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Submissions of Lake Ontario Waterkeeper

Re: Relicensing hearing before the Canadian Nuclear Safety Commission (CNSC) for the Cameco

Corporation Port Hope Conversion Facility

Notice of Public Hearing, Ref. 2016-H-03

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 ………………………………………………………………………………………..…… 6

• About Lake Ontario Waterkeeper ……………………………………………………………. 6 • About the PHCF and its VIM project ………………………………………………………… 6

Water quality concerns at the PHCF ……………………………………………………………….. 8

• Current threats to local water quality for PHCF discharges……………………………….. 8 • Impacts of the VIM project on local waterbodies …………………………………………. 10 • Regulatory limits for liquid contaminant discharges from the PHCF ……………………. 10 • Monitoring releases from the PHCF into the Port Hope Harbour ……………………….. 11

Local aquatic ecosystems and the PHCF’s once-through cooling water system ………… 12 Public information sharing and the PHCF ………………………………………………………. 15

• Cameco’s Public Information Program ……………………………………………………. 15 • Release event reporting ……………………………………………………………………… 16 • Public information to assist with reviews of the current licensing application ………… 16

The requested licence period ……………………………………………………………………… 17 Conclusion …………………………………………………………………………………………….. 17 Appendix I: Independent Review of Hydrological Issues Pertaining to a Review of Cameco Vision

in Motion Initiative and Cameco’s Application for 2017 Renewal of Site License, Wilf Ruland, 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, Cameco staff

and CNSC staff

Appendix V: Meeting notes from Site Visit, September 26, 2016

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EXECUTIVE SUMMARY Cameco Corporation (Cameco) is currently applying to renew its Fuel Facility Operating Licence FFOL-3631.0/2017 (the licence) for its Port Hope Conversion Facility (PHCF). This licence was issued on February 28, 2012, (valid from March 1, 2012) and will expire February 28, 2017.

The requested licence is for a ten-year period and would permit Cameco to continue to produce nuclear fuel for reactors in Canada and abroad. Currently, the facility is permitted to process and produce up to 2,800 tonnes of uranium as UO2 which is used for CANDU reactor fuel and up to 12,500 tonnes of UF6 which is exported for processing into light water reactor fuel. The requested licence would also permit Cameco to make significant changes to its facility, renovating some buildings, decommissioning others, and building entirely new facilities on the PHCF site. These changes collectively comprise its Vision in Motion (VIM) project. More specifically, Cameco’s proposed VIM project involves:

• Removing up to 150,000 cubic metres (m3) of radioactive contaminated waste. This includes contaminated soil excavation, “legacy” drummed waste generated at the facility before 1988, and rubble from demolished older buildings at the PHCF site and Center Pier). This waste will be taken to Canadian Nuclear Laboratories’ secure long-term waste management facility in Port Hope;

• Removing 11 older or under-utilized buildings from the PHCF site and Center Pier; • Constructing of 4 new buildings and the refurbishment or modification of 7 other buildings

at the site; • Installing of new pump and treat wells to address the groundwater contamination that

will remain under the PHCF site after VIM is completed; • Improving the facility’s stormwater management infrastructure; and • Moving the eastern fence-line of the PHCF away from the harbour to help facilitate greater

public access to Port Hope’s waterfront. Waterkeeper has been involved in several other past decision-making processes before the CNSC concerning this facility, including its environmental assessment (EA) under the Canadian Environmental Assessment Act, 1992, as well as its application for a Certificate of Approval from the then Ontario Ministry of Environment for its industrial sewage permit. During these processes, Waterkeeper expressed concerns regarding the facility’s poor stormwater management, the need for better cooling water technology, and the need for better environmental monitoring and public communication. 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 PHCF and VIM on local surface water and groundwater quality; and

• Pippa Feinstein, JD, counsel and case manager for Waterkeeper who examined and made recommendations concerning the PHCF’s Public Information Program (PIP) and Fisheries Act compliance.

Overall, Waterkeeper has noticed an improvement in Cameco’s operations at the PHCF. More environmental monitoring is being undertaken, the VIM should address several legacy issues

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hindering the facility’s environmental performance, and communications and information sharing between the facility and local residents is becoming more robust. That being said, more work is needed. Cameco explains its VIM project “is an opportunity to make [its facility] more visually appealing, improve environmental performance and operational efficiency, return the Center Pier to the Municipality and improve public access to the waterfront”.1 These are all very important goals that Waterkeeper wholeheartedly supports. Such efforts to increase and support the swimmability, drinkability and fishability of the Port Hope Harbour and lakeshore are long overdue. Since the early 1930s, refining activity around the PHCF site has proved detrimental to the swimmability, drinkability, and fishability of the Port Hope Harbour and surrounding lakeshore, Alexander Creek, and the Ganaraska River. While much of the initial environmental degradation was due to a lack of understanding of the harmful substances being refined there, more recently effluent discharge limits and environmental monitoring requirements have remained lax, contributing further to historical pollution. The PHCF’s location in the heart of the community’s harbour, embedded in a densely populated town, is important to acknowledge. Many homes, business, and important aquatic communities and habitats lie within its 1km exclusion zone. As a result, Waterkeeper stresses it is especially important for Cameco’s VIM and its continuing conversion operations to be thoroughly scrutinized to ensure both are undertaken in a precautionary, responsible, and effective way. Further, fully transparent, accountable, and ongoing communication with the public about the progress of its VIM and continuing conversion operations will be crucial. These are the ingredients necessary for the facility’s social licence to continue operate in the community. Should the CNSC grant Cameco’s licence renewal request, Waterkeeper recommends that the following conditions be placed on its approval: Recommendations concerning the PHCF’s effluent discharges and effluent monitoring programs:

1) A final VIM-specific wastewater treatment plan should be provided for public review upon its completion;

2) A final plan for handling contaminated water from Port Hope Harbour during and after the completion of VIM and PHAI remediation efforts. This plan should also be provided for public review;

3) The proposed1825 kg/year release limit for Uranium from the sanitary sewer system into the harbour must be lowered. Reasonable Action Levels for Uranium and all other COPCs from all three pathways to the environment are required. These limits should be provided for public review once completed;

4) Future quarterly and annual compliance compliance monitoring reports should provide the full list of COPCs which are being monitored for in the sanitary sewer discharges. Additionally, the combined annual mass loading of Uranium from the sanitary sewer discharges should also be reported;

5) In the post-VIM period, uncontrolled contaminated stormwater discharges via the storm sewer system should be monitored at least quarterly;

1 Cameco’s relicensing application, CMD 16-H8.1 at p6.

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o This should be done at all active storm sewer lines, o Monitoring should be conducted for all identified COPCs, o Monitoring results should be included in all quarterly and annual compliance

reports, o A calculation of the combined annual mass loading of Uranium to the harbour

from all active sewers should be reported in annual compliance reports; 6) Monitoring of the Pump and Treat system should continue as planned;

o Groundwater monitoring results showing the areas of contaminated groundwater discharges not being contained by the system should also be reported in quarterly and annual compliance reports,

o Future quarterly and annual compliance reports should contain the full list of COPCs, those that are being monitored, and any reasons for the exclusion of others from being monitored,

o A calculation of the combined annual mass loading of Uranium to the harbour from all areas of uncontained contaminated groundwater should be reported in annual compliance reports.

Recommendations concerning the PHCF’s Fisheries Act compliance:

7) Cameco’s Fisheries Act self-assessment report should be made publicly accessible as well as CNSC staff’s review of it once it has been completed.

Recommendations concerning the PHCF’s Public information and disclosure programs:

8) The webpage reporting incidents should be included as a shortcut tab to the homepage for the facility, as its current location is difficult to find;

9) The incident reports should include actual data of measured releases; 10) Appropriate Effluent Release Limits and Action Limits should be included in these reports

to provide the public with a better understanding of the severity of the incident; 11) The date on the first line of each report should be specified as its posting date.

Recommendation concerning the requested licence period’s length:

1) Based on the lack of information currently available to the Commission, Cameco's relicensing application should be denied until all relevant information is available for the Commission to make a more informed decision. In the alternative, a three to five-year licence should be granted rather than a ten-year licence.

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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 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 PHCF relicensing process to ensure the Commission considers the public’s need for a swimmable, drinkable, fishable Lake Ontario when considering whether to renew the PHCF licence and/or add any new licence terms.

About the PHCF and the VIM Project

Cameco first applied to make certain improvements to its Port Hope facility in 2008 – a project that was called Vision 2010. Waterkeeper participated in the CNSC’s public hearing for this application and raised the following:

• That Cameco’s project could be an important opportunity to remediate contaminated lands and restore Port Hope’s waterfront from industrial to public use; and

• That Cameco’s project would be difficult for an EA to assess because it involved simultaneously decommissioning, remediating, and refurbishing different parts of its facility, as well as constructing completely new buildings.

Waterkeeper also requested that the EA, once undertaken, be based on real data rather than risk assessment. In 2009, Cameco requested a Certificate of Approval (CoA) for sewage works which would permit it to release cooling water effluent into Lake Ontario.2 Waterkeeper prepared submissions to the CNSC, Environmental Commissioner of Ontario, and the then Ontario Minister of Environment (MOE) raising the following:

• That the MOE was obligated to consider the CoA application in light of the extensive historic contamination in Port Hope;

• That cooling water can degrade the environment (due to both chemical and thermal pollution) and that Cameco must mitigate this impact by implementing ‘gold-standard’ cooling water technology; and

• That the terms of both federal and provincial permits related to Cameco’s facility should be better coordinated.

In 2011, the Environmental Impact Statement (EIS) for Cameco’s refurbishing and decommissioning project was released. Waterkeeper was an intervener in the CNSC’s public

2 Although, it appears it had been releasing effluent into the lake for decades prior to this point, without any permit to do so.

