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 OPG Response: This response was prepared in consideration of the reference to Information Request (IR) EIS-02-34 (OPG 2012a). It is assumed, based on that response, that zones of mineralization refers to the Ordovician shales that are intersected within the vent and main shaft only and represent approximately 4% by volume the rock to be placed in the Waste Rock Management Area (WRMA) and which will be stored in a temporary stockpile within the WRMA. GOLDER (2011, Table 3) reports that the highest concentrations of trace metals (As, Cu, Co, Ni, Pb, Tl and Zn) are found in the shale sequence. As reported in GOLDER (2011) and in OPG’s response to IR-EIS-03-96 (OPG 2012b), the results of short-term laboratory leach testing indicate a potential for some metals (aluminum, boron, cobalt, thallium and vanadium) to leach at concentrations slightly above the Provincial Water Quality Objectives (MOEE 1994). However, these tests are considered to be conservative and not fully representative of weathering and other processes likely to occur in the field. Further preliminary water quality modelling being completed in support of the design of the stormwater management pond has identified no potential concerns with metals in the stormwater pond discharge as a result of leaching from the waste rock. Kinetic testing is designed to provide an indication of how materials will react over time. For sulphidic materials, humidity cell testing is the standard kinetic test that measures the weathering of sulphide minerals. Other kinetic tests are intended primarily to measure secondary mineral precipitation and dissolution weathering characteristics (MEND 2009). Neither of these tests are directly applicable to the DGR Project because much of this testing is directed towards characterizing sulphidic materials in areas of mineralization, which as described above, are not observed in large quantities at the DGR site and are therefore not expected to control the drainage chemistry. In addition, these kinetic lab tests have inherent uncertainties and, when the results are applied to predictive modelling, would not provide more certainty than the short-term leach results. In fact, the short-term leach results have been used in a conservative way because it was assumed that the concentrations leaching from the waste rock are the same through the life of the project, and do not decrease with time as would be expected. The guidelines presented in Price (1997), MEND (2009) and INAP (2012) are largely meant for geochemical characterization of sulphidic deposits and advocate for a phased approach with respect to geochemical characterization. Static testing (which includes short-term leach testing) is the first phase of geochemical characterization, and is a precursor to kinetic testing. Kinetic testing is commonly required to assess the relative rates of the various acid rock drainage and metal leaching reactions over time. Field-scale leach tests may be initiated to provide a better representation of material reactivity for specific waste rock management area conditions. Kinetic testing is typically only performed if static tests indicate a potential for acid generation or metal leaching. Given that the results of the geochemical testing (GOLDER 2011) indicated no potential for acid generation, the overall sulphide content was low, and the leachate concentrations were not significantly above the criteria (Provincial Water Quality Objectives), kinetic testing was not recommended. Page 65 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 Information Request and Response While small-scale field cells can also be designed to measure the drainage conditions under ambient conditions, field cells are not appropriate in this circumstance because of the short length of construction. By the time the target rock had been excavated, and meaningful data obtained from the field test charges, the full target waste rock piles will already be in place, and monitoring data from these waste rock piles would provide the data that the small-scale field cell results were intended to provide. In addition, the DGR Project has already been designed to mitigate potential environmental effects of the waste rock piles, specifically the Ordovician shales. This includes using the shale in berms and capping the pile if it is not used after one year. Given the low permeability of the dense glacial till underlying the WRMA, no appreciable migration of the waste rock leachate into the groundwater is expected, as described in OPG’s response to IR-EIS-03-57 (OPG 2012c). A shallow groundwater monitoring program is being commissioned in 2012 to establish baseline groundwater conditions and allow for the detection of future WRMA effects, if any, on the groundwater system during DGR construction and operations. As the waste rock pile will develop slowly during the first year while the shafts are being excavated, a reasonable approach to confirm the geochemical properties and modelling predictions would be to monitor the waste shale rock as it is excavated, as well as the drainage chemistry from the WRMA. Should monitoring results indicate that the waste shale rock pile is behaving differently than suggested by the laboratory data, adjustments can be made such as removing the shale from the site, covering the shale pile earlier or changing runoff collection routing, to ensure proper mitigation and treatment, as described further in the response to IR-EIS-04-130. References: INAP. 2012. International Network for Acid Prevention. The GARD Guide. Accessed on August 7, 2012 from www.gardguide.com. GOLDER. 2011. Results of Geochemical Testing of Rock Samples from the Deep Geologic Repository (DGR). Golder Associates Ltd. Technical Memorandum from C.McRae to D.Barker (NWMO). (included in CEAA Registry Doc# 523) MEND. 2009. Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials. MEND Report 1.20.1. Mining Environment Neutral Drainage Program, Natural Resources Canada. MOEE. 1994. Water Management Policies Guidelines, Provincial Water Quality Objectives of the Ministry of Environment and Energy. PIBS #3303e. OPG. 2012a. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste - Submission of Responses to Information Request Package #2”, CD# 00216-CORR-00531-00115, June 1, 2012. (CEAA Registry #523) OPG. 2012b. OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Page 66 of 69
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Dr. Stella Swanson September 28, 20
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Attachment 1 to OPG letter, Albert
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Ontario Power Generation's Response to the Joint Review

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