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Independent Review of Hydrogeological Issues
Pertaining to the MOECC’s Request
for an Amended License Renewal for Various Remedial Activities
at the Deloro Mine Site
Prepared for:
Lake Ontario Waterkeeper
Prepared by Wilf Ruland (P. Geo.)
766 Sulphur Springs Road
Dundas, Ontario
L9H 5E3
(905) 648-1296
deerspring1@gmail.com
October 9, 2017
page 1
1) Introduction
I am a hydrogeologist, and I have worked as an environmental consultant for 31
years (2 years for a larger firm in Germany, and 29 years independently in Canada). I
am a specialist in groundwater and surface water contamination issues, and have
dealt with 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. A copy of my Curriculum Vitae is
available upon request.
I have reviewed and provided comments on many landfills and contaminated sites
over the course of my career. I have likewise reviewed remediation proposals for
numerous landfills and contaminated sites, and recently reviewed plans for the
development of near surface disposal facilities for low level nuclear waste in Chalk
River, Port Hope and Port Granby Ontario. All of these make me qualified to
consider the technical water-related issues being discussed in this matter.
I have been retained by Lake Ontario Waterkeeper to review an application from
Ontario’s Ministry of the Environment and Climate Change (MOECC) for an
amended renewal of Canadian Nuclear Safety Commission (CNSC) license
WNSL-W1-3301.00/2017. The CNSC has had regulatory oversight of remedial
activities at the Deloro Mine site under the aforementioned license since 2009 under
the Nuclear Safety and Control Act (NSCA).
The MOECC’s remedial activities have progressed to the point where in the
MOECC’s opinion the CNSC’s oversight is no longer needed in two parts of the site.
License renewal is being sought only for the third (Young’s Creek Area) part of the
site. This review of the MOECC’s application for an amended license renewal has
been funded by the CNSC.
In this review I will provide comments on:
• the understanding of the Deloro site and its surroundings including the local
geology, hydrology and hydrogeology;
• the nature and extent of contamination of the site by inorganic mining wastes as
well as by radiological wastes;
• the remedial activities carried out to date, and the proposed further remediation;
• recent groundwater and surface water monitoring program results;
• potential radiological impacts on groundwater and surface water going forward;
• the overall merits of the MOECC’s application for amended license renewal.
In order to carry out this work, I have reviewed a series of documents and the most
important of these are listed as references in Appendix 1 of this review.
page 2
This review outlines my findings, conclusions and recommendations regarding the
water-related aspects of the MOECC’s application for amended license renewal.
2) Overview of the Deloro Site
a) Topography and Drainage
The Deloro site had its beginnings as a gold mining operation situated along the
banks of the Moira River. The topography is generally low-lying and hummocky,
and prior to the mining the topography was generally bedrock-controlled. Since then
the topography was extensively altered through mining and smelting/refining
operations and the disposal of mining and smelting/refining wastes.
The Moira River cuts through the site, and is the predominant drainage feature. A
small side channel / tributary of the Moira River (Young’s Creek) is found on the east
side of the site. A small drainage swale (called the New Westerly Creek) drains the
west side of the site.
Elevations over the Site range from approximately 210 masl along the north boundary of
the Industrial and Mining (IMA) Area to approximately 185 masl along the banks of the
Moira River and in low-lying areas in the south of the property. As mentioned above, the
surface topography of the Site has been extensively modified over the years due to
mining and refining activity on the Site. The topography is being further altered in the
course of the current remediation of the site.
b) Geology
The Deloro Site is situated very close to the contact between the Precambrian
basement bedrock and the overlying Paleozoic sedimentary bedrock.
The site’s Precambrian bedrock is comprised of highly metamorphosed, continental
shelf sediments with a large proportion of felsic plutonic rocks (granite and tonalite).
The bedrock was mined for gold, nickel, cobalt and arsenic - and the primary
contaminant of concern at the site is arsenic.
The bedrock surface is irregular and hummocky, and the bedrock often protrudes
through the overburden. Overburden at the site is generally thin (3 meters thick),
though it reaches thicknesses of up to 9 meters in a few places. There are naturally
occurring sand and clay deposits, as well as a wide variety of mining and refining
wastes which were disposed of at the site - often in the bedrock valleys.
page 3
c) Hydrogeology
As outlined above the overburden at the site is thin and has been heavily altered. The
predominant groundwater flow system is in the Precambrian granitic bedrock.
Groundwater is generally flowing inward toward the Moira River floodplain from the
higher lands surrounding the river valley. Groundwater movement will be through
fractures in the bedrock - there is no flow through the intact rock. The fracture flow
will be rapid but relatively low in volume, because of the small apertures of the
fractures and the low porosity of the bedrock.
In the absence of remediation, the heavily contaminated slag and tailing deposits at
the site would have continued causing heavy groundwater contamination - all of
which would over time be discharged to the Moira River.
d) Information Sources
I have drawn on a variety of sources of information for this section of my review (see
Appendix 1). The most detailed source of information about the site topography,
drainage, geology, and hydrogeology was the May 2007 report entitled “Deloro Mine
Site Cleanup Site-Wide Hydrogeological Conditions Final Report”, prepared by
CH2M Hill.
I also met with several MOECC staff on October 2, 2017 for several hours and was
able to discuss various aspects of the site contamination and their remediation,
following which I was accompanied by the same staff for a tour of the site. In
advance of the tour/meeting I corresponded with MOECC staff, and requested the
many site-specific reports which are listed in Appendix 1.
3) Overview of the Deloro Remediation Site
a) History
The Deloro site started its life as a gold mine in the 1860s, and was host to a variety
of mining, refining and smelting operations for almost 100 years (until 1961). Little
care was given in the handling of waste products, and over the years the Deloro site
became heavily contaminated with heavy metals.
For a period, uranium-bearing ores were brought to the site from the Eldorado
Refinery in Port Hope for smelting and refining of cobalt - and this resulted in the
deposition at the site of mildly radioactive slag and tailings. These low level
radioactive materials are the reason for the CNSC’s involvement with the site.
page 4
The 202 hectare site was abandoned by its former owner and escheated to the Crown
in 1987, and is under the care and control of the MOECC. An environmental
assessment (EA) was carried out to evaluate remedial options, and the resulting EA
Study Report was completed in 2008 and has guided a wholesale remediation of the
site ever since.
The contaminant of primary concern is arsenic. Prior to the commencement of
remediation the contamination of soil, shallow groundwater and surface water by
arsenic was pervasive at the Deloro site - and was causing unacceptable on-site and
off-site contamination.
