume which can be used to map groundwater flow patterns and velocities on the Darlington Nuclear property.

e) EIS is Missing Clear Plans/Criteria for Contaminated Water Discharges

One of the pathways by which the proposed project could cause significant environmental impacts is via discharges of contaminated water from the property. This issue does not get sufficient attention in the EIS for a number of discharges of contaminated water including the following:

page 6 i) Flows of Sewage and Other Liquids to Off-Site Wastewater Treatment Plant

Page 5-38 and page 6-17 of the EIS Report indicate that “all domestic sewage will be directed to the wastewater treatment plant” by sanitary sewer, and that the existing DNGS buildings will also be serviced by the sewer system. Using an off-site wastewater treatment plant to deal with sewage from the site introduces a pathway for contaminants to escape the site and cause off-site water contamination. The receiving wastewater treatment plant is the nearby Courtice Water Pollution Control Plant. Key measures which will be used to ensure that nothing other than domestic sewage will be going into the sewer system leading to the plant should be specified in the EIS. These measures should include: • a corporate best practices approach to handling of all liquids, • only discharges of normal domestic sewage from buildings permitted; • proper training of personnel, • a rigorous program of independent testing of discharges to the sewer system. Currently there is no discussion of the safeguards needed around this issue in the EIS. This is a matter of considerable concern, because it is possible that the discharge criteria for the sewer discharges could be less stringent than other discharge criteria for the site.

ii) General Lack of Contaminated Water Treatment/Discharge Criteria

This issue comes up repeatedly with respect to the streams of contaminated water which will be generated by the proposed project. Page 5-38 of the EIS makes the critical commitment that “all water impacted by radioactive or conventional contaminants, discharged from any liquid stream... to the environment... will be treated as necessary to meet regulatory requirements”. Missing from this commitment are the regulatory requirements that are proposed to be used, and the EIS can not be considered complete until the regulatory criteria to be used in determining acceptability of all discharges to surface waters are specified. Page 5-37 of the EIS suggests that “... changes in Lake Water Quality associated with these processes are not likely to be meaningful (ie. concentrations will meet regulatory requirements).” I disagree with this statement. The implicit assumption in the above statement is that if “regulatory requirements” are met, then changes in Lake Ontario water quality will not be “meaningful”. However if for example the regulatory requirements which are selected are based on less stringent limits, then there is a real possibility of significant impacts occurring even though the limits are being met. It is worth considering the various “Evaluation Criteria” which are listed for Site Drainage and Water Quality in Table 5.3-2 on page 5-27 of the EIS. A total of 9 Evaluation Criteria are listed, including MISA limits and “Professional Judgement” among others. I am concerned that a combination of outdated and/or loose MISA limits and “professional judgement” may be used to water down other more stringent criteria like the Provincial Water Quality Objectives, and that discharges from the site will cause impacts to surface water quality in Lake Ontario. There should be no possibility of the proponent “shopping around” to find the most convenient treatment/discharge criteria for various parameters or for regulatory approvals of massive contaminant dilution schemes - the best way to ensure that this will not occur is for the treatment/discharge criteria to be specified at the assessment stage of the project. This provides certainty about potential water quality impacts from the undertaking.

page 7 Clarity is need now on the issue of treatment/discharge criteria for all surface water discharges to Lake Ontario. Until such clarity is provided, the conclusion of the EIS that “no residual adverse effects are predicted” is open to question. This issue of treatment/discharge water quality standards needs to be addressed up front in the EIS. In my professional opinion the appropriate standards to be applied would be the Provincial Water Quality Objectives, (PWQO), which reflect the current water quality in Lake Ontario. Only where no PWQO exist should criteria from other jurisdictions be used.

iii) Intent to Rely on Dilution to Reduce Contaminant Concentrations in Discharges

I am concerned about the apparent intention of OPG to use massive dilution in order to meet regulatory criteria. Chapter 5 of the “Surface Water Environment, Assessment of Effects” Technical Supporting Document (TSD) discusses the available dilution factors of the different reactor designs in considerable detail, clearly signalling the intent of OPG to use the massive dilution available in the lake and in the water flows from the proposed plant in order to meet regulatory criteria. Absent from the TSD or the EIS are mass loading calculations, which would show the actual mass of each contaminant which the proposed NND facility would be discharging into Lake Ontario per day or year. If OPG is proposing to rely on dilution rather than treatment to meet the PWQO, then I believe that mass loading calculations should be done up front and presented for consideration in the EIS.

iv) Many Potential Contaminants Apparently Not Considered in the EIS

I am concerned that a very small subset of the PWQO have been used in the one table (Table 5.1-1) of the “Surface Water Environment, Assessment of Effects” Technical Supporting Document (TSD) which presents water quality after dilution at the edge of the “mixing zone” where the dilution is proposed to occur. The table lists a total of 16 parameters together with their PWQO or Interim PWQO, and their projected concentrations at the edge of the mixing zone. It also lists a few other parameters for which there are no PWQO. By my count, there are a total of over 220 parameters for which there are PWQO or Interim PWQO. Table 5.1-1 only lists 16 of those 220+ parameters, leaving potential Lake Ontario levels of the other 200+ parameters open to question. I believe that the EIS or a Technical Supporting Document (TSD) should provide clarity about each of the parameters for which there is a PWQO or an Interim PWQO. As it stands there are 200+ potential contaminants for which OPG has made no projections about Lake Ontario water quality impacts. If OPG is confident that a given parameter with a PWQO or Interim PWQO will not be found in any of the effluent streams from the proposed NND facility, then this should be stated up front (with a firm commitment being provided that the parameter will not be in the plant’s effluent streams). This commitment should also be incorporated into monitoring plans, which can be designed to confirm that there are zero discharges for the parameter. On the other hand, for all parameters which could be present in the various discharge streams from the proposed NND facility there should a clear estimate of what levels of the contaminant in question are going to be getting into Lake Ontario as a result of this proposal.

page 8 v) Lack of Blasting Water Treatment/Discharge Criteria

Page 5-38 of the EIS Report indicates that “... all water having come into contact with blasting agents and other contaminants (eg. ammonium nitrate/fuel oil -ANFO) and other contaminants” will be collected, and appropriately managed and disposed of without specifying how this will be done. The contaminants found in blasting agents can have significant negative impacts on water quality. Detailed descriptions of proposed blasting water testing requirements, and collection and treatment facilities are required in the EIS. In particular, the regulatory standards which will be applied to discharges of treated water need to specified up front in the EIS. In my professional opinion the appropriate standards to be applied would be the Provincial Water Quality Objectives, (PWQO), which reflect the current water quality in Lake Ontario.

vi) Lack of Steam Generator Blowdown Treatment/Discharge Criteria

Page 5-38 of the EIS Report indicates that “Intermittent releases of Steam Generator blowdown will be tested and treated, if necessary, to comply with the appropriate criteria for discharge to Lake Ontario.”. Detailed descriptions of the proposed steam generator blowdown water testing requirements and collection/treatment facilities are needed in the EIS. In particular, the regulatory standards which will be applied to discharges of treated water need to specified up front in the EIS. In my professional opinion the appropriate standards to be applied would be the Provincial Water Quality Objectives, (PWQO), which reflect the current water quality in Lake Ontario.

vii) Lack of Discharge Criteria for Radioactive Liquid Waste Management Systems

The Radioactive Liquid Waste Management Systems are mentioned in Table 3.1-1 on page 3-6 of the “Surface Water Environment, Assessment of Effects” Technical Supporting Document (TSD). The table indicates that the radioactive liquid waste streams will be discharged to Lake Ontario after stringent testing and treatment to maintain acceptable (radio)activity levels for release. It also indicates that these waste streams may contain conventional (ie. non- radioactive) contaminants. The treatment/discharge criteria for radioactive and conventional contaminants are not specified in the EIS. Detailed descriptions of the regulatory standards which will be applied to discharges of the treated radioactive and conventionally contaminated water need to specified up front in the EIS. In my professional opinion the appropriate standards to be applied to conventional (ie. non-radioactive) parameters would be the Provincial Water Quality Objectives (PWQO), which reflect the current water quality in Lake Ontario.

viii) Lack of Discharge Criteria for Inactive Drainage System

The Inactive Drainage System collects water in sumps from various buildings (such as turbine building, waste treatment building, pumphouses, etc.) as described in Table 3.1-1 on page 3-8 of the “Surface Water Environment, Assessment of Effects” Technical Supporting Document (TSD).

page 9 The table indicates that the wastewater is to be “treated as required to comply with discharge criteria prior to release to Lake Ontario or sanitary sewer.” This wording highlights the need for careful consideration of the quality of sewage discharges from the site as discussed in Section 3)e)i above. As in the other examples provided above, the treatment/discharge criteria for the Inactive Drainage System are not specified in the EIS.

ix) Summary

Further examples of liquid waste streams and discharges for which there are no treatment/discharge criteria in the EIS could be provided but I see little point in doing so. Overall the problem with the EIS is that there are multiple assurances that liquid waste streams will be treated in accordance with regulatory criteria, without specifying which specific criteria will be applied. This raises concerns about whether the criteria will be stringent enough to prevent impacts on Lake Ontario and its aquatic environment. The concerns are heightened because the EIS makes multiple assumptions that various liquids waste streams can be perfectly mitigated (through the aforesaid undefined treatment/discharge criteria), and then scopes those liquid waste streams right out of the EIS since they are assumed to be mitigated to the point of negligible impact.

f) Impacts of Nuclear Waste Disposal Not Considered in EIS

The EIS does not consider the impacts of the disposal of low- and intermediate-level radioactive wastes (L&ILW) or the disposal of high-level wastes from the proposed NND plant. While various nuclear waste storage options are discussed in the EIS, the environmental impacts of the long-term disposal of such wastes are not assessed. Given that the proposed NND facility will be producing a radioactive waste stream throughout its operating life, the EIS should have included an assessment of the impacts of that waste stream on the environment.

