Submission of Lake Ontario Waterkeeper - Reviewing Canadian Nuclear Safety Commission (CNSC) staff’s status report on Canadian Nuclear Laboratories Limited’s (CNL) Port Hope Area Initiative (PHAI), and participating in the Commission Meeting process

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Submissions of Lake Ontario Waterkeeper
Re: Reviewing Canadian Nuclear Safety
Commission (CNSC) staff’s status report on
Canadian Nuclear Laboratories Limited’s (CNL) Port
Hope Area Initiative (PHAI), and participating in the
Commission Meeting process.
Notice of Public Meeting, Ref. 2016-M-01
October 3, 2016
Submitted to:
Participant Funding Program Administrators cnsc.pfp.ccsn@canada.ca
and the CNSC Secretariat cnsc.interventions.ccsn@canada.ca
Cc: Julia Szymanski julia.szymanski@canada.ca, and Adam Levine
adam.levine@canada.ca

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TABLE OF CONTENTS
Executive Summary …………………………………………………………………………………… 3
Background ………………………………………………………………………………………..…… 5
• About Lake Ontario Waterkeeper ……………………………………………………………. 5
• About the PHAI ………………………………………………………………………………… 5
• A visit to the PHAI sites while preparing these submissions ……………………………… 7
Water quality concerns in Lake Ontario.…………………………………………………………… 8
Water Effluent concerns and the PHAI project ………………………………………. ……….… 9
Interjurisdictional cooperation and the PHAI …………………………………………………… 12
• The MOECC’s involvement with the PHAI ………………………………………………… 12
The PHAI’s Public Information Program …………………………………………………………. 14
Conclusion …………………………………………………………………………………………….. 16
Appendix I: Independent Review of Hydrological Issues Pertaining to the Review of the CNSC Staff
Status Report on CNL’s Port Hope Area Initiative, Wilf Ruland, P. Geo, October 3, 2016
Appendix II: Wilf Ruland, P. Geo CV
Appendix III: Pippa Feinstein, JD CV
Appendix IV: Compiled Questions and Answers between Mr. Ruland, Ms. Feinstein and PHAI staff
Appendix V: Meeting notes from Site Visit, September 23, 2016

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EXECUTIVE SUMMARY
The Port Hope Area Initiative (PHAI) is an internationally significant undertaking. It is the biggest
radioactive waste clean-up project in Canadian history, and involves one of the largest nuclear
waste holding facilities in North America.
The PHAI is comprised of two distinct projects: the Port Hope waste relocation project (“Port
Hope Project”), and the Port Granby waste relocation project (“Port Granby Project”). Together,
both projects seek to clean up a combined two-million cubic metres (m3
) of low-level radioactive
waste from various sites across Port Hope and Port Granby.
The Port Hope Project involves excavating 1,223,250 m3
of historic radioactive waste from
several sites around the town of Port Hope to a Long-term Waste Management Facility (PH
LTWMF) just north of the community. The project was subject to an environmental assessment
(EA) under the Canadian Environmental Assessment Act, 1992 (CEAA, 1992) which was
conducted from 2001 to 2007. In 2009, the CNSC granted a five-year Nuclear Waste Substance
Licence to Atomic Energy Canada Limited (AECL) to implement the project. In 2012, AECL
applied to have its licence extended for ten years. This was granted by the Canadian Nuclear
Safety Commission (CNSC), making the current licence valid until December 31, 2022.
The Port Granby Project involves the removal of 450,000 m3
of historic radioactive waste from
the existing and poorly contained Port Granby waste management facility to a new above-
ground waste management facility (the PG LTWMF) 700 metres north of the Lake Ontario
shoreline. The Port Granby Project was also subject to a federal EA under CEAA, 1992 and the
project was approved in 2009. After a public hearing in September 2010, the CNSC granted
AECL a ten-year licence to implement this project.
Both Port Granby and Port Hope’s new LTWMFs have their own Waste Water Treatment Plants
(WWTPs) to treat the sites’ stormwater and leachate before it is released into Lake Ontario.
AECL/CNL’s licences for both projects authorize it to:
• Develop and construct new long-term waste facilities;
• Remediate historic waste sites;
• Transport waste to its facilities; and
• Conduct long-term maintenance and monitoring of its waste sites.
Lake Ontario Waterkeeper (Waterkeeper) has been involved with decision-making processes for
the PHAI for almost a decade. The organization has also enjoyed long-standing relationships
with many Port Hope residents since its founding in 2001. Waterkeeper is very aware of the
beauty of the Port Hope and Port Granby areas: their preserved historical town buildings and
houses; their active aquatic communities along the lake’s shoreline, the Ganaraska River, and
local creeks; their local beaches; and their stunning cycling and walking trails.
Waterkeeper is sensitive to issues involving environmental concerns over the nuclear waste
contamination throughout Port Hope and Port Granby, as well as the social stigma that has
accompanied these concerns. Waterkeeper is committed to assisting the local community and
PHAI project management to carry out the initiative in a transparent, cooperative, and effective
way. Waterkeeper is also dedicated to ensuring PHAI facilities and operations are held to a high

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standard, so that the legacy waste in the community is removed responsibly and stored and
treated well.
Waterkeeper was provided with participant funding in order to be able to intervene in this matter
before the CNSC and has retained two experts to examine the PHAI and make recommendations
for its improvement:
• Wilf Ruland, P. Geo, an experienced Hydrogeologist who examined the potential
impacts of the PHAI activities and facilities on local surface water. He examined and
made recommendations concerning the LTWMF and WWTP plans for both Port Hope
and Port Granby projects as well as environmental monitoring for the PHAI and relevant
environmental release limits.
• Pippa Feinstein, JD, counsel and case manager for Waterkeeper who examined and
made recommendations concerning interjurisdictional regulation of the PHAI and the
quality of the PHAI’s Public Information Program (PIP).
Overall, both Mr. Ruland and Ms. Feinstein were impressed with the work that has been
undertaken on the PHAI to date. The design of the LTWMFs and WWTPs are state of the art,
and the technology being used to implement the initiative is very impressive. Similarly, the PHAI’s
efforts to engage the community and share information about its work have been extensive.
At the same time, there is room for improvement. The following is a summary of Waterkeeper’s
recommendations for improvements to the PHAI. Each will be discussed in greater detail and
with more context in the remainder of these submissions below. A more detailed and
comprehensive list of recommendations can also be found in the conclusion of these
submissions.
1. The LTWMFs and WWTPs should have more comprehensive, explicit, and
enforceable effluent release limits. Additions of effluent release limits for Uranium and
other contaminants of primary concern (COPC) should be added to the existing CNSC
licenses for these facilities, and design objectives for facilities should be adopted as
licence limits;
2. Monitoring plans for the LTWMFs and WWTPs should be extended to cover a longer
period of time. Because the environmental threats of radioactive contamination remain
for centuries, a longer monitoring regime for the LTWMFs and WWTPs is required than
what is currently specified;
3. Better inter-jurisdictional cooperation between the federal and Ontario
governments is still required. While the federal government has taken on a leadership
role in the PHAI, the Ministry of Environment and Climate Change (MOECC) must still
ensure non-radioactive contaminants falling under provincial jurisdiction are meeting
provincial standards;
4. The PHAI’s PIP should be strengthened by including more data sharing with the
public. Results of environmental sampling should be made public and the PHAI should
notify the public of any reportable release events.

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Background
About Lake Ontario Waterkeeper
Waterkeeper is a grassroots environmental organization that uses research, education, and legal
tools to protect and restore the public’s right to swim, drink, and fish in Lake Ontario. Founded
in 2001, Waterkeeper is a non- political registered charity focusing on environmental research
and justice issues in the public interest. It is dedicated to protecting and celebrating the Lake
Ontario watershed, including the wetlands, streams, rivers, and creeks that flow into the lake.
Waterkeeper also works with communities to facilitate the use of environmental laws to protect
their rights to swim, drink, and fish. The organization participates in legal processes to help
ensure that environmental decisions are made on the basis of sound and tested scientific
evidence by independent decision-makers and in the public interest. Waterkeeper is
participating in the current PHAI Update meeting process to ensure the Commission considers
the public’s need for a swimmable, drinkable, fishable Lake Ontario when examining CNSC
staff’s update report.
About the PHAI
The PHAI is comprised of the Port Hope Project and the Port Granby Project. Waterkeeper has
been studying each project, and has been involved in several decision-making processes for
them before the CNSC and MOECC for almost a decade. Each project is discussed below, in
addition to Waterkeeper’s past involvement and concerns.
The Port Hope Project involves the remediation of large volumes of low-level radioactive waste
from a variety of locations throughout the municipality, including:
• 450,000 m3
of waste from the existing Welcome Waste Management Facility;  
• 572,000 m3
of waste from Port Hope’s harbour, the Highland Drive Municipal Landfill,
and residential properties;  
• 150,000 m3
of legacy waste from the Cameco Port Hope Conversion Facility (PHCF) as
well as waste from building demolition associated with Cameco’s Vision in Motion
project; and  
• 51,250 m3
of waste from contaminated industrial waste sites including the Port Hope
Centre Pier, Lions Park, and the municipal sewage treatment plant.
Much of this legacy waste was a product of the ore refining activity undertaken in Port Hope
which began in the 1930s. Water from the harbour and lakes was used by the new refining
facilities to extract radium from the ore brought down from Deloro’s northern mine. At that time,
there wasn’t a proper understanding of the harm these activities, or the waste they produced,
could have on the health of locals and the environment. Unfortunately, radioactive waste and
byproducts from the refining process were spread over the town in several smaller landfills, or
else salvaged as building materials in residents’ homes.
By the 1970s, this legacy waste was considered a significant problem, and from 1976 to 1980,
the federal government assisted with an effort to clean up legacy waste sites. That initiative
removed approximately 100,000 m3
of waste, although it led to the discovery of significantly
more waste in need of excavation and treatment. A task force was subsequently instituted to