The presence of arsenic is driving the site remediation, and the remedial activities
required to bring arsenic levels into compliance with provincial groundwater and
surface water limits will have the benefit of adequately dealing with the other
contaminants at the site - including the low level radiological slag and tailing wastes.
b) Overview of Site Areas
The site has been divided into three areas for the purposes of characterization and
remediation of the wastes which are present at the site:
- the Industrial and Mine Area (IMA);
- the Tailings Area (TA);
- the Young’s Creek Area (YCA).
Wastes from within each of these areas are being remediated within their respective
area. In terms of contamination the IMA was worst contaminated, followed by the
TA (which received tailings from the IMA), and finally the YCA (which received
overflows of tailings from the TA). Low level radiological wastes were present and
co-mingled with the other wastes in all three areas, and make up an estimated 2% to
6% of the 650,000 cubic meters of wastes originally needing remediation at the site.
Following below is a brief description of each of the areas, together with a brief
description of the remediation being done.
i) The Industrial and Mine Area (IMA) is situated on the west side of the Moira
River. This was the centre of historic mining and industrial activity at the site. The
IMA included at least 7 mine shafts, as well as a variety of structures used at various
times and in various ways to support the mining and smelting and refining operations
at the site. The IMA was the most heavily contaminated part of the site.
Waste materials from across the IMA were excavated and brought to a Waste Con-
solidation Area (WCA) situated roughly in the centre of the IMA. The radiological
wastes in the IMA were generally buried near the bottom of the WCA. The WCA has
been engineered to provide secure long-term containment of the IMA wastes. The
WCA is not lined, but it has a perimeter clay berm and a leachate collection system.
page 5
Inflow into the Waste Consolidation Area (WCA) of upstream groundwater and
surface water is prevented, through engineered diversion features. A very low-
permeability cap constructed of a composite of materials is designed to minimize the
inflow of rainwater. Over time the WCA will slowly dewater, and the current flow of
contaminated leachate will be reduced to a trickle.
Much of the arsenic-laden leachate from the WCA is treated in an Arsenic
Treatment Plant (ATP), which serves the Deloro site. The ATP has an MOECC
Environmental Compliance Approval (ECA) which governs the design, maintenance,
level of treatment, discharge, and monitoring of the facility. The final treated effluent
from the ATP is discharged to the Moira River. The ATP also receives leachate from
the other parts of the site.
According to the MOECC staff, the remediation of the IMA (including construction,
filling, capping and vegetation of the WCA) is now complete with only a few minor
details left to be attended to. I was impressed during my tour of the site to see the
attention which had been paid various details of the final cover of the WCA,
including innovative and very effective measures to prevent erosion of the final cover
on the WCA’s cap and sideslopes.
ii) The Tailings Area (TA) was once a natural lowland area in the Moira River
floodplain. It received ferric hydroxide tailings from the site operations for many
years - these tailings had the appearance of “red mud”. Some of the tailings
contained low level radiological contaminants.
A 0.5 meter thick crushed limestone cap was placed on the TA in the 1980s to
provide a radiation barrier and to prevent erosion of the tailings. In 2011/2012 the TA
was properly capped with a multilayer impermeable cover, including a leachate
collection system which was installed in the base of the cover.
Ten thousand poplar trees (which are notable for their heavy uptake of moisture)
were planted on top of the TA, in order to further minimize the possible infiltration of
rainwater into the TA. The design of the cover included sufficient topsoil to allow the
shallow-rooted poplars to get the rainfall-derived moisture and the nutrients they
need without interfering with the deeper impermeable and collection layers.
There are also perimeter toe drains collecting leachate from the TA, and all leachate
from the TA is conveyed across the Moira River to the ATP. A total of 4500 meters of
leachate collection piping are now in place to help contain this part of the site. To
date, 34 million litres of contaminated groundwater have been collected and treated
from this part of the site. The remediation of the TA was completed in 2012, and
there is now a thriving poplar plantation on top of the TA.
page 6
iii) The Young’s Creek Area (YCA) is currently being remediated. Construction and
base lining of a containment cell is completed, and it is ready to receive wastes from
across the YCA. Remedial activities are anticipated to be completed in 2021.
The contamination in the YCA is primarily found in the upper 0.5 meters of the
overburden, which is underlain by a dense clay layer. The goal in the remediation is
to remove these upper contaminated 0.5 meters of overburden (and associated
vegetation) and landfill them in the YCA’s dedicated Containment Cell (CC). There
are on-site and off-site components of the YCA. The radiological contaminants are
only found on the on-site portion of the YCA, in the part closest to the TA (which is
where they came from originally).
Part of the off-site portion of the YCA has already been remediated. Remediation of
the on-site portion which includes the radiological contaminants is just getting
underway and will take until 2021. One goal of the remediation is to bury the
radiological contaminants as deeply as possible within the Containment Cell, as was
done in the IMA’s Waste Consolidation Area.
c) The Radiological Wastes
There were originally unsecured low level radiological wastes/contaminants present
in each of the site’s waste remediation areas - the IMA, the TA, and the YCA.
The presence on the site of low level radioactive contaminants which required
remediation led the MOECC to apply for and obtain a Waste Nuclear Site License
(WNSL-W1-3301.00/2016) in 2009 - it has been in effect ever since.
Careful consideration was given to dealing with the radiological contaminants which
were found in each of the site’s waste/remediation areas. Remediation of the
radiological contaminants in the IMA and the TA has been completed, and they are
securely contained within the impermeably covered WCA and TA.
At this point the MOECC’s remediation of the site has progressed to the point
where in the MOECC’s opinion the nuclear substances in the IMA and TA have
been successfully remediated, such that they no longer pose a threat to the
environment or members of the public.  As a result the MOECC is seeking to renew
its license under the Nuclear Safety and Control Act (for the YCA portion of the
Deloro mine site only), and to have the IMA and TA areas removed from its license.
In my review I have considered only those aspects of the application which pertain to
surface water and groundwater related risks and potential impacts, as this is my area
of expertise. My comments on these aspects of the remediation and the amended
license renewal application are provided in the following sections of this review.
page 7
4) Groundwater Contamination Issues
Overall the groundwater contamination at the Deloro site is a side issue to the main
concern, which is the contamination of surface water flowing off of the site.
The Deloro site was built on the banks of the Moira River, and the soil and
groundwater contamination is found in the immediate area of the river (and Young’s
Creek). The contaminated groundwater which is present on-site will not be flowing
anywhere except into the river.