4) Lack of Commitment to Best Industry Management Practices

Page 3-20 of the EIS Report indicates that the Precautionary Principle has been applied throughout the preparation of the EIS, and that “industry standards and best practices” were applied. It is commendable that best practices were applied to the preparation of the EIS.

However there appears to be a disconnect between the best practices which were apparently followed in the preparation of the EIS, and the fact that within the EIS there is only reference to Good Industry Management Practices (or GIMPs) being applied over the lifetime of the project, rather than best practices. Remember that the EIS deals with a major nuclear power generating facility, with multiple possible impacts on the environment. GIMPs should not be the standard used at this site - best industry management practices should be applied through the life of the NND project, in order to ensure that the best possible protection of the environment is provided.

page 10 5) Case History of Existing Darlington Nuclear Facility not Utilized in EIS

For major projects like the Darlington NND proposal, a good way of assessing whether the assurances provided in environmental assessment documents can be relied on to protect the environment is to take a look at the proponent’s track record at nearby similar facilities. In the case of the proposed Darlington NND facility, the Province of Ontario’s most recently constructed nuclear power generating station is situated immediately adjacent to the proposed NND site. Under these circumstances, detailed information on the environmental track record of the existing facility would have been very useful in terms of providing an objective measure of the proponent’s success in preventing water quality impacts to Lake Ontario. Page 2-81 of the EIS states the following: “OPG has over three decades of experience sampling, testing, documenting and reporting on air, water..” and “Through its monitoring program, OPG demonstrates that emissions are kept within the appropriate limits.”

Given these statements it is not clear why the EIS did not present detailed monitoring information outlining the success or failure in preventing water quality impacts from the existing Darlington Nuclear facility. One reference I was able to find was to existing stormwater quality from the Darlington Nuclear facility was in Section 4.3 of the “Surface Water Environment, Existing Environmental Conditions” Technical Supporting Document (TSD). Stormwater would normally be a liquid discharge stream that could be expected to be relatively innocuous, however Section 4.3 of the TSD describes the following problems in some detail: • in the 1990s, special studies were carried out in which stormwater quality was monitored at 9 of the plants 22 stormwater outfalls (the implication is that there was little monitoring done prior to this time); • follow-up studies were done 2001/2002 (the implication is that there have not been further studies); • actual stormwater monitoring data are not provided in the TSD but there is a written description of results of the studies; • the 1996 study showed that several of the stormwater discharges were acutely toxic to daphnia magna and rainbow trout; • there was still one incident of stormwater discharges being acutely toxic to daphnia magna and rainbow trout in 2001; • petroleum hydrocarbons were detected in storm runoff in both the 1996 and 2001 studies; • concentrations of aluminum, iron, lead, copper, zinc, cadmium and TSS exceeded PWQO in one or more sampling events in the 2001 study; • results were not compared to the PWQO, but to the Durham Sewer Use By-law or US EPA limits (both of which are less stringent than the PWQO for the parameters of concern). The TSD declines to provide any other water quality monitoring information on the historic or current liquid effluent discharges from the existing Darlington Nuclear facility on the basis of the following rationale: “The proposed new-build reactors will be constructed with a different reactor design than the existing DNGS .. thus a detailed assessment of liquid effluents would provide limited insight into the effects of the NND”. I disagree - existing monitoring information should have been assessed to determine the success of OPG as a proponent in preventing water quality impacts on Lake Ontario.

page 11 6) Inadequate/Incomplete Water Quality Impact Assessment a) Introduction

There are two main media by which contaminants from the proposed NND facility can cause off- site environmental impacts - air and water. As a result, the assessment of impacts on water quality should be one of the central aspects of the EIS. For a project of this magnitude and importance, it is reasonable to expect that all aspects of the EIS should be complete prior to its submission. In my professional opinion, the EIS for the proposed NND facility is not adequate because it is not complete, for the reasons provided below. b) Impact Assessment does not Consider A Variety of Screened-out Potential Impacts

As described in Section 3 of this review, the EIS is missing numerous plans which will be required for impact management including: • plans for water quality protection during site preparation/construction; • plans for dealing with wastes or contaminated soils; • plans and criteria for treatment/discharge of various contaminated water effluent streams. Although these plans and criteria are not yet developed, the EIS assumes that for the most part they will be absolutely successful in mitigation of a variety of impacts which are then screened out of the EIS and not carried forward for further consideration. An illustrative example of this problem is the issue of stormwater management. Although the NND site will be one of the largest construction sites in the province with up to 12.4 million cubic meters of soil and rock to be excavated and moved, there are no stormwater management plans for the project. Even basic conceptual details and commitments are missing at this time. Despite the lack of even basic conceptual details and commitments regarding stormwater management plans in the EIS, these plans are assumed to be perfectly effective in mitigation of stormwater impacts such that these are screened out of the EIS (as described on pages C-5 and C-6 of the “Surface Water Environment, Assessment of Effects” Technical Supporting Document (TSD). A test of how reasonable the assumption of perfect effectiveness in mitigation of stormwater impacts really is, is provided by the track record of the existing Darlington Nuclear Plant. As discussed in Section 5 of this review, the monitoring of stormwater quality at the existing plant’s 22 outfalls appears to have been sporadic and haphazard at best. When detailed monitoring and assessment of stormwater quality was done, numerous exceedences of the PWQO were found and at some outfall locations the stormwater was found to be acutely toxic to aquatic organisms. There is a very long list of potential impacts on Lake Ontario water quality which have been screened out of the EIS in a similar manner, including but not limited to: • water quality impacts related to explosives (eg. ammonium nitrate fuel oil) used in blasting; • erosion of silt particles during site preparation and construction leading to high suspended solids loading in discharges to the lake; • stormwater management issues; • management of existing contaminated soils on the NND site; • management of construction wastes, hazardous materials, fuels and lubricants; • operations of site services and utilities (including discharges to the sewer system); • management of conventional liquid waste. A review of the case history provided by the existing Darlington facility would have provided a good check on whether it was reasonable to screen out these impacts, but this was not done.

page 12 c) Regulatory Criteria for Surface Water Treatment/Discharges not Specified

There will be numerous liquid effluent streams coming from the proposed NND facility, each of which has the potential to cause contamination of Lake Ontario. As described in detail in Section 3)e of this review, the EIS is full of assurances that effluent will treated to meet regulatory requirements before discharge (and that this will prevent impacts on Lake Ontario water quality) without specifying or committing to what the treatment criteria might be. In the absence of commitments to treatment/discharge criteria these assurances are open to question. Specific treatment/discharge criteria are required for a variety of inorganic, organic, and radiological parameters before the EIS can be considered complete.

d) Lack of Details about Required Monitoring Plans

For most contaminated water treatment/discharges from the site, the EIS assumes perfect treatment and mitigation to the point of negligible impacts without specifying how this is to occur. In this context, the monitoring plans for the site take on heightened importance given that the monitoring provides the test of whether the EIS assurances of negligible impacts are being met. Section 11 of the EIS deals with the inappropriately named “follow-up program”, which in fact is what would normally be called a Monitoring Program for the NND site. Few details are provided, and yet again there is only a “plan to have a plan” for many critical aspects of the proposal that will need monitoring including: • groundwater quality and groundwater levels; • stormwater flows and stormwater quality; • water quality of a variety of liquid waste effluent streams; • the Radiological Environmental Monitoring Program (REMP). Section 11 of the EIS (which deals with various aspects of the required monitoring programs for the project) includes discussion of the following: • a plan for developing actual monitoring plans; • “stakeholders” including regulatory agencies; • adaptive management; • reporting requirements. Table 11.6-2 lists Elements to be included in monitoring programs for the proposed NND facility. Missing entirely from the Table (and from Section 11 for that matter) is any list of the conventional and radiological contaminants which would be part of the monitoring programs, the frequency of monitoring of the various surface water and effluent flows, or any list of the discharges which would be monitored. In the absence of even these most basic details this aspect of the EIS can not be considered complete.

e) Lack of Details about Required Contingency Plans

At an industrial project of the magnitude proposed for the Darlington NND project, there can be certainty that spills, leaks, and releases of various contaminants will occur. For this reason, it is crucial that at least the conceptual details of effective plans are provided up front outlining how the proponent proposes to deal with various scenarios of contaminant releases to the environment. Section 7 of the EIS Report discusses the possibility of Malfunctions, Accidents, and Malevolent Acts. Table 7.2-1 lists a variety of scenarios in which spills, leaks and releases of contaminants may occur. Bounding scenarios are selected and assessed, but always on the assumption that the various plans which are missing (even at a conceptual level) from the EIS will be in place for all possible scenarios. In the absence of such plans, I do not consider this to be a reasonable assumption.

page 13 f) Summary

The EIS for the proposed NND facility is not complete, and thus is also not adequate. Different aspects of the EIS which are needed are discussed in detail above and include the following: • the impact assessment does not consider a variety of screened-out potential impacts; • regulatory criteria for surface water treatment/discharges are not specified; • there is a lack of details about required monitoring plans; • there is a lack of details about required contingency plans. Further work is required on the EIS. As it stands it does not in my professional opinion provide a complete or adequate assessment of the potential water-related impacts of the proposed NND facility.

