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Ontario Power Generation's Response to the Joint Review

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Attachment 1 <strong>to</strong> OPG letter, Albert Sweetnam <strong>to</strong> Dr. Stella Swanson, “Deep Geologic Reposi<strong>to</strong>ry Project for Low and Intermediate Level Waste – Submission of<br />

<strong>Response</strong>s <strong>to</strong> <strong>the</strong> Final Sub-set of Package #4 Information Requests”, CD#: 00216-CORR-00531-00143.<br />

IR# EIS Guidelines<br />

Section<br />

EIS-04-135 � Section 11.4.7,<br />

Atmosphere<br />

Information Request and <strong>Response</strong><br />

Information Request:<br />

Discuss <strong>the</strong> potential implementation of a part-time or emergency exhaust ventilation filtration system that could be<br />

used <strong>to</strong> capture dust and aerosol releases in <strong>the</strong> event of accident scenarios such as underground fires or explosions.<br />

Context:<br />

In <strong>the</strong> description of <strong>the</strong> ventilation system design, it is stated that no exhaust air filtration will exist due <strong>to</strong> <strong>the</strong> rationale<br />

that radioactive gases existing in this airflow will not be captured by a filtration system. It is stated, however, that<br />

condensate water from <strong>the</strong> exhaust airflow stream will be recovered in order <strong>to</strong> sequester and treat tritium<br />

contaminants. Under exceptional circumstances, however, as would exist in <strong>the</strong> event of underground fires, explosions<br />

or o<strong>the</strong>r events, aerosols and fugitive dusts may be liberated and transported by <strong>the</strong> airflow that could potentially<br />

contaminate <strong>the</strong> surface environment if <strong>the</strong>y were not filtered.<br />

OPG <strong>Response</strong>:<br />

The ventilation system design does not include exhaust air filtration primarily because filtration is not required in order<br />

<strong>to</strong> meet criteria under normal operations and credible accidents. Also, <strong>the</strong> primary radionuclides in <strong>the</strong> air exhaust -<br />

tritium and carbon-14 - will be present mostly in gaseous form and <strong>the</strong>refore are not captured by industrial highefficiency<br />

particulate filters.<br />

1) Preliminary Design Basis<br />

Under normal operating conditions, radioactive particulate releases are not expected at <strong>the</strong> DGR because: (1) <strong>the</strong>re<br />

will be no waste conditioning processes at <strong>the</strong> DGR; (2) all <strong>the</strong> waste packages arriving at <strong>the</strong> DGR will be closed with<br />

lids, and (3) external loose contamination will be checked prior <strong>to</strong> acceptance at <strong>the</strong> DGR (Section 7.4.2.1 of <strong>the</strong><br />

Preliminary Safety Report (PSR), OPG 2011). The underground exhaust air is expected <strong>to</strong> contain diesel combustion<br />

products (gases and particulate), dust/particulate (non-radioactive), tritium (primarily as HTO vapor) and C-14 (primarily<br />

as CO2). The levels of airborne tritium and C-14 will be within respective criteria, and no filtration will be required (OPG<br />

2011, Sections 7.4.2.3 and 7.4.3). The preclosure safety assessment has evaluated <strong>the</strong> consequences of a range of<br />

accidents involving radioactive waste packages (OPG 2011, Section 7.5.1). These accidents include underground fires<br />

and breach of packages. In all cases, <strong>the</strong> dose consequences from air released from <strong>the</strong> ventilation exhaust would be<br />

within criteria at <strong>the</strong> relevant recep<strong>to</strong>r points (i.e., within public dose criteria at <strong>the</strong> nearest Bruce nuclear site fence line)<br />

(OPG 2011, Section 7.5.4). Consequently, exhaust filtration is not required <strong>to</strong> meet dose criteria in <strong>the</strong> event of<br />

accidents. This is in part because of <strong>the</strong> following fac<strong>to</strong>rs:<br />

� <strong>the</strong> wastes are solid materials and not easily dispersed as particulate in air,<br />

� <strong>the</strong> higher activity wastes are in more robust packages (e.g., intermediate level resin wastes are in steel<br />

containers within concrete overpack),<br />

� <strong>the</strong> containers are not moved quickly, nor in large numbers in any shipments.<br />

Page 42 of 69

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