There are a significant number of monitoring wells on-site - for the most part these
wells are situated around the WCA and the TA (presumably to monitor possible
outflows from these parts of the site). Contaminant impacts are concentrated in the
shallow groundwater flow system in the overburden and the shallow bedrock. The
heaviest arsenic contamination is found in the IMA wells.
Over the longer term (once all site remediation is complete) the MOECC will need to
make decisions about whether it considers the residual arsenic levels in the Moira
River to be acceptable. It is my sense that even now the primary source of arsenic
contamination in the river is coming from contaminated groundwater discharges in
the IMA. As the WCA dewaters and flows dwindle, there will an opportunity to
utilize the freed up ATP capacity by installing additional purge wells along the WCA
perimeter and directing leachate from the new wells to the ATP.
In the meantime regarding the issue of radiological contaminants, 2016 samples from
on-site pumping and monitoring wells were analyzed for gross alpha, gross beta,
radium-226, thorium-230, uranium-234 and uranium-238. There were no detections
of radium-226 or thorium-230. Uranium isotopes were detected but were in all cases
below their respective drinking water quality standards.
From the perspective of radiological contamination of groundwater - either now or in
the future - I see no potential issues or pathways which could lead to either
environmental contamination or health risks to humans.
5) Surface Water Contamination Issues
The driver for the site remediation of the Deloro site was always the contamination
(of soils, groundwater and surface water) by arsenic - and at this point the main
concern is the level of arsenic in surface waters at the downstream site boundaries.
Arsenic levels in the Moira River at the downstream property boundary at Highway 7
(Station DM7) are occasionally above the PWQO - usually during summer low flows.
page 8
The surface water being sampled at Station DM7 is now coming entirely from
upstream parts of the site which have been remediated. Gradual further improvement
of water quality can be anticipated as the WCA dewaters and contributes ever less
contaminated groundwater discharge to the river.
Arsenic levels in Young’s Creek at the downstream property boundary at Highway 7
(Station DM2) are generally above the PWQO of 100 micrograms per litre (ug/L) -
only falling below the PWQO during winter low flows. Water quality in the Moira
River downstream of the confluence of Young’s Creek and the river (at Station DM1)
will be degraded compared to water quality upstream of the Young’s Creek input, due
to the inputs from Young’s Creek.
The YCA has not yet been remediated, so it is no surprise that it continues to
contribute a significant contamination load to off-site surface waters. This should
progressively improve following completion of the remediation of the YCA in 2021.
Regarding the issue of radiological contaminants, 2016 surface water samples were
analyzed for gross alpha, gross beta, radium-226, thorium-230, uranium-234 and
uranium-238. There was one trace detection of radium-226 in 2016, with no other
detections of radium-226 or thorium-230. Uranium isotopes were detected in 2016
but were in all cases below their respective drinking water quality standards.
In the 2016 Annual Report for the Deloro site the surface water sampling results for
radiological contaminants were compared to drinking water quality standards rather
than Ontario’s surface water quality standards (the Provincial Water Quality
Objectives, or PWQO) to which they would normally be compared. This is a
conservative approach, as the PWQO are not as well developed or as stringent as the
drinking water quality standards.
The 2016 surface water quality monitoring results for radionuclides came back with
all samples well below their respective drinking water quality standards, and the
majority of results came back below their respective detection limits. The annual
report indicates and other MOECC documentation confirms that the site’s surface
water monitoring for radionuclides will continue through the mid-term and into the
long term monitoring period.
In the meantime, from the perspective of radiological contamination of surface water
- either now or in the future - I see no potential issues or pathways which could lead
to either unacceptable environmental contamination or health risks to humans.
Even if someone were inclined to ignore the warning signs and draw all of their
drinking water supplies from the Highway 7 bridge over Young’s Creek, there would
be no risk of harm from radiological contaminants. There would be other compelling
reasons for not doing this, but there is no radiological issue of concern.
page 9
6) Discussion
A century’s worth of mining, smelting and refining at the Deloro mine site left
behind a badly contaminated site which was abandoned by its former owners, with
the orphan site subsequently coming under the care and control of the MOECC. The
province of Ontario is committed to the wholesale remediation of the Deloro site, and
this remediation is occurring under the supervision of the MOECC.
The remediation of the Deloro site is now entering its final phase. The remediation
which has been carried out to date in the IMA and the TA has been successful, and
included careful evaluation of optimal remediation approaches (through an
environmental assessment) combined with successful implementation in the field.
The remediated parts of the site have been impressively restored to a natural state
which is both pleasing to the eye as well as conducive to the rapid establishment of a
healthy post-remediation ecosystem. I would like to commend those individuals and
organizations which have been involved in the remediation to date - from my
perspective as a technical advisor to Lake Ontario Waterkeeper, the remediation to
date is a good news story for the Lake Ontario watershed.
There is no reason to think that the final phase of the remediation (of the Young’s
Creek Area, or YCA) will be anything but a success as well. The construction/
remediation area is neat and well-organized, appropriate site control and safety
procedures are in place and being followed, and the MOECC has an experienced and
well qualified team to see the project through to its conclusion.
The CNSC’s involvement pertains to what is really a side issue at this site, namely
the presence of low level radiological wastes in the form of slag and tailings which
were distributed across the site.
Careful mapping was carried out and identified areas of radiological contamination
across the site, and in the first two phases of the remediation project the radiological
wastes have been brought into secure and very long-term containment. Post-
remediation mapping of radioactivity has confirmed the success of the remediation in
both the IMA and the TA.
At this point the MOECC is seeking to renew its license under the Nuclear Safety
and Control Act, amended to include the YCA portion of the Deloro mine site only
(and to have the IMA and TA areas removed from the license).
From the perspective of water-related potential on-site and/or off-site radiological
impacts on groundwater, surface water, the natural environment and humans I see no
further threat or risk from this site and would thus support the MOECC’s application.
page 10
7) Conclusions and Recommendations
1) The Deloro site started its life as a gold mine in the 1860s, and was host to a
variety of mining, refining and smelting operations for almost 100 years (until 1961).
In keeping with the practices of the time, little care was given in the handling of
waste products and over the years the Deloro site became heavily contaminated with
heavy metals.
2) For a period, uranium-bearing ores were brought to the site from the Eldorado
Refinery in Port Hope for smelting and refining of cobalt - and this resulted in the
deposition at the site of mildly radioactive slag and tailings. These low level
radioactive materials are the reason for the CNSC’s involvement with the site.