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find a home for this waste. After a survey of many other communities across the country, none
of which were ultimately prepared to accept the waste, Port Hope and Port Granby began plans
to hold and manage the waste in their home communities. By this time, the Port Granby waste
site had already become a source of concern as it was seeping significant amounts of
contaminated effluent into the lake. Being so close to the shoreline which was quickly eroding,
the containment of radioactive waste at that site was becoming increasingly more precarious
with time.1
As early as 2001, Waterkeeper studied and expressed concern about the lack of containment at
the old Port Granby waste facility. The organization prepared a report discussing the sources of
contamination at the site, as well as their environmental effects. Importantly, Waterkeeper at this
time was also concerned about the apparent lack involvement by the then Ministry of
Environment (MOE) in addressing the environmental damage caused by the poorly contained
Port Granby waste site.2
Also in 2001, Port Hope, Port Granby and the federal government signed an agreement to initiate
the PHAI and store legacy waste in a more contained and safe way in both communities.
Several years later, when plans for the PHAI were developed and the EA was completed,
Waterkeeper intervened in the 2009 licence hearing for the Port Hope Project. At that hearing it
submitted the following:
• That CNSC staff’s proposed criteria for permissible effluent discharges were
inappropriate, as some values were hundreds of times above the Provincial Water Quality
Objectives (PWQOs);
• That the MOE must exercise its jurisdiction over provincially-regulated contaminants at
the LTWMF;
• That limits on effluent should be explicitly delineated as licence requirements in the CNSC
licence itself;
• That both federal and provincial agencies had jurisdiction over radioactive and non-
radioactive waste respectively, and that better coordination between federal and
provincial authorities on this issue was required;
• That the project should have had more explicit and documented financial guarantees and
a Preliminary Decommissioning Plan at the time of the licence hearing. Neither had been
addressed in AECL’s application; and
• That AECL did not release objective information or data to the public about its project.
Instead it provided “subjective, inaccurate, inaccessible, opaque, and broad messaging
about its activities”.3
In 2012, when AECL applied to extend its licence for another ten years, Waterkeeper argued the
following:
• That there was a significant lack of procedural, technical, and policy advice in planning
for the project;

1
1977 Environmental Impact Study (EIS) for Port Granby, conducted by Eldorado Nuclear Limited pursuant to the
Environmental Assessment Review Process Act (EARPA).
2
Lake Ontario Waterkeeper, A Study of Leaks at the Port Granby Low-Level Waste Management Facility, 2001.
3
Lake Ontario Waterkeeper, Review of the Environmental Assessment and licence application for the Port Hope Long-Term
Low-Level Radioactive Waste Management Project, 2009.

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• That the project’s wastewater standards continued to be extremely lax, far exceeding
other government standards. While the CNSC noted the standards would be temporary,
and re-evaluated once AECL constructed a new wastewater facility, Waterkeeper argued
that revised regulatory standards should be set before the construction of a new system.
Waterkeeper also requested that the process for setting these standards be subject to
meaningful public participation (either via an EA or Environmental Bill of Rights (EBR)
hearing);
• That the CNSC and MOE were still not collaborating or consulting one another about the
regulation of nuclear and non-nuclear industrial waste requiring disposal; and
• That AECL’s approach to public consultation was very poor. Waterkeeper requested a
more robust public engagement strategy from the company.4
Of these concerns, some have been addressed by the PHAI, and others persist. Since
Waterkeeper’s comments in 2012, the CNSC has created a Jurisdictional Regulatory Group
(JRG) in which the Commission ensures it communicates with the MOECC at least semi-
annually, providing project updates to two regional offices. Furthermore, the PHAI’s approach to
public engagement has increased with its Public Information Exchange (PIE) resource centre,
active community outreach program, and an easy-to-navigate website. Its WWTPs are also state
of the art, providing reverse osmosis treatment to effluent water they will receive, which will
significantly mitigate any adverse impacts of the release of treated water into Lake Ontario.
However, more work is required. More comprehensive effluent limits still need to be better
delineated in CNSC licences, and amounts should conform to all applicable laws and guidelines.
Furthermore, it will be important for the PHAI to release actual sampling results from its
environmental monitoring programs to ensure that the PHAI public messaging about the safety
of the projects can be supported by proper scientific evidence. Finally, the MOECC should be
more involved in the project than is currently the case. While it is a step in the right direction to
have established the JRG, the MOECC must also be more hands-on in efforts to ensure the PHAI
projects meet Ontario’s environmental laws and guidelines.
A visit to the PHAI sites while preparing these submissions
On September 23, 2016, Wilf Ruland and Pippa Feinstein met with Sarah Anderson, Glenn Case,
and Pierre LeBel at the PHAI Management Office in Port Hope for a site visit and to discuss
potential issues of concern for Waterkeeper. The meeting lasted three hours and involved a tour
of the Port Hope and Port Granby LTWMF construction areas, as well as the Highland Drive site
and the Port Hope Harbour.
Information obtained during this meeting has been used to help inform these submissions, and
notes from the meeting have been included as Appendix V to this submission.

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Lake Ontario Waterkeeper, Intervention before the CNSC concerning AECL”s application to remove the hold points and to
amend the expiry date of Waste Nuclear Substance Licence for the Port Hope Long-Term Low-Level Radioactive Waste
Management Project, 2012.

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Water quality concerns in Lake Ontario
When considering the environmental impacts of the PHAI and measuring its success, it is
imperative to do so with a view to its historical and environmental context.
Despite many human stressors, the Lake Ontario watershed remains resilient and continues to
support diverse ecosystems. Lake Ontario’s archipelagos, beaches, bays, tributaries, islands
and wetlands provide many opportunities for swimming, canoeing, fishing, nature observation
and other forms of recreation. Lake Ontario also provides drinking water to over 9-million
Americans and Canadians
Along the shoreline of Lake Ontario in the Port Hope area, alewife, rainbow smelt, threespine
stickleback, and lake whitefish spawn. The Ganaraska River has resident populations of brown
trout, brook trout, rainbow trout, and walleye. Northern pike and lake whitefish also spawn in the
river which provides nursery habitat for these species. The Ganaraska River, is a “key producer”
spawning site for wild chinook salmon and coho salmon.5
During Ms. Feinstein and Mr. Ruland’s
site visit on September 23rd
, over 70 people were lined up on either side of the Ganaraska
watching one of the semi-annual salmon spawning runs.
The Port Hope Harbour also provides sheltered warmer water for a modest aquatic community.
Smallmouth bass, yellow perch, and spottail shiner all enjoy habitat in the harbour. The Harbour
also hosted the marina of the Port Hope Yacht Club for 50 years before the club stopped
operating earlier this year.
The West Beach, located just west of Port Hope’s harbour and the PHCF, provides important
recreational space along the lakeshore. In summer, it is filled with wildflowers just above its
pebble beach, and the beach includes a small park with a play area for children.
The waterfront trail running along between Port Hope and Port Granby also sees lots of traffic,
particularly on the weekends as many cyclists and joggers enjoy the scenic path.
At the same time, the area around Port Hope has been designated by the federal government
under the Great Lakes Water Quality Agreement as an Area of Concern “because a review of
available data indicated that water quality and environmental health were severely degraded”.6
The focus of the remediation efforts has been on Port Hope’s harbour. The AoC’s most recent
Status of Beneficial Use Impairments from 2010 stresses the importance of PHAI efforts to
remediate local waterbodies.
Ultimately, while the north shore of the lake is resilient, it is still fragile. All development and
activity that could affect the water quality of the lake must be pursued in sensitive ways that
mitigate any adverse impact to the greatest extent possible. While cleaning up areas of
contamination is important for the long-term health of this part of our lake, cleanup activities will
still be disruptive. The discussion below includes a description of the PHAI’s impacts on local
water quality and offers recommendations for how these impacts may be further mitigated.

5
Appendix E, the Environmental Assessment Report for Cameco’s Port Hope Conversion Facility Relicensing
Application, CNSC Staff CMD 16-H8 at p21.
6
“Port Hope Area of Concern”, Environment and Climate Change Canada, online: www.ec.gc.ca.

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Water Effluent Concerns and the PHAI Project
Mr. Ruland has explained in his review of the PHAI that the new LTWMFs are very secure and
that the new WWTPs are state of the art. He notes that efforts to remove waste from
contaminated sites across Port Hope and the older Welcome and Port Granby low-level
radioactive waste facilities will result in the immediate and permanent improvement of
groundwater and surface water quality in those locations. He also finds the Clean-up Criteria for
the remediation of these older waste facilities to be adequate and appropriate.
Mr. Ruland explains that the areas that require more CNSC attention concern the establishment
of effluent limits on the WWTPs, and the monitoring plans for the facilities during their operations
and post-closure. With regards to effluent limits, Mr. Ruland recommends the following:
That the site licenses for the older Port Granby and Welcome waste management facilities
be immediately amended to include an Effluent Discharge Level of 0.15 mg/L for Uranium.
Currently, neither the older Port Granby Waste Management Facility nor the Welcome Waste
Management Facility’s CNSC licenses include any limit on Uranium effluent at all. The Port
Granby Waste Management Facility’s only liquid effluent limit was Radium-226 (at 0.37bq/L) and
the Welcome Waste Management Facility’s only liquid effluent limits were for Radium-226 (also
at 0.37bq/L) and Arsenic (at 0.5mg/L).
Mr. Ruland explains that Uranium is a “key indicator” of low-level radioactive waste and a
surrogate for the presence of many other potentially harmful contaminants. He asserts the lack
of Uranium liquid effluent release limits is neither proactive nor precautionary.7
As such he
recommends that Uranium discharge limits be immediately included in both facilities’ licenses.
He believes an effluent discharge limit of 0.15 mg/L to be sufficient.
The design objectives for both the new Port Hope WWTP and Port Granby WWTP should
be made licence conditions for those facilities.
Mr. Ruland has found that the current design objectives for the WWTP in The Port Granby
Environmental Management Plan are adequate. Further, given the monitoring results from the
Port Granby WWTP (which began operating this past April), the WWTPs should easily be able to
operate well below these design objectives.