7) Potential Effects of the Nearby St. Mary’s Quarry on the Proposed NND Facility

One area of critical concerns about the NND project following my review are the potentially significant threats which the St. Mary’s Cement facility (which is immediately east of the NND property) may pose to the proposed nuclear facility. The St. Mary’s operation, which has been at that location for decades, includes a quarry which recently received approval for extraction to a final depth of close to 200 meters below ground surface (over 190 meters below lake level) - this is deep enough that it could be considered an open- pit mine. Some information about the St. Mary’s quarry is provided on pages 4-8 and 4-9 as well as Figures 4.4-5B, 4.4-10, and 4.4-11 in the Geology and Hydrogeology Existing Features technical supporting document. The existing St. Mary’s quarry is currently situated in the northeast of the St. Mary’s property, but the approved quarry operations plans have the quarry extending southwestward all the way to the southeastern DN property boundary. The quarry will be about 80 meters deep within a distance of less than 100 meters from the DN property boundary, and 200 meters deep within 500 meters from the DN property boundary. The NND proposal involves construction of a nuclear generating station on the east side of the DN property - that is, the proposal is to build the nuclear generating station at the point on the DN property which is closest to the St. Mary’s quarry. I have three main concerns about the proximity of the quarry to the proposed NND facility: • There will be ongoing blasting occurring for decades in the immediate proximity of the proposed NND facility, carried out by a third party over whom the proponent has no control. The potential effects of vibrations from blasting on the proposed nuclear plant are a significant concern. • The great depth of mining which will be carried out at the St. Mary’s Quarry will be removing a huge mass of bedrock from the property, in addition to removing a significant mass of groundwater from surrounding areas due to quarry dewatering operations. In a quarry or open pit mining operation of this scale there is a phenomenon which is termed “induced seismicity” which could come into play. In essence what can happen is that the removal of millions of tonnes of bedrock and groundwater can lead to human-induced seismic events which are sometimes triggered by the blasting associated with the mining operation.

page 14 • Another concern is the potential for significant subsidence on the NND property due to dewatering of the bedrock groundwater flow system by the quarry. The quarry will have to pump ever greater amounts of water as it goes ever deeper into the bedrock, in order to keep a dry working area for blasting and aggregate extraction. As a groundwater-bearing formation is dewatered it will compact (in a process often referred to as subsidence). If there is any karstification or even any moderate permeability of any of the bedrock layers beneath the site and quarry, then subsidence could prove to be a significant problem on the DN property. Blasting on the St. Mary’s and Darlington properties and any induced seismic events (as described above) could increase bedrock permeability, exacerbating this effect. These concerns have not been identified in the EIS Report or the supporting documentation, and in my professional opinion the EIS is not complete until the potential for serious negative impacts on the proposed nuclear plant from the St. Mary’s Quarry operation have been investigated, considered, and discussed in detail.

8) Discussion

Preparation of the EIS and the Technical Support Documents (TSDs) for the proposed New Nuclear - Darlington (NND) facility has clearly been a major undertaking. In many aspects the EIS and supporting documents provide a good and thorough discussion of issues related to the potential impacts of the proposed NND facility. There are however a number of areas which have not been covered at the level of detail one would expect for a project of this importance and magnitude. Overall it is my professional opinion that the EIS can not be considered complete and requires further work in a number of areas. The unsupported assumption that various impact management plans and discharge criteria (which have yet to be developed) will be perfectly effective in reducing water quality impacts on Lake Ontario to negligible levels is extremely problematic, since that assumption of negligible impacts is then used to screen various potential impacts out from further consideration in the EIS. One way of testing the validity of the assumption that various impact management plans and discharge criteria (which have yet to be developed) will be perfectly effective in reducing Lake Ontario water quality impacts to negligible levels would be to provide and discuss in detail the results of monitoring the water quality impacts of the existing Darlington Nuclear Station. However, the Project Team has for the most part declined to provide such information and discussion in the EIS and/or technical support documents. The one reference I was able to find to monitoring of the water quality of discharges related to the existing Darlington Nuclear Generating Station did not inspire great confidence in this regard. As discussed in Section 5 of this review, the assessment of stormwater quality at 9 of the existing plant’s 22 outfalls revealed sporadic and haphazard monitoring and numerous exceedences of the PWQO and at some outfall locations the stormwater was found to be acutely toxic to aquatic organisms. The lack of decision on a reactor type makes the EIS a very cumbersome document, and makes the assessment of potential impacts much more challenging. In some cases the lack of a decision on reactor type is used as justification for not going into issues in more depth. Finally, the presence of the massive St. Mary’s Quarry immediately adjacent to the proposed NND facility raises a number of very problematic questions which do not appear to have been considered at all in the EIS.

page 15 9) Conclusions

1) The proposed New Nuclear - Darlington (NND) has the potential to cause a wide variety of negative impacts on water quality in Lake Ontario.

2) Preparation of the Environmental Impact Statement (EIS) and the Technical Support Documents (TSDs) for the proposed New Nuclear - Darlington (NND) facility has clearly been a major undertaking. In many aspects the EIS and supporting documents provide a good and thorough discussion of issues related to the potential impacts of the proposed NND facility.

3) Following careful review, it is nonetheless my professional opinion that the Environmental Impact Statement (EIS) of the proposed NND facility has been issued prematurely. The The EIS does not provide an adequate assessment of the potential impacts of the proposed NND project.

4) There has been no decision on reactor type. Critical environmental protection plans (even at a conceptual level) are missing entirely from the EIS and supporting documentation. Critical treatment/discharge criteria for the various liquid waste streams coming off the NND facility and property have not been committed to by OPG, and as a result it is not possible to reasonably assess the impacts of the proposed nuclear plant on water quality in Lake Ontario.

5) Despite the fact that various critical environmental protection plans are missing entirely from the EIS and that critical treatment/discharge criteria for the various liquid waste streams coming off the NND facility/property have not been committed to by OPG, the EIS is built around the assumption that the missing plans and treatment/discharge criteria will be perfectly effective in mitigating various potential impacts to the point where these impacts can be screened out of the EIS. This is not a precautionary approach to assessing potential impacts of the project.

6) One way of testing the validity of the assumption that various impact management plans and discharge criteria (which have yet to be developed) will be perfectly effective in reducing Lake Ontario water quality impacts to negligible levels would be to provide and discuss in detail the results of monitoring the water quality impacts of the existing Darlington Nuclear Station. However, the Project Team has mostly declined to provide such information and discussion. The one reference to monitoring of the water quality of discharges related to the existing Darlington Nuclear Generating Station does not inspire confidence. As discussed in Section 5 of this review, the monitoring of stormwater quality at 9 of the existing plant’s 22 outfalls revealed haphazard monitoring and numerous exceedences of the PWQO, and at some outfall locations the stormwater was found to be acutely toxic to aquatic organisms.

7) The EIS includes the inappropriate predetermination of a key aspect of the proposed project - one which will result in infilling of up to 40 hectares of the Lake Ontario shoreline. A decision of this magnitude should not have been predetermined in the EIS. In my professional opinion, this question should have been properly assessed through alternative designs in the EIS.

8) This review raises serious concerns about the potential for serious negative impacts on the proposed nuclear plant from the St. Mary’s Quarry operation. These concerns have not been identified in the EIS Report or the supporting documentation, and in my professional opinion the EIS is not complete until these concerns have been investigated, considered, and discussed in detail.

page 16 10) Recommendations

1) The EIS should not be approved in its current form. It should be revised and expanded to include the information outlined below.

2) The conceptual details of various environmental management plans including all key aspects required for Lake Ontario water quality protection should be included in the EIS.

3) Best industry management practices should be applied through the life of the NND project, in order to ensure that the best possible protection of the environment is provided.

4) Discharge/treatment criteria for various inorganic, organic, and radiological parameters which are most likely to be problematic from a water quality perspective should be committed to up front by OPG and included in the EIS.

5) If massive dilution is going to be relied upon in order to reduce contamination levels in Lake Ontario, then calculations should be carried out for the mass loading of a variety of critical contaminants (conventional and radiological) to the lake.

6) If at all possible, the reactor type to be used should be selected before the EIS is completed.

7) The question of whether infilling of up to 40 hectares of the Lake Ontario shoreline is necessary should be properly assessed through evaluation of alternative designs in the EIS.

