Ontario Power Generation's Response to the Joint Review

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Attachment 1 to OPG letter, Albert Sweetnam to Dr. Stella Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to the Final Sub-set of Package #4 Information Requests”, CD#: 00216-CORR-00531-00143. IR# EIS Guidelines Section Information Request and Response o handling of algal blooms in the pond should these occur; o addition of makeup water to the permanent pool if the water surface falls below the normal water level; o control of unwanted vegetation growth and replanting of desired vegetation around the pond perimeter; o embankment and shoreline repairs; o removal of trash, debris and plugged ice from the inlet and outlet works; o repairs or replacement of pipe culverts, concrete structures; and o lubrication and replacement of seals in the valve in the discharge pipe. Sediment accumulation and clear-out frequency is being considered in the design of the SWMP. An allowance has been made for sediment accumulation in the permanent pool; this volume is sufficiently large such that the clear-out frequency will be annually, at a maximum. References: GOLDER. 2011. Hydrology and Surface Water Quality Technical Support Document. Golder Associates Ltd. report for the Nuclear Waste Management Organization NWMO DGR-TR-2011-04 R000. Toronto, Canada. (CEAA Registry Doc# 299) MOE (Ontario Ministry of the Environment). 2003. Stormwater Management Planning and Design Manual. ISBN 0- 7794-2969-9. MOEE (Ontario Ministry of Environment and Energy). 1994. Protocol for Conducting a Storm Water Control Study. August. ISBN 0-7778-1786-1. NWMO. 2011. DGR EA Follow-up Monitoring Program. Nuclear Waste Management Organization document NWMO DGR-TR-2011-10 R000. Toronto, Canada. (CEAA Registry Doc# 299) OPG. 2011a. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Preliminary Safety Report. Ontario Power Generation report 00216-SR-01320-00001 R000. Toronto, Canada. (CEAA Registry Doc# 300) OPG. 2011b. OPG’s Deep Geologic Repository for Low and Intermediate Level Waste – Environmental Impact Statement. Ontario Power Generation report 00216-REP-07701-00001 R000. Toronto, Canada. (CEAA Registry Doc# 298) OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission for the July 18, 2012 JRP Technical Information Session”, CD# 00216-CORR-00531-00123, July 12, 2012. (CEAA Registry Doc# 636) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Information Requests”, CD# 00216-CORR-00531-00108, March 9, 2012. (CEAA Registry Doc# 363) Page 41 of 69
Attachment 1 to OPG letter, Albert Sweetnam to Dr. Stella Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Responses to the Final Sub-set of Package #4 Information Requests”, CD#: 00216-CORR-00531-00143. IR# EIS Guidelines Section EIS-04-135 � Section 11.4.7, Atmosphere Information Request and Response Information Request: Discuss the potential implementation of a part-time or emergency exhaust ventilation filtration system that could be used to capture dust and aerosol releases in the event of accident scenarios such as underground fires or explosions. Context: In the description of the ventilation system design, it is stated that no exhaust air filtration will exist due to the rationale that radioactive gases existing in this airflow will not be captured by a filtration system. It is stated, however, that condensate water from the exhaust airflow stream will be recovered in order to sequester and treat tritium contaminants. Under exceptional circumstances, however, as would exist in the event of underground fires, explosions or other events, aerosols and fugitive dusts may be liberated and transported by the airflow that could potentially contaminate the surface environment if they were not filtered. OPG Response: The ventilation system design does not include exhaust air filtration primarily because filtration is not required in order to meet criteria under normal operations and credible accidents. Also, the primary radionuclides in the air exhaust - tritium and carbon-14 - will be present mostly in gaseous form and therefore are not captured by industrial highefficiency particulate filters. 1) Preliminary Design Basis Under normal operating conditions, radioactive particulate releases are not expected at the DGR because: (1) there will be no waste conditioning processes at the DGR; (2) all the waste packages arriving at the DGR will be closed with lids, and (3) external loose contamination will be checked prior to acceptance at the DGR (Section 7.4.2.1 of the Preliminary Safety Report (PSR), OPG 2011). The underground exhaust air is expected to contain diesel combustion products (gases and particulate), dust/particulate (non-radioactive), tritium (primarily as HTO vapor) and C-14 (primarily as CO2). The levels of airborne tritium and C-14 will be within respective criteria, and no filtration will be required (OPG 2011, Sections 7.4.2.3 and 7.4.3). The preclosure safety assessment has evaluated the consequences of a range of accidents involving radioactive waste packages (OPG 2011, Section 7.5.1). These accidents include underground fires and breach of packages. In all cases, the dose consequences from air released from the ventilation exhaust would be within criteria at the relevant receptor points (i.e., within public dose criteria at the nearest Bruce nuclear site fence line) (OPG 2011, Section 7.5.4). Consequently, exhaust filtration is not required to meet dose criteria in the event of accidents. This is in part because of the following factors: � the wastes are solid materials and not easily dispersed as particulate in air, � the higher activity wastes are in more robust packages (e.g., intermediate level resin wastes are in steel containers within concrete overpack), � the containers are not moved quickly, nor in large numbers in any shipments. Page 42 of 69
Page 2 and 3: Dr. Stella Swanson September 28, 20
Page 4 and 5: Attachment 1 to OPG letter, Albert
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Page 76 and 77: Table of Contents CLOSURE WALL CAPA
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Serge Clement 1011170042-TM-G2100-0
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APPENDIX A Derivation of Conversion
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External radius of liner =
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ATTACHMENT 2 Attachment to OPG lett
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8. Letter from A. Sweetnam to S. Sw
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OPG’s L&ILW Deep Geologic Reposit
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Ontario Power Generation's Response to the Joint Review

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