3) The Deloro site is being remediated under the care and control of the Ministry of
the Environment and Climate Change (MOECC). The main issues of concern which
have driven the remediation of the site are the very high levels of arsenic
contamination in soils, groundwater and surface water. Other heavy metals and
radiological contaminants are also present, but remediation of the arsenic issue will
also address the concerns pertaining to the heavy metals and the radiological wastes.
4) There were originally unsecured low level radiological wastes/contaminants
present in each of the site’s waste remediation areas (the IMA, the TA, and the YCA)
and co-located with the other wastes in all three areas, making up an estimated 2% to
6% of the 650,000 cubic meters of wastes originally needing remediation at the site.
5) Two thirds of the site have been successfully remediated. The already-remediated
portions of the site are the Industrial and Mine Area (IMA) and the Tailings Area
(TA), which were the most-contaminated parts of the site. Careful consideration was
given to dealing with the radiological contaminants which were found in each of the
site’s waste/remediation areas. Remediation of the radiological contaminants in the
IMA and the TA has been completed, and they are securely contained within the
WCA and the impermeably covered TA. Remedial works have commenced in the
Young’s Creek Area (YCA) part of the site, and should be completed by 2021.
6) The presence on the site of low level radioactive contaminants which required
remediation led the MOECC to apply for and obtain a Waste Nuclear Site License
(WNSL-W1-3301.00/2017) in 2009. It has been in effect ever since.
page 11
7) Conclusions and Recommendations - continued
7) I have carefully reviewed the groundwater monitoring results presented in the
2016 Annual Monitoring Report for the site. As described in Section 4 of this review,
all radionuclides tested for were well below their respective drinking water quality
standards. From the perspective of radiological contamination of groundwater -
either now or in the future - I see no potential issues or pathways from this site which
could lead to either environmental contamination or health risks to humans.
8) The main threat from the site has always been contamination of surface water.
In the 2016 Annual Report for the Deloro site the surface water sampling results for
radiological contaminants were compared to drinking water quality standards rather
than Ontario’s surface water quality standards (the Provincial Water Quality
Objectives) to which they would normally be compared. This is a conservative
approach, as the PWQO are not as well developed or as stringent as the drinking
water quality standards.
In 2016 surface water samples were analyzed for gross alpha, gross beta, radium-226,
thorium-230, uranium-234 and uranium-238. As described in Section 5 of this
review, the 2016 surface water quality monitoring results for these radionuclides
came back with all samples well below their respective drinking water quality
standards, and the majority of results came back below their respective detection
limits.
From the perspective of radiological contamination of surface water - either now or
in the future - I see no potential issues or pathways which could lead to either
unacceptable environmental contamination or health risks to humans.
9) At this point the MOECC’s remediation of the site has progressed to the point
where in the MOECC’s opinion the nuclear substances in the IMA and TA have
been successfully remediated, such that they no longer pose a threat to the
environment or members of the public. 
As a result the MOECC is seeking to renew its license under the Nuclear Safety and
Control Act (for the YCA portion of the Deloro mine site only), and to have the IMA
and TA areas removed from its license.
From the perspective of water-related potential on-site and/or off-site radiological
impacts on groundwater, surface water, the natural environment and humans I see no
further threat or risk from this site and would thus support the MOECC’s application.
page 12
8) Signature and Professional Stamp
This Review has been prepared in its entirety by Wilf Ruland (P. Geo.). It is based on
my honest conviction and my knowledge of the matters discussed herein following
careful review of the Application for an Amended Site License Renewal and
associated documentation, as well as review or reference to other documents listed in
the Reference List.
This Review has been prepared for my clients (Lake Ontario Waterkeeper), and its
preparation has been funded by the Canadian Nuclear Safety Commission.
Signed on the 9th of October, 2017


Wilf Ruland (P.Geo.)
766 Sulphur Springs Road
Dundas, Ont.
L9H 5E3
Tel: (905) 648-1296
deerspring1@gmail.com
page 13
Appendix 1 -
References
References which were considered in the course of preparing this review included the
following:
CNSC (September 8, 2017). Designated Officer Document, from Dana Pandolfi
(CNSC Senior Project Officer, Wastes and Decommissioning Division).
Document number DNCFR-WDD-DOD-17-005.
CNSC (December 30, 2016). Waste Nuclear Site License WNSL-W1-3301.00/2016,
Deloro Mine Site.
CNSC (August 2009). Record of Proceedings, Including Reasons for Decision in the
Matter of Environmental Assessment Screening Report Regarding the Proposed
Deloro Mine Site Cleanup Project.
CNSC (July 2009). Environmental Assessment Screening Report Proposed Deloro
Mine Site Cleanup Project Deloro, Ontario. Report prepared for the CNSC
by CNSC staff.
CNSC (July 2009). Commission Member Document 09-H110. Information and
Recommendation of Canadian Nuclear Safety Commission Staff, in the Matter
of Recommendation for the Acceptance of the Proposed Environmental
Screening Report and Decision Regarding the Proposed Deloro Mine Site
Cleanup Project, Deloro Ontario.
CH2M Hill (May, 2007). Deloro Mine Site Cleanup Site-Wide Hydrogeological
Conditions Final Report. Report prepared for Ontario Ministry of the
Environment (MOE).
page 14
Chapman, L.J. and Putnam, D.F. 1984. The Physiography of Southern Ontario, 3rd
Edition.
Domenico, P.A. and Schwartz, F.W. 1998. Physical and Chemical Hydrogeology.
Freeze, R.A. and Cherry, J.A. 1979. Groundwater.
McIntosh Perry Consulting Engineers Ltd., July 2016. Application for Site Conditional
Clearance, CNSC Licence WNSL-W1-3301.00/2016. Includes 6 appendices:
- Waste Nuclear Site Licence

- Environmental Compliance Approvals

- Updated Radiological Characterization Report (Young’s Creek Area)
- RESRAD-Offsite Modelling Report

- Ministerial letter of Commitment

- Provincial Regulatory Framework
Ontario Geologic Survey, 1992. Geology of Ontario.
Ontario Regulation 169/03: Ontario Drinking Water Quality Standards. Updated
January 2017.
Ontario Ministry of the Environment and Climate Change. June 2017. Deloro Mine Site
Cleanup Project WNSL-W1-3301.00/2016, Annual Report to the Canadian
Nuclear Safety Commission January 1, 2016 – December 31, 2016.