8) A Technical Supporting Document (TSD) should be developed which provides detailed information and discussion about the results of monitoring the water quality impacts of the existing Darlington Nuclear Station. This case history should be used in the EIS to test the validity of assumptions about the effectiveness of various mitigation measures which are proposed in the EIS.

8) Basic conceptual details of monitoring plans for all water and effluent discharges from the NND property should be provided in the EIS. Likewise basic conceptual details of contingency plans for various scenarios of contaminant releases to the environment should be provided in the EIS.

9) The concerns which have been raised in this review about the potential for serious negative impacts on the proposed NND nuclear plant from the adjacent St. Mary’s Quarry operation should be investigated, considered, and discussed in detail in a stand-alone TSD and presented and discussed in detail in the EIS.

page 17 Appendix A

Curriculum Vitae

of Wilf Ruland (P. Geo.)

page 18 Curriculum Vitae of Wilf Ruland

(Professional Geoscientist)

Address: Wilf Ruland (P. Geo.)

Education:

1988 Master of Sciences in Earth Sciences, University of Waterloo. Supervisor: Dr. John Cherry Master’s project focussed on the hydrogeological properties of fractured clay deposits in Lambton County. 15 courses provided a broad background in hydrogeology.

1982 Honours Bachelor of Science in Geography and Geology, McMaster University. 30 courses provided a broad background in natural science, geography and geology.

Experience:

since 1988 Environmental Consultant, as head of own consulting firm (Citizens’ Environmental Consulting). Active as advisor and consultant on issues related to groundwater or surface water contamination or depletion for private citizens, citizens’ groups, environmental groups, First Nations, companies and public agencies from across Ontario. Specialization in addressing landfill-related groundwater and surface water contamination problems through review of hydrogeological impact studies, field investigations, and participation in public meetings and hearings. Ongoing contracts include investigations of water contamination at landfills near St. Catharines, Brockville, Kingston, Waterloo, and Windsor. Other significant areas of work include review of pit and quarry proposals and applications for Permits to Take Water, investigations of well interference resulting from quarries, and groundwater contamination emanating from major industrial properties and gas stations.

page 19 Experience: continued

1988-1993 Research Associate, Waterloo Centre for Groundwater Research, University of Waterloo

Work included research into the hydrogeology of fractured clays and into the impacts of landfills on groundwater.

1983-1985 Hydrogeologist, Ingenieur-Geologisches Institut, Westheim, Germany. Work included hydrogeological field work, supervision and evaluation of drilling programs, supervision and evaluation of pumping tests, research and preparation of hydrogeologic reports, and supervision of environmental monitoring for a major railway construction project.

Publications, Papers and Research Reports:

Worthington, S.R.H., Smart, C.C., and Ruland, W.W. 2002. Assessment of Groundwater Velocities to the Municipal Wells at Walkerton. Paper presented at the 3rd Joint IAH-CNC/CGS Conference, October 20 - 23, 2002 in Niagara Falls, Ontario. Worthington, S.R.H., Smart, C.C., and Ruland, W. 2001. Karst Hydrogeological Investigations at Walkerton. Report prepared for and submitted as evidence at the Walkerton Inquiry. Ruland, W.W., Schellenberg, S.S., and Farquhar, G. 1993. The Fate of Landfill Leachate in Waste Water Treatment Plants and in Groundwater at Attenuation Landfills. Report prepared for the Ontario Ministry of Environment and Energy. Ruland, W.W., Cherry, J.A., and Feenstra, S. 1991. The Depth of Fractures and Active Ground Water Flow in a Clayey Till Plain in Southwestern Ontario. Published in the Journal of Ground Water, Vol. 29, No. 3, p. 405-417. D’Astous, A.Y., Ruland, W.W., Bruce, R.J., Cherry, J.A., and Gillham, R.W. 1989. Fracture Effects in the Shallow Groundwater Zone in Weathered Sarnia Area Clay. Published in the Canadian Geotechnical Journal, Vol. 26, No. 1, p. 43-56.

Fracture Depths and Active Groundwater Flow in a Clayey Till in Lambton County, Ontario. 1988. Unpublished M.Sc.Project, University of Waterloo.

Cherry, J.A., MacQuarrie, K.T.B., and Ruland, W.W. 1987. Hydrogeologic Aspects of Landfill Impacts on Groundwater and Some Regulatory Implications. Paper presented at the PCAO/MOE Seminar on Landfill Regulations May 13, 1987.

Schulman, D. and Ruland, W.W. 1987. Landfills: in Waste Management Master Plans - What You Should Know. WPIRG publication, May 1987.

page 20 Wilf Ruland (P. Geo.) - Partial List of Consulting Experience:

1) Investigations/Reviews of Landfill-Related Water Contamination:

Niagara Road 12 Landfill, near Grimsby, Ontario. - Peer Review for the Niagara Road 12 Litizen Liaison Committee (since 2008).

Humberstone Landfill in Owen Sound, Ontario. - Peer Review for the Humberstone Public Liaison Committee (since 2007).

City of Owen Sound’s Derby Landfill site, near Owen Sound, Ontario. - investigation and review for the Ledingham family (2004-2006)

Town of Northeastern Manitoulin and the Islands Landfill, near Little Current, Ontario; - investigation and review for Mr. Raeburn Smith and Mrs. Virginia Smith (since 2004).

Rennie and Brampton Street Landfill Sites, Hamilton, Ontario; - Peer Review for the Rennie/Brampton Citizens’ Liaison Committee (2001-2005).

Town of Thessalon Landfill Site, near Thessalon, Ontario; - investigation for Mr. Mark Petingalo and Mrs. Wendy Petingalo (in 2000).

City of Brockville Landfill Site, Brockville, Ontario; - review for Brockville Public Liaison and Monitoring Group (since 1997). Fletcher Tile Landfill Site, near Chatham, Ontario; - investigation for Citizens Opposed to Landfill Development (1996-1997). Bracebridge Landfill Site, Bracebridge, Ontario; - investigation for Dr. David Kent (1995-1996). Waterloo Sanitary Landfill Site, Waterloo, Ontario; - review for Waterloo Waste and Water Watchers (since 1995). Innisfil Landfill Site, Innisville, Ontario; investigation for Mrs. Helen Hodgson (1995 - 1999). Tom Howe Landfill Site, near Hagersville, Ontario; - review for the Mississaugas of the New Credit First Nation (since 1994). Wolfe Island Waste Disposal Site, Wolfe Island, Ontario; - investigation for Ms. Theresa James (since 1994). Bensfort Road Landfill, near Peterborough, Ontario; - investigation for Mr. Gary McCarrell and Mrs. Lori McCarrell (1991-1993). Orillia Landfill Site, in Orillia, Ontario; investigation for Citizens Acting Now (1991). Storrington Landfill near Kingston, Ontario; - investigation for Storrington Committee Against Trash (1990-1997).

Glenridge Quarry Landfill in St. Catharines, Ontario; - review for Glenridge Landfill Citizens’ Committee (since 1989).

Warwick Landfill near Watford, Ontario; - investigation for Watford Warwick Landfill Committee (1989-1996).

Brow Quarry Landfill near Dundas, Ontario; - investigation for Greensville Against Serious Pollution (1988-1989).

page 21 Essex County Landfill No. 3 in Maidstone Township, Ontario; - reviews for Maidstone Against Dumping and Maidstone Township (since 1988). Town of Cobourg Landfill, in Haldimand Township, Ontario; - investigation for Mr. Joe Sherman (1988-1991).

2) Reviews of Proposals to Site New or Expand Existing Landfills

Proposal to massively expand the Richmond Landfill near Napanee, Ontario; - review for the Concerned Citizens Committee of Tyendinaga Twp. (2004 - 2006, and since 2010).

Proposal to expand and significantly alter the Edwards Landfill (including excavation of hazardous wastes, and relocation of other wastes) near Cayuga, Ontario; - review for Haldimand Against Landfill Transfers (2004 - 2006)

Proposal to massively expand the Warwick Landfill near Watford, Ontario; - Peer Review for the Township of Warwick (1998-2008). Proposal to massively expand the Richmond Landfill near Napanee, Ontario; - Peer Review for the Town of Greater Napanee (1998 - 1999). Proposal to site a landfill near Cochrane, Ontario; - review for the Fournier Action Committee (1997 -1999). Proposal to site a landfill in the abandoned Adams Mine Site near Kirkland Lake; - review for the Coalition of Temiskaming Concerned Citizens (in 1995). Proposal to site a landfill in the Taro East Quarry near the Niagara Escarpment in Stoney Creek, Ontario; - review for Stoney Creek Residents Against Pollution (in 1995). Proposal to develop a perimeter-berm landfill around the Lake Ontario Steel Company Limited property in Whitby, Ontario; Peer Review for the Lasco Berm Liason Committee (1991-1995). Proposal to build a landfill in a Class 2 Wetland near Cayuga, Ontario; - review for Haldimand-Norfolk Organization for a Pure Environment (1989-1990). Proposal to site a landfill in the Acton Quarry near Milton, Ontario; - review for Protect Our Water and Environmental Resources (in 1989).

3) Review of Landfill Closure and End Use Plans

Closure Plan for the Tom Howe Landfill Site, for the Mississaugas of the New Credit First Nation (2005, and 2009/2010).

