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SECTION PAGE
1. SCOPE .................................................................................................................. 1
2. PURPOSE .............................................................................................................. 2
3. DEFINITIONS ........................................................................................................ 2
3.1 Terms ................................................................................................................... 2
3.2 Acronyms ............................................................................................................. 3
4. REQUIREMENTS ................................................................................................... 3
5. RESPONSIBILITIES ................................................................................................. 3
5.1 Canadian Nuclear Laboratories ............................................................................ 3
5.2 Canadian Nuclear Safety Commission .................................................................. 4
5.3 Property Owner ................................................................................................... 4
6. PROCESS .............................................................................................................. 4
6.1 Overview of Protocol ........................................................................................... 4
6.2 Constraint Scenarios ............................................................................................ 4
6.2.1 Access Constraint: Property Access is Not Provided by Property
Owner ............................................................................................................ 5
6.2.2 Physical Constraint: Requirement to Maintain Structural Integrity
or Stability of a Property ................................................................................ 5
6.2.3 Operational Constraint: Clean Up Below a Specified Depth is not
Reasonably Feasible ....................................................................................... 5
6.2.4 Non-LLRW Constraint: Source of Soil Contamination is Not Related
to Historic LLRW ............................................................................................. 5
6.2.5 Environmental Constraint: Removal of Historic LLRW
Contamination will have a Detrimental Impact on an
Environmental Feature ................................................................................... 6
Prepared by: Date: Reviewed by: Date: Approved by: Date:
G. Case 2015/04/15 W. van Veen 2015/04/15 C. Hebert 2015/04/15
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TABLE OF CONTENTS
SECTION PAGE
7. REFERENCES ....................................................................................................... 10
APPENDICES
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Operating Procedure
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PORT HOPE AREA INITIATIVE SPECIAL CIRCUMSTANCES PROTOCOL
1. SCOPE
This document applies to the Port Hope Long-Term Low-Level Radioactive Waste Management
Project that involves the cleanup of properties contaminated with historic low-level radioactive
waste (LLRW) in the Municipality of Port Hope (MPH) and transportation of the LLRW for
consolidation in a single long-term waste management facility to be constructed at the site of
the existing Welcome Waste Management Facility. The Port Hope Project (PHP) is a federal
undertaking that is being conducted under a Waste Nuclear Substance Licence (WNSL) [1]
issued to Canadian Nuclear Laboratories (CNL) by the Canadian Nuclear Safety Commission
(CNSC). The WNSL sets out the conditions under which the clean-up work will be carried out
and more specifically identifies the Clean-up Criteria to be applied in the conduct of routine
remedial work. Appendix C of the WNSL sets out the clean-up criteria to be applied for three
land use classifications: Column A (Residential /Parkland /Institutional); Column B (Industrial/
Commercial /Community); and, Column C (Welcome Waste Management Facility and Highland
Drive Landfill).
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2. PURPOSE
The objective of the PHP is to clean up historic LLRW exceeding the clean-up criteria presented
in Appendix C of the WNSL. Presently the estimate is that some 1.2 million cubic metres of
historic LLRW will be addressed by the PHP. It is anticipated that the vast majority of properties
cleaned up under the Port Hope Project will meet the clean-up criteria defined in the WNSL;
however, it is also anticipated that a small number of unique situations will be encountered
where it may not be possible or practical to meet these criteria due to access, and property-
specific physical, operational, environmental or social constraints. To address these infrequent
situations that may arise during the implementation of the PHP, the following protocol (the
Protocol) has been prepared to provide an appropriate process for the identification and
application of property specific clean-up criteria or approaches, which hereinafter are referred
to as Special Circumstances. Note 2 in Appendix C of the WNSL references the term special
circumstances as follows: Concentrations higher than criteria listed may be acceptable at
depths >1.5 m as well as for special circumstance properties. The Protocol outlines the basis
for the term Special Circumstances for the purpose of meeting the requirements of the PHP
WNSL.
3. DEFINITIONS
3.1 Terms
Special Circumstance unique situation where property-specific constraints make it unduly
onerous to apply the clean-up criteria prescribed in the PHP WNSL, and where it is appropriate
to apply an alternative clean-up approach that will ensure the protection of human health and
the environment.
Low-Level Radioactive Waste historic waste sourced from Eldorado Nuclear operations
between 1932 and 1988 exceeding the clean-up criteria prescribed in the PHP WNSL.
