BRUCE HEAVY WATER PLANT DECOMMISSIONING PROJECT

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Environment Canada Environnement Canada Environmental Protection Branch Protection de l’environnement Ontario Region Région de l’Ontario 4905 Dufferin Street 4905, rue Dufferin Downsview, Ontario Downsview, Ontario M3H 5T4 M3H 5T4 June 30, 2003 Larry Chamney Canadian Nuclear Safety Commission P.O. Box 1046, Station B Ottawa, Ontario K1P 5S9 RE: Request for “Sign-Off” on the Comprehensive Study Report (CSR) for the Bruce Heavy Water Plant Decommissioning Project This is in response to your letter dated January 27, 2003, pursuant to section 12(3) of the Canadian Environmental Assessment Act (CEAA) regarding the above mentioned project. As per Environment Canada’s May 10, 2002 letter (J. Clarke, EC to L. Chamney, CNSC) we are in possession of specialist or expert information and knowledge in relation to the assessment of this project. In context of our role as an expert Federal Authority per section 12(3) of CEAA, we have reviewed the CNSC’s Comprehensive Study Report (CSR) for the Bruce Heavy Water Plant Decommissioning Project (January 2003) and OPG’s Bruce Heavy Water Plant Decommissioning Environmental Assessment Study Report (December 2002), and are providing comments with respect to the following areas of EC’s mandate: • section 36(3) of the Fisheries Act • Canadian Environmental Protection Act; • Department of Environment Act; • Migratory Birds Convention Act; • National Accord for the Protection of Species at Risk, which commits all provinces to the protection of species at risk as listed through the Committee on the Status of Endangered Wildlife in Canada (COSEWIC); • Canada Wildlife Act, which provides information on species at risk as designated by COSEWIC; • A Wildlife Policy for Canada, which aims to maintain and restore ecological processes and the diversity of ecosystems, species and genetic variability within species; • Federal Policy on Wetland Conservation, which is a shared federal responsibility that directs all departments to sustain wetland functions in the delivery of their programs, services or expenditures; • Canadian Biodiversity Strategy, which is in response to United Nations Convention on Biological Diversity; • Environment Canada’s Sustainable Development Strategy; • Canada Water Act, which provides information on surface hydrology, water quality, hydrogeology; and • any other federal policies respecting environmental matters.
This does not relieve the proponent from meeting the requirements of the federal Fisheries Act, including section 36(3), the Migratory Birds Regulations, or any regulations made under the Canadian Environmental Protection Act, 1999 that are applicable to the project or to any effluent or discharge that may result from the project. Information and comments provided here should not be construed as a fettering of the government's ability to make decisions and/or enforce any applicable regulations. Our May 10, 2002 letter identified a number of areas that we suggested the CNSC should resolve during the public review of the EA Report. We are generally satisfied with the proponent’s response to our comments, as summarized in Table C.4.2(b). However, we would like to provide the following two comments. Terrestrial Environment Our May 10 letter noted that demolition activities, including the felling of towers, is expected to take place over a period of two years, during which time the proponent indicated that it would adhere to the Ontario Ministry of the Environment noise guidelines. We indicated that compliance with provincial noise guidelines would not necessarily ensure that there would be no adverse environmental effects on wildlife, in particular breeding birds in Inverhuron Provincial Park. We asked that residual noise generated by the felling of the towers in the adjacent habitat areas be assessed in the same manner as residual noise on local communities. The December 2002 EA Study Report selects only human receptors as VECs, and does not appear to acknowledge potential impacts on wildlife, including breeding birds (p. 8- 10). The noted “shielding effect” of forests in noise dissipation would not be applicable to species living near the edges of the forest. However, given the ~ 2 km separation between the Heavy Water Plant site and the nearest forest receptor, we do not expect that there is a likelihood of significant adverse environmental effects. We would suggest however that this potential effect be monitored through the follow-up program. Noting that the proponent has indicated that a “fence-line” locations will be used for the noise monitors, we would request that such a monitored be installed at the southern boundary of the BNPD site, adjacent to Inverhuron Provincial Park. Contaminated Soil and Groundwater The December 2002 EA Study Report indicates that all soils that exceed applicable soil quality guidelines will be identified through additional soil sampling, and that soils exceeding these guidelines will be removed from the site. We further note that the “End State Follow-up Program” (Table 10.3) includes additional soil samples upon completion of the demolition and decommissioning work to ensure that no soils exceeding applicable guidelines remain. Noting that the CNSC’s CSR indicates that the follow-up program will be further developed in more detail during the licensing assessment of the detailed Decommissioning Plan, we would like to request that the CNSC provide EC with a copy of the Soils, Geology and Hydrogeology Demolition/Remediation Phase Monitoring and End State Follow-up monitoring programs.
Page 1 and 2: COMPREHENSIVE STUDY REPORT BRUCE HE
Page 3 and 4: 1.0 INTRODUCTION The Canadian Nucle
Page 5 and 6: 2.3 Regulatory Requirements The BHW
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Page 9 and 10: The regulatory compliance programs
Page 11 and 12: 10.4 Cumulative Environmental Effec
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Bruce Heavy Water Plant Decommissio
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SITE STUDY AREA FOR BHWP DECOMMISSI
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LOCATIONS OF SOIL SAMPLING ON BHWP
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LAND USE ON THE BRUCE NUCLEAR SITE
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Environmental Component Table 7.1 A
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ONTARIO POWER GENERATION - BRUCE HE
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QTF Inc R. R. 3 Tiverton, Ontario N
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ONTARIO POWER GENERATION - BRUCE HE
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BRUCE HEAVY WATER PLANT DECOMMISSIONING PROJECT

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