Yankovich IAEA RSLS(Oct2011)-Canada Documents...Canadian Nuclear Safety Commission (CNSC) determined...

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Balancing Risk:Some Canadian Perspectives on

Remediation of Legacy Sites

T.L. Yankovich, Saskatchewan Research Council, CANA DA


� JURISDICTION (i.e., provincial and federal)� REGULATORY AGENCY (e.g., Canadian

Nuclear Safety Commission, Environment Canada, Ontario Ministry of Natural Resources, Fisheries and Oceans Canada, etc.)

� TOPIC (e.g., the environment, radiological contaminants, non-radiological contaminants, fisheries, etc.)

Some General Points:

In general, regulations in Canada are developed and enforced by:


Key Regulatory Jurisdictions in Canada:

� Protection of the Environment in Canada falls under provincial jurisdiction (under the Canadian Constitution).

For Example:


Key Regulatory Jurisdictions in Canada:Some Examples

� All aspects of operations and activities pertaining to radiological

substances are regulated at the federal level under the

Canadian Nuclear Safety Commission (CNSC).

� This includes all nuclear facilities in Canada.

� In addition to being regulated federally, some facilities also fall

under provincial jurisdiction (e.g. Canadian CANDU facilities,

which are provincial Crown Corporations in most cases).

� By comparison, Atomic Energy of Canada Limited is a federal

Crown Corporation.

� The jurisdiction under which a given facility falls with respect to

non-radiological contaminants and other topics (e.g. fisheries)

will define the Regulatory Agencies with which the facility

interacts (i.e., to whom the facility reports).

� CNSC regulates the packaging and transport of nuclear

substances in Canada in cooperation with Transport Canada.


The Breakdown:

The Provinces

Regulation in

Canada

� Covers all federal works and

undertakings (e.g., those that

are being undertaken in federal

facilities, such as Federal Crown

Corporations).

� Covers any activity that is

regulated at the federal level

(e.g., all nuclear facilities).

� Includes inter-provincial and

international trans-boundary

issues.

� With the exception of any work

and undertakings pertaining to

radiological substances, the

Province is responsible for all

work and undertakings in

provincial facilities.

The Federal House


Each Regulation and Regulatory Instrument Falls under the Responsibility of a Specific Regulatory Body

The Federal

House

The

Provinces

Regulatory Level

Topic Federal House The Provinces (e.g. Ontario)

Radiological Substances

Canadian Nuclear Safety Commission (CNSC)

not applicable

Water Quality

Environment Canada

Ontario Ministry of Environment (OMOE)

Protection of

Fisheries

Fisheries and Oceans Canada (DFO)

Ontario Ministry of Natural Resources (OMNR)

Protection of

Species at Risk

Environment Canada

OMNR

Etc.

Etc.

Etc.


Taking it a Step Further . . . . .

Therefore, there is a need to ensure

harmonization or coordination between

jurisdictions, which requires producing

guidance at the ‘right’ level of detail.


These include:

� Regulations

� Standards

� Guidelines

� Codes of Practice

� Notices

� And Others.

There are a Number of Regulations and Regulatory Instruments that are Typically Applied Under Each Level

In Canada:

Canadian regulatory standards are not very prescriptive, allowing the licensee to develop and propose a variety of methods of demonstrating compliance for Regulatoryapproval.


Critical to the Development of Regulations and Regulatory Criteria:

In Canada, the development of regulations and regulatory instruments must be done in a transparent, defensible and well-defined manner with Public and Stakeholder consultation.

AND . . . . .


� Establishment of expert working groups.

� Organization of specialized workshops and Public

Stakeholders meetings.

� Invitations of the Public and Stakeholders to comment on

draft regulations and regulatory instruments.

� Peer review and public review.

� Publication of accessible fact sheets and reports

containing technical details supporting regulations and

regulatory instruments.

� Publication of schedules for review and finalization of

draft regulations and regulatory instruments in accessible

publications (e.g. the Canada Gazette, the Ontario

Gazette, the Manitoba Gazette, etc.).

� And other processes.

Examples of Process Transparency:


The Challenge Lies in Balancing Scientific Understanding with the Need to Decide…

… where time-frame matters (!)

For example, if a protection goal is

demonstration of ‘successful’ site

remediation, it can take decades to

understand; however, risk management

and regulatory compliance typically

happens ‘now’ (and people living in an

area want it now).

WHERE . . . . .

‘Don’t keep studying it, just do it.’