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hearing to consider the EIS and determine whether to grant Cameco a licence that would cover its planned renovations. For its intervention, Waterkeeper retained the services of David Dillenbeck and Wilf Ruland who provided expert reports concerning stormwater and wastewater issues at the site. The following is a brief summary of Waterkeeper’s submissions concerning the EIS:

• That the Cameco site is contaminated with a variety of pollutants (including over 87,500 cubic metres of contaminated soil) that fall under both federal and provincial jurisdiction (containing Uranium, Petroleum Hydrocarbons, Vinyl Chloride, Trichloroethylene, Ammonia, Radium-226, and Arsenic);

• That the site is located in a designated Area of Concern (A of C) and that there are many pathways for the contaminated site to pollute surrounding surface and groundwater;

• That there was no stormwater quantity or quality management system at the facility and that stormwater from the facility ran directly into Port Hope’s harbour via outfalls and terrestrial runoff;

• That the EIS lacked sufficient information (especially with regards to baseline characterization) and that it lacked a commitment to conduct surface water monitoring during the project’s operations;

• That the project provided an opportunity to institute a stormwater management system. Here, Waterkeeper made several recommendations concerning preferable options for such a system;

• That a better plan to address flooding and spills was required; • That wastewater estimates according to Cameco (48,000 m3) may be low and that there

was contradictory information about these estimates in Cameco’s application. Clarification of its plans, and the data used to inform them, were requested;

• That a plan be instituted for the contaminated water produced from the dewatering process for contaminated soil, as no such plan was specified;

• That the harbour wall be made impermeable to prevent further groundwater movement from the site, as no such plan was specified; and

• That the methods for sampling, processing, and disposal of contaminated soil be further clarified. Waterkeeper recommended that Cameco use best industry practices when addressing these issues at their facility.

The EA for the project proceeded as a comprehensive report which was released in May 2012. It concluded that Cameco’s proposed changes to its facility would not cause significant environmental effects, taking specific mitigation measures into account. Since these past processes, some of Waterkeeper’s past concerns have been addressed by Cameco and the plans for its VIM project: new impenetrable harbour walls will be installed along the west wall of the harbour, plans to address flooding and spilling are being developed with adequate ‘severe storm’ scenarios being taken into account, monitoring and sampling plans for the site have been improved, stormwater infrastructure will be upgraded, and public information-sharing with the public has increased. At the same time, many concerns persist: additional environmental monitoring is still required to better understand the PHCF’s effects on the local environment, more comprehensive and demanding effluent release limits must be developed and made legally enforceable, information-sharing with the public must be more robust and include better data sharing.

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The Commission can only renew Cameco’s a licence if it finds the legal test in section 24(4) of the Nuclear Safety and Control Act (NSCA) is met. This section specifies: No licence shall be issued, renewed, amended or replaced — and no authorization to transfer one given — unless, in the opinion of the Commission, the applicant or, in the case of an application for an authorization to transfer the licence, the transferee

(a) is qualified to carry on the activity that the licence will authorize the licensee to carry on; and (b) will, in carrying on that activity, make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed.

Waterkeeper submits that this test will only be met if the Commission adopts the recommendations included in these submissions. Water quality concerns and the PHCF Mr. Ruland has been retained by Waterkeeper to review Cameco’s plans for its VIM project as well as its continuing conversion operations. He had previously reviewed the VIM and Cameco’s operations for Waterkeeper in 2011, and was thus familiar with the facility, its operations, and areas in which its impact on local water quality could be improved. In his review for this current relicensing process, Mr. Ruland noted that Cameco’s operations and plans have generally improved over the last five years. At the same time, he has still identified several areas that require more work. Waterkeeper accepts all of Mr. Ruland’s recommendations and submits them for the Commission’s consideration. There are four categories of findings and recommendations below:

• An overview of current threats to local water quality posed by the PHCF’s effluent discharges;

• The adverse impacts the VIM project will have on local waterbodies and recommendations for how they should be addressed;

• The current effluent release limits for the facility and recommendations for how they should be strengthened; and

• The current water quality monitoring plans and how they should be improved. Current threats to local water quality from PHCF discharges Due to decades of refining operations around the Port Hope Harbour, and due to the lack of knowledge in the early days of this activity about the adverse impacts of these substances could have on the health of locals and the environment, refining operations were not adequately contained and local water quality was severely degraded. Mr. Ruland explains that local groundwater and soils on the PHCF site and its surroundings have long been contaminated with the following Contaminants of Primary Concern (COPC): Uranium, Arsenic, Ammonia, Nitrate, Flouride, Radium-226, Trecholoroethylene, Dichloroethylene, and Vinyl Chloride.

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Contaminated soils and groundwater are present across the main PHCF site, as well as the Center Pier, and Port Hope Harbour. Mr. Ruland has found that Uranium levels below certain portions of the PHCF measure in the 1000s of ug/L, with peak levels of over 20,000 ug/L; this is between 50 and 1000 times higher than the Ontario Drinking Water Quality Standard for Uranium (which is 20 ug/L), and between 200 and 4000 times higher than the Ontario Provincial Water Quality Objectives for Uranium (5 ug/L).3 While the Center Pier, harbour, and a few meters into the harbour’s west wall will be excavated down to bedrock by the Port Hope Area Initiative (PHAI), much of the contaminated soils and water below the PHCF will remain. Cameco is trying to remediate this contamination below its facility. Approximately 60% of contaminated groundwater is currently contained by the facility’s pump and treat system, reducing the previous release of 25-30 kg/yr of Uranium into the harbour down to 5 kg/yr. Cameco expects that these emissions will be further reduced after the VIM project is completed and the new impermeable harbour walls are installed. Cameco is expecting the pump and treat system to capture 95% percent of groundwater flow to the harbour once the VIM is completed.4 Other contaminated water is also discharged into the harbour via the stormwater system for the facility. Mr. Ruland believes that there are leaks and breaks in the PHCF’s aging stormwater network, and that some amount of contaminated groundwater enters the pipes and is released directly into the harbour. While Mr. Ruland stresses this issue is not as serious as it was when he first identified it back in 2011, it is still a significant cause for concern. In particular, he found that the PHCF lacked any Effluent Release Limits or Action Levels for these stormwater discharges, meaning that these pollution pathways were essentially not being regulated at all. There is a significant lack of transparency with regards to current monitoring plans to track stormwater discharges into the harbour. While Cameco has asserted it monitors stormwater discharge points semi-annually, there is no additional publicly available information concerning this monitoring plan. This ultimately prevents public scrutiny of the plan (for instance, Mr. Ruland has been unable to determine whether it adequately protects local water quality, or whether it could be improved in certain ways). It also raises questions with regards to the extent to which the CNSC is aware of this situation. Mr. Ruland found that the majority of water contamination in the harbour was a result of the PHCF’s contaminated stormwater discharges and that average Uranium concentrations in the storm sewer discharges to the harbour were 218 ug/L.5 Uranium is a “key indicator” of low-level radioactive waste and a surrogate for the presence of many other potentially harmful contaminants, thus these findings for Uranium would likely be similar for other COPCs being released into the harbour via PHCF’s stormwater system. The PHCF also releases wastewater into the municipal sewer system where it is fed into the Port Hope’s municipal Water Treatment Plant and treated (to an unknown extent) before being

3 Independent Review of Hydrological Issues Pertaining to a Review of Cameco Vision in Motion Initiative and Cameco’s Application for 2017 Renewal of Site License, Wilf Ruland, October 3, 2016 at p 7, (the “Ruland Report”). 4 Appendix V to this submission, Meeting notes from September 26 Site Visit. 5 Ruland Report at p 7.

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released into Lake Ontario. Mr. Ruland found that the PHCF’s discharges of Uranium into the municipal sewer systems averaged at 19 ug/L, almost four times the PWQO for this contaminant.6 Impacts of the VIM Project on local waterbodies During the implementation phase of the VIM project, the PHCF will generate considerably more contaminated waste water in need of treatment. Cameco does not yet have a plan for addressing this issue, instead assuring that it will either be treated at the municipal treatment plant, or else its own water treatment system (which evaporates wastewater). However, it is unclear whether either of these facilities will have the capacity to treat this additional PHCF wastewater. This plan also raises questions concerning the ability of the municipal treatment plant to adequately treat the contaminants present in PHCF wastewater. Most municipal treatment plants in Ontario do not have the capacity to treat for radioactive contaminants.7 The additional wastewater present in the harbour during excavation activities is also cause for concern. As the dredging and excavation work in and around the harbour progresses, the contaminant concentrations in the harbour water will become increasingly elevated. While the harbour will be sealed off to prevent the entry of fish during this work, Mr. Ruland highlighted questions about what will happen once the harbour is opened up to the lake again. It will be important, and difficult, to ensure contaminants in the harbour water are not freely discharged into the lake once the harbour mouth is reopened. To address this, Mr. Ruland recommends that regular monitoring of both the harbour and beyond the harbour’s mouth be undertaken (at least monthly, and after any rain events) to determine how contaminants in the water are behaving. He also believes the results of these samples should be made publicly available.8 Waterkeeper strongly supports both recommendations. Regulatory limits for liquid contaminant discharges from the PHCF Mr. Ruland explains in his expert report that he has “grave concerns” about the licencing oversight by the CNSC of the PHCF’s operations. These concerns extend to the regulation of contaminated liquid effluents from the site, effluent monitoring, and lack of publicly available information concerning this monitoring. The PHCF discharges contaminated water into the Port Hope Harbour and Lake Ontario via three pathways: 1) contaminated stormwater discharges to the municipal sewer system (which are ultimately released into the Lake after an unknown level of treatment); 2) releases of contaminated stormwater (via PHCF’s storm sewer network) into the harbour; and 3) groundwater from contaminated areas of the PHCF site discharging to the harbour. However,

6 Ruland Report at p 8. 7 Review of the State of Knowledge of Municipal Effluent Science and Research Report, Prepared for: The Development Committee for the MWWE Canada-Wide Strategy Canadian Council of Ministers of the Environment, Hydromantis Inc., University of Waterloo, Dept. of Civil Engineering, January 2006, at p 30. 8 Ruland Report at pp 10-11.

