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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 />

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

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

This response was prepared in consideration of <strong>the</strong> reference <strong>to</strong> Information Request (IR) EIS-02-34 (OPG 2012a). It<br />

is assumed, based on that response, that zones of mineralization refers <strong>to</strong> <strong>the</strong> Ordovician shales that are intersected<br />

within <strong>the</strong> vent and main shaft only and represent approximately 4% by volume <strong>the</strong> rock <strong>to</strong> be placed in <strong>the</strong> Waste Rock<br />

Management Area (WRMA) and which will be s<strong>to</strong>red in a temporary s<strong>to</strong>ckpile within <strong>the</strong> WRMA. GOLDER (2011,<br />

Table 3) reports that <strong>the</strong> highest concentrations of trace metals (As, Cu, Co, Ni, Pb, Tl and Zn) are found in <strong>the</strong> shale<br />

sequence.<br />

As reported in GOLDER (2011) and in OPG’s response <strong>to</strong> IR-EIS-03-96 (OPG 2012b), <strong>the</strong> results of short-term<br />

labora<strong>to</strong>ry leach testing indicate a potential for some metals (aluminum, boron, cobalt, thallium and vanadium) <strong>to</strong> leach<br />

at concentrations slightly above <strong>the</strong> Provincial Water Quality Objectives (MOEE 1994). However, <strong>the</strong>se tests are<br />

considered <strong>to</strong> be conservative and not fully representative of wea<strong>the</strong>ring and o<strong>the</strong>r processes likely <strong>to</strong> occur in <strong>the</strong> field.<br />

Fur<strong>the</strong>r preliminary water quality modelling being completed in support of <strong>the</strong> design of <strong>the</strong> s<strong>to</strong>rmwater management<br />

pond has identified no potential concerns with metals in <strong>the</strong> s<strong>to</strong>rmwater pond discharge as a result of leaching from <strong>the</strong><br />

waste rock.<br />

Kinetic testing is designed <strong>to</strong> provide an indication of how materials will react over time. For sulphidic materials,<br />

humidity cell testing is <strong>the</strong> standard kinetic test that measures <strong>the</strong> wea<strong>the</strong>ring of sulphide minerals. O<strong>the</strong>r kinetic tests<br />

are intended primarily <strong>to</strong> measure secondary mineral precipitation and dissolution wea<strong>the</strong>ring characteristics (MEND<br />

2009). Nei<strong>the</strong>r of <strong>the</strong>se tests are directly applicable <strong>to</strong> <strong>the</strong> DGR Project because much of this testing is directed<br />

<strong>to</strong>wards characterizing sulphidic materials in areas of mineralization, which as described above, are not observed in<br />

large quantities at <strong>the</strong> DGR site and are <strong>the</strong>refore not expected <strong>to</strong> control <strong>the</strong> drainage chemistry. In addition, <strong>the</strong>se<br />

kinetic lab tests have inherent uncertainties and, when <strong>the</strong> results are applied <strong>to</strong> predictive modelling, would not provide<br />

more certainty than <strong>the</strong> short-term leach results. In fact, <strong>the</strong> short-term leach results have been used in a conservative<br />

way because it was assumed that <strong>the</strong> concentrations leaching from <strong>the</strong> waste rock are <strong>the</strong> same through <strong>the</strong> life of <strong>the</strong><br />

project, and do not decrease with time as would be expected.<br />

The guidelines presented in Price (1997), MEND (2009) and INAP (2012) are largely meant for geochemical<br />

characterization of sulphidic deposits and advocate for a phased approach with respect <strong>to</strong> geochemical<br />

characterization. Static testing (which includes short-term leach testing) is <strong>the</strong> first phase of geochemical<br />

characterization, and is a precursor <strong>to</strong> kinetic testing. Kinetic testing is commonly required <strong>to</strong> assess <strong>the</strong> relative rates<br />

of <strong>the</strong> various acid rock drainage and metal leaching reactions over time. Field-scale leach tests may be initiated <strong>to</strong><br />

provide a better representation of material reactivity for specific waste rock management area conditions. Kinetic<br />

testing is typically only performed if static tests indicate a potential for acid generation or metal leaching. Given that <strong>the</strong><br />

results of <strong>the</strong> geochemical testing (GOLDER 2011) indicated no potential for acid generation, <strong>the</strong> overall sulphide<br />

content was low, and <strong>the</strong> leachate concentrations were not significantly above <strong>the</strong> criteria (Provincial Water Quality<br />

Objectives), kinetic testing was not recommended.<br />

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