Decision-Making InputsTechnical Analysis

(e.g., physical,ecological,

socio-economic,other) Decision

Makingprioritizing

problems andactions, ensuring

effective implementation

EIAEIA

Public Involvement

Other Input(e.g., benefit-cost

analysis,political priorities)

Facts/ Values


In Canada:

� Legacy sites can range from:

o Residential areas requiring remediation (such as in Port Hope, ON) to

o Operating nuclear sites (e.g., Chalk River Laboratories) to

o Abandoned uranium mine/mill sites (e.g., Gunnar and Lorado in northern Saskatchewan)

The question is, can guidance be developed to cover these diverse types of sites, given the

complexity even within a given type of site?


Some Relevant Conceptsand Terminology:

Those sites for which there is no owner, or the owner cannot or will not finance the costs of remediation.

In general, orphaned or abandoned mines can be defined as:

Responsibility for such sites typically ends up with Government

(Provincial or Federal).

There are >10,000 such sites in Canada, including a number of

uranium mine/mill sites in Northern Saskatchewan.

Reference: Tremblay, 2005


SRC is managing the Cleanup of the Gunnar, Lorado and 36 Satellite Mine Sites in Northern Saskatchewan on behalf of the Provincial and Federal Governments under Project CLEANS.

Remediation is scheduled for completion in 2015 with long-term monitoring to follow.


Project Objectives:

1. Eliminate or reduce public safety hazards and environmental risks.

2. Develop options that are technically and economically feasible.

3. Establish a cost-effective environmental monitoring program and minimize long-term care and maintenance at the Site.


Project Endpoints:

� Site does not pose environmental and public healthrisks.

� Flora and fauna adjacent to and within the site are notsignificantly impacted by contaminants.

� Traditional use of resources adjacent to and within thesite are safely conducted.

� The desire is to have the Site managed through theinstitutional controls program for long-term care andmaintenance.

My current focus is the remediationof the Gunnar Mine Site.


Other Possible Remediation ‘Aspirations’:

� Environment is safe for humans and non-human biota;

� Long-term adverse effects are minimized;� Reclaimed landscape is stable and self-sustaining;

and,� Restrictions on future land use are minimized.

(from Pollock and Hiller, 2011)


The History of Gunnar UraniumMine and Mill:

�Operated from 1953-1964�Average grade was 0.18%.� ~8.5 million tons of rock mined and processed�Open pit and underground mine.�Over 5 million tons of unconfined tailings� The pit and subsurface workings were flooded, shaft

plugged with concrete, and mine site abandoned�All buildings, tailings, and waste rock piles were left on site

“as is”.


Key Aspects of the Gunnar Mine Site:Evaluation of Remediation Options through the Environmental Assessment (EA) Process

Dry Tailings

Buildings and Structures

Mine Pit

Waste Rock Piles

Wet Tailings

Under Licence Exemption until April 30, 2013.


A Somewhat Simplistic View:

EnvironmentalAssessment

InstitutionalControl

SiteRemediation

Site Licensing(as dictated byrad inventories)

Monitoring and Follow-up

Adaptive Management


� On July 23, 2010, the Canadian Nuclear Safety Commission (CNSC) determined that the potential risk to the Public associated with historical buildings on the Gunnar Mine Site should be dealt with outside the EA.

� The Order directed that eleven actions and measures be undertaken to secure the Gunnar Mine Site and ensure public safety.

Not All Sites are Comparable/‘Generic’ :Abatement and Demolition Outside the EA


�Development of safe work plans, including:� Occupational Health and Safety Plan� Structural Safety Assessment� Hazardous Substances and Materials

Inventory� Demolition Plan� Waste Management Plan

�Establishment of barriers�Removal of overhead hazards�Abatement and demolition of non-

process buildings (e.g., wooden structures; asbestos abatement)

�Securing the site

Before

After

In the Short Term –Securing the Buildings and Structures on the Gunnar Site


Practicalities: It’s Not Only About Rad

SRC’s Asbestos Expert


In the Short-term, Mitigation of RiskDemolition of the Gunnar Head-frame:


In the Long-term, Implementation of EA OutcomesBasic Remediation Alternatives:

� Mine Pit:�Leave as a water body or dewater?

� Tailings and Waste Rock:�Cover or relocate to mine pit?�Relocate ‘contaminated’ waste rock to

an engineered lined landfill and use “clean” waste rock as cover on tailings?

� Waste Disposal:�Dispose of in the mine

pit or an approved landfill?


� Regardless of whether the mine pit is left as a water body or dewatered, water treatment will be required.

� Benchtop testing is, therefore, underway to test technologies that could be applied to remove uranium, radium-226 and other contaminants from pit and seepage water.

� Toxicity testing is also being done for pre- and post-treatment mine waters.

Gunnar Pit Options:


Tailings Remediation:

� Covering of the tailings with clean local borrow material is being considered.

� Greenhouse and field testing of revegetationtechnologies at the Gunnar Mine Site using local borrow is underway.