Ontario Ministry of the Environment and Climate Change (MOECC). March 16,
2017. Letter plus attachments from Katharine Faaren (MOECC) to Dana
Pandolfi (CNSC). Attachments included:
- Environmental Assessment Objectives and Associated Summary of Work
- Update of Work Completed at the Deloro Site
- Surface Water Risk Review
- MOECC Response to CNSC Comments
Ontario Ministry of the Environment (MOE). 1994, updated 1998. Water
Management: Policies, Guidelines, Provincial Water Quality Objectives.
page 15

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Independent Review of Hydrogeological Issues at Deloro Mine Site

  • 1. Independent Review of Hydrogeological Issues Pertaining to the MOECC’s Request for an Amended License Renewal for Various Remedial Activities at the Deloro Mine Site Prepared for: Lake Ontario Waterkeeper Prepared by Wilf Ruland (P. Geo.) 766 Sulphur Springs Road Dundas, Ontario L9H 5E3 (905) 648-1296 deerspring1@gmail.com October 9, 2017 page 1
  • 2. 1) Introduction I am a hydrogeologist, and I have worked as an environmental consultant for 31 years (2 years for a larger firm in Germany, and 29 years independently in Canada). I am a specialist in groundwater and surface water contamination issues, and have dealt with 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. A copy of my Curriculum Vitae is available upon request. I have reviewed and provided comments on many landfills and contaminated sites over the course of my career. I have likewise reviewed remediation proposals for numerous landfills and contaminated sites, and recently reviewed plans for the development of near surface disposal facilities for low level nuclear waste in Chalk River, Port Hope and Port Granby Ontario. All of these make me qualified to consider the technical water-related issues being discussed in this matter. I have been retained by Lake Ontario Waterkeeper to review an application from Ontario’s Ministry of the Environment and Climate Change (MOECC) for an amended renewal of Canadian Nuclear Safety Commission (CNSC) license WNSL-W1-3301.00/2017. The CNSC has had regulatory oversight of remedial activities at the Deloro Mine site under the aforementioned license since 2009 under the Nuclear Safety and Control Act (NSCA). The MOECC’s remedial activities have progressed to the point where in the MOECC’s opinion the CNSC’s oversight is no longer needed in two parts of the site. License renewal is being sought only for the third (Young’s Creek Area) part of the site. This review of the MOECC’s application for an amended license renewal has been funded by the CNSC. In this review I will provide comments on: • the understanding of the Deloro site and its surroundings including the local geology, hydrology and hydrogeology; • the nature and extent of contamination of the site by inorganic mining wastes as well as by radiological wastes; • the remedial activities carried out to date, and the proposed further remediation; • recent groundwater and surface water monitoring program results; • potential radiological impacts on groundwater and surface water going forward; • the overall merits of the MOECC’s application for amended license renewal. In order to carry out this work, I have reviewed a series of documents and the most important of these are listed as references in Appendix 1 of this review. page 2
  • 3. This review outlines my findings, conclusions and recommendations regarding the water-related aspects of the MOECC’s application for amended license renewal. 2) Overview of the Deloro Site a) Topography and Drainage The Deloro site had its beginnings as a gold mining operation situated along the banks of the Moira River. The topography is generally low-lying and hummocky, and prior to the mining the topography was generally bedrock-controlled. Since then the topography was extensively altered through mining and smelting/refining operations and the disposal of mining and smelting/refining wastes. The Moira River cuts through the site, and is the predominant drainage feature. A small side channel / tributary of the Moira River (Young’s Creek) is found on the east side of the site. A small drainage swale (called the New Westerly Creek) drains the west side of the site. Elevations over the Site range from approximately 210 masl along the north boundary of the Industrial and Mining (IMA) Area to approximately 185 masl along the banks of the Moira River and in low-lying areas in the south of the property. As mentioned above, the surface topography of the Site has been extensively modified over the years due to mining and refining activity on the Site. The topography is being further altered in the course of the current remediation of the site. b) Geology The Deloro Site is situated very close to the contact between the Precambrian basement bedrock and the overlying Paleozoic sedimentary bedrock. The site’s Precambrian bedrock is comprised of highly metamorphosed, continental shelf sediments with a large proportion of felsic plutonic rocks (granite and tonalite). The bedrock was mined for gold, nickel, cobalt and arsenic - and the primary contaminant of concern at the site is arsenic. The bedrock surface is irregular and hummocky, and the bedrock often protrudes through the overburden. Overburden at the site is generally thin (3 meters thick), though it reaches thicknesses of up to 9 meters in a few places. There are naturally occurring sand and clay deposits, as well as a wide variety of mining and refining wastes which were disposed of at the site - often in the bedrock valleys. page 3
  • 4. c) Hydrogeology As outlined above the overburden at the site is thin and has been heavily altered. The predominant groundwater flow system is in the Precambrian granitic bedrock. Groundwater is generally flowing inward toward the Moira River floodplain from the higher lands surrounding the river valley. Groundwater movement will be through fractures in the bedrock - there is no flow through the intact rock. The fracture flow will be rapid but relatively low in volume, because of the small apertures of the fractures and the low porosity of the bedrock. In the absence of remediation, the heavily contaminated slag and tailing deposits at the site would have continued causing heavy groundwater contamination - all of which would over time be discharged to the Moira River. d) Information Sources I have drawn on a variety of sources of information for this section of my review (see Appendix 1). The most detailed source of information about the site topography, drainage, geology, and hydrogeology was the May 2007 report entitled “Deloro Mine Site Cleanup Site-Wide Hydrogeological Conditions Final Report”, prepared by CH2M Hill. I also met with several MOECC staff on October 2, 2017 for several hours and was able to discuss various aspects of the site contamination and their remediation, following which I was accompanied by the same staff for a tour of the site. In advance of the tour/meeting I corresponded with MOECC staff, and requested the many site-specific reports which are listed in Appendix 1. 3) Overview of the Deloro Remediation Site a) History The Deloro site started its life as a gold mine in the 1860s, and was host to a variety of mining, refining and smelting operations for almost 100 years (until 1961). Little care was given in the handling of waste products, and over the years the Deloro site became heavily contaminated with heavy metals. For a period, uranium-bearing ores were brought to the site from the Eldorado Refinery in Port Hope for smelting and refining of cobalt - and this resulted in the deposition at the site of mildly radioactive slag and tailings. These low level radioactive materials are the reason for the CNSC’s involvement with the site. page 4
