Science Response : significance of reported annual mortality at the PLNGS

New Brunswick Electric Power Corporation (NB Power) conducted impingement and entrainment monitoring at the Point Lepreau Nuclear Generating Station (PLNGS), as a requirement for a license renewal process with the Canadian Nuclear Safety Commission (CNSC). A self-assessment report (EcoMetrix 2017) prepared by NB Power provided analysis and interpretation of the results of impingement and entrainment sampling. It was reported that the current operation of the station may be causing residual, serious harm to fish that are part of, or support, a commercial, recreational, or Aboriginal (CRA) fishery. Consequently, NB Power was required to apply for authorization under paragraph 35(2)(b) of the Fisheries Act in order to be compliant with the Act. Since the request for an authorization under paragraph 35(2)(b) of the Fisheries Act for the PLNGS was received prior to the coming in force of the current Fisheries Act (2019) and met the transitional provisions, the impacts of these studies were evaluated under the 2012 Fisheries Act, which prohibited works, undertakings and activities that would result in serious harm to fish that were part of or that supported a CRA fishery (paragraph 35(1)). In 2019, the Fisheries Act was modernized to restore the protection against the death of fish, other than by fishing (paragraph 34.4(1)) and the harmful alteration, disruption or destruction of fish habitat (paragraph 35.2) to all fish and fish habitat. Fisheries and Oceans Canada (DFO), Fish and Fish Habitat Protection Program (FFHPP) requested advice from DFO Science to determine if the serious harm to fish reported by NB Power could be offset or if it would prevent DFO from attaining fisheries management objectives. This advice would inform the decision-making process for authorization. The authorization has since been issued, based on informal advice; however, FFHPP requested the advice be published to ensure the advice that supported the authorization is formally documented, and to support the decision-making process related to offsetting requirements if NB Power constructs a second reactor or modifies its water intake requirements. The objective of this peer review process is to review the self-assessment report submitted by NB Power on impingement and entrainment monitoring and reported mortality at the PLNGS, and to evaluate the methods employed to estimate annual reported losses. The field methods used in the self-assessment do not address other sources of mortality, such as impingement on the cooling water system’s trash racks or marine mammal (seals) mortality. The discharge of the cooling water or the potential impacts of the thermal plume are not subject to an authorization under paragraph 35(2)(b) of the Fisheries Act, as these may be considered a deleterious substance under the provisions of paragraph 36(3) of the Fisheries Act, which is administered by Environment and Climate Change Canada (ECCC). A Thermal Plume Assessment was initiated in support of the Environmental Risk Assessment in May 2018. The final version of the report regarding this study was submitted to the CNSC in June of 2020. The following seven terms of reference (TOR) are addressed in this review: With respect to the entrainment/impingement study provided by the proponent: 1. Are the field methods and analytical methods used to evaluate impingement and entrainment consistent with best practices? 2. Is the species list representative of the species targeted by commercial, recreational, and Aboriginal (CRA) fisheries in the area? 3. Are the population units and life history values used in the analysis applicable to the species? With respect to the ‘significance’ of reported annual mortality: 4. Will the reported annual mortality have an effect on the localized population levels? 5. Will the reported annual mortality result in losses in future productivity (i.e., the calculations in the report do not consider subsequent offspring losses or cumulative impacts)? 6. The report gives mortality rates, can this be extrapolated to indicate an impact on CRA fisheries? In addition, FFHPP had requested science advice on the following question: 7. What are the possible mitigation and offsetting methods that could be implemented to reduce the impacts associated with the operations of the PLNGS? This Science Response Report results from the regional peer review of March 21, 2023, on the Review of Impingement and Entrainment Monitoring and Reported Mortality at the Point Lepreau Nuclear Generating Station.

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