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none of these discharges are being addressed in the current CNSC licence which constitutes a “significant failure in oversight”.9 According to CNSC staff’s draft Licence Conditions Handbook, it appears as though only the sanitary sewer system (the least contaminated of the three pathways) will be subject to a release limit. Further, this release limit is only for Uranium and is astronomically high: 1825 kg/yr or 1.8 tonnes per year. Cameco has explained this is a theoretical limit which was arrived at by calculating the maximum amount that could be discharged to the water until the regulatory limit of a 1mSv public dose would be reached for Port Hope inhabitants. Mr. Ruland notes that this limit fails to take into consideration the fact that Uranium contamination adversely impacts humans and aquatic biota not only due of its radioactivity, but also its toxic chemical properties. Furthermore, as already explained in this submission above, Uranium as an indicator substance and surrogate for other contaminants, As such, permitting exceptionally large discharges of Uranium will by extension also likely permit similarly high levels of other COPCs. This proposed release limit for Uranium is over 90 times higher than the ODWQs for Uranium and 365 times higher than the PWQO for Uranium. Mr. Ruland warns that,

The CNSC’s proposed release limit of 1825 kg/year in sanitary sewer discharges is so absurdly high that there would be appalling exceedances of the ODWQs and PWQOs in whatever surface water body was receiving these discharges, with dire consequences for aquatic life. If discharged to the Port Hope Harbour, 1825 kg/year of Uranium would turn the Harbour into a killing zone for aquatic life.10

If released to the lake, elevated contaminant levels would cause this killing zone extend into the lake itself. To address this concern, Mr. Ruland recommends that Cameco and CNSC staff immediately develop more appropriate Action Levels for Uranium for all three pathways through which contaminated water reaches the harbour and lake. He also recommends that similarly appropriate Action Levels, and more responsible Effluent Release Limits for all COPCs being released into the environment via these pathways. All these limits should be included as conditions for Cameco’s new licence. Waterkeeper strongly supports these recommendations. Monitoring of releases from the PHCF into the Port Hope Harbour There is a lack of publicly available information concerning the specifics of much of the wastewater monitoring at the PHCF. It appears as though wastewater discharges from the sanitary sewers are monitored weekly for Uranium, Flouride, Ammonia and Nitrates, although there is no available information as to whether any other COPCs are tested for. Mr. Ruland recommends that monitoring should include all COPCs for the site, if it doesn’t already and that these monitoring results be included with other monitoring results currently reported in Cameco’s quarterly compliance reports. Mr. Ruland also recommends a calculation of the combined annual mass loading of Uranium to the harbour from all sanitary sewer discharges be done every year and reported in the annual compliance monitoring reports for the facility. Waterkeeper strongly supports these recommendations

9 Ruland Report at p 11. 10 Ruland Report at p12.

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Monitoring results from the uncontrolled stormwater releases (via the storm sewer system) are also not publicly available. Current monitoring plans are also inadequate with monitoring only being conducted at seven of ten active outfalls, and only semi annually. It is also unclear which contaminants are being tested for. Mr. Ruland recommends that monitoring should be conducted at least quarterly and that all discharge points be monitored for all COPCs. The results of this monitoring should be included in quarterly and annual compliance reports, and a calculation of the combined annual mass loading of Uranium to the harbour from all active storm sewers should be done every year and reported in annual compliance monitoring reports for the facility. Waterkeeper strongly supports these recommendations The results of Cameco’s Pump and Treat monitoring system are not publicly reported. However, Mr. Ruland was able to obtain a report from Cameco staff after his site visit that contains monitoring results from 2015. The report he obtained shows that pumping wells are monitored monthly for a short list of COPCs (Uranium, Radium-226, Arsenic, Nitrate, Flouride, and Ammonia) and annual monitoring occurs at these wells for a longer list of general chemistry parameters, VOCs and metals. Much of the contaminated water is extracted and evaporated at the facility’s treatment system, while the remainder leaks into the harbour. Mr. Ruland recommends that the combined annual mass loading of Uranium to the harbour from all areas of uncontained contaminated groundwater be assessed and reported in the facility’s annual compliance reports. Waterkeeper strongly supports these recommendations and would also recommend that the results of this pump and treat monitoring be publicly released in quarterly and annual compliance reports. Local aquatic ecosystem and the PHCF’s once-through cooling water system

Port Hope supports significant fish populations. The Environmental Risk Assessment (ERA) for the facility includes a description of the local aquatic environment. It explains that alewife, rainbow smelt, threespine stickleback, and lake whitefish spawn along the shoreline of Lake Ontario in Port Hope. It notes 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 ERA explains that the Ganaraska River is a (“key producer”) spawning site for wild chinook salmon and coho salmon. It also explains the harbour provides sheltered warmer water for a modest aquatic community including smallmouth bass, yellow perch, and spottail shiner.11

The PHCF relies on a once-through cooling system for its conversion operations. The system draws in water from an intake pipe in the harbour, close the open lake. The water then gets passed through pipes around the UO2 and UF6 facilities’ machinery, absorbing the heat generated in processing the substances, and thus cooling them down. Once the water passes

11 Appendix E, the Environmental Assessment Report for Cameco’s Port Hope Conversion Facility Relicensing Application, CNSC Staff CMD 16-H8 at p21 (the “PHCF Environmental Assessment Report”).

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through the facilities, it is discharged back into the harbour at a higher temperature, and with some degree of contamination picked up while passing through the pipes. The system is subject to conditions in an Environmental Compliance Approval (ECA) as well as a permit to take water (PTW), both issued by the Ontario Ministry of Environment and Climate Change (MOECC). Over its past licence term, Cameco initiated a self-assessment to determine whether it would require a permit from the Department of Fisheries and Oceans Canada (DFO) to operate its once-through cooling system. Baseline impingement12 sampling was conducted from October to December 2012, and then again from April to July 2013. Apparently only round goby, alewife and crayfish were found to have been impinged and not in significant numbers. Baseline entrainment13 sampling occurred from June to July 13 and March to July 2014. During 2013 testing, rainbow trout, brown trout, blue gill, smallmouth bass, and crayfish juveniles were identified as well as round goby eggs, and white sucker eggs and larva. The ERA for Cameco’s application confirms no species at risk were identified during these studies except for an incident between April and May 2014 when the north side of the intake structure breached and allowed fish to pass through the cooling system, bypassing the intake screen. During that incident, round goby, rainbow trout, brook sickleback, white sucker, yellow perch and a juvenile snapping turtle were sucked into the system. The snapping turtle is a federal and provincial species of concern, subject to a federal management plan. The intake structure was subsequently repaired and no more snapping turtles have been found to be impacted by the cooling water system.14 No action is mentioned with regards to preventing similar incidents from happening again. Nor does it appear as though there is regular monitoring of the cooling water system’s intake outside of these self-assessment periods. The ERA also discusses three thermal studies which were conducted on behalf of the PHCF between 2011 and 2014. In assessing thermal discharges from the cooling system, CNSC staff observed thermal exceedances in the summer months of 2011 but noted they were probably due to natural processes in the harbour. Staff also noticed that exceedances were observed or predicted between September and December (of an unspecified year). They were associated with one of the two cooling water outfalls, and risks to different species were identified on the assumption that fish spent the entire period in the turning basin during the exceedances. However, further study indicated that fish did not necessarily spend a significant amount of time in the turning basin during October and November. No tagging study was done to determine fish movement during December, which was the month that exhibited the highest number of thermal exceedances. It does not appear as though any further efforts were undertaken to verify the cause of thermal exceedances, better map how fish populations may be have been affected, determine whether

12 The term impingement refers to a process whereby larger aquatic species are killed by being drawn up and crushed against the intake grate of the cooling water system. 13 The term entrainment refers to a process whereby juvenile fish, eggs, and larvae are drawn through the intake grates and into the cooling water system, often resulting in death or serious injury. 14 PHCF Environmental Assessment Report at p31.

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these exceedances have continued since 2014, or determine the adequacy of thermal discharge limits for the facility.15 If any impingement, entrainment, thermal pollution, or other monitoring is conducted to asses the PHCF’s cooling water system system, Waterkeeper recommends that their findings be included in quarterly or annual compliance reports. In its current relicensing application, Cameco explains, “[t]he self-assessment determined that much less that one kilogram of fish was lost to the ecosystem with the existing cooling water operation and mitigation in place. At this low potential impact, an authorization is not required”.16 Cameco fails to mention over what period this one kilogram of fish is killed. And despite asserting a permit would not be needed, Cameco also concedes that CNSC staff were still reviewing its study to determine whether this is in fact the case. In CNSC staff’s CMD for this hearing, they confirm that they are still in the process of reviewing this document, although they provide no estimated completion date for their review.17 When Ms. Feinstein requested a copy of this report, or more information about its findings, Cameco refused to provide further information. When Ms. Feinstein inquired with the Commission about when CNSC staff would complete their review of this assessment, staff explained their review would not be completed by the hearing in November. Staff also asserted that “[w]hile Cameco has submitted the self-assessment and it is discussed in the CMD, it is not linked to Cameco’s licence application for the renewal of the PHCF and therefore, does not impact or impede the decision for Cameco’s licence application”.18 However, a Memorandum of Understanding (MOU) between the CNSC and DFO requires that when rendering a licence decision, Commission Members must consider “the intent and requirements of the Fishers Act, [Species at Risk Act], and their associated regulatory and policy frameworks”.19 Licence hearings determine the conditions to be applied to facilities’ operations. Cameco’s self-assessment should have been made available to help inform any need for CNSC licence conditions to be drafted concerning the cooling water system. Waterkeeper submits that CNSC staff should have completed their assessment for the licence hearing so that the results of Cameco’s assessment and staff’s recommendations concerning the need for a DFO permit could be subject to public review, and if needed incorporated into the facility’s licence conditions. However, Waterkeeper does not necessarily accept that such a licence, if needed, should be granted to the facility without a full public review of the facts. Waterkeeper recommends that this report be made publicly accessible, in addition to the findings of CNSC staff’s review of it, as soon as the review is completed.