7 Independent Review of Hydrological Issues Pertaining to the Review of the CNSC Staff Status Report on CNL’s
Port Hope Area Initiative, Wilf Ruland, P. Geo, October 3, 2016, p 7 (the “Ruland Report”).

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Design Objectives are not in and of themselves effluent limits. However, including these design
objectives as licence conditions for both the Port Hope and Port Granby WWTPs will make them
legally enforceable effluent release limits. If a CNSC regulated facility is found to contravene its
licence conditions, it can be subject to disciplinary action such as fines (“Administrative
Monetary Penalties”), temporary licence suspension, revocation, or prosecution.8
Action Levels for the Port Hope and Port Granby WWTPs should be set within 12 months
of the commencement of these facilities’ operation.
Mr. Ruland agrees that the proposal to set Action Levels once 12 months worth of each WWTPs’
monitoring data is available, is reasonable.
Mr. Ruland stresses that these Action Levels should be significantly lower than the WWTPs’
effluent release limits. He also recommends that established Action Levels cover all the
parameters listed in Table D-3 produced above. Mr. Ruland explains that this list is sufficiently
comprehensive to protect the local environment and Lake Ontario. Especially important is the
fact that it contains all the identified Contaminants of Potential Concern (COPCs) for both
WWTPs: Arsenic, Cobalt, Radium-226, and Uranium.
Heavy metals to be monitored downstream from the Port Granby LTWMF should be
explicitly delineated and more comprehensive.
Currently, the parameter list for the proposed downstream aquatic environment water quality
monitoring program at Port Granby’s WWTP ensures that “heavy metals” will be tested for
without specifying which metals this term actually includes. An explicit list should be developed.

8
Canadian Nuclear Safety Commission, “The CNSC’s approach to compliance verification and enforcement”, online:
http://nuclearsafety.gc.ca/.

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Mr. Ruland recommends that this list be at least as comprehensive as the the parameters listed
in Table D-3 pf Port Granby’s EMP provided above.
Furthermore, Mr. Ruland raises concern over the fact that no regulatory levels for downstream
monitoring have been established except for Uranium. As such, Mr. Ruland recommends that
Control Levels and Action Levels be set for the three other Port Granby COCs: Arsenic, Radium-
226 and Cobalt.
Regulatory Levels for the Port Hope Environmental Management Plan must be clarified.
The Port Hope EMP requires further information and direction concerning the specifics of its
proposed monitoring program for downstream aquatic environment quality. Mr. Ruland found
the descriptions of the program in section 5.1 of the EMP to be “rambling and unfocussed”.9
The Port Hope WWTP effluent monitoring program should be more comprehensive.
Mr. Ruland could not find a parameter list for effluent monitoring at the WWTP. Further, the only
proposed licence limits and Action Levels for the facility concerned Arsenic and Radium-226.
Mr. Ruland recommends that Effluent Release Limits corresponding to the Design Objectives in
the License Conditions Handbook should be imposed on the Port Hope WWTP.
Surface water monitoring downstream from the Port Hope LTWMF should be explicitly
delineated and more comprehensive
Mr. Ruland found the Port Hope downstream surface water quality monitoring program didn’t
include a parameter list. He recommends that at a minimum, it should include all the parameters
included in the design objectives table in the Port Hope Licence Conditions Handbook.
The Control Levels and Action Levels for Uranium proposed in the Port Granby EMP should
be adopted in the Port Hope EMP
Currently, the Port Hope EMP is lacking any specific values for its Control Levels or Action Levels
for Uranium. As such, Mr. Ruland recommends that the existing Uranium Control Level proposed
in the Port Granby EMP of 0.0016 mg/L and the proposed Action Level of 0.012 mg/L be applied
to the Port Hope EMP.
Mr. Ruland also recommends that in addition to adopting these Action Levels and Control Levels
for Uranium, the CNSC should develop suitable Control Levels and Action Levels for the two
other COPCs; Arsenic and Radium-226.
Downstream water quality monitoring in Lake Ontario at the effluent release points for the
Port Granby and Port Hope WWTPs should continue as long as the facilities are operating.
Mr. Ruland noted he is very impressed by the design of both the Port Hope and Port Granby
LTWMFs and their respective WWTPs. At the same time, he cautions that there may still be the
possibility that unforeseen problems may arise. Continuous and comprehensive effluent
monitoring can alert the PHAI staff of any problems which may otherwise go unnoticed. As

9
Ruland Report, p10.

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such regular monitoring can help prevent environmentally harmful releases and must thus
continue as long as the facilities are active.
There should be a longer-term monitoring plan for the facility after the WWTPs close.
Mr. Ruland recommends that downstream surface water monitoring in nearby creeks to the Port
Granby and Port Hope LTWMFs should continue at quarterly intervals for a minimum of five years
after the facilities close. After this time, the creeks should still be monitored semi-annually for 20
years, and annually for an additional 25 years. By this 50-year mark, Mr. Ruland recommends
that periodic checks should be made every five years to confirm the integrity of the LTWMF’s
covers, and the water quality in nearby streams. These five-year periodic inspections of the
LTWMF tops and nearby creeks should continue for 500 years.
The PHAI must include a plan for managing contaminated water in the harbour during PHAI
and VIM dredging and excavation activity.
When the PHAI and Cameco’s Vision in Motion project begin their planned dredging and
excavating activities in and around the harbour, the harbour water will become especially
contaminated. The harbour mouth will be closed to the lake during these remediation activities
so as to prevent aquatic species’ contact with the released contamination. However, as the
harbour remains closed over this time, inflows of rainwater, groundwater and stormwater will
increase the volume of contaminated water. The PHAI and VIM need to create a plan to manage
this significant amount of contaminated water.
A plan is needed to address how contaminated harbour water will be treated and managed
once dredging and excavation work ceases and the harbour mouth is opened again.
Mr. Ruland highlights how important it will be for the PHAI and VIM project to monitor the impact
of contaminated harbour water on local lake water quality. He recommends that monitoring of
lake water beyond the mouth of the harbour occur at least monthly and after any rain events of
more than 50mm.
Interjurisdictional Cooperation and the PHAI
The Ontario Ministry of Environment and Climate Change’s involvement with the PHAI
Waterkeeper still finds the absence of Ontario involvement in the PHAI troubling. In its
explanation of the Port Hope Area of Concern, the federal Ministry of the Environment and
Climate Change explains “Undertaking environmental restoration requires a large amount of
scientific and technical expertise, local knowledge and hard work. One agency or group cannot
engage in such a large task on their own without the help of others”. The Ministry then lists the
participants that contribute to these PHAI efforts: Natural Resources Canada, Atomic Energy of
Canada Limited, Public Works and Government Services Canada, the Municipality of Port Hope,
and the Municipality of Clarington.10
The MOECC is also excluded from the federal-municipal
agreement establishing the PHAI and its terms of reference.

10
Environment and Climate Change Canada, “Port Hope Area of Concern”, online: www.ec.gc.ca.

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Waterkeeper has wanted the province to play a more significant role in the PHAI since 2001.
After raising this issue with the province at that time, Waterkeeper’s files include an MOE letter
in which it explains that since the federal government was involved in addressing Port Granby’s
and Port Hope’s waste, the MOE would not also be involved in its licensing process, nor would
it conduct a complimentary environmental assessment for the PHAI.11
The 2005 draft of the PHAI EA study report confirmed that the MOE would not undertake a
complimentary EA. Rather, the Ministry committed to preparing comments concerning the
federal EA once that review was completed. That being said, the MOE “expected that
implementation [of the PHAI projects] will consider provincial legislative codes, and guidelines
with regards to discharges and management of non-radiological waste”.12
Importantly, the
PHAI’s own EA report confirmed that even if the province was not leading this initiative, the
provincial Environmental Bill of Rights (EBR), Environmental Protection Act (EPA), Ontario Water
Resources Act (ODRA), and the Sustainable Development Act (SDA) were all applicable to the
PHAI.13
During the 2007 hearing before the CNSC, submissions from CNSC staff on the EA for the Port
Hope Project confirmed provincial regulations were applicable to the project, citing the Provincial
Water Quality Objectives and sediment guidelines.14
In 2013, the CNSC established a Jurisdictional Regulatory Group (JRG) including both the CNSC
and Peterborough and Pickering offices of the MOECC. Meetings between these authorities has
since been convened by the CNSC twice a year and has mainly involved one-way
communication from the CNSC to the MOECC. This is done mainly by providing PHAI progress
updates to MOECC officers.
During the September 23, 2016 site visit, PHAI staff confirmed that ECAs were required for
municipal landfill sites and temporary generator systems, but that they were not required for the
LTWMFs or WWTPs, due to the involvement of federal authorities. However, if the EPA and
ODRA are applicable to the PHAI, it is unclear exactly why the WWTPs and LTWMFs would be
automatically exempt from having to obtain ECAs for their activities. According to both Acts,
ECAs are required for facilities that release pollutants into the water, or stores waste. Further,
certain non-radioactive contaminants stored at the LTWMFs and treated at the WWTPs are
provincially regulated substances. Other elements of the PHAI such as the remediation of the
Highland Drive landfill and the stockpiling of municipal waste during that process would require
MOECC oversight and amendments to the landfill’s existing ECA.
Waterkeeper recommends that space be made for the MOECC to meaningfully provide
regulatory oversight to aspects of the PHAI with which it shares jurisdiction with the federal
government. If it determines that separate ECAs are not required for the WWTPs and LTWMFs,
it should at least be able to participate in processes that set regulatory effluent limits and Action
Levels for the facilities so that it can ensure the PHAI facilities adhere to provincial environmental
laws and regulations. The PHAI should also share its raw environmental monitoring data results

11
Communications with the MOE Concerning the Federal Environmental Assessment for the Port Hope Area Remediation,
2001.
12
PHAI Draft Environmental Assessment Study Report, 2005 at p7-67.
13
Ibid p7-69.
14
CNSC hearing 2007 at p 85.

