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This is the first edition of CSA N288.7 Groundwater protection programs at Class I nuclear facilities and uranium mines and mills.
The purpose of this Standard is to provide requirements and guidance which facilitate groundwater protection at Class 1 nuclear facilities and uranium mines and mills. Compliance with the Standard will allow facilities to demonstrate that they will not pose an unreasonable risk to the environment or the health and safety of humans and non-human biota from groundwater.
The CSA N-Series Standards provide an interlinked set of requirements for the management of nuclear facilities and activities. The CSA N286 Standard provides overall direction to management to develop and implement sound management practices and controls while the other CSA nuclear Standards provide specific technical requirements and guidance that support the management system. This Standard works in harmony with CSA N286 and does not duplicate the generic requirements of CSA N286; however, it may provide more specific direction for meeting those requirements.
This Standard addresses the design, implementation, and management of a groundwater protection program that incorporates best practices in Canada and internationally.
Users of this Standard are reminded that additional and site-specific requirements might be specified by federal, provincial/territorial, or municipal authorities. This Standard should not be considered a replacement for the requirements contained in any
a) applicable federal/territorial, or provincial statute, including the Nuclear Safety and Control Act; or
b) regulation, license, or permit issued pursuant to an applicable statute.
0.1 Nuclear facilities and uranium mines and mills
Nuclear facilities and uranium mines and mills are required to demonstrate [NSCA, Section 24 (4) b.] that they have made adequate provision for the protection of human health and the environment from any releases of contaminants of potential concern (COPC). This can involve a number of interrelated assessments and programs (which in some cases are managed under a larger environmental protection program or environmental management system), which can include, but is not limited to, the following:
a) an environmental assessment (EA)
b) an environmental risk assessment (ERA)
c) an environmental monitoring program (EMP)
d) an effluent monitoring program
e) a groundwater protection program (GWPP)
f) a groundwater monitoring program (GWMP)
g) a buried and underground piping and tank program and
h) a facility decommissioning plan.
0.2 Groundwater protection programs and groundwater monitoring programs
This Standard provides
a) requirements and guidance on the elements of GWPPs; and
b) detailed guidance on developing GWMPs as an element of the broader GWPP.
A graded approach, commensurate with risk, can be defined and used when applying the requirements of this standard.
Note: See CSA N286 standards for further information on the graded approach.
0.2.2 Groundwater protection programs
GWPPs are implemented to
a) prevent or minimize releases of nuclear or hazardous substances to groundwater
b) prevent or minimize the effects of physical stressors on groundwater end uses and
c) to confirm that adequate measures are in place to stop, contain, control, and monitor any releases and physical stressors that can occur under normal operation.
GWPPs are developed on a site-specific basis.
Important elements of a GWPP are
a) identification of sources of COPCs
b) investigation of releases under normal operation and source characterization
c) site characterization
d) assessment of groundwater end-use
e) assessment of groundwater vulnerability
f) a GWMP and
g) risk management (as required).
Note: Risk management is an element of a GWPP, but is not addressed in this Standard (see Clause 1.7).
Together these elements provide the basis to develop groundwater protection goals for the facility.
Note: CSA N288.6 provides guidance on evaluating and characterizing risks to receptors resulting from exposure to contaminants released from nuclear facilities.
0.2.3 Groundwater monitoring programs
A GWMP is one of the many elements of a broader GWPP (see Clause 0.2.2). The GWMP provides the means to evaluate whether groundwater protection goals are achieved. GWMPs are designed on a site-specific basis and vary widely in terms of their overall scale, objectives, components, and complexity.
Note: The evaluation of GWMP results relative to groundwater protection goals might be undertaken as part of the environmental risk assessment (see CSA N288.6).
The objectives of the GWMP will depend on the phase of the particular project (e.g., planning, permitting, site preparation and construction, operations, decommissioning, and closure) and on the goals defined for the GWPP (Clause 4.2).
The scope of a GWMP will depend on many considerations, including, but not limited to, the following:
a) past, current, or anticipated future activities
b) nuclear and hazardous substances present
c) findings of the site characterization, groundwater end use assessment, and groundwater vulnerability assessment;
d) objectives identified for the GWMP and
e) likelihood and severity of releases.
0.3 Relationship to environmental assessment (EA)
An EA is used to predict the environmental, social, and economical effects of proposed initiatives before they are carried out. Elements of a GWPP and a GWMP can be carried out as part of an EA or as a supporting study following the completion of an EA to
a) characterize the existing environment
b) make predictions in the EA
c) verify the predictions made in the EA
d) propose appropriate mitigation measures, where required
e) confirm the effectiveness of identified mitigation measures
f) confirm that groundwater management practices are effective and
g) optimize monitoring activities and reporting.
Note: An EA can contain information required for the various elements of the GWPP (see Clause 6.1.4).
0.4 Relationship to environmental risk assessment (ERA)
An ERA of a nuclear facility is a systematic process used to identify, quantify, and characterize the risk posed by contaminants and physical stressors in the environment on biological receptors (human and non-human), including the magnitude and extent of the potential effects associated with a facility.