End Use Plan for the Glenridge Quarry Naturalization Site (formerly the Glenridge Laandfill), for the Glenridge Landfill Liaison Committee (2002). Closure and post-Closure Care Plan for the Brockville Landfill Site, for the Brockville Public Liaison and Monitoring Group (2000-2001).

Closure and End Use Plan for Essex County Landfill No. 3, for Maidstone Against Dumping (1996).

page 22 4) Other Landfill-Related Projects

Peer Review of proposal to expand the Clean Harbors Hazardous Waste Landfill Facility near Sarnia, Ontario (starting in 2010); for the Township of St. Clair. Member of the Expert Panel (appointed by the Minister of the Environment) to look into potential health and environmental impacts from the Taro East Landfill in Stoney Creek, Ontario (in 2000). The final report of the Expert Panel was released in October 2000, and the Addendum Report was released in December 2000. Technical advisor to private citizens who successfully prosecuted the City of Hamilton (which pleaded guilty) for contamination by PCB-laden leachate of Redhill Creek (in 2000). The resulting $450,000 fine was a record for fines paid under such prosecutions.

5) Reviews of Waste Management Master Plan (WMMP) Studies

Region of Haldimand-Norfolk Waste Management Master Plan (WMMP); - review for the Mississaugas of the New Credit First Nation (1995-1996). South Simcoe County Waste Management Master Plan; - review for the South Simcoe Waste Action Network (since 1994). Leeds and Grenville Waste Management Master Plan; - review for Sabourins Crossing Residents Against Megadumps (in 1994). Pembroke and Area Waste Management Master Plan; - review for the Snake River/Micksburg Anti-Dump Association (1991-1992). Northumberland County Waste Management Master Plan; - review for Mr. and Mrs. J. Sherman (1989-1991). Wellington County Waste Management Master Plan; - review for the Concerned Alma Citizens (1988-1991).

6) Nuclear-Related Review Work

Review of the Draft Environmental Impact Statement for the proposed Darlington ‘B’ New Nuclear Power Plant Project; - review for Lake Ontario Waterkeeper (starting in 2010).

Review of the proposed remediation of the Cameco Nuclear Waste Processing Facility in Port Hope, Ontario (starting in 2009). - review for Lake Ontario Waterkeeper (starting in 2009). Review of the Draft Guidelines for the Environmental Impact Statement for the proposed Darlington ‘B’ New Nuclear Power Plant Project; - review for Lake Ontario Waterkeeper (2008).

page 23 7) Other Investigations of Groundwater Contamination

Contamination by petroleum hydrocarbons of a greenhouse property from an adjacent Hydro One maintenance center in Kenora, Ontarioo; investigation for the Schmidt Family (2008) Impacts of residual contamination on a former industrial property, which is now the site of St. Mary’s High School; investigation for Environment Hamilton (2002 - 2004).

Contamination by petroleum hydrocarbons and volatile organic chemicals (VOCs) from a former service center near High Park, Toronto; investigation for Mr. Gerard Kennedy, MPP (in 2002). Contamination of municipal water supply wells by E-coli bacteria in Walkerton, Ontario; - investigation for Concerned Walkerton Citizens (2000 - 2002).

Contamination by petroleum hydrocarbons and volatile organic chemicals (VOCs) from an Imperial Oil fuel and liquid transfer facility in Kapuskasing, Ontario; investigation for the Schlechter family (in 2000). Contamination by petroleum hydrocarbons from a Gulf Canada gas station in Port Loring, Ontario; - investigation for People Against Contaminated Water (PACW); (1999 - 2001). Contamination by petroleum hydrocarbons from a gas station in Bamberg, Ontario; - investigation for the Bush and Fink families (1997 - 1998). Groundwater contamination in Cambridge, Ontario caused by Ciba-Geigy Canada Ltd; - investigation for Thomas Construction Company Ltd. (1993 - 1997). Groundwater contamination from the Bristol Aerospace Plant near Lockport, Manitoba; - investigation for Mrs. Elizabeth Andresen and Miss Ursula von Krogh (in 1993). Extensive water contamination in Elmira, Ontario caused by Uniroyal Chemical Ltd; - investigation for Assuring Protection for Tomorrow’s Environment (since 1989).

8) Review or Preparation of Applications for Permits to Take Water Review of an application for a Permit to Take Water for a Water Bottling Operation (to be operated by CJC Bottling Limited), with water to be taken from a well which feeds the headwaters of Colborne Creek; for the Concerned Citizens of Northumberland (2001 - 2004).

Review of an application for a Permit to Take Water for a municipal water supply project (for the Village of Woodville), with water to be taken from pumping wells near 5 families’ homes; - for the Mariposa Aquifer Protection Association (2000 - 2004). Review of an application for a Permit to Take Water for a Water Bottling Operation (to be operated by Artemesia Springs Limited), with water to be taken from a springwell which feeds a headwater stream of the Rocky Saugeen River; - for the Water Protection Coalition of South Grey (1999 - 2001). Review of an application for a Permit to Take Water for a Water Bottling Operation (to be operated by Aquafarms 93 Limited), with water to be taken from a spring and 3 pumping wells situated near the headwaters of the Beaver River; - for Ms. Samantha Wickens and other local residents (in 1999).

Preparation of an application for a Permit to Take Water for a fish farming operation (to be operated by Van Aqua Inc.), with water to be taken from a pumping well near the Town of Burford in Brant County; for Mr. Peter Van Kruistum (in 1988).

page 24 9) Reviews/Investigations Related to Impacts of Major Water-Takings

Impacts of ongoing pumping of municipal supply wells K50/K51 in Wilmot Township; - review for Wilmot Center Monitoring Program Public Liaison Committee (since 2003).

Impacts of ongoing dewatering of the Canadian Gypsum Company mine near Hagersville Ontario; - review for residents of 3rd Line, Six Nations Indian Reserve (1999-2003).

10) Reviews/Investigations related to Impacts from Pits, Quarries, and Mines

Investigation of potential impacts from the unlicensed Nichol Quarry near Hagersville, Ontario; - review for the Mississaugas of the New Credit First Nation (since 2007).

Impacts of the proposed expansion of the Nelson Aggregates Quarry near Mount Nemo, Ontario; - review for Protecting Escaparment Rural Land (since 2005).

Cumulative impacts of the proposed Halminen Quarry and Lafarge Quarry near Buckhorn, Ontario; - review for Friends of Life in the Kawarthas (2004 - 2006). Impacts of the proposed expansion of the Graham Brothers Aggregates Limited gravel pit near Caledon, Ontario; review for Dr. David Sylvester (2000 - 2001). Impacts of the proposed Nichol Gravel Limited quarry near Hagersville, Ontario; - review for the Mississaugas of the New Credit First Nation (1999 - 2001). Impacts of well interference from the Canadian Gypsum Company mine near Hagersville; - investigation for several families on the Six Nations Reserve (1999 - 2003). Impacts of well interference from the Dunnville Rock Products Quarry near Dunnville; - investigation for Mr. Ken Ricker and Mrs. Ethel Ricker (1997 - 2000). Impacts of water takings asssociated with the Acton Quarry near Acton, Ontario; - review for Protect Our Water and Environmental Resources (since 1997). Impacts of a quarry proposed adjacent to Mitchell Lake, near Victoria Road, Ontario; - review for the Northern Victoria Ratepayers Association (1997 - 1999). Impacts of a quarry, proposed to be located on the Bruce Peninsula; - review for Mr. Ziggy Kleinau (1996). Impacts of a proposed gravel pit, to be sited near Grippen Lake, Ontario; - review for Township Residents Against Pit Pollution (1995 - 1998).

Impacts of a gravel pit to be built in an Earth Science Area of Natural Interest (ANSI); - review for Ms. Jeanette Mazur (1995 - 1996). Impacts of the proposed Seeley and Arnill Quarry near Orillia, Ontario; - review for Mr. David Lowry (1993 - 1997)

Impacts of a proposed expansion of the Walker Brothers Quarry, near St. Catharines; - review for Mrs. Ronnie DeMeel (1992).

Impacts of six (6) proposed gravel pit operations in Oro Twp., Ontario; - review for Dr. E.J. Beaton and Dr. A.C. Beaton (1990 - 1992).

page 25 11) Participation in Public Hearings

An application to develop a quarry in the Niagara Escarpment Plan area near Duntroon, Ontario; • before the Ontario Municipal Board; • Hearing is ongoing.

An application to develop a gravel pit in the Municipality of Grey Highlands, Ontario; • before the Ontario Municipal Board; • Decision dated April 30, 2008.

An application to massively expand the Dufferin Aggregates Milton Quarry; • before the Joint Board; • Decision dated June 8, 2005.

An application for conversion of 81 cottages into permanent homes adjacent to a World Biosphere Reserve, Class 1 Wetland and Wilderness Area in Turkey Point; • before the Ontario Municipal Board; • Decision dated August 13, 2002.

An application to develop a quarry near Mitchell Lake and Victoria Road, Ontario; • before the Ontario Municipal Board; • Decision dated January 22, 1999.