  • 5. The 202 hectare site was abandoned by its former owner and escheated to the Crown in 1987, and is under the care and control of the MOECC. An environmental assessment (EA) was carried out to evaluate remedial options, and the resulting EA Study Report was completed in 2008 and has guided a wholesale remediation of the site ever since. The contaminant of primary concern is arsenic. Prior to the commencement of remediation the contamination of soil, shallow groundwater and surface water by arsenic was pervasive at the Deloro site - and was causing unacceptable on-site and off-site contamination. The presence of arsenic is driving the site remediation, and the remedial activities required to bring arsenic levels into compliance with provincial groundwater and surface water limits will have the benefit of adequately dealing with the other contaminants at the site - including the low level radiological slag and tailing wastes. b) Overview of Site Areas The site has been divided into three areas for the purposes of characterization and remediation of the wastes which are present at the site: - the Industrial and Mine Area (IMA); - the Tailings Area (TA); - the Young’s Creek Area (YCA). Wastes from within each of these areas are being remediated within their respective area. In terms of contamination the IMA was worst contaminated, followed by the TA (which received tailings from the IMA), and finally the YCA (which received overflows of tailings from the TA). Low level radiological wastes were present and co-mingled with the other wastes in all three areas, and make up an estimated 2% to 6% of the 650,000 cubic meters of wastes originally needing remediation at the site. Following below is a brief description of each of the areas, together with a brief description of the remediation being done. i) The Industrial and Mine Area (IMA) is situated on the west side of the Moira River. This was the centre of historic mining and industrial activity at the site. The IMA included at least 7 mine shafts, as well as a variety of structures used at various times and in various ways to support the mining and smelting and refining operations at the site. The IMA was the most heavily contaminated part of the site. Waste materials from across the IMA were excavated and brought to a Waste Con- solidation Area (WCA) situated roughly in the centre of the IMA. The radiological wastes in the IMA were generally buried near the bottom of the WCA. The WCA has been engineered to provide secure long-term containment of the IMA wastes. The WCA is not lined, but it has a perimeter clay berm and a leachate collection system. page 5
  • 6. Inflow into the Waste Consolidation Area (WCA) of upstream groundwater and surface water is prevented, through engineered diversion features. A very low- permeability cap constructed of a composite of materials is designed to minimize the inflow of rainwater. Over time the WCA will slowly dewater, and the current flow of contaminated leachate will be reduced to a trickle. Much of the arsenic-laden leachate from the WCA is treated in an Arsenic Treatment Plant (ATP), which serves the Deloro site. The ATP has an MOECC Environmental Compliance Approval (ECA) which governs the design, maintenance, level of treatment, discharge, and monitoring of the facility. The final treated effluent from the ATP is discharged to the Moira River. The ATP also receives leachate from the other parts of the site. According to the MOECC staff, the remediation of the IMA (including construction, filling, capping and vegetation of the WCA) is now complete with only a few minor details left to be attended to. I was impressed during my tour of the site to see the attention which had been paid various details of the final cover of the WCA, including innovative and very effective measures to prevent erosion of the final cover on the WCA’s cap and sideslopes. ii) The Tailings Area (TA) was once a natural lowland area in the Moira River floodplain. It received ferric hydroxide tailings from the site operations for many years - these tailings had the appearance of “red mud”. Some of the tailings contained low level radiological contaminants. A 0.5 meter thick crushed limestone cap was placed on the TA in the 1980s to provide a radiation barrier and to prevent erosion of the tailings. In 2011/2012 the TA was properly capped with a multilayer impermeable cover, including a leachate collection system which was installed in the base of the cover. Ten thousand poplar trees (which are notable for their heavy uptake of moisture) were planted on top of the TA, in order to further minimize the possible infiltration of rainwater into the TA. The design of the cover included sufficient topsoil to allow the shallow-rooted poplars to get the rainfall-derived moisture and the nutrients they need without interfering with the deeper impermeable and collection layers. There are also perimeter toe drains collecting leachate from the TA, and all leachate from the TA is conveyed across the Moira River to the ATP. A total of 4500 meters of leachate collection piping are now in place to help contain this part of the site. To date, 34 million litres of contaminated groundwater have been collected and treated from this part of the site. The remediation of the TA was completed in 2012, and there is now a thriving poplar plantation on top of the TA. page 6
  • 7. iii) The Young’s Creek Area (YCA) is currently being remediated. Construction and base lining of a containment cell is completed, and it is ready to receive wastes from across the YCA. Remedial activities are anticipated to be completed in 2021. The contamination in the YCA is primarily found in the upper 0.5 meters of the overburden, which is underlain by a dense clay layer. The goal in the remediation is to remove these upper contaminated 0.5 meters of overburden (and associated vegetation) and landfill them in the YCA’s dedicated Containment Cell (CC). There are on-site and off-site components of the YCA. The radiological contaminants are only found on the on-site portion of the YCA, in the part closest to the TA (which is where they came from originally). Part of the off-site portion of the YCA has already been remediated. Remediation of the on-site portion which includes the radiological contaminants is just getting underway and will take until 2021. One goal of the remediation is to bury the radiological contaminants as deeply as possible within the Containment Cell, as was done in the IMA’s Waste Consolidation Area. c) The Radiological Wastes There were originally unsecured low level radiological wastes/contaminants present in each of the site’s waste remediation areas - the IMA, the TA, and the YCA. The presence on the site of low level radioactive contaminants which required remediation led the MOECC to apply for and obtain a Waste Nuclear Site License (WNSL-W1-3301.00/2016) in 2009 - it has been in effect ever since. Careful consideration was given to dealing with the radiological contaminants which were found in each of the site’s waste/remediation areas. Remediation of the radiological contaminants in the IMA and the TA has been completed, and they are securely contained within the impermeably covered WCA and TA. At this point the MOECC’s remediation of the site has progressed to the point where in the MOECC’s opinion the nuclear substances in the IMA and TA have been successfully remediated, such that they no longer pose a threat to the environment or members of the public.  As a result the MOECC is seeking to renew its license under the Nuclear Safety and Control Act (for the YCA portion of the Deloro mine site only), and to have the IMA and TA areas removed from its license. In my review I have considered only those aspects of the application which pertain to surface water and groundwater related risks and potential impacts, as this is my area of expertise. My comments on these aspects of the remediation and the amended license renewal application are provided in the following sections of this review. page 7