15 PHCF Environmental Assessment Report at p32. 16 Cameco’s relicensing application, CMD 16-H8.1 at p61. 17 CNSC Staff CMD 16-H8 at p76. 18 Appendix IV to these submissions, Ms. Feinstein’s personal communication with CNSC staff, September 23. 19 Canadian Nuclear Safety Commission and Fisheries and Oceans Canada, “Memorandum of Understanding Between Fisheries and Oceans Canada and the Canadian Nuclear Safety Commission for Cooperation and Administration of the Fisheries Act and Species at Risk Act Related to Regulating Nuclear Materials and Energy Development”, December 16, 2013, at sections 3 and 4.

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Public information sharing at the PHCF Cameco’s Public Information Program

According to the proposed Licence Conditions Handbook for the PHCF, “The primary goal of a public information and disclosure program is to ensure that information related to the health, safety and security of persons and the environment, and other issues associated with the lifecycle of the nuclear facilities are effectively communicated to the public”.20 A robust and transparent PIP also lies at the heart of any facility’s social licence to operate within a community.

Section 2.6 of the PHCF’s current licence requires a Public Information Program (PIP).21 Public Disclosure protocols are usually developed as part of the PIP.

Ms. Feinstein requested a copy of the facility’s PIP for review, however, Cameco only provided its Public Disclosure Protocol (PDP), which is already publicly available via an embedded link on the PHCF’s website. When asked about why the full PIP couldn’t be released, Cameco explained that it never discloses program documents to the public, and that its PIP is considered a program document.

From what Ms. Feinstein has been able to gather, the PIP involves public presentations and “community forums” about the facility and provides tours of its facility to interested members of the public. At the same time, it appears the company relies on its website as its main public interface and forum for public information disclosure.

CNSC staff’s CMD noted that CNSC staff had made recommended improvements to the PHCF’s PIP.22 When Ms. Feinstein asked about the improvements CNSC staff had recommended, staff replied that there were two separate discussions between Cameco and CNSC staff concerning their program. One concerned some “administrative changes” to its program that Cameco made in September 2015. The other concerned a generic request by CNSC staff in 2016 that required all Class 1A and 1B facilities to review how events are reported to the CNSC and the public.23

This seems inconsistent with Cameco’s explanation of the improvements they were asked to make to their PIP. At the September 26 site visit, Cameco staff explained that CNSC staff’s recommendations for the company’s PIP were in response to an incident earlier that year which involved a transport accident in which transported yellow cake was released from a vehicle after it was involved in an accident on Highway 4 near Swift Current, SK.24 Cameco has since refused to disclose any further information about what their current PIP improvements concern.

20 Draft licence condition 1.4, in CNSC Staff CMD 16-H8. 21 Current Nuclear Fuel Facility Operating Licence, Cameco Corporation Port Hope Conversion Facility, FFOL-3631.00/2017, section 2.6. 22 CNSC Staff CMD 16-H8 at p75. 23 Regulatory action – Issued to multiple licensees: Class 1 nuclear facilities and uranium mines and mills, 2016, “Request pursuant to subsection 12(2) of the General Nuclear Safety and Control Regulations – reporting processes”, February 25, 2016, online: http://nuclearsafety.gc.ca. 24 See: “Nuclear-related event reports”, 2016 Transport/In Transit events, online: http://nuclearsafety.gc.ca.

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With such limited information, it is difficult to provide general comments about Cameco’s PIP. Furthermore, the opacity with regards to Cameco’s PIP is concerning as one would expect the public communications strategy to be especially open to the public and available for broad inquiry and input.

Release event reporting

Over this past licence period, there have been 15 “minor spills” from the PHCF. Each was reported to the CNSC and MOECC. These release events involved discharges of potable water, steam condensate, contaminated groundwater, and hydraulic fluid to the harbour.25 Cameco has assured the Commission in its application that all these events were disclosed to the public by being posted to their website. Cameco’s Public Disclosure Protocol for the PHCF confirms that the company undertakes to provide “timely information postings” on its website about “unusual operational events” that may have off-site consequences. The Protocol also confirms that environmental incidents reported to the CNSC under section 29 of the General Nuclear Safety and Control Regulations and non-routine environmental incidents reported to the MOECC Ontario Spills Action Center are also posted online.

Cameco’s webpage for the Port Hope Conversion facility contains a lot of important information about the PHCF, presented in very accessible ways. This homepage26 contains simplified explanations of its current licence renewal application, notes from recent community forum events, a 2016 survey of public attitudes to the facility, and the most recent quarterly compliance report for the PHCF. This homepage for the facility also contains links to a simplified version of its Vision in Motion project description, a description of its UF6 conversion process and a frequently asked questions (FAQ) page. Entering “Cameco Port Hope” into a Google search engine, this is the first page that appears.

The homepage also contains three tabs to the right of the webpage each containing more information about “Environment and Safety”, “Community”, and “Economy”. The bottom of the main “Environment and Safety” webpage is an embedded link that when clicked on opens a new webpage with incident reports. Incidents are listed and briefly described, in some instances with follow-up comments or updated notes added to them.

While Waterkeeper commends Cameco for posting these events, postings should be more prominent on the facility’s website, as their current location is easily missed. These alerts are presumably intended as public warnings, and thus should be easily and quickly accessible. Waterkeeper recommends that a link to this webpage with reported incidents be included as a shortcut tab to the homepage for the PHCF. Waterkeeper also recommends that each incident report include actual data of measurable releases. If the data is not available at the time of posting, it should be added as an update to the report once quantities have been assessed. Applicable Effluent Release Limits or Action Limits should also be included in each report so that the public the public can gauge the severity of the incident. Finally, Waterkeeper recommends that the date on the first line of each report be specified as its posting date so that members of the public can more easily compare posting dates with event dates.

25 Cameco’s relicensing application, CMD 16-H8.1 at p 40. 26 This webpage is found online at: https://www.cameco.com/fuel_services/port_hope_conversion/.

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Public information to assist with reviews of the current relicensing application

There have been several points over the course of preparing for these hearings that Mr. Ruland and Ms. Feinstein have not had access to sufficient information. These public information shortages concerned water treatment issues during VIM construction and implementation, Cameco’s Fisheries Act self-assessment, Cameco’s full PIP, and the PHCF’s stormwater management plan. At the site visit between Cameco staff, Mr. Ruland and Ms. Feinstein, Cameco’s hesitancy to release raw data and large reports was discussed. Apparently, Cameco’s past disclosures had at some point been taken and used out of context by members of the public, causing difficulties for the company. Waterkeeper is sensitive to this issue, and at the same time believes that this past experience should not permit the company’s operations to remain opaque or exempt from public scrutiny. Cameco may still provide the context it deems appropriate to accompany any release of raw monitoring data or plans, helping to ensure that it is properly understood by the public. The requested licence period The next ten years will see significant changes to the PHCF, not to mention significant changes to the ecosystems in which it is situated (especially Port Hope Harbour). Ten years is simply too long a period to go without proposer public review of the facility and its operations. Based on the lack of information available to the Commission to fully assess the PHCF’s impact on the local environment, or its mitigation plans, Cameco's relicensing application should be denied until all relevant information is available. Should the CNSC decide to renew the PHCF’s licence, Waterkeeper submits this should only be done for a three to five-year term rather than ten years. This will provide Cameco with enough time to gather additional information the Commission will require to make a more informed licensing decision. Given the changes to its facility in the last five years since Waterkeeper’s involvement in Cameco’s last relicensing application, this seems like a more reasonable licence term that ensures accountability and proper public review of its operations. Certain documents, including the PHCF’s Environmental Risk Assessment (ERA), already have to be updated every five years.27 Conclusion Since Waterkeeper’s last review of the PHCF and VIM project, several improvements to Cameco’s environmental footprint have occurred or been planned: new impenetrable harbour walls will be installed along the west wall of the harbour, plans to address flooding and spilling are being developed with adequate ‘severe storm’ characteristics being taken into account,

27 Cameco’s relicensing application, CMD 16-H8.1 at p18.

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monitoring and sampling plans for the site have been improved, stormwater infrastructure will be upgraded, and public information-sharing with the public has increased. At the same time, many concerns persist: additional environmental monitoring is still required to better understand the PHCF’s effects on the local environment, more comprehensive and demanding effluent release limits must be developed for the PHCF and made legally enforceable as licence terms, information-sharing with the public must be more robust and include increased disclosure of monitoring plans and sampling data. If the Commission chooses to approve Cameco’s relicensing application, Waterkeeper submits the following recommendations should be adopted by the Commission and added as conditions on Cameco’s new licence. Recommendations concerning the PHCF’s effluent discharges and effluent monitoring programs:

2) A final VIM-specific wastewater treatment plan should be provided for public review upon its completion;

3) A final plan for handling contaminated water from Port Hope Harbour during and after the completion of VIM and PHAI remediation efforts. This plan should also be provided for public review;

4) The proposed1825 kg/year release limit for Uranium from the sanitary sewer system into the harbour must be lowered. Reasonable Action Levels for Uranium and all other COPCs from all three pathways to the environment are required. These limits should be provided for public review once completed;

5) Future quarterly and annual compliance compliance monitoring reports should provide the full list of COPCs which are being monitored for in the sanitary sewer discharges. Additionally, the combined annual mass loading of Uranium from the sanitary sewer discharges should also be reported;

6) In the post-VIM period, uncontrolled contaminated stormwater discharges via the storm sewer system should be monitored at least quarterly;

o This should be done at all active storm sewer lines, o Monitoring should be conducted for all identified COPCs, o Monitoring results should be included in all quarterly and annual compliance

reports, o A calculation of the combined annual mass loading of Uranium to the harbour

from all active sewers should be reported in annual compliance reports; 7) Monitoring of the Pump and Treat system should continue as planned;

o Groundwater monitoring results showing the areas of contaminated groundwater discharges not being contained by the system should also be reported in quarterly and annual compliance reports,

o Future quarterly and annual compliance reports should contain the full list of COPCs, those that are being monitored, and any reasons for the exclusion of others from being monitored,

o A calculation of the combined annual mass loading of Uranium to the harbour from all areas of uncontained contaminated groundwater should be reported in annual compliance reports.