An application to develop a gravel pit adjacent to a Class 1 Wetland along the shore of Lake Katchewanooka near Lakefield, Ontario; • before the Ontario Municipal Board; • Decision dated June 4, 1998.

An application to develop a quarry near Kinmount, Ontario; • before the Ontario Municipal Board; • Decision dated August 18, 1995.

An act (Bill 62) to amend the Environmental Protection Act to phase out landfilling in the Niagara Escarpment Plan Area; • before the Standing Committee on the Administration of Justice; • Bill 62 received Royal Assent June 23, 1994.

An application to expand the Eastview Road Landfill Site near Guelph, Ontario; • before the Environmental Assessment Board; • Decision EP 92-02 dated September 22, 1993.

An application to develop six (6) gravel pits on the Oro Moraine in Oro Twp.; • before the Ontario Municipal Board; • Decision dated July 23, 1993.

page 26 An application to expand the Storrington Landfill Site; • before the Environmental Assessment Board; • Decision EP 91-01 dated March 31, 1993.

An amendment (No. 52/89) to the Niagara Escarpment Plan to delete waste disposal sites as a permitted land use in lands protected by the Plan; • before a Niagara Escarpment Commission Hearing Officer; • Decision dated Oct. 22, 1991.

An appeal against a zoning bylaw and a proposed plan of subdivision (which allowed construction of a golf course on a Class 1 Wetland); • before the Ontario Municipal Board; • Decision dated August 29, 1990.

An application to expand the Seeley and Arnill Aggregates Ltd. gravel pit in Oro Twp.; • before the Ontario Municipal Board; • Decision dated May 29, 1990.

An application to expand Essex County Landfill No. 3; • before the Environmental Assessment Board; • Decision EP 89-02 dated December 12, 1989.

An application to expand the Town of Cobourg landfill; • before the Environmental Assessment Board; • Decision EP 89-01 dated October 16, 1989.

page 27 Appendix 2

References

The following major references were considered in the course of preparing this review:

Environmental Impact Statement, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by SENES Consultants Limited in association with MMM Group Limited. Aquatic Environment, Assessment of Environmental Effects, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by Golder Associates and SENES Consultants Limited. Aquatic Environment, Existing Environmental Conditions, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by Golder Associates and SENES Consultants Limited. Geological and Hydrogeological Environment, Assessment of Environmental Effects, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by CH2M Hill Canada Limited. Geological and Hydrogeological Environment, Existing Environmental Conditions, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by CH2M Hill Canada Limited and Kinetrics Inc. Malfunctions, Accidents, and Malevolent Acts, Assessment of Environmental Effects, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by SENES Consultants Limited. Radiation and Radioactivity Environment, Assessment of Environmental Effects, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. August 2009. Prepared by SENES Consultants Limited and AMEC NSS. Radiation and Radioactivity Environment, Existing Environmental Conditions, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by AMEC NSS. Surface Water Environment, Assessment of Environmental Effects, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by Golder Associates. Surface Water Environment, Existing Environmental Conditions, Technical Support Document, New Nuclear - Darlington, Environmental Assessment. September 2009. Prepared by Golder Associates.

OPG Responses to Darlington Joint Review Panel EIS Information Requests.

page 28 APPENDIX A.5

! D. Dillenbeck, “Review of Environmental Impact Statement New Nuclear -- ! Darlington Environmental Assessment” (February 2011).

" Curriculum Vitae, D. Dillenbeck. " Review of Environmental Impact Statement New Nuclear – Darlington Environmental Assessment February 1, 2011

Author: David Dillenbeck, Aquatic Biologist Prepared for: Lake Ontario Waterkeeper

Contents

1. Expertise and Experience of the Author 2. Introduction 3. Goal of this Review 4. Surface Water Quality Monitoring Program a. Purpose b. Water Sampling locations c. Water Sample collection frequency and duration d. Analytical parameters and Method Detection Limits e. Additional Analytical Parameters f. Data Presentation and Analysis g. Reporting frequency h. Specific Assessment Criteria and Threshold Definition 5. Stormwater Quality Monitoring Program a. Purpose b. Water Sampling locations c. Water Sample collection frequency and duration d. Analytical parameters and Method Detection Limits e. Data Presentation and Analysis f. Reporting frequency g. Specific Assessment Criteria and Threshold Definition 6. Bounding Scenarios for Possible Liquid Effluents 7. Assessment of Environmental Impact 8. MOE Mandate 9. Compliance

1 1 Expertise and Experience of the Author

I was employed by the Ontario Ministry of the Environment (MOE) for more than 21 years, from 1975 to 1996. During that time I held several progressively responsible positions at the MOE Kingston Regional Office, including River Systems Biologist and finally, eight years as the Regional Biologist. In the latter capacity, I reviewed and provided comment on technical reports submitted to the Ministry in support of applications for approval of regulated activities. I also prepared expert opinion statements regarding the impact or potential impact of discharges of various materials to the aquatic environment. I have appeared as a witness for the Crown in many prosecutions involving violations of environmental legislation, and I have been recognized by the court as an expert witness. I have also appeared before the Ontario Municipal Board and the Environmental Assessment Advisory Committee. I have investigated fish kills and aquatic nuisance complaints (such as algae blooms, aquatic plants, or pollen), examined and identified biological samples, and provided general water quality information to the public. After I resigned from the Ontario Ministry of the Environment I purchased a car wash in Perth, Ontario and I assumed the day-to-day operation of that business. I have continued to work as a professional biologist on a part-time basis. I have provided advice and assistance, impact assessment reports and expert opinion evidence in court for the Environmental Bureau of Investigation, for two of the Canadian members of the Waterkeeper Alliance (i.e. the Petitcodiac Riverkeeper and the Lake Ontario Waterkeeper), and for the Investigation and Enforcement Branch of the Ontario Ministry of the Environment, I have also assisted several environmental groups, including the Gorge Environmental Committee, in Moncton, New Brunswick and the Tay Valley Township Residents Group and provided Environmental Assessment services to Ontario Lake Assessments.

2 Introduction

I have reviewed the Environmental Impact Statement, New Nuclear – Darlington(the EIS) and several of the Technical Support Documents (TSD's) pertaining to the New Nuclear - Darlington Project (NND Project). The latter include two Surface Water Environment (SWE) TSD's, two Aquatic Environment (AE) TSD's, and the Ecological Risk Assessment and Assessment of Effects on Non-Human Biota TSD.

3 Goal of this Review

The objectives of this review are: • to identify shortcomings, if any, in the EIS or in the noted TSD's;

2 • to request additional information from the proponent that will clarify any noted deficiencies; • to assess the overall validity of these reports and their conclusions; and • to suggest alternative or additional means to ensure that the project can and will be carried out with minimal impact on the aquatic environment.

4 Surface Water Quality Monitoring Program

The early detection and identification of the source of a potentially deleterious substance(s) is essential. In this way, the source can be eliminated or at least reduced and the impact prevented or minimized.

An effective water quality monitoring program is the most practical means to achieve this goal. The elements of such a program that need to be defined include: • Water Sampling locations; • Water Sample collection frequency; • Analytical parameters, and possibly Method Detection Limits [MDL’s]; • Reporting frequency; • Data analysis methodology; • Criteria to be used to assess and evaluate the data: • CWQO's or PWQO's or most stringent criteria available; • When data are presented, whether in a table or a graph, include the criteria, for reference; and • Any threshold(s) for action, who determines when a threshold has been exceeded, what specific action is to be taken if a threshold is reached, and by whom.

4 a) Purpose

The purpose of this proposed water quality monitoring program is to augment the existing database and to enable timely identification of potential deleterious effects on water quality that may occur within the study area, particularly in the Site Study Area. Justification for this proposal is based on the following:

In the EIS, s. 2.9.3 Environmental Monitoring, p. 2-81, it is stated that: “OPG has over three decades of experience sampling, testing, documenting and reporting ... at the DN Site.”... “The emissions and environmental media currently monitored at DNGS are comprehensive in terms of substances and locations”.

Additionally, in s. 3.2.3 Characterization of the Baseline (Existing) Environment, p. 3-1, it is stated that: “[T]here is a very large base of environmental information on which to draw from”.

Despite these claims, the following quote appears in the SWE-EEC, s. 2.2.5, p. 2-30:

3 The Darlington Environmental Effects Final Report [Ontario Hydro 1997b] describes the existing lake water quality database as poor to fair. It appears as though only limited additional water quality has been collected since this report was published. Adequate data and studies do not exist (with regard to temporal, spatial and precision requirements) to characterize baseline conditions and undertake the potentially required assessments. Therefore, a lake water quality sampling program similar to that of the Pickering A Return to Service (PARTS) EA Follow-Up Monitoring Program was conducted from November 2007 to September 2008 (see Chapter 3.0 for details).

I am in agreement with the latter statements. I would add that there are many stormwater outfalls that have not been adequately characterized and that at some locations sampling frequency is not sufficient to enable a timely response to a potentially deleterious discharge.