14
with the local MOECC offices so that their officers can verify the facilities’ compliance with
provincial standards.
The PHAI’s Public Information Program
A Public Information Program (PIP) for the PHAI is required by section 3(j) of the Nuclear Safety
Control Act. This section states the purpose of a PIP is to “inform persons living in the vicinity of
the site of the general nature and characteristics of the anticipated effects on the environment
and the health and safety of persons that may result from the activity to be licensed”.15
The
“primary goal of PIP is to ensure: 1) the health, safety and security of persons and environment
is effectively communicated, and 2) a commitment to and protocol for ongoing timely
information”.16
The objectives of the PHAI’s Public Information Program are to:
• Provide the public and other stakeholders with effective access to timely information in
order to prepare them for upcoming work and help them understand project activities,
programs, timing, environmental protection and mitigation measures, long-term benefits
and economic opportunities.  
• Build and maintain active support for and confidence in the PHAI with the public and all
levels of political leadership in the host communities by ensuring that stakeholders are
fully briefed on the background, goals and current developments of the projects.  
• Position the PHAI Management Office as the primary source for accurate project
information to reduce the potential for externally generated project delays that may result
from misinformation and misconceptions.  
• Provide open and transparent public disclosure about unplanned project activities and
events, proportionate with the public’s perception of risk and the level of public interest
in the PHAI’s activities.17
 
The PHAI’s information-sharing methods include the Project Information Exchange (PIE). The
PIE is housed in the foyer of the PHAI management office. It contains to scale models of what
the Port Hope and Port Granby LTWMFs will both look like once completed. It also contains
several bookshelves of information about the two projects for members of the public to take and
learn from. Resources range from one-page explanations of radiological testing and where and
when this will happen in the community, to larger maps and plans for PHAI excavations, to
several hundred-page reports about the PHAI’s EAs and commissioned public attitude surveys.
Other information-sharing methods include and online communications, newsletters, after-hours
telephone access, presentations, site tours, public information sessions, media relations,
participation in external events, key stakeholder liaisons.
Postcards with information about the PHAI are given to local businesses, the PHAI hosts school
trips, and goes to community events to share information about the initiative with local residents.
There are also Citizen Liaison Groups in Port Hope and Port Granby that seek to increase the
transparency of the project. These Committees determine their own action goals and discussion
topics at the start of each year. Recent goals/topics have included: environmental monitoring;

15
Public Information and Disclosure, RG/GD 99.3 at 1.3.
16
Ibid at 2.1
17
Canadian Nuclear Laboratories, PHAI Phase 2 Public Information Program, section 3.

15
communication plans between the PHAI and the pubic; compliance with regulations;
explanations of major project sites; and property values in the community. Meetings of these
Committees include roundtable discussions and ‘feature’ (i.e. more directed) discussions with
relevant experts. The Committees meet quarterly.
From this review, PHAI’s PIP appears to be quite robust and its information is being made very
accessible. One important aspect that is missing from the PIP is any significant data-sharing
component. There is also some lack of clarity about about exactly what kinds of environmental
incidents must be reported on the PHAI website.
All reportable incidents pursuant to CNSC and MOECC laws and regulations should be
reported to the PHAI website within four days of their occurrence or discovery.
The PIP’s Public Disclosure Protocol (PDP) notes, “The PHAI Management Office is committed
to providing open and transparent public disclosure about unplanned project activities such as:
• Events that have off-site effects or could result in public interest and concern and/or
media attention  
• Serious vehicle or industrial accidents  
• Operational developments that result in significant changes to facility design or operation
or to  project schedule  
• Natural events such as floods that have an impact on project activities.18
 
There is a clear and visible tab on the PHAI website’s homepage that reads “Public Disclosures”.
The tab leads to a webpage for PHAI to report incidents. One incident from April 21, 2016 is
already reported: it involved a small quantity of untreated ground/surface water being discharged
when a pipe was broken during the construction of the Port Granby LTWMF.
Waterkeeper commends the PHAI for its work and considerable community engagement. The
organization also understands that proactive information disclosure is one of the top issues
Citizen Liaison Groups are interested in discussing more in the coming years. In order to assist
these groups and the PHAI in this endeavor, Waterkeeper recommends that the PDP be
amended to confirm that all reportable incidents to the CNSC and MOECC be uploaded onto its
website.
Waterkeeper also recommends that all incident reports include: an online posting date, the date
of the accident (or estimated date), and estimated or known quantities and concentrations of
any releases. If this information is not known at the time of posting, it should be noted as an
incident update to the original notice as soon as the relevant information is obtained.
All PHAI monitoring results should be reported clearly on the PHAI website and in real time
when feasible.
PHAI staff have confirmed that quarterly monitoring results from the WWTP will be provided on
the PHAI website, as the facilities are commissioned.
The PHAI website already contains a significant amount of information concerning environmental
monitoring, explaining in simple terms the monitoring it conducts for air quality, noise, and odour,

18
Canadian Nuclear Laboratories, PHAI Phase 2 Public Information Program, section 6.

16
groundwater and soil quality, surface water quality, fish and fish habitat, and plant and wildlife.
The website already provides real-time weather monitoring data.
Waterkeeper recommends that sampling results from each of these types of monitoring should
be posted to the PHAI website within four days of being received or analysed. Depending on
whether sampling occurs weekly, monthly posting would ideally be weekly or monthly. However,
if all monitoring results (rather than calculated averages) would be provided in the PHAIs
quarterly compliance reports this may be acceptable. Once this data is posted, it should also
remain online, so as to facilitate members of the public’s comparisons with subsequent sampling
results.
Since 2011, the federal government has promoted increased data sharing by its departments,
including Environment Canada, Fisheries and Oceans Canada, and Natural Resources Canada.19
Given the significant involvement of the federal government with the PHAI, ensuring that the
project meets its goals for publicly available and usable data would be consistent with its
promises in this area.
Conclusion
The following is a summary of Waterkeeper’s recommendations for improvements to the PHAI:
1. That the site licenses for the older` Port Granby and Welcome waste management
facilities be immediately amended to include an Effluent Discharge Level of 0.15 mg/L for
Uranium;
2. The design objectives for both the new Port Hope WWTP and Port Granby WWTP should
be made licence conditions for those facilities;
3. Action Levels for the Port Hope and Port Granby WWTPs should be set within 12 months
of the commencement of these facilities’ operation;
4. Heavy metals to be monitored downstream from the Port Granby LTWMF should be
explicitly delineated and more comprehensive;
5. Regulatory Levels for the Port Hope Environmental Management Plan must be clarified;
6. The Port Hope WWTP effluent monitoring program should be more comprehensive;
7. Surface water monitoring downstream from the Port Hope LTWMF should be explicitly
delineated and more comprehensive;
8. The Control Levels and Action Levels for Uranium proposed in the Port Granby EMP
should be adopted in the Port Hope EMP;
9. Downstream water quality monitoring in Lake Ontario at the effluent release points for the
Port Granby and Port Hope WWTPs should continue as long as the facilities are
operating;
10. There should be a longer-term monitoring plan for the facility after the WWTPs close.
11. The PHAI must include a plan for managing contaminated water in the harbour during
PHAI and VIM dredging and excavation activity;

19
Press Release, “Minister Day Launches Open Data Portal” Treasury Board of Canada Secretarial, March 17, 2011, online:
www.tbs-sct.gc.ca.

17
12. A plan is needed to address how contaminated harbour water will be treated and
managed once dredging and excavation work ceases and the harbour mouth is opened
again;
13. That space be made for the MOECC to meaningfully provide regulatory oversight to
aspects of the PHAI with which it shares jurisdiction with the federal government;
14. All reportable incidents pursuant to CNSC and MOECC laws and regulations should be
reported to the PHAI website within four days of their occurrence or discovery;
15. All monitoring results should be reported clearly on the PHAI website and in real time
where feasible.

Independent Review of Hydrogeological Issues
Pertaining to the Review of the CNSC Staff Status Report
on CNL’s Port Hope Area Initiative
Prepared for:
Lake Ontario Waterkeeper
c/o Mr. Mark Mattson, President
Prepared by Wilf Ruland (P. Geo.)
766 Sulphur Springs Road
Dundas, Ontario
L9H 5E3
(905) 648-1296
deerspring1@gmail.com
October 3rd, 2016
page 1

Table of Contents
1) Introduction.............................................................................................................................

3
2) Background and Overview of the PHAI.................................................................................

4
3) Water Quality Protection Measures........................................................................................

4
.................................................................................................................a) Introduction

4
b) ........................................................Current LLRW Locations are Poorly Controlled

5
c) .................................................Long Term Waste Management Facilities are Secure

5
...........................................................................d) Environmental Protection Programs

6
4) Waste Water Treatment Plants (WWTPs)...............................................................................

6
.................................................................................................................a) Introduction

6
...............................................................b) Historic and Future Effluent Release Limits

7
5) Water Quality Monitoring Programs......................................................................................