Recommendations concerning the PHCF’s Fisheries Act compliance:

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8) Cameco’s Fisheries Act self-assessment report should be made publicly accessible as well as CNSC staff’s review of it once it has been completed.

Recommendations concerning the PHCF’s Public information and disclosure programs:

9) The webpage reporting incidents should be included as a shortcut tab to the homepage for the facility, as its current location is difficult to find;

10) The incident reports should include actual data of measured releases; 11) Appropriate Effluent Release Limits and Action Limits should be included in these reports

to provide the public with a better understanding of the severity of the incident; 12) The date on the first line of each report should be specified as its posting date.

Recommendation concerning the requested licence period’s length:

13) Based on the lack of information currently available to the Commission, Cameco's relicensing application should be denied until all relevant information is available for the Commission to make a more informed decision. In the alternative, a three to five-year licence should be granted rather than a ten-year licence.

Independent Review of Hydrogeological Issues

Pertaining to a Review of the Cameco Vision in Motion Initiative

and Cameco’s Application for 2017 Renewal of Site License

Prepared for:

Lake Ontario Waterkeeperc/o Mr. Mark Mattson, President

Prepared by Wilf Ruland (P. Geo.)

766 Sulphur Springs RoadDundas, Ontario

L9H 5E3(905) 648-1296

deerspring1@gmail.com

October 3rd, 2016

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Table of Contents

1) Introduction.............................................................................................................................! 3

2) Background and Overview of the PHCF................................................................................! 4

3) Brief Overview of the PHAI...................................................................................................! 5

4) Description of the Contamination at the PHCF ....................................................................! 5.................................................................................................................a) Introduction ! 5

................................................................................b) Contaminated Soils at the PHCF ! 6........................................................c) Contaminated Sediments in Port Hope Harbour ! 6

d) ....................................................................Contaminated Groundwater at the PHCF! 7..................................e) PHCF-Contaminated Storm Sewer Discharges to the Harbour! 7

......................................f) Discharges from the PHCF to the Municipal Sanitary Sewer! 8

5) Vision in Motion Project - Opportunities and Concerns .......................................................! 8.................................................................................................................a) Introduction ! 8

..............................................................................................b) VIM Project Description! 9.................................................................c) Potential for Flooding of VIM Excavations! 9

........................................d) Treatment of Contaminated Wastewater from VIM Project! 10...............e) Management of Water in Port Hope Harbour During PHAI/VIM Projects! 10

.........................................................................f) Incomplete Remediation of the PHCF! 11

6) 2017 Site License Renewal and Concerns about Effluent Releases and Monitoring ........! 11...............................................................................................................a) Introduction ! 11

.............b) Inadequate Regulation of Contaminated Liquid Emissions from the PHCF! 11........c) Improvements Needed for Monitoring/Reporting of Contaminated Discharges! 13

7) Discussion ..............................................................................................................................! 14

8) Conclusions............................................................................................................................! 15

9) Recommendations..................................................................................................................! 16

Appendix 1) List of Documentation Reviewed or Referenced.................................................! 18

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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 have been retained as an expert by Lake Ontario Waterkeeper (LOW) to provide an independent review of the Cameco Vision in Motion (VIM) initiative and the associated 2017 Site License Renewal Application for the Cameco Port Hope Conversion Facility (PHCF). I should note that LOW received CNSC funding to support my review.

Vision in Motion is Cameco’s name for a process by which the company will be permitted (through legal agreement with the Canadian government and local municipalities) to bring up to 150,000 m3 of Low Level Radioactive Wastes (LLRWs) including contaminated soils and building demolition debris into the soon to be opened Port Hope Long Term Waste Management Facility (LTWMF) for long-term storage/disposal.

The 2017 License Renewal Application (if approved) will provide a 10-year extension to Cameco’s operating license for the PHCF including explicit approval to carry out the activities associated with VIM.

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 VIM and/or the PHCF’s current and proposed future operations under the proposed new site license. Such impacts can affect water quality and aquatic life in Port Hope Harbour and/or Lake Ontario.

The adequacy of VIM and the proposed 2017 site license renewal (from a water quality protection perspective) can be measured at this time by the degree to which Cameco’s associated documentation provides:

- an accurate understanding of existing soil, groundwater and surface water conditions on the Cameco PHCF property and its surroundings;- a well thought-out and comprehensive plan to remove the LLRW from the PHCF property;- plans for operating the PHCF through the 10-year license period such that there will be progressive improvement to the facility’s current impacts on groundwater and surface water quality; - appropriate water quality monitoring plans and follow-up monitoring plans;- realistic contingency plans;- adequate oversight and regulation by the CNSC for the VIM project and the PHCF over the 2017 to 2027 license period.

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.

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I toured the PHCF and surrounding area (on September 26th, 2016), and asked questions about various aspects of the VIM proposal of the Cameco representatives with whom I was touring the PHCF. I had submitted (through LOW) an information request and a series of questions - most of which were discussed during or immediately following the site tour. I also attended a Sept. 26th public meeting hosted by Cameco and the Port Hope Area Initiative (or PHAI) on the remediation of the Port Hope waterfront including the PHCF clean-up under the VIM process.

This review outlines my findings, conclusions and recommendations following my review of thedocumentation prepared by Cameco in support of the 2017 license renewal application and the associated VIM project. This documentation as well as other related information can be found here:https://www.cameco.com/fuel_services/port_hope_conversion/

In the course of my review I have also carefully considered other background documents which are available regarding the PHCF, and regarding the PHAI which is the larger process under which the Port Hope LTWMF is being developed and under which up to 150,000 m3 of Cameco’s LLRW will be allowed to be brought to the LTWMF.

In my comments which follow below I will be highlighting some key aspects of the information which has been provided in the documentation which I have reviewed, and I will be outlining some areas where I believe that environmental protections in VIM process and the 2017-2027 PHCF operations should be strengthened going forward.

2) Background and Overview of the PHCF

The Port Hope Conversion Facility (PHCF) is an active Uranium processing facility which has been the site of operations for the processing of nuclear materials since 1932. Initially the site was used by a private corporation to extract Radium from ore, and subsequently the PHCF was used to process Uranium. Uranium processing was carried out by a federal Crown Corporation at the site from 1942 through 1988), after which the crown corporation was privatized.

Up to 150,000 m3 of the wastes generated by the Crown Corporation prior to its privatization in 1988 are now being allowed to be deposited in the Port Hope LTWMF, as per the Federal Agreement which established the Port Hope Area Initiative (PHAI) which governs the operations of the LTWMF. The PHAI is briefly described in the next section of this review.

Because of its long history, the site of the PHCF has experienced significant environmental contamination including contamination of on-site soils and groundwater - and there are currently emissions of liquids from the PHCF property which are contaminated with Uranium and other parameters. Contaminated materials are also found in sediments in the adjacent Port Hope Harbour, which is one of 43 designated Great Lakes Areas of Concern under the Canada - United States Great Lakes Water Quality Agreement.

The Vision in Motion (VIM) project provides Cameco with a unique, one-time opportunity to carry out significant remediation of PHCF and to unburden itself of up to 150,000 m3 of LLRW which it has been storing since it became a corporation in 1988.

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3) Brief Overview of the PHAI

The PHAI is a process under which the federal government will be accepting historic low-level radioactive waste (LLRW) from across Port Hope and environs, and securing these LLRWs 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. Most of the wastes from these sources will be going to the Port Hope LTWMF (including the 150,000 m3 coming from Cameco), and a smaller amount will be going to the Port Granby LTWMF.

Both LTWMFs are very well-designed facilities which will provide secure and long-term storage/disposal of the LLRW. The LTWMFs will hydraulically isolate the wastes (through a very low-permeability base liner and a similarly low-permeability cover), and each LTWMF has a highly sophisticated waste water treatment plant (WWTP) which will treat all contaminated liquids being generated by the LTWMFs.

The legal agreement with the Federal Government allows for up to 150,000 m3 of Cameco-owned legacy wastes (generated by its Crown Corporation predecessor prior to 1988) as well as additional contaminated soils and wastes from building demolition associated with the Cameco Vision in Motion (VIM) project.

Following completion of the PHAI most of Port Hope’s LLRW sources will be remediated - with the exception of the Cameco Port Hope Conversion Facility, at which even after completion of the PHAI there will be some contaminated soil and contaminated groundwater under various parts of the site.

4) Description of the Contamination at the PHCF

a) IntroductionAs described previously, there has been processing of nuclear materials ongoing at the PHCF site since 1932. In the early decades of operations, little was known about the harmful nature of the materials being handled at the site. More recent investigations have shown that water and soils on the site and its surroundings have been contaminated by substances from the PHCF including the following contaminants of primary concern (COPCs):- Uranium, - Arsenic, - Ammonia, - Nitrate, - Fluoride, - Radium-226, - Trichloroethylene, - Dichlorethylene, and - Vinyl Chloride.

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Types of water/soil contamination which are of concern include the following:- there are contaminated soils across significant areas on the PHCF site, including the main plant

site and the Centre Pier;- there are contaminated sediments (several meters thick) in the Port Hope Harbour;- there is contaminated groundwater which is present in two main plumes on the PHCF site, and

although most is contained and treated some of this contaminated groundwater is discharging to the Port Hope Harbour;

- the discharges from the PHCF storm sewer system are carrying contaminants into the Port Hope Harbour;

- the discharges from the PHCF to the municipal sanitary sewer system are carrying contaminants into the Port Hope Sewage Treatment Plant (STP).