Note: Further information on ERAs can be found in CSA N288.6.
This Standard assumes that an ERA of some form has already been completed. The ERA can be part of an EA, the environmental management system, or any other document that contains the required information. All references to an ERA in this Standard are to be understood as referring to any document that contains the required information.
An ERA can provide the basis for the scope and complexity of a GWMP. An ERA can provide input into the GWMP by identifying
a) the specific nuclear and hazardous substances of concern
b) the sources of these substances or release points
c) information needed regarding groundwater end-use and vulnerability and
d) areas where receptors are potentially exposed to substances of concern carried in groundwater.
An ERA can also contribute to the development of groundwater evaluation criteria (see Clause 7.2.8 and Annex B) through its tiered approach and through iterative refinement of the conceptual site model (CSM) (see Clause 6.2).
The site characterization required to establish a GWMP can provide the hydrogeologic framework, pathways, and subsurface transfer parameters that are needed to refine or update the ERA. The GWMP can also inform, update, and help refine the ERA by providing groundwater quality data that are used in estimating exposure concentrations/activities of nuclear and hazardous substances.
0.5 Relationship to environmental monitoring programs (EMPs)
An EMP consists of a risk-informed set of integrated and documented activities to sample, measure, process, interpret, and report the concentrations or activities of hazardous or nuclear substances in environmental media (or the intensity of physical stressors) which are used in estimating exposure and risk to receptors. EMPs or GWMPs can also provide data on water levels and quality. The concentration or activity of hazardous or nuclear substances in environmental media are used to assess
a) exposure of receptors to those substances
b) the potential effects on human health and the environment
c) the intensity of physical stressors or their potential effect on human health and the environment; and
d) the physical, chemical, and biological parameters of the environment pertinent to the design of the EMP.
Note: Further information on EMPs can be found in CSA N288.4.
Groundwater monitoring can be included in the EMP, or can be designed as a separate monitoring program. If the GWMP is a separate program, it is desirable that it and the EMP will allow the programs to complement, inform, and guide each other.
Groundwater monitoring data can supplement existing EMP information and can support the development or refinement of the CSM used to understand contaminant concentrations/activities, transport/flow paths, and potential effects. Environmental monitoring can complement groundwater monitoring where there are surface water bodies (i.e., if there are groundwater discharge or recharge areas) adjacent to monitoring sites and where the GWMP might not identify point source releases within the site.
0.6 Relationship to effluent monitoring programs
Effluent monitoring is a risk-informed activity that quantifies or estimates the nuclear and hazardous substances being released into the surface water or air environment by a facility.
Note: Further information on effluent monitoring is provided in CSA N288.5.
It is desirable that there be good integration between the GWMP and the effluent monitoring program. The information obtained from one program can be used to complement the other.
1) Groundwater monitoring data can supplement existing effluent monitoring information (for example, to provide an indication of whether or not nuclear and hazardous substances associated with effluent releases are measured in groundwater).
2) Where a building foundation drainage system or storm water and drainage control system intercepts a groundwater plume, monitoring of the foundation drainage systems can be considered a form of groundwater monitoring.
Contaminants in groundwater that are pumped for treatment and discharged to or mixed with the effluent stream are reported under a facility's effluent monitoring program and not through the GWMP.
Emissions such as those from diffuse non-point sources (e.g., seepage into groundwater, and runoff into surface water and recharge zones), are addressed through either the GWMP or the effluent monitoring program. Factors to consider when determining where to address these emissions include professional judgment and consideration of
a) the goals and objectives of the two programs;
b) any other relevant technological, operational, economic, or site-specific factors (effluent monitoring is usually in or near known potential sources, and the sources are often subject to operational controls); and
c) the need for timely measurement results (i.e., when results might be required to take corrective action).
The preeminent consideration is to confirm that all emissions that are identified as being of concern in an ERA (CSA N288.6) are adequately assessed through environmental monitoring (CSA N288.4), groundwater monitoring (CSA N288.7), or effluent monitoring (CSA N288.5).
1.1.1 Types of facilities
This Standard addresses the design and operation of GWPPs for Class I nuclear facilities and uranium mines and mills.
1) In this Standard, any type of Class I nuclear facility and uranium mine and mill (refer to the definition of nuclear facility in Clause 3.1) is included in the term nuclear facilities.
2) Conventional waste management facilities on a Class I nuclear facility (or uranium mine and mill) are included in the scope of this Standard.
3) The applicability and suitability of this Standard to nuclear facilities will require professional judgment, knowledge of the relevant geological and hydrogeological conditions (e.g., travel time, position of freshwater aquifers, etc.), and validation of the CSM. For example, due to the potentially different environment encountered at great depths, portions of this Standard are likely not applicable to all aspects of deep subsurface facilities. Groundwater protection for such Class I facilities will be assured in the permitting and licensing process, and portions of this Standard can be used as applicable.
4) Not all Class I nuclear facilities and uranium mines and mills will need a GWPP. See Clause 5 on criteria for establishing a GWPP.