8
.................................................................................................................a) Introduction

8
................................................................b) Regulatory Levels in the Port Granby EMP

8
........................................c) Port Granby WWTP Effluent Quality Monitoring Program

9
d) Downstream Surface Water Quality Monitoring Program for Port Granby LTWMF

9
.................................................................e) Regulatory Levels in the Port Hope EMP

10
f) ........................................Port Hope WWTP Effluent Quality Monitoring Programs

10
..g) Downstream Surface Water Quality Monitoring Program for Port Hope LTWMF

11
h) ............Duration of the Downstream Surface Water Quality Monitoring Programs

11
..........................................i) Wrap Up Comments on the PHAI Monitoring Programs

12
6) Water Management in the Sealed-off Port Hope Harbour and Monitoring in the Lake ..

12
7) Discussion ..............................................................................................................................

13
8) Conclusions............................................................................................................................

14
9) Recommendations..................................................................................................................

15
Appendix 1) List of Documentation Reviewed or Referenced.................................................

17
page 2

1) Introduction
I am a hydrogeologist, and I have worked as a professional for 30 years (2 years in Germany and
28 years in Canada). I am a specialist in groundwater and surface water contamination issues,
and have investigated many such issues over the course of my consulting career. I have given
testimony as an expert witness on hydrogeological issues before various boards, including the
Environmental Review Tribunal, the Environmental Assessment Board, the Joint Board, the
Ontario Municipal Board, the Niagara Escarpment Commission, and the Canadian Nuclear
Safety Commission (CNSC). A copy of my Curriculum Vitae is available upon request.
I’ve been retained as an expert by Lake Ontario Waterkeeper (LOW) to provide an independent
review of the CNSC Staff Report on Canadian Nuclear Laboratories Ltd. (CNL) Port Hope Area
Initiative (PHAI). I should note that LOW received CNSC funding to support my review.
The focus of my review are the potential groundwater and surface water quality impacts related
to inorganic, organic, and radiological contaminants which may be associated with any aspect of
the PHAI’s Port Hope and Port Granby projects.
The adequacy of the Port Hope Area Initiative’s two projects (from a water quality protection
perspective) can be measured at this time by the degree to which these projects provide:
- an accurate understanding of existing soil, groundwater and surface water conditions in
the Port Hope Area;
- a well thought-out and comprehensive plan to mitigate or eliminate potential soil,
groundwater and surface water quality impacts caused by historic Low Level Radioactive
Waste (LLRW) in the Port Hope area;
- appropriate water quality monitoring plans and follow-up monitoring plans;
- realistic contingency plans;
- adequate oversight for the project by PHAI staff, as well as adequate oversight and
regulation by the CNSC.
In order to carry out my work, I have reviewed numerous documents and the most important of
these are listed as references in Appendix 1 of this review.
I toured the area of the PHAI Port Hope and Port Granby Projects (on September 23rd, 2016),
and asked questions about various aspects of the proposal of the PHAI representatives who were
present on the day of the tour. I also submitted (through LOW) an information request and a
series of questions - most of which were discussed during the site tour.
This review outlines my ﬁndings, conclusions and recommendations following my review of the
CNSC Staff Report on CNL’s Port Hope Area Initiative (PHAI). The CNSC Staff Report on the
PHAI is a Commission Member Document or CMD (No. 16-M44), which provides an excellent
background and overview description of the current status of the PHAI.
In the course of my review I have carefully considered numerous background documents which
are available regarding the PHAI, and following my review I can report that I do not disagree
with any aspect of the information which is provided in the CMD. In fact, I can highly
recommend the CMD as providing a concise but reasonably detailed summary of the current
status of the PHAI.
page 3

In my comments which follow I will be highlighting some key aspects of the information which
is provided in the CMD on the PHAI, and I will be outlining some areas where I believe the
PHAI could be strengthened going forward.
2) Background and Overview of the PHAI
The PHAI is a process under which the federal government is offering to accept historic low-
level radioactive waste (LLRW) from across Port Hope and environs, and to secure these in two
dedicated long-term waste management facilities (LTWMFs) - one in Port Hope and one near
Port Granby. The details of this program are spelled out in a Federal Agreement with local
governments.
There are several major LLRW sources in Port Hope, and a multitude of smaller ones. The CMD
indicates that the wastes from these sources will be going to the two LTMFs as follows:
Port Granby LTWMF
- 450,000 m3 of LLRW from the existing Port Granby WMF (situated very near Lake Ontario)
will be relocated 700 meters inland to the Port Granby LTWMF.
Port Hope LTWMF
- 450,000 m3 of LLRW from the existing Port Hope WMF will be relocated to the new Port
Hope LTWMF (on the same site);
- 51,250 m3 will be coming from 3 contaminated industrial waste sites (Port Hope Center Pier,
Lions Park, and the Port Hope sewage treatment plant;
- following detailed radiological surveys of 4800 properties, it is estimated that small amounts of
LLRW waste will be coming from an estimated 375 residential properties;
- 572,000 m3 of LLRW will be coming from various remediation sites including the Port Hope
Harbour, the Highland Drive Municipal Landﬁll, and the aforementioned residential properties;
- 150,000 m3 of Cameco-owned legacy wastes (generated prior to 1988) as well as additional
contaminated soils and wastes from building demolition associated with the Cameco Vision in
Motion (VIM) project will be coming to the LTWMF.
The Clean-up Criteria are provided in the CNSC Site Licenses, and I have no issue with them.
Following completion of the PHAI all of the above LLRW sources will be remediated - with the
exception of the Cameco Port Hope Conversion Facility, which even after completion of the
PHAI will have some contaminated soil and contaminated groundwater under various buildings.
3) Water Quality Protection Measures
a) Introduction
The remediation works associated with the PHAI’s Port Hope Project and the Port Granby
project are both entirely in keeping with the mission of LOW. They will result in the mitigation
and/or elimination of LLRW contamination at major and minor site across the Port Hope area -
leaving behind vastly improved soil, groundwater and surface water quality.
page 4

The following aspects of the PHAI will result in much improved water quality:
- LLRW wastes and soils will be removed from numerous poorly controlled sites across the Port
Hope area, and will be deposited in 2 secure LTWMFs;
- the 2 LTWMFs are designed with state of the art features to provide secure and permanent
containment of the LLRWs which they receive;
- wastewater from each of the LTWMFs will be treated at a dedicated waste water treatment plant
(WWTP), before being discharged to Lake Ontario.
I will discuss each of these water quality protection measures in more detail below.
b) Current LLRW Locations are Poorly Controlled
The LLRW wastes in Port Hope date back to a time when little was known about the potentially
harmful nature and the safe storage of such wastes. As a result, none of the locations at which
the LLRWs are presently situated are what I would consider well-designed or well-controlled
when it comes to the prevention of groundwater and surface water contamination.
After-the-fact efforts have been made to investigate and mitigate water contamination with mixed
results, depending on the waste location being considered.
In all cases, relocation of the wastes to the secure LTWMFs will result in an immediate and
permanent improvement to groundwater and/or surface water quality at the current LLRW waste
locations. As such, it is a very good thing that the Port Hope Project and the Port Granby Project
are now in the implementation phase. Contaminated soils and wastes from the LLRW sites will
be deposited in well-designed and secure sites, which are discussed in more detail in the next
section of this review. The Clean-up Criteria for LLRW site remediation are provided in the
CNSC Site Licenses for each project’s LTWMF, and are adequate and appropriate.
c) Long Term Waste Management Facilities are Secure
The design of the LTWMFs is unique in my experience with landﬁlls and industrial and
hazardous waste sites in Ontario. The LTWMs have been designed to both prevent leakage of
contaminated water out of the facilities, and to prevent rainfall from getting into the facilities
once they are closed.
A state of the art base liner will prevent leakage of contaminated liquids out of the facilities.
While the designs of the liners are subtly different in response to the differing geology at each of
the LTWMF locations, both consist of multiple layers of mainly synthetic materials (bolstered by
the liquid retention capabilities of natural clay). The thickness of the base liners of the LTWMFs
is 1.35 meters, and both allow for containment and collection of any contaminated liquids being
generated by the wastes.
A unique and likewise state of the art cover system will prevent rainfall from getting into either
of the facilities once they are ﬁlled and closed. The designs of the cover systems are slightly
different in response to the differing planned end uses of each of the LTWMF locations, but both
consist of multiple layers of natural and synthetic materials designed to shed incoming rainfall
(to prevent it from seeping into the underlying wastes), and to minimize gamma radiation at the
ground surface above the covers. The thickness of the LTWMF cover systems is over 2 meters.
page 5