I will be discussing each of these types of contamination in the next subsections of this review.

b) Contaminated Soils at the PHCFContaminated soils are present in various locations across the PHCF, including the main plant site (with hot spots at the uranium hexafluoride (UF6) plant, and in areas closest to the Harbour) and the Center Pier. The contaminants include Low Level Radioactive Wastes (LLRWs) such as Uranium as well as various conventional industrial contaminants.

Much of the PHCF property is paved and almost all unpaved areas are relatively flat, so in most cases the contaminated soils are locked in place and not subject to erosion. However if water passes through the contaminated soils, then there is a potential for contaminants to be leached from the soils and transported to the Harbour via the groundwater flow system. Significant amounts of contaminated soils (especially those situated in areas closest to the Port Hope Harbour) are planned to be removed as part of the VIM project.

c) Contaminated Sediments in Port Hope HarbourContaminated materials are found in sediments in the Port Hope Harbour, which is adjacent to and has been contaminated by the PHCF. The Port Hope Harbour is one of 43 designated Great Lakes Areas of Concern under the Canada - United States Great Lakes Water Quality Agreement.

The International Joint Commission website provides a description of the contaminated harbour sediments (which it indicates are contaminated with uranium- and thorium-series radionuclides, heavy metals, and PCBs) here:http://ijc.org/files/publications/PortHopeHarbourAreaOfConcernStatusOfBeneficialUseImpairments.pdf

The Canadian Government’s description of the Port Hope Harbour contamination can be found here:http://www.ec.gc.ca/raps-pas/default.asp?lang=En&n=8BB3DAED-1

Under the Port Hope Area Initiative, the contaminated sediments in the Port Hope Harbour are to be excavated and deposited in the Port Hope LTWMF. Close coordination with the PHCF will be required for this work to be carried out successfully.

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d) Contaminated Groundwater at the PHCFThere is extensive and significant groundwater contamination on the PHCF property. The indicator parameter which in most cases can be used to track this contamination is Uranium, which is also one of the COPCs.

The Ontario Drinking Water Quality Standard (ODWQS) for Uranium is 20 micrograms per Liter (ug/L) and the Ontario Provincial Water Quality Objective (PWQO) for Uranium is 5 ug/L. Uranium levels in the groundwater beneath the Cameco property are often in the 1000s of ug/L, with peak levels of over 20,000 ug/L.

This contaminated groundwater is mostly being contained and collected through a Pump and Treat (P+T) system. It is estimated that currently on the order of 60% of the groundwater flow to the Harbour is contained by the P+T System, and that the original approximately 25-30 kg/year mass loading of Uranium to the Harbour has been reduced to about 5 kg/year by the P+T system. Further expansion of the system (with 5 new wells) is planned as part of VIM, which will help to further reduce the mass loading to the Harbour.

e) PHCF-Contaminated Storm Sewer Discharges to the Harbour When I first conducted a review of the PHCF under a prior contract for LOW in 2011, I found evidence of a storm sewer system which had not been well maintained and monitored - and which was leaking significant amounts of contaminated water into the Port Hope Harbour. It was (and still is) my interpretation that the majority of the contamination in the storm sewer discharges to the Harbour is caused by discharge of contaminated groundwater into the system via leaks and breaks in the aging storm sewer network.

At the time of my review in 2011 the available information indicated that average Uranium concentrations in the storm sewer discharges to the Harbour were 218 ug/L, compared to the PWQO for Uranium of 5 ug/L. I was quite concerned about what I found in my 2011 review, and I provided a number of recommendations for Cameco to address the problem.

I am pleased to report that significant progress has been made by Cameco in the 5 years since I issued my original report:- a major study of the storm sewer system was conducted in 2011;- the volume of water being captured by the P+T System was increased significantly, reducing the

amount of groundwater available to leak into the storm sewer system;- a number of the storm sewer lines and outfalls have been decommissioned, reducing the

number of active storm sewer outlets to the Harbour to 10;- regular semi-annual water quality monitoring is now being conducted on 6 of the 10 active

outlets, with more frequent monitoring of a 7th outlet.

This having been said, there are still significant problems associated with Cameco’s storm sewer discharges to the Port Hope Harbour:

1) There are no specific Effluent Release Limits for the storm sewer discharges, nor are there specific Action Levels for the storm sewer discharges - in effect, these discharges are currently unregulated.

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2) Although there is a semi-annual storm sewer discharge monitoring program, there is no information from that monitoring program presented in either the current (2015/2016) Quarterly Compliance Monitoring and Operational Performance Reports or the 2015 Annual Compliance Monitoring and Operational Performance Report. The information is also not presented in the 2015 Annual Groundwater and Surface Water Review Report. It is effectively hidden from public scrutiny. Perhaps it is also effectively hidden from scrutiny by Cameco’s regulator - the CNSC.

3) My expectation is that the majority of the water contamination in the Harbour is currently coming from the contaminated storm sewer discharges, which in 2009 had average Uranium concentrations of 218 ug/L. I have no information available to me that would allow me to in any way quantify the more recent releases of Uranium and other harmful contaminants to the Port Hope Harbour from the Cameco PHCF’s storm sewer discharges. Average 2015 levels of Uranium in Port Hope Harbour were 2.9 ug/L, so there is clearly considerable mixing and dilution occurring in the Harbour. By comparison, the PWQO for Uranium is 5 ug/L.

4) Please note that I have only been discussing Uranium as it is the site indicator parameter and one of the site COPCs - but there are also many other contaminants which will be present in the unregulated and undisclosed storm sewer discharges to the Harbour from the PHCF.

f) Discharges from the PHCF to the Municipal Sanitary SewerThere are also discharges of wastewater from the PHCF to the municipal sanitary sewer. Contained in these discharges are inputs from washrooms, showers, site laundry facilities, and Powerhouse boiler blowdown.

Average Uranium levels in the sanitary sewer discharges were 19 ug/L in 2015, vs. the PWQO for Uranium of 5 ug/L. Following treatment at the Port Hope STP, the treated PHCF wastewater is discharged to Lake Ontario. I have not found water quality monitoring information for Lake Ontario in the reports I’ve seen, however such information is available in the annual monitoring reports for the PHAI - average Uranium levels in Lake Ontario in 2015 were 0.4 ug/L.

It is not clear whether the Port Hope STP is able to remove the low levels of Uranium and other contaminants in the wastewater from the PHCF - but it will certainly provide significant dilution, as will the lake.

5) Vision in Motion Project - Opportunities and Concerns

a) IntroductionThe significance and beneficial aspects of the Vision in Motion (VIM) project for Cameco’s PHCF are tremendous. The Vision in Motion (VIM) project provides Cameco with a unique, one-time opportunity to carry out significant remediation of PHCF and to unburden itself of up to 150,000 m3 of LLRW which it has been storing since it became a corporation in 1988.

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There is no cost to Cameco for the storage/disposal of the LLRW at the Port Hope LTWMF, but Cameco is responsible for the costs of removing the materials from its property. Although these costs will be significant, there are nonetheless very considerable benefits to Cameco in making the best use of the 150,000 m3 waste allotment which it has under the Federal Agreement.

I strongly urge Cameco to make the greatest possible use of the opportunities for site improvements and historic waste removal that the VIM project presents.

b) VIM Project DescriptionThe VIM project is described in various documents, including the “2017 License Renewal Application for the Port Hope Conversion Facility - Supplemental VIM Submission” which is hereafter referred to as the VIM Submission.

The VIM project (which at the time was named Vision 2010) went through an Environmental Assessment process, which culminated in the release of an Environmental Impact Statement (EIS) and Comprehensive Study Report (CSR) which ultimately were accepted by the CNSC and the Canadian government. Since then, the VIM project has been refined such that there will be less building removals and somewhat less excavation of contaminated soils on the PHCF property than originally envisioned.

An overview list of VIM project activities which will result in environmental improvements is provided on page 12 of the VIM Submission and includes the following:- removal of drummed legacy wastes (from Cameco’s Crown Corporation predecessor) from

three Cameco storage locations in Port Hope;- demolition of 6 buildings and partial demolition of another on the PHCF property;- demolition of 3 buildings on the Centre Pier;- removal of contaminated soils from the Centre Pier (in cooperation with the PHAI) and the

PHCF property;- removal of redundant equipment from various buildings; - construction of berms/barriers which will provide flood protection, visual, noise and gamma

radiation shielding along the east property fenceline; - installation of 5 new wells for the groundwater pump and treat system;- improvements to the storm sewer infrastructure including installation of oil/grit separators,

backflow prevention valves to prevent incursions of Harbour water during periods of wind-driven higher lake levels, and new piping in areas of soil excavation.

c) Potential for Flooding of VIM ExcavationsIn my previous review of the Vision 2010 project I had expressed significant concerns about the potential for flooding of excavation sites during major storm events, resulting in major contamination of Port Hope Harbour.

I no longer have this concern, in part because the extent of the VIM excavations has been scaled back significantly, in part because the VIM documentation now tries to address this issue, and in part because I have learned that for the harbour dredging period (which will cover much of the VIM duration) the entire Port Hope Harbour will be sealed off from access by fish - which will have been removed from the Harbour beforehand.

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d) Treatment of Contaminated Wastewater from VIM ProjectDuring the period when building removal and soil excavations are occurring as part of the VIM project, these areas will be generating contaminated wastewater additional to what is currently generated by the PHCF.

Cameco has not yet decided how to ensure treatment of this contaminated wastewater - the options being considered are either upgrading the capacity of the existing on-site waste water treatment system (done through evaporation of waste liquids) or releasing the waste water to the Port Hope STP (assuming acceptable conditions can be negotiated). If additional contaminated waste water is being sent to the Port Hope STP then it will be important to make sure that the STP can handle the increased volumes and contaminant load.