4 b) Water Sampling Locations

Water samples have been collected at the following locations:

Lake Ontario - Locations within the Site Study Area: SW7, SW8: Existing Discharge Diffuser Zone SW9, SW10: New Build Zone (new diffuser) SW11: Existing Intake Zone

On-Site: SW12: Coots Pond SW13: Tree Frog Pond (to be eliminated) SW14: SWM (Storm Water Management) Pond SW15: Darlington Creek

4 c) Water Sample Collection Frequency and Duration

Sample size refers to the number of observations in a dataset. The sample size, which usually represented by n, has a direct impact on the precision of the estimates (such as the mean, etc.) that are derived from the dataset and on the ability to draw valid conclusions from those estimates. Regardless of the sample size, there will be some margin of error. However, smaller sample sizes tend to be associated with a larger margin of error and larger sample sizes tend to be associated with a smaller margin of error. Consequently, it is very important for the dataset to have a sample size sufficiently large to ensure that the conclusions drawn are valid.

Some clarification is necessary with respect to sample size (in this case, the number of water samples) at the various locations that comprised the Integrated Lake Ontario Water Quality Sampling Program. It is indicated in Tables C-1, C-2, C-3 and C-4, Appendix C, of the SWE-EEC, that five water samples were collected at each discrete sampling location during each of the four campaigns. What is not clear is whether those five samples were collected on the same date or on five separate dates during each

4 campaign. If they were collected on the same date, were all five samples collected consecutively or at five separate times during the day? If all five samples were collected on the same date and consecutively, were they collected individually or were five subsamples taken from one larger sample? (With the exception of the 'five individual samples collected on five separate dates' example, I would consider five samples collected in each of the other circumstances to be replicate samples).

If five individual samples were collected at each location during each of the four separate campaigns, then the sample size would be:

5 samples X 4 campaigns = 20.

However, if five replicate samples were obtained from one larger sample, then the sample size would be:

1 sample X 4 campaigns = 4.

Taking five replicates of the same sample does not increase the sample size.

The margin of error for a dataset with n=4 will be much larger than the margin of error for a dataset with n=20. Therefore, the precision of estimates such as the mean, based on n=4 will be much lower than a mean based on n=20. I believe that this matter can be resolved because it is stated in the SWE-EEC, s.3.4.1 Sampling Methodologies and Protocols, p. 3-5, that “The date and time of collection were recorded”, as was sampling depth. Therefore,

I request that the Proponent provide the dates, times and sampling depths for the samples collected for the Integrated Lake Ontario Water Quality Sampling Program.

With respect to the Surface Water Quality Monitoring Program, water samples should be collected on at least four occasions annually, during the ice-free period, as has been done in the past. In order to create a reliable and representative database, the program should be conducted in this manner for a continuous period of at least three years. A review of the sampling locations and sampling frequency may be carried out after the third complete year. Under no circumstances should the Surface Water Quality Monitoring Program be suspended or discontinued.

It is important to identify and quantify substances at the point of discharge to the receiving body of water. Initial dilution can significantly reduce or even eliminate the possibility of detecting the substance in the receiving body of water.

4 d) Analytical Parameters and MDL's

The water samples collected for the Surface Water Quality Monitoring Program should be analyzed for the same conventional parameters as are identified in Table 3.5-1,

5 Water Quality Parameters, SWE-EEC, p. 3-9. A review of the conventional parameters and/or frequency may be carried out after the third complete year.

I am not able to comment on the either the necessary parameters or the sampling frequency with respect to water sampling for radiological purposes.

With respect to Minimum Detection Limits (MDL's), it is my recommendation that for substances with established criteria for the protection of aquatic life, the MDL be equal to or less than that criteria. For example, a situation may arise where the MDL for a substance is greater than the established criteria for that substance. Consequently, it is not possible to determine whether or not the concentration of a substance that is reported as “less than the MDL” exceeded the established criteria for that substance.

4 e) Additional Analytical Parameters

The proponent states (in the SWE-EEC, s. 4.3.4 Site Liquid Effluent Discharges, p. 4-25) that, due to different reactor design than the DNGS, the liquid effluents from the NND cannot yet be determined. Furthermore, only during post-construction phases (i.e. operation) will sampling of liquid effluents discharged from NND be conducted.

In the SWE-EEC, s. 2.0 Existing Environment Characterization Program, p. 2-1, it is stated that “The essential aspect of the method adopted for defining the “Project for EA Purposes” is the use of a bounding framework that brackets the variables to be assessed. This bounding framework is defined within a Plant Parameter Envelope (PPE). The PPE is a set of design parameters that delimit key features of the Project. The bounding nature of the PPE allows for appropriate identification of a range of variables within a project for the purpose of environmental assessment”.

Is it not possible and appropriate to identify potentially harmful substances that may be present within the Plant Parameter Envelope, in a manner similar to the bounding framework method that was used for other aspects of the Project?

4 f) Data Presentation and Analysis

Appendix C of the SWE-EEC contained the raw data from the 2007-2008 Baseline Surface Water Quality Program. For each discrete sampling date (i.e. sampling campaign), the data for all sampling locations was presented. This method of data presentation is excellent for making 'between location' comparisons and for examining the overall situation in the study area at a specific point in time. However, it is not convenient for making 'within location' comparisons or for examining the situation at a specific location throughout the period in question. By examining 'within location' data one is able to identify temporal variations that may not be exhibited at nearby locations, or that may be a consequence from an adjacent location. Both methods of data presentation are valid and useful and I recommend that both methods of data presentation be required in the respective reports for all future studies.

6 I suggest that in future Surface Water Quality reporting it would also be very useful to have the raw data tabulated for all sampling dates at each discrete sampling location and to have a thorough discussion and interpretation of the situation at each sampling location.

4 g) Reporting Frequency

I recommend that reports pertaining to water quality be required and that these reports be submitted annually. In addition, each report should pertain to no more than 12 months of data and that each report be submitted within 6 months of the end of the sampling period to which the report pertains.

4 h) Specific Assessment Criteria and Threshold Definition

I recommend that one exceedance of a specific water quality objective trigger additional water sampling at the location of the exceedance and at other locations that might reasonably be expected to have affected the location and locations that might reasonably be expected to have been affected by the location.

It is entirely appropriate to use water quality objectives and guidelines that have been established for the protection of aquatic life to define the threshold of impairment. Examples include the CCME-CWQG's or the MOE-PWQO's.

5 Stormwater Quality Monitoring Program

It is not unusual for the volume of an individual stormwater discharge to be continuously low or even non!existent during one or more periods during a year. Such discharges may not be considered significant. However, if the concentration of an undesirable or deleterious substance contained in this discharge is elevated, the discharge may be very significant. It may be contributing a greater contaminant load to the receiving body of water than other larger volume discharges that contain much lower concentrations of those same substances. It is often the low volume discharges that are overlooked and either not monitored or are inadequately monitored, while the larger volume discharges are more frequently monitored and reported on. For whatever reason, the stormwater discharges at the Darlington Nuclear site seem to have been inadequately monitored and assessed.

According to the SWE: Existing Environmental Conditions TSD (p. 4-18), storm runoff leaves the DN site "through at least 22 outfalls", 18 of these discharge directly to Lake Ontario (11 are submerged conduits, 7 are direct outfalls through swales, ditches or culverts). From the information presented in this TSD, it seems that stormwater at the DN site has been very poorly characterized at a few locations and not at all at most locations. Where it has been characterized and found to be contaminated, remediation has not been pursued effectively.

7 5 a) Purpose

It is my opinion that a comprehensive stormwater monitoring program be established in order to characterize all of the stormwater discharges from the DN site (i.e. identify and quantify the substances contained in each discharge). This should be done prior to the commencement of the Site Preparation and Construction Phase. In this way, any perturbations that may occur during Site Preparation and Construction can be readily identified and abated in a timely manner.

It is important to identify and quantify any zone of initial dilution/mixing at the point of discharge. Depending on the concentrations and volumes of the stormwater discharges, localized areas of impairment may exist that have not been identified by previous Lake Ontario Water Quality sampling programs.

5 b) Stormwater Sampling Locations

A number of locations on the DN site were identified as point source stormwater outfalls: “storm runoff generated at the DN site leaves the site through at least 22 outfalls; 18 of those outfalls discharge directly to Lake Ontario” SWE-EEC, p. 4-18.

Of the 18 outfalls that discharge directly to Lake Ontario, 11 outfalls are submerged conduits below lake water level and 7 outfalls discharge to swales, ditches, and culverts, which in turn discharge to Lake Ontario. Figure 4.3-2, Stormwater Management Drainage Areas, SWE-EEC, p. A-19, identifies 14 stormwater outfalls that discharge directly to Lake Ontario and 4 that discharge indirectly to Lake Ontario. The 14 stormwater outfalls that discharge directly to Lake Ontario are (from west to east): A, B, O, N-2/M, L, J(J-1), K2, K, K(K-1), I, H, H, G-2 and G. Some sampling was conducted at some of those locations, however, data tabulations were not provided. The discussion of the analytical results, though very limited, did indicate that some of the discharges contained elevated concentrations of substances of concern and that some failed rainbow trout and Daphnia magna acute lethality tests.

I request that the Proponent provide all of the stormwater data (tabulated by date for each sampling location), including the toxicology data, and a thorough discussion and interpretation of that data.