The unique (in Canada) combination of an impermeable cover and an impermeable base liner
(with leachate collection facilities) for the LTWMFs constitutes what I am calling a “clamshell”
design, which will ensure that after closure the LLRWs inside the LTWMFs will first be slowly
dewatering and will then remain entombed for the very long term.
d) Environmental Protection Programs
Notwithstanding the the innovative designs discussed above, very thorough Environmental
Protection Plans (EPPs) have been developed for each of the LTWMFs.
Each of the EPPs includes careful consideration of the following issues:
- safely managing the incoming wastes;
- air quality protection including dust prevention/mitigation;
- managing storm water and storm events, including erosion and sediment control;
- managing potentially contaminated water;
- spill prevention and mitigation (including safe fueling and maintenance) plans;
- radiological security including personnel and equipment decontamination;
- environmental monitoring plans for air, groundwater, stormwater, and treated surface water;
- a variety of contingency plans including responses to potential fires, storm events, accidents,
and spills;
- proactive personnel training programs.
I have few issues with the component parts of the EPPs for the two projects. My main concerns
relate to the effluent release limits and the downstream receiving surface water quality
monitoring programs for each facility, and these are discussed in more detail in Section 4) below.
4) Waste Water Treatment Plants (WWTPs)
a) Introduction
Contaminated liquids will be generated by rain falling onto the wastes being deposited in the
LTWMFs for as long as they are open to the elements. Once the final cover installation has been
completed (preventing further wetting of the wastes by rainfall), the flow of liquids should reduce
to an easily managed trickle within a few years as the wastes dewater.
The WWTPs for the Port Hope Project and the Port Granby Project are different in design,
reflecting the different nature of the wastes they will be receiving. The wastes coming into the
PH LTWMF are metals-rich, and in order to deal with the metals the wastewater will first be
processed through chemical precipitation followed by clarification and sand filtering. The wastes
coming into the PG LTWMF are high in organic matter (ammonia nitrate), and in order to deal
with these the wastewater will first be subject to biological treatment.
Following the first treatment steps described above, wastewater at both WWTPs will then be
further treated through reverse osmosis systems - in which the wastewater is forced through a
membrane in order to remove the most problematic contaminants including uranium, arsenic and
radium. The resulting treated water will be very low in contaminants, far lower than if treated
through conventional waste water treatment facilities. Contaminant levels in effluent from the
WWTPs should be close to drinking water quality following the reverse osmosis treatment.
page 6

The reverse osmosis systems on the new WWTPs generate a contaminated solid byproduct,
which will be disposed of in the LTWMFs while they are open. In the longer term the liquid
flows requiring treatment and the resultant byproduct production should rapidly dwindle, but in
the interim post-closure period there will be solids requiring secure long-term storage/disposal
coming from the WWTPs.
The WWTPs are the critical final step in the containment and protection of the environment from
the LLRWs, so diligent maintenance and downstream monitoring to ensure and confirm their
proper functioning is essential. Likewise essential are robust discharge limits for the treated
wastewater - which has been a problem in the past.
b) Historic and Future Effluent Release Limits
In my review of the historic discharge limits in the CNSC Licenses for the wastewater treatment
facilities at the Welcome WMF and the Port Granby WMF I was surprised to find that there was
no effluent release limit for Uranium in liquid effluent for either facility.
The only contaminant with a release limit for liquid effluent at the Port Granby WMF was
Radium-226 (with a limit of 0.37 Bq/L). Only two contaminants had a release limit at the Port
Hope WMF - Radium-226 (with a limit of 0.37 Bq/L) and Arsenic (with a limit of 0.5 mg/L).
In my professional opinion these historic limits in CFSC Licenses for the wastewater treatment
facilites at the PH WMF and the PG WMF were inadequate, and were not protective of the
natural environment. Uranium is the key indicator of LLRW contamination in the Port Hope area
and is a surrogate for the presence of many other also potentially harmful contaminants.
My interpretation of the lack of liquid effluent release limits for Uranium in the CFSC Licenses
is that there was effectively no limit set by the regulator on the amount of Uranium (and the
many other parameters which also had no discharge limit) being discharged in liquid effluent
from the facilities. I do not consider this to be either proactive or precautionary. I should note
that the liquid effluent being discharged from the facilities ended up in Lake Ontario.
Looking forward a sophisticated new WWTP is in operation, treating leachate and contaminated
water from the Port Granby WMF (and from the PG LTWMF once it begins receiving waste). I
have seen “Design Objectives for the LTWMF Water Treatment System” covering numerous
contaminants in the License Conditions Handbook for the Port Granby facility. I can support
these Design Objectives, and in fact I expect that the effluent being discharged from the WWTP
will easily meet the Design Objectives. I would however like to see the CNSC give “teeth” to
these Design Objectives by making them Effluent Release Limits on the Site License. My sense
is that Design Objectives are not enforceable - Effluent Release Limits are.
Likewise a new state of the art WWTP will soon be in operation and treating leachate and
contaminated water from the Port Hope WMF (and from the PH LTWMF once it begins
receiving waste). I have seen “Design Objectives for the LTWMF Water Treatment System”
covering numerous contaminants in the License Conditions Handbook for the Port Hope facility.
I can support these Design Objectives, and in fact I expect that the effluent being discharged from
the WWTP will easily meet the Design Objectives. I would however like to see the CNSC give
“teeth” to these Design Objectives by making them Effluent Release Limits on the Site License.
page 7

5) Water Quality Monitoring Programs
a) Introduction
For any contaminated waste management facility, an important conﬁrmation of successful site
design and operations is provided by water quality monitoring conducted in the natural
environment downgradient and downstream of the site. There are quite a few separate
components to the water quality monitoring programs for the Port Hope and Port Granby
projects.
I will not be providing comments on the groundwater quality monitoring, as my funding did not
allow that and because I see very little potential for the the PHAI to cause groundwater quality
impacts. Instead, there will be a progressive improvement in groundwater quality as existing
poorly controlled LLRW locations are excavated and relocated to the new and secure LTWMFs.
The groundwater quality impacts from the existing LLRW locations will diminish steadily over
time once the sources are removed, and there will be negligible impacts from the LTWMFs.
The program for downstream surface water quality monitoring is described in the September
2011 Environmental Monitoring Program (EMP) for the Port Granby Project and in the August
2012 EMP for the Port Hope Project.
There are many components to the surface water quality monitoring programs. These include
monitoring at the LTWMFs and their nearby WWTPS, and in Port Hope at some of the existing
major existing LLRW locations. The monitoring is further subdivided into phases which
correspond to the 2 remaining phases of the projects:
- the current construction and development phase (which is the time at which any downstream
impacts are most likely);
- the long-term post-closure maintenance and monitoring phase.
I will be focussing my comments on water quality monitoring being done during the current
construction and development phase. I will start with comments on components of the Port
Granby EMP, and follow with comments on components of the Port Hope EMP.
b) Regulatory Levels in the Port Granby EMP
Specific regulatory levels have been developed for the surface waters which are downstream of the
Port Granby LTWMF and WWTP. As set out in Section 5.1 of the Port Granby EMP, the following
three tiers of levels have been established:
Regulatory Level – It is anticipated that regulatory levels will be specified in the Site License
as not to be exceeded in carrying out the licensed activities. These levels are contaminant
concentrations that have been established by regulatory authorities to ensure the protection
of human health and the environment.
Action Level - These levels are set below the regulatory levels to warn of a potential adverse
environmental effect and allow actions/contingency plans to be implemented to correct the
situation. It is anticipated that the Site License will require the licensee to establish
acceptable action levels for the LTWMF. The license will also outline the requirement to
report to the CNSC exceedances of the action levels.
page 8

Administrative Control Level - These lower concentration value administrative control
levels are established to warn of potential environmental effects before the action levels have
been exceeded. When these administrative control levels are exceeded, an action plan will be
implemented at the operations level to increase surveillance, identify the root cause and
implement the appropriate contingency/mitigative action plan to control the release/
exposure.
It is indicated in Section 5.1.1.1 that the key contaminants of potential concern (COPCs) in
drainage water, groundwater and surface water at the Port Granby WMF are Arsenic, Cobalt,
Radium-226 and Uranium.
c) Port Granby WWTP Effluent Quality Monitoring Program
The effluent monitoring program for the critical construction and development phase are
provided in EMP Section 6.1.
Effluent quality monitoring is to be conducted weekly, which I consider to be an appropriate
frequency. The parameter list for the effluent monitoring is provided in EMP Table D-3, and I
consider this list to be appropriate.
It is my professional opinion that Effluent Release Limits corresponding to the Design Objectives
in Table D-3 should be imposed on the Port Granby WWTP by the CNSC - these should be hard
upper limits on the permitted quality of the effluent releases (compliance to be verified through
the weekly monitoring).
Section 6.1 of the Port Granby EMP also indicates that Action Levels should be established once
12 months worth of data have been obtained following the commissioning of the new WWTP,
and this is a reasonable proposal. I would however recommend that the proposed Action Levels
(which should be significantly lower than the effluent release limits) should cover all of the
parameters listed in Table D-3, and in particular the COPCs Arsenic, Cobalt, Radium-226 and
Uranium.
d) Downstream Surface Water Quality Monitoring Program for Port Granby LTWMF
The downstream surface water quality monitoring program during the critical construction and
development phase is described in EMP Section 8.1.3.1. Monitoring will be quarterly (which is
appropriate) and suitable monitoring locations have been established - upstream and downstream
of the site, and in Lake Ontario at the effluent diffuser and 20 meters to either side of it.
There is an incomplete reference to the Table intended to be showing monitoring methodologies
at the top of page 8-13 of the PG EMP - I am assuming the reference should be to Table D-17.
Table D-17 provides the parameter list for the proposed aquatic environment water quality
monitoring program, but simply states that the parameter list will include “heavy metals” instead
of listing them individually. I consider this to be a mistake - the individual parameters to be
monitored should be specified and should at a minimum include all of the metals in Table D-3.
No regulatory levels have been established except for the following (for Uranium):
- an Administrative Control Level of 0.0016 mg/L (which is appropriate);
- an Action Level of 0.012 mg/L (which is appropriate).
page 9