  • 8. 4) Groundwater Contamination Issues Overall the groundwater contamination at the Deloro site is a side issue to the main concern, which is the contamination of surface water flowing off of the site. The Deloro site was built on the banks of the Moira River, and the soil and groundwater contamination is found in the immediate area of the river (and Young’s Creek). The contaminated groundwater which is present on-site will not be flowing anywhere except into the river. There are a significant number of monitoring wells on-site - for the most part these wells are situated around the WCA and the TA (presumably to monitor possible outflows from these parts of the site). Contaminant impacts are concentrated in the shallow groundwater flow system in the overburden and the shallow bedrock. The heaviest arsenic contamination is found in the IMA wells. Over the longer term (once all site remediation is complete) the MOECC will need to make decisions about whether it considers the residual arsenic levels in the Moira River to be acceptable. It is my sense that even now the primary source of arsenic contamination in the river is coming from contaminated groundwater discharges in the IMA. As the WCA dewaters and flows dwindle, there will an opportunity to utilize the freed up ATP capacity by installing additional purge wells along the WCA perimeter and directing leachate from the new wells to the ATP. In the meantime regarding the issue of radiological contaminants, 2016 samples from on-site pumping and monitoring wells were analyzed for gross alpha, gross beta, radium-226, thorium-230, uranium-234 and uranium-238. There were no detections of radium-226 or thorium-230. Uranium isotopes were detected but were in all cases below their respective drinking water quality standards. From the perspective of radiological contamination of groundwater - either now or in the future - I see no potential issues or pathways which could lead to either environmental contamination or health risks to humans. 5) Surface Water Contamination Issues The driver for the site remediation of the Deloro site was always the contamination (of soils, groundwater and surface water) by arsenic - and at this point the main concern is the level of arsenic in surface waters at the downstream site boundaries. Arsenic levels in the Moira River at the downstream property boundary at Highway 7 (Station DM7) are occasionally above the PWQO - usually during summer low flows. page 8
  • 9. The surface water being sampled at Station DM7 is now coming entirely from upstream parts of the site which have been remediated. Gradual further improvement of water quality can be anticipated as the WCA dewaters and contributes ever less contaminated groundwater discharge to the river. Arsenic levels in Young’s Creek at the downstream property boundary at Highway 7 (Station DM2) are generally above the PWQO of 100 micrograms per litre (ug/L) - only falling below the PWQO during winter low flows. Water quality in the Moira River downstream of the confluence of Young’s Creek and the river (at Station DM1) will be degraded compared to water quality upstream of the Young’s Creek input, due to the inputs from Young’s Creek. The YCA has not yet been remediated, so it is no surprise that it continues to contribute a significant contamination load to off-site surface waters. This should progressively improve following completion of the remediation of the YCA in 2021. Regarding the issue of radiological contaminants, 2016 surface water samples were analyzed for gross alpha, gross beta, radium-226, thorium-230, uranium-234 and uranium-238. There was one trace detection of radium-226 in 2016, with no other detections of radium-226 or thorium-230. Uranium isotopes were detected in 2016 but were in all cases below their respective drinking water quality standards. In the 2016 Annual Report for the Deloro site the surface water sampling results for radiological contaminants were compared to drinking water quality standards rather than Ontario’s surface water quality standards (the Provincial Water Quality Objectives, or PWQO) to which they would normally be compared. This is a conservative approach, as the PWQO are not as well developed or as stringent as the drinking water quality standards. The 2016 surface water quality monitoring results for radionuclides came back with all samples well below their respective drinking water quality standards, and the majority of results came back below their respective detection limits. The annual report indicates and other MOECC documentation confirms that the site’s surface water monitoring for radionuclides will continue through the mid-term and into the long term monitoring period. In the meantime, from the perspective of radiological contamination of surface water - either now or in the future - I see no potential issues or pathways which could lead to either unacceptable environmental contamination or health risks to humans. Even if someone were inclined to ignore the warning signs and draw all of their drinking water supplies from the Highway 7 bridge over Young’s Creek, there would be no risk of harm from radiological contaminants. There would be other compelling reasons for not doing this, but there is no radiological issue of concern. page 9
  • 10. 6) Discussion A century’s worth of mining, smelting and refining at the Deloro mine site left behind a badly contaminated site which was abandoned by its former owners, with the orphan site subsequently coming under the care and control of the MOECC. The province of Ontario is committed to the wholesale remediation of the Deloro site, and this remediation is occurring under the supervision of the MOECC. The remediation of the Deloro site is now entering its final phase. The remediation which has been carried out to date in the IMA and the TA has been successful, and included careful evaluation of optimal remediation approaches (through an environmental assessment) combined with successful implementation in the field. The remediated parts of the site have been impressively restored to a natural state which is both pleasing to the eye as well as conducive to the rapid establishment of a healthy post-remediation ecosystem. I would like to commend those individuals and organizations which have been involved in the remediation to date - from my perspective as a technical advisor to Lake Ontario Waterkeeper, the remediation to date is a good news story for the Lake Ontario watershed. There is no reason to think that the final phase of the remediation (of the Young’s Creek Area, or YCA) will be anything but a success as well. The construction/ remediation area is neat and well-organized, appropriate site control and safety procedures are in place and being followed, and the MOECC has an experienced and well qualified team to see the project through to its conclusion. The CNSC’s involvement pertains to what is really a side issue at this site, namely the presence of low level radiological wastes in the form of slag and tailings which were distributed across the site. Careful mapping was carried out and identified areas of radiological contamination across the site, and in the first two phases of the remediation project the radiological wastes have been brought into secure and very long-term containment. Post- remediation mapping of radioactivity has confirmed the success of the remediation in both the IMA and the TA. At this point the MOECC is seeking to renew its license under the Nuclear Safety and Control Act, amended to include the YCA portion of the Deloro mine site only (and to have the IMA and TA areas removed from the license). From the perspective of water-related potential on-site and/or off-site radiological impacts on groundwater, surface water, the natural environment and humans I see no further threat or risk from this site and would thus support the MOECC’s application. page 10
