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 EIS-04-160 � Section 8.3, Operation � Section11.4.1, Geology and Geomorphology Information Request and Response Level Waste - Submission of Responses to Information Request (IR) Package #3”, CD# 00216-CORR-00531-00117, July 9, 2012. (CEAA Registry #608) OPG. 2012c. Attachment 1 to OPG Letter, A. Sweetnam to S. Swanson, “Deep Geologic Repository Project for Low and Intermediate Level Waste – Submission of Previously Committed Responses to Information Requests”, CD# 00216-CORR-00531-00126, August 9, 2012. (CEAA Registry #682) Price, W.A. 1997. Draft Guidelines and Recommended Methods for the Prediction of Metal Leaching and Acid Rock Drainage. BC Ministry of Employment & Investment, Energy and Minerals Division. Information Request: Provide a detailed waste rock monitoring program that: � Verifies predictions made during the EA regarding waste rock characterization and leachate quality; and � Evaluates the effectiveness of measures that have been implemented to prevent and control contaminant leaching. The waste rock monitoring program should include the following: 1. confirmation (during construction) of mineralogy as well as contaminant levels in rock for each horizon; 2. testing should there be potential for risk based on solids characterization; and 3. management plans (e.g., segregation of problematic waste) if risk is confirmed. Note: This IR is a follow-up to JRP IR EIS-02-34. Context: The waste rock monitoring program should continually inform the management of waste rock on-site. Potentially problematic waste rock may need to be segregated (placed into a different pile). Monitoring of changes in water quality due to the waste rock pile should be carefully tracked over time to ensure that predictions about contaminant loadings are still being met. The Canadian Nuclear Safety Commission recommends using the following for general guidance: Price W.A. (2009) Prediction manual for drainage chemistry from sulfidic geologic materials. MEND Report 1.20.1. OPG Response: The waste rock monitoring program will include collection and geochemical testing of rock samples from each major horizon during shaft sinking, at a maximum interval of 50 metres. These results will provide an early indication of any substantial variance from the acid generation potential, elemental content and metal leaching potential as presented in the EIS. On-going geological characterization carried out with the Geoscientific Verification Plan (NWMO 2011) will Page 67 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 include examination for hydrocarbon occurrence that may require mitigation within the waste rock management area (WRMA). As described in the response to Information Request (IR) EIS-04-159, the guidelines presented in MEND (2009) are largely meant for geochemical characterization of sulphidic deposits and are not entirely applicable to the DGR Project. However, waste rock testing will include elemental composition (by aqua regia digestion and XRF), acid-base accounting, and short-term leach testing (modified from ASTM D3987 for a 4:1 water to rock ratio). Waste rock monitoring will be concurrent with surface water quality monitoring and each will complement and inform the other. Surface water samples will be submitted for laboratory analysis for metals, anions and salinity, among others, and will provide additional assurance that the waste rock and its leachate have been accurately characterized. These data will also provide information that can be used to design additional mitigation measures if required. At least one surface water monitoring location will be sited immediately downstream of the WRMA in order to characterize the runoff prior to discharge to the stormwater management pond. Samples will be collected quarterly at a minimum throughout the site preparation and construction phase as described in the EA Follow-up Monitoring Program. Depending on the results of the rock monitoring program described above, additional surface water samples may be collected in order to further characterize “first flush” events (spring runoff and the first rainfall after a prolonged dry period). Because of the variability of site conditions (waste rock characteristics and seasonal variations in precipitation and runoff events), the timing and frequency of the sampling will be determined in the field to best observe and understand the characteristics of the WRMA runoff. If the waste rock monitoring program results indicate that the rock leachate varies significantly from predicted characteristics, continuous monitoring at the surface water monitoring location may be implemented. A water quality monitor may be used in the field to measure electrical conductivity (EC) and pH. The EC values can be plotted against rainfall events; changes in EC could be correlated to the laboratory analysis and could potentially be used to identify trends in water quality. The groundwater monitoring program described in the EA Follow-up Monitoring program includes routine (quarterly) sampling from monitoring wells situated in the uppermost aquifer immediately downgradient of the WRMA. This groundwater monitoring, implemented in 2012 to establish baseline and background conditions, would allow the influence of WRMA operation on groundwater quality to be observed, were it to occur. As shown on the surface facility layout in OPG’s presentation to the Technical Information Session on July 18, 2012 (OPG 2012, Slide 11), the waste rock will be segregated at surface into three areas based on the type of rock (dolostones, shales, limestone). The shale and dolostones resulting from the shaft excavations will either be reused onsite or covered within one year of excavation, therefore further segregation is not proposed. Additionally, the rock reused in berms will be covered, providing further means to manage and redirect runoff. The majority of the waste rock will come from the excavation at the repository level. During the first year of underground development, the volume of rock excavated will be relatively small. Monitoring results characterizing the Page 68 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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