I would urge the CNSC to also require that Control Levels and Action levels be set for the 3 other
Port Granby COPCs (Arsenic, Cobalt, and Radium -226).
e) Regulatory Levels in the Port Hope EMP
The discussion in Section 5.1 of the Port Hope EMP of regulatory levels for the downstream surface
waters receiving treated effluent coming from the LTWMF is rambling and unfocussed, and requires
some editing so that it can provide clear direction for the effluent and downstream water quality
monitoring programs in the EMP.
It is indicated in Section 5.1.1.1 that the key contaminants of potential concern (COPCs) in
drainage water, groundwater and surface water at the Port Hope WMF are Arsenic, Radium-226
and Uranium.
f) Port Hope WWTP Effluent Quality Monitoring Program
The effluent monitoring program for the critical construction and development phase in discussed
in EMP Section 6.1.
Effluent quality monitoring is to be conducted weekly, which I consider to be an appropriate
frequency. The parameter list for the effluent monitoring is not provided - instead reference is
made to a parameter list from a different report. I consider this to be poor practice - the EMP
should include its own parameter list for effluent monitoring. At a minimum the parameter list
should include all of the parameters listed in the Design Objectives table on page 18 of the Port
Hope License Conditions Handbook.
The EMP indicates in Section 6.1 that Table B-1 provides the License Limits and Action Levels
for the current wastewater treatment facility. Review of Table B-1 reveals that there are only
license limits for two contaminants (Arsenic and Radium-226) - I support the license limits for
those parameters. But given that Uranium is ubiquitous in the LLRWs and on the list of COPCs
for the Port Hope WMF and LTWMF, I find it inexplicable that there is no License Limit for
Uranium in the discharges from the wastewater treatment facilities. This oversight should be
corrected immediately.
Looking forward it is my professional opinion that Effluent Release Limits corresponding to the
Design Objectives in the License Conditions Handbook should be imposed on the Port Hope
WWTP by the CNSC - these should be hard upper limits on the permitted quality of the effluent
releases (compliance to be verified through the weekly monitoring).
Section 6.1 of the EMP indicates that Action Levels should be established once 12 months worth
of data have been obtained following the commissioning of the WWTP, and this is a reasonable
proposal. I would however recommend that the proposed Action Levels (which should be
significantly lower than the effluent release limits) should cover all of the parameters listed in the
Design Objectives table in the Port Hope License Conditions Handbook, and in particular should
include the COPCs Arsenic, Radium-226 and Uranium.
page 10

g) Downstream Surface Water Quality Monitoring Program for Port Hope LTWMF
As mentioned previously, there is a rather lengthy discussion of regulatory levels in Section 5.1
of the Port Hope EMP. It is not clear from this discussion which of the many regulatory levels
listed under the heading “Environmental Monitoring and Assessment” are intended to apply to
the downstream water quality monitoring program.
The actual downstream surface water quality monitoring program during the critical construction
and development phase is described in Section 8.1.3.1 of the EMP. Monitoring will be quarterly
(which is appropriate) and suitable monitoring locations have been established - in Brand Creek
upstream and downstream of the site, and in Lake Ontario at the effluent diffuser and 20 meters
to either side of it.
A parameter list is not specified in Section 8.1.3.1 of the EMP - I recommend that at a minimum
the parameter list should include all of the parameters listed in the Design Objectives table in the
Port Hope License Conditions Handbook. More likely is that the EMP’s authors intended the
parameter list in Table D-3 of the Port Hope EMP to be used (as it is in other parts of the Port
Hope surface water monitoring program).
The only regulatory levels to be specified in Section 8.1.3.1 is a Control Level for Uranium, at
0.015 mg/L - which seems high for a Control Level. By contrast the Control Level for Uranium
proposed in the Port Granby EMP is 0.0016 mg/L, which I consider to be more appropriate.
There is no Action Level established for Uranium in the Port Hope EMP - I would recommend
that the Action Level of 0.012 from the Port Granby EMP be adopted. I would also urge the
CNSC to require that Control Levels and Action levels be set for the 2 other Port Hope COPCs
(Arsenic and Radium-226).
h) Duration of the Downstream Surface Water Quality Monitoring Programs
There is no end-point or minimum duration specified for the downstream surface water
monitoring programs for the 2 LTWMFs and their respective WWTPs.
Given the potentially hazardous and/or toxic nature of the wastes being deposited in the
LTWMFs, the design goal of the LTWMFs has been to keep these isolated from the environment
over the very long term. While I do not anticipate any issues, long-term monitoring is an
essential component of ensuring that the design goal is met.
I recommend that downstream water quality monitoring in Lake Ontario continue for as long as
the WWTPs are in operation and discharging treated effluent to the lake. I recommend that
downstream surface water monitoring in the nearby creeks should continue at the present
quarterly frequency for a minimum of 5 years after site closure, and that after that monitoring can
be stepped down to semi-annually for 20 years, and after that down to annually for another 25
years.
At the 50 year point, a decision can be made about the need for further regular downstream
monitoring. In my professional opinion it would be appropriate for periodic checks to made on
the LTWMFs to confirm integrity of their covers (perhaps every 5 years), and for downstream
surface water quality monitoring to be conducted during such inspections. These inspections
(with downstream monitoring) should continue for a minimum of 500 years.
page 11

i) Wrap Up Comments on the PHAI Monitoring Programs
I have spent considerable time carefully examining and providing comments regarding key
sections of the Port Hope and Port Granby EMPs which focus on effluent quality monitoring and
downstream surface water quality monitoring.
I have done so because these are the critical safeguards for the downstream natural environment
including Lake Ontario. I am very impressed by the design of both the Port Hope and Port
Granby LTWMFs and their respective WWTPs, but even with the best design there is always the
possibility that unforeseen problems may arise leading to higher than predicted releases of
contaminants from these facilities. In the event of such an occurrence, monitoring of effluent
quality and downstream surface water quality can provide an essential indicator of problems
which may otherwise go unnoticed.
6) Water Management in the Sealed-off Port Hope Harbour and Monitoring in the Lake
One aspect of the Port Hope waterfront remediation which involves both the PHAI and Cameco
is the remediation of the Port Hope Harbour. The Harbour is to be dredged to remove the
contaminated sediments which have made it one of 43 designated Great Lakes Areas of Concern
under the Canada - United States Great Lakes Water Quality Agreement.
The PHAI and Cameco Vision in Motion (VIM) plans include a provision for fish to be removed
from the Port Hope Harbour beforehand - with the Harbour then being sealed off for the duration
of the project during which Harbour impacts are anticipated. While this provides assurance that
efforts are being made to prevent harm to fish, there is a broader question regarding how the
contaminated water in the Harbour is going to be handled.
The various VIM and PHAI operations taking place in and around the harbour will be causing the
harbour water to be contaminated during a years-long period. This would not be a problem,
except that there are ongoing inflows to the harbour (of rainfall, groundwater and storm water)
and the Harbour mouth is to be sealed off so there will be no place for the surplus (contaminated)
water to go.
I have not been able to find any information in the VIM or PHAI documentation on how the
surplus contaminated water from the Port Hope Harbour is going to be handled during the VIM/
PHAI project period. This is clearly an issue which needs to addressed, as otherwise there will
be an ongoing poorly controlled and untreated flow of contaminated Harbour water into Lake
Ontario.
Monitoring will be critical to ensure that impacted Harbour water is not causing unacceptable
contamination of Lake Ontario. The PHAI monitoring proposals are provided in the Port Hope
EMP, and the Port Hope Harbour is discussed in Section 9.1.3.3. Review of Section 9.1.3.3
indicates that this aspect of the EMP has not yet been thought through or properly developed.
There is no reference to plans to monitor water quality in Lake Ontario (just beyond the Harbour
mouth), but I strongly recommend that such monitoring should be carried out. Lake Ontario
water quality monitoring should be done frequently (at minimum on a monthly basis, plus after
page 12

any rain events exceeding 50 mm), and should include the full list of COPCs identified for the
PHCF. The results of this monitoring should be made publicly available.
It could be argued that the Lake Ontario monitoring should be done either partly or entirely
through the VIM project (rather than through the PHAI project), but the question of who does the
monitoring is immaterial from my perspective - what is important is that the monitoring be done,
that it be reviewed by competent technical people who will ensure that any developing issues are
dealt with quickly and thoroughly, and that the results will be made publicly available.
7) Discussion
As an independent technical reviewer of the CMD on the PHAI project, I find myself in the
happy position of being able to report to my clients at LOW that I whole-heartedly support the 2
projects at the heart of the PHAI.
The current locations at which LLRWs are stored are not well-secured from the perspective of
preventing environmental contamination. Their relocation to the 2 well-designed and secure
LTWMFs will be an entirely positive development for the people and the environment in the Port
Hope area. This a major project - unprecedented in Canada - and it has obviously been well-
funded, well-designed, and thought through with careful attention to details.
The removal of the LLRW materials from across the Port Hope area will provide a significant
and permanent improvement in water quality on-site and downgradient/downstream of each of
the properties from which the wastes are being removed, and these improvements will ripple
down the watershed to also benefit Lake Ontario.
The clean-up criteria for remediation of the LLRW sites across the Port Hope area are adequate,
and consistent with criteria used in other clean-ups around the province. They will allow the
community to move forward with confidence.
I do not have any real concerns about the technical design details of the LTWMFs and the
WWTPs for the PH Project or the Port Granby Project. I find both project designs to be
impressive in terms of their innovation, scope and attention to detail.
The only issues I am raising and providing recommendations on pertain to:
- the regulation of such projects by the CNSC, which needs to be bringing the site licenses up to
date so that the effluent discharge limits better reflect the capabilities of the new WWTPs (as
discussed in Section 4);
- the monitoring programs for the projects, which could use some fine-tuning (as discussed in
Section 5).
I am also providing recommendations on an area of overlapping responsibility between the VIM
and PHAI projects, namely the management of the Port Hope Harbour clean-up. I could not find
plans for management of the contaminated water being generated in the sealed off Harbour in
either the VIM or PHAI documentation, but such plans (and plans for downstream monitoring in
Lake Ontario) will clearly be needed.
page 13