This Standard may also apply to the design and operation of GWPPs for
a) Class II nuclear facilities; and
b) facilities that use or store naturally occurring radioactive materials.
Note: In these situations, however, the operator of the nuclear facility is responsible for determining the applicability and suitability of this Standard in consultation with the AHJ.
1.1.2 Facility lifecycle
This Standard addresses monitoring performed during
a) baseline characterization
b) site preparation, construction, and commissioning
d) refurbishment or restarting after a prolonged shut-down
e) decommissioning and
f) post-decommissioning prior to abandonment and institutional control.
Note: The nature and extent of groundwater monitoring requirements change over the lifecycle of the facility.
1.2 Operating conditions
1.2.1 Monitoring during normal operations
The monitoring described in this Standard is applicable where nuclear and hazardous substances might be released to groundwater during normal operations over the lifecycle of a nuclear facility.
Note: Any release resulting from a deviation from routine operational practice that is expected to occur once or several times during the operating lifetime of a nuclear facility or licensed activity (i.e., reasonably foreseeable upset events, also known as anticipated operational occurrences including leaks and spills) is considered part of normal operation. This definition of operating conditions is consistent with usage in CSA N288.4, CSA N288.5, and CSA N288.6.
1.2.2 Monitoring during accidental releases
This Standard does not address groundwater monitoring during accidental releases.
1) Monitoring during accidental releases is not included in this standard due to the emergent and highly specific nature of such events. Planning to mitigate impacts to groundwater from accidental releases is important and parts of this Standard may be used in this planning.
2) Some parts of this Standard might be applicable to the monitoring of groundwater following an accidental release. In these cases, the operator of the nuclear facility is responsible for determining the applicability of this Standard.
1.3 Spill response and the management of the spill event
This Standard does not address spill response and the management of the spill event; however, if there is residual contamination to groundwater then this Standard would apply.
Note: A facility should have in place a spill response plan to address the immediate response to spills. Some parts of the Standard are applicable to the longer term monitoring of groundwater following a spill event.
1.4 Contaminants and physical characteristics
This Standard considers the following COPCs or groundwater characteristics that might cause potential adverse effects:
a) hazardous substances such as toxic, corrosive, or deleterious substances;
b) nuclear substances; and
c) geochemical (e.g., groundwater quality) and physical characteristics of groundwater (e.g., groundwater quantity or temperature).
1.5.1 Leak detection
This Standard addresses
a) the role of monitoring in relation to leak detection, although this monitoring does not replace leak prevention
b) review of structures, systems, and components (SSCs), and sentinel monitoring to provide early warning of any potential groundwater contamination issues, notwithstanding technical limitations (see Clause 6.3.4) and
c) to a limited degree, repair, preventative maintenance, and ageing of monitoring equipment.
1.5.2 Mixed effluent and groundwater
This Standard does not address groundwater that is intercepted, collected, mixed with an effluent stream, and subsequently discharged.
Note: Monitoring of that effluent is discussed in and is part of CSA N288.5, as outlined in Clause 1.5.2 of CSA N288.5 (see Clause 0.6 of this Standard).
1.6 Interpretation of data
The Standard provides guidance on the interpretation of groundwater monitoring data, relative to the objectives of the GWMP.
Note: Users are cautioned that the statutes, regulations, licences, and permits that govern a nuclear facility can impose requirements regarding data analysis and interpretation that differ from those described in the Standard. The operator of the nuclear facility is responsible for determining what data analysis and interpretation are necessary to confirm compliance with the statutes, regulations, licences, or permits that govern the operation of the nuclear facility.
1.7 Risk management and remediation
This Standard does not provide guidance on risk management or remediation.
Note: This Standard provides guidance to identify situations where risk management and remediation might be needed to protect identified receptors, but does not provide further advice on selecting or implementing risk management or remediation options.
1.8 Dose assessment methods
This Standard does not address dose assessment methods.
1) The GWMP does provide information for the groundwater pathway and input for dose assessment.
2) It is anticipated that dose assessment might be one of the tools used in either interpreting groundwater data or in defining groundwater evaluation criteria for the program.
3) Guidance on dose assessment methods is provided in CSA N288.6.
This Standard provides guidance on reporting the results of a GWMP.
Note: Users are cautioned that the statutes, regulations, licences, and permits that govern a nuclear facility might impose reporting requirements that differ from those described in the Standard. The operator of the nuclear facility is responsible for determining the required frequency and content of reports to regulatory agencies necessary to confirm compliance with the statutes, regulations, licences, or permits that govern the operation of the nuclear facility.
In this Standard, shall is used to express a requirement (i.e., a provision that the user is obliged to satisfy to comply with the standard); should is used to express a recommendation or that which is advised but not required; and may is used to express an option or that which is permissible within the limits of the standard.
Notes accompanying clauses do not include requirements or alternative requirements; the purpose of a note accompanying a clause is to separate explanatory or informative material from the text explanatory or informative material.
Notes to tables and figures are considered part of the table or figure and may be written as requirements.
Annexes are designated normative (mandatory) or informative (non-mandatory) to define their application.