Waste Rock Options:

� Leave in place and cover.� Relocate into the dewatered pit.� Relocate into an engineering landfill.� Relocate on the tailings footprint.


Waste Rock Issues:

�Horizontal and vertical heterogeneity.

�Infiltration of contaminants, including radionuclides and chemicals.

�Representation of waste rock contamination throughout the piles using surface radioactivity data.

�Logistics at a remote site.


From IAEA (2005 ):IAEA, 2005. Plan of activities on the radiation protection of the environment. AP-24.08.2005.

Project/ActivityFeasibility Study

Statement of Intentby the Proponent

AbandonProject

Guidelines for EIA forRegulatory Authorities

Project/Activity SCOPING:Determine EIA Coverage

BASELINE STUDY:Describe the Environment

DESCRIBE the Project

IDENTIFY Impacts

EVALUATION Impacts

Prepare Draft EIS

Preventative Measures

MITIGATION

Final EIS Report

Consideration of All Phasesof the Project/Activity:

•Exploration•Development•Construction•Mining•Remediation•Decommissioning•Post-decommissioning

Mon

itor

and

Rev

iew

Pub

lic C

onsu

ltatio

n an

d C

omm

unic

atio

n / S

ocio

-eco

nom

ic Is

sues

Significant Adverse Effect

NotEconomically

Viable

Project/ActivityFeasibility Study

Statement of Intentby the Proponent

AbandonProject

Guidelines for EIA forRegulatory Authorities

Project/Activity SCOPING:Determine EIA Coverage

BASELINE STUDY:Describe the Environment

DESCRIBE the Project

IDENTIFY Impacts

EVALUATION Impacts

Prepare Draft EIS

Preventative Measures

MITIGATION

Final EIS Report

Consideration of All Phasesof the Project/Activity:

•Exploration•Development•Construction•Mining•Remediation•Decommissioning•Post-decommissioning

Mon

itor

and

Rev

iew

Pub

lic C

onsu

ltatio

n an

d C

omm

unic

atio

n / S

ocio

-eco

nom

ic Is

sues

Significant Adverse Effect

NotEconomically

Viable


From UNEP ( 1992):Environmental impact assessment training resource manual, Division of Technology, Industry and Economics.


Social Health (SIA)(socio-economic, ethical, cultural, etc.)

EcologicalHealth(ERA)

Human Health(HHRA)

Interactions(Risk

Management)

Project

InteractionsEvaluate the significance of residual

environmental effects

Environment(humans + non-human species)



Human Health(HHRA)

Interactions(Risk

Management)



Human Health(HHRA)



Human Health(HHRA)

Interactions(Risk

Management)

Project

InteractionsEvaluate the significance of residual

environmental effects

Environment(humans + non-human species)

But at what point do we have ‘adequate’ information to determine a path-forward and how do we judge when remediation is ‘complete’?

� Depends of what is considered

‘significant’ (e.g., relative to baseline,

relative to impact, etc.)

� Effort should be commensurate with risk

(e.g., in terms of monitoring requirements

to assess trending over time)

� It is important to deal with the source(s).

� It is important to minimize the footprint.

� Where possible, progressive

decommissioning should be undertaken.

� It is important to avoid perpetual

monitoring.

� ‘Completeness’ of remediation depends

on the desired end-state of the Site.


Inputs via:

• Historic streambed• Historic drill holes• Surface streams• Catchment 3• Infiltration

Outputs via:

• Seepages

Characterization of the Waste Rock itself


Conceptual Model of Licensing Packages for CLEANS Sites


Benchmarking against Remediation of AREVA’s Cluff Lake Site


A Few Thoughts on Licensing:

� ‘SMART’ licensing is all about traceability and documentation (Specific, Measurable, Achievable, Realistic and Time Framed)

� Such an approach is in everyone’s good interest, as the status of remediation efforts is demonstrable and sites (or parts of sites) can achieve institutional control sooner.

� An envelope approach can help with proactive management and prioritization.


� The rate of release can be smaller at abandoned sites

due to the lack of operational process (and in such

cases, monitoring may be done less frequently).

� Care must be taken during remediation of abandoned

sites, especially if remote, since there is no active

process to address impacts created (e.g., if

contaminated water is generated, it cannot be run

through the mill to reprocess).

� In general, focus should be placed on changes in

environmental quality over time at monitoring locations

following remediation, as opposed to comparing with

regional values (as long as ‘external factors’, such as

climate change, can be accounted for).

Operating Sites ≠ Abandoned Sites:


Thank You!

Any Questions?For more info – www.saskcleans.ca

Yankovich IAEA RSLS(Oct2011)-Canada Documents...Canadian Nuclear Safety Commission (CNSC) determined...

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