8) Conclusions
1) There is a major existing problem in Port Hope, caused by the presence of numerous locations
at which there are low-level radioactive wastes (LLRWs). These locations come in all sizes
from very small to very large, but what they have in common is that the wastes were deposited
many years ago and that the wastes are not properly controlled for the long-term.
2) The Port Hope Area Initiative (PHAI) is a unique and major LLRW remediation project,
which is aimed at providing secure long-term management of the LLRWs from around Port
Hope. The PHAI has its basis in a legal agreement between the Federal Government and local
communities, and involves a major clean-up of the LLRW locations in Port Hope which is
unprecedented in Canada.
3) Seen from the perspective of groundwater and downstream surface water quality, the PHAI
projects will provide major and permanent environmental benefits. Contaminated soils and
wastes are to be relocated to secure LTWMFs from numerous impacted properties and storage
facilities across the Port Hope area. The long-term result will be mitigation or elimination of
contaminants on these properties and at these facilities, and immediate decreases in
contaminant discharges to the waters of Port Hope Harbour and Lake Ontario.
4) The CNSC’s regulation of the existing major historic waste sites has not been adequate. There
have been no effluent release limits applied to Uranium discharges in treated wastewater from
the Port Hope and Port Granby Waste Management Facilities. Realistic and environmentally
protective regulatory levels for effluent quality are required for the new Port Hope and Port
Granby wastewater treatment plants (WWTPs) going forward, as discussed in Section 4 of this
review.
5) Fortunately it should not be a problem for the WWTPs to meet stringent effluent quality limits.
Initial testing of the effluent from the Port Granby WWTP shows exceptionally low levels of
various COPCs and other contaminants of concern.
6) The downstream surface water quality monitoring programs for the Port Hope and Port
Granby projects require some fine-tuning, as described in Section 5 of this review.
7) The management of the Port Hope Harbour clean-up is an area of overlapping responsibility
between the VIM and PHAI projects. I could not find plans for management of the
contaminated water being generated in the sealed off Harbour in either the VIM or PHAI
documentation, but such plans (and plans for downstream monitoring in Lake Ontario) will
clearly be needed - as discussed in detail in Section 6 of this review.
8) Recommendations are provided below to address the issues identified in Sections 4, 5, and 6
of this review.
page 14

9) Recommendations
1) The Effluent Release Limits contained in the Site Licenses for the Port Hope and Port Granby
Long-Term Low-Level Radioactive Waste Management Projects should immediately be
amended to include an Effluent Release Limit of 0.15 mg/L for Uranium.
2) The “Design Objectives for the LTWMF Water Treatment System” in the License Conditions
Handbook for the Port Granby facility should be made Effluent Release Limits on the Site
License by the CNSC. Likewise, the “Design Objectives for the LTWMF Water Treatment
System” in the License Conditions Handbook for the Port Hope facility should be made
Effluent Release Limits on the Site License by the CNSC.
3) Action Levels should be established once 12 months worth of data have been obtained
following the commissioning of the new Port Granby WWTP, and these Action Levels (which
should be significantly lower than the effluent release limits) should cover all of the
parameters listed in Table D-3 of the Port Granby EMP - in particular the COPCs Arsenic,
Cobalt, Radium-226 and Uranium.
4) Table D-17 of the Port Granby EMP provides the parameter list for the proposed downstream
aquatic environment water quality monitoring program, but simply states that the parameter
list will include “heavy metals” instead of listing them individually. The individual
parameters to be monitored should be specified and should at a minimum include all of the
metals in Table D-3. No regulatory levels for downstream monitoring have been established
except for Uranium. I recommend that the CNSC should also require that Control Levels and
Action levels be set for the 3 other Port Granby COPCs (Arsenic, Cobalt, and Radium-226).
5) The discussion in Section 5.1 of the Port Hope EMP of regulatory levels for the downstream
surface waters receiving treated effluent coming from the LTWMF is rambling and
unfocussed, and requires some editing so that it can provide clear direction for the effluent and
downstream water quality monitoring programs in the EMP.
6) Action Levels should be established once 12 months worth of data have been obtained
following the commissioning of the Port Hope WWTP, and these Action Levels (which should
be significantly lower than the effluent release limits) should cover all of the parameters listed
in the Design Objectives table in the Port Hope License Conditions Handbook - in particular
should include the COPCs Arsenic, Radium-226 and Uranium.
page 15

9) Recommendations - continued
7) Section 8.1.3. of the Port Hope EMP dos not provide a parameter list for the proposed
downstream aquatic environment water quality monitoring program. A parameter list should
be specified and should at a minimum include should include all of the parameters listed in the
Design Objectives table in the Port Hope License Conditions Handbook.
8) The Control Level for Uranium proposed in the Port Granby EMP of 0.0016 mg/L should be
adopted in the Port Hope EMP, and likewise the Action Level of 0.012 mg/L from the Port
Granby EMP should be adopted in the Port Hope EMP. I also recommend that the CNSC
require Control Levels and Action levels to be set for the 2 other Port Hope COPCs (Arsenic
and Radium-226).
9) I recommend that downstream water quality monitoring in Lake Ontario at the effluent release
point for each facility continue for as long as the Port Hope and Port Granby WWTPs are in
operation and discharging treated effluent to the lake.
10) I recommend that downstream surface water monitoring in the nearby creeks to the Port
Hope and Port Granby LTWMFs should continue at the present quarterly frequency for a
minimum of 5 years after site closure, and that after that monitoring can be stepped down to
semi-annually for 20 years, and after that down to annually for another 25 years. Starting at
the 50 year point, I recommend that it would be appropriate for periodic checks to made on
the LTWMFs to confirm integrity of their covers (perhaps every 5 years), and for
downstream surface water quality monitoring to be conducted during such inspections.
These inspections (with downstream monitoring) should continue for a minimum of 500
years following closure of the LTWMFs.
11) The final plan for handling contaminated water from the Port Hope Harbour during the VIM/
PHAI project period should be provided for public/stakeholder review once it has been
completed. It is not clear from the documentation who is responsible for this issue, but it
needs to be addressed by either Cameco or the PHAI.
12) The plan for monitoring Lake Ontario outside the Harbour mouth during the VIM/PHAI
project period should also be provided for public/stakeholder review at that time. Lake
Ontario water quality monitoring is required and should be done at minimum on a monthly
basis (plus after any rain events exceeding 50 mm), and should include the full list of COPCs
identified for the PHCF. The results of this monitoring should be made publicly available.
Cameco and the PHAI will need to determine who is responsible for the monitoring.
page 16

Appendix 1- References
The references considered in the course of preparing this review include the following:
Progress Update, Port Hope Area Initiative, Public Meeting Scheduled for November 9, 2016.

Commission Member Document (CMD16-M44). Dayed Sept. 2, 2016
2015 Port Granby Annual Compliance Report, Port Granby Project. Issued April 2016 by Canadian

Nuclear Laboratories.
Waste Nuclear Site Licence No. WNSL-W1-2311.01/2021, Port Granby LLRW Management

Project. Issued to Canadian Nuclear Laboratories by the CNSC on Oct. 22, 2014.
License Conditions Handbook WNSL-W1-LCH-2311, Revision 1, Port Granby LLRW Management

Project. Issued by Nuclear Processing and Facilities Division, December 4, 2014.
ENVIRONMENT AL MONITORING PLAN PORT GRANBY PROJECT, PHAI Management

Office, AECL. 2011/09/01.
PORT GRANBY PROJECT BIOPHYSICAL EFFECTS MONITORING PLAN, PHAI Management
Office, AECL. 2011/07/27
SCREENING REPORT , The Port Granby Long-Term Low-Level Radioactive Waste Management

Project. August 2009. Prepared by Natural Resources Canada and the CNSC.
2015 Port Hope Annual Compliance Report, Port Hope Project. Issued April 28, 2016 by Canadian

Nuclear Laboratories.
Waste Nuclear Site Licence No. WNSL-W1-2310.01/2022, Port Hope LLRW Management

Project. Issued to Canadian Nuclear Laboratories by the CNSC on Oct. 22, 2014.
License Conditions Handbook WNSL-W1-LCH-2310, Revision 1, Port Hope LLRW Management

Project. Issued by Nuclear Processing and Facilities Division, December 4, 2014.
ENVIRONMENT AL MONITORING PLAN PORT HOPE PROJECT, PHAI Management

Office, AECL. 2012/08/23.
PORT HOPE PROJECT BIOPHYSICAL EFFECTS MONITORING PLAN, PHAI Management

Office, AECL. 2012/03/03.
SCREENING REPORT , The Port Hope Long-Term Low-Level Radioactive Waste Management

Project. December 2006. Prepared by Natural Resources Canada and the CNSC.
page 17

CNSC COMMISSION MEMBER DOCUMENT (CMD: 16-H8.1). Submitted: 02 September 2016

by Cameco. Cameco PHCF Request for a Licensing Decision Regarding:

Renewal of Operating Licence FFOL-3631.0/2017 for the Port Hope Conversion Facility
CNSC Commission Member Document (CMD: 16-H8). Submitted 02 September 2016 by CNSC

Staff. Regarding A Licence Renewal Commission Public Hearing.

Scheduled for: 9-10 November 2016
Cameco 2017 LICENCE RENEWAL APPLICATION FOR THE PHCF. Supplemental VIM

Dated February 1, 2016
Cameco 2017 LICENCE RENEWAL APPLICATION FOR THE PHCF.

Dated November 20, 2015
CNSC Record of Proceedings, Including Reasons for Decision regarding the Comprehensive Study

Report for Cameco Corporation's Proposed Redevelopment of the Port Hope Conversion

Facility (Vision 2010). May 30,2012
page 18

Submission of Lake Ontario Waterkeeper - Reviewing Canadian Nuclear Safety Commission (CNSC) staff’s status report on Canadian Nuclear Laboratories Limited’s (CNL) Port Hope Area Initiative (PHAI), and participating in the Commission Meeting process

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