5 c) Stormwater Sample Collection Frequency and Duration Each of the known stormwater outfalls should be sampled at least monthly during the ice-free period until a general characterization of each discharge has been obtained. At sampling locations where flow may be intermittent or low, the water samples should be reasonably well spaced throughout the year. If this is not possible, then they should be collected after significant rainfall events. In this way, the discharge of any substance(s) to Lake Ontario that may not be addressed in the known industrial point sources (through the C of A or MISA monitoring) can be identified.

8 A review of the sampling locations and sampling frequency may be carried out after the third complete year and sampling may be reduced to bi-monthly or perhaps quarterly, but under no circumstances should the Stormwater Quality Monitoring Program be suspended or discontinued.

5 d) Analytical Parameters and Method Detection Limits Stormwater quality data collection should include routine water chemistry parameters, heavy metals and organic compounds, such as were collected for the Lake Ontario Water Quality Monitoring Program In addition, the stormwater quality monitoring program should include the following for each identified stormwater outfall: • Determination of the total volume discharged monthly and annually: • Flow information should be collected weekly and during significant rainfall events until such time as an accurate determination of the volume discharged has been obtained, at which point the frequency may be reduced. • Loading discharged to the receiver (based on the above volume and concentrations): • An assessment of the impact of the contaminant loads on the water quality in the immediate area of the discharge. • Acute lethality testing, i.e. Daphnia and rainbow trout toxicity testing: • Toxicity testing should be conducted on at least one occasion for each stormwater outfall and more frequently at any outfalls that may be found to be toxic. • With respect to MDL's, as was recommended for surface water quality monitoring.

5 e) Data Presentation and Analysis

Data analysis methodology as was recommended for surface water quality reporting,

5 f) Reporting Frequency

As was recommended for surface water quality reporting, I recommend that reports pertaining to stormwater quality be required and that these reports be submitted annually. In addition, each report should pertain to no more than 12 months of data and each report should be submitted within 6 months of the end of the sampling period to which the report pertains.

5 g) Specific Assessment Criteria and Threshold Definition

With respect to assessment Criteria and threshold definition, I recommend that the existing water quality objectives and guidelines (i.e. the CCME-CWQG's or the MOE-

9 PWQO's) that have been established for the protection of aquatic life be used to identify potential impairment of a receiving waterbody by a stormwater discharge.

6 Bounding Scenarios for Possible Liquid Effluents

It is stated that the sampling of effluent streams cannot be performed until reactor technology has been chosen. Although this is true, would it not be possible to identify substances that may potentially be present in liquid effluents and to prepare "bounding scenario's" for potential contaminants and effluent streams?

I am not aware of any discussion in the TSD' s pertaining to the range in concentrations of particular substances that could be expected in the effluent from a particular technology (i.e. the range in concentrations of cobalt anticipated in the effluent if once through cooling was chosen, or the range in concentrations of boron anticipated in the effluent if the cooling tower option was chosen, etc.), If bounding scenarios had been presented, then a discussion of potential mitigative or remedial measures could have been undertaken.

7 Assessment of Environmental Impact

To effectively ascertain whether or not there has been environmental impact in a given situation, it is necessary to establish two elements. First, one must determine the most appropriate component of the environment in which to monitor for impact. Second, one must recognize a threshold, above which, environmental impact will be deemed to have occurred.

In my opinion, the most effective element of the aquatic environment in which to monitor for potential impact is the surface water component. It is an ideal early warning system. With appropriate monitoring, water quality degradation can be detected long before aquatic biota start exhibiting evidence of environmental stress. The establishment of guidelines “for the protection of aquatic life” by many governments and environmental groups demonstrates the widespread acceptance of this concept.

However, the proponent has not identified any VEC's (Valued Environmental Components) for the Surface Water Environment and states in section 4.6 of the Surface Water Environment – Existing Environmental Conditions TSD, that: “Surface water is a pathway for effects on non-human biota and to VEC's in other environmental components”, and that: “Changes in surface water quality will be the basis for considering effects on VEC's in other environmental components”. Taken together, these statements indicate that the proponent believes the degradation of water quality is not, in and of itself, an issue.

The other significant concept that must addressed is that of “the threshold of meaningful effects”.

10 The assessment of meaningful effects by means of population-level biota assessment has been promoted throughout the documents. On page 2-7 of the Aquatic Environment – Existing Environmental Conditions TSD, the proponent defines meaningful effects as: “those effects which have the potential to affect populations of aquatic biota”. In the next paragraph it is stated that: “Beyond the range of naturally occurring fluctuations, the compensatory scope of some species populations may be insufficient to offset the effects of certain perturbations and the viability of those populations could be affected”.

The latter statement anticipates that population-level assessment will result in at least some population effects as a consequence of “certain perturbations”. I believe that effective water quality monitoring combined with timely identification and elimination or mitigation of the cause would greatly reduce the likelihood of this occurrence.

On page 2-9 of the Aquatic Environment – Assessment of Environmental Effects TSD, it is stated that: “For effects that relate to changes in aquatic habitat, the area of habitat effected and the qualitative function of the habitat constitute the criteria of assessment”, and that: “For effects that relate to various aquatic species the criterion of assessment is population conservation”. Water quality monitoring was not discussed as an effective means of impact assessment with respect to either the aquatic habitat or aquatic species.

Furthermore, the actual threshold (i.e. what substance at what concentration) was not defined. In my opinion, applicable thresholds have been established by federal and provincial regulators and these are embodied in the CCME-CWQG's and in the MOE- PWQO's, respectively. These guidelines and objectives have been established for the protection of aquatic life and the exceedance of these guidelines and objectives 'may impair' water quality and therefore endanger aquatic life. It is much more expedient to monitor water quality and respond when degradation has been detected than it is to monitor the aquatic population and respond when population impact is detected.

In summary, I recommend that a comprehensive water quality monitoring combined with the use of CCME-CWQG's or MOE-PWQO's or most stringent criteria available, would be the most effective means of assessing environmental impact and of preventing environmental degradation.

11 Appendix: Compliance a. Ontario Ministry of the Environment Policy

The following information is contained in the publication entitled Water Management – Goals, Policies, Objectives and Implementation Procedures of the Ministry of the Environment. November 1978, Revised May 1984 and commonly referred to as “The Blue Book”. It expresses the intent of the MOE's water management policies and its role in surface water quality issues through the implementation of these policies.

Surface Water Quality Management section

Policy 1 - Areas With Water Quality Better Than the Objectives, page 13: “violation of the Provincial Water Quality Objectives will not be allowed.”

Policy 2 – Areas With Water Quality Not Meeting the Objectives, page 14: “Evaluations of existing conditions in problem areas shall be conducted and remedial measures shall be taken to upgrade water quality to the Provincial Water Quality Objectives as stipulated under Policy 3”, and “deviations from Policy 2 may be allowed, subject to the approval of the Director, Water Resources Branch”.

Policy 3 – Effluent Requirements

Toxicity Testing, page 18: “Bioassay tests may be required to identify discharges deleterious to aquatic organisms. Undiluted industrial effluents or other discharges which induce more than 50% mortality over 96 hours under static test conditions may require more rigorous biological testing to determine if additional treatment is needed to afford adequate protection to the environment. Biological responses other than mortality may also be used to demonstrate impairment.”

Procedures for the Taking and Discharge of Cooling Water, item (c) Contaminants in Discharge Water, page 19: “The use of cooling water for waste disposal shall be minimized. Such waste as may be permitted to be disposed of in this manner shall be at such levels as determined by application on a case-by-case basis to the Ministry. Substances used as biocides in condenser cleaning will only be permitted in the cooling water at residual levels to be approved by the Ministry of the Environment on a case-by- case basis.”

Policy 5 – Mixing Zones

3. “No conditions within the mixing zone should be permitted which: ...

12 c) result in bioconcentration of toxic materials which are harmful to the organism or its consumer;”

It is important to be aware of the MOE's mandate in this matter and to anticipate that these issues will be brought forward by the Ministry. b. Federal Fisheries Act

The Fisheries Act (s.36(3)) states that, “no person shall deposit or permit the deposit of a deleterious substance”. It is not necessary to establish whether or not the discharge did in fact produce/result in an effect and it is my opinion that the deposit of a substance in excess of established Guidelines /Objectives constitutes “deleterious”. c. Ontario Water Resources Act

The Ontario Water Resources Act (s.30(1)) states that every person that discharge any material “that may impair the quality of the water” is guilty of an offence.

13 David Dillenbeck, Biologist

Mr. Dillenbeck worked for the Ontario Ministry of Environment and Energy for nearly 21 years and continues to work as a professional biologist. He appeared as an expert witness in many prosecutions involving violations of environmental legislation. His expertise includes the impact of discharges of materials to aquatic environments, surface water quality, the zebra mussel introduction in the Great Lakes, and several types of aquatic nuisances (ﬁsh kills, algae blooms, etc.).

As a river systems biologist for nine years, he was in charge of all phases of point source discharge surveys. The point sources surveyed included industrial discharges and process efﬂuents, water and waste water treatment facilities and waste disposal sites. Mr. Dillenbeck holds a Honours bachelor degree in biology and is a member of the North American Benthological Society and of the Canadian Society of Environmental Biologists.!