It would have been good for this issue to have been clarified in time for the public review of the VIM proposal and 2017 license application - the fact that it has not been clarified means that there will likely not be any opportunity for public review and comment prior to the site license being issued. It is also not clear what process for CNSC review will be followed regarding this issue. I recommend that the final proposal for the VIM project’s wastewater treatment be provided for public review once it has been completed.

e) Management of Water in Port Hope Harbour During PHAI/VIM ProjectsAs indicated previously, PHAI/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 gojng 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 VIM monitoring proposal is provided on page 24 of the VIM submission. I have not been able to find any 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 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.

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It could be argued that the Lake Ontario monitoring should be done either partly or entirely through the PHAI project (rather than through the VIM 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.

f) Incomplete Remediation of the PHCFThe PHCF site will not be completely remediated following this work, but given that this is a working industrial site this is not required.

What is important however is that the 2017-2027 CNSC site license (which will include authorization to proceed with the VIM project) should include regulatory levels for contaminated water discharges which will be protective of the aquatic environment and water quality in Port Hope Harbour and Lake Ontario during and after the VIM project. As will be discussed in more detail in following sections of this review, the proposed regulatory levels in the new site license do not meet this test.

6) 2017 Site License Renewal and Concerns about Effluent Releases and Monitoring

a) IntroductionThe CNSC Hearing for which this review has been prepared and at which it will be presented is being held in regard to the 2017 License Renewal Application (which includes authorization for the VIM project). My concerns regarding the VIM project were provided in the previous section of this review.

I also have grave concerns about the licensing and oversight by CNSC of the Cameco PHCF with respect to the regulation of contaminated liquid emissions from the PHCF, about the monitoring of such emissions, and about the disclosure of information regarding such monitoring.

b) Inadequate Regulation of Contaminated Liquid Emissions from the Cameco PHCFThere are 3 streams of liquid emissions from the PHCF, all of which are carrying contaminants from the site into the Port Hope Harbour or Lake Ontario:- mildly contaminated waste water is being discharged to the sanitary sewer system, and from

there to the Port Hope STP and ultimately into Lake Ontario; - contaminated stormwater is discharging to the Harbour via the storm sewer network;- contaminated groundwater from the site is discharging into the Harbour.

The existing CNSC Site License does not include any mention of any regulatory levels regarding these contaminated liquid emissions from the PHCF - they are currently not being regulated in any way that I can find by the CNSC.

I consider this to be a significant failure in oversight of the PHCF by the CNSC. It needs to be corrected in the proposed 2017 Site License Renewal which is being applied for by Cameco.

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However review of the CNSC’s draft License Conditions Handbook reveals that under the Environmental Protection section of the Handbook only 1 of the 3 streams of liquid discharges from the site is proposed to be addressed, namely the sanitary sewer discharges (which are the least contaminated of the 3 streams). Moreover, the only regulatory level which is mentioned for the sanitary sewer stream is a release limit of 1825 kg/year of Uranium.

I understand from conversations with PHCF staff and from a report which they have prepared entitled “Calculating Doses to the Public - Derived Release Limits and Operating Release Levels” hereafter referred to as the “DRL/ORL Report” that this release limit of 1825 kg/year of Uranium is a theoretical upper limit on Uranium releases which has been derived by calculating how much Uranium would have to be released from the PHCF in order to cause a radioactivity dose to a person exceeding the regulatory limit of 1 mSv/year.

What this sole release limit for the contaminated liquid discharges from the PHCF fails to do is to address the fact that Uranium aside from its radioactive properties is also a toxic chemical contaminant if ingested (it damages the kidneys), that Uranium is also harmful to aquatic life, and that at this site Uranium is a surrogate for many other COPCs which are all present in varying quantities in the contaminated liquid streams discharging from the PHCF into the Harbour and Lake Ontario. The draft CNSC Site License and draft License Conditions Handbook utterly fail to address these concerns.

The PHCF is a federal facility, and thus its liquid discharges are not being meaningfully regulated by Ontario’s Ministry of the Environment and Climate Change (MOECC). In the absence of MOECC regulation, the CNSC is the sole regulator of this facility when it comes to discharges of contaminated liquids to the environment. The CNSC is failing in this regard.

The Ontario Drinking Water Quality Standard (ODWQS) for Uranium is 20 ug/L and the Provincial Water Quality Objective (PWQO) in surface waters is 5 ug/L. The CNSC’s proposed release limit of 1825 kg/year in sanitary sewer discharges is so absurdly high that there would be appalling exceedences of the PWQO and the ODWQS in whatever surface water body was receiving these discharges, with dire consequences for aquatic life.

If discharged to the Port Hope Harbour, 1825 kg/year of Uranium would turn the Harbour into a killing zone for aquatic life. A rough estimate suggests that the Harbour holds about 50,000,000 Liters of water. 1825 kg/year equals 5 kg/day or 5,000,000,000 ug/day. Thus 1825 kg/year translates into a Harbour’s worth of water contaminated to 100 ug/L (20 times the PWQO for Uranium) every day, throughout the 10-year license period. If discharged into Lake Ontario, 1825 kg/year of Uranium would cause the formation of a killing zone for aquatic life in the area where the discharge was mixing with the lake water.

These extreme numbers arise from calculations using the only regulatory level which Cameco’s and the CNSCs documents are currently indicating would be applied to contaminated water discharges from the PHCF - namely the 1825 kg/year release limit for Uranium.

I strongly recommend that Action Levels or some other form of effluent quality limits are needed for all of the water-related COPCs at the Cameco PHCF (they are listed on page 5 of this review) and for each of the 3 streams of contaminated water discharges from the PHCF. I strongly recommend that Cameco and CNSC staff get to work on developing them.

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c) Improvements Needed for Monitoring and Reporting of Contaminated Discharges from PHCFTo recap, there are 3 streams of liquid emissions from the PHCF, all of which are carrying contaminants from the site into the Port Hope Harbour or Lake Ontario:- mildly contaminated waste water is being discharged to the sanitary sewer system, and from

there to the Port Hope STP and ultimately into Lake Ontario; - contaminated stormwater is discharging to the Harbour via the storm sewer network;- contaminated groundwater from the site is discharging into the Harbour.

Monitoring of Sanitary Sewer Discharges The monitoring of wastewater discharges to the sanitary sewer system is reported in the quarterly and annual Compliance Monitoring Reports. Wastewater monitoring is occurring at a frequency of weekly, which is appropriate. The list of COPCs which are reported on for the sanitary sewer monitoring is limited to Uranium, Fluoride, Ammonia and Nitrates in these reports. It is not clear if there is monitoring for the other PHCF COPCs - I recommend that future quarterly and annual Compliance Monitoring Reports should provide the full list of COPCs which are being monitored, and if results are not being reported for some COPCs then this should be explained.

Otherwise I find the reporting of the results of monitoring of sanitary sewer discharges from the site to be satisfactory. I should note that I recommend that the calculation of the combined annual mass loading of Uranium in the sanitary sewer discharges be continued and reported in the Annual Compliance Monitoring Reports.

Monitoring of Contaminated Storm Sewer DischargesThe monitoring results for the uncontrolled discharges to the Harbour via the storm sewer system are not reported in the quarterly or annual Compliance Monitoring Reports, or in any other report which I could find or obtain from Cameco. Wastewater monitoring is occurring at a frequency of semi-annually, which is not frequent enough - I recommend quarterly monitoring.

Storm sewer monitoring is currently done at only 7 of 10 active storm sewer lines with outlets to the Harbour - I recommend that all active storm sewer lines should be monitored.

I do not know which parameters from the list of COPCs for the site are included in the storm sewer monitoring - the only results available to me are the Uranium results for 2015. It is not clear if there is monitoring for the other PHCF COPCs. I recommend that monitoring should be for the full list of PHCF COPCs (which are provided on page 5 of this review for easy reference)

I recommend that storm sewer monitoring results should be reported in future quarterly and Annual Compliance Monitoring Reports, that these reports should provide a list or table showing the full list of COPCs which are being monitored, and if results are not being reported for some COPCs then this should be explained. I also recommend that a calculation of the combined annual mass loading of Uranium to the Harbour from all active storm sewers be done every year and reported in the Annual Compliance Monitoring Reports.

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Monitoring of Pump and Treat System Water Quality The monitoring of Pump and Treat (P+T) system water quality is reported in the 2015 Annual Groundwater and Surface Water Quality Monitoring Report. Pumping well water quality monitoring is occurring at a frequency of monthly for a short list of COPCs (Uranium, Radium-226, Arsenic, Nitrate, Fluoride, and Ammonia), which is appropriate. Water quality in observation wells is generally monitored quarterly for the same short list, which is likewise appropriate. There is also annual water quality monitoring for a considerably longer list of general chemistry parameters, VOCs and metals which provides helpful information.

The contaminated water pumped from the P+T System wells is treated through on-site evaporation by Cameco - there are no liquid discharges from this treatment system. However a small portion of the contaminated groundwater beneath the site escapes the P+T system and discharges to the Harbour.

I recommend that a calculation of the combined annual mass loading of Uranium to the Harbour from all areas of uncontained contaminated groundwater be done every year and reported in the Annual Compliance Monitoring Reports.

In summary, I believe that all 3 streams of contaminated liquids which are being discharged from the site should be properly monitored for water quality, and that the monitoring information on these discharges should be presented in the Annual Compliance Monitoring Reports for the PHCF. This would mark a significant change from current practice, in which the results of the monitoring of contaminated storm sewer discharges to the Port Hope Harbour are not disclosed in the publicly available monitoring reports.

7) Discussion The Cameco website indicates that the PHCF is one of only 4 uranium conversion facilities in the western world. At a world class facility, I think it is reasonable for the public to expect world class oversight by the regulator of the facility (the CNSC) and world class monitoring of the facility’s impacts. My review of the CNSC oversight and the PHCF’s water quality monitoring programs suggest that improvements to both are needed.