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3.2 Acronyms
CNL Canadian Nuclear Laboratories
CNSC Canadian Nuclear Safety Commission
COPC Contaminant of Potential Concern
EASR Environmental Assessment Study Report
LCH Licence Condition Handbook
LLRW Low-Level Radioactive Waste
NRCan Natural Resources Canada
PHAI Port Hope Area Initiative
PHAI MO Port Hope Area Initiative Management Office
PHP Port Hope Project
RAP Remedial Action Plan
RVSOP Remediation Verification Standard Operating Procedure
WNSL Waste Nuclear Substance Licence
4. REQUIREMENTS
The Protocol is to be utilized for a situation on a specific property where the application of
Column A or Column B clean-up criteria, as set out in the Port Hope WNSL, is not considered
practical or feasibly achievable due to existing conditions/circumstances on the property and
where the residual risk to the environment and human health is considered acceptable.
Through the Protocol the requirements are set out to demonstrate and document that all
practical clean-up options have been considered and that the development of property specific
clean-up criteria or a property-specific approach developed in accordance with the Protocol is
an appropriate way to address the historic LLRW present on the property.
5. RESPONSIBILITIES
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6. PROCESS
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6.2.6 Social/Heritage Constraint: High Community Impact with Low Safety Return
A circumstance may be encountered where the application of the WNSL Clean-up Criteria may
adversely impact or require the destruction of a significant social or heritage aspect of the
community (e.g., historic building, mature tree, etc.). For this circumstance the application of
generic criteria could lead to a significant community impact with minimal return in terms of an
overall improvement in risk to human health or environment. Recognition of this situation as a
potential special circumstance would prompt the application of a property-specific approach
leading to the preservation of the social/heritage feature.
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Application Request
For an individual property or group of properties, the PHAI MO Manager of Port Hope Site
Characterization and/or Construction and Remediation will:
Review relevant property information on file and prepare/provide a summary report
outlining the findings of studies conducted on the property(s) in question;
Request the application of the Protocol and identify the appropriate Protocol scenario
or scenarios as per sections 6.2.1 to 6.2.6 for the property(s) in question;
Identify the affected parties that need to be consulted in the application of the Protocol
(e.g., property owner(s));
Describe the anticipated outcome regarding the extent of the proposed cleanup and the
material that may be left on the property and any implications (including any risks) to
human health and the environment;
Describe the property-specific verification process that will be followed to confirm the
application of the Protocol based upon the approved PHP RVSOP;
Compile the documentation necessary to support the recommendation in accordance
with the applicable scenario(s); and
Submit the documentation to the PHAI MO Director of Project Delivery along with a
completed application form to apply the Protocol to the property(s) in question.
Application Acceptance
The review and approval of the application of the Protocol to a property or group of properties
will be conducted by the PHAI MO Director of Project Delivery who will:
Review the Application in a preliminary manner to confirm that the Application is
complete or request additional required information within 5 business days;
Review the Application and supporting information in detail, and consult with third
parties and subject matter experts as required;
Accept, accept in part, or reject the application based upon a prescribed evaluation
process to provide consistency and traceability between evaluations;
Attest that the decision is in line with this Protocol, the PHP WNSL and LCH;
Document and sign the decision and the basis/supporting rationale behind the decision;
and,
Complete all above steps within 21 business days of receipt of a complete Application.
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7. REFERENCES
[1] Waste Nuclear Substance Licence, Port Hope Long-Term Low-Level Radioactive Waste
Management Project, WNSL-W1-2310.00/2202, November 2012
[2] Port Hope Long-Term Low-Level Radioactive Waste Management Project, Licence
Condition Handbook, WNSL-W1-2310.00/2202, Revision 1, November 2014
[3] Environmental Assessment Study Report and Supporting Documents, Port Hope Long-
Term Low-Level Radioactive Waste Management Project, May 2006.
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Appendix A
Access Constraint
Description of the Special Circumstance
CNL as the Licensee, first needs to be granted access to a property to initially identify and
delineate LLRW, and then be granted access a second time to perform any required cleanup.
This Special Circumstance occurs when a property owner refuses to grant first or second access,
and there is no basis for the CNSC to place an order on the property owner requiring him/her
under the Nuclear Safety and Control Act to grant access (i.e., there is no evidence of licensable
material on the property).
Identification of Special Circumstance
CNL has a communication strategy in place that outlines the frequency and content of access
request attempts. This Protocol will apply to a property once all the prescribed communications
steps have been exhausted without securing an access agreement from the property owner,
and there is no evidence of licensable material that would require an intervention by the CNSC.
A final step in the Communications Strategy is the issuance of a letter by Registered Mail or
courier with a Final Reply Date, a date which after an application can be made to the PHAI MO
Director of Project Delivery for closure of the property file under the terms of this Special
Circumstance Protocol.
Approval Process
Access Constraint Special Circumstance has a two-stage approval process:
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Appendix B
Physical Constraint
Description of the Special Circumstance
This Special Circumstance occurs when the excavation of historic LLRW contaminated soil
required to meet applicable WNSL clean-up criteria on a property will cause unacceptable or
unreasonable-to-mitigate instability in surrounding structures and slopes in the opinion of a
qualified party.
Identification of Special Circumstance
The development and technical review of the draft Remedial Action Plans (RAP) for a property
requiring the removal of historic LLRW contaminated soil will include an assessment of the
potential for unacceptable risks associated with excavation stability and/or unacceptable risks
due to the integrity of physical structures or slopes at and near the excavation site. Should the
technical review identify such a potential, the information will be forwarded to a professional
geotechnical specialist/engineer for a more in-depth review and assessment. Should the review
validate the concern regarding unacceptable risk to the stability and/or integrity of physical
structures or slopes on or near the excavation site, an application for Physical Constraint Special
Circumstance will be prepared.
Documentation Required for Approval
Technical Evidence Required:
o A geotechnical specialist/engineer written assessment stating that integrity
will be compromised if the property is excavated below a certain depth.
Assessment recommends acceptable limits of excavation and is signed by the
geotechnical specialist/engineer.
A revised RAP reflecting the geotechnical specialist/engineer recommended
excavation limits in light of the stability concerns.
A map detailing the proposed excavation limits and characterization data below
these limits (i.e., where and the nature of what material may be left behind).
Technical justification of why the Special Circumstances application is acceptable
(i.e., acceptable risk to human health and the environment, no licensable quantities
remain, etc.).
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Outcome
Property deemed a Physical Constraint Special Circumstance.
Municipality and CNSC informed of the designation.
All contaminated material above the excavation limit will be removed to meet
applicable WNSL Clean-up Criteria.
No unacceptable residual health and safety concerns based on current and
foreseeable land use.
Documentation on the quantity and characteristics of LLRW that remains on the
property.
Documented characterization of property post-cleanup (above and below
excavation limits).
Closed property file archived properly.
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Appendix C
Operational Constraint
Description of the Special Circumstance
It is anticipated that certain properties may require the cleanup of soils below what would be
considered a reasonable depth for a typical environmental cleanup in order to meet the Licence
Criteria. This Operational Constraint Special Circumstance occurs when documented LLRW
contamination on a property is in a quantity and location at a depth, below which it is
reasonable to assume that this remaining material does not pose an unacceptable risk to
human health and the environment.
Identification of Special Circumstance
The development and technical review of the draft Remedial Action Plans for a property
requiring the removal of LLRW contaminated soil will include an assessment of the potential for
excavation of soils at depths below what would be considered reasonable for a typical
environmental cleanup (e.g., >3 metres). Should the technical review identify such a potential,
the information will be forwarded to a geotechnical specialist/engineer for a more in-depth
review and assessment. Should the review validate the concern regarding the
unreasonableness of the depth of excavation, an application for Operational Constraint Special
Circumstance will be prepared.
Should this Special Circumstance be applied in situations where licensable material will be
potentially left on the property; discussions with the CNSC will be convened prior to
implementation of this Special Circumstance.
Documentation Required for Approval
Technical Evidence Required:
o Technical information delineating the location, concentration and depth of
the LLRW.
o Analysis to determine restrictions limiting excavation depth, based upon but
not limited to the following:
Soil type: geotechnical concerns regarding deep excavation in
identified soil type and potential excavation stability issues.
Confounding material excavation concerns: type of material to be
excavated such as municipal solid waste, wet sediments, etc.
Groundwater/Surface water concerns: confirm if groundwater will be
present; utilize standard industrial practices to assess if excavation
beneath the water table would ever be advised on the property, and
how deep it might extend.
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Outcome
Property deemed an Operational Constraint Special Circumstances.
Municipality and CNSC informed of the designation.
All LLRW above the excavation limit removed to meet applicable WNSL Clean-up
Criteria.
Current land use is unrestricted by any remaining material.
No unacceptable residual health and safety concerns based upon current and
foreseeable land use.
Documented characterization of property post-cleanup (above and below
excavation limits).
Closed property file archived properly.
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Appendix D
Non-LLRW Constraint
Description of the Special Circumstance
Some properties are contaminated by other, non-LLRW sources. It is anticipated that these
properties may exceed the Licence Criteria, even after the property has been remediated for
the removal of historic LLRW. This Non-LLRW Constraint Special Circumstance occurs when any
exceedance above the applicable WNSL criteria is caused by another source of contamination
(e.g., foundry wastes).
Identification of Special Circumstance
As accepted by the CNSC, the identification and delineation of historic LLRW contamination is
based upon the use of the Four Signature COPC (radium-226, thorium-230, uranium and
arsenic). However the application of the RVSOP, to confirm that historic LLRW has been
successfully removed, is based upon soil analysis for the full suite of 21 COPCs. The potential
need for this special circumstance is identified at properties where screening analyses of soil
samples at the limits of the excavation indicate that other sources of soil contamination are
present, in spite of the fact that the Four Signature COPC are at concentrations below their
individual WNSL Clean-up Criterion.
Documentation Required for Approval
Technical Evidence Required:
o Analytical results demonstrating that the delineation of the historic LLRW to
be removed from the property has been correctly defined based upon the
Four Signature COPC.
o Updated RAP for the property accurately reflecting the required limits of
excavation.
o Geotechnical logs and other supporting information, such as analytical
results for samples collected in the local area as well as previous experience,
which would suggest that other sources of contaminated soil may be present
beyond the limits of the historic LLRW on the property.
o Screening level sample results (e.g., XRF or other real time instruments) for
clean boundary samples that confirm or negate the presence of other soil
contaminants at concentrations exceeding WNSL Clean-up Criteria.
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Outcome
Property deemed a Non-LLRW Constraint Special Circumstances.
Municipality and CNSC informed of the designation.
All LLRW related material remediated to meet applicable cleanup criteria.
Property owner will be notified that the material removed had above background
levels of other COPCs. The property owner will also be notified that no testing was
done on soil remaining on the property. Property owner will not be provided with
the actual test results unless requested.
LLRW contamination remediated to meet applicable PHP WNSL Cleanup Criteria for
applicable land usage.
No CNSC licensable material on the property.
Closed property file archived properly.
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Appendix E
Environmental Constraint
Description of the Special Circumstance
It is anticipated that environmentally sensitive special features or areas may be discovered
during the course of the PHP. Removal of historic LLRW using the PHP WNSL Cleanup Criteria
could have a detrimental impact on this special environmental feature and that the
development of a property specific cleanup criteria or approach would be more appropriate
than the destruction of this special environmental feature or ecological community.
Identification of the Special Circumstance
During the development of the remedial action plan for the property, available environmental
data collected during the preparation of the Port Hope Environmental Assessment Study Report
will be reviewed, if available for the property. The review will be from the perspective of
identification of unique environmental considerations and identification of potential impacts on
specific environmental features or ecological communities that may occur as a result of the
proposed remedial work based upon application of PHP WNSL cleanup criteria.
Documentation Required for Approval
Technical Evidence Required:
o Identification and delineation of COPCs present on the property.
o Assessment of the significance of the environmental feature by an
appropriately qualified subject matter expert (e.g., biologist, botanist,
archeologist, Willow Beach Naturalists Group, Environment Canada, Ministry
of Natural Resources, etc.).
o Detailed description of the requirements to complete the cleanup without
the application of the Protocol.
o Assessment of the risk to the environmental feature resulting from a full
scale cleanup as compared to a partial cleanup so as not to adversely impact
the feature.
Technical justification of why the Special Circumstances application is acceptable
(i.e., no unacceptable risk to human health and the environment, no licensable
quantities remain, etc.).
Recommendation of a more appropriate RAP reflecting the limitations/restrictions
on excavation.
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Appendix F
Social/Heritage Constraint
Description of the Special Circumstance
A special circumstance may be encountered where the application of the PHP WNSL Cleanup
Criteria may adversely impact or require the destruction of a significant social or heritage
aspect of the community (e.g., historic landmark, feature or building, mature tree(s), etc.). For
this circumstance the application of generic criteria would lead to a significant community
impact with minimal return in terms of an overall improvement in the safety for human health
or environment. Recognition of this situation as a potential special circumstance would prompt
the application of a property-specific approach leading to the preservation of the
social/heritage feature.
Identification of Special Circumstance
During the development of the remedial action plans for some properties, significant
social/heritage features may be identified on the property that warrant an assessment by a
qualified subject matter expert (e.g. archeologist, urban planner) as well as consultation with
local area community based groups (e.g., local branch of the Architectural Conservancy of
Ontario, Heritage Business Association, Port Hope Tree Committee, etc.) as appropriate. The
assessment will identify special social/heritage concerns that warrant further consideration as a
Special Circumstance in the design of the remedial action plans for the property.
Documentation Required for Approval
Technical Evidence Required:
o Identification and delineation of COPCs present on the property.
o Assessment of the significance of the social/heritage feature by an
appropriately qualified subject matter expert (e.g., archeologist, architect,
biologist, historian, etc.).
o Detailed description of the requirements to complete the cleanup without
the application of the Protocol.
o Assessment of the risk to the social/heritage feature resulting from a full
scale cleanup as compared to a partial cleanup so as not to adversely impact
the feature.
Recommendation of a more appropriate RAP reflecting the limitations/restrictions
on excavation.
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