  • 11. 7) Conclusions and Recommendations 1) The Deloro site started its life as a gold mine in the 1860s, and was host to a variety of mining, refining and smelting operations for almost 100 years (until 1961). In keeping with the practices of the time, little care was given in the handling of waste products and over the years the Deloro site became heavily contaminated with heavy metals. 2) For a period, uranium-bearing ores were brought to the site from the Eldorado Refinery in Port Hope for smelting and refining of cobalt - and this resulted in the deposition at the site of mildly radioactive slag and tailings. These low level radioactive materials are the reason for the CNSC’s involvement with the site. 3) The Deloro site is being remediated under the care and control of the Ministry of the Environment and Climate Change (MOECC). The main issues of concern which have driven the remediation of the site are the very high levels of arsenic contamination in soils, groundwater and surface water. Other heavy metals and radiological contaminants are also present, but remediation of the arsenic issue will also address the concerns pertaining to the heavy metals and the radiological wastes. 4) There were originally unsecured low level radiological wastes/contaminants present in each of the site’s waste remediation areas (the IMA, the TA, and the YCA) and co-located with the other wastes in all three areas, making up an estimated 2% to 6% of the 650,000 cubic meters of wastes originally needing remediation at the site. 5) Two thirds of the site have been successfully remediated. The already-remediated portions of the site are the Industrial and Mine Area (IMA) and the Tailings Area (TA), which were the most-contaminated parts of the site. Careful consideration was given to dealing with the radiological contaminants which were found in each of the site’s waste/remediation areas. Remediation of the radiological contaminants in the IMA and the TA has been completed, and they are securely contained within the WCA and the impermeably covered TA. Remedial works have commenced in the Young’s Creek Area (YCA) part of the site, and should be completed by 2021. 6) The presence on the site of low level radioactive contaminants which required remediation led the MOECC to apply for and obtain a Waste Nuclear Site License (WNSL-W1-3301.00/2017) in 2009. It has been in effect ever since. page 11
  • 12. 7) Conclusions and Recommendations - continued 7) I have carefully reviewed the groundwater monitoring results presented in the 2016 Annual Monitoring Report for the site. As described in Section 4 of this review, all radionuclides tested for were well below their respective drinking water quality standards. From the perspective of radiological contamination of groundwater - either now or in the future - I see no potential issues or pathways from this site which could lead to either environmental contamination or health risks to humans. 8) The main threat from the site has always been contamination of surface water. In the 2016 Annual Report for the Deloro site the surface water sampling results for radiological contaminants were compared to drinking water quality standards rather than Ontario’s surface water quality standards (the Provincial Water Quality Objectives) to which they would normally be compared. This is a conservative approach, as the PWQO are not as well developed or as stringent as the drinking water quality standards. In 2016 surface water samples were analyzed for gross alpha, gross beta, radium-226, thorium-230, uranium-234 and uranium-238. As described in Section 5 of this review, the 2016 surface water quality monitoring results for these radionuclides came back with all samples well below their respective drinking water quality standards, and the majority of results came back below their respective detection limits. From the perspective of radiological contamination of surface water - either now or in the future - I see no potential issues or pathways which could lead to either unacceptable environmental contamination or health risks to humans. 9) At this point the MOECC’s remediation of the site has progressed to the point where in the MOECC’s opinion the nuclear substances in the IMA and TA have been successfully remediated, such that they no longer pose a threat to the environment or members of the public.  As a result the MOECC is seeking to renew its license under the Nuclear Safety and Control Act (for the YCA portion of the Deloro mine site only), and to have the IMA and TA areas removed from its license. From the perspective of water-related potential on-site and/or off-site radiological impacts on groundwater, surface water, the natural environment and humans I see no further threat or risk from this site and would thus support the MOECC’s application. page 12
  • 13. 8) Signature and Professional Stamp This Review has been prepared in its entirety by Wilf Ruland (P. Geo.). It is based on my honest conviction and my knowledge of the matters discussed herein following careful review of the Application for an Amended Site License Renewal and associated documentation, as well as review or reference to other documents listed in the Reference List. This Review has been prepared for my clients (Lake Ontario Waterkeeper), and its preparation has been funded by the Canadian Nuclear Safety Commission. Signed on the 9th of October, 2017 Wilf Ruland (P.Geo.) 766 Sulphur Springs Road Dundas, Ont. L9H 5E3 Tel: (905) 648-1296 deerspring1@gmail.com page 13
  • 14. Appendix 1 - References References which were considered in the course of preparing this review included the following: CNSC (September 8, 2017). Designated Officer Document, from Dana Pandolfi (CNSC Senior Project Officer, Wastes and Decommissioning Division). Document number DNCFR-WDD-DOD-17-005. CNSC (December 30, 2016). Waste Nuclear Site License WNSL-W1-3301.00/2016, Deloro Mine Site. CNSC (August 2009). Record of Proceedings, Including Reasons for Decision in the Matter of Environmental Assessment Screening Report Regarding the Proposed Deloro Mine Site Cleanup Project. CNSC (July 2009). Environmental Assessment Screening Report Proposed Deloro Mine Site Cleanup Project Deloro, Ontario. Report prepared for the CNSC by CNSC staff. CNSC (July 2009). Commission Member Document 09-H110. Information and Recommendation of Canadian Nuclear Safety Commission Staff, in the Matter of Recommendation for the Acceptance of the Proposed Environmental Screening Report and Decision Regarding the Proposed Deloro Mine Site Cleanup Project, Deloro Ontario. CH2M Hill (May, 2007). Deloro Mine Site Cleanup Site-Wide Hydrogeological Conditions Final Report. Report prepared for Ontario Ministry of the Environment (MOE). page 14
  • 15. Chapman, L.J. and Putnam, D.F. 1984. The Physiography of Southern Ontario, 3rd Edition. Domenico, P.A. and Schwartz, F.W. 1998. Physical and Chemical Hydrogeology. Freeze, R.A. and Cherry, J.A. 1979. Groundwater. McIntosh Perry Consulting Engineers Ltd., July 2016. Application for Site Conditional Clearance, CNSC Licence WNSL-W1-3301.00/2016. Includes 6 appendices: - Waste Nuclear Site Licence
 - Environmental Compliance Approvals
 - Updated Radiological Characterization Report (Young’s Creek Area) - RESRAD-Offsite Modelling Report
 - Ministerial letter of Commitment
 - Provincial Regulatory Framework Ontario Geologic Survey, 1992. Geology of Ontario. Ontario Regulation 169/03: Ontario Drinking Water Quality Standards. Updated January 2017. Ontario Ministry of the Environment and Climate Change. June 2017. Deloro Mine Site Cleanup Project WNSL-W1-3301.00/2016, Annual Report to the Canadian Nuclear Safety Commission January 1, 2016 – December 31, 2016. Ontario Ministry of the Environment and Climate Change (MOECC). March 16, 2017. Letter plus attachments from Katharine Faaren (MOECC) to Dana Pandolfi (CNSC). Attachments included: - Environmental Assessment Objectives and Associated Summary of Work - Update of Work Completed at the Deloro Site - Surface Water Risk Review - MOECC Response to CNSC Comments Ontario Ministry of the Environment (MOE). 1994, updated 1998. Water Management: Policies, Guidelines, Provincial Water Quality Objectives. page 15