The VIM project and the associated 2017 PHCF License Renewal Application provide a unique and major opportunity for Cameco to improve the PHCF site and its operations, and to reduce its impacts on soil, groundwater and surface water. The 2017 License Application which is intended to authorize the VIM project and extend the license of the facility also provides an opportunity to strengthen CFSC oversight of the facility and its operations, and to make improvements to site water quality monitoring and Cameco’s reporting on that aspect of the monitoring program.

Overall, I find the Cameco PHCF to be a reasonably well run industrial facility from a water quality perspective. There are no discharges of liquid effluent from plant processes.Historic soil and groundwater contamination at such sites is not uncommon, and what differentiates good from bad facilities is how they go about dealing with them. Cameco is doing a better job than many, although there is need for further improvement as set out in this review.

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8) Conclusions

1) The Cameco Port Hope Conversion Facility (PHCF) is an active Uranium processing facility which has been the site of operations for the processing of nuclear materials since 1932.

2) Because of its long history, the site of the PHCF has experienced significant environmental contamination including contamination of on-site soils and groundwater - and there are currently emissions of liquids from the PHCF property which are contaminated with Uranium and other parameters. Contaminated materials are also found in sediments in the adjacent Port Hope Harbour, which is one of 43 designated Great Lakes Areas of Concern.

3) The Port Hope Area Initiative (PHAI) is a unique and major Low Level Radioactive Waste (LLRW) remediation project, which is aimed at providing secure long-term management of the LLRWs from around Port Hope. The legal agreement which established the PHAI provides for 150,000 m3 of legacy LLRWs from Cameco’s PHCF to be brought to the LTWMF.

4) The Vision in Motion (VIM) project is Cameco’s name for this unique, one-time opportunity to carry out significant remediation of PHCF and to unburden itself of up to 150,000 m3 of LLRW which it has been storing since it became a private corporation in 1988.

5) A description of the soil and water contamination at the PHCF is provided in Section 4 of this review. The list of contaminants of primary concern (COPCs) in soil and water includes both radioactive parameters such as Uranium as well as conventional industrial contaminants such as ammonia, TCE and vinyl chloride.

6) The impacted liquid stream which is least-well monitored and which is poorly disclosed by Cameco is the flow of contaminated water going into Port Hope Harbour from the PCHF’s aging storm sewer system. While it appears that there has likely been significant progress made in reducing the site’s contaminated storm water discharges, the lack of disclosure makes it impossible to determine just how much progress has been made.

7) Opportunities and concerns associated with the VIM project are discussed in Section 5 of this review. My most significant concern is the dearth of information on how surplus contaminated water from the sealed off Port Hope Harbour is going to be handled during the VIM/PHAI project period. This is an issue which needs to addressed by Cameco or the PHAI process, as otherwise there will be an ongoing poorly controlled and untreated flow of contaminated Harbour water into Lake Ontario. Monitoring of the lake’s water quality just beyond the Harbour will be required, but does not seem to be planned at present.

8) In my professional opinion there has been a significant failure in oversight of the PHCF by the CNSC with regard to the issue of contaminated liquid emissions from the facility, and the monitoring and reporting of these emissions. The 2017 License Renewal application provides an opportunity to address this concern - which is discussed in detail in Section 6 of this review.

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9) Recommendations

1) The significance and beneficial aspects of the Vision in Motion (VIM) project for Cameco’s PHCF are tremendous. I strongly urge Cameco to make the greatest possible use of the opportunities for site improvements and historic waste removal that the VIM project presents.

2) I recommend that the final plan for the VIM project’s wastewater treatment be provided for public/stakeholder review once it has been completed.

3) The final plan for handling contaminated water from the Port Hope Harbour during the VIM/PHAI project 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.

4) 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 frequently (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.

5) The 1825 kg/year release limit for Uranium for the PHCF in the 2017 License Application documents is not acceptable as the sole regulatory level for COPCs in liquid emissions from the facility. There are 3 contaminated liquid streams coming from the facility, and Action Levels or some other form of effluent quality limits are needed for the water-related COPCs for each of the 3 stream of contaminated water discharges from the PHCF. Once they have been developed they should be circulated for public/stakeholder review.

6) The monitoring of wastewater discharges to the sanitary sewer system should continue to be reported in the quarterly and annual Compliance Monitoring Reports. Wastewater monitoring is occurring at a frequency of weekly, which is appropriate. I recommend that future quarterly and annual Compliance Monitoring Reports should provide the full list of COPCs which are being monitored, and if results are not being reported for some COPCs then this should be explained. The calculation of the combined annual mass loading of Uranium in the sanitary sewer discharges should be continued and reported in the Annual Compliance Monitoring Reports.

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9) Recommendations - continued

7a) In the post-VIM period, the monitoring of the water quality of the uncontrolled, contaminated discharges to the Harbour via the storm sewer system should be done on a quarterly basis.

7b) The storm sewer water quality monitoring should be done at all active storm sewer lines.

7c) Monitoring should be for the full list of PHCF COPCs for contaminated water (which are provided on page 5 of this review for easy reference).

7d) The results of this monitoring should be reported in the quarterly and annual Compliance Monitoring Reports. These reports should provide a list or table showing the full list of COPCs which are being monitored, and if results are not being reported for some COPCs then this should be explained.

7e) A calculation of the combined annual mass loading of Uranium to the Harbour from all active storm sewers should be done every year and reported in the Annual Compliance Monitoring Reports.

8a) Monitoring of the Pump and Treat system’s pumping well water quality for a current short list of COPCs (at a minimum for Uranium, Radium-226, Arsenic, and Ammonia) should continue, as should the quarterly monitoring of groundwater observation wells for the same short list of COPCs. The annual monitoring of all pumping and observation wells for a longer list of general chemistry parameters, VOCs and metals should also continue.

8b) The groundwater monitoring results showing the areas of contaminated groundwater discharges which are not contained by the Pump and Treat system should be reported in the quarterly and annual Compliance Monitoring Reports.

8c) I recommend that future quarterly and annual Compliance Monitoring Reports should provide the full list of COPCs which are being monitored, and if results are not being reported for some COPCs then this should be explained.

8d) I recommend that a calculation of the combined annual mass loading of Uranium to the Harbour from all areas of uncontained contaminated groundwater be done every year and reported in the Annual Compliance Monitoring Reports.

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Appendix 1- References The references considered in the course of preparing this review include the following:

Cameco PHCF, Calculating Dose to the Public, Derived Release Limits and Operating Release Levels ! Public Summary. Undated document.

Cameco PHCF, Preliminary Decommissioning Plan, Public Summary. Undated document.

Cameco PHCF, Environmental Risk Assessment, Public Summary. Undated document.

Cameco PHCF Safety Report, Public Summary. Undated document.

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

DRAFT Licence Conditions Handbook, Cameco PHCF, Nuclear Fuel Facility Operating Licence ! FFOL-3631.00/2027, Revision 0. Prepared by CNSC staff, September 2016.

Draft NUCLEAR FUEL FACILITY OPERATING LICENCE, CAMECO PHCF. !!! LICENCE NUMBER: FFOL-3631.00/2027. Prepared by CNSC staff, September 2016.

Environmental Assessment Report, Cameco PHCF Operating License Renewal. ! !! Prepared by CNSC staff, September 2016.

Letter from Dale Clark (Vice President of Fuel Services Division, Cameco) to Mr. Marc Leblanc, ! Commission Secretary, CNSC. Re: PHCF Renewal of License FFOL-3631.0/2017. ! Letter dated August 4, 2016.

2007-2015 Operational Performance Report and Forward Outlook in Support of the Renewal of: ! Port Hope Conversion Facility Operating Licence FFOL-3631.00/2017 ! !! Submitted to the CNSC by Cameco, August 4, 2016.

Groundwater Pump and Treat System Performance Overview For The Cameco PHCF.! April 26, 2016. Report prepatred by Cameco.

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

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Cameco 2017 LICENCE RENEWAL APPLICATION FOR THE PHCF.! Dated November 20, 2015

Cameco 2016 2nd Quarterly Compliance Monitoring & Operational Performance Report. ! Submitted on: August 19, 2016

Cameco 2016 1st Quarterly Compliance Monitoring & Operational Performance Report. !Submitted ! on: May 19, 2016

Cameco 2015 Annual Compliance Monitoring & Operational Performance Report. !! Submitted on: March 31, 2016

Cameco 2014 Annual Compliance Monitoring & Operational Performance Report. !! Submitted on: March 30, 2015

Ontario Ministry of the Environment, Amended Environmental Compliance Approval ! ! ! No. 4998-9CKL7F for Cameco PHCF. Issued November 12, 2013

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

NUCLEAR FUEL FACILITY OPERATING LICENCE CAMECO CORPORATION PHCF. ! LICENCE NUMBER: FFOL-3631.00/2017. Valid from 01 March 2012 to 28 February 2017, ! issued February 28, 2012.

Independent Review of Hydrogeological Issues Pertaining to the Cameco Environmental Impact ! Statement for the Proposed Vision 2010 Project. Prepared for: Lake Ontario Waterkeeper by ! Wilf Ruland (P. Geo.). July 7th, 2011.

Environmental Impact Statement, Cameco Vision 2010. Volumes 1-3. December 2010. ! Prepared by SENES Consultants Limited.

2009 Annual Compliance Report for the PHCF. 2010. Prepared by Cameco.

PORT HOPE CONVERSION FACILITY SITE-WIDE RISK ASSESSMENT: Human Health and ! Ecological Risk Assessment. Prepared for Cameco by: SENES Consultants Ltd. June 2009.

PROJECT DESCRIPTION CAMECO VISION 2010, PHCF. Prepared for Cameco by: SENES ! Consultants